DOE/EIS-0423-S 1 

March 2013 

LONG-TERM MANAGEMENT AND 

STORAGE OF ELEMENTAL MERCURY 

U.S. Department of Energy 

Office of Environmental Management 

Washington , DC 
AVAILABILITY OF THIS 

DRAFT LONG-TERM MANAGEMENT AND 

STORAGE OF ELEMENTAL MERCURY 

SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT 

For additional information on this 

Draft Mercury Storage SEIS, contact: 

David Levenstein, Document Manager

Office of Environmental Compliance (EM–11)

U.S. Department of Energy

Post Office Box 2612 

Germantown, MD 20874 

Website: http://www.mercurystorageeis.com 

Printed with soy ink on recycled paper 
DRAFT

LONG-TERM MANAGEMENT AND 

STORAGE OF ELEMENTAL MERCURY

SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT

Cover Sheet 

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

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

U.S. Bureau of Land Management (BLM) 

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

Impact Statement (Draft Mercury Storage SEIS) (DOE/EIS-0423-S1) 

Candidate Locations for Storage Facility(ies): Colorado, Idaho, Missouri, Nevada, New Mexico, 

South Carolina, Texas, Washington 

Contacts: For copies of this draft supplemental environmental impact statement (SEIS), visit DOE’s 

National Environmental Policy Act (NEPA) website at http://energy.gov/nepa or contact 

David Levenstein at the address below. 

For additional information on For general information on the DOE NEPA process, 

this Draft Mercury Storage SEIS, contact: contact: 

David Levenstein, Document Manager Carol M. Borgstrom, Director 

Office of Environmental Compliance (EM–11) Office of NEPA Policy and Compliance (GC–54) 

U.S. Department of Energy U.S. Department of Energy 

Post Office Box 2612 1000 Independence Avenue, SW 

Germantown, MD 20874 Washington, DC 20585 

Website: http://www.mercurystorageeis.com Website: http://energy.gov/nepa 

Telephone: 202-586-4600, or leave a message at 

800-472-2756 

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

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

within the United States. Therefore, DOE has analyzed the storage of up to 10,000 metric tons 

(11,000 tons) of elemental mercury in a facility(ies) constructed and operated in accordance with the 

Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act (RCRA) 

(74 FR 31723). DOE issued the Final Long-Term Management and Storage of Elemental Mercury 

Environmental Impact Statement (Final Mercury Storage EIS) (DOE/EIS-0423) in January 2011. The 

Final Mercury Storage EIS analyzed the potential environmental, human health, and socioeconomic 

impacts of elemental mercury storage at seven candidate locations: Grand Junction Disposal Site near 

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

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

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

Specialists, LLC, site near Andrews, Texas. As required by Council on Environmental Quality (CEQ) 

NEPA regulations, the No Action Alternative was also analyzed as a basis for comparison. DOE has 

subsequently reconsidered the range of reasonable alternatives evaluated in the Final Mercury 

Storage EIS. Accordingly, DOE has prepared this Draft Mercury Storage SEIS to evaluate three 

additional locations for a long-term mercury storage facility(ies), all three of which are in the vicinity of 

the Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico. Both the January 2011 Final 

Mercury Storage EIS and this Draft Mercury Storage SEIS were prepared in accordance with NEPA 

(42 U.S.C. 4321 et seq.), the CEQ implementing regulations (40 CFR 1500–1508), and DOE’s NEPA 
implementing procedures (10 CFR 1021). DOE intends to decide (1) where to locate the elemental 

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

of existing and new buildings. In the January 2011 Mercury Storage EIS, DOE identified the Waste 

Control Specialists, LLC, site near Andrews, Texas, as the Preferred Alternative for the long-term 

management and storage of mercury. At this time, DOE has not changed the Preferred Alternative. 

Based on analysis from this Draft Mercury Storage SEIS and public comment, the Preferred Alternative 

may or may not change in the Final Mercury Storage SEIS. DOE will issue a Record of Decision no 

sooner than 30 days after publication of the EPA Notice of Availability for the Final Mercury 

Storage SEIS in the Federal Register. The selection of a site will be based on the January 2011 Mercury 

Storage EIS, this Mercury Storage SEIS, and other appropriate factors and will be announced in a Record 

of Decision in the Federal Register. 

On January 1, 2013, the prohibition on the export of mercury went into effect pursuant to the Mercury 

Export Ban Act of 2008. As of March 1, 2013, several waste management companies have notified DOE

of their intent to accumulate and store excess mercury at RCRA-permitted facilities in accordance with 

Section 5(g)(2)(b) of the Act. All of these companies have certified that they will ship the excess 

elemental mercury to a DOE-designated facility(ies), when such a facility(ies) is operational and ready to 

accept the mercury. Until such time that DOE has designated a facility(ies) and is ready to accept 

mercury for long-term management and storage, similar notifications may be received by DOE from other 

waste management companies. 

Public Comments: On June 5, 2012, DOE published the “Notice of Intent to Prepare a Supplemental 

Environmental Impact Statement for the Long-Term Management and Storage of Elemental Mercury” in 

the Federal Register (77 FR 33204). Publication of the Notice of Intent initiated a 30-day public scoping 

period. During this time, DOE solicited comments from Federal, state, and local agencies; stakeholders; 

tribal nation representatives; and the general public to assist in defining the scope of this Draft Mercury 

Storage SEIS. A summary of these scoping comments is found in Chapter 1, Section 1.6.1, of this Draft 

Mercury Storage SEIS. Comments on this Draft Mercury Storage SEIS may be submitted during the 

45-day public comment period, which will begin upon publication of EPA’s Notice of Availability in the 

Federal Register. Public hearings on this Draft Mercury Storage SEIS will be held during this 45-day 

public comment period. The dates, times, and locations of these public hearings will be published in a 

DOE Federal Register notice and will be announced through other media. DOE will consider any 

comments received after the comment period ends to the extent practicable. 
A Message to Stakeholders 

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

Storage of Elemental Mercury Supplemental Environmental Impact Statement (Draft Mercury 

Storage SEIS). It is a key step in carrying out the intent of Congress in the Mercury Export Ban 

Act of 2008 to reduce mercury in the global environment. The U.S. Environmental Protection 

Agency and the U.S. Bureau of Land Management are cooperating agencies in the preparation of 

this Draft Mercury Storage SEIS. 

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

that can accept U.S. elemental mercury. This Draft Mercury Storage SEIS, together with the 

January 2011 Final Long-Term Management and Storage of Elemental Mercury Environmental 

Impact Statement, is intended to provide decisionmakers and the public with clear, 

reliable, and credible information about the impacts of the proposed action and reasonable 

mercury storage alternatives. You can also find additional information on the website at 

www.mercurystorageeis.com and in the reading rooms listed in Section 6 of the Summary and 

Guide for Stakeholders in this Draft Mercury Storage SEIS. 

I look forward to receiving your comments on this Draft Mercury Storage SEIS, and I hope you 

will continue to participate in the decisionmaking process as we develop the Final Mercury 

Storage SEIS and the Record of Decision. 

David Levenstein

EIS Document Manager 

U.S. Department of Energy 

For additional information on this Draft Mercury Storage SEIS, contact: 

David Levenstein, Document Manager 

Office of Environmental Compliance (EM–11) 

U.S. Department of Energy 

Post Office Box 2612 

Germantown, MD 20874 

Website: http://www.mercurystorageeis.com 

i

Table of Contents 

List of Figures ............................................................................................................................................ viii 

List of Tables ................................................................................................................................................ x 

List of Abbreviations and Acronyms .......................................................................................................... xii 

Measurement Units ..................................................................................................................................... xv 

Conversions................................................................................................................................................ xvi 

Summary and Guide for Stakeholders .................................................................................................. S–1

S.1 Introduction ........................................................................................................................ S–1

S.1.1 Why Reduce the Amount of Mercury in the Environment? .............................. S–2

S.1.2 What Are DOE’s Objectives? ............................................................................ S–3

S.1.3 How Much Mercury Could DOE Manage and Store? ....................................... S–3

S.1.4 Where Would the Mercury Come From? .......................................................... S–3

S.2 What Does This SEIS Address? ......................................................................................... S–4

S.2.1 Decisions to Be Made ........................................................................................ S–4

S.2.2 Scope of This SEIS ............................................................................................ S–4

S.2.3 Affected Environment and Environmental Consequences ................................ S–5

S.3 Mercury Storage Site Alternatives ..................................................................................... S–5

S.3.1 Candidate Sites Evaluated in the January 2011 Mercury Storage EIS .............. S–6

S.3.2 Candidate Sites Evaluated in This Draft Mercury Storage SEIS ....................... S–6

S.4 DOE Mercury Storage Facility(ies) Description ................................................................ S–7

S.4.1 New Storage Facility(ies) Design and Construction .......................................... S–8

S.4.2 Existing Facility(ies) Modification and Upgrades ............................................. S–8

S.4.3 Operation of a Mercury Storage Facility(ies) .................................................... S–9

S.5 Comparison of Impacts and Alternatives ........................................................................... S–9

S.5.1 Major Conclusions ........................................................................................... S–10

S.5.2 Cumulative Impacts ......................................................................................... S–13

S.5.3 The Preferred Alternative ................................................................................ S–14

S.6 Public Involvement .......................................................................................................... S–15

S.6.1 Public Scoping Meetings ................................................................................. S–15

S.6.2 Public Scoping Comments ............................................................................... S–15

S.6.3 How Can I Participate in This Process? ........................................................... S–15

S.6.4 Watch for the Final Mercury Storage SEIS ..................................................... S–16

S.6.5 Visit a Reading Room ...................................................................................... S–16 

Chapter 1 Introduction and Purpose and Need for Agency Action .............................................. 1–1

1.1 Introduction ........................................................................................................................ 1–1

1.2 Purpose and Need for Agency Action ................................................................................ 1–2

1.3 Proposed Action ................................................................................................................. 1–3

1.3.1 Estimated Mercury Inventory ............................................................................ 1–3

1.4 Decisions to Be Made ........................................................................................................ 1–5

1.5 Scope of This SEIS ............................................................................................................ 1–5

1.5.1 Candidate Site Identification ............................................................................. 1–6

1.5.2 Construction ....................................................................................................... 1–6

1.5.3 Operations .......................................................................................................... 1–6

1.5.4 Transportation .................................................................................................... 1–6

1.5.5 Closure of Mercury Storage Facility(ies) .......................................................... 1–7

1.6 Public Involvement in Developing the Scope of This SEIS .............................................. 1–7

1.6.1 Summary of Major Public Scoping Comments and DOE’s Responses ............. 1–7
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

ii

1.7 Other Relevant National Environmental Policy Act Reviews ........................................... 1–8

1.7.1 Final Environmental Impact Statement for the Waste Isolation Pilot 

Plant and Two Associated SEISs ...................................................................... 1–9

1.7.2 Draft Environmental Impact Statement for the Disposal of 

Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and 

GTCC-Like Waste .............................................................................................. 1–9

1.7.3 Final Site-Wide Environmental Impact Statement for the Y–12 National 

Security Complex ............................................................................................. 1–10

1.8 Organization of This Mercury Storage SEIS .................................................................... 1–10

1.9 References ........................................................................................................................ 1–11

Chapter 2 Facility Description, Alternatives, and Comparison of Environmental 

Consequences .................................................................................................................... 2–1

2.1 Introduction ........................................................................................................................ 2–1

2.2 Mercury Storage Facility(ies) ............................................................................................ 2–3

2.2.1 New Facility(ies) Description ............................................................................ 2–4

2.2.2 Construction Requirements ................................................................................ 2–6

2.2.3 Operations Requirements ................................................................................... 2–7

2.3 Alternative Sites Evaluated ................................................................................................ 2–9

2.3.1 January 2011 Mercury Storage EIS Candidate Sites ....................................... 2–10

2.3.2 WIPP Facility and Vicinity .............................................................................. 2–11

2.3.2.1 WIPP Vicinity Section 10 ............................................................... 2–14

2.3.2.2 WIPP Vicinity Section 20 ............................................................... 2–14

2.3.2.3 WIPP Vicinity Section 35 ............................................................... 2–14

2.4 Preferred Alternative ........................................................................................................ 2–14

2.5 Alternatives Considered but Eliminated from Detailed Analysis .................................... 2–15

2.6 Comparison of Alternatives ............................................................................................. 2–15

2.6.1 Summary of Environmental Consequences ..................................................... 2–21

2.6.1.1 Land Use and Visual Resources ...................................................... 2–22

2.6.1.2 Geology, Soils, and Geologic Hazards ............................................ 2–22

2.6.1.3 Water Resources .............................................................................. 2–22

2.6.1.4 Meteorology, Air Quality, and Noise .............................................. 2–23

2.6.1.5 Ecological Resources ....................................................................... 2–24

2.6.1.6 Cultural and Paleontological Resources .......................................... 2–24

2.6.1.7 Site Infrastructure ............................................................................ 2–24

2.6.1.8 Waste Management ......................................................................... 2–25

2.6.1.9 Occupational and Public Health and Safety .................................... 2–25

2.6.1.10 Ecological Impacts .......................................................................... 2–28

2.6.1.11 Socioeconomics ............................................................................... 2–29

2.6.1.12 Environmental Justice ..................................................................... 2–29

2.6.2 Summary of Cumulative Impacts .................................................................... 2–29

2.7 References ........................................................................................................................ 2–31

Chapter 3 Affected Environment ...................................................................................................... 3–1

3.1 Approach to Defining the Affected Environment .............................................................. 3–1

3.2 Waste Isolation Pilot Plant Site and Vicinity ..................................................................... 3–2

3.2.1 Land Use and Visual Resources ........................................................................ 3–2

3.2.1.1 Land Use ............................................................................................ 3–2

3.2.1.2 Visual Resources ............................................................................... 3–5
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iii

3.2.2 Geology, Soils, and Geologic Hazards .............................................................. 3–6

3.2.2.1 Geology ............................................................................................. 3–6

3.2.2.2 Soils ................................................................................................. 3–11

3.2.2.3 Geologic Hazards ............................................................................ 3–12

3.2.3 Water Resources .............................................................................................. 3–13

3.2.3.1 Surface Water .................................................................................. 3–13

3.2.3.2 Groundwater .................................................................................... 3–14

3.2.4 Meteorology, Air Quality, and Noise .............................................................. 3–17

3.2.4.1 Meteorology and Air Quality .......................................................... 3–17

3.2.4.2 Noise ................................................................................................ 3–20

3.2.5 Ecological Resources ....................................................................................... 3–21

3.2.5.1 Terrestrial Resources ....................................................................... 3–21

3.2.5.2 Wetlands .......................................................................................... 3–21

3.2.5.3 Aquatic Resources ........................................................................... 3–21

3.2.5.4 Threatened and Endangered Species ............................................... 3–21

3.2.6 Cultural and Paleontological Resources .......................................................... 3–22

3.2.6.1 Prehistoric Resources ...................................................................... 3–22

3.2.6.2 Historic Resources ........................................................................... 3–23

3.2.6.3 American Indian Resources ............................................................. 3–23

3.2.6.4 Paleontological Resources ............................................................... 3–24

3.2.7 Site Infrastructure ............................................................................................ 3–24

3.2.7.1 Ground Transportation .................................................................... 3–24

3.2.7.2 Electricity ........................................................................................ 3–24

3.2.7.3 Fuel .................................................................................................. 3–24

3.2.7.4 Water ............................................................................................... 3–24

3.2.8 Waste Management.......................................................................................... 3–25

3.2.8.1 Waste Minimization ........................................................................ 3–25

3.2.9 Occupational and Public Health and Safety ..................................................... 3–26

3.2.9.1 Normal Operations .......................................................................... 3–26

3.2.9.2 Facility Accidents ............................................................................ 3–27

3.2.9.3 Transportation.................................................................................. 3–27

3.2.10 Socioeconomics ............................................................................................... 3–28

3.2.10.1 Regional Economic Characteristics ................................................. 3–28

3.2.10.2 Demographic and Housing Characteristics ..................................... 3–28

3.2.10.3 Local Transportation ....................................................................... 3–28

3.2.11 Environmental Justice ...................................................................................... 3–28

3.2.11.1 WIPP Vicinity Section 10 ............................................................... 3–30

3.2.11.2 WIPP Vicinity Section 20 ............................................................... 3–31

3.2.11.3 WIPP Vicinity Section 35 ............................................................... 3–32

3.3 References ........................................................................................................................ 3–33

3.3.1 References in Addition to Those from the Draft GTCC EIS ........................... 3–33

3.3.2 References Incorporated from the Draft GTCC EIS ........................................ 3–36

Chapter 4 Environmental Consequences ......................................................................................... 4–1

4.1 Introduction ........................................................................................................................ 4–1

4.2 Waste Isolation Pilot Plant Site .......................................................................................... 4–2

4.2.1 Land Use and Visual Resources ........................................................................ 4–3

4.2.1.1 WIPP Vicinity Section 10 ................................................................. 4–3

4.2.1.2 WIPP Vicinity Section 20 ................................................................. 4–3

4.2.1.3 WIPP Vicinity Section 35 ................................................................. 4–3
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

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4.2.2 Geology, Soils, and Geologic Hazards .............................................................. 4–4

4.2.2.1 WIPP Vicinity Section 10 ................................................................. 4–4

4.2.2.2 WIPP Vicinity Section 20 ................................................................. 4–5

4.2.2.3 WIPP Vicinity Section 35 ................................................................. 4–5

4.2.3 Water Resources ................................................................................................ 4–5

4.2.3.1 WIPP Vicinity Section 10 ................................................................. 4–5

4.2.3.2 WIPP Vicinity Section 20 ................................................................. 4–6

4.2.3.3 WIPP Vicinity Section 35 ................................................................. 4–7

4.2.4 Meteorology, Air Quality, and Noise ................................................................ 4–7

4.2.4.1 WIPP Vicinity Section 10 ................................................................. 4–7

4.2.4.2 WIPP Vicinity Section 20 ................................................................. 4–9

4.2.4.3 WIPP Vicinity Section 35 ................................................................. 4–9

4.2.5 Ecological Resources ....................................................................................... 4–10

4.2.5.1 WIPP Vicinity Section 10 ............................................................... 4–10

4.2.5.2 WIPP Vicinity Section 20 ............................................................... 4–10

4.2.5.3 WIPP Vicinity Section 35 ............................................................... 4–10

4.2.6 Cultural and Paleontological Resources .......................................................... 4–11

4.2.6.1 WIPP Vicinity Section 10 ............................................................... 4–11

4.2.6.2 WIPP Vicinity Section 20 ............................................................... 4–11

4.2.6.3 WIPP Vicinity Section 35 ............................................................... 4–12

4.2.7 Site Infrastructure ............................................................................................ 4–12

4.2.7.1 WIPP Vicinity Section 10 ............................................................... 4–12

4.2.7.2 WIPP Vicinity Section 20 ............................................................... 4–13

4.2.7.3 WIPP Vicinity Section 35 ............................................................... 4–13

4.2.8 Waste Management.......................................................................................... 4–14

4.2.8.1 WIPP Vicinity Section 10 ............................................................... 4–14

4.2.8.2 WIPP Vicinity Section 20 ............................................................... 4–14

4.2.8.3 WIPP Vicinity Section 35 ............................................................... 4–15

4.2.9 Occupational and Public Health and Safety ..................................................... 4–15

4.2.9.1 WIPP Vicinity Section 10 ............................................................... 4–15

4.2.9.2 WIPP Vicinity Section 20 ............................................................... 4–31

4.2.9.3 WIPP Vicinity Section 35 ............................................................... 4–31

4.2.10 Ecological Risk ................................................................................................ 4–31

4.2.10.1 WIPP Vicinity Section 10 ............................................................... 4–31

4.2.10.2 WIPP Vicinity Section 20 ............................................................... 4–39

4.2.10.3 WIPP Vicinity Section 35 ............................................................... 4–39

4.2.11 Socioeconomics ............................................................................................... 4–39

4.2.11.1 WIPP Vicinity Section 10 ............................................................... 4–39

4.2.11.2 WIPP Vicinity Section 20 ............................................................... 4–40

4.2.11.3 WIPP Vicinity Section 35 ............................................................... 4–40

4.2.12 Environmental Justice ...................................................................................... 4–40

4.2.12.1 WIPP Vicinity Section 10 ............................................................... 4–40

4.2.12.2 WIPP Vicinity Section 20 ............................................................... 4–40

4.2.12.3 WIPP Vicinity Section 35 ............................................................... 4–41

4.3 Closure ............................................................................................................................. 4–41

4.4 Cumulative Impacts ......................................................................................................... 4–42

4.4.1 Methodology and Analytical Baseline ............................................................. 4–42

4.4.2 Potential Cumulative Actions .......................................................................... 4–43

4.4.2.1 Waste Isolation Pilot Plant Vicinity Reference Locations .............. 4–43

4.5 Mitigation Measures......................................................................................................... 4–46
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4.6 Resources ......................................................................................................................... 4–47

4.6.1 Unavoidable Adverse Environmental Impacts ................................................ 4–47

4.6.2 Irreversible and Irretrievable Commitment of Resources ................................ 4–48

4.6.2.1 Land Use .......................................................................................... 4–48

4.6.2.2 Energy and Water ............................................................................ 4–49

4.6.2.3 Materials and Geologic Resources .................................................. 4–49

4.6.2.4 Waste ............................................................................................... 4–49

4.6.3 Relationship Between Short-Term Uses of the Environment and 

Maintenance and Enhancement of Long-Term Productivity ........................... 4–49

4.7 References ........................................................................................................................ 4–50

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

Requirements .................................................................................................................... 5–1

5.1 Introduction ........................................................................................................................ 5–1

5.2 Laws, Regulations, and Other Potentially Applicable Requirements ................................ 5–1

5.3 Permits and Notifications ................................................................................................... 5–3

5.4 Consultations ...................................................................................................................... 5–5

5.4.1 Consultations Regarding Ecological Resources ................................................ 5–6

5.4.2 Consultations Regarding Cultural Resources .................................................... 5–6

5.5 References .......................................................................................................................... 5–6

Chapter 6 Glossary ............................................................................................................................. 6–1 

Chapter 7 List of Preparers ............................................................................................................... 7–1 

Chapter 8 Distribution List ............................................................................................................... 8–1 

Chapter 9 Index .................................................................................................................................. 9–1 

Appendix A The Mercury Export Ban Act of 2008 and Federal Register Notices .......................... A–1

A.1 Public Law 110-414: Mercury Export Ban Act—October 14, 2008 ................................ A–2

A.2 Notice of Intent to Prepare a Supplemental Environmental Impact Statement for the 

Long-Term Management and Storage of Elemental Mercury ........................................ A–10

Appendix B Impact Assessment Methodology ....................................................................................B–1

B.1 Introduction ........................................................................................................................B–1

B.2 Updates to Occupational and Public Health and Safety Methodology ..............................B–3

B.3 Updates to Socioeconomics and Environmental Justice Methodology ..............................B–4

B.4 References ..........................................................................................................................B–6

Appendix C Storage Facility Construction and Operations Data .................................................... C–1

C.1 Transportation Requirements .............................................................................................C–1

C.2 Mercury Storage Facility....................................................................................................C–5

C.2.1 Introduction ........................................................................................................C–5

C.2.2 Physical Description ..........................................................................................C–7

C.2.3 Construction Data ..............................................................................................C–9

C.2.4 Operations Data ...............................................................................................C–11

C.3 References ........................................................................................................................C–12
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Appendix D Human Health and Ecological Risk Assessment Analysis ........................................... D–1

D.1 Introduction ....................................................................................................................... D–1

D.2 Overview of Input Data and Assumptions ........................................................................ D–1

D.2.1 Quantity of Mercury to Be Shipped .................................................................. D–1

D.2.2 Assumptions About Transportation Analysis ................................................... D–3

D.2.3 Assumptions About the Mercury Storage Facility ............................................ D–6

D.2.4 Assumptions About Mercury Containers .......................................................... D–8

D.3 Overview of Mercury Toxicity and Risk ........................................................................ D–11

D.3.1 Toxic Effects of Mercury ................................................................................ D–12

D.3.2 Factors Strongly Influencing the Risks Associated with the 

Proposed Action .............................................................................................. D–20

D.4 References ....................................................................................................................... D–21

Appendix E Updates to the January 2011 Mercury Storage EIS .......................................................E–1

E.1 Introduction ........................................................................................................................ E–1

E.2 Updates to Occupational and Public Health and Safety Analysis ...................................... E–1

E.3 Updates to Socioeconomics and Environmental Justice Analysis ..................................... E–7

E.3.1 Summary Comparison of Candidate Site Updates ............................................. E–8

E.3.2 Y–12 National Security Complex .................................................................... E–11

E.3.2.1 Affected Environment ..................................................................... E–11

E.3.2.2 Environmental Consequences.......................................................... E–13

E.3.3 Grand Junction Disposal Site ........................................................................... E–15

E.3.3.1 Affected Environment ..................................................................... E–15

E.3.3.2 Environmental Consequences.......................................................... E–18

E.3.4 Hanford Site ..................................................................................................... E–19

E.3.4.1 Affected Environment ..................................................................... E–19

E.3.4.2 Environmental Consequences.......................................................... E–21

E.3.5 Hawthorne Army Depot ................................................................................... E–25

E.3.5.1 Affected Environment ..................................................................... E–25

E.3.5.2 Environmental Consequences.......................................................... E–28

E.3.6 Idaho National Laboratory ............................................................................... E–30

E.3.6.1 Affected Environment ..................................................................... E–30

E.3.6.2 Environmental Consequences.......................................................... E–33

E.3.7 Kansas City Plant ............................................................................................. E–35

E.3.7.1 Affected Environment ..................................................................... E–35

E.3.7.2 Environmental Consequences.......................................................... E–38

E.3.8 Savannah River Site ......................................................................................... E–40

E.3.8.1 Affected Environment ..................................................................... E–40

E.3.8.2 Environmental Consequences.......................................................... E–43

E.3.9 Waste Control Specialists, LLC, Site .............................................................. E–45

E.3.9.1 Affected Environment ..................................................................... E–45

E.3.9.2 Environmental Consequences.......................................................... E–47

E.4 Environmental Documentation Review ........................................................................... E–50

E.5 References ........................................................................................................................ E–52

Appendix F Common and Scientific Names of Plant and Animal Species ...................................... F–1 

Appendix G Cooperating Agency Agreements .................................................................................. G–1

G.1 Correspondence with the U.S. Department of the Interior ................................................ G–2

G.1.1 U.S. Department of Energy’s Correspondence to the U.S. Department 

of the Interior .................................................................................................... G–2

G.1.2 Response from the U.S. Department of the Interior ......................................... G–4
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G.2 Correspondence with the U.S. Environmental Protection Agency ................................... G–5

G.2.1 U.S. Department of Energy’s Correspondence to the U.S. Environmental 

Protection Agency............................................................................................. G–5

G.2.2 Response from the U.S. Environmental Protection Agency ............................. G–7

G.3 Correspondence with the New Mexico Environment Department ................................... G–8

G.3.1 U.S. Department of Energy’s Correspondence to the New Mexico 

Environment Department .................................................................................. G–8

Appendix H Contractor National Environmental Policy Act Disclosure Statement ...................... H–1 

Appendix I Responses to Consultation Requests ................................................................................ I–1 

I.1 Correspondence with the New Mexico Ecological Services Office ................................... I–2 

I.1.1 U.S. Department of Energy’s Correspondence to the New Mexico 

Ecological Services Office .................................................................................. I–2 

I.1.2 Response from the New Mexico Ecological Services Office ............................. I–9 

I.2 Correspondence with the New Mexico Department of Game and Fish ............................ I–13 

I.2.1 U.S. Department of Energy’s Correspondence to the New Mexico 

Department of Game and Fish .......................................................................... I–13 

I.2.2 Response from the New Mexico Department of Game and Fish ..................... I–16 

I.3 Correspondence with the New Mexico Energy, Minerals and Natural Resources 

Department ........................................................................................................................ I–22 

I.3.1 U.S. Department of Energy’s Correspondence to the New Mexico 

Energy, Minerals and Natural Resources Department ...................................... I–22 

I.3.2 Response from the New Mexico Energy, Minerals and Natural Resources 

Department ....................................................................................................... I–25 

I.4 Correspondence with the New Mexico Historic Preservation Division ............................ I–27 

I.4.1 U.S. Department of Energy’s Correspondence to the New Mexico 

Historic Preservation Division .......................................................................... I–27 

I.4.2 Response from the New Mexico Historic Preservation Division ..................... I–30 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

viii

List of Figures 

Figure S–1. The Mercury Cycle ............................................................................................................ S–3

Figure S–2. Alternative Sites Analyzed for U.S. Department of Energy Storage of Mercury .............. S–7

Figure S–3. Conceptual Exterior of a New Mercury Storage Facility(ies) ............................................ S–8

Figure S–4. Risk Ranking Matrix ........................................................................................................ S–12 

Figure 1–1. The Mercury Cycle ............................................................................................................ 1–2 

Figure 2–1. Potential Sources of Mercury in the United States ............................................................ 2–2 

Figure 2–2. Typical Elemental Mercury Storage Containers ................................................................ 2–4

Figure 2–3. Conceptual Exterior Representation of a New Mercury Storage Facility .......................... 2–5 

Figure 2–4. Conceptual Layout of a New Mercury Storage Facility .................................................... 2–5 

Figure 2–5. Alternative Sites for Long-Term Storage of Mercury ........................................................ 2–9 

Figure 2–6. WIPP Facility in State of New Mexico ............................................................................ 2–12 

Figure 2–7. WIPP Vicinity Reference Locations ................................................................................ 2–13 

Figure 3–1. Location of the Waste Isolation Pilot Plant Site in Eddy County, New Mexico................ 3–3 

Figure 3–2. Four Property Areas Within the Waste Isolation Pilot Plant Boundary ............................. 3–4

Figure 3–3. Location of the Waste Isolation Pilot Plant Site Within the Great Plains Province in 

Southeastern New Mexico ................................................................................................. 3–7 

Figure 3–4. Stratigraphic Column for the Waste Isolation Pilot Plant Site and Surrounding Area ...... 3–8 

Figure 3–5. Stratigraphy of Aquifer Units at the Waste Isolation Pilot Plant Site .............................. 3–15 

Figure 3–6. Populations Residing in the Two-County Area Surrounding the Waste Isolation 

Pilot Plant in 2000 and 2010 ............................................................................................ 3–30 

Figure 3–7. Populations Residing Within 16 Kilometers (10 miles) of the Storage Location at 

Waste Isolation Pilot Plant Vicinity Section 10 ............................................................... 3–31 

Figure 3–8. Populations Residing Within 16 Kilometers (10 miles) of the Storage Location at 

Waste Isolation Pilot Plant Vicinity Section 20 ............................................................... 3–32 

Figure 3–9. Populations Residing Within 16 Kilometers (10 miles) of the Storage Location at 

Waste Isolation Pilot Plant Vicinity Section 35 ............................................................... 3–33 

Figure 4–1. Candidate Mercury Storage and Greater-Than-Class C Waste Disposal Facility 

Locations .......................................................................................................................... 4–44 

Figure C–1. Dimensions of a Typical 3-Liter Flask ...............................................................................C–1

Figure C–2. Dimensions of a Typical 1-Metric-Ton Container .............................................................C–2

Figure C–3. Example Box Pallet for Shipping 3-Liter Flasks in a 7-Flask by 7-Flask 

Configuration .....................................................................................................................C–3

Figure C–4. Conceptual Layout for a New Mercury Storage Facility ...................................................C–7

Figure C–5. Conceptual Schematic for Receiving and Shipping Area and Handling Area of a 

New Mercury Storage Facility ...........................................................................................C–8

Figure D–1. 7- by 7-Array of 3-Liter Flasks ......................................................................................... D–9

Figure D–2. 3-Liter Flasks in Box Pallets on a Seismically Rated Rack ............................................ D–10 

Figure D–3. 1-Metric-Ton Container .................................................................................................. D–10 

Figure D–4. 1-Metric-Ton Containers in a Spill Tray ......................................................................... D–11 

Figure D–5. Risk (Frequency and Consequence) Ranking Matrix ..................................................... D–13 
Table of Contents 

ix

Figure E–1. Populations Residing Within the Five-County Area Surrounding Y–12 National 

Security Complex ............................................................................................................. E–12 

Figure E–2. Block Groups Containing Minority and Low-Income Populations Surrounding 

Y–12 National Security Complex .................................................................................... E–14 

Figure E–3. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Y–12 National Security Complex .............................................................................. E–15 

Figure E–4. Populations Residing Within the Two-County Area Surrounding the Grand 

Junction Disposal Site ...................................................................................................... E–17 

Figure E–5. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Grand Junction Disposal Site ..................................................................................... E–18 

Figure E–6. Populations Residing Within the Two-County Area Surrounding the 200-West 

Area at the Hanford Site ................................................................................................... E–20 

Figure E–7. Block Groups Containing Minority and Low-Income Populations Surrounding the 

200-West Area at the Hanford Site .................................................................................. E–22 

Figure E–8. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the 200-West Area at the Hanford Site ............................................................................ E–23 

Figure E–9. Populations Residing Within Mineral County, Nevada, Surrounding the Hawthorne 

Army Depot ...................................................................................................................... E–26 

Figure E–10. Block Group Containing Minority and Low-Income Populations Surrounding the 

Hawthorne Army Depot ................................................................................................... E–27 

Figure E–11. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Hawthorne Army Depot ............................................................................................. E–28 

Figure E–12. Populations Residing Within the Two-County Area Surrounding Idaho National 

Laboratory ........................................................................................................................ E–31 

Figure E–13. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Radioactive Waste Management Complex ................................................................ E–32 

Figure E–14. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Idaho Nuclear Technology and Engineering Center .................................................. E–33 

Figure E–15. Populations Residing Within the Four-County Area Surrounding the Kansas City 

Plant ................................................................................................................................. E–36 

Figure E–16. Block Groups Containing Minority and Low-Income Populations Surrounding the 

Kansas City Plant ............................................................................................................. E–37 

Figure E–17. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Kansas City Plant ....................................................................................................... E–38 

Figure E–18. Populations Residing Within the Four-County Area Surrounding the Savannah 

River Site .......................................................................................................................... E–41 

Figure E–19. Block Groups Containing Minority and Low-Income Populations Surrounding the 

Savannah River Site ......................................................................................................... E–42 

Figure E–20. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Savannah River Site ................................................................................................... E–43 

Figure E–21. Populations Residing Within the Three-County Area Surrounding the Waste 

Control Specialists Site .................................................................................................... E–46 

Figure E–22. Block Groups Containing Minority and Low-Income Populations Surrounding the 

Waste Control Specialists Site ......................................................................................... E–48 

Figure E–23. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at 

the Waste Control Specialists Site ................................................................................... E–49 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

x

List of Tables 

Table S–1. Summary of Cumulative Impacts Assessment ................................................................. S–14

Table 1–1. Anticipated Mercury Inventory .......................................................................................... 1–4 

Table 2–1. Comparison of Action Alternatives – Physical Setting and Location Factors ................. 2–17 

Table 2–2. Comparison of Action Alternatives – Environmental Consequences .............................. 2–18 

Table 2–3. Summary of Consequences and Risks from All Onsite Mercury Spill Scenarios ........... 2–26 

Table 2–4. Transportation Kilometers and Frequency Analysis for Transport Accidents ................. 2–27 

Table 2–5. Summary of Transportation Consequences and Risks to Human Receptors ................... 2–27 

Table 2–6. Summary of Consequences and Risk to Ecological Receptors – Transportation 

Accident with Pallet Fire .................................................................................................. 2–28 

Table 2–7. Summary of Cumulative Impacts Assessment ................................................................. 2–30 

Table 3–1. General Regions of Influence for the Affected Environment ............................................ 3–2

Table 3–2. Annual Emissions of Criteria Pollutants and Volatile Organic Compounds from 

Selected Major Facilities and Total Point and Area Source Emissions in Eddy 

County Encompassing the Waste Isolation Pilot Plant Site ............................................. 3–18 

Table 3–3. National Ambient Air Quality Standards or New Mexico State Ambient Air 

Quality Standards and Highest Background Levels Representative of the Waste 

Isolation Pilot Plant Area, 2003–2007 ............................................................................. 3–19 

Table 3–4. Federally and State-Listed Species Potentially Occurring at the Waste Isolation 

Pilot Plant Site .................................................................................................................. 3–22 

Table 4–1. Air Pollutant Emissions from Transportation of Elemental Mercury by Truck to All 

WIPP Vicinity Reference Locations .................................................................................. 4–8 

Table 4–2. Air Pollutant Emissions from Transportation of Elemental Mercury by Rail to All 

WIPP Vicinity Reference Locations .................................................................................. 4–8 

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

Occurrence ....................................................................................................................... 4–19 

Table 4–4. Summary of Types of Accidents Considered in Onsite Spill Analysis ............................ 4–20 

Table 4–5. Summary of Risks of All Onsite Elemental Mercury Spill Scenarios – All 

WIPP Vicinity Reference Locations ................................................................................ 4–22 

Table 4–6. Frequency Analysis of Truck and Railcar Accidents – All WIPP Vicinity Reference 

Locations .......................................................................................................................... 4–23 

Table 4–7. Summary of Transportation Risks to Human Receptors, Spills of Elemental 

Mercury onto the Ground or into Water – All WIPP Vicinity Reference Locations ....... 4–25 

Table 4–8. Predicted Range of Distances Downwind Within Which Acute Airborne Severity 

Levels Are Exceeded – Crashes with Fires ...................................................................... 4–26 

Table 4–9. Summary of Acute-Inhalation Risks to Human Receptors, Accidents with Fires, 

Transportation Routes to All WIPP Vicinity Reference Locations ................................. 4–27 

Table 4–10. Predicted Range of Distances Downwind to Which Lakes Could Potentially Be 

Contaminated Above Levels Safe for Consumption of Fish – Accidental Truck and 

Railcar Crashes with Fires ............................................................................................... 4–27 

Table 4–11. Summary of Transportation Risks to Human Receptors – All WIPP Vicinity 

Reference Locations ......................................................................................................... 4–28 

Table 4–12. Predicted Range of Distances Downwind to Which Acute Airborne Severity Levels 

Are Exceeded – IDA Fires ............................................................................................... 4–30 

Table 4–13. Predicted Range of Distances Downwind to Which Lakes Could Potentially Be 

Contaminated Above Levels Safe for Consumption of Fish – Intentional 

Destructive Acts ............................................................................................................... 4–31 
Table of Contents 

xi

Table 4–14. Screening Values and Equivalent Deposited Screening Values ...................................... 4–32 

Table 4–15. Summary of Potential Exposure of Receptors to Consequence Severity Levels II, 

III, and IV – Truck Spill with Wooden Pallet Fire and No Rain ..................................... 4–34 

Table 4–16. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and No Rain, All Sites .................................... 4–35 

Table 4–17. Summary of Potential Exposure of Receptors to Consequence Severity Levels II, 

III, and IV – Truck Spill with Wooden Pallet Fire and Rain ........................................... 4–36 

Table 4–18. Frequencies, Consequences, and Risks to Ecological Receptors from 

Truck Crashes with Wooden Pallet Fires and Rain, All Sites .......................................... 4–36 

Table 4–19. Frequencies, Consequences, and Risks to Ecological Receptors from 

Railcar Crashes with Wooden Pallet Fires and No Rain, All Sites .................................. 4–37 

Table 4–20. Summary of Potential Exposure of Receptors to Consequence Severity Levels II, 

III, and IV – Intentionally Initiated Railcar Spill with Fire, No Rain .............................. 4–38 

Table 4–21. Summary of Potential Exposure of Receptors to Consequence Severity Levels II, 

III, and IV – Intentionally Initiated Railcar Spill with Fire and Rain .............................. 4–39 

Table 4–22. Actions That May Contribute to Cumulative Impacts ..................................................... 4–43 

Table 5–1. Environmental Permit Summary ........................................................................................ 5–4 

Table 5–2. Summary of Consultations ................................................................................................. 5–6 

Table B–1. General Regions of Influence .............................................................................................B–3 

Table B–2. Site-Specific Thresholds for Identification of Minority and Low-Income 

Communities Within the 16-Kilometer (10-Mile) Region of Influence ............................B–5 

Table B–3. Site-Specific Thresholds for Identification of Minority and Low-Income 

Communities Within the 3.2-Kilometer (2-Mile) Region of Influence .............................B–5 

Table B–4. Environmental Justice Impact Assessment Protocol ..........................................................B–6 

Table C–1. Data for a Mercury Storage Facility – New Construction..................................................C–9 

Table C–2. Resource Commitments for Construction of a New Mercury Storage Facility ...............C–10 

Table C–3. Air Emissions During Construction of a New Mercury Storage Facility ........................C–10 

Table C–4. Resource Commitments for Operation of a New Mercury Storage Facility ....................C–11 

Table D–1. Dispatching Sites, Years, and Quantities of Elemental Mercury ...................................... D–2 

Table D–2. Estimate of Amounts of Mercury to be Transported ......................................................... D–5 

Table D–3. Basic Probabilities Used in the Transportation Risk Analysis .......................................... D–6 

Table D–4. Physical Data for a Mercury Storage Facility – New Construction .................................. D–8 

Table D–5. Definition of Consequence Severity Bands for Acute Inhalation of Elemental 

Mercury and Inorganic Mercury – Public Receptors ...................................................... D–14 

Table D–6. Proposed EPA Values for Mercury Vapor AEGLs ......................................................... D–15 

Table D–7. Summary of Definitions of Consequence Severity Levels ............................................. D–19 

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

Mercury, Public Receptors ................................................................................................. E–2

Table E–2. Distances to the Closest Site Boundary or Public Receptor Compared with 

Calculated Distances – Outdoor Earthquake Scenario ....................................................... E–3

Table E–3. Predicted Range of Distances Downwind to Which Acute Airborne Severity Levels 

Are Exceeded – Crashes with Fires ................................................................................... E–5

Table E–4. Predicted Range of Distances Downwind to Which Acute Airborne Severity 

Levels Are Exceeded – IDA Fires...................................................................................... E–6

Table E–5. Section Updates for Socioeconomics and Environmental Justice Analyses ...................... E–8

Table E–6. Summary Comparison of Changes to Environmental Justice Data ................................... E–9
xii

List of Abbreviations and Acronyms 

°C degrees Celsius 

°F degrees Fahrenheit 

1-MT 1-metric-ton 

3-L 3-liter 

ACGIH American Conference of Governmental Industrial Hygienists 

ACS American Community Survey 

AEGL Acute Exposure Guideline Level 

bgs below ground surface 

BLM U.S. Bureau of Land Management 

BNSF Burlington Northern Santa Fe

C&D construction and demolition 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CH contact-handled 

CO carbon monoxide 

CWC Central Waste Complex 

dBA decibels A-weighted 

DLA Defense Logistics Agency 

DNSC Defense National Stockpile Center 

DOE U.S. Department of Energy 

Draft Mercury Draft Long-Term Management and Storage of Elemental Mercury Supplemental 

Storage SEIS Environmental Impact Statement 

EIS environmental impact statement 

EPA U.S. Environmental Protection Agency 

ERPG Emergency Response Planning Guideline 

FL frequency level 

FLPMA Federal Land Policy and Management Act 

GJDS Grand Junction Disposal Site 

GTCC greater-than-Class C 

GTCC EIS Draft Environmental Impact Statement for the Disposal of Greater-Than-Class C 

(GTCC) Low-Level Radioactive Waste and GTCC-Like Waste 

Hanford Hanford Site 
List of Abbreviations and Acronyms 

xiii

IDA intentional destructive act 

IDLH immediately dangerous to life or health 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

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

Receipt, Management, and Long-Term Storage of Elemental Mercury 

KCP Kansas City Plant 

LCF latent cancer fatality 

Ldn day–night average sound level 

LLW low-level radioactive waste 

LMP Land Management Plan 

LWA Land Withdrawal Act 

LWB land withdrawal boundary 

MB marker bed 

Mercury Storage EIS Long-Term Management and Storage of Elemental Mercury Environmental 

Impact Statement 

MM EIS Final Mercury Management Environmental Impact Statement

MSL mean sea level 

NEPA National Environmental Policy Act 

NMAC New Mexico Administrative Code 

NMSA New Mexico Statutes Annotated 

NO2 nitrogen dioxide 

NOI Notice of Intent 

NRC U.S. Nuclear Regulatory Commission 

O3 ozone 

PAC Protective Action Criterion 

PCB polychlorinated biphenyl 

PGA peak ground acceleration 

PMn particulate matter with an aerodynamic diameter less than or equal to

n micrometers 

PPE personal protective equipment 

ppm part(s) per million 

PSD Prevention of Significant Deterioration 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

xiv

R&R reclamation and recycling 

RCRA Resource Conservation and Recovery Act 

RfC reference concentration 

RH remote-handled 

ROD Record of Decision 

ROI region of influence 

RWMC Radioactive Waste Management Complex 

SEIS supplemental environmental impact statement 

SHPO State Historic Preservation Officer 

SL severity level 

SO2 sulfur dioxide 

SRS Savannah River Site 

SWDA Solid Waste Disposal Act 

TEEL Temporary Emergency Exposure Limit 

the Act Mercury Export Ban Act of 2008 

TLV threshold limit value 

TRAGIS Transportation Routing Analysis Geographic Information System 

TRU transuranic 

TSCA Toxic Substances Control Act 

TSD treatment, storage, and disposal 

TWA time-weighted average 

USGS U.S. Geological Survey 

VOC volatile organic compound 

VRM Visual Resource Management 

WCS Waste Control Specialists, LLC, site 

WIPP Waste Isolation Pilot Plant 

WIPP SEIS II Waste Isolation Pilot Plant Disposal Phase Final Supplemental Environmental 

Impact Statement 

Y–12 Y–12 National Security Complex 
xv

Measurement Units 

The principal measurement units used in this Long-Term Management and Storage of Elemental Mercury 

Supplemental Environmental Impact Statement (Mercury Storage SEIS) are SI units (the abbreviation for 

the Système International d’Unites). The SI system is an expanded version of the metric system that was 

accepted in 1966 in Elsinore, Denmark, as the legal standard by the International Organization for 

Standardization. In this system, most units are made up of combinations of seven basic units, of which 

length in meters, mass in kilograms, and volume in liters are of most importance in this Mercury 

Storage SEIS. Exceptions are radiological units that use the English system (e.g., rem, millirem). 

SCIENTIFIC (EXPONENTIAL) NOTATION 

Numbers that are very small or very large are often expressed in scientific, or exponential, notation as a 

matter of convenience. For example, the number 0.000034 may be expressed as 3.4×10-5 or 3.4E-05, and 

65,000 may be expressed as 6.5×104 or 6.5E+04. In this Mercury Storage SEIS, numerical values that are 

less than 0.001 or greater than 9,999 are generally expressed in scientific notation, i.e., 1.0×10-3 and 

9.9×103, respectively. 

Multiples or submultiples of the basic units are also used. A partial list of prefixes that denote multiples 

and submultiples follows, with the equivalent multiplier values expressed in scientific notation. 

Prefix Symbol Multiplier

atto a 0.000 000 000 000 000 001 1×10-18

femto f 0.000 000 000 000 001 1×10-15

pico p 0.000 000 000 001 1×10-12

nano n 0.000 000 001 1×10-9

micro μ 0.000 001 1×10-6

milli m 0.001 1×10-3

centi c 0.01 1×10-2

deci d 0.1 1×10-1

deka da 10 1×101

hecto h 100 1×102

kilo k 1,000 1×103

mega M 1,000,000 1×106

giga G 1,000,000,000 1×109

tera T 1,000,000,000,000 1×1012

peta P 1,000,000,000,000,000 1×1015

exa E 1,000,000,000,000,000,000 1×1018

The following symbols are occasionally used in conjunction with numerical expressions: 

 < less than 

≤ less than or equal to 

 > greater than 

≥ greater than or equal to 
xvi

Conversions 

English to Metric Metric to English

Multiply by To get Multiply by To get

Area

square inches

square feet

square yards

acres

square miles

Length

inches

feet

feet

yards

miles

Temperature

degrees 

Fahrenheit

Volume

fluid ounces 

gallons

cubic feet

cubic yards

Weight

ounces

pounds

short tons

6.4516

0.092903

0.8361

0.40469

2.58999

2.54

30.48

0.3048

0.9144

1.60934

Subtract 32, then 

multiply by 0.55556

29.574

3.7854

0.028317

0.76455

28.3495

0.45360

0.90718

square centimeters

square meters

square meters

hectares

square kilometers

centimeters

centimeters

meters

meters

kilometers

degrees

Celsius

milliliters

liters

cubic meters

cubic meters

grams

kilograms

metric tons

Area

square centimeters

square meters

square meters

hectares

square kilometers

Length

centimeters

centimeters

meters

meters

kilometers

Temperature

degrees

Celsius

Volume

milliliters

liters

cubic meters

cubic meters

Weight

grams

kilograms

metric tons

0.155

10.7639

1.196

2.471

0.3861

0.3937

0.0328

3.281

1.0936

0.6214

Multiply by 1.8,

then add 32

0.0338

0.26417

35.315

1.308

0.03527

2.2046

1.1023

square inches

square feet

square yards

acres

square miles

inches

feet

feet

yards

miles

degrees 

Fahrenheit

fluid ounces

gallons

cubic feet

cubic yards

ounces

pounds

short tons
SUMMARY AND GUIDE FOR STAKEHOLDERS

S–1 

SUMMARY AND GUIDE FOR STAKEHOLDERS 

S.1 INTRODUCTION 

This Summary and Guide for Stakeholders presents a concise overview of the major issues addressed in 

this Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental 

Impact Statement (Draft Mercury Storage SEIS).

The U.S. Department of Energy (DOE) prepared this draft SEIS as part of DOE’s ongoing process to 

establish a facility(ies) for storing elemental mercury in accordance with the Mercury Export Ban Act 

of 2008 (the Act). The U.S. Environmental Protection Agency (EPA) and the U.S. Bureau of Land 

Management (BLM) are cooperating agencies on this SEIS. 

The text box at left provides a synopsis of the 

relevant features of the Act, and Appendix A of this 

draft SEIS contains a complete copy of the Act. 

To evaluate the range of reasonable alternatives for 

siting, constructing, and operating a facility or 

facilities to meet its obligations under the Act, DOE 

prepared the Final Long-Term Management and 

Storage of Elemental Mercury Environmental Impact 

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

in accordance with the National Environmental 

Policy Act (NEPA) of 1969 and its implementing 

regulations (40 CFR 1500–1508, 10 CFR 1021). 

The Final Mercury Storage EIS, issued in 

January 2011 (76 FR 5156), evaluated seven 

candidate locations for the elemental mercury 

storage facility(ies), as well as a No Action 

Alternative. Those sites are the Grand Junction 

Disposal Site near Grand Junction, Colorado; 

Hanford Site near Richland, Washington; Hawthorne 

Army Depot near Hawthorne, Nevada; Idaho 

National Laboratory near Idaho Falls, Idaho; Kansas 

City Plant in Kansas City, Missouri; Savannah River 

Site near Aiken, South Carolina; and Waste Control 

Specialists, LLC, site near Andrews, Texas. As 

stated in DOE’s Notice of Intent issued on 

June 5, 2012 (77 FR 33204), DOE has subsequently 

reconsidered the range of reasonable alternatives 

evaluated in the January 2011 Mercury Storage EIS. 

Accordingly, DOE identified two candidate locations 

that would be evaluated in an SEIS for the long-term 

management and storage of elemental mercury in its 

Notice of Intent. Subsequently, after consideration 

of scoping comments received, DOE identified a 

third candidate location. DOE has prepared this 

draft SEIS to evaluate three additional alternative 

sites for a long-term mercury storage facility(ies), all 

of which are located in the vicinity of the Waste 

Isolation Pilot Plant (WIPP) near Carlsbad, New 

Mexico, which DOE operates for disposal of defense 

The Mercury Export Ban Act

of 2008 (the Act)

The Act prohibits the sale, distribution, or 

transfer of mercury by Federal agencies 

to other government agencies and 

private entities as of October 14, 2008.

It bans the export of elemental mercury 

from the United States as of 

January 1, 2013.

The U.S. Department of Energy (DOE) 

must designate a facility(ies) for 

long-term management and storage of 

mercury generated in the United States.

Any such facility(ies) must comply with 

applicable requirements of the Solid 

Waste Disposal Act, as amended by the 

Resource Conservation and Recovery 

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

The Act does not specify how long 

mercury may require storage at the 

DOE-designated facility(ies).

DOE is required to charge a fee to cover 

the cost of mercury storage.

The Act requires the U.S. Environmental 

Protection Agency (EPA) to report to 

Congress on whether to expand the 

export ban to cover one or more mercury 

compounds. This report was issued in 

October 2009.

EPA must report to Congress by 

January 1, 2017, on the global supply 

and trade of elemental mercury, 

including whether additional primary 

mercury mining has occurred as a 

consequence of the Act.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

S–2

transuranic waste. DOE is not proposing changes to any other key parameters of the January 2011 

Mercury Storage EIS, including the quantity or characteristics of the mercury inventory, the approach for 

long-term storage and management of this inventory, the design of the facilities, or the 40-year period of 

analysis. 

DOE’s process for siting, constructing, and operating the requisite facility(ies) involves compliance with 

the provisions of NEPA, which requires Federal agencies to integrate environmental values into their 

decisionmaking by considering the potential environmental impacts of proposed actions and the range of 

reasonable alternatives to those actions. For major Federal actions significantly affecting the quality of 

the human environment, agencies must prepare an environmental impact statement, which considers the 

potentially affected environment, including the natural physical environment (e.g., air, water, geology, 

soils, plant and animal life) and the relationship between humans and the environment (e.g., health, 

safety, jobs, schools, housing, cultural resources, and aesthetics). Addressing environmental justice, the 

process of identifying and addressing disproportionately high and adverse effects of agency programs, 

policies, and activities on minority and low-income populations, is also a key component of an 

environmental impact statement. As discussed in Appendix E, Section E.4, environmental documentation 

that has become available since publication of the January 2011 Mercury Storage EIS has been reviewed, 

and with the exception of the socioeconomics and environmental justice resource areas, no other changes 

to the affected environment as presented in Chapter 3 of the January 2011 Mercury Storage EIS were 

found to be necessary. The analyses presented in Chapter 4 of the January 2011 Mercury Storage EIS

remain valid and are incorporated into this draft SEIS with two exceptions: (1) the occupational and 

public health and safety analysis; and (2) the socioeconomics and environmental justice analysis. This 

draft SEIS includes updates to the occupational and public health and safety analysis resulting from 

changes to the definition of severity levels (i.e., magnitude of impacts) for acute-inhalation exposures to 

the public under certain accident scenarios. This draft SEIS also includes updates to the socioeconomics 

and environmental justice analyses to incorporate 2010 decennial census information that was not 

available at the time the January 2011 Mercury Storage EIS was published. The updates to the analyses 

are presented in Appendix B and Appendix E of this draft SEIS. Relevant information and data from the 

January 2011 Mercury Storage EIS that remain unchanged have been reproduced and presented in this 

draft SEIS for the convenience of the reader. 

S.1.1 Why Reduce the Amount of Mercury in the Environment? 

Mercury is an element that enters the environment as a result of 

natural processes (e.g., volcanoes, wildfires, surface emissions) and 

human activities (see Figure S–1). Mercury and its compounds are 

toxic; therefore, they pose human health and ecological risks. The 

potential effects may be widespread because mercury is easily 

dispersed throughout the environment. Moreover, the free trade of 

elemental mercury on the world market has encouraged its 

continued use, resulting in increasingly higher levels of mercury in the global environment. This has 

increased the risk of neurological and reproductive effects for humans and wildlife, and it means mercury 

is a pollutant of environmental concern throughout the world. By banning the export of U.S. mercury, 

Congress anticipated reducing the amount of mercury available in commerce worldwide, thus reducing 

the associated health risks. 

