4–1

CHAPTER 4

ENVIRONMENTAL CONSEQUENCES 

Chapter 4 presents the potential impacts on the human environment of implementing reasonable alternatives for 

the long-term management and storage of elemental mercury. Seven candidate sites for mercury storage are 

evaluated. A No Action Alternative is also evaluated, which includes the impacts of continued storage of elemental 

mercury in the absence of a facility designated by the U.S. Department of Energy. Each of the alternatives is 

discussed separately in Sections 4.2 through 4.9, beginning with the No Action Alternative. Activities and impacts 

associated with closure of mercury storage facilities are presented in Section 4.10. Cumulative impacts, mitigation 

measures, and resource commitments are presented in Sections 4.11, 4.12, and 4.13, respectively. 

4.1 INTRODUCTION 

This chapter describes the potential environmental and human health impacts associated with 

implementation of each of the alternatives considered in this Long-Term Management and Storage of 

Elemental Mercury Environmental Impact Statement (Mercury Storage EIS). As presented in Chapter 1, 

the U.S. Department of Energy’s (DOE’s) proposed action is to select a suitable location for the long-term 

management and storage of elemental mercury generated in the United States. The seven candidate sites 

evaluated as alternatives for long-term mercury1

 storage comprise the following: Grand Junction Disposal 

Site (GJDS), Hanford Site (Hanford), Hawthorne Army Depot, Idaho National Laboratory (INL), Kansas 

City Plant (KCP), Savannah River Site (SRS), and Waste Control Specialists, LLC (WCS), site. 

Detailed descriptions of each alternative are provided in Chapter 2, Section 2.4. DOE has identified the 

WCS site as the Preferred Alternative, as described in Chapter 2, Section 2.5. A summary comparison of 

the projected environmental effects among alternatives is presented in Chapter 2, Section 2.7. Sitespecific information for each of the environmental disciplines and resource areas considered is presented 

in Chapter 3; this information provides the basis for this environmental consequences analysis. 

Specifically, the environmental impacts analyses performed consider all disciplines where the potential 

exists for effects on the natural and human environment, including consideration of resource conditions 

that could affect the implementation of alternatives, as follows: 

 Land use and visual resources 

 Geology, soils, and geologic hazards 

 Water resources 

 Meteorology, air quality, and noise 

 Ecological resources 

 Cultural and paleontological resources 

 Site infrastructure 

 Waste management 

 Occupational and public health and safety 

 Ecological risk 

 Socioeconomics 

 Environmental justice 

These disciplines were analyzed in a manner commensurate with the importance of the issue or the 

relative expected level of impact under a specific alternative—the sliding-scale assessment approach 

(DOE 2004:1, 2). 

 

1

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

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

4–2

Although the Mercury Export Ban Act of 2008 (P.L. 110-414) contemplates indefinite storage, DOE has 

used a 40-year period of analysis in this Mercury Storage EIS for the purposes of evaluating potential 

environmental impacts associated with long-term storage. This 40-year timeframe corresponds to the 

planning projection for receipt into storage of up to 10,000 metric tons (11,000 tons) of elemental 

mercury, as described in Chapter 2, Section 2.1. It also reflects the expected operational design life of the 

proposed building or buildings for long-term storage of elemental mercury. A 40-year period of analysis 

is consistent with the timeframe used in previous analyses by the Defense Logistics Agency 

(DLA 2004a:1-1) and the U.S. Environmental Protection Agency (EPA) (EPA 1997). 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. 

There currently is no approved method of treating high-purity elemental mercury for disposal. It is not 

known when such a treatment method might become available. The new mercury storage facility could 

be constructed in a modular fashion to accommodate storage of mercury on an as-needed basis (see 

Chapter 2, Sections 2.2.1 and 2.3.1). 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. As a conservative assumption, the impacts analyses presented in this chapter evaluate the 

construction and operation of a new mercury storage facility with 13,950 square meters (150,000 square 

feet) of storage space, which is necessary to accommodate the projected volume of elemental mercury 

over the 40-year period of analysis. Additional National Environmental Policy Act (NEPA) analysis 

would 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. Closure of the storage facility 

would occur at the end of storage activities, as discussed in Section 4.10. 

The results of the environmental impacts analysis performed for the alternatives evaluated in this Mercury 

Storage EIS were calculated using appropriate computer models and by applying projected facility 

construction and operations parameters, as appropriate. Appendix B describes the general impact 

assessment methods employed for each discipline and presents the region of influence (ROI) for each 

resource area evaluated. Appendix C presents data that were used to support the analysis of impacts from 

construction and operations of a mercury storage facility or facilities at each of the alternative locations 

analyzed in this environmental impact statement (EIS). Finally, detailed descriptions of the methods for 

the evaluation of human health and ecological risk from normal operations, facility accidents, and 

transportation are presented in Appendix D. 

4.2 NO ACTION ALTERNATIVE 

Under the No Action Alternative, DOE would not designate and operate a facility for the long-term 

management and storage of elemental mercury generated within the United States, as further described in 

Chapter 2, Section 2.4.1. Elemental mercury would continue to be generated from other sources, 

including chlor-alkali facilities, the gold-mining industry, and waste reclamation and recycling facilities. 

As identified in Chapter 1, Table 1–1, the vast majority of mercury covered by this EIS would be 

generated by reclamation and recycling facilities and the gold-mining industry. Under the No Action 

Alternative, this mercury would have to be stored indefinitely at multiple, privately owned 

(i.e., non-DOE) facilities. It could be argued that the biggest impact of the No Action Alternative would 

be widely dispersed storage. The potential benefit of Federal action would be long-term storage and 

maintenance of this material as opposed to continued, dispersed storage by multiple private entities. 

Excess elemental mercury in storage that could not be sold would be stored in accordance with law. 

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

their storage capacity by constructing additional storage space. 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). In brief, such facilities vary in location, size, geographic 

distribution, natural and human environments, and in the nature of their operations. Therefore, the 

potential for and nature of environmental impacts from implementing the No Action Alternative at such 

sites would be highly speculative. 
Environmental Consequences 

4–3

The approximately 1,200 metric tons (1,330 tons) of DOE mercury currently stored in some 35,000 3-liter 

(3-L) (34.6-kilogram [76-pound]) flasks at the Y–12 National Security Complex (Y–12) would continue 

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

In the following sections, therefore, the potential impacts on most resource areas at non-DOE storage 

facilities are discussed qualitatively, while continued mercury storage at DOE’s Y–12 is discussed 

semi-quantitatively. 

4.2.1 Land Use and Visual Resources 

No impacts on land use and visual resources are expected at most non-DOE storage sites and at 

Y–12 as no new construction or substantial facility modifications would be required. Land use would not 

change at most non-DOE sites, and land use at Y–12 would remain predominantly industrial. As 

indicated in Section 4.2, non-DOE storage facilities may be constructed, and some non-DOE storage sites 

may need to modify their storage capacity, resulting in land disturbance and related visual impacts. 

Construction of RCRA-compliant hazardous waste treatment, storage, and disposal (TSD) facilities 

(40 CFR 264) could trigger additional land use and zoning requirements at existing sites, depending on 

what would be allowable under local land use plans and zoning ordinances. As discussed in Section 4.2, 

any analysis of impacts on land use and visual resources at non-DOE storage sites would be highly 

speculative at this time. 

4.2.2 Geology, Soils, and Geologic Hazards 

Continued mercury storage at Y–12 would have no impact on geologic or soil resources as there would be 

no new construction. The potential for geologic conditions to affect existing facilities at Y–12 is low (see 

Chapter 3, Section 3.9.2.3). However, earthquakes have historically produced ground motion effects 

equivalent to Modified Mercalli Intensity (MMI) VI at the site, and the maximum predicted earthquake 

for Y–12 could produce intensities of up to MMI VII (see Appendix B, Table B–4). The predicted peak 

ground acceleration at the site from an earthquake with an annual probability of occurrence of 1 in 

2,500 is 0.22 g (force of acceleration relative to that of Earth’s gravity). While ground motion in this 

range could cause considerable damage to ordinary structures, damage to properly designed and 

constructed facilities is not expected. DOE applies the seismic engineering provisions from the latest 

building codes as the minimum standard for the design, construction, and upgrade of its facilities. 

For non-DOE sites, it is assumed that such storage facilities would be compliant with modern building 

codes that specify criteria for seismic design in accordance with the assessed hazard for the affected 

locality. At some locations, construction of new storage space, such as a typical single-story warehouse 

structure on a concrete foundation, would have negligible-to-minor incremental impacts on geology and 

soils and geologic resource demands. Mercury storage space constructed to be compliant with RCRA 

permit requirements, as discussed in Section 4.2.1, or existing, commercial RCRA-permitted facilities, 

where excess elemental mercury could be sent, would have to meet applicable location, design, 

construction, and performance standards under Title 40 of the Code of Federal Regulations (CFR), 

Part 264, to safeguard the stored material from release, including threats from natural hazards such as 

earthquakes. 

An analysis of potential environmental consequences resulting from an earthquake-induced accident is 

described in Section 4.2.9.2. 

4.2.3 Water Resources 

No impacts on water resources are expected at Y–12 as there would be no new construction. As 

discussed in Section 4.2, any analysis of impacts on water resources at non-DOE storage sites would be 

highly speculative at this time. At some non-DOE sites, new facility construction that might be 
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4–4

undertaken would expose soils and sediments to possible erosion by heavy rainfall or by wind and could 

convey other pollutants in stormwater runoff. Nevertheless, appropriate soil erosion and sediment control 

measures and spill prevention and waste management practices would serve to minimize suspended 

sediment, the transport of other deleterious materials, and potential water quality impacts. It is assumed 

that all construction would be conducted in accordance with applicable state- or EPA-issued National 

Pollutant Discharge Elimination System (NPDES) general permits for stormwater discharges associated 

with construction activities. 

Routine mercury storage at new or existing non-DOE storage facilities and ongoing mercury storage at 

Y–12 would have no impact on surface water or groundwater. Potential impacts on water resources 

would be limited to the potential for spills and other unforeseen releases that might occur during mercury 

storage and/or during shipment, such as for transport to an RCRA-permitted storage facility. DOE 

assumes that non-DOE storage facility operators would adhere to their established procedures and 

safeguards for proper management and handling of elemental mercury, facility maintenance, and spill 

prevention and response. Mercury flasks would continue to be stored at Y–12 in wooden box pallets 

within the existing warehouse, which has epoxy-sealed and curbed concrete floors. Appropriate best 

management practices for material storage and handling, including inspections of mercury storage 

locations and mercury vapor monitoring, would continue. All activities would be conducted in 

accordance with applicable DOE policies and procedures that address spill prevention, response, and 

cleanup. DOE maintains a stormwater pollution prevention plan for Y–12 to minimize the discharge of 

pollutants in stormwater runoff (see Chapter 3, Section 3.9.3.1). 

4.2.4 Meteorology, Air Quality, and Noise 

4.2.4.1 Meteorology 

Meteorological events such as heavy snow, tornadoes, high winds, and lightning can result in damage to 

buildings such as mercury storage warehouses. The frequency and consequences of such events vary with 

the locations of existing mercury storage facilities (see Section 4.2.9.3). It is assumed that new and 

existing non-DOE storage facilities and sources of elemental mercury would be compliant with modern 

building codes that specify criteria for structural loading in accordance with the assessed meteorological 

hazards. Mercury storage space constructed to be compliant with RCRA permit requirements, as 

discussed in Section 4.2, or existing, commercial RCRA-permitted facilities, where excess elemental 

mercury could be sent from non-DOE storage facilities, would meet applicable design, construction, and 

operation requirements under Title 40 of the CFR, Section 264.31, and applicable state RCRA 

requirements to prevent the release of stored materials. With regard to DOE storage facilities, DOE 

Order 420.1B and its companion guide (DOE Guide 420.1-2) also explicitly require that facilities be 

designed, constructed, and operated so that the public, workers, and environment are protected from 

adverse impacts of natural phenomena hazards. This includes hurricanes and tornadoes, high winds, 

excessive snow or ice, etc. The Order also stipulates natural phenomena hazards mitigation for DOE 

facilities. East-central Tennessee has a temperate climate, and the region is not prone to hurricanes, 

frequent tornadoes, or heavy snows. Regardless, continued use of the existing Y–12 warehouse for 

storage of elemental mercury would be subject to periodic review to minimize the risk from 

meteorological phenomena. 

4.2.4.2 Air Quality 

Impacts on air quality are anticipated to be negligible from ongoing activities related to storage of 

elemental mercury. No construction of additional storage space is expected to be required at Y–12. 

However, new construction or construction of additional storage space at some non-DOE storage sites 

would result in short-term increases in emissions of criteria and toxic air pollutants from construction 

equipment. Also, additional short-term air quality impacts would result from truck or rail shipments of 

elemental mercury from non-DOE storage facilities such as for storage in an RCRA-permitted storage 
Environmental Consequences 

4–5

facility. The existing primary sources of criteria air pollutants at any existing storage sites could include 

heating systems, boilers, and material-handling equipment such as forklifts. 

4.2.4.3 Noise 

Most activities related to storage, such as inspections, would be performed inside the new or existing 

storage facilities and would result in negligible or no noise impacts on nearby noise-sensitive areas. 

Regular maintenance of the storage facilities is expected to continue and is not expected to result in any 

offsite noise impacts. At non-DOE storage facilities, activities associated with readying elemental 

mercury for shipment, such as for transport to an RCRA-permitted storage facility, could result in shortterm increases in offsite noise, including noise associated with increased truck traffic. No increase in 

truck traffic is expected at Y–12. 

4.2.5 Ecological Resources 

As indicated in Section 4.2, some non-DOE storage sites may require new construction or may need to 

expand and/or modify their storage capacity; construction activities would result in land disturbance, with 

the potential to disturb terrestrial resources and other ecological resources, and related visual impacts. As 

discussed in Section 4.2, any analysis of impacts on ecological resources at non-DOE storage sites would 

be highly speculative at this time. Under the No Action Alternative, no existing facilities at Y–12 would 

be modified, nor would any new mercury storage facilities be constructed at Y–12, and no incremental 

impacts on ecological resources would occur. 

4.2.6 Cultural and Paleontological Resources 

As discussed in Section 4.2, any analysis of impacts on cultural and paleontological resources at nonDOE storage sites would be highly speculative at this time. At Y–12, there are 76 existing historic 

properties that, along with an associated historic district, are eligible for listing in the National Register of 

Historic Places (NRHP) (see Chapter 3, Section 3.9.6.2). There would be no impact on these properties at 

Y–12 from continued mercury storage. 

4.2.7 Site Infrastructure 

Depending on the need for new construction or for non-DOE storage sites to modify their mercury storage 

capacity, as discussed in Section 4.2, additional increases in utility resource consumption could occur. 

However, utility demands for warehouse operations, including lighting and ventilation, are not 

particularly resource intensive. Under the No Action Alternative, there would be no change in utility 

infrastructure demands associated with continued storage of elemental mercury at Y–12. Operation of the 

storage warehouse is expected to continue to require up to about 0.2 megawatt-hours of electricity and 

988 liters (261 gallons) of water annually (DLA 2004a:4-28). 

4.2.8 Waste Management 

Mercury storage operations at non-DOE storage sites and at Y–12 under the No Action Alternative would 

generate small volumes of mercury-contaminated waste. The waste would primarily consist of cleaning 

rags used during facility maintenance activities, personal protective equipment (PPE), and materials used 

during spill response activities. Existing site waste management practices are assumed to continue at all 

non-DOE sites, with mercury-contaminated wastes shipped off site by a commercial waste management 

company for proper disposal. As discussed in Section 4.2, any analysis of impacts on waste management 

at non-DOE storage sites would be highly speculative at this time. 

It is estimated that 109 55-gallon (208-liter) drums of mercury-contaminated waste would be generated 

based on a 40-year period of analysis of continued mercury storage at Y–12. This volume (equivalent to 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–6

3 55-gallon drums annually) is significantly less than the total amount of routine hazardous waste 

generated each year at Y–12 (see Chapter 3, Section 3.9.8). Hazardous waste generated during routine 

Y–12 operations is shipped off site for treatment and disposal at either DOE or licensed commercial 

facilities. 

4.2.9 Occupational and Public Health and Safety 

The No Action Alternative is described in the introductory paragraphs of Section 4.2. The analysis of 

risks associated with the No Action Alternative can be divided into two parts: 

 Risks associated with the operation of non-DOE storage facilities. These risks are very hard to 

describe quantitatively because to do so would be highly speculative based on the available 

data. 

 Risks associated with the storage of mercury at Y–12. These risks can be analyzed and 

characterized to the same level of detail as those for the candidate storage facilities under the 

action alternatives. 

Before discussing the human health risks associated with specific alternatives, it is convenient to describe 

assumptions, data, and methods of analysis that are common to all alternatives. This is done in 

Section 4.2.9.1. Section 4.2.9.2 then discusses normal operations risks under the No Action Alternative, 

followed by facility accident risks (see Section 4.2.9.3), transportation risks (see Section 4.2.9.4), and 

intentional destructive acts (see Section 4.2.9.5). In addition, there are a few site-specific considerations 

that are discussed in the appropriate sections on occupational and public health and safety. 

4.2.9.1 Considerations Common to All Alternatives 

Appendix D of this Mercury Storage EIS contains a detailed description of the analyses that were 

performed to assess the human health risks to workers and members of the public. Many of the analytical 

considerations and many of the results are the same under each alternative. Therefore, the reader is 

frequently referred to Appendix D to avoid excessive repetition. 

4.2.9.1.1 Toxic Effects of Mercury 

This study considers three forms of mercury:2

 (a) elemental mercury, which is the form in which mercury 

would be stored and transported; (b) inorganic/divalent mercury,3

 which is the form into which elemental 

mercury can be converted if it is involved in a fire;4

 and (c) methylmercury, which can potentially be 

formed if elemental mercury or inorganic mercury becomes mixed with soil or sediment.5

 

EPA (1997a–c), in its Mercury Study Report to Congress, provides exhaustive descriptions of the 

potential effects of these forms of mercury on humans. Appendix D, Sections D.3.1 through D.3.3, 

provide a summary of that information; a condensed version is presented briefly below. 

 

2

 The consequences of exposure to mercury depend on the form of mercury. See Appendix D, Section D.1.1.2, for a discussion. 

For a more-detailed primer on the forms of mercury, see GreenFacts (2009). 3

 Mercury can exist in three oxidation states (EPA 1997d:2-2): elemental (Hg0), mercurous, (Hg2

2+) and mercuric (Hg2+). 

Mercurous compounds are unstable in the environment. In this EIS, Hg2+ is referred to interchangeably as “inorganic” or 

“divalent” mercury; both terms are shorthand for inorganic mercury compounds. See Appendix D, Section D.1.1.2, for further 

discussion. 4

 The potential formation of divalent mercury in a fire is extremely important for the assessment of risk in this EIS. Elemental 

mercury (i.e., the form in which the mercury would be stored) has a very small dry deposition velocity and is only slightly 

affected by precipitation scavenging (i.e., washout by rain or snow). However, divalent mercury has a significant dry 

deposition velocity and is quite effectively removed by precipitation. Therefore, the only scenarios in this EIS that lead to 

deposition on the ground from a vapor cloud are the fire scenarios. See Appendix D, Section D.7.3.3, for further discussion. 5

 Methylmercury is used as a surrogate for organomercuric compounds, as is the case in EPA’s Mercury Study Report to

Congress (EPA 1997a). See Appendix D, Section D.1.1.2, for further discussion. 
Environmental Consequences 

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The principal route of exposure to elemental mercury is by inhalation. Once absorbed through the 

lungs, it is readily distributed throughout the body and causes a range of adverse neurological effects 

at low exposure levels, such as (a) tremors; (b) emotional liability; (c) insomnia; (d) muscle 

weakness, twitching, and atrophy; (e) headaches; and (f) impairment of cognitive function. Elemental 

mercury may also result in adverse renal effects and pulmonary dysfunction. 

In contrast to elemental mercury, ingestion of inorganic mercury salts with subsequent absorption 

through the gastrointestinal tract is an important route of exposure. Adverse effects of exposure to 

inorganic mercury include kidney disease, peripheral and motor neurotoxicity, and renal impairment. 

Methylmercury is a highly toxic substance that is readily absorbed through the gastrointestinal tract. 

As is well known, the principal concern is ingestion of methylmercury in fish. Once in the body, it 

readily passes into the adult and fetal brain, where it accumulates and is subsequently converted to 

inorganic mercury. Consequently, the nervous system is considered to be the critical target organ 

system for methylmercury toxicity. The nervous system of developing organisms is considered of 

special concern. 

Human Receptors

The purpose of the human health analysis in this EIS is to assess the risk of exposure of various human 

receptors to levels of mercury in its various forms that could cause health effects, as described in the 

foregoing paragraphs. Three human receptors are considered: 

 Involved workers – those inside the storage building or working on unloading mercury trucks 

or railcars 

 Noninvolved workers – those nearby but still on site 

 Members of the public 

Assessment of Risk

Risk under any specific accident scenario is generally expressed as a function of two numbers: the 

predicted frequency of occurrence of the scenario and the predicted severity of the consequences. For the 

purposes of this analysis, the matrix shown in Figure 4–1 was used to assess the magnitude of the risk. 

The derivation of the frequencies (f) of the scenarios that were considered for this risk assessment is 

provided in Appendix D, Section D.1.1.1. The predicted frequencies are then assigned to one of four 

bands: 

 Frequency Level (FL)-IV (high) – more than or equal to once in 100 years (f ≥ 10-2 per year) 

 FL-III (moderate) – less than once in 100 years to once in 10,000 years (10-2 per year 

> f ≥ 10-4 per year) 

 FL-II (low) – less than once in 10,000 years to once in 1 million years (10-4 per year 

> f ≥ 10-6 per year) 

 FL-I (negligible) – less than once in 1 million years (f < 10-6 per year) 
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Figure 4–1. Risk (Frequency and Consequence) Ranking Matrix 

The form of the risk matrix and the definition of the FLs are consistent with guidance provided by DOE 

(DOE Standard 3009-94) in its Preparation Guide for U.S. Department of Energy Nonreactor Nuclear 

Facility Documented Safety Analyses. 

The definition of Severity Levels (SLs) I through IV for human receptors is described in detail in 

Appendix D, Section D.1.1. It is necessary to assign these levels for several cases: (a) acute-inhalation 

exposures to the public, (b) acute-inhalation exposures to workers, (c) chronic-inhalation exposures to the 

public and workers, and (d) exposures to mercury deposited on the ground. How these SLs are assigned 

is discussed in Section D.1.1.2. The assignment of SLs for acute inhalation (i.e., inhalation of elemental 

mercury or inorganic mercury) is discussed in detail in Sections D.1.1.2.1 and D.1.1.2.3. The SLs are 

related to EPA’s Acute Exposure Guideline Levels (AEGLs), as summarized in Table 4–1. 

Table 4–1. Definition of Consequence Severity Bands for Acute Inhalation of 

Elemental Mercury and Inorganic Mercury – Public Receptorsa

Acute-Inhalation 

Consequence Severity Level 

Corresponding Airborne 

Concentrations of Elemental Mercury Expected Health Effects 

Inhalation Severity Level IV ≥ AEGL-3 Potential for lethality as concentration 

increases above AEGL-3 

Inhalation Severity Level III < AEGL-3 and ≥ AEGL-2 Potential for severe, sublethal, 

irreversible health effects 

Inhalation Severity Level II < AEGL-2 and ≥ 0.1×AEGL-2b Potential for reversible health effects 

Inhalation Severity Level I < 0.1×AEGL-2b Potential for minor irritation, equated 

with negligible-to-very-low 

consequences 

a Exposure period up to 8 hours. 

b Ideally, this should be tied to some multiple or fraction of AEGL-1. However, AEGL-1 has not been defined for elemental mercury. 

Key: 2=greater than or equal to; L=less than; AEGL=Acute Exposure Guideline Level. 
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As described below, there are three AEGLs. They represent threshold exposure limits for the general 

public and are applicable to emergency exposure periods ranging from 10 minutes to 8 hours. It is 

believed that the recommended exposure levels protect the general population, including infants and 

children and other individuals who may be susceptible. However, although the AEGL values represent 

threshold levels for the general public, it is recognized that individuals, subject to unique or idiosyncratic 

responses, could experience the effects described at concentrations below the corresponding AEGL. The 

three AEGLs have been defined as follows: 

AEGL-1 is the airborne concentration above which it is predicted that the general population, including 

susceptible individuals, could experience notable discomfort, irritation, or certain asymptomatic 

nonsensory effects. However, the effects are not disabling and are transient and reversible upon 

cessation of exposure. 

AEGL-2 is the airborne concentration above which it is predicted that the general population, including 

susceptible individuals, could experience irreversible or other serious, long-lasting adverse health 

effects or an impaired ability to escape. 

AEGL-3 is the airborne concentration above which it is predicted that the general population, including 

susceptible individuals, could experience life-threatening health effects or death. 

Airborne concentrations below AEGL-1 represent exposure levels that can produce mild and 

progressively increasing but transient and nondisabling odor, taste, and sensory irritation or certain 

asymptomatic, nonsensory effects. 

EPA’s proposed AEGLs for elemental mercury are shown in Table 4–2. 

Table 4–2. Proposed EPA Values for Mercury Vapor AEGLs 

Exposure 10 minutes 30 minutes 60 minutes 4 hours 8 hours 

Guideline 

AEGL-1a NR NR NR NR NR 

AEGL-2 3.1 mg/m3 2.1 mg/m3 1.7 mg/m3 0.67 mg/m3 0.33 mg/m3

AEGL-3 16 mg/m3 11 mg/m3 8.9 mg/m3 2.2 mg/m3 2.2 mg/m3

a Table 4–1 uses 0.1 × AEGL-2 as a surrogate for AEGL-1. The reasons for doing so are described in Appendix D, 

Section D.1.1.2.1. 

Note: Reported values are in milligrams per cubic meter, NOT parts per million. AEGLs for durations of exposure other than 

those explicitly listed in this table are obtained by linear interpolation. 

Key: AEGL=Acute Exposure Guideline Level; EPA=U.S. Environmental Protection Agency; mg/m3

=milligrams per cubic 

meter; NR=not recommended (due to insufficient data). 

Source: EPA 2009a. 

Note that AEGL-1 has not been defined: the reasons for using 0.1 × AEGL-2 as a threshold below which 

health effects caused by exposure to elemental mercury are expected to be negligible or very low are 

given in Appendix D, Section D.1.1.2.1, which also explains why the same AEGLs as in Table 4–2 and 

the same SLs as in Table 4–1 also apply to inorganic mercury. AEGLs for methylmercury are not used in 

this study because the accident scenarios considered are such that they only lead to inhalation of 

elemental mercury or inorganic mercury. Methylmercury can only be formed after deposition of the 

inorganic mercury on the ground and mixing in soil or sediment. 

One important consideration is that the AEGLs are intended for one-time exposures only. Therefore, it is 

necessary to consider the possibility that these levels would not be protective if the same individual were 

exposed twice. Appendix D, Section D.4.6, shows that, even with conservative assumptions, the 

acute-inhalation risks from exposure to two accidental spills of mercury over the period of 40 years 

assumed for this analysis would be negligible under most accident scenarios and at most low. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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For workers, the National Institute for Occupational Safety and Health has published a benchmark for 

acute exposures that are immediately dangerous to life or health (IDLH) (CDC 2009). For mercury, this 

is 10 milligrams per cubic meter (see Appendix D, Table D–21). The IDLH represents the maximum 

concentration of a substance in air from which healthy workers can escape without loss of life or 

irreversible health effects under conditions of a maximum 30-minute exposure time. 

In principle, it would be possible to develop an SL scheme, tied to the IDLH, similar to that in Table 4–1. 

Unfortunately, there are no IDLH equivalents of the three AEGLs. However, the IDLH approximately 

equals AEGL-3 for a 30-minute exposure (11 milligrams per cubic meter; see Table 4–2). It therefore 

seems reasonable to adopt the same acute-inhalation SLs for workers as for members of the public. One 

could make a case that this is conservative because workers are generally expected to be healthy while the 

AEGLs are crafted to include susceptible members of the public. Therefore, Table 4–1 applies to workers 

as well as to the public. 

For chronic-inhalation exposures to humans, EPA has published a reference concentration (RfC) of 

0.0003 milligrams per cubic meter (EPA 2009e). The consequences of exposures below this level are 

negligible, so, in terms of the SLs in Figure 4–1, the RfC marks the boundary between SL-I and -II. The 

analysis performed for this EIS shows that all chronic-inhalation exposure scenarios lead to predicted 

airborne exposures to both the noninvolved worker and the general public in the SL-I range. Therefore, 

there is no need to define thresholds for SL-III and -IV. 

For chronic-inhalation exposures to humans inside the building, it is assumed that, during normal 

operations, involved workers would never be exposed to airborne concentrations of mercury vapor above 

the American Conference of Governmental Industrial Hygienists’ (ACGIH’s) time-weighted 

average/threshold limit value (TWA/TLV) of 0.025 milligrams per cubic meter of mercury vapor 

(OSHA 2002). Referring to Figure 4–1, this defines the threshold between SL-I and -II. The analysis 

performed for this EIS shows that involved worker exposures would always be below this threshold, 

assuming a combination of ventilation, inspection, monitoring, and use of PPE, as recommended by the 

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

Long-Term Storage of Elemental Mercury (Interim Guidance) (DOE 2009c). Therefore, there is no need 

to define the thresholds for SL-III and -IV. 

Appendix D, Section D.1.1.2.6, discusses a value for the level of deposited mercury that can be used to 

define the boundary between SL-I and -II based on an extensively studied real-life case, that of the 

remediation of East Fork Poplar Creek in Oak Ridge, Tennessee, and its floodplain (ATSDR 2009a, 

2009b; ORNL 2009). Mercury was discharged into the creek from 1950 to 1963 as a result of separations 

of lithium isotopes at Y–12 in support of the hydrogen bomb project. Note that this discharge was not a 

result of elemental mercury storage at Y–12. The Agency for Toxic Substances and Disease Registry 

made a finding, based on mercuric chloride, that a cleanup level of 180 milligrams of mercury per 

kilogram of soil is protective of public health. This is based on a “worst-case” scenario involving young 

children who live close to East Fork Poplar Creek and play in the East Fork Poplar Creek floodplain. 

This scenario is considered the worst case because it involves the most sensitive population (young 

children) exposed to the most highly absorbable forms of inorganic mercury (mercuric chloride and 

elemental mercury). The most probable route of exposure to inorganic mercury would be swallowing 

dust and dirt. 

Based on the foregoing case, it is judged that the boundary between SL-I (negligible-to-very-low 

consequences) and -II (onset of adverse consequences due to ingestion of inorganic mercury) is 

180 milligrams per kilogram of inorganic mercury. Beyond that, no guidance has been found as to what 

level would cause irreversible health effects or fatalities. However, the analysis performed for this EIS 

shows that there are no scenarios in which mercury would be deposited (either by dry or wet deposition) 

at levels above 180 milligrams per kilogram, so there is no need to define the thresholds for SL-III 

and -IV. 
Environmental Consequences 

4–11

4.2.9.1.2 Factors Strongly Influencing the Risks Associated with the Proposed Action 

There are a number of reasons for expecting the risks associated with the transport and storage of 

elemental mercury to be low; these are described below. 

Elemental mercury has been stored and transported safely for many years. There is a long history of 

mercury storage at sites holding the Defense National Stockpile Center (DNSC) inventory. Currently, 

4,436 metric tons (4,890 tons) are held at three depots: New Haven, Indiana; Somerville, New Jersey; 

and Warren, Ohio. Formerly, 699 metric tons (770 tons) of this inventory was held at Y–12, but this 

portion was moved to Warren in early 2005 (Munger 2005). 

In the course of preparation of the Defense Logistics Agency Final Mercury Management Environmental 

Impact Statement (DLA 2004a, 2004b), information was gathered from site visits, phone calls, and 

various documents. The inspection reports for the mercury storage areas were reviewed for information 

about past releases of mercury. No mercury has reportedly escaped from any of the warehouses, and 

there is no known member of the public that has been affected at any of the existing storage locations. 

Decades of experience in maintaining the stockpile of mercury indicate that spills of mercury resulting in 

environmental contamination have not occurred, and that that normal (accident-free) operating conditions 

should be maintained at the storage facilities. The storage facilities are built to ensure containment of the 

mercury under most conditions. Spilled mercury is not known to overrun the spill trays (that can hold the 

contents of several flasks) or containment berms or penetrate the concrete floors and reach any 

surface-water or groundwater sources before cleanup. 

In addition, Oak Ridge National Laboratory examined 3-L flasks removed from the DNSC inventory 

(DOE 2009c). It is known that mercury does not react with steel containers at ambient temperatures; this 

was confirmed by metallurgical analysis of 3-L flasks from the DNSC inventory. Thus, containers in 

static storage in a well-maintained facility should have a long lifetime. 

The vapor pressure of mercury at typical ambient temperatures is very low. As noted in Appendix D, 

Section D.7.1.3, the assumed temperature of any spillage of elemental mercury is 20 degrees Celsius (C) 

(68 degrees Fahrenheit [F] or 293 Kelvin). At that temperature, its saturated vapor density is only 

14 milligrams per cubic meter.6

 This is equivalent to a release of pure elemental mercury vapor that has 

already been diluted by five orders of magnitude (i.e., mixed with five times its mass of air). Hence, a 

relatively small amount of additional dilution is required to bring the concentration down to the 

benchmarks such as the 30-minute AEGL-3 of 11 milligrams per cubic meter or the 60-minute AEGL-2 

of 1.7 milligrams per cubic meter. It is for this reason that the human health risks predicted under all 

scenarios involving the evaporation of a spill of elemental mercury are in the negligible-to-low range at 

all sites. 

For releases of elemental mercury vapor, the dry deposition velocity and the scavenging rate7

 are 

essentially zero. It is only during fire scenarios that elemental mercury is converted into forms that have 

non-zero dry deposition velocities or scavenging rates (see Appendix D, Section D.7.3.3). Therefore, for 

spills of elemental mercury with no accompanying fires, there is no need to be concerned about any 

pathways that result from deposition onto the ground or into water bodies from airborne plumes. 

 

6

 Even at a conservatively high temperature of 40 C (104 F or 313 Kelvin), the saturated vapor pressure is only 

65.9 milligrams per cubic meter, still approximately five orders of magnitude more dilute than a pure release of elemental 

mercury vapor. 7

 The scavenging rate is a measure of how rapidly rainfall can remove mercury from a plume. It is defined and discussed in 

Appendix D, Section D.7.3.3. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–12

For releases of elemental mercury vapor leaking from the storage building or accidentally released 

nearby, there is substantial dilution in the building wake.

8

 Any new construction and any existing 

buildings that are candidate storage facilities are sufficiently large that mixing in the turbulent building 

wake would dilute the elemental mercury concentrations to levels well below 0.1 × AEGL-2 

(see Appendix D, Section D.8.2.1). 

For fires accompanied by a spill of mercury, substantial plume rise is always predicted. This means that 

there is considerable initial dilution as the plume rises. Therefore, predicted close-in airborne 

concentrations and deposited levels of mercury under the plume are very low, and the peaks occur at 

various distances downwind that depend on the specific weather conditions, by which time considerable 

dilution in addition to that caused by plume rise dilution has already taken place. 

4.2.9.1.3 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites and to the No Action Alternative. As noted above, consequences to the 

involved worker are predicted to be negligible (SL-I) because involved workers would never be exposed 

to airborne concentrations of mercury vapor above the ACGIH’s 8-hour TWA/TLV of 0.025 milligrams 

per cubic meter of mercury vapor. Therefore, the risks to involved workers would be negligible. 

Appendix D, Section D.4.1.1, reports on mercury vapor concentrations observed over several months in 

2001 and 2002 in mercury storage warehouses at the Defense Logistics Agency’s Somerville Depot 

(Shim, Hsieh, and Watts 2002). The only occasions on which concentrations above 0.025 milligrams per 

cubic meter were encountered occurred during overpacking of flasks in drums, which is not expected 

during the 40-year period of analysis. In addition, the measurements showed that many of the higher 

observed levels arose from residual contamination of the floor, which would not be the case in a new 

storage facility. In addition, once the mercury had been overpacked and placed in a warehouse that had 

not previously been used for storage, the average mercury vapor concentration9

 taken over various 

periods from 2 days to a week was 0.00012 milligrams per cubic meter, with a peak of 

0.00032 milligrams per cubic meter. 

 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 

3-L flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this 

source of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building 

wake. Appendix D, Section D.4.2.3, shows that the predicted long-term average concentration in the 

building wake for any of the seven candidate storage sites and Y–12 is not more than 

8.0 × 10-5 milligrams per cubic meter. This is well below EPA’s chronic-inhalation-exposure RfC of 

3.0 × 10-4 milligrams per cubic meter. Hence, consequences would be in the SL-I range, and the risk to 

both noninvolved workers and members of the public would be negligible. 

Appendix D, Section D.4.1.2, reviews observed concentrations near Defense Logistics Agency mercury 

storage warehouses (Shim, Hsieh, and Watts 2002) and confirms that these observations are consistent 

with the prediction that long-term exposure to elemental mercury vapor during normal operations is well 

below EPA’s RfC of 3.0 × 10-4 milligrams per cubic meter. 

8

 The building wake is a volume of highly turbulent air immediately downwind of the building. Any release of mercury vapor 

from or adjacent to the building would be thoroughly mixed into this wake and extensively diluted before traveling downwind. 

Appendix D, Section D.7.2.1, describes how to calculate concentrations in the wake. 9

 The sampling times for the concentrations were either 30 seconds (Lumex monitor) or a few minutes (Tekran monitor), so the 

concentrations discussed above show that the 8-hour TWA was not exceeded. 
Environmental Consequences 

4–13

4.2.9.1.4 Facility Accidents 

Appendix D, Section D.2.4, contains detailed considerations of the likelihood of occurrence of candidate 

facility (onsite) accident scenarios initiated by failures of engineered systems or human errors. 

Section D.2.5 describes candidate external events and their likelihood of occurrence. Table 4–3 

summarizes the results of this analysis. These results are the same for all potential storage sites and do 

not provide a means of discriminating between them. They are slightly different under the No Action 

Alternative, which is discussed further below. 

Table 4–4 lists the accident scenarios that remain for consequence analysis after eliminating those with 

negligible (FL-I) frequency from Table 4–3. These accident scenarios are the same for all candidate 

storage sites and are slightly different under the No Action Alternative. 

As described above, the saturated vapor density of mercury at the assumed release temperature of 20 °C 

(68 °F) is about 14 milligrams per cubic meter. This is only a little above the 30-minute IDLH of 

10 milligrams per cubic meter or the 30-minute AEGL-3 of 11 milligrams per cubic meter. In practice, if 

there is a spill while a worker is present, that worker would leave the building rapidly, in much less than 

the half-an-hour for which he or she could potentially be exposed to the IDLH and still be able to escape. 

Therefore, the involved worker would be exposed to a toxic load much less than that accumulated in a 

half-hour’s exposure to 10 to 11 milligrams per cubic meter. As previously discussed, if the exposure lies 

between AEGL-3 and AEGL-2, it is considered to be in the SL-III range. If the worker moves rapidly, 

the equivalent toxic load could conceivably be less than AEGL-2 (SL-II) or even 0.1 × AEGL-2 (SL-I). 

Per Table 4–3, the frequencies of all of the scenarios in Table 4–4 are low (FL-II) or moderate (FL-III). 

Combining this with a consequence in the SL-I to -II range gives a risk in the negligible-to-low range for 

the involved worker in the storage building at all sites. 

Table 4–3. Generic Summary of Candidate Onsite Accident Scenarios and 

Their Likelihood of Occurrence 

Hazard Activity Postulated Scenario 

Frequency of 

Releasea

Evaluated 

Further Commentsa

Kinetic Onsite 

material 

handling 

Single flask is dropped 

during handling, resulting 

in breach. 

Moderate 

(FL-III) 

Yes Consolidation of partially filled 

pallets could lead to a relatively 

large number of handling 

events per year. 

Kinetic Onsite 

material 

handling 

Single pallet is dropped 

during transfer to storage 

racks, resulting in breach. 

Moderate 

(FL-III) 

Yes Assumes pallet dropped from 

3.7 meters (12 feet) and all 

49 flasks breached. 

Conservatively assumed that 

could occur outside the 

building as well as inside. 

Kinetic Onsite 

material 

handling 

Triple-pallet collapse. Moderate 

(FL-III) 

Yes Requires failure of storage 

rack. Could only occur inside 

building. 

Kinetic Onsite 

material 

handling 

Single 1-MT container 

drop. 

Moderate 

(FL-III) 

Yes Could occur inside or outside 

building. Assumes container 

dropped from a height of less 

than 1.5 meters (5 feet). 

Fire Onsite 

storage 

Building fire involving 

multiple flasks or 1-MT 

containers. 

Negligible 

(FL-I) 

No No ignition sources, controls on 

flammable materials, reliable 

fire protection system. 

Forklift fire Onsite 

storage 

Forklift crashes and burns. Negligible 

(FL-I) 

No DOE guidance recommends 

using electric forklift. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–14

Table 4–3. Generic Summary of Candidate Onsite Accident Scenarios and 

Their Likelihood of Occurrence (continued)

Hazard Activity Postulated Scenario 

Frequency of 

Releasea

Evaluated 

Further Commentsa

Fire/ 

explosion 

nearby 

All 

activities 

Fire/explosion at nearby 

building impacts mercury 

containers. 

Negligible 

(FL-I) 

No No other facilities containing 

explosives or potentially 

flammable materials close 

enough to impact storage 

building. 

Wildfire All 

activities 

Wildfire consumes storage 

building. 

Negligible 

(FL-I) 

No Although wildfires are 

common, fire monitoring, 

prevention and suppression 

systems greatly reduce the 

likelihood of mercury release. 

Earthquake All 

activities 

Earthquake results in 

building damage and 

causes pallets and/or 

flasks to fall and spill. 

Moderate 

(FL-III) 

Yes Requires an earthquake and 

failure of flasks or 1-MT 

containers. Two alternatives 

considered: building remains 

recognizably intact or building 

collapses completely.b

Flood All 

activities 

Storage building floods, 

causing failure of 3-L 

flasks or 1-MT containers. 

Moderate 

(FL-III) 

Yes Requires failure of flasks or 

1-MT containers. Bounded by 

earthquake scenario. 

Weather All 

activities 

High winds or tornadoes 

result in roof failure and 

cause pallets and/or flasks 

to fall. 

Low (FL-II) 

or negligible 

(FL-I) 

(tornadoes); 

negligible 

(FL-I) 

(high winds) 

Yes Requires failure of flasks or 

1-MT containers. Bounded by 

earthquake scenario. 

Weather All 

activities 

Lightning strike causes 

small building fire 

involving limited number 

of mercury containers. 

Negligible 

(FL-I) 

No Lightning strike as initiator of 

building fire not considered 

credible. Assumes building 

lightning protected as required 

by building codes. 

Weather All 

activities 

Snow load causes roof 

collapse, resulting in 

mercury containers’ 

falling. 

Negligible 

(FL-I) 

No Assumes building designed to 

requirements of building codes. 

Surface 

transportation 

Onsite 

storage 

Vehicle or train crashes 

into building, resulting in 

mercury container breach. 

Negligible 

(FL-I) 

No Slow vehicle speeds in vicinity 

of building. 

Aircraft crash All 

activities 

Aircraft crashes into 

building, resulting in fire, 

mercury container breach. 

Negligible 

(FL-I) 

No Limited target area given type 

of aircraft, flight vectors, and 

size of storage area within 

building. 

a For justification of frequency assignments and comments, see Appendix D, Sections D.2.4 and D.2.5. 

b No effort is made to split the moderate frequency between earthquake with building collapse and earthquake without building collapse 

(i.e., conservatively, the frequency of occurrence of both scenarios is moderate). 

Key: 1-MT=1-metric-ton; 3-L=3-liter; DOE=U.S. Department of Energy; FL=frequency level. 
Environmental Consequences 

4–15

Table 4–4. Summary of Types of Accidents Considered in 

Onsite Spill Analysis 

Accident Scenario 

Could Occur 

Indoors? 

Could Occur 

Outdoors? 

Single-flask spill Yes Noa

Single-pallet spill Yes Yes 

Triple-pallet spill Yes Nob

1-metric-ton container spillb Yes Yes 

Earthquake spillc Yesd Yese

a Mercury flasks are transported and stored in pallets in a 7- by 7-flask configuration. Flasks may 

be removed from a pallet if they are leaking or if partially filled flasks are consolidated. 

b Triple-pallet collapse could only occur when the pallets are inside on the storage racks. 

c This scenario also encompasses the risk from tornadoes, high winds, and floods. 

d Earthquake leaves building relatively intact. 

e Earthquake causes building collapse. 

Under all of the scenarios in Table 4–4, both indoors and outdoors (except the earthquake with building 

collapse), the evaporating mercury would mix into the building wake. Appendix D, Section D.4.2.3, 

shows that the predicted concentrations in the wake are all in the SL-I range. Therefore, the risks to the 

noninvolved worker and the public from all of these scenarios would be negligible. 

For the specific case of an earthquake with building collapse, the rate of evaporation was estimated, and a 

Gaussian atmospheric dispersion model was used to predict the distances downwind to which the various 

SLs would be exceeded; see Appendix D, Section D.4.2.4. The results show that, for all of the candidate 

storage sites, exposures exceeding SL-I would never affect the nearest member of the public, so public 

risks would be negligible. However, this conclusion may not apply to the No Action Alternative; see 

below for further discussion. 

4.2.9.1.5 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury to the candidate storage sites over the 40-year 

period of analysis. This transportation could occur by either truck or railcar. For the case of truck 

transportation, there are two scenarios, as follows: 

 Scenario 1: full truck loads from all dispatching sites 

 Scenario 2: half-full truck loads from reclamation and recycling facilities, domestic 

gold-mining facilities, and the Port of New York (shipments from Peru),10 but full truck loads 

from Y–12 and chlor-alkali facilities 

 These assumptions, together with knowledge of truck routes and historical frequencies of 

crashes of various types, can be combined to produce estimates of the frequency at which 

crashes might occur anywhere along the routes traveled by mercury trucks or railcars. 

Frequencies are estimated for four types of consequences: Crash with spill of elemental 

mercury onto the ground without fire 

 Crash with spill of elemental mercury into water 

 

10 An estimate of this mercury was included in the quantity estimates as a conservative planning assumption regarding potential 

contributions to excess elemental mercury. However, the inclusion of an estimate for this mercury does not reflect a 

conclusion that such mercury would be “generated in the United States” as that phrase is used in the Act. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–16

 Crash with fire in dry weather conditions (without rain) (to analyze the effects of dry 

deposition) 

 Crash with fire in wet weather conditions (with rain) (to analyze the effects of wet deposition) 

The results of the frequency analysis for all candidate storage sites are shown in Appendix D, 

Tables D–12, D–13, D–14, and D–16. 

For exposures occurring via evaporation from a spill of elemental mercury with no fire during a 

transportation accident, the fraction of the mercury being carried by the truck or railcar that would be 

spilled is highly uncertain. It is extremely unlikely that all 3-L flasks or all 1-metric-ton (1-MT) (1.1-ton) 

containers would be breached. However, to be conservative, it is assumed that such a catastrophic release 

could take place. The largest amount of mercury that can be carried in a truck or railcar is that contained 

in 54 1-MT containers. Assuming that all of this mercury is spilled and spreads until the pool is at its 

capillary depth of 0.36 centimeters (0.14 inches) (so conservative as to be essentially inconceivable in an 

outdoor spill),11 the predicted rate of evaporation that would conservatively apply to all weather 

conditions would be 7.35 × 10-5 kilograms per second (see Appendix D, Section D.7.1). Running this 

through the Gaussian model and ranging over all possible combinations of atmospheric stability class and 

windspeed, the predicted maximum distances to the airborne toxic benchmarks are as follows: SL-IV, less 

than 100 meters (330 feet); SL-III, about 100 meters (330 feet); and SL-II, about 340 meters (1,115 feet). 

As a result, a specific individual could not be exposed to concentrations that are greater than SL-I if he or 

she lives more than 340 meters (1,115 feet) from a crash. Conservatively, assuming that the individual 

lives immediately adjacent to the road, that specific individual could only be exposed above SL-I if the 

crash occurs along a 680-meter (2,230-foot) stretch of road (340 meters [1,115 feet] on each side). This is 

a small fraction of any of the routes (for example, the average length of a truck trip to GJDS is 

approximately 2,000 kilometers [1,260 miles]). The frequency of occurrence of a truck crash with spill 

on the truck routes to GJDS is 0.0031 per year; see Table D–13 (Truck Scenario 2). The product of the 

fraction of the route and the frequency of occurrence is about 1.1 × 10-6 per year, a low (FL-II) frequency. 

Under Truck Scenario 1 and the Railcar Scenario, similar reasoning shows that the corresponding 

frequencies would be negligible (FL-I). Therefore, the risk to a member of the public from transportation 

spills onto the ground without fire en route to GJDS would be negligible under Truck Scenario 1 and the 

Railcar Scenario and low under Truck Scenario 2. This analysis applies to all other candidate storage 

sites. 

Spills occurring during a transportation accident could result in leakage of the mercury cargo into the 

surrounding environment. The most significant and challenging scenario (from a cleanup standpoint) 

would be a spill directly into a surface-water body, such as a lake or river. This could occur if a truck or 

railcar crashes on a bridge over a river or if it falls into a river or lake while traveling alongside the water 

body. 

It is in principle possible to calculate the frequency at which a truck might crash on a bridge. This is 

simply (frequency of crash anywhere along the route) × (number of bridge miles directly above 

water)/(average length of trip). If, for example, there were on average 10 kilometers (6.2 miles) of such 

bridges on an average 2,000-kilometer (1,260-mile) trip, one would simply multiply the frequency of spill 

by 10/2,000 = 0.005. This would make the frequency of a truck crash on a bridge low and the frequency 

of a rail crash on a bridge negligible. This conclusion must be tempered by the observation that 

probabilities of crashes per mile on bridges might be higher than those on highways in general because, 

for example, bridges ice up before the neighboring roadway does. However, no good data on this are 

 

11 Surface tension is what prevents the mercury pool from spreading any further. However, the mercury will only spread until 

the pool is at its capillary depth of 0.36 centimeters (0.14 inches) if the surface is perfectly smooth. See Appendix D, 

Section D.7.1.4. 
Environmental Consequences 

4–17

available at the time of writing, so this analysis is not used in estimates of the risk of spillage directly into 

water. 

Another way in which mercury might be spilled into water is if a truck or railcar crashes while traveling 

beside a river or other body of water. The number of miles for which this is possible is very site specific. 

For example, Interstate 70 in Colorado follows rivers and streams much of the distance in the state to get 

to GJDS. These include the Colorado River, Clear Creek, Eagle River, Straight Creek, and Gore Creek. 

The route to GJDS contains the greatest distance of any route where there might be a potential for spillage 

into a river, although at the time of writing no information had been collected on the fractions of that 

route where the road or rail is close enough for it to be plausible that a truck or railcar might crash directly 

into the river. 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors and humans (inorganic compounds 

of mercury and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

This EIS also considers railcar or truck crashes that involve fires. 

