DOE/EA-1568

OCTOBER 2006

U. S. DEPARTMENT OF ENERGY

SAVANNAH RIVER OPERATIONS OFFICE

SAVANNAH RIVER SITE

ENVIRONMENTAL ASSESSMENT

FOR THE

REPLACEMENT SOURCE OF STEAM

FOR A AREA

AT THE SAVANNAH RIVER SITE
DOE/EA-1568

 

ENVIRONMENTAL ASSESSMENT

FOR THE

REPLACEMENT SOURCE OF STEAM 

FOR A AREA

AT THE SAVANNAH RIVER SITE

OCTOBER 2006

U. S. DEPARTMENT OF ENERGY

SAVANNAH RIVER OPERATIONS OFFICE

SAVANNAH RIVER SITE
ii

TABLE OF CONTENTS

Page

1.0 INTRODUCTION ...............................................................................................1 

1.1 Background ..............................................................................................1 

1.2 Purpose and Need for Proposed Action.....................................................1 

2.0 PROPOSED ACTION AND ALTERNATIVES ..................................................3 

2.1 Proposed Action .......................................................................................3 

2.2 Alternative Action: Upgrade the Existing Steam Generation Plant ............4 

2.3 ‘No Action’ Alternative.............................................................................5 

3.0 AFFECTED ENVIRONMENT............................................................................5 

3.1 Land Use ..................................................................................................5 

3.2 Meteorology and Climatology...................................................................5 

3.3 Geology and Soils.....................................................................................6 

3.4 Surface Hydrology....................................................................................6 

3.5 Ecological Resources................................................................................6 

3.6 Cultural Resources....................................................................................7 

4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTIONS AND 

ALTERNATIVES................................................................................................7 

4.1 Construction-Related and Soil Disturbing Activities..................................8 

4.2 Water Quality Impacts ..............................................................................8 

4.3 Air Quality Impacts...................................................................................9 

4.4 Waste Disposition...................................................................................10 

4.5 Human Health and Environmental Justice................................................10 

4.6 Socioeconomic Resources.......................................................................11 

4.7 Archaeological and Cultural Resources ...................................................11 

4.8 Threatened and Endangered Species and Floodplain/Wetland Resources.11 

4.9 Transportation ........................................................................................11 

4.10 Accident Analysis....................................................................................12 

4.11 Cumulative Impacts ................................................................................13 

5.0 REGULATORY AND PERMITTING REQUIREMENTS CONSIDERED.......14 

5.1 National Environmental Policy Act of 1969 as amended ..........................15 

5.2 Air Quality Regulations...........................................................................15 

5.3 Solid Waste Regulations .........................................................................15 

5.4 Domestic Water Regulations...................................................................15 

5.5 Liquid Discharge Regulations..................................................................16 

6.0 AGENCIES AND PERSONS CONSULTED.....................................................16 

7.0 REFERENCES ..................................................................................................16 
iii

LIST OF FIGURES

Page

Figure 1-1. Location of Major Production, Support, and Research and 

Development Areas at the Savannah River Site 2 

LIST OF TABLES

Page

Table 4-1. Calculated air emissions from the wood- and low NOx oil-fired 

boilers 9 

Table 4-2. Summary of the potential impacts from the construction and 

operation of the replacement steam generation facility 13 
iv

LIST OF ACRONYMS AND ABBREVIATIONS

AEGLs Acute Exposure Guide Levels

BE Biological Evaluation

BMP Best Management Practices

CEQ Counsel on Environmental Quality

CPRB Coal Pile Runoff Basin

CO carbon monoxide

CSWTF Central Sanitary Wastewater Treatment Facility

DOE Department of Energy 

EPA Environmental Protection Agency

ERPG Emergency Response Planning Guidelines

ESCO Energy Services Company

HVAC Heating, Ventilation, and Air Conditioning

lb/hr pounds per hour

MACT Maximum Achievable Control Technology

MARs Materials At Risk

msl mean Sea Level

NEPA National Environmental Policy Act

NESHAP National Emission Standards for Hazardous Air Pollutants

NPDES National Pollutant Discharge Elimination System

NOx nitrogen oxides

Pb lead

PEL/TWA Permissible Exposure Limit/Time Weighted Average

PM particulate matter

SCDHEC South Carolina Department of Health and Environmental Control

SOx sulfur dioxides

SRARP Savannah River Archaeological Research Program

SREL Savannah River Ecology Laboratory

SRNL Savannah River National Laboratory

SRS Savannah River Site

T&E Threatened and Endangered

TEEL Temporary Emergency Exposure Level

TP total particulates

VOC volatile organic carbon

WSRC Washington Savannah River Company
v 

This Page Intentionally Left Blank
1 

1.0 INTRODUCTION

The U.S. Department of Energy (DOE) prepared this environmental assessment (EA) to 

analyze the potential environmental impacts of the proposed construction and operation of

a replacement steam plant in A Area at the Savannah River Site (SRS) (Figure 1-1). The

potential environmental impacts of upgrading the existing steam plant, Building 784-A, 

and the “no action” alternative are also considered.