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

processes because it is a good conductor of electricity and it alloys, or mixes, readily with other metals. 

Historically, it has been used in batteries, paint, thermometers, thermostats, auto lighting switches, 

fluorescent lights, dental fillings, and medical devices such as blood pressure monitors. Many of these 

uses have declined in recent years. 

For purposes of this 

supplemental environmental 

impact statement, “mercury” 

refers to elemental mercury 

unless otherwise indicated.
Summary and Guide for Stakeholders 

S–3

Figure S–1. The Mercury Cycle 

S.1.2 What Are DOE’s Objectives?

DOE prepared the January 2011 Mercury Storage EIS, and subsequently this draft SEIS, to evaluate the 

potential impacts of the proposed action, i.e., to establish a facility(ies) for the long-term management and 

storage of mercury. In accomplishing this, DOE is committed to the following overall objectives for its 

mercury storage program: 

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

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

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

S.1.3 How Much Mercury Could DOE Manage and Store? 

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

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

least 40 years. The Mercury Export Ban Act of 2008 does not specify how long the DOE mercury storage 

facility(ies) would need to be operated. Therefore, it is possible that more or less than 10,000 metric tons 

(11,000 tons) of mercury could eventually require storage for a period longer or shorter than 40 years. 

Additional NEPA documentation 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. 

Further discussion of the estimated mercury inventory is presented in Chapter 1, Section 1.3.1, of this 

draft SEIS. 

S.1.4 Where Would the Mercury Come From? 

Potential sources of mercury that may require long-term storage by DOE are shown in Chapter 2, 

Figure 2–1. They include the following: chlor-alkali plants that continue to use mercury-cell technology; 

gold mining, which produces byproduct mercury; mercury waste reclamation and recycling; and, 

potentially, some or all of the mercury currently stored at the Y–12 National Security Complex. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

S–4

Shipment estimates from the January 2011 Mercury Storage EIS are presented in Appendix C, 

Section C.1, of this draft SEIS. It is estimated that there would be about 79 truck shipments per year 

during the first two years of operation, 39 per year between the third and seventh years of operation, and 

27 per year between the eighth and fortieth years of operation. If transported by rail, there would be 

about 23 rail shipments per year during the first two years of operation, 8 per year between the third and 

seventh years of operation, and only 5 per year between the eighth and fortieth years of operation.1

1

 For purposes of analysis, the January 2011 Mercury Storage EIS assumes a 40-year operational period with the first year 

starting in 2013 and the fortieth year, in 2052. An operational start date is not known at this time; however, the period of 

analysis remains 40 years. For example, if the mercury storage facility(ies) were to start operations in 2014, the last year of 

operations would likewise shift to 2053, and so forth. 

S.2 WHAT DOES THIS SEIS ADDRESS? 

This draft SEIS addresses the short- and long-term potential health and environmental effects of 

establishing and operating a DOE facility(ies) to provide the necessary capability for this storage at three 

new candidate locations in the vicinity of WIPP near Carlsbad, New Mexico. 

S.2.1 Decisions to Be Made 

In making long-term mercury management decisions, DOE will consider the results of the January 2011 

Mercury Storage EIS and this draft SEIS, public comments, and other relevant factors. DOE intends to 

make the following decisions: 

Where to locate the mercury storage facility(ies) 

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

for mercury storage 

DOE will make a decision on the proposed action no sooner than 30 days after publication of EPA’s 

Notice of Availability of the Final Mercury Storage SEIS in the Federal Register. DOE will announce its 

decision in a Record of Decision (ROD) published in the Federal Register. 

S.2.2 Scope of This SEIS 

This draft SEIS includes the following: 

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

Consideration of the No Action Alternative 

Consideration of construction of new facilities 

Potential health and environmental effects, including transportation to potential storage 

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

Comparison of the analytic results for all sites 

The issues and concerns raised by stakeholders during the public scoping period for this 

draft SEIS, along with DOE’s responses

The DOE Preferred Alternative 

 
Summary and Guide for Stakeholders 

S–5

S.2.3 Affected Environment and Environmental Consequences 

Chapter 2 of this draft SEIS presents a description of the three new candidate locations in the vicinity of 

WIPP near Carlsbad, New Mexico, and a summary and comparison of potential impacts associated with 

providing a capability for the long-term management and storage of elemental mercury. These locations 

will be referred to individually as “WIPP Vicinity Section 10”; “WIPP Vicinity Section 20”; and 

“WIPP Vicinity Section 35” or together as the “WIPP Vicinity reference locations.” The No Action 

Alternative is also discussed as required under NEPA for use as a basis of comparison. 

The affected environment for the WIPP Vicinity reference locations is described in Chapter 3 of this draft 

SEIS and includes land use and visual resources; geology, soils, and geologic hazards; water resources; 

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

infrastructure; waste management; occupational and public health and safety; socioeconomics; and 

environmental justice. 

In Chapter 4 of this draft SEIS, DOE presents the potential environmental impacts of the proposed action 

for the three new alternative sites within defined regions of influence (ROIs) specific to each resource 

area and site evaluated. ROIs encompass the geographic areas within which any meaningful potential 

impact is expected to occur, and can include the area within which the proposed action would take place, 

the site as a whole, or nearby offsite areas. ROIs that are defined with the term “nearby offsite areas” 

may be different for each site depending on the extent to which meaningful impacts are expected to occur. 

For example, impacts on historic resources were evaluated at specific facility locations within each 

candidate site, whereas human health risks to the general public were assessed for offsite areas of the 

candidate location. Brief descriptions of the ROIs for each resource area are presented in Appendix B. 

Resource areas analyzed for each candidate site include land use and visual resources; geology, soils, and 

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

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

safety; ecological risk; socioeconomics; and environmental justice. The potential impacts analyzed from 

construction and modification of a mercury storage facility(ies) include those related to visual, ecological, 

and water resources; land disturbance; resource use; air emissions and noise; and employment. 

Operational impacts, including those related to resource use, air emissions, and human health effects, and 

transportation impacts, including those related to air emissions, human health, and ecological risk, are 

also analyzed. See Section S.5, “Comparison of Impacts and Alternatives,” of this Summary and Guide 

for Stakeholders. 

S.3 MERCURY STORAGE SITE ALTERNATIVES 

To meet the requirements of the Act, DOE proposes to designate one or more existing or new facilities 

for the long-term management and storage of mercury. As required by NEPA, the No Action Alternative 

is evaluated to serve, among other things, as a basis for comparison with the action or site alternatives. 

Under the No Action Alternative, DOE would not establish a facility(ies) for long-term management and 

storage of mercury as is required by the Act. Because the Act also prohibits the export of mercury after 

January 1, 2013, companies in the United States would have to find another way to manage their 

excess mercury. Any excess mercury would remain the responsibility of its owners or would be sent to 

commercial waste management facilities. Approximately 1,200 metric tons (1,300 tons) of DOE mercury 

currently stored at the DOE Y–12 National Security Complex in Tennessee would continue to be 

managed and stored at this location. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

S–6

S.3.1 Candidate Sites Evaluated in the January 2011 Mercury Storage EIS

The January 2011 Mercury Storage EIS evaluated seven candidate sites for the long-term management 

and storage of elemental mercury:

New construction at the Grand Junction Disposal Site

New construction in the 200-West Area at the Hanford Site

Existing storage buildings in the Central Magazine Area at the Hawthorne Army Depot

New construction at Idaho National Laboratory’s Idaho Nuclear Technology and Engineering 

Center or existing storage buildings at the Radioactive Waste Management Complex

Existing building at the Bannister Federal Complex’s Kansas City Plant

New construction in E Area at the Savannah River Site

New construction at the Waste Control Specialists, LLC, site

S.3.2 Candidate Sites Evaluated in This Draft Mercury Storage SEIS

This draft SEIS evaluates three additional candidate sites for the long-term management and storage of 

elemental mercury:

New construction at WIPP Vicinity Section 10

New construction at WIPP Vicinity Section 20

New construction at WIPP Vicinity Section 35

WIPP is the Nation’s only underground repository for the permanent disposal of defense-generated 

transuranic waste. The WIPP site, located in Eddy County, New Mexico, encompasses approximately 

41 square kilometers (16 square miles) under the jurisdiction of DOE pursuant to the Waste Isolation 

Pilot Plant Land Withdrawal Act (WIPP LWA) (P.L. 102-579). Three options for long-term storage of 

mercury in the vicinity of WIPP have been identified: (1) new construction in Section 10 outside the land 

withdrawal boundary; (2) new construction in Section 20 inside the land withdrawal boundary;

2

and 

(3) new construction in Section 35 outside the land withdrawal boundary. The candidate sites analyzed in 

the January 2011 Mercury Storage EIS and in this draft SEIS are presented below in Figure S–2 and 

discussed further in Chapter 2, Section 2.3, of this draft SEIS.

 

2 The WIPP LWA, Public Law No. 102-579, was signed into law on October 20, 1992, and was later amended by the WIPP 

LWA Amendments of 1996, Public Law No. 104-201. The WIPP LWA withdrew approximately 41 square kilometers 

(16 square miles) of land from the public domain for the purpose of creating and operating WIPP, the geologic repository in 

New Mexico designated as the national disposal site for transuranic waste generated by atomic energy defense activities.
Summary and Guide for Stakeholders 

S–7

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

S.4 DOE MERCURY STORAGE FACILITY(IES) DESCRIPTION 

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

Resource Conservation and Recovery Act (RCRA)–regulated/permitted design with proper spill 

containment features and emergency response procedures 

Security and access control 

Fire suppression systems 

Ventilated storage and handling area(s) 

Fully enclosed weather-protected building(s) 

Reinforced-concrete floors able to accommodate mercury storage 

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

and handling. The Storage Area would constitute approximately 90 percent of the floor space. The 

Storage Area would generally be a large open space similar to a warehouse, where storage, inspection, 

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

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

Other containers could be approved and accepted on a case-by-case basis. The 3-liter flasks would be 

single-, double-, or triple-stacked, and the 1-metric-ton containers would be single- or double-stacked. 

Appendix C of the January 2011 Mercury Storage EIS addressed both the potential construction of new 

facilities and the potential modification of existing facilities for purposes of mercury storage at the 

candidate sites evaluated in the January 2011 Mercury Storage EIS. Since there are no existing facilities 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

S–8

available for use at the three WIPP Vicinity reference locations, a new facility(ies) would have to be 

constructed. As such, only data for new construction are reproduced in Appendix C of this draft SEIS. 

S.4.1 New Storage Facility(ies) Design and Construction 

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

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

40 years. Figure S–3 provides a conceptual illustration of what the exterior of a new mercury storage 

facility(ies) might look like. Chapter 2 and Appendix C of this draft SEIS provide a conceptual layout of 

the interior and how the mercury containers might be stored, as well as additional details and data related 

to the requirements for construction and operation of a new facility(ies). 

Figure S–3. Conceptual Exterior of a New Mercury Storage Facility(ies) 

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

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

(20 feet) to accommodate the potential for triple stacks of pallets of 3-liter flasks. The new facility(ies) 

design would feature a specific Handling Area where container integrity inspections and any necessary 

reflasking activities would be performed. The new facility(ies) would also have a reinforced-concrete 

floor, strong enough to withstand the heavy loads from mercury storage. The floors would be treated with 

an epoxy sealant to add strength and spill containment properties. Lighting, ventilation, fire suppression, 

and security systems would be incorporated into the facility(ies) design. Security systems could include 

security alarms and surveillance cameras. A new full-size, standalone facility would encompass 

approximately 3.1 hectares (7.6 acres). The facility(ies) would be RCRA-regulated and -permitted, and, 

as such, would require secondary containment (e.g., curbing), regular inspection of stored materials, strict 

record-keeping, and periodic reporting to the state. 

S.4.2 Existing Facility(ies) Modification and Upgrades 

Existing facilities were considered in the January 2011 Mercury Storage EIS only if their former use was 

consistent with the storage of hazardous materials, thus keeping the need for modifications to a minimum. 

Alternative locations with existing facilities analyzed in the January 2011 Mercury Storage EIS were the 

storage buildings at the Hawthorne Army Depot, the Radioactive Waste Management Complex at DOE’s

Idaho National Laboratory, and the Main Manufacturing Building at DOE’s Kansas City Plant in 

Missouri. The Container Storage Building at the Waste Control Specialists, LLC, site was also 

considered for interim storage pending construction of a new facility(ies). The analysis presented in this 

draft SEIS only considers new construction for the long-term management and storage of mercury at the 

WIPP Vicinity reference locations. 
Summary and Guide for Stakeholders 

S–9

S.4.3 Operation of a Mercury Storage Facility(ies) 

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

Facility(ies) security 

Shipping and receiving 

Inspections 

Monitoring and long-term storage 

Record-keeping 

Emergency and small-spill response 

These tasks are described in greater detail in Chapter 2, Section 2.2.3, and Appendix C of this draft SEIS. 

S.5 COMPARISON OF IMPACTS AND ALTERNATIVES 

The overall conclusion of the impact analyses presented in this draft SEIS is that there would be no major 

differences in impacts on resource areas among the mercury storage site alternatives. This conclusion is 

based upon the evaluation of the candidate sites analyzed in the January 2011 Mercury Storage EIS and 

the three additional WIPP Vicinity reference location sites analyzed in this draft SEIS. 

Chapter 2, Section 2.6, presents a more detailed comparison of the alternatives analyzed in this draft SEIS 

and the January 2011 Mercury Storage EIS, including a No Action Alternative. Table 2–2 presents a 

comparison of potential impacts on resources from the transportation, receipt, and long-term storage of 

mercury at each of the candidate mercury storage sites. The potential environmental consequences for all 

resource areas are summarized further in Chapter 2 of this draft SEIS. Additional details on potential 

environmental consequences are discussed in Chapter 4 of the January 2011 Mercury Storage EIS and 

this draft SEIS. 

Potential impacts presented in the January 2011 Mercury Storage EIS associated with the No Action 

Alternative would remain unchanged relative to the scope of this draft SEIS. The No Action Alternative 

would affect all sources of mercury and would involve various mercury storage locations, many of which 

are undetermined. Such facilities could vary in location, size, natural and human environments, and in the 

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

stored under the No Action Alternative, the potential environmental consequences would be highly 

speculative. The DOE mercury currently stored at the Y–12 National Security Complex would continue 

to be managed and stored in this location. No new construction would be required at the Y–12 National 

Security Complex, nor would any incremental increase in impacts on resource areas occur because 

storage operations at the Y–12 National Security Complex would not change. 

On January 1, 2013, the prohibition on the export of mercury went into effect pursuant to the Mercury 

Export Ban Act of 2008. As of March 1, 2013, five waste management companies have notified DOE of 

their intent to accumulate and store excess mercury at RCRA-permitted facilities in accordance with 

Section 5(g)(2)(b) of the Act. The companies and storage locations that have submitted notifications are 

(1) Chemical Waste Management, Inc., at its facility in Emelle, Alabama; (2) Clean Harbors 

Environmental Services, Inc., at its facility in Wichita, Kansas; (3) EQ Detroit, Inc., at its facility in 

Detroit, Michigan; (4) Veolia ES Technical Solutions, L.L.C., at its facility in Port Washington, 

Wisconsin; and (5) Waste Management Mercury Waste, Inc., at its facility in Union Grove, Wisconsin.3

 

All of these companies have certified that they will ship the excess elemental mercury to a 

DOE-designated facility(ies) when such a facility(ies) is operational and ready to accept the mercury. 

 

3

 The listing of companies by name is for informational purposes only and does not imply or suggest an endorsement by DOE. 

Until such time that DOE has designated a facility(ies) and is ready to accept mercury for long-term management and storage, 

similar notifications may be received by DOE from other waste management companies. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

S–10

S.5.1 Major Conclusions

The impacts on the various resource areas at any of the candidate sites analyzed in the January 2011 

Mercury Storage EIS or this draft SEIS from construction and operation of a mercury storage facility(ies)

would range from none to minor. The analyses in this draft SEIS support the following conclusions, all 

of which remain valid for the seven candidate sites initially evaluated in the January 2011 Mercury 

Storage EIS and now similarly apply to the three additional WIPP Vicinity candidate sites subsequently 

evaluated in this draft SEIS.

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

candidate sites.

In the areas of geology, soils, and geologic and meteorological hazards, construction of a new 

storage facility(ies) would expose surface soil for up to 6 months. Although unlikely to occur 

over the 40-year analysis period, geologic hazards such as earthquakes could potentially have an 

adverse effect on a mercury storage facility(ies). However, design for construction of a new 

facility(ies) or modification of existing buildings would take seismic and meteorological risks 

into consideration to minimize potential adverse impacts.

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

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

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

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

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

inspections.

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

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

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

Air emissions associated with operations using existing buildings for mercury storage would be 

negligible and limited to employee vehicles, trucks, semiannual testing of emergency generators, 

and small amounts of mercury vapor from storage containers or residual contamination, where 

applicable. Occasionally, some mercury vapors would result from repackaging of mercury in 

new containers. The Handling Area would be outfitted with a vacuum air exhaust and mercury 

vapor filter that would maintain air emissions exhausted to the outside at negligible 

concentrations. Carbon dioxide is a compound associated with global climate change. The 

addition of carbon dioxide to the environment from constructing and/or operating a mercury 

storage facility(ies) at any of the candidate sites would have a negligible effect on the global 

climate.

Engine exhaust emissions from transporting mercury would be in proportion to the number of 

miles required to transport the mercury to the storage facility(ies). For the WIPP Vicinity 

reference locations, these emissions are projected to fall within the range established for the 

candidate sites evaluated in the January 2011 Mercury Storage EIS. Truck and/or rail transport

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

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

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

truck and/or rail shipments is expected to decrease over time.
Summary and Guide for Stakeholders

S–11

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

candidate sites.

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

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

No impacts on cultural or paleontological resources are expected under site alternatives 

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

the buildings would be required. New facility(ies) construction would result in negligible impacts 

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

at the DOE Grand Junction Disposal Site in Colorado and the WIPP Vicinity reference locations 

in New Mexico, where procedures would need to be developed to plan for the possibility of 

inadvertent discoveries during construction.

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

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

supplies. Existing utility capacity in the vicinity of the candidate sites is adequate and could 

easily accommodate utility demands for construction and operations at all candidate sites except 

at the DOE Grand Junction Disposal Site in Colorado. For the WIPP Vicinity reference 

locations, minor to moderate infrastructure upgrades would be necessary to connect to existing 

utility infrastructure.

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

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

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

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

negligible associated risks. Risks were determined using the risk matrix approach, which defines 

levels of risk in terms of frequency of release and severity of consequence (see Figure S–4). 

DOE, EPA, and other Government agencies use this approach. Events have a high (level IV) 

frequency if they occur once in 100 years or more frequently; moderate (level III) between once 

in 10,000 years and once in 100 years; low (level II) between once in 1 million years and once in 

10,000 years; and negligible (level I) less than once in 1 million years. Consequence severity 

levels depend on the receptor (human or ecological) and the pathway (e.g., inhalation or 

ingestion). For example, for acute (up to about 8-hour) inhalation exposures, severity level IV 

corresponds to the possibility of fatality; severity level III to severe, nonlethal health effects; 

severity level II to reversible health effects; and severity level I to negligible health effects or 

minor irritation. Risks are considered negligible if either frequency or severity is at level I. 

Frequency levels and severity levels are discussed in more detail in Chapter 4, Section 4.2.9, and 

Appendix D of this draft SEIS.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

S–12

Figure S–4. Risk Ranking Matrix 

Human health impacts from facility(ies) accidents would range from severity level I to level II 

with an associated negligible-to-low risk for both involved and noninvolved workers and 

negligible risk to members of the public at all candidate sites evaluated. 

Transportation impacts under all alternatives would be dependent on the method of 

transportation (i.e., truck or rail), the number of miles traveled, and the nature of the potential 

accident. For truck travel, the projected frequency of fatalities due to mechanical impact would 

range from 7.8 × 10-4 to 1.2 × 10-3 per year for the action alternatives. For rail travel, the range 

would be slightly lower—from 1.0 × 10-4 to 1.9 × 10-4 fatalities per year. For the WIPP Vicinity 

reference locations, these impacts are projected to fall within the range established for the 

candidate sites evaluated in the January 2011 Mercury Storage EIS. In addition to the possibility 

of fatal accidents due to mechanical impact, exposure to mercury from spills could impact human 

health. For truck or rail spills directly onto the ground, the consequences could range from 

severity level I to IV with negligible risk. For truck or rail spills directly into water bodies, the 

consequences could be as high as severity level II with negligible-to-low risk (but with a large 

degree of uncertainty). For truck and rail spills with fire resulting in airborne mercury vapors, the 

consequences from the inhalation pathway could be severity level II with low risk or as high as 

severity level III with negligible risk. For truck or rail spills with fire, the consequences from 

deposition of airborne mercury onto soil could be severity level I with an associated negligible 

risk. For truck or rail spills with fire, the consequences from deposition of airborne mercury into 

water bodies, the transformation of mercury into methylmercury and bioaccumulation in fish, 

followed by the subsequent consumption of fish, could be severity level I to II with an associated 

negligible-to-low risk. Transportation impacts considered Truck Scenarios 1 and 2. Scenario 1 

assumes fully loaded truck shipments, whereas Scenario 2 assumes a portion of mercury 

shipments would be on partially loaded trucks. Truck Scenarios 1 and 2 are defined in more 

detail in Appendix D, Section D.2.2. 
Summary and Guide for Stakeholders 

S–13

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

trends under all alternatives. 

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

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

Minority and/or low-income populations have not been identified within the 16-kilometer 

(10-mile) or the 3.2-kilometer (2-mile) ROI associated with any of the WIPP Vicinity reference 

locations. Environmental justice analyses previously presented in the January 2011 Mercury 

Storage EIS were updated to reflect the 2010 decennial census and resulted in some changes to 

the data associated with those candidate sites previously analyzed, as discussed in Appendix B 

and Appendix E, Section E.3.1, of this draft SEIS. Census data indicate that minority and/or 

low-income populations are now present within the 16-kilometer (10-mile) ROI at the Hanford 

Site and Hawthorne Army Depot, in addition to the populations previously identified at the DOE 

Kansas City Plant, the DOE Savannah River Site, and the Waste Control Specialists, LLC, site. 

Within a smaller 3.2-kilometer (2-mile) radius, minority and low-income populations are now 

present at the Hawthorne Army Depot, in addition to those previously identified at the DOE 

Kansas City Plant. However, environmental justice analyses indicate that no disproportionately 

high and adverse effects on minority or low-income populations would be expected at any of the 

candidate sites due to construction or operations of a mercury storage facility(ies). 

S.5.2 Cumulative Impacts 

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

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

to cumulative impacts include onsite and offsite projects conducted by government agencies, businesses, 

or individuals that are within the ROIs of the actions considered in this draft SEIS. For the WIPP 

Vicinity reference locations, the ROIs used in the cumulative impacts analysis were generally assumed to 

be within a 16-kilometer (10-mile) radius of the locations. This radius was selected because any adverse 

impacts from normal operations and facility(ies) accidents would be limited to a distance significantly 

less than 16 kilometers (10 miles). 

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

facility(ies) range from none, to negligible, to minor. Those resource areas that were predicted to be 

impacted in a minor way were evaluated for their potential to contribute to cumulative impacts within the 

ROI; specifically, this draft SEIS analysis includes an evaluation of land use, air quality, infrastructure, 

and ecological resources. It was determined that the potential contribution to cumulative impacts on those 

resource areas evaluated would be negligible, as summarized in Table S–1 and addressed in greater detail 

in Chapter 2, Section 2.6.2, and Chapter 4, Section 4.4, of this draft SEIS. These findings are consistent 

with the level of cumulative impacts projected for the seven candidate storage locations evaluated in the 

January 2011 Mercury Storage EIS (see Chapter 2, Section 2.7.2, and Chapter 4, Section 4.11, of the 

January 2011 Mercury Storage EIS). 

For the WIPP Vicinity reference locations, the only major projects ongoing or planned within the 

16-kilometer (10-mile) ROI are the operations of WIPP for disposal of defense-generated transuranic 

wastes, the proposed greater-than-Class C (GTCC) waste disposal facility, which could be located in 

close proximity to WIPP, underground potash mining, and the operation of production oil wells. 

Depending on the type of facility selected (i.e., borehole, trench, or vault), the GTCC waste disposal 

facility could require up to 44 hectares (110 acres). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

S–14

Table S–1. Summary of Cumulative Impacts Assessment 

Alternative Resource Area Cumulative Impacts

Contribution of 

Proposed Action to 

Cumulative Impacts

WIPP Vicinity 

Reference Locations 

(Sections 10, 20, and 35)

Land Use Rural area; limited development 

expected within the ROI. GTCC 

waste disposal facility could require 

up to 44 hectares (110 acres) if 

WIPP vicinity is selected; one of the 

locations being considered is WIPP 

Vicinity Section 35. A mercury 

storage facility and GTCC waste 

disposal facility could be located 

within the 260-hectare (640-acre) 

area that comprises Section 35 

without interference with operations

or compromising the safety and 

security of these facilities. Also 

present within the ROI are a number 

of oil wells and underground potash 

mines located in the vicinity of 

WIPP, including an existing potash 

mine lease on WIPP Vicinity 

Section 10 and one oil well in WIPP 

Vicinity Section 35. No substantial 

cumulative impacts on land use.

Negligible

Air Quality No exceedance of air quality 

standards.

Negligible

Infrastructure No substantial cumulative impacts 

on regional power consumption or 

impact on existing capacities. A 

maximum of 79 shipments would be 

made to the proposed mercury 

storage facility during the peak year 

of operations and is not expected to 

appreciably increase demands on 

transportation systems near the 

WIPP Vicinity reference locations.

Negligible

Ecological 

Resources

No substantial cumulative impacts 

on terrestrial resources or loss of 

habitat due to disturbance of land 

(see Land Use above).

Negligible

Key: GTCC=greater-than-Class C; ROI=region of influence; WIPP=Waste Isolation Pilot Plant. 

S.5.3 The Preferred Alternative 

In the January 2011 Mercury Storage EIS, DOE identified the Waste Control Specialists, LLC, site near 

Andrews, Texas, as the Preferred Alternative for the long-term management and storage of mercury. At 

this time, DOE has not changed the Preferred Alternative. Based on analysis from this draft SEIS and 

public comment, the Preferred Alternative may or may not change in the final SEIS. DOE will issue a 

ROD no sooner than 30 days after publication of the EPA Notice of Availability for the Final Mercury 

Storage SEIS in the Federal Register. The selection of a site will be based on the January 2011 Mercury 

Storage EIS, this Mercury Storage SEIS, and other appropriate factors and will be announced in a ROD in 

the Federal Register. 
Summary and Guide for Stakeholders 

S–15

S.6 PUBLIC INVOLVEMENT 

On June 5, 2012, DOE published the “Notice of Intent to Prepare a 

Supplemental Environmental Impact Statement for the Long-Term 

Management and Storage of Elemental Mercury” in the Federal Register

(77 FR 33204). Publication of the Notice of Intent initiated a 30-day 

public scoping period. During this time, DOE solicited comments from 

Federal, state, and local agencies; stakeholders; tribal nation 

representatives; and the general public to assist in defining the scope of 

this draft SEIS. 

S.6.1 Public Scoping Meetings 

DOE hosted two scoping meetings to obtain public comments on the 

proposed scope of this draft SEIS: 

June 26, 2012, in Carlsbad, New Mexico 

June 28, 2012, in Albuquerque, New Mexico 

Approximately 65 people attended these public scoping meetings at which 

DOE provided information on the Mercury Export Ban Act of 2008, the 

January 2011 Mercury Storage EIS, and the scope of this draft SEIS. 

S.6.2 Public Scoping Comments 

As discussed in Chapter 1, Section 1.6, of this draft SEIS, DOE received 

92 comment documents (emails, faxes, letters, and transcripts of oral comments) during the scoping 

period, including some comments that were received after the scoping period ended. DOE considered all 

oral and written public comments in refining the scope of this draft SEIS. 

Comments received during the public scoping period focused primarily on opposition to or support for 

including locations in the WIPP vicinity among the candidate sites, and environmental, health, and safety 

concerns associated with transporting and storing mercury. 

S.6.3 How Can I Participate in This Process? 

DOE is soliciting comments on this draft SEIS during the 45-day public comment period, during which 

public hearings will be held to provide interested members of the public with opportunities to learn more 

about the content of this draft SEIS, hear DOE representatives present a summary of the results of the 

draft SEIS analyses, ask clarifying questions, and provide oral and written comments. The dates, times, 

and locations of public hearings will be published in DOE’s Notice of Availability in the Federal Register

for this draft SEIS. The project website (http://www.mercurystorageeis.com) also informs the public 

about the January 2011 Mercury Storage EIS, the preparation of the Final Mercury Storage SEIS, public 

hearings, comment submission, and other pertinent information. 

To submit written comments or request more information, contact: 

David Levenstein, Document Manager 

Office of Environmental Compliance (EM–11) 

U.S. Department of Energy 

Post Office Box 2612 

Germantown, MD 20874 

Website: http://www.mercurystorageeis.com 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

S–16

S.6.4 Watch for the Final Mercury Storage SEIS

When the final SEIS is published, its availability will be announced in EPA’s Federal Register Notice of 

Availability, in local newspapers, and via U.S. mail. The Final Mercury Storage SEIS will be sent to 

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

(http://www.mercurystorageeis.com), on DOE’s NEPA website (http://energy.gov/nepa), and for review 

in public reading rooms. Oral and written comments received during the public comment period will be 

considered equally in preparing the final SEIS, and DOE responses will be presented in a comment 

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

DOE will announce a decision regarding future actions in a ROD to be published in the Federal Register 

no sooner than 30 days after EPA’s Notice of Availability for the final SEIS is published. The ROD will 

describe the alternative selected for implementation and explain how environmental impacts will be 

avoided, minimized, or mitigated. 

S.6.5 Visit a Reading Room 

Review copies of this Draft Mercury Storage SEIS and other pertinent documents are available at the 

following reading rooms. 

Colorado 

Mesa County Library 

530 Grand Avenue 

Grand Junction, CO 81502-5019 

(970) 243-4442 

U.S. Department of Energy 

Office of Legacy Management 

2597 Legacy Way 

Grand Junction, CO 81503 

(970) 248-6089 

District of Columbia 

U.S. Department of Energy 

Freedom of Information Reading Room 

1000 Independence Avenue, SW 

Room 1G-033 

Washington, DC 20585 

(202) 586-5955 

Georgia 

Augusta State University 

Reese Library 

2500 Walton Way 

Augusta, GA 30904 

(706) 737-1745 

Savannah State University 

Asa H. Gordon Library 

2200 Tompkins Road 

Savannah, GA 31404 

(912) 356-2183 

Idaho 

U.S. Department of Energy 

Public Reading Room 

1776 Science Center Drive 

Idaho Falls, ID 83402 

(208) 526-0833 
Summary and Guide for Stakeholders

S–17

Missouri

Mid-Continent Public Library

Blue Ridge Branch

9253 Blue Ridge Boulevard

Kansas City, MO 64138

(816) 761-3382

Nevada

Mineral County Library

First & “A” Street

Hawthorne, NV 89415

(775) 945-2778

New Mexico

U.S. Department of Energy

Government Information Department

Zimmerman Library/University of New Mexico

1 University of New Mexico

Albuquerque, NM 87131

(505) 277-7180

U.S. Department of Energy

Carlsbad Field Office

WIPP Information Center

4021 National Parks Highway

Carlsbad, NM 88220

(575) 234-7348 

Eunice Public Library

1039 10th Street

Eunice, NM 88231

(575) 394-2336

Oregon

Portland State University

Government Information

Branford Price Millar Library

1875 SW Park Avenue

Portland, OR 97201

(503) 725-5874

South Carolina

University of South Carolina–Aiken

Gregg-Graniteville Library

471 University Parkway

Aiken, SC 29801

(803) 641-3320

South Carolina State Library

1500 Senate Street

Columbia, SC 29211

(803) 734-8026

Texas

Andrews County Library

109 NW 1st Street

Andrews, TX 79714

(432) 523-9819

Washington

U.S. Department of Energy

Public Reading Room

Consolidated Information Center

2770 University Drive

Room 101L

Richland, WA 99352

(509) 372-7443

University of Washington

Suzzallo-Allen Library

Government Publications Division

Seattle, WA 98195

(206) 543-1937

Gonzaga University

Foley Center Library

101-L East 502 Boone

Spokane, WA 99258

(509) 313-5931

CHAPTER 1

INTRODUCTION AND

PURPOSE AND NEED FOR AGENCY ACTION

1–1

CHAPTER 1 

INTRODUCTION AND PURPOSE AND NEED 

FOR AGENCY ACTION 

The U.S. Department of Energy (DOE) is required to develop a capability for the safe and secure long-term 

management and storage of elemental mercury pursuant to the Mercury Export Ban Act of 2008 (P.L. 110-414). 

Accordingly, DOE will identify or construct an appropriate facility(ies) to host this capability. DOE’s proposed 

action is to select a suitable location for the long-term management and storage of elemental mercury generated 

within the United States. DOE has prepared this Draft Long-Term Management and Storage of Elemental Mercury 

Supplemental Environmental Impact Statement (Draft Mercury Storage SEIS) (DOE/EIS-0423-S1) in accordance 

with implementing regulations under the National Environmental Policy Act (40 CFR 1500–1508; 10 CFR 1021). 

To date, DOE has not issued a Record of Decision pursuant to the Long-Term Management and Storage of 

Elemental Mercury Environmental Impact Statement (Mercury Storage EIS) issued in January 2011. Prior to 

making a final decision, DOE is considering three additional locations that are reasonable to site a storage 

facility(ies) for elemental mercury. Relevant information and data from the January 2011 Mercury Storage EIS that 

remain unchanged have been reproduced and presented in this draft SEIS for the convenience of the reader. The 

U.S. Environmental Protection Agency and the U.S. Bureau of Land Management are cooperating agencies in the 

preparation of this Draft Mercury Storage SEIS.

1.1 INTRODUCTION 

What Is Elemental Mercury?

Why is it of Concern?

Elemental mercury is a dense, naturally occurring metal 

that is liquid at room temperature. Mercury is a globally 

deposited pollutant, affecting water bodies near industrial 

sources (e.g., the Great Lakes) and remote areas (e.g., the 

Arctic Circle). Mercury is found in the environment as 

elemental mercury (e.g., elemental mercury vapor [Hg0], 

inorganic mercury compounds (e.g., mercuric chloride [HgCl2] 

and mercuric sulfide [HgS]); and organic mercury compounds 

(e.g., methylmercury [CH3Hg]). 

Mercury and its compounds are persistent, bioaccumulative, 

and toxic. The toxic effects of mercury depend on its 

chemical form and the route of exposure. Methylmercury, a 

mercury compound that is generally not used commercially or 

stored, is the most toxic form. It can affect the immune 

system; alter genetic systems; and damage the nervous 

system, including coordination and the senses of touch, taste, 

and sight. Methylmercury can be particularly damaging to 

developing embryos. Exposure to methylmercury is usually 

by ingestion; it is absorbed more readily than other forms of 

mercury. Less toxic than methylmercury, elemental mercury 

(Hg0) vapors can cause tremors, gingivitis, and excitability 

when inhaled over a long period of time. If elemental mercury 

is ingested, it is absorbed relatively slowly and can pass 

through the digestive system without causing damage 

(USGS 2000).

It is estimated that since the 19th century, the total amount of 

mercury available in the environment has increased by a 

factor of two to five above pre-industrial levels. As the 

quantity of available mercury in the environment has 

increased, so have the risks of neurological and reproductive 

problems for humans and wildlife. These increases in risk 

make mercury a pollutant of environmental concern in the 

United States and throughout the world (EPA 2000:1).

Mercury is a naturally occurring element. 

Mercury enters the environment through 

natural processes such as volcanoes and 

wildfires. Human activities that release 

mercury to the environment include fuel 

burning, incineration, metal smelting, use of 

mercury in industrial processes, mining, 

waste disposal, and production of 

commercial products containing mercury. 

Sometimes called “quicksilver,” liquid 

mercury has been used in manufacturing 

processes because it conducts electricity, 

reacts to temperature changes, and alloys 

with many other metals. Examples of 

products that historically contained or 

currently contain mercury include batteries, 

paint, thermometers, thermostats, blood 

pressure monitors, switches for automobile 

lighting, fluorescent lights, and dental 

fillings. 

The mercury emitted from human activities 

is primarily in its elemental or inorganic 

forms. This inorganic form of mercury, 

when bound to airborne particles (Hgp) or in 

its gaseous divalent form (Hg+2), is readily 

removed from the atmosphere by dry 

deposition (settling) onto land surfaces and 

wet deposition (precipitation), including 

deposition in water bodies. Most of the 

mercury in water, soil, sediment, plants, and 

animals is in the form of inorganic mercury 

salts (e.g., mercuric chloride) and organic 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

1–2

mercury (e.g., methylmercury). As it cycles through the environment, mercury undergoes a series of 

chemical and physical transformations (EPA 1997:2-2, 2000:1). Figure 1–1 provides a simplified 

diagram of how mercury moves through the environment. 

Figure 1–1. The Mercury Cycle 

1.2 PURPOSE AND NEED FOR AGENCY ACTION 

The Mercury Export Ban Act of 2008 (P.L. 110-414), hereafter referred to as “the Act,” prohibits, as of 

October 14, 2008, any Federal agency from conveying, selling, or distributing to any other Federal 

agency, any state or local government agency, or any private individual or entity any elemental mercury1

under the control or jurisdiction of the Federal agency (with certain limited exceptions, as described in 

the Act). A copy of the Act is included in Appendix A. The Act also prohibits the export of mercury 

from the United States effective January 1, 2013 (subject to certain essential-use exemptions). The 

United States is a net exporter of mercury, exporting over 600 metric tons (660 tons) of mercury between 

2004 and 2007 (USGS 2009). Therefore, banning the export of mercury from the United States is 

expected to result in surplus inventories of mercury. 

Section 5 of the Act, “Long-Term Storage,” directs the U.S. Department of Energy (DOE) to designate a 

DOE facility(ies) for the long-term management and storage of mercury generated within the United 

States.2

 DOE needs to provide such a facility(ies) capable of managing a mercury inventory estimated to 

 

1 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this supplemental 

environmental impact statement. 

2

 DOE has interpreted Section 5 of the Act to authorize DOE to designate an existing and/or new storage facility(ies) at property 

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

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

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

Federal agency would afford DOE the same level of responsibility and control over stored mercury as a facility owned by 

DOE. 
Introduction and Purpose and Need for Agency Action 

1–3

range up to 10,000 metric tons (11,000 tons) based on a 40-year period of analysis, as described in the 

next section. The Act specifies that the new DOE mercury storage facility(ies) shall not include the 

Y–12 National Security Complex (Y–12) or any other portion or facility of the Oak Ridge Reservation in 

Oak Ridge, Tennessee. 

Section 5 of the Act authorizes DOE to assess and collect a fee at the time of delivery of mercury to the 

DOE storage facility(ies) to cover certain costs of long-term management and storage. These costs 

include operations and maintenance, security, monitoring, reporting, personnel, administration, 

inspections, training, fire suppression, closure, and other costs required for compliance with applicable 

laws; such costs shall not include costs associated with land acquisition or permitting. A fee structure has 

not been determined; however, it is expected that it would be competitive with the costs of other mercury 

storage options. In addition, the generators of the mercury will be responsible for the costs of shipping 

mercury to the DOE storage facility(ies). Therefore, much of the costs of mercury storage will be borne 

by the generators of mercury. The incentive for generators to send their mercury to the DOE facility(ies) 

is that DOE would take ownership of the mercury and indemnify the generator from future liability, in 

accordance with Section 5(e) of the Act. 

1.3 PROPOSED ACTION 

As stated in the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental 

Impact Statement (Mercury Storage EIS), DOE proposes to construct one or more new facilities and/or 

select one or more existing facilities (including modification as needed) for the long-term management 

and storage of mercury, as mandated by Section 5 of the Act. Any such facility(ies) must comply with 

applicable requirements of Section 5 of the Act, “Management Standards for a Facility,” including the 

requirements of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery 

Act (RCRA) (42 U.S.C. 6901 et seq.) and other permitting requirements. 

1.3.1 Estimated Mercury Inventory 

Chapter 1, Section 1.3.1, of the January 2011 Mercury Storage EIS provides information on the inventory 

developed for analysis and is hereby incorporated into this Draft Long-Term Management and Storage of 

Elemental Mercury Supplemental Environmental Impact Statement (Draft Mercury Storage SEIS). The 

same inventory is used in this draft SEIS and is shown in Table 1–1. 

The Act does not specify how long the DOE mercury storage facility(ies) would need to be operated. For 

purposes of analysis in the January 2011 Mercury Storage EIS and this draft SEIS, DOE assumed the 

mercury storage facility(ies) would operate over a 40-year timeframe. For purposes of analysis, the 

January 2011 Mercury Storage EIS assumes a 40-year operational period with the first year starting in 

2013 and the fortieth year, in 2052. An operational start date is not known at this time; however, the 

period of analysis remains 40 years. For example, if the mercury storage facility(ies) were to start 

operations in 2014, the last year of operations would likewise shift to 2053, and so forth. This 

corresponds to the 40-year planning projection for receipt into storage of up to 10,000 metric tons 

(11,000 tons) of mercury. A 40-year period of analysis is consistent with the timeframe used in previous 

analyses by the Defense Logistics Agency (DLA 2004) and the U.S. Environmental Protection 

Agency (EPA) (EPA 2007). These are estimates with a degree of uncertainty; therefore, it is possible that 

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

shorter than 40 years. Additional National Environmental Policy Act (NEPA) documentation would be 

required to expand the facility(ies) to accept more than 10,000 metric tons of mercury or extend its 

operations beyond the 40-year period of analysis. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

1–4

Table 1–1. Anticipated Mercury Inventory

Source

Years Sent

to Storagea

Quantity

(metric tons)b

DOE Y–12 National Security Complex in Oak Ridge, Tennesseec 1st – 2nd 1,200

Closure of chlor-alkali plants or conversion to non-mercury-cell technology 1st – 7th 1,100

Waste reclamation and recycling facilities 1st – 40th 2,500

Byproduct of gold mining 1st – 40th 3,700–4,900

Total 8,500–9,700

a For purposes of analysis, the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact 

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

Statement assume a 40-year operational period. It was assumed that the mercury from the Y–12 National Security Complex 

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

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

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

b Rounded to two significant figures.

c Depending on ongoing DOE mission needs, the entire inventory of Y–12 National Security Complex mercury or a portion of 

this inventory could be retained in storage at Y–12 National Security Complex. It is also possible that other governmental 

sources of elemental mercury could be transferred to the storage facility(ies).

Note: To convert metric tons to tons, multiply by 1.1023.

Key: DOE=U.S. Department of Energy.

There is considerable uncertainty regarding the 10,000-metric-ton (11,000-ton) estimate of mercury that 

could be sent to DOE for storage. Estimates of mercury generated from gold mining are dependent on the 

amount of gold mining conducted. Mercury from gold mining could decrease as existing gold deposits 

are depleted or could increase if additional deposits are discovered. The amount of gold mined is also 

dependent on the price of gold. The quantity of mercury from waste reclamation and recycling facilities 

is dependent on the volume of waste and recyclable materials processed and is likely to decrease as 

programs to collect mercury-containing thermometers, thermostats, switches, and natural gas metering 

devices are completed. In addition, chlor-alkali plants may close or convert their mercury-cell processes 

before 2013.

The Act prohibits the export of elemental mercury from the United States beginning in 2013. The Act 

does not ban the export of mercury compounds. Recognizing the potential for exported mercury 

compounds to be processed into elemental mercury, Congress directed EPA to publish, no later than 

1 year after the date of enactment of the Act, a report on “mercuric chloride, mercurous chloride or 

calomel, mercuric oxide, and other mercury compounds, if any, that may currently be used in significant 

quantities in products or processes.” EPA submitted a report entitled Potential Export of Mercury 

Compounds from the United States for Conversion to Elemental Mercury to Congress in October 2009. 

The report provides information on sources, amounts, and uses of mercury compounds; assesses the 

potential for these compounds to be processed into elemental mercury after export; and provides 

information for Congress to consider in determining whether to extend the Act’s mercury export 

prohibition to include one or more of these mercury compounds. The report concludes that one mercury 

compound—mercury(I) chloride (also known as mercurous chloride or calomel)—is likely to be exported 

and processed into elemental mercury after export. Mercury(I) chloride is currently produced in 

significant quantities from pollution-control equipment at U.S. gold mines. The report also finds that 

three other mercury compounds—mercury(II) oxide, mercury(II) sulfate, and mercury(II) nitrate—could 

possibly be exported and processed into elemental mercury after export (EPA 2009). If certain mercury 

compounds are eventually added to the mercury export ban, additional environmental review may be 

necessary. Mercury must meet the acceptance criteria for the DOE storage facility(ies) and must be at 

least 99.5 percent pure elemental mercury (DOE 2009a).
Introduction and Purpose and Need for Agency Action 

1–5

1.4 DECISIONS TO BE MADE 

DOE intends to decide (1) where to locate the mercury storage facility(ies), and (2) whether to use 

existing buildings, new buildings, or a combination of existing and new buildings. 

DOE’s objectives for the long-term management and storage of mercury are important to DOE, EPA, and 

the public. They are, in part, as follows: 

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

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

Comply with applicable Federal, state, and local statutes and regulations. 

DOE will make a decision on the proposed action no sooner than 30 days after publication of EPA’s 

Notice of Availability of the Final Mercury Storage SEIS in the Federal Register. DOE will announce its 

decision in a Record of Decision published in the Federal Register. 

1.5 SCOPE OF THIS SEIS 

In the January 2011 Mercury Storage EIS, DOE analyzed the following alternative locations for hosting 

the mercury storage facility(ies). 

Grand Junction Disposal Site near Grand Junction, Colorado 

Hanford Site in the 200-West Area near Richland, Washington 

Hawthorne Army Depot in the Central Magazine Area near Hawthorne, Nevada 

Idaho National Laboratory’s Idaho Nuclear Technology and Engineering Center or Radioactive 

Waste Management Complex near Idaho Falls, Idaho 

Bannister Federal Complex’s Kansas City Plant in Kansas City, Missouri 

Savannah River Site E Area near Aiken, South Carolina 

Waste Control Specialists, LLC, site near Andrews, Texas 

The analyses presented in the January 2011 Mercury Storage EIS remain valid and are incorporated into 

this draft SEIS with two exceptions: (1) the occupational and public health and safety analysis; and (2) the 

socioeconomics and environmental justice analysis. This draft SEIS includes updates to the occupational 

and public health and safety analysis resulting from changes to the definition of severity levels 

(i.e., magnitude of impacts) for acute-inhalation exposures to the public under certain accident scenarios. 

This draft SEIS also includes updates to the socioeconomics and environmental justice analyses to 

incorporate 2010 decennial census information that was not available at the time the January 2011 

Mercury Storage EIS was published. The updates to the analyses are presented in Appendix B and 

Appendix E of this draft SEIS. Relevant information and data from the January 2011 Mercury 

Storage EIS that remain unchanged have been reproduced and presented in this draft SEIS for the 

convenience of the reader. 

In this draft SEIS, DOE analyzes three additional locations in the vicinity of the Waste Isolation Pilot 

Plant (WIPP) near Carlsbad, New Mexico. WIPP is a deep geologic repository for the disposal of 

radioactive transuranic (TRU) waste generated through defense-related activities. Chapter 3, “Affected 

Environment,” provides a description of this area.

One of the locations addressed in this draft SEIS lies within the boundary stipulated for WIPP under the 

WIPP Land Withdrawal Act, while the other two locations are outside this boundary but near WIPP to 

take advantage of existing infrastructure used for WIPP such as roads and electricity. Chapter 2, 

Figure 2–6, shows the section, township, and range of these parcels of land. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

1–6

1.5.1 Candidate Site Identification

Chapter 1, Section 1.5.1, of the January 2011 Mercury Storage EIS provides information on the screening 

approach used to identify the sites included in the environmental impact statement (EIS). The candidate 

sites were included in the EIS analyses if they met most of the criteria listed below. The same approach 

applies to the identification of the locations analyzed in this draft SEIS.

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

not interfere with future mission compatibility.

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

capability and flexibility for operational expansion, if necessary.

The facility(ies) is, or will be, capable of complying with RCRA permitting requirements 

(see Chapter 5, Sections 5.2.4 and 5.3, of the January 2011 Mercury Storage EIS).

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

that would support mercury loadings.

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

new construction would be feasible, as may be required.

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

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

Recognizing that existing buildings are not available at the three WIPP locations addressed in this draft 

SEIS, DOE evaluated construction and operation of a new facility(ies) that would meet RCRA 

requirements. Because the mercury would of necessity be transported to the designated facility(ies), DOE 

included transportation analyses in the scope of this draft SEIS. These three aspects of this draft SEIS

follow the same approach as that used in the January 2011 Mercury Storage EIS and are introduced in the 

sections below.

1.5.2 Construction

Construction impacts are those related to land disturbance, water and air resources, employment, and 

resource use. Chapter 2, Section 2.2.2, and Appendix C, Section C.2.3, describe construction activities. 

Chapter 4, Sections 4.2.1, 4.2.3, 4.2.4, 4.2.11, and 4.6, describe the environmental impacts of the 

construction activities.

1.5.3 Operations

Operational impacts include those related to water and air resources, human health effects, including 

accidents, and resource use. Chapter 2, Section 2.2.3, and Appendix C, Section C.2.4, describe 

operational activities. Chapter 4, Sections 4.2.3, 4.2.4, 4.2.9, and 4.6 describe the environmental impacts 

of the operational activities.

1.5.4 Transportation

Transportation impacts include those related to air emissions, human health, and ecological risk. DOE 

analyzed the transport of mercury from potential source locations to the designated DOE mercury storage 

facility(ies), including potential transport of DOE mercury from existing storage at Y–12 in Oak Ridge, 
Introduction and Purpose and Need for Agency Action 

1–7

Tennessee. DOE evaluated impacts for the transportation of mercury by truck and rail, including 

transportation accidents, in Chapter 4, Section 4.2.9.1.3. 

1.5.5 Closure of Mercury Storage Facility(ies) 

For a complete life-cycle analysis, DOE considered the possibility that the facility(ies) could be no longer 

needed. If the mercury storage facility(ies) is no longer needed at some point in the future, DOE would 

close it, as described in Chapter 4, Section 4.3. More detailed analysis of closure activity impacts is not 

possible at this time because DOE has not yet developed plans for future use or closure of this building(s). 

Reuse or closure plans would be subject to additional environmental analysis, as appropriate. 

1.6 PUBLIC INVOLVEMENT IN DEVELOPING THE SCOPE OF THIS SEIS 

As a preliminary step in the development of an EIS (or SEIS), regulations established by the Council on 

Environmental Quality (40 CFR 1501.7) and DOE require “an early and open process for determining 

the scope of issues to be addressed and for identifying the significant issues related to a Proposed Action.” 

The purpose of this scoping process is (1) to inform the public about a proposed action and the 

alternatives being considered and (2) to identify and clarify issues relevant to the EIS by soliciting public 

comments. 

On June 5, 2012, DOE published the “Notice of Intent to Prepare a Supplemental Environmental Impact 

Statement for the Long-Term Management and Storage of Elemental Mercury” in the Federal Register

(77 FR 33204) (see Appendix A). Publication of the Notice of Intent initiated a 30-day public scoping 

period. During this time, DOE solicited comments from Federal, state, and local agencies; stakeholders; 

tribal nation representatives; and the general public to assist in defining the scope of this draft SEIS. 

DOE hosted two meetings to obtain public comments on the proposed scope of this draft SEIS. The 

public scoping meetings were held on June 26, 2012, in Carlsbad, New Mexico, and June 28, 2012, in 

Albuquerque, New Mexico. 

A total of approximately 65 people attended these meetings. Each meeting began with a short DOE 

presentation on the NEPA process and the proposed scope of this draft SEIS. Following the presentation, 

attendees were invited to provide comments. Oral comments were recorded by a court reporter; written 

comments were also accepted. In addition, the public was provided with the opportunity to discuss issues 

directly with DOE management and technical specialists who staffed an exhibit area. 

For those individuals who could not attend one of the public scoping meetings, DOE 

provided other methods to submit comments: (1) the mercury storage project website 

(http://www.mercurystorageeis.com), (2) email to David.Levenstein@em.doe.gov, and (3) U.S. mail to 

Mr. David Levenstein, Document Manager, Office of Environmental Compliance (EM–11), 

U.S. Department of Energy, Post Office Box 2612, Germantown, Maryland 20874. 

DOE received 92 comment documents during the scoping period. A total of 19 oral comments were 

recorded in the meeting transcripts. DOE considered all public comments equally in refining the scope of 

this draft SEIS; the comments and DOE’s responses are summarized below. 

1.6.1 Summary of Major Public Scoping Comments and DOE’s Responses 

Candidate Sites in the WIPP Vicinity 

Comments: Commentors expressed concern about New Mexico becoming a “dumping ground,” and 

opposition to expansion of the WIPP mission. Several commentors stated that mercury storage would do 

nothing to clean up existing mercury contamination in the region and would not reduce mercury levels in 

New Mexico. Other commentors pointed out that there are legal restrictions under the WIPP Land 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

1–8

Withdrawal Act limiting WIPP to the disposal of TRU waste from defense activities. Opposition to 

locating a disposal facility for greater-than-Class C (GTCC) and DOE GTCC-like waste in the WIPP 

vicinity was included in a number of comments about the scope of the SEIS. 

Other commentors expressed support for including the locations in the WIPP vicinity among the 

candidate sites for long-term management and storage of mercury. Some commentors noted that the Act 

created a real need for the long-term storage facility. Other commentors stated that the mercury storage 

facility would not interfere with the mission of WIPP. A few commentors noted that there is an existing 

potash mining lease associated with one of the proposed locations (i.e., WIPP Vicinity Section 10), which 

could potentially interfere with siting a mercury storage facility at this location. 

Response: This draft SEIS is being prepared in response to a specific requirement that DOE identify, 

construct, and operate a facility(ies) for mercury storage as opposed to disposal. Mercury cleanup is 

addressed under other statutes and regulations. The Act considers the Nation’s best interests in removing 

excess mercury in the United States from global commerce by placing it in a safe and secure facility(ies). 

DOE acknowledges that new legislation may be required for DOE to construct and operate a facility for 

long-term management and storage of mercury at any of the WIPP Vicinity reference locations. In the 

Notice of Intent published on June 5, 2012, DOE identified two candidate locations that would be 

evaluated in an SEIS for the long-term management and storage of elemental mercury. After 

consideration of scoping comments received, DOE decided to evaluate a third candidate location. The 

third location is WIPP Vicinity Section 35, located adjacent to and outside of the WIPP land withdrawal 

boundary approximately 5.6 kilometers (3.5 miles) southeast of the WIPP facility. 

Environmental Considerations 

Comments: Commentors expressed concern regarding safety aspects of transporting the mercury to the 

storage facility, the potential for spills, and potential mercury toxicity to downstream surface-water 

locations. Commentors recognized that DOE has established an excellent safety record regarding 

transportation to and disposal of TRU waste at WIPP, and that job creation in the Carlsbad area would 

benefit the community. DOE was encouraged to include information on habitat areas and threatened and 

endangered species in Eddy County. Commentors expressed concern about potential environmental 

justice issues and requested that an adequate region of influence be included in the SEIS. One commentor 

asked that the SEIS define what “long-term” management means and include consideration of disposal 

in salt. 

