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Finding of No Significant Impact

for the

Offsite Transportation of Certain

Low-level and Mixed Radioactive Waste

from the Savannah River Site

for Treatment and Disposal at

Commercial and Government Facilities

Agency: U. S. Department of Energy

Action: Finding of No Significant Impact

Summary: The Department of Energy (DOE) has prepared an environmental assessment

(EA) (DOE/EA-1308) to analyze the potential environmental impacts associated with the

proposed offsite transportation of certain low-level radioactive waste (LLW) and mixed

(i.e., hazardous and radioactive) low-level radioactive waste (MLLW) from the Savannah

River Site (SRS), located near Aiken, South Carolina. Based on the analyses in the EA,

DOE has determined that the action is not a major Federal action significantly affecting

the quality of the human environment within the meaning of the National Environmental

Policy Act of 1969 (NEPA). Therefore, the preparation of an environmental impact

statement (EIS) is not required, and DOE is issuing this Finding of No Significant Impact

(FONSI).

Public Availability: Copies of the EA and FONSI or further information on the DOE

NEPA process are available from:

Andrew R. Grainger

NEPA Compliance Officer

Savannah River Operations Office

Bldg. 742-A/Room 185

Aiken, South Carolina 29808

Phone/FAX: (800) 881-7292

E-mail: nepa@srs.gov

Background: At SRS, operations, waste management, environmental restoration, and

decontamination and decommissioning activities generate a variety of LLW and MLLW

streams each year. By definition, LLW is radioactive waste that is not classified as

high-level waste, transuranic waste, or spent nuclear fuel, and does not contain waste

designated as hazardous by either the Resource Conservation and Recovery Act (RCRA)

or the Toxic Substances Control Act (TSCA). LLW management is subject to the

provisions of the Atomic Energy Act, DOE Order 435.1, and the DOE manual

accompanying that Order. LLW is categorized as either contact- or remote-handled, and
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as alpha or nonalpha on the basis of the waste forms and levels of radioactivity present.

Most LLW consists of relatively large volumes of waste materials contaminated with

small amounts of radionuclides, such as contaminated equipment, protective clothing,

paper, rags, packaging material, and solidified sludges. Most LLW contains short-lived

radionuclides and generally can be handled without shielding or remote handling

equipment. MLLW contains both hazardous waste subject to regulation under RCRA

and LLW subject to regulations under the Atomic Energy Act. MLLW includes such

materials as tritiated mercury, tritiated oil contaminated with mercury, other

mercury-contaminated materials, radioactively contaminated solvents, radioactively

contaminated polychlorinated biphenyls (PCBs), radioactively contaminated lead

shielding, and equipment from the tritium facilities in H Area.

The proposed management of the five waste forms included in the EA associated with

this FONSI was previously addressed in two different EISs prepared and issued by DOE:

the Final EIS, Savannah River Site, Waste Management, DOE/EIS-0217 (SRWMEIS),

and the Final Programmatic EIS for Managing Treatment, Storage and Disposal of

Radioactive and Hazardous Waste, DOE/EIS-0200-F (WMPEIS). In the SRWMEIS,

DOE’s preferred alternative for managing these waste forms was through either shallow

land or RCRA-licensed disposal at SRS. In addition, either onsite or offsite treatment

preceded disposal for some specific wastes in four of the five general waste forms.

However, treatment residuals were to be returned to SRS for onsite storage or disposal.

DOE had decided to implement this option and issued a Record of Decision (ROD) on

October 30, 1995. In the WMPEIS, these five waste forms were encompassed in the two

broad waste types of LLW and MLLW for evaluation. DOE's preferred alternative

consisted of minimum treatment of LLW although each site may perform additional

treatment if cost effective. The preferred alternative for disposal of LLW was to continue

to the extent practicable onsite disposal as well as selection of Hanford Site and Nevada

Test Site as regional disposal locations. DOE's preferred alternative for MLLW treatment

consisted of onsite and regional treatment at Hanford Site, Idaho National Engineering

and Environmental Laboratory, Oak Ridge Reservation and SRS consistent with Site

Treatment Plans. The preferred alternative for MLLW disposal consisted of two regional

disposal sites, Hanford Site and Nevada Test Site. DOE decided to implement the

preferred alternative and issued a ROD on February 25, 2000. The decisions did not

preclude DOE's use of commercial treatment and disposal facilities, consistent with

current DOE Orders and Policy.