1.1 Background

The existing steam plant in A Area is comprised of two coal-fired boilers located in 

Building 784-A, producing 325 pounds per square inch gauge saturated steam at a 

minimum of 15,000 pounds per hour (lb/hr). The two 60,000 lb/hr capacity coal fired 

boilers were installed in 1953. Steam is used in A Area primarily for process loads, space 

heating, domestic hot water, and heating, ventilation, and air conditioning (HVAC) 

humidification needs. Multi-cone dust collectors are used as air pollution control devices 

to collect particulate matter. Savannah River National Laboratory (SRNL) and the 

Savannah River Ecology Laboratory (SREL) use steam primarily for HVAC and 

intermittently for process needs. 

The existing steam plant was sized to supply a much higher volume of steam demand. 

Current and projected demands for steam are lower than historical levels as a result of 

facility deactivation and decommissioning that has taken place in A Area. Steam is vented 

during most months to maintain boiler operation as the current system is greatly oversized 

for current steam needs. The pollution control systems on the existing steam plant would

not be adequate to meet new air emission limits which go into effect in 2007. Capital 

investment to upgrade the existing facility would be necessary to meet the new limits if a 

replacement steam plant is not built.

This document was prepared in compliance with the National Environmental Policy Act 

(NEPA) of 1969, as amended; the requirements of the Council on Environmental Quality 

(CEQ) Regulations for Implementing NEPA (40 CFR Parts 1500-1508); and the DOE 

Regulations for implementing NEPA (10 CFR Part 1021, as amended). NEPA requires 

the assessment of potential consequences of Federal actions that may significantly impact 

or affect the quality of the human environment. Based on the potential for impacts 

described within this EA, DOE will either publish a finding of no significant impact or 

prepare an environmental impact statement.

1.2 Purpose and Need for Proposed Action

On September 13, 2007, new emission standards promulgated under 40 CFR Part 63, 

Subpart DDDDD “National Emission Standards for Hazardous Air Pollutants (NESHAP) 

for Industrial, Commercial, and Industrial Boilers and Process Heaters”, will go into effect 

for existing boilers. The A Area steam plant does not currently meet the new Maximum 

Achievable Control Technology (MACT) air permit restrictions. The purpose of the 
2 

proposed and alternative actions is to ensure that A-Area steam needs are satisfied in a 

timely, technically reliable, and cost-effective manner while compliance with the new air 

emissions standards is achieved and maintained. 

Figure 1-1. Location of Major Production, Support, and Research and Development 

Areas at the Savannah River Site. 
3 

2.0 PROPOSED ACTION AND ALTERNATIVES

2.1 Proposed Action

The proposed action is to replace the existing over-capacity steam production system with 

a new system having controls capable of meeting the new emission standards and 

appropriately sized to meet current and projected A-Area steam demands. The existing 

steam plant would cease to operate once the replacement boilers are operational. 

Dismantlement and removal of Building 784-A would be a separate NEPA action and 

therefore is not considered in this EA.

DOE proposes to replace the existing coal-fired A-Area boilers with a smaller, less 

polluting, wood-fired boiler and a backup oil-fired boiler. If DOE decides to replace the 

existing steam plant, start of construction and completion of the proposed facility are 

planned for February 2007 and July 2008, respectively. Due to the length of time required 

for contracting, funding, design, permitting, construction, and startup the new facility 

would not be in operation by the September 13, 2007, effective date for the new emission 

standards, and DOE would have to shut down the existing facility. SRS requested, in 

accordance with South Carolina Department of Health and Environmental Control 

(SCDHEC) recommendation, a one-year extension to the compliance date for the new 

emission standard for the existing A-Area steam boilers, as allowed in 40 CFR 63.6 (i), to 

provide time for installation of the replacement system. SCDHEC has conditionally 

approved this one-year compliance date extension. The new steam facility would be 

compliant with the 40 CFR Part 63, Subpart DDDDD standards upon startup. The 

existing steam facility would be shut down upon startup of the new facility.

The scope of the new A-Area Steam Plant was developed by an Energy Services 

Company (ESCO) under the requirements of the Federal Energy Management Program, 

which is managed by DOE. Under this Program, ESCOs must guarantee and annually 

validate energy and maintenance cost savings that result from the more efficient operations 

of their projects compared to the costs for the facilities and equipment they replace. For 

this project the ESCO evaluated the use of natural gas, coal, and fuel oil as the primary 

fuel source for the new A-Area steam plant. These alternative fuel sources were not 

selected for the following reasons:

• Natural Gas – No satisfactory supply exists within 20 miles of the Site.

• Fuel Oil –Executive Order 13123, (Greening the Government Through 

Efficient Energy Management) recommends against the use of petroleum 

products for new energy sources and the price of fuel oil is highly volatile, 

making savings estimation highly problematic for large fuel oil

expenditures.

• Coal – use of coal would require significant Clean Air Act controls and the 

equipment for Clean Coal technology is 50 percent of the cost of a new 

boiler, making it prohibitively expensive for such a small boiler.
4 

The new steam production facility would be sized to meet A-Area steam loads and SRNL 

process needs. Steam production would meet an average demand of 15,000 lb/hr and a 

peak demand of approximately 35,000 lb/hr. The steam source would be capable of 

combusting both solid fuels and fuel oil. Biomass fuels (i.e., wood) would be used the 

majority of the time, with fuel oil serving as a backup energy source during maintenance 

outages or peak demands. The most economical fuel that is readily available and 

allowable by the SCDHEC regulations is woody biomass.