Response: As discussed in Chapter 4, Section 4.2.9.1.3, DOE evaluates potential health and safety 

impacts of transportation in this draft SEIS, including accidents and routine operations. DOE agrees that 

WIPP has established an excellent transportation and onsite safety record. The scope of analysis for this 

draft SEIS includes land use and visual resources; geology, soils, and geologic hazards; water resources; 

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

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

socioeconomics; and environmental justice. The region of influence for environmental justice analysis 

was defined taking into consideration the distance from the candidate sites where significant impacts 

would occur. The SEIS scope does not include analysis related to final disposal of mercury; long-term 

management and storage of mercury has been defined as 40 years for purposes of analysis, but may be 

indefinite until a final disposal pathway can be identified that complies with all disposal regulations. 

1.7 OTHER RELEVANT NATIONAL ENVIRONMENTAL POLICY ACT REVIEWS 

The January 2011 Mercury Storage EIS contains descriptions of relevant NEPA documents, including 

NEPA documents pertaining to the candidate sites analyzed in that EIS. Those descriptions are 

incorporated in this draft SEIS, and the reader is referred to Chapter 1, Section 1.9, of the January 2011 

Mercury Storage EIS. The following additional documents are relevant to this draft SEIS. 
Introduction and Purpose and Need for Agency Action

1–9

1.7.1 Final Environmental Impact Statement for the Waste Isolation Pilot Plant and 

Two Associated SEISs

In the Final Environmental Impact Statement for the Waste Isolation Pilot Plant (DOE/EIS-0026) 

(DOE 1980) and two SEISs (DOE/EIS-0026-S-1 and DOE/EIS-0026-S-2) issued in 1990 and 1997 

(DOE 1990, 1997), DOE analyzed the development, operation, and transportation activities associated 

with WIPP, a mined repository for TRU waste near Carlsbad, New Mexico. In the 1997 Waste Isolation 

Pilot Plant Disposal Phase Final Supplemental Environmental Impact Statement (WIPP SEIS II), DOE 

analyzed the impacts from management and operation of WIPP to support disposal of TRU waste. DOE 

determined that the operation of WIPP during the period when it would be accepting waste shipments 

from around the DOE complex could be accomplished safely and that WIPP would not be expected to 

result in any long-term (over 10,000 years) impacts on human health as long as the repository was not 

disturbed after decommissioning (DOE 1997). In the Record of Decision associated with the 

1997 WIPP SEIS II (63 FR 3624), DOE announced its decision that WIPP would be developed and begin 

accepting TRU waste for disposal. Since then, DOE published eight supplement analyses of the 

1997 WIPP SEIS II. The supplement analyses indicated that the identified and projected impacts for all 

resource areas, including cumulative impacts, were not substantially changed from those previously 

evaluated, nor did they represent significant new circumstances or information relative to environmental 

concerns (DOE 2009b).

1.7.2 Draft Environmental Impact Statement for the Disposal of 

Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and

GTCC-Like Waste

DOE prepared the Draft Environmental Impact Statement for the Disposal of Greater-Than-Class C 

(GTCC) Low-Level Radioactive Waste and GTCC-Like Waste (Draft GTCC EIS) (DOE/EIS-0375) 

(DOE 2011) to evaluate the potential environmental impacts associated with the proposed development, 

operation, and long-term management of a disposal facility or facilities for GTCC low-level radioactive 

waste (LLW) and DOE GTCC-like waste. GTCC LLW has radionuclide concentrations exceeding the 

limits for Class C LLW established by the U.S. Nuclear Regulatory Commission (NRC). GTCC LLW is

generated by activities licensed by the NRC or Agreement States and cannot be disposed of in currently 

licensed commercial LLW disposal facilities. DOE prepared this EIS in response to its obligations set 

forth in Section 631 of the Energy Policy Act of 2005.

The NRC LLW classification system does not apply to radioactive wastes generated or owned by DOE 

and disposed of in DOE facilities. However, DOE owns or generates LLW and non-defense-generated 

TRU radioactive waste, which have characteristics similar to those of GTCC LLW and for which there 

may be no path for disposal. DOE included these wastes for evaluation in the Draft GTCC EIS because 

similar approaches may be used to dispose of both types of radioactive waste. For the purposes of the 

Draft GTCC EIS, DOE referred to this waste as “GTCC-like waste.” The total volume of GTCC LLW 

and DOE GTCC-like waste addressed in the Draft GTCC EIS is about 12,000 cubic meters 

(420,000 cubic feet), and it contains about 160 million curies of radioactivity. About three-fourths of this 

volume is GTCC LLW, with DOE GTCC-like waste making up the remaining one-fourth of the volume. 

DOE evaluated potential disposal locations at the Hanford Site in Washington; Idaho National 

Laboratory; Los Alamos National Laboratory in New Mexico; the Nevada National Security Site; the 

Savannah River Site in South Carolina; WIPP, including a location within and a location outside the land 

withdrawal boundary (Sections 27 and 35) in New Mexico; and generic commercial sites assumed to be 

located throughout the United States in the four NRC regions. DOE evaluated WIPP deep geologic 

repository disposal and disposal in intermediate-depth boreholes, near-surface trenches, and aboveground 

vaults, as appropriate to each site.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

1–10

1.7.3 Final Site-Wide Environmental Impact Statement for the Y–12 National 

Security Complex

As one of the National Nuclear Security Administration’s major production facilities, Y–12 is the primary 

site for enriched uranium processing and storage, and one of the primary manufacturing facilities for 

maintaining the U.S. nuclear weapons stockpile. Y–12 supplies nuclear weapons components, dismantles 

weapons components, safely and securely stores and manages special nuclear material, supplies special 

nuclear material for use in naval and research reactors, and dispositions surplus materials. The Final 

Site-Wide Environmental Impact Statement for the Y–12 National Security Complex (DOE/EIS-0387) 

(NNSA 2011) analyzes the potential environmental impacts of reasonable alternatives for ongoing and 

foreseeable future operations, facilities, and activities at Y–12. This EIS is relevant because it includes 

management of the 1,200 metric tons (1,300 tons) of mercury currently stored at Y–12. 

1.8 ORGANIZATION OF THIS MERCURY STORAGE SEIS

This draft SEIS consists of one volume, which includes the Summary and Guide for Stakeholders. The 

chapters are briefly described below.

Chapter 1, “Introduction and Purpose and Need for Agency Action,” introduces the health and 

environmental concern about mercury, provides background information on the Mercury Export 

Ban Act of 2008, describes the purpose and need for action and the proposed action, and 

summarizes the mercury inventory used in this draft SEIS, as well as the January 2011 Mercury 

Storage EIS. It also describes the scope of this draft SEIS and other relevant NEPA documents. 

Chapter 2, “Facility Description, Alternatives, and Comparison of Environmental Consequences,” 

describes the new mercury storage candidate sites analyzed in this draft SEIS, the activities that 

would take place, and a comparison of impacts associated with the candidate sites analyzed in this 

draft SEIS and in the January 2011 Mercury Storage EIS. 

Chapter 3, “Affected Environment,” describes the potentially affected environments in the WIPP 

vicinity. The level of detail presented for each resource (e.g., air quality, water resources) 

depends on the likelihood that the resource would be affected by mercury management and 

storage activities. 

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

environment of the proposed mercury storage facility alternatives, including cumulative impacts 

and unavoidable adverse impacts. It also discusses potential future closure activities, irreversible 

and irretrievable commitments of resources, the relationship between short-term uses of the 

environment and long-term productivity, and mitigation. 

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

Requirements,” describes the environmental and health and safety compliance requirements 

governing implementation of the alternatives, a summary of permit requirements, and the status 

of consultations with Federal and state agencies and American Indian tribal governments. 

Chapters 6, 7, 8, and 9 are the “Glossary,” “List of Preparers,” “Distribution List,” and “Index,” 

respectively.
Introduction and Purpose and Need for Agency Action 

1–11

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

alternatives and detailed information to support the impact analyses. The appendices are as follows: 

Appendix A – “The Mercury Export Ban Act of 2008 and Federal Register Notices”

Appendix B – “Impact Assessment Methodology”

Appendix C – “Storage Facility Construction and Operations Data”

Appendix D – “Human Health and Ecological Risk Assessment Analysis”

Appendix E – “Updates to the January 2011 Mercury Storage EIS”

Appendix F – “Common and Scientific Names of Plant and Animal Species”

Appendix G – “Cooperating Agency Agreements”

Appendix H – “Contractor National Environmental Policy Act Disclosure Statement”

Appendix I – “Responses to Consultation Requests”

1.9 REFERENCES 

DLA (Defense Logistics Agency), 2004, Final Mercury Management Environmental Impact Statement, 

Defense National Stockpile Center, Fort Belvoir, Virginia, March. 

DOE (U.S. Department of Energy), 1980, Final Environmental Impact Statement, Waste Isolation Pilot 

Plant, DOE/EIS-0026, Vol. 1, Washington, DC, October. 

DOE (U.S. Department of Energy), 1990, Final Supplemental Environmental Impact Statement for the 

Waste Isolation Pilot Plant, DOE/EIS-0026-FS, Washington, DC, January. 

DOE (U.S. Department of Energy), 1997, Waste Isolation Pilot Plant Disposal Phase Final Supplemental 

Environmental Impact Statement, DOE/EIS-0026-S-2, Carlsbad Area Office, Carlsbad, New Mexico, 

September. 

DOE (U.S. Department of Energy), 2009a, U.S. Department of Energy Interim Guidance on Packaging, 

Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, Office of 

Environmental Management, Washington, DC, November 13. 

DOE (U.S. Department of Energy), 2009b, Supplement Analysis for the Waste Isolation Pilot Plant 

Site-Wide Operations, DOE/EIS-0026-SA-07, Carlsbad Field Office, Carlsbad, New Mexico, May. 

DOE (U.S. Department of Energy), 2011, Draft Environmental Impact Statement for the 

Disposal of Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC-Like Waste, 

DOE/EIS-0375-D, Office of Environmental Management, Washington, DC, February. 

EPA (U.S. Environmental Protection Agency), 1997, Mercury Study Report to Congress, Vol. III, Fate 

and Transport of Mercury in the Environment, EPA-452/R-97-005, Office of Air Quality Planning & 

Standards and Office of Research and Development, December. 

EPA (U.S. Environmental Protection Agency), 2000, Mercury Research Strategy, EPA/600/R-00/073, 

Office of Research and Development, Washington, DC, September. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

1–12

EPA (U.S. Environmental Protection Agency), 2007, Mercury Storage Cost Estimates, Office of 

Pollution Prevention and Toxics and Office of Solid Waste and Emergency Response, Washington, DC, 

November.

EPA (U.S. Environmental Protection Agency), 2009, Report to Congress, Potential Export of Mercury 

Compounds from the United States for Conversion to Elemental Mercury, Office of Pollution Prevention 

and Toxic Substances, Washington, DC, October 14.

NNSA (National Nuclear Security Administration), 2011, Final Site-Wide Environmental Impact 

Statement for the Y–12 National Security Complex, DOE/EIS-0387, Oak Ridge Y–12 Area Office, Oak 

Ridge, Tennessee, February.

USGS (U.S. Geological Survey), 2000, Mercury in the Environment, Fact Sheet 146-000, accessed 

through http://www.usgs.gov/themes/factsheet/146-00/, October.

USGS (U.S. Geological Survey), 2009, Mineral Commodity Summaries 2009, Reston, Virginia, 

January 29.

Utah (Utah Department of Environmental Quality), 2009, Atmospheric Transport of Mercury, accessed 

through http://www.mercury.utah.gov/atmospheric_transport.htm, August 11.

Code of Federal Regulations

10 CFR 1021, U.S. Department of Energy, “National Environmental Policy Act Implementing 

Procedures.”

40 CFR 1500–1508, Council on Environmental Quality, Regulations for Implementing the Procedural 

Provisions of the National Environmental Policy Act.

40 CFR 1501.7, Council on Environmental Quality, “NEPA and Agency Planning: Scoping.”

Federal Register

63 FR 3624, U.S. Department of Energy, 1998, “Record of Decision for the Department of Energy’s 

Waste Isolation Pilot Plant Disposal Phase,” January 23. 

77 FR 33204, U.S. Department of Energy, 2012, “Notice of Intent to Prepare a Supplemental 

Environmental Impact Statement for the Long-Term Management and Storage of Elemental Mercury,” 

June 5.

United States Code

42 U.S.C. 6901 et seq., Resource Conservation and Recovery Act of 1976, as amended.

U.S. Public Laws

P.L. 110-414, Mercury Export Ban Act of 2008.
CHAPTER 2

FACILITY DESCRIPTION, ALTERNATIVES, AND 

COMPARISON OF ENVIRONMENTAL CONSEQUENCES

CHAPTER 2 

FACILITY DESCRIPTION, ALTERNATIVES, AND COMPARISON OF 

ENVIRONMENTAL CONSEQUENCES 

2–1

Chapter 2 provides descriptions of basic design requirements for a new facility(ies) that may be used for the 

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

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

Statement (Draft Mercury Storage SEIS). Seven candidate sites were previously evaluated as alternatives for 

long-term mercury storage in the January 2011 Long-Term Management and Storage of Elemental Mercury 

Environmental Impact Statement (Mercury Storage EIS) (DOE 2011) and are still under consideration. A summary 

description of these alternative locations is provided in this chapter; however, detailed descriptions can be found in 

Chapter 2 of the January 2011 Mercury Storage EIS. This chapter concludes with a summary of impacts and a 

comparison of impacts analyzed in this Draft Mercury Storage SEIS with those analyzed in the January 2011

Mercury Storage EIS.

2.1 INTRODUCTION 

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

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

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

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

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

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

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

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

accordance with the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery 

Act (RCRA) (42 U.S.C. 6901 et seq.). The mercury to be stored at the DOE facility(ies) must be 

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

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

facility(ies) are illustrated in Figure 2–1 and include (1) that resulting from closure of chlor-akali plants 

or conversion to non-mercury-cell technology; (2) that generated as a byproduct of the gold-mining 

process; (3) that reclaimed from recycling and waste recovery activities; (4) DOE mercury at the Y–12 

National Security Complex (Y–12); and (5) other relatively minor sources. Only four chlor-alkali 

plants are expected to still be using mercury-cell technology beyond 2010: Ashta Chemical in Ohio, 

 

1 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this supplemental 

environmental impact statement. 

2

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

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

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

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

Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement, DOE has 

reexamined these estimates. For purposes of analysis, DOE assumes the operation of a mercury storage facility(ies) with a 

capacity of 10,000 metric tons over a 40-year period of analysis. These are estimates with a degree of uncertainty; therefore, it 

is possible that more or less than 10,000 metric tons of mercury could eventually require storage for a period longer or shorter 

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

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

3

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

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

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

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

greater than 99.5 percent purity by volume would be accepted for long-term storage in a DOE facility(ies). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

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PPG Industries in West Virginia, and Olin Corporation in Tennessee and Georgia (Chlorine 

Institute 2008).4 Mining in the state of Nevada accounts for more than 80 percent of gold production and 

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

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

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

of approximately 97 metric tons (107 tons) of byproduct mercury in 2002 (Miller and Jones 2005). 

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

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

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

companies shown on the map in Figure 2–1 account for the majority of secondary mercury reclamation 

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

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

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

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

Figure 2–1. Potential Sources of Mercury in the United States

 

4 Olin Corporation has announced that its chlor-alkali plants in Tennessee and Georgia will be consolidated and converted to 

mercury-free technology by the end of 2012 (Pavey 2012). The fate of this mercury is uncertain and may still be eventually 

shipped to a DOE facility(ies) for long-term management and storage; therefore, the quantities of mercury analyzed in this 

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

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

2–3

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

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

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

consolidated long-term storage at several candidate DNSC and non-DNSC sites. In the Record of 

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

DLA selected the Hawthorne Army Depot in Nevada, a non-DNSC candidate site analyzed in the 

MM EIS, for storage of approximately 4,400 metric tons (4,900 tons) of mercury. All 4,400 metric tons 

(4,900 tons) of defense-related mercury has been successfully transferred to the Hawthorne Army Depot 

for long-term management and storage (DLA 2012). This quantity of defense-related mercury is not 

included in the estimates of excess mercury that may require long-term storage in a DOE-designated 

facility(ies), although the Hawthorne Army Depot site was evaluated in the January 2011 Long-Term 

Management and Storage of Elemental Mercury Environmental Impact Statement (Mercury Storage EIS)

for storage of the additional mercury for which DOE would be responsible. 

2.2 MERCURY STORAGE FACILITY(IES) 

As required by Section 5 of the Act, DOE has developed guidance, entitled U.S. Department of Energy 

Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of 

Elemental Mercury (Interim Guidance) (DOE 2009), establishing basic standards and procedures for the 

receipt, management, and long-term storage of mercury at a DOE facility(ies). The guidance is based on 

laws, regulations, DOE Orders, and best management practices. The Interim Guidance discusses DOE’s 

anticipated waste acceptance criteria for discarded mercury to be stored at the facility(ies). All mercury 

to be stored at the facility(ies) must meet these requirements. Further, it describes the procedures DOE 

would use to receive, store, and monitor the mercury. In addition, spill and emergency response 

procedures are described. 

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

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

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

procedures 

Security and access control 

Fire suppression systems 

Ventilated storage and handling area(s) 

Fully enclosed weather protected building 

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

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

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

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

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

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

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

approximately 90 percent of the floor space. The Storage Area would generally be a large open space 

similar to a warehouse, where storage, inspection, and monitoring could be effectively performed. The 

other functional areas would occupy the remaining 10 percent of the facility(ies). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–4

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

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

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

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

These containers are typically made of carbon steel or stainless steel and also satisfy the U.S. Department 

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

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

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

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

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

containers (6,000 metric tons [6,600 tons]). The 40:60 split is based on a rough estimate of known 

inventories (DOE 2009). All mercury currently stored at Y–12 is in 3-L flasks. It is anticipated that most 

of the mercury shipped from the chlor-alkali and mining facilities would be in 1-MT containers, whereas 

most of the mercury shipped from reclamation and recycling facilities would be in 3-L flasks.

Figure 2–2. Typical Elemental Mercury Storage Containers

2.2.1 New Facility(ies) Description

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

providing the safe and secure long-term storage of mercury. Figure 2–3 provides a conceptual illustration 

of what the exterior of a new mercury storage facility(ies) might look like, and Figure 2–4 provides a 

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

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

and data related to requirements for construction and operation of a new facility(ies).
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–5

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

Figure 2–4. Conceptual Layout of a New Mercury Storage Facility
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

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

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

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

seismic and safety considerations, as well as the requirements of an RCRA permit. If constructed, the 

height of the building would be approximately 6.1 meters (20 feet) to accommodate the potential triple 

stacking of 3-L flasks. The new facility(ies) would have a reinforced-concrete floor, strong enough to 

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

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

systems. Mercury containers would be stored in spill trays designed to contain at least 10 percent of the 

volume of mercury stored in each spill tray in the unlikely event one of the containers were to leak. The 

exterior of the storage facility(ies) would likely be sheet metal panels fastened to structural steel supports 

and connected together to form a weather-protected structure. The Receiving and Shipping Area would 

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

monitoring systems would be incorporated into the facility(ies) design. Monitoring systems could include 

security alarms and surveillance cameras. A new full-size, standalone facility boundary would 

encompass approximately 3.1 hectares (7.6 acres) and would include a paved area for delivery truck 

access and vehicle parking. The facility(ies) would also need to be RCRA regulated and permitted, and 

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

stored materials, strict record-keeping, and periodic reporting.

2.2.2 Construction Requirements

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

require the disturbance of approximately 3.1 hectares (7.6 acres) of land for building construction and 

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

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

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

storage, a new facility(ies) could be constructed in a modular fashion to accommodate storage of mercury 

on an as-needed basis. The ability to build the storage facility(ies) in a modular fashion would also 

ensure that the facility(ies) is sized correctly for the amount of mercury that would eventually require 

storage. For example, the Storage Areas of the facility(ies) could be built in two sections, one section at a 

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

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

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

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

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

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

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

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

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

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

(11,000-ton) capacity are discussed in Chapter 4, Section 4.6.2, and Appendix C, Section C.2.3.

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

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

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

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

systems; and implementing spill prevention and containment measures.
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–7

2.2.3 Operations Requirements

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

shipments. Operations personnel would include management and administrative staff, facility 

technicians, facility maintenance staff, subject matter experts, and security staff. Administrative staff 

would be responsible for permit maintenance, fee collection, record-keeping, and reporting. The Office 

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

Area would be ventilated through the use of a high-negative draw system for removing vapors from 

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

through a sulfur filter to remove mercury vapors and be discharged to the outside. An air conditioning 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

required.

If DOE elects to transfer any excess mercury stored at Y–12, it is assumed that this mercury would be 

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

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

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

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

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

available for long-term storage, are discussed in Appendix D, Section D.2.2. The amount of mercury in 

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

transportation regulations.

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

facility(ies).5 In summary, it is anticipated that the mercury from Y–12 would be transferred in the first 

2 years of operation, the mercury from chlor-alkali facilities would be shipped in the first 7 years of 

operation, and any mercury from mining and reclamation and recycling facilities would be shipped at a 

steady rate over the 40-year period of analysis. This corresponds to an estimated 66 to 79 truck deliveries 

(or 23 railcar deliveries) per year in the first two years of operation, 26 to 39 truck deliveries (or 8 railcar 

deliveries) per year between the third and seventh years of operation, and then 14 to 27 truck deliveries 

(or 5 railcar deliveries) per year thereafter.

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

(11,000-ton) capacity are discussed in Chapter 4, Section 4.6.2, and Appendix C, Section C.2.4.

 

5

For purposes of analysis, the January 2011 Mercury Storage EIS assumes a 40-year operational period with the first year 

starting in 2013 and the fortieth year, in 2052. An operational start date is not known at this time; however, the period of 

analysis remains 40 years. For example, if the mercury storage facility(ies) were to start operations in 2014, the last year of 

operations would likewise shift to 2053, and so forth.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–8

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

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

below (DOE 2009).

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

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

allowed access within the facility(ies) boundary. It is conservatively assumed for labor estimates 

that security personnel would guard the facility(ies) 24 hours per day, 7 days per week, although 

this level of security may not be required at all times. Security alarms and surveillance cameras 

may also be used.

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

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

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

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

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

of hazardous waste. See Appendix C, Section C.1, for a detailed discussion of shipping 

containers and methods. After arriving at the facility(ies), if visible mercury contamination or 

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

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

the generator’s expense.

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

would be measured and verified to be below any actionable levels. As discussed in Section 5.3 of 

the Interim Guidance, the actionable level for mercury vapor is the American Conference of 

Governmental Industrial Hygienists’ threshold limit value of 0.025 milligrams per cubic meter as 

a time-weighted average. A visual inspection would follow to detect any obvious problems that 

may have occurred while on the truck or railcar. If the initial inspections and manifest 

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

Area, where additional visual inspections would be performed to check for leaks, structural 

integrity of pallets and containers, approved container types, corrosion, etc. The mercury would 

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

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

process would be placed into long-term storage and location data would be recorded.

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

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

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

ventilated using low-vacuum, high-volume industrial-sized roof- or wall-mounted vent fans. 

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

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

to be completed and maintained in accordance with RCRA regulations. These documents would 

be stored in the Office Administration Area.

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

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

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

the facility(ies) to new containers. The likelihood of these types of occurrences is considered 

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

be negatively ventilated using a hooded duct system equipped with a sulfur filter designed to 

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

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

(208-liter) drums, characterized, and disposed of off site at an appropriate facility.
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–9

2.3 ALTERNATIVE SITES EVALUATED 

Chapter 2, Section 2.4, of the January 2011 Mercury Storage EIS describes seven candidate sites for the 

long-term management and storage of elemental mercury. This Draft Long-Term Management and 

Storage of Elemental Mercury Supplemental Environmental Impact Statement (Draft Mercury Storage 

SEIS) evaluates three additional candidate sites for the long-term management and storage of elemental 

mercury: Waste Isolation Pilot Plant (WIPP) Vicinity Section 10, WIPP Vicinity Section 20, and WIPP 

Vicinity Section 35. The names and locations of the candidate sites analyzed in the January 2011

Mercury Storage EIS and in this draft SEIS are listed below and presented in Figure 2–5. 

New construction at the Grand Junction Disposal Site 

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

Existing storage buildings at the Hawthorne Army Depot in the Central Magazine Area 

New construction at Idaho National Laboratory’s (INL’s) Idaho Nuclear Technology and 

Engineering Center (INTEC) 

Existing storage buildings at INL’s Radioactive Waste Management Complex (RWMC) 

Existing building at the Bannister Federal Complex’s Kansas City Plant (KCP) 

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

New construction at the Waste Control Specialists, LLC, site (WCS) 

New construction at WIPP Vicinity Section 10 

New construction at WIPP Vicinity Section 20 

New construction at WIPP Vicinity Section 35 

Figure 2–5. Alternative Sites for Long-Term Storage of Mercury 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–10

The January 2011 Mercury Storage EIS also analyzed the potential impacts associated with the No Action 

Alternative. The No Action Alternative is discussed in Chapter 2, Section 2.4.1, of the January 2011

Mercury Storage EIS (DOE 2011). Under the No Action Alternative, DOE would not designate a 

facility(ies) for the long-term management and storage of mercury. The No Action Alternative would 

affect all sources of mercury. Excess mercury that could not be sold would be stored as a commodity to 

the extent allowed by law. Some mercury would likely be considered waste and would be stored in 

accordance with law. Such storage would not necessarily occur at the sites identified as potential sources 

of excess mercury. This storage service might be provided by a commercial waste management 

company(ies). As discussed further in Chapter 2, Section 2.6.1, several waste management companies 

have notified DOE of their intent to accumulate and store excess mercury at RCRA-permitted facilities in 

accordance with Section 5(g)(2)(b) of the Mercury Export Ban Act of 2008. Approximately 

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

is currently stored in approximately 35,000 of the 3-L flasks at Y–12.

2.3.1 January 2011 Mercury Storage EIS Candidate Sites

The candidate sites analyzed in the January 2011 Mercury Storage EIS are summarized as follows:

Grand Junction Disposal Site: The Grand Junction Disposal Site is located approximately 

29 kilometers (18 miles) southeast of Grand Junction, Colorado. The new facility would be 

constructed in the northwestern corner of the 146-hectare (360-acre) site, which is owned by DOE 

and managed by DOE’s Office of Legacy Management. Currently, the site has a 38-hectare (94-acre) 

area used to dispose of uranium mill tailings.

Hanford Site in the 200-West Area: Hanford occupies 151,775 hectares (375,040 acres) along the 

Columbia River in the southeastern portion of the state of Washington. Hanford is owned by the 

Federal Government and is managed by DOE. The new facility would be located in the 200-West 

Area of Hanford at the Central Waste Complex (CWC). Located in the 200-West Area, the CWC 

receives, stores, and distributes solid radioactive and nonradioactive waste.

Hawthorne Army Depot in the Central Magazine Area: The Hawthorne Army Depot is located 

approximately 16 kilometers (10 miles) from Hawthorne, Nevada. The 59,500-hectare 

(147,000-acre) site is owned and managed by the U.S. Department of Defense. DOE would designate 

a maximum of 29 buildings existing in the Central Magazine Area, which would provide up to 

approximately 27,000 square meters (290,000 square feet) of storage space for DOE storage of 

mercury. NOTE: Currently, DLA Strategic Materials (formerly DNSC) is storing approximately 

4,400 metric tons (4,900 tons) of elemental mercury at the Hawthorne Army Depot (DLA 2012).

Idaho National Laboratory’s Idaho Nuclear Technology and Engineering Center or 

Radioactive Waste Management Complex: The INL site is a 230,323-hectare (569,135-acre) area 

located in southeastern Idaho. INL consists of several facility areas situated on an expanse of 

otherwise undeveloped, cool desert terrain. A new facility would be located at INTEC. Current 

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

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

demolition of excess facilities. RWMC has a number of buildings in the Transuranic Storage Area 

currently dedicated to storage, staging, characterization, and shipping of transuranic (TRU) waste. 

Seven Type II storage modules could be used for the storage of mercury; each building would provide

approximately 2,700 square meters (29,000 square feet) of storage.

Bannister Federal Complex’s Kansas City Plant: KCP is part of the 125-hectare (310-acre) 

Bannister Federal Complex located 13 kilometers (8 miles) south of downtown Kansas City, 

Missouri. KCP occupies 55 hectares (136 acres) of the complex and is under the custody and control 

of DOE’s National Nuclear Security Administration. Approximately 14,000 square meters 

(150,000 square feet) of existing storage space within KCP could be available for the long-term 

storage of mercury.
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–11

Savannah River Site E Area: SRS is located in south-central South Carolina and occupies 

approximately 80,290 hectares (198,400 acres) in Aiken, Barnwell, and Allendale Counties. E Area 

is located in the central part of SRS. The current land use designation for E Area is Site Industrial 

Use. E Area, which includes the Old Burial Ground, Mixed Waste Management Facility, TRU waste 

pads, and E Area Vaults, receives low-level radioactive, TRU, and mixed low-level radioactive waste 

from all site areas. The new facility would be located in E Area of SRS.

Waste Control Specialists, LLC, Site: Waste Control Specialists, LLC, a commercial entity, owns 

and operates a large 541-hectare (1,338-acre) site for the treatment, storage, and landfill disposal of 

various hazardous and radioactive wastes. The site is located approximately 50 kilometers (31 miles) 

west of Andrews, Texas, and 10 kilometers (6 miles) east of Eunice, New Mexico. The new facility 

would be located either north or south of the existing WCS complex of buildings. The Container 

Storage Building, an existing building located within WCS, is presently configured to store hazardous 

waste and, with minor modifications, could provide storage of up to approximately 2,000 metric tons 

(2,200 tons) of elemental mercury.

2.3.2 WIPP Facility and Vicinity

WIPP is the Nation’s only underground repository for the permanent disposal of defense-generated TRU

waste. The WIPP site is located in Eddy County in the Chihuahuan Desert of southeastern New Mexico 

(see Figure 2–6). The site is about 42 kilometers (26 miles) east of Carlsbad in a region known as 

Los Medaños, a relatively flat, sparsely inhabited plateau with little surface water. The WIPP site 

encompasses approximately 41 square kilometers (16 square miles) under the jurisdiction of DOE 

pursuant to the Waste Isolation Pilot Plant Land Withdrawal Act (WIPP LWA) (P.L. 102-579). The 

WIPP site covers 16 sections (each section is 2.6 square kilometers [1 square mile]) of Federal land in 

Township 22 South, Range 31 East, and is divided into four areas under DOE control (see Figures 2–6 

and 2–7). A chain-link fence surrounds the innermost Property Protection Area, which includes all of the 

surface facilities. Surrounding this inner area is the Exclusive Use Area, which is surrounded by a 

barbed-wire fence. Enclosing these two areas is the Off-Limits Area, which is unfenced to allow 

livestock grazing but, like the other two areas, is patrolled and posted against trespassing or other land 

uses. Beyond the Off-Limits Area, the land is managed under the traditional public land use concept of 

multiple uses, but mining and drilling are restricted. The WIPP site includes all of the necessary surface 

and subsurface facilities to manage waste handling and disposal operations. In the Notice of Intent 

published on June 5, 2012, DOE identified two candidate locations that would be evaluated in a 

supplemental environmental impact statement (SEIS) for the long-term management and storage of 

elemental mercury. After consideration of scoping comments received that identified potash mining 

interests in the area, DOE decided to evaluate a third candidate location. A total of three options for longterm storage of mercury in the vicinity of WIPP have been identified: (1) new construction in Section 10 

outside the land withdrawal boundary (LWB); (2) new construction in Section 20 inside the LWB;6and 

(3) new construction in Section 35 outside the LWB. These locations will be referred to individually as 

“WIPP Vicinity Section 10”; “WIPP Vicinity Section 20”; and “WIPP Vicinity Section 35” or together as 

the “WIPP Vicinity reference locations.” Figures 2–6 and 2–7 show the WIPP facility relative to the 

WIPP Vicinity reference locations.

 

6 The Waste Isolation Pilot Plant Land Withdrawal Act (WIPP LWA) (P.L. 102-579) was signed into law on October 20, 1992, 

and was later amended by the WIPP LWA Amendments of 1996 (P.L. 104-201). The WIPP LWA withdrew approximately 

41 square kilometers (16 square miles) of land from the public domain for the purpose of creating and operating WIPP, the 

geologic repository in New Mexico designated as the national disposal site for TRU waste generated by atomic energy defense 

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

2–12

Figure 2–6. WIPP Facility in State of New Mexico
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–13

Figure 2–7. WIPP Vicinity Reference Locations
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

2–14

2.3.2.1 WIPP Vicinity Section 10 

This alternative involves construction of a new facility, as described in Appendix C, Section C.2. The 

new facility would be located in Section 10, Township 22 South, Range 31 East, approximately 

5.6 kilometers (3.5 miles) north of the WIPP facility, as illustrated in Figures 2–6 and 2–7. A full-size 

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

(7.6 acres) of the available (approximately 260-hectare [640-acre]) area proposed for locating the facility, 

as shown in Figure 2–7. The available area for siting a mercury storage facility is not confined to any 

particular part of Section 10; therefore, the entire 260-hectare (640-acre) Section 10 is defined as the 

available area. However, it may be more advantageous to site the facility near the North Access Road for 

truck access and connection to existing utility infrastructure. Truck and rail access are available at the 

WIPP site. 

2.3.2.2 WIPP Vicinity Section 20 

This alternative involves construction of a new facility, as described in Appendix C, Section C.2. The 

new facility would be located in Section 20, Township 22 South, Range 31 East, across the WIPP access 

road to the west of the WIPP facility within the DOE Exclusive Use Area, as illustrated in Figures 2–6 

and 2–7. As shown in Figure 2–7, a full-size mercury storage facility with up to a 10,000-metric-ton 

(11,000-ton) capacity would occupy 3.1 hectares (7.6 acres) of the available (approximately 21-hectare 

[53-acre]) area proposed for locating the facility. The available area is defined to the south by a rail line, 

the east by North Access Road, the west by the boundary of the Off-Limits Area, and the north by the 

lateral extension of the Exclusive Use Area boundary. Truck and rail access are available at the WIPP 

site. 

2.3.2.3 WIPP Vicinity Section 35 

This alternative involves construction of a new facility, as described in Appendix C, Section C.2. The 

new facility would be located in Section 35, Township 22 South, Range 31 East, approximately 

5.6 kilometers (3.5 miles) southeast of the WIPP facility, as illustrated in Figures 2–6 and 2–7. A 

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

3.1 hectares (7.6 acres) of the available (approximately 260-hectare [640-acre]) area proposed for locating 

the facility, as shown in Figure 2–7. The available area for siting a mercury storage facility is not 

confined to any particular part of Section 35; therefore, the entire 260-hectare (640-acre) Section 35 is 

defined as the available area. However, it may be more advantageous to site the facility near 

Mill’s Ranch Road or Red Road for truck access and connection to existing utility infrastructure. Truck 

and rail access are available at the WIPP site. 

2.4 PREFERRED ALTERNATIVE 

In the January 2011 Mercury Storage EIS, DOE identified WCS near Andrews, Texas, as the Preferred 

Alternative for the long-term management and storage of mercury. Based on analysis from this draft 

SEIS and public comment, the Preferred Alternative may or may not change in the final SEIS. At this 

time, DOE has not changed the Preferred Alternative. In the Final Mercury Storage SEIS, DOE will reevaluate and indicate whether the Preferred Alternative will be changed. DOE will make a decision no 

sooner than 30 days after publication of the U.S. Environmental Protection Agency Notice of Availability 

for the Final Mercury Storage SEIS in the Federal Register. The selection of a site will be based on the 

January 2011 Mercury Storage EIS, this Mercury Storage SEIS, and other appropriate factors and will be 

announced in a ROD in the Federal Register. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–15

2.5 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED 

ANALYSIS 

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

Environmental Quality regulations (40 CFR 1502.14(a)), the reasons for elimination of these alternatives 

from detailed study are presented in Chapter 2, Section 2.6, of the January 2011 Mercury Storage EIS 

(DOE 2011). Alternatives may be eliminated from further consideration because of technical immaturity, 

regulatory unacceptability, or because they do not support the purpose and need for the proposed action. 

2.6 COMPARISON OF ALTERNATIVES 

This section presents a comparison of alternatives analyzed in this draft SEIS and the January 2011 

Mercury Storage EIS, including the No Action Alternative. The analyses presented in the January 2011 

Mercury Storage EIS remain valid and are incorporated into this draft SEIS with two exceptions: (1) the 

occupational and public health and safety analysis; and (2) the socioeconomics and environmental justice 

analysis. This draft SEIS includes updates to the occupational and public health and safety analysis 

resulting from changes to the definition of severity levels (i.e., magnitude of impacts) for acute-inhalation 

exposures to the public under certain accident scenarios. This draft SEIS also includes updates to the 

socioeconomics and environmental justice analyses to incorporate 2010 decennial census information that 

was not available at the time the January 2011 Mercury Storage EIS was published. The updates to the 

analyses are presented in Appendix B and Appendix E of this draft SEIS and are also included as 

appropriate in the comparison of alternatives presented in this section. Relevant information and data 

from the January 2011 Mercury Storage EIS that remain unchanged have been reproduced and presented 

in this draft SEIS for the convenience of the reader. Table 2–1 presents a comparison of key physical 

setting and location factors, i.e., those factors that provide some means of discerning the differences 

among action alternative sites regarding their surroundings, operational experience, or land use 

compatibility. 

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

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

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

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

action alternatives are not presented in Table 2–2 and include water resources, noise, ecological 

resources, cultural and paleontological resources, waste management, and socioeconomics. 

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

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

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

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

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

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

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

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

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

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

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

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

Therefore, the environmental consequences of the No Action Alternative on water resources could be 

more or less than under the action alternatives. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–16

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

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

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

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

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

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

action alternatives. 

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

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

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

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

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

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

storage facility(ies), it is reasonable to expect that environmental consequences associated with 

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

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

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

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

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

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

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

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

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

show somewhat larger impacts than those in which an existing facility(ies) is modified with respect to 

certain resource areas, e.g., land use, visual resources, air quality, short-term impacts, and commitment of 

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

2–17

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

Site/Resource 

Factor

Alternatives That Use Existing Buildings Alternatives That Require New Construction

INL

RWMC

Hawthorne 

Army Depot KCP GJDS

Hanford 

200-West Area

SRS

E Area WCS

INL

INTEC

WIPP Vicinity

Section 10 Section 20 Section 35

Site size in hectares 

(acres)

INL: 230,323

(569,135)

RWMC: 76

(187)

59,500

(147,000)

55

(136)

146

(360)

Hanford: 151,775

(375,040)

200 Areas: 5,064

(12,513)

SRS: 80,290

(198,400)

E Area: 134

(330)

Entire site: 5,460

(13,500)

Facilities: 541

(1,338)

INL: 230,323

(569,135)

INTEC: 107

(264)

WIPP: 4,144

(10,260)

Section 10: 260

(640)

WIPP: 4,144

(10,260)

Section 20: 21

(53)

WIPP: 4,144

(10,260)

Section 35: 260

(640)

Compatible with 

land use plans?

Yes Yes; 

facility use 

agreement between 

DoD and DOE 

may be required.

Yes 1996 MOU possible 

restriction on land 

use and current 

zoning – under 

evaluation.

Yes Yes Yes Yes BLM-administered land 

outside the WIPP LWB 

used for a mercury 

storage facility would be 

withdrawn from all forms 

of entry, appropriation, 

and disposal under the 

public land laws and 

reserved for the purposes 

of operating a mercury 

storage facility. Existing 

potash mining lease may 

impact siting a facility.

Land inside the 

WIPP LWB used 

for a mercury 

storage facility 

would be subject to 

the provisions of 

the WIPP LWA 

and may require 

Federal legislation.

BLM-administered land 

outside the WIPP LWB 

used for a mercury 

storage facility would be 

withdrawn from all forms 

of entry, appropriation, 

and disposal under the 

public land laws and 

reserved for the purposes 

of operating a mercury 

storage facility.

Facility or site 

operates under 

existing RCRA 

storage permits.a

Yes Yes No No Yes Yes Yes Yes WIPP operates under a RCRA storage and disposal permit.

Seismic riskb 0.12 g 0.57 g 0.05 g 0.14 g 0.18 g 0.17 g 0.12 g 0.12 g 0.08 g

Nearest surface-water 

feature

Big Lost River 

Channel 1.6 km 

(1 mile) northwest. 

Diversion spread 

areas (intermittent and 

seasonal) 1.6 km 

(1 mile) west.

Walker Lake 5.0 km 

(3.1 miles) northwest.

Blue River borders 

site to the east and 

Indian Creek borders 

site to the south.

Cheney Reservoir 

0.6 km (1 mile) 

southeast.

Columbia River 

10 km (6.2 miles) 

north. Cold Creek 

(ephemeral) 4.8 km 

(3 miles) south.

Upper Three Runs 

Creek 500 m 

(1,640 feet) north.

No perennial features 

within 16 km 

(10 miles). Ranch 

house drainage area 

(intermittent and 

seasonal) 0.4 km 

(0.25 miles) southeast.

Big Lost River 

channel 900 m 

(2,950 feet) 

northwest.

Laguna Grande de la Sal, a salt lake, approximately 13 kilometers (8 miles) 

to the west-southwest.

Site in 100-year 

floodplain?

No No Yes; 

flood protection 

system designed for 

500-year flood event.

No No No No Yes; 

diversion dam 

designed for 

300-year flood 

event.

No

Residential population 

within 16-km 

(10-mile) radiusc

175

(9.8% minority)

(18% low-income)

2,583

(23% minority)

(15% low-income)

705,513

(36% minority)

(13% low-income)

2,823

(14% minority)

(11% low-income)

147

(38% minority)

(18% low-income)

6,691

(38% minority)

(20% low-income)

3,322

(47% minority)

(12% low-income)

205

(11% minority)

(15% low-income)

550

(44% minority)

(6% low-income)

575

(45% minority)

(5% low-income)

430

(44% minority)

(6% low-income)

Residential population 

within 3.2-km 

(2-mile) radiusc

0 169

(23% minority)

(20% low-income)

26,192

(52% minority)

(20% low-income)

194

(12% minority)

(10% low-income)

0 0 27

(35% minority)

(7.8% low-income)

0 36

(45% minority)

(5% low-income)

21

(46% minority)

(5% low-income)

13

(47% minority)

(5% low-income)

Environmental justice 

considerations 

within 16-km 

(10-mile) radiusc

No minority or 

low-income 

census block groups.

1 that is both a 

minority and 

low-income 

census block group 

(out of 4 blocks).

157 minority only, 

5 low-income only, 

and 88 that are both 

minority and 

low-income 

census block groups 

(out of 659 blocks).

No minority or 

low-income 

census block groups.

2 minority only 

census block groups 

and 1 that is both a 

minority and lowincome census block 

group 

(out of 4 blocks).

4 minority census 

block groups and 

1 low-income 

census block group 

(out of 15 blocks).

2 minority and 

no low-income 

census block groups 

(out of 8 blocks).

No minority or 

low-income 

census block groups.

No minority or low-income census block groups.

Site employment 8,485 (INL) 500–650 2,400 7 9,759 (Hanford) 8,400 (SRS) 150 8,485 (INL) 1,100 (WIPP)

a This factor does not imply that a permit already exists for the storage of DOE mercury; rather, this factor is intended to establish a candidate site’s experience operating under other RCRA storage permits. The conditions of any RCRA permit would have to be modified, or in some cases a new application would have to be submitted for approval.

b Seismic risk is based on predicted peak acceleration for an earthquake event expected to occur once in 2,500 years. Earthquake-produced ground motion is expressed in units of percent g (i.e., force of acceleration relative to that of Earth’s gravity). Meteorological risks associated with tornadoes, hurricanes, or floods are bounded by 

earthquake scenario risks.

c Population data have been updated per 2010 census data. The January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement was based on 2000 census data. See Appendix E.

Note: Various mercury storage locations, many of which are undetermined, would be involved under the No Action Alternative; therefore, these locations are not presented in the above table. Section 2.6 presents a discussion comparing the potential environmental consequences of the No Action Alternative against those of the action 

alternatives.

Key: BLM=U.S. Bureau of Land Management; DoD=U.S. Department of Defense; DOE=U.S. Department of Energy; GJDS=Grand Junction Disposal Site; Hanford=Hanford Site; INL=Idaho National Laboratory; INTEC=Idaho Nuclear Technology and Engineering Center; KCP=Kansas City Plant; km=kilometers; LWA=Land 

Withdrawal Act; LWB=land withdrawal boundary; m=meters; MOU=Memorandum of Understanding; RCRA=Resource Conservation and Recovery Act; RWMC=Radioactive Waste Management Complex; SRS=Savannah River Site; WCS=Waste Control Specialists, LLC, site; WIPP=Waste Isolation Pilot Plant.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–18

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

Resource/Site

Alternatives That Use Existing Buildings Alternatives That Require New Construction

INL

RWMC

Hawthorne 

Army Depot KCP GJDS

Hanford 

200-West Area

SRS

E Area WCS

INL

INTEC

WIPP Vicinity

Section 10 Section 20 Section 35

Land use and 

visual resources

New land would not be disturbed nor would any of the proposed 

existing buildings have to be expanded to accommodate the long-term 

storage of mercury. Therefore, there would be no impacts on land use 

or visual resources.

Construction of a new mercury storage facility(ies) would disturb approximately 3.1 hectares (7.6 acres) of land. Because of the low profile of a new storage building, there would be minimal 

impacts on visual resources.

Geology and soils None May require minor 

trenching for utility 

connections.

None Potentially would disturb and expose up to 3.1 hectares (7.6 acres) of land (i.e., soil) to a depth of approximately 60 centimeters (24 inches) for 6 months. Geologic resource commitments for 

construction of a new facility(ies) would include approximately 4,755 cubic meters (6,220 cubic yards) of concrete and 3,875 cubic meters (5,070 cubic yards) of crushed stone.

Air quality Negligible air emissions would occur for modification of existing 

buildings. Operation of a long-term mercury storage facility(ies) 

would not involve the treatment or processing of mercury; therefore, 

air emissions would be negligible and limited to employee vehicles, 

trucks, semiannual testing of emergency generators, and venting of 

residual mercury vapors. Truck and/or rail transport of mercury would 

result in negligible emissions of criteria and toxic air pollutants.

Minor short-term air quality impacts would occur during construction of a new storage facility(ies), primarily due to dust generation and emissions from heavy equipment. Operation of a long-term 

mercury storage facility(ies) would not involve the treatment or processing of mercury; therefore, air emissions would be negligible and limited to onsite employee vehicles, trucks, semiannual 

testing of emergency generators, and venting of residual mercury vapors. Truck and/or rail transport of mercury would result in negligible emissions of criteria and toxic air pollutants.

Carbon dioxide would be generated from fuel-burning equipment used in construction of a new facility(ies), if applicable, and from transportation of mercury to the storage facility(ies); however, emissions (maximum of 3,699 metric tons [4,077 tons]) would be negligible 

compared with the annual worldwide generation of carbon dioxide (estimated at 26.4 billion metric tons [29.1 billion tons]) and would have a negligible effect on the global climate.

Infrastructure Negligible; 

capacity would meet 

increased demands.

Negligible; 

capacity would meet 

increased demands. 

Negligible; 

capacity would meet 

increased demands.

Moderate; 

electrical capacity 

would have to be 

increased. No 

public water 

supply. No rail 

access.

Negligible; 

capacity would meet 

increased demands.

Negligible; 

capacity would meet 

increased demands.

Negligible; 

capacity would meet

increased demands.

Negligible; 

capacity would meet 

increased demands.

Minor upgrades would 

be required to provide 

water and sanitary

service to site. 

Moderate impacts on 

electrical infrastructure. 

Negligible impacts on 

available infrastructure 

capacities.

Minor upgrades would 

be required to connect 

water and sanitary 

service to existing 

WIPP infrastructure. 

Moderate impacts 

on electrical 

infrastructure. 

Negligible impacts on 

available infrastructure 

capacities.

Minor upgrades would 

be required to provide 

water and sanitary service 

to site. 

Moderate impacts on 

electrical infrastructure. 

Negligible impacts on 

available infrastructure 

capacities.

Occupational and 

public health 

and safetya

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

Facility accidentsb Consequences range from SL-I to SL-II with an associated negligible-to-low risk to involved workers and noninvolved workers from both inside and outside spills. Consequences of SL-I with an associated negligible risk to public receptors from inside and outside spills.

Transportationa, c

Truck kilometers 

(miles)

2,662,210

(1,654,225)

3,127,892

(1,943,587)

2,230,117

(1,385,734)

2,509,474

(1,559,319)

3,399,774

(2,112,527)

2,707,719

(1,682,503)

2,907,276

(1,806,502)

2,662,210

(1,654,225)

3,007,088

(1,868,523)

Annual truck accident 

fatalitiesd

9.2×10-41.1×10-37.8×10-48.7×10-41.2×10-39.4×10-41.0×10-39.2×10-41.0×10

-3

Truck accident –

human healthb

For spills onto the ground with subsequent evaporation of mercury, the frequency component of the human health risk would be negligible. The risk would also be negligible. Consequences could be in the SL-I, SL-II, SL-III, or SL-IV range. However, SL-III and SL-IV 

would only be encountered at short distances (< 100 meters [330 feet]). For direct spills of mercury into water, the consequences could be SL-I or SL-II with a negligible-to-low risk (but with a large degree of uncertainty). For truck accidents with fires, acute-inhalation 

exposures could be in the SL-I, SL-II, or SL-III range, all with corresponding low risks. For deposition directly onto the ground, consequences would be SL-I with negligible risks. For deposition onto the surface of a water body with subsequent human consumption of 

fish, the frequency side of the risk estimate is always negligible for fish consumption above the SL-I/SL-II threshold at the national average consumption rate and for subsistence fishermen at the average and 95th percentile consumption rates, with negligible risks. 

However, in severe cases, there is the potential for contaminating water bodies above the SL-I/SL-II threshold (but still with negligible risk) for the 95th percentile subsistence fisherman up 7,000 meters (23,000 feet) downwind.
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–19

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

Resource/Site

Alternatives That Use Existing Buildings Alternatives That Require New Construction

INL

RWMC

Hawthorne 

Army Depot KCP GJDS

Hanford 

200-West Area

SRS

E Area WCS

INL

INTEC

WIPP Vicinity

Section 10 Section 20 Section 35

Transportationa, c

(continued)

Rail kilometers 

(miles)

600,162

(372,924)

635,564

(394,922)

403,890

(250,966)

510,579

(317,260)

729,541

(453,317)

461,068

(286,495)

634,260

(394,112)

600,162

(372,924)

685,920

(426,212)

Annual rail accident 

fatalitiesd

1.5×10-41.6×10-41.0×10-41.3×10-41.9×10-41.2×10-41.6×10-41.5×10-41.7×10

-4

Rail accident –

human healthb, e

For spills of mercury onto the ground with subsequent evaporation of mercury, the frequency component of the human health risk would be negligible. The risk would also be negligible. Consequences could be in the SL-I, SL-II, SL-III, or SL-IV range. However, SL-III 

and SL-IV would only be encountered at short distances (< 100 meters [330 feet]). For direct spills of mercury into water, the consequences could be SL-I or SL-II with a negligible-to-low risk (but with a large degree of uncertainty). For railcar accidents with fires, acuteinhalation exposures could be in the SL-I, SL-II, or SL-III range with low risks. For deposition directly onto the ground, consequences would be SL-I with negligible risks. For deposition onto the surface of a water body with subsequent human consumption of fish, the 

frequency side of the risk estimate is always negligible for fish consumption at the national average consumption rate and for subsistence fishermen at the average and 95th percentile consumption rates, with negligible risks, with the exception of the dry deposition case, in 

which there is a low predicted frequency that the 95th percentile subsistence fisherman could be exposed above the SL-I/SL-II threshold. In severe cases, there is the potential for contaminating water bodies above the SL-I/SL-II threshold for the 95th percentile 

subsistence fisherman up to 10 kilometers (6.2 miles) downwind.

Ecological 

impactsa, b, c

In the Truck Scenarios with dry deposition, three receptors could potentially be exposed at the SL-II level with a corresponding low risk: sediment-dwelling biota, soil invertebrates, and plants. All other ecological receptors would be exposed at the SL-I level with 

negligible risk. In the Truck Scenario with rain, only one ecological receptor could potentially be exposed at the SL-IV level: sediment-dwelling biota. The corresponding risk would be moderate. In the same accident scenario, soil invertebrates could be exposed at the 

SL-III level, with a corresponding low risk. Plants, the American robin, and the river otter could be exposed at the SL-II level, with corresponding low risk. All other ecological receptors would be exposed at the SL-I level with negligible risk. For Railcar Scenarios with 

dry deposition, sediment-dwelling biota could be exposed at the SL-III level with corresponding low risk; soil invertebrates, plants, and the American robin at the SL-II level with corresponding low risk, and all other ecological receptors at the SL-I level with 

corresponding negligible risk. For Railcar Scenarios with rain, the frequency of exposure of any ecological receptor is negligible and all risks would be negligible. Exposures within this negligible risk range could be SL-IV (sediment-dwelling biota and soil invertebrates), 

SL-III (plants), and SL-II (American robin, aquatic biota, and short-tailed shrew). Note that, in all transportation scenarios, aquatic biota, the short-tailed shrew, the great blue heron, and the red-tailed hawk have negligible predicted ecological risk.

Environmental

justicef

None No disproportionately 

high and adverse 

impacts. Potential 

transportation routes 

are adjacent to 

identified minority 

and/or low-income 

populations; 

transportation 

accidents are 

predicted to pose a 

negligible-to-low risk 

to human health.

No disproportionately 

high and adverse 

impacts. Potential 

transportation routes 

are adjacent to 

identified minority 

and/or low-income 

populations; 

transportation 

accidents are 

predicted to pose a 

negligible-to-low risk 

to human health.

None No disproportionately 

high and adverse 

impacts. Potential 

transportation routes 

are adjacent to 

identified minority 

and/or low-income 

populations; 

transportation 

accidents are 

predicted to pose a 

negligible-to-low risk 

to human health.

No disproportionately 

high and adverse 

impacts. Potential 

transportation routes 

are adjacent to 

identified minority 

populations; 

transportation 

accidents are 

predicted to pose a 

negligible-to-low risk 

to human health.

No disproportionately 

high and adverse 

impacts. Potential 

transportation routes 

are near 

identified minority 

populations; 

transportation 

accidents are 

predicted to pose a 

negligible-to-low risk 

to human health.

None None None None

a Risk is an assessment that is a function of the frequency of an event and the magnitude of its potential impact. See Appendix D, Section D.3.1, of this draft SEIS, for detailed discussion on the qualitative (i.e., negligible, low, moderate, and high) risk assessment.

b Consequences are presented by SLs (Severity Levels), with SL-I representing negligible-to-very-low consequences and SL-IV representing the most severe consequences. SLs are defined in Appendix D, Section D.3.1, of this draft SEIS.

c The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table; see Chapter 4 and Appendix D for more details. Truck Scenarios 1 and 2 are defined in Appendix D, Section D.2.2, of this draft SEIS.

d Annual fatalities for truck or rail transportation are due to mechanical impacts only and represent the predicted annual average occurrence of an accident involving a fatality over the 40-year analysis period of this environmental impact statement. 

e Potential transportation impacts by rail to GJDS or WIPP Vicinity Section 10 or 35 would involve intermodal transportation: rail transport to Grand Junction/WIPP, transfer from rail to truck, and truck transport to GJDS/WIPP Vicinity Section 10 or 35.

f Population data have been updated per 2010 census data. The January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement was based on 2000 census data. See Appendix E.