For wooden pallets of 49 3-L flasks, the material of combustion is the wood of the crate.12 It is assumed 

that the amount of wood in a truck or railcar full of 1-MT containers is encompassed by the amount of 

wood in a truck or railcar full of pallets. Either the crash itself or the heat of the fire would rupture an 

indeterminate number of flasks or 1-MT containers. The mercury is assumed to spread out over the bed 

of the truck or railcar, with the burning wood standing in or near the pool and causing evaporation by 

radiative heat transfer. The extent of the pool area is limited: the difficult question of how many flasks or 

1-MT containers might rupture is finessed by this assumption. It is believed that this is a conservative 

scenario—more than likely the mercury would run out of the damaged truck or railcar so that the 

optimum configuration of burning materials and the pool (i.e., optimum for radiative heat transfer to the 

 

12 The Interim Guidance (DOE 2009c) envisages that 3-L flasks or 1-MT containers may be transported in either wooden or 

metal pallets. In this EIS, the assumption is that the pallets are made of wood because this gives a conservatively high 

estimate of the heat that might be available to evaporate mercury. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–18

pool) is unlikely to occur. Essentially, the mercury would reach its boiling point and evaporate at that 

temperature (at a rate controlled by the windspeed over the surface) until all the available fuel has burned. 

Appendix D, Section D.8.4.1, shows that the calculated rate of evaporation for a truck pallet fire is 

1.3 kilograms per second and for a railcar pallet fire is 1.6 kilograms per second, with corresponding 

durations of release of 762 and 1,308 seconds, respectively. Section D.8.4.1 also considers how high the 

plume, containing products of combustion, mercury vapor, and entrained air, would rise. The analysis 

shows that 100 meters (330 feet) is realistic or conservative for all conditions of atmospheric stability 

class and windspeed for truck and railcar scenarios. The plume is therefore assumed to rise to a height of 

100 meters (330 feet) immediately above the source of release, at which point it defines the input for the 

Gaussian dispersion model. Using standard plume rise models, the initial radius of the plume at this 

height is taken to be about 0.6Δh, where Δh is the height of plume rise. 

Mercury released during a fire is converted into the divalent inorganic mercury form. Conservatively, it 

is assumed that it is all converted into the divalent form (see Appendix D, Section D.7.3.3). In this form, 

mercury can deposit by dry deposition or wet deposition. Section D.7.3.3 discusses the choice of dry 

deposition velocities and the rainfall scavenging rate for use in the Gaussian dispersion model. 

The Gaussian model calculations for the fire scenarios were carried out in three weather conditions that 

are representative of the full range of weather conditions: 

 Atmospheric Stability Class A with a windspeed of 1.5 meters per second, representative of 

conditions of low windspeed and high ambient thermally generated turbulence 

 Atmospheric Stability Class D with a windspeed of 4.5 meters per second, representative of 

“average” weather conditions dominated by mechanically generated turbulence 

 Atmospheric Stability Class F with a windspeed of 1.5 meters per second, representative of 

conditions with low ambient turbulence 

Human Exposure – Inhalation Pathway 

The generic results of the calculations for the inhalation pathway following a crash with fire for any 

potential site are shown in Table 4–5. 

Table 4–5. Predicted Range of Distances (meters) Downwind Within Which 

Acute Airborne Severity Levels Are Exceeded – Crashes with Fires, All Sites 

Type of Accident 

Atmospheric 

Stability 

Class/Windspeed 

0.1×AEGL-2 

(SL-II) 

AEGL-2 

(SL-III) 

AEGL-3 

(SL-IV) 

A/1.5 m/s <100–2,600 160–700 Nowhere 

Truck crash, D/4.5 m/s <100–16,000 Nowhere Nowhere 

wooden pallets F/1.5 m/s <100–40,000 600–1,300 Nowhere 

A/1.5 m/s <100–2,800 140–840 Nowhere 

Railcar crash, D/4.5 m/s <100–20,000 700–2,300 Nowhere 

wooden pallets F/1.5 m/s <100–40,000 440–2,100 Nowhere 

Note: To convert meters to feet, multiply by 3.281. 

Key: <=less than; AEGL=Acute Exposure Guideline Level; m/s=meters per second; SL=severity level. 

The combination of the consequence results above with the frequencies of crashes with fires is explained 

in Appendix D, Section D.4.5, and produces the results in Table 4–6. 
Environmental Consequences 

4–19

Table 4–6. Summary of Inhalation Risks to Human Receptors, 

Accidents with Fires, All Sites 

Both Truck Scenarios with Pallet Fire Railcar Scenario with Pallet Fire 

Frequencya FL-III FL-II 

Consequenceb SL-II SL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7.

b The highest consequence in any weather condition. 

Key: FL=frequency level; SL=severity level. 

Note that the risks presented in the above scenarios are individual risks: they are the answer to the 

question, “What is the risk to me?” This is not the same as the risk that, somewhere along a 

transportation route, airborne concentrations would exceed the various SLs. Those risks would in fact be 

higher. 

Human Exposure – Deposition Pathway 

The analyses performed for this EIS show that, under all fire scenarios listed in Table 4–6, with and 

without rain, mercury deposited on the ground would never cause the benchmark of 180 milligrams per 

kilogram to be exceeded. Therefore, the corresponding risks would be negligible. 

4.2.9.1.6 Fire – Intentional Destructive Acts 

The analysis of intentional destructive acts (IDAs) applies to all sites and all transportation routes. A 

wide range of IDA scenarios involving a release of mercury can be postulated for the sites and 

transportation routes being considered for mercury storage. Each involves an action by intruders or 

insiders that affects mercury inventories either at the storage facility or during transportation to the 

storage facility. The human health impacts of an IDA are directly related to the amount of mercury 

available for dispersion, as well as the means of dispersing it to the environment. Other factors that affect 

impacts include population density, distance to the population, and meteorology. 

IDA scenarios were selected based on the amount of mercury at the storage facility or in a transport 

vehicle. Other factors that were considered include the nature of the IDA event that would result in the 

highest dispersion of mercury to the environment. The likelihood or frequency of the IDA scenarios 

analyzed in this section cannot be quantified because of the dependence on unpredictable intruder actions 

and security measures that would be employed by DOE. Each IDA scenario assumes multiple actions by 

intruders with no successful mitigation or protection measures by DOE. Conservative analytical 

assumptions are also imposed on the calculations. The results are presented in terms of consequences, but 

not annual risks because of the lack of an annual probability or frequency for these IDA events. 

The accident analyses in Appendix D show that the largest airborne and ground mercury concentrations 

would result from scenarios in which a quantity of mercury in containers is exposed to a fire. The energy 

of a fire would increase the mercury release rate and plume release height. Since the accident analysis 

evaluates fire scenarios involving available fuel in a truck or railcar that contains mercury, the IDA 

scenarios were developed to incorporate larger quantities of flammable material in concert with mercury 

in containers on a truck or railcar. The largest easily accessible and mobile source of large quantities of 

flammable material is a gasoline tank truck, which may contain between 18,927 and 34,069 liters 

(5,000 and 9,000 gallons) of gasoline. The IDA scenario postulates that a group of individuals hijack a 

fully loaded 34,069-liter (9,000-gallon) gasoline tank truck, which they then drive into either a truck or 

railcar loaded with mercury being carried in either 34.6-kilogram (76-pound) flasks or 1-MT (1.1-ton) 

containers. Another postulated scenario would involve two groups of armed intruders: one hijacking the 

loaded tanker truck and the other disabling the train or truck carrying mercury. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–20

The postulated armed intruders would incapacitate any persons accompanying the shipment; release the 

gasoline in the gasoline tanker on and around the mercury storage containers; and set the gasoline on fire, 

thereby engulfing the mercury cargo in an unmitigated fire. This IDA event may occur either in transit or 

at the unloading location at the mercury storage facility. The same quantity of gasoline and mercury are 

assumed to be available under both scenarios; these quantities would only be limited by the transport 

capacity of the truck or railcar. The most vulnerable large quantities of mercury were determined to be 

truck or rail shipments either in transit or at the facility prior to unloading. 

IDA scenarios involving an attack on the storage facility other than during unloading of a truck or railcar 

are predicted to be less likely because of the distribution of mercury within the facility, presence of 

security, and facility design features that would ameliorate mercury releases to the environment. 

Appendix D, Section D.2.6, describes a fire caused by an IDA. The parameters needed for input into the 

atmospheric dispersion model are discussed in Section D.7.4.2, where it is explained that the railcar fire is 

a somewhat conservative bounding case for the truck fire. The results of the analyses are as follows. 

Human Exposure – Atmospheric Pathway 

Per Appendix D, Section D.7.4.2, Table D–63, the duration of release is 10,660 seconds (approximately 

3 hours). Interpolation in Section D.3, Table D–22, gives a corresponding AEGL-2 (SL-III) of 

1 milligram per cubic meter (1.0 × 10-6 kilograms per cubic meter) and an AEGL-3 (SL-IV) of 

4.4 milligrams per cubic meter (4.4 × 10-6 kilograms per cubic meter). 

The results of the analysis are as follows: 

 In Atmospheric Stability Class D conditions with a windspeed of 4.5 meters per second: 

 The thresholds for SL-IV (AEGL-3) and SL-III (AEGL-2) are not predicted to be exceeded 

anywhere. 

 Concentrations in the SL-II range (0.1 × AEGL-2 to AEGL-2) could extend out to about 

34 kilometers (21 miles). 

 In Atmospheric Stability Class D conditions with a windspeed of 4.5 meters per second: 

 SL-II concentrations exceeding 0.1 × AEGL-2 could extend from less than 100 meters 

(330 feet) out to about 40 kilometers (25 miles). 

 SL-III concentrations exceeding AEGL-2 could extend from about 100 meters (330 feet) out 

to about 5.6 kilometers (3.5 miles). 

 Concentrations greater than the SL-IV threshold (AEGL-3) could be exceeded in a “hot spot” 

extending from about 560 to 760 meters (1,800 to 2,500 feet) downwind 

It is therefore clear that, should there be an IDA involving a railcar or truck with fire, there would 

potentially be a need to monitor bodies of water for accumulation of methylmercury in fish to a 

considerable distance downwind. 

Because frequencies are not assigned to IDA scenarios, it is not possible to match the concentrations 

described above with corresponding estimates of risk. 

Human Exposure – Deposition Pathway 

The calculations predict that the threshold for SL-II (180 milligrams per kilogram) would not be exceeded 

anywhere. 
Environmental Consequences 

4–21

4.2.9.2 Normal Operations Risks – No Action Alternative 

The generic discussion of normal operations is provided in Section 4.2.9.1.3. For storage of elemental 

mercury in non-DOE storage facilities under the No Action Alternative, it seems reasonable to assume 

that normal operations would be carried out to standards sufficient to protect involved workers, 

noninvolved workers, and members of the public so that their associated risks are negligible. For 

continued storage at Y–12, the generic analysis applies and the risk there from normal operations is also 

predicted to be negligible. 

4.2.9.3 Facility Accident Risks – No Action Alternative 

Many of the potential accident scenarios associated with the storage and movement of elemental mercury 

under the No Action Alternative would be the same as for transportation to and storage at one of the 

candidate mercury storage facilities. Thus, it is likely that mercury would be placed in 3-L flasks or 

1-MT containers. Therefore, accidents involving the dropping of these or the dropping of pallets would 

be possible, both indoors and outdoors. Buildings would be vulnerable to external events, such as 

earthquakes, high winds, and aircraft crashes. It is not known whether all new storage buildings or 

buildings in which mercury is currently stored or handled are designed to the same standards as required 

for the candidate storage facilities (for example, in their ability to resist earthquakes or high winds). The 

consequences of accidents involving severe damage to a building would depend on how much mercury is 

actually present in the building and on where it is located relative to nearby populations; for example, it is 

conceivable that the distance to the fence line could be short and that there could be houses backing up to 

that fence line, in which case the risks could be higher than those predicted for the candidate storage 

buildings in Section 4.2.9.1.4. 

For continued storage at Y–12, the analysis of onsite spills is exactly the same as for the generic analysis 

and leads to the same conclusions: 

 For the involved and noninvolved workers, frequencies would be in the low (FL-II) or 

moderate (FL-III) range. 

 Consequences would be in the SL-I to SL-II range. 

 Risks would be in the negligible-to-low range. 

 For the public, risks would be negligible. 

4.2.9.4 Transportation Risks – No Action Alternative 

Under the No Action Alternative, elemental mercury would be transported between various facilities. It 

seems likely that the total amount transported would be about the same as that used for analysis purposes 

in this EIS, although the amount transported could be less if some storage occurs at source locations. 

What is not known is how much would be transported as full truck or railcar loads and how much as 

partial loads (e.g., one pallet or one 1-MT container on a truck, or fewer flasks than a full pallet), or the 

distances that mercury might be transported. It would appear that the various transportation spills with 

fires that were analyzed for the candidate storage facilities would also be possible under the No Action 

Alternative, with concomitant, but currently unquantifiable, risks to human health (see Section 4.2.9.1.5). 

However, since the generic predicted consequences of crashes with fires were performed for full trucks or 

railcars, the results presented in Table 4–5 should bound the magnitude of the consequences. 

For transportation under the No Action Alternative, the types of spills directly onto the ground or into 

bodies of water seem to be similar to those discussed in Section 4.2.9.1.5, so those types of risks would 

also exist for transportation to new and existing non-DOE mercury storage facilities. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–22

Since there would be no transportation to or from Y–12 under the No Action Alternative, there would be 

no transportation risks for that site. 

4.2.9.5 Intentional Destructive Acts – No Action Alternative 

The generic discussion of IDA fires is in Section 4.2.9.1.6. The same types of IDA scenarios would 

appear to be possible for transportation of elemental mercury under the No Action Alternative. 

Therefore, the analysis of IDA consequences in Section 4.2.9.1.6 should bound those for commercial 

transport. 

At Y–12, the mercury storage warehouse is located within a high-security area that is protected by the 

Perimeter Intrusion Detection and Assessment System, which includes a range of physical and personnel 

security provisions designed to protect nuclear materials at DOE sites. This would appear to make IDAs 

directly on the storage facility highly unlikely. In addition, under the No Action Alternative, there would 

be no transportation of mercury to or from Y–12; thus, no transportation IDAs could occur. 

4.2.10 Ecological Risk 

This section contains a generic discussion of ecological risks, followed by one specific to the No Action 

Alternative. 

4.2.10.1 Ecological Risk – Generic Discussion 

The ecological risk assessment considers chronic exposures to the following potentially sensitive 

ecological receptors: 

 Plants 

 Soil invertebrates 

 The short-tailed shrew 

 The American robin 

 The red-tailed hawk 

 The great blue heron 

 The river otter 

 Aquatic biota 

 Sediment-dwelling (i.e., benthic) biota 

Appendix D, Section D.5, contains a discussion of why these representative receptors were chosen. 

Ecological exposures from elemental mercury deposited onto surface soil, sediment, and surface water are 

expected to pose the greatest risk to ecological receptors. The ecological health consequence levels for 

these receptors are expressed in terms of environmental-medium- and receptor-specific ecological 

benchmark values or equivalent screening values that are the upper concentration limits for mercury in 

soil, sediment, and/or surface water. The screening values are expressed in milligrams per kilogram or 

micrograms per liter depending on whether they are for mercury in soil/sediment or mercury in water, 

respectively. Section D.5 describes how these values are calculated. 

Table 4–7 provides the screening values for the receptors listed above. The output of the atmospheric 

dispersion model provides airborne concentrations in kilograms per cubic meter and amounts of deposited 

mercury in kilograms per square meter. For ease of comparison with these outputs, the ecological 

screening values can be converted into equivalent levels of deposited mercury (independent of the 

mercury release scenario). Note that, for each receptor, there are two screening values: one for ingestion 

of whatever portion of the deposited mercury is converted into methylmercury in the soil, sediment, or 

water and one for the portion that remains in the inorganic form. 
Environmental Consequences 

4–23

Table 4–7. Screening Values and Equivalent Deposited Screening Values 

Ecological Receptor, Pathway 

Inorganic or 

Methylmercury 

Screening Value 

(mg/kg or μg/L) 

Equivalent Deposited Screening 

Value (kg/m2

) 

Plants Inorganic 3.00×10-1 2.76×10-5

Soil invertebrates Inorganic 1.00×10-1 9.18×10-6

Short-tailed shrew Inorganic 1.10×102 1.01×10-2

River otter, sediment Inorganic 2.00×100 2.23×10-1

River otter, water Inorganic 1.62×103 2.67×10-1

American robin Inorganic 7.36×102 1.84×10-4

Red-tailed hawk Inorganic 1.40×100 1.49×10-1

Great blue heron, sediment Inorganic 5.26×103 3.12×10-2

Great blue heron, water Inorganic 1.03×101 3.61×10-2

Aquatic biota Inorganic 1.30×100 3.36×10-2

Sediment-dwelling biota Inorganic 1.50×10-1 6.35×10-6

Plants Methyl None None 

Soil invertebrates Methyl 2.50×100 1.13×10-2

Short-tailed shrew Methyl 8.00×10-2 3.60×10-4

River otter, sediment Methyl 1.00×10-2 1.31×10-4

River otter, water Methyl 6.86×100 7.78×10-4

American robin Methyl 2.09×100 4.50×10-5

Red-tailed hawk Methyl 3.20×10-2 3.09×10-2

Great blue heron, sediment Methyl 5.40×10-1 5.02×10-4

Great blue heron, water Methyl 8.00×10-3 3.11×10-3

Aquatic biota Methyl 2.80×10-3 2.72×10-4

Sediment-dwelling biota Methyl None None 

Key: mg/kg=milligrams per kilogram; μg/L=micrograms per liter; kg/m2=kilograms per square meter. 

In a similar manner to the human health evaluation, the SL to which a particular ecological consequence 

estimate is assigned is obtained by dividing the predicted exposure concentration of mercury by the 

appropriate screening value for ecological effects. If the ratio is 20 or higher, SL-IV is assigned; between 

10 and 20, SL-III; between 1 and 10, SL-II; and below 1, SL-I (which is predicted to be negligible). 

4.2.10.1.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike divalent mercury. As a 

result, risks to ecological receptors from slow leaks, accidental spills at storage sites, and spills without 

fires during transportation (other than those directly into a water body) are considered to be negligible at 

all storage sites and along all transportation routes. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–24

4.2.10.1.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 

which also makes the following conclusions regarding the consequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that, except for a direct spillage of elemental mercury into a body of water, the 

consequences to ecological receptors would be negligible. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk to ecological receptors would be 

negligible or low for all transportation routes. However, because of the above-mentioned uncertainty 

about fast-flowing rivers, this observation should be tempered by noting that the uncertainty in the above 

statement regarding this prediction is large. 

4.2.10.1.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. The analysis uses the same computer runs as were used for the analysis of human 

receptors. Analyses have been carried out for the following three weather conditions (the same as for the 

human health risk assessment): 

 Atmospheric Stability Class A with a windspeed of 1.5 meters per second 

 Atmospheric Stability Class D with a windspeed of 4.5 meters per second 

 Atmospheric Stability Class F with a windspeed of 1.5 meters per second 

Table 4–8 shows the results of the consequence calculations in the three stability classes for the specific 

case of a truck crash with a wooden pallet fire and dry deposition. The results in this table apply to all 

transportation routes to all sites. The results for a railcar crash with a wooden pallet fire are similar and 

may be found in Appendix D, Section D.5.4.3.2. 
Environmental Consequences 

4–25

Table 4–8. Summary of Potential Exposure of Receptors to Deposited Mercury at 

Severity Levels II, III, and IV – Truck Spill with Wooden Pallet Fire and No Rain 

Distance (meters) to Which 

Benchmark is Exceeded 

(Aa, 1.5 m/sb) 

Distance (meters) to Which 

Benchmark is Exceeded 

(Da, 4.5 m/sb) 

Distance (meters) to Which 

Benchmark is Exceeded 

Ecological (Fa, 1.5 m/sb) 

Receptor SL-II SL-III SL-IV SL-II SL-III SL-IV SL-II SL-III SL-IV 

Sedimentdwelling 

biota 

2,000 to 

3,000 

700 to 

1,000 

500 to 

700 

10,000 to 

20,000 

1,000 to 

2,000 

Soil 

invertebrates 

2,000 to 

3,000 

500 to 

700 

300 to 

500 

10,000 to 

20,000 

Plants 1,000 to 

2,000 

5,000 to 

7,000 

American 

robin 

1,000 to 

2,000 

2,000 to 

3,000 

River otter 500 to 

700 

Aquatic 

biota 

Short-tailed 

shrew 

Great blue 

heron 

Red-tailed 

hawk 

a Atmospheric Stability Class. 

b Windspeed measured at 10 meters. 

Note: Shaded cells denote no exceedance of the appropriate benchmark. The ranges in this table indicate that there is uncertainty in the predicted 

distance to which the various benchmarks are exceeded. The distances downwind at which the various concentrations are first encountered can 

conservatively be set to 0. To convert meters to feet, multiply by 3.281. 

Key: m/s=meters per second; SL=severity level. 

Table 4–8 shows characteristic behavior for elevated releases. In Atmospheric Stability Class A 

conditions, the associated high degree of atmospheric turbulence brings mercury down to ground level 

quickly, but also dilutes the plume quickly. More receptors are affected than in the other two stability 

classes, but not for great distances. The results for Stability Class F are strongly affected by the fact that 

the dry deposition velocity is an order of magnitude lower than it is in the other two weather conditions 

(see Appendix D, Table D–56). If the dry deposition velocity had been of the same order, many more 

receptors would have been affected. This leaves Stability Class D as the intermediate case in which the 

plume does not dilute as quickly as in Stability Class A, but also does not bring mercury down to ground 

level as quickly near the source. 

Table 4–8 shows that, for a truck crash with a wooden pallet fire in dry weather, sediment-dwelling biota 

and soil invertebrates could be exposed to deposited levels of mercury in the SL-IV range, but over 

distances of no more than 700 meters (2,300 feet), and then only in Atmospheric Stability Class A 

conditions. Similarly, it is only in Class A conditions that sediment-dwelling biota and soil invertebrates 

could be exposed to SL-III levels of deposited mercury out to about 1,000 meters (3,300 feet). In 

Class A, D, and F conditions, some ecological receptors (not the same number in each class) are predicted 

to be exposed to deposited levels of mercury in the SL-II range or lower. 

The consequences above can be combined with the predicted frequencies of crashes with fires from 

Appendix D, Tables D–12 and D–13, to provide risks. Appendix D, Tables D–12 and D–13, show that 

the predicted frequencies of spills with fires are in the FL-III range under both truck scenarios 

(see Section 4.2.9.1.5) at all of the candidate storage sites. Conservatively, these frequencies are 

associated with the highest SL predicted in any weather condition in Table 4–8, a conservative 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–26

assumption.13 Table 4–9 summarizes the FL, consequence level, and risk under both truck scenarios with 

fires in dry weather and applies to all candidate storage sites. 

Table 4–9. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, All Sitesa

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Levelc Riskd

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a Applies equally to all seven candidate sites. 

b Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

c The highest consequence in any weather condition from Table 4–8. 

d Applies to both Truck Scenarios 1 and 2.

The following observations apply to the results represented in Table 4–9: 

 As noted above, if a particular outcome occurs even in only one of the three representative 

weather conditions listed above, it is conservatively assumed to occur always (e.g., sedimentdwelling biota would only be exposed to potentially high concentrations in Atmospheric 

Stability Class A conditions) . This introduces conservatism into the frequency portion of the 

risk equation. 

 The truck results apply to both Scenarios 1 and 2. 

 For all receiving sites, there is a high risk that, in the event of a truck crash with fire and no rain 

somewhere along the truck routes, areas contain deposited mercury in the SL-IV range for 

sediment-dwelling biota and soil invertebrates living in such areas. Per Figure 4–1, these 

indicate situations of major concern. 

 Though not shown explicitly in Table 4–9, there is also a moderate risk that, somewhere along 

the truck routes, sediment-dwelling biota and soil invertebrates could be exposed to SL-III 

levels of deposited mercury in areas in addition to those in the previous bullet. 

 For all receiving sites, there is a low risk that, somewhere along the truck routes, areas contain 

deposited levels of mercury in the SL-II range for nearby plants, American robins, and river 

otters. Per Figure 4–1, these indicate situations of minimal concern. Furthermore, though not 

shown explicitly in Table 4–9, there could be a low risk that areas along truck routes (in 

addition to the areas in the previous two bullets) contain deposited mercury in the SL-II range 

for sediment-dwelling biota and soil invertebrates. 

 

13 In principle, one could calculate the probability, conditional on the occurrence of the crash with fire, that an SL-IV 

consequence for (say) sediment-dwelling biota could occur. This probability is less than unity because it does not occur in all 

weather conditions. It might be small enough that, when multiplied by the FL-III frequencies mentioned above, it would drop 

those frequencies into the a lower frequency range. However, this calculation is not possible because the calculations reported 

in Table 4–8 were only done for the three representative weather conditions, not all weather conditions. Nevertheless, omitting 

this step in the calculation of frequency does add considerable conservatism. 
Environmental Consequences 

4–27

 For truck routes to all receiving sites, the risks to the short-tailed shrew, aquatic biota, the great 

blue heron, and the red-tailed hawk are negligible. 

It is important to understand the meaning of the risks presented in Table 4–9. A high risk to sedimentdwelling biota with an SL-IV consequence, for example, means that somewhere along the route areas 

would be contaminated to such an extent that a population of sediment-dwelling biota living entirely 

within one such area would accumulate enough mercury through normal ingestion activities to cause a 

high health consequence. Appendix D, Table D–43, does not provide the risk to a specific population of 

such receptors within a given small area. In any event, for sediment-dwelling biota, such an identification 

is not possible. If it were possible, the risk to such a specifically identified receptor would be smaller than 

that indicated in Table 4–9. 

The risks of other potential fire scenarios are similarly calculated and are summarized as follows: 

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–10. 

 For railcar crashes with wooden pallet fires and without rain (dry deposition), see Table 4–11. 

 The predicted frequency of railcar crashes with wooden pallet fires and rain is negligible, so 

risks are negligible and no summary table is presented. 

As can be seen, the scenarios that involve metal pallets have reduced predicted ecological risk. 

Table 4–10. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, All Sitesa

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Level Riskc

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a Applies equally to all seven candidate sites. 

b Frequencies of truck crashes with fires and rain from Appendix D, Table D–16. 

c Applies to both Truck Scenarios 1 and 2.

Table 4–11. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, All Sitesa

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Level Risk 

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a Applies equally to all seven candidate sites. 

b Frequencies of railcar crashes with spills from Appendix D, Table D–14. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–28

4.2.10.1.4 Intentionally Initiated Spills During Transportation with Fires 

Table 4–12 summarizes the predicted distances to which ecological receptors would receive various 

levels of exposure following an intentionally initiated fire caused by crashing a fully loaded gasoline 

tanker into a train. Table 4–12 is also bounding for deliberately initiated truck fires. The results are 

similar to those in Table 4–8 except that predicted distances are greater. Table 4–12 can be regarded as 

an upper bound assessment of consequences for any kind of transportation fire, deliberately initiated or 

otherwise. The results cannot be put into the perspective of risk because it is not possible to estimate the 

frequency of an IDA. 

4.2.10.2 Ecological Risk – No Action Alternative 

Transportation of mercury by road and rail would continue under the No Action Alternative. What is not 

known is the average, maximum, and minimum loads per truck or railcar. However, accidental or 

deliberately initiated truck fires or railcar fires could occur, and the generic analysis provides a picture of 

what kinds of scenarios and risks there might be. 

The frequency of onsite fires sufficient to cause a release of mercury at Y–12 is predicted to be negligible, 

just as it is for all of the candidate sites. In addition, there would be no transportation to or from Y–12 

under the No Action Alternative. Therefore, the risks to ecological receptors under the No Action 

Alternative at Y–12 would be negligible. In addition, there could be no deliberately initiated 

transportation IDA for Y–12. 

4.2.11 Socioeconomics 

As indicated in Section 4.2, some non-DOE storage sites may require new construction or need to modify 

their storage capacity by constructing additional storage space. As discussed in Section 4.2, any analysis 

of impacts on socioeconomics at non-DOE storage sites would be highly speculative at this time. Under 

the No Action Alternative, elemental mercury would remain in storage at Y–12. Labor resources 

associated with mercury storage at Y–12 would remain at less than 0.05 full-time equivalent workers 

(DLA 2004a:4-26). Therefore, no incremental socioeconomic or related transportation impacts would 

occur at Y–12. 

4.2.12 Environmental Justice 

The population of one of the block groups within the 16-kilometer (10-mile) radius surrounding Y–12 

was identified as a minority community, the population of another, as a low-income community 

(see Chapter 3, Section 3.9.11). As discussed in Sections 4.2.9 and 4.2.10, implementing the No Action 

Alternative would result in negligible offsite human health and ecological risks from mercury emissions 

during normal operations and accidents. Therefore, no disproportionately high and adverse effects on 

minority or low-income populations would occur at Y–12 under the No Action Alternative. 

 
Table 4–12. Summary of Potential Exposure of Ecological Receptors to Low, Moderate, or High Levels of Expo

Initiated Railcar Spill with Fire 

4–29

Dry Deposition Wet Deposition 

Distance (meters) to Which 

Benchmark is Exceeded 

(Da, 4.5 m/sb) 

Distance (meters) to Which 

Benchmark is Exceeded 

(Fa, 1.5 m/sb) 

Distance (meters) to Which 

Benchmark is Exceeded 

(Da, 4.5 m/sb) 

D

Ecological 

Receptor SL-II SL-III SL-IV SL-II SL-III SL-IV SL-II SL-III SL-IV SL

Sedimentdwelling biota >40,000 

10,000 to 

20,000 

5,000 to 

7,000 >40,000 

2,000 to 

3,000 

700 to 

1,000 >40,000 >40,000 

20,000 to 

30,000 >40

Soil invertebrates >40,000 

10,000 to 

20,000 

2,000 to 

3,000 

30,000 to 

40,000 

1,000 to 

2,000 >40,000 

30,000 to 

40,000 

20,000 to 

30,000 >40

Plants 

>40,000 

5,000 to 

7,000 >40,000 

10,000 to 

20,000 

7,000 to 

10,000 

30,00

40,

American robin 

20,000 to 

30,000 

3,000 to 

5,000 >40,000 

7,000 to 

10,000c

5,000 to

7,000 

30,00

40,

River otter 2,000 to 

3,000 

700 to 

1,000 

20,000 to 

30,000 

3,000 to 

5,000 

2,000 to 

3,000 

20,00

30,

Aquatic biota 

10,000 to 

20,000 

2,000 to 

3,000 500 to 700 

10,00

20,

Short-tailed shrew 

10,000 to 

20,000 

1,000 to 

2,000 

10,00

20,

Great blue heron 

7,000 to 

10,000 

700 to 

1,000 

10,00

20,

Red-tailed hawk 

a Atmospheric Stability Class. 

b Windspeed measured at 10 meters (33 feet). Note: Shaded cells denote no exceedance of the appropriate benchmark. The ranges in this table indicate that there is uncertainty in the predicted distance to which the vario

distances downwind at which the various concentrations are first encountered can conservatively be set to 0. To convert meters to feet, multiply by 3.281. 

Key: >=greater than; m/s=meters per second; SL=severity level. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–30

4.3 LONG-TERM MERCURY MANAGEMENT AND STORAGE AT GRAND 

JUNCTION DISPOSAL SITE 

Under this alternative, a new mercury storage facility would be constructed at DOE’s GJDS. GJDS 

occupies 146 hectares (360 acres) located 29 kilometers (18 miles) southeast of Grand Junction, Colorado, 

as further described in Chapter 2, Section 2.4.2. 

4.3.1 Land Use and Visual Resources 

Minor impacts on land use and visual resources are expected from construction and operation of a new 

mercury storage building at GJDS. Construction of this new facility would result in the disturbance of 

approximately 3.1 hectares (7.5 acres) for building construction and laydown areas (see Chapter 2, 

Section 2.3.1). The proposed mercury storage facility would be located in the northwestern corner of the 

present GJDS complex, adjacent to the existing disposal area. Approximately half of the proposed site 

area was disturbed from past activities. The completed elemental mercury storage facility boundary would 

similarly encompass approximately 3.1 hectares (7.5 acres) within its fenced perimeter, which corresponds 

to approximately 2 percent of the site. The footprint of the mercury storage building would occupy 

approximately 1.6 hectares (3.9 acres) of this area. The low profile of the new building would only 

marginally affect the overall viewshed of the surroundings area. Therefore, mercury storage operations 

would not result in a change to U.S. Bureau of Land Management (BLM) visual resource management 

(VRM) classifications. 

Mesa County land use regulations require that a warehouse or storage facility be located in an industrial or 

commercial zoning district. The current land use of GJDS is Agricultural Forestry Transitional. An 

amendment to the land use code would be required for a warehousing use to occur in this zoning district. 

As discussed in Chapter 1, Sections 1.6 and 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. 

4.3.2 Geology, Soils, and Geologic Hazards 

4.3.2.1 Geology and Soils 

Construction of a new mercury storage facility under this alternative is expected to temporarily disturb no 

more than about 3.1 hectares (7.5 acres) of land at GJDS; most of this land has been previously disturbed 

in association with site clearing and construction in support of the existing disposal facility. The depth of 

excavation required would be less than about 0.6 meters (2 feet), as the new facility would be constructed 

on a reinforced-concrete slab and atop a gravel base. Additional trenching may be necessary to install 

foundation footings or to connect the new mercury storage facility with existing utilities; trenches could be 

about 0.6 meters (2 feet) wide by 1.2 meters (4 feet) deep. Mineral and other geologic resources would be 

required to support the construction effort, including approximately 4,760 cubic meters (6,200 cubic 

yards) of concrete and 3,900 cubic meters (5,100 cubic yards) of gravel (see Appendix C, Table C–2). 

These resources would be procured from local and/or regional commercial vendors; construction 

aggregate is relatively abundant in the GJDS region. 

Although soils cleared for construction would briefly be subject to wind and water erosion, adherence to 

standard best management practices for soil erosion and sediment control (e.g., use of sediment fencing, 

staked hay bales, mulching and geotextile matting, and rapid reseeding) during facility construction would 

serve to minimize soil erosion and loss. 
Environmental Consequences 

4–31

At GJDS, specific construction limitations include stoniness of the soils down to weathered shale, which 

presents site development limitations due to the potential presence of cobble- and boulder-size rocks in the 

relatively thick colluvial, terrace, and alluvial deposits across the site (see Chapter 3, Section 3.2.2.2). 

However, due to the limited extent of and relatively limited depth of excavation, the stoniness of site soils 

should not present substantial constraints for construction. Loss of erodible soils such as loess, which 

occurs at the site, particularly on steep slopes, would also present a development constraint. A site survey 

and geotechnical study would be conducted to confirm site geologic characteristics for facility engineering 

purposes, and location of the building footprint and adherence to the aforementioned best management 

practices would serve to minimize construction impacts on nearby slopes. 

During operations, previously disturbed areas would not be subject to long-term soil erosion, as the areas 

within the footprint of the completed mercury storage facility would have been revegetated or would 

return to natural conditions. There would be no additional impact on geology and soils from operations. 

4.3.2.2 Geologic Hazards 

Hazards from large-scale geologic conditions, such as earthquakes, and other site geologic conditions with 

the potential to affect GJDS are summarized in Chapter 3, Section 3.2.2.3. Site geologic conditions would 

be unlikely to affect the mercury storage facility over the 40-year period of analysis. 

Colorado is considered to have minor earthquake activity overall, with low-to-moderate seismicity in the 

Grand Junction region. Earthquakes have historically produced ground motion effects equivalent to 

MMI V in the vicinity of the site (see Appendix B, Table B–4). Although the site is located within several 

kilometers of potentially active faults, the predicted peak ground acceleration at the site from an 

earthquake with an annual probability of occurrence of 1 in 2,500 is 0.14 g. Ground motion in this range 

could cause slight damage to ordinary structures, but is not expected to affect modern structures designed 

and constructed to withstand the assessed hazard. DOE applies the seismic engineering provisions from 

the latest building codes as the minimum standard for the design, construction, and upgrade of its 

facilities. As further described in Appendix B, Section B.3.2, DOE Order 420.1B and its companion guide 

(DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so that the public, 

workers, and environment are protected from adverse impacts of natural phenomena hazards, including 

earthquakes. Thus, the mercury storage facility would be sited and designed to address the risk from 

geologic hazards, and the predicted ground motion would be unlikely to cause a breach in mercury 

containers from structural failure. An analysis of potential environmental consequences resulting from an 

earthquake-induced accident is described in Section 4.3.9.2. 

4.3.3 Water Resources 

4.3.3.1 Surface Water 

There would be no direct impact from construction on natural surface-water drainages in the vicinity of 

GJDS. The closest surface-water feature to the proposed construction location is an ephemeral wash 

located approximately 240 meters (800 feet) north of the existing disposal site boundary; this would not be 

impacted by facility construction. The closest major streams to the site are Kannah Creek and the 

Gunnison River, which lie about 3.8 and 6.4 kilometers (2.4 and 4 miles), respectively, at their closest 

point from GJDS. Intervening ephemeral drainages comprise the surface-water flow path to these major 

streams. In addition, Cheney Reservoir is located approximately 0.6 kilometers (1 mile) southeast of 

GJDS at its closet point, but it is not along the surface-water flow path from GJDS (see Chapter 3, 

Section 3.2.3.1). 

During construction, stormwater runoff from construction areas could potentially impact downstream 

surface-water quality. Appropriate soil erosion and sediment control measures, as described in 

Section 4.3.2.1, and spill prevention practices would be employed to minimize suspended sediment and 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–32

deleterious material transport (such as from spills and leaks from construction equipment) and potential 

water quality impacts. An NPDES General Permit Notice of Intent would be filed to address stormwater 

discharges associated with construction activity (see Chapter 5, Section 5.3). Also, development and 

implementation of a stormwater pollution prevention plan would be required for the construction activity. 

It is conservatively estimated that construction activities would require approximately 1,270,000 liters 

(336,000 gallons) of water over the 6-month construction period. This volume would primarily be 

required for dust control and soil compaction. It is anticipated that water would be trucked to the site from 

approved offsite sources. There would be no diversion of nearby surface water or onsite groundwater. 

During operations, water use would generally be limited to that required to serve the potable and sanitary 

needs of the storage facility workforce. Total annual consumption is estimated to be about 88,500 liters 

(23,375 gallons). At GJDS, a water storage tank would be sufficient to supply this volume, as further 

discussed in Section 4.3.7.2. 

Design, construction, and operation of the mercury storage facility would feature structural controls and 

practices to prevent the release of elemental mercury and to prevent any spills or other releases, should 

they occur as a result of abnormal operating conditions, from reaching soils or surfaces where they could 

be conveyed to surface waters or groundwater. Structural elements include containment and other 

engineering features, including the use of spill trays, sloped floors, and floors constructed to be impervious 

to liquid mercury releases, as further described in Appendix C, Section C.2.1. In addition, facility 

operations would be conducted in accordance with an integrated contingency plan (ICP) and spill 

prevention, control, and countermeasures (SPCC) plan, or equivalent plans as mandated by state 

requirements for RCRA-permitted facilities (40 CFR 264.40 et seq.), which set forth the actions facility 

personnel would take to respond to fires, explosions, or any accidental release of mercury to air, soil, or 

surface water at the facility. 

The site is not located within or adjacent to a 100-year floodplain and is not subject to riverine flooding. 

The site is subject to sheet flow from higher elevations, as discussed in Chapter 3, Section 3.2.3.1. DOE 

Order 420.1B and its companion guide (DOE Guide 420.1-2) require that DOE facilities be designed, 

constructed, and operated to protect the public, workers, and environment from natural phenomena 

hazards, including flooding, and specifically to adhere to the flood design and evaluation criteria specified 

in DOE Standards 1020-2002 and 1023-95. The potential for sheet flooding and other precipitation effects 

(e.g., scour and erosion) would be accounted for in the design of foundations, walls, roof structures, and 

drainage and stormwater management systems for the storage facility. As a result, the operation of the 

new mercury storage facility would also incorporate appropriate stormwater management controls to 

safely collect and convey stormwater from the facility while minimizing washout, soil erosion, and offsite 

water quality impacts. 

There would be discharge of effluents to either surface water or groundwater from storage facility 

operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) would be 

generated and managed via the existing wastewater collection tanks (see Section 4.3.8). As the facility 

would be designed and operated to prevent any spills from reaching the ground, there would be no impact 

on groundwater from routine operations. 

4.3.3.2 Groundwater 

Excavation activities are not expected to impact shallow groundwater that can occur in paleochannels at 

the site. The site survey and geotechnical study that would be performed would be used to confirm the 

presence of and avoid any such features prior to construction (see Section 4.3.2.1). As the facility would 

be designed and operated to prevent any spills from reaching the ground, there would be no impact on 

groundwater from routine operations. 
Environmental Consequences 

4–33

4.3.4 Meteorology, Air Quality, and Noise 

4.3.4.1 Meteorology 

Meteorological events can result in damage to buildings such as mercury storage warehouses. The 

frequency and consequences of such events were considered in selecting the accident events evaluated in 

Section 4.3.9.2. DOE Order 420.1B and its companion guide (DOE Guide 420.1-2) require that facilities 

be designed, constructed, and operated so that the public, workers, and environment are protected from 

adverse impacts of natural phenomena hazards, including meteorological events. This includes hurricanes 

and tornadoes, high winds, excessive snow or ice, etc. DOE Standards 1020-2002 and 1023-95 implement 

DOE Order 420.1B and provide site assessment criteria and stipulate that DOE facilities, at a minimum, 

must be designed and constructed to the latest model buildings codes, applicable local building codes, or 

industry standards. The Order also stipulates natural phenomena hazards mitigation for DOE facilities. 

RCRA-permitted facilities, such as the proposed mercury storage facility, must also meet applicable 

design, construction, and operation requirements under Title 40 of the CFR, Section 264.31, and 

applicable state RCRA requirements to prevent the release of stored wastes. As the Grand Junction region 

is susceptible to regular occurrence of high winds, the new mercury storage facility would be designed and 

constructed to withstand and mitigate the potential for high winds and other meteorological events, such as 

heavy snow. 

4.3.4.2 Air Quality 

Minor short-term air quality impacts would result from construction of a mercury storage facility at GJDS. 

These impacts would include an increase in criteria and toxic air pollutant concentrations from 

construction equipment emissions (see Appendix C, Section C.2.3). These emissions would occur over a 

6-month construction period and are not expected to result in exceedance of the ambient air quality 

standards. 

Minor short-term air quality impacts would result from an increase in truck or rail activity while mercury 

is moved to GJDS from storage. Truck and rail transport are discussed in more detail in Section 4.3.9.3. 

Estimated emissions from truck and rail transportation are presented in Tables 4–15 and 4–16. Over the 

40-year period of analysis, the estimated number of truck or rail shipments would diminish over time and 

resulting emissions would decrease. 

Operation of the mercury storage facility at GJDS is expected to have negligible emissions, consisting of 

emissions from employee vehicles, trucks, semiannual testing of emergency generators, and possibly 

mercury vapor from any spills or from mercury containers. No localized emissions from space heating are 

anticipated associated with mercury storage facility operations, as electric heating is anticipated for areas 

requiring climate control. Compliance with the conformity regulations is discussed in Appendix B, 

Section B.5.1.2. 

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

elemental mercury vapor escaping from storage containers or residual contamination. Mercury vapor 

transported downwind could then be inhaled by noninvolved workers (those outside the storage facility) or 

nearby offsite individuals. Appendix D, Section D.4.1, presents a conservative analysis that shows that for 

a long-term, undetected slow leak inside the proposed mercury storage facility, the predicted long-term 

average concentration in the building wake never exceeds 80 nanograms per cubic meter. The EPA 

threshold for chronic exposure to airborne mercury is 300 nanograms per cubic meter, so slow releases of 

mercury would have a negligible effect on noninvolved workers and the public, with a corresponding 

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

4–34

Table 4–13. Air Pollutant Emissions from Transportation of Elemental Mercury by 

Truck to Candidate Storage Sites 

Pollutant Truck Emissions by Pollutant (metric tons) 

Site 

Carbon 

Monoxide 

Nitrogen 

Dioxide 

Volatile 

Organic 

Compounds PM2.5 PM10

Sulfur 

Dioxide 

Carbon 

Dioxide 

Grand Junction 

Disposal Site 

3.81 14.2 0.760 0.305 0.382 0.0237 2,540 

Hanford Site 5.17 19.2 1.03 0.413 0.518 0.0321 3,440 

Hawthorne Army 

Depot 

4.75 17.7 0.948 0.380 0.477 0.0295 3,160 

Idaho National 

Laboratory 

4.05 15.1 0.807 0.323 0.406 0.0251 2,690 

Kansas City Plant 3.39 12.6 0.676 0.271 0.340 0.0211 2,250 

Savannah River 

Site 

4.11 15.3 0.820 0.329 0.413 0.0256 2,740 

Waste Control 

Specialists, LLC 

4.42 16.5 0.881 0.353 0.443 0.0275 2,940 

Note: Emissions are based on truck mileage (see Section 4.3.9.3) and emission factors calculated using the 

U.S. Environmental Protection Agency’s mobile source emission factor model, Mobile6 (EPA 2003); to convert metric tons 

to tons, multiply by 1.1023. 

Key: PMn=particulate matter with an aerodynamic diameter less than or equal to n micrometers. 

Table 4–14. Air Pollutant Emissions from Transportation of Elemental Mercury by 

Rail to Candidate Storage Sites 

Pollutant Locomotive Emissions by Pollutant (metric tons) 

Site 

Carbon 

Monoxide 

Nitrogen 

Dioxide 

Volatile 

Organic 

Compounds PM2.5 PM10

Sulfur 

Dioxide 

Carbon 

Dioxide 

Grand Junction 

Disposal Sitea

1.63 9.48 0.527 0.273 0.283 0.184 645 

Hanford Site 2.24 13.2 0.734 0.383 0.395 0.263 857 

Hawthorne Army 

Depot 

1.95 11.5 0.639 0.333 0.344 0.229 747 

Idaho National 

Laboratory 

1.84 10.8 0.604 0.315 0.325 0.216 705 

Kansas City Plant 1.24 7.30 0.406 0.212 0.218 0.145 475 

Savannah River 

Site 

1.50 8.85 0.493 0.257 0.265 0.176 575 

Waste Control 

Specialists, LLC 

1.94 11.5 0.638 0.333 0.343 0.228 745 

a The Grand Junction Disposal Site has no rail access, thus mercury would need to be transported from the nearest railhead 

in the city of Grand Junction. The additional emissions from transportation by truck are included. 

Note: Emissions are based on locomotive fuel usage (see Section 4.3.9.3) and the U.S. Environmental Protection Agency 

emission factors for locomotives (EPA 2009b); to convert metric tons to tons, multiply by 1.1023. 

Key: PMn=particulate matter with an aerodynamic diameter less than or equal to n micrometers. 

Annual carbon dioxide emissions would be highest during the year 2013, at approximately 257 metric tons 

(284 tons) per year, as a result of moving elemental mercury to the site by truck; these annual truck 

emissions would be greater than rail emissions from shipping mercury. The emissions would minimally 

add to global annual emissions of carbon dioxide, which were estimated to be 26.4 billion metric tons 

(29.1 billion tons) per year from 2000 through 2005 from fossil fuel use worldwide (IPCC 2007:3), and 

U.S. carbon dioxide emissions, which were 5.98 billion metric tons (6.59 billion tons) in 2006 

(EPA 2008:ES-5). Global climate change is further discussed in Section 4.11.4.2. 
Environmental Consequences 

4–35

4.3.4.3 Noise 

Short-term noise impacts at GJDS could result from construction of a mercury storage facility. These 

impacts would include an increase in traffic to the site and an increase in noise resulting from construction 

equipment. These impacts would occur during the 6-month construction period. Since the nearest noisesensitive receptor, a residence, is located 3 kilometers (2 miles) from the site, the increase in noise levels 

at this location from construction equipment is expected to be negligible. The estimated average noise 

level during the daytime (8-hour equivalent sound level) from four items of construction equipment 

operating at this distance is estimated to be 24 decibels A-weighted (dBA), which would likely be below 

the background sound level. The increase in traffic noise levels along U.S. Route 50 from construction 

activity is expected to be less than 1 dBA since the increase in traffic resulting from construction would be 

much less than the existing traffic on U.S. Route 50. 

Short-term noise impacts could occur along U.S. Route 50 as a result of increased truck activity during the 

period that elemental mercury is transported to the site. The resulting increase in day-night average noise 

levels along U.S. Route 50 is expected to be less than 1 dBA. As such, the change in truck traffic is not 

expected to result in a change in noise levels along this route or other shipping routes that would be 

noticeable to the public or result in an increase in annoyance. 

Operation of the mercury storage facility at GJDS is expected to have a negligible impact on noise levels 

around the site since the noise sources would be limited to a few employee vehicles, occasional delivery 

trucks, and semiannual testing of the emergency generator. 

4.3.5 Ecological Resources 

4.3.5.1 Terrestrial Resources 

As discussed in Chapter 3, Section 3.2.5.1, the majority of the land upon which the proposed mercury 

storage facility would be built (approximately 1 hectare [2.5 acres]) is disturbed land within an already 

developed facility area. The remainder of this land (approximately 0.7 hectares [1.6 acres]) contains 

native vegetation that would be destroyed by the construction of a new mercury storage facility. Wildlife 

occurring within both the disturbed and the undisturbed portion of the proposed site would be displaced by 

construction activities. Additional impacts could include noise and light disturbances resulting from 

construction and other human activities. 

Adherence to best management practices for land cover management (e.g., washing down construction 

equipment and vehicle tire treads) would serve to reduce the chance of introducing invasive plant species. 

Impacts on animals from construction would be limited to species adapted to human disturbance. During 

operations, there would be no additional impacts on terrestrial resources, as temporarily disturbed areas 

beyond the facility footprint would be revegetated and/or would revert to more-natural conditions. 

4.3.5.2 Wetlands and Aquatic Resources 

No wetlands or aquatic features currently exist within the proposed mercury storage facility construction 

site at GJDS. Therefore, no impacts on wetlands or aquatic resources are expected. 

4.3.5.3 Threatened and Endangered Species 

No threatened or endangered species are known or are expected to exist within the proposed construction 

site at GJDS. Thus, no impacts on threatened or endangered species are expected from construction or 

operations. Consultations have been initiated with the appropriate U.S. Fish and Wildlife Service office 

and state wildlife agency to support this analysis (see Chapter 5, Section 5.4). 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–36

4.3.6 Cultural and Paleontological Resources 

4.3.6.1 Prehistoric Resources 

GJDS and the surrounding area contain a high density of potentially significant cultural resources. More 

data are needed to determine the eligibility of potentially significant sites for listing in the NRHP by the 

State Historic Preservation Office (SHPO) (see Chapter 3, Section 3.2.6.1). Therefore, the potential exists 

for construction impacts and effects from facility operations. DOE has initiated consultation with the 

Colorado SHPO to support this analysis (see Chapter 5, Section 5.4). 

4.3.6.2 Historic Resources 

There would be no impact on historic resources at GJDS from construction or operation of the new 

mercury storage facility. The majority of properties in the vicinity are less than 50 years old and, are 

therefore ineligible for inclusion in the NRHP. To date, no historic properties have been identified on or 

near the site (see Chapter 3, Section 3.2.6.2). 

4.3.6.3 American Indian Resources 

There have been no American Indian sites identified at GJDS based on work performed in support of the 

existing disposal facility, and no impact on American Indian resources from construction or operations are 

anticipated (see Chapter 3, Section 3.2.6.3). 

4.3.6.4 Paleontological Resources 

There would be no impact on unique paleontological resources as none have been identified or are likely 

to occur on the site. 