A large quantity of low value woody biomass (tree tops, small diameter trees, branches, 

limbs, etc.) is generated as a byproduct of forest management practices. During tree 

harvesting this material is generally left at the logging site before the logs are hauled for 

processing. The material left at the logging site will either decay or be consumed in a 

controlled burn prior to tree plantings. SRS would utilize a contract with a fuel 

supplier/vendor for the woody biomass. Harvesting this currently underutilized byproduct 

of timber production offers a tremendous opportunity for energy systems to use this 

resource. The primary source of wood fuel for the A-Area Powerhouse will be obtained 

from SRS and offsite timber and wood waste left over from logging operations. No 

additional harvesting is planned on SRS; however, the possibility of planting and utilizing 

short rotation woody crops may be evaluated as a sustainable source of fuel through 

establishing and monitoring of experimental and demonstration sites.

The facility would be equipped with pollution control and monitoring equipment required 

to meet current and anticipated environmental requirements. The design of the new 

facility would minimize operating and maintenance costs. 

A steel framed industrial structure would be constructed on a concrete pad to house the 

steam generators and all piping necessary to interface with existing site utilities. The 

existing A-Area well water system would supply process water for the steam system. The 

steam supply would be connected to the existing steam system at the nearest convenient 

overhead location. Domestic water would be supplied from the existing domestic water 

system. Boiler blowdown would be routed to the existing sanitary sewer system. 

Generated ash would be disposed of in an appropriate approved solid waste management 

facility. The balance of the plant, which would include all associated fuel handling, 

storage equipment, and a three- to five-day biomass supply, would be contained inside a 

protective structure located on the site of the coal storage area adjacent to the existing 

A-Area steam plant. 

The primary location being considered for the proposed facility is an area adjacent to the 

site of the existing steam generation plant. An alternative location for the proposed 

facility is an existing asphalt parking lot located near SRNL. 

2.2 Alternative Action: Upgrade the Existing Steam Generation Plant

The pollution control systems on the existing steam plant (Building 784-A) are not 

adequate to meet new air emission limits which go into effect in 2007. An alternative 

action would be to upgrade the existing coal-fired boilers with new emission control 

technology and continuous opacity monitoring to meet new regulatory requirements. 
5 

Although these upgrades would provide for regulatory compliance, the cost of a new 

pollution control system for the existing boilers would be approximately $3 million and the 

upgraded plant would still be oversized and too large to efficiently and cost effectively 

provide steam to A Area. 

2.3 ‘No Action’ Alternative

The no action alternative consists of DOE continuing to operate the existing A-Area steam 

plant with no changes in air emissions control technology. If the ‘no action’ alternative is 

implemented, DOE would not be in compliance with the requirements of the new MACT 

air quality permit requirements. 

3.0 AFFECTED ENVIRONMENT

SRS is a 310-square-mile Federal reservation located along the Savannah River in 

southwestern South Carolina (Figure 1-1). The site is approximately 25 miles southeast of 

Augusta, Georgia and 20 miles south of Aiken, South Carolina. The initial mission at SRS 

was the production of heavy water and strategic radioactive isotopes (e.g., plutonium-239 

and tritium) in support of national defense. However, with the end of the Cold War, the 

site’s primary mission has evolved into environmental cleanup and restoration. Following 

is a brief description of selected environmental components of the SRS-affected (existing) 

environment. Characterization of the affected environment is important because it 

provides a baseline for assessing the potential environmental impacts of the proposed and 

alternative actions considered in this EA. 

3.1 Land Use

Forestland (mostly southern pine plantation) is the dominant land use at SRS 

(approximately 80 percent of land area), with the remainder consisting of aquatic habitats 

and developed areas (Halverson et al. 1997). The developed landscapes consist primarily 

of roadways, administrative, and industrialized areas that are continually exposed to high 

levels of human disturbance (Noah 1995). Both the primary and secondary sites being 

considered for the proposed new steam generation plant are located within a previously 

developed, industrial landscape (A Area) of SRS.

3.2 Meteorology and Climatology

The SRS region possesses a humid subtropical climate characterized by relatively short, 

mild winters and extended, hot summers. Summer-like weather conditions typically last 

from May through September, with July and August normally being the hottest months. 

January and February are typically the coldest months. Due to its proximity to the sea, the 

region can be significantly impacted by maritime weather conditions (e.g., hurricanes). 

Precipitation in the region averages in excess of 47 inches per year (Kilgo and Blake

2005). Generally, the spring and autumn seasons tend to be drier than the winter and 
6 

summer seasons. Spring and summer thunderstorms can be intense. More detailed 

information regarding SRS meteorology and climatology can be found in Bauer et al. 

(1989). The general meteorological and climatological data reported for SRS would be 

representative of conditions present in the project area.

3.3 Geology and Soils

The physiography of SRS is comprised of two major components: The Aiken Plateau and 

the alluvial terraces of the Savannah River. The Aiken Plateau is a dissected sandy plain 

situated between the Savannah and Congaree Rivers in the Upper Atlantic Coastal Plain of 

South Carolina. Its sandy sediments dominate the SRS landscape and range in elevation 

from 250-400 feet above mean sea level (msl). The alluvial terraces of the Savannah River 

occur below 250 feet msl. The proposed A-Area steam plant project area lies north of the 

interface between these two physiographic components at an approximate elevation of 350 

feet above msl. 