Note: Various mercury storage locations, many of which are undetermined, would be involved under the No Action Alternative; therefore, these locations are not presented in the above table. Section 2.6 presents a discussion comparing the potential environmental consequences of the No Action Alternative against those of the action 

alternatives.

Key: <=less than; GJDS=Grand Junction Disposal Site; Hanford=Hanford Site; INL=Idaho National Laboratory; INTEC=Idaho Nuclear Technology and Engineering Center; KCP=Kansas City Plant; RWMC=Radioactive Waste Management Complex; SRS=Savannah River Site; WCS=Waste Control Specialists, LLC, site; 

WIPP=Waste Isolation Pilot Plant.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

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Facility Description, Alternatives, and Comparison of Environmental Consequences

2–21

2.6.1 Summary of Environmental Consequences

This section summarizes the potential impacts on resources under the draft SEIS alternatives. Detailed 

descriptions and in-depth discussions of impacts on resources are provided in Chapter 4 of this 

draft SEIS. This draft SEIS evaluates the impacts on resource areas of the transportation, receipt, and 

long-term storage of mercury at a designated facility, including construction of the facility. Impacts for 

the action alternatives other than the WIPP Vicinity reference locations are summarized in the 

January 2011 Mercury Storage EIS Chapter 2, and a detailed discussion is presented in Chapter 4.

As described in Section 2.2.2, a new mercury storage facility(ies) could be built in a modular fashion by 

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

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

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

constructed in a modular fashion, impacts would be spread over a longer period and would occur at 

different times; however, the peak of these impacts would be less.

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

would be stored as a commodity to the extent allowed by law. Some mercury would likely be considered 

waste and would be stored in accordance with law. Such storage would not necessarily occur at the sites 

identified as potential sources of excess mercury. This storage service might be provided by a 

commercial waste management company or companies. In brief, such facilities could vary in location, 

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

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

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

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

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

environmental consequences under the No Action Alternative is provided in Chapter 4 of the 

January 2011 Mercury Storage EIS.

On January 1, 2013, the prohibition on the export of mercury went into effect pursuant to the Mercury 

Export Ban Act of 2008. As of March 1, 2013, five waste management companies have notified DOE of 

their intent to accumulate and store excess mercury at RCRA-permitted facilities in accordance with 

Section 5(g)(2)(b) of the Act. The companies and storage locations that have submitted notifications 

are (1) Chemical Waste Management, Inc., at its facility in Emelle, Alabama; (2) Clean Harbors 

Environmental Services, Inc., at its facility in Wichita, Kansas; (3) EQ Detroit, Inc., at its facility in 

Detroit, Michigan; (4) Veolia ES Technical Solutions, L.L.C., at its facility in Port Washington, 

Wisconsin; and (5) Waste Management Mercury Waste, Inc., at its facility in Union Grove, Wisconsin.7 

All of these companies have certified that they will ship the excess elemental mercury to a 

DOE-designated facility(ies), when such a facility(ies) is operational and ready to accept the mercury

(Clean Harbors 2012; EQ Detroit 2013; Veolia 2013; WM and Chemical 2012).

 

7 The listing of companies by name is for informational purposes only and does not imply or suggest an endorsement by DOE. 

Until such time that DOE has designated a facility(ies) and is ready to accept mercury for long-term management and storage, 

similar notifications may be received by DOE from other waste management companies.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–22

2.6.1.1 Land Use and Visual Resources

For the WIPP Vicinity reference locations, the required land disturbance for the construction of a mercury 

storage facility would be approximately 3.1 hectares (7.6 acres). Additionally, the low profile of a longterm mercury storage building, if it were to be constructed, would have minimal impacts on visual 

resources and would not change the U.S. Bureau of Land Management visual resource management 

classifications.

As discussed in Chapter 4, Section 4.2.1, and Chapter 5, Section 5.2, land administered by the 

U.S. Bureau of Land Management at WIPP Vicinity Section 10 or WIPP Vicinity Section 35, both 

located outside the WIPP LWB, used for construction and operations of a long-term management and 

storage facility for elemental mercury would be withdrawn from all forms of entry, appropriation, and 

disposal under the public land laws and reserved for the purposes of operating a mercury storage facility

pursuant to the Federal Land Policy and Management Act of 1976. Potash mining in the region 

surrounding WIPP, including an existing lease for future underground mining operations in Section 10, 

may influence the ability to site a mercury storage facility due to the potential for increased risk of land 

subsidence.

Land at WIPP Vicinity Section 20 inside the WIPP LWB used for construction and operations of a longterm management and storage facility for elemental mercury would be subject to the provisions of the 

WIPP LWA (P.L. 102-579) and may require Federal legislation.

2.6.1.2 Geology, Soils, and Geologic Hazards

Construction of a new storage facility would expose surficial soils for a duration of up to 6 months. 

These activities would disturb up to 3.1 hectares (7.6 acres) at a depth less than 60 centimeters (24 inches) 

for the installation of a reinforced-concrete slab and asphalt-covered lots on a compacted gravel base. 

Some trenching may be required below 60 centimeters (24 inches) for the installation of utilities or 

concrete footers. Adherence to best management practices for erosion and sediment control would be 

implemented during periods of construction to mitigate impacts due to soil erosion and loss. Geologic 

resources would include approximately 4,755 cubic meters (6,220 cubic yards) of concrete and 

3,875 cubic meters (5,070 cubic yards) of crushed stone. These resources are commonly available, and 

the quantities are relatively small for a construction project and would not impact regional supplies.

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

particularly for the WIPP Vicinity Section 10 and WIPP Vicinity Section 35 candidate sites.

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

and the surrounding area. The predicted peak ground acceleration from a seismic event with an annual 

probability of occurrence of once in 2,500 years for the WIPP Vicinity reference locations is 0.08 g. A

qualitative description of predicted damage for such an event is slight damage to ordinary structures and 

no damage to properly designed and constructed buildings. The final design for construction of a new 

facility or modification to existing buildings would take seismic risk into consideration to protect the 

public, workers, and the environment from potential adverse effects of a significant seismic event. 

Therefore, facilities built in an area of higher seismic risk could involve additional design and 

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

2.6.1.3 Water Resources

Ground-disturbing activities performed involving the construction of a new mercury storage facility 

would be conducted with best management practices in place. Appropriate permits would be obtained 

and a stormwater pollution prevention plan and soil erosion and sediment controls would be implemented 

to minimize potential water quality impacts. Construction of a new mercury storage facility would 
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–23

require approximately 1,270,000 liters (336,000 gallons) of water over the 6-month construction period 

for dust suppression and for potable and sanitary needs.

During operation of a mercury storage facility, best management practices for storage of mercury would 

be employed to prevent spills and releases of mercury into the environment, including the use of spill 

trays under mercury containers, spill containment features, and regular inspections in accordance with 

RCRA regulations. Operation of a mercury storage facility under all action alternatives would require 

88,500 liters (23,375 gallons) of water per year for potable and sanitary needs.

2.6.1.4 Meteorology, Air Quality, and Noise

As discussed in Chapter 4, meteorological risks associated with tornadoes, hurricanes, or floods are 

bounded by earthquake scenario risks. Seismic risks have been previously discussed in Section 2.6.1.2.

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

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

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

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

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

existing buildings for mercury storage would be negligible.

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

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

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

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

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

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

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

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

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

of mercury is expected to occur in 2013, the first year of facility operation. The frequency of truck and/or 

rail shipments is expected to decrease over time. Maximum air emissions from transporting the mercury 

would occur under the Hanford 200-West Area alternative, as evaluated in the January 2011 Mercury 

Storage EIS (DOE 2011); expected emissions are directly proportional to the number of miles required to 

transport the mercury to the facility. Truck transport to Hanford is predicted to yield the highest 

concentrations of carbon monoxide, nitrogen dioxide, volatile organic compounds, particulate matter, and 

carbon dioxide, and rail transport to Hanford is predicted to yield the highest concentrations of sulfur 

dioxide. As discussed in the January 2011 Mercury Storage EIS, transport of mercury would require up 

to approximately 170,000 truck miles or 56,000 rail miles in its first year of operation under the Hanford 

200-West Area alternative.

Carbon dioxide is a compound associated with global climate change. Peak annual carbon dioxide 

emissions generated from construction of a new facility at one of the WIPP Vicinity reference locations 

would be approximately 259 metric tons (286 tons). The second highest year of carbon dioxide emissions 

would be during the first year the mercury is transported by truck to the site, when emissions would be 

approximately 258 metric tons (285 tons) per year. Transportation by rail would result in less air 

emissions than for truck transportation. Comparing these values with the 26.4 billion metric tons 

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

fuel use annually from 2000 through 2005 and U.S. carbon dioxide annual emissions of 5.98 billion

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

dioxide from implementation of the action at any of the WIPP Vicinity reference locations would have a 

negligible effect on the global climate.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–24

Short-term noise impacts at the WIPP Vicinity reference locations 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 construction noise 

would occur during normal working hours and only for a short period of time, the impacts are expected to 

be negligible. Operational activities associated with the long-term storage of mercury would not result in 

a measureable increase in noise above background levels. The receipt of mercury shipments by truck or 

rail during normal working hours would also not result in a significant increase in noise above current 

vehicular or rail activity.

2.6.1.5 Ecological Resources

Construction of a new facility may impact some areas that have not previously been disturbed, although 

none of these areas contain critical habitat or protected plant or animal species. Terrestrial habitats

present within the WIPP Vicinity reference locations include desert grassland and short-grass prairie 

ecosystems. None of the alternatives proposed are expected to adversely impact wetlands or aquatic 

species. No threatened or endangered species are known or expected to occur within areas proposed 

under any of the alternatives. However, DOE would consult immediately with the U.S. Fish and Wildlife 

Service, as well as the New Mexico Department of Game and Fish, in the event that a listed species is 

identified within the proposed mercury storage area. Therefore, construction of a mercury storage facility 

at any of the WIPP Vicinity reference locations is not expected to adversely affect any ecological 

resources.

2.6.1.6 Cultural and Paleontological Resources

The land in the vicinity of WIPP has been determined to represent a potentially significant contributor of 

cultural resources. The majority of the WIPP Vicinity reference locations have not been examined for the 

presence of cultural resources; however, some surveys have been conducted. There are no known cultural 

or paleontological resources existing on WIPP Vicinity Section 10 or WIPP Vicinity Section 20. Of the 

seven cultural resource sites found on WIPP Vicinity Section 35, one is currently recommended as being 

potentially eligible for listing on the National Register of Historic Places. Also, construction of a new 

storage facility at any of the WIPP Vicinity reference locations is not expected to have an impact on 

American Indian resources. If potential historic features are identified during construction, appropriate 

consultations with the New Mexico State Historic Preservation Officer would be initiated to properly 

manage the discovery site.

2.6.1.7 Site Infrastructure

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

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

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

electricity, fuel, and water supplies. The frequency of mercury shipments is projected to be very small 

compared with baseline truck and rail traffic; therefore, existing road and rail systems would be adequate 

for supporting the transfer of mercury. However, direct rail shipments to WIPP Vicinity Section 10 and 

WIPP Vicinity Section 35 would not be possible; this mode of transportation would require rail transport 

to the WIPP facility, transfer of mercury to trucks, and a short truck transport of mercury to the 

DOE facility in Section 10 or 35.

Construction of a new facility is projected to require 193,000 liters (51,000 gallons) of diesel fuel and 

1,270,000 liters (336,000 gallons) of water over a 6-month construction period. Electricity would be 

supplied by a diesel-fired generator. Water and fuel would be delivered by tanker truck as needed. 

Therefore, construction of a new facility would have negligible impacts at any of the sites because the 

existing infrastructure would not be used to supply any of the necessary utility resources.
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–25

Annual operation of a mercury storage facility is projected to require 253 megawatt-hours of electricity, 

606 liters (160 gallons) of diesel fuel, and 88,500 liters (23,400 gallons) of water. Diesel fuel would be 

delivered to the site as needed to meet demand and would not impact existing infrastructure. For WIPP 

Vicinity Section 10 and WIPP Vicinity Section 35, minor infrastructure upgrades would be necessary to 

provide water and sanitary service. For WIPP Vicinity Section 20, minor infrastructure upgrades would 

be required to connect water and sanitary systems to existing WIPP infrastructure. In each location, 

moderate upgrades would be required to provide connections to electrical service. Operation of a 

mercury storage facility would have negligible impacts on the capacities of available infrastructure.

2.6.1.8 Waste Management

Construction of a new facility is projected to generate approximately 270 cubic meters (355 yards) of 

nonhazardous solid waste construction debris and 9,850 liters (2,600 gallons) of sanitary liquid waste. 

These volumes are comparable to a typical construction site and are expected to have negligible impacts 

on regional facilities.

The operation of a mercury storage facility is expected to generate a total of 910 drums (208 liters 

[55 gallons] each) of hazardous waste and 2,360,000 liters (623,000 gallons) of sanitary liquid waste over 

the 40-year period of analysis. On an annual basis, this yields approximately 23 drums of hazardous 

waste and 58,960 liters (15,575 gallons) of sanitary liquid waste. The hazardous waste, consisting of 

cleaning rags, personal protective equipment, spill response materials, and mercury vapor filters, would 

be shipped for offsite treatment and/or disposal in a licensed facility. Since the mercury storage facility

would not involve any treatment or processing of mercury, the rate of hazardous waste generation would 

remain very low. Existing sanitary systems at all of the alternative sites can meet the projected sanitary 

liquid waste volume.

Therefore, waste management impacts for construction and operation of a mercury storage facility at any

WIPP Vicinity reference location would be negligible.

2.6.1.9 Occupational and Public Health and Safety

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

members of the public. The impacts are similar for any of the WIPP Vicinity reference locations. The 

analysis considers various scenarios. Scenarios were developed for the following activities: (1) normal 

operations, (2) facility accidents, (3) transportation, and (4) intentional destructive acts (IDAs). The 

respective sections of Chapter 4 discuss human health consequences and associated risk analysis in detail 

under each of the WIPP Vicinity reference locations. This summary presents the most conservative 

(i.e., maximum) consequence, and thus risk, to a human receptor that could be expected to occur under 

certain scenarios. Consequences are presented in terms of severity levels (SLs), with SL-I representing 

negligible-to-very-low consequences and SL-IV representing the most severe consequences. SLs are 

defined for various receptor scenarios in Appendix D, Section D.3.1. Overall risk is a function of the 

frequency at which an event might occur and the probable severity of the event.

Normal Operations

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

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

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

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

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

contamination of a container. Under all alternatives, the consequences to involved workers, noninvolved 

workers, or members of the public are predicted to be negligible (i.e., SL-I), with negligible associated 

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

2–26

Facility Accidents

Facility accidents are exposure scenarios initiated by failure of engineered systems or caused by human 

error. Accidents could include mercury spills inside or outside the storage building. Of the various 

scenarios considered, those with the highest probability of occurring would likely be (1) a container or 

pallet drop during transfer from the transport vehicle to permanent storage (e.g., by forklift), (2) a collapse 

of storage racks, (3) an earthquake event, or (4) a flood event. The consequences and risks of the flood 

event are bounded by the earthquake analysis.

The consequences and associated risks to human health receptors would be identical under all action 

alternatives evaluated and are summarized in Table 2–3.

Table 2–3. Summary of Consequences and Risks

from All Onsite Mercury Spill Scenarios

Scenario

Consequence

(Risk)

Spills Inside Building

Involved worker SL-I to SL-II

(Negligible to low)

Noninvolved workera SL-I

(Negligible)

Member of the public SL-I

(Negligible)

Spills Outside Building

Involved worker SL-I to SL-II

(Negligible to low)

Noninvolved workera SL-I to SL-II

(Negligible to low)

Member of the public SL-I

(Negligible)

a A noninvolved worker is nearby (outside the building) but still on site.

Key: SL=severity level.

Transportation

Transportation consequences under all alternatives are a function of the methods of transportation 

(i.e., truck or rail), the number of miles traveled, and the nature of the accident. The distance between the 

WIPP Vicinity reference locations (approximately 5.6 kilometers [3.5 miles]) is considered a negligible 

difference in transportation risk calculations. Table 2–4 presents the number of kilometers that would be 

traveled and the annual frequency of fatal accidents that are projected to occur.

In addition to fatal accidents due to mechanical impact, exposure to mercury from spills that could result 

from transportation accidents could impact human health. Table 2–5 summarizes the consequences and 

associated risk to human health receptors under certain scenarios.
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–27

Table 2–4. Transportation Kilometers and Frequency Analysis

for Transport Accidents

Mode of 

Transport

WIPP Vicinity Reference Locations 

(Sections 10, 20, and 35)

Kilometers

(miles)

Annual Frequency

of Fatal Accidentsa

Truckb 3,007,088

(1,868,523)

1.0×10-3

Railc 685,920

(426,212)

1.7×10-4

a Fatality caused by mechanical impact, not exposure to mercury.

b The greatest transportation impact under either Truck Scenario 1 or 2 is presented 

in this table. Truck Scenarios 1 and 2 are defined in Appendix D, Section D.2.2.

c WIPP Vicinity Sections 10 and 35 do not have direct rail access. Potential 

transportation impacts by rail would involve intermodal transportation: rail 

transport to WIPP, transfer from rail to truck, and truck transport to WIPP 

Vicinity Section 10 or 35.

Key: WIPP=Waste Isolation Pilot Plant.

Table 2–5. Summary of Transportation Consequences and Risks to Human Receptors

Scenario

Trucka Railcar

Consequence

(Risk)

Spill onto ground SL-I to SL-IV

(Negligible)

SL-I to SL-IV

(Negligible)

Spill into waterb SL-I to SL-II

(Negligible to low)

SL-I to SL-II

(Negligible to low)

Spill with fire – inhalation SL-III

(Negligible) or

SL-II

(Low)

SL-III

(Negligible) or

SL-II

(Low)

Spill with fire – dry deposition

onto soil

SL-I

(Negligible)

SL-I

(Negligible)

Spill with fire – wet deposition

onto soil

SL-I

(Negligible)

SL-I

(Negligible)

Consumption of 

methylmercury in fish – dry 

deposition onto water

Potentially above SL-I/SL-II 

(Negligible)

Potentially above SL-I/SL-II 

(Negligible to low)

Consumption of 

methylmercury in fish – wet 

deposition onto water

Potentially above SL-I/SL-II 

(Negligible)

Potentially above SL-I/SL-II 

(Negligible)

a The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table. Truck 

Scenarios 1 and 2 are defined in Appendix D, Section D.2.2.

b Due to a large range of uncertainty, estimating the consequences of this scenario is difficult.

Key: SL=severity level.

Intentional Destructive Acts

The most plausible scenario for an IDA in the context of mercury would be the deliberate crash of a 

gasoline tanker into a truck or railcar carrying mercury with a subsequent fire. Other scenarios involving 

an attack on a storage facility other than during unloading of a truck or railcar are judged to be less likely 

because of the distribution of mercury within the facility, security measures, and facility design features 

that would mitigate the impacts of mercury releases into the environment. Therefore, the IDA analysis 

summarized below applies to all the action alternatives similarly.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–28

Human exposure pathways from an IDA include atmospheric inhalation and dry or wet deposition. The 

most severe case for atmospheric exposure pathways would be at the SL-III level and could occur 

between approximately 100 meters (330 feet) and 5.6 kilometers (3.5 miles) downwind of the release 

point. The deposition benchmark of 180 milligrams per kilogram in soil would not be exceeded 

anywhere. However, sufficient mercury could be deposited on lakes such that, in the event of rain, 

methylmercury might accumulate to potentially hazardous levels in fish up to 10 kilometers (6.2 miles) 

downwind for national average consumption rates, 20 kilometers (12.4 miles) for the average subsistence 

fisherman, and 40 kilometers (24.8 miles) for the 95th percentile subsistence fisherman.

2.6.1.10 Ecological Impacts

Consequences and, hence, risks to ecological receptors would be negligible except if there is a fire. The 

frequency of onsite fires sufficient to cause a release of mercury at any of the storage sites is predicted to 

be negligible; consequently, the ecological risk would also be negligible. Ecological risk would be 

evident only in the event of a transportation accident with fire; thus, the ecological risk would be similar 

under all action alternatives. Table 2–6 presents the ecological risk to various sensitive receptors.

Table 2–6. Summary of Consequences and Risk to Ecological Receptors –

Transportation Accident with Pallet Fire

Receptor

Trucka Railcar

Deposition Pathway

Dry Wet Dry Wet

Consequence

(Risk)

Sediment-dwelling biota SL-II

(Low)

SL-IV

(Moderate)

SL-III

(Low)

b

(Negligible)

Soil invertebrates SL-II

(Low)

SL-III

(Low)

SL-II

(Low)

b

(Negligible)

Plants SL-II

(Low)

SL-II

(Low)

SL-II

(Low)

b

(Negligible)

American robin SL-I

(Negligible)

SL-II

(Low)

SL-II

(Low)

b

(Negligible)

River otter SL-I

(Negligible)

SL-II

(Low)

SL-I

(Negligible)

b

(Negligible)

Aquatic biota SL-I

(Negligible)

SL-I

(Negligible)

SL-I

(Negligible)

b

(Negligible)

Short-tailed shrew SL-I

(Negligible)

SL-I

(Negligible)

SL-I

(Negligible)

b

(Negligible)

Great blue heron SL-I

(Negligible)

SL-I

(Negligible)

SL-I

(Negligible)

b

(Negligible)

Red-tailed hawk SL-I

(Negligible)

SL-I

(Negligible)

SL-I

(Negligible)

b

(Negligible)

a The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table. Truck 

Scenarios 1 and 2 are defined in Appendix D, Section D.2.2.

b The predicted frequency of railcar crashes with pallet fires in the presence of rain is negligible; therefore, the 

associated risks would be negligible and consequences are not presented in the table.

Key: SL=severity level.
Facility Description, Alternatives, and Comparison of Environmental Consequences

2–29

2.6.1.11 Socioeconomics

Construction of a new facility is projected to require the employment of approximately 18 people for 

approximately 6 months. Operation of the mercury storage 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 then approximately 5 to 6 individuals for the remainder of the analysis 

period. The projected employment for construction and operations and associated indirect employment 

would have a negligible impact on socioeconomic conditions (i.e., overall employment and population 

trends) for the WIPP vicinity region.

During construction of a new storage facility, it is estimated that construction-related transportation would 

average 45 vehicle trips per day. During operations, the greatest impact would be during the first 2 years,

when it is estimated that approximately 11 vehicles a day would be associated with facility employment. 

At the peak of operations, it is estimated that up to 79 shipments of mercury would be made in a year. 

The minimal increase in the number of vehicle trips projected during construction or operations of a 

mercury facility over baseline vehicular traffic would be negligible for any of the WIPP Vicinity 

reference locations.

2.6.1.12 Environmental Justice

Analysis of census population block groups within a region of influence (ROI), defined as a 16-kilometer 

(10-mile) radius surrounding a site, did not identify minority or low-income communities near the WIPP 

Vicinity reference locations. Therefore, no disproportionately high and adverse impacts or risks are 

expected to occur for any population group, including the minority and low-income population groups 

near these candidate sites.

Five census blocks are located within 16 kilometers (10 miles) of WIPP Vicinity Section 10. Three 

census blocks are located within 16 kilometers of WIPP Vicinity Section 20. Three census blocks are 

located within 16 kilometers of WIPP Vicinity Section 35. None of the census blocks within the ROI for 

the WIPP Vicinity reference locations contain a high minority or low-income population. Therefore, no 

disproportionately high and adverse effects on minority or low-income populations are expected.

2.6.2 Summary of Cumulative Impacts

The Council on Environmental Quality regulations implementing the National Environmental Policy Act 

define cumulative effects as “impacts on the environment which result from the action when added to 

other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or 

non-Federal) or person undertakes such other actions” (40 CFR 1508.7). Actions that may contribute to 

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

individuals that are within the ROIs of the actions considered in this draft SEIS. The ROIs used in the 

cumulative impacts analysis were generally assumed to be within a 16-kilometer (10-mile) radius of the

WIPP Vicinity reference locations.

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

range from none, to negligible, to minor. Those resource areas that were predicted to be impacted in a 

minor way were evaluated for their potential to contribute to cumulative impacts within the ROI. Where 

impacts were predicted not to occur or were negligible, cumulative impacts were not analyzed since there 

would be either no or only a very small incremental increase in impacts on the resources within the ROI. 

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

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

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

evaluation of land use, air quality, infrastructure, and ecological resources. It was determined that the 

potential contribution to cumulative impacts on those resource areas evaluated would be negligible. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–30

Table 2–7 summarizes the potential contributions to cumulative impacts for these resource areas. 

Chapter 4, Section 4.4, provides a detailed discussion of the cumulative impacts assessment and potential 

contributing actions that were considered. A discussion of global commons impacts is also provided in 

Section 4.2.4.

Table 2–7. Summary of Cumulative Impacts Assessment

Alternative Resource Area Cumulative Impacts

Contribution of 

Proposed Action to 

Cumulative Impacts

WIPP Vicinity 

Reference Locations 

(Sections 10, 20, and 35)

Land Use Rural area; limited development 

expected within the ROI. GTCC 

waste disposal facility could require 

up to 44 hectares (110 acres) if 

WIPP vicinity is selected; one of the 

locations being considered is WIPP 

Vicinity Section 35. A mercury 

storage facility and GTCC waste 

disposal facility could be located 

within the 260-hectare (640-acre) 

area that comprises Section 35 

without interference with operations

or compromising the safety and 

security of these facilities. Also 

present within the ROI are a number 

of oil wells and underground potash 

mines located in the vicinity of 

WIPP, including an existing potash 

mine lease on WIPP Vicinity 

Section 10 and one oil well in WIPP 

Vicinity Section 35. No substantial 

cumulative impacts on land use.

Negligible

Air Quality No exceedance of air quality 

standards.

Negligible

Infrastructure No substantial cumulative impacts 

on regional power consumption or 

impact on existing capacities. A 

maximum of 79 shipments would be 

made to the proposed mercury 

storage facility during the peak year 

of operations and is not expected to 

appreciably increase demands on 

transportation systems near the 

WIPP Vicinity reference locations.

Negligible

Ecological 

Resources

No substantial cumulative impacts 

on terrestrial resources or loss of 

habitat due to disturbance of land 

(see Land Use above).

Negligible

Key: GTCC=greater-than-Class C; ROI=region of influence; WIPP=Waste Isolation Pilot Plant.
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–31

2.7 REFERENCES 

Chlorine Institute, 2008, Eleventh Annual Report to EPA, Chlor-Alkali Industry Mercury Use and 

Emissions in the United States for the Year 2007, Arlington, Virginia, September 26.

Clean Harbors (Clean Harbors Environmental Services), 2012, Wichita, Kansas, personal communication 

(letter) to S. Chu, U.S. Department of Energy, Washington, DC, December 4. 

Clinkenbeard, J., 2009, California Department of Conservation, California Geological Survey, personal 

communication (telephone conversation) with K. Prindiville, Science Applications International 

Corporation, Richland, Washington, “California Gold Mining,” November 18. 

DLA (Defense Logistics Agency), 2004, Final Mercury Management Environmental Impact Statement, 

Defense National Stockpile Center, Fort Belvoir, Virginia, March. 

DLA (Defense Logistics Agency), 2012, Mercury Management Environmental Impact Statement –

Mercury Consolidation Update, Strategic Materials, accessed through https://www.dnsc.dla.mil/eis/, 

October. 

DOE (U.S. Department of Energy), 2009, U.S. Department of Energy Interim Guidance on Packaging, 

Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, Office of 

Environmental Management, Washington, DC, November 13. 

DOE (U.S. Department of Energy), 2011, Final Long-Term Management and Storage of Elemental 

Mercury Environmental Impact Statement, DOE/EIS-0423, Office of Environmental Management, 

Washington, DC, January. 

EPA (U.S. Environmental Protection Agency), 2005, Global Mercury Commodity Market Study, Office 

of Pollution Prevention and Toxics and Office of Solid Waste and Emergency Response, Washington, 

DC, May. 

EPA (U.S. Environmental Protection Agency), 2007, Mercury Storage Cost Estimates, Office of 

Pollution Prevention and Toxics and Office of Solid Waste and Emergency Response, Washington, DC, 

November. 

EQ Detroit (EQ Detroit, Inc.), 2013, Detroit, Michigan, personal communication (letter) to S. Chu, 

U.S. Department of Energy, Washington, DC, February 20. 

IPCC (Intergovernmental Panel on Climate Change), 2007, A Report of Working Group I of the 

Intergovernmental Panel on Climate Change, Summary for Policymakers, Cambridge University Press, 

Cambridge, United Kingdom, and New York, New York. 

Krahulec, K., 2009, Utah Geologic Survey, Energy and Minerals Group, personal communication 

(telephone conversation) with K. Prindiville, Science Applications International Corporation, Richland, 

Washington, “Utah Gold Mining,” November 16. 

Mannon, J., 2009, Cripple Creek and Victor Gold Mining Company, Victor, Colorado, personal 

communication (telephone conversation) with K. Prindiville, Science Applications International 

Corporation, Richland, Washington, “Byproduct Mercury from Cresson Gold Mine,” November 17. 

Miller, G., and G. Jones, 2005, Mercury and Modern Gold Mining in Nevada, Final Report to 

U.S. Environmental Protection Agency Region IX, University of Nevada, Department of Natural 

Resources and Environmental Sciences, Reno, Nevada, October 25. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

2–32

NMA (National Mining Association), 2009, Gold Production by State, accessed through 

http://www.nma.org/pdf/g_production.pdf, August 11.

Pavey, R., 2012, “Olin Prepares for Mercury Free Future After 47 Years,” The Augusta Chronicle, 

July 15.

Szumigala, D., 2009, Alaska Division of Geological and Geophysical Surveys, personal communication 

(telephone conversation) with K. Prindiville, Science Applications International Corporation, Richland, 

Washington, “Alaska Gold Mining,” September 4.

Townsend, B., 2009, South Dakota Department of Environment and Natural Resources, Minerals and 

Mining Program, personal communication (telephone conversation) with K. Prindiville, Science 

Applications International Corporation, Richland, Washington, “South Dakota Gold Mining,” 

November 13.

USGS (U.S. Geological Survey), 2009, Mineral Commodity Summaries 2009, Reston, Virginia, 

January 29.

Veolia (Veolia Environmental Services), 2013, Port Washington, Wisconsin, personal communication 

(letter) to S. Chu, U.S. Department of Energy, Washington, DC, January 3.

WM and Chemical (WM Mercury Waste, Inc., and Chemical Waste Management, Inc.), 2012, personal 

communication (letter) to S. Chu, U.S. Department of Energy, Washington, DC, August 1.

Code of Federal Regulations

40 CFR 1502.14(a), Council on Environmental Quality, “Environmental Impact Statement: Alternatives 

Including the Proposed Action.”

40 CFR 1508.7, Council on Environmental Quality, “Cumulative Impact.”

49 CFR 172.101, Pipeline and Hazardous Materials Safety Administration, U.S. Department of 

Transportation, “Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, 

Emergency Response Information, Training Requirements, and Security Plans: Purpose and Use of 

Hazardous Materials Table.”

Federal Register

69 FR 23733, Defense Logistics Agency, Defense National Stockpile Center, 2004, “Record of Decision 

for the Final Mercury Management Environmental Impact Statement,” April 30.

74 FR 31723, U.S. Department of Energy, 2009, “Notice of Intent to Prepare an Environmental Impact 

Statement for the Long-Term Management and Storage of Elemental Mercury,” July 2.

United States Code

42 U.S.C. 6901 et seq., Resource Conservation and Recovery Act of 1976.

U.S. Public Laws

P.L. 102-579, The Waste Isolation Pilot Plant Land Withdrawal Act.

P.L. 104-201, Waste Isolation Pilot Plant Land Withdrawal Act Amendments of 1996.
CHAPTER 3 

AFFECTED ENVIRONMENT

3–1

CHAPTER 3 

AFFECTED ENVIRONMENT 

Chapter 3 presents a description of the affected environment for the Waste Isolation Pilot Plant (WIPP) Vicinity 

reference locations considered in this Draft Long-Term Management and Storage of Elemental Mercury

Supplemental Environmental Impact Statement (Draft Mercury Storage SEIS), which provides the context for 

understanding the environmental consequences of the action alternatives described in Chapter 4. Chapter 3 of 

the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

(Mercury Storage EIS) (DOE 2011a) presents a description of the affected environment for the other seven 

candidate sites being considered for the long-term management and storage of elemental mercury. As discussed 

in Appendix E, Section E.4, environmental documentation that has become available since publication of the 

January 2011 Mercury Storage EIS has been reviewed, and with the exception of the socioeconomics and 

environmental justice resource areas, no significant changes to the affected environment as presented in 

Chapter 3 of the January 2011 Mercury Storage EIS were found to be necessary. This Draft Mercury Storage 

SEIS includes updates to the socioeconomics and environmental justice resource areas to incorporate 2010 

decennial census information that was not available at the time the January 2011 Mercury Storage EIS was 

published. The updates to the affected environment descriptions for the socioeconomics and environmental 

justice resource areas are presented in Appendix B and Appendix E of this Draft Mercury Storage SEIS. A 

significant portion of this chapter is based on the affected environment descriptions for the WIPP vicinity as 

presented in Chapter 4, Section 4.2, and Chapter 11, Section 11.1, of the Draft Environmental Impact Statement 

for the Disposal of Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC-Like Waste

(Draft GTCC EIS) (DOE 2011b). Text adopted and incorporated into this supplemental environmental impact 

statement (SEIS), in part or in whole, from the Draft GTCC EIS has been reviewed, updated, or amended as 

necessary for the specific candidate sites analyzed in this SEIS (i.e., Sections 10, 20, and 35) and to support the 

impacts analysis for these sites presented in Chapter 4.

3.1 APPROACH TO DEFINING THE AFFECTED ENVIRONMENT 

This chapter describes the environment at the Waste Isolation Pilot Plant (WIPP) Vicinity reference 

locations that could be affected through implementing the alternatives evaluated in this Draft Long-Term 

Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement (Draft

Mercury Storage SEIS). As described in Chapter 2, the WIPP Vicinity reference locations consist of three 

candidate sites: Section 10 outside the WIPP land withdrawal boundary (LWB); Section 20 inside the 

WIPP LWB; and Section 35 outside the WIPP LWB (see Figures 3–1 and 3–2). For the WIPP Vicinity 

reference locations, the affected environment is described for the following resource areas: land use and 

visual resources; geology, soils, and geologic hazards; water resources; meteorology, air quality, and 

noise; ecological resources; cultural and paleontological resources; infrastructure; waste management; 

occupational and public health and safety; socioeconomics; and environmental justice. This supplemental 

environmental impact statement (SEIS) provides a description of the existing environment of the WIPP 

site as a whole, as well as that of the WIPP Vicinity reference locations within which the proposed action 

would take place. 

The U.S. Department of Energy (DOE) evaluated the environmental impacts of managing and storing 

elemental mercury1 within defined regions of influence (ROIs). These ROIs are specific to the resource 

area evaluated; encompass geographic areas within which any meaningful impact is expected to occur; 

and can include the areas within which the proposed action would take place, the sites as a whole, or 

nearby or distant offsite areas. For example, impacts on historic resources were evaluated at specific 

facility locations within each site, whereas human health risks to the general public were assessed for an 

area within a 16-kilometer (10-mile) radius of the facility location. Brief descriptions of the ROIs for 

each resource area are given in Table 3–1; more specific information on methodology and the definition 

of ROIs is presented in Appendix B of the January 2011 Long-Term Management and Storage of 

Elemental Mercury Environmental Impact Statement (Mercury Storage EIS). Appendix F, Table F–1,

lists the scientific names of plants and animals used in this chapter, grouped by common name in 

alphabetical order. 

 

1

 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this SEIS. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

3–2

Table 3–1. General Regions of Influence for the Affected Environment 

Environmental Resource Area Region of Influence

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

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

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

groundwater

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

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

and surrounding areas, including transportation corridors where proposed 

activities might increase noise levels

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

Cultural and paleontological resources The project location and adjacent areas

Infrastructure The project location, the site, and local areas supporting the site

Waste management The waste management facilities located on the site

Occupational and public health 

and safety

The site, offsite areas, and the transportation corridors

Socioeconomics The counties where approximately 90 percent of site employees reside

Environmental justice The area within 16 kilometers of the site and the area within 3.2 kilometers of 

the site as a subset of the 16-kilometer area

Note: To convert kilometers to miles, multiply by 0.6214. 

The existing environmental conditions for each resource area were determined from information provided 

in previous environmental impact statements and environmental studies, other government reports and 

databases, and relevant laws and regulations. 

3.2 WASTE ISOLATION PILOT PLANT SITE AND VICINITY 

3.2.1 Land Use and Visual Resources 

3.2.1.1 Land Use 

WIPP is the Nation’s only underground repository for the permanent disposal of defense-generated 

transuranic (TRU) waste. The WIPP site is located in Eddy County in the Chihuahuan Desert of 

southeastern New Mexico (see Figure 3–1). The site is about 42 kilometers (26 miles) east of Carlsbad in 

a region known as Los Medaños, a relatively flat, sparsely inhabited plateau with little surface water. The 

WIPP site encompasses approximately 41 square kilometers (16 square miles) under the jurisdiction of 

DOE pursuant to the Waste Isolation Pilot Plant Land Withdrawal Act (WIPP LWA) (P.L. 102-579). The 

WIPP LWA transferred responsibility of the WIPP withdrawal area from the Secretary of the Interior to 

the Secretary of Energy. The land is permanently withdrawn from all forms of entry, appropriation, and 

disposal under the public land laws and is reserved for uses associated with the purposes of WIPP. 
Affected Environment 

3–3

Source: DOE 2006a.

Figure 3–1. Location of the Waste Isolation Pilot Plant Site in

Eddy County, New Mexico 

The WIPP site covers 16 sections (each section is 2.6 square kilometers [1 square mile or 640 acres]) of 

Federal land in Township 22 South, Range 31 East, and is divided into four areas under DOE control 

(see Figure 3–2). A chain-link fence surrounds the innermost Property Protection Area, which includes 

all of the surface facilities. Surrounding this inner area is the Exclusive Use Area, which is surrounded by 

a barbed-wire fence. Enclosing these two areas is the Off-Limits Area, which is unfenced to allow 

livestock grazing but, like the other two areas, is patrolled and posted against trespassing or other land 

uses. Beyond the Off-Limits Area, the land is managed under the traditional public land use concept of 

multiple uses, but mining and drilling are restricted. The boundary of WIPP was set to extend at least 

1.6 kilometers (1 mile) beyond any underground development (Sandia 2008). WIPP includes all of the 

necessary surface and subsurface facilities to manage waste handling and disposal operations. 
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Figure 3–2. Four Property Areas Within the 

Waste Isolation Pilot Plant Boundary 

There are four property areas adopted within the 4,146-hectare (10,240-acre) WIPP site (see 

Figure 3–2): 

Property Protection Area. This is the 14-hectare (35-acre) interior core of the site that is 

surrounded by a chain-link fence. It is under tight, 24-hour security. 

Exclusive Use Area. This 112-hectare (277-acre) area is surrounded by a barbed-wire fence and 

is restricted for the exclusive use of DOE and its contractors and subcontractors in support of the 

project. The area is marked with “no trespassing” signs and is patrolled by WIPP security 

personnel. 

Off-Limits Area. This is a 588-hectare (1,454-acre) area where unauthorized entry and 

introduction of weapons and/or dangerous materials are prohibited. Prohibition signs are posted 

at consistent intervals along its perimeter. Unless they pose a threat to security, safety, or the 

environmental quality of the WIPP site, grazing and public thoroughfares can occur in this area. 

This area is patrolled by WIPP security personnel to prevent unauthorized activities or use. 

WIPP Site (Land Withdrawal) Boundary. This 4,146-hectare (10,240-acre) area delineates the 

perimeter of the WIPP site. The LWB was established to extend at least 1.6 kilometers (1.0 mile) 

beyond any WIPP underground development. 
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Except for the facilities within the boundaries of the posted 112-hectare (277-acre) Exclusive Use Area, 

surface land use remains largely unchanged from its pre-1992 multiple land use designation. Those who 

wish to conduct activities that might affect lands that are under the jurisdiction of WIPP but outside the 

Property Protection Area are required by the WIPP Land Management Plan (LMP) to prepare a land use 

request (DOE 2007). Mining and drilling for reasons other than to support WIPP activities are prohibited 

within the WIPP site except at two 129-hectare (320-acre) tracts of land within the WIPP LWB that are 

leased for oil and gas development. These adjoining lease tracts occupy Section 31 in the far southwest 

corner of the WIPP site (DOE 1993). 

Extensive potash mining occurs in the vicinity of WIPP outside of the LWB, particularly to the north, 

west, and southwest of the WIPP site. Potash leases in the vicinity of WIPP are held by two commercial 

mining companies: Mosaic Potash Carlsbad, Inc. and Intrepid Potash NW, LLC. In 2010, several potash 

leases were reassigned to Western Ag-Minerals, Inc. (a wholly owned subsidiary of Mosaic Potash 

Carlsbad, Inc.) from Yates Petroleum Corporation, which include Township 22 South, Range 31 East, 

Section 10 for future exploration (Rutley 2012). 

Portions of two grazing allotments administered by the U.S. Bureau of Land Management (BLM) occur 

within the WIPP site boundary (DOE 1993). Nearly 5.2 percent of one 22,493-hectare (55,581-acre) 

allotment overlaps the WIPP site but does not include areas that are posted “no trespassing.” About 

9.5 percent of the other 31,393-hectare (77,574-acre) grazing allotment overlaps the remainder of the 

WIPP site boundary, including the Exclusive Use Area that is posted against trespassing and fenced to 

prevent grazing (DOE 1993). 

The WIPP LMP focuses on management protocols for the following: administration of the plan, 

environmental compliance, wildlife, cultural resources, grazing, recreation, energy and mineral sources, 

land and realty, reclamation, security, industrial safety, emergency management, maintenance, and work 

control (DOE 1993). 

Most land in the vicinity of the WIPP site is managed by BLM. Land use in the surrounding area 

includes livestock grazing, potash mining, oil and gas development, and recreation (e.g., hunting, 

camping, hiking, off-highway vehicle operation, horseback riding, and bird watching) (DOE 1993, 2007). 

The dominant land use in the WIPP vicinity is cattle grazing; smaller amounts of land are used for oil and 

gas extraction and potash mining. There is an existing oil well on WIPP Vicinity Section 35, adjacent to 

and southeast of the WIPP LWB. There is little privately owned land near WIPP, although two ranches 

are located within 16 kilometers (10 miles) of the site (DOE 1997). The only agricultural land within 

48 kilometers (30 miles) is irrigated farmland along the Pecos River, near the municipalities of Carlsbad 

and Loving. No dry-land farming takes place near WIPP (DOE 1980). 

The region is popular for recreation, providing opportunities for hunting, camping, hiking, and bird 

watching. The area has a very low population density, with approximately 25 residents at various 

locations within 16 kilometers (10 miles) of the site. The nearest community is the village of Loving, 

New Mexico, which is located 29 kilometers (18 miles) west-southwest of WIPP. This community has an 

estimated population of about 1,300 residents. 

3.2.1.2 Visual Resources 

BLM is responsible for managing public lands identified for multiple uses. BLM is also responsible for 

ensuring that the scenic values of these public lands are considered before allowing uses that may have 

negative visual impacts. BLM accomplishes this through its Visual Resource Management (VRM) 

system, a system that involves inventorying scenic values and establishing management objectives for 

those values through the area resource management planning process. VRM classes are based on relative 

visual ratings of BLM-inventoried lands. Each class describes the different degree of modification 

allowed to the basic elements of the landscape. 
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The developed areas at WIPP and in the vicinity of WIPP occur within a BLM VRM Class IV zone. The 

objective of VRM Class IV is to provide for management activities that require major modifications of 

the existing character of the landscape. The level of change to the characteristic landscape can be high. 

These management activities may dominate the view and be the major focus of viewer attention. 

However, every attempt should be made to minimize the impact of these activities through careful 

location; minimal disturbance; and repeating the basic landscape elements of color, form, line, and 

texture. 

3.2.2 Geology, Soils, and Geologic Hazards 

The geologic resources at the WIPP Vicinity reference locations are described with respect to geology, 

soils, and geologic hazards. Geologic resources are consolidated or unconsolidated earth material, 

including ore and aggregate material, fossil fuels, and significant landforms. Soil resources are the loose 

surface materials of the earth in which plants grow, usually consisting of disintegrated rock, organic 

matter, and soluble salts. Geologic hazards can include seismic activity, landslides, volcanic eruptions, 

and erosional processes. 

The WIPP Vicinity reference locations occupy three 2.6-square-kilometer (1-square-mile) or 260-hectare 

(640-acre) parcels: Section 10, which is outside and immediately adjacent to the northeast of the WIPP 

LWB; Section 20, which is inside the WIPP LWB; and Section 35, which is outside and immediately 

adjacent to the southeast of the WIPP LWB. Given the close proximity of the WIPP Vicinity reference 

locations to the WIPP repository site, the regional geologic setting and stratigraphy at the reference 

locations can be inferred from the extensive data on the WIPP site that are summarized below. 

3.2.2.1 Geology 

WIPP is located in southeastern New Mexico, in the Pecos Valley Section of the Great Plains 

physiographic province (see Figure 3–3). The terrain throughout the province varies from plains and 

lowlands to rugged canyons. In the immediate vicinity of WIPP, numerous small mounds formed by 

wind-blown sand characterize the land surface. A 410,000- to 510,000-year-old layer enriched in calcium 

carbonate material, the Mescalero caliche, is typically present beneath the surface layer of sand. The 

caliche layer overlies a 600,000-year-old volcanic ash layer (DOE 1996a). The Mescalero caliche can be 

found over large portions of the Pecos River drainage area and is generally considered to be an indicator 

of surface stability (DOE 1980). 

A high plains desert environment characterizes the area. Because of the seasonal nature of the rainfall, 

most surface drainage is intermittent. The Pecos River, 16 kilometers (10 miles) southwest of the WIPP 

boundary, is a perennial river and the master drainage for the region. A natural divide lies between the 

Pecos River and the WIPP site. As a result, the Pecos drainage system does not currently affect the site. 

Local surface drainage features include Nash Draw and the San Simon Swale. 

The topography of the Pecos Valley section ranges from flat plains and lowlands to rugged canyon lands, 

with elevations of 1,830 meters (6,000 feet) mean sea level (MSL) in the northwest, 1,520 meters 

(5,000 feet) MSL in the north, 1,220 meters (4,000 feet) MSL in the east, and 610 meters (2,000 feet) 

MSL in the south. The valley has an uneven rock floor, resulting from differential weathering of 

limestones, sandstones, shales, and gypsums. The Pecos Valley section is drained mainly by the Pecos 

River, the only perennial stream in the region. The Pecos drainage system flows to the southeast; its 

closest point is about 16 kilometers (10 miles) from the WIPP site. The Pecos River Valley shows 

characteristic lowland topography marked by widespread karst topography, with solution-subsidence 

features (e.g., sinkholes) resulting from dissolution of Permian rocks from the Ochoan Series 

(Mercer 1983; Powers et al. 1978). 
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Source: DOE 1997.

Figure 3–3. Location of the Waste Isolation Pilot Plant Site 

Within the Great Plains Province in 

Southeastern New Mexico 

The land surface of the WIPP site is hummocky, with numerous eolian sand ridges and dunes, and it 

slopes gently from an elevation of about 1,090 meters (3,570 feet) MSL at its eastern boundary to about 

990 meters (3,250 feet) MSL along its western boundary. An extensive layer of hard caliche (the 

Mescalero caliche) lies between the surficial sand deposits and the underlying Gatuña Formation. It 

ranges in age from about 510,000 years at its base to 410,000 years at the top (DOE 1997; Powers et 

al. 1978).

The topography across the WIPP Vicinity reference locations exhibits some broad valley forms, possibly 

indicating areas of concentrated surface runoff and integrated drainages during prolonged rainfall events. 

Sand dunes are present, but are likely thinner and more uniform than local dune fields. Calcrete 

exposures appear as heavily vegetated semicircular features on aerial photos, particularly in a portion of 

WIPP Vicinity Section 35. These are thought to represent intradune areas that focus water drainage and 

enhance vegetation growth, causing degradation of the underlying calcrete and creating slight topographic 

depressions. These surface features, however, have no relationship to dissolution or subsidence of deeper 

evaporite units. 

The WIPP site is located in the northern portion of the Delaware Basin, a structural basin underlying 

present-day southeastern New Mexico and western Texas that contains a thick sequence of sandstones, 

shales, carbonates, and evaporites. The WIPP repository is located in the Salado Formation, a massive 

bedded salt unit of Permian age, ranging from about 350 to 1,160 meters (1,150 to 3,800 feet) below the 
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ground surface near the WIPP site. The WIPP disposal horizon is 655 meters (2,150 feet) below the 

ground surface. The sediments accumulated during the Permian period represent the thickest portion of 

the sequence in the northern Delaware Basin and are divided into four series (see Figure 3–4). From 

oldest to youngest, these series are the Wolfcampian, Leonardian, Guadalupian, and Ochoan. The 

Ochoan Series consists of extensive evaporite deposits; the series is divided into four formations. From 

oldest to youngest, these formations are Castile, Salado (the lower part of which contains the WIPP 

repository), Rustler, and Dewey Lake. 

Source: EPA 2006.

Figure 3–4. Stratigraphic Column for the 

Waste Isolation Pilot Plant Site and 

Surrounding Area 

The following sections describe the geologic formations important to understanding the long-term 

performance of WIPP, starting with the host rock for the WIPP repository (the Salado Formation), the 

formations below the Salado (the Castile and Bell Canyon Formations), and the formations above the 

Salado (the Rustler, Dewey Lake, Santa Rosa, and Gatuña Formations). 

Salado Formation. The Permian Salado Formation is a massive bedded salt formation that is 

predominantly halite (sodium chloride) and is thick and laterally extensive. DOE selected the 

Salado Formation as the site of the WIPP repository for several geologically related reasons 

(DOE 1980, 1990): (1) the Salado halite units have very low permeability to fluid flow, which 

impedes groundwater flow into and out of the repository; (2) the Salado is regionally widespread; 

(3) the Salado includes continuous halite beds without complicated structure; (4) the Salado is 
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deep with little potential for dissolution; (5) the Salado is near enough to the surface that access is 

reasonable; and (6) the Salado is largely free of mobile groundwater, when compared with 

existing mines and other potential repository sites. 

The Salado Formation ranges in thickness from approximately 540 to 646 meters 

(1,770 to 2,120 feet). The Salado is composed of four members. From oldest to youngest, they 

are the Lower Member, the McNutt Potash member, the Vaca Triste Sandstone, and the Upper 

Member. The WIPP repository is located in the Lower Member and in the thickest part of the 

Salado Formation. 

Although the most common Delaware Basin evaporite mineral is halite, there are less soluble 

layers or interbeds (dominantly anhydrite, polyhalite, and claystone) and more soluble admixtures 

(for example, sylvite, glauberite, kainite) within the formation. These other minerals result in 

chemical and physical properties of the bulk Salado that are different from those of pure halite 

layers contained within it. In particular, the McNutt is locally explored and mined for 

potassium-bearing minerals of economic interest. Within the Delaware Basin, a system is used 

for numbering the more significant sulfate beds within the Salado, designating these beds as 

marker beds (MBs) from MB100 (near the top of the formation) to MB144 (near the base). The 

system is generally used within the Carlsbad Potash District, as well as at and around the WIPP 

site. The repository is located between MB139 and MB138 (see Figure 3–4) while the potash in 

the McNutt is generally located between MB116 and MB126. 

Castile Formation. The Permian Castile Formation directly underlies the Salado Formation and 

typically consists of three relatively thick anhydrite/carbonate units and two thick halite units in 

the WIPP area. It is approximately 390 meters (1,280 feet) thick and is present from 

approximately 810 to 1,200 meters (2,660 to 3,940 feet) below ground surface (bgs) at the site, 

which is approximately 155 meters (509 feet) below the level of the repository. The more brittle 

anhydrite units of the Castile are locally fractured, and the fracture zones are relatively permeable 

and act as zones for accumulation of brine trapped in the Castile since the Permian period 

(DOE 1997). 

Bell Canyon Formation. The Permian Bell Canyon Formation underlies the Castile Formation 

and is composed of a layered sequence of sandstones, shales, siltstones, and limestones near the 

WIPP site. It is also the uppermost target of hydrocarbon exploration in the local area. It is 

approximately 350 meters (1,150 feet) thick and is present from approximately 1,200 to 

1,550 meters (3,940 to 5,090 feet) bgs at the site. The top of the Bell Canyon is approximately 

545 meters (1,790 feet) below the level of the repository. 

Rustler Formation. The upper Permian Rustler Formation lies above the WIPP repository and 

directly overlies the Salado Formation. It is divided into five members. From the base of the 

Rustler Formation, these members are the Los Medaños, the Culebra Dolomite, the Tamarisk, the 

Magenta Dolomite, and the Forty-niner. The Culebra consists of locally argillaceous and 

arenaceous, well to poorly indurated dolomicrite with numerous cavities (vugs), fractures, and 

silty zones. The Magenta is a silty, gypsiferous, laminated dolomite. The other three members 

contain layers of claystone or mudstone sandwiched between layers of anhydrite/gypsum. In the 

southeast corner of the WIPP site and farther to the east, halite beds are also present in the 

non-dolomite members of the Rustler Formation. The Rustler Formation is approximately 

94 meters (310 feet) thick and is present from approximately 164 to 257 meters (538 to 843 feet) 

bgs at the WIPP site. The top of the formation dips to the east-northeast across much of the 

WIPP site (Powers 2009). Its base is approximately 400 meters (1,312 feet) above the level of 

the repository. The Rustler Formation contains the most extensive water-bearing units in the 

WIPP site area. 
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Dewey Lake Formation. The Dewey Lake Formation overlies the Rustler Formation at WIPP 

and is Permo-Triassic in age. It consists largely of reddish-brown siltstones and claystones, with 

lesser amounts of very fine to fine sandstone. Sediments are typically cemented with sulfates 

(gypsum and anhydrite). The formation generally thickens across the WIPP site from west to east 

to a maximum thickness of more than 183 meters (600 feet) in the eastern part of the Delaware 

Basin east of the site. At the WIPP site, it is approximately 146 meters (480 feet) thick and 

occurs from approximately 16 to 162 meters (52 to 532 feet) bgs. The base of the Dewey Lake is 

approximately 495 meters (1,623 feet) above the level of the repository. The groundwater from 

the Dewey Lake Formation is primarily used for livestock watering and irrigation (Powers 2009). 

Santa Rosa Formation. The Triassic Santa Rosa Formation, the basal formation of the Dockum 

Group, overlies the Dewey Lake Formation and consists of light reddish-brown sandstones and 

conglomerates, siltstone, and claystone. The Santa Rosa Formation is several hundred feet thick 

east of the WIPP site, but it thins to the west. It is about 12 meters (40 feet) thick near the center 

of the WIPP site and is absent in the western third of the site as a result of erosion. The Santa 

Rosa is used as a source of groundwater to the east of the WIPP site (DOE 1996a; Powers 2009). 

Gatuña Formation. The Miocene-Pleistocene Gatuña Formation overlies the Santa Rosa 

Formation and is somewhat similar in lithology and color, although the Gatuña is also 

characterized by a wide range of lithologies (coarse conglomerates to gypsum-bearing 

claystones). The upper Gatuña contains a 600,000-year-old volcanic ash layer (DOE 1996a). 