4.3.7 Site Infrastructure 

4.3.7.1 Ground Transportation 

Construction and operations of a new mercury storage facility at GJDS are not expected to appreciably 

increase demands on the road system leading to the site. Projected peak traffic volumes and the number of 

shipments associated with mercury storage operations are presented in Section 4.3.11. 

4.3.7.2 Electricity, Fuel, and Water 

The projected electricity, fuel, and water requirements for construction and operations of a new mercury 

storage facility are summarized in Appendix C, Tables C–2 and C–4. To support construction, electric 

power would likely be supplied via a diesel-fired generator. Diesel fuel would also be required to operate 

construction equipment. Total diesel fuel demand for construction is estimated at 193,000 liters 

(51,000 gallons) over the 6-month construction timeframe. Liquid fuels are not considered to be limiting 

resources as they would be provided by local or regional suppliers and delivered to the point of use as 

needed. Raw water would be required for dust control, soil compaction, and other construction uses; some 

potable water would also be required for sanitary uses by the construction workforce. Raw water would 

likely be delivered to the site via a refillable water truck, as there is no public water service to the site. 

Construction is projected to require approximately 1,230,000 liters (325,000 gallons) of raw water and 

about 40,900 liters (10,800 gallons) of potable water, for a total of 1,270,000 liters (336,000 gallons). 

On an annualized basis, utility demands for mercury storage facility operations would be relatively small 

compared with construction. Electricity requirements would total 253 megawatt-hours annually for 

facility lighting, ventilation, and heating. An estimated 606 liters (160 gallons) of diesel fuel would be 

consumed annually for operation of an emergency onsite generator. Water use would be limited to that 
Environmental Consequences 

4–37

required to support the potable and sanitary needs of the facility workforce and would total about 

88,500 liters (23,400 gallons) per year (see Appendix C, Table C–4). 

At GJDS, the operational electricity demand would have a moderate impact on the existing electric power 

infrastructure. The electrical distribution infrastructure would need to be upgraded or an additional 

electrical substation would need to be tied into the site’s distribution system to provide adequate electricity 

for mercury storage facility operations. GJDS is operating at 14 percent of its installed annual electric 

power capacity of 109 megawatt-hours. Electric power requirements for a new mercury storage facility 

would increase the site’s annual electrical energy consumption to 268 megawatt-hours. The increase 

would be nearly 2.5 times the site’s existing capacity. 

While diesel fuel is not routinely used or stored at GJDS, the projected diesel fuel required for emergency 

generator operations would be negligible and would be supplied from local vendors. 

Public water is not available at GJDS, and potable water needs are supplied via bottled water. Current 

process water used at the site is supplied from offsite sources and stored in a 37,850-liter (10,000-gallon) 

supply tank. Water demands for operation of a new mercury storage facility at the site would need to be 

supplied via bottled water and a new water storage tank dedicated to the mercury storage facility. 

4.3.8 Waste Management 

Waste generation associated with the proposed construction and operation of the RCRA-permitted 

mercury storage facility at GJDS would have a negligible impact on the site considering the relatively 

small volumes of hazardous and nonhazardous waste projected to be generated. 

Construction of the proposed mercury storage facility is estimated to generate 271 cubic meters (355 cubic 

yards) of nonhazardous solid waste (construction debris) and approximately 9,850 liters (2,600 gallons) of 

nonhazardous sanitary liquid waste (see Appendix C, Table C–2). Construction debris would be shipped 

off site to the Mesa County Landfill. Portable toilet facilities, serviced by a local or regional contractor, 

would be used to serve the sanitary needs of the construction workforce. 

It is estimated that 910 55-gallon (208-liter) drums of hazardous waste would be generated over the 

40-year period of analysis for mercury storage facility operations. This generation volume equates to an 

average annual generation rate of 23 55-gallon drums, or approximately 5 cubic meters (6.5 cubic yards) 

(approximately 1 metric ton [1.1 tons or 2,200 pounds] by weight) of hazardous waste. This waste would 

primarily consist of cleaning rags used during facility maintenance activities, PPE used during monitoring 

activities, materials used during spill response activities, and mercury vapor filters used in the Handling 

Area. Although GJDS does not currently generate hazardous waste, the estimated yearly generation rate 

of mercury-contaminated waste would be a relatively small volume compared with most facilities that 

manage hazardous waste. As necessary, mercury-contaminated waste would be disposed of off site using 

licensed hazardous waste disposal contractors. Operation of the proposed mercury storage facility would 

require GJDS to obtain an EPA identification number and applicable RCRA TSD facility permit. 

Facility operations would also generate an estimated 59,000 liters (15,600 gallons) of nonhazardous 

sanitary waste annually (see Appendix C, Table C–4). The site’s existing onsite wastewater tank system 

would be used to collect this wastewater; the system would be emptied as needed using a licensed 

contractor. 

4.3.9 Occupational and Public Health and Safety 

If GJDS is chosen as the site for mercury storage, a new facility would be built. Most of the risks that 

pertain to GJDS are the same as those discussed in Sections 4.2.9.1 through 4.9.2.5, with a few exceptions, 

as discussed below. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–38

4.3.9.1 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites. Consequences to the involved worker are predicted to be negligible 

because involved workers would never be exposed to airborne concentrations of mercury vapor above the 

ACGIH’s 8-hour TWA/TLV of 0.025 milligrams per cubic meter of mercury vapor. This corresponds to 

keeping exposures to the involved worker in the SL-I (negligible) range.14 This would be achieved by 

adherence to good operating practices, in particular, attention to ventilation, inspection, monitoring, and 

use of PPE, as described in the Interim Guidance (DOE 2009c). Therefore, the risks to involved workers 

would be negligible during normal operations. 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 

3-L flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this source 

of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building wake. 

Appendix D, Section D.4.1.2, shows that the predicted long-term average concentration in the building 

wake for new construction is about 2.0 × 10-5 milligrams per cubic meter. This is well below EPA’s 

chronic-inhalation-exposure RfC of 3.0 × 10-4 milligrams per cubic meter. Hence, consequences would be 

in the SL-I range, and the risk to both noninvolved workers and the public would be negligible. 

4.3.9.2 Facility Accidents 

Table 4–3 provides a summary of the likelihood of occurrence of candidate mercury storage facility 

accident scenarios initiated by failures of engineered systems, human errors, or external events, and 

Table 4–4 lists the accident scenarios that remain for consequence analysis after eliminating those with 

negligible frequency from Table 4–3. These are the scenarios that are analyzed for GJDS. 

With specific reference to GJDS, commentors asked whether the aircraft crash scenario should be 

predicted to have negligible (FL-I) frequency in light of the fact that students in light aircraft fly over the 

site while training. Statistics on how often this occurs are not available, but some general observations can 

be made. As discussed in Appendix D, Section D.2.5.7, a previous analysis of a small aircraft crash into a 

hazardous and radioactive waste storage facility concluded that 9 drums would fail and 22 drums would 

leak based on both the aircraft engine impact and subsequent aircraft fuel fire. The earthquake accident 

analysis described in Section D.2.5.2 assumes that all the 3-L flasks and 1-MT containers would fail inside 

the storage building. The storage building is designed to hold 6,000 1-MT containers and over 

100,000 3-L flasks. Therefore, in the event of a general aviation aircraft that is being used for flying 

lessons crashing into the building, approximately 31 flasks or containers could be damaged by impact and 

fire loads to the extent that they leak mercury. The resultant pool of mercury and release to the 

environment from such an event would constitute a very small fraction (less than 0.1 percent) of that 

calculated for the earthquake event. In addition, the analysis in Section D.2.5.7 shows that, in several 

independent analyses, the frequency of small aircraft crashes into specific buildings at DOE sites is less 

than 10-6 per year. The predicted frequency of earthquakes severe enough to cause spills is 4.0 × 10-4 per 

year (see Section D.2.5.2). It is unlikely that the presence of training aircraft would increase aircraft crash 

frequencies by more than two orders of magnitude. Therefore, the earthquake risk bounds the aircraft risk, 

probably by a large margin. 

 

14 For definitions of SLs for various types of exposures, see Section 4.2.9.1.1 and Appendix D, Section D.1.1.1. For a discussion 

on how risk is assessed, see Sections 4.2.9.1.1 and D.1.2. 
Environmental Consequences 

4–39

4.3.9.2.1 Worker Inside Building – All Onsite Spill Scenarios 

The analysis of risks to the involved worker under all onsite scenarios is the same as in Section 4.2.9.1.4, 

which shows the following: 

 The predicted frequencies of all the scenarios in Table 4–3 are in the moderate (FL-III) or low 

(FL-II) range. 

 The predicted consequences to the involved worker are all in the SL-I to -II range. This is based 

on a qualitative analysis of how quickly a worker can walk out of the building and on the 

observation that the saturated vapor density of mercury vapor at the assumed release 

temperature of 20 °C (68 °F) is only 14 milligrams per cubic meter, so that less than a factor of 

two extra dilution is required to bring that vapor density below the 30-minute IDLH of 

10 milligrams per cubic meter or the 30-minute AEGL-3 of 8.9 milligrams per cubic meter. 

 Per Figure 4–1, the resulting risks would be in the negligible-to-low range. 

4.3.9.2.2 Predicted Concentrations in Building Wake – All Onsite Spill Scenarios 

As mentioned above, a new facility would be built at GJDS for mercury storage. All non-buoyant releases 

that occur inside the building or immediately adjacent to it would be mixed into the turbulent building 

wake, as described in Appendix D, Section D.7.2.1. For new construction at GJDS, these concentrations 

in the turbulent building wake are all below one-tenth of AEGL-2 (0.17 milligrams per cubic meter for a 

duration of release of 1 hour). Therefore, the predicted concentrations are SL-I for both noninvolved 

workers and members of the public. 

The only scenario from Table 4–3 that does not result in mixing in the building wake is the outside 

earthquake scenario. Under this scenario, the building is assumed to have collapsed completely, so that 

the resulting mercury pool is effectively outside. Appendix D, Section D.7.1.2, describes how the release 

rate is calculated in these circumstances. As shown in Table D–52, the release rate of the outside 

earthquake scenario in Atmospheric Stability Class D with a windspeed of 4.5 meters per second is 

7.98 × 10-4 kilograms per second. This release rate was input into a ground-level Gaussian dispersion 

model, which calculated downwind concentrations in a spectrum of weather conditions, ranging from 

Atmospheric Stability Classes A through F, and in four discrete ranges of windspeed (the calculated rate 

of release is representative or conservative for all but a small fraction of higher-windspeed conditions). 

From this calculation, the maximum downwind distance to which a concentration greater than AEGL-3 

could be exceeded at GJDS is predicted to be less than 100 meters (330 feet) (the model is not valid at 

distances shorter than 100 meters [330 feet]); AEGL-2 could be exceeded downwind to a distance of about 

300 meters (980 feet); and a concentration between 0.1 × AEGL-2 and AEGL-2 could be exceeded to a 

distance of about 1.1 kilometers (0.68 miles). At GJDS, the proposed new building is expected to be no 

more than 30 meters (98 feet) from the site boundary to the north and west. However, the nearest 

residence in those directions is more than 4 kilometers (2.5 miles) away.15 Therefore, the concentration to 

which any resident individual could be exposed negligible, and the corresponding risk would be 

negligible. 

The other possibility is that there could be an individual in the vicinity of the site boundary at the time of 

an accidental spill. The most likely place for such an individual to be is on the site access road, which 

enters the site just south of the proposed storage facility. However, the frequency of such an event is 

given by the product of four statistically independent factors: (1) the frequency of occurrence of the 

earthquake (4 × 10-4 per year); (2) the probability that the earthquake, given its occurrence, is severe 

 

15 This information was obtained using Google Earth. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–40

enough to cause the total collapse of the building; (3) the probability that the individual will be near the 

site boundary at the time of the accident; and (4) the probability that the wind is blowing towards the 

individual at that time. From the Gaussian computer runs, the latter probability is 0.09 or approximately 

0.1. The other two probabilities (complete building collapse and an individual’s being in the vicinity) are 

unknown, but it seems reasonable to suppose that their product does not exceed 1/40, which would take 

the overall probability (and hence risk) below 10-6 per year (i.e., negligible).16 Table 4–15 summarizes the 

results for all accidental spills of elemental mercury on site (without fire). 

Table 4–15. Summary of Risks of all Onsite Elemental Mercury Spill 

Scenarios – Grand Junction Disposal Site 

Scenario Frequency Consequenceb Risk 

Spills Inside Buildinga

Involved worker FL-II – FL-III SL-I – SL-II N–L for all inside spills 

Noninvolved worker FL-II – FL-III SL-II N for all inside spills 

Member of the public FL-II – FL-III SL-II N for all inside spills 

Spills Outside Building 

Involved worker FL-II – FL-III SL-I – SL-II 

Noninvolved worker FL-II – FL-III SL-I – SL-II 

N–L for outside 

earthquake spill; N for all 

other outside spills 

Member of the public 

1-metric-ton container spill FL-II SL-I N 

Single-pallet spill FL-III SL-I N 

Earthquake with building 

collapsec

FL-III SL-I N 

a The inside spill scenarios considered are single flask, single pallet, triple pallet, 1-metric-ton container, full spill tray under a 

pallet, and earthquake with intact building walls. 

b For definitions of severity levels, see Section 4.2.9.1.1. 

c This scenario encompasses the risk from floods, high winds, and tornadoes. 

Key: FL=frequency level; L=low; N=negligible; SL=severity level. 

4.3.9.3 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury over a 40-year period of analysis to GJDS. These 

assumptions, together with knowledge of truck routes and historical frequencies of crashes of various 

types, can be combined to produce estimates of the frequency at which crashes might occur anywhere 

along the routes traveled by mercury trucks or railcars. The results of the analysis are shown in 

Table 4–16. 

 

16 It is recognized that the foregoing reasoning is subjective.
Environmental Consequences 

4–41

Table 4–16. Frequency Analysis of Truck and Railcar Accidents – Grand Junction Disposal Site 

Scenario Truck Miles 

Frequency of 

Accidents 

(per year) 

Frequency of 

Accidents with 

Spills 

(per year) 

Frequency of 

Accidents with 

Fires 

(per year) 

Frequency of 

Accidents with 

Death 

(per year)a

909,667 1.1×10-2 1.9×10-3 1.5×10-4 5.1×10 Truck – Scenario 1 -4

– High – FL-IV Moderate – FL-III Moderate – FL-III Moderate – FL-III 

1,559,319 1.6×10-2 3.1×10-3 2.5×10-4 8.7×10 Truck – Scenario 2 -4

– High – FL-IV Moderate – FL-III Moderate – FL-III Moderate – FL-III 

317,260 2.0×10-3 9.2×10-6 2.1×10-5 1.3×10 Railcar -4

– Moderate – FL-III Low – FL-II Low – FL-II Moderate – FL-III 

a Fatality caused by mechanical impact, not by exposure to mercury. 

Note: To convert miles to kilometers, multiply by 1.60934. 

Key: FL=frequency level. 

The above frequencies are for an accident anywhere along any of the transportation routes taken over a 

40-year period of analysis. To estimate the probability of a crash in the vicinity of or on the site, begin 

with the average length of a truck or rail trip to GJDS (about 2,000 kilometers [1,260 miles]) and 

approximate an onsite crash with a crash in the last mile of the trip. The frequency of a crash in the last 

mile of those trips is a fraction, 0.00079, of the frequencies in Table 4–16. The frequency of accidents 

with spills would be low under both truck scenarios and negligible under the Railcar Scenario. The 

frequency of crashes with fires or death would be negligible under all scenarios. 

With specific reference to GJDS, the railhead is in the city of Grand Junction. In the Railcar Scenario, 

pallets would need to be transferred from railcars to trucks and then driven approximately 32 kilometers 

(20 miles) to GJDS. The predicted frequency of a crash with a spill during that 32-kilometer (20-mile) 

stretch would be 20 × 8.5 × 10-8 per truck (see Appendix D, Table D–10), or 1.7 × 10-6 per trip. Per 

Table D–9, there would be on average 59 pallets and 150 1-MT containers shipped per year. In principle, 

these would take up just over 17 trucks. Conservatively assuming they would be shipped in half 

truckloads, there would be 35 truckloads per year, leading to an estimated crash with spill frequency of 

approximately 6.0 × 10-5 per year. This increases the frequency of a crash with a spill by about a factor of 

6, since the railcar frequency of a crash with a spill is estimated to be only 9.2 × 10-6 per year. However, 

the increase of 6.0 × 10-5 per year is still well below the Truck Scenario 2 frequency of a crash with a spill 

of 3.1 × 10-3 per year. Thus, conservatively bounding the consequences of spills by those from railcars, 

the risks from spills with no fire could increase six-fold over the risk from rail transportation alone, but 

would still be much less than the risk of shipping by truck alone. 

In addition, there would be transfer operations at the Grand Junction goods yard. The operations taking 

place at that yard would be to transfer pallets and 1-MT containers from railcars to trucks. As stated 

above, 59 pallets and 150 1-MT containers would be shipped per year. The probability of a drop per 

handling event is 2.0 × 10-5. Therefore, the probability of pallet drop per year is approximately 0.002 per 

year, and the probability of a 1-MT container drop per year is 0.003. These are both moderate (FL-III) 

frequencies. If the transfer operations take place adjacent to large buildings, the wake effect could make 

the consequences SL-I, in which case risks would be negligible. In the absence of buildings, runs of the 

Gaussian computer model show concentrations at the SL-II level extending to only about 40 meters, which 

would likely be well inside the distance to any public receptor. Based on this analysis, the transfer 

operations in Grand Junction do not appear to add greater than negligible risk. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–42

With respect to transportation accidents involving spills of mercury, the following four scenarios were 

considered: 

 Spill of elemental mercury onto the ground without fire 

 Spill of elemental mercury directly into water 

 Fire with mercury spill 

 In dry weather 

 In wet weather 

4.3.9.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground 

For exposures occurring via the inhalation pathway from a spill with no fire during a transportation 

accident, the fraction of the mercury being carried by the truck or railcar that would be spilled is highly 

uncertain. It is extremely unlikely that all flasks or all 1-MT containers would be breached. However, to 

be conservative, it is assumed that such a catastrophic release could take place. The largest amount of 

mercury that can be carried in a truck or a railcar is that contained in 54 1-MT containers. Assuming that 

all of this mercury is spilled and spreads until the pool is at its capillary depth of 0.36 centimeters 

(0.14 inches) (so conservative as to be essentially inconceivable in an outdoor spill),17 the predicted rate of 

evaporation would be 1.25 × 10-5 kilograms per second (see Appendix D, Section D.4.3.1). Running this 

through the Gaussian model and ranging over all possible combinations of atmospheric stability class and 

windspeed, the predicted maximum distances to the airborne toxic benchmarks are as follows: AEGL-3, 

less than 100 meters (330 feet); AEGL-2, about 100 meters (330 feet); and 0.1 × AEGL-2, about 

340 meters (1,115 feet). As a result, a specific individual could not be exposed to concentrations that are 

greater than negligible if he or she lives more than 340 meters (1,115 feet) from a crash. Conservatively, 

assuming that the individual lives immediately adjacent to the road, that individual could only be exposed 

above 0.1 × AEGL-2 if the crash occurs along a 680-meter (2,230-foot) stretch of road (340 meters 

[1,115 feet] on either side). This is a small fraction of any of the routes (i.e., the average length of a truck 

trip to GJDS is approximately 2,000 kilometers [1,260 miles]). The frequency of occurrence of a truck 

crash with spill on the truck routes to GJDS is 0.0031 per year; see Table 4–16 (Truck Scenario 2). The 

product of the fraction of the route and the frequency of occurrence is about 1.1 × 10-6 per year, a low 

frequency. Under Truck Scenario 1 and the Railcar Scenario, the frequencies would be negligible. 

Therefore, the risk to a member of the public from transportation spills onto the ground without fire en 

route to GJDS would be negligible under Truck Scenario 1 and the Railcar Scenario and low under Truck 

Scenario 2. 

4.3.9.3.2 Transportation Accident with Spill of Elemental Mercury Directly into Water 

Spills occurring during a transportation accident could result in leakage of the mercury cargo into the 

surrounding environment. The most significant and challenging scenario (from a cleanup standpoint) 

would be a spill directly into a surface-water body such as a lake or river. This could occur if a truck or 

railcar crashes on a bridge over a river or if it falls into a river or lake while traveling alongside the water 

body. 

With specific reference to GJDS, Interstate 70 in Colorado follows rivers and streams much of the distance 

in the state to get to GJDS. These include the Colorado River, Clear Creek, Eagle River, Straight Creek, 

and Gore Creek. Interstate 70 crosses streams and rivers repeatedly and is often elevated directly above 

streams or rivers, especially over Vail Pass, through Glenwood Canyon, and through Debeque Canyon. 

Thus, the route to GJDS contains the greatest distance of any route where there is potential for spillage 

into a river to occur, although at the time of writing no information had been collected on the fractions of 

 

17 Surface tension is what prevents the mercury pool from spreading any further. However, the mercury will only spread until the

pool is at its capillary depth of 0.36 centimeters (0.14 inches) if the surface is perfectly smooth. See Appendix D, 

Section D.7.1.4. 
Environmental Consequences 

4–43

that route where the road or rail is close enough for it to be plausible that a truck or railcar might crash 

directly into the river. 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to humans (inorganic compounds of mercury and 

methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

Table 4–17 summarizes the risks associated with accidental spillages of elemental mercury during 

transportation to GJDS. 

Table 4–17. Summary of Transportation Risks to Human Receptors, Spills of Elemental Mercury 

onto the Ground or into Water, Grand Junction Disposal Site 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto the Ground 

Frequencya FL-I FL-II FL-I 

Consequence SL-II SL-II SL-II 

Risk Negligible Low Negligible 

Spill into Water

Frequencyb FL-III FL-III FL-II 

Consequence SL-I – SL-II SL-I – SL-II SL-I – SL-II 

Riskc Negligible to low Negligible to low Negligible to low 

a Frequency at which spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded. 

b Frequencies of railcar or truck crashes with spills from Table 4–16. 

c These estimates of risk are subject to large uncertainty. 

Key: FL=frequency level; SL=severity level. 

4.3.9.3.3 Transportation Accident with Fire 

The fire calculations are described in Section 4.2.9.1.5. Table 4–18 shows the results of the calculations 

of acute-inhalation risks from transportation accidents with fires on transportation routes to GJDS. The 

table encompasses both truck scenarios and the Railcar Scenario. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–44

Table 4–18. Summary of Acute-Inhalation Risks to Human Receptors, 

Accidents with Fires, Transportation Routes to Grand Junction Disposal Site 

Both Truck Scenarios with Wooden Pallets Railcar Scenario with Wooden Pallets 

Frequencya FL-III FL-II 

Consequenceb SL-II FL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7.

b The highest consequence in any weather condition. 

Key: FL=frequency level; SL=severity level. 

Note that the risks presented in the above scenarios are individual risks: they are the answer to the 

question, “What is the risk to me?” This is not the same as the risk that, somewhere along a transportation 

route, airborne concentrations would exceed the various SLs. Those risks would in fact be higher. 

The analyses performed for this EIS show that, under all fire scenarios, with and without rain, mercury 

deposited on the ground would never cause the benchmark of 180 milligrams per kilogram to be exceeded. 

Therefore, the corresponding risks would be negligible. 

Table 4–19 summarizes the human health risks associated with all transportation spills. 

Table 4–19. Summary of Transportation Risks to Human Receptors, Grand Junction Disposal Site 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto ground Negligible Low Negligible 

Spill into water Negligible to low within 

a large range of 

uncertainty 

Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Spill with fire – inhalation, 

wooden pallets 

Low Low Low 

Spill with fire – dry and wet 

deposition, wooden pallets 

Negligible Negligible Negligible 

4.3.9.4 Intentional Destructive Acts 

The discussion of IDAs is the same for all sites and transportation routes (see Section 4.2.9.1.6). 

4.3.10 Ecological Risk 

There is a generic analysis of ecological risk in Section 4.2.10.1, which applies without modification to 

GJDS. 

4.3.10.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike inorganic compounds 

formed from divalent mercury. As a result, risks to ecological receptors from slow leaks, accidental spills 

at storage sites, and spills without fires during transportation are considered to be negligible at all storage 

sites and along all transportation routes. 
Environmental Consequences 

4–45

4.3.10.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 

which also makes the following conclusions regarding the consequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

ecological receptors could be managed so that they are negligible or low. Given this assumption and the 

fact that the frequency of crashes with spills on any of the transportation routes is no more than moderate 

(and this is an upper bound on the frequency of spills directly into water), the risk would be negligible or 

low for all transportation routes. However, because of the above-mentioned uncertainty about fastflowing rivers, this observation should be tempered by noting that the uncertainty regarding this prediction 

of risk is very large. 

4.3.10.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5, and 

Section 4.2.10.1. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. Table 4–20 summarizes the FL, consequence level, and risk to ecological receptors in the 

case of a truck crash with pallet fire and no rain (dry deposition) and applies to all candidate storage sites. 

For the interpretation of Table 4–20, see Section 4.2.10.1.3. The risks of other potential fire scenarios are 

summarized as follows: 

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–21. 

 For railcar crashes with wooden pallet fires and without rain (dry deposition), see Table 4–22. 

 The predicted frequency of railcar crashes with pallet fires and rain is negligible, so risks would 

be negligible and no summary table is presented. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–46

Table 4–20. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, Grand Junction Disposal Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

b Applies to both Truck Scenarios 1 and 2. 

Table 4–21. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, Grand Junction Disposal Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a Frequencies of truck crashes with fires and rain from Appendix D, Table D–16. 

b Applies to both Truck Scenarios 1 and 2. 

Table 4–22. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, Grand Junction Disposal Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Risk 

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a Frequencies of railcar crashes with fires from Appendix D, Table D–14. 

4.3.10.4 Intentionally Initiated Transportation Fires 

The analysis of the ecological effects of intentionally initiated transportation fires is the same for all sites 

(see Section 4.2.10.1.4). 
Environmental Consequences 

4–47

4.3.11 Socioeconomics 

Employment during construction is expected to average 18 people for approximately 6 months. Operation 

of the facility 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 approximately 

5 individuals thereafter, resulting in an increase of the full-time equivalent workforce at GJDS of a factor 

of 3 to 5. In spite of this projected increase in jobs supporting construction and operations at GJDS and 

associated indirect employment, this alternative would have a negligible-to-minor impact on 

socioeconomic conditions (i.e., overall employment, population trends, and traffic) in the ROI because the 

largest estimated increase in employment would only increase the ROI workforce by approximately 

0.01 percent. 

Construction-related transportation, including employee vehicle trips and equipment and materials 

shipments, is not expected to adversely impact traffic conditions on roads leading to the site. It is assumed 

that there would be approximately 1.5 employees per vehicle, and every vehicle is counted twice to 

account for round trips. It is estimated that average construction transportation of 45 vehicles a day could 

increase the average annual daily traffic count on U.S. Route 50 by less than 0.5 percent. 

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of elemental mercury for storage. Appendix C, Section C.1, provides an estimate of the number of 

shipments by truck. The additional vehicles due to facility operations are not expected to noticeably 

increase traffic volumes on roads leading to the site. The greatest impact would be during the first 2 years 

of operations, when it is estimated that approximately 11 vehicles a day could increase the average annual 

daily traffic count on U.S. Route 50 by approximately 0.1 percent. During this time, it is estimated that up 

to 78 shipments of elemental mercury would be made each year. Approximately 96 percent of the 

additional vehicles would be attributed to employee transportation. 

4.3.12 Environmental Justice 

None of the block groups within either the 16-kilometer (10-mile) or the 3-kilometer (2-mile) radius 

surrounding GJDS contain a disproportionately high number of minority or low-income individuals (see 

Chapter 3, Section 3.2.11). Therefore, no disproportionately high and adverse effects on minority or lowincome populations are expected. 

4.4 LONG-TERM MERCURY MANAGEMENT AND STORAGE AT HANFORD 

SITE 

Under this alternative, a new mercury storage facility would be constructed at DOE’s Hanford. Hanford 

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

portion of the state of Washington. Within this site, the new mercury storage facility would be built in the 

200-West Area adjacent to the Central Waste Complex (CWC), as further described in Chapter 2, 

Section 2.4.3. 

4.4.1 Land Use and Visual Resources 

Negligible impacts on land use and visual resources are expected from construction and operation of a 

new mercury storage building at Hanford. Construction of this new facility would require the disturbance 

of approximately 3.1 hectares (7.5 acres) for building construction and laydown areas (see Chapter 2, 

Section 2.3.1). The site would be located adjacent to the existing CWC in the 200-West Area. This area 

of Hanford is highly developed and has been subject to disturbance from past operations. The completed 

facility boundary would similarly encompass approximately 3.1 hectares (7.5 acres) within its fenced 

perimeter, which corresponds to less than 0.1 percent of the land within the 200 Areas at Hanford. The 

footprint of the mercury storage building would occupy approximately 1.6 hectares (3.9 acres) of this area. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–48

Mercury storage operations would be compatible with DOE’s Industrial-Exclusive land use designation 

for this area. The low profile of the new building is not expected to affect the overall viewshed of this 

area from on- or offsite vantage points. Therefore, mercury storage operations would not result in a 

change to BLM VRM classifications. 

4.4.2 Geology, Soils, and Geologic Hazards 

4.4.2.1 Geology and Soils 

Construction of a new mercury storage facility in the Hanford 200-West Area would generally have the 

same direct impacts on geology and soils in terms of land area disturbed, depth of excavation, and 

geologic resource demands as described in Section 4.3.2.1. Geologic resources, including concrete and 

coarse aggregate (gravel) totaling 8,640 cubic meters (11,300 cubic yards), would be required for 

construction (see Appendix C, Table C–2) and would be procured from local and/or regional commercial 

vendors. Trenching may be necessary to place foundation footers or to connect the new mercury storage 

facility with existing 200-West Area utilities. As the new facility would be located adjacent to the existing 

CWC, the area has largely been disturbed by historical activities. Excavation in the 200-West Area would 

encounter the gravel-dominated sediments of the Hanford formation, which are up to 100 meters 

(330 feet) thick across the 200 Areas (see Chapter 3, Section 3.3.2). Nevertheless, the lateral and vertical 

extent of subsurface strata would not be greatly impacted by excavation and site-clearing activities, and no 

special construction techniques should be necessary to work in these materials. Although boulder-size 

rocks can occur in the Hanford formation, a site survey and geotechnical study would be conducted to 

confirm site geologic characteristics for facility siting and engineering purposes. 

Natural soils comprising alluvial and windblown sands across the 200-West Area could be more prone to 

erosion. However, adherence to standard best management practices for soil erosion and sediment control 

during construction would serve to minimize soil erosion and loss (see Section 4.3.2.1). During 

operations, the previously disturbed areas would not be subject to long-term soil erosion, and temporarily 

disturbed areas would likely revert to natural conditions. There would be no additional impact on geology 

and soils from operations. 

4.4.2.2 Geologic Hazards 

Hazards from large-scale geologic conditions, such as earthquakes, and other site geologic conditions with 

the potential to affect the 200-West Area at Hanford are summarized in Chapter 3, Section 3.3.2.3. The 

seismicity of the Columbia Plateau, as determined by the rate of earthquakes per area and the magnitude 

of these events, is lower than that of other regions in the Pacific Northwest. However, the 200-West Area 

is located approximately 8 kilometers (5 miles) from the potentially active Central Gable Mountain Fault. 

The Hanford region is one of relatively moderate to high seismicity overall. Ground shaking of MMI VII 

associated with postulated earthquakes is possible and supported by the historical record for the region 

(see Appendix B, Table B–4). The predicted peak ground acceleration at the site from an earthquake with 

an annual probability of occurrence of 1 in 2,500 is 0.18 g. Ground motion in this range could cause slight 

to moderate damage to ordinary structures, but is not expected to affect modern structures designed and 

constructed to withstand the assessed hazard. As further described in Appendix B, Section B.3.2, DOE 

Order 420.1B and its companion guide (DOE Guide 420.1-2) require that facilities be designed, 

constructed, and operated so that the public, workers, and environment are protected from adverse impacts 

of natural phenomena hazards, including earthquakes. Thus, the mercury storage facility would be sited 

and designed to address the risk from geologic hazards, and the predicted ground motion would be 

unlikely to cause a breach in mercury containers from structural failure. An analysis of potential 

environmental consequences resulting from an earthquake-induced accident is described in 

Section 4.4.9.2. 
Environmental Consequences 

4–49

4.4.3 Water Resources 

4.4.3.1 Surface Water 

Facility construction activities are not expected to have any direct impact on surface water features, 

including the Columbia River, as there are no natural, perennial surface water drainages in the vicinity of 

CWC in the 200-West Area. The closest surface water feature to CWC is Cold Creek, an ephemeral 

stream located approximately 4.8 kilometers (3 miles) southwest of the site. 

Stormwater runoff from the construction site would be unlikely to reach Cold Creek, and appropriate soil 

erosion and sediment control measures and spill prevention and waste management practices would be 

employed to minimize suspended sediment, the transport of other deleterious materials, and potential 

water quality impacts, as noted in Section 4.3.3.1. 

Construction activities would require as much as 1,270,000 liters (336,000 gallons) of water over the 

6-month construction period. This volume would primarily be required for dust control and soil 

compaction. It is anticipated that water would be trucked to the construction site and supplied from the 

200 Area water system, which draws from the Columbia River. During operations, water use would 

generally be limited to that required to serve the potable and sanitary needs of the storage facility 

workforce. Total annual consumption is estimated to be no more than about 88,500 liters 

(23,375 gallons). Depending on the number of personnel drawn from the existing DOE workforce at 

Hanford, water use by dedicated mercury storage facility staff could be greatly reduced. These 

construction and operations volumes are very small compared with the volume of water currently 

withdrawn and used by DOE in the 200 Areas (see Section 4.4.7.2). 

As previously noted in Section 4.3.3.1, design, construction, and operation of the mercury storage facility 

would incorporate structural controls and practices to prevent the release of elemental mercury and to 

prevent any spills or other releases, should they occur as a result of abnormal operating conditions, from 

reaching soils or surfaces where they could be conveyed to surface waters or groundwater. Facility 

operations would be conducted in accordance with an ICP and SPCC plan, or equivalent plans as 

mandated by state requirements governing the site, which set forth the actions facility personnel would 

take to respond to fires, explosions, or any accidental release of mercury to air, soil, or surface water at the 

facility. 

The site is not located within or adjacent to a 100-year floodplain and is not subject to riverine or stream 

flooding from Cold Creek. CWC is also located beyond the estimated probable maximum flood boundary 

of Cold Creek (see Chapter 3, Section 3.3.3.1). Regardless, DOE Order 420.1B and its companion guide 

(DOE Guide 420.1-2) require that DOE facilities be designed, constructed, and operated to protect the 

public, workers, and environment from natural phenomena hazards, including flooding, and specifically to 

adhere to the flood design and evaluation criteria specified in DOE Standards 1020-2002 and 1023-95. 

The potential for sheet flooding and other precipitation effects (e.g., scour and erosion) would be 

accounted for in the design of foundations, walls, roof structures, and drainage and stormwater 

management systems for the storage facility. Consequently, the new mercury storage facility would also 

incorporate appropriate stormwater management controls to safely collect and convey stormwater from the 

facility while minimizing washout, soil erosion, and offsite water quality impacts. 

There would be no direct discharge of effluents to either surface water or groundwater from storage 

facility operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) 

would be generated and managed via either the existing CWC sanitary waste system or a new sanitary 

waste disposal system permitted by the Washington State Department of Health (see Section 4.4.8). 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–50

4.4.3.2 Groundwater 

Facility construction is not expected to have any impact on groundwater hydrology or existing 

contaminant plumes in the 200-West Area due to the depth to groundwater and the shallow depth of 

excavation. As the facility would be designed and operated to prevent any spills from reaching the 

ground, there would be no impact on groundwater from routine operations. 

4.4.4 Meteorology, Air Quality, and Noise 

4.4.4.1 Meteorology 

Meteorological events can result in damage to buildings such as mercury storage warehouses. The 

frequency and consequences of such events were considered in selecting the accident events evaluated in 

Section 4.4.9.2. As previously detailed and described in Section 4.3.4.1, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so 

that the public, workers, and environment are protected from adverse impacts of natural phenomena 

hazards, including meteorological events. RCRA-permitted facilities, such as the proposed mercury 

storage facility, must also meet applicable design, construction, and operation requirements under Title 40 

of the CFR, Section 264.31 and applicable state RCRA requirements to prevent the release of stored 

wastes. As the Hanford region is susceptible to occasional occurrence of high winds, the mercury storage 

facility would be designed and constructed to withstand the potential for high winds and other 

meteorological events, such as heavy snow. 

4.4.4.2 Air Quality 

Minor short-term air quality impacts would result from construction of a mercury storage facility in the 

200-West Area. These impacts would include an increase in criteria and toxic air pollutant concentrations 

from construction equipment emissions (see Appendix C, Section C.2.3). These emissions would occur 

over a 6-month construction period and are not expected to result in exceedance of the ambient air quality 

standards. 

Operation of the mercury storage facility in the 200-West Area is expected to have negligible emissions, 

consisting of emissions from employee vehicles, trucks or trains, semiannual testing of emergency 

generators, and possibly mercury vapor from any spills or from mercury containers. No localized 

emissions from space heating are anticipated associated with mercury storage facility operations, as 

electric heating is anticipated for areas requiring climate control. Compliance with the conformity 

regulations is discussed in Appendix B, Section B.5.1.2. 

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

elemental mercury vapor escaping from storage containers or residual contamination. Mercury vapor 

transported downwind could then be inhaled by noninvolved workers (those outside the storage facility) or 

nearby offsite individuals. Appendix D, Section D.4.1, presents a conservative analysis that shows that for 

a long-term, undetected slow leak inside the proposed mercury storage facility, the predicted long-term 

average concentration in the building wake never exceeds 80 nanograms per cubic meter. The EPA 

threshold for chronic exposure to airborne mercury is 300 nanograms per cubic meter, so slow releases of 

mercury would have a negligible effect on noninvolved workers and the public, with a corresponding 

negligible risk. 

Air quality impacts from transportation of mercury to Hanford would be similar to those discussed in 

Section 4.3.4.2. Truck and rail transport are discussed in more detail in Section 4.4.9.3. Estimated 

emissions from truck and rail transportation are presented in Tables 4–15 and 4–16. 

Annual carbon dioxide emissions would be highest during the year 2013, at approximately 380 metric tons 

(419 tons) per year, as a result of moving elemental mercury to the site by truck; these annual truck 
Environmental Consequences 

4–51

emissions would be greater than rail emissions from shipping mercury. As similarly noted in 

Section 4.3.4.2, such emissions would minimally add to global and U.S. annual emissions of carbon 

dioxide. Global climate change is further discussed in Section 4.11.4.2. 

4.4.4.3 Noise 

Short-term noise impacts at Hanford could result from construction of a mercury storage facility in the 

200-West Area. These impacts would include an increase in traffic to the site and an increase in noise 

resulting from construction equipment. These impacts would occur during the 6-month construction 

period. Since the nearest residence is located more than 8 kilometers (5 miles) from the site, the increase 

in noise levels at this location from construction equipment is expected to be negligible. The increase in 

traffic noise levels along Washington State Routes 240 and 24 from construction activity is expected to be 

less than 1 dBA since the increase in traffic resulting from construction would be much less than the 

existing traffic on State Routes 240 and 24. 

Short-term noise impacts could occur along State Route 240 as a result of increased truck activity during 

the period that elemental mercury is transported to the site. The resulting increase in day-night average 

noise levels along State Route 240 is expected to be less than 1 dBA. As such, the change in truck traffic 

is not expected to result in a change in noise levels along this route or other shipping routes that would be 

noticeable to the public or result in an increase in annoyance. If the mercury is shipped by rail instead of 

by truck, some additional rail activity from placing railcars at the site could result in some increase in 

noise levels near the site. 

Operation of the mercury storage facility at Hanford is expected to have a negligible impact on noise 

levels around the site since the noise sources would be limited to a few employee vehicles, occasional 

delivery trucks, and semiannual testing of the emergency generator. 

4.4.5 Ecological Resources 

4.4.5.1 Terrestrial Resources 

Habitat in the immediate vicinity of the proposed mercury storage facility location adjacent to CWC in the 

200-West Area consists of disturbed land within a developed setting. Little native vegetation remains 

within the area; impacts would be limited to introduced species in an already disturbed landscape. 

Adherence to best management practices for land cover management (e.g., washing down construction 

equipment and vehicle tire treads) would serve to reduce the chance of introducing invasive plant species. 

Impacts on animals from construction would be limited to species adapted to human disturbance. During 

operations, there would be no additional impacts on terrestrial resources, as temporarily disturbed areas 

beyond the facility footprint would be revegetated and/or would revert to more-natural conditions. 

4.4.5.2 Wetlands and Aquatic Resources 

No wetlands or aquatic resources exist within the vicinity of the proposed construction site in the 

200-West Area. Therefore, no impacts on wetlands or aquatic habitats are expected. 

4.4.5.3 Threatened and Endangered Species 

No threatened or endangered species are known or are expected to exist within the area of the proposed 

mercury storage facility in the 200-West Area. Thus, no impacts on threatened or endangered species are 

expected from construction or operations. Consultations have been initiated with the appropriate U.S. Fish 

and Wildlife Service office and state wildlife agency to support this analysis (see Chapter 5, Section 5.4). 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–52

4.4.6 Cultural and Paleontological Resources 

4.4.6.1 Prehistoric Resources 

As noted in Chapter 3, Section 3.3.6.1, White Bluffs Road, which was in use prior to the exploration and 

settlement of the area, traverses the northwestern portion of the 200-West Area in a south-to-northeast 

direction. The only other prehistoric resources found in the 200 Areas were two cryptocrystalline flakes 

found northwest of White Bluffs Road and one cryptocrystalline projectile point base located just east of 

the 200-East Area. Thus, there would be no impact on these prehistoric resources from construction and 

operations of a new mercury storage facility in the 200-West Area adjacent to CWC. 

4.4.6.2 Historic Resources 

Much of the 200 Areas have been altered by Hanford operations. As previously stated in Chapter 3, 

Section 3.3.6.2, White Bluffs Road is of historic significance for its role in European-American 

immigration, development, agriculture and Hanford operations. Buildings associated with the Manhattan 

Project and Cold War era are also found within the 200-East and 200-West Areas, along with a small 

portion of one of the Hanford Atmospheric Dispersion Test Facility arc roads; however, none of these 

structures would be impacted by construction or operations of the proposed mercury storage facility. DOE 

has initiated consultation with the Washington SHPO to support this analysis (see Chapter 5, Section 5.4). 

4.4.6.3 American Indian Resources 

No American Indian resources would be directly affected in the 200 Areas by facility construction and 

operations. Although there have been no traditional cultural properties identified in the 200 Areas, White 

Bluffs Road, which was originally used as an American Indian trail, traverses the 200-West Area. Also 

many sites used for American Indian hunting and religious activities lie just to the north on Gable 

Mountain and Gable Butte. These sites are associated with the Gable Mountain/Gable Butte Cultural 

District and within the viewshed of the 200 Areas (see Chapter 3, Section 3.3.6.3). DOE has initiated the 

consultation process with area and regional tribal nations who may have an interest in the proposed action 

and alternatives (see Chapter 5, Section 5.4). 

4.4.6.4 Paleontological Resources 

There would be no impacts on known or unique paleontological resources under this alternative, as no 

such resources have been discovered within the 200 Areas (see Chapter 3, Section 3.3.6.4). As is the case 

for other cultural resources at Hanford, if any paleontological resources were found, procedures are in 

place to properly manage the discovery site. 

4.4.7 Site Infrastructure 

4.4.7.1 Ground Transportation 

Construction and operations of a new mercury storage facility at Hanford are not expected to appreciably 

increase demands on the road and rail systems leading to the site. Projected peak traffic volumes and the 

number of shipments associated with mercury storage operations are presented in Section 4.4.11. 

4.4.7.2 Electricity, Fuel, and Water 

Utility resource demands and associated assumptions for construction and operation of a new mercury 

storage facility in Hanford’s 200-West Area would be very similar to those described in Section 4.3.7.2. 

The 200 Areas’ current annual electricity consumption is 51 percent of its capacity. Under this alternative, 

the projected annual operational electricity requirements (253 megawatt-hours) of a new mercury storage 
Environmental Consequences 

4–53

facility would have a negligible impact (0.6 percent increase) when compared with the 200-West Area’s 

current annual electrical energy use. This increase could easily be accommodated by the 200 Areas’ 

existing electric power distribution infrastructure (see Chapter 3, Section 3.3.7.2). 

Fuel oil is the primary liquid fuel used across the 200 Areas. Fuel availability at Hanford is limited only 

by the ability to ship it to the site; volume can be increased as needed. Diesel fuel consumption (606 liters 

[160 gallons]) to support mercury storage operations would be negligible (0.02 percent increase) when 

compared with the 200 Areas’ annual consumption of fuel oil (see Chapter 3, Section 3.3.7.3). 

Water requirements for construction and operation of a new mercury storage facility would be negligible 

compared with the sitewide water usage and capacity of the 200 Areas and Hanford as a whole 

(see Chapter 3, Section 3.3.7.4). Water requirements during construction (1,270,000 liters 

[336,000 gallons]) would temporarily increase annual sitewide water consumption by 0.16 percent. The 

annual water demand for mercury storage operations (88,500 liters [23,400 gallons]) would constitute 

about 0.03 percent of the 200 Areas’ consumption and 0.003 percent of Hanford’s potable water 

production capacity. 

4.4.8 Waste Management 

Waste generation associated with construction and operations of a new mercury storage facility in 

Hanford’s 200-West Area would be similar to that discussed in Section 4.3.8. Facility construction 

activities would generate an estimated 271 cubic meters (355 cubic yards) of nonhazardous solid waste 

and 9,850 liters (2,600 gallons) of nonhazardous sanitary liquid waste. These nonhazardous waste streams 

are minimal compared with the current onsite generation rate of nonhazardous waste at Hanford from 

construction and demolition activities (see Chapter 3, Section 3.3.8.1). It is assumed that constructiongenerated solid waste would be disposed of off site at the Roosevelt Regional Landfill. Portable toilet 

facilities, serviced by a local or regional contractor, would be used to serve the sanitary needs of the 

construction workforce. 

As further described in Section 4.3.8, operation of a new mercury storage facility at Hanford is expected to 

generate an estimated 910 55-gallon (208-liter) drums of hazardous waste over the 40-year period of 

analysis. This equates to about 23 55-gallon drums, or approximately 5 cubic meters (6.5 cubic yards) 

annually. This hazardous waste volume is negligible as it represents only 1 percent of the forecasted 

Hanford sitewide hazardous waste generation volume for fiscal year 2008 (see Chapter 3, Section 3.3.8). 

Various RCRA-regulated hazardous waste streams are actively generated and managed at Hanford (see 

Chapter 3, Section 3.3.8.1). No changes in Hanford’s generator status would be required to construct and 

operate the proposed mercury storage facility, nor are any substantial effects on Hanford’s waste 

management infrastructure expected. 

Facility operations would also generate an estimated 59,000 liters (15,600 gallons) of nonhazardous 

sanitary waste annually. This yearly generation rate is miniscule (0.03 percent) compared with Hanford’s 

sitewide average sanitary waste generation rate of 219 million liters (57.9 million gallons) 

(DOE 2000:3-139). Sanitary wastewater would either be discharged to existing sewer systems and/or 

septic systems or to a new, dedicated septic system permitted by the Washington State Department of 

Health. 

DOE continues to manage several ongoing programs and projects at Hanford in support of sitewide 

remediation. Neither construction nor operation of the proposed mercury storage facility is anticipated to 

impact resources (e.g., funding, labor, facilities, and equipment) associated with current and/or future site 

environmental restoration efforts. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–54

4.4.9 Occupational and Public Health and Safety 

If Hanford is chosen as the site for mercury storage, a new facility would be built. Most of the risks that 

pertain to Hanford are the same as those discussed in Sections 4.2.9.1 through 4.2.9.5. 

4.4.9.1 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites. Consequences to the involved worker are predicted to be negligible 

because involved workers would never be exposed to airborne concentrations of mercury vapor above the 

ACGIH’s 8-hour TWA/TLV of 0.025 milligrams per cubic meter of mercury vapor. This corresponds to 

keeping exposures to the involved worker in the SL-I (negligible) range.18 This would be achieved by 

adherence to good operating practices, in particular attention to ventilation, inspection, monitoring, and 

use of PPE, as described in the Interim Guidance (DOE 2009c). Therefore, the risks to involved workers 

would be negligible during normal operations. 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 3-L 

flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this source 

of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building wake. 

Appendix D, Section D.4.1.2, shows that the predicted long-term average concentration in the building 

wake for new construction is about 2.0 × 10-5 milligrams per cubic meter. This is well below EPA’s 

chronic-inhalation-exposure RfC of 3.0 × 10-4 milligrams per cubic meter. Hence, consequences would be 

in the SL-I range, and the risk to both noninvolved workers and the public would be negligible. 

4.4.9.2 Facility Accidents 

Section 4.2.1.9.4 provides a discussion of facility accident risks that applies to all sites. Table 4–3 

contains a summary of the likelihood of occurrence of candidate facility accident scenarios initiated by 

failures of engineered systems, human errors, or external events, and Table 4–4 lists the accident scenarios 

that remain for consequence analysis after eliminating those with negligible frequency from Table 4–3. 

The analysis of the scenarios at Hanford is exactly the same as described in Section 4.2.1.9.4, with the 

exception of a member of the public in the case of an outside earthquake spill. The atmospheric dispersion 

calculations show that, for this spill, the maximum distance downwind to which a concentration greater 

than AEGL-3 could be exceeded is less than 100 meters (330 feet); for AEGL-2, the corresponding 

distance is approximately 300 meters (980 feet); and for 0.1 × AEGL-2, it is 1.1 kilometers (0.68 miles). 

However, the distance to the closest site boundary from Hanford’s 200 Areas is 3.5 kilometers (2.2 miles), 

so consequences and hence risks to members of the public would be negligible. Table 4–23 summarizes 

the results for all accidental spills of elemental mercury on site (without fire). 

 

18 For definitions of SLs for various types of exposures, see Section 4.2.9.1.1 and Appendix D, Section D.1.1.1. For a discussion 

of how risk is assessed, see Sections 4.2.9.1.1 and D.1.1.2. 
Environmental Consequences 

4–55

Table 4–23. Summary of Risks of all Onsite Elemental Mercury Spill Scenarios – Hanford Site 

Scenario Frequency Consequenceb Risk 

Spills Inside Buildinga

Involved worker FL-II – FL-III SL-I – SL-II N–L for all inside spills 

Noninvolved worker FL-II – FL-III SL-II N for all inside spills 

Member of the public FL-II – FL-III SL-II N for all inside spills 

Spills Outside Building 

Involved worker FL-II – FL-III SL-I – SL-II 

Noninvolved worker FL-II – FL-III SL-I – SL-II 

N–L for outside 

earthquake spill; N for all 

other outside spills 

Member of the public 

1-metric-ton container spill FL-II SL-I N 

Single-pallet spill FL-III SL-I N 

Earthquake with building 

collapseb

FL-III SL-I N 

a The inside spill scenarios considered are single flask, single pallet, triple pallet, 1-metric-ton container, full spill tray under a 

pallet, and earthquake with intact building walls. 

b This scenario encompasses the risk from floods, high winds, and tornadoes. 

Key: FL=frequency level; L=low; N=negligible; SL=severity level. 