Seven soil associations are represented within SRS (Rogers 1990). Generally, sandy soils 

occupy the uplands and ridges and are less fertile than the loamy-clayey soils of the stream

terraces and floodplains. Dominant soils in previously developed or disturbed areas such 

as the proposed sites for the new steam plant are mapped as Udorthents (Uu; Urban land, 

0 – 6 percent slope) (Rogers 1990). 

3.4 Surface Hydrology

The Savannah River forms the western boundary of SRS and receives drainage from five 

major tributaries which originate on or drain through the site. These tributaries are Upper 

Three Runs, Fourmile Branch, Pen Branch, Steel Creek, and Lower Three Runs. There 

are also two major surface water impoundments (PAR Pond and L Lake) on SRS. 

A small Carolina bay is located to the east of the existing steam plant location. This 

waterbody, which historically has received wash down water from the steam plant, is part 

of the Metallurgical Laboratory Hazardous Waste Management Facility. Surface waters in 

the Carolina bay drain to Tims Branch, a tributary to Upper Three Runs. Surface runoff 

from the existing coal pile storage area flows to the outfall A-10 Coal Pile Runoff Basin

(CPRB). This retention basin does not overflow to State waters. Surface runoff from the 

alternative site located between Road A-1 and the 713-A Pad flows to an existing outfall 

which discharges to an unnamed tributary to Tims Branch.

3.5 Ecological Resources

Since 1951, when the U.S. Government acquired SRS, natural resource management 

practices and natural succession outside of the developed areas have resulted in increased 

ecological complexity and diversity on the site. As noted in Section 4.1, SRS terrestrial

habitat is primarily comprised of forestland. However, over 20 percent of the SRS surface 

area is covered by water, including wetlands, bottomland hardwoods, cypress-tupelo 

swamp forests, two large cooling water reservoirs (PAR Pond and L Lake), creeks and 
7 

streams, and over 300 isolated upland Carolina bays and wetland depressions (Davis and 

Janecek 1997; Halverson et al. 1997).

SRS has seven Federally-listed species which are afforded protection under the 

Endangered Species Act of 1973 (Hyatt 1994). These include the bald eagle (Haliaeetus 

leucocephalus), wood stork (Mycteria americana), red-cockaded woodpecker (Picoides 

borealis), American alligator (Alligator mississippiensis), shortnose sturgeon (Acipenser 

brevirostrum), smooth purple coneflower (Echinacea laevigata), and pondberry (Lindera 

melissifolia). No Federally-listed threatened and endangered (T&E) species are known to 

occur on or near the proposed A-Area steam plant sites. Additional information regarding 

the ecological characteristics of SRS can be found in Halverson et al. (1997).

3.6 Cultural Resources

Through a cooperative agreement, DOE and the South Carolina Institute of Archaeology 

and Anthropology of the University of South Carolina conduct the Savannah River 

Archaeological Research Program (SRARP) to provide services required by Federal law 

for the protection and management of archaeological resources. To facilitate the 

management of these resources, SRS is divided into three archaeological zones based on 

an area’s potential for containing sites of historical or archaeological significance (DOE 

1995). Zone 1 represents areas with the greatest potential for having significant 

resources; Zone 2 possesses areas with moderate potential; and Zone 3 represents areas of 

low archaeological significance.

The proposed sites for the replacement steam Industrialized areas of SRS possess a low 

archaeological sensitivity because it is likely that any resources that may have been 

originally present were destroyed during construction of the A-Area industrial complex. 

4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTIONS 

AND ALTERNATIVES

Two potential sites within A Area have been identified for the proposed new steam 

generation plant. Both sites, which are encompassed within a previously developed 

industrial landscape, were selected to facilitate plant tie-in to existing site infrastructure 

(e.g., power, domestic water, steam lines, sanitary sewer).

The primary site is located within the area of the coal pile storage area of the existing 

steam plant. The benefits of this site are (a) its proximity to the 751-A Operations Center, 

(b) minimal site preparation required for construction, and (c) the existing tie-in to the 

A-10 CPRB for the collection/treatment of storm water runoff. Conversely, 

implementation of the proposed action on this site could (a) extend the future remediation 

of a portion of the coal pile storage area and downstream retention basin, (b) interfere 

with existing powerhouse operations during facility construction, (c) be more costly with 

respect to provision of utilities, and (d) potentially allow for minor contamination of the 
8 

wood supply with left over coal constituents, i.e. coal dust. The alternative or secondary 

site is located in a parking lot near SRNL. The benefits of choosing this site are (a) 

reduced steam losses to SRNL, (b) less costly to install utilities, (c) no impact on future 

remediation of the coal pile storage area and downstream retention basin, (d) no 

interference with existing steam plant operations during facility construction, and (e) fewer 

underground interferences. The cons of this location include (a) greater site preparation 

requirements (e.g., asphalt disposal), (b) potential aesthetic impacts (plant would be 

located adjacent to both SRNL and SREL), (c) loss of parking spaces, and (d) close

proximity to parking areas used by privately-owned vehicles.