The formation is generally less than 15 meters (50 feet) thick across the WIPP site and occurs at 

depths of 4.6 to 6.1 meters (15 to 20 feet) bgs. The Gatuña Formation is in turn overlain by the 

Mescalero caliche and surficial sand deposits (Powers 2009). 

Mescalero Caliche and Other Surface Deposits. The Mescalero caliche is a pedogenic 

carbonate unit that is continuous across the WIPP site, with thicknesses of up to 1.8 meters 

(6 feet). The unit is exposed in places but may also underlie dune sand (to depths of up to 

6.1 meters [20 feet]). The continuity of the Mescalero is disrupted by erosion and solution and by 

plant growth. Funnel-like features called “flowerpots” can be seen throughout areas where the 

unit is well-exposed; mesquite and creosote bush root systems are found in some of these 

features. The presence of the Mescalero caliche indicates general stability across the land 

surface, since it took about 100,000 years to form and developed about 500,000 years ago 

(Powers 2009). 

Above the Mescalero is the Berino soil, a thick, reddish, semi-consolidated sand containing little 

carbonate, ranging in thickness from centimeters (inches) to 0.30 to 0.61 meters (1 to 2 feet). The 

Berino soil is likely derived from wind-blown material modified by pedogenic processes. It is 

often found in flowerpots and as a thin soil veneer on the surface of the Mescalero caliche 

(Powers 2009). 

Geologic resources in the vicinity of WIPP include oil and gas and potash. Prior to 1970, most 

commercially related drilling in the WIPP area targeted shallow oil (1,200 to 1,400 meters [3,940 to 

4,590 feet] in depth) in the Bell Canyon Formation. From 1970 to the mid-1980s, most drilling near 

WIPP focused on gas exploration in the deeper Morrow and Atoka Formations (approximately 

4,000 meters [13,100 feet]). During the late 1980s and early 1990s, commercial oil was discovered in the 

Permian Cherry Canyon and Brushy Canyon Formations, which lie below the Bell Canyon Formation 

described above. These discoveries were made at locations adjacent to the eastern and northeastern 

boundary of WIPP, at a depth of approximately 2,100 to 2,400 meters (6,890 to 7,870 feet). These 

formations are the primary exploration and development targets in the Permian Basin, one of the most 

actively explored areas in the United States (Broadhead et al. 1995). 
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Oil and gas exploration drilling activities in the New Mexico portion of the Permian Basin (in which the 

WIPP site is located) have fluctuated considerably since 1997. As many as 57 rigs were working in the 

basin in late 1997, but the maximum number dropped to about 15 in 2000. The maximum rig count 

increased to approximately 65 in 2001, dropped to the low 30s in 2002, and then steadily increased to 

approximately 60 in 2005. It is assumed that hydrocarbon exploration drilling activities in the region of 

the WIPP site will continue for the foreseeable future (Crossroads 2005). At present, there are no oil 

wells located on WIPP Vicinity Section 10 or Section 20; however, one oil well is located on WIPP 

Vicinity Section 35. 

Within an area extending 1 mile from the WIPP LWB, in-place oil reserves are estimated at 

35.3 million barrels and in-place gas reserves are estimated at 28,780,000 cubic feet in the Morrow 

and Atoka Formations and in shallower Bell Canyon and Cherry Canyon Formation reservoirs 

(Broadhead et al. 1995). 

Bedded potash (a mixture of several soluble oxide, sulfate, and chloride compounds containing 

potassium, used chiefly in fertilizers) was discovered in Eddy County, New Mexico, in 1925. By 1944, 

New Mexico was the largest domestic potash producer, representing 85 percent of consumption. 

Development continued through the 1950s and 1960s, reversed in the 1970s, and had declined by 

the mid-1990s. 

Since 1997, potash mining activities in the region of the WIPP site have continued. Approximately 

1,500,000 tons of potash were produced in 1997, and production has slowly declined since that time. 

In 2005, approximately 1,000,000 tons were produced (NMEMNRD 2006). 

The majority of actively mined and potential resources of potash ore are found in the 37-meter-thick 

(120-foot-thick) McNutt Member of the Salado Formation, which is the host for 11 ore zones. 

3.2.2.2 Soils 

Soils of the region have developed mainly from Quaternary and Permian parent material. Parent material 

from the Quaternary System is represented by alluvial deposits of major streams, dune sand, and other 

surface deposits. These are mostly loamy and sandy sediments containing some coarse fragments. Parent 

material from the Permian System is represented by limestone, dolomite, and gypsum bedrock. Soils of 

the region have developed in a semiarid, continental climate with abundant sunshine, low relative 

humidity, erratic and low rainfall, and a wide variation in daily and seasonal temperatures. Subsoil colors 

are normally light brown to reddish brown but are often mixed with lime accumulations (caliche) that 

result from limited, erratic rainfall and insufficient leaching. 

A soil association is a landscape with a distinctive pattern of soil types (series). It normally consists of 

one or more major soils and at least one minor soil. There are three soil associations within 

8.3 kilometers (5 miles) of the WIPP site: the Kermit-Berino, the Simona-Pajarito, and the 

Pyote-Maljamar-Kermit. Of these three associations, only the Kermit-Berino soil series has been mapped 

across the WIPP site by Chugg et al. (1952, Sheet No. 113). These are sandy soils developed on eolian 

material. The Kermit-Berino soils include active dune areas. The Berino soil has a sandy A horizon; the 

B horizons include more argillaceous material and weak-to-moderate soil structures. A and B horizons 

are described as noncalcareous, and the underlying C horizon is commonly caliche. Bachman 

(1980, p. 44) interpreted the Berino soil as a paleosol that is a remnant B horizon of the underlying 

Mescalero. Rosholt and McKinney (1980, Table 5) applied uranium-trend methods to samples of the 

Berino soil from the WIPP site area and interpreted the age of formation of the Berino soil as 

330,000 ± 75,000 years. 

Generally, the Berino Series, which covers about 50 percent of the site, consists of deep, noncalcareous, 

yellow-red to red sandy soils that developed from wind-worked material of mixed origin. These soils are 
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described as undulating to hummocky and gently sloping (0 to 3 percent slopes). The soils are the most 

extensive of the deep, sandy soils in the Eddy County area. Berino soils are subject to continuing wind 

and water erosion. If the vegetative cover is seriously depleted, the water-erosion potential is slight, but 

the wind-erosion potential is very high. These soils are particularly sensitive to wind erosion in the 

months of March, April, and May, when rainfall is minimal and winds are highest. 

The Kermit Series consists of deep, light-colored, noncalcareous, excessively drained loose sands, 

typically yellowish-red fine sand. The surface is undulating to billowy (from 0 to 3 percent slopes) and 

consists mostly of stabilized sand dunes. Kermit soils are slightly to moderately eroded. Permeability is 

very high, and, if vegetative cover is removed, the water-erosion potential is slight, but the wind-erosion 

potential is very high. 

The WIPP Vicinity reference locations are situated on Quaternary age alluvium, playa lake deposits, and 

semi-stabilized and active dune sands. These deposits compose the majority of surface exposures and 

most of the shallow subsurface sediments in the WIPP site region. Just below these deposits is a fairly 

continuous mantle of caliche (called the Mescalero). The Mescalero caliche is a well-lithified alluvial 

deposit of chalky, finely crystalline limestone that is fairly continuous across the WIPP site and can be up 

to 1.8 meters (6 feet) thick. It thickens and is more indurated to the east of the site. Overlying the 

Mescalero is the Berino soil, a thick, reddish, semi-consolidated sand containing little carbonate, ranging 

in thickness from centimeters (inches) to 0.3 to 0.6 meters (1 to 2 feet). 

No natural factors within the WIPP Vicinity reference locations that would affect the engineering aspects 

of slope stability or subsidence have been reported. The presence of the Mescalero caliche is generally 

considered to be an indicator of surface stability (DOE 1997). Liquefaction of saturated sediments is a 

potential hazard during or immediately following large earthquakes. Whether soils will liquefy depends 

on several factors, including the magnitude of the earthquake, peak ground velocity, susceptibility of soils 

to liquefaction, and depth to groundwater. There are no saturated sediments in the area of the WIPP land 

withdrawal. 

3.2.2.3 Geologic Hazards 

No surface displacement or faulting younger than early Permian has been reported, indicating that 

tectonic movement since then, if any, has not been noteworthy. No mapped Quaternary (last 1.9 million 

years) or Holocene (last 10,000 years) faults exist closer to the site than the western escarpment of the 

Guadalupe Mountains, about 100 kilometers (60 miles) to the west-southwest (DOE 1997). 

The strongest earthquake on record within 290 kilometers (180 miles) of the site was the Valentine, 

Texas, earthquake of August 16, 1931 (DOE 1997), with an estimated Richter magnitude of 6.4. A 

Modified Mercalli Intensity of V was estimated for this earthquake’s ground shaking at WIPP. At 

Intensity V, ground shaking is felt by nearly everyone; a few instances of cracked plaster occur; and 

unstable objects are overturned. This is the strongest ground-shaking intensity known for the WIPP site. 

From November 1974 to August 2006, the largest earthquake within 300 kilometers (184 miles) of the 

WIPP site occurred on April 14, 1995 (based on a search of the U.S. Geological Survey [USGS] National 

Earthquake Information Center data). It was located 32 kilometers (20 miles) east-southeast of Alpine, 

Texas (approximately 240 kilometers [150 miles] south of the site), and was assigned a Richter magnitude 

of 5.7. It was the largest event within 300 kilometers (184 miles) of the site since the Valentine, Texas, 

earthquake, and had no effect on any structures at WIPP (Sanford et al. 1995). From 1974 to 2006, 

recorded earthquakes within a 300-kilometer (184-mile) radius of WIPP have ranged from magnitude 2.3 

to 5.7 (USGS 2010). 

Earthquake-produced ground motion is expressed in units of percent g (force of acceleration relative to 

that of Earth’s gravity). For the purposes of comparing the relative seismic hazard based on predicated 
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earthquake-produced ground motions among the various mercury storage candidate sites evaluated in the 

January 2011 Mercury Storage EIS (DOE 2011a) and this SEIS, the latest probabilistic peak (horizontal) 

ground acceleration (PGA) data from USGS are used. The PGA values cited are based on a 2 percent 

probability of exceedance in 50 years. This corresponds to an annual probability (chance) of occurrence 

of about 1 in 2,500. For the WIPP site, the calculated PGA is approximately 0.08 g (USGS 2012).

Potash mining in the vicinity of WIPP outside of the LWB is subterranean and uses both room-and-pillar 

and modified long wall production techniques. In March 2012, WIPP registered a seismic event 

associated with a large mine roof fall approximately 8.7 kilometers (5.4 miles) west-southwest of the 

WIPP facility with an estimated Richter magnitude of 2.9 to 3.2. Although events of this significance are 

not usually expected, mining in the vicinity of the WIPP site would be expected to cause some gradual 

subsidence over time relative to the mining techniques used (Rutley 2012).

The nearest potentially active volcanoes are in the Zuni-Bandera volcanic field in northwestern 

New Mexico. Volcanoes in this area are of the cinder cone (basaltic) type. They have not been active in 

at least 2,000 years and are considered to be dormant (NMBGMR 2008).

3.2.3 Water Resources

3.2.3.1 Surface Water

There are no natural surface-water bodies within the boundaries of the WIPP site. Widespread eolian 

(sand dune) deposits that are of Holocene age or older indicate that little surface drainage has developed 

within and around the site. The nearest significant surface-water body, Laguna Grande de la Sal, is 

located about 13 kilometers (8 miles) west-southwest of the site in Nash Draw,2 where there are shallow 

brine ponds. Small, manmade earthen livestock watering holes (called “tanks”) occur around the WIPP 

site, particularly to the south, but are not hydrologically connected to the formations overlying the WIPP 

repository. The watering holes are constructed to hold runoff and not allow it to infiltrate. There may be 

minor leakage through the unsaturated zone beneath them that eventually reaches a Dewey Lake water 

table. The predominant use of surface water in the region is for livestock watering and irrigation 

(DOE 1997, 2008a; Powers 2009).

The Pecos River is the only perennial stream in the region (see Figure 3–1). The river flows to the southsoutheast and is, at its closest point (the Malaga Bend), about 16 kilometers (10 miles) west of the WIPP 

site. The WIPP site is within the Pecos River drainage basin, although a natural divide lies between the 

Pecos River and the WIPP site. As a result, the Pecos drainage system does not currently affect the site. 

At least 90 percent of the mean annual precipitation at the WIPP site (30 centimeters [12 inches]) is lost 

by evapotranspiration, although precipitation rates may exceed evapotranspiration during intense 

thunderstorms that produce runoff and percolation. The average annual streamflow of the Pecos River at 

Malaga Bend (from 1938 through 2008) was 4.6 cubic meters per second (164.5 cubic feet per second) 

(USGS 2009). The maximum recorded streamflow (with a monthly mean of 119 cubic meters per second

[4,200 cubic feet per second]) occurred in August 1996 at the Malaga Bend; its maximum elevation was 

90 meters (300 feet) below the surface elevation of the WIPP site (DOE 1997, 2006; USGS 2009).

Surface-water samples collected along the Pecos River and from various tanks around the WIPP site are 

routinely analyzed for radionuclides, including uranium, plutonium, americium, potassium-40, cobalt-60, 

cesium-137, and strontium-90. In 2007, uranium and plutonium concentrations were compared to 

baseline levels observed between 1985 and 1989. The highest concentrations of uranium-234, 

uranium-235, and uranium-238 detected in the Pecos River and surrounding tanks were found to fall 

 

2 Nash Draw is a surface depression, about 32 kilometers (20 miles) long and 8 to 19 kilometers (5 to 12 miles) wide, located 

about 6 kilometers (3.7 miles) to the west of the WIPP site (Lorenz 2006). The valley is notable for its karst features and for 

exposures of some of the geologic units underlying the WIPP region.
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within the ranges of baseline levels. Plutonium-238, plutonium-239, and plutonium-240 were not 

detected. Americium-241 was found in water (at 1.14 × 10-3 becquerels per liter) from Tut tank, 

northwest of the border of the WIPP site, but no baseline data were available for comparison. The only 

other radionuclide detected in 2007 that exceeded its baseline range was potassium-40, found in a sample 

from an onsite sewage lagoon at 148 becquerels per liter (the baseline value for potassium-40 was 

76 becquerels per liter) (DOE 2008a). Again in 2011, potassium-40 was the only radionuclide found to 

exceed baseline ranges in a water sample taken from the same onsite sewage lagoon at 235 becquerels per 

liter. Sewage contains significant potassium from human excretions and potassium-40 makes up 

0.012 percent of all naturally occurring potassium. Since potassium-40 was not detected in any other 

surface-water sample, sewage is the likely source (DOE 2012). 

3.2.3.2 Groundwater 

Several water-bearing zones have been identified and extensively studied at and near the WIPP site. 

Limited amounts of potable water are found in the middle Dewey Lake Formation and the overlying 

Triassic Dockum Group (Santa Rosa Sandstone) in the southern part within the WIPP LWB. Two 

water-bearing units in the Rustler Formation, the Culebra and Magenta Dolomite Members, produce 

brackish to saline water at the WIPP site and surrounding locations. Another very-low-transmissivity, 

saline water-bearing zone occurs along the contact between the Rustler and Salado Formations 

(DOE 2008a). Mercer (1983) reports no evidence of water in the Gatuña Formation or surficial materials 

at the WIPP site. Figure 3–5 shows the stratigraphic relationships of these aquifer units. 

Lower Water-Bearing Horizons (below Salado Formation). The term “water-bearing 

horizons” is used in this discussion because nothing below the Salado can properly be termed an 

aquifer. The Castile Formation is the basal unit of the Ochoan series and represents the oldest of 

the water-bearing units at the WIPP site. The formation is about 390 meters (1,280 feet) thick. It 

consists of three thick anhydrite units interbedded with halite and acts as an aquitard between the 

overlying Salado Formation and the underlying water-bearing sandstones, shales, and limestones 

of the Bell Canyon Formation (Guadalupian series). No regional groundwater flow system 

appears to be present in the Castile Formation in the WIPP site area. Fracturing within 

an anhydrite layer of the upper Castile has created isolated, high-permeability regions 

(brine reservoirs) that contain brine at higher-than-hydrostatic pressure (DOE 1996b, 1999, 

2008a; Popielak et al. 1983). 

Salado Formation. The Salado Formation is a regional aquiclude made up of massive halite 

beds. Estimated hydraulic conductivities range from 10-16 to 10-11 meters per second for impure 

halite intervals and from 10-13 to 10-10 meters per second in anhydrite (Beauheim and 

Roberts 2002; Roberts et al. 1999). Although the hydraulic conductivity of the Salado Formation 

is extremely low, it is not dry. Brine content within the Salado is estimated at 1–2 percent by 

weight, and thin clay seams have been observed to contain up to 25 percent brine by volume 

(DOE 1999). 

Occurrence of groundwater in the Salado Formation is restricted because halite does not have 

primary porosity, solution channels, or open fractures. No evidence of circulating water has been 

found in the unit; however, small trapped pockets of brine (e.g., in MB139, which is an anhydrite 

rather than a halite) and nonflammable gas have been found. Inflow of trapped brine into the 

repository excavation has been observed in boreholes and from “weeps,” which are localized 

brine seeps issuing from the surfaces of the repository walls, floors, and roofs. These flows are 

created when intact rock is disturbed by mining. The volumes of brine observed from these 

occurrences have been small, and flow into the repository ceased within 3 years of initial 

observation. 
Affected Environment 

3–15

Figure 3–5. Stratigraphy of Aquifer Units at the 

Waste Isolation Pilot Plant Site 

Upper Water-Bearing Horizons. Directly above the Salado Formation in Nash Draw is a zone 

of dissolution residue capable of transmitting water. The transmissivity of this interval, referred 

to as the “Rustler-Salado contact,” decreases from Nash Draw eastward to the WIPP site area. 

Small quantities of brine were found in this zone in WIPP site test holes (DOE 2008a). 

The 95-meter-thick (310-foot-thick) Rustler Formation, which directly overlies the Salado 

Formation, ranges in depth from 164 to 257 meters (538 to 843 feet) at the WIPP site. There are 

five members of the Rustler Formation. In ascending order, these members are the Los Medaños 

Member, Culebra Dolomite Member, Tamarisk Member, Magenta Dolomite Member, and 

Forty-niner Member. Only the Culebra and Magenta Dolomite Members have enough 

transmissivity to produce water to wells. The other three members act as aquitards (DOE 1996b).

The Culebra Dolomite Member of the Rustler Formation is composed predominantly of fractured, 

microcrystalline dolomite and ranges in thickness from 5.8 to 12.5 meters (19 to 41 feet) in the 

WIPP site region. It is the first significant water-bearing unit above the Salado Formation at the 

WIPP site. Regional flow of groundwater in the Culebra Dolomite is generally to the south. 

Because of its lateral continuity and high transmissivity (as high as 10-3 square meters per second 

[DOE 2008b]), it is considered to be the most likely pathway if contaminants were to be released 
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from the WIPP site in the event of a postulated future human intrusion. Estimates of hydraulic 

conductivity in the Culebra Dolomite vary widely, but in general, they decrease from 10-4 meters 

per second in Nash Draw to 10-14 meters per second east of the WIPP site (DOE 1999). These 

conductivity variations are believed to be controlled by the relative abundance of pore-filling 

cements, stress-relief fracturing, and fracturing related to dissolution of the upper Salado 

Formation rather than by primary depositional features of the unit. Porosities measured 

in core samples from the Culebra range from 0.03 to 0.30 (Kelley and Saulnier 1990; 

TerraTek, Inc. 1996). Although the dolomite matrix provides most of the unit’s storage capacity, 

fluid movement occurs mainly through fractures and vugs. Recent studies of the Culebra show 

that it is a heterogeneous system with anisotropic characteristics, suggesting variability of fracture 

orientations on a local scale, especially in the WIPP site area (DOE 2008a; Lorenz 2006). These 

studies support the interpretation that the Culebra Dolomite and other members of the Rustler 

Formation are unkarsted strata (DOE 2008b; Lorenz 2006).

The Magenta Dolomite Member of the Rustler Formation is above the Culebra Dolomite and is 

separated from it by the Tamarisk Member. The Magenta is about 8 meters (26 feet) thick and 

consists of fine-grained gypsiferous dolomite. The Magenta Dolomite is less transmissive 

(about 10-7 square meters per second [DOE 2008b]) than the Culebra Dolomite, having hydraulic 

conductivities one to two orders of magnitude less than those of the Culebra in most locations 

(from 10-9 to 10-3 meters per second). Like those of the Culebra Dolomite, its hydraulic 

conductivities increase to the west toward Nash Draw. The hydraulic gradient of the Magenta 

also increases toward the west, ranging from 0.003 to 0.0038 on the east side of the WIPP site 

to 0.0061 along its west side (DOE 1997, 1999). 

The reddish-brown fine sandstone, siltstone, and silty claystone of the Dewey Lake Red Beds 

Formation overlie the Rustler Formation. The formation is about 150 meters (490 feet) thick at 

the center of the WIPP site, thinning to the west. The upper portion of the Dewey Lake consists 

of a fairly thick (up to 80 meters [164 feet]) unsaturated zone. Just below this zone is a saturated 

zone perched above a cementation change from carbonate (above) to sulfate (below). The 

saturated zone, which makes up the middle portion of the Dewey Lake, occurs at depths of 

about 50 to 80 meters (164 to 262 feet). In this zone, water is transmitted through open fractures. 

Below it, fractures tend to be completely filled with gypsum (DOE 1999, 2008a). 

The Santa Rosa Formation thins from being 66 meters (217 feet) thick along the eastern WIPP 

site boundary to zero near the center of the WIPP site. Anthropogenic water has been found in 

the formation in the center part of the WIPP site. The Gatuña Formation unconformably 

overlies the Santa Rosa. It ranges in thickness from about 6 to 9 meters (19 to 31 feet) and 

consists of silt, sand, and clay, with deposits formed in localized depressions. Saturation in the 

Gatuña occurs in discontinuous perched zones. This water may also have an anthropogenic 

source (DOE 1999, 2008a). 

Groundwater samples from monitoring wells in the Culebra Member of the Rustler Formation have been 

characterized as saline to brine, with total dissolved solid concentrations ranging from 4,000 to 

360,000 milligrams per liter. Water from the Culebra has been classified as Class III water by 

U.S. Environmental Protection Agency (EPA) guidelines and is not acceptable for human consumption or 

for agricultural purposes (DOE 2007; Richey et al. 1985). 

Groundwater in the overlying Dewey Lake Formation is of better quality, with an average total dissolved 

solids value of 3,350 milligrams per liter. This water has been classified as Class II water by EPA 

guidelines and is suitable for livestock consumption (DOE 2007). 
Affected Environment 

3–17

Fujita Scale of Tornado Intensities

F0 Gale 18–32 meters per second (m/s)

40–72 miles per hour (mph)

F1 Moderate 33–50 m/s

73–112 mph

F2 Significant 51–70 m/s

113–157 mph

F3 Severe 71–92 m/s

158–206 mph

F4 Devastating 93–116 m/s

207–260 mph

F5 Incredible 117–142 m/s

261–318 mph

3.2.4 Meteorology, Air Quality, and Noise 

3.2.4.1 Meteorology and Air Quality 

Located in Eddy County in the Chihuahuan Desert of southeastern New Mexico, the regional climate 

around the WIPP site is semiarid, characterized by warm temperatures, low precipitation and humidity, 

and a high rate of evaporation (DOE 1997). 

In 2006, about 40 percent of the time, winds blew inclusively from the east-southeast to south-southeast, 

with the highest winds from the southeast (DOE 2007). Windspeeds categorized as calm (less than 

0.5 meters per second [1.1 miles per hour]) occurred less than 0.5 percent in 2006. Winds of 3.71 to 

6.30 meters per second (8.30 to 14.1 miles per hour) were the most prevalent, occurring about 36 percent 

of the time. 

For the 1986–2007 period, the annual average temperature at the WIPP site was 17.9 degrees Celsius ( C) 

(64.3 degrees Fahrenheit [ F]) (WRCC 2008). December was the coldest month, averaging 7.2 C 

(44.9 F) and ranging from –1.3 C to 15.6 C (29.6 F to 60.1 F), and July was the warmest month, 

averaging 28.4 C (83.2 F) and ranging from 20.6 C to 36.4 C (69.1 F to 97.5 F). For the same 

period, the highest temperatures reached 50.0 C (122 F) and the lowest reached –17.2 C (1 F). Days 

with a maximum temperature of higher than or equal to 32.2 C (90 F) occurred about one-third of the 

time, while those with a minimum temperature of less than or equal to 0 C (32 F) occurred about 

20 percent of the time. 

Annual precipitation at the WIPP site averages about 33.8 centimeters (13.32 inches) (WRCC 2008).

Precipitation is the highest in summer and tapers off markedly in winter. About 60 percent of the 

precipitation from June through September is in the form of high-intensity, short-duration thunderstorms, 

sometimes accompanied by hail (DOE 2004a). Rains are brief but occasionally intense and can result in 

flash flooding in arroyos and along the floodplains. Measurable snow is rare and, if it occurs, remains on 

the ground for only a short time. Light snow typically occurs from December to January, and the annual 

average snowfall in the area is about 2.3 centimeters (0.9 inches). 

Strong winds are common and can blow from any 

direction, creating potentially violent windstorms 

that carry large volumes of dust and sand 

(DOE 2004a). In late winter and spring, there are 

strong west winds and dust storms. On rare 

occasions, a tropical hurricane may cause heavy rain 

in eastern and central New Mexico as it moves 

inland from the western part of the Gulf of Mexico, 

but there is no record of serious wind damage from 

these storms (WRCC 2008). 

Tornadoes in the area surrounding the WIPP site, 

which is located on the edge of the tornado alley in 

the central United States, are common but less 

frequent and destructive than those in the tornado 

alley. For the period 1950–2008, 512 tornadoes were reported in New Mexico (an average of about 

9 tornadoes per year); they occurred mostly at lower elevations in eastern New Mexico near Texas 

(NCDC 2008). For the same period, a total of 52 tornadoes (an average of about 1 tornado per year) were 

reported in Eddy County, which includes the WIPP site. However, most tornadoes occurring in Eddy 

County were relatively weak (i.e., 49 were F0 or F1, and 3 were F2 on the Fujita tornado scale). No 

deaths and 29 injuries were associated with these tornadoes. 
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Both the State of New Mexico and the EPA have authority for regulating compliance with portions of the 

Clean Air Act Amendments. On the basis of an initial 1993 air emissions inventory, the WIPP site is not 

required to obtain Clean Air Act permits (DOE 2007). WIPP was required to obtain a New Mexico 

Air Quality Control Regulation 702 operating permit (recodified in 2001 as 20.2.72 New Mexico 

Administrative Code [NMAC], “Construction Permits”) for two backup diesel generators at the site 

in 1993. There have been no activities or modifications to the operating conditions of the diesel 

generators that would require reporting under the conditions of the permit in 2006. 

Annual emissions for major facility sources and total point and area sources for 2002 for criteria 

pollutants and volatile organic compounds (VOCs) in Eddy County, New Mexico, including the WIPP 

site, are presented in Table 3–2 (EPA 2008a). Data for 2002 are the most recent emission inventory data 

available on the EPA website (EPA 2009). Area sources consist of nonpoint and mobile sources. Point 

sources account for most total sulfur dioxide (SO2) and nitrogen dioxide (NO2) emissions in the county; 

SO2 is emitted equally from industrial fuel combustion and from petroleum and related industries, and 

NO2 is emitted mostly from industrial fuel combustion. For carbon monoxide (CO) and particulate matter 

with an aerodynamic diameter less than or equal to 10 micrometers (PM10), area sources account for most 

of total emissions in the county; for VOCs and particulate matter with an aerodynamic diameter less than 

or equal to 2.5 micrometers (PM2.5), emissions from area sources are higher than those from point 

sources. CO is emitted from on-road sources. PM10/PM2.5 are emitted from miscellaneous sources, and 

VOCs are omitted from many different activities, with the highest contribution coming from petroleum 

and related industries. 

Table 3–2. Annual Emissions of Criteria Pollutants and Volatile Organic Compounds 

from Selected Major Facilities and Total Point and Area Source Emissions in 

Eddy County Encompassing the Waste Isolation Pilot Plant Site 

Emission Category

Emission Rates (tons per year)a

SO2 NO2 CO VOCs PM10 PM2.5

Agave Gas Plant 2,099 2.0 0.6 20.2 0.0 0.0

Artesia Gas Plant 838 919 301 52.6 1.9 1.9

Empire Abo Plant 0.0 29.1 1.0 2.2 1,307 1,143

Indian Basin Gas Plant 2,040 361 396 60.4 2.4 2.2

Navajo Refining Co. Artesia 1,975 387 394 1,204 187 112

Total point sources 7,515 6,661 5,399 3,444 1,847 1,569

Total area sources 268 1,776 20,326 4,778 25,479 3,175

County total 7,783 8,437 25,725 8,222 27,326 4,744

a

 Data in italics are examples of selected major facilities and are not added to yield total. 

Note: Emissions for selected major facilities are total point and area sources for 2002. 

Key: CO=carbon monoxide; NO2=nitrogen dioxide; PMn=particulate matter with an aerodynamic diameter less than or equal to 

n micrometers; SO2=sulfur dioxide; VOC=volatile organic compound. 

Source: EPA 2009. 

Among criteria pollutants (SO2, NO2, CO, ozone [O3], PM10 and PM2.5, and lead), the New Mexico State 

Ambient Air Quality Standards are identical to the National Ambient Air Quality Standards for NO2

(EPA 2008b; 20.2.3 NMAC), as shown in Table 3–3. The State of New Mexico has established more 

stringent standards for SO2 and CO but has no standards for O3, particulate matter, or lead. In addition, 

the state has adopted standards for hydrogen sulfide and total reduced sulfur and has still retained the 

standard for total suspended particulates, which used to be one of the criteria pollutants but was replaced 

by PM10 in 1987. 
Affected Environment 

3–19

Table 3–3. National Ambient Air Quality Standards or New Mexico State Ambient Air Quality 

Standards and Highest Background Levels Representative of the 

Waste Isolation Pilot Plant Area, 2003–2007 

Criteria Pollutants

Averaging

Period

Most Stringent

Standard or

Guidelinea

Maximum 

Waste Isolation Pilot Plant 

Area Concentrationb, c

Carbon monoxide 8 hours 8.7 ppm 3.5 ppm (40%)

Albuquerque, Bernalillo County (2004)d

1 hour 13.1 ppm 9.6 ppm (73%)

Albuquerque, Bernalillo County (2003)d

Nitrogen dioxide Annual 0.05 ppm 0.006 ppm (12%)

Artesia, Eddy County (2003)

1 hour 0.10 ppmef

Ozoneg 8 hours 0.075 ppme 0.076 ppm (101%)

Carlsbad, Eddy County (2006)

PM10 24 hours 150 μg/m3e 88 μg/m3(59%)

Hobbs, Lea County (2003)

PM2.5 Annual 15.0 μg/m3e 7.3 μg/m3(49%)

Hobbs, Lea County (2007)

24 hours 35 μg/m3e 18 μg/m3(51%)

Hobbs, Lea County (2005)

Sulfur dioxide Annual 0.02 ppm 0.001 ppm (5.0%)

Artesia, Eddy County (2007)

24 hours 0.10 ppm 0.004 ppm (4.0%)

Artesia, Eddy County (2006)

3 hours 0.50 ppm 0.017 ppm (3.4%)

Artesia, Eddy County (2006)

1 hour 0.075 ppm f

Lead Calendar

quarterh

1.5 μg/m3e 0.03 μg/m3(2.0%)

Bernalillo County (2003)d

Rolling 

3-month

0.15 μg/m3ef

a

 The more stringent standard between the National Ambient Air Quality Standards (NAAQS) and the State Ambient Air 

Quality Standards (SAAQS) is listed when both are available. 

b Monitored concentrations are the highest arithmetic mean for calendar-quarter lead; second-highest for 1-hour, 3-hour, and 

24-hour sulfur dioxide, 1-hour and 8-hour carbon monoxide, 1-hour ozone, and 24-hour PM10; fourth-highest for 8-hour 

ozone; 98th percentile for 24-hour PM2.5; arithmetic mean for annual sulfur dioxide, nitrogen dioxide, PM10, and PM2.5. 

c

 Values in parentheses are monitored concentrations as a percentage of SAAQS or NAAQS. 

d These locations with highest observed concentrations in the state of New Mexico are not representative of the Waste Isolation 

Pilot Plant site but are presented to show that these pollutants are not a concern over the state of New Mexico. 

e

 Values are NAAQS. No SAAQS exists. 

f

 No measurement is available. 

g On June 15, 2005, the U.S. Environmental Protection Agency revoked the 1-hour ozone standard for all areas except the 

8-hour ozone nonattainment Early Action Compact areas. (Those do not yet have an effective date for their 8-hour 

designations.) The 1-hour standard will be revoked for these areas 1 year after the effective date of their designation as 

attainment or nonattainment for the 8-hour ozone standard. 

h Used old standard because no data in the new standard format are available. 

Key: μg/m3=micrograms per cubic meter; PMn=particulate matter with an aerodynamic diameter less than or equal to 

n micrometers; ppm=parts per million. 

Note: New Mexico also has ambient standards for total suspended particulates, hydrogen sulfide, and total reduced sulfur, but no 

ambient values were reported representative of the area. 

Source: EPA 2008a, 2009; 20.2.3 New Mexico Administrative Code. 
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The WIPP site is located in Eddy County. Currently, the entire county, including the WIPP site, is 

designated as being in attainment for all criteria pollutants (40 CFR 81.332). The whole state is 

designated as an attainment area, except for a small portion in the south-central part of the state, Anthony 

(adjacent to El Paso, Texas), which is not in attainment for PM10. 

Seven classes of EPA-regulated pollutants have been monitored at WIPP since August 1986. Monitoring 

results indicated that air quality around the WIPP site usually met Federal and state standards, except for 

occasional exceedances for total suspended particulates during periods of high wind and blowing sands 

and infrequent exceedances for SO2 (DOE 1997). After notifying the EPA, on October 30, 1994, DOE 

terminated onsite monitoring of criteria pollutants at the WIPP site because there was no longer a 

regulatory requirement to do so. Currently, VOC monitoring is performed to comply with the provisions 

of the WIPP Hazardous Waste Facility Permit. In 2006, three of the nine target compounds were detected 

above the method reporting limit (DOE 2007). The most substantial results were at least three orders of 

magnitude below the lower action level as described by the Hazardous Waste Facility Permit. 

To establish representative background concentrations for the WIPP site, nearby urban or suburban 

measurements were used. The highest concentration levels for SO2, NO2, PM10, and PM2.5 around the 

WIPP site are less than or equal to 59 percent of their respective standards in Table 3–3 (EPA 2008b). 

The highest annual O3 concentrations reported in 2006 were slightly higher than the standard; however, 

compliance with the O3 standard is based on the 3-year average of the fourth highest value reported 

annually. The annual concentration for 8-hour ozone was 0.066 parts per million (ppm) in 2007, 

0.076 ppm in 2006, 0.067 ppm in 2005, 0.065 ppm in 2004, and 0.065 ppm in 2003 (EPA 2012). The 

highest 3-year average during the 2003–2007 timeframe was 0.070 ppm, which is in compliance with the 

standard. No measurement data for CO and lead around the WIPP site are available, but those values are 

expected to be lower. They would be lower for CO because of the distance from urban areas and major 

highways, and they would be lower for lead because of the distance from industrial processes, such as 

smelters. 

The WIPP site and its vicinity are classified as Prevention of Significant Deterioration (PSD) Class II 

areas. The nearest Class I area is Carlsbad Caverns National Park, about 61 kilometers (38 miles) 

west-southwest of WIPP (40 CFR 81.421). Guadalupe Mountains National Park in Texas is about 

100 kilometers (62 miles) west-southwest of WIPP (40 CFR 81.429). There are no facilities currently 

operating at the WIPP site that are subject to PSD regulations. 

3.2.4.2 Noise 

The State of New Mexico and Eddy County have established no quantitative noise-level regulations. 

The major noise sources associated with disposal operations at WIPP include traffic noise from site 

workforce vehicles, salt haulage vehicles, and waste transport vehicles; from the Waste Handling 

Building during normal operations; and from infrequent emergency diesel generator testing. The Waste 

Isolation Pilot Plant Disposal Phase Final Supplemental Environmental Impact Statement reported that 

an overall sound pressure level of 50 decibels A-weighted (dBA) might occur 120 meters (400 feet) away 

as a result of normal operations (DOE 1997). Because the WIPP facility is more than 2.4 kilometers 

(1.5 miles) from the fence line, generator noise is inaudible at the fence line and hence at any nearby 

residence. 

The ambient noise level in the WIPP area before construction was 26 to 28 dBA, similar to wilderness 

natural background noise levels (DOE 1997). For the general area surrounding the WIPP site, the 

countywide day–night average sound level (Ldn) based on population density is estimated to be 33 dBA 

for Eddy County, typical of the lower end of the range for rural areas (33–47 dBA) (Eldred 1982). 
Affected Environment 

3–21

3.2.5 Ecological Resources 

3.2.5.1 Terrestrial Resources 

The area surrounding the WIPP site is characterized by large, stabilized sand dunes. It is located within a 

transition area between the northern extension of the Chihuahuan Desert (desert grassland) and the 

southern Great Plains (short-grass prairie) and shares the vegetative characteristics of both areas 

(DOE 1980). More than 100 species of plants have been identified within the WIPP LWB (DOE 1993). 

Numerous species of forbs and perennial grasses are present. The dominant shrubs include shinnery oak 

(Quercus havardii), mesquite (Prosopis glandulosa), sand sagebrush (Artemisia filifolia), dune yucca 

(Yucca campestris), and smallhead snakeweed (Gutierrezia microcephala) (DOE 1980, 1997). Russian 

thistle (Salsola kali) is a nonnative species that is commonly established in disturbed areas (DOE 1980). 

More than 45 mammal species (including 15 bat species) occur within Lea and Eddy Counties, with 

39 species occurring in the WIPP site area (DOE 1980). Mule deer (Odocoileus hemionus), pronghorn 

(Antilocapra americana), and coyote (Canis latrans) are among the larger mammals found in the area 

(DOE 1980, 1997). 

More than 120 species of birds have been documented on or near the WIPP site (DOE 1980). Common 

bird species include the loggerhead shrike (Lanius ludovicianus), pyrrhuloxia (Cardinalis sinuatus), and 

black-throated sparrow (Amphispiza bilineata) (DOE 1997). The availability of nesting sites may limit 

bird populations in the project area (DOE 1980). 

Twenty-three reptile and 10 amphibian species occur in the area (DOE 1980, 1993). Most desert 

amphibians are generally seen only following spring or summer rains (DOE 1993). 

3.2.5.2 Wetlands 

No wetlands occur on the WIPP site or in the immediate vicinity of the site. 

3.2.5.3 Aquatic Resources 

The two-county region lies within the drainage basin of the Pecos River. However, the only permanent 

aquatic habitats near the WIPP site include earthen watering ponds for livestock (DOE 1997). These 

manmade livestock watering holes, which are not hydrologically connected to the formations overlying 

the WIPP site, are located several miles away (DOE 2007). Two salt pile evaporation ponds, a detention 

basin, and two manmade ponds occur within the developed portions of the WIPP site. However, these 

ponds do not provide productive aquatic habitats. 

3.2.5.4 Threatened and Endangered Species 

The endangered, threatened, and other special status species reported from the area of Eddy and Lea 

Counties, including the WIPP Vicinity reference locations, are listed in Table 3–4. (Special status aquatic 

species and species that primarily occur near major aquatic habitats are not included because no aquatic 

habitats in which those species occur are located near the WIPP site.) None of the species listed in 

Table 3–4 were observed within the WIPP LWB in 1996, and there is no designated critical habitat for 

federally listed species at the WIPP site (DOE 1997). Critical habitat for the gypsum wild-buckwheat 

(Eriogonum gypsophilum) is over 30 miles (48 kilometers) from the WIPP site. Favorable habitat for the 

lesser prairie-chicken (Tympanuchus pallidicinctus), a Federal candidate species, does occur within the 

WIPP LWB and other surrounding areas (DOE 2007). WIPP employees have instituted measures, in 

consultation with BLM, to protect the lesser prairie-chicken and its habitat. They include the 

establishment of periods during which offsite field activities may not be performed during the species’ 

breeding season (DOE 2007). 
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Table 3–4. Federally and State-Listed Species Potentially Occurring at the

Waste Isolation Pilot Plant Site

Common Name Scientific Name Federal Status State Status

Plants

Glass Mountain coral-root Hexalectris nitida Endangered

Guadalupe jewelflower Streptanthus sparsiflorus Species of Concern

Gypsum wild-buckwheat Eriogonum gypsophilum Threatened Endangered

Hershey’s cliff daisy Chaetopappa hersheyi Species of Concern

Kuenzler hedgehog cactus Echinocereus fendleri var. kuenzleri Endangered Endangered

Lee’s pincushion cactus Escobaria sneedii var. leei Threatened Endangered

Sneed pincushion cactus Coryphantha sneedii var. sneedii Threatened Endangered

Wright’s water-willow Justicia wrightii Species of Concern

Birds

American peregrine falcon Falco peregrinus anatum Threatened

Arctic peregrine falcon Falco peregrinus tundrius Threatened

Baird’s sparrow Ammodramus bairdi Threatened

Least tern (interior population) Sterna antillarum athalassos Endangered Endangered

Lesser prairie-chicken Tympanuchus pallidicinctus Candidate

Southwestern willow flycatcher Empidonax trallii extimus Endangered Endangered

Sprague’s pipit Anthus spragueii Candidate

Mammals

Black-footed ferret Mustela nigripes Endangered

Source: BISON 2012; NMRPTC 2012; USFWS 2012.

3.2.6 Cultural and Paleontological Resources

Roughly 1,370 hectares (3,380 acres) of the 4,140 hectares (10,240 acres) managed by WIPP have been 

surveyed for cultural resources. The surveys identified approximately 60 archaeological sites and 

90 isolated finds (DOE 2002a). The largest survey was done in 1987 by Mariah and Associates. The 

1987 survey examined portions of 45 sections surrounding the WIPP facility (DOE 2002b).

3.2.6.1 Prehistoric Resources

People have been living in the desert southwest for more than 10,000 years. Prehistoric people tended to 

live nomadic lifestyles, collecting resources from different areas at different times of the year 

(DOE 2002b). Most prehistoric archaeological sites in the WIPP area represent short-term use. In the 

mid-1500s, the Jumano and Apachean people used the area. They collected goods seasonally and traded 

with nearby Puebloan people. The Spanish were the first Europeans to cross what would become 

southeastern New Mexico. In historic times, the region was only lightly populated because of a lack of 

resources. Some ranching took place on the WIPP property during the 1940s and 1950s. Evidence of 

these activities is still visible in some locations.

WIPP Vicinity Section 10 is located on BLM-managed land just to the northeast of the WIPP LWB, 

WIPP Vicinity Section 20 is in the WIPP LWB, and WIPP Vicinity Section 35 is located on 

BLM-managed land just to the southeast of the WIPP LWB. The majority of Section 10, Section 20, and 

Section 35, all within Township 22 South, Range 31 East, have not been examined for the presence of 

cultural resources. However, some cultural resource surveys have been undertaken in anticipation of 
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3–23

development. No archaeological sites have been found in WIPP Vicinity Section 10 or Section 20. 

Seven archaeological sites have been identified within WIPP Vicinity Section 35. Of the seven resources 

identified, one is currently recommended as being potentially eligible for listing on the National Register 

of Historic Places. Another site has been very heavily impacted by past activities and no longer requires 

consideration. Most of the discovered resources appear to be the remains of camps that show evidence of 

food preparation.

A review of cultural resource information for the region revealed that the Maroon Cliffs Archaeological 

District is located northwest of WIPP. It is the closest archaeological district to the reference locations. 

The 4,770-hectare (11,780-acre) district contains evidence of habitation ranging from the Archaic period 

(5000 B.C.) to the Jornada Mogollon period (A.D. 900 to 1450) (BLM 1988). Pit houses have been 

reported among the archaeological sites documented at this location. The district includes a wide variety 

of topographic features. The district is located roughly 11 kilometers (7 miles) northwest of the project 

area.

From about 10,000 B.C. to the late 1800s, southeastern New Mexico was inhabited by aboriginal hunters 

and gatherers who subsisted on various wild plants and animals. In the late 1800s, the region was settled 

by ranchers and farmers. Known archaeological sites in the vicinity of WIPP are primarily the remains of 

prehistoric camps and short-term settlements. These areas are generally marked by hearth features, 

scattered burned rock, flaked stone projectile points, cutting and scraping tools, pottery fragments, and 

ground stone implements. Locations generally represent short-term, seasonal occupations by small, 

nomadic groups of hunters and gatherers who used the plants and animals in the dune lands east of the 

Pecos River. In a few cases, sites with evidence of structures have been reported, probably associated 

with occupations of several weeks to months.

3.2.6.2 Historic Resources

Historic remains or features (more than 50 years old) are rare but have occasionally been identified. 

These include features and debris related to agricultural ranching in the twentieth century, including 

fences that may still be in use. The majority of historic sites identified to date include elements that could 

contribute to their eligibility for listing in the National Register of Historic Places. 

With few exceptions, cultural resources known or anticipated in the area covered by the WIPP LWB are 

significant; they must be identified, recorded, assessed through an inventory, and considered in any plan 

of development for the area. When compared with most other portions of southeastern New Mexico, the 

locations (and nature) of cultural resources within the WIPP LWB can be described relatively well on the 

basis of an intensive inventory of portions of the area, limited excavation, and other investigative work on 

some sites.

Several surveys have been completed in the WIPP LWB, and 59 archaeological sites and 91 isolated 

occurrences (single artifact or only a few artifacts, or isolated features that can be fully recorded in the 

field) have been identified to date. The sites and isolates identified are almost exclusively prehistoric. 

Only one site with both prehistoric and historic components was noted. Approximately 37 percent of the 

area within the WIPP LWB has been inventoried for cultural resources. Extrapolating the current number 

of resources located to date to the rest of the (unsurveyed) area indicates that about 99 additional sites and 

153 isolates could be present at the site. The land within the WIPP LWB appears to represent a 

potentially significant contributor of cultural resources and should be regarded as such when land 

management decisions are made (DOE 2002b).

3.2.6.3 American Indian Resources

There are no known American Indian sacred sites or burials in the WIPP Vicinity reference locations.
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3.2.6.4 Paleontological Resources 

Paleontological resources are the physical remains, impressions, or traces of plants or animals from a 

former geological age that may be sources of information on paleoenvironments and the evolutionary 

development of plants and animals. No paleontological resources have been identified in the WIPP 

Vicinity reference locations. 

3.2.7 Site Infrastructure 

3.2.7.1 Ground Transportation 

The WIPP site can be reached by rail or highway. Rail access to WIPP is provided by a rail line 

connecting with a spur of the Burlington Northern Santa Fe (BNSF) Railroad near the Mosaic Potash 

Nash Draw Mine, 9.6 kilometers (6 miles) southwest of the site. This section of rail, which was 

constructed under the auspices of Right-of-Way Reservation NM 55699, granted on September 27, 1983, 

is approximately 8 kilometers (5 miles) in length. The rail line includes an adjacent service road. Both 

the railroad and service road were constructed on an easement width of 46 meters (150 feet). 

The WIPP site can also be accessed by the North and South Access Roads constructed for the WIPP 

project. The North Access Road, also known as Louis Whitlock Road, is approximately 21 kilometers 

(13 miles) in length, with an easement width of 37 meters (120 feet). Use of this road is restricted to 

DOE personnel, agents, and contractors of DOE on official business related to the WIPP project or to 

BLM personnel, permittees, licensees, or lessees. Signs are placed and maintained at the turnout of 

U.S. Route 62/180 stating the restrictions on access. Persons desiring access to Texas State Route 128 

can use Lea County Line Road immediately to the east. The South Access Road, also known as 

WIPP Road, is approximately 6.4 kilometers (4 miles) in length, with an easement width of 43 meters 

(140 feet). Multiple-use access for the South Access Road will be allowed unless it is determined that 

access by industry or the general public represents a significant safety risk to WIPP personnel or to the 

public. Upon determination, general access of the South Access Road may be restricted at the boundary 

of the 580-hectare (1,450-acre) Off-Limits Area in accordance with DOE Manual 470.4-2, Physical 

Protection. Average daily traffic on the access roads is estimated to be 800 vehicles on the North Access 

Road and 400 vehicles on the South Access Road (NMED 2007). 

3.2.7.2 Electricity 

Electricity is supplied to the WIPP area by Xcel Energy. Xcel owns a substation on the WIPP land 

withdrawal area located just to the east of the Property Protection Area, and owns the 115-kilovolt 

transmission lines to the substation. The peak load use is estimated to be 4 megawatts, with an available 

peak load capacity of 20 megawatts. 

3.2.7.3 Fuel 

WIPP utilizes gasoline and diesel as fuel for mobile equipment, the site emergency generators, and the 

diesel fire pump upon failure of the electric-powered fire pump. WIPP has attempted to partner with 

private industry for bio-fuels for both gasoline and diesel. WIPP has not been successful in obtaining 

bio-fuels or bio-fuel blends due to lack of availability. Fuel consumption in fiscal year 2011 was 

73,615 liters (19,447 gallons). 

3.2.7.4 Water 

The WIPP site water supply is categorized as a nontransient, noncommunity system for reporting and 

testing requirements. Water service for the WIPP facility is furnished by the City of Carlsbad from a 

city-owned waterline that originates at the Double Eagle South Well Field 31 miles (50 kilometers) north 

of the facility. The volume capacity of the waterline is such that it meets all water requirements for the 
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3–25

operation of the WIPP facility. As specified in a bill of sale transferring this waterline from DOE to the 

City of Carlsbad in June 2009, Carlsbad will provide up to 25 million liters per year (6.6 million gallons 

per year) of water to the WIPP facility free of charge for the next 100 years. Annual water use at the 

WIPP site is approximately 15 million liters per year (4 million gallons per year). 

The City of Carlsbad is serviced by two separate well fields: Sheep’s Draw and Double Eagle. 

Approximately 98 percent of Carlsbad’s water is supplied by groundwater pumped from nine wells 

located 11 kilometers (7 miles) southwest of Carlsbad in an area called Sheep’s Draw in the foothills of 

the Guadalupe Mountains. The other 2 percent comes from the Double Eagle water system. The Double 

Eagle well system is located near Maljamar, New Mexico. It serves the Ridgecrest Subdivision, Connie 

Road, Blackfoot Road, Hobbs Highway Industrial Park Area, Brantley Lake State Park, and the WIPP 

site. In 2007, the city of Carlsbad’s water supply system pumped 9.5 billion liters (2.5 billion gallons) of 

water (Carlsbad 2008a). 

The Double Eagle system that supplies water to the WIPP site has 29 wells in two well fields (north and 

south). Twelve of the wells are operational in the north well field; two are operational in the south well 

field. The south well field is the main source of water for the WIPP site and a handful of other users. 

Double Eagle water is withdrawn from the Ogallala Aquifer (Carlsbad 2008a, 2008b). The Double Eagle 

system has a total capacity of approximately 9.5 billion liters per year (2.5 billion gallons per year). 

Existing storage facilities include a 11.4-million-liter (3-million-gallon) reservoir, a 1.6-million-liter 

(0.42-million-gallon) reservoir, and a 3.8-million-liter (1-million-gallon) reservoir. A 7.6-million-liter 

(2-million-gallon) reservoir has also been added to the south well field. 

3.2.8 Waste Management 

WIPP is the Nation’s only underground repository for the permanent disposal of defense-generated TRU 

waste. WIPP holds a Hazardous Waste Facility Permit under the Resource Conservation and Recovery 

Act from the State of New Mexico for TRU-mixed waste storage and disposal. In addition, the WIPP 

facility is a large-quantity generator of hazardous waste, generating about 10,800 kilograms 

(23,700 pounds) of hazardous waste in 2011. 

Site-generated nonhazardous solid waste that is not recycled is shipped off site and disposed of at the 

Eddy County Sandpoint Landfill, the nearest municipal solid waste landfill to the site. In 2011, WIPP 

generated 98 metric tons (108 tons) of solid waste. WIPP has an onsite construction and demolition 

debris landfill for site-generated construction and demolition (C&D) wastes. Disposal in the onsite C&D 

landfill is limited to 23 metric tons (25 tons) per day. In 2011, WIPP generated about 64 metric tons 

(70 tons) of C&D waste. 

Support structures at the WIPP facility used to manage waste generated from facility operations include a 

sewage treatment system. The sewage treatment system at WIPP is a zero-discharge facility consisting of 

two primary settling lagoons, two polishing lagoons, a chlorination system, and four evaporation basins. 

The sewage treatment system is designed to dispose of domestic sewage and site-generated brine waters 

from observation well pumping and from underground dewatering activities at WIPP (Sandia 2008). The 

existing sewage treatment system for WIPP site operations is located approximately one-half mile from 

the site and is designed and permitted for 87,000 liters (23,000 gallons) per day. In 2011, approximately 

12 million liters (3.1 million gallons) were managed in the sewage treatment system, or on average, 

31,650 liters (8,360 gallons) per day. 

3.2.8.1 Waste Minimization 

An active Pollution Prevention Program has been in place at WIPP since the 1990s with recycling as a 

key component of the program. As a result, WIPP has long recycled the waste streams that can be 

recycled within its regional infrastructure. These include a narrow scope of nonhazardous, C&D, 
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hazardous, universal, and New Mexico special waste streams. Nonhazardous wastes that are recycled are 

paper, plastics, cardboard, and aluminum cans. C&D wastes that are recycled are metals and, during 

fiscal year 2011, asphalt. Other wastes recycled or recovered include circuit boards, used oil, used 

antifreeze, and batteries. Computers and electronics are either donated for reuse or sent to UNICOR for 

recycling. WIPP also encourages its onsite subcontractors to recycle.

3.2.9 Occupational and Public Health and Safety 

This section summarizes the environmental health risks arising from the effects of exposures to hazardous 

chemicals and ionizing radiation during normal operations, facility accidents, and transportation activities. 

3.2.9.1 Normal Operations 

The following discussion is based on current operations at WIPP and is assumed to be applicable to all 

three WIPP Vicinity reference locations. According to the Waste Isolation Pilot Plant Annual Site 

Environmental Report for 2010 (DOE 2011c), WIPP continues to have no reportable, unauthorized 

contaminant (both ionizing radiation and hazardous chemicals) releases. 

3.2.9.1.1 Exposure to Ionizing Radiation 

The dose limit for WIPP operations is given in Title 40 of the Code of Federal Regulations (CFR) 

Part 191, Subpart A, and requires that the combined annual dose equivalent to any member of the general 

public in the vicinity of the site not exceed 25 millirem per year to the whole body and 75 millirem per 

year to any critical organ. Potential radiation exposures of the offsite general public can occur as a result 

of three pathways: (1) air transport, (2) water ingestion, and (3) ingestion of game animals. Of these three 

pathways, only the air pathway is considered to be credible. Elevated concentrations of radionuclides 

have not been detected in groundwater or game animals in the site vicinity. 

In 2011, the whole body dose to the highest-exposed individual from airborne releases was estimated to 

be less than 1.75 10-5 millirem per year (DOE 2012). This individual was assumed to reside 

7.5 kilometers (4.6 miles) west-northwest of the site. A hypothetical individual residing at the site fence 

line in the northwest sector was estimated to receive a whole body dose of less than 1.29 10-3 millirem 

per year (DOE 2012). These values are well below the dose limit of 100 millirem per year from all 

exposure pathways set by DOE to protect the general public from the operation of its facilities. 