4.4.9.3 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury over a 40-year period of analysis to Hanford. 

These assumptions, together with knowledge of truck routes and historical frequencies of crashes of 

various types, can be combined to produce estimates of the frequency at which crashes might occur 

anywhere along the routes traveled by mercury trucks or railcars. The results of the analysis are shown in 

Table 4–24. 

Table 4–24. Frequency Analysis of Truck and Railcar Accidents – Hanford Site 

Scenario 

Truck 

Miles 

Frequency of 

Accidents 

(per year) 

Frequency of 

Accidents with 

Spills (per year) 

Frequency of 

Accidents with 

Fires in Dry 

Weather 

(per year) 

Frequency of 

Accidents with 

Fires in Wet 

Weather 

(per year) 

Frequency of 

Accidents with 

Deatha 

(per year) 

1,251,164 1.4×10-2 2.5×10-3 2.0×10-4 6.4×10-6 7.0×10 Truck – -4

Scenario 1 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III 

2,112,527 1.9×10-2 4.1×10-3 3.4×10-4 1.1×10-5 1.2×10 Truck – -3

Scenario 2 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III 

453,317 2.8×10-3 1.3×10-5 3.0×10-5 9.6×10-7 1.9×10 Railcar -4

– Moderate – FL-III Low – FL-II Low – FL-II Negligible – FL-I Moderate – FL-III 

a Fatality caused by mechanical impact, not by exposure to mercury. 

Note: To convert miles to kilometers, multiply by 1.60934. 

Key: FL=frequency level. 

The above frequencies are for an accident anywhere along any of the transportation routes taken over a 

40-year period of analysis to Hanford. A crash that occurs in the last mile of the trip was used to estimate 

the frequency of an onsite crash in the vicinity of the storage building. The frequency of such accidents 

with spills would be low under both truck scenarios and negligible under the Railcar Scenario. The 

frequency of crashes with fires or death would be negligible under all scenarios. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–56

With respect to transportation accidents involving spills of mercury, the following four scenarios were 

considered: 

 Spill of elemental mercury onto the ground without fire 

 Spill of elemental mercury directly into water 

 Fire with mercury spill 

 In dry weather 

 In wet weather 

4.4.9.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground 

Section 4.2.9.1.5 contains an analysis of spills of elemental mercury onto the ground following a truck or 

railcar crash without fire. A conservative estimate of the rate of evaporation from the resulting pool and 

the subsequent atmospheric dispersion (applicable to all sites) shows that a specific individual could not be 

exposed to concentrations that are greater than negligible if he or she lives more than 340 meters 

(1,115 feet) from a crash. Conservatively, assuming that the individual lives immediately adjacent to the 

road, that individual could only be exposed to such concentrations if the crash occurs along a specific 

680-meter (2,230-foot) stretch of any of the routes to Hanford. The same reasoning as is used in the 

generic discussion in Section 4.2.9.1.5 shows that the risk to a member of the public from transportation 

spills onto the ground without fire en route to Hanford would be negligible under Truck Scenario 1 and the 

Railcar Scenario, but low under Truck Scenario 2. 

4.4.9.3.2 Transportation Accident with Spill of Elemental Mercury Directly into Water 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to humans (inorganic compounds of mercury and 

methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

Table 4–25 summarizes the risks to human receptors arising from spillages of elemental mercury during 

transportation to Hanford. 
Environmental Consequences 

4–57

Table 4–25. Summary of Transportation Risks to Human Receptors, Spills of Elemental Mercury 

onto the Ground or into Water, Hanford Site 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto the Ground 

Frequencya FL-I FL-II FL-I 

Consequence SL-II SL-II SL-II 

Risk Negligible Low Negligible 

Spill into Water 

Frequencyb FL-III FL-III FL-II 

Consequence SL-I – SL-II SL-I – SL-II SL-I – SL-II 

Riskc Negligible to low Negligible to low Negligible to low 

a Frequency at which spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded. 

b Frequencies of railcar or truck crashes with spills from Table 4–24. 

c These estimates of risk are subject to large uncertainty. 

Key: FL=frequency level; SL=severity level. 

4.4.9.3.3 Transportation Accident with Fire 

The fire calculations are described in Section 4.2.9.1.5. Table 4–26 shows the results of the calculations 

of acute-inhalation risks from transportation accidents with fires on transportation routes to Hanford. The 

table encompasses both truck scenarios and the Railcar Scenario. 

Table 4–26. Summary of Acute-Inhalation Risks to Human Receptors, Accidents with Fires, 

Transportation Routes to Hanford Site 

Both Truck Scenarios with Wooden Pallets Railcar Scenario with Wooden Pallets 

Frequencya FL-III FL-II 

Consequenceb SL-II FL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7. 

b The highest consequence in any weather condition. 

Key: FL=frequency level; SL=severity level. 

Note that the risks presented in the above scenarios are individual risks: they are the answer to the 

question, “What is the risk to me?” This is not the same as the risk that, somewhere along a transportation 

route, airborne concentrations would exceed the various SLs. Those risks would in fact be higher. 

The analyses performed for this EIS show that, under all fire scenarios listed in Table 4–26, with and 

without rain, mercury deposited on the ground would never cause the benchmark of 180 milligrams per 

kilogram to be exceeded. Therefore, the corresponding risks would be negligible. 

Table 4–27 summarizes the human health risks associated with all transportation spills. 

Table 4–27. Summary of Transportation Risks to Human Receptors, Hanford Site 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto ground Negligible Low Negligible 

Spill into water Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Spill with fire – inhalation, 

wooden pallets 

Low Low Low 

Spill with fire – dry and 

wet deposition, wooden 

pallets 

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

4–58

4.4.9.4 Intentional Destructive Acts 

The discussion of IDAs is the same for all sites and transportation routes (see Section 4.2.9.1.6). 

4.4.10 Ecological Risk 

There is a generic analysis of ecological risk in Section 4.2.10.1, which applies without modification to 

Hanford. 

4.4.10.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike inorganic compounds 

formed from divalent mercury. As a result, risks to ecological receptors from slow leaks, accidental spills 

at storage sites, and spills without fires during transportation are considered to be negligible at all storage 

sites and along all transportation routes. 

4.4.10.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 

which also makes the following conclusions regarding the consequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

ecological receptors could be managed so that they are negligible or low. Given this assumption and the 

fact that the frequency of crashes with spills on any of the transportation routes is no more than moderate 

(and this is an upper bound on the frequency of spills directly into water), the risk would be negligible or 

low for all transportation routes. However, because of the above-mentioned uncertainty about fastflowing rivers, this observation should be tempered by noting that the uncertainty regarding this prediction 

of risk is very large. 
Environmental Consequences 

4–59

4.4.10.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5, and 

Section 4.2.10.1. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. Table 4–28 summarizes the FL, consequence level, and risk to ecological receptors in the 

case of a truck crash with a pallet fire and no rain (dry deposition) and applies to all candidate storage 

sites. 

Table 4–28. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, Hanford Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

b Applies to both Truck Scenarios 1 and 2. 

For the interpretation of Table 4–28, see Section 4.2.10.1.3. The risks of other potential fire scenarios are 

summarized as follows: 

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–29. 

 For rail crashes with wooden pallet fires and without rain (dry deposition), see Table 4–30. 

 The predicted frequency of railcar crashes with pallet fires and rain is negligible, so risks would 

be negligible and no summary table is presented. 

4.4.10.4 Consequences – Intentionally Initiated Fire with Mercury Spill 

The consequences of intentionally initiated fires to ecological receptors are the same for all sites and 

transportation routes (see Section 4.2.10.1.4). 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–60

Table 4–29. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, Hanford Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Table D–16. 

b Applies to both Truck Scenarios 1 and 2. 

Table 4–30. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, Hanford Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Risk

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a Frequencies of rail crashes with fires from Appendix D, Table D–14. 

4.4.11 Socioeconomics 

Under this alternative, a new facility for long-term storage of elemental mercury would be constructed in 

the 200-West Area. Employment during construction is expected to average 18 people for approximately 

6 months. Operation of the facility 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 approximately 5 individuals thereafter, resulting in a possible increase of the existing 

Hanford workforce of less than 0.1 percent and an increase in the ROI workforce of approximately 

0.006 percent. Neither construction nor operation of a new facility is expected to generate substantial 

direct or indirect employment. Thus, negligible impacts on socioeconomic conditions (i.e., overall 

employment, population trends, and traffic) in the ROI would result from implementing this alternative. 

Construction-related transportation, including employee vehicle trips and equipment and materials 

shipments, is not expected to adversely impact traffic conditions on roads leading to the site. It is assumed 

that there would be approximately 1.5 employees per vehicle, and every vehicle is counted twice to 

account for round trips. It is estimated that average construction transportation of 45 vehicles a day could 

increase the average annual daily traffic counts by as little as 1 percent, if utilizing State Route 240, to as 

much as 5 percent, if utilizing State Route 24. It is likely that these additional vehicles would use a 

combination of routes, thus the additional load would not be concentrated on one route. Fifty-three 

percent of these vehicles would be attributed to employee transportation. 
Environmental Consequences 

4–61

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of elemental mercury to the site for storage. Appendix C, Section C.1, provides an estimate of the number 

of shipments by truck. The additional vehicles due to facility operations are not expected to noticeably 

increase traffic volumes on roads leading to the site. The greatest impact would be during the first 2 years 

of operations, when it is estimated that approximately 11 vehicles a day could increase the average annual 

daily traffic counts by as little as 0.3 percent, if utilizing State Route 240, to slightly over 1 percent, if 

utilizing State Route 24. During this time, it is estimated that up to 78 shipments of elemental mercury 

would be made each year. Approximately 96 percent of the additional vehicles would be attributed to 

employee transportation. 

4.4.12 Environmental Justice 

No populations have been identified within the 16-kilometer (10-mile) radius surrounding the 200 Areas at 

Hanford (see Chapter 3, Section 3.3.11). Therefore, no disproportionately high and adverse effects on 

minority or low-income populations are expected. Consultations have been initiated with regional tribal 

nations including the Confederated Tribes and bands of the Yakama Nation, and the Confederated Tribes f 

the Umatilla Indian reservation, as discussed in Section 4.4.6.3. 

4.5 LONG-TERM MERCURY MANAGEMENT AND STORAGE AT HAWTHORNE 

ARMY DEPOT 

Under this alternative, elemental mercury would be stored at the Hawthorne Army Depot. The depot 

comprises 59,500 hectares (147,000 acres) and is located approximately 16 kilometers (10 miles) from 

Hawthorne, Nevada. Implementation of this alternative would involve modification of a maximum of 

29 existing storage buildings within the depot’s Central Magazine Area to accommodate mercury storage, 

as further described in Chapter 2, Section 2.4.4. 

4.5.1 Land Use and Visual Resources 

No additional impacts on land use or visual resources are anticipated at the Hawthorne Army Depot since 

no new construction or other substantial ground-disturbing activities would be required. Elemental 

mercury would be stored within up to 29 storage buildings located in Group 110 within the Central 

Magazine Area adjacent to the buildings where U.S. Department of Defense mercury is presently planned 

for storage; each building would provide approximately 929 square meters (10,000 square feet) of floor 

space. Collectively, these 29 buildings would provide up to 27,000 square meters (290,000 square feet) of 

space for DOE storage of elemental mercury. Receipt, staging, and storage activities would generally take 

place inside the buildings and would not require the use of any additional site acreage. Therefore, onsite 

land use would remain predominantly light industrial, and viewsheds would not be affected. Scheduled 

maintenance and repairs to the storage buildings would be consistent with the existing land use and visual 

character of the site. Storage of elemental mercury is likewise not expected to affect offsite land uses and 

viewsheds from public vantage points in the vicinity of the Hawthorne Army Depot. No applicable land 

use plans, policies, or controls have been identified that would restrict storage of elemental mercury at this 

location (Hartman 2009a). Because there would be no change to the visual landscape as a result of this 

alternative, there would be no associated change in BLM VRM classifications. 

4.5.2 Geology, Soils, and Geologic Hazards 

4.5.2.1 Geology and Soils 

Upgrades and internal modifications of the 29 structures in the Central Magazine Area at the Hawthorne 

Army Depot would have a very small impact on geology and soils. Direct impacts would be limited to 

trenching between existing depot structures and the storage buildings and between the storage buildings to 

install utilities and other systems (e.g., fire suppression). The depth of excavation required would be about 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–62

0.6 meters (2 feet) wide by 1.2 meters (4 feet) deep, where necessary for utility trenching, and geologic 

resource requirements would likely be a fraction of the 4,740 cubic meters (6,200 cubic yards) of concrete 

and 3,900 cubic meters (5,100 cubic yards) of gravel required for a new storage facility (see Appendix C, 

Table C–2). 

Soil disturbance for utility trenching and to areas outside the perimeter of the storage buildings to support 

upgrades to flooring inside the facilities would be minimal. Nevertheless, adherence to standard best 

management practices for soil erosion and sediment control (e.g., use of sediment fencing, staked hay 

bales, mulching and geotextile matting, and rapid reseeding) in of any disturbed areas would serve to 

minimize any soil erosion and loss. There would be no additional impact on geology and soils from 

operations. 

4.5.2.2 Geologic Hazards 

Hazards from large-scale geologic conditions, such as earthquakes, and other site geologic conditions with 

the potential to affect Hawthorne Army Depot are summarized in Chapter 3, Section 3.4.2.3. The region 

surrounding the depot is one of high seismicity. The Walker Lake Valley, in which the depot is located, is 

bisected by an active fault, part of the regional Walker Lake fault zone (see Chapter 3, Section 3.4.2.1). 

While the Hawthorne area has historically experienced ground shaking of MMI VIII (see Appendix B, 

Table B–4), no depot facilities have suffered structural damage due to earthquakes during over 60 years of 

operations. Nevertheless, the predicted peak ground acceleration at the site from an earthquake with an 

annual probability of occurrence of 1 in 2,500 is 0.57 g. Ground motion in this range could cause 

considerable damage to ordinary substantial buildings, although it is only expected to cause slight damage 

to specially designed structures. This magnitude of ground motion is also supported by the historical 

record for the area. As further described in Appendix B, Section B.3.2, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, or upgraded as 

necessary, and operated so that the public, workers, and environment are protected from adverse impacts 

of natural phenomena hazards, including earthquakes. Upgrade and modification of existing storage 

facilities in the Central Magazine Area would include retrofits to flooring to contain any mercury spills, 

should they occur (see Appendix C, Table C–1). However, the original construction of the structures is 

particularly unique in that the facilities are constructed of reinforced concrete and are designed to be 

resistant to accidental detonation of ammunition. Such facilities would be unlikely to collapse or be 

destroyed by the maximum predicted earthquake ground motion at the site, even without structural 

upgrade. Thus, such ground motion would be unlikely to cause a breach in mercury containers from 

structural failure. 

An analysis of potential environmental consequences resulting from an earthquake-induced accident is 

described in Section 4.5.9.2. 

4.5.3 Water Resources 

4.5.3.1 Surface Water 

Building upgrades and modifications in the Central Magazine Area would not have any impact on surface 

water features. The closest natural surface water features are ephemeral streams that flow into Walker 

Valley from the mountains to the north of the Central Magazine Area. The closest surface drainage 

feature is the Pamlico Ditch, a runoff diversion ditch located approximately 0.6 kilometers (0.4 miles) 

south of the southern end of the designated DOE mercury storage area. 

Walker Valley is extremely arid, and stormwater runoff from the work sites in the Central Magazine Area 

would be unlikely to reach any ephemeral drainages on the valley floor or Pamlico Ditch. Regardless, 

appropriate soil erosion and sediment control measures and spill prevention and waste management 

practices would be employed to minimize suspended sediment, the transport of other deleterious materials, 
Environmental Consequences 

4–63

and potential water quality impacts, as noted in Section 4.3.3.1. As necessary, an NPDES Construction 

Stormwater General Permit would be obtained from the Nevada Division of Environmental Protection. 

Water requirements to support building modifications and upgrades at Hawthorne Army Depot would be 

relatively small. Some water may be necessary for dust control and soil compaction, for utility trenching, 

and to support floor repairs within the existing storage structures, but the volume would be very small 

compared with that required for construction of a new mercury storage facility. It is anticipated that any 

water would be trucked to the work areas on an as-needed basis. During operations, it is expected that 

water use would be relatively small under normal operations and limited to that required to serve the 

potable and sanitary needs of the storage facility workforce. Total annual consumption is estimated to be 

no more than about 88,500 liters (23,375 gallons). Depending on the number of personnel drawn from the 

existing depot workforce, water use by dedicated mercury storage facility staff could be greatly reduced. 

These construction and operations volumes are very small compared with the volume of surface water and 

supplemental groundwater currently withdrawn and used by Hawthorne Army Depot (see Section 4.5.7.2). 

As previously noted in Section 4.3.3.1, design, construction, and operation of the mercury storage facility 

would incorporate structural controls and practices to prevent the release of elemental mercury and to 

prevent any spills or other releases, should they occur as a result of abnormal operating conditions, from 

reaching soils or surfaces where they could be conveyed to surface waters or groundwater. The existing 

storage facilities in the Central Magazine Area would be modified as necessary to meet these 

requirements, as summarized in Appendix C, Table C–1. Facility operations would be conducted in 

accordance with an ICP and SPCC plan, or equivalent plans as mandated by state requirements governing 

the site, which set forth the actions facility personnel would take to respond to fires, explosions, or any 

accidental release of mercury to air, soil, or surface water at the facility. 

The 29 storage structures are not located within or adjacent to a 100-year floodplain and the storage area is 

not subject to stream flooding. Some portions of the depot facility complex are subject to periodic flash 

flooding. A runoff diversion ditch (Pamlico Ditch) and flood levee are located approximately 

0.6 kilometers (0.4 miles) south of the southern end of the designated DOE mercury storage area. These 

are designed to capture and redirect any substantial runoff moving northwest across the valley floor and 

across the southern portion of the Central Magazine Area. DOE Order 420.1B and its companion guide 

(DOE Guide 420.1-2) require that DOE facilities be designed, constructed, and operated to protect the 

public, workers, and environment from natural phenomena hazards, including flooding, and specifically to 

adhere to the flood design and evaluation criteria specified in DOE Standards 1020-2002 and 1023-95. 

The potential for sheet flooding and other precipitation effects (e.g., scour and erosion) would be 

accounted for in the modification of the 29 structures composing the storage facility. Consequently, the 

upgraded mercury storage buildings at the Hawthorne Army Depot would incorporate appropriate 

stormwater management controls to safely collect and convey stormwater from the facility while 

minimizing washout, soil erosion, and offsite water quality impacts. 

There would be no direct discharge of effluents to either surface water or groundwater from storage 

facility operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) 

would be generated and managed via either the depot’s existing sanitary waste system or a new sanitary 

waste disposal system permitted by the State of Nevada (see Section 4.5.8). 

4.5.3.2 Groundwater 

Storage building modifications are not expected to have any impact on groundwater hydrology or existing 

contaminant plumes at the Hawthorne Army Depot, as the depth to groundwater is 60 meters (200 feet) or 

more across the southern portion of the depot. As the facility would be designed and operated to prevent 

any spills from reaching the ground, there would be no impact on groundwater from routine operations. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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4.5.4 Meteorology, Air Quality, and Noise 

4.5.4.1 Meteorology 

Meteorological events can result in damage to buildings such as mercury storage warehouses. The 

frequency and consequences of such events were considered in selecting the accident events evaluated in 

Section 4.5.9.2. As previously detailed and described in Section 4.3.4.1, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so 

that the public, workers, and environment are protected from adverse impacts of natural phenomena 

hazards, including meteorological events. RCRA-permitted facilities, such as the proposed mercury 

storage facility, must also meet applicable design, construction, and operation requirements under 

Title 40 of the CFR, Section 264.31 and applicable state RCRA requirements to prevent the release of 

stored wastes. As the Hawthorne region is susceptible to regular occurrence of high winds, mercury 

would be housed in structures modified to withstand the potential for high winds and other meteorological 

events, such as heavy snow. 

4.5.4.2 Air Quality 

Negligible-to-very-minor short-term air quality impacts with little or no measurable effect on air quality 

would result from modification of existing structures for mercury storage in the Central Magazine Area. 

Criteria and toxic air pollutant emissions from construction equipment (see Appendix C, Section C.2.3) 

would be limited to those from construction employee vehicles and work trucks; little or no heavy 

equipment is expected to be used. 

Emissions from operation of the 29 storage facilities in the Central Magazine Area would be very small, 

consisting of emissions from employee vehicles, trucks or trains, semiannual testing of emergency 

generators, and possibly mercury vapor from any spills or from mercury containers. No localized 

emissions from space heating are anticipated associated with mercury storage facility operations, as 

electric heating is anticipated for areas requiring climate control. Compliance with the conformity 

regulations is discussed in Appendix B, Section B.5.1.2. 

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

elemental mercury vapor escaping from storage containers or residual contamination. Mercury vapor 

transported downwind could then be inhaled by noninvolved workers (those outside the storage facility) or 

nearby offsite individuals. Appendix D, Section D.4.1, presents a conservative analysis that shows that for 

a long-term, undetected slow leak inside the proposed mercury storage facility, the predicted long-term 

average concentration in the building wake never exceeds 80 nanograms per cubic meter. The EPA 

threshold for chronic exposure to airborne mercury is 300 nanograms per cubic meter, so slow releases of 

mercury would have a negligible effect on noninvolved workers and the public, with a corresponding 

negligible risk. 

Air quality impacts from transportation of mercury to Hawthorne Army Depot would be similar to those 

discussed in Section 4.3.4.2. Truck and rail transport are discussed in more detail in Section 4.5.9.3. 

Estimated emissions from truck and rail transportation are presented in Tables 4–15 and 4–16. 

Annual carbon dioxide emissions would be highest during the year 2013, at approximately 367 metric tons 

(405 tons) per year, as a result of moving elemental mercury to the site by truck; these annual truck 

emissions would be greater than rail emissions from shipping mercury. As similarly noted in 

Section 4.3.4.2, such emissions would minimally add to global and U.S. annual emissions of carbon 

dioxide. Global climate change is further discussed in Section 4.11.4.2. 
Environmental Consequences 

4–65

4.5.4.3 Noise 

Short-term noise impacts at the Hawthorne Army Depot could result from modification of the existing 

storage buildings for mercury storage. These impacts would include an increase in traffic to the site and 

an increase in noise resulting from construction equipment. These impacts would occur during the 

6-month construction period. Since the nearest noise-sensitive receptor, a residence, is located 

4.9 kilometers (3 miles) from the site, the increase in noise levels at this location from construction 

equipment is expected to be negligible. The estimated average noise level during the daytime (8-hour 

equivalent sound level) from one item of construction equipment operating at this distance is estimated to 

be 4 dBA, which would be well below the background sound level. The increase in traffic noise levels 

along U.S. Route 95 from construction activity is expected to be less than 1 dBA since the increase in 

traffic resulting from construction would be much less than the existing traffic on U.S. Route 95. 

Short-term noise impacts could occur along U.S. Route 95 as a result of increased truck activity during the 

period that elemental mercury is transported to the site. The resulting increase in day-night average noise 

levels along U.S. Route 95 is expected to be less than 1 dBA. As such, the change in truck traffic is not 

expected to result in a change in noise levels along this route or other shipping routes that would be 

noticeable to the public or result in an increase in annoyance. If the mercury is shipped by rail instead of 

by truck, some additional rail activity from placing railcars at the site could result in some increase in 

noise levels near the site. 

Operation of the mercury storage facility at the Hawthorne Army Depot is expected to have a negligible 

impact on noise levels around the site since the noise sources would be limited to a few employee 

vehicles, occasional delivery trucks, and semiannual testing of the emergency generator. 

4.5.5 Ecological Resources 

4.5.5.1 Terrestrial Resources 

Habitat in the immediate vicinity of the Central Magazine Area consists of disturbed land within a 

developed setting. Little native vegetation remains within the area of the 29 structures designated for the 

proposed mercury storage facility. Since existing structures would be used for mercury, no new land or 

habitat would be disturbed under this alternative. Adherence to best management practices for land cover 

management (e.g., washing down construction equipment and vehicle tire treads) would serve to reduce 

the chance of introducing invasive plant species. Impacts on animals from construction would be limited 

to species adapted to human disturbance. During operations, there would be no additional impacts on 

terrestrial resources, as temporarily disturbed areas beyond the facility footprint would be revegetated 

and/or would revert to more-natural conditions. 

4.5.5.2 Wetlands and Aquatic Resources 

No wetlands or aquatic resources exist within the area of the proposed mercury storage facility within the 

Central Magazine Area. Therefore, no impacts on wetlands or aquatic habitats are expected. 

4.5.5.3 Threatened and Endangered Species 

No threatened or endangered species are known or are expected to exist within the area of the proposed 

mercury storage facility within the Central Magazine Area. Thus, no impacts on threatened or endangered 

species are expected from facility modifications or operations. Consultations have been initiated with the 

appropriate U.S. Fish and Wildlife Service office and state wildlife agency to support this analysis 

(see Chapter 5, Section 5.4). 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–66

4.5.6 Cultural and Paleontological Resources 

4.5.6.1 Prehistoric Resources 

Previous surveys have identified 15 prehistoric sites at the Hawthorne Army Depot that are designated for 

listing in the NRHP. Additional archaeological sites were identified on property adjacent to the depot 

(see Chapter 3, Section 3.4.6.1). Since the structures that may be used for mercury storage are located on 

property that has been disturbed by construction, it is unlikely that any prehistoric resources would be 

impacted. DOE has initiated consultation with the Nevada SHPO to support this analysis (see Chapter 5, 

Section 5.4). 

4.5.6.2 Historic Resources 

An NRHP nomination for architectural resources was drafted for Hawthorne Army Depot in 1989 for its 

significance as the largest depot in the world; its importance in World War II; and its integrity of 

landscape, infrastructure, and architecture (see Chapter 3, Section 3.4.6.2). As there would be no new 

construction and the existing structures that may be used for mercury storage are located on property that 

has been disturbed by construction, it is unlikely that any historic resources would be impacted. However, 

as some modification of existing structures is likely, DOE has initiated consultation with the Nevada 

SHPO (see Chapter 5, Section 5.4). 

4.5.6.3 American Indian Resources 

The Walker River Indian Reservation is located approximately 13 kilometers (8 miles) north of the 

Hawthorne Army Depot (see Chapter 3, Section 3.4.6.3). As no new construction would be required, no 

impact on American Indian resources is expected. However, DOE has initiated consultation with the 

Walker River Paiute Tribe (see Chapter 5, Section 5.4). 

4.5.6.4 Paleontological Resources 

There would be no impact on unique paleontological resources at Hawthorne Army Depot as none have 

been identified; construction activity at the site would be limited to completing of modifications of 

existing storage facilities on already disturbed land. 

4.5.7 Site Infrastructure 

4.5.7.1 Ground Transportation 

Construction and operations of a new mercury storage facility at the Hawthorne Army Depot are not 

expected to appreciably increase demands on the road and rail systems leading to the site. Projected peak 

traffic volumes and the number of shipments associated with mercury storage operations are presented in 

Section 4.5.11. 

4.5.7.2 Electricity, Fuel, and Water 

Utility resource demands and associated assumptions to establish and operate a mercury storage facility at 

the Hawthorne Army Depot would generally be similar to those described in Section 4.3.7.2. However, 

construction requirements would likely be less than those at GJDS, as activities would be limited to 

modifying, upgrading, and refurbishing the existing structures. Conversely, utility demands such as 

electricity consumption for operation of the 29 storage buildings modified for mercury storage could be 

slightly greater than those for a single, new storage facility. Nevertheless, for electrical energy, annual 

electricity consumption at Hawthorne Army Depot is 7 percent of its sitewide capacity (see Chapter 3, 

Section 3.4.7). The projected annual operational electricity requirements to support mercury storage 
Environmental Consequences 

4–67

(253 megawatt-hours) would be minor (3.4 percent increase) when compared with the current annual 

sitewide electricity usage, and would be about 0.2 percent of the annual sitewide electric supply capacity. 

Fuel oil is the main liquid fuel used at Hawthorne Army Depot; fuel consumption (606 liters 

[160 gallons]) for the operation of buildings in the Central Magazine Area for mercury storage would be 

negligible (0.02 percent) when compared with the depot’s annual consumption of fuel oil. 

Water requirements for facility modifications and mercury storage operations in the Central Magazine 

Area would be negligible compared with the Hawthorne Army Depot’s sitewide water usage and capacity 

(see Chapter 3, Section 3.4.7). Water requirements for facility modifications (of less than 1,270,000 liters 

[336,000 gallons]) would temporarily increase annual sitewide water consumption by no more than 

0.4 percent. The annual water demand for mercury storage operations (88,500 liters [23,400 gallons]) 

would constitute about 0.03 percent of the depot’s consumption and 0.004 percent of the site’s total water 

production capacity. 

4.5.8 Waste Management 

Waste generation associated with modification of existing facilities to support operation of a new mercury 

storage facility at Hawthorne Army Depot would be similar to that discussed in Section 4.3.8. 

Modification of 29 of the depot’s storage buildings is expected to generate much less than the 271 cubic 

meters (355 cubic yards) of nonhazardous solid waste and 9,850 liters (2,600 gallons) of nonhazardous 

sanitary liquid waste projected to be generated during construction of a new facility. Nevertheless, the 

maximum volumes are negligible compared with the current waste generation activities at the depot, as 

described in Chapter 3, Section 3.4.8.1. If approved, construction-generated solid waste would be 

disposed of within the onsite state-permitted construction and demolition landfill. Portable toilet facilities, 

serviced by a local or regional contractor, would be used to serve the sanitary needs of the construction 

workforce. 

Operation of the existing structures, as modified for mercury storage, within the Central Magazine Area is 

expected to generate an estimated 910 55-gallon (208-liter) drums of hazardous waste over the 40-year 

period of analysis, as further described in Section 4.3.8. This equates to about 23 55-gallon drums, or 

approximately 5 cubic meters (6.5 cubic yards) annually. This estimated yearly hazardous waste 

generation rate is minor (about 2 percent) compared with the 47,442 kilograms (104,590 pounds) of 

hazardous waste managed each year by the Hawthorne Army Depot (see Chapter 3, Section 3.4.8.1). The 

Hawthorne Army Depot is a listed hazardous waste large-quantity generator. No changes in generator 

status would be required to operate the proposed mercury storage facility, nor are any substantial effects 

on the depot’s waste management infrastructure expected. Further, the Hawthorne Army Depot has 

existing plans and procedures for site-specific management of mercury-contaminated materials (Tetra 

Tech 2007). Existing storage buildings modified for mercury storage would require an RCRA TSD 

facility permit. 

Facility operations would also generate an estimated 59,000 liters (15,600 gallons) of nonhazardous 

sanitary waste annually. This yearly generation rate of is very small (0.2 percent) compared with the 

depot’s average sanitary waste generation rate of 34.5 million liters (9.1 million gallons) 

(DLA 2004a:3-74). Sanitary wastewater would be discharged to the depot’s sanitary sewer system. 

Waste management activities at Hawthorne Army Depot include ongoing munitions recycling activities 

and RCRA-based remediation investigations. Neither facility modifications nor operation of the proposed 

mercury storage facility is anticipated to impact site resources (e.g., funding, labor, facilities, and 

equipment) associated with current and/or future site environmental restoration efforts. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–68

4.5.9 Occupational and Public Health and Safety 

The analysis of risk at the Hawthorne Army Depot is similar to that presented in Sections 4.2.9.1 through 

4.2.9.5. Mercury at Hawthorne Army Depot would not be stored in a single, large building, but in up to 

29 buildings with dimensions of approximately 61 meters (200 feet) long, 15 meters (50 feet) wide, and 

12 meters (39 feet) high (see Appendix D, Table D–51). However, this difference in dimensions does not 

change the generic conclusions about human health risks. 

4.5.9.1 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites. Consequences to the involved worker are predicted to be negligible 

because involved workers would never be exposed to airborne concentrations of mercury vapor above the 

ACGIH’s 8-hour TWA/TLV of 0.025 milligrams per cubic meter of mercury vapor. This corresponds to 

keeping exposures to the involved worker in the SL-I (negligible) range.19 This would be achieved by 

adherence to good operating practices, in particular attention to ventilation, inspection, monitoring, and 

use of PPE, as described in the Interim Guidance (DOE 2009c). Therefore, the risks to involved workers 

would be negligible during normal operations. 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 

3-L flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this source 

of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building wake. 

Appendix D, Section D.4.1.2, shows that the predicted long-term average concentration in the building 

wake for existing buildings is about 8.0 × 10-5 milligrams per cubic meter. This is well below EPA’s 

chronic-inhalation-exposure RfC of 3.0 × 10-4 milligrams per cubic meter. Hence, consequences would be 

in the SL-I range, and the risk to both noninvolved workers and the public would be negligible. 

4.5.9.2 Facility Accidents 

Section 4.2.9.1.4 provides a discussion of facility accident risks that applies to all sites. Table 4–3 

contains a summary of the likelihood of occurrence of candidate facility accident scenarios initiated by 

failures of engineered systems, human errors, or external events, and Table 4–4 lists the accident scenarios 

that remain for consequence analysis after eliminating those with negligible frequency from Table 4–3. 

The analysis of the scenarios at the Hawthorne Army Depot is similar to that for the same scenarios in 

Section 4.2.9.1.4. The different dimensions of the buildings affect the building wake calculations, but do 

not affect conclusions about the magnitude of the risks. For a member of the public in the case of an 

outside earthquake spill, the rate of evaporation calculated for Hawthorne Army Depot is somewhat larger 

than that for new construction (because of the somewhat greater floor space available in the 29 separate 

buildings at the Hawthorne Army Depot). The atmospheric dispersion calculations show that, for this 

spill, the maximum distance downwind to which a concentration greater than AEGL-3 could be exceeded 

is less than 100 meters (330 feet); for AEGL-2, the corresponding distance is about 380 meters 

(1,250 feet); and for 0.1 × AEGL-2, it is approximately 1.6 kilometers (1 mile). However, the distance to 

the closest site boundary from the proposed mercury storage facilities is 3.7 kilometers (2.3 miles), so 

consequences and hence risks to members of the public would be negligible. Table 4–31 summarizes the 

results for all accidental spills of elemental mercury on site (without fire). 

 

19 For definitions of SLs for various types of exposures, see Section 4.2.9.1.1 and Appendix D, Section D.1.1.1. For a discussion 

of how risk is assessed, see Sections 4.2.9.1.1 and D.1.1.2. 
Environmental Consequences 

4–69

Table 4–31. Summary of Risks of all Onsite Elemental Mercury 

Spill Scenarios – Hawthorne Army Depot 

Scenario Frequency Consequence Risk 

Spills Inside Buildinga

Involved worker FL-II – FL-III SL-I – SL-II N–L for all inside spills 

Noninvolved worker FL-II – FL-III SL-II N for all inside spills 

Member of the public FL-II – FL-III SL-II N for all inside spills 

Spills Outside Building 

Involved worker FL-II – FL-III SL-I – SL-II 

Noninvolved worker FL-II – FL-III SL-I – SL-II 

N–L for outside earthquake 

spill; N for all other outside 

spills 

Member of the public 

1-metric-ton container spill FL-II SL-I N 

Single-pallet spill FL-III SL-I N 

Earthquake with building 

collapseb

FL-III SL-I N 

a The inside spill scenarios considered are single flask, single pallet, triple pallet, 1-metric-ton container, full spill tray under a 

pallet, and earthquake with intact building walls. 

b This scenario encompasses the risk from floods, high winds, and tornadoes. 

Key: FL=frequency level; L=low; N=negligible; SL=severity level. 

4.5.9.3 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury over a 40-year period of analysis to the Hawthorne 

Army Depot. These assumptions, together with knowledge of truck routes and historical frequencies of 

crashes of various types, can be combined to produce estimates of the frequency at which crashes might 

occur anywhere along the routes traveled by mercury trucks or railcars. The results of the analysis are 

shown in Table 4–32. 

Table 4–32. Frequency Analysis of Truck and Railcar Accidents – Hawthorne Army Depot 

Scenario 

Truck 

Miles 

Frequency of 

Accidents 

(per year) 

Frequency of 

Accidents with 

Spills (per year) 

Frequency of 

Accidents with 

Fires in Dry 

Weather 

(per year) 

Frequency of 

Accidents with 

Fires in Wet 

Weather 

(per year) 

Frequency of 

Accidents with 

Deatha 

(per year) 

1,161,577 1.3×10-2 2.3×10-3 1.9×10-4 6.1×10-6 6.5×10 Truck – -4

Scenario 1 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III 

1,943,587 1.8×10-2 3.8×10-3 3.1×10-4 9.9×10-6 1.1×10 Truck – -3

Scenario 2 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III 

394,922 2.5×10-3 1.1×10-5 2.6×10-5 8.3×10-7 1.6×10 Railcar -4

– Moderate – FL-III Low – FL-II Low – FL-II Negligible – FL-I Moderate – FL-III 

a Fatality caused by mechanical impact, not by exposure to mercury. 

Note: To convert miles to kilometers, multiply by 1.60934. 

Key: FL=frequency level. 

The above frequencies are for an accident anywhere along any of the transportation routes taken over a 

40-year period of analysis to the Hawthorne Army Depot. A crash that occurs in the last mile of the trip 

was used to estimate the frequency of an onsite crash in the vicinity of the storage building. The 

frequency of such accidents with spills would be low under both truck scenarios and negligible under the 

Railcar Scenario. The frequency of crashes with fires or death would be negligible under all scenarios. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–70

Specific to the routes to the Hawthorne Army Depot, the length of road or railroad that lies within the 

Walker River Indian Reservation is about 32 kilometers (20 miles).20 This is about 1 percent of the 

average length of a truck or rail route to the Hawthorne Army Depot. Therefore, the frequencies of the 

various types of spills or fires in Table 4–32 should be multiplied by 0.01 to obtain the predicted 

frequencies of accidents with spills on the reservation; doing so yields the following: 

 The frequency of all railcar spills would be negligible (FL-I), with the result that the associated 

risk would always be negligible. 

 Under the truck scenarios, the frequencies of spills with fires in wet weather would be negligible 

(FL-I) and so would the associated risks. 

 Under the truck scenarios with spills of elemental mercury with or without fire, the frequencies 

would be low (FL-II). 

With respect to transportation accidents involving spills of mercury, the following four scenarios were 

considered: 

 Spill of elemental mercury onto the ground without fire 

 Spill of elemental mercury directly into water 

 Fire with mercury spill 

 In dry weather 

 In wet weather 

4.5.9.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground 

Section 4.2.9.1.5 contains an analysis of spills of elemental mercury onto the ground following a truck or 

railcar crash without fire. A conservative estimate of the rate of evaporation from the resulting pool and 

the subsequent atmospheric dispersion (applicable to all sites) shows that a specific individual could not be 

exposed to concentrations that are greater than negligible if he or she lives more than 340 meters 

(1,115 feet) from a crash. Conservatively, assuming that the individual lives immediately adjacent to the 

road, that individual could only be exposed to such concentrations if the crash occurs along a specific 

680-meter (2,230-foot) stretch of any of the routes to the Hawthorne Army Depot. The same reasoning as 

is used in the generic discussion in Section 4.2.9.1.5 shows that the risk to a member of the public from 

transportation spills onto the ground without fire en route to the Hawthorne Army Depot would be 

negligible under Truck Scenario 1 and the Railcar Scenario, but low under Truck Scenario 2. 

4.5.9.3.2 Transportation Accident with Spill of Elemental Mercury Directly into Water 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to humans (inorganic compounds of mercury and 

methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

 

20 Information from www.nevadadot.com. 
Environmental Consequences 

4–71

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

Table 4–33 summarizes the risks to human receptors arising from spillages of elemental mercury during 

transportation to the Hawthorne Army Depot. 

Table 4–33. Summary of Transportation Risks to Human Receptors, Spills of Elemental Mercury 

onto the Ground or into Water, Hawthorne Army Depot 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto the Ground 

Frequencya, b FL-I FL-II FL-I 

Consequence SL-II SL-II SL-II 

Risk Negligible Low Negligible 

Spill into Water 

Frequencyc, d FL-III FL-III FL-II 

Consequence SL-I–SL-II SL-I–SL-II SL-I–SL-II 

Riske Negligible to low Negligible to low Negligible to low 

a Frequency at which spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded. 

b For spills on the Walker River Indian Reservation, all of these frequencies would be FL-I, and the risks would be negligible. 

c Frequencies of railcar or truck crashes with spills from Table 4–32. 

d These estimates of risk are subject to large uncertainty. 

e For spills on the Walker River Indian Reservation, the frequency of spills into water bodies would be negligible and so would 

the associated risks. 

Key: FL=frequency level; SL=severity level. 

4.5.9.3.3 Transportation Accident with Fire 

The fire calculations are described in Section 4.2.9.1.5. Table 4–34 shows the results of the calculations 

of acute-inhalation risks from transportation accidents with fires on transportation routes to the Hawthorne 

Army Depot. The table encompasses both truck scenarios and the Railcar Scenario. 

Table 4–34. Summary of Acute-Inhalation Risks to Human Receptors, Accidents with Fires, 

Transportation Routes to Hawthorne Army Depot 

Both Truck Scenarios with Wooden Pallets Railcar Scenario with Wooden Pallets 

Frequencya FL-IIIc FL-IId

Consequenceb SL-II FL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7. 

b The highest consequence in any weather condition. 

c For spills on the Walker River Indian Reservation, this frequency would be FL-II, and the risks would be low. 

d For spills on the Walker River Indian Reservation, the frequency of this scenario would be FL-I, and the risks would be 

negligible. 

Key: FL=frequency level; SL=severity level. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–72

Note that the risks presented in the above scenarios are individual risks: they are the answer to the 

question, “What is the risk to me?” This is not the same as the risk that, somewhere along a transportation 

route, airborne concentrations would exceed the various SLs. Those risks would in fact be higher. 

The analyses performed for this EIS show that, under all fire scenarios listed in Table 4–34, with and 

without rain, mercury deposited on the ground would never cause the benchmark of 180 milligrams per 

kilogram to be exceeded. Therefore, the corresponding risks would be negligible. 

Table 4–35 summarizes the human health risks associated with all transportation spills. 

Table 4–35. Summary of Transportation Risks to Human Receptors, Hawthorne Army Depota

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto ground Negligible Low Negligible 

Spill into water Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Spill with fire – 

inhalation, wooden pallets 

Low Low Low 

Spill with fire – dry and 

wet deposition, wooden 

pallets 

Negligible Negligible Negligible 

a Does not include risks of spills on the Walker River Indian Reservation (see Tables 4–33 and 4–34). 

4.5.9.4 Intentional Destructive Acts 

The discussion of IDAs is the same for all sites and transportation routes (see Section 4.2.9.1.6). 

4.5.10 Ecological Risk 

There is a generic analysis of ecological risk in Section 4.2.10.1, which applies without modification to the 

Hawthorne Army Depot. 

4.5.10.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike inorganic compounds 

formed from divalent mercury. As a result, risks to ecological receptors from slow leaks, accidental spills 

at storage sites, and spills without fires during transportation are considered to be negligible at all storage 

sites and along all transportation routes. 

4.5.10.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 

which also makes the following conclusions regarding the consequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 
Environmental Consequences 

4–73

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

ecological receptors could be managed so that they are negligible or low. Given this assumption and the 

fact that the frequency of crashes with spills on any of the transportation routes is no more than moderate 

(and this is an upper bound on the frequency of spills directly into water), the risk would be negligible or 

low for all transportation routes. However, because of the above-mentioned uncertainty about fastflowing rivers, this observation should be tempered by noting that the uncertainty regarding this prediction 

of risk is very large. 

4.5.10.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5, and 

Section 4.2.10.1. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. Table 4–36 summarizes the FL, consequence level, and risk to ecological receptors in the 

case of a truck crash with a pallet fire and no rain (dry deposition) and applies to all candidate storage 

sites. 

Table 4–36. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, Hawthorne Army Depota

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Level Riskc

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a For spills on the Walker River Indian Reservation, the frequency level would be FL-II. The risks to sediment-dwelling 

biota and soil invertebrates would be moderate; the risks to all other receptors would not change. 

b Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

c Applies to both Truck Scenarios 1 and 2. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–74

For the interpretation of Table 4–36, see Section 4.2.10.1.3. The risks of other potential fire scenarios are 

summarized as follows: 

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–37. 

 For railcar crashes with wooden pallet fires and without rain (dry deposition), see Table 4–38. 

 The predicted frequency of railcar crashes with pallet fires and rain is negligible, so risks would 

be negligible and no summary table is presented. 

Table 4–37. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, Hawthorne Army Depota

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Level Riskc

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a For spills on the Walker River Indian Reservation, the frequency level would be FL-I, and the risks to all receptors would 

be negligible. 

b Frequencies of truck crashes with spills from Appendix D, Table D–16. 

c Applies to both Truck Scenarios 1 and 2. 

Table 4–38. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, Hawthorne Army Depota

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Level Risk

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a For spills on the Walker River Indian Reservation, the frequency level would be FL-I, and the risks to all receptors would 

be negligible. 

b Frequencies of railcar crashes with fires from Appendix D, Table D–14. 

4.5.10.4 Consequences – Intentionally Initiated Fire with Mercury Spill 

The consequences of intentionally initiated fires to ecological receptors are the same for all sites (see 

Section 4.2.10.1.4). 

4.5.11 Socioeconomics 

Under this alternative, existing storage facilities (igloos) in the Hawthorne Army Depot’s Central 

Magazine Area would be modified for long-term storage of elemental mercury. Employment during 
Environmental Consequences 

4–75

renovations is expected to be less than that estimated for constructing a new facility, as described in 

Section 4.3.11. Appendix C, Table C–1, summarizes the necessary modifications to bring the existing 

storage buildings at Hawthorne Army Depot up to specifications to support mercury storage. Operation of 

the facility 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 approximately 

5 individuals thereafter, resulting in a possible increase in the depot’s workforce of approximately 1 to 

2 percent and an increase in the ROI workforce of 0.02 percent. Neither modification nor operation of the 

storage buildings is expected to generate substantial new, direct or indirect employment. Thus, negligible 

impacts on socioeconomic conditions (i.e., overall employment, population trends, and traffic) in the ROI 

would result from implementing this alternative. 

Construction-related transportation needed to modify the existing facility, including employee vehicle 

trips and equipment and materials shipments, is not expected to adversely impact traffic conditions on 

roads leading to the site. It is likely that significantly fewer than the 45 vehicles a day estimated for 

construction of a new mercury storage facility would be needed to support facility modification 

(see Section 4.3.11). Therefore, construction-related transportation is expected to increase the average 

annual daily traffic count on U.S. Route 95 by no more than 2 percent. 

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of mercury to the site for storage. Appendix C, Section C.1, provides an estimate of the number of 

shipments by truck. The additional vehicles due to facility operation are not expected to noticeably 

increase traffic volumes on roads leading to the site. The greatest impact would be during the first 2 years 

of operations, when it is estimated that approximately 11 vehicles a day could increase the average annual 

daily traffic count on U.S. Route 95 by less than 0.5 percent. During this time, it is estimated that up to 

78 shipments would be made each year. Approximately 96 percent of the additional vehicles would be 

attributed to employee transportation. 

4.5.12 Environmental Justice 

None of the block groups within the 16-kilometer (10-mile) radius surrounding the proposed storage site 

at the Hawthorne Army Depot contain a disproportionately high number of minority or low-income 

individuals, and no populations have been identified within the 3-kilometer (2-mile) radius surrounding 

the storage site (see Chapter 3, Section 3.4.11). Therefore, no disproportionately high and adverse effects 

on minority or low-income populations are expected. The Walker River Indian Reservation lies outside 

the 16-kilometer (10-mile) radius of the proposed storage site; however, transportation of mercury through 

the reservation is a consideration. Therefore, consultation has been initiated with the Walker River Paiute 

Tribe, as discussed in Section 4.5.6.3. 

4.6 LONG-TERM MERCURY MANAGEMENT AND STORAGE AT IDAHO 

NATIONAL LABORATORY 

Under this alternative, elemental mercury would be stored at DOE’s INL. INL is a 230,323-hectare 

(569,135-acre) area located in southeastern Idaho. Two options have been identified at 

INL: (1) construction of a new mercury storage facility within the Idaho Nuclear Technology and 

Engineering Center (INTEC) or (2) modification of existing waste storage facilities at the Radioactive 

Waste Management Complex (RWMC) to accommodate mercury storage. These options are further 

described in Chapter 2, Section 2.4.5. In the following sections, differences in potential impacts between 

the options are identified, where appropriate. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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4.6.1 Land Use and Visual Resources 

Idaho Nuclear Technology and Engineering Center Option 

Negligible impacts on land use and visual resources are expected from construction and operation of a 

new mercury storage building at INTEC at INL. Construction of this new facility would require the 

disturbance of approximately 3.1 hectares (7.5 acres) for building construction and laydown areas 

(see Chapter 2, Section 2.3.1). The proposed mercury storage facility would be located in the southeastern 

corner of INTEC. This area of INL is highly developed and has been subject to disturbance from past 

operations. The completed facility boundary would similarly encompass approximately 3.1 hectares 

(7.5 acres) within its fenced perimeter, which corresponds to approximately 3 percent of the land within 

INTEC. The footprint of the mercury storage building would occupy approximately 1.6 hectares 

(3.9 acres) of this area. Mercury storage operations would be compatible with DOE facility operations 

currently conducted within the INL Central Core Area. The low profile of the new building is not 

expected to affect the overall viewshed of this area from on- or offsite vantage points. Therefore, mercury 

storage operations would not result in a change to BLM VRM classifications. 

Radioactive Waste Management Complex Option

No additional impacts on land use or visual resources are anticipated from storing elemental mercury at 

RWMC at INL since no new construction or other substantial ground-disturbing activities would be 

required. Elemental mercury would be stored within seven existing RCRA-permitted modular buildings 

located along the eastern perimeter of RWMC; each building would provide approximately 2,700 square 

meters (29,000 square feet) of floor space. Collectively, these seven buildings would provide 

approximately 19,000 square meters (196,000 square feet) of space for DOE storage of elemental mercury. 

Receipt, staging, and storage activities would generally take place inside these storage modules and would 

not require the use of any additional site acreage, although some minor modifications to the existing 

buildings might be required (see Chapter 2, Section 2.4.5.2). Therefore, onsite land use would remain 

predominantly industrial, and viewsheds would not be affected. Scheduled maintenance and repairs to the 

storage buildings would be consistent with the existing land use and visual character of the site. Storage 

of elemental mercury is likewise not expected to affect offsite land uses and viewsheds from public 

vantage points in the vicinity of RWMC. Mercury storage operations would be compatible with DOE 

hazardous waste storage operations currently conducted in these buildings. Because there would be no 

change to the visual landscape as a result of this alternative, there would be no associated change in BLM 

VRM classifications. 

4.6.2 Geology, Soils, and Geologic Hazards 

4.6.2.1 Geology and Soils 

Idaho Nuclear Technology and Engineering Center Option

Construction of a new mercury storage facility in the southeastern portion of INTEC would generally have 

the same direct impacts on geology and soils in terms of land area disturbed, depth of excavation, and 

geologic resource demands as described in Section 4.3.2.1. Geologic resources, including concrete and 

coarse aggregate (gravel) totaling 8,640 cubic meters (11,300 cubic yards), would be required for 

construction (see Appendix C, Table C–2) and would be procured from local and/or regional commercial 

vendors. Trenching may be necessary to install foundation footings or to connect the new mercury storage 

facility with existing INTEC utilities. Areas within the INTEC perimeter have largely been disturbed by 

historical activities. Excavation at INTEC would encounter Big Lost River alluvium, composed of gravelsand-silt mixtures that are from 7.6 to 19.8 meters (25 to 65 feet) thick. Due to the relatively shallow 

depth of excavation and nature of the surficial geologic strata, it is not expected that basaltic bedrock 
Environmental Consequences 

4–77

would be encountered (see Chapter 3, Section 3.5.2). Nevertheless, a site survey and geotechnical study 

would be conducted to confirm site geologic characteristics for facility siting and engineering purposes. 