4.1 Construction-Related and Soil Disturbing Activities

The proposed and alternative actions (excluding the ‘no action’ alternative) would involve 

construction-related and soil disturbing activities (e.g., site preparation and facility 

construction, infrastructure tie-ins) within a previously developed area. These activities 

would be relatively short-lived, cause minimal disruption to other facility or area 

operations, and be conducted using appropriate best management practices (e.g., storm 

water and sediment erosion control measures). No known waste sites or contaminated 

soils would be disturbed. Regardless of the site chosen, the potential for these activities to 

significantly adversely impact the human environment would be negligible.

4.2 Water Quality Impacts

Liquid waste generated by the proposed replacement steam plant (e.g., boiler blowdown, 

wash waters) would be discharged to the sanitary sewer system for treatment in the 

Central Sanitary Wastewater Treatment Facility (CSWTF). The volume of waste water 

generated by the new plant would be less than that currently being generated by the 

existing facility. The impacts of constructing and operating the CSWTF have been 

assessed in a previous NEPA document (DOE 1993). The potential impacts of the receipt 

and treatment of effluent from the new steam plant by the CSWTF would be negligible 

and bounded by previous NEPA review.

Surface runoff from the primary site is routed to the A-10 CPRB which does not normally 

discharge to State surface waters. Emergency overflow from the basin would be to an 

unnamed tributary to Tims Branch (Upper Three Runs drainage). The existing retention 

basin has sufficient capacity to accommodate any additional storm water runoff resulting 

from implementation of the proposed action. Since there is no surface discharge from the 

basin, floodplain hydrology or wetlands within the downstream drainage would not be 

impacted. Storm water runoff from the alternative site presently discharges to an 

unnamed tributary of Tims Branch via Outfall A-05. Since this site is currently a paved

parking lot, it is not expected that the placement of the proposed facility at this location 

would (a) significantly increase the volume of surface runoff generated during storm 

events or (b) adversely impact floodplain hydrology or wetlands within the receiving 

stream.
9 

4.3 Air Quality Impacts

The National Ambient Air Quality Standards established by the EPA define the maximum 

allowable concentration of criteria air pollutants that may be present in the ambient air 

over a specific averaging time period. These standards were established to protect human 

health (primary standards) and welfare (secondary standards) with a regional margin of 

safety. Criteria pollutant standards establish maximum concentrations for ozone, nitrogen 

oxides (NOx), sulfur dioxides (SOx), carbon monoxide (CO), lead, and particulate matter 

with a diameter of 10 microns or less (PM10). Ozone is formed by the photo-oxidation of 

reactive hydrocarbons in the presence of nitrogen oxide.

Air emissions resulting from construction-related activities would be generated by 

diesel-powered equipment (e.g., trucks, backhoes, bulldozers, equipment emissions, and 

fugitive dust) would be short-lived, minimal, and not require permitting. Since both the 

primary and secondary sites for the proposed action are already developed, there would be 

no land clearing or open burning of debris required. 

Implementation of the proposed action would involve construction of a wood-fired boiler

with a fuel oil fired backup boiler equipped with air emission control technology capable 

of meeting the new air permit requirements which go into effect in 2007. Preliminary 

calculated air emissions from operation of the wood-fired and oil-fired boilers are

presented in Table 4-1. Current A Area emissions are presented in the “A Area” column 

in tons per year (tons/yr). Preliminary air emissions calculated for the wood- and oil-fired 

boilers are totaled in the “total” column. Differences from current air emissions are listed 

in the “Difference” column. Pollutants calculated to increase compared to current 

operations are CO (53.653 tons/year), and volatile organic carbon (VOC) (2.411 tons/yr). 

Many pollutants, such as SO2 (-244.198 tons/yr), total particulates (-69.700 tons/yr), and 

PM10 (-32.063 tons/yr), were calculated to decrease after ceasing operation of the current 

boilers and starting operation of the new wood- and oil-fired boilers. 

 

Table 4-1. Calculated air emissions from the wood- and low NOx oil-fired boilers.

 

 

Pollutant A-Area Wood Oil Total Difference

(tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)

CO 43.205 94.608 2.250 96.858 53.653

NO2 54.005 34.690 4.500 39.190 -14.815 

PM10 38.820 6.307 0.450 6.757 -32.063 

TP 79.115 8.515 0.900 9.415 -69.700

SO2 283.465 3.942 35.325 39.267 -244.198

VOC 0.360 2.681 0.090 2.771 2.411

Pb 0.320 0.008 0.001 0.008 -0.312

PM2.5 26.825 5.519 0.113 5.631 -21.193 
10 

The equivalent consumption of coal per pound of steam exported would decrease due to 

the use of wood for fuel, the improved efficiency, and turndown of the new boilers. The 

decreased coal consumption in favor of wood as a fuel would result in less total ash and 

combustion by products. In addition, emissions of NOx, SOx, and toxic air pollutants 

would be reduced. The use of wood versus coal as a fuel source would significantly 

benefit regional air quality because of reduced emissions of carbon dioxide (a greenhouse 

gas) and particulate matter (specifically PM2.5). This latter air pollutant constituent is a 

major causative factor in asthma. Additionally, the combustion of wood is much less 

polluting in terms of sulfur dioxide (SO2) a known precursor to secondary PM2.5 formation 

and acid rain.