While these two EISs addressed treatment and disposal of LLW and MLLW at SRS, the

onsite treatment and disposal facilities for most of these five waste forms do not exist.

For various reasons, the proposed projects that would have provided the facilities, such as

new low-activity waste and RCRA disposal vaults, have been cancelled. Some of the

reasons for cancellation include recognition of existing DOE complex capacity, inability

to meet current South Carolina Department of Health and Environmental Control

(SCDHEC) RCRA waste disposal facility requirements, and funding limitations. DOE’s

inability to meet South Carolina’s waste disposal requirements is the primary problem,

and it is not correctable. SRS does not have a naturally occurring confining clay layer of
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sufficient thickness to meet South Carolina requirements for a RCRA disposal unit as

defined in South Carolina Hazardous Waste Management Regulations R.61-104.IV.C.1.a.

Because of this, DOE has no plans to construct and operate such facilities at SRS.

Therefore, DOE is proposing to use offsite commercial and Government facilities for

treatment and disposal of these wastes.

Purpose and Need for Agency Action: DOE needs a viable near-term treatment and

disposal option for these five LLW and MLLW forms that are generated at SRS. DOE

needs to take action in a cost-effective and timely manner because onsite treatment and

disposal capabilities for these waste forms do not exist at SRS at this time and/or it is

more beneficial to DOE to dispose of the waste at another location. In addition, these

waste forms would comprise an estimated volume of approximately 136,057 cubic meters

(4,804,282 cubic feet). If not dispositioned upon generation, storage of this volume of

waste would likely exceed RCRA and TSCA regulatory limits. Storage without treatment

would not be consistent with the agreements between DOE and the State of South

Carolina concerning MLLW management under the SRS Site Treatment Plan that was

developed pursuant to the Federal Facility Compliance Act of 1992. Violating these

agreements could result in fines and penalties for DOE as well as suspension of the site's

RCRA Permit.

Proposed Action: DOE proposes to transport, by rail or truck, certain SRS LLW and

MLLW forms to commercial and Government facilities for treatment and disposal.

Although the treatment and disposal operations at the commercial and Government

facilities are beyond the scope of the EA, the Government facilities are separately covered

through appropriate NEPA documentation. Additionally, DOE would ensure all

commercial facilities are properly licensed to receive the radioactive material prior to

shipment and perform reviews of the facility's operations. None of these wastes, or

residuals or secondary waste generated during the offsite treatment, would be returned to

SRS under the proposed action. The estimated volume that would be shipped under this

proposed action on an annual basis would range from 5,664 to 12,744 cubic meters

(200,000 to 450,000 cubic feet).

The shipping vendor would be responsible for providing the modes of transportation

(either rail or truck), equipment, security and health and safety requirements to ship the

waste from SRS. The shipping containers would be provided by either DOE or the

vendor. SRS personnel would be responsible for loading the waste into the appropriate

U. S. Department of Transportation (DOT)-approved shipping containers. The vendor

would take custody of the packaged waste at the SRS staging area. DOE would ensure

that external contamination to the containers leaving SRS does not exceed DOT limits.