Natural and disturbed soils at INTEC could be more prone to erosion. However, adherence to standard 

best management practices for soil erosion and sediment control during construction would serve to 

minimize soil erosion and loss (see Section 4.3.2.1). 

Due to the potential risk of excavating contaminated soils, the construction area would also be surveyed 

prior to any ground disturbance. Any contamination would be remediated as necessary. During 

operations, the previously disturbed areas would not be subject to long-term soil erosion, and temporarily 

disturbed areas would be revegetated. There would be no additional impact on geology and soils from 

operations. 

Radioactive Waste Management Complex Option

Internal modifications of the existing storage modules would have a negligible impact on geology and 

soils, as activities would largely be limited to reinforcing the concrete floors of the existing structures. 

Some trenching could be necessary to upgrade or install utilities and other systems (e.g., fire suppression). 

Any contamination would be remediated as necessary. The depth of excavation required would be about 

0.6 meters (2 feet) wide by 1.2 meters (4 feet) deep, where necessary for utility trenching. If necessary, 

trenching could encounter basaltic bedrock, as surface sediments vary in thickness from about 0.6 to 

7 meters (2 to 23 feet). A site survey and geotechnical study would be conducted to confirm site geologic 

characteristics for facility siting and engineering purposes. Geologic resource requirements would likely 

be a fraction of the volume required for a new storage facility. 

Soil disturbance for utility trenching and to areas outside the perimeter of the existing storage modules to 

support upgrades to flooring inside the facilities would be minimal. Nevertheless, adherence to standard 

best management practices for soil erosion and sediment control (e.g., use of sediment fencing, staked hay 

bales, mulching and geotextile matting, and rapid reseeding) in any disturbed areas would serve to 

minimize any soil erosion and loss. 

4.6.2.2 Geologic Hazards 

Hazards from large-scale geologic conditions, such as earthquakes, and other site geologic conditions with 

the potential to affect INL facilities would be substantially similar for INTEC and RWMC, as summarized 

in Chapter 3, Section 3.5.2.3. Such conditions have been extensively evaluated in previous analyses. To 

be specific, the Eastern Snake River Plain, on which INL is situated, is a region of relatively low 

seismicity, although higher rates of seismic activity are indicated for regions in the surrounding Basin and 

Range Physiographic Province. The Arco Segment of the Lost River Fault terminates approximately 

32 kilometers (20 miles) to the west of INTEC. The Lost River Fault is considered to be capable or 

potentially active. Ground shaking of MMI VI has been reported on the site in the recent past, associated 

with a major earthquake epicenter in the Borah Peak Range northwest of INL and in association with the 

Lost River Fault. Otherwise, relatively few and minor earthquakes have occurred in the area surrounding 

INL. MMI VI shaking typically causes only slight damage to ordinary structures, while MMI VII shaking 

can cause moderate damage in well-constructed, ordinary structures but is not expected to damage 

facilities that have been specially designed or upgraded (see Appendix B, Table B–4). The predicted peak 

ground acceleration at the site from an earthquake with an annual probability of occurrence of 1 in 2,500 is 

0.12 g. Peak ground motion in this range is only expected to cause slight damage to ordinary structures 

and is consistent with effects at the site associated with historical activity in the Borah Peak Range. As 

further described in Appendix B, Section B.3.2, DOE Order 420.1B and its companion guide (DOE 

Guide 420.1-2) require that facilities be designed, constructed, upgraded as necessary, and operated so that 

the public, workers, and environment are protected from adverse impacts of natural phenomena hazards, 

including earthquakes. The Order also stipulates natural phenomena hazards mitigation for DOE facilities. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–78

In the case of existing RWMC storage modules, upgrades would include retrofits to flooring to ensure 

structural stability and floor coatings to prevent penetration of spills, should they occur (see Appendix C, 

Table C–1). Neither newly designed and constructed facilities nor the existing specially designed and 

upgraded RWMC facilities would be likely to suffer substantial structural damage from the maximum 

predicted earthquake ground motion at the site. Thus, predicted ground motion would be unlikely to cause 

a breach in mercury containers from structural failure. 

An analysis of potential environmental consequences resulting from an earthquake-induced accident is 

described in Section 4.6.9.2. 

Further, the volcanic hazard at INL has been extensively studied. The most recent eruptions within the 

INL area occurred about 2,100 years ago in an area 31 kilometers (19 miles) southwest of the site at the 

Craters of the Moon Wilderness Area. The estimated recurrence interval (repeat time) for volcanism 

associated with the five identified volcanic zones ranges from 16,000 to 100,000 years. As a result, 

volcanism is not expected to reoccur within the 40-year design life of the mercury storage facility. 

INL seismic stations are located near or within identified volcanic rift zones to provide early warning of 

any signs of renewed volcanic activity. 

4.6.3 Water Resources 

4.6.3.1 Surface Water 

Idaho Nuclear Technology and Engineering Center Option

Facility construction activities are not expected to have any direct impact on surface water features, 

including the Big Lost River. INTEC is situated on an alluvial plain with its northwestern corner located 

approximately 60 meters (200 feet) from the Big Lost River channel near the channel’s intersection with 

Lincoln Boulevard. However, the proposed new mercury storage facility site is situated approximately 

900 meters (3,000 feet) from the channel. INTEC is surrounded by a stormwater drainage ditch system 

that directs runoff from most areas to an abandoned gravel pit on the northeastern side of INTEC where it 

infiltrates into the subsurface. Facility construction would not impact these features. 

Stormwater runoff from the construction site would be unlikely to reach the Big Lost River, and 

appropriate soil erosion and sediment control measures and spill prevention and waste management 

practices would be employed to minimize suspended sediment, the transport of other deleterious materials, 

and potential water quality impacts, as noted in Section 4.3.3.1. At INL, all construction and other 

ground-disturbing activities would be conducted in accordance with the current NPDES General Permit 

for Storm Water Discharges from Construction Sites. Stormwater pollution prevention plans are 

completed for individual construction projects (see Chapter 3, Section 3.5.3.1). 

Construction activities would require as much as 1,270,000 liters (336,000 gallons) of water over the 

6-month construction period. This volume would primarily be required for dust control and soil 

compaction. It is anticipated that water would be trucked to the construction site and supplied from the 

INTEC water system. During operations, water use would generally be limited to that required to serve 

the potable and sanitary needs of the storage facility workforce. Total annual consumption is estimated to 

be no more than about 88,500 liters (23,375 gallons). Depending on the number of personnel drawn from 

the existing DOE workforce at INTEC, water use by dedicated mercury storage facility staff could be 

greatly reduced. These construction and operations volumes are relatively small compared with the 

volume of water currently withdrawn and used by DOE at INTEC (see Section 4.6.7.2). 

As previously noted in Section 4.3.3.1, design, construction, and operation of the mercury storage facility 

would incorporate structural controls and practices to prevent the release of elemental mercury and to 

prevent any spills or other releases, should they occur as a result of abnormal operating conditions, from 
Environmental Consequences 

4–79

reaching soils or surfaces where they could be conveyed to surface waters or groundwater. Facility 

operations would be conducted in accordance with an ICP and SPCC plan, or equivalent plans as 

mandated by state requirements governing the facility, which set forth the actions facility personnel would 

take to respond to fires, explosions, or any accidental release of mercury to air, soil, or surface water at 

the facility. 

While located at INTEC on an alluvial plain adjacent to the Big Lost River, there is no record of historical 

flooding at the site. The INL diversion dam was designed to secure INL facilities, including INTEC, from 

the 300-year flood, and the latest flood studies performed for the site indicate the potential for 

substantially less flooding at INL facilities than predicted by previous studies. Nevertheless, the analysis 

of the probable maximum flood, which included failure of Mackay Dam upstream of INL, predicts a peak 

surface water elevation at INTEC equal to the average elevation at that facility. This would flood INTEC 

and result in ponding in low-lying areas, although predicted flood velocities would be fairly slow and 

water depths shallow. This could impact certain facilities, with the greatest potential for impact in the 

northern part of INTEC (see Chapter 3, Section 3.5.3.1). The proposed location of the new mercury 

storage facility greatly minimizes the potential for flooding over the long term. DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that DOE facilities be designed, constructed, and operated 

to protect the public, workers, and environment from natural phenomena hazards, including flooding, and 

specifically to adhere to the flood design and evaluation criteria specified in DOE Standards 1020-2002 

and 1023-95. The potential for sheet flooding and other precipitation effects (e.g., scour and erosion) 

would be accounted for in the design and upgrade of foundations, walls, roof structures, and drainage and 

stormwater management systems for the storage facility. Consequently, the new mercury storage facility 

would incorporate appropriate stormwater management controls to safely collect and convey stormwater 

from the facility while minimizing washout, soil erosion, and offsite water quality impacts. 

There would be no direct discharge of effluents to either surface water or groundwater from storage 

facility operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) 

would be generated and managed via the existing INTEC sanitary waste system (see Section 4.6.8). 

Radioactive Waste Management Complex Option

Modification of the existing RWMC storage modules to support mercury storage would not have any 

impact on surface water features. The closest surface water features are the INL diversion spreading 

areas, located about 1.6 kilometers (1 mile) east of RWMC, and the Big Lost River channel, located 

approximately 3.2 kilometers (2 miles) southeast of RWMC. 

Appropriate soil erosion and sediment control measures and spill prevention and waste management 

practices would be employed to minimize suspended sediment, the transport of other deleterious materials, 

and potential water quality impacts. As under the INTEC Option, any exterior work that may be required 

would be subject to the current INL NPDES General Permit for Storm Water Discharges from 

Construction Sites. 

Water requirements to support modifications and upgrades at RWMC would be very small compared with 

those under the INTEC Option for construction of a new mercury storage facility. It is anticipated that any 

water needed could be obtained from the existing RWMC groundwater supply system. During operations, 

it is expected that water use would be relatively small under normal operations and limited to that required 

to serve the potable and sanitary needs of the storage facility workforce. Total annual consumption is 

estimated to be no more than about 88,500 liters (23,375 gallons). Moreover, there may be no net increase 

in water use, as use of the RWMC facilities for elemental mercury storage would substitute for existing 

waste management activities, especially if mercury storage staff are drawn from the existing INTEC 

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

4–80

Use and operations of the RWMC storage modules for mercury storage must include the structural 

controls and practices to prevent and respond to any release of elemental mercury, as discussed under the 

INTEC Option. As necessary, the RWMC storage modules would be modified to meet these 

requirements, as summarized in Appendix C, Table C–1. Likewise, facility operations would be 

conducted in accordance with an ICP and SPCC plan or updated existing plans, which set forth the actions 

facility personnel would take to respond to fires, explosions, or any accidental release of mercury to air, 

soil, or surface water at the facility. 

RWMC is separated from the Big Lost River by a lava ridge that serves as a hydraulic barrier; therefore, 

the Big Lost River is not a surface water flowpath. Analysis of the probable maximum flood due to the 

failure of Mackay Dam showed that RWMC would not be inundated from flow from the Big Lost River. 

RWMC has experienced flooding as a result of rapid snowmelt and heavy precipitation, with the latest 

event in 1982. However, upgrades to the perimeter drainage system have greatly reduced the likelihood of 

local basin flooding affecting RWMC. RWMC has a peripheral drainage ditch and a main discharge 

channel that are designed for a maximum 10,000-year combined rain-on-snow storm event (see Chapter 3, 

Section 3.5.3.1). Regardless, as further described above under the INTEC Option, DOE Order 420.1B and 

its companion guide (DOE Guide 420.1-2) require that DOE facilities be designed, constructed, and 

operated to protect the public, workers, and environment from natural phenomena hazards, including 

flooding, and specifically to adhere to the flood design and evaluation criteria specified in DOE 

Standards 1020-2002 and 1023-95. Use of the RWMC storage modules for mercury storage would 

require that they be evaluated and upgraded, as necessary, to incorporate any additional appropriate 

stormwater management controls to safely collect and convey stormwater from the facility while 

minimizing washout, soil erosion, and offsite water quality impacts. 

There would be no direct discharge of effluents to either surface water or groundwater from storage 

facility operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) 

would be generated and managed via the RWMC existing sewage disposal system. 

4.6.3.2 Groundwater 

Idaho Nuclear Technology and Engineering Center Option

Facility construction is not expected to have any impact on groundwater hydrology or existing 

contaminant plumes beneath INTEC due to the depth to groundwater and the shallow depth of excavation. 

As the facility would be operated to prevent any spills from reaching the ground, there would be no impact 

on groundwater from routine operations. 

Radioactive Waste Management Complex Option

Storage module modifications are not expected to have any direct impact on groundwater hydrology or 

existing contaminant plumes as there would be little excavation activity required, although trenching, if 

required, could encounter locally perched groundwater conditions at depths ranging from about 0.6 to 

7 meters (2 to 23 feet). In such cases, the excavations may have to be dewatered and the groundwater 

contained for testing and treatment, if found to be contaminated, prior to discharge. As the facility would 

be operated to prevent any spills from reaching the ground, there would be no impact on groundwater 

from routine operations. 

4.6.4 Meteorology, Air Quality, and Noise 

4.6.4.1 Meteorology 

Meteorological events can result in damage to buildings such as mercury storage warehouses. The 

frequency and consequences of such events were considered in selecting the accident events evaluated in 

Section 4.6.9.2. As previously detailed and described in Section 4.3.4.1, DOE Order 420.1B and its 
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4–81

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so 

that the public, workers, and environment are protected from adverse impacts of natural phenomena 

hazards, including meteorological events. RCRA-permitted facilities, such as the proposed mercury 

storage facility, must also meet applicable design, construction, and operation requirements under 

Title 40 of the CFR, Section 264.31 and applicable state RCRA requirements to prevent the release of 

stored wastes. As the INL region is susceptible to regular occurrence of high winds, the existing RWMC 

facilities would be upgraded or modified and the new mercury storage facility at INTEC designed and 

constructed to withstand the potential for high winds and other meteorological events, such as heavy snow. 

4.6.4.2 Air Quality 

Idaho Nuclear Technology and Engineering Center Option

Minor short-term air quality impacts would result from construction of a mercury storage building at 

INTEC. These impacts would include an increase in criteria and toxic air pollutant concentrations from 

construction equipment emissions (see Appendix C, Section C.2.3). These emissions would occur over a 

6-month construction period and are not expected to result in exceedance of air quality standards. 

Emissions from operation of a new mercury storage facility at INTEC would be very small, consisting of 

emissions from employee vehicles, trucks or trains, semiannual testing of emergency generators, and 

possibly mercury vapor from any spills or from mercury containers. No localized emissions from space 

heating are anticipated associated with mercury storage facility operations, as electric heating is 

anticipated for areas requiring climate control. Compliance with the conformity regulations is discussed in 

Appendix B, Section B.5.1.2. 

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

elemental mercury vapor escaping from storage containers or residual contamination. Mercury vapor 

transported downwind could then be inhaled by noninvolved workers (those outside the storage facility) or 

nearby offsite individuals. Appendix D, Section D.4.1, presents a conservative analysis that shows that for 

a long-term, undetected slow leak inside the proposed mercury storage facility, the predicted long-term 

average concentration in the building wake never exceeds 80 nanograms per cubic meter. The EPA 

threshold for chronic exposure to airborne mercury is 300 nanograms per cubic meter, so slow releases of 

mercury would have a negligible effect on noninvolved workers and the public, with a corresponding 

negligible risk. 

Air quality impacts from transportation of mercury to INL would be similar to those discussed in 

Section 4.3.4.2. Truck and rail transport are discussed in more detail in Section 4.6.9.3. Estimated 

emissions from truck and rail transportation are presented in Tables 4–15 and 4–16. 

Annual carbon dioxide emissions would be highest during the year 2013, at approximately 304 metric tons 

(335 tons) per year, as a result of moving elemental mercury to the site by truck; these annual truck 

emissions would be greater than rail emissions from shipping mercury. As similarly noted in 

Section 4.3.4.2, such emissions would minimally add to global and U.S. annual emissions of carbon 

dioxide. Global climate change is further discussed in Section 4.11.4.2. 

Radioactive Waste Management Complex Option

Negligible short-term air quality impacts with little or no measurable effect on air quality would result 

from modification of the existing storage modules for mercury storage at RWMC. Criteria and toxic air 

pollutant emissions from construction equipment (see Appendix C, Section C.2.3) would be limited to 

those from construction employee vehicles and work trucks; no heavy equipment is expected to be used. 

Emissions and air quality impacts from RWMC facility operations would be similar to but likely less than 

those described above for the INTEC Option. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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Air quality impacts from transportation of mercury to INL would be similar to those discussed above for 

the INTEC Option and further discussed in Section 4.3.4.2. 

4.6.4.3 Noise 

Idaho Nuclear Technology and Engineering Center Option

Short-term noise impacts at INL could result from construction of a new mercury storage facility within 

INTEC. These impacts would include some increase in traffic to the site and an increase in noise resulting 

from construction employee vehicles, equipment delivery, and heavy equipment operations. These 

impacts would occur during the 6-month construction period. Since the nearest noise-sensitive receptor, a 

residence, is located more than 16 kilometers (10 miles) from the site, the increase in noise levels at this 

location from construction equipment is expected to be negligible. The increase in traffic noise levels 

along U.S. Route 20 from construction activity is expected to be less than 1 dBA since the increase in 

traffic resulting from construction would be much less than the existing traffic on U.S. Route 20. 

Short-term noise impacts could occur along U.S. Route 20 as a result of increased truck activity during the 

period that elemental mercury is transported to the site. The resulting increase in day-night average noise 

levels along U.S. Route 20 is expected to be less than 1 dBA. As such, the change in truck traffic is not 

expected to result in a change in noise levels along this route or other shipping routes that would be 

noticeable to the public or result in an increase in annoyance. If the mercury is shipped by rail instead of 

by truck, some additional rail activity from placing railcars at the site could result in some increase in 

noise levels near the site. 

Operation of the mercury storage facility within INTEC is expected to have a negligible impact on noise 

levels around the site since the noise sources would be limited to a few employee vehicles, occasional 

delivery trucks, and semiannual testing of the emergency generator. 

Radioactive Waste Management Complex Option

Activities and associated noise impacts from modification of the RWMC storage modules to accommodate 

mercury storage would be similar to but somewhat smaller than those described for the INTEC Option. 

Similarly, since the nearest noise-sensitive receptor, a residence, is located 16 kilometers (10 miles) from 

the site, the increase in noise levels at this location from construction equipment is expected to be 

negligible. The increase in traffic noise levels along U.S. Route 20 from construction activity is expected 

to be less than 1 dBA since the increase in traffic resulting from construction would be much less than the 

existing traffic on U.S. Route 20. 

Noise impacts from mercury storage facility operations would be similar to those discussed for the INTEC 

Option. 

4.6.5 Ecological Resources 

4.6.5.1 Terrestrial Resources 

Habitat in the immediate vicinity of INTEC and RWMC consists of disturbed land within a developed 

setting. Little native vegetation remains within the area of the proposed mercury storage facilities; 

impacts would be limited to introduced species in an already disturbed landscape. Adherence to best 

management practices for land cover management (e.g., washing down construction equipment and 

vehicle tire treads) would serve to reduce the chance of introducing invasive plant species. Impacts on 

animals from construction would be limited to species adapted to human disturbance. During operations, 

there would be no additional impacts on terrestrial resources, as temporarily disturbed areas beyond the 

facility footprint would be revegetated and/or would revert to more-natural conditions. 
Environmental Consequences 

4–83

4.6.5.2 Wetlands and Aquatic Resources 

No wetlands or aquatic resources exist within the area of the proposed mercury storage facilities at INTEC

or RWMC. Therefore, no impacts on wetlands or aquatic habitats are expected. 

4.6.5.3 Threatened and Endangered Species 

No threatened or endangered species are known or are expected to exist within the areas designated for the 

proposed mercury storage facility at INTEC or RWMC. Thus, no impacts on threatened or endangered 

species are expected from facility modifications, construction, or operations. Consultations have been 

initiated with the appropriate U.S. Fish and Wildlife Service office and state wildlife agency to support 

this analysis (see Chapter 5, Section 5.4). 

4.6.6 Cultural and Paleontological Resources 

4.6.6.1 Prehistoric Resources 

Most of the prehistoric sites or locations at INL appear to be concentrated along Big Lost River and Birch 

Creek, atop buttes and within craters or caves. There would be no impact on these resources under either 

the INTEC or RWMC Options. Given the high density of prehistoric sites at INL, there is always a 

possibility of identifying a new site, although construction of a new mercury storage facility would be 

conducted within the heavily disturbed INTEC. Nevertheless, any inadvertent discoveries of resources 

would be managed in accordance with the Idaho National Laboratory Cultural Resource Management 

Plan (DOE 2009a) (see Chapter 3, Section 3.5.6.1). 

4.6.6.2 Historic Resources 

There are at least 200 historical properties at INL, including the Experimental Breeder Reactor I, which is 

a National Historic Landmark. Many of these properties are considered eligible for listing in the 

NRHP because of their exceptional scientific and engineering significance since World War II. Previous 

projects and ground-disturbing activities were reviewed in accordance with the Idaho National Laboratory 

Cultural Resource Management Plan in 2007 (see Chapter 3, Section 3.5.6.2). No adverse effects on 

historic properties were identified. No impact on historical resources is expected under either the INTEC 

or RWMC Options for mercury storage. DOE has initiated consultation with the Idaho SHPO to support 

this analysis (see Chapter 5, Section 5.4). 

4.6.6.3 American Indian Resources 

The INL site is considered part of the Shoshone-Bannock Tribes’ ancestral homeland. DOE has an 

agreement that allows unrestricted access to certain areas of INL to Shoshone-Bannock tribal members. 

The agreement provides for routine tribal participation in new and ongoing INL projects (see Chapter 3, 

Section 3.5.6.3). Consultation with the Shoshone-Bannock Tribe has been initiated by DOE (see Chapter 

5, Section 5.4). However, no impacts on American Indian resources are expected under either the INTEC 

or RWMC Options. 

4.6.6.4 Paleontological Resources 

No impacts on unique paleontological resources are expected under either the INTEC or RWMC Options 

as the affected sites have been previously disturbed. As is the case for other cultural resources, if any 

paleontological resources were found (see Chapter 3, Section 3.5.6.4), procedures are in place to properly 

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

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4.6.7 Site Infrastructure 

4.6.7.1 Ground Transportation 

Construction or modification and operations of a new mercury storage facility at INL are not expected to 

appreciably increase demands on the road and rail systems leading to the site. Projected peak traffic 

volumes and the number of shipments associated with mercury storage operations are presented in 

Section 4.6.11. 

4.6.7.2 Electricity, Fuel, and Water 

Utility resource demands and associated assumptions for construction and operation of a new mercury 

storage facility at INL under the INTEC and RWMC Options would generally be similar to those 

described in Section 4.3.7.2. However, under the RWMC Option, utility requirements for construction 

would likely be considerably less than those for construction of a new facility as activities would be 

limited to modification of the existing storage modules for mercury storage at RWMC. Use of the existing 

RWMC facilities for mercury storage would likely have little or no incremental operational impact on site 

utility infrastructure, as the storage modules are or have previously been in operation for other uses. 

INTEC’s current annual electricity consumption is about 10 percent of the INL site capacity. RWMC’s 

current electricity consumption is 0.6 percent of the available sitewide capacity. The projected annual 

operational electricity requirement to support mercury storage (253 megawatt-hours) would be negligible 

(0.6 and 8 percent increase at INTEC and RWMC, respectively) when compared with the current annual 

INTEC and RWMC electricity usage, and would be about 0.05 percent of the annual sitewide electric 

supply capacity. 

The availability of liquid fuels at INL is not limited, and volume can be increased as needed. Diesel fuel 

consumption (606 liters [160 gallons]) to support operations of a new mercury storage facility would be 

negligible (0.01 percent increase) when compared with INL’s annual consumption of liquid fuels (see 

Chapter 3, Section 3.5.7.3). 

Water requirements for construction and operation of a new mercury storage facility would similarly be 

negligible compared with INTEC’s and RWMC’s water usage and INL site capacity (see Chapter 3, 

Section 3.5.7.4). INTEC’s and RWMC’s current annual water usage are 1 and 0.02 percent, respectively, 

of the INL water rights capacity. Water requirements for new construction (1,270,000 liters 

[336,000 gallons]) would temporarily increase INTEC’s water use by no more than 0.3 percent. The 

annual water demand for mercury storage operations (88,500 liters [23,400 gallons]) would constitute 

about 0.02 and 0.8 percent, respectively, of INTEC’s and RWMC’s water consumption. 

4.6.8 Waste Management 

Both modification and operation of the existing RWMC waste storage modules (RWMC Option) for 

mercury storage and construction and operation of a new mercury storage facility at INTEC (INTEC 

Option) are expected to have a negligible impact on waste generation and waste management 

infrastructure at INL. Internal modification of RWMC storage modules for interim mercury storage is 

expected to generate much less than the 271 cubic meters (355 cubic yards) of nonhazardous solid waste 

and 9,850 liters (2,600 gallons) of nonhazardous sanitary liquid waste projected to be generated during 

construction of a new facility. Nevertheless, the maximum volumes are negligible compared with the 

current waste generation activities at INL, as described in Chapter 3, Section 3.5.8. It is assumed that 

construction-generated solid waste would be disposed of either in the INL Central Facilities Area landfill 

or off site at the Bonneville County Landfill. Portable toilet facilities, serviced by a local or regional 

contractor, would be used to serve the sanitary needs of the construction workforce under either option. 
Environmental Consequences 

4–85

Operation of the mercury storage facility within either RWMC or INTEC is expected to generate an 

estimated 910 55-gallon (208-liter) drums of hazardous waste over the 40-year period of analysis, as 

further described in Section 4.3.8. This equates to about 23 55-gallon drums, or approximately 5 cubic 

meters (6.5 cubic yards) annually. This estimated yearly hazardous waste generation rate is negligible 

(about 0.2 percent) compared to the hazardous and other waste volumes (which include mercurycontaminated waste) generated and managed each year at INL (see Chapter 3, Section 3.5.8). INL is a 

listed hazardous waste generator. No changes in generator status would be required to operate the 

proposed mercury storage facility, nor are any substantial effects on INL’s waste management 

infrastructure expected. 

New mercury storage facility operations would also generate an estimated 59,000 liters (15,600 gallons) of 

nonhazardous sanitary wastewater annually. Nonetheless, operation of the RWMC storage modules is not 

expected to result in a substantial increase in sanitary waste generation as the modules are already in 

operation for other purposes. Under the INTEC Option, the projected annual sanitary waste generation 

rate from operation of a new mercury storage facility would be miniscule (0.003 percent) compared with 

the 1,698 million liters (448.5 million gallons) of wastewater collected, treated, and discharged to the 

INTEC New Percolation Ponds each year (DOE 2008a:5.8). 

DOE continues to manage several ongoing programs and projects at INL in support of sitewide 

remediation. Neither construction or modification nor operation of the proposed mercury storage facilities 

is anticipated to impact resources (e.g., funding, labor, facilities, and equipment) associated with current 

and/or future site environmental restoration efforts. 

4.6.9 Occupational and Public Health and Safety 

There are two options for mercury storage at INL: new construction at INTEC or use of existing buildings 

at RWMC. Under the RWMC Option, the principal difference is that elemental mercury would not be 

stored in a single large building, but in up to seven buildings with approximate dimensions of 61 meters 

(200 feet) long, 43 meters (140 feet) wide, and 7.4 meters (24 feet) high (see Appendix D, Table D–51). 

Most of the risks that pertain to both options are the same as those discussed in Sections 4.2.9.1 through 

4.9.2.5. 

4.6.9.1 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites. Consequences to the involved worker are predicted to be negligible 

because involved workers would never be exposed to airborne concentrations of mercury vapor above the 

ACGIH’s 8-hour TWA/TLV of 0.025 milligrams per cubic meter of mercury vapor. This corresponds to 

keeping exposures to the involved worker in the SL-I (negligible) range.21 This would be achieved by 

adherence to good operating practices, in particular attention to ventilation, inspection, monitoring, and 

use of PPE, as described in the Interim Guidance (DOE 2009c). Therefore, the risks to involved workers 

would be negligible during normal operations. 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 

3-L flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this source 

of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building wake. 

Appendix D, Section D.4.1.2, shows that the predicted long-term average concentration in the building 

wake for new construction is about 2.0 × 10-5 milligrams per cubic meter and about 4.0 × 10-5 milligrams 

 

21 For definitions of SLs for various types of exposures, see Section 4.2.9.1.1 and Appendix D, Section D.1.1.1. For a discussion 

of how risk is assessed, see Sections 4.2.9.1.1 and D.1.1.2. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–86

per cubic meter in the wake of existing buildings at RWMC. This is well below EPA’s chronic-inhalation 

exposure RfC of 3.0 × 10-4 milligrams per cubic meter. Hence, consequences would be in the SL-I range, 

and the risk to both noninvolved workers and the public would be negligible. 

4.6.9.2 Facility Accidents 

Section 4.2.9.1.4 provides a discussion of facility accident risks that applies to all sites. Table 4–3 

contains a summary of the likelihood of occurrence of candidate facility accident scenarios initiated by 

failures of engineered systems, human errors, or external events, and Table 4–4 lists the accident scenarios 

that remain for consequence analysis after eliminating those with negligible frequency from Table 4–3. 

The analysis of the scenarios at INL is similar to that for the same scenarios in Section 4.2.9.1.4. There 

are some differences because the RWMC Option includes interim storage of elemental mercury in up to 

seven relatively small buildings at RWMC within INL. For a member of the public in the case of an 

outside earthquake spill at RWMC, the atmospheric dispersion calculations show that the maximum 

distance downwind to which a concentration greater than AEGL-3 could be exceeded is less than 

100 meters (330 feet); for AEGL-2, the corresponding distance is about 320 meters (1,050 feet); and for 

0.1 × AEGL-2, it is approximately 1.3 kilometers (0.8 miles). However, the distance to the closest site 

boundary from the proposed INL storage site is 5.8 kilometers (3.6 miles), so consequences and hence 

risks to members of the public would be negligible. Similar reasoning leads to the same conclusion for 

new construction at INTEC. Table 4–39 summarizes the results for all accidental spills of elemental 

mercury on site (without fire). 

Table 4–39. Summary of Risks for all Onsite Spill Scenarios of Elemental Mercury – 

Idaho National Laboratory (RWMC and INTEC) 

Scenario Frequency Consequence Risk 

Spills Inside Buildinga

Involved worker FL-II – FL-III SL-I – SL-II N–L for all inside spills 

Noninvolved worker FL-II – FL-III SL-II N for all inside spills 

Member of the public FL-II – FL-III SL-II N for all inside spills 

Spills Outside Building 

Involved worker FL-II – FL-III SL-I – SL-II 

Noninvolved worker FL-II – FL-III SL-I – SL-II 

N–L for outside earthquake 

spill; N for all other outside 

spills 

Member of the public 

1-metric ton container 

spill 

FL-II SL-I N 

Single pallet spill FL-III SL-I N 

Earthquake with building 

collapseb

FL-III SL-I N 

a The inside spill scenarios considered are single flask, single pallet, triple pallet, 1-metric-ton container, full spill tray under a 

pallet, and earthquake with intact building walls. 

b This scenario encompasses the risk from floods, high winds, and tornadoes. 

Key: FL=frequency level; INTEC=Idaho Nuclear Technology and Engineering Center; L=low; N=negligible; 

RWMC=Radioactive Waste Management Complex; SL=severity level. 

4.6.9.3 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury over a 40-year period of analysis to INL. These 

assumptions, together with knowledge of truck routes and historical frequencies of crashes of various 

types, can be combined to produce estimates of the frequency at which crashes might occur anywhere 

along the routes traveled by mercury trucks or railcars. The transportation analysis applies equally to new 

construction at INTEC and existing buildings at RWMC. The results of the analysis are shown in 

Table 4–40. 
Environmental Consequences 

4–87

Table 4–40. Frequency Analysis of Truck and Railcar Accidents – Idaho National Laboratory 

Scenario 

Truck 

Miles 

Frequency of 

Accidents 

(per year) 

Frequency of 

Accidents with 

Spills (per year) 

Frequency of 

Accidents with 

Fires in Dry 

Weather 

(per year) 

Frequency of 

Accidents with 

Fires in Wet 

Weather (per 

year) 

Frequency of 

Accidents with 

Deatha

(per year) 

984,288 1.2×10-2 2.0×10-3 1.6×10-4 5.1×10-6 5.5×10 Truck – -4

Scenario 1 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III 

1,654,225 1.6×10-2 3.3×10-3 2.7×10-4 8.6×10-5 9.2×10 Truck – -4

Scenario 2 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III 

394,112 2.5×10-3 1.1×10-5 2.6×10-5 8.3×10-7 1.6×10 Railcar -4

– Moderate – FL-III Low – FL-II Low – FL-II Negligible – FL-I Moderate – FL-III 

a Fatality caused by mechanical impact, not by exposure to mercury. 

Note: To convert miles to kilometers, multiply by 1.60934. 

Key: FL=frequency level. 

The above frequencies are for an accident anywhere along any of the transportation routes taken over a 

40-year period of analysis to INL. A crash that occurs in the last mile of the trip was used to estimate the 

frequency of an onsite crash in the vicinity of the storage building(s). The frequency of accidents with 

spills would be low under both truck scenarios and negligible under the Railcar Scenario. The frequency 

of crashes with fires or death would be negligible under all scenarios. 

With respect to transportation accidents involving spills of mercury, four scenarios were considered: 

 Spill of elemental mercury onto the ground without fire 

 Spill of elemental mercury directly into water 

 Fire with mercury spill 

 In dry weather 

 In wet weather 

4.6.9.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground 

Section 4.2.9.1.5 contains an analysis of spills of elemental mercury onto the ground following a truck or 

railcar crash without fire. A conservative estimate of the rate of evaporation from the resulting pool and 

the subsequent atmospheric dispersion (applicable to all sites) shows that a specific individual could not be 

exposed to concentrations that are greater than negligible if he or she lives more than 340 meters 

(1,115 feet) from a crash. Conservatively, assuming that the individual lives immediately adjacent to the 

road, that individual could only be exposed to such concentrations if the crash occurs along a specific 

680-meter (2,230-foot) stretch of any of the routes to INL. The same reasoning as is used in the generic 

discussion in Section 4.2.9.1.5 shows that the risk to a member of the public from transportation spills 

onto the ground without fire en route to INL would be negligible under Truck Scenario 1 and the Railcar 

Scenario, but low under Truck Scenario 2. 

4.6.9.3.2 Transportation Accident with Spill of Elemental Mercury Directly into Water 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–88

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to humans (inorganic compounds of mercury and 

methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

Table 4–41 summarizes the risks to human receptors arising from spillages of elemental mercury during 

transportation to INL. 

Table 4–41. Summary of Transportation Risks to Human Receptors, Spills of Elemental Mercury 

onto the Ground or into Water, Idaho National Laboratory 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto the Ground 

Frequencya FL-I FL-II FL-I 

Consequence SL-II SL-II SL-II 

Risk Negligible Low Negligible 

Spill into Water 

Frequencyb FL-III FL-III FL-II 

Consequence SL-I–SL-II SL-I–SL-II SL-I–SL-II 

Riskc Negligible to low Negligible to low Negligible to low 

a Frequency at which spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded. 

b Frequencies of railcar or truck crashes with spills from Table 4–40. 

c These estimates of risk are subject to large uncertainty. 

Key: FL=frequency level; SL=severity level. 

4.6.9.3.3 Transportation Accident with Fire 

The fire calculations are described in Section 4.2.9.1.5. Table 4–42 shows the results of the calculations 

of acute-inhalation risks from transportation accidents with fires on transportation routes to INL (both 

INTEC and RWMC). The table encompasses both truck scenarios and the Railcar Scenario. 

Note that the risks presented in the above scenario are individual risks: they are the answer to the question, 

“What is the risk to me?” This is not the same as the risk that, somewhere along a transportation route, 

airborne concentrations would exceed the various SLs. Those risks would in fact be higher. 
Environmental Consequences 

4–89

Table 4–42. Summary of Acute-Inhalation Risks to Human Receptors, 

Accidents with Fires, Transportation Routes to Idaho National Laboratory 

Both Truck Scenarios with Wooden Pallets Railcar Scenario with Wooden Pallets 

Frequencya FL-III FL-II 

Consequenceb SL-II SL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7.

b The highest consequence in any weather condition. 

Key: FL=frequency level; SL=severity level. 

The analyses performed for this EIS show that, under all fire scenarios listed in Table 4–42, with and 

without rain, mercury deposited on the ground would never cause the benchmark of 180 milligrams per 

kilogram to be exceeded. Therefore, the corresponding risks would be negligible. 

Table 4–43 summarizes the human health risks associated with all transportation spills. 

Table 4–43. Summary of Transportation Risks to Human Receptors, Idaho National Laboratory 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto ground Negligible Low Negligible 

Spill into water Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Spill with fire – 

inhalation, wooden pallets 

Low Low Low 

Spill with fire – dry and 

wet deposition, wooden 

pallets 

Negligible Negligible Negligible 

4.6.9.4 Intentional Destructive Acts 

The discussion of IDAs is the same for all sites and transportation routes (see Section 4.2.9.1.6). 

4.6.10 Ecological Risk 

There is a generic analysis of ecological risk in Section 4.2.10.1, which applies without modification to 

INL (both INTEC and RWMC). 

4.6.10.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike inorganic compounds 

formed from divalent mercury. As a result, risks to ecological receptors from slow leaks, accidental spills 

at storage sites, and spills without fires during transportation are considered to be negligible at all storage 

sites and along all transportation routes. 

4.6.10.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–90

which also makes the following conclusions regarding the consequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

ecological receptors could be managed so that they are negligible or low. Given this assumption and the 

fact that the frequency of crashes with spills on any of the transportation routes is no more than moderate 

(and this is an upper bound on the frequency of spills directly into water), the risk would be negligible or 

low for all transportation routes. However, because of the above-mentioned uncertainty about fastflowing rivers, this observation should be tempered by noting that the uncertainty regarding this prediction 

of risk is very large. 

4.6.10.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5, and 

Section 4.2.10.1. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. Table 4–44 summarizes the FL, consequence level, and risk to ecological receptors in the 

case of a truck crash with a pallet fire and no rain (dry deposition) and applies to all candidate storage 

sites. 

Table 4–44. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, Idaho National Laboratory 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

b Applies to both Truck Scenarios 1 and 2. 
Environmental Consequences 

4–91

For the interpretation of Table 4–44, see Section 4.2.10.1.3. The risks of other potential fire scenarios are 

summarized as follows: 

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–45. 

 For railcar crashes with wooden pallet fires and without rain (dry deposition), see Table 4–46. 

 The predicted frequency of railcar crashes with pallet fires and rain is negligible, so risks would 

be negligible and no summary table is presented. 

Table 4–45. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, Idaho National Laboratory 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Table D–16. 

b Applies to both Truck Scenarios 1 and 2. 

Table 4–46. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, Idaho National Laboratory 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Risk

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a Frequencies of railcar crashes with fires from Appendix D, Table D–14. 

4.6.10.4 Consequences – Intentionally Initiated Fire with Mercury Spill 

The consequences of intentionally initiated fires to ecological receptors are the same for all sites 

(see Section 4.2.10.1.4). 

4.6.11 Socioeconomics 

Idaho Nuclear Technology and Engineering Center Option

Under the INTEC Option at INL, a new facility for long-term storage of elemental mercury would be 

constructed. Employment during construction is expected to average 18 people for approximately 

6 months. Operation of the facility is estimated to require approximately 8 individuals for routine 

maintenance and support activities during the first 7 years, when higher volumes of shipments are 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–92

expected, and approximately 5 individuals thereafter, resulting in a possible increase of the INL 

workforce of less than 0.1 percent and an increase in the ROI of 0.006 percent. This estimate assumes that 

new employees would be hired for construction and operations of the new facility rather than drawn from 

existing onsite personnel. Regardless, neither construction nor operation of a new facility is expected to 

generate substantial direct or indirect employment. Thus, negligible impacts on socioeconomic conditions 

(i.e., overall employment, population trends, and traffic) in the ROI would result from implementing this 

alternative. 

Construction-related transportation, including employee vehicle trips and equipment and materials 

shipments, is not expected to adversely impact traffic conditions on roads leading to the site. It is assumed 

that there would be approximately 1.5 employees per vehicle, and every vehicle is counted twice to 

account for round trips. It is estimated that average construction transportation of 45 vehicles a day could 

increase the average annual daily traffic count on State Route 33 by approximately 7 percent. Fifty-three 

percent of these vehicles would be attributed to employee transportation. 

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of mercury to the site for storage. Appendix C, Section C.1, provides an estimate of the number of 

shipments by truck. The additional vehicles due to facility operations are not expected to noticeably 

increase traffic volumes on roads leading to the site. The greatest impact would be during the first 2 years 

of operations, when it is estimated that approximately 11 vehicles a day could increase the average annual 

traffic count on State Route 33 by approximately 2 percent. During this time, it is estimated that up to 

78 shipments would be made each year. Approximately 96 percent of the additional vehicles would be 

attributed to employee transportation. 

Radioactive Waste Management Complex Option

Modifications of the existing RWMC storage modules and subsequent operations for interim storage of 

elemental mercury under the RWMC Option would result in additional but substantially smaller 

socioeconomic impacts than those described above for the INTEC Option. However, even combined with 

the INTEC Option, the total impact on socioeconomic conditions in the ROI surrounding INL would be 

negligible. Appendix C, Table C–1, summarizes the necessary modifications to the RWMC storage 

modules to meet the specifications for interim mercury storage. 

4.6.12 Environmental Justice 

Idaho Nuclear Technology and Engineering Center Option

None of the block groups within either the 16-kilometer (10-mile) radius or the 3-kilometer (2-mile) radius 

surrounding INTEC contain a disproportionately high number of minority or low-income individuals 

(see Chapter 3, Section 3.5.11). Therefore, no disproportionately high and adverse effects on minority or 

low-income populations are expected. The Fort Hall Reservation lies well beyond the 16-kilometer 

(10-mile) radius of the proposed storage site; however, it is possible that mercury shipments originating 

from points south and east of the site could be transported through the reservation. Therefore, consultation 

has been initiated with the Shoshone-Bannock Tribe of the Fort Hall Reservation, as described in 

Section 4.6.6.3. 

Radioactive Waste Management Complex Option

None of the block groups within either the 16-kilometer (10-mile) radius or the 3-kilometer (2-mile) radius 

surrounding RWMC contain a disproportionately high number of minority or low-income individuals 

(see Chapter 3, Section 3.5.11). Therefore, no disproportionately high and adverse effects on minority or 

low-income populations are expected. The Fort Hall Reservation lies well beyond the 16-kilometer 

(10-mile) radius of the proposed storage site; however, it is possible that mercury shipments originating 
Environmental Consequences 

4–93

from points south and east of the site could be transported through the reservation. Therefore, consultation 

has been initiated with the Shoshone- Bannock Tribe of the Fort Hall Reservation, as described in 

Section 4.6.6.3. 

4.7 LONG-TERM MERCURY MANAGEMENT AND STORAGE AT KANSAS CITY 

PLANT 

Under this alternative, elemental mercury would be stored at DOE’s KCP. 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. Implementation of this alternative would involve 

modification of an existing building (i.e., Main Manufacturing Building [Building 1]), as further described 

in Chapter 2, Section 2.4.6. 

4.7.1 Land Use and Visual Resources 

No additional impacts on land use or visual resources are anticipated at KCP since no new construction or 

other substantial ground-disturbing activities would be required. Elemental mercury would be stored in an 

existing building within the central portion of the site complex, where approximately 14,000 square meters 

(150,000 square feet) of floor space would initially be available if National Nuclear Security 

Administration operations move to a new facility in 2013. Receipt, staging, and storage activities would 

generally take place inside the available storage space and would not require the use of any additional site 

acreage, although some minor modifications to the existing building might be required (see Chapter 2, 

Section 2.4.6). Onsite land use is expected to remain predominantly light industrial, and viewsheds would 

not be affected. Scheduled maintenance and repairs to the storage building would be consistent with the 

existing land use and visual character of the site. Although no applicable land use plans, policies, or 

controls have been identified that would specifically restrict storage of elemental mercury, such storage 

might not be considered compatible with proposed redevelopment of the site, adjacent residential zoning, 

or the proximity of sensitive populations (at a hospital and schools) within 0.8 kilometers (0.5 miles) of 

this location (Neef 2009). Because there would be no change to the visual landscape in the vicinity of 

KCP as a result of this alternative, there would be no associated change in BLM VRM classifications. 

4.7.2 Geology, Soils, and Geologic Hazards 

4.7.2.1 Geology and Soils 

Renovation of the existing Main Manufacturing Building at KCP would have little or no impact on 

geology and soils, because activities would largely be limited to installing concrete spill containment 

curbing within the existing warehouse, and the existing structures are within a previously disturbed 

industrial complex. The structure has sufficient storage space and existing perimeter security, which 

would limit the need for facility additions. The facility has previously undergone structural upgrades for 

seismic safety. 

As described in Chapter 3, Section 3.6.2.2, some areas of soil contamination have been identified at KCP. 

Any contamination identified during building renovation would be remediated as necessary. Due to the 

vintage of the building space, refurbishment or enhancement of some building systems (e.g., fire 

protection) may be necessary and could necessitate some trenching and other temporary ground-disturbing 

activity around the existing structure. The depth of excavation required would be about 0.6 meters (2 feet) 

wide by 1.2 meters (4 feet) deep, where necessary for utility trenching. Adherence to standard best 

management practices for soil erosion and sediment control (e.g., use of sediment fencing, staked hay 

bales, mulching and geotextile matting, and rapid reseeding) in any disturbed areas would serve to 

minimize any soil erosion and loss. There would be no additional impact on geology and soils from 

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

4–94

4.7.2.2 Geologic Hazards 

Most of Missouri’s earthquake activity has been concentrated in the southeastern corner of the state, which 

is associated with the New Madrid seismic zone (see Chapter 3, Section 3.6.2.3). In contrast, the 

northwestern portion of the state, where KCP is located, is seismically stable. Nevertheless, it is estimated 

that the maximum ground shaking across northwestern Missouri and KCP from the great New Madrid 

earthquake sequence of 1811–1812 was in the MMI VI to VII range. MMI VI shaking typically causes 

only slight damage to ordinary structures, while MMI VII shaking can cause moderate damage in wellconstructed, ordinary structures but is not expected to damage facilities that have been specially designed 

or upgraded to withstand the assessed hazard (see Appendix B, Table B–4). The predicted peak ground 

acceleration at the site from an earthquake with an annual probability of occurrence of 1 in 2,500 is 0.05 g. 

Peak ground motion in this range would be felt but is not expected to cause damage to either ordinary or 

specialized structures. As further described in Appendix B, Section B.3.2, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so 

that the public, workers, and environment are protected from adverse impacts of natural phenomena 

hazards, including earthquakes. The existing KCP warehouse has been seismically upgraded. Thus, the 

building is not expected to suffer substantial structural damage from the predicted earthquake ground 

motion at the site. The predicted ground motion would also be unlikely to cause a breach in mercury 

containers from structural failure. An analysis of potential environmental consequences resulting from an 

earthquake-induced accident is described in Section 4.7.9.2. 

4.7.3 Water Resources 

4.7.3.1 Surface Water 

Modification of the existing structure to support mercury storage would not have any impact on surface 

water features, including the Blue River and Indian Creek, which border the site complex. Renovation 

activities are expected to be confined to the interior of the facility, although limited, temporary disturbance 

of areas around the exterior of the warehouse is not out of the question. Should exterior ground-disturbing 

activity be necessary, appropriate soil erosion and sediment control measures and spill prevention and 

waste management practices would be employed to minimize suspended sediment, the transport of other 

deleterious materials, and potential water quality impacts, as noted in Section 4.3.3.1. 

Water requirements to support facility renovations at KCP would be very small compared with 

construction of a new mercury storage facility. It is anticipated that any water needed could be obtained 

from the existing municipal water system that serves KCP. During operations, it is expected that water 

use would be relatively small under normal operations and limited to that required to serve the potable and 

sanitary needs of the storage facility workforce. Total annual consumption is estimated to be no more than 

about 88,500 liters (23,375 gallons). Moreover, there may be little incremental water use at KCP, as use 

of the warehouse facilities for elemental mercury storage would substitute for existing operational 

activities, especially if mercury storage staff are drawn from the existing KCP workforce. 

As previously noted in Section 4.3.3.1, design, construction, and operation of the mercury storage facility 

would incorporate structural controls and practices to prevent the release of elemental mercury and to 

prevent any spills or other releases, should they occur as a result of abnormal operating conditions, from 

reaching soils or surfaces where they could be conveyed to surface waters or groundwater. The existing 

building space at KCP would be modified as necessary to meet these requirements as summarized in 

Appendix C, Table C–1. Facility operations would be conducted in accordance with an ICP and SPCC 

plan, or equivalent plans as mandated by state requirements governing the facility, which set forth the 

actions facility personnel would take to respond to fires, explosions, or any accidental release of mercury 

to air, soil, or surface water at the facility. 
Environmental Consequences 

4–95

While the Blue River and Indian Creek are subject to frequent flooding due to intense urban development, 

seasonal floods have typically only affected vacant portions of the Bannister Federal Complex to the 

northeast of the proposed mercury storage location. A flood protection system completed in 1994 is 

designed to prevent 500-year floods from reaching any of the structures located within the site complex 

(see Chapter 3, Section 3.6.3.1). However, the flood protection system is not a passive one. Effective 

operation of the system requires manual closing of floodgates and placement of stop logs and sandbags. It 

has been estimated that it would take 32 workers approximately 4 hours to close the floodgates. DOE 

Order 420.1B and its companion guide (DOE Guide 420.1-2) require that DOE facilities be designed, 

constructed, and operated to protect the public, workers, and environment from natural phenomena 

hazards, including flooding, and specifically to adhere to the flood design and evaluation criteria specified 

in DOE Standards 1020-2002 and 1023-95. Use of the KCP Main Manufacturing Building for mercury 

storage would require that the structure and flood protection system be evaluated and further upgraded, as 

necessary, and that any additional appropriate stormwater management controls be incorporated to safely 

collect and convey stormwater from the facility while minimizing washout, soil erosion, and offsite water 

quality impacts. 

There would be no discharge of effluents to either surface water or groundwater from storage facility 

operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) would be 

generated and managed via the existing connection to the Kansas City sanitary sewer system 

(see Section 4.7.8). As the facility would be operated to prevent any spills from reaching the ground, there 

would be no impact on groundwater from routine operations. 

4.7.3.2 Groundwater 

Facility renovation is not expected to have any impact on groundwater hydrology or existing contaminant 

plumes beneath KCP as activities would generally be confined to the interior of the renovated structures. 

As necessary, identified contaminant plumes would be evaluated prior to renovation to assess the potential 

for impacts. 