In 2011, the collective dose to the population living within 80 kilometers (50 miles) of WIPP was 

calculated to be 2.67 10-5 person-rem per year (DOE 2012). If this dose were distributed uniformly to 

all individuals living within 80 kilometers (50 miles) of the site – a total of 92,599 people – the average 

dose to each person would be about 2.88 10-7 millirem per year (DOE 2012). This is an extremely 

small fraction of the average dose of 620 millirem per year to members of the general public from 

exposure to natural background and manmade sources of radiation (NCRP 2009). 

Before operations started at WIPP for receipt and disposal of TRU waste, estimates were developed for 

the doses that could be expected to occur to workers (Bradley et al. 1993). The doses for each worker 

during normal contact-handled (CH) waste handling operations at WIPP were estimated to be as follows: 

waste handlers would receive 0.70 rem per year; radiation control technicians, 0.60 rem per year; and an 

average individual, 0.68 rem per year. The estimated annual doses to these three categories of workers 

for handling all TRU (CH and remote-handled [RH]) waste are given as 0.79 rem per year, 0.87 rem per 

year, and 0.81 rem per year, respectively. The average individual represents the dose associated with the 

range of activities at WIPP and is thus a composite (or average) worker. The waste acceptance criteria for 

WIPP limit the contact dose rate to 200 millirem per hour for CH wastes and 1,000 rem per hour for RH 

wastes. The project has a self-imposed limit of 1 rem per year for worker exposure at WIPP, which is 

lower than the occupational exposure limit of 5 rem per year given in 10 CFR 835. 
Affected Environment 

3–27

Data on actual operations at WIPP indicate that workers are receiving very low doses from external 

gamma radiation (Jierree 2009; McCauslin 2010). The total annual worker dose commitment for the 

years 1999 through 2009 was 12.4 person-rem (or an average of about 1.1 person-rem per year) and 

ranged from a low of 0.331 person-rem per year to a maximum of 2.298 person-rem per year. Of the 

more than 1,100 workers who were monitored for radiation exposure in 2009, 68 had reportable doses. 

Most of the individuals who had reportable doses were waste handlers and radiological control 

technicians. 

The proposed mercury storage facility(ies) would contain no radioactive materials and thus would not 

alter the current exposure of members of the public or workers to ionizing radiation. 

3.2.9.1.2 Exposure to Hazardous Chemicals 

Polychlorinated biphenyls (PCBs) are a class of compounds regulated by the Toxic Substances Control 

Act. The PCB storage and disposal regulations are listed in the applicable subparts of 40 CFR Part 761, 

“Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use 

Prohibitions.”

WIPP handles TRU waste3containing PCBs. On May 15, 2003, EPA Region VI approved the disposal of 

waste containing PCBs at the WIPP facility. PCBs exist in DOE’s TRU waste as mixtures of synthetic 

organic chemicals with physical properties ranging from oily liquids to waxy solids. The WIPP facility 

began receiving PCB-contaminated waste on February 5, 2005. The EPA renewed the disposal authority 

on April 30, 2008. The required PCB annual report, containing information on PCB waste received and 

disposed of at the WIPP facility in 2011, was submitted to EPA Region VI on July 13, 2012. Exposure of 

workers and the public to PCBs has been and remains minimal (DOE 2004b). 

In addition, WIPP monitors VOCs. The nine compounds monitored are 1,1,1-trichloroethane, 

1,1,2,2-tetrachloroethane, 1,1-dichloroethylene, 1,2-dichloroethane, carbon tetrachloride, chlorobenzene, 

chloroform, methylene chloride, and toluene. The running annual average for repository VOC sample 

results remained below the concentrations of concern as listed in the WIPP permit (DOE 2011c). 

3.2.9.2 Facility Accidents 

According to the Waste Isolation Pilot Plant Annual Site Environmental Report for 2010 (DOE 2011c), 

WIPP continued to have no reportable, unauthorized contaminant releases. There is no record of 

accidental fires, explosions, ionizing radiation releases, or hazardous chemical releases. 

3.2.9.3 Transportation 

The principal business of WIPP is to receive and dispose of TRU waste. To that end, shipping containers 

for TRU waste are brought onto the site by truck. In the first 10 years of WIPP operations, there were a 

total of eight traffic accidents involving WIPP trucks (DOE 2009), with no injuries or fatalities. 

For the Supplement Analysis for the Waste Isolation Pilot Plant Site-Wide Operations (DOE 2009), DOE 

estimated the routine exposures of the populations along the transportation routes to WIPP to ionizing 

radiation and concluded that the estimated mean number of latent cancer fatalities (LCFs) over the entire 

shipping campaign would be 0.23. Occupational exposures would amount to 0.29 LCFs over the same 

period of time. There is no routine exposure to hazardous chemicals because these are inside the shipping 

container. DOE (2009) also reports on analyses of hypothetical severe accidents. Bounding analysis of 

worst-case severe accidents predicts a mean number of LCFs of 0.1, and bounding individual probabilities 

 

3

 TRU waste is waste that contains alpha particle-emitting radionuclides with atomic numbers greater than uranium (92) and 

half-lives greater than 20 years, in concentrations greater than 100 nanocuries per gram of waste. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

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of an LCF of about 2.3 × 10-7. Bounding analyses of worst-case releases of VOCs show that no human 

health effects would be expected from such scenarios. 

3.2.10 Socioeconomics 

Socioeconomic variables at WIPP are associated with community growth and development within the 

WIPP ROI that could potentially be affected, directly or indirectly, by project-related changes. Included 

are economic characteristics, the region’s demography, housing, and local transportation.

WIPP is located in southeastern New Mexico, approximately 32 kilometers (20 miles) east of Carlsbad. 

The majority of people employed at WIPP reside in two counties: Eddy and Lea. Therefore, these two 

counties are identified as the ROI in this socioeconomics analysis. Approximately 1,100 persons are 

employed at WIPP (DOE 2011b:4-35).

3.2.10.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the ROI increased by approximately 27 percent to 58,157. During 

this period, the unemployment rate of the ROI decreased from 5.5 percent to 4.9 percent. The 

unemployment rate in the ROI peaked during 2010 at 6.5 percent. By July 2012, the unemployment rate 

of the ROI was 4.5 percent, which was lower than the unemployment rate for New Mexico (7.4 percent) 

(BLS 2012). 

3.2.10.2 Demographic and Housing Characteristics 

In 2010, the population of the two-county ROI was 118,556. From 2000 to 2010, the ROI population 

grew by approximately 11 percent, compared with 13 percent growth throughout the State of New 

Mexico. The percentage of the ROI population under the age of 18 was approximately 28 percent; 

Women ages 18 to 39 composed approximately 28 percent of the population (Census 2011a). Young 

children and pregnant women are considered to be among the most vulnerable populations to mercury 

poisoning. There were 47,504 housing units in the ROI in 2010, 64 percent of which were 

owner-occupied, 26 percent were renter-occupied, and 10 percent were vacant (Census 2011b, 2011c).

3.2.10.3 Local Transportation 

As discussed in Section 3.2.7.1, the WIPP site can be reached by rail or highway. Rail access to WIPP is 

provided by a rail line connecting with a spur of the BNSF Railroad near the Mosaic Potash Nash Draw 

Mine, 9.6 kilometers (6 miles) southwest of the site. The WIPP site can also be accessed by the North 

and South Access Roads constructed for the WIPP project. The North Access Road is restricted to DOE 

personnel, agents, and contractors of DOE on official business related to the WIPP project or to BLM 

personnel, permittees, licensees, or lessees. Multiple-use access for the South Access Road will be 

allowed unless it is determined that access by industry or the general public represents a significant safety 

risk to WIPP personnel or to the public. Traffic in the vicinity of WIPP has experienced temporary 

increases in volume at various times due to oil production activities. 

3.2.11 Environmental Justice 

Under Executive Order 12898, DOE is responsible for identifying and addressing any disproportionately 

high and adverse impacts on minority and low-income populations. Minority persons are those who 

identify themselves as American Indian or Alaska Native, Asian, Black or African American, Hispanic or 

Latino (of any race), Native Hawaiian or other Pacific Islander, or multiracial (CEQ 1997). Persons who 

report that their income is less than the Federal poverty threshold are designated as low-income. 

A 16-kilometer (10-mile) radius was chosen as the ROI for this analysis to provide a reasonable estimate 

of the potentially affected population surrounding the facility(ies). An additional ROI of those residing 
Affected Environment 

3–29

within an approximately 3.2-kilometer (2-mile) radius of each candidate site was used as a subset of the 

16-kilometer (10-mile) ROI to guard against inadvertently diluting represented minority and low-income 

populations most likely to experience any potentially adverse impacts associated with mercury storage. 

The 16-kilometer (10-mile) radius surrounding the candidate storage locations at WIPP encompasses 

parts of two counties in New Mexico: Eddy and Lea. Figure 3–6 shows populations residing in the 

two-county area, as reported in the 2000 and 2010 censuses (Census 2001a, 2011d). In this figure, lightly 

shaded bars show populations in 2000 and the darker bars show those in 2010. From 2000 to 2010, the 

population of Eddy and Lea Counties increased by approximately 11 percent to 118,556. Over this 

period, the total minority population increased by approximately 32 percent to 62,600 and the low-income 

population decreased by approximately 13 percent to 17,540 (Census 2001a, 2001b, 2011d, 2011e). 

Demographic data from the 2010 census show that the total minority population residing in the 

two-county area composed approximately 53 percent of the total population. The White Hispanic 

population residing in the two-county area composed approximately 55 percent of the county’s total 

minority population, while those self-identified as “some other race” (meaning those who provided 

write-in entries such as Mexican, Puerto Rican, or Cuban) composed approximately 31 percent of the 

county’s total minority population. Persons who declared that they are of Hispanic or Latino origin are 

included in the “total Hispanic” population, regardless of race. They composed approximately 48 percent 

of the total population and approximately 91 percent of the total minority population residing in Eddy and 

Lea Counties in 2010. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

3–30

Figure 3–6. Populations Residing in the Two-County Area Surrounding the 

Waste Isolation Pilot Plant in 2000 and 2010 

3.2.11.1 WIPP Vicinity Section 10 

In 2010, 550 people lived within 16 kilometers (10 miles) of WIPP Vicinity Section 10. This area 

included an estimated 44 percent minority and 6 percent low-income population. By comparison, Eddy 

and Lea Counties included a 53 percent minority and 16 percent low-income population, and 

New Mexico included a 60 percent minority and 18 percent low-income population. There are five 

census block groups located within the 16-kilometer (10-mile) radius surrounding Section 10, none of 

which contained a minority or low-income population. As described in Appendix B, Section B.11.1, of 

the January 2011 Mercury Storage EIS and as updated in Appendix B, Section B.3, of this SEIS, minority 

and low-income populations or communities are identified by comparing block-group data to the 

surrounding state- and county-level data to determine if the minority or low-income population 

percentage is meaningfully greater than that of the general population. Figure 3–7 shows the cumulative 

populations living at a given distance from Section 10. It is estimated that approximately 36 people reside 

within approximately 3.2 kilometers (2 miles) of Section 10, consisting of a 45 percent minority 

population and a 5 percent low-income population (Census 2011d, 2011e).
Affected Environment 

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Figure 3–7. Populations Residing Within 16 Kilometers (10 miles) of the Storage Location at 

Waste Isolation Pilot Plant Vicinity Section 10 

3.2.11.2 WIPP Vicinity Section 20 

In 2010, 575 people lived within 16 kilometers (10 miles) of WIPP Vicinity Section 20. This area 

included an estimated 45 percent minority and 5 percent low-income population. By comparison, Eddy 

and Lea Counties included a 53 percent minority and 16 percent low-income population, and New 

Mexico included a 60 percent minority and 18 percent low-income population. There are three census 

block groups located within the 16-kilometer (10-mile) radius surrounding Section 20, none of which 

contained a minority or low-income population. Figure 3–8 shows the cumulative populations living at a 

given distance from Section 20. It is estimated that approximately 21 people reside within approximately 

3.2 kilometers (2 miles) of Section 20, consisting of a 46 percent minority population and a 5 percent 

low-income population (Census 2011d, 2011e). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

3–32

Figure 3–8. Populations Residing Within 16 Kilometers (10 miles) of the Storage Location at 

Waste Isolation Pilot Plant Vicinity Section 20 

3.2.11.3 WIPP Vicinity Section 35 

In 2010, 430 people lived within 16 kilometers (10 miles) of WIPP Vicinity Section 35. This area 

included an estimated 44 percent minority and 6 percent low-income population. By comparison, 

Eddy and Lea Counties included a 53 percent minority and 16 percent low-income population, and 

New Mexico included a 60 percent minority and 18 percent low-income population. There are three 

census block groups located within the 16-kilometer radius surrounding Section 35, none of which 

contained a minority or low-income population. Figure 3–9 shows the cumulative populations living at a 

given distance from Section 35. The total population living within 16 kilometers of Section 35 is 

primarily concentrated to the north and northwest along the outskirts of Carlsbad. The distribution of the 

total minority and low-income populations is similar to that of the total population. It is estimated that 

approximately 13 people reside within approximately 3.2 kilometers (2 miles) of Section 35, consisting of 

a 47 percent minority population and a 5 percent low-income population (Census 2011d, 2011e). 
Affected Environment 

3–33

Figure 3–9. Populations Residing Within 16 Kilometers (10 miles) of the Storage Location at 

Waste Isolation Pilot Plant Vicinity Section 35 

3.3 REFERENCES 

3.3.1 References in Addition to Those from the Draft GTCC EIS

Bachman, G.O., 1980, Regional Geology and Cenozoic History of Pecos Region, Southeastern New 

Mexico, Open-File Report 80-1099, U.S. Geological Survey, Denver, Colorado.

BISON (Biota Information System of New Mexico), 2012, Database Query, accessed through 

http://www.bison-m.org/reports.aspx?rtype=13&status=%27201%27,%27202%27, September 10. 

BLS (Bureau of Labor Statistics), 2012, Databases & Tools, Local Area Unemployment Statistics, 

accessed through http://www.bls.gov/data/. 

Census (U.S. Census Bureau), 2001a, 2000 Decennial Census, Summary File 1, Table P8, “Hispanic or 

Latino by Race,” accessed through http://factfinder2.census.gov/faces/nav/jsf/pages/index.xhtml, May 23. 

Census (U.S. Census Bureau), 2001b, 2000 Decennial Census, Summary File 3, Table P088, “Ratio of 

Income in 1999 to Poverty Level – Universe: Population for Whom Poverty Status is Determined,”

accessed through http://factfinder2.census.gov/faces/nav/jsf/pages/index.xhtml, May 23. 

Census (U.S. Census Bureau), 2011a, 2010 Decennial Census, Summary File 1, Table P12, “Sex by 

Age – Universe: Total Population,” accessed through http://factfinder2.census.gov/faces/nav/jsf/pages/ 

index.xhtml, August 18. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

3–34

Census (U.S. Census Bureau), 2011b, 2010 Decennial Census, Summary File 1, Table H3, “Occupancy 

Status – Universe: Housing Units,” accessed through http://factfinder2.census.gov/faces/nav/jsf/pages/ 

index.xhtml, August 18. 

Census (U.S. Census Bureau), 2011c, 2010 Decennial Census, Summary File 1, Table H4, “Tenure –

Universe: Occupied Housing Units,” accessed through http://factfinder2.census.gov/faces/nav/jsf/pages/ 

index.xhtml, August 18. 

Census (U.S. Census Bureau), 2011d, 2010 Decennial Census, Summary File 1, Table P5, “Hispanic or 

Latina Origin by Race – Universe: Total Population,” accessed through http://factfinder2.census.gov/ 

faces/nav/jsf/pages/index.xhtml, August 18. 

Census (U.S. Census Bureau), 2011e, 2006–2010 American Community Survey 5-Year Estimates, 

Table C17002, “Ratio of Income to Poverty Level in the Past 12 Months – Universe: Population for 

Whom Poverty Status is Determined,” accessed through http://factfinder2.census.gov/faces/nav/jsf/pages/ 

index.xhtml, December 8. 

Chugg, J.C., G.W. Anderson, D.L. Kink, and L.H. Jones, 1952, Soil Survey of Eddy Area, New Mexico,

U.S. Department of Agriculture. 

DOE (U.S. Department of Energy), 2004b, Supplement Analysis for Disposal of Polychlorinated 

Biphenyl-Commingled Transuranic Waste at the Waste Isolation Pilot Plant, DOE/EIS-0026-SA-02, 

Carlsbad Field Office, Carlsbad, New Mexico, June. 

DOE (U.S. Department of Energy), 2009, Supplement Analysis for the Waste Isolation Pilot Plant 

Site-Wide Operations, DOE/EIS-0026-SA-07, Carlsbad Field Office, Carlsbad, New Mexico, May. 

DOE (U.S. Department of Energy), 2011a, Final Long-Term Management and Storage of Elemental 

Mercury Environmental Impact Statement, DOE/EIS-0423, Office of Environmental Management, 

Washington, DC, January. 

DOE (U.S. Department of Energy), 2011b, Draft Environmental Impact Statement for the Disposal of 

Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC-Like Waste, DOE/EIS-0375-D, 

Office of Environmental Management, Washington, DC, February. 

DOE (U.S. Department of Energy), 2012, Waste Isolation Pilot Plant Annual Site Environmental Report 

for 2011, DOE/WIPP-12-3489, Carlsbad Field Office, Carlsbad, New Mexico, September. 

EPA (U.S. Environmental Protection Agency), 2012, Air Quality Statistics Reports for 2003–2007, 

Carlsbad-Artesia, NM, accessed through www.epa.gov/airquality/airdata/ad_rep_con.html, November 26. 

NMRPTC (New Mexico Rare Plant Technical Council), 2012, New Mexico Rare Plants, accessed 

through http://nmrareplants.unm.edu/county_result.php?output=html, September 10. 

Rosholt, J.N., and C.R. McKinney, 1980, Uranium Series Disequilibrium Investigations Related to 

the WIPP Site, New Mexico (USA), Part II, Uranium Trend Dating of Surficial Deposits and Gypsum 

Spring Deposit Near WIPP Site, New Mexico, Open-File Report 80-879, U.S. Geological Survey, 

Denver, Colorado. 

Rutley, J.S., 2012, U.S. Bureau of Land Management, Carlsbad Field Office, personal communication 

(email) to D. Levenstein, U.S. Department of Energy, Office of Environmental Management, “Potash 

Mining in the Vicinity of WIPP,” December 5. 
Affected Environment 

3–35

USFWS (U.S. Fish and Wildlife Service), 2012, All Listed and Sensitive Species in New Mexico 

by County, accessed through http://www.fws.gov/southwest/es/NewMexico/SBC_view_all_BC.cfm, 

September 10. 

USGS (U.S. Geological Survey), 2012, Earthquake Hazards Program – Hazards, Interactive Hazards 

Map Conterminous US 2008, accessed through http://earthquake.usgs.gov/hazards/apps/map/, September. 

Code of Federal Regulations

10 CFR 835, U.S. Department of Energy, “Occupational Radiation Protection.”

40 CFR 81.332, U.S. Environmental Protection Agency, “Designation of Areas for Air Quality Planning 

Purposes, Section 107 Attainment Status Designations: New Mexico.”

40 CFR 81.421, U.S. Environmental Protection Agency, “Designation of Areas for Air Quality Planning 

Purposes, Identification of Mandatory Class I Federal Areas Where Visibility is an Important Value: 

New Mexico.”

40 CFR 81.429, U.S. Environmental Protection Agency, “Designation of Areas for Air Quality Planning 

Purposes, Identification of Mandatory Class I Federal Areas Where Visibility is an Important 

Value: Texas.”

40 CFR 761, U.S. Environmental Protection Agency, “Polychlorinated Biphenyls (PCBs) Manufacturing, 

Processing, Distribution in Commerce, and Use Prohibitions.”

Executive Orders

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and 

Low-Income Populations, February 11, 1994. 

New Mexico Administrative Code

20.2.3 NMAC, New Mexico Environmental Improvement Board, “Ambient Air Quality Standards.”

U.S. Public Laws

P.L. 102-579, The Waste Isolation Pilot Plant Land Withdrawal Act. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

3–36

3.3.2 References Incorporated from the Draft GTCC EIS

Beauheim, R.L., and R.M. Roberts, 2002, “Hydrology and Hydraulic Properties of a Bedded Evaporite 

Formation,” Journal of Hydrology 259(1 4):66 88. 

BLM (U.S. Bureau of Land Management), 1988, Carlsbad Resource Management Plan, U.S. Department 

of the Interior, Roswell District, New Mexico. 

Bradley, E.W., et al., 1993, Technical Basis for External Dosimetry at the Waste Isolation Pilot Plant 

(WIPP), DOE/WIPP-93-068, Waste Isolation Division, Westinghouse Electric Corp., Carlsbad, New 

Mexico, and Science Applications International Corporation, Oak Ridge, Tennessee. 

Broadhead, R.F., et al., 1995, “Oil and Gas Resource Estimates,” in Evaluation of Mineral Resources at 

the Waste Isolation Pilot Plant (WIPP) Site, Westinghouse Electric Corporation, Waste Isolation 

Division, Carlsbad, New Mexico. 

Carlsbad, 2008a, City of Carlsbad Municipal Water System 2007 Annual Consumer Report on the 

Quality of Your Drinking Water, Carlsbad, N.M., accessed through http://www.cityofcarlsbadnm.com/ 

documents/CCR2007.pdf, August. 

Carlsbad, 2008b, Infrastructure Improvement Plan for Water, Wastewater, and Roadway, Carlsbad, 

N.M., accessed through http://www.cityofcarlsbadnm.com/documents/INFRASTRUCTURECAPITAL 

IMPROVEMENTPLAN-1-22-2008revised03-18-08.pdf, August. 

CEQ (Council on Environmental Quality), 1997, Environmental Justice Guidance Under the National 

Environmental Policy Act, Executive Office of the President, Washington, DC, accessed through 

http://www.whitehouse.gov/CEQ/, December. 

Crossroads, 2005, “Unconventional Natural Gas Drives New Mexico Rig Count,” ERMS 547000, 

Crossroads – Economic Trends in the Desert Southwest, Issue 1, Federal Reserve Bank of Dallas, El Paso 

Branch. 

DOE (U.S. Department of Energy), 1980, Final Environmental Impact Statement, Waste Isolation Pilot 

Plant, DOE/EIS-0026, Vol. 1, Assistant Secretary for Defense Program, Washington, DC, October. 

DOE (U.S. Department of Energy), 1990, Final Supplement Environmental Impact Statement, Waste 

Isolation Pilot Plant, DOE/EIS-0026-FS, Vol. 1, Office of Environmental Restoration and Waste 

Management, Washington, DC, January. 

DOE (U.S. Department of Energy), 1993, Waste Isolation Pilot Plant Land Management Plan, 

DOE/WIPP 93-004, Carlsbad, New Mexico. 

DOE (U.S. Department of Energy), 1996a, Transuranic Waste Baseline Inventory Report, Rev. 3, 

DOE/CAO-95-1121, ERMS 243330, Washington, DC. 

DOE (U.S. Department of Energy), 1996b, Title 40 CFR Part 191 Compliance Certification Application 

for the Waste Isolation Pilot Plant, DOE/CAO-1996-218, Waste Isolation Pilot Plant, Carlsbad Area 

Office, Carlsbad, New Mexico. 

DOE (U.S. Department of Energy), 1997, Waste Isolation Pilot Plant Disposal Phase Final Supplemental 

Environmental Impact Statement, DOE/EIS-0026-S-2, Carlsbad Field Office, Carlsbad, New Mexico, 

September. 
Affected Environment

3–37

DOE (U.S. Department of Energy), 1999, The Geologic and Hydrogeologic Setting of the Waste Isolation 

Pilot Plant, SAND98-2084, accessed through http://www.osti.gov/energycitations/servlets/purl/

4168-7GgR2f/webviewable/4168.pdf, July 2008.

DOE (U.S. Department of Energy), 2002a, Environmental Assessment for the Actinide Chemistry and 

Repository Science Laboratory, Final, DOE/EA-1404, Carlsbad Field Office, Carlsbad, New Mexico.

DOE (U.S. Department of Energy), 2002b, Waste Isolation Pilot Plant Land Management Plan, 

DOE/WIPP 93-004, Carlsbad Field Office, Carlsbad, New Mexico, January.

DOE (U.S. Department of Energy), 2004a, Waste Isolation Pilot Plant Environmental Monitoring Plan, 

DOE/WIPP 99-2194, Rev. 2, prepared by Washington TRU Solutions LLC, accessed through htpp://

www.wipp.energy.gov/library/EMP/emp.emp.htm, May 2008.

DOE (U.S. Department of Energy), 2006, Waste Isolation Pilot Plant Annual Site Environmental Report 

for 2005, DOE/WIPP-06-2225, September.

DOE (U.S. Department of Energy), 2007, Waste Isolation Pilot Plant Annual Site Environmental Report 

for 2006, DOE/WIPP-07-2225, Carlsbad Field Office, Carlsbad, New Mexico, September, accessed 

through http://www.wipp.energy.gov/library/ser/07-2225.pdf/, May 2008.

DOE (U.S. Department of Energy), 2008a, Waste Isolation Pilot Plant Annual Site Environmental Report 

for 2007, DOE/WIPP-08-2225, Carlsbad Field Office, Carlsbad, New Mexico, September.

DOE (U.S. Department of Energy), 2008b, “Hydrological Investigations,” Appendix HYDRO-2009, in 

Title 40 CFR Part 191, Subparts B and C – Compliance Recertification Application for the Waste 

Isolation Pilot Plant, DOE/WIPP 01-3199, draft, Carlsbad Field Office, Carlsbad, New Mexico, 

December.

DOE (U.S. Department of Energy), 2011c, Waste Isolation Pilot Plant Annual Site Environmental Report 

for 2010, DOE/WIPP-11-2225, September.

Eldred, K.M., 1982, “Standards and Criteria for Noise Control – An Overview,” Noise Control 

Engineering 18(1):16–23, January–February.

EPA (U.S. Environmental Protection Agency), 2006, Technical Support Document for Section 194.14/15 

Evaluation of Karst at the WIPP Site, Center for the Waste Isolation Pilot Plant, accessed through 

http://www.epa.gov/radiation/docs/wipp/recertification/194_14-15-karst-sd.pdf, July 2008.

EPA (U.S. Environmental Protection Agency), 2008a, National Ambient Air Quality Standards (NAAQS), 

accessed through http://www.epa.gov/air/criteria.html, October 20.

EPA (U.S. Environmental Protection Agency), 2008b, Energy CO2 Emissions by State, accessed through 

http://www.epa.gov/climatechange/emissions/state_energyco2inv.html, April 19.

EPA (U.S. Environmental Protection Agency), 2009, AirData: Access to Air Pollution Data, accessed 

through http://www.epa.gov/air/data/.

Jierree, C., 2009, Radiological Control and Dosimetry, Waste Isolation Pilot Plant, New Mexico, personal 

communication (email) to G. Dixon, U.S. Department of Energy, Office of Environmental Management, 

“WIPP External Doses,” November 4.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

3–38

Kelley, V.A., and G.J. Saulnier, Jr., 1990, Core Analyses for Selected Samples from the Culebra Dolomite 

at the Waste Isolation Pilot Plant Site, SAND90-7011, Sandia National Laboratories, Albuquerque, New 

Mexico. 

Lorenz, J.C., 2006, Assessment for the Potential for Karst in the Rustler Formation at the WIPP Site, 

SAND2005-7303, Sandia National Laboratories, Albuquerque, New Mexico, January. 

McCauslin, S., 2010, U.S. Department of Energy, Carlsbad Field Office, personal communication (email) 

to M. Picel, Argonne National Laboratory, Argonne, Illinois, July 27. 

Mercer, J.W., 1983, Geohydrology of the Proposed Waste Isolation Pilot Plant Site, Los Medaños Area, 

Southeastern New Mexico, Water Resources Investigations Report 83-4016, U.S. Geological Survey. 

NCDC (National Climatic Data Center), 2008, Storm Events, National Oceanic and Atmospheric 

Administration, Satellite and Information Service, accessed through http://www4.ncdc.noaa.gov/cgi-win/ 

wwcgi.dll?wwEvent~Storms, July. 

NCRP (National Council on Radiation Protection and Measurements), 2009, Ionizing Radiation Exposure 

of the Population of the United States, Report No. 160, Bethesda, Maryland. 

NMBGMR (New Mexico Bureau of Geology and Mineral Resources), 2008, Geologic Background –

Zuni-Bandera Volcanic Field, accessed through http://geoinfo.nmt.edu/tour/federal/monuments/ 

el_malpais/zuni-bandera/background.html, August 19. 

NMED (New Mexico Environment Department), 2007, Waste Isolation Pilot Plant Hazardous Waste 

Permit, Attachment G – Traffic Patterns, Santa Fe, New Mexico, February. 

NMEMNRD (New Mexico Energy, Minerals, and Natural Resources Department), 2006, New Mexico 

Potash Production and Value, 1980–2005, accessed through www.emnrd.state.nm.us/MMD/MRRS/ 

documents/Potash.pdf. 

Popielak, R.S., et al., 1983, Brine Reservoirs in the Castile Formation, Southeastern New Mexico, 

TME 3153, prepared for U.S. Department of Energy, Albuquerque, New Mexico. 

Powers, D.W., et al., 1978, Geological Characterization Report – Waste Isolation Pilot Plant (WIPP) 

Site, Southeastern New Mexico, Vols. 1 and 2, SAND78-1596, Sandia National Laboratories, 

Albuquerque, New Mexico. 

Powers, D.W., 2009, Geology of the WIPP Vicinity for Disposal of GTCC Low-Level and GTCC-Like 

Radioactive Waste, memorandum to S. Wagner, Sandia National Laboratories, Carlsbad, New Mexico, 

September 28. 

Richey, S.F., et al., 1985, Geohydrology of the Delaware Basin and Vicinity, Texas and New Mexico, 

Water Resources Investigations Report 84-4077, U.S. Geological Survey. 

Roberts, R.M., et al., 1999, Hydraulic Testing of Salado Formation Evaporites at the Waste Isolation 

Pilot Plant Site: Final Report, SAND98-2537, Sandia National Laboratories, Albuquerque, New Mexico. 

Sandia (Sandia National Laboratories), 2008, GTCC LLW Environmental Impact Statement: Pre-Closure 

Assessment Data Package, Waste Isolation Pilot Plant, prepared by Sandia, Carlsbad, New Mexico, for 

U.S. Department of Energy, Washington, DC, October. 
Affected Environment 

3–39

Sanford, A., et al., 1995, A Report on the Seismicity of the WIPP Site for the Period April 1, 1995 

Through June 30, 1995, WD:95:02158, Westinghouse Electric Corporation, Carlsbad, New Mexico. 

TerraTek, Inc., 1996, Physical Property Characterization of Miscellaneous Rock Samples, 

Contract AA-2896, TR97-03, ERMS# 410250, report prepared for Sandia National Laboratories. 

USGS (U.S. Geological Survey), 2009, National Water Information System – Surface Water: USGS 

08406500 Pecos River near Malaga, NM Annual and Monthly Statistics (1938 to 2008), accessed through 

http://nwis.waterdata.usgs.gov/nm/nwis/current/?type=flow&group_key=county_cd, March 26. 

USGS (U.S. Geological Survey), 2010, Earthquake Search Results, USGS Earthquake Database, National 

Earthquake Information Center (NEIC), accessed through http://earthquake.usgs.gov/earthquakes/ 

eqarchives/epic/epic_circ.php, May. 

WRCC (West Regional Climate Center), 2008, Historical Climate Information, accessed through 

http://www.wrcc.dri.edu/CLIMATEDATA.html, May. 

Code of Federal Regulations

40 CFR 191, U.S. Environmental Protection Agency, “Environmental Radiation Protection Standards for 

Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes.”

New Mexico Administrative Code

20.2.72 NMAC, New Mexico Environment Department, “Air Quality (Statewide): Construction Permits.”

U.S. Department of Energy Directives

DOE Manual 470.4-2, Physical Protection, August 26, 2005. 

CHAPTER 4

ENVIRONMENTAL CONSEQUENCES

4–1

CHAPTER 4 

ENVIRONMENTAL CONSEQUENCES 

Chapter 4 presents the potential impacts on the human environment of implementing the alternative locations that 

are being considered in this Draft Long-Term Management and Storage of Elemental Mercury Supplemental 

Environmental Impact Statement (Draft Mercury Storage SEIS). Seven candidate sites were evaluated as 

alternatives for long-term mercury storage in the January 2011 Long-Term Management and Storage of Elemental 

Mercury Environmental Impact Statement (Mercury Storage EIS) (DOE 2011a), and a discussion of the impacts 

associated with these candidate sites can be found in Chapter 4 of the January 2011 Mercury Storage EIS. The 

analyses presented in the January 2011 Mercury Storage EIS remain valid and are incorporated into this Draft 

Mercury Storage SEIS with two exceptions: (1) the occupational and public health and safety analysis; and (2) the 

socioeconomics and environmental justice analysis. This Draft Mercury Storage SEIS includes updates to the 

occupational and public health and safety analysis resulting from changes to the definition of severity levels 

(i.e., magnitude of impacts) for acute-inhalation exposures to the public under certain accident scenarios. This 

Draft Mercury Storage SEIS also includes updates to the socioeconomics and environmental justice analyses to 

incorporate 2010 decennial census information that was not available at the time the January 2011 Mercury 

Storage EIS was published. The updates to the analyses are presented in Appendix B and Appendix E of this 

Draft Mercury Storage SEIS. A No Action Alternative was also evaluated in the January 2011 Mercury 

Storage EIS, which includes the impacts of continued storage of elemental mercury in the absence of a facility(ies)

designated by the U.S. Department of Energy. Potential impacts associated with each Waste Isolation Pilot Plant 

Vicinity reference location are discussed in Section 4.2. Activities and impacts associated with closure of a 

mercury storage facility(ies) are presented in Section 4.3. Cumulative impacts, mitigation measures, and resource 

commitments are presented in Sections 4.4, 4.5, and 4.6, respectively.

4.1 INTRODUCTION 

1 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this supplemental 

environmental impact statement. 

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

implementation of the three Waste Isolation Pilot Plant (WIPP) Vicinity reference locations considered in 

this Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental 

Impact Statement (Draft Mercury Storage SEIS). As presented in Chapter 1, the U.S. Department of 

Energy’s (DOE’s) proposed action is to select a suitable location(s) for the long-term management and 

storage of elemental mercury1 generated in the United States. 

A detailed description of the WIPP Vicinity reference locations is provided in Chapter 2, Section 2.3. A 

summary comparison of the projected environmental effects among all alternatives analyzed in this draft 

SEIS and in the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental 

Impact Statement (Mercury Storage EIS) is presented in Chapter 2, Section 2.6. Site-specific information 

for the WIPP Vicinity reference locations 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 impact 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 

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

4–2

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). 

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

used a 40-year period of analysis 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. A 40-year period of analysis is consistent with the timeframe used in previous 

analyses by the Defense Logistics Agency (DLA 2004:1-1) and the U.S. Environmental Protection 

Agency (EPA) (EPA 1997a–e). These are estimates with a degree of uncertainty; therefore, it is possible 

that more or less than 10,000 metric 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(ies) could be constructed in a modular fashion to accommodate storage of 

mercury on an as-needed basis (see Chapter 2, Sections 2.2.2). The ability to build the storage 

facility(ies) in a modular fashion would also ensure that the facility(ies) is sized correctly for the amount 

of mercury that would eventually require storage. As a conservative assumption, the impact analyses 

presented in this chapter evaluate the construction and operation of a new, full-size 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 of mercury or extend its operations beyond the 40-year period of 

analysis. Closure of the storage facility(ies) would occur at the end of storage activities, as discussed in 

Section 4.3. 

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

January 2011 Mercury Storage EIS and this draft SEIS 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 operation of a mercury storage facility(ies) at 

each of the alternative locations analyzed in this draft SEIS. Finally, Appendix D includes overviews of 

input data and analysis assumptions, and mercury toxicity and approach to evaluating risk from normal 

operations, facility accidents, and transportation. Additional detail for these subject areas can also be 

found in Appendices B, C, and D of the January 2011 Mercury Storage EIS. 

4.2 WASTE ISOLATION PILOT PLANT SITE 

Under this alternative, elemental mercury would be stored at one of three WIPP Vicinity reference 

locations, as described in Chapter 2, Section 2.3. WIPP is the Nation’s only underground repository for 

the permanent disposal of defense-generated transuranic waste. The WIPP site is located in Eddy County 

in the Chihuahuan Desert of southeastern New Mexico (see Chapter 3, Figure 3–1). The site is about 

42 kilometers (26 miles) east of Carlsbad in a region known as Los Medaños, a relatively flat, sparsely 

inhabited plateau with little surface water. The WIPP site encompasses approximately 41 square 

kilometers (16 square miles) under the jurisdiction of DOE pursuant to the Waste Isolation Pilot Plant 

Land Withdrawal Act (LWA) (P.L. 102-579). Under this alternative, a new mercury storage facility 

would be constructed at or in the vicinity of the WIPP site. The new mercury storage facility would be 

similar to that proposed at some of the other candidate sites previously analyzed in the January 2011 
Environmental Consequences

4–3

Mercury Storage EIS. Many of the impacts on resource areas are similar for all of the WIPP Vicinity 

reference locations; however, differences in potential impacts among the three locations are identified, 

where appropriate.

4.2.1 Land Use and Visual Resources

4.2.1.1 WIPP Vicinity Section 10

Minor impacts on land use and visual resources are expected from construction and operation of a new 

mercury storage building at WIPP Vicinity Section 10. Construction of this new facility would require 

the disturbance of approximately 3.1 hectares (7.6 acres) for building construction and laydown areas 

(see Chapter 2, Section 2.2.2). The proposed mercury storage facility would be located on relatively 

undisturbed land in Section 10 adjacent to and north of the WIPP land withdrawal boundary (LWB). The 

mercury storage facility would be located outside of the WIPP LWB. The completed facility boundary 

would similarly encompass approximately 3.1 hectares (7.6 acres) within its fenced perimeter. The 

footprint of the mercury storage building would occupy approximately 1.6 hectares (3.9 acres) of this 

area. Mercury storage operations in this area would be compatible with current WIPP waste management 

and storage operations. Pursuant to the Federal Land Policy and Management Act of 1976, this land 

would be withdrawn from all forms of entry, appropriation, and disposal under the public land laws and 

reserved for the purposes of operating a mercury storage facility. DOE would prepare a land management 

plan, as appropriate, and provide opportunities for the public and for Federal, state, and local agencies to 

participate in the land use planning. Potash mining in the region surrounding WIPP, including an existing 

lease for future underground mining operations in Section 10, may influence the ability to site a mercury 

storage facility due to the potential for increased risk of land subsidence. Since the mercury storage 

facility would occupy approximately 1 percent of the 260 hectares (640 acres) that comprise Section 10, it 

is expected that there would be negligible impacts on livestock grazing activities. Future land use 

activities that would be permitted within or immediately adjacent to the mercury storage facility would be 

limited to those that would not jeopardize the integrity of the facility, create a security risk, or create a 

worker or public safety risk. The low profile of the new building would have a negligible impact on the 

overall viewshed of this area from offsite vantage points. Therefore, mercury storage operations would 

not result in a change to U.S. Bureau of Land Management visual resource management classifications.

4.2.1.2 WIPP Vicinity Section 20

Minor impacts on land use and visual resources are expected from construction and operation of a new 

mercury storage building at WIPP Vicinity Section 20. The proposed mercury storage facility would be 

located on relatively undisturbed land to the west of WIPP directly across North Access Road. The 

mercury storage facility would be located within the WIPP LWB. Impacts would be similar to those 

described above for WIPP Vicinity Section 10; however, visual impacts would be less noticeable due to 

the proximity to other structures associated with WIPP. Use of WIPP Vicinity Section 20 would need to 

be considered against requirements described in the WIPP LWA. Use of WIPP Vicinity Section 20 for 

construction and operation of a facility for the long-term management and storage of elemental mercury 

would alter the current land use and could require Federal legislation.

4.2.1.3 WIPP Vicinity Section 35

Minor impacts on land use and visual resources are expected from construction and operation of a new 

mercury storage building at WIPP Vicinity Section 35. The proposed mercury storage facility would be 

located on relatively undisturbed land in Section 35 adjacent to and east of the WIPP LWB. The mercury 

storage facility would be located outside of the WIPP LWB. Impacts would be similar to those described 

above for WIPP Vicinity Section 10; however, Section 35 is not currently under an existing lease for 

potash mining. One oil well exists within Section 35. Use of WIPP Vicinity Section 35 would require 

this land to be withdrawn from all forms of entry, appropriation, and disposal under the public land laws 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–4

and reserved for the purposes of operating a mercury storage facility. Use of WIPP Vicinity Section 35

for construction and operation of a facility for the long-term management and storage of elemental 

mercury would alter the current land use.

4.2.2 Geology, Soils, and Geologic Hazards

4.2.2.1 WIPP Vicinity Section 10

4.2.2.1.1 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 (7.6 acres) of land at WIPP. 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 atop 

a gravel base. Additional trenching may be necessary to install foundation footings or connect the new 

mercury storage facility to regional utility infrastructure; trenches could be about 0.6 meters (2 feet) wide 

by 1.2 meters (4 feet) deep. 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.

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) during facility construction would serve to minimize 

soil erosion and loss.

At WIPP, the Mescalero caliche could present site development limitations due to the presence of this 

calcium carbonate cemented unit (see Chapter 3, Section 3.2.2). However, due to the limited depth of 

excavation and the limited thickness of the caliche layer, it should not present substantial constraints for 

construction. A site survey and geotechnical study would be conducted to confirm site geologic and 

hydrogeologic characteristics for facility siting and engineering purposes. This would include an analysis 

to assess the potential for subsurface dissolution features and land subsidence. Location of the building 

footprint and adherence to best management practices would serve to minimize construction impacts.

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 be engineered to minimize soil 

erosion or would be returned to natural conditions. There would be no additional impact on geology and 

soils from operations. 

4.2.2.1.2 Geologic Hazards

Hazards from large-scale geologic conditions, such as earthquakes, and other site geologic conditions 

with the potential to affect WIPP 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. 

The WIPP region is considered to be an area of low-to-moderate seismicity. Earthquakes have 

historically produced ground motion effects equivalent to Modified Mercalli Intensity V in the vicinity of 

the site (see the January 2011 Mercury Storage EIS: Appendix B, Table B–4). As described in Chapter 3, 

Section 3.2.2.3, Section 10 is located about 100 kilometers (60 miles) from the closest potentially active 

fault. In addition, the predicted peak ground acceleration at the site from an earthquake with an annual 

probability of occurrence of 1 in 2,500 is 0.08 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 the January 2011 Mercury Storage EIS, Appendix B, Section B.3.2, DOE Order 420.1B and 
Environmental Consequences

4–5

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 4.2.9.1.2.

Potash mining in the region surrounding WIPP, including an existing lease for future underground mining 

operations in Section 10, may influence the ability to site a mercury storage facility due to the potential 

for increased risk of land subsidence.

4.2.2.2 WIPP Vicinity Section 20

As described in Chapter 3, Section 3.2.2, the geology, soils and geologic hazards of Sections 10 and 20 

are similar. Therefore, the environmental impacts of construction and operation of a mercury storage 

facility at Section 20 would be similar to that described in Section 4.2.2.1 for Section 10.

4.2.2.3 WIPP Vicinity Section 35

As described in Chapter 3, Section 3.2.2, the geology, soils and geologic hazards of Sections 10 and 35 

are similar. Therefore, the environmental impacts of construction and operation of a mercury storage 

facility at Section 35 would be similar to that described in Section 4.2.2.1 for Section 10.

4.2.3 Water Resources

4.2.3.1 WIPP Vicinity Section 10

4.2.3.1.1 Surface Water

Facility construction activities at the WIPP site are not anticipated to have direct impacts on surface-water 

features that are within or adjacent to the site boundary. The WIPP site has no natural surface-water 

bodies within the site boundary, and the nearest significant surface-water bodies, Laguna Grande de la Sal 

and the Pecos River, are located 13 kilometers (8 miles) west-southwest and 16 kilometers (10 miles) 

west of the site, respectively. As discussed in Chapter 3, Section 3.2.3.1, the topography in the vicinity of 

the WIPP site exhibits some broad valley forms, potentially indicative of areas of concentrated surface 

runoff and integrated drainages during prolonged rainfall events. In general, the Pecos River drainage 

system drains to the southeast. The WIPP site is within the Pecos River drainage basin; however, a 

drainage divide occurs between the Pecos River and the WIPP site.

Section 10 is not located within or adjacent to the 100- or 500-year floodplains of the Pecos River. 

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 the 

environment from natural phenomena hazards, including flooding, and specifically that DOE facilities 

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.

During facility construction, adherence to best management practices for soil erosion and sediment 

control, such as the use of sediment fencing, hay bales, mulching, geotextile matting, and rapid reseeding 

would minimize soil erosion and loss. Additionally, spill prevention and waste management practices 

would be utilized to minimize suspended sediment, the transport of other deleterious materials, 

and potential water quality impacts. WIPP does not have an existing National Pollutant Discharge

Elimination System permit or construction stormwater discharge permit. Regulatory notification to either 

EPA or the authorized state regulatory compliance division of the intent to provide long-term storage and 
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4–6

management of elemental mercury would be required for WIPP. Communication and coordination with

all applicable regulatory agencies, including site-specific discussions and facility-specific permitting 

requirements (application for new permits or modification to existing permits), will be required for the 

long-term management and storage of elemental mercury.

Design, construction, and operation of the proposed mercury facility would incorporate structural controls 

and practices to prevent the release of elemental mercury and to prevent any spills or other releases. 

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, of the January 2011 Mercury Storage EIS (DOE 2011a). Facility operations 

would also be conducted in accordance with an integrated contingency plan and spill prevention, control, 

and countermeasures plan, or equivalent plans as mandated by facilities permitted under the Resource

Conservation and Recovery Act (RCRA) (40 CFR 264.50 et seq.) In the event that abnormal operating 

conditions occur, and there is a release of elemental mercury, the structural controls and practices will 

prevent contamination from reaching the soil or other surfaces where it could be transferred to surface 

waters or groundwater.

It is conservatively estimated that construction activities for a new mercury storage facility would require 

approximately 1,270,000 liters (336,000 gallons) of water over a 6-month construction period. This 

volume would primarily be required for dust control and soil compaction. For the proposed facility in 

Section 10, it is anticipated that water would be trucked to the construction site and stored in a temporary 

storage tank that would be sufficient to supply this volume. There would be no diversion of nearby 

surface water or onsite groundwater during the construction phase. 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). 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 a separate nonhazardous sanitary liquid waste storage and treatment or septic 

system that would be installed.

4.2.3.1.2 Groundwater

As described in Chapter 3, Section 3.2.3.2, there are no known natural groundwater features within 

Section 10 that would affect the engineering aspects of slope stability or subsidence. The 

Gatuña Formation, which unconformably overlies the Santa Rosa, is also known to have saturated 

zones occurring in discontinuous perched zones that may be due to an anthropogenic source 

(DOE 1999a, 2008). Facility construction is not expected to have any impact on groundwater hydrology 

due to the depth of the excavation. Excavation for preparing the site and laying the foundation is not 

expected to exceed a depth of 0.6 meters (2 feet), with the exception of small trenches, which could be 

approximately 1.2 meters (4 feet) deep, for connecting the utilities or installing concrete footers. In the 

event that perched groundwater was encountered by trenching to depths of no greater than 1.2 meters 

(4 feet), excavations may have to be dewatered and the groundwater contained for testing and treatment, 

if found contaminated, prior to discharge. Because 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.

4.2.3.2 WIPP Vicinity Section 20

Surface-water impacts would be consistent with those addressed in Section 4.2.3.1 for Section 10. 

However, it is anticipated that any water needed for the construction of the proposed facility in Section 20 

would be obtained from the existing WIPP supply system instead of being trucked in to the site as 

described for Section 10. It is conservatively estimated that construction activities for a new mercury 

storage facility would require approximately 1,270,000 liters (336,000 gallons) of water over a 6-month 

construction period.
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4–7

Groundwater impacts would be consistent with those addressed above for Section 10. As described in 

Chapter 3, Section 3.2.3.2, there are no known natural groundwater features within Section 20 that would 

affect the engineering aspects of slope stability or subsidence. However, anthropogenic water has been 

found near the center part of WIPP in the Santa Rosa Formation, which is also near Section 20. Facility 

construction is not expected to have any impact on groundwater hydrology due to the depth of the 

excavation. Because 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.

4.2.3.3 WIPP Vicinity Section 35

Surface-water impacts would be consistent with those addressed in Section 4.2.3.1 for Section 10. It is 

anticipated that any water needed for the construction of the proposed facility in Section 35 would be 

trucked in to the site as described for Section 10. 

Groundwater impacts would be consistent with those addressed above for Sections 10 and 20. Facility 

construction is not expected to have any impact on groundwater hydrology due to the depth of the 

excavation. Because 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.

4.2.4 Meteorology, Air Quality, and Noise

4.2.4.1 WIPP Vicinity Section 10

4.2.4.1.1 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 

Chapter 4, Section 4.9.9.2, of the January 2011 Mercury Storage EIS (DOE 2011a). As previously stated,

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 the 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 Code of Federal Regulations (CFR), Section 264.31, and applicable 

state RCRA requirements to prevent the release of stored wastes. As the WIPP region is susceptible to 

regular occurrence of high winds, the new mercury storage facility at Section 10 would be designed and 

constructed to withstand potential high winds and tornadoes and other meteorological events.

4.2.4.1.2 Air Quality

Minor short-term air quality impacts would result from construction of a mercury storage building within

Section 10. 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, of the January 2011 Mercury Storage EIS (DOE 2011a).

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) 
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4–8

or nearby offsite individuals. Section 4.2.9.1 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 about 20 nanograms per cubic meter for new 

construction within Section 10. 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.

Minor short-term air quality impacts would result from an increase in truck or rail activity while mercury 

is moved to any of the WIPP Vicinity reference locations for long-term management and storage. Truck 

and rail transport are discussed in more detail in Section 4.2.9.1.3. Estimated emissions from truck and 

rail transportation are presented in Tables 4–1 and 4–2. Over the 40-year period of analysis, the estimated 

number of truck or rail shipments would diminish over time and resulting emissions would decrease.

Annual carbon dioxide emissions would be highest during construction. The second highest year of 

carbon dioxide emissions would be during the first 2 years of operations, when the mercury is delivered to 

the site. Emissions during these first 2 years of operations would be approximately 258 metric tons 

(285 tons) per year, which would be more than rail emissions. As similarly noted in Chapter 4, 

Section 4.3.4.2, of the January 2011 Mercury Storage EIS, 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 of the January 2011 Mercury Storage EIS.

Table 4–1. Air Pollutant Emissions from Transportation of Elemental Mercury by

Truck to All WIPP Vicinity Reference Locations

Pollutant Truck Emissions by Pollutant (metric tons)

Site

Carbon 

Monoxide

Nitrogen 

Dioxide

Volatile 

Organic 

Compounds PM2.5 PM10

Sulfur 

Dioxide

Carbon 

Dioxide

WIPP Vicinity 

Section 10, 20, or 35

2.56 9.53 0.51 0.204 0.257 0.0159 1,700

Note: Emissions are based on truck mileage 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. Values represent 

total emissions over 40 years.

Key: PMn=particulate matter with an aerodynamic diameter less than or equal to n micrometers; WIPP=Waste Isolation Pilot 

Plant.

Table 4–2. Air Pollutant Emissions from Transportation of Elemental Mercury by

Rail to All WIPP Vicinity Reference Locations

Pollutant Locomotive Emissions by Pollutant (metric tons)

Site

Carbon 

Monoxide

Nitrogen 

Dioxide

Volatile 

Organic 

Compounds PM2.5 PM10

Sulfur 

Dioxide

Carbon 

Dioxide

WIPP Vicinity 

Section 10, 20, or 

35a

2.1 12.4 0.69 0.36 0.371 0.247 806

a Transportation by rail to Section 10 or 35 would involve intermodal transportation: rail to WIPP, then truck from WIPP to the 

Section 10 or 35 location. The additional emissions from transportation by truck from WIPP to the Section 10 or 35 location 

(approximately 300 miles per year) are negligible.

Note: Emissions are based on locomotive fuel usage and the U.S. Environmental Protection Agency emission factors for 

locomotives (EPA 2009); to convert metric tons to tons, multiply by 1.1023. Values represent total emissions over 40 years.

Key: PMn=particulate matter with an aerodynamic diameter less than or equal to n micrometers; WIPP=Waste Isolation Pilot 

Plant.
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4–9

4.2.4.1.3 Noise

Short-term noise impacts near WIPP Vicinity Section 10 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 residence is located 

more than 5 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 four items of construction equipment operating at this 

distance is estimated to be 17 decibels A-weighted (dBA), which is well below background sound levels. 

The increase in traffic noise levels along Texas State Route 128 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 Route 128. 

Short-term noise impacts could occur along State Route 128 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 128 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 a new mercury storage facility at WIPP Vicinity Section 10 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.

4.2.4.2 WIPP Vicinity Section 20

Meteorological impacts on a facility at WIPP Vicinity Section 20 would be similar to those on a facility at 

WIPP Vicinity Section 10, discussed in Section 4.2.4.1.1.

Air quality impacts from construction and operation of a facility at WIPP Vicinity Section 20 would be 

similar to those from a facility at WIPP Vicinity Section 10, discussed in Section 4.2.4.1.2. Emissions 

from truck and rail shipments are presented in Tables 4–1 and 4–2.

Noise impacts from construction and operation of a facility at WIPP Vicinity Section 20 would be similar 

to those from a facility at WIPP Vicinity Section 10, discussed in Section 4.2.4.1.3.

4.2.4.3 WIPP Vicinity Section 35

Meteorological impacts on a facility at WIPP Vicinity Section 35 would be similar to those on a facility at 

WIPP Vicinity Section 10, discussed in Section 4.2.4.1.1.

Air quality impacts from construction and operation of a facility at WIPP Vicinity Section 35 would be 

similar to those from a facility at WIPP Vicinity Section 10, discussed in Section 4.2.4.1.2. Emissions 

from truck and rail shipments are presented in Tables 4–1 and 4–2.

Noise impacts from construction and operation of a facility at WIPP Vicinity Section 35 would be similar 

to those from a facility at WIPP Vicinity Section 10, discussed in Section 4.2.4.1.3.
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4–10

4.2.5 Ecological Resources

Anticipated impacts on ecological resources include the permanent disturbance of 3.1 hectares (7.6 acres) 

of land needed for the construction and operation of the proposed mercury storage facility. Following the 

decommissioning phase, it is assumed that the land disturbed by the construction and operation of the 

facility would eventually return to its original vegetative state through succession. Disturbed habitat 

types within the required footprint include mainly desert grassland and short-grass prairie. Although 

Section 10 and Section 20 are relatively undisturbed when compared to the developed center of WIPP 

(the area inside of the Property Protection Area boundary and vicinity), Section 10 is farther from the 

developed center of the WIPP site.

4.2.5.1 WIPP Vicinity Section 10

4.2.5.1.1 Terrestrial Resources

Terrestrial habitats present within Section 10 include desert grassland and short-grass prairie ecosystems. 

A total of 3.1 hectares (7.6 acres) of land within these ecosystems would be permanently disturbed for the 

construction and operation of the proposed mercury storage facility.

4.2.5.1.2 Wetlands and Aquatic Resources

No wetlands or aquatic resources exist within Section 10; thus, no impacts on wetlands or aquatic habitats 

are anticipated.