SRS currently receives approximately 500 truck loads of coal per year to supply steam to 

the area. Due to the lower British thermal unit content and density of wood, it is expected 

that the amount of truck traffic associated with fuel delivery would be double that required 

for coal (i.e., 1000 deliveries per year versus the current 500). Each truck would carry 

approximately 20 tons of woody biomass per load. Vehicular traffic in the A Area has 

decreased as operations and facilities are being decommissioned and demolished. Any 

particulate air emissions from increased truck traffic would be offset by the reduced 

emissions from the combustion of woody biomass fuel.

Fuel handling and storage, for an approximate three- to five-day biomass supply, would be 

contained inside a protective structure at the plant site to minimize the emission of fugitive 

airborne particulates associated with fuel handling. Air emissions from the proposed 

replacement steam plant would be in compliance with applicable air quality regulations and 

would not significantly impact the human environment. 

4.4 Waste Disposition

Implementation of the proposed action would generate some building material debris and 

associated rubble. These waste streams would be disposed of onsite in a permitted land 

fill. Waste ash generated by the combustion of the woody material would be deposited in 

an approved solid waste management facility. The current method of disposal for coal ash 

generated by the existing steam production facility is by trucking to an approved ash 

disposal basin. The impacts of constructing and operating the aforementioned waste 

disposal facilities have been assessed in a previous NEPA document (DOE 1995). The 

potential impacts associated with the disposition of waste streams generated by 

implementation of the proposed action would be negligible and bounded by previous 

NEPA review.

4.5 Human Health and Environmental Justice

The use of personal protective equipment/clothing and enforcement of Occupational 

Safety and Health Act compliant work conditions would minimize impacts to human 

health and safety. Any air impacts associated with the proposed action would be minimal, 

and not evidenced beyond the region of SRS. There would be no disproportionately high 
11 

and adverse human health or environmental effects on minority and low income 

populations in the SRS region of influence.

4.6 Socioeconomic Resources

Workforce requirements and costs associated with implementation of the proposed and 

alternative actions would be minimal when compared to the total SRS budget and 

employment (approximately $1.5 billion and 9,000 personnel, respectively). Construction 

personnel (approximately 50) would be offsite craftsman. Operational staff 

(approximately 11 individuals) would be derived from the existing SRS workforce. The 

cost (~$6.7 million) of upgrading the existing facility to ensure regulatory compliance with 

respect to the new air emission requirements would be cost prohibitive for the 50-year-old 

plant. However, the upgraded facility would still be too large to efficiently and cost 

effectively provide steam to the A Area. The socioeconomic impacts associated with 

implementation of the proposed action would be negligible.

4.7 Archaeological and Cultural Resources

The primary and secondary sites for the proposed action possess a low archaeological 

sensitivity because they have both been subjected to prior development and construction

related activities. The potential for the proposed and alternative actions to significantly 

impact archaeological or cultural resources at SRS would be negligible. 

4.8 Threatened and Endangered Species and Floodplain/Wetland Resources

Federally-listed T&E species do not occur within or near the proposed project area. No 

effect is expected on the smooth purple coneflower, pondberry, red-cockaded 

woodpecker, bald eagle, shortnose sturgeon, or wood stork population status within the 

selected project areas or on a site-wide level. Project implementation in the currently 

industrialized area would not significantly impact floodplain/wetland resources within the 

receiving drainage or be expected to have a measurable impact on any migratory avian 

species. Logging residues, when left to decay, can contribute nutrients to the site and

habitat for various organisms. Removal of logging residues for use as biomass fuel would 

reduce this nutrient input and alter the habitat. 

4.9 Transportation

Construction and operation of the proposed facility would not result in the rerouting of 

either pedestrian or vehicular traffic within or near the project area. Due to the lower 

British thermal unit content and density of wood, it is expected that the amount of truck 

traffic associated with fuel delivery would be double that required for coal (i.e., 1000 

deliveries per year). Each truck will deliver approximately 20 tons of woody biomass per 

load. SRS currently receives approximately 500 truck loads of coal per year to supply 

steam to the area. This increase in vehicular truck traffic could easily be accommodated 

by the existing site infrastructure (e.g., roadways) and not significantly impact area 

operations or create local traffic congestion. No measurable impact on local 
12 

transportation-related resources or site operations would be expected from 

implementation of the proposed action.

4.10 Accident Analysis

The maximum reasonable foreseeable accident associated from the proposed action would 

be release of the chemicals that would be used to treat steam plant boiler makeup water. 

The release may be accidental or malicious. The bounding credible releases are considered 

to be 1) fire, which results in the boiling and airborne release of chemical tank contents, 

and 2) spill, which includes an immediate airborne release from splashing of tank contents 

and longer term airborne re-suspension of spilled chemicals. The chemicals of interest are 

Olin Sodium Hydroxide Solution, ChemTreat BL-1253 (sodium sulfite solution), and 

ChemTreat BL-1106. These Materials At Risk (MARs) would be stored in chemical tanks 

located within a single structure. 

A worst case engineering calculation to evaluate the most bounding credible release of the 

chemicals was performed for two tanks (twice the volume) of chemicals instead of the one 

tank that is planned. Chemical concentrations are determined for receptors (individuals) at 

328 feet and 2099 feet (assumed to be offsite for the A-Area steam plant). Where Acute 

Exposure Guide Levels (AEGL), Emergency Response Planning Guidelines (ERPG), or 

Temporary Emergency Exposure Level (TEEL) threshold quantities are not available, 

Permissible Exposure Limit/Time Weighted Average (PEL/TWA) values are used for risk 

level determinations. There are three levels of ERPGs:

• ERPG-1. The maximum concentration in air below which it is believed 

nearly all individuals could be exposed for up to one hour without 

experiencing other than mild transient adverse health effects or perceiving a 

clearly defined objectionable odor.