4.7.4 Meteorology, Air Quality, and Noise 

4.7.4.1 Meteorology 

Meteorological events can result in damage to buildings such as mercury storage warehouses. The 

frequency and consequences of such events were considered in selecting the accident events evaluated in 

Section 4.7.9.2. As previously detailed and described in Section 4.3.4.1, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so 

that the public, workers, and environment are protected from adverse impacts of natural phenomena 

hazards, including meteorological events. RCRA-permitted facilities, such as the proposed mercury 

storage facility, must also meet applicable design, construction, and operation requirements under 

Title 40 of the CFR, Section 264.31, and applicable state RCRA requirements to prevent the release of 

stored wastes. As the KCP region is susceptible to regular occurrence of high winds, mercury storage 

would be housed in facilities modified and rated to withstand the potential for high winds and other 

meteorological events, such as heavy snow. 

4.7.4.2 Air Quality 

Negligible short-term air quality impacts with little or no measurable effect on air quality would result 

from modification of the existing Main Manufacturing Building at KCP. Criteria and toxic air pollutant 

emissions from construction equipment (see Appendix C, Section C.2.3) would be limited to those from 

construction employee vehicles and work trucks; no heavy equipment is expected to be used. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–96

Emissions during KCP mercury storage operations would be very small, consisting of those from 

employee vehicles, trucks or trains, semiannual testing of emergency generators, and possibly mercury 

vapor from any spills or from mercury containers. No localized emissions from space heating are 

anticipated associated with mercury storage facility operations, as electric heating is anticipated for areas 

requiring climate control. Although the KCP Main Manufacturing Building is heated by natural gas, it is 

anticipated that facility modifications would include isolating the mercury storage area from the existing 

heating system. Compliance with the conformity regulations is discussed in Appendix B, Section B.5.1.2. 

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

elemental mercury vapor escaping from storage containers or residual contamination. Mercury vapor 

transported downwind could then be inhaled by noninvolved workers (those outside the storage facility) or 

nearby offsite individuals. Appendix D, Section D.4.1, presents a conservative analysis that shows that for 

a long-term, undetected slow leak inside the proposed mercury storage facility, the predicted long-term 

average concentration in the building wake never exceeds 80 nanograms per cubic meter. The EPA 

threshold for chronic exposure to airborne mercury is 300 nanograms per cubic meter, so slow releases of 

mercury would have a negligible effect on noninvolved workers and the public, with a corresponding 

negligible risk. 

Air quality impacts from transportation of mercury to KCP would be similar to those discussed in 

Section 4.3.4.2. Truck and rail transport are discussed in more detail in Section 4.7.9.3. Estimated 

emissions from truck and rail transportation are presented in Tables 4–15 and 4–16. 

Annual carbon dioxide emissions would be highest during the year 2013, at approximately 145 metric tons 

(160 tons) per year, as a result of moving elemental mercury to the site by truck; these annual truck 

emissions would be greater than the rail emissions from shipping mercury. As similarly noted in 

Section 4.3.4.2, such emissions would minimally contribute to global and U.S. annual emissions of carbon 

dioxide. Global climate change is further discussed in Section 4.11.4.2. 

4.7.4.3 Noise 

Short-term noise impacts at KCP could result from modification of warehouse space to accommodate 

mercury storage. These impacts would include some increase in traffic to the site and an increase in noise 

resulting from construction employee vehicles and some equipment delivery. These impacts would occur 

during the 6-month construction period. Since the nearest noise-sensitive receptor, a residence, is located 

150 meters (500 feet) from the site, there would be a small increase in noise levels at this location; 

however, because these activities would be indoors, noise impacts would be negligible. The estimated 

average noise level during the daytime (8-hour equivalent sound level) from one item of construction 

equipment operating at this distance is estimated to be 52 dBA, which might result in an increase in 

average noise levels at the nearest residence. The maximum sound level from operation of this equipment 

could be about 65 dBA, which would likely be heard above existing daytime noise at the nearest 

residence. The increase in traffic noise levels along access routes from construction activity is expected to 

be less than 1 dBA since the increase in traffic resulting from construction would be much less than the 

existing traffic on routes such as East Bannister Road. 

Short-term noise impacts could occur along East Bannister Road as a result of increased truck activity 

during the period that elemental mercury is transported to the site. The resulting increase in day-night 

average noise levels along such routes as East Bannister Road is expected to be less than 1 dBA. As such, 

the change in truck traffic is not expected to result in a change in noise levels along this route or other 

shipping routes that would be noticeable to the public or result in an increase in annoyance. If the mercury 

is shipped by rail instead of by truck, some additional rail activity from placing railcars at the site could 

result in some increase in noise levels near the site. 
Environmental Consequences 

4–97

Operation of the mercury storage facility at KCP is expected to have a negligible impact on noise levels 

around the site since the noise sources would be limited to a few employee vehicles, occasional delivery 

trucks, and semi-annual testing of the emergency generator. 

4.7.5 Ecological Resources 

4.7.5.1 Terrestrial Resources 

KCP constitutes an industrial area with little habitat available. Thus, little native vegetation remains 

within the site. Further, since an existing building would be used for mercury storage, there would be no 

impacts on terrestrial resources from internal facility modifications and subsequent operations. 

4.7.5.2 Wetlands and Aquatic Resources 

No wetlands or aquatic resources exist within the facility complex or would be affected by activities to 

upgrade the existing building to house the proposed mercury storage facility. Thus, no impacts on 

wetlands or aquatic habitats are expected. 

4.7.5.3 Threatened and Endangered Species 

No threatened or endangered species are known or are expected to exist within the area of the Bannister 

Federal Complex. Therefore, no impacts on threatened or endangered species are expected from facility 

modifications or normal operations. Consultations have been initiated with the appropriate U.S. Fish and 

Wildlife Service office and state wildlife agency to support this analysis (see Chapter 5, Section 5.4). 

4.7.6 Cultural and Paleontological Resources 

4.7.6.1 Prehistoric Resources 

There would be no impact on prehistoric resources at KCP from use of the existing warehouse for mercury 

storage. A 2007 cultural resource assessment of the Bannister Federal Complex and areas adjacent to 

KCP identified no prehistoric resources. Further, KCP has been previously disturbed by construction of 

the existing complex, thus the probability of finding intact prehistoric resources is low (see Chapter 3, 

Section 3.6.6.1). 

4.7.6.2 Historic Resources 

Use of the existing warehouse at KCP for mercury storage is not expected to have any impact on historic 

resources or NRHP eligibility (see Chapter 3, Section 3.6.6.2). DOE has initiated consultation with the 

Missouri SHPO to support this analysis (see Chapter 5, Section 5.4). 

4.7.6.3 American Indian Resources 

There would be no impact on American Indian resources at KCP from use of the existing warehouse for 

mercury storage. Most of the historic American Indian villages in the region (i.e., Osage, Missouri, and 

the Kansa) were not located in the KCP area but south on the Osage River or north and east along the 

Mississippi. The 2007 cultural resource assessment indicated a low probability of finding any American 

Indian sites within the KCP area (see Chapter 3, Section 3.6.6.3). 

4.7.6.4 Paleontological Resources 

Since KCP is located on alluvium from the Blue River floodplain, which is bordered by outcrops of 

Pennsylvanian age shale, there is a possibility that fossils may exist (see Chapter 3, Section 3.6.6.4), 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–98

although no unique paleontological resources are known. However, use of the existing KCP facility for 

mercury storage would have no impact on these outcrops. 

4.7.7 Site Infrastructure 

4.7.7.1 Ground Transportation 

Facility modifications of the existing Main Manufacturing Building and operations of the facility to 

support mercury storage at KCP are not expected to appreciably increase demands on the road and rail 

systems leading to the site. Projected peak traffic volumes and the number of shipments associated with 

mercury storage operations are presented in Section 4.7.11. 

4.7.7.2 Electricity, Fuel, and Water 

Utility resource demands and associated assumptions for construction and operation of a new mercury 

storage facility at KCP would generally be similar to those described in Section 4.3.7.2. However, 

construction requirements would likely be less than those for GJDS, as activities would be limited to 

modifying and refurbishing the existing Main Manufacturing Building (Building 1) at KCP to support 

mercury storage. However, utility demands, such as electrical energy consumption for operation of the 

mercury storage facility within Building 1 (see Chapter 2, Figure 2–19), could be slightly greater than 

those for a single, new storage facility due to inefficiency associated with utilizing part of such a large 

structure to house the mercury storage mission. The projected annual operation electricity requirements to 

support mercury storage (253 megawatt-hours) would be negligible (0.2 percent increase) when compared 

with the current annual sitewide electricity usage (see Chapter 3, Section 3.6.7). 

Natural gas, with fuel oil backup, is used at KCP. Diesel fuel required (606 liters [160 gallons]) for the 

operation of the mercury storage facility within Building 1 would be a small percentage (3 percent) of the 

fuel oil used annually at KCP as a backup fuel source. This volume would be resupplied from local or 

regional vendors as needed. 

Water requirements for facility modifications and operation of a new mercury storage facility within 

Building 1 also would be negligible compared with KCP’s sitewide water usage, which is supplied by the 

Kansas City municipal system. Water requirements during construction (1,270,000 liters 

[336,000 gallons]) would temporarily increase site water consumption by 0.2 percent. The annual water 

demand for mercury storage operations (88,500 liters [23,400 gallons]) would constitute about 

0.02 percent of KCP’s current water use. 

4.7.8 Waste Management 

Modification of the existing building at KCP for mercury storage is expected to generate much less than 

the 271 cubic meters (355 cubic yards) of nonhazardous solid waste and 9,850 liters (2,600 gallons) of 

nonhazardous sanitary liquid waste projected to be generated during construction of a new facility. 

Nevertheless, maximum waste-generation volumes are negligible compared with the current waste 

generation activities at KCP, as described in Chapter 3, Section 3.6.8.1. It is assumed that constructiongenerated solid waste would be disposed of off site at the Johnson County Mixed Solid Waste Landfill. 

Portable toilet facilities, serviced by a local or regional contractor, would be used to serve the sanitary 

needs of the construction workforce. 

Operation of a new mercury storage facility within the Main Manufacturing Building is expected to 

generate an estimated 910 55-gallon (208-liter) drums of hazardous waste over the 40-year period of 

analysis, as further described in Section 4.3.8. This equates to about 23 55-gallon drums, or 

approximately 5 cubic meters (6.5 cubic yards) annually. This estimated yearly hazardous waste 

generation rate is minor (about 6 percent) compared with the 17 metric tons (18.7 tons) of hazardous waste 
Environmental Consequences 

4–99

generated and managed each year at KCP (see Chapter 3, Section 3.6.8.1). If existing DOE operations at 

KCP end, the estimated volume of mercury-contaminated waste generated from mercury storage 

operations within the Main Manufacturing Building would still be relatively small compared with most 

RCRA TSD facility operations. KCP is currently a listed hazardous waste large-quantity generator. No 

changes in KCP’s generator status would be required to operate the proposed mercury storage facility. 

Facility operations would also generate an estimated 59,000 liters (15,600 gallons) of nonhazardous 

sanitary waste annually. This yearly generation rate is miniscule (0.02 percent) compared with the 

estimated 326 million liters (86 million gallons) of sanitary and pretreated industrial wastewater that KCP 

discharges to the Kansas City municipal sewer system each year (see Chapter 3, Section 3.6.3.1). 

DOE and the U.S. General Service Administration continue to investigate and remediate soil and 

groundwater contamination at several sites across the Bannister Federal Complex. Neither construction 

nor operation of the proposed mercury storage facility is anticipated to impact resources (e.g., funding, 

labor, facilities, and equipment) associated with current and/or future site environmental restoration 

efforts. 

4.7.9 Occupational and Public Health and Safety 

Mercury would be stored in the existing Bannister Federal Complex, where Honeywell operations occupy 

about 279,000 square meters (3 million square feet) of an even larger building, which has a height of about 

10 meters (33 feet). The mercury storage area itself would be approximately 14,000 square meters 

(150,000 square feet), a small fraction of the total area. Thus, the building wake is unrelated to the size of 

the mercury storage area. It is arbitrarily assumed to be of approximately 134 by 134 meters (500 by 

500 feet), but would likely be much larger.22 Most of the risks that pertain to KCP are the same as those 

discussed in Sections 4.2.9.1 through 4.9.2.5. 

4.7.9.1 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites. Consequences to the involved worker are predicted to be negligible 

because involved workers would never be exposed to airborne concentrations of mercury vapor above the 

ACGIH’s 8-hour TWA/TLV of 0.025 milligrams per cubic meter of mercury vapor. This corresponds to 

keeping exposures to the involved worker in the SL-I (negligible) range.23 This would be achieved by 

adherence to good operating practices, in particular attention to ventilation, inspection, monitoring, and 

use of PPE, as described in the Interim Guidance (DOE 2009c). Therefore, the risks to involved workers 

would be negligible during normal operations. 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 

3-L flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this source 

of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building wake. 

Appendix D, Section D.4.1.2, shows that the predicted long-term average concentration in the building 

wake at KCP is about 1.0 × 10-5 milligrams per cubic meter. Hence, consequences would be in the 

SL-I range, and the risk to both noninvolved workers and the public would be negligible. 

 

22 The simple building wake approximation in Appendix D, Table D–28, tends to break down if the building becomes very wide. 23 For definitions of SLs for various types of exposures, see Section 4.2.9.1.1 and Appendix D, Section D.1.1.1. For a discussion 

of how risk is assessed, see Sections 4.2.9.1.1 and D.1.1.2. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–100

4.7.9.2 Facility Accidents 

Section 4.2.9.1.4 provides a discussion of facility accident risks that applies to all sites. Table 4–3 

contains a summary of the likelihood of occurrence of candidate facility accident scenarios initiated by 

failures of engineered systems, human errors, or external events, and Table 4–4 lists the accident scenarios 

that remain for consequence analysis after eliminating those with negligible frequency from Table 4–3. 

The analysis of the scenarios at KCP is similar to that for the same scenarios in Section 4.2.9.1.4. The 

different dimensions of the buildings affect the building wake calculations, but do not affect conclusions 

about the magnitude of the risks. However, of all seven candidate sites, KCP is the one that is, without 

doubt, an urban site. This has the effect of increasing the ambient turbulence intensity in any specific 

weather condition, thus increasing the predicted rate of dilution and decreasing the predicted distance the 

plume would travel downwind before diluting below any specific benchmark. The atmospheric dispersion 

calculations show that, for the outside earthquake spill, the maximum distance downwind to which a 

concentration greater than AEGL-3 could be exceeded is less than 100 meters (330 feet); for AEGL-2, the 

corresponding distance is also less than 100 meters (330 feet); and for 0.1 × AEGL-2, it is about 

340 meters (1,115 feet). The distance to the closest site boundary from the proposed storage location 

within KCP is approximately 350 meters (1,150 feet), so consequences and corresponding risks to 

members of the public would be negligible. Table 4–47 summarizes the results for all accidental spills of 

elemental mercury on site (without fire). 

Table 4–47. Summary of Risks of all Onsite Elemental Mercury 

Spill Scenarios – Kansas City Plant 

Scenario Frequency Consequence Risk 

Spills Inside Buildinga

Involved worker FL-II – FL-III SL-I – SL-II N–L for all inside spills 

Noninvolved worker FL-II – FL-III SL-II N for all inside spills 

Member of the public FL-II – FL-III SL-II N for all inside spills 

Spills Outside Building 

Involved worker FL-II – FL-III SL-I – SL-II 

Noninvolved worker FL-II – FL-III SL-I – SL-II 

N–L for outside earthquake 

spill; N for all other outside 

spills 

Member of the public 

1-metric ton container 

spill 

FL-II SL-I N 

Single-pallet spill FL-III SL-I N 

Earthquake with building 

collapseb

FL-III SL-I N 

a The inside spill scenarios considered are single flask, single pallet, triple pallet, 1-metric-ton container, full spill tray under a 

pallet, and earthquake with intact building walls. 

b This scenario encompasses the risk from floods, high winds, and tornadoes. 

Key: FL=frequency level; L=low; N=negligible, SL=severity level. 

4.7.9.3 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury over a 40-year period of analysis to KCP. These 

assumptions, together with knowledge of truck routes and historical frequencies of crashes of various 

types, can be combined to produce estimates of the frequency at which crashes might occur anywhere 

along the routes traveled by mercury trucks or railcars. The results of the analysis are shown in 

Table 4–48. 
Environmental Consequences 

4–101

Table 4–48. Frequency Analysis of Truck and Railcar Accidents – Kansas City Plant 

Scenario 

Truck 

Miles 

Frequency of 

Accidents 

(per year) 

Frequency of 

Accidents 

with Spills 

(per year) 

Frequency of 

Accidents with 

Fires in Dry 

Weather 

(per year) 

Frequency of 

Accidents with 

Fires in Wet 

Weather 

(per year) 

Frequency of 

Accidents with 

Deatha

(per year) 

754,705 9.7×10-3 1.5×10-3 1.2×10-4 3.8×10-6 4.3×10 Truck – -4

Scenario 1 – Moderate – FL-III Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III

1,385,734 1.5×10-2 2.8×10-3 2.2×10-4 7.0×10-6 7.8×10 Truck – -4

Scenario 2 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III

250,966 1.6×10-3 7.2×10-6 1.6×10-5 5.1×10-7 1.0×10 Railcar -4

– Moderate – FL-III Low – FL-II Low – FL-II Negligible – FL-I Moderate – FL-III

a Fatality caused by mechanical impact, not by exposure to mercury. 

Note: To convert miles to kilometers, multiply by 1.60934. 

Key: FL=frequency level. 

The above frequencies are for an accident anywhere along any of the transportation routes taken over a 

40-year period of analysis to KCP. A crash that occurs in the last mile of the trip was used to estimate the 

frequency of an onsite crash in the vicinity of the storage building. The frequency of accidents with spills 

would be low under both truck scenarios and negligible under the Railcar Scenario. The frequency of 

crashes with fires or death would be negligible under all scenarios. 

With respect to transportation accidents involving spills of mercury, the following four scenarios were 

considered: 

 Spill of elemental mercury onto the ground without fire 

 Spill of elemental mercury directly into water 

 Fire with mercury spill 

 In dry weather 

 In wet weather 

4.7.9.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground 

Section 4.2.9.1.5 contains an analysis of spills of elemental mercury onto the ground following a truck or 

railcar crash without fire. A conservative estimate of the rate of evaporation from the resulting pool and 

the subsequent atmospheric dispersion (applicable to all sites) shows that a specific individual could not be 

exposed to concentrations that are greater than negligible if he or she lives more than 340 meters 

(1,115 feet) from a crash. Conservatively, assuming that the individual lives immediately adjacent to the 

road, that individual could only be exposed to such concentrations if the crash occurs along a specific 

680-meter (2,230-foot) stretch of any of the routes to KCP. The same reasoning as is used in the generic 

discussion in Section 4.2.9.1.5 shows that the risk to a member of the public from transportation spills 

onto the ground without fire en route to KCP would be negligible under Truck Scenario 1 and the Railcar 

Scenario, but low under Truck Scenario 2. 

4.7.9.3.2 Transportation Accident with Spill of Elemental Mercury Directly into Water 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 
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4–102

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors and humans (inorganic compounds 

of mercury and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

Table 4–49 summarizes the risks to human receptors arising from spillages of elemental mercury during 

transportation to KCP. 

Table 4–49. Summary of Transportation Risks to Human Receptors, Spills of 

Elemental Mercury onto the Ground or into Water, Kansas City Plant 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto the Ground 

Frequencya FL-I FL-II FL-I 

Consequence SL-II SL-II SL-II 

Risk Negligible Low Negligible 

Spill into Water 

Frequencyb FL-III FL-III FL-II 

Consequence SL-I – SL-II SL-I – SL-II SL-I – SL-II 

Riskc Negligible to low Negligible to low Negligible to low 

a Frequency at which that spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded. 

b Frequencies of railcar or truck crashes with spills from Table 4–48. 

c These estimates of risk are subject to large uncertainty. 

Key: FL=frequency level; SL=severity level. 

4.7.9.3.3 Transportation Accident with Fire 

The fire calculations are described in Section 4.2.9.1.5. Table 4–50 shows the results of the calculations 

of acute-inhalation risks from transportation accidents with fires on transportation routes to KCP. The 

table encompasses both truck scenarios and the Railcar Scenario. 

Note that the risks presented in the above scenario are individual risks: they are the answer to the question, 

“What is the risk to me?” This is not the same as the risk that, somewhere along a transportation route, 

airborne concentrations would exceed the various SLs. Those risks would in fact be higher. 
Environmental Consequences 

4–103

Table 4–50. Summary of Acute-Inhalation Risks to Human Receptors, 

Accidents with Fires, Transportation Routes to Kansas City Plant 

Both Truck Scenarios with Wooden Pallets Railcar Scenario with Wooden Pallets 

Frequencya FL-III FL-II 

Consequenceb SL-II FL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7.

b The highest consequence in any weather condition. 

Key: FL=frequency level; SL=severity level. 

The analyses performed for this EIS show that, under all fire scenarios listed in Table 4–50, with and 

without rain, mercury deposited on the ground would never cause the benchmark of 180 milligrams per 

kilogram to be exceeded. Therefore, the corresponding risks would be negligible. 

Table 4–51 summarizes the human health risks associated with all transportation spills. 

Table 4–51. Summary of Transportation Risks to Human Receptors, Kansas City Plant 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto ground Negligible Low Negligible 

Spill into water Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Spill with fire – inhalation, 

wooden pallets 

Low Low Low 

Spill with fire – dry and 

wet deposition, wooden 

pallets 

Negligible Negligible Negligible 

4.7.9.4 Intentional Destructive Acts 

The discussion of IDAs is the same for all sites and transportation routes (see Section 4.2.9.1.6). 

4.7.10 Ecological Risk 

There is a generic analysis of ecological risk in Section 4.2.10.1, which applies without modification to 

KCP. 

4.7.10.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike inorganic compounds 

formed from divalent mercury. As a result, risks to ecological receptors from slow leaks, accidental spills 

at storage sites, and spills without fires during transportation are considered to be negligible at all storage 

sites and along all transportation routes. 

4.7.10.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–104

which also makes the following conclusions regarding the consequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

ecological receptors could be managed so that they are negligible or low. Given this assumption and the 

fact that the frequency of crashes with spills on any of the transportation routes is no more than moderate 

(and this is an upper bound on the frequency of spills directly into water), the risk would be negligible or 

low for all transportation routes. However, because of the above-mentioned uncertainty about fastflowing rivers, this observation should be tempered by noting that the uncertainty regarding this prediction 

of risk is very large. 

4.7.10.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5, and 

Section 4.2.10.1. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. Table 4–52 summarizes the FL, consequence level, and risk to ecological receptors in the 

case of a truck crash with pallet fire and no rain (dry deposition) and applies to all candidate storage sites. 

Table 4–52. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, Kansas City Plant 

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Level Riskc

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

b Applies to both Truck Scenarios 1 and 2. 
Environmental Consequences 

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For the interpretation of Table 4–52, see Section 4.2.10.1.3. The risks of other potential fire scenarios are 

summarized as follows:

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–53. 

 For railcar crashes with wooden pallet fires and without rain (dry deposition), see Table 4–54. 

 The predicted frequency of railcar crashes with pallet fires and rain is negligible, so risks would 

be negligible and no summary table is presented. 

Table 4–53. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, Kansas City Plant 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Table D–16. 

b Applies to both Truck Scenarios 1 and 2. 

Table 4–54. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, Kansas City Plant 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Risk

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a Frequencies of railcar crashes with fires from Appendix D, Table D–14. 

4.7.10.4 Consequences – Intentionally Initiated Fire with Mercury Spill 

The consequences of intentionally initiated fires to ecological receptors are the same for all sites 

(see Section 4.2.10.1.4). 

4.7.11 Socioeconomics 

Under this alternative, existing space in KCP would be modified for long-term storage of elemental 

mercury. Employment during renovations is expected to be less than that estimated for constructing a new 

facility, as described in Section 4.3.11. Appendix C, Table C–1, summarizes the necessary modifications 

to bring the facility up to specifications to support mercury storage. Operation of the facility is estimated 

to require approximately eight individuals for routine maintenance and support activities during the first 

7 years, when higher volumes of shipments are expected, and approximately five individuals thereafter. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–106

Operation of the facility is not expected to generate substantial direct or indirect employment. The largest 

estimated increase in employment would only increase the ROI workforce by 0.001 percent. Thus, 

negligible impacts on socioeconomic conditions (i.e., overall employment, population trends, and traffic) 

in the ROI would result from implementing this alternative. 

Construction-related transportation needed to modify the existing facility, including employee vehicle 

trips and equipment and materials shipments, is not expected to adversely impact traffic conditions on 

roads leading to the site. It is likely that significantly fewer than the 45 vehicles estimated to construct a 

new mercury storage facility would be needed to support facility modifications (see Section 4.3.11). 

Therefore, construction-related transportation is expected to increase the average annual daily traffic count 

on Bannister Road by no more than 0.2 percent. 

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of elemental mercury to the site for storage. Appendix C, Section C.1, provides an estimate of the number 

of shipments by truck. The additional vehicles due to facility operations are not expected to noticeably 

increase traffic volumes on roads leading to the site. The greatest impact would be during the first 2 years 

of operations, when it is estimated that approximately 11 vehicles a day could increase the average annual 

daily traffic count on Bannister Road by less than 0.1 percent. During this time, it is estimated that up to 

78 shipments would be made each year. Approximately 96 percent of the additional vehicles would be 

attributed to employee transportation. 

4.7.12 Environmental Justice 

An analysis of populations in census block groups found that, of the 671 block groups within the 

16-kilometer (10-mile) radius of KCP, 172 contained a disproportionately high number of minority 

individuals, 2 contained a disproportionately high number of low-income individuals, and 74 contained a 

disproportionately high number of both minority and low-income individuals. A total of 423 block groups 

did not contain a disproportionately high number of minority or low-income individuals. Of the 41 census 

block groups within the 3-kilometer (2-mile) radius of KCP, 16 contained a disproportionately high 

number of minority individuals and 1 contained a disproportionately high number of both minority and 

low-income individuals. Twenty-four block groups within this ROI did not contain a disproportionately 

high number of minority or low-income individuals (see Chapter 3, Section 3.6.11). As discussed in 

Chapter 3, Section 3.6.1.1, and Section 4.7.1, the surrounding area includes residential, commercial, 

industrial, and public use lands; there would be no impacts on land use as a result of implementing the 

KCP alternative. Impacts on air quality under this alternative would be negligible, as discussed in 

Section 4.7.4.2. No impacts on ecological resources would occur under this alternative, as discussed in 

Section 4.7.5. There is a low probability of discovering American Indian archaeological sites in the KCP 

area; thus, there would be negligible impacts on American Indian cultural resources, as discussed in 

Chapter 3, Section 3.6.6.3, and Section 4.7.6.3. A negligible change in socioeconomic conditions would 

result under this alternative, as discussed in Section 4.7.11. 

An analysis of populations that may be susceptible due to disproportional human health impact factors 

within the area is presented in Chapter 3, Section 3.6.11. As discussed in Section 4.7.9, implementing the 

KCP alternative would result in negligible offsite human health risks from mercury emissions during 

normal operations and facility accidents. As discussed in Section 4.7.9.3, transportation accidents have 

been identified as posing a negligible-to-low human health risk following dry deposition onto the ground 

or into water bodies. If a transportation accident were to occur at or near the entrance to the facility, it 

would be reasonable to conclude that the consequences to human health of that accident would be borne 

by a disproportionately high number of minority and low-income individuals who reside in areas close to 

KCP. 
Environmental Consequences 

4–107

4.8 LONG-TERM MERCURY MANAGEMENT AND STORAGE AT SAVANNAH 

RIVER SITE 

Under this alternative, a new mercury storage facility would be constructed at DOE’s SRS. SRS occupies 

approximately 80,290 hectares (198,400 acres) and is located approximately 24 kilometers (15 miles) 

southeast of Augusta, Georgia, and 19 kilometers (12 miles) south of Aiken, South Carolina. Within this 

site, the new mercury storage facility would be built in E Area, as further described in Chapter 2, 

Section 2.4.7. 

4.8.1 Land Use and Visual Resources 

Negligible impacts on land use and visual resources are expected from construction and operation of a 

new mercury storage building within E Area of SRS. Construction of this new facility would require the 

disturbance of approximately 3.1 hectares (7.5 acres) for building construction and laydown areas 

(see Chapter 2, Section 2.3.1). The proposed mercury storage facility would be located in the northcentral portion of E Area. This area has been subject to disturbance from past operations. The completed 

facility boundary would similarly encompass approximately 3.1 hectares (7.5 acres) within its fenced 

perimeter, which corresponds to approximately 2.3 percent of the land comprising E Area. The footprint 

of the mercury storage building would occupy approximately 1.6 hectares (3.9 acres) of this area. 

Mercury storage operations would be compatible with current DOE waste management and storage 

operations conducted in this area. The low profile of the new building is not expected to affect the overall 

viewshed of this area from on- or offsite vantage points. Therefore, mercury storage operations would not 

result in a change to BLM VRM classifications. 

4.8.2 Geology, Soils, and Geologic Hazards 

4.8.2.1 Geology and Soils 

Construction of a new mercury storage facility in E Area at SRS would generally have the same direct 

impacts on geology and soils in terms of land area disturbed, depth of excavation, and geologic resource 

demands as described in Section 4.3.2.1. Geologic resources, including concrete and coarse aggregate 

(gravel) totaling 8,640 cubic meters (11,300 cubic yards), would be required for construction 

(see Appendix C, Table C–2) and would be procured from local and/or regional commercial vendors. 

Trenching may be necessary to install foundation footers or to connect the new mercury storage facility 

with existing utilities. Locations near existing structures and many open areas within the E Area perimeter 

have largely been disturbed by site clearing, grading, fill placement, and soil compaction. Excavation in 

E Area would encounter clayey and silty quartz sand sediments up to 18 meters (60 feet) thick 

(see Chapter 3, Section 3.7.2). No special construction techniques should be necessary to work in these 

materials. Nevertheless, a site survey and geotechnical study would be conducted to confirm site geologic 

characteristics for facility siting and engineering purposes. 

Natural and disturbed soils in E Area could be more prone to erosion. However, adherence to standard 

best management practices for soil erosion and sediment control during construction would serve to 

minimize soil erosion and loss (see Section 4.3.2.1). 

Due to the potential risk of excavating contaminated soils, the construction area would also be surveyed 

prior to any ground disturbance. Any contamination would be remediated as necessary. During 

operations, the previously disturbed areas would not be subject to long-term soil erosion and temporarily 

disturbed areas would be revegetated. There would be no additional impact on geology and soils from 

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

4–108

4.8.2.2 Geologic Hazards 

The Atlantic Coastal Plain tectonic province, in which SRS is located, is characterized by generally low 

seismic activity. SRS has been affected by distant earthquakes that have occurred within the state, 

including the Charleston earthquake of 1886, which is estimated to have produced a peak ground 

acceleration across SRS of 0.1 g and shaking of MMI VII to VIII (see Chapter 3, Section 3.7.2.3). 

MMI VII shaking can cause moderate damage in well-constructed, ordinary structures but is not expected 

to damage facilities that have been specially designed or upgraded to withstand the assessed hazards. 

MMI VIII motion can cause slight damage in specially designed structures and considerable damage in 

ordinary structures (see Appendix B, Table B–4). The predicted peak ground acceleration at the site from 

an earthquake with an annual probability of occurrence of 1 in 2,500 is 0.17 g. Peak ground motion in this 

range is only expected to cause slight to moderate damage to ordinary structures and negligible damage to 

structures designed in accordance with the assessed hazard. This magnitude of ground motion is also 

supported by the historical record for the area. As further described in Appendix B, Section B.3.2, DOE 

Order 420.1B and its companion guide (DOE Guide 420.1-2) require that facilities be designed, 

constructed, and operated so that the public, workers, and environment are protected from adverse impacts 

of natural phenomena hazards, including earthquakes. A newly designed and constructed mercury storage 

facility in E Area would be unlikely to suffer substantial structural damage from the predicted earthquake 

ground motion at the site. Thus, such ground motion would be unlikely to cause a breach in mercury 

containers from structural failure. 

An analysis of potential environmental consequences resulting from an earthquake-induced accident is 

described in Section 4.8.9.2. 

4.8.3 Water Resources 

4.8.3.1 Surface Water 

Facility construction activities are not expected to have any direct impact on surface water features, 

including Upper Three Runs Creek and its 100-year floodplain immediately to the north and the 

headwaters to Fourmile Branch located just to the south of E Area. While stormwater runoff from the 

construction site would be unlikely to reach either stream, appropriate soil erosion and sediment control 

measures and spill prevention and waste management practices would be employed to minimize 

suspended sediment, the transport of other deleterious materials, and potential water quality impacts, as 

noted in Section 4.3.3.1. All construction and other ground-disturbing activities would be conducted in 

accordance with SRS’s NPDES General Permit for stormwater discharges associated with construction 

activity (see Chapter 3, Section 3.7.3.1). 

Water demands for construction and operation of a new mercury storage facility in E Area would be 

similar to those described in Section 4.3.3.1. It is anticipated that water for construction and operations 

would be supplied via E Area’s groundwater supply system. Total annual consumption is estimated to be 

no more than about 88,500 liters (23,375 gallons). Depending on the number of personnel drawn from the 

existing DOE workforce at SRS, water use by dedicated mercury storage facility staff could be greatly 

reduced. These construction and operations volumes are relatively small compared with the volume of 

water currently withdrawn and used by DOE at SRS (see Section 4.8.7.2). 

As previously noted in Section 4.3.3.1, design, construction, and operation of the mercury storage facility 

would incorporate structural controls and practices to prevent the release of elemental mercury and to 

prevent any spills or other releases, should they occur as a result of abnormal operating conditions, from 

reaching soils or surfaces where they could be conveyed to surface waters or groundwater. Facility 

operations would be conducted in accordance with an ICP and SPCC plan, or equivalent plans as 

mandated by state requirements governing the site, which set forth the actions facility personnel would 
Environmental Consequences 

4–109

take to respond to fires, explosions, or any accidental release of mercury to air, soil, or surface water at 

the facility. 

E Area facilities are located outside the 100-year floodplain, and soils across the area are not subject to 

seasonally high water tables, based on the soils analysis. Nevertheless, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that DOE facilities be designed, constructed, and operated 

to protect the public, workers, and environment from natural phenomena hazards, including flooding, and 

specifically to adhere to the flood design and evaluation criteria specified in DOE Standards 1020-2002 

and 1023-95. The potential for sheet flooding and other precipitation effects (e.g., scour and erosion) 

would be included in the design of foundations, walls, roof structures, and drainage and stormwater 

management systems for the storage facility. Consequently, the new mercury storage facility would 

incorporate appropriate stormwater management controls to safely collect and convey stormwater from the 

facility while minimizing washout, soil erosion, and offsite water quality impacts. 

There would be no direct discharge of effluents to either surface water or groundwater from storage 

facility operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) 

would be generated and managed via the existing E Area sanitary waste system (see Section 4.8.8). 

4.8.3.2 Groundwater 

Facility construction is not expected to have any impact on groundwater hydrology or existing 

contaminant plumes beneath the area due to the depth to groundwater and the shallow depth of excavation. 

As the facility would be designed and operated to prevent any spills from reaching the ground, there 

would be no impact on groundwater from routine operations. 

4.8.4 Meteorology, Air Quality, and Noise 

4.8.4.1 Meteorology 

Meteorological events can result in damage to buildings such as mercury storage warehouses. The 

frequency and consequences of such events were considered in selecting the accident events evaluated in 

Section 4.8.9.2. As previously detailed and described in Section 4.3.4.1, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so 

that the public, workers, and environment are protected from adverse impacts of natural phenomena 

hazards, including meteorological events. RCRA-permitted facilities, such as the proposed mercury 

storage facility, must also meet applicable design, construction, and operation requirements under 

Title 40 of the CFR, Section 264.31, and applicable state RCRA requirements to prevent the release of 

stored wastes. As the SRS region is susceptible to regular occurrence of high winds and occasional 

hurricanes and tornadoes, the new mercury storage facility in E Area would be designed and constructed 

as appropriate to minimize the risk from meteorological phenomena. 

4.8.4.2 Air Quality 

Minor short-term air quality impacts would result from construction of a mercury storage building at SRS. 

These impacts would include an increase in criteria and toxic air pollutant concentrations from 

construction equipment emissions (see Appendix C, Section C.2.3). These emissions would occur over a 

6-month construction period and are not expected to result in exceedance of air quality standards. 

Emissions from operations of the new mercury storage facility would be very small, consisting of 

emissions from employee vehicles, trucks or trains, semiannual testing of emergency generators, and 

possibly mercury vapor from any spills or from mercury containers. No localized emissions from space 

heating are anticipated associated with mercury storage facility operations, as electric heating is 

anticipated for areas requiring climate control. Compliance with the conformity regulations is discussed in 

Appendix B, Section B.5.1.2. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–110

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

elemental mercury vapor escaping from storage containers or residual contamination. Mercury vapor 

transported downwind could then be inhaled by noninvolved workers (those outside the storage facility) or 

nearby offsite individuals. Appendix D, Section D.4.1, presents a conservative analysis that shows that for 

a long-term, undetected slow leak inside the proposed mercury storage facility, the predicted long-term 

average concentration in the building wake never exceeds 80 nanograms per cubic meter. The EPA 

threshold for chronic exposure to airborne mercury is 300 nanograms per cubic meter, so slow releases of 

mercury would have a negligible effect on noninvolved workers and the public, with a corresponding 

negligible risk. 

Air quality impacts from transportation of mercury to SRS would be similar to those discussed in 

Section 4.3.4.2. Truck and rail transport are discussed in more detail in Section 4.8.9.3. Estimated 

emissions from truck and rail transportation are presented in Tables 4–15 and 4–16. 

Annual carbon dioxide emissions would be highest during construction. The second highest year of 

carbon dioxide emissions would be the year 2013, at approximately 113 metric tons (124 tons) per year, as 

a result of moving mercury to the site by truck; these annual truck emissions would be greater than rail 

emissions from shipping mercury. As similarly noted in Section 4.3.4.2, such emissions would minimally 

add to global and U.S. annual emissions of carbon dioxide. Global climate change is further discussed in 

Section 4.11.4.2. 

4.8.4.3 Noise 

Short-term noise impacts at SRS could result from construction of a new mercury storage facility in 

E Area. These impacts would include some increase in traffic to the site and an increase in noise resulting 

from construction employee vehicles, equipment delivery, and heavy equipment operation. These impacts 

would occur during the 6-month construction period. Since the nearest noise-sensitive receptor, a 

residence, is located more than 9.7 kilometers (6 miles) from the site, the increase in noise levels at this 

location from construction equipment is expected to be negligible. The estimated average noise level 

during the daytime (8-hour equivalent sound level) from one item of construction equipment operating at 

this distance is estimated to be well below background sound levels. The increase in traffic noise levels 

along South Carolina Highways 19 and 25 from construction activity is expected to be less than 1 dBA 

since the increase in traffic resulting from construction would be much less than the existing traffic on 

Highways 19 and 125. 

Short-term noise impacts could occur along South Carolina Highways 19 and 125 as a result of increased 

truck activity during the period that elemental mercury is transported to the site. The resulting increase in 

day-night average noise levels along Highways 19 and 125 is expected to be less than 1 dBA. As such, 

the change in truck traffic is not expected to result in a change in noise levels along these routes or other 

shipping routes that would be noticeable to the public or result in an increase in annoyance. If the mercury 

is shipped by rail instead of by truck, some additional rail activity from placing railcars at the site could 

result in some increase in noise levels near the site. 

Operation of the mercury storage facility at SRS is expected to have a negligible impact on noise levels 

around the site since the noise sources would be limited to a few employee vehicles, occasional delivery 

trucks, and semiannual testing of the emergency generator. 

4.8.5 Ecological Resources 

4.8.5.1 Terrestrial Resources 

Construction of the proposed new mercury storage facility in E Area would result in ground-disturbing 

activities. Habitat in the immediate vicinity of E Area consists of disturbed land within a developed 
Environmental Consequences 

4–111

setting. Little native vegetation remains within the area of the proposed mercury storage facilities; 

impacts would be limited to introduced species in an already disturbed landscape. Adherence to best 

management practices for land cover management (e.g., washing down construction equipment and 

vehicle tire treads) would serve to reduce the chance of introducing invasive plant species. Impacts on 

animals from construction would be limited to species adapted to human disturbance. During operations, 

there would be no additional impacts on terrestrial resources, as temporarily disturbed areas beyond the 

facility footprint would be revegetated and/or would revert to more-natural conditions. 

4.8.5.2 Wetlands and Aquatic Resources 

No wetlands or aquatic resources exist within the area of the proposed mercury storage facilities within 

E Area. Therefore, no impacts on wetlands or aquatic habitats are expected. 

4.8.5.3 Threatened and Endangered Species 

No threatened or endangered species are known or are expected to exist in the vicinity of the proposed 

mercury storage facilities within E Area at SRS (see Chapter 3, Section 3.7.5.4). Thus, no impacts on 

threatened or endangered species are expected from facility modifications, construction, or operations. 

Consultations have been initiated with the appropriate U.S. Fish and Wildlife Service office and state 

wildlife agency to support this analysis (see Chapter 5, Section 5.4). 

4.8.6 Cultural and Paleontological Resources 

4.8.6.1 Prehistoric Resources 

No impacts on prehistoric resources are expected from construction or operations of a new mercury 

storage facility in E Area. The area has been previously disturbed and no such resources have been 

identified there (see Chapter 3, Section 3.7.6.1). 

4.8.6.2 Historic Resources 

There would be no impact on historic resources or structures potentially eligible for listing in the NRHP 

from mercury storage facility construction or operations, as E Area has been previously disturbed and no 

historic resources have been identified (see Chapter 3, Section 3.7.6.2). DOE has initiated consultation 

with the South Carolina SHPO to support this analysis (see Chapter 5, Section 5.4). 

4.8.6.3 American Indian Resources 

No American Indian sites have been identified in E Area. As E Area has been previously disturbed, there 

is a low probability that resources of interest to American Indian tribes would be affected from proposed 

construction and operations (see Chapter 3, Section 3.7.6.3). DOE has initiated the consultation process 

with area and regional tribal nations who may have an interest in the proposed action and alternatives 

(see Chapter 5, Section 5.4). Nevertheless, DOE has initiated consultation with the Catawba Indian 

Nation (see Chapter 5, Section 5.4). 

4.8.6.4 Paleontological Resources 

Construction of a new mercury storage facility is not expected to have any impact on unique 

paleontological resources, as no noteworthy resources have been identified in E Area (see Chapter 3, 

Section 3.7.6.4). 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–112

4.8.7 Site Infrastructure 

4.8.7.1 Ground Transportation 

Construction and operations of a new mercury storage facility at SRS are not expected to appreciably 

increase demands on the road and rail systems leading to the site. Projected peak traffic volumes and the 

number of shipments associated with mercury storage operations are presented in Section 4.8.11. 

4.8.7.2 Electricity, Fuel, and Water 

Utility resource demands and associated assumptions for construction and operation of a new mercury 

storage facility in SRS’s E Area would be very similar to those described in Section 4.3.7.2. SRS’s 

current annual electricity consumption is 8 percent of its annual capacity. Under this alternative, the 

projected annual operational electricity requirements (253 megawatt-hours) of a new mercury storage 

facility would have a negligible impact (0.07 percent increase) when compared with SRS’s sitewide 

annual electrical energy use. This increase could easily be accommodated by the sitewide and E Area’s 

existing electric power distribution infrastructure (see Chapter 3, Section 3.7.7.2). 

Diesel fuel availability at SRS is limited only by the ability to ship it to the site; volume can be increased 

as needed. Diesel fuel consumption (606 liters [160 gallons]) to support mercury storage operations 

would be negligible (0.10 percent increase) when compared with the annual sitewide consumption of 

diesel fuel (see Chapter 3, Section 3.7.7.3). 

Water requirements for construction and operation of a new mercury storage facility would be negligible 

compared with SRS’s sitewide water usage and capacity (see Chapter 3, Section 3.7.7.4). Water 

requirements during construction (1,270,000 liters [336,000 gallons]) would temporarily increase annual 

sitewide water consumption by about 0.07 percent. The annual water demand for mercury operations 

(88,500 liters [23,400 gallons]) would constitute about 0.005 percent of the site’s current consumption. 

4.8.8 Waste Management 

Waste generation associated with construction and operations of a new mercury storage facility in SRS’s 

E Area would be similar to that discussed in Section 4.3.8. Facility construction activities would generate 

an estimated 271 cubic meters (355 cubic yards) of nonhazardous solid waste and 9,850 liters 

(2,600 gallons) of nonhazardous sanitary liquid waste. These nonhazardous waste streams are minimal 

(less than 1 percent) compared with SRS’s 5-year average generation rate of nonhazardous waste 

(see Chapter 3, Section 3.7.8.1). It is assumed that construction-generated solid waste would be disposed 

of at the SRS Construction and Demolition Landfill, as is the current practice at the site. Portable toilet 

facilities, serviced by a local or regional contractor, would be used to serve the sanitary needs of the 

construction workforce. 

As further described in Section 4.3.8, operation of a new mercury storage facility at SRS is expected to 

generate an estimated 910 55-gallon (208-liter) drums of hazardous waste over the 40-year period of 

analysis. This equates to about 23 55-gallon drums or approximately 5 cubic meters (6.5 cubic yards) 

annually. This hazardous waste volume is minor (about 3 percent) compared with SRS’s 5-year average 

volume of hazardous waste generated sitewide (see Chapter 3, Section 3.7.8.1). As such, no impacts 

related to the generation of mercury-contaminated waste during the operation of the proposed mercury 

storage facility are expected. 

SRS is currently generating and managing RCRA-regulated mercury-contaminated and other hazardous 

waste. The hazardous waste is temporarily stored in existing RCRA-permitted hazardous waste storage 

buildings within the N Area and shipped off site to commercial RCRA-permitted TSD facilities. No 
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4–113

changes in SRS’s hazardous waste generator status would be required to construct and operate the 

proposed mercury storage facility. 

Facility operations would also generate an estimated 59,000 liters (15,600 gallons) of nonhazardous 

sanitary wastewater annually. This yearly generation rate is miniscule compared with SRS’s sitewide 

sanitary waste generation and other waste management activities (see Chapter 3, Section 3.7.8.1). 

Sanitary wastewater would either be discharged to existing sewer systems and/or septic systems that 

service E Area or to a new, dedicated sewage disposal system permitted by the South Carolina Department 

of Health and Environmental Control. 

DOE continues to manage several ongoing programs and projects at SRS in support of sitewide 

remediation. Neither construction nor operation of the proposed mercury storage facility is anticipated to 

impact resources (e.g., funding, labor, facilities, and equipment, etc.) associated with current and/or future 

site remediation efforts. 

Section 3155 of the National Defense Authorization Act for Fiscal Year 2002 (P.L. 107-107) requires a 

“Plan for Disposition” that is to specify a “means by which all such defense plutonium defense plutonium 

materials will be removed in a timely manner from the SRS for storage and disposal elsewhere” prior to 

SRS’s receiving surplus defense plutonium waste. The law does not include provisions that would 

regulate the storage of mercury within the proposed mercury storage facility. As such, the act is not 

anticipated to impact the construction and/or operation of the mercury storage facility at SRS. 

4.8.9 Occupational and Public Health and Safety 

If SRS is chosen as the site for mercury storage, a new facility would be built. Most of the risks that 

pertain to SRS are the same as those discussed in Sections 4.2.9.1 through 4.2.9.5. 

4.8.9.1 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites. Consequences to the involved worker are predicted to be negligible 

because involved workers would never be exposed to airborne concentrations of mercury vapor above 

ACGIH’s 8-hour TWA/TLV of 0.025 milligrams per cubic meter of mercury vapor. This corresponds to 

keeping exposures to the involved worker in the SL-I (negligible) range.24 This would be achieved by 

adherence to good operating practices, in particular attention to ventilation, inspection, monitoring, and 

use of PPE, as described in the Interim Guidance (DOE 2009c). Therefore, the risks to involved workers 

would be negligible during normal operations. 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 

3-L flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this source 

of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building wake. 

Appendix D, Section D.4.1.2, shows that the predicted long-term average concentration in the building 

wake for new construction is about 2.0 × 10-5 milligrams per cubic meter. This is well below EPA’s 

chronic-inhalation-exposure RfC of 3.0 × 10-4 milligrams per cubic meter. Hence, consequences would be 

in the SL-I range, and the risk to both noninvolved workers and the public would be negligible. 

 

24 For definitions of SLs for various types of exposures, see Section 4.2.9.1.1 and Appendix D, Section D.1.1.1. For a discussion 

of how risk is assessed, see Sections 4.2.9.1.1 and D.1.1.2. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–114

4.8.9.2 Facility Accidents 

Section 4.2.9.1.4 provides a discussion of facility accident risks that applies to all sites. Table 4–3 

contains a summary of the likelihood of occurrence of candidate facility accident scenarios initiated by 

failures of engineered systems, human errors, or external events, and Table 4–4 lists the accident scenarios 

that remain for consequence analysis after eliminating those with negligible frequency from Table 4–3. 

The analysis of the scenarios at SRS is exactly the same as for the same scenarios in Section 4.2.9.1.4, 

with the exception of a member of the public in the case of an outside earthquake spill. The atmospheric 

dispersion calculations show that, for this spill, the maximum distance downwind to which a concentration 

greater than AEGL-3 could be exceeded is less than 100 meters (330 feet); for AEGL-2, the corresponding 

distance is about 300 meters (980 feet); and for 0.1 × AEGL-2, it is 1.1 kilometers (0.68 miles). However, 

the distance to the closest site boundary from the proposed mercury storage facility is 8 kilometers 

(5 miles), so consequences and hence risks to members of the public would be negligible. Table 4–55 

summarizes the results for all accidental spills of elemental mercury on site (without fire). 

Table 4–55. Summary of Risks of all Onsite Elemental Mercury 

Spill Scenarios – Savannah River Site 

Scenario Frequency Consequence Risk 

Spills Inside Buildinga

Involved worker FL-II – FL-III SL-I – SL-II N–L for all inside spills 

Noninvolved worker FL-II – FL-III SL-II N for all inside spills 

Member of the public FL-II – FL-III SL-II N for all inside spills 

Spills Outside Building 

Involved worker FL-II – FL-III SL-I – SL-II 

Noninvolved worker FL-II – FL-III SL-I – SL-II 

N–L for outside earthquake spill; 

N for all other outside spills 

Member of the public 

1-metric ton container 

spill 

FL-II SL-I N 

Single-pallet spill FL-III SL-I N 

Earthquake with building 

collapseb

FL-III SL-I N 

a The inside spill scenarios considered are single flask, single pallet, triple pallet, 1-metric-ton container, full spill tray under a 

pallet, and earthquake with intact building walls. 

b This scenario encompasses the risk from floods, high winds, and tornadoes. 

Key: FL=frequency level; L=low; N=negligible; SL=severity level. 