4.2.5.1.3 Threatened and Endangered Species

Although no threatened or endangered species have been observed at WIPP during historical surveys and 

no federally designated critical habitat exists on site, DOE would nonetheless consult immediately with 

the U.S. Fish and Wildlife Service, as well as the New Mexico Department of Game and Fish, for 

guidance on how to proceed in the event that a listed species is identified within the proposed mercury 

storage area. In addition, DOE has instituted measures, in consultation with the U.S. Bureau of Land 

Management, to protect the lesser prairie-chicken and its habitat at WIPP. These measures would be 

adhered to during the construction and operation phases of the project and include the establishment of 

periods during which offsite field activities may not be performed during the species’ breeding season 

(DOE 2011b).

4.2.5.2 WIPP Vicinity Section 20

Existing conditions at Section 20 are similar to those within Section 10, and impacts on ecological 

resources within Section 20, including terrestrial resources, wetlands and aquatic resources, and 

threatened and endangered species, would be similar to those described for Section 10 in Section 4.2.5.1. 

The same precautions and measures discussed in Section 4.2.5.1.3 regarding protection of these resources 

would be adopted and adhered to in the event that the mercury storage facility is constructed in 

Section 20.

4.2.5.3 WIPP Vicinity Section 35

Existing conditions at Section 35 are similar to those within Section 10, and impacts on ecological 

resources within Section 35, including terrestrial resources, wetlands and aquatic resources, and 

threatened and endangered species, would be similar to those described for Section 10 in Section 4.2.5.1. 

The same precautions and measures discussed in Section 4.2.5.1.3 regarding protection of these resources 

would be adopted and adhered to in the event that the mercury storage facility is constructed in 

Section 35.
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4–11

4.2.6 Cultural and Paleontological Resources

DOE initiated consultation with the New Mexico State Historic Preservation Division, State Historic 

Preservation Officer (SHPO) to support the analysis in this section (see Chapter 5, Section 5.4.2, and 

Appendix I). In its August 31, 2012, response to DOE, the State Historic Preservation Division agreed 

with DOE on the need for preconstruction surveys and construction monitoring, where applicable 

(see Appendix I). If one of the WIPP Vicinity reference locations is selected for a mercury storage 

facility, procedures would be developed in consultation with the SHPO to properly manage any 

inadvertent discoveries of resources and to perform required consultations. Inadvertent discoveries 

of such resources would be handled in accordance with 36 CFR 800.11 (for historic properties) or 

43 CFR 10.4 (for American Indian human remains, funerary objects, sacred objects, or objects of cultural 

patrimony), as appropriate.

4.2.6.1 WIPP Vicinity Section 10

4.2.6.1.1 Prehistoric Resources

No impacts on prehistoric resources are expected from construction or operation of a new mercury 

storage facility at Section 10. The closest archaeological district is located roughly 11 kilometers 

(7 miles) northwest of the project area. The land within the WIPP LWB has been determined to represent 

a potentially significant contributor of cultural resources and DOE direction includes regarding it as such 

when land management decisions are made (DOE 2002a). Although Section 10 is not within the WIPP 

LWB, due to its proximity, it is anticipated that resources of cultural significance might be encountered. 

If any resources are discovered during construction, DOE would follow the procedures established with 

the SHPO to ensure they were handled in accordance with 36 CFR 800.11 or 43 CFR 10.4, as 

appropriate.

4.2.6.1.2 Historic Resources

No impacts on historic resources are expected from construction or operation of a new mercury storage 

facility at Section 10. However, only roughly 1,370 hectares (3,380 acres) of the 4,140 hectares 

(10,240 acres) managed by WIPP have been surveyed for cultural resources. If the mercury storage 

facility is constructed on undisturbed land within Section 10 and historic resources are discovered, DOE 

would work with the New Mexico SHPO to properly manage the discovery site and to perform required 

consultations, as described in Section 4.2.6.

4.2.6.1.3 American Indian Resources

There would be no impact on American Indian resources as none have been identified or are likely to 

occur on the site.

4.2.6.1.4 Paleontological Resources

There would be no impact on unique paleontological resources as none have been identified or are likely 

to occur on the site.

4.2.6.2 WIPP Vicinity Section 20

As described in Chapter 3, Section 3.2.6, the cultural and paleontological resources of WIPP Vicinity 

Sections 10 and 20 are similar. Therefore, the environmental impacts of construction and operation of a 

mercury storage facility at Section 20 would be similar to those described in Section 4.2.6.1 for 

Section 10.
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4–12

The majority of Section 20 has not been examined for the presence of cultural resources; however, no 

archaeological sites have been located from the cultural resources surveys that have been conducted 

within the section (see Chapter 3, Section 3.2.6.1).

Historic remains or features (more than 50 years old) are rare but have occasionally been identified within 

Section 20 (see Chapter 3, Section 3.2.6.2). With few exceptions, cultural resources known or anticipated 

in the area covered by the WIPP LWB are significant; they must be identified, recorded, assessed through 

an inventory, and considered in any plan of development for the area. Fifty-nine archaeological sites and 

91 isolated occurrences have been identified to date. The sites and isolates identified are almost 

exclusively prehistoric. Only one site with both prehistoric and historic components was noted. The land 

within the WIPP LWB has been determined to represent a potentially significant contributor of cultural 

resources, and DOE direction includes regarding it as such when land management decisions are made 

(DOE 2002a). If the mercury storage facility is constructed within Section 20 and prehistoric or historic 

resources are discovered, DOE would work with the New Mexico SHPO to properly manage the 

discovery site and to perform required consultations, as described in Section 4.2.6.

4.2.6.3 WIPP Vicinity Section 35

As described in Chapter 3, Section 3.2.6, the cultural and paleontological resources of WIPP Vicinity 

Sections 10 and 35 are similar. Therefore, the environmental impacts of construction and operation of a 

mercury storage facility at Section 35 would be similar to those described in Section 4.2.6.1 for 

Section 10.

The WIPP Vicinity reference location in Section 35 is located on BLM-managed land just to the southeast 

of the WIPP LWB. The majority of Section 35 has not been examined for the presence of cultural 

resources; however, some cultural resource surveys were undertaken, and archaeological sites were found

(see Chapter 3, Section 3.2.6.1). Currently there are seven known cultural resources located in 

Section 35. Of the seven resources, only one, 54373, is currently recommended as being potentially 

eligible for listing on the National Register of Historic Places. The land in the vicinity of WIPP has been 

determined to represent a potentially significant contributor of cultural resources, and DOE direction 

includes regarding it as such when land management decisions are made (DOE 2002a). If the mercury 

storage facility is constructed within Section 35 and prehistoric or historic resources are discovered, DOE 

would work with the New Mexico SHPO to properly manage the discovery site and to perform required 

consultations, as described in Section 4.2.6.

4.2.7 Site Infrastructure

Infrastructure requirements for a new mercury storage facility, presented below, can be found in 

Appendix C.

4.2.7.1 WIPP Vicinity Section 10

4.2.7.1.1 Ground Transportation

Construction and operation of a new mercury storage facility outside the LWB in Section 10 are not 

expected to appreciably increase demands on the road system leading to the site. Projected traffic 

volumes and the number of shipments associated with mercury storage operations are presented in 

Section 4.2.11.

4.2.7.1.2 Electricity, Fuel, and Water

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 
Environmental Consequences

4–13

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. 

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. A new service connection to the Xcel Energy powerline would 

need to be established that is separate from the electrical substation that supports WIPP operations, 

leading to a moderate impact on electrical infrastructure.

An estimated 606 liters (160 gallons) of diesel fuel would be consumed annually for operation of an 

emergency onsite generator used to support a mercury storage facility. Compared to the 73,615 liters 

(19,447 gallons) of gasoline and diesel fuel used at WIPP for mobile vehicles and emergency generators,

the projected fuel requirements for emergency generator operations at a mercury storage facility would be 

negligible and would be supplied from local vendors.

Water use would be limited to that required to support the potable and sanitary needs of the facility 

workforce and would total about 88,500 liters (23,400 gallons) per year. Potable water would either be 

trucked to the site and stored for use or would be made available through a tie-in to a nearby public water 

supply main.

4.2.7.2 WIPP Vicinity Section 20

4.2.7.2.1 Ground Transportation

Construction and operation of a new mercury storage facility inside the LWB in Section 20 are not 

expected to appreciably increase demands on the road system leading to the site. Projected traffic 

volumes and the number of shipments associated with mercury storage operations are presented in 

Section 4.2.11.

4.2.7.2.2 Electricity, Fuel, and Water

Demands for electricity, fuel, and water would be similar to those described for WIPP Vicinity Section 10 

as discussed above in Section 4.2.7.1.2; however, delivery of these services for operation of the storage 

facility may be different. Most infrastructure tie-ins could be made directly to WIPP’s existing 

infrastructure. The electrical distribution infrastructure would need to be upgraded to provide adequate 

electricity for mercury storage facility operations, leading to a moderate impact on electrical 

infrastructure. Access to potable water would be made available through tie-in to the existing water 

supply at WIPP.

4.2.7.3 WIPP Vicinity Section 35

4.2.7.3.1 Ground Transportation

Construction and operation of a new mercury storage facility outside the LWB in Section 35 are not 

expected to appreciably increase demands on the road system leading to the site. Projected traffic 

volumes and the number of shipments associated with mercury storage operations are presented in 

Section 4.2.11.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–14

4.2.7.3.2 Electricity, Fuel, and Water

Demands for electricity, fuel, and water would be similar to those described for WIPP Vicinity Section 10 

as discussed above in Section 4.2.7.1.2.

4.2.8 Waste Management

4.2.8.1 WIPP Vicinity Section 10

Waste generation associated with the proposed construction and operation of the RCRA-permitted 

mercury storage facility outside the WIPP LWB in Section 10 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 270 cubic meters 

(355 cubic yards) of nonhazardous solid waste (construction debris) and approximately 9,850 liters 

(2,600 gallons) of nonhazardous sanitary liquid waste. Construction debris may be disposed of in the 

permitted WIPP site construction and demolition landfill provided it does not exceed the daily limit on 

disposal; otherwise, this waste would be transported off site for disposal at the Eddy County Sandpoint 

Landfill. Sanitary solid waste would be shipped to the Eddy County Sandpoint Landfill. Portable toilet 

facilities, serviced by a local or regional contractor, would be used to serve the nonhazardous sanitary 

liquid waste 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, personal protective 

equipment (PPE) used during monitoring activities, materials used during spill response activities, and 

mercury vapor filters used in the Handling Area. In comparison, operations at WIPP currently generate 

approximately 53.5 cubic meters (70 cubic yards) of hazardous waste. The estimated yearly generation 

rate of mercury-contaminated waste generated by mercury storage facility operations 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.

New mercury storage facility operations would also generate an estimated 2,360,000 liters 

(623,000 gallons) of nonhazardous liquid sanitary waste over the 40-year period of analysis, or 

58,960 liters (15,575 gallons) annually, or approximately 161.5 liters (43 gallons) per day. In 

comparison, 31,649 liters (8,361 gallons) per day of nonhazardous sanitary waste were generated by 

WIPP operations in 2011. Since the new mercury storage facility would be located outside the LWB, a 

separate nonhazardous sanitary liquid waste storage and treatment or septic system would be installed.

4.2.8.2 WIPP Vicinity Section 20

Waste generation associated with the proposed construction and operation of the mercury storage facility 

inside the WIPP LWB in Section 20 would have a negligible impact on the site considering the relatively 

small volumes of hazardous and nonhazardous waste projected to be generated. The amounts of waste 

generated during construction and operation would be similar to those described for WIPP Vicinity 

Section 10 discussed above in Section 4.2.8.1.

As stated above for WIPP Vicinity Section 10, operation of a new mercury storage facility would 

generate an estimated 2,360,000 liters (623,000 gallons) of nonhazardous liquid sanitary waste over the 

40-year period of analysis or 58,960 liters (15,575 gallons) annually, or approximately 161.5 liters 

(43 gallons) per day. By comparison, 31,649 liters (8,361 gallons) per day of nonhazardous sanitary 
Environmental Consequences

4–15

waste was generated by WIPP operations in 2011. WIPP’s sanitary disposal system is designed for 

87,000 liters (23,000 gallons) per day, or almost 32 million liters (8.4 million gallons) annually 

(DOE 2010: 28). Liquid sanitary waste generation from mercury storage facility operations, therefore, 

would have less than a 1 percent impact on WIPP’s sanitary liquid waste system.

4.2.8.3 WIPP Vicinity Section 35

Waste generation associated with the proposed construction and operation of the mercury storage facility 

inside the WIPP LWB in Section 35 would have a negligible impact on the site considering the relatively 

small volumes of hazardous and nonhazardous waste projected to be generated. The amounts of waste 

generated during construction and operation would be similar to those described for WIPP Vicinity 

Section 10 discussed above in Section 4.2.8.1.

4.2.9 Occupational and Public Health and Safety

Descriptions of the assumptions, data, and methods of analysis are summarized in Appendix D of this 

draft SEIS. Additional detail is provided in Appendix D of the January 2011 Mercury Storage EIS

(DOE 2011a), as updated in Appendices B and E of this draft SEIS.

2

 Many of the analytical 

considerations and many of the results are the same for all three WIPP Vicinity Sections 10, 20, and 35, 

as well as the alternative sites analyzed in the January 2011 Mercury Storage EIS. Therefore, the reader 

is frequently referred to Appendix D of this draft SEIS and Appendix D of the January 2011 Mercury 

Storage EIS (as updated in Appendix E, Section E.2, of this draft SEIS), where appropriate, to avoid 

excessive repetition. Details or results specific to the WIPP Vicinity reference locations are discussed in 

the appropriate sections on occupational and public health and safety.

4.2.9.1 WIPP Vicinity Section 10

4.2.9.1.1 Normal Operations

Normal operations are discussed in Appendix D, Section D.4.1, of the January 2011 Mercury 

Storage EIS. 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 American Conference of Governmental Industrial 

Hygienists’ 8-hour time-weighted average/threshold limit value of 0.025 milligrams per cubic meter of 

mercury vapor. This corresponds to keeping exposures to the involved worker in the Severity

Level (SL)-I (negligible) range.3 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 

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

Long-Term Storage of Elemental Mercury (Interim Guidance) (DOE 2009). As discussed in the Interim 

Guidance, the design, installation, and operation of ventilation systems would be in accordance with the 

American Society of Heating, Refrigerating, and Air-Conditioning Engineers standards. Therefore, the 

risks to involved workers would be negligible during normal operations.

 

2

Since publication of the January 2011 Mercury Storage EIS, DOE has published new criteria for assessing the severity of 

exposure to mercury vapor. This has resulted in changes to the definition of severity levels (i.e., magnitude of impacts) for 

assessing acute-inhalation exposures to the public under certain accident scenarios. Appendix B and Appendix E of this draft 

SEIS update parts of Chapter 4 and Appendix D of the January 2011 Mercury Storage EIS. The impact analyses for the WIPP 

Vicinity reference locations discussed in this draft SEIS have incorporated the revised criteria.

3

For definitions of SLs for various types of exposures, see Appendix D, Section D.3.1, of this SEIS. For a discussion of how 

risk is assessed, see Appendix D, Section D.2, of this draft SEIS and Appendix D, Section D.1.1, of the January 2011 Mercury 

Storage EIS (as updated in Appendix E, Section E.2 of this draft SEIS).
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

4–16

For people outside the building during normal operations (noninvolved workers4 and members of the 

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

3-liter 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. The January 2011 Mercury Storage EIS 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 value is well below EPA’s chronic-inhalation-exposure reference concentration 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

 It is recognized that there may be no noninvolved workers immediately adjacent to a storage facility in Section 10 or 35, 

which is outside the WIPP LWB. However, for the sake of conservatism, it is assumed that there could be workers near the 

storage facility engaged in operations other than those related to the handling of mercury. 

4.2.9.1.2 Facility Accidents 

The analysis of potential accidents at the WIPP Vicinity reference locations differs very little from that at 

the other sites considered in the January 2011 Mercury Storage EIS. There is no difference for accidents 

initiated by engineering failure or human error. There are small differences in the analysis of some of the 

external events, but these do not make any significant difference to the analysis of accident risks at the 

WIPP Vicinity reference locations. 

Engineering Failures and Human Errors

Appendix D, Section D.2.4, of the January 2011 Mercury Storage EIS contains detailed considerations of 

the likelihood of occurrence of candidate facility (onsite) accident scenarios initiated by failures of 

engineered systems or human errors. These considerations remain unchanged for potential accidents 

occurring at the WIPP Vicinity reference locations. 

External Events

Appendix D, Section D.2.5, of the January 2011 Mercury Storage EIS describes candidate external events 

and their likelihood of occurrence. External events that were considered are listed below: 

Wildfires 

Earthquakes 

High winds or tornadoes 

Floods 

Lightning 

Snow loads 

Aircraft crashes 

Vehicle crashes 

Nearby facility fires or explosions 

Each event is considered in terms of its likelihood of occurrence and its potential impact in terms of a 

mercury release from the flasks and 1-metric-ton (1-MT) storage containers. The potential frequency and 

magnitude of these events can vary significantly between the candidate sites due to the wide spectrum of 

climate, topography, seismology, and collocated site facilities that exist at each location. However, the 

analyses of wildfires, floods, lightning, snow loads, vehicle crashes, and nearby facility fire or explosions 

remain the same, with the only differences being in seismic events, high winds or tornadoes, and aircraft 

crashes. 

 
Environmental Consequences

4–17

Earthquakes

Earthquake-produced ground motion is expressed in units of percent g (force of acceleration relative to 

that of Earth’s gravity). The latest probabilistic peak ground acceleration (PGA) data from the 

U.S. Geological Survey are used to assess seismic hazard among the various mercury storage candidate 

sites. The PGA values cited are based on a 2 percent frequency of exceedance in 50 years. This 

corresponds to an annual frequency (chance) of occurrence of about 1 in 2,500 years or 4 × 10-4per year. 

For all three potential sites at WIPP, this acceleration is 0.08 g (USGS 2012). At any of the WIPP

Vicinity reference locations, the new facility would be designed to withstand this acceleration. This 

frequency is moderate (Frequency Level [FL]-III), as it is at all of the other candidate sites.

The PGA value varies at the other sites considered in the January 2011 Mercury Storage EIS, from 0.05 g

at the Kansas City Plant to 0.57 g at the Hawthorne Army Depot. However, the buildings at each site are 

designed to withstand these design-basis earthquakes, with the result that the frequency of an earthquake 

severe enough to damage the storage building is the same at all of the sites, FL-III. The subsequent 

consequence analysis also is unchanged from that at other sites with new buildings, with the result that 

predicted risk from seismic events is little to no different in the vicinity of WIPP than it is at the 

other sites.

For an earthquake accident in this draft SEIS, it is conservatively assumed that all flasks would release 

their entire contents of mercury with no retention of any of the mercury within the flasks. In addition, it is 

conservatively assumed that the earthquake would cause the building roof to collapse and that the roof 

would then fall onto and breach all 1-MT mercury storage containers. As a result, a pool of mercury 

within the storage building would become the source of release to the environment. The following two 

alternative earthquake scenarios are considered:

The building remains sufficiently intact so that the spill can still be regarded as occurring inside 

the building, and the building still generates a turbulent building wake (see Appendix D, 

Section D.7.2.1, of the January 2011 Mercury Storage EIS).

The building collapses and the spilled pool of mercury is, for all intents and purposes, in the 

open air.

No attempt was made to assess the relative conditional probabilities of these two scenarios, i.e., they are 

both assigned a moderate (FL-III) frequency.

The possibility that there could be a fire subsequent to the earthquake remains. In some environmental 

impact statements, a seismic event that then causes a fire is only considered when there is a natural gas 

main, hydrogen, propane, or solvents in the building (e.g., DOE 1999b:E-5.4; 2001:D-82, D-83). In one 

document, the presence of a natural gas pipeline within a building that could be ruptured by an earthquake 

and cause a subsequent fire was not analyzed because the earthquake-induced damage to the building 

would result in a dilution of the released natural gas to below its flammability limit (DOE 2002b:C-11). 

Since a new facility would be constructed at WIPP with the sole purpose of storing mercury, the building 

would have no fuel pipelines or stored fuels. The frequency of an earthquake with subsequent fire would 

be negligible.

Tornadoes

In Appendix D, Table D–6, of the January 2011 Mercury Storage EIS, data are presented on tornado 

occurrence frequency and severity, using the Fujita or “F” Scale, for the seven sites considered for 

mercury storage and the Y–12 National Security Complex (Y–12). Tornadoes of severity F1 and F0 are 

not expected to cause storage building damage sufficient to result in any significant mercury release to the 

environment. Many well-constructed buildings would survive an F2 tornado without serious damage to 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

4–18

the roof or walls. However, for the purposes of the present analysis, it is conservatively assumed that 

an F2 tornado would cause the building to collapse and release the contents of all flasks and 1-MT storage 

vessels – the same source term as for an earthquake. 

In the vicinity of WIPP, the historical frequency of occurrence of tornadoes of F2 severity or 

greater is 1.08 per year, including a frequency of 0.06 per year of tornadoes of severity F3 

(Tornadohistoryproject 2012). Using this frequency of occurrence of F2 or greater tornadoes, and the 

same methodology that was used in the January 2011 Mercury Storage EIS Appendix D, the predicted 

frequency of a damaging tornado strike on a new storage facility at any of the WIPP Vicinity reference 

locations is 8.78 × 10-8 per year (just under 1 chance in 10 million per year). This is a negligible 

frequency. Since the source term is conservatively assumed to be the same as for an earthquake, which, 

as noted above, has a moderate frequency (F-III), tornado risks are bounded by earthquake risks. 

Other High Winds

The WIPP Vicinity reference locations are not located in an area prone to hurricanes. Therefore, the 

frequency of high straight-line winds that would be as damaging as a tornado of F2 or greater severity is 

negligible. 

Aircraft Crashes 

There is an existing study of aircraft crashes at WIPP (DOE 2011b). This shows that the predicted 

frequency of occurrence of an aircraft crash anywhere on the WIPP site is 9.5 × 10-7 per year (just under 

1 chance in 1 million per year). This is a negligible frequency. This is because there are no airports close 

to WIPP – the nearest are at Cavern City (44.3 kilometers [27.5 miles], commercial aircraft), Lea County 

Regional (64.2 kilometers [39.9 miles], general aviation), JAL (66 kilometers [41 miles], general 

aviation), and Zip Franklin Memorial (73.7 kilometers [45.8 miles], general aviation).5 The frequency of 

a crash into a specific building would be even lower. 

5

 This information was obtained from www.airnav.com, accessed on August 16, 2012. Commercial airports handle a range of 

aircraft up to and including large passenger and cargo aircraft. General aviation airports, which include air taxi, handle small 

aircraft. 

Summary of Candidate Onsite Scenarios 

Table 4–3 summarizes the results of the analysis of onsite scenarios. These results are the same for all 

potential storage sites and do not provide a means of discriminating between them. 

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. 

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 SL-II range gives a risk in the negligible-to-low range for the involved 

worker in a mercury storage building at any of the WIPP Vicinity reference locations. 

 
Environmental Consequences

4–19

Table 4–3. 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. 

Could only occur inside 

building.

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 Limited ignition sources, 

electric forklift,b controls on 

flammable materials, 

reliable fire protection 

system, building constructed 

of nonflammable materials.

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.c

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

4–20

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

Their Likelihood of Occurrence (continued)

Hazard Activity Postulated Scenario

Frequency 

of Releasea

Evaluated 

Further Commentsa

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, of the January 2011

Mercury Storage EIS (DOE 2011a).

b The Final Mercury Management Environmental Impact Statement (DLA 2004) determined that the frequency of a forklift fuel 

fire was negligible to low; the use of an electric forklift reduces this frequency to negligible. See Appendix D, 

Section D.2.4.5, of the January 2011 Mercury Storage EIS.

c 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.

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 spill 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 flasks from partially filled or smaller pallets 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.
Environmental Consequences

4–21

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, of 

the January 2011 Mercury Storage EIS (as updated in Appendix E, Section E.2, of this draft SEIS) shows 

that, for new construction, the predicted concentrations in the wake are all in the SL-I range, even taking 

into consideration the revised Protective Action Criterion 1 of 0.15 milligrams per cubic meter. 

Therefore, the risks to the noninvolved worker and the public from all of these scenarios at the WIPP 

Vicinity reference locations would be negligible.

For the specific case of an earthquake with building collapse, the spilled mercury would evaporate as if in 

the open air. Appendix D, Section D.7.1.2, of the January 2011 Mercury Storage EIS describes how the 

release rate is calculated in these circumstances. For a new building, that release rate in Atmospheric 

Stability Class D with a windspeed u of 4.5 meters per second would be 8.45 × 10-4kilograms per second. 

Equations 7–2 and 7–3 in Appendix D of the January 2011 Mercury Storage EIS show that the 

evaporation rate for other windspeeds u is proportional to (u/4.5)0.8. These release rates were input into a 

ground-level Gaussian dispersion model, which calculated downwind concentrations in six Atmospheric 

Stability Classes A–F, each with four discrete windspeeds, 1.5, 4.5, 6.5, and 8.5 meters per second, 

i.e., 24 weather conditions in all.6 The maximum predicted distances to consequence SL-II, SL-III, and 

SL-IV are shown Appendix E, Table E–2. The maximum downwind distance from new construction to 

which a concentration could exceed SL-IV would be less than 100 meters (330 feet); SL-III could be 

exceeded to a distance of about 200 meters (660 feet); and SL-II could be exceeded to a distance of about 

790 meters (2,600 feet). There are similar results for existing buildings.

In the vicinity of Section 10, the nearest structures are oil wells, with the closest being at a distance of 

500 meters (1,600 feet), while the closest storage/transfer facility is at a distance of 1,200 meters 

(3,850 feet). Oil wells are rarely visited. Therefore, the storage/transfer facility is assumed to be the 

nearest facility at which there might be a member of the public during an earthquake with building 

collapse. That person would never see concentrations at the SL-II, SL-III, or SL-IV level. The maximum 

concentration might be in the SL-I range. This corresponds to negligible risk. Section 20 is inside the 

WIPP LWB and is 2,000 meters (6,400 feet) from the closest site boundary, so the risk to the public is 

negligible for this site also.

Table 4–5 summarizes the calculated risks for all of the hypothetical accidental releases considered for a

new storage facility constructed on WIPP Vicinity Section 10.

 

6 These 24 weather conditions are representative of the full range of weather conditions that can occur at each of the potential 

storage locations, including the WIPP Vicinity reference locations.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–22

Table 4–5. Summary of Risks of All Onsite Elemental Mercury Spill Scenarios –

All WIPP Vicinity Reference Locations

Scenario Frequency Consequencea Risk

Spills Inside Buildingb

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 N–L for outside earthquake spill; 

Noninvolved worker N for all other outside spills FL-II – FL-III SL-I – SL-II

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 For definitions of severity levels, see Appendix D, Section D.3.1.

b 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.

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

Key: FL=frequency level; L=low; N=negligible; SL=severity level.

4.2.9.1.3 Transportation

This subsection considers transportation by road or rail. The potential truck routes considered are 

conventional commercial routes that have no hazardous material restrictions. The potential domestic 

truck and rail routes considered and their estimated mileage were obtained using DOE’s TRAGIS 

[Transportation Routing Analysis Geographic Information System] (Johnson and Michelhaugh 2003). 

Origination and destination points in TRAGIS are defined by nodes; therefore, the closest TRAGIS node 

to a given site was used for a particular origination or destination point. Details of the assumptions about 

the transportation analysis are given in Appendix D, Section D.2.2.

These assumptions, together with estimated mileage of potential truck routes determined using DOE’s 

TRAGIS and known 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 estimated for five types of consequences are shown in Table 4–6:

Crash with spill of elemental mercury onto the ground without fire

Crash with spill of elemental mercury into water

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)

Crash with death caused by mechanical impact

The frequency of accidents with fire in wet weather was obtained from the frequency of accidents in dry 

weather by multiplying by the fraction of the time it rains each year. For the WIPP site, hourly data were 

available from an onsite meteorological station over a period of 5 years from 2007–2011. The number of 

hours for which there was rainfall over the 5 years was counted and then divided by the total number of 

hours in 5 years (43,800) to give the probability of rain in the vicinity of WIPP, which is 0.015.
Environmental Consequences

4–23

Table 4–6. Frequency Analysis of Truck and Railcar Accidents –

All WIPP Vicinity Reference Locations

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)

Truck –

Scenario 1b

1,046,223 1.2×10-22.1×10-31.7×10-45.4×10-65.9×10-4

– High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III

Truck –

Scenario 2b

1,868,523 1.8×10-23.7×10-33.0×10-49.6×10-61.0×10-3

– High – FL-IV Moderate – FL-III Moderate – FL-III Low – FL-II Moderate – FL-III

Railcarc 426,212 2.6×10-3

1.2×10-52.8×10-58.9×10-71.7×10-4

– 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.

b Truck Scenarios 1 and 2 are defined in Appendix D, Section D.2.2.

c Transportation by rail to Section 10 or 35 would involve intermodal transportation: rail to WIPP, then truck from WIPP to the Section 10 

or 35 location. The risk associated with additional truck miles to Section 10 or 35 (approximately 300 miles per year) is negligible.

Note: To convert miles to kilometers, multiply by 1.60934.

Key: FL=frequency level.

For comparison, the comparable figures for the other potential storage sites ranged from 0.016 at the 

Hawthorne Army Depot to 0.056 at the Savannah River Site, with an average of 0.032 (see Appendix D, 

Table D–16, in the January 2011 Mercury Storage EIS). Since, for any given site, the transportation 

routes run through many different parts of the United States, this average was chosen as the multiplier to 

estimate the frequency of crashes with fire during rain starting with the frequency of crashes with fire in 

dry weather. Considering all potential candidate sites, including the WIPP Vicinity reference locations, 

the average reduces slightly to 0.030. However, for consistency with the January 2011 Mercury 

Storage EIS, the multiplicative factor is left at a slightly conservative 0.032. Thus, in Table 4–6, the 

frequency of accidents with fires in wet weather is obtained from the frequency of accidents with fires in 

dry weather multiplied by 0.032.

The frequencies shown in Table 4–6 are for an accident anywhere along any of the transportation routes 

taken to WIPP over a 40-year period of analysis. The frequency of accidents with spills or accidents with 

fires in dry weather would be moderate under both Truck Scenarios and low under the Railcar Scenario. 

The frequency of crashes with fires in wet weather would be low under both Truck Scenarios and 

negligible under the Railcar Scenario. The frequency of accidents with death caused by mechanical 

impact would be moderate under all scenarios.

As noted, the above frequencies are for an accident anywhere along any of the transportation routes taken 

to WIPP over a 40-year period of analysis. 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.

4.2.9.1.3.1 Transportation Accident with Spill of Elemental Mercury onto the Ground

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-liter flasks or all 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 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

4–24

an outdoor spill),7 the predicted rate of evaporation in a windspeed u of 4.5 meters per second would be 

7.35 × 10-5 kilograms per second, with the evaporation rates for different windspeeds u being scaled 

by the factor (u/4.5)0.8 (see Appendix D, Section D.7.1.2, of the January 2011 Mercury Storage EIS).

Running these rates of release through the Gaussian model of atmospheric dispersion 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, less than 

100 meters (330 feet);8

and SL-II, about 230 meters (750 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 230 meters (750 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 460-meter (1,500-foot) 

stretch of road (230 meters [750 feet] on each side). This is a small fraction of any of the routes 

(for example, the average length of a truck trip to the WIPP Vicinity reference locations is approximately 

2,400 kilometers [1,500 miles]). The frequency of occurrence of a truck crash with spill on the truck 

routes to WIPP is 0.0037 per year; see Table 4–6 (Truck Scenario 2). The product of the fraction of the 

route and the frequency of occurrence is about 7.0 × 10-7 per year, a negligible (FL-I) frequency. Under 

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

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

transportation spills onto the ground without fire en route to WIPP would be negligible under all 

transportation scenarios. 

7

 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. If the surface is rough, the 

mercury will pool in hollows and depressions and the effective surface area for evaporation will be less than it would be for a 

smooth surface. See Appendix D, Section D.7.1.4, of the January 2011 Mercury Storage EIS. 

8

 The predicted distance for SL-IV is in fact different from and less than that for SL-III. However, both distances are less than 

100 meters (330 feet). Since the atmospheric dispersion model is not valid at distances from the source less than 100 meters 

(330 feet), both distances are written as “less than 100 meters (330 feet).”

4.2.9.1.3.2 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, of the January 2011 Mercury Storage EIS. 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 during transportation to the WIPP Vicinity reference locations 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 

 
Environmental Consequences

4–25

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

this prediction of risk is very large.

Table 4–7 summarizes the risks arising from spillages of elemental mercury during transportation 

to WIPP.

Table 4–7. Summary of Transportation Risks to Human Receptors, Spills of Elemental Mercury 

onto the Ground or into Water – All WIPP Vicinity Reference Locations

Truck Scenario 1a Truck Scenario 2a Railcar Scenario

Spill onto the Ground

Frequencyb FL-I FL-I FL-I

Consequence SL-II SL-II SL-II

Risk Negligible Negligible Negligible

Spill into Water

Frequencyc FL-III FL-III FL-II

Consequence SL-I – SL-II SL-I – SL-II SL-I – SL-II

Riskd Negligible to low Negligible to low Negligible to low

a Truck Scenarios 1 and 2 are defined in Appendix D, Section D.2.2.

b Frequency at which spill occurs close enough to a specific individual to cause Acute Exposure Guideline Level 2 to be 

exceeded.

c Frequencies of railcar or truck crashes with spills from Table 4–6.

d These estimates of risk are subject to large uncertainty.

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

4.2.9.1.3.3 Transportation Accident with Fire

For wooden pallets of 49 3-liter flasks, the material of combustion is the wood of the crate.9 It is assumed 

that the amount of wood in a truck or railcar full of 1-MT containers is bounded 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 maximum extent of the pool area that could potentially be affected by 

radiative heat transfer is limited to the size of the bed of the truck or railcar, regardless of the number of 

flasks or 1-MT containers that might be ruptured. 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 pool) is unlikely to occur

or the number of ruptured containers would be far less than that required to fill the bed of the truck or 

railcar. 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.7.4.1, of the January 2011 Mercury Storage EIS 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, with a 

windspeed of 4.5 meters per second. The corresponding rates with a windspeed of 1.5 meters per second 

are 0.55 and 0.68 kilograms per second, respectively. Appendix D, Section D.7.4.1, of the January 2011

Mercury Storage EIS 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 

 

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

metal pallets. In this draft SEIS, 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 Supplemental Environmental Impact Statement

4–26

conservative for all conditions of atmospheric stability class and windspeed for the Truck and Railcar 

Scenarios. The plume is therefore assumed to rise to a height of 100 meters 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 20 percent of it is converted into the divalent form (see Appendix D, Section D.7.3.3, of 

the January 2011 Mercury Storage EIS). In this form, mercury can deposit by dry deposition or wet 

deposition. The January 2011 Mercury Storage EIS Appendix D, Section D.7.3.3, also 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 (Transportation Fire Scenarios)

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

potential site are shown in Table 4–8.

Table 4–8. Predicted Range of Distances (meters) Downwind Within Which

Acute Airborne Severity Levels Are Exceeded – Crashes with Fires

Type of Accident

Atmospheric 

Stability 

Class/Windspeed

PAC-1

(SL-II)

AEGL-2 

(SL-III)

AEGL-3 

(SL-IV)

Truck crash, 

wooden pallets

A/1.5 m/s <100–3,500 <100–130 Nowhere

D/4.5 m/s <100–25,000 Nowhere Nowhere

F/1.5 m/s <100–>40,000a 500–1,200 Nowhere

Railcar crash, 

wooden pallets

A/1.5 m/s <100–3,700 130–830 Nowhere

D/4.5 m/s <100–30,000 550–2,300 Nowhere

F/1.5 m/s <100–>40,000a 350–2,050 Nowhere

a The limit of validity of the dispersion model is 40,000 meters (approximately 25 miles).

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

Key: <=less than; AEGL=Acute Exposure Guideline Level; m/s=meters per second; PAC=Protective Action Criterion; 

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, of the January 2011 Mercury Storage EIS (as updated in Appendix E, 

Section E.2, of this draft SEIS), and produces the results in Table 4–9.
Environmental Consequences

4–27

Table 4–9. Summary of Acute-Inhalation Risks to Human Receptors, Accidents with Fires,

Transportation Routes to All WIPP Vicinity Reference Locations

Both Truck Scenariosa

with Wooden Pallets

Railcar Scenario 

with Wooden Pallets

Frequencyb FL-III FL-II

Consequencec SL-II SL-II

Risk Low Low

a Truck Scenarios 1 and 2 are defined in Appendix D, Section D.2.2.

b Frequencies of railcar or truck crashes with spills and fires from Table 4–8.

c The consequence in any weather (dry or wet) condition that yields the highest risk.

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.

Human Exposure – Deposition on the Ground

The analyses performed for this draft SEIS show that, under all fire scenarios listed in Table 4–10, 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 4–10. Predicted Range of Distances (meters) Downwind to Which Lakes Could

Potentially Be Contaminated Above Levels Safe for Consumption of Fish –

Accidental Truck and Railcar Crashes with Fires

Type of 

Accident/Frequency 

Level

Atmospheric 

Stability 

Class/Windspeed

Consumption of Fish

National 

Average

Subsistence Fisherman

Average 95th Percentile

Truck Crash with Fire, 

Dry Deposition/FL-IIIa

A/1.5 m/s Nowhere Nowhere 500–700

D/4.5 m/s Nowhere Nowhere Nowhere

F/1.5 m/s Nowhere Nowhere Nowhere

Truck Crash with Fire, 

Wet Deposition/FL-IIb

A/1.5 m/s <100 500–700 2,000–3,000

D/4.5 m/s Nowhere 700–1,000 3,000–5,000

F/1.5 m/s <100 1,000–2,000 5,000–7,000

Railcar Crash with Fire, 

Dry Deposition/FL-IIc

A/1.5 m/s 100–200 300–500 700–1,000

D/4.5 m/s Nowhere Nowhere 2,000–3,000

F/1.5 m/s Nowhere Nowhere Nowhere

Railcar Crash with Fire, 

Wet Deposition/FL-Ib

A/1.5 m/s 200–300 1,000–2,000 3,000–5,000

D/4.5 m/s 300–500 1,000–2,000 5,000–7,000

F/1.5 m/s 700–1,000 3,000–5,000 7,000–10,000

a From Appendix D, Tables D–13 and D–14, of the January 2011 Mercury Storage EIS.

b From Appendix D, Table D–17, of the January 2011 Mercury Storage EIS.

c From Appendix D, Table D–15, of the January 2011 Mercury Storage EIS.

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

Key: <=less than; FL=frequency level; m/s=meters per second.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–28

Human Exposure – Consumption of Fish

Appendix D, Section D.1.1.2.7, of the January 2011 Mercury Storage EIS, presents the reasons for the 

choice of 0.3 milligrams of methylmercury per kilogram of fish tissue, wet weight, as the boundary 

between SL-I and SL-II for the accumulation of methylmercury in fish to levels that could be harmful 

to humans if consumed at the national average rate of 0.0175 kilograms per day. Appendix D, 

Section D.1.1.2.7, of the January 2011 Mercury Storage EIS also considers subsistence fishermen. Based 

on data provided by EPA (2001), a subsistence fisherman would on average consume 0.059 kilograms per 

day, while the 95th percentile of fish consumption is 0.170 kilograms per day (about 62 kilograms 

per year). Table 4–10 summarizes the results of the analysis of distances downwind to which bodies of 

water might be contaminated with methylmercury to levels at which fish caught there would be unsafe for 

human consumption.

Appendix D, Section D.4.5, of the January 2011 Mercury Storage EIS, presents a semi-quantitative 

analysis of these results and the associated risks. Should a truck or rail accident with fire occur, the risk 

to fishermen (that eat fish at both the national average and subsistence consumption rates) would be 

negligible, with the possible exception of a low risk for a subsistence fisherman that eats fish at the 95th 

percentile consumption rate following a railcar fire with dry deposition. However, irrespective of 

frequency, should such an accident occur within a few kilometers upwind of a body of water used by 

subsistence fishermen, it would be advisable as a mitigation measure to monitor the levels of 

methylmercury in fish to ensure that subsistence fishermen do not consume amounts of methylmercury 

that might cause adverse health effects. Subsequent to mandated reporting of any such release by the 

shipper of the elemental mercury, the appropriate state environmental agency would be responsible for 

determining appropriate fish consumption advisories and monitoring requirements of mercury 

concentrations in waters and fish stocks.

Table 4–11 summarizes the human health risks associated with all transportation spills.

Table 4–11. Summary of Transportation Risks to Human Receptors –

All WIPP Vicinity Reference Locations

Spill Scenario Truck Scenario 1a Truck Scenario 2a Railcar Scenario

Elemental mercury, spill 

onto ground

Negligible Negligible Negligible

Elemental mercury, 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 Low Low Low

Spill with fire, dry and 

wet deposition onto soils

Negligible Negligible Negligible

Fish consumption 

pathway – national 

average

Negligible Negligible Negligible

Fish consumption 

pathway – average 

subsistence fisherman

Negligible Negligible Negligible

Fish consumption 

pathway – 95th percentile 

subsistence fisherman

Negligible Negligible Negligible to low – dry 

deposition

Negligible – wet deposition

a Truck Scenarios 1 and 2 are defined in Appendix D, Section D.2.2.
Environmental Consequences

4–29

4.2.9.1.4 Intentional Destructive Acts

A wide range of intentional destructive acts (IDAs) involving a release of mercury can be postulated for 

the WIPP Vicinity Section 10 site itself and transportation routes being considered. 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 or hazardous material transporters. Each IDA 

scenario assumes multiple actions by intruders with no successful mitigation or protection measures. 

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 of the January 2011 Mercury Storage EIS (as updated in 

Appendix E, Section E.2, of this draft SEIS) 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 another truck or a 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.

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 considered 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, of the January 2011 Mercury Storage EIS describes a fire caused by an IDA. 

The parameters needed for input into the atmospheric dispersion model are discussed in Appendix D, 

Section D.7.4.2, of the January 2011 Mercury Storage EIS, 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.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–30

Human Exposure – Atmospheric Pathway

Per Appendix D, Table D–64, of the January 2011 Mercury Storage EIS, the duration of release is 

10,660 seconds (approximately 3 hours). Interpolation from Appendix D, Table D–6, gives a 

corresponding Acute Exposure Guideline Level (AEGL)-2 (SL-III) of 1 milligram per cubic meter 

(1.0 × 10-6kilograms per cubic meter) and an AEGL-3 (SL-IV) of 4.4 milligrams per cubic meter 

(4.4 × 10-6kilograms per cubic meter). The “surrogate AEGL-1” is the American Conference of 

Governmental Industrial Hygienists’ threshold limit value of 0.025 milligrams per cubic meter as a 

time-weighted average for an 8-hour workday exposure, as discussed in Appendix B.

The results of the atmospheric dispersion analyses and predictions of potential acute-inhalation exposures 

are shown in Table 4–12.

Table 4–12. Predicted Range of Distances (meters) Downwind to Which

Acute Airborne Severity Levels Are Exceeded – IDA Fires

Type of Accident

Atmospheric 

Stability 

Class/Windspeed

ACGIH TLV 

8-hour TWA 

(SL-II)

AEGL-2

(SL-III)

AEGL-3

(SL-IV)

Truck crash A/1.5 m/s <100–9.000 370–780 Nowhere

D/4.5 m/s <100–>40,000a Nowhere Nowhere

F/1.5 m/s <100–>40,000a 100–5,700 680–870

a The limit of validity of the dispersion model is 40,000 meters (approximately 25 miles).

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

Key: <=less than; ACGIH=American Conference of Governmental Industrial Hygienists; AEGL=Acute Exposure 

Guideline Level; IDA=intentional destructive act; m/s=meters per second; SL=severity level; TLV=threshold limit value; 

TWA=time-weighted average.

Comparisons with the railcar crash results in Table 4–8 show that the predicted downwind distances are, 

as expected, generally greater for the IDA fire. As noted above, 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 – Inorganic Mercury Deposited on the Ground

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

anywhere following an IDA.

Human Exposure – Consumption of Fish

The predicted ranges of distances downwind to which bodies of water could be contaminated with 

methylmercury at levels that would be unsafe for human consumption of fish caught there are shown in 

Table 4–13.

As can be seen, lakes located up to tens of kilometers (tens of miles) downwind could be contaminated to 

levels unacceptable for subsistence fishermen; lakes up to 10 kilometers (approximately 6 miles) 

downwind could be unacceptable for people who consume fish at the national average rate. However, as 

noted previously, it is not possible to associate risks with these predictions.
Environmental Consequences

4–31

Table 4–13. Predicted Range of Distances (meters) Downwind to Which Lakes Could

Potentially Be Contaminated Above Levels Safe for Consumption of Fish –

Intentional Destructive Acts

Type of Accident

Atmospheric 

Stability 

Class/Windspeed

Consumption of Fish

National Average

Subsistence Fisherman

Average 95th Percentile

IDA Fire, Dry 

Deposition

A/1.5 m/s Nowhere 1,000–2,000 2,000–3,000

D/4.5 m/s Nowhere Nowhere 10,000–20,000

F/1.5 m/s Nowhere Nowhere 1,000–2,000

IDA Fire, Wet 

Deposition

A/1.5 m/s 2,000–3,000 7,000–10,000 10,000–20,000

D/4.5 m/s 5,000–7,000 10,000–20,000 30,000–40,000

F/1.5 m/s 7,000–10,000 10,000–20,000 20,000–30,000

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

Key: IDA=intentional destructive act; m/s=meters per second.

4.2.9.2 WIPP Vicinity Section 20

The consequences to involved and noninvolved workers remain the same for WIPP Vicinity Section 20 as 

they were presented for WIPP Vicinity Section 10 in Section 4.2.9.1. Because WIPP Vicinity Section 20 

is located inside the WIPP LWB and is a further distance from potential public receptors, the 

consequences to the public would also be smaller than those calculated in the previous sections for WIPP 

Vicinity Section 10.

4.2.9.3 WIPP Vicinity Section 35

The consequences to involved and noninvolved workers remain the same for WIPP Vicinity Section 35 as 

they were presented for WIPP Vicinity Section 10 in Section 4.2.9.1.

4.2.10 Ecological Risk

4.2.10.1 WIPP Vicinity Section 10

The following is a summary of the generic analysis of ecological risks that appears in Appendix D, 

Section D.5, of the January 2011 Mercury Storage EIS. It applies equally to all of the sites being 

considered as possibilities for mercury storage, including WIPP.

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, of the January 2011 Mercury Storage EIS contains a discussion of why these 

representative receptors were chosen. Ecological exposures from elemental mercury deposited onto 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–32

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 environmentalmedium- 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. Appendix D, Section D.5, of the January 2011

Mercury Storage EIS describes how these values are calculated.

Table 4–14 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.

Table 4–14. 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 3.00×10-12.76×10-5

Soil invertebrates Inorganic 1.00×10-19.18×10-6

Short-tailed shrew Inorganic 1.10×1021.01×10-2

American robin Inorganic 2.00×1001.84×10-4

Red-tailed hawk Inorganic 1.62×1031.49×10-1

Great blue heron, sediment Inorganic 7.36×1023.12×10-2

Great blue heron, water Inorganic 1.40×1003.61×10-2

River otter, sediment Inorganic 5.26×1032.23×10-1

River otter, water Inorganic 1.03×1012.67×10-1

Aquatic biota Inorganic 1.30×1003.36×10-2

Sediment-dwelling biota Inorganic 1.50×10-16.35×10-6

Plants Methyl None None

Soil invertebrates Methyl 2.50×1001.13×10-2

Short-tailed shrew Methyl 8.00×10-23.60×10-4

American robin Methyl 1.00×10-24.50×10-5

Red-tailed hawk Methyl 6.86×1003.09×10-2

Great blue heron, sediment Methyl 2.09×1005.02×10-4

Great blue heron, water Methyl 3.20×10-23.11×10-3

River otter, sediment Methyl 5.40×10-11.31×10-4

River otter, water Methyl 8.00×10-37.78×10-4

Aquatic biota Methyl 2.80×10-32.72×10-4

Sediment-dwelling biota Methyl None None

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

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 correspond to negligible consequences).
Environmental Consequences

4–33

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. For ecological receptors, 

ingestion of soil contaminated with mercury represents the greatest plausible long-term threat from 

mercury releases. As discussed in Appendix D of the January 2011 Mercury Storage EIS, 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.

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, of 

the January 2011 Mercury Storage EIS, 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.

Based on the comments above about cleanup, consequences to ecological receptors would likely be in the 

negligible-to-low range. However, 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. For direct spillages, 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, of the 

January 2011 Mercury Storage EIS. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–34

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

Truck Fires – Dry Deposition

Table 4–15 presents the predicted ranges of distances downwind to which ecological receptors might be

exposed in SL-II, SL-III, and SL-IV following a truck crash with fire for each of the three weather 

conditions for which calculations were performed.

Table 4–15. Summary of Potential Exposure of Receptors to Consequence

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

Ecological 

Receptor

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 

(Fa, 1.5 m/sb)

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

Sedimentdwelling biota 1,000–2,000 3,000–5,000

Soil 

invertebrates 700–1,000 2,000–3,000

Plants 300–500

American 

robin 

River otter 

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 4–16 shows that, for a truck crash with a pallet fire but no rain, no ecological receptors could be 

exposed to deposited mercury in the SL-IV and SL-III ranges in any weather conditions. Two receptors 

(sediment-dwelling biota and soil invertebrates) could be exposed in the SL-II range in Atmospheric 

Stability Class D with a windspeed of 4.5 meters per second. Three receptors (sediment-dwelling biota, 

soil invertebrates, and plants) could be exposed in the SL-II range in Atmospheric Stability Class A with 

a windspeed of 1.5 meters per second.

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

in Appendix D, Tables D–13 and D–14, of the January 2011 Mercury Storage EIS to provide risks. 

Tables D–13 and D–14 show that the predicted frequencies of spills with fires are in the FL-III range 

under both Truck Scenarios and for all of the candidate storage sites. Conservatively, these frequencies 
Environmental Consequences 

4–35

are associated with the highest SL predicted in any weather condition in Table 4–15, a conservative 

assumption.10

 Table 4–16 summarizes the FL, consequence level, and risk to ecological receptors and 

applies to all candidate storage sites. 

Table 4–16. Frequencies, Consequences, and Risks to Ecological Receptors from 

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

10 In principle, one could calculate the probability that, conditional on the occurrence of the crash with fire, 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 in Table 4–16, it would drop 

those frequencies into a lower frequency range. However, this is not possible because the calculations reported in Table 4–16 

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. 

Ecological Receptor

Frequency Level (FL) 

of Crash with Fireb

Consequence 

Severity Level (SL)c Riskd

Sediment-dwelling biota FL-III (moderate) SL-II Low

Soil invertebrates FL-III (moderate) SL-II Low

Plants FL-III (moderate) SL-II Low

American robin FL-III (moderate) SL-I Negligible

River otter FL-III (moderate) SL-I Negligible

Aquatic biota FL-III (moderate) SL-I Negligible

Short-tailed shrew FL-III (moderate) SL-I Negligible

Great blue heron FL-III (moderate) SL-I Negligible

Red-tailed hawk FL-III (moderate) SL-I Negligible

a

 Applies equally to all candidate sites. 

b Frequencies of truck crashes with fires from Table 4–6.

c

 The highest consequence in any weather condition from Table 4–15.

d Applies to both Truck Scenarios 1 and 2. 

As can be seen, only three receptors have a non-negligible risk: sediment-dwelling biota, soil 

invertebrates, and plants. 

Truck Fires – Wet Deposition

The wet deposition analysis proceeded exactly as for the dry deposition, except that the quantity against 

which equivalent deposited screening values were compared was the amount of mercury deposited on the 

ground by the action of rain instead of by dry deposition. Table 4–17 is analogous to Table 4–15, but for 

wet deposition instead of dry deposition. 

Table 4–17 shows that, for a truck crash with a pallet fire and rain, sediment-dwelling biota could be 

exposed to deposited mercury in the SL-IV range over distances of up to 500 meters (1,640 feet); in 

the SL-III range, up to 2,000 meters (6,600 feet); and in the SL-II range, up to about 20,000 meters 

(approximately 12.4 miles). The consequences above can be combined with the predicted frequencies of 

crashes with fires and rain from the January 2011 Mercury Storage EIS Appendix D, Table D–17, to 

provide risks; see Table 4–18. The predicted frequencies of truck spills with fire and rain are in the low 

(FL-II) range for all of the candidate storage sites and under both Truck Scenarios. Conservatively, these 

frequencies are associated with the highest SL predicted in any weather condition in Table 4–17. 

Table 4–18 summarizes the FL, consequence level, and risk to ecological receptors. 

Table 4–18 shows that, for all candidate sites, there is a moderate risk that, somewhere along the truck 

routes, for truck crashes with pallet fires and rain, areas could contain deposited mercury in the SL-IV 

range for sediment-dwelling biota. Per the risk matrix in Appendix D, Section D.3.1, these indicate 

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

4–36

situations of concern. Furthermore, though not shown explicitly in Table 4–18, there could be a low risk 

that areas along truck routes could contain deposited mercury in the SL-III range for sediment-dwelling 

biota.

Table 4–17. Summary of Potential Exposure of Receptors to Consequence Severity Levels II, 

III, and IV – Truck Spill with Wooden Pallet Fire and Rain

Ecological 

Receptor

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

(Fa, 1.5 m/sb)

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

Sedimentdwelling 

biota 

3,000–

5,000

300–500 100–200 10,000–

20,000

500–700 100–200 10,000–

20,000

1,000–

2,000

300–500

Soil 

invertebrates

3,000–

5,000

200–300 7,000–

10,000

300–500 7000–

10,000

700–1,000

Plants 1,000–

2,000

1,000–

2,000

3,000–5,000

American 

robin

500–700 700–1,000 2,000–3,000

River 

otter 

100–200 300–500

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 

distances 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 4–18. Frequencies, Consequences, and Risks to Ecological Receptors from

Truck Crashes with Wooden Pallet Fires and Rain, All Sitesa

Ecological Receptor

Frequency Level (FL) 

of Crash with Fireb

Consequence 

Severity Level (SL)c Riskd

Sediment-dwelling biota FL-II (low) SL-IV Moderate

Soil invertebrates FL-II (low) SL-III Low

Plants FL-II (low) SL-II Low

American robin FL-II (low) SL-II Low

River otter FL-II (low) SL-II Low

Aquatic biota FL-II (low) SL-I Negligible

Short-tailed shrew FL-II (low) SL-I Negligible

Great blue heron FL-II (low) SL-I Negligible

Red-tailed hawk FL-II (low) SL-I Negligible

a Applies equally to all candidate sites. 

b Frequencies of truck crashes with fires and rain from Table 4–6.

c The highest consequence in any weather condition from Table 4–17.

d Applies to both Truck Scenarios 1 and 2.
Environmental Consequences

4–37

For all candidate sites, there is a low risk that, for the same event, somewhere along the truck routes, areas 

could contain deposited mercury in the SL-III range for soil invertebrates. Per the risk matrix in 

Appendix D, Section D.3.1, these indicate situations of minimal concern. Furthermore, though not shown 

explicitly in Table 4–18, there is a low risk that areas along truck routes could contain deposited mercury 

in the SL-II range for sediment-dwelling biota and soil invertebrates.