• ERPG-2. The maximum concentration in air below which it is believed 

nearly all individuals could be exposed for up to one hour without 

experiencing or developing irreversible or other serious health effects or 

symptoms that could impair their abilities to take protective action; and

• ERPG-3. The maximum concentration in air below which it is believed 

nearly all individuals could be exposed for up to one hour without 

experiencing or developing life-threatening health effects.

The threshold quantities of the MARs were compared to ERPG to qualitatively evaluate 

the risk. Release of the MAR chemicals was not evaluated as a composite, such as might 

be the case if the tank contents were to spill and become mixed. The concentrations are 

then compared to the individual threshold quantities provided in Revision 21, of AEGLs, 

ERPGs, and TEELS for Chemicals of Concern to determine whether the consequence risk 

to receptors would be such that safety related controls would be required to prevent or 

mitigate a release. 

Release of the quantities of chemicals evaluated would result in concentrations well below 

the ERPG-3 limits for the onsite worker (100 meters) and ERPG-2 for the offsite public. 
13 

At these concentrations no safety related controls would be required to prevent or 

mitigate a release of the MARs.

4.11 Cumulative Impacts

The CEQ regulations define cumulative impacts as impacts on the environment that result 

when the incremental impact of an action is added to the impacts of other past, present, 

and reasonably foreseeable future action within a given spatial or temporal boundary. The 

incremental impacts associated with implementation of the proposed and alternative 

actions considered in this EA are so small that their potential contribution to a cumulative 

effect on an area- or region-wide basis would be negligible. The application of air 

pollution control technology and the use of wood fuel would minimize the potential for air 

emissions resulting from project implementation to interact with other SRS pollutant 

sources or have a cumulative impact on criteria air pollutants. The calculated increase in 

CO release, while double the amount currently produced, is still below Prevention of 

Significant Deterioration limits thresholds of 100 tons per year. The significant reduction 

of SO2 and particulate matter greatly overshadows the increase in CO. Additionally, the 

disposition of waste streams generated by facility construction and operation would easily 

be accommodated by onsite wastewater treatment and landfill capacity. Harvesting and 

utilizing a renewable resource (woody biomass) would have less impact on the 

environment and is preferred to the burning of non-renewable resources (fossil fuels). The 

potential for the incremental impacts of the proposed action to contribute to a cumulative 

effect is further minimized by the constantly improving quality of the SRS environment 

resulting from ongoing cleanup and restoration efforts. A summary of the potential 

environmental consequences of the new steam generation facility is presented Table 4-2. 

 

Table 4-2. Summary of the potential impacts from the construction and operation of the 

replacement steam generation facility.

 

Impact Subject Environmental Consequences

Water Quality Water use by the proposed facility construction and operation 

would be minimal and would tie into existing groundwater wells 

and distribution systems. Facility effluents and storm water run 

off would be treated in existing SRS facilities. Negligible

impacts would be realized on ground and surface waters. 

Air Quality Air emissions from construction of the proposed facility would 

be minimal. Burning wood instead of coal in a new and more 

efficient plant would reduce toxic air pollutant emissions and 

benefit regional air quality.
14 

Table 4-2 (cont.) Summary of the potential impacts from the construction and operation 

of the replacement steam generation facility.

Impact Subject Environmental Consequences 

Land Impact to land resources would be minimal. The proposed 

action would be constructed within an existing developed area 

on a less than 3-acre site and would comprise less than 0.002 

percent of undeveloped land on SRS. The proposed project 

would be compatible with other industrial land use in A Area.

Socioeconomic 

Resources 

Direct and indirect socioeconomic impacts of the proposed 

action would be negligible 

Waste 

Disposition

Impacts on SRS waste management operations as a result of the 

proposed action would be minimal. The proposed project 

would be compatible with existing SRS waste handling 

infrastructure.

Ecology and 

Cultural 

Resources

No impacts on sensitive ecological (e.g., threatened and 

endangered species, fish/wildlife habitat, and wetlands) or 

known archaeological /cultural resources would be realized.

Transportation Truck trips for fuel delivery would double; however, impacts on 

onsite transportation resources from the new facility 

construction and operation would be minimal. 

Accident 

Analysis

Release of the quantities of chemicals evaluated would result in 

concentrations well below the ERPG-3 limits for the onsite 

worker (328 feet) and ERPG-2 (2099 feet) for the offsite public. 

At these concentrations no safety related controls would be 

required to prevent or mitigate a release.

Cumulative 

Impacts

Incremental impacts of the actions considered in this EA are so 

small that their potential contribution to a cumulative effect on 

an area or region wide basis would be negligible.