The vendors would be responsible for ensuring that all DOT and DOE regulations and

Orders are met for LLW and MLLW shipments. The vendors would also be responsible

for ensuring compliance with all Federal, State, and local licenses, permits, and other

required documentation to treat and/or dispose of LLW and MLLW.
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The proposed action would include the transportation of the LLW and MLLW to seven

potential offsite-processing locations for treatment and disposal. The seven commercial

or Government facilities located within a general area are grouped such that the

calculations for six destinations cover the seven potential offsite-processing locations, as

well as future/additional locations that are near the six destinations. The six destinations

chosen are: 1) Idaho Falls, Idaho; 2) Eunice, New Mexico; 3) Mercury, Nevada; 4) Oak

Ridge, Tennessee; 5) Clive, Utah; and 6) Richland, Washington. With the exception of

Mercury, Nevada, and Idaho Falls, Idaho, all destination facilities are accessible by both

rail and truck. No rail shipments are planned to Nevada, at this time. For shipments to

Idaho Falls, Idaho, results are presented for two separate legs consisting of 1) rail from

SRS to Pocatello, Idaho, and 2) truck from Pocatello to Idaho Falls, Idaho.

Although DOE-SR has cradle-to-grave responsibility for its wastes, the transportation of

the treated waste from those facilities to the final disposal facility would be the

responsibility of vendor. DOE does not evaluate transporting the treated waste from

commercial treatment facilities to the final disposal facility in this EA. However, since

the waste constituents would have been either immobilized, thermally treated, thermally

encapsulated, solidified, amalgamated, volume reduced, or containerized at the

commercial treatment facilities, and the radiation levels or hazard volumes of the waste

have not been increased, the transportation impacts would be no greater than those that

would result from transporting the untreated waste from SRS to final disposal facility,

and those impacts are evaluated in this EA. The various commercial vendor facilities are

accessible by either rail or truck. Each of these offsite facilities would be required by law

to have in place all necessary U. S. Nuclear Regulatory Commission (NRC), State, and

local licenses and/or permits to either treat or dispose of the waste forms in question.

DOE would ensure the receiving facility is properly licensed prior to shipment of the

waste. In addition it should be noted that in the case of transportation accidents, the

Federal Government is ultimately responsible for the cleanup after the bond limit of the

carrier is exceeded.

The facility's waste acceptance criteria are essential to the proper operation of the

radiological waste treatment/disposal facility. SRS will comply with the facility's waste

acceptance criteria through auditable waste characterization and certification activities.

This would enable DOE Savannah River Operations Office and the facility’s host State to

ensure that all safety, health physics/radiation monitoring procedures, Quality

Assurance/Quality Control procedures, transportation procedures, volume reduction

procedures, and laboratory procedures at the disposal facility would be met. Further,

meeting the waste acceptance criteria for disposal of MLLW is driven by RCRA. These

criteria must be met before these waste forms could be offered to any commercial or

Government facility for final disposal. In the event that these criteria can’t be met for a

specific volume of waste to be shipped, then those materials would remain at SRS until

an alternative management option can be determined. In addition, the commercial

facility's activities would be closely scrutinized by DOE, NRC, the U. S. Environmental

Protection Agency, and State agencies that regulate the management of radiological and

hazardous waste.
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DOE Order 435.1, Radioactive Waste Management, and DOE Manual 435.1 (which

describes how the Order is implemented) identify the requirements that DOE must follow

and the controls and oversight that must be in place before DOE ships waste to a

commercial facility for treatment, storage or disposal. In making a decision to use a

commercial facility for managing DOE radioactive waste, the DOE Field Element

Manager must ensure that the decision is protective of the public and the environment.

This responsibility is effected by ensuring the following: (1) the commercial facility is

properly licensed and/or permitted; (2) the facility complies with applicable regulations;

and (3) the facility has an acceptable history of operational and regulatory performance.

Based on the characteristics of the waste that is being considered for transfer to the

commercial facility, a review would be conducted of the licenses and permits held by the

facility to determine if they provide appropriate coverage for management of the waste.