4.8.9.3 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury over a 40-year period of analysis to SRS. These 

assumptions, together with knowledge of truck routes and historical frequencies of crashes of various 

types, can be combined to produce estimates of the frequency at which crashes might occur anywhere 

along the routes traveled by mercury trucks or railcars. The results of the analysis are shown in 

Table 4–56. 
Environmental Consequences 

4–115

Table 4–56. Frequency Analysis of Truck and Railcar Accidents – Savannah River Site 

Scenario 

Truck 

Miles 

Frequency of 

Accidents 

(per year) 

Frequency of 

Accidents with 

Spills (per year) 

Frequency of 

Accidents with 

Fires in Dry 

Weather 

(per year) 

Frequency of 

Accidents with 

Fires in Wet 

Weather 

(per year) 

Frequency of 

Accidents with 

Deatha 

(per year) 

869,314 1.1×10-2 1.8×10-3 1.4×10-4 4.4×10-6 4.9×10 Truck – -4

Scenario 1 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III 

1,682,503 1.7×10-2 3.3×10-3 2.7×10-4 8.6×10-6 9.4×10 Truck – -4

Scenario 2 – High –FL-IV Moderate – FL-III Moderate –FL-III Low – FL-II Moderate – FL-III 

304,329 1.9×10-3 8.8×10-6 2.0×10-5 6.4×10-7 1.2×10 Railcar -4

– Moderate – FL-III Low – FL-II Low – FL-II Negligible – FL-I Moderate – FL-III 

a Fatality caused by mechanical impact, not by exposure to mercury. 

Note: To convert miles to kilometers, multiply by 1.60934. 

Key: FL=frequency level. 

The above frequencies are for an accident anywhere along any of the transportation routes taken over a 

40-year period of analysis to SRS. A crash that occurs in the last mile of the trip was used to estimate the 

frequency of an onsite crash in the vicinity of the storage building. The frequency of accidents with spills 

would be low under both truck scenarios and negligible under the Railcar Scenario. The frequency of 

crashes with fires or death would be negligible under all scenarios. 

With respect to transportation accidents involving spills of mercury, the following four scenarios were 

considered: 

 Spill of elemental mercury onto the ground without fire 

 Spill of elemental mercury directly into water 

 Fire with mercury spill 

 In dry weather 

 In wet weather 

4.8.9.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground 

Section 4.2.9.1.5 contains an analysis of spills of elemental mercury onto the ground following a truck or 

railcar crash without fire. A conservative estimate of the rate of evaporation from the resulting pool and 

the subsequent atmospheric dispersion (applicable to all sites) shows that a specific individual could not be 

exposed to concentrations that are greater than negligible if he or she lives more than 340 meters 

(1,115 feet) from a crash. Conservatively, assuming that the individual lives immediately adjacent to the 

road, that individual could only be exposed to such concentrations if the crash occurs along a specific 

680-meter (2,230-foot) stretch of any of the routes to SRS. The same reasoning as is used in the generic 

discussion in Section 4.2.9.1.5 shows that the risk to a member of the public from transportation spills 

onto the ground without fire en route to SRS would be negligible under Truck Scenario 1 and the Railcar 

Scenario, but low under Truck Scenario 2. 

4.8.9.3.2 Transportation Accident with Spill of Elemental Mercury Directly into Water 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–116

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors and humans (inorganic compounds 

of mercury and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

Table 4–57 summarizes the risks arising from spillages of elemental mercury during transportation to 

SRS. 

Table 4–57. Summary of Transportation Risks to Human Receptors, Spills of Elemental Mercury 

onto the Ground or into Water, Savannah River Site 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto the Ground 

Frequencya FL-I FL-II FL-I 

Consequence SL-II SL-II SL-II 

Risk Negligible Low Negligible 

Spill into Water 

Frequencyb FL-III FL-III FL-II 

Consequence SL-I – SL-II SL-I – SL-II SL-I – SL-II 

Riskc Negligible to low Negligible to low Negligible to low 

a Frequency at which spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded. 

b Frequencies of railcar or truck crashes with spills from Table 4–56. 

c These estimates of risk are subject to large uncertainty. 

Key: FL=frequency level; SL=severity level. 

4.8.9.3.3 Transportation Accident with Fire 

The fire calculations are described in Section 4.2.9.1.5. Table 4–58 shows the results of the calculations 

of acute-inhalation risks from transportation accidents with fires on transportation routes to SRS. The 

table encompasses both truck scenarios and the Railcar Scenario. 

Note that the risks presented in the above scenario are individual risks: they are the answer to the question, 

“What is the risk to me?” This is not the same as the risk that, somewhere along a transportation route, 

airborne concentrations would exceed the various SLs. Those risks would in fact be higher. 
Environmental Consequences 

4–117

Table 4–58. Summary of Acute-Inhalation Risks to Human Receptors, 

Accidents with Fires, Transportation Routes to Savannah River Site 

Both Truck Scenarios with Wooden Pallets Railcar Scenario with Wooden Pallets 

Frequencya FL-III FL-II 

Consequenceb SL-II SL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7.

b The highest consequence in any weather condition. 

Key: FL=frequency level; SL=severity level. 

The analyses performed for this EIS show that, under all fire scenarios listed in Table 4–58, with and 

without rain, mercury deposited on the ground would never cause the benchmark of 180 milligrams per 

kilogram to be exceeded. Therefore, the corresponding risks would be negligible. 

Table 4–59 summarizes the human health risks associated with all transportation spills. 

Table 4–59. Summary of Transportation Risks to Human Receptors, Savannah River Site 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto ground Negligible Low Negligible 

Spill into water Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Spill with fire – 

inhalation, wooden pallets 

Low Low Low 

Spill with fire – dry and 

wet deposition, wooden 

pallets 

Negligible Negligible Negligible 

4.8.9.4 Intentional Destructive Acts 

The discussion of IDAs is the same for all sites and transportation routes (see Section 4.2.9.1.6). 

4.8.10 Ecological Risk 

There is a generic analysis of ecological risk in Section 4.2.10.1, which applies without modification to 

SRS. 

4.8.10.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike inorganic compounds 

formed from divalent mercury. As a result, risks to ecological receptors from slow leaks, accidental spills 

at storage sites, and spills without fires during transportation are considered to be negligible at all storage 

sites and along all transportation routes. 

4.8.10.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–118

which also makes the following conclusions regarding the condequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

ecological receptors could be managed so that they are negligible or low. Given this assumption and the 

fact that the frequency of crashes with spills on any of the transportation routes is no more than moderate 

(and this is an upper bound on the frequency of spills directly into water), the risk would be negligible or 

low for all transportation routes. However, because of the above-mentioned uncertainty about fastflowing rivers, this observation should be tempered by noting that the uncertainty regarding this prediction 

of risk is very large. 

4.8.10.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5, and 

Section 4.2.10.1. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. Table 4–60 summarizes the FL, consequence level, and risk to ecological receptors in the 

case of a truck crash with pallet fire and no rain (dry deposition) and applies to all candidate storage sites. 

Table 4–60. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, Savannah River Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

b Applies to both Truck Scenarios 1 and 2. 
Environmental Consequences 

4–119

For the interpretation of Table 4–60, see Section 4.2.10.1.3. The risks of other potential fire scenarios are 

summarized as follows: 

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–61. 

 For railcar crashes with wooden pallet fires and without rain (dry deposition), see Table 4–62. 

 The predicted frequency of railcar crashes with pallet fires and rain is negligible, so risks would 

be negligible and no summary table is presented. 

Table 4–61. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, Savannah River Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Table D–16. 

b Applies to both Truck Scenarios 1 and 2. 

Table 4–62. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, Savannah River Site 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Risk

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a Frequencies of railcar crashes with fires from Appendix D, Table D–14. 

4.8.10.4 Consequences – Intentionally Initiated Fire with Mercury Spill 

The consequences of intentionally initiated fires to ecological receptors are the same for all sites 

(see Section 4.2.10.1.14). 

4.8.11 Socioeconomics 

Under this alternative, a new facility for long-term storage of elemental mercury would be constructed in 

the SRS E Area. Employment during construction is expected to average 18 people for approximately 

6 months. Operation of the facility 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 approximately 5 individuals thereafter, resulting in an increase of the SRS workforce of less 

than 0.1 percent and an increase in the ROI workforce of 0.003. Neither construction nor operation of a 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–120

new facility is expected to generate substantial direct or indirect employment. Thus, negligible impacts on 

socioeconomic conditions (i.e., overall employment, population trends, and traffic) in the ROI would 

result from implementing this alternative. 

Construction-related transportation, including employee vehicle trips and equipment and materials 

shipments, is not expected to adversely impact traffic conditions on roads leading to the site. It is assumed 

that there would be approximately 1.5 employees per vehicle, and every vehicle is counted twice to 

account for round trips. It is estimated that average construction transportation of 45 vehicles a day could 

increase the average annual daily traffic counts by less than 1 percent, if utilizing Highway 19, to almost 

4 percent, if utilizing Secondary Road 64. It is likely that these additional vehicles would use a 

combination of routes; thus the additional traffic would not be concentrated on one particular route. 

Fifty-three percent of the vehicles would be attributed to employee transportation. 

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of elemental mercury to the site for storage. Appendix C, Section C.1, provides an estimate of the number 

of shipments by truck. The additional vehicles due to facility operations are not expected to noticeably 

increase traffic volumes on roads leading to the site. The greatest impact would be during the first 2 years 

of operations, when it is estimated that approximately 11 vehicles a day could increase the average annual 

daily traffic counts by no more than 0.1 percent, if utilizing Highway 19, to as much as approximately 

1 percent, if utilizing Secondary Road 62. During this time, it is estimated that up to 78 shipments would 

be made each year. Approximately 96 percent of the additional vehicles would be attributed to employee 

transportation. 

4.8.12 Environmental Justice 

An analysis of populations in census block groups found that, of the 15 block groups within the 

16-kilometer (10-mile) radius of the SRS E Area, 4 contained a disproportionately high number of 

minority individuals and none contained a disproportionately high number of low-income individuals. No 

populations have been identified within the 3-kilometer (2-mile) radius surrounding E Area 

(see Chapter 3, Section 3.7.11). As discussed in Chapter 3, Section 3.7.1.1, and Section 4.8.1, the 

surrounding area includes urban, residential, industrial, agricultural, and recreational land uses; there 

would be no offsite impacts on land use as a result of implementing the SRS alternative. Impacts on air 

quality under this alternative would be minor during construction and negligible during operations, as 

discussed in Section 4.8.4.2. Impacts on ecological resources are expected to be minimal under this 

alternative, as discussed in Section 4.8.5. There is a low probability that resources of interest to American 

Indian tribes occur in E Area at SRS; thus, there would be no impacts on American Indian cultural 

resources, as discussed in Chapter 3, Section 3.7.6.3, and Section 4.8.6.3. A negligible change in 

socioeconomic conditions would result under this alternative, as discussed in Section 4.8.11. 

An analysis of populations that may be susceptible due to disproportional human health impact factors 

within the area is presented in Chapter 3, Section 3.7.11. As discussed in Section 4.8.9, implementing the 

SRS alternative would result in negligible offsite human health risks from mercury emissions during 

normal operations and facility accidents. As discussed in Section 4.8.9.3, transportation accidents have 

been identified as posing a negligible-to-low human health risk following dry deposition onto the ground 

or into water bodies. Three of the four block groups identified that consist of a disproportionately high 

number of minority individuals are located at or near the site boundary along the potential transportation 

routes of South Carolina Highway 19 and adjoining U.S. Route 278. If a transportation accident were to 

occur at or near this site entrance, it would be reasonable to conclude that the consequences to human 

health of that accident would be borne by a disproportionately high number of minority individuals who 

reside in this area. 
Environmental Consequences 

4–121

4.9 LONG-TERM MERCURY MANAGEMENT AND STORAGE AT WASTE 

CONTROL SPECIALISTS, LLC 

Under this alternative, elemental mercury would be stored at the WCS site. WCS owns and commercially 

operates the 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 13 kilometers (8 miles) east of Eunice, New Mexico. Implementation of this 

alternative would involve interim use of the Container Storage Building (CSB) located in the existing 

facility complex at the site until a new facility could be constructed. The new mercury storage facility 

would be similar to that proposed at the other candidate sites and would be constructed at one of two 

identified locations (i.e., a north and a south site relative to the developed WCS facilities area) on the 

WCS site, as further described in Chapter 2, Section 2.4.8. In the following sections, differences in 

potential impacts between the two elements of the alternative are identified, where appropriate. 

4.9.1 Land Use and Visual Resources 

Minor impacts on land use and visual resources are expected from construction and operation of a new 

mercury storage building at WCS. Construction of this new facility would require the disturbance of 

approximately 3.1 hectares (7.5 acres) for building construction and laydown areas (see Chapter 2, 

Section 2.3.1). The proposed mercury storage facility would be located on relatively undisturbed land in 

either the northwestern or southwestern corners of the WCS facilities area and adjacent to the existing 

built-up facility complex. As an interim measure, elemental mercury could be stored in the existing CSB 

within the existing WCS facility complex (see Chapter 2, Figure 2–24). The completed facility boundary 

would similarly encompass approximately 3.1 hectares (7.5 acres) within its fenced perimeter, which 

corresponds to less than 1 percent of the land comprising the WCS site. The footprint of the mercury 

storage building would occupy approximately 1.6 hectares (3.9 acres) of this area. Mercury storage 

operations would be compatible with current WCS waste management and storage operations conducted 

in this area. No applicable land use plans, policies, or controls have been identified that would restrict 

storage of elemental mercury at this location (Beverly 2009a). The low profile of the new building is not 

expected to affect the overall viewshed of this area from on- or offsite vantage points. Therefore, mercury 

storage operations would not result in a change to BLM VRM classifications. 

4.9.2 Geology, Soils, and Geologic Hazards 

4.9.2.1 Geology and Soils 

Construction of a new mercury storage facility within the WCS perimeter fence would generally have the 

same direct impacts on geology and soils in terms of land area disturbed, depth of excavation, and 

geologic resource demands as described in Section 4.3.2.1. Geologic resources, including concrete and 

coarse aggregate (gravel) totaling 8,640 cubic meters (11,300 cubic yards), would be required for 

construction (see Appendix C, Table C–2) and would be procured from local and/or regional commercial 

vendors. Trenching may be necessary to install foundation footers or to connect the new mercury storage 

facility with existing utilities. Excavation adjacent to WCS would encounter sandy and clayey loam soils 

and caliche (calcium-cemented soils) developed from the Blackwater Draw Formation, which can be up to 

17 meters (55 feet) thick across the site (see Chapter 3, Section 3.8.2). This unit is further underlain by the 

pebbly and cherty caprock caliche to the north and northwest of the WCS facility complex and by the 

sands and gravels of the Ogallala-Antlers-Gatuna geologic unit to the south of the facilities area. Due to 

the depth of excavation even where trenching is required (i.e., up to 1.2 meters [4 feet]) and the locations 

being considered on the site, no effect on the underlying claystones and sandstones/siltstones is expected. 

While the presence of caliche hardpans presents a slight limitation for site development, standard 

excavation activities should be sufficient. Nevertheless, a site survey and geotechnical study would be 

conducted to confirm site geologic characteristics for facility siting and engineering purposes. This would 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–122

include an analysis to assess the potential for subsurface dissolution features or site-specific land 

subsidence. 

Natural soils at WCS, especially the eolian sands, could be more prone to erosion. However, adherence to 

standard best management practices for soil erosion and sediment control during construction would serve 

to minimize soil erosion and loss (see Section 4.3.2.1). During operations, the previously disturbed areas 

would not be subject to long-term soil erosion, and temporarily disturbed areas would be revegetated. 

Interim use of the existing WCS CSB for mercury storage would have a negligible impact on geology and 

soils. No exterior modifications would be required to the RCRA-permitted facility, although interior 

modifications would be performed to upgrade mechanical systems (see Appendix C, Table C–1). 

Nevertheless, adherence to standard best management practices for soil erosion and sediment control 

(e.g., use of sediment fencing, staked hay bales, mulching and geotextile matting, and rapid reseeding) in 

any disturbed areas would serve to minimize any soil erosion and loss. Geologic resource requirements 

would be minimal. 

4.9.2.2 Geologic Hazards 

The WCS site lies in the Central Basin Platform region, which has crustal properties that indicate 

minimum risk due to faulting and seismicity. Seismicity of the immediate WCS site region is relatively 

low, with historical earthquakes in the region having produced ground shaking up to MMI V 

(see Appendix B, Table B–4). The predicted peak ground acceleration at the site from an earthquake with 

an annual probability of occurrence of 1 in 2,500 is 0.12 g. Ground motion in this range could cause slight 

damage to ordinary structures, but is not expected to affect modern structures that have been designed and 

constructed to withstand the assessed hazard. DOE applies the seismic engineering provisions from the 

latest building codes as the minimum standard for the design, construction, and upgrade of its facilities. 

As further described in Appendix B, Section B.3.2, DOE Order 420.1B and its companion guide (DOE 

Guide 420.1-2) require that facilities be designed, constructed, and operated so that the public, workers, 

and environment are protected from adverse impacts of natural phenomena hazards, including 

earthquakes. The Order also stipulates natural phenomena hazards mitigation for DOE facilities. The new 

mercury storage facility would be sited and designed to address the risk from geologic hazards. The 

existing CSB would be evaluated and structural upgrades implemented, as necessary, prior to use. 

However, neither the existing CSB nor a newly designed and constructed mercury storage facility would 

be likely to suffer substantial structural damage from the maximum predicted earthquake ground motion at 

the site. Thus, such ground motion would be unlikely to cause a breach in mercury containers from 

structural failure. An analysis of potential environmental consequences resulting from an earthquakeinduced accident is described in Section 4.9.9.2. 

4.9.3 Water Resources 

4.9.3.1 Surface Water 

Facility construction activities at the WCS site are not expected to have any direct impact on surface-water 

features. The northern half of the WCS site drains toward an interior playa approximately 2.4 kilometers 

(1.5 miles) north-northeast of the WCS site, while the southern half of the site and the existing WCS 

facilities drain toward the ranch house drainage. This drainage feature crosses the WCS property about 

0.4 kilometers (0.25 miles) southeast of the existing WCS facilities and flows from east to west 

(see Chapter 3, Section 3.8.3.1). The new mercury storage facility would be sited to avoid these features 

and designed to minimize the risk from hydrologic and geologic hazards. Use of and interior modification 

of the existing CSB would not have any impact on surface-water features. The closest surface-water 

feature is the ranch house drainage, as discussed above. 
Environmental Consequences 

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Stormwater runoff from the construction site would be unlikely to reach the ranch house drainage or the 

playa, and appropriate soil erosion and sediment control measures and spill prevention and waste 

management practices would be employed to minimize suspended sediment, the transport of other 

deleterious materials, and potential water quality impacts, as noted in Section 4.3.3.1. An NPDES General 

Permit Notice of Intent would be filed to address stormwater discharges associated with construction 

activity (see Chapter 5, Section 5.3). Also, development and implementation of a stormwater pollution 

prevention plan would be required for the construction activity. 

Water demands for construction and operation of a new mercury storage facility on the WCS site would be 

similar to those described in Section 4.3.3.1. It is anticipated that water for construction and operations 

would be supplied via the existing WCS groundwater supply system. These construction and operations 

volumes are relatively small compared with the volume of water currently withdrawn and used by WCS 

on an annual basis (see Section 4.9.7.2). Water requirements to support interior modifications of the CSB 

would be very small compared with those for construction of the new mercury storage facility 

(see Section 4.3.3.1). It is anticipated that any water needed would be obtained from the existing WCS 

facility supply system. During CSB operations, it is expected that any incremental water use would be 

relatively small compared with existing WCS operations and limited to that required to serve the potable 

and sanitary needs of the storage facility workforce. Total annual consumption for interim use of the 

facility is estimated to be a fraction of the 88,500 liters (23,375 gallons) estimated to be required for 

operation of a new facility sized to store up to 10,000 metric tons (11,000 tons) of mercury. Further, there 

may be no net increase in water use at WCS, as use of the existing facility for elemental mercury storage 

would substitute for existing waste management activities, especially if mercury storage staff are drawn 

from the existing WCS workforce. 

As previously noted in Section 4.3.3.1, design, construction, and operation of the mercury storage facility 

would incorporate structural controls and practices to prevent the release of elemental mercury and to 

prevent any spills or other releases, should they occur as a result of abnormal operating conditions, from 

reaching soils or surfaces where they could be conveyed to surface waters or groundwater. As necessary, 

the CSB would be modified to meet these requirements (see Appendix C, Table C–1). Facility operations 

would be conducted in accordance with an ICP and SPCC plan, or equivalent plans as mandated by state 

requirements governing the site and existing operations, which set forth the actions facility personnel 

would take to respond to fires, explosions, or any accidental release of mercury to air, soil, or surface 

water at the facility. 

A hydraulic study was performed to delineate the 100- and 500-year floodplains for the ranch house 

drainage south of the WCS facility complex. The existing CSB and other existing WCS facilities are 

outside the delineated floodplains. Further, the existing topography and soil permeability prevent frequent 

ponding in the vicinity of the existing facilities and adjacent areas. Drainage from the existing WCS 

complex is conveyed southeast to the ranch house drainage. DOE Order 420.1B and its companion guide 

(DOE Guide 420.1-2) require that DOE facilities be designed, constructed, upgraded as necessary, and 

operated to protect the public, workers, and environment from natural phenomena hazards, including 

flooding, and specifically to adhere to the flood design and evaluation criteria specified in DOE 

Standards 1020-2002 and 1023-95. Additional surveys and a site-specific flood hazard analysis would be 

conducted, as necessary, as part of the site selection and design process for a new mercury storage facility. 

There would be no direct discharge of effluents to either surface water or groundwater from storage 

facility operations and no impact on water quality. Only nonhazardous sanitary wastewater (sewage) 

would be generated and managed via the existing WCS sanitary waste system (see Section 4.9.8). 

4.9.3.2 Groundwater 

Facility construction is not expected to have any impact on groundwater hydrology due to the depth of 

excavation relative to the depth of groundwater. Even across the northern and northwestern portions of 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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the WCS site where the new mercury storage facility could be constructed, the depth to the water table is 

approximately 24 meters (80 feet) (see Chapter 3, Section 3.8.3.2). 

Locally, the potential does exist for perched groundwater to be encountered by trenching to depths of no 

greater than about 1.2 meters (4 feet). In such cases, the excavations may have to be dewatered and the 

groundwater contained for testing and treatment, if found to be contaminated, prior to discharge. There 

would be no impact on groundwater from modifications to the CSB. 

As the facility would be designed and operated to prevent any spills from reaching the ground, there 

would be no impact on groundwater from routine operations. 

4.9.4 Meteorology, Air Quality, and Noise 

4.9.4.1 Meteorology 

Meteorological events can result in damage to buildings such as mercury storage warehouses. The 

frequency and consequences of such events were considered in selecting the accident events evaluated in 

Section 4.9.9.2. As previously detailed and described in Section 4.3.4.1, DOE Order 420.1B and its 

companion guide (DOE Guide 420.1-2) require that facilities be designed, constructed, and operated so 

that the public, workers, and environment are protected from adverse impacts of natural phenomena 

hazards, including meteorological events. RCRA-permitted facilities, such as the proposed mercury 

storage facility, must also meet applicable design, construction, and operation requirements under Title 40 

of the CFR, Section 264.31, and applicable state RCRA requirements to prevent the release of stored 

wastes. As the WCS site region is susceptible to regular occurrence of high winds, the existing CSB 

would be upgraded and the new mercury storage facility designed and constructed to withstand the 

potential for high winds and tornadoes and other meteorological events. 

4.9.4.2 Air Quality 

Minor short-term air quality impacts would result from construction of a mercury storage building at 

WCS. These impacts would include an increase in criteria and toxic air pollutant concentrations from 

construction equipment emissions (see Appendix C, Section C.2.3). These emissions would occur over a 

6-month construction period and are not expected to result in exceedance of air quality standards. 

Negligible, short-term air quality impacts with little or no measurable effect on air quality would result 

from modification of the existing CSB for interim mercury storage. Criteria and toxic air pollutant 

emissions from construction equipment (see Appendix C, Section C.2.3) would be limited to those from 

construction employee vehicles and work trucks, with no heavy equipment use expected. 

Emissions from operations of the new mercury storage facility would be very small, consisting of 

emissions from employee vehicles, trucks or trains, semiannual testing of emergency generators and 

possibly mercury vapor from any spills or from mercury containers. No localized emissions from space 

heating are anticipated associated with mercury storage facility operations, as electric heating is 

anticipated for areas requiring climate control. Compliance with the conformity regulations is discussed in 

Appendix B, Section B.5.1.2. Emissions and air quality impacts from operation of the CSB for mercury 

storage would be similar to but less than those described for new facility operations. 

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

elemental mercury vapor escaping from storage containers or residual contamination. Mercury vapor 

transported downwind could then be inhaled by noninvolved workers (those outside the storage facility) or 

nearby offsite individuals. Appendix D, Section D.4.1, presents a conservative analysis that shows that for 

a long-term, undetected slow leak inside the proposed mercury storage facility, the predicted long-term 

average concentration in the building wake never exceeds 80 nanograms per cubic meter. The EPA 

threshold for chronic exposure to airborne mercury is 300 nanograms per cubic meter, so slow releases of 
Environmental Consequences 

4–125

mercury would have a negligible effect on noninvolved workers and the public, with a corresponding 

negligible risk. 

Air quality impacts from transportation of mercury to WCS would be similar to those discussed in 

Section 4.3.4.2. Truck and rail transport are discussed in more detail in Section 4.9.9.3. Estimated 

emissions from truck and rail transportation are presented in Tables 4–15 and 4–16. 

Annual carbon dioxide emissions would be highest during construction. The second highest year of 

carbon dioxide emissions would be the year 2013 as a result of moving mercury to the site, when 

emissions would be approximately 229 metric tons (252 tons) per year, which would be more than rail 

emissions. As similarly noted in Section 4.3.4.2, such emissions would minimally add to global and 

U.S. annual emissions of carbon dioxide. Global climate change is further discussed in Section 4.11.4.2. 

4.9.4.3 Noise 

Short-term noise impacts at WCS could result from construction of a new mercury storage facility. These 

impacts would include some increase in traffic to the site and an increase in noise resulting from 

construction employee vehicles, equipment delivery, and heavy equipment operation. These impacts 

would occur during the 6-month construction period. Since the nearest noise-sensitive receptor, a 

residence, is located 5.6 kilometers (3.5 miles) from the site, the increase in noise levels at this location 

from construction equipment is expected to be negligible. The estimated average noise level during the 

daytime (8-hour equivalent sound level) from four items of construction equipment operating at this 

distance is estimated to be 13 dBA, which is well below background sound levels. The increase in traffic 

noise levels along Texas State Highway 176 from construction activity is expected to be less than 1 dBA 

since the increase in traffic resulting from construction would be much less than the existing traffic on 

Highway 176. Activities and associated noise impacts from modification of the CSB would be similar to 

but less than those described above. 

Short-term noise impacts could occur along Highway 176 as a result of increased truck activity during the 

period that elemental mercury is transported to the site. The resulting increase in day-night average noise 

levels along Highway 176 is expected to be less than 1 dBA. As such, the change in truck traffic is not 

expected to result in a change in noise levels along this route or other shipping routes that would be 

noticeable to the public or result in an increase in annoyance. If the mercury is shipped by rail instead of 

by truck, some additional rail activity from placing railcars at the site could result in some increase in 

noise levels near the site. 

Operation of the new mercury storage facility at WCS is expected to have a negligible impact on noise 

levels around the site since the noise sources associated with mercury storage would be limited to a few 

employee vehicles, occasional delivery trucks, and semiannual testing of the emergency generator. Noise 

impacts from mercury storage facility operations within the CSB would be similar to those discussed for 

the new mercury storage facility. 

4.9.5 Ecological Resources 

4.9.5.1 Terrestrial Resources 

Habitat in the immediate vicinity of the construction sites consists mainly of shrublands with grassy 

patches. The vegetation is typical of the surrounding region; common species include shinnery oak 

mesquite, and soapweed (WCS 2007:8–10, 83). Construction of the new mercury storage facility would 

result in the loss of 3.1 hectares (7.5 acres) of this land cover. Adherence to best management practices 

for land cover management (e.g., washing down construction equipment and vehicle tire treads) would 

serve to reduce the chance of introducing invasive plant species. Impacts on animals from construction 

would be limited to species adapted to human disturbance. During operations, there would be no 
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additional impacts on terrestrial resources, as temporarily disturbed areas beyond the facility footprint 

would be revegetated and/or would revert to more-natural conditions. 

Since an existing building (i.e., the CSB) would be used for interim mercury storage, no land would be 

disturbed and no terrestrial resources would be impacted. 

4.9.5.2 Wetlands and Aquatic Resources 

No wetlands or aquatic resources exist within the proposed locations of the new mercury storage facility at 

WCS. Therefore, no impacts on wetlands or aquatic habitats are expected. 

No land would be disturbed and no wetlands or aquatic resources would be impacted from use of the 

existing CSB. 

4.9.5.3 Threatened and Endangered Species 

No threatened or endangered species are known or are expected to exist within the area of the proposed 

mercury storage facilities at WCS. Thus, no impacts on threatened or endangered species are expected 

from facility modifications, construction, or normal operations. Consultations have been initiated with the 

appropriate U.S. Fish and Wildlife Service office and state wildlife agency to support this analysis (see 

Chapter 5, Section 5.4). 

4.9.6 Cultural and Paleontological Resources 

4.9.6.1 Prehistoric Resources 

No impacts on prehistoric resources are expected from construction of a new mercury storage facility or 

use of the existing CSB for mercury storage at WCS. A previous survey found an absence of prehistoric 

occupation or exploitation of the area. The potential to find buried deposits is low (see Chapter 3, 

Section 3.8.6.1). 

4.9.6.2 Historic Resources 

There would be no impact on historic resources from mercury storage facility construction or from 

operations. Surveys conducted found an absence of historic occupation or exploitation of the area 

(see Chapter 3, Section 3.8.6.1). The potential to find buried deposits is low, and there are no sites 

currently listed or nominated for listing in the NRHP. DOE has initiated consultation with the Texas 

SHPO to support this analysis (see Chapter 5, Section 5.4). 

4.9.6.3 American Indian Resources 

Previous surveys have not identified any American Indian resources on the site (see Chapter 3, 

Section 3.8.6.2); therefore, there would be no impact from use of the existing CSB or construction and 

operations of a new mercury storage facility. 

4.9.6.4 Paleontological Resources 

Construction and operations of a new mercury storage facility are not expected to have any impact on 

unique paleontological resources, as no such resources have been identified in deposits at WCS 

(see Chapter 3, Section 3.8.6.3). 
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4–127

4.9.7 Site Infrastructure 

4.9.7.1 Ground Transportation 

Construction and operations of a new mercury storage facility at WCS or use of the CSB is not expected to 

appreciably increase demands on the road and rail systems leading to the site. Projected peak traffic 

volumes and the number of shipments associated with mercury storage operations are presented in 

Section 4.9.11. 

4.9.7.2 Electricity, Fuel, and Water 

Utility resource demands and associated assumptions for construction and operation of a new mercury 

storage facility at WCS would be very similar to those described in Section 4.3.7.2. Under this alternative, 

the projected annual operational electricity requirements (253 megawatt-hours) of a new mercury storage 

facility would have a minor impact (7 percent increase) when compared with WCS’s current annual 

electrical energy use. It is expected that this increase could be accommodated by the site’s existing 

electric power distribution infrastructure (see Chapter 3, Section 3.8.7.2). 

Fuel availability is limited only by the ability to ship it to the site; volume can be increased as needed. 

Projected diesel fuel consumption (606 liters [160 gallons]) to support mercury storage operations would 

be negligible (0.7 percent increase) when compared with WCS’s annual consumption of diesel fuel 

(see Chapter 3, Section 3.8.7.3). 

Water requirements for construction and operation of a new mercury storage facility would be minor 

compared with WCS’s sitewide water usage, which is supplied by the Eunice, New Mexico, municipal 

water system. Water requirements during construction (1,270,000 liters [336,000 gallons]) would 

temporarily increase annual sitewide water consumption by about 5 percent. The annual water demand for 

mercury storage operations (88,500 liters [23,400 gallons]) would constitute about 0.4 percent of WCS’s 

current water use. 

4.9.8 Waste Management 

Both modification and operation of the existing CSB for interim mercury storage and construction and 

operation of a new mercury storage facility at WCS are expected to have a negligible impact on waste 

generation and waste management infrastructure. Internal modification of the CSB for interim mercury 

storage is expected to generate much less than the 271 cubic meters (355 cubic yards) of nonhazardous 

solid waste and 9,841 liters (2,600 gallons) of nonhazardous sanitary liquid waste projected to be 

generated during construction of a new facility. Nevertheless, the maximum volumes are negligible 

compared with the current waste generation and management activities at WCS, as described in Chapter 3, 

Section 3.8.8. It is assumed that construction-generated solid waste would be disposed of off site at the 

Lea County Landfill in New Mexico. Portable toilet facilities, serviced by a local or regional contractor, 

would be used to serve the sanitary needs of the construction workforce. 

Operation of the mercury storage facility within either the CSB or a new mercury storage facility is 

expected to generate an estimated 910 55-gallon (208-liter) drums of hazardous waste over the is 40-year 

operational period as further described in Section 4.3.8. This equates to about 23 55-gallon drums, or 

approximately 5 cubic meters (6.5 cubic yards) annually. This estimated yearly hazardous waste 

generation rate is minor (ranging from about 0.5 to 7 percent) compared with the hazardous waste volumes 

(which include mercury-contaminated waste) received and managed over the last several years by WCS 

(see Chapter 3, Section 3.8.8.1). WCS is a listed hazardous waste large-quantity generator. No changes in 

generator status would be required to operate the proposed mercury storage facility, nor are any substantial 

effects on WCS’s waste management infrastructure expected. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–128

New mercury storage facility operations would also generate an estimated 59,000 liters (15,600 gallons) of 

nonhazardous sanitary wastewater annually. Nonetheless, operation of the CSB is not expected to result in 

a substantial increase in sanitary waste generation as the facility is already in operation for other purposes. 

The projected annual generation of sanitary waste from operation of a new mercury storage facility is 

minor (about 6 percent) compared with the roughly 1 million liters (270,000 gallons) of wastewater 

collected and disposed of off site by a commercial sanitary waste contractor each year (see Chapter 3, 

Section 3.8.7.4). 

4.9.9 Occupational and Public Health and Safety 

If WCS is chosen as the site for mercury storage, a new facility would be built. Most of the risks that 

pertain to WCS are the same as those discussed in Sections 4.2.9.1 through 4.2.9.5. 

4.9.9.1 Normal Operations 

Normal operations are discussed in Appendix D, Section D.4.1. The considerations there are common to 

all of the proposed storage sites. Consequences to the involved worker are predicted to be negligible 

because involved workers would never be exposed to airborne concentrations of mercury vapor above 

ACGIH’s 8-hour TWA/TLV of 0.025 milligrams per cubic meter of mercury vapor. This corresponds to 

keeping exposures to the involved worker in the SL-I (negligible) range.25 This would be achieved by 

adherence to good operating practices, in particular attention to ventilation, inspection, monitoring, and 

use of PPE, as described in the Interim Guidance (DOE 2009c). Therefore, the risks to involved workers 

would be negligible during normal operations. 

For people outside the building during normal operations (noninvolved workers and members of the 

public), a chronic, long-term release is bounded by consideration of a full spill tray under a pallet of 

3-L flasks that remains undetected indefinitely (a highly conservative assumption given the expected 

inspection and monitoring activities within the storage building). The steady state release from this source 

of mercury vapor is assumed to leak from the building and to be mixed into its turbulent building wake. 

Appendix D, Section D.4.1.2, shows that the predicted long-term average concentration in the building 

wake for new construction is about 2.0 × 10-5 milligrams per cubic meter. This is well below EPA’s 

chronic-inhalation-exposure RfC of 3.0 × 10-4 milligrams per cubic meter. Hence, consequences would be 

in the SL-I range, and the risk to both noninvolved workers and the public would be negligible. 

4.9.9.2 Facility Accidents 

Section 4.2.9.1.4 provides a discussion of facility accident risks that applies to all sites. Table 4–3 

contains a summary of the likelihood of occurrence of candidate facility accident scenarios initiated by 

failures of engineered systems, human errors, or external events, and Table 4–4 lists the accident scenarios 

that remain for consequence analysis after eliminating those with negligible frequency from Table 4–3. 

The analysis of the scenarios at WCS is exactly the same as for the same scenarios in Section 4.2.9.1.4, 

with the exception of a member of the public in the case of an outside earthquake spill. The atmospheric 

dispersion calculations show that, for this spill, the maximum distance downwind to which a concentration 

greater than AEGL-3 could be exceeded is less than 100 meters (330 feet); for AEGL-2, the corresponding 

distance is about 300 meters (980 feet); and for 0.1 × AEGL-2, it is 1.1 kilometers (0.68 miles). The 

distance to the closest site boundary from the proposed mercury storage facility is about 70 meters 

(230 feet), so high consequences would not be exceeded beyond this boundary. The nearest residence is 

approximately 5.4 kilometers (3.4 miles) away. Therefore, the risk to resident members of the public 

would be negligible. Table 4–63 summarizes the results for all accidental spills of elemental mercury on 

site (without fire). 

 

25 For definitions of SLs for various types of exposures, see Section 4.2.9.1.1 and Appendix D, Section D.1.1.1. For a discussion 

of how risk is assessed, see Sections 4.2.9.1.1 and D.1.1.2. 
Environmental Consequences 

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Table 4–63. Summary of Risks of all Onsite Elemental Mercury 

Spill Scenarios – Waste Control Specialists, LLC 

Scenario Frequency Consequence Risk 

Spills Inside Buildinga

Involved worker FL-II – FL-III SL-I – SL-II N–L for all inside spills 

Noninvolved worker FL-II – FL-III SL-II N for all inside spills 

Member of the public FL-II – FL-III SL-II N for all inside spills 

Spills Outside Building 

Involved worker FL-II – FL-III SL-I – SL-II 

Noninvolved worker FL-II – FL-III SL-I – SL-II 

N–L for outside earthquake spill; 

N for all other outside spills 

Member of the public 

1-metric-ton container spill FL-II SL-I N 

Single-pallet spill FL-III SL-I N 

Earthquake with building 

collapseb

FL-III SL-I N 

a The inside spill scenarios considered are single flask, single pallet, triple pallet, 1-metric-ton container, full spill tray under a 

pallet, and earthquake with intact building walls. 

b This scenario encompasses the risk from floods, high winds, and tornadoes. 

Key: FL=frequency level; L=low; N=negligible; SL=severity level. 

4.9.9.3 Transportation 

Appendix D, Section D.2.7, describes the assumptions regarding the transportation of a total of up to 

10,000 metric tons (11,000 tons) of elemental mercury over a 40-year period of analysis to WCS. These 

assumptions, together with knowledge of truck routes and historical frequencies of crashes of various 

types, can be combined to produce estimates of the frequency at which crashes might occur anywhere 

along the routes traveled by mercury trucks or railcars. The results of the analysis are shown in 

Table 4–64. 

Table 4–64. Frequency Analysis of Truck and Railcar Accidents – Waste Control Specialists, LLC 

Scenario 

Truck 

Miles 

Frequency of 

Accidents 

(per year) 

Frequency of 

Accidents with 

Spills 

(per year) 

Frequency of 

Accidents with 

Fires in Dry 

Weather 

(per year) 

Frequency of 

Accidents with 

Fires in Wet 

Weather 

(per year) 

Frequency of 

Accidents with 

Deatha 

(per year) 

1,000,305 1.2×10-2 2.0×10-3 1.6×10-4 5.1×10-6 5.6×10-4 Truck – 

Scenario 1 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III

1,806,502 1.7×10-2 3.5×10-3 2.9×10-4 9.2×10-6 1.0×10-3 Truck – 

Scenario 2 – High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III

394,112 2.5×10-3 1.1×10-5 2.6×10-5 8.3×10-7 1.6×10-4 Railcar 

– Moderate – FL-III Low – FL-II Low – FL-II Negligible – FL-I Moderate – FL-III

a Fatality caused by mechanical impact, not by exposure to mercury. 

Note: To convert miles to kilometers, multiply by 1.60934. 

Key: FL=frequency level. 

The above frequencies are for an accident anywhere along any of the transportation routes taken over a 

40-year period of analysis to WCS. A crash that occurs in the last mile of the trip was used to estimate the 

frequency of an onsite crash in the vicinity of the storage building. The frequency of accidents with spills 

would be low under both truck scenarios and negligible under the Railcar Scenario. The frequency of 

crashes with fires or death would be negligible under all scenarios. 

With respect to transportation accidents involving spills of mercury, the following four scenarios were 

considered: 
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 Spill of elemental mercury onto the ground without fire 

 Spill of elemental mercury directly into water 

 Fire with mercury spill 

 In dry weather 

 In wet weather 

4.9.9.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground 

Section 4.2.9.1.5 contains an analysis of spills of elemental mercury onto the ground following a truck or 

railcar crash without fire. A conservative estimate of the rate of evaporation from the resulting pool and 

the subsequent atmospheric dispersion (applicable to all sites) shows that a specific individual could not be 

exposed to concentrations that are greater than negligible if he or she lives more than 340 meters 

(1,115 feet) from a crash. Conservatively, assuming that the individual lives immediately adjacent to the 

road, that individual could only be exposed to such concentrations if the crash occurs along a specific 

680-meter (2,230-foot) stretch of any of the routes to WCS. The same reasoning as is used in the generic 

discussion in Section 4.2.9.1.5 shows that the risk to a member of the public from transportation spills 

onto the ground without fire en route to WCS would be negligible under Truck Scenario 1 and the Railcar 

Scenario, but low under Truck Scenario 2. 

4.9.9.3.2 Transportation Accident with Spill of Elemental Mercury Directly into Water 

The consequences of the spillage of elemental mercury into a water body are discussed in Appendix D, 

Section D.5.4.2. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to humans 

(and ecological receptors) is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to humans (inorganic compounds of mercury and 

methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

humans could be managed so that they are negligible or low. Given this assumption and the fact that the 

frequency of crashes with spills on any of the transportation routes is no more than moderate (and this is 

an upper bound on the frequency of spills directly into water), the risk would be negligible or low for all 

transportation routes. However, because of the above-mentioned uncertainty about fast-flowing rivers, 

this observation should be tempered by noting that the uncertainty regarding this prediction of risk is very 

large. 

Table 4–65 summarizes the risks arising from spillages of elemental mercury during transportation to 

WCS. 
Environmental Consequences 

4–131

Table 4–65. Summary of Transportation Risks to Human Receptors, Spills of Elemental Mercury 

onto the Ground or into Water, Waste Control Specialists, LLC 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto the Ground 

Frequencya FL-I FL-II FL-I 

Consequence SL-II SL-II SL-II 

Risk Negligible Low Negligible 

Spill into Water 

Frequencyb FL-III FL-III FL-II 

Consequence SL-I – SL-II SL-I – SL-II SL-I – SL-II 

Riskc Negligible to low Negligible to low Negligible to low 

a Frequency at which spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded. 

b Frequencies of railcar or truck crashes with spills from Table 4–64. 

c These estimates of risk are subject to large uncertainty. 

Key: FL=frequency level; SL=severity level. 

4.9.9.3.3 Transportation Accident with Fire 

The fire calculations are described in Section 4.2.9.1.5. Table 4–66 shows the results of the calculations 

of acute-inhalation risks from transportation accidents with fires on transportation routes to WCS. The 

table encompasses both truck scenarios and the Railcar Scenario. 

Table 4–66. Summary of Acute-Inhalation Risks to Human Receptors, Accidents 

with Fires, Transportation Routes to Waste Control Specialists, LLC 

Both Truck Scenarios with Wooden Pallets Railcar Scenario with Wooden Pallets 

Frequencya FL-III FL-II 

Consequenceb SL-II SL-II 

Risk Low Low 

a Frequencies of railcar or truck crashes with spills and fires from Appendix D, Section D.2.7. 

b The highest consequence in any weather condition. 

Key: FL=frequency level; SL=severity level. 

Note that the risks presented in the above scenario are individual risks: they are the answer to the question, 

“What is the risk to me?” This is not the same as the risk that, somewhere along a transportation route, 

airborne concentrations would exceed the various SLs. Those risks would in fact be higher. 

The analyses performed for this EIS show that, under all fire scenarios listed in Table 4–66, with and 

without rain, mercury deposited on the ground would never cause the benchmark of 180 milligrams per 

kilogram to be exceeded. Therefore, the corresponding risks would be negligible. 

Table 4–67 summarizes the human health risks associated with all transportation spills. 

Table 4–67. Summary of Transportation Risks to Human Receptors, 

Waste Control Specialists, LLC 

Truck Scenario 1 Truck Scenario 2 Railcar Scenario 

Spill onto ground Negligible Low Negligible 

Spill into water Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Negligible to low within a 

large range of uncertainty 

Spill with fire – inhalation, 

wooden pallets 

Low Low Low 

Spill with fire – dry and 

wet deposition, wooden 

pallets 

Negligible Negligible Negligible 
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4.9.9.4 Intentional Destructive Acts 

The discussion of IDAs is the same for all sites and transportation routes (see Section 4.2.9.1.6).

4.9.10 Ecological Risk 

There is a generic analysis of ecological risk in Section 4.2.10.1, which applies without modification to 

WCS. 

4.9.10.1 Slow Leaks, Accidental Spills at Storage Sites, and Spills Without Fires During 

Transportation 

Ecological risks associated with slow leaks during normal operations and accidental spills arise from the 

escape of mercury vapors from containers during storage and handling. Ingestion of soil contaminated 

with mercury represents the greatest plausible long-term threat from mercury releases. As discussed in 

Appendix D, deposition of airborne mercury is the primary mechanism of soil contamination. However, 

elemental mercury is not subject to significant atmospheric deposition, unlike inorganic compounds 

formed from divalent mercury. As a result, risks to ecological receptors from slow leaks, accidental spills 

at storage sites, and spills without fires during transportation are considered to be negligible at all storage 

sites and along all transportation routes. 

4.9.10.2 Spills of Elemental Mercury into Water Bodies 

It is conceivable that, during transportation, there could be a crash and a resulting spill of elemental 

mercury into a river or other body of water. For an assessment of the physical and chemical phenomena 

that would control how such a spill might affect ecological receptors, see Appendix D, Section D.5.4.2, 

which also makes the following conclusions regarding the consequences of the spillage of elemental 

mercury into a water body. In summary: 

 The available understanding of the behavior of elemental mercury spilled into a river or other 

water body is subject to great uncertainty so that an estimate of the consequences to ecological 

receptors is not possible. 

 Should such a spillage occur, it appears that the processes that convert elemental mercury into 

forms that are potentially hazardous to ecological receptors (inorganic compounds of mercury 

and methylmercury) are slow and would generally allow ample time for cleanup. 

 If the spillage occurs onto the banks of a river or water body, but not directly into it, 

transportation to the water body would be slow, again allowing ample time for cleanup. 

The foregoing observations might break down if there is spillage into a fast-flowing river. 

The overall conclusion is that a direct spillage of mercury into a body of water could be of concern if it is 

not cleaned up, but that there is generally adequate time for such cleanup. Hence, the consequences to 

ecological risk could be managed so that they are negligible or low. Given this assumption and the fact 

that the frequency of crashes with spills on any of the transportation routes is no more than moderate (and 

this is an upper bound on the frequency of spills directly into water), the risk would be negligible or low 

for all transportation routes. However, because of the above-mentioned uncertainty about fast-flowing 

rivers, this observation should be tempered by noting that the uncertainty regarding this prediction of risk 

is very large. 
Environmental Consequences 

4–133

4.9.10.3 Transportation Spills with Fires 

Ecological risks associated with transportation spills with fires principally arise from ingestion of mercury 

in soil, wetland sediments, or water bodies. Some of this mercury subsequently is converted to 

methylmercury; this conversion is taken into account in the analysis in Appendix D, Section D.5, and 

Section 4.2.10.1. 

The following analysis of consequences considers truck and railcar crashes with fires, in each case with 

wooden pallets. Table 4–68 summarizes the FL, consequence level, and risk to ecological receptors in the 

case of a truck crash with a pallet fire and no rain (dry deposition) and applies to all candidate storage 

sites. 

Table 4–68. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, Waste Control Specialists, LLC 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota III (moderate) IV High 

Soil invertebrates III (moderate) IV High 

Plants III (moderate) II Low 

American robin III (moderate) II Low 

River otter III (moderate) II Low 

Aquatic biota III (moderate) I Negligible 

Short-tailed shrew III (moderate) I Negligible 

Great blue heron III (moderate) I Negligible 

Red-tailed hawk III (moderate) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Tables D–12 and D–13. 

b Applies to both Truck Scenarios 1 and 2. 

For the interpretation of Table 4–68, see Section 4.2.10.1.3. The risks of other potential fire scenarios are 

summarized as follows: 

 For truck crashes with wooden pallet fires and rain (wet deposition), see Table 4–69. 

 For railcar crashes with wooden pallet fires and without rain (dry deposition), see Table 4–70. 

 The predicted frequency of railcar crashes with pallet fires and rain is negligible, so risks would 

be negligible and no summary table is presented. 

Table 4–69. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, Waste Control Specialists, LLC 

Ecological Receptor 

Frequency Level of 

Crash with Firea Consequence Level Riskb

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) IV Moderate 

American robin II (low) IV Moderate 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) II Low 

Great blue heron II (low) II Low 

Red-tailed hawk II (low) I Negligible 

a Frequencies of truck crashes with spills from Appendix D, Table D–16. 

b Applies to both Truck Scenarios 1 and 2. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–134

Table 4–70. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, Waste Control Specialists, LLC 

Ecological Receptor 

Frequency Level of 

Crash with Fireb Consequence Level Risk 

Sediment-dwelling biota II (low) IV Moderate 

Soil invertebrates II (low) IV Moderate 

Plants II (low) III Low 

American robin II (low) II Low 

River otter II (low) II Low 

Aquatic biota II (low) II Low 

Short-tailed shrew II (low) I Negligible 

Great blue heron II (low) I Negligible 

Red-tailed hawk II (low) I Negligible 

a Frequencies of railcar crashes with fires from Appendix D, Table D–14. 

4.9.10.4 Consequences – Intentionally Initiated Fire with Mercury Spill 

The consequences of intentionally initiated fires to ecological receptors are the same for all sites 

(see Section 4.2.10.1.4). 

4.9.11 Socioeconomics 

Under this alternative, a new facility for long-term storage of elemental mercury would be constructed at 

WCS. Employment during construction is expected to average 18 people for approximately 6 months. 

Operation of the facility 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 

approximately 5 individuals thereafter, resulting in an increase of the existing WCS workforce of 

approximately 3 to 5 percent and an increase in the ROI workforce of approximately 0.2 percent. Neither 

construction nor operation of a new facility is expected to generate substantial direct or indirect 

employment. Thus, negligible impacts on socioeconomic conditions in the ROI would result from 

implementing this alternative. 

Construction-related transportation, including employee vehicle trips and equipment and materials 

shipments is not expected to adversely impact traffic conditions on roads leading to the site. It is assumed 

that there would be approximately 1.5 employees per vehicle, and every vehicle is counted twice to 

account for round trips. It is estimated that average construction transportation of 45 vehicles a day could 

increase the average annual daily traffic count on State Highway 176 by less than 2 percent; 53 percent of 

these vehicles would be attributed to employee transportation. 

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of elemental mercury to the site for storage. Appendix C, Section C.1, provides an estimate of the number 

of shipments by truck. The additional vehicles due to facility operations are not expected to noticeably 

increase traffic volumes on roads leading to the site. The greatest impact would be during the first 2 years 

of operations, when it is estimated that approximately 11 vehicles a day could increase the average annual 

daily traffic count on State Highway 176 by less than 0.5 percent. Approximately 96 percent of the 

additional vehicles would be attributed to employee transportation. 