5.0 REGULATORY AND PERMITTING REQUIREMENTS CONSIDERED

DOE policy is to conduct its operations in compliance with all applicable Federal, State 

and local laws and regulations, as well as DOE Orders. The following provides discussion 

of major regulatory permit programs that may be applicable to the proposed action.
15 

5.1 National Environmental Policy Act of 1969 as amended

This EA has been prepared in compliance with the NEPA of 1969, as amended; the 

requirements of the CEQ Regulations for Implementing NEPA (40 CFR Parts 

1500-1508); and DOE Regulations (10 CFR Part 1021), and DOE Order 451.1B. NEPA, 

as amended, requires “all agencies of the Federal Government” to prepare a detailed 

statement on the environmental effects of proposed “major Federal actions significantly 

affecting the quality of the human environment”. This EA has been written to comply 

with NEPA and analyze the potential environmental impacts for the replacement source of 

steam for A Area at SRS.

5.2 Air Quality Regulations

A SCDHEC Title V air emissions permit would be required and MACT regulations would

be addressed. Air emission permits and controls would comply with 40 CFR 61-62 Air 

Pollution Control Regulations and Standards. Air emission permits and sources must 

comply with 40 CFR Part 63 NESHAP for Industrial, Commercial, and Institutional 

Boilers and Process Heaters.

5.3 Solid Waste Regulations

Small amounts of nonradioactive, nonhazardous waste materials (e.g., building material 

debris, construction rubble and office waste) would be deposited in a permitted sanitary 

landfill, a construction and demolition landfill, or erosion control pit during construction 

and operation of the new replacement source of steam.

A permit would be required to land apply ash resulting from combustion of solid fuels. 

The preferred ash disposal method is at a permitted solid waste landfill. Construction 

activities shall comply with the National Pollutant Discharge Elimination System (NPDES) 

general permit requirements for storm water discharges from construction activities. 

Storm water discharges associated with normal facility operation would meet the 

requirements for storm water discharges from industrial activities. Bulk petroleum storage 

shall comply with the NPDES permit for Discharge to Surface Waters for discharges from 

bulk petroleum storage facilities. Bulk petroleum storage shall also comply with 

requirements of 40 CFR Part 60, Standards of Performance for Volatile Organic Liquid 

Storage Vessels for Which Construction, Reconstruction, or Modification Commenced 

After July 23, 1984.

5.4 Domestic Water Regulations

The domestic water tie-in for the toilets, showers, and sinks would require a Public Water 

Works permit from the State of South Carolina (SCDHEC Regulation R61-58).
16 

5.5 Liquid Discharge Regulations

Both a Sanitary Sewer Construction Permit (SCDHEC Regulation R61-67) and a Sanitary 

Sewer Operation NPDES permit (SCDHEC Regulation R61-68) would be needed from 

the State of South Carolina for construction and operation of the proposed facility’s 

sanitary waste system. 

6.0 AGENCIES AND PERSONS CONSULTED

The United States Department of Agriculture Forest Service-Savannah River, SRARP, 

and SREL were consulted during the preparation of this EA.

7.0 REFERENCES

Bauer, L.R., D.W. Hayes, C.H. Hunter, W.L. Marter, and R.A. Moyer, 1989. Reactor 

Operation Environmental Information Document, Volume III: Meteorology, Surface 

Hydrology, Transport and Impacts, WSRC-89-817, Westinghouse Savannah River 

Company, Savannah River Site, Aiken, South Carolina.

Davis, C.E. and L.L. Janecek, 1997. DOE Research Set-Aside Areas of the Savannah 

River Site, Savannah River Ecology Laboratory, P.O. Drawer E, Aiken, South Carolina.

DOE (U.S. Department of Energy),1995. Final Environmental Impact Statement 

Savannah River Site Waste Management. DOE/EIS-0217. Volume I. Savannah River 

Operations Office. Aiken, South Carolina. 

Halverson, N.V., L.D. Wike, K.K. Patterson, J.A. Bowers, A.L. Bryan, K.F. Chen, C.L. 

Cummins, B.R. del Carmen, K.L. Dixon, D.L. Dunn, G.P. Friday, J.E. Irwin, R.K. Kolka, 

H.E. Mackey, Jr., J.J. Mayer, E.A. Nelson, M.H. Paller, V.A. Rogers, W.L. Specht, H.M. 

Westbury, and E.W. Wilde, 1997. SRS Ecology Environmental Information Document,

WSRC-TR-97-0223, Westinghouse Savannah River Company, Aiken, South Carolina. 

Hyatt, P.E., 1994. Savannah River Site Proposed, Threatened, Endangered and Sensitive 

Plants and Animals, Internal Report of the Savannah River Forest Station. Revised

August 1994, USDA Forest Service-Savannah River, New Ellenton, South Carolina.

Kilgo, J.C. and J.I. Blake (eds.). 2005. Ecology and Management of a Forested 

Landscape: Fifty Years on the Savannah River Site, Island Press, Covelo, California.

Noah, J.C., 1995. Land-Use Baseline Report: Savannah River Site, WSRC-TR-95-0276. 

Westinghouse Savannah River Company, Savannah River Site, Aiken, South Carolina.

Revision 21 of AEGLs, ERPGs, and TEELS for Chemicals of Concern, U.S. Department 

of Energy, Office of Environment, Safety and Health.

Rogers, V.A., 1990. Soil Survey of Savannah River Plant Area, Parts of Aiken, Barnwell, 

and Allendale Counties, South Carolina, United States Department of Agriculture, Soil 

Conservation Service, Aiken, South Carolina.