This would be accomplished through a reading of the licenses and permits and through

discussions with the issuing authority (Federal, State, or local licensing/permitting

authority). This review would confirm that the facility is authorized to receive the

radionuclides in the waste to be transferred, and, if the waste contains constituents subject

to RCRA or TSCA, that the facility has the appropriate authorization to receive and

manage those constituents. Discussions with regulatory authorities and reviews of

inspection reports would also be used to determine whether the facility has a history of

acceptable operational and regulatory performance. Once a determination has been made

by a DOE organization that a commercial facility has an acceptable operational and

regulatory history, this determination can be used by other DOE organizations, e.g., a

DOE organization can use the results of a review performed by another DOE organization

or DOE contractor in making a decision on the acceptability of the commercial facility's

performance. However, it is the responsibility of a DOE organization using a commercial

facility to ensure, on an annual basis, that the facility is maintaining an acceptable

performance record, either through their own review or that conducted by another DOE

organization or contractor. Documentation of the results of the evaluation of regulatory

compliance and acceptable operational history as discussed above is adequate for

showing that the use of the commercial facility will be protective of public health and the

environment.

If the proposed action were selected, an amended ROD would have to be issued by DOE

for the SRWMEIS. The decision in the ROD would be to further implement the

Moderate Treatment Configuration Alternative through the offsite transportation of

certain LLW and MLLW for treatment and/or final disposal at commercial and

Government facilities.

Alternatives: In accordance with NEPA regulations, DOE examined the following

alternatives to the proposed action: (1) no action, continue to store these waste forms at

SRS; and (2) construct and operate onsite treatment and disposal facilities. The no-action

alternative is to continue to store these waste forms onsite. The impacts associated with

the proposed action would not occur. DOE would not provide onsite treatment or

disposal capabilities for these waste forms. Storage space and disposal capacity needs
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would increase each year as waste was generated. Environmental restoration and

decontamination and decommissioning projects at SRS would have to be postponed

because of lack of available storage space and treatment and disposal capacity to handle

the waste generated by these activities. If not dispositioned upon generation, storage of

these waste forms could also result in violations of RCRA and TSCA regulatory limits.

The potential outcome of this could be significant fines and penalties for SRS. Also, the

average costs associated with the proper management of stored waste is approximately

$45 per 1.0 cubic meter (35.3 cubic feet) per year. These costs would be in addition to

the ultimate treatment and/or disposal costs for these SRS waste forms.

The other alternative to the proposed action would be to construct and operate onsite

treatment and disposal facilities for these waste forms. This would include the

construction and operation of the following new facilities: a non-alpha vitrification

facility, a containment building, 3 low-activity waste disposal vaults, and 26 RCRA

disposal vaults. The environmental impacts and administrative decisions associated with

these facilities were addressed in other NEPA documents. However, expenditure of

capital funds for new treatment and disposal facilities while offsite capacity exists for

these waste forms is not a cost-effective solution. The RCRA disposal vaults could not

be built onsite to meet current SCDHEC requirements for such facilities. Therefore,

given the current funding limitations and alternatives available for these waste forms,

DOE does not plan to build the previously proposed treatment and disposal facilities.

Environmental Impacts: The EA did not assess local impacts associated with the

ongoing operation of an already-licensed offsite vendor facility proposed to receive DOE

waste for treatment or disposal. DOE’s proposed waste load associated with this ongoing

operation will be a small part of that facility’s throughput. The facility would operate

well within its established standards and the vendor’s part of this proposal is of low

potential for significant impacts. No impacts to human health and worker safety would

be expected to result from the loading operations portion of the proposed action. The

human population exposures resulting from the proposed offsite shipments would be

several orders of magnitude less than naturally occurring background radiation exposure

to the same population; thus, no impacts are expected on human health. Based on the

analysis of non-radiological accident scenarios, the proposed action would be expected to

result in about nine non-fatal accidents and no fatal accidents. No latent cancer fatalities

would be expected from the proposed action. A bounding accident scenario involving the

release of the entire contents of a tanker truck carrying liquid LLW into streams of

various sizes would result in observable deleterious impacts to biota in the smallest

streams (10 cubic feet per second flow or less). However, based on the fact that there

would only be ten such shipments made under the proposed action, no accidents of this

type would be expected to occur. There would be little to no potential for a

disproportionately high adverse impact to either poor or minority communities as a result

of the proposed action.