4.9.12 Environmental Justice 

An analysis of populations in census block groups found that, of the eight block groups within the 

16-kilometer (10-mile) radius of WCS, one contained a disproportionately high number of minority 

individuals and none contained a disproportionately high number of low-income individuals. There are 

only two block groups within the 3-kilometer (2-mile) ROI, none of which contained a disproportionately 
Environmental Consequences 

4–135

high number of minority or low-income individuals (see Chapter 3, Section 3.8.11). As discussed in 

Chapter 3, Section 3.8.1.1, and Section 4.9.1, land use in the surrounding area includes industrial activity 

and ranching, and there would be no offsite impacts on land use as a result of implementing the WCS 

alternative. Impacts on air quality under this alternative would be minor during construction and 

negligible during operations, as discussed in Section 4.9.4.2. Impacts on ecological resources are expected 

to be minimal under this alternative, as discussed in Section 4.9.5. There have been no American Indian 

resources identified on WCS; thus, there would be no impacts on American Indian cultural resources, as 

noted in Chapter 3, Section 3.8.6.2, and Section 4.9.6.3. A negligible change in socioeconomic conditions 

would result under this alternative, as discussed in Section 4.9.11. 

An analysis of populations that may be potentially susceptible due to disproportional human health impact 

factors within the area is presented in Chapter 3, Section 3.8.11. As discussed in Section 4.9.9, 

implementing the WCS alternative would result in negligible offsite human health risks from mercury 

emissions during normal operations and facility accidents. As discussed in Section 4.9.9.3, transportation 

accidents have been identified as posing a negligible-to-low human health risk following dry deposition 

onto the ground or into water bodies. The block group identified that consists of a disproportionately high 

number of minority individuals is located approximately 10 kilometers (6 miles) to the west in the city of 

Eunice. If a transportation accident were to occur at or near the site entrance, it would be reasonable to 

conclude that the consequences to human health of that accident would not be borne by a 

disproportionately high number of minority individuals since the identified block group lies beyond the 

potentially impacted area of approximately 1.6 kilometers (1 mile), as discussed in Chapter 3, 

Section 3.2.11. 

4.10 CLOSURE 

At the end of their useful lives, proposed mercury storage facilities would be subject to closure. This 

would occur under all the action alternatives. Under the No Action Alternative, existing mercury storage 

facilities could also be subject to closure. 

The DOE mercury storage facilities would be closed in a manner that (1) minimizes the need for further 

maintenance and (2) controls, minimizes or eliminates, to the extent necessary to protect human health and 

the environment, postclosure escape of hazardous waste, hazardous constituents, and contaminated runoff 

to the ground or surface waters or to the atmosphere from the facility (40 CFR 264.11). All hazardous 

waste and hazardous waste residues would be removed from the facility, and remaining containers and any 

soil containing or contaminated with hazardous waste or hazardous waste residues would be 

decontaminated or removed (40 CFR 264.178). 

Closure would be executed in accordance with a detailed closure plan prepared by the facility operator 

(i.e., by DOE or DOE’s authorized contractor). This plan would be subject to review and approval by 

EPA or the state’s environmental protection agency responsible for permitting the long-term elemental 

mercury storage facility. The closure plan would also contain a credible site-specific cost estimate for 

these actions to allow DOE to allocate adequate funding such that closure activities could be conducted in 

a timely manner. 

Closure activities would involve removing any remaining elemental mercury in storage and transporting it 

to suitable TSD facilities, as appropriate. In addition, the closure plan would include a detailed description 

of the steps needed to remove or decontaminate all hazardous waste residues and contaminated 

containment system components, equipment, structures, and soils during closure (40 CFR 264.112(b)(4)). 

For example, storage facilities would be inspected for residual mercury contamination. Affected surfaces 

would then be cleaned with a mercury-absorbing cleaner, as appropriate. Any contaminated materials 

would be isolated and contained. Workers performing such inspections, testing, and cleanup activities 

would wear appropriate personal protective gear, including disposable coveralls and air filtration systems. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–136

Contaminated debris or soils, contaminated PPE, and other contaminated materials used for cleanup would 

be packaged prior to transport off site to a commercial hazardous waste management facility for mercury 

recovery, recycling, and/or disposal. 

It is not possible to project the volume of mercury-contaminated material that may be generated from 

closure activities. It is likely, however, that much less waste would be generated during closure than 

during normal facility operations. 

Closure activities are expected to occur mostly inside the storage facilities, except for the transport of 

wastes, and are expected to result in negligible air and water emissions. The cleaning procedure would be 

designed to minimize the release of any material to the air or water (i.e., mercury or cleaning agent). 

Therefore, air and water quality impacts from such activities are expected to be minor and human health 

risks to be low. Because the shipment of wastes resulting from closure should be limited to a few truck 

trips, impacts on traffic and transportation are expected to be negligible. As there would be little air or 

water emissions and no land disturbance, no impacts are expected on land use and visual resources, 

geology and soils, water resources, air quality and noise, ecological resources, cultural and paleontological 

resources, site infrastructure, or socioeconomics. 

Further analysis of alternatives for future use of mercury storage facilities is not possible at this time. 

Future plans for facility reuse or other disposition would be the subject of additional NEPA analysis, as 

appropriate. 

4.11 CUMULATIVE IMPACTS 

The cumulative impacts analysis has been conducted in accordance with the Council on Environmental 

Quality (CEQ) regulations that implement NEPA and the CEQ handbook, Considering Cumulative Effects 

Under the National Environmental Policy Act (CEQ 1997). 

4.11.1 Methodology and Analytical Baseline 

The CEQ regulations implementing NEPA 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). The regulations further explain that “cumulative effects can result from individually 

minor but collectively significant actions taking place over a period of time.” The cumulative impacts 

assessment is based on both geographic and time considerations. Both site (see Section 4.11.3) and global 

commons (see Section 4.11.4) cumulative impacts are addressed. 

The methodologies used to analyze cumulative impacts of the alternatives evaluated in this Mercury 

Storage EIS are described in more detail in Appendix B, Section B.12. The ROIs used in the cumulative 

impacts analysis were generally assumed to be within a 16-kilometer (10-mile) radius of each facility 

location. The general approach to the analysis involves the following process: 

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

conditions described in Chapter 3). 

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

described in Sections 4.3 through 4.9). 

 Reasonably foreseeable future actions were identified. 

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

estimated. 
Environmental Consequences 

4–137

The analysis of constructing and operating a mercury storage facility(ies) at each site determined that 

impacts on the various resource areas ranged from none, to negligible, to minor. No resource area at any 

of the seven candidate storage sites evaluated under the action alternatives was predicted to be impacted at 

a level greater than minor. In keeping with CEQ regulations (40 CFR 1508.7), those resource areas that 

were predicted to be impacted in a minor way were evaluated for their potential to contribute to 

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

cumulative impacts were not analyzed since there would be either no, or only a very small incremental 

increase in impacts on the resource within the ROI. Thus, cumulative impacts are not addressed for any of 

the alternative sites for geology and soils, water resources, cultural and paleontological resources, waste 

management, occupational and public health and safety, socioeconomics, or environmental justice. 

Two additional criteria used to determine whether project impacts could contribute to cumulative impacts 

within the ROI were land disturbance associated with new construction and air quality impacts resulting 

from mercury emissions. Thus, the following discussion of cumulative impacts addresses mercury 

emissions for all sites, land use impacts for sites where new construction is required, and resource areas 

for those sites where impacts were predicted to be minor. 

4.11.2 Potential Cumulative Actions 

Actions that may contribute to cumulative impacts include on- and offsite projects conducted by 

government agencies, businesses, or individuals that are within the 16-kilometer (10-mile) ROI considered 

in this Mercury Storage EIS. Information on present and future actions was gathered based on a review of 

local (i.e., city and county) and Federal Government information, as well as any known plans in the 

private sector. Additionally, NEPA documents were reviewed to determine if current or proposed projects 

could affect the cumulative impacts analysis. The potential actions listed in Table 4–71 are those that may 

contribute to cumulative impacts on or within the ROI of the seven candidate sites evaluated under the 

action alternatives. Potential contributions to cumulative impacts at non-DOE mercury storage sites under 

the No Action Alternative were not evaluated because potential changes at existing mercury storage sites 

are highly speculative. DOE’s Y–12 was not evaluated since, under the No Action Alternative, no change 

is expected to occur at the site relative to mercury management and storage. In general, those actions that 

are speculative, not yet well defined, or are expected to have a negligible contribution to cumulative 

impacts are not included in the cumulative impact estimates. 

4.11.3 Cumulative Impacts by Site 

Cumulative impacts are described for each site under consideration for mercury storage. 

4.11.3.1 Grand Junction Disposal Site 

The cumulative impacts of locating a mercury storage facility at GJDS on land use, visual resources, air 

quality, and infrastructure were evaluated and predicted to be negligible. Since there were either no or 

negligible impacts associated with locating a storage facility at GJDS on geology and soils, water 

resources, ecological resources, cultural and paleontological resources, waste management, occupational 

and public heath and safety, socioeconomics, and environmental justice, these resources were not 

evaluated with respect to their contribution to cumulative impacts. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–138

Table 4–71. Actions That May Contribute to Cumulative Impacts 

Location Description Reference 

Grand Junction Disposal Site 

Onsite DOE 

action 

Open portion of disposal cell will close in 2023 Geiser 2009 

Delta County, 

Colorado 

Construction of Solid Waste Disposal Facility Rice 2009 

Hanford Site 

Onsite DOE 

actions 

Central Plateau closure 

River Corridor Cleanup Project 

Continuing decommissioning of eight surplus production 

reactors and their support facilities in the 100 Areas 

Decommissioning of the N Reactor and its support 

facilities 

Actions involving the development and use of borrow 

pits 

Continued operation and development of additional 

disposal cells at the Environmental Restoration 

Disposal Facility near the 200-West Area 

Operation of the Waste Treatment Plant 

Development of an integrated disposal facility 

Closure of the high-level radioactive waste tanks, 

decommissioning of the Fast Flux Test Facility, and 

other actions specified in the Tank Closure and Waste 

Management Environmental Impact Statement for the 

Hanford Site, Richland, Washington

DOE 2009b 

Waste management operations at the Central Waste 

Complex 

DOE 2009d 

Onsite Non-DOE 

actions 

Management of the Hanford Reach National Monument 

and Saddle Mountain National Wildlife Refuge 

Operations of the US Ecology Commercial Low-Level 

Radioactive Waste Disposal Facility near the 200-East 

Area 

DOE 2009b 

Franklin County, 

Washington 

No major projects are planned for the portion of Franklin 

County, Washington, within the 16-kilometer ROI 

Wendt 2009 

Hawthorne Army Depot 

Long-term management of the defense stockpile of 

elemental mercury 

DLA 2004a 

Ongoing operations of the Defense Environmental 

Restoration Program 

DoD 2009 

Onsite DoD 

actions 

Construction and operations of 30-megawatt geothermal 

facility 

DoD 2008; The Humboldt 

Sun 2009 

Offsite action Construction and operations of transmission line Hawthorne 2009 

Mineral County, 

Nevada 

No major projects are planned within the 16-kilometer 

ROI 

Hartman 2009b 

Idaho National Laboratory 

Onsite DOE 

actions 

Construction and operations of Integrated Waste 

Treatment Unit 

INL 2009 

Idaho Cleanup Project CH2M-WG Idaho 2009a, 2009b, 

2009c 

Bingham 

County, Idaho 

No major projects are planned within the 16-kilometer 

ROI 

Mecham 2009 
Environmental Consequences 

4–139

Table 4–71. Actions That May Contribute to Cumulative Impacts (continued)

Location Description Reference 

Kansas City Plant 

Offsite action Plans within the 16-kilometer ROI include 

44 nonresidential, 46 residential, and 27 capital 

improvement projects 

Lebofsky 2009 

Offsite action U.S. Route 71 expansion near Grandview, Missouri Hicks 2009 

Savannah River Site 

Continued transformation of nuclear weapons complex to 

be smaller, more-responsive, efficient, and secure 

DOE 2008b:Table 3.16-4 

Construction and operations of MOX Fuel Fabrication 

Facility 

DOE and NNSA 2009 

Construction and operations of Pit Disassembly and 

Conversion Facility 

DOE 2008b:6.4, 6.5 

Construction and operations of Biomass Cogeneration 

Facility 

DOE 2008c 

High-level waste tank closure DOE 2002 

Onsite DOE 

actions 

Interim remedial action for the E Area low-level waste 

facility 

Sauerborn 2009 

Offsite action Expansion of Vogtle Electric Generating Plant NRC 2009; Owens 2009 

Waste Control Specialists, LLC, Site 

Widening of Texas State Highway 176 Beverly 2009b 

Construction and operation of Louisiana Energy Services 

National Enrichment Facility 

Operation of Wallac Quarry 

Operation of Lea County Landfill 

Operation of Sundance Services, Inc. 

(oilfield services company) 

Offsite actions 

Operation of DD Landfarm 

WCS 2009 

Note: To convert kilometers to miles, multiply by 0.6214. 

Key: DoD=U.S. Department of Defense; DOE=U.S. Department of Energy; MOX=mixed oxide; ROI=region of influence. 

4.11.3.1.1 Land Use 

A mercury storage facility at GJDS would require 3.1 hectares (7.5 acres) of land, with most construction 

taking place within the developed portion of the site. The only major project planned within the 

16-kilometer (10-mile) ROI is a landfill to be constructed in Delta County, Colorado. The landfill is to 

occupy 45 hectares (110 acres) south of GJDS near the Delta County line. Since construction of the 

mercury storage facility would be compatible with existing land use at GJDS, would largely take place on 

previously disturbed land, and would represent a relatively small portion of the planned development 

within a 16-kilometer (10-mile) radius, the mercury storage facility’s contribution to cumulative impacts 

on land use would be negligible. 

4.11.3.1.2 Visual Resources 

Construction of a new mercury storage facility at GJDS would result in a minor change to the visual 

environment. However, the overall BLM VRM Class IV rating of the site would not change. The new 

Delta County Landfill would be built on undisturbed land and would therefore change the visual 

appearance of the landfill site; however, these two projects are not within sight of each other. Thus, 

considering the minor change in the appearance of the GJDS and the distance between it and the proposed 

landfill, the mercury storage facility’s contribution to cumulative impacts on visual resources within the 

ROI would be negligible. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–140

4.11.3.1.3 Air Quality 

As noted in Section 4.4.4.2, construction of the mercury storage facility at GJDS would result in minor 

short-term impacts on air quality. Emissions would occur over a 6-month construction period and are not 

expected to result in exceedance of the ambient air quality standards. Due to the short duration of the 

construction phase of the project, the distance between GJDS and the proposed Delta County Landfill, as 

well as the likely difference in timing of the projects, cumulative impacts on air quality are unlikely. 

As described in Section 4.3.9.1, exposures to the public from small amounts of mercury vapor emitted 

from storage containers or residual contamination during operation of a mercury storage facility would be 

expected to have a negligible effect on public health. Mercury inhalation exposure to the public is 

primarily from exposure to elemental mercury, less than 50 percent of which can be attributed to local 

sources. Thus, it is regional and background sources that account for the majority of total mercury 

exposure, except where there are large nearby sources. Inhalation exposures are insignificant when 

compared with ingestion routes. The primary source of mercury emissions in the United States is coalfired utility boilers (33 percent of all emissions). Other sources include burning hazardous wastes 

(19 percent), commercial/industrial boilers (18 percent), medical waste incinerators (10 percent), chlorine 

production (4.5 percent), and broken mercury products (1 percent). An estimated breakdown of national 

emissions of mercury is presented in Volume II of the Mercury Study Report to Congress

(EPA 1997b:5-2). Less than half of the mercury deposition within the United States is estimated to come 

from sources within the country (EPA 1997b:5-3; 1997c:3-42; 1997e:5-2; 2009c:1; NADP 2005:11). 

Existing sources of mercury emissions in Mesa County, Colorado, include an electric utility plant and 

various landfills (EPA 2009d). The Delta County Landfill would be a potential future mercury emission 

source. For most of the public, inhalation exposures of elemental mercury are insignificant when 

compared with ingestion of methylmercury (EPA 1997b:5-2). 

Transportation of mercury to the storage facility would also result in minor short-term air quality impacts, 

as is the case for construction; these impacts are not likely to overlap in place and time with operations of 

the Delta County Landfill. Thus, considering the low levels of emissions, the distance between the two 

facilities, and potential differences in delivery routes and timing of deliveries, cumulative impacts would 

be negligible. 

4.11.3.1.4 Infrastructure 

Construction and operation of a mercury storage facility are not expected to appreciably increase demands 

on the transportation systems leading to the GJDS. Fuel and water requirements during construction and 

operation of the storage facility would be minimal and would not impact regional supplies. Both would be 

delivered by truck on an as-needed basis. Demands for these resources at the Delta County Landfill, while 

unknown at this time, also are not expected to impact local or regional supplies. Thus, cumulative impacts 

on fuel and water supplies are not expected. 

Electricity demand during construction would be minimal and would likely be supplied by a diesel-fired 

generator. However, during operation of the facility, electric power requirements would increase the site’s 

annual electrical energy consumption to 268 megawatt-hours. The increase would be nearly 2.5 times the 

site’s existing capacity. As a result, the electrical distribution infrastructure would need to be upgraded to 

provide adequate electricity for mercury storage facility operations. However, even considering the asyet-unknown electrical requirement of the Delta County Landfill, the increase in electric power usage 

within the ROI from these two projects is not expected to have a cumulative impact on the ability of 

Public Service Company of Colorado to supply power. 
Environmental Consequences 

4–141

4.11.3.2 Hanford Site 

The cumulative impacts of locating a mercury storage facility at Hanford on land use and air quality were 

evaluated and predicted to be negligible. Since there were either no or negligible impacts associated with 

locating a storage facility at Hanford on visual resources, geology and soils, water resources, ecological 

resources, cultural and paleontological resources, infrastructure, waste management, occupational and 

public heath and safety, socioeconomics, and environmental justice, these resources were not evaluated 

with respect to their contribution to cumulative impacts. 

4.11.3.2.1 Land Use 

A mercury storage facility would require 3.1 hectares (7.5 acres) of land within the 200-West Area, an 

area designated as Industrial-Exclusive (see Chapter 3, Section 3.3.1.1). Construction would take place 

within a 22-hectare (54-acre) disturbed area just to the south of CWC. As noted in Table 4–71, numerous 

projects with the potential to disturb a large area of land could take place at Hanford. Although Hanford is 

larger than the 16-kilometer (10-mile) ROI evaluated in this EIS, the cumulative impacts analysis 

presented within the Draft Tank Closure and Waste Management Environmental Impact Statement for the 

Hanford Site, Richland, Washington (TC & WM EIS) estimated that nearly 1,100 hectares (2,720 acres) of 

the site could be affected by past, present, and reasonably foreseeable future actions (DOE 2009b:T-6). 

Thus, since the mercury storage facility would be built within a disturbed area, would be compatible with 

existing land use, and would represent a very small percentage of potential Hanford land disturbance, the 

mercury storage facility’s contribution to cumulative impacts on land use would be negligible. 

One area of potential conflict with possible future development within the 200-West Area involves the 

area immediately to the west of CWC. Under certain alternatives considered in the TC & WM EIS

(DOE 2009b), this area would be used for certain facilities and an expansion of CWC. Although this area 

slightly overlaps the area selected for a mercury storage facility, both are large enough to easily 

accommodate proposed development. 

4.11.3.2.2 Air Quality 

As noted in Section 4.4.4.2, construction of the mercury storage facility at Hanford would result in minor 

short-term impacts on air quality. Emissions would occur over a 6-month construction period and are not 

expected to result in exceedance of the ambient air quality standards. Due to the short duration of the 

project, peak air pollutant concentrations from this and other Hanford projects would likely occur at 

different times. Thus, minor increases in air pollutants during construction of the mercury storage facility 

would be unlikely to contribute to cumulative air quality impacts. Emissions from tank closure and waste 

management activities at Hanford would result in elevated concentrations of carbon monoxide and 

particulate matter within the ROI (DOE 2009b). 

Exposures to the public from small amounts of mercury vapor emitted from storage containers or residual 

contamination during operation of a mercury storage facility are expected to have a negligible effect on 

public health. Sources of mercury inhalation exposure to the public are discussed in Section 4.11.3.1.3. 

Existing sources of mercury emissions in Benton County, Washington, include a manufacturing plant and 

a landfill (EPA 2009d). 

Transportation would also result in minor short-term air quality impacts, as is the case for construction 

impacts; these impacts are not likely to overlap in place and time with other projects and activities within 

the ROI. Since transportation-related air quality impacts associated with mercury storage and other 

activities within the ROI would be short term and are not expected to substantially change existing 

baseline conditions, their contribution to cumulative impacts would be negligible. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4–142

4.11.3.3 Hawthorne Army Depot 

The cumulative impact of locating a mercury storage facility at the Hawthorne Army Depot on air quality 

was evaluated and predicted to be negligible. Since there were either no or negligible impacts associated 

with locating a storage facility at the Hawthorne Army Depot on land use, visual resources, geology and 

soils, water resources, ecological resources, cultural and paleontological resources, infrastructure, waste 

management, occupational and public heath and safety, socioeconomics, and environmental justice, these 

resources were not evaluated with respect to their contribution to cumulative impacts. 

Negligible short-term air quality impacts would result from modification of existing structures for mercury 

storage in the Central Magazine Area. However, the proposed storage location is immediately adjacent to 

the area that will store DNSC mercury. The analysis of the impacts of storing DNSC mercury concluded 

that modifications to existing facilities would be negligible (DLA 2004a). Thus, considering that the 

Hawthorne Army Depot is in a rural area with few nearby sources of air pollution and few air quality 

issues, and that the modification of existing facilities to accommodate the storage of mercury for both the 

proposed DOE and DNSC projects would have negligible impacts, cumulative air quality impacts would 

be negligible. 

Exposures to the public from small amounts of mercury vapor emitted from storage containers or residual 

contamination during operation of a mercury storage facility are expected to have a negligible effect on 

public health. Sources of mercury inhalation exposure to the public are discussed in Section 4.11.3.1.3. 

There are no existing sources of mercury emissions reported in Mineral County, Nevada (EPA 2009d); 

however, the storage of DNSC mercury would be a potential future source of public exposure to elemental 

mercury. Still, the analysis of the impacts of storing DNSC mercury concluded that there would be 

negligible cumulative impacts on public health associated with storing DNSC mercury at Hawthorne 

Army Depot (DLA 2004a). Thus, considering the levels of mercury projected to be emitted from both 

storage projects, and that no other existing sources of mercury emissions are reported for Mineral County, 

it is unlikely that cumulative air quality impacts would result. 

As described in Section 4.5.4.2, air quality impacts from transporting mercury to a storage facility at the 

Hawthorne Army Depot were predicted to be minor and of short duration. Also, they are not likely to 

overlap in place and time with other activities within the ROI. For example, although shipments 

associated with the storage of mercury analyzed in this EIS would take place over the 40-year period of 

analysis, those associated with DNSC mercury would occur over a period of a few months (DLA 2004a). 

Other projects listed in Table 4–71 are also expected to have short-term transportation impacts on air 

quality. Since transportation-related air quality impacts associated with mercury storage and other 

activities within the ROI are not expected to substantially differ from existing baseline conditions, 

cumulative impacts would be negligible. 

4.11.3.4 Idaho National Laboratory 

The cumulative impacts of locating a mercury storage facility at INL on land use and air quality were 

evaluated and predicted to be negligible. Since there were either no or negligible impacts associated with 

locating a storage facility at INL on visual resources, geology and soils, water resources, ecological 

resources, cultural and paleontological resources, infrastructure, waste management, occupational and 

public heath and safety, socioeconomics, and environmental justice, these resources were not evaluated 

with respect to their contribution to cumulative impacts. 

4.11.3.4.1 Land Use – Idaho Nuclear Technology and Engineering Center 

A mercury storage facility at INTEC, which is located within the Central Core Area of INL, would require 

3.1 hectares (7.5 acres) of land. The Integrated Waste Treatment Unit, which is being constructed at 

INTEC as part of the Idaho Cleanup Project, is the only other major project being undertaken at INL. 
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Since both the proposed mercury storage facility and the Integrated Waste Treatment Unit would 

encompass limited acreage and would be compatible with existing land use at INL, their contributions to 

cumulative impacts on land use would be negligible. 

4.11.3.4.2 Land Use – Radioactive Waste Management Complex 

There would be no cumulative impacts on land use at INL if RWMC is the location selected for mercury 

storage. This is the case since an existing structure would be used in place of building a new facility. 

4.11.3.4.3 Air Quality 

As noted in Section 4.6.4.2, construction of the mercury storage facility at INTEC would result in minor 

short-term impacts on air quality, while those associated with modifying existing storage modules at 

RWMC would be negligible. Emissions at INTEC would occur over a 6-month construction period and 

are not expected to result in exceedance of ambient air quality standards. Due to the short duration of 

construction, peak air pollutant concentrations would likely occur at different times than those of the 

Integrated Waste Treatment Unit. Thus, increases in air emissions during construction of the mercury 

storage facility would be unlikely to contribute to cumulative air quality impacts. 

Exposures to the public from small amounts of mercury vapor emitted from storage containers or residual 

contamination during operation of a mercury storage facility are expected to have a negligible effect on 

public health. Sources of mercury inhalation exposure to the public are discussed in Section 4.11.3.1.3. 

Existing sources of mercury emissions in Bingham, Butte, and Jefferson Counties in Idaho include a food 

processing plant, INL, and various landfills (EPA 2009d). 

Air quality impacts from transporting mercury to a storage facility at either INTEC or RWMC would be 

minor, of short duration, and are not likely to overlap in place and time with those associated with the 

Integrated Waste Treatment Unit. Since transportation-related air quality impacts associated with mercury 

storage and the Integrated Waste Treatment Unit would be short term and are not expected to substantially 

change existing baseline conditions, their contribution to cumulative impacts would be negligible. 

4.11.3.5 Kansas City Plant 

The cumulative impacts of locating a mercury storage facility at KCP on air quality were evaluated and 

predicted to be negligible. Since there were either no or negligible impacts associated with locating a 

storage facility at KCP on land use, visual resources, geology and soils, water resources, ecological 

resources, cultural and paleontological resources, infrastructure, waste management, occupational and 

public heath and safety, socioeconomics, and environmental justice, these resources were not evaluated 

with respect to their contribution to cumulative impacts. 

As addressed in Section 4.7.4.2, negligible short-term air quality impacts with little or no measurable 

effect on air quality standards would result from modification of the existing Main Manufacturing 

Building at KCP. Also, exposures to the public from small amounts of mercury vapor emitted from 

storage containers or residual contamination during operation of a mercury storage facility are expected to 

have a negligible effect on public health. Sources of mercury inhalation exposure to the public are 

discussed in Section 4.11.3.1.3. Existing sources of mercury emissions in Jackson County, Missouri, and 

Wyandotte County, Kansas, include electric utility plants, several manufacturing plants, a water treatment 

plant, and various landfills (EPA 2009d). 

The transportation of mercury to a storage facility at KCP was predicted to have minor impacts on air 

quality; these impacts are not likely to overlap in place and time with the many other activities within the 

ROI (see Table 4–71). Due to the very large volume of traffic within the ROI, the limited air emissions 

from site-related traffic are not expected to substantially change baseline conditions; thus, their cumulative 

contributions to impacts on air quality would be negligible. 
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4.11.3.6 Savannah River Site 

The cumulative impacts of locating a mercury storage facility at SRS on land use and air quality were 

evaluated and predicted to be negligible. Since there were either no or negligible impacts associated with 

locating a storage facility at SRS on visual resources, geology and soils, water resources, ecological 

resources, cultural and paleontological resources, infrastructure, waste management, occupational and 

public heath and safety, socioeconomics, and environmental justice, these resources were not evaluated 

with respect to their contribution to cumulative impacts. 

4.11.3.6.1 Land Use 

A mercury storage facility would require 3.1 hectares (7.5 acres) of land. This disturbance would take 

place within E Area, which is located within the Industrial Core Management Area of SRS. As noted in 

Table 4–71, numerous projects, including the interim remedial action at the E Area low-level waste 

facility, are planned within the ROI both on and off SRS. These projects would generally take place 

within disturbed areas or be located adjacent to existing facilities. Since the mercury storage facility would 

represent a small percentage of potential future land disturbance within the ROI and would be compatible 

with existing land use, its contribution to cumulative impacts on land use would be negligible. 

4.11.3.6.2 Air Quality 

As noted in Section 4.8.4.2, construction of the mercury storage facility at SRS would result in minor 

short-term impacts on air quality. Emissions would occur over a 6-month construction period and are not 

expected to result in exceedance of the ambient air quality standards. Due to the short duration of the 

project, peak air pollutant concentrations from this and other projects within the ROI would likely occur at 

different times. Thus, minor increases in air pollutants during construction of the mercury storage facility 

would be unlikely to contribute to cumulative air quality impacts. Existing contributions of SRS activities 

to concentrations of particulate matter with an aerodynamic diameter less than or equal to 2.5 micrometers 

within the ROI approach the 24-hour average standard (see Chapter 3, Table 3–15). 

Exposures to the public from small amounts of mercury vapor emitted from storage containers or residual 

contamination during operation of a mercury storage facility are expected to have a negligible effect on 

public health. Sources of mercury inhalation exposure to the public are discussed in Section 4.11.3.1.3. 

Existing sources of mercury emissions in Aiken, Allendale, and Barnwell Counties, South Carolina, and 

Burke and Richmond Counties, Georgia, include electric utility plants, several manufacturing plants, SRS, 

and various landfills (EPA 2009d). 

Transportation of mercury to a storage facility at SRS would result in minor short-term air quality impacts. 

As is the case for construction, impacts are not likely to overlap in place and time with other projects and 

activities within the ROI. Since transportation-related air quality impacts associated with mercury storage 

and other activities within the ROI would be of short duration and are not expected to substantially change 

existing baseline conditions, their contribution to cumulative impacts would be negligible. 

4.11.3.7 Waste Control Specialists, LLC, Site 

The cumulative impacts of locating a mercury storage facility at WCS on land use, visual resources, air 

quality, and ecological resources were evaluated and predicted to be negligible. Since there were either no 

or negligible impacts associated with locating a storage facility at WCS on geology and soils, water 

resources, cultural and paleontological resources, infrastructure, waste management, occupational and 

public heath and safety, socioeconomics, and environmental justice, these resources were not evaluated 

with respect to their contribution to cumulative impacts. 
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4.11.3.7.1 Land Use 

A mercury storage facility at WCS, which would be constructed within an undeveloped portion of the site, 

would require 3.1 hectares (7.5 acres) of land. As noted in Table 4–71, there are a number of projects 

planned and under way within the ROI that would disturb a relatively large area of land within the ROI. 

Much of this development is concentrated along the State Highway 176 corridor (including widening of 

the highway itself) in the immediate vicinity of WCS. Although the mercury storage facility would add to 

the developing nature of the ROI, due to the limited area of disturbance, its contribution to cumulative 

impacts on land use would be negligible. 

There would be no cumulative impacts on land use at WCS from use of the existing CSB for interim 

mercury storage. 

4.11.3.7.2 Visual Resources 

The overall BLM VRM Class IV rating of the site would not change, but the facility would result in a 

minor change to the local visual environment. Although the mercury storage facility would add to the 

changing viewscape of the ROI, due to its location adjacent to existing facilities and relatively small size, 

its contribution to cumulative impacts on visual resources would be negligible. 

4.11.3.7.3 Air Quality 

As noted in Section 4.9.4.2, construction of the mercury storage facility at WCS would result in minor 

short-term impacts on air quality. Emissions would occur over a 6-month construction period and are not 

expected to result in exceedance of the ambient air quality standards. Due to the short duration of the 

project, peak air pollutant concentrations from this and other projects within the ROI would likely occur at 

different times. Thus, minor increases in air emissions during construction of the mercury storage facility 

would be unlikely to contribute to cumulative air quality impacts. 

Exposures to the public from small amounts of mercury vapor emitted from storage containers or residual 

contamination during operation of a mercury storage facility are expected to have a negligible effect on 

public health. Sources of mercury inhalation exposure to the public are discussed in Section 4.11.3.1.3. 

Existing sources of mercury emissions in Andrews County, Texas, and Lea County, New Mexico, include 

WCS and various landfills (EPA 2009d). 

Transportation of mercury to a storage facility at WCS would also result in minor short-term air quality 

impacts; as is the case for construction, these impacts are not likely to overlap in place and time with other 

projects and activities within the ROI. Since transportation-related air quality impacts associated with 

mercury storage and other activities within the ROI would be short term and are not expected to 

substantially change existing baseline conditions, their contribution to cumulative impacts would be 

negligible. 

Transportation impacts associated with use of the CSB would be similar to those described above for new 

facility construction. 

4.11.3.7.4 Ecological Resources 

A mercury storage facility could be built either to the north or south of the existing developed portion 

(facilities area) of WCS. Neither of these areas has been disturbed by current site development, and each 

exhibits terrestrial resources common to the area (see Chapter 3, Section 3.8.5). Construction of a 

mercury storage facility would result in the loss of 3.1 hectares (7.5 acres) of habitat. As noted in 

Table 4–71, numerous projects are planned, or have been built, within the ROI, with most development 

along the State Highway 176 corridor. While the total acreage involved is not available, all of these 

projects have disturbed native habitat. Although mercury storage facility construction would remove a 
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small area of habitat, its contribution to cumulative impacts on terrestrial resources would be negligible. 

Due to the lack of occurrence of (or disturbance to) wetlands, aquatic resources, or threatened or 

endangered species within the potential development sites, the new facility would not contribute to 

cumulative impacts on those resources. 

4.11.4 Global Commons Cumulative Impacts 

Cumulative effects may also occur on a global scale. Both ozone depletion and global climate change are 

addressed below as they relate to the proposed mercury storage facility. 

4.11.4.1 Ozone Depletion 

The Mercury Storage EIS alternatives are not expected to use or discharge substantial quantities of any 

ozone-depleting compounds. Construction and operations activities would be accomplished using 

materials and equipment formulated to be compliant with laws and regulations to reduce the use of ozonedepleting compounds. Any release of ozone-depleting compounds would be incidental to the conduct of 

the Mercury Storage EIS activities. Emissions of ozone-depleting compounds would be very small and 

would represent a negligible contribution to the destruction of the Earth’s protective ozone layer. 

4.11.4.2 Global Climate Change 

The “natural greenhouse effect” is the process by which part of terrestrial radiation is absorbed by gases in 

the atmosphere, warming the Earth’s surface and atmosphere. This greenhouse effect and the Earth’s 

radiation balance are affected largely by water vapor, carbon dioxide, and trace gases, which absorb 

infrared radiation and are referred to as greenhouse gases. Other greenhouse gases include nitrous oxide, 

halocarbons, and methane. 

There is consensus among scientists, including those on the Intergovernmental Panel on Climate Change 

(IPCC), that increases in atmospheric concentrations of certain pollutants can produce changes in the 

Earth’s atmospheric energy balance and thereby influence global climate. These pollutants are commonly 

referred to as “greenhouse gases,” and this warming effect is referred to as “global warming.” Water 

vapor (1 percent of the atmosphere) is the most common and dominant greenhouse gas; only small 

amounts of water vapor are produced as the result of human activities. The principal greenhouse gases 

resulting from human activities are carbon dioxide, methane, nitrous oxide, and halocarbons. Halocarbons 

include chlorofluorocarbons; hydrofluorocarbons, which are replacing chlorofluorocarbons as refrigerants; 

and perfluorocarbons, which are a byproduct of aluminum smelting. Other gases of concern include sulfur 

hexafluoride, which is widely used in insulation for electrical equipment. These gases are released in 

different quantities and have different potencies in their contributions to global warming (IPCC 2007; 

Justus and Fletcher 2006). 

Sources of anthropogenic carbon dioxide include combustion of fossil fuels such as natural gas, oil, 

gasoline, and coal. It is estimated that carbon dioxide atmospheric levels have risen by more than 

35 percent since the preindustrial period (since 1750) as a result of human activities. Emissions of other 

greenhouse gases have also risen. Annual global emissions of carbon dioxide were estimated to be 

26.4 billion metric tons (29.1 billion tons) per year from 2000 through 2005 from fossil fuel use 

worldwide (IPCC 2007:3). Carbon dioxide is the most important anthropogenic greenhouse gas and is 

therefore of primary concern in this EIS. 

The IPCC concluded that warming of the Earth’s climate system is unequivocal, and that most of the 

observed increase in global average temperatures is very likely due to the observed increase in 

anthropogenic greenhouse gas concentrations. The IPCC reports potential impacts from warming of the 

climate system, including expansion of sea water volume; decreases in mountain glaciers and snow cover 
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resulting in sea level rise; changes in arctic temperatures and ice; changes in precipitation, ocean salinity, 

and wind patterns; and changes in extreme weather (IPCC 2007:3–8). 

The release of anthropogenic greenhouse gases and their potential contribution to global warming are 

inherently cumulative phenomena. Cumulative impacts of the emission of carbon dioxide and other 

greenhouse gases from Mercury Storage EIS alternatives and other activities at the candidate sites and 

throughout the region would contribute to changes related to global climate discussed above. As 

described in this chapter (see Tables 4–15 and 4–16) and Appendix C, Section C.2, the Mercury Storage

EIS alternatives could produce various quantities of carbon dioxide from construction and operation. 

Specifically, the emission estimates for the Mercury Storage EIS alternatives account for facility-specific 

fuel-burning sources from construction activity and mobile source emissions from mercury shipments. 

Emissions from employee vehicles and indirect emissions from electricity use were not estimated. 

Greenhouse gas emissions projected from the proposed mercury storage facility are relatively small 

compared with the 26.4 billion metric tons (29.1 billion tons) of carbon dioxide emitted worldwide from 

fossil fuel use (IPCC 2007:3) and the 5.98 billion metric tons (6.59 billion tons) (EPA 2008:ES-5) of 

estimated U.S. carbon dioxide emissions in 2006. However, emissions from the storage facility(ies), in 

combination with past and future emissions from all other sources, would contribute incrementally to the 

climate change impacts described above. Although the cumulative emissions of greenhouse gases and the 

impacts on global climate and the resulting environmental, economic, and social consequences could be 

significant, at present there is no methodology that would allow DOE to estimate the specific impacts (if 

any) this increment of climate change would produce in the vicinity of the storage facility(ies) or 

elsewhere. 

4.12 MITIGATION MEASURES 

This section summarizes the mitigation measures that could be used to avoid or reduce environmental 

impacts resulting from implementation of the alternatives, as described in the preceding sections. As 

specified in CEQ’s NEPA regulations (40 CFR 1508.20), mitigation includes the following: 

 Avoiding impacts altogether by not taking a certain action or parts of an action 

 Minimizing impacts by limiting the degree or magnitude of the action and its implementation 

 Rectifying impacts by repairing, rehabilitating, or restoring the affected environment 

 Reducing or eliminating impacts over time by preserving and maintaining the affected 

environment during duration of the action 

 Compensating for impacts by replacing or providing substitute resources or environments 

Following the completion of an EIS and its associated Record of Decision (ROD), DOE is required to 

prepare a mitigation action plan that addresses any mitigation commitments expressed in the ROD 

(10 CFR 1021.331). If the ROD contains no mitigation commitments, a mitigation action plan is not 

required. The mitigation action plan would explain how certain measures would be planned and 

implemented to mitigate any adverse environmental impacts identified in the ROD. The mitigation action 

plan would be prepared before DOE would take any action requiring mitigation. 

As described throughout this chapter, the impacts of construction and normal operations of the 

DOE-designated mercury storage facility(ies) would be negligible to minor and would not require 

mitigation to reduce impacts to acceptable levels. Activities associated with the establishment of a new 

mercury storage facility would follow standard procedures for minimizing construction impacts on such 

resources as air quality and surface water, as well as operational impacts on public health and safety, 
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including accident prevention. These practices are required by Federal and state licensing and permitting 

requirements, as noted throughout this chapter and further discussed in Chapter 5. Further, DOE has 

considered mitigation in the formulation of the alternatives as currently proposed, which serve to prevent 

or reduce short- and/or long-term environmental impacts. Specifically, site location, design, and 

construction of the proposed new mercury storage facility would be conducted in accordance with the 

standards specified under Title 40 of the CFR, Part 264, for hazardous waste TSD facilities. These include 

but are not limited to the location and performance standards for new RCRA-permitted facilities under 

Title 40 of the CFR, Section 264.18 that address seismic considerations, floodplains, and other natural 

hazards. 

Nonetheless, mitigation measures could be used to further reduce potential mercury vapor emissions from 

mercury storage facility operations. Although mercury vapor emissions during normal operations would 

be below all applicable standards, emissions could be further reduced by using mercury vapor filters and 

by lowering the temperature of the air in the storage building through the use of air conditioning. Filters 

would actively remove mercury vapor as air passes through the filters, and air conditioning would reduce 

mercury vapor emissions because cooler temperatures result in less mercury vaporization. Although 

mercury vapor filters could be used to further reduce mercury emissions, these filters would require 

expensive changes in facility design, as well as changes in operations and maintenance procedures. They 

would also generate additional hazardous waste (e.g., spent filters) requiring disposal. Although air 

conditioning could be used to further reduce mercury vapor emissions, air conditioning equipment would 

be expensive both to install and to operate (e.g., maintenance and energy costs) and would consume 

electrical energy that may be generated by burning greenhouse-gas-generating fossil fuels. 

4.13 RESOURCES 

This section describes any unavoidable adverse environmental impacts that could result from 

implementation of the alternatives; irreversible and irretrievable commitments of resources; and the 

relationship between short-term uses of the environment and the maintenance and enhancement of longterm productivity. Unavoidable adverse environmental impacts are impacts that would occur after 

implementation of all feasible mitigation measures. A resource commitment is considered irreversible 

when direct and indirect impacts from its use limit future use options. Irreversible commitments apply 

primarily to nonrenewable resources, such as cultural resources, and also to those resources that are 

renewable only over long periods of time, such as soil productivity. A resource commitment is considered 

irretrievable when the use or consumption of the resource is neither renewable nor recoverable for future 

use. Irretrievable commitment applies to the loss of production, harvest, or natural resources. The 

relationship between short-term uses of the environment and the maintenance and enhancement of longterm productivity addresses issues associated with the condition and maintenance of existing 

environmental resources used to support the proposed action and the function of these resources after their 

use. 

4.13.1 Unavoidable Adverse Environmental Impacts 

Implementing any of the action alternatives considered in the EIS for the long-term storage of elemental 

mercury would result in unavoidable adverse impacts on the human environment. In general, these 

impacts are expected to be negligible overall and would arise from incremental impacts attributed to the 

construction and normal operations of new and/or modified mercury storage facilities at any of the seven 

candidate sites. 

As further described in this chapter, construction of a new mercury storage facility at any site would result 

in land disturbance, generation of fugitive dust and noise, soil erosion, consumption of utilities and natural 

resources, and increased vehicle traffic that would be unavoidable, even with the application of best 

management and conservation practices. These activities would generally occur in or adjacent to 

previously disturbed areas with existing complementary land uses. Construction activities are expected to 
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have negligible impacts overall and would be temporary in nature (i.e., lasting up to 6 months). The 

completed mercury storage facility would occupy up to 3.1 hectares (7.5 acres) of land over the long term 

(assumed, for purposes of analysis, to be up to 40 years). Activities performed to modify or upgrade 

existing facilities for long- term storage of elemental mercury would also result in some unavoidable 

adverse impacts that would generally be similar to but less than those noted above for construction of a 

new storage facility. 

Operations of new or modified facilities at any of the seven candidate sites would have minimal 

unavoidable adverse impacts on air quality associated with semiannual testing of diesel fuel–fired 

emergency generators. Emissions would also be generated from employee vehicle trips, relatively 

infrequent delivery vehicle trips, and truck trips for transporting elemental mercury to the facility. The 

associated emissions would not measurably degrade ambient air quality or jeopardize impact compliance 

with air quality standards around any candidate site. 

Also unavoidable would be the generation of small amounts of hazardous and industrial waste associated 

with normal facility operations. Any waste generated during operations would be collected, packaged, and 

eventually removed for suitable recycling or disposal in accordance with applicable EPA and/or state 

regulations. Sanitary wastewater would also be generated and disposed of through onsite sewage disposal 

systems or municipal sanitary sewer systems, as appropriate for each site. 

Under the No Action Alternative, operation of non-DOE mercury storage facilities and Y–12 would also 

result in some unavoidable adverse impacts in terms of air emissions, consumption of utility resources, 

and waste generation. However, at some storage locations, mercury storage may necessitate that the 

owners provide for expanded storage, resulting in additional construction and operational environmental 

impacts (see Section 4.2). 

Future closure of mercury storage facilities (see Section 4.10) would result in the one-time generation of 

waste material. Such waste would be collected, packaged as appropriate, and removed for suitable 

recycling or disposal in accordance with applicable EPA and/or state regulations. 

4.13.2 Irreversible and Irretrievable Commitment of Resources 

This section summarizes the major irreversible and irretrievable commitments of resources that have been 

identified under each alternative considered in this Mercury Storage EIS. Implementation of any of the 

alternatives considered for long-term storage of elemental mercury, including the No Action Alternative, 

would entail the commitment of land, energy (e.g., electricity, fossil fuels), water, construction materials 

(e.g., steel, concrete), geologic resources, equipment, human labor, and capital. In general, the 

commitments of energy, materials, labor, and capital would be irreversible and, once committed, these 

resources would be unavailable for other purposes. Capital would be committed permanently. In 

addition, the generation of waste would indirectly entail the irreversible and irretrievable commitment of 

resources due to the land required for landfill space, utilities consumed to operate disposal facilities, and 

human labor. 

Key resource commitments for construction and operation of a new mercury storage facility are presented 

in Appendix C, Tables C–2 and C–4. The No Action Alternative would entail the least commitment of 

land, material, and energy resources based on the analyses presented in this chapter. 

4.13.2.1 Land Use 

Operation of modified existing facilities or proposed new facilities for mercury storage would require the 

commitment of land to the prescribed use over the 40-year period of analysis considered in this EIS. 

Thus, the commitment of land is irreversible in the short term, but not necessarily irreversible over the 

long term. Over the long term, the land that would be occupied by either existing or proposed facilities 
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could ultimately be returned to open space uses if buildings, roads, and other structures were removed and 

the land revegetated. Alternatively, the facilities could be modified for use in other DOE programs. 

4.13.2.2 Energy and Water 

Energy expended directly or indirectly to support long-term storage of mercury would be in the form of 

electricity to operate equipment and fossil fuels to operate equipment and vehicles. Electricity and fuels 

would be purchased from commercial sources. Consumption of electricity and fossil fuels would be an 

irretrievable commitment of nonrenewable resources. Water consumed for construction and operations 

would constitute an irreversible commitment and would not be available for other uses. Water would be 

obtained via each site’s existing water supply system, as described in this chapter. However, these 

resources are readily available, and the amounts projected to be required are not expected to deplete 

available supplies. 

4.13.2.3 Materials and Geologic Resources 

The irreversible and irretrievable commitment of materials, equipment, and other resources comprises 

those used in the modification or new construction of mercury storage facilities at the candidate sites. 

This includes materials that cannot be recovered or recycled, materials that are contaminated and cannot 

be effectively decontaminated, and materials consumed or reduced to unrecoverable forms of waste. 

Principal construction materials would include steel, concrete (a product of cement, sand, gravel, and other 

minerals), asphalt, and gravel, although other materials such as wood, plastics, and other metals would 

also be used (see Appendix C, Section C.2.3). For practical purposes, materials including concrete and 

steel and other materials incorporated into the framework of existing or new facilities would be 

unrecoverable and irretrievably lost. Certain materials and equipment used during operation of the storage 

facilities could be recycled when the facilities are closed. All materials and commodities would be 

procured from commercial vendors in the regions surrounding each candidate site, and all are commonly 

available materials that are not expected to be in short supply in the affected regions. 

4.13.2.4 Waste 

Mercury storage operations at any candidate site would generate nonrecyclable waste streams, such as 

solid waste, sanitary wastewater, and potentially hazardous (mercury-contaminated) waste. The treatment 

and disposal of any solid waste would cause irreversible and irretrievable commitments of landfill space, 

energy, and materials. Hazardous waste disposal would require an irreversible and irretrievable 

commitment of land. This space would be unavailable for wastes from other sources. Sanitary 

wastewater generated and discharged to treatment systems and/or to the land would eventually be recycled 

through the ecosphere and would not entail a permanent commitment or impairment of resources. 

4.13.3 Relationship Between Short-Term Uses of the Environment and Maintenance 

and Enhancement of Long-Term Productivity 

Under each action alternative, adverse impacts from short-term use of resources would be balanced by 

long-term benefits and enhancement of long-term productivity associated with the reduction of elemental 

mercury in the environment. Each of the action alternatives would entail similar relationships between 

local, short-term uses of the environment and the maintenance and enhancement of long-term productivity. 

However, there would be differences in the relative magnitude of the short-term uses based on differences 

in location, including use of existing and/or new storage facilities, utility and transportation infrastructure 

availability, and labor availability and utilization. Regardless, upon completion of mercury storage 

activities at any of the candidate locations, land and facilities could be returned to other uses, including 

long-term productive uses (see Section 4.13.2.1). 
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Under the No Action Alternative, environmental resources have already been committed to activities 

Y–12 and, possibly, at some existing source locations. There could be environmental impacts at non-DOE 

storage sites in the short term associated with the need to provide for new or increased storage 

requirements. Such activities could adversely affect the long-term productivity of the environment. 

4.14 REFERENCES 

ATSDR (Agency For Toxic Substances and Disease Registry), 2009a, Health Consultation Proposed 

Mercury Clean-Up Level For The East Fork Poplar Creek Flood Plain Soil, Oak Ridge, Tennessee, 

U.S. Department of Health and Human Services, Public Health Service, accessed through 

http://www.atsdr.cdc.gov/HAC/pha/efork2/oak_p1.html, November 12. 

ATSDR (Agency For Toxic Substances and Disease Registry), 2009b, Public Health Consultation: Y–12 

Weapons Plant Chemical Releases into East Fork Poplar Creek, Oak Ridge, Tennessee, U.S. Department 

of Health and Human Services, Public Health Service, accessed through 

http://www.atsdr.cdc.gov/hac/pha/efork1/y12_p1.html, November 12. 

Beverly, M., 2009a, County Manager, Lea County, Lovington, New Mexico, personal communication 

(telephone conversation) with S. Robinson, Science Applications International Corporation, Germantown, 

Maryland, September 24. 

Beverly, M., 2009b, County Manager, Lea County, Lovington, New Mexico, personal communication 

(telephone conversation) with S. Robinson, Science Applications International Corporation, Germantown, 

Maryland, “Future Plans in the Waste Control Specialists Site Region,” July 29. 

CDC (Centers for Disease Control and Prevention), 2009, Documentation for Immediately Dangerous to 

Life or Health Concentrations, and 1988 OSHA PEL Project Documentation, accessed through 

http://www.cdc.gov/niosh/database.html, June 11. 

CEQ (Council on Environmental Quality), 1997, Considering Cumulative Effects Under the National 

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

CH2M-WG Idaho, 2009a, Safely Delivering the Idaho Cleanup Project, accessed through 

https://idahocleanupproject.com/, December 1. 

CH2M-WG Idaho, 2009b, Idaho Cleanup Project, Idaho Nuclear Technology and Engineering Center 

(INTEC), accessed through https://idahocleanupproject.com/Progress/INTEC/tabid/127/Default.aspx, 

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