For all candidate sites, there is a low risk that, for the same event, somewhere along the truck routes, areas 

could contain deposited mercury in the SL-II range for plants, the American robin, and the river otter. Per 

the risk matrix in Appendix D, Section D.3.1, these indicate situations of minimal concern.

For all candidate sites, the risk to aquatic biota, the short-tailed shrew, the great blue heron, and the 

red-tailed hawk is negligible.

Railcar Fires

The risks associated with railcar fires are calculated in the same way as for truck fires. Table 4–19 shows 

the risk results for dry deposition. As can be seen, only sediment-dwelling biota can be exposed in the 

SL-III range, with a corresponding low risk. Soil invertebrates, plants, and the American robin could be 

exposed in the SL-II range, also with a corresponding low risk. Consequences and risks to all other 

receptors are negligible.

Per Table 4–6, the frequencies of railcar crashes with subsequent fire and rain would be negligible for the

rail routes to every site. Therefore, all corresponding risks would be negligible.

Table 4–19. Frequencies, Consequences, and Risks to Ecological Receptors from

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

Ecological Receptor

Frequency Level (FL) 

of Crash with Fireb

Consequence 

Severity Level (SL) Risk

Sediment-dwelling biota FL-II (low) SL-III Low

Soil invertebrates FL-II (low) SL-II Low

Plants FL-II (low) SL-II Low

American robin FL-II (low) SL-II Low

River otter FL-II (low) SL-I Negligible

Aquatic biota FL-II (low) SL-I Negligible

Short-tailed shrew FL-II (low) SL-I Negligible

Great blue heron FL-II (low) SL-I Negligible

Red-tailed hawk FL-II (low) SL-I Negligible

a Applies equally to all candidate sites. 

b Frequencies of railcar crashes with fires from Table 4–6.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–38

4.2.10.1.4 Consequences – Intentionally Initiated Fire with Mercury Spill

Tables 4–20 and 4–21 summarize the results of calculations of the impact on ecological receptors 

resulting from an intentionally initiated gasoline tanker fire (IDA fire), described in Appendix D, 

Section D.2.6, of the January 2011 Mercury Storage EIS. As described previously, the railcar fire is 

taken as the surrogate for both railcar and truck IDA fires. Table 4–20 is for dry deposition and 

Table 4–21 is for wet deposition.

Table 4–20. Summary of Potential Exposure of Receptors to Consequence Severity Levels II, 

III, and IV – Intentionally Initiated Railcar Spill with Fire, No Rain

Ecological 

Receptor

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 

(Fa, 1.5 m/sb)

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

Sedimentdwelling 

biota 

3,000–

5,000

1,000–

2,000

30,000–

40,000

5,000–

7,000

Soil 

invertebrates

3,000–

5,000

20,000–

30,000

3,000–

5,000

Plants 1,000–

2,000

3,000–

5,000

700–

1,000

American 

robin 

1,000–

2,000

River otter 

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 

distances 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 4–20 shows the following for an intentionally initiated railcar fire with dry deposition:

No receptors would be exposed at the SL-IV level.

Sediment-dwelling biota could be exposed up to SL-III levels, but only in Atmospheric Stability 

Class A with a low windspeed, and then out to no more than 2,000 meters (6,600 feet).

Soil invertebrates, plants, and the American robin could be exposed at the SL-II level to 

considerable distances downwind.
Environmental Consequences

4–39

Table 4–21. Summary of Potential Exposure of Receptors to Consequence Severity Levels II, 

III, and IV – Intentionally Initiated Railcar Spill with Fire and Rain

Ecological 

Receptor

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 

(Fa, 1.5 m/sb)

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

Sedimentdwelling 

biota 

20,000–

30,000

5,000–

7,000

3,000–

5,000

>40,000c 10,000–

20,000

5,000–

7,000

30,000–

40,000

10,000–

20,000

10,000–

20,000

Soil 

invertebrates 

20,000–

30,000

3,000–

5,000

2,000–

3,000

>40,000c 7,000–

10,000

3,000–

5,000

30,000–

40,000

10,000–

20,000

7,000–

10,000

Plants 10,000–

20,000

1,000–

2,000

300–500 20,000–

30,000

2,000–

3,000

1,000–

2,000

20,000–

30,000

5,000–

7,000

2,000–

3,000

American 

robin 

7,000–

10,000

500–700 200–300 10,000–

20,000

2,000–

3,000

500–700 10,000–

20,000

3,000–

5,000

1,000–

2,000

River otter 3,000–

5,000

100–200 5,000–

7,000

7,000–

10,000

1,000–

2,000

200–300

Aquatic 

biota 

1,000–

2,000

3,000–

5,000

5,000–

7,000

200–300

Short-tailed 

shrew 

700–

1,000

2,000–

3,000

3,000–

5,000

Great blue 

heron 

300–500 2,000–

3,000

3,000–

5,000

Red-tailed 

hawk 

a Atmospheric Stability Class.

b Windspeed measured at 10 meters.

c The limit of validity of the model is 40,000 meters (approximately 25 miles).

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

distances 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: >=greater than; m/s=meters per second; SL=severity level.

Table 4–21 shows that the IDA fire with rain could lead to severe consequences to ecological receptors at 

considerable distances downwind.

It is not possible to estimate the frequencies of IDAs, so the risks are not tabulated.

4.2.10.2 WIPP Vicinity Section 20

The consequences to ecological resources remain the same for WIPP Vicinity Section 20 as they were 

presented for WIPP Vicinity Section 10 in Section 4.2.10.1.

4.2.10.3 WIPP Vicinity Section 35

The consequences to ecological resources remain the same for WIPP Vicinity Section 20 as they were 

presented for WIPP Vicinity Section 10 in Section 4.2.10.1.

4.2.11 Socioeconomics

4.2.11.1 WIPP Vicinity Section 10

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 to 6 individuals thereafter, resulting in a possible increase of the WIPP workforce of 

approximately 0.7 percent and an increase in the ROI of approximately 0.01 percent. This estimate 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

4–40

assumes that new employees would be hired for construction and operation 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 and population trends) 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 by approximately 0.9 percent on U.S. Route 62 or 

up to approximately 3.2 percent on Texas State Route 128. Fifty-three percent of these vehicles would be 

attributed to employee transportation. Impacts on traffic during construction would be minor.

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 by approximately 0.2 percent on U.S. Route 62 or up to approximately 0.9 percent on State 

Route 128. At the peak of operations, it is estimated that up to 79 shipments would be made in a year. 

Approximately 96 percent of the additional vehicles would be attributed to employee transportation. 

Impacts on traffic during operations would be minor.

Traffic in the vicinity of WIPP has experienced temporary increases in volume at various times due to oil 

production activities; however, these impacts are perceived to be transient in nature and would not impact 

shipments of mercury to the site.

4.2.11.2 WIPP Vicinity Section 20

The socioeconomic impacts would be identical to those described above in Section 4.2.11.1 for 

Section 10. Therefore, negligible impacts on socioeconomic conditions in the ROI would result from 

implementation of this alternative. Impacts on traffic during construction and operation would be minor.

4.2.11.3 WIPP Vicinity Section 35

The socioeconomic impacts would be identical to those described above in Section 4.2.11.1 for 

Section 10. Therefore, negligible impacts on socioeconomic conditions in the ROI would result from

implementation of this alternative. Impacts on traffic during construction and operation would be minor.

4.2.12 Environmental Justice

4.2.12.1 WIPP Vicinity Section 10

None of the block groups within either the 16-kilometer (10-mile) radius or the 3.2-kilometer (2-mile)

radius surrounding WIPP Vicinity Section 10 contain a minority or low-income population 

(see Chapter 3, Section 3.2.11.1). Therefore, no disproportionately high and adverse effects on minority 

or low-income populations are expected.

4.2.12.2 WIPP Vicinity Section 20

None of the block groups within either the 16-kilometer (10-mile) radius or the 3.2-kilometer (2-mile) 

radius surrounding WIPP Vicinity Section 20 contain a minority or low-income population 
Environmental Consequences 

4–41

(see Chapter 3, Section 3.2.11.2). Therefore, no disproportionately high and adverse effects on minority 

or low-income populations are expected. 

4.2.12.3 WIPP Vicinity Section 35 

None of the block groups within either the 16-kilometer (10-mile) radius or the 3.2-kilometer (2-mile) 

radius surrounding WIPP Vicinity Section 35 contain a minority or low-income population 

(see Chapter 3, Section 3.2.11.3). Therefore, no disproportionately high and adverse effects on minority 

or low-income populations are expected. 

4.3 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 treatment, storage, and disposal 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. 

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

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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. 

4.4 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). 

4.4.1 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. 

The ROI used in the cumulative impacts analysis is assumed to be within a 16-kilometer (10-mile) radius 

of the WIPP Vicinity reference locations. 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 Chapter 4). 

Reasonably foreseeable future actions were identified. 

Cumulative impacts of the proposed action at the WIPP Vicinity reference locations were 

estimated. 

The analysis of constructing and operating a mercury storage facility at any of the WIPP Vicinity 

reference locations determined that impacts on the various resource areas ranged from none to moderate. 

In keeping with CEQ regulations (40 CFR 1508.7), those resource areas that were predicted to be 

impacted at greater than a negligible level 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. This does not mean that other site activities associated with these 

resource areas are negligible; it means that impacts associated with a mercury storage facility would have 

a negligible contribution to their cumulative impacts. 
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4.4.2 Potential Cumulative Actions

Actions that may contribute to cumulative impacts at any of the WIPP Vicinity reference locations 

include on- and offsite projects conducted by government agencies, businesses, or individuals that are 

within the 16-kilometer (10-mile) ROI. The potential actions listed in Table 4–22 are those that may 

contribute to cumulative impacts on or within the ROI.

Table 4–22. Actions That May Contribute to Cumulative Impacts

Location Description Reference

Waste Isolation Pilot Plant

Onsite DOE Action Construction of a facility to dispose of greater-than-Class C low-level 

radioactive waste. Disposal in a trench, borehole, vault, or 

underground repository is being considered; one of the locations being 

considered is WIPP Vicinity Section 35.

DOE 2011b

Offsite Action No known actions proposed by the U.S. Bureau of Land Management, 

the predominant land steward within the region of influence.

DOE 2011b

Also present within the region of influence are a number of oil wells 

and underground potash mines located in the vicinity of WIPP, 

including an existing potash mine lease on WIPP Vicinity Section 10

and one oil well in WIPP Vicinity Section 35.

Rutley 2012

DOE 2011b

Key: DOE=U.S. Department of Energy; WIPP=Waste Isolation Pilot Plant.

A fluorine extraction and depleted uranium deconversion facility has been proposed for a site located 

22.5 kilometers (14 miles) west of Hobbs, New Mexico (NRC 2012). Analysis of this project has 

projected that it would generally have small impacts on the environment. Additionally, the facility site is 

64 kilometers (40 miles) northeast of the proposed mercury storage site. Thus, this project would not be 

expected to contribute to cumulative impacts.

4.4.2.1 Waste Isolation Pilot Plant Vicinity Reference Locations

The cumulative impacts of locating a mercury storage facility at any of the WIPP Vicinity reference 

locations on land use, air quality, infrastructure, and ecological resources were evaluated and predicted to 

be greater than negligible. Since there were either no or negligible impacts associated with locating a 

storage facility at any of the WIPP Vicinity reference locations on visual resources, geology and soils, 

water resources, cultural and paleontological resources, waste management, occupational and public 

health and safety, socioeconomics, and environmental justice, these resources were not evaluated with 

respect to their contribution to cumulative impacts.

4.4.2.1.1 Land Use

A mercury storage facility could be constructed at the Section 10 site located just to the north of the WIPP 

site boundary, the Section 20 site located within the Off-Limits Area, or the Section 35 site located just to 

the southeast of the WIPP site boundary (see Figure 4–1). At any of the WIPP Vicinity reference 

locations, the facility would require 3.1 hectares (7.6 acres). The mercury storage facility would be 

located on relatively undisturbed, rural land. The only major DOE project planned within the 

16-kilometer (10-mile) ROI is the proposed greater-than-Class C (GTCC) waste disposal facility, also 

located in close proximity to WIPP, including an option to locate the facility in Section 35 

(see Figure 4–1). Depending on the type of facility selected (i.e., borehole, trench, vault, or underground 

repository), the GTCC waste disposal facility could require up to 44 hectares (110 acres) (DOE 2011b). 

A mercury storage facility and GTCC waste disposal facility could be located within the 260-hectare 

(640-acre) area that comprises Section 35 without interference with operations or compromising the 

safety and security of these facilities. Also present within the ROI are a number of oil wells and extensive 

potash mining that occur in the vicinity of WIPP outside of the LWB. Although the mercury storage 
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facility would slightly increase development with the ROI, due to the limited area of disturbance, its 

contribution to cumulative impacts on land use would be negligible. 

Figure 4–1. Candidate Mercury Storage and Greater-Than-Class C 

Waste Disposal Facility Locations 

4.4.2.1.2 Air Quality 

Construction of a mercury storage facility at any of the WIPP Vicinity reference locations 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. Also, it has been estimated 

that total peak-year emission rates for construction of a facility for disposal of GTCC waste would be 

small (DOE 2011b). Thus, due to the projected low levels of emissions and the fact that peak air 

pollutant concentrations from the two proposed facilities would likely occur at different times, 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. Further, since such emissions are not expected from other activities within the ROI, there 

would be no cumulative impacts related to mercury emissions. 
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4–45

Transportation of mercury to a storage facility at any of the WIPP Vicinity reference locations would 

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.

4.4.2.1.3 Site Infrastructure

Construction and operation of a mercury storage facility are not expected to appreciably increase demands 

on the transportation systems leading to the WIPP Vicinity reference locations. A maximum of 

79 shipments would be made to the proposed mercury storage facility during the peak year of operation 

(see Appendix C). Depending on the alternative, the proposed GTCC waste disposal facility would 

involve 630 to 1,685 truck trips per year during its 20 years of operations (DOE 2011b). Since WIPP 

received its first shipment of transuranic waste in 1999, WIPP has received 10,244 shipments 

through 2011, an average of approximately 800 shipments per year (DOE 2012).

Fuel and water requirements during construction and operation of the mercury storage facility would be 

minimal and would not impact regional supplies. During construction, both would be delivered by truck 

on an as-needed basis. During operations, fuel oil would continue to be supplied via truck; however, 

potable water would be supplied through tie-in to the existing water supply at WIPP. Fuel oil needed for 

construction and operation of the proposed GTCC waste disposal facility would also be delivered by 

truck and water use would be small, with impacts on the water supply system being negligible 

(DOE 2011b). Demand for these resources is not expected to impact local or regional supplies. Thus, 

cumulative impacts on fuel and water supplies are not expected. 

Electricity demand during construction of the mercury storage facility would be minimal and would likely 

be supplied by a diesel-fired generator. However, during operations, electric power requirements would 

increase the annual electrical energy consumption at the WIPP site, resulting in the need to provide a new 

service connection to the Xcel Energy powerline that is separate from the electrical substation that 

supports WIPP operations (see Section 4.2.7). This would lead to a moderate impact on electrical 

infrastructure. In additional to the proposed mercury storage facility and WIPP, the proposed GTCC 

waste disposal facility would create a small increase in the electrical energy demand (DOE 2011b). 

However, the increase in electric power demand from these projects is not expected to have a cumulative 

impact on the ability of Xcel Energy to supply power within the ROI.

4.4.2.1.4 Ecological Resources

None of the WIPP Vicinity reference locations have been disturbed by current development, and each 

exhibits terrestrial resources common to the area (see Chapter 3, Section 3.2.5.1). Construction of a 

mercury storage facility would result in the loss of 3.1 hectares (7.6 acres) of desert grassland and shortgrass prairie habitat. There are no wetlands or aquatic habitat at any of the sites, nor have any federally 

threatened or endangered species or critical habitat been identified. Depending on the type of facility 

selected (i.e., borehole, trench, vault, or underground repository), the GTCC waste disposal facility could 

disturb up to 44 hectares (110 acres) of similar habitat within and adjacent to the WIPP site boundary. 

Although mercury storage facility construction would remove a small area of habitat, its contribution to 

cumulative impacts on terrestrial resources would be negligible. Due to the lack of occurrence of 

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.
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4.5 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 throughout the duration of the action 

Compensating for impacts by replacing or providing substitute resources or environments 

Following the completion of an environmental impact statement 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(ies) 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, 

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(ies) would be conducted in accordance with the 

standards specified under 40 CFR 264 for hazardous waste treatment, storage, and disposal facilities. 

These include, but are not limited to, the location and performance standards for new RCRA-permitted 

facilities under 40 CFR 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(ies) operations. Although mercury vapor emissions from the Storage Area of the 

facility 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 be expensive to operate and maintain in order to achieve relatively small 

decreases in emissions that would already be low. 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. 
Environmental Consequences 

4–47

As a mitigation measure, emergency response planning for a facility accident would take into account the 

potential for individuals to be linguistically isolated and implement appropriate steps to ensure timely 

communication of hazards that may adversely affect such offsite individuals. DOE works closely with 

Federal, state, and local agencies that would provide first responders. Emergency response planning 

would take into account the applicable procedures in DOE’s Emergency Management Guide

(DOE Guide 151.1-4). 

Irrespective of frequency, should a transportation accident occur within a few kilometers upwind of a 

body of water used by subsistence fishermen, it would be advisable as a mitigation measure to monitor 

the levels of methylmercury in fish and to post appropriate advisories to ensure that subsistence fishermen 

do not consume amounts of methylmercury that might cause adverse health effects. Subsequent to 

mandated reporting of any such release by the shipper of the elemental mercury, the appropriate state 

environmental agency would be responsible for determining appropriate fish consumption advisories and 

monitoring requirements of mercury concentrations in waters and fish stocks. 

4.6 RESOURCES 

This section describes any unavoidable adverse environmental impacts that could result from siting a 

mercury storage facility(ies) at any of the candidate sites evaluated in the January 2011 Mercury Storage 

EIS and in this draft SEIS; irreversible and irretrievable commitments of resources; and the relationship 

between short-term uses of the environment and the maintenance and enhancement of long-term 

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 

long-term 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. 

4.6.1 Unavoidable Adverse Environmental Impacts 

Siting a mercury storage facility(ies) at any of the candidate sites considered in the January 2011 Mercury 

Storage EIS and this draft SEIS 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 candidate sites. 

As further described in this chapter, construction of a new mercury storage facility(ies) 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 

have negligible impacts overall and would be temporary in nature (i.e., lasting up to 6 months). A 

full-size mercury storage facility would occupy up to 3.1 hectares (7.6 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. 
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4–48

Operations of new or modified facilities at any of the 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(ies). The 

associated emissions would not measurably degrade ambient air quality or jeopardize 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(ies) 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 Chapter 4, Section 4.2, of the January 2011 Mercury Storage EIS).

Future closure of mercury storage facilities (see Chapter 4, Section 4.10, of the January 2011 Mercury

Storage EIS) 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.

4.6.2 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 the January 2011 Mercury Storage EIS and this draft SEIS. 

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(ies) are 

presented in Appendix C. The No Action Alternative would entail the least commitment of land, 

material, and energy resources based on the analyses presented in Chapter 4 of the January 2011 Mercury

Storage EIS.

4.6.2.1 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. 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 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.
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4–49

4.6.2.2 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 operation 

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.

4.6.2.3 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). For practical purposes, materials including concrete, 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.

4.6.2.4 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.

4.6.3 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.

Under the No Action Alternative, environmental resources have already been committed to activities 

at Y–12 and at some existing source locations. There could be environmental impacts at non-DOE 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

4–50

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. 

4.7 REFERENCES 

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Environmental Policy Act, Executive Office of the President, Washington, DC, January. 

DLA (Defense Logistics Agency), 2004, Final Mercury Management Environmental Impact Statement, 

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DOE (U.S. Department of Energy), 2008, Waste Isolation Pilot Plant Annual Site Environmental Report 

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EPA (U.S. Environmental Protection Agency), 1997a, Mercury Study Report to Congress, Vol. V, Health 

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EPA (U.S. Environmental Protection Agency), 2001, Water Quality Criterion for the Protection of 

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EPA (U.S. Environmental Protection Agency), 2003, User’s Guide to MOBILE6.1 and MOBILE6.2, 

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of Transportation and Air Quality, August.

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Johnson, P.E., and R.D. Michelhaugh, 2003, Transportation Routing Analysis Geographic Information 

System (TRAGIS) User’s Manual, ORNL/NTRC-006, Oak Ridge National Laboratory, Oak Ridge, 

Tennessee, June.

NRC (U.S. Nuclear Regulatory Commission), 2012, Environmental Impact Statement for the Proposed 

Fluorine Extraction Process and Depleted Uranium Deconversion Plant in Lea County, New Mexico, 

NUREG-2113, Office of Federal and State Materials and Environmental Management Programs, 

Washington, DC, accessed through http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2113/, 

August.

Rutley, J.S., 2012, U.S. Bureau of Land Management, Carlsbad Field Office, personal communication 

(email) to D. Levenstein, U.S. Department of Energy, Office of Environmental Management, “Potash 

Mining in the Vicinity of WIPP,” December 5.

Tornadohistoryproject, 2012, Custom Search: New Mexico Tornadoes 1950–2011, accessed through 

http://www.tornadohistory project.com/custom/1698849/table, November.

USGS (U.S. Geological Survey), 2012, Earthquake Hazards Program – Hazards, Interactive Hazards 

Map Conterminous US 2008, accessed through http://earthquake.usgs.gov/hazards/apps/map, September.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

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Code of Federal Regulations

10 CFR 1021.331, U.S. Department of Energy, “National Environmental Policy Act Implementing 

Procedures: Mitigation Action Plan.”

36 CFR 800.11, Advisory Council on Historic Preservation, “Protection of Historic Properties: 

Documentation Standards.”

40 CFR 264, U.S. Environmental Protection Agency, “Standards for Owners and Operators of Hazardous 

Waste Treatment, Storage, and Disposal Facilities.”

40 CFR 1508.7, Council on Environmental Quality, “Terminology and Index: Cumulative Impact.”

40 CFR 1508.20, Council on Environmental Quality, “Terminology and Index: Mitigation.”

43 CFR 10.4, Office of the Secretary of the Interior, “Human Remains, Funerary Objects, Sacred Objects, 

or Objects of Cultural Patrimony from Federal or Tribal Lands: Inadvertent Discoveries.”

U.S. Department of Energy Directives

DOE Guide 151.1-4, Response Elements Emergency Management Guide, July 11, 2007.

DOE Guide 420.1-2, Guide for the Mitigation of Natural Phenomena Hazards for DOE Nuclear 

Facilities and Nonnuclear Facilities, March 28, 2000.

DOE Order 420.1B, Facility Safety, December 22, 2005.

DOE Standard 1020-2002, Natural Phenomena Hazards Design and Evaluation Criteria for Department 

of Energy Facilities, January 2002.

DOE Standard 1023-95, Natural Phenomena Hazards Assessment, April 2002.

U.S. Public Laws

P.L. 102-579, The Waste Isolation Pilot Plant Land Withdrawal Act.

P.L. 110-414, Mercury Export Ban Act of 2008.
CHAPTER 5

ENVIRONMENTAL LAWS, REGULATIONS, PERMITS, AND 

OTHER POTENTIALLY APPLICABLE REQUIREMENTS

5–1

CHAPTER 5

ENVIRONMENTAL LAWS, REGULATIONS, PERMITS,

AND OTHER POTENTIALLY APPLICABLE REQUIREMENTS

Chapter 5 presents the laws, regulations, permits, and other requirements that could potentially apply to the 

proposed action. The proposed action would be implemented in accordance with all applicable Federal, state, and 

local laws and regulations and in full compliance with U.S. Department of Energy policies, orders, procedures, and 

guidance documents. Consultations have been initiated with Federal and state agencies in accordance with 

applicable requirements.

5.1 INTRODUCTION

In compliance with the National Environmental Policy Act (NEPA) of 1969, as amended, Council on 

Environmental Quality (CEQ) NEPA regulations (40 CFR 1500–1508), and U.S. Department of Energy 

(DOE) NEPA implementing procedures (10 CFR 1021), DOE must consider applicable environmental 

regulations and any permitting or licensing requirements (including permit applications for new permits 

or permit modifications for existing permits) when evaluating alternatives for implementing the proposed 

action. The initial Notice of Intent (NOI) announcing the preparation of the January 2011 Long-Term 

Management and Storage of Elemental Mercury Environmental Impact Statement (Mercury Storage EIS)

(DOE 2011), issued on July 2, 2009 (74 FR 31723), and the NOI announcing the preparation of this 

supplement to the January 2011 Mercury Storage EIS, issued on June 5, 2011 (77 FR 33204), identify

that one of the issues to be considered is compliance with all applicable Federal, state, and local statutes 

and regulations and required Federal and state environmental permits, consultations, and notifications. 

Chapter 5 of the January 2011 Mercury Storage EIS discusses a range of potentially applicable Federal 

laws, regulations, and laws from the states where the potential candidate sites evaluated in the 

January 2011 Mercury Storage EIS are located. This chapter includes a range of potentially applicable 

Federal laws and regulations, and laws from New Mexico applicable to the three candidate sites identified 

near the Waste Isolation Pilot Plant (WIPP) that are evaluated in this Draft Long-Term Management and 

Storage of Elemental Mercury Supplemental Environmental Impact Statement: two outside the land 

withdrawal boundary (LWB) and one within the LWB in the vicinity of WIPP. These locations will be 

referred to individually as “WIPP Vicinity Section 10,” “WIPP Vicinity Section 20,” or “WIPP Vicinity 

Section 35,” or together as the “WIPP Vicinity reference locations.” State statutes typically mirror the 

Federal statutes in that they are required to be, at a minimum, equally as stringent.

This chapter identifies major requirements that could be applicable to the proposed action, which is to 

designate and operate a facility(ies) for the long-term management and storage of elemental mercury 

generated within the United States.1 Section 5.2 describes the laws, regulations, and other applicable 

requirements that set environmental protection requirements that could apply to the WIPP Vicinity 

reference locations in New Mexico. Section 5.3 discusses potentially applicable permits. Section 5.4 

describes applicable consultations.

5.2 LAWS, REGULATIONS, AND OTHER POTENTIALLY APPLICABLE 

REQUIREMENTS

This section describes the Mercury Export Ban Act of 2008 and the Waste Isolation Pilot Plant Land 

Withdrawal Act of 1992. Chapter 5, Sections 5.1 and 5.2, of the January 2011 Mercury Storage EIS

(DOE 2011) describe additional Federal laws, regulations, and other potentially applicable requirements 

as they relate generally to Federal actions, specifically to elemental mercury management and storage, 

and to the construction and operation of a long-term management and storage facility(ies) for elemental 

 

1 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this 

supplemental environmental impact statement.
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5–2

mercury at any of the candidate sites, including the WIPP Vicinity reference locations. These additional 

Federal laws, regulations, and potentially applicable requirements are identified in the January 2011 

Mercury Storage EIS. Mercury is addressed in numerous U.S. Environmental Protection Agency 

regulations, including regulations pertaining to air quality, water quality, hazardous waste management, 

and pollution prevention.

The Mercury Export Ban Act of 2008

On October 14, 2008, President George W. Bush signed into law the Mercury Export Ban Act of 2008 

(the Act), Public Law No. 110-414. The overarching purpose of the Act is “to prohibit the sale, 

distribution, transfer, and export of elemental mercury.”

Section 3 of the Act amends the Toxic Substances Control Act (TSCA) to prohibit any Federal agency 

from selling, distributing, conveying, or transferring to any other Federal, state, or local agency, or any 

private entity or individual, any elemental mercury under the control or jurisdiction of the Federal agency, 

effective beginning on the date of enactment of the Act. The Act sets forth two exceptions to this 

prohibition: (1) “a transfer between Federal agencies of elemental mercury for the sole purpose of 

facilitating storage of mercury to carry out this Act; or” (2) “a conveyance, sale, distribution, or transfer 

of coal.”

Section 4 amends TSCA to prohibit the export of elemental mercury from the United States effective 

January 1, 2013. Section 4 also establishes certain reporting requirements and provides an essential use 

exemption.

Section 5, entitled “Long-Term Storage,” directs DOE to designate a facility(ies) for the long-term 

management and storage of elemental mercury generated within the United States. It states that DOE’s 

facility(ies) must be operational by January 1, 2013, and ready to accept custody of elemental mercury 

delivered to such a facility(ies). The Act also requires DOE to assess fees based upon the pro rata costs 

of long-term management and storage of the elemental mercury. The Act establishes October 1, 2012, as 

the date on which DOE must make public the fee schedule. Section 5(d)(1) further provides that the 

elemental mercury stored at the facility(ies) is subject to the requirements of the Solid Waste Disposal 

Act (SWDA), including the hazardous waste management requirements under Subtitle C of the SWDA; 

however, the Act provides that the elemental mercury stored at the DOE facility(ies) “shall not be subject 

to the storage prohibition of Section 3004(j) of the SWDA.”

DOE’s designation of a facility(ies) for the purpose of long-term management and storage of elemental 

mercury is a Federal action that is governed by NEPA and is the basis for DOE’s preparation of this 

supplemental environmental impact statement.

Federal Land Policy and Management Act of 1976, as amended

On October 21, 1976, President Gerald R. Ford signed into law the Federal Land Policy and Management 

Act (FLPMA) of 1976, Public Law No. 94-579. FLPMA governs the way in which the public lands 

administered by the U.S. Bureau of Land Management (BLM) are managed. The passage of FLPMA is 

called the “organic act” because it consolidated many of BLM’s responsibilities. Various land and 

resource management policies, statutes, and authorities were established, amended, or repealed by 

FLPMA. FLPMA addresses land use planning, land acquisition, fees and payments, administration of 

Federal land, range management, and rights-of-way on Federal land. FLPMA also establishes the concept 

of multiple use of public lands, which means they are utilized in a combination that will best meet present

and future needs.
Environmental Laws, Regulations, Permits, and Other Potentially Applicable Requirements

5–3

Two of the WIPP vicinity candidate sites considered for the long-term management and storage of 

elemental mercury are in Section 10 and Section 35, areas located outside the WIPP LWB. 

BLM-administered land outside the WIPP LWB used for construction and operations of a long-term 

management and storage facility for elemental mercury would be withdrawn from all forms of entry, 

appropriation, and disposal under the FLPMA and reserved for the purposes of operating a mercury 

storage facility, as was done for the WIPP land withdrawal.

The Waste Isolation Pilot Plant Land Withdrawal Act of 1992, as amended

On October 30, 1992, President George H.W. Bush signed into law the Waste Isolation Pilot Plant Land 

Withdrawal Act of 1992, Public Law No. 102-579, subsequently amended by the Waste Isolation Pilot 

Plant Land Withdrawal Act Amendments of 1996, Public Law No. 104-201 (WIPP LWA). The WIPP 

LWA withdrew land from the public domain for the purpose of creating and operating WIPP, the 

geologic repository in New Mexico designated as the national disposal site for transuranic waste 

generated by atomic energy defense activities.

One of the WIPP vicinity candidate sites considered for the long-term management and storage of 

elemental mercury is in Section 20, an area located inside the WIPP LWB. Land inside the WIPP LWB 

used for construction and operations of a long-term management and storage facility for elemental 

mercury would be subject to the provisions of the WIPP LWA (as discussed for WIPP) and may require

Federal legislation.

5.3 PERMITS AND NOTIFICATIONS

This section summarizes the general requirements for either permit modification or permit application for 

the WIPP Vicinity reference locations, noting that there is a degree of uncertainty in the permitting 

process. Regulatory agencies responsible for applicable permitting at these locations are also identified. 

Table 5–1 summarizes the existing and potential new environmental permits for air, water, and hazardous 

waste for the WIPP Vicinity reference locations.

Regulatory notification to either the U.S. Environmental Protection Agency or the authorized New 

Mexico regulatory compliance divisions of the intent to provide long-term storage and management of 

elemental mercury and any treatment, storage, and disposal (TSD) facility design changes, 

modifications, etc., would be required. Communication and coordination with all applicable regulatory 

agencies, including site-specific discussions and facility-specific permitting requirements (application for 

new permits or modification to existing permits), will be required for the long-term management and 

storage of elemental mercury at the selected site. For example, because of the requirement that the 

elemental mercury storage facility(ies) operate under a permit pursuant to Section 3005 of SWDA, 

hazardous waste TSD facility requirements and all associated permitting will be necessary.

WIPP has experience applying for and operating under air quality and hazardous waste facility permits. 

The WIPP Vicinity reference locations would require new permits or modifications to existing permits, 

where appropriate. These new or modified permits would be subject to approval by the applicable 

regulatory agency.
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5–4

Table 5–1. Environmental Permit Summary

Permits

WIPP Vicinity Reference Locations

New Mexico

Air

Existing Permit(s) None for WIPP Vicinity reference locations. However, WIPP has an 

Air Quality Permit (310-M-2) issued by the State of New Mexico for 

the operation of two emergency generators.

New Permit Application Yes, State

Permit Modification No

Regulatory Notification Yes, State

Water

National Pollutant Discharge Elimination System

Existing Permit(s) No

New Permit Application Yes, State

Permit Modification No

Regulatory Notification Yes, State

General Construction Stormwater Permit

Existing Permit(s) No

New Permit Application Yes, State

Permit Modification No

Regulatory Notification Yes, Federal

Hazardous Waste

Existing Permit(s) None for WIPP Vicinity reference locations. However, WIPP has a 

Hazardous Waste Facility Permit (NM 4890139088) issued by the 

State of New Mexico for mixed transuranic waste storage and disposal.

New Permit Application Yes, State

Permit Modification No

Regulatory Notification Yes, State
Environmental Laws, Regulations, Permits, and Other Potentially Applicable Requirements

5–5

Potential permits that may be required for the WIPP Vicinity reference locations are described below.

New Mexico Statutes Annotated (NMSA), Chapter 74, Environmental Improvement, Article 2, 

Air Pollution, and Implementing Regulations at New Mexico Administrative Code (NMAC),

Title 20, Environmental Protection, Chapter 2, Air Quality. Establishes air quality standards and 

requires a permit prior to construction or modification of an air contaminant source. Also requires an 

operating permit for major producers of air pollutants and imposes emission standards for hazardous 

air pollutants.

NMSA, Chapter 74, Article 6, Water Quality, and Implementing Regulations at NMAC, 

Title 20, Chapter 6, Water Quality. Establishes water quality standards and requires a permit prior 

to the construction or modification of a water discharge source.

NMSA, Chapter 74, Article 9, Solid Waste Act, and Implementing Regulations at NMAC,

Title 20, Chapter 9, Solid Waste. Requires a permit prior to construction or modification of a solid 

waste disposal facility.

NMSA, Chapter 74, Article 4, Hazardous Waste, and Implementing Regulations at NMAC,

Title 20, Chapter 4, Hazardous Waste. Establishes permit requirements for construction, operation, 

modification, and closure of a hazardous waste management facility and establishes state standards

for cleanup of releases from leaking underground storage tanks.

Environmental Oversight and Monitoring Agreement. Agreement in Principle between DOE and 

the State of New Mexico. Provides DOE support for state activities in environmental oversight, 

monitoring, access, and emergency response.

5.4 CONSULTATIONS

NEPA and CEQ regulations require DOE and other Federal agencies to consult with Federal agencies, 

federally recognized tribal governments, and state and local agencies with jurisdiction or special expertise 

regarding any environmental impact of Federal actions. Agencies involved include those with authority 

to issue applicable permits, licenses, and other regulatory approvals, as well as those responsible for 

protecting significant resources (e.g., endangered species, critical habitats, or historic resources). The 

majority of consultations are in the areas of ecological and cultural resources, and American Indian 

heritage, religious and cultural areas. In addition, DOE policies require consultation with American 

Indian tribal governments with regard to any DOE action that might affect any property to which these 

governments attach religious or cultural importance. DOE is committed to fulfilling its responsibilities of 

providing open communication and full consultations with federally recognized tribal governments.

If a proposed action has the potential to disturb sensitive species or habitats, ecological resource 

consultations with the appropriate agencies are required. If a proposed action has the potential to disturb 

or disrupt a cultural resource or an archaeological site, cultural resource consultations are required.

If, at any time during implementation of a proposed action, an inadvertent discovery is made with 

potential impacts on ecological, cultural, or American Indian artifacts or materials or human remains, all 

activity would cease until consultation with affected agencies, organizations, and/or governments is 

completed. Actions would not resume until a plan is established to mitigate any potential adverse impacts 

and all applicable consultations have been completed. Table 5–2 provides a summary of consultations 

pertaining to the WIPP Vicinity reference locations. Chapter 5, Table 5–4, of the January 2011 Mercury 

Storage EIS (DOE 2011) presents a summary of consultations for all other candidate sites.
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Table 5–2. Summary of Consultationsa

Subject Consultation Letter Addressed to

Ecological 

Resources

Mr. Wally Murphy, Field Supervisor 

U.S. Fish and Wildlife Service

New Mexico Ecological Services Office

2105 Osuna NE

Albuquerque, NM 87113

Matthew Wunder, Division Chief

Conservation Services

New Mexico Department of Game and Fish

P.O. Box 25112

Santa Fe, NM 87504

Tony Delfin, State Forester

Forestry Division

1220 South Saint Francis Drive

Santa Fe, NM 87505

Cultural 

Resources

Jan Biella, State Historic Preservation Officer

Historic Preservation Division

Department of Cultural Affairs

Bataan Memorial Building

407 Galisteo Street, Suite 236

Santa Fe, NM 87501

a Copies of letters are presented in Appendix I.

5.4.1 Consultations Regarding Ecological Resources

Consultations with applicable organizations regarding ecological resources for the WIPP Vicinity 

reference locations have been initiated (see Table 5–2). The consultations support the process to obtain 

input regarding the potential for ecological impacts on threatened, endangered, or otherwise protected 

species or habitats.

5.4.2 Consultations Regarding Cultural Resources

Consultation with the New Mexico State Historic Preservation Officer has been initiated for the WIPP 

Vicinity reference locations (see Table 5–2). The consultation supports the process to obtain input 

regarding the potential for impacts on cultural resources.

5.5 REFERENCES

DOE (U.S. Department of Energy), 2011, Final Long-Term Management and Storage of Elemental 

Mercury Environmental Impact Statement, DOE/EIS-0423, Office of Environmental Management, 

Washington, DC, January.
CHAPTER 6

GLOSSARY

6–1

CHAPTER 6

GLOSSARY

accident – An unplanned sequence of events 

resulting in undesirable consequences, such as 

the release of hazardous material to the 

environment.

active fault – A fault that is likely to have 

another earthquake sometime in the future. 

Faults are commonly considered to be active if 

they have moved one or more times in the last 

10,000 years. In assessing seismic hazard as 

part of the U.S. Geological Survey’s National 

Earthquake Hazard Reduction Program, faults 

for which there is surface evidence of tectonic 

activity during the Quaternary Period are 

considered active.

acute – Severe but of short duration; not 

chronic.

Acute Exposure Guideline Levels (AEGLs) –

Threshold values published by the National 

Research Council and National Academy of 

Sciences for use in chemical emergency 

planning, prevention, and response programs. 

AEGLs represent threshold exposure limits for 

the general population, including susceptible 

individuals, and are developed for exposure 

periods of 10 minutes, 30 minutes, 1 hour, 

4 hours, and 8 hours. AEGL values are defined 

for varying degrees of severity of toxic effects, 

as follows:

AEGL-1: The airborne level of concentration 

of a substance above which the exposed 

population could experience notable 

discomfort, irritation, or certain 

asymptomatic nonsensory effects. However, 

the effects would not be disabling and would 

be transient and reversible upon cessation of 

exposure.

AEGL-2: The airborne level of concentration 

of a substance above which the exposed 

population could experience irreversible or 

other serious, long-lasting adverse health 

effects or an impaired ability to escape.

AEGL-3: The airborne level of concentration 

of a substance above which the exposed 

population could experience life-threatening 

health effects or death.

air pollutant – Generally, an airborne substance 

that could, in high-enough concentrations, harm 

living things or cause damage to materials. 

From a regulatory perspective, an air pollutant is 

a substance for which emissions or atmospheric 

concentrations are regulated or for which 

maximum guideline levels have been established 

due to potential harmful effects on human health 

and welfare.

air quality – The cleanliness of the air as 

measured by the levels of pollutants relative to 

the standards or guideline levels established to 

protect human health and welfare. Air quality is 

often expressed in terms of the pollutant for 

which concentrations are the highest percentage 

of a standard (e.g., air quality may be 

unacceptable if the level of one pollutant is 

150 percent of its standard, even if levels of 

other pollutants are well below their respective 

standards).

air quality control region – Geographic 

subdivisions of the United States designed to 

deal with pollution on a regional or local level. 

Some regions span more than one state.

alloy – A mixture containing mostly metals. For 

example, brass is an alloy of copper and zinc. 

An amalgam is an alloy (e.g., an amalgam of 

mainly silver and mercury).

alluvium (alluvial) – Unconsolidated, poorly 

sorted detrital sediments, ranging from clay to 

gravel sizes, deposited by streams.

ambient – Surrounding.

ambient air – The atmosphere around people, 

plants, and structures.
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6–2

ambient air quality standards – Regulations 

prescribing the levels of airborne pollutants that 

may not be exceeded during a specified time in a 

defined area.

American Indian Religious Freedom Act of 

1978 – An act that protects and preserves for 

American Indians their traditional religious 

rights, including the rights of access to religious 

sites, use and possession of sacred objects, and 

worship through traditional ceremonies and 

rites.

anthropogenic – Caused or produced by 

humans.

aquatic – Living or growing in, on, or near 

water.

aquifer – An underground geologic formation, 

group of formations, or part of a formation 

capable of yielding a significant amount of water 

to wells or springs.

aquitard – A relatively less permeable geologic 

unit that inhibits the flow of water.

Archaeological Resources Protection Act of 

1979 – An act protecting cultural resources on 

federally owned lands. This act requires a 

permit for archaeological excavations or the 

removal of any archaeological resources on 

public or American Indian lands. It also 

prohibits interstate or foreign trafficking in 

cultural resources taken in violation of state or 

local laws and requires Federal agencies to 

develop plans for surveying lands under their 

control.

archaeological site – Any location where 

humans have altered the terrain or discarded 

artifacts during prehistoric or historic times.

artifact – An object produced or shaped by 

human beings and of archaeological or historic 

interest.

artisanal gold mining – A general term used in 

reference to small-scale mining operations 

prevalent in some developing countries that 

employ the crude and highly polluting process of 

mixing mercury with sediments from river 

bottoms and adjacent areas to extract gold.

atmospheric dispersion – The distribution of 

pollutants from their source into the atmosphere 

by wind, turbulent air motion attributable to 

solar heating of Earth’s surface, or air movement 

over rough terrain and variable land and water 

surfaces.

attainment area – An area considered to have 

air quality as good as or better than the National 

Ambient Air Quality Standards for a given 

pollutant. An area may be in attainment for one 

pollutant and nonattaining for others. (See also 

nonattainment area.)

basalt – The most common volcanic rock, dark 

gray to black in color, high in iron and 

magnesium and low in silica. It is typically 

found in lava flows.

baseline – A quantitative expression of 

conditions, costs, schedule, or technical progress 

that constitutes the standard against which to 

measure the performance of an effort. For 

National Environmental Policy Act evaluations, 

baseline is defined as the existing environmental 

conditions against which impacts of the 

proposed action and its alternatives can be 

compared. The environmental baseline is the 

site environmental conditions as they exist or are 

estimated to exist in the absence of the proposed 

action.

basin – Geologically, a circular or elliptical 

downwarp or depression in the Earth’s surface 

that collects sediment. Younger sedimentary 

beds occur in the center of basins. 

Topographically, a depression into which water 

from the surrounding area drains.

bedding plane – Surface separating layers of 

sedimentary rocks and deposits. Each bedding 

plane marks the termination of one deposit and 

the beginning of another of different character, 

such as a surface separating a sandstone bed 

from an overlying mudstone bed. Rock tends to 

break or separate readily along bedding planes.

bedrock – The solid rock that lies beneath soil 

and other loose surface materials.
Glossary

6–3

bioaccumulation – The accumulation or 

buildup of contaminants in living systems by 

biological processes. Methylmercury can 

bioaccumulate in animal tissue.

bioaccumulation factor – The ratio of the 

concentration of a chemical in an organism to its 

concentration in a medium to which the 

organism is exposed.

bound – An analysis of impacts or risks such 

that the result overestimates or describes a limit 

on (i.e., “bounds”) potential impacts or risks.

bounding analysis – An analysis designed to 

overestimate or determine an upper limit to 

potential impacts or risks.

cancer – The name given to a group of diseases 

characterized by uncontrolled cellular growth 

where the cells have invasive characteristics that 

enable the disease to transfer from one organ to 

another.

carbon dioxide – A colorless, odorless, 

nonpoisonous gas that is a normal component of 

the ambient air and an expiration product of 

normal animal life.

carbon monoxide – A common air pollutant 

formed by incomplete combustion; a colorless, 

odorless gas that is toxic if breathed in high 

concentrations over an extended period; when 

humans are exposed to lower concentrations, it 

can result in chronic effects.

carbonate – A sedimentary rock made mainly 

of calcium carbonate (CaCO3). Limestone and 

dolomite are common carbonate sedimentary 

rocks. (See dolomite and limestone.)

carcinogen – A substance or agent that produces 

or incites cancerous growth.

chronic – Lasting for a long period or marked 

by frequent recurrence.

Class I area – A specifically designated area 

where the degradation of air quality is 

stringently restricted (e.g., many national parks, 

wilderness areas). (See Prevention of 

Significant Deterioration.)

Class II area – Most of the country that is not 

designated as Class I is designated as Class II. 

Class II areas are generally cleaner than air 

quality standards require, and moderate 

increases in new pollution are allowed after a 

regulatory-mandated impacts review.

clay – The name for a family of finely 

crystalline sheet silicate minerals that commonly 

form as a product of rock weathering. Also, any 

soil particle smaller than or equal to about 

0.002 millimeters (0.00008 inches) in diameter.

Clean Air Act – An act mandating and 

providing for the enforcement of regulations to 

control air pollution from various sources.

Clean Air Act Amendments of 1990 –

Amendments expanding the U.S. Environmental 

Protection Agency’s enforcement powers and 

adding restrictions on air toxics, ozone-depleting 

chemicals, stationary and mobile emission 

sources, and emissions implicated in acid rain 

and global warming.

Code of Federal Regulations – A publication in 

codified form of all Federal regulations in force.

colluvium (colluvial) – A loose deposit of rock 

debris accumulated at the base of a cliff or slope.

conformity – As defined in the Clean Air Act, 

“the nation’s compliance with an 

implementation plan’s purpose of eliminating or 

reducing the severity and number of violations 

of the National Ambient Air Quality Standards 

and achieving expeditious attainment of such 

standards. Activities in conformity will not 

(1) cause or contribute to any new violation of 

any standard in any area, (2) increase the 

frequency or severity of any existing violation of 

any standard in any area, or (3) delay timely 

attainment of any standard or any required 

interim emission reduction or other milestones 

in any area.”

conglomerate – A sedimentary rock made of 

rounded rock fragments, such as pebbles, 

cobbles, and boulders, in a finer-grained matrix. 

To be classified as a conglomerate, some of the 

constituent pebbles must be at least about 

2 millimeters (one-thirteenth of 1 inch) across.
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6–4

criteria pollutant – An air pollutant that is 

regulated by National Ambient Air Quality 

Standards. The U.S. Environmental Protection 

Agency must describe the characteristics and 

potential health and welfare effects that form the 

basis for setting, or revising, the standard for 

each regulated pollutant. Criteria pollutants 

include sulfur dioxide, nitrogen dioxide, carbon 

monoxide, ozone, lead, and two size classes of 

particulate matter, less than 10 micrometers 

(0.0004 inches) in diameter, and less than 

2.5 micrometers (0.0001 inches) in diameter. 

New pollutants may be added to, or removed 

from, the list of criteria pollutants as more 

information becomes available. (See National 

Ambient Air Quality Standards.) Note: 

Sometimes pollutants regulated by state laws are 

also called criteria pollutants.

critical habitat – Habitat essential to the 

conservation of an endangered or threatened 

species that has been designated as critical by 

the U.S. Fish and Wildlife Service or the 

National Marine Fisheries Service following the 

procedures outlined in the Endangered Species 

Act and its implementing regulations 

(50 CFR 424). (See endangered species and 

threatened species.)

The lists of critical habitats can be found in 

Title 50 of the Code of Federal Regulations, 

Sections 17.95 (fish and wildlife) and 

17.96 (plants), and in Part 226 (marine species).

cultural resources – Archaeological sites, 

architectural features, historic resources,

traditional-use areas, and American Indian 

sacred sites.

cumulative impacts – Impacts on the 

environment that result when the incremental 

impact of a proposed action is added to the 

impacts from other past, present, and reasonably 

foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person 

undertakes the other actions. Cumulative 

impacts can result from individually minor but 

collectively significant actions taking place over 

a period of time.

day-night average sound level – The 24-hour, 

A-weighted equivalent sound level expressed in 

decibels. A 10-decibel penalty is added to sound 

levels between 10:00 P.M. and 7:00 A.M. to 

account for increased annoyance due to noise 

during night hours.

decibel – A unit for expressing the relative 

intensity of sounds on a logarithmic scale from 

zero for the average least perceptible sound to 

about 130 for the average level at which sound 

causes pain to humans. For traffic and industrial 

noise measurements, the A-weighted decibel, a 

frequency-weighted noise unit, is widely used. 

The A-weighted decibel scale corresponds 

approximately to the frequency response of the 

human ear and thus correlates well with 

loudness.

decibel, A-weighted – A unit of sound 

measurement that incorporates a metering 

characteristic and the “A” weighting specified 

by the American National Standards Institute in 

S1.4–1983 (R 2001) to account for the 

frequency response of the human ear.

decontamination – The removal of chemical 

contamination from facilities, equipment, or 

soils by washing, heating, chemical or 

electrochemical action, mechanical cleaning, or 

other techniques.

deposition – In geology, the laying down of 

potential rock-forming materials; sedimentation. 

In atmospheric transport, the settling out on 

ground and building surfaces of atmospheric 

aerosols and particles (“dry deposition”) or their 

removal from the air to the ground by 

precipitation (“wet deposition”).

dip – A measure of the angle between the flat 

horizon and the slope of a sedimentary layer, 

fault plane, metamorphic foliation, or other 

geologic structure.

discharge – In surface-water hydrology, the 

amount of water issuing from a spring or in a 

stream that passes a specific point in a given 

period of time. 
Glossary

6–5

dolomite – A mineral composed of calciummagnesium-carbonate (CaMg[CO3]2) that is the 

chief constituent of a sedimentary rock 

commonly called dolomite, as well as of some 

kinds of marble. It is thought to form by 

the alteration of limestone by seawater. 

(See carbonate.)

drainage basin – The land area drained by a 

particular stream.

drinking water standards – The level of 

constituents or characteristics in a drinking 

water supply specified in regulations under the 

Safe Drinking Water Act as the maximum 

permissible.

earthquake – A sudden ground motion or 

vibration of the Earth. It can be produced by a 

rapid release of stored-up energy along an active 

fault.

ecology – A branch of science dealing with the 

interrelationships of living organisms with one 

another and with their nonliving environment.

ecosystem – A community of organisms and 

their physical environment interacting as an 

ecological unit.

effluent – A waste stream flowing into the 

atmosphere, surface water, groundwater, or soil.

endangered species – Plants or animals that are

in danger of extinction through all or a 

significant portion of their ranges and that have 

been listed as endangered by the U.S. Fish and 

Wildlife Service or the National Marine 

Fisheries Service, following the procedures 

outlined in the Endangered Species Act and its 

implementing regulations (50 CFR 424). 

(See threatened species.) The lists of 

endangered species can be found in Title 50 of 

the Code of Federal Regulations, Sections 17.11 

(wildlife), 17.12 (plants), and 222.23(a) (marine 

organisms).

Endangered Species Act of 1973 – An act 

requiring Federal agencies, with the consultation 

and assistance of the Secretaries of the Interior 

and Commerce, to ensure that their actions will 

not likely jeopardize the continued existence of 

any endangered or threatened species or 

adversely affect the habitat of such species.

environmental assessment (EA) – A concise 

public document that a Federal agency prepares 

under the National Environmental Policy Act 

(NEPA) to provide sufficient evidence and 

analysis to determine whether a proposed 

agency action would require preparation of an 

environmental impact statement (EIS) or a 

Finding of No Significant Impact. A Federal 

agency may also prepare an EA to aid its 

compliance with NEPA when no EIS is 

necessary or to facilitate preparation of an EIS

when one is necessary. An EA must include 

brief discussions of the need for the proposal, 

alternatives, environmental impacts of the 

proposed action and alternatives, and a list of 

agencies and persons consulted. (See Finding of 

No Significant Impact, environmental impact 

statement, and National Environmental Policy 

Act.)

environmental impact statement – The 

detailed written statement that is required by 

Section 102(2)(C) of the National 

Environmental Policy Act (NEPA) for a 

proposed major Federal action significantly 

affecting the quality of the human environment. 

A U.S. Department of Energy (DOE) EIS is 

prepared in accordance with applicable 

requirements of the Council on Environmental 

Quality NEPA regulations in Title 40 of the 

Code of Federal Regulations (CFR), 

Parts 1500–1508, and DOE NEPA regulations in 

Title 10 of the CFR, Part 1021. The statement 

includes, among other information, discussions 

of the environmental impacts of the proposed 

action and all reasonable alternatives, adverse 

environmental effects that cannot be avoided 

should the proposal be implemented, the 

relationship between short-term uses of the 

human environment and enhancement of 

long-term productivity, and any irreversible and 

irretrievable commitments of resources.
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environmental justice – The fair treatment and 

meaningful involvement of all people regardless 

of race, color, national origin, or income with 

respect to the development, implementation, and 

enforcement of environmental laws, regulations, 

and policies. Fair treatment means that no 

group of people, including racial, ethnic, or 

socioeconomic groups, should bear a 

disproportionate share of the negative 

environmental consequences resulting from 

industrial, municipal, or commercial operations 

or the execution of Federal, state, local, or tribal 

programs and policies. Executive Order 12898 

directs Federal agencies to make achieving 

environmental justice part of their missions by 

identifying and addressing disproportionately 

high and adverse effects of agency programs, 

policies, and activities on minority and lowincome populations. (See minority population 

and low-income population.)

erosion – Removal of material by water, wind, 

or ice.

Exclusive Use Area – A 112-hectare (277-acre) 

area surrounded by a barbed-wire fence that is 

restricted for the exclusive use of the 

U.S. Department of Energy and its contractors 

and subcontractors in support of Waste Isolation 

Pilot Plant activities. The area is marked with 

“no trespassing” signs and is patrolled by WIPP

security personnel.

exposure – The condition of being subject to the 

effects of, or acquiring a dose of, a potential 

stressor such as a hazardous chemical agent; 

also, the process by which an organism acquires 

a dose of a chemical such as mercury. Exposure 

can be quantified as the amount of the agent 

available at various boundaries of the organism 

(e.g., skin, lungs, gut) and available for 

absorption.

exposure limit – The level of exposure to a 

hazardous chemical (set by law or a standard) at 

which or below which adverse human health 

effects are not expected to occur. (See reference 

concentration and reference dose.)

exposure pathway – The course a chemical or 

physical agent takes from the source to the 

exposed organism. An exposure pathway 

describes a mechanism by which chemicals or 

physical agents at or originating from a release 

site reach an individual or population. Each 

exposure pathway includes a source or release 

from a source, an exposure route, and an 

exposure point. If the exposure point differs 

from the source, the transport/exposure medium 

such as air or water is also included. 

(See exposure.)

fault – A fracture or a zone of fractures within a 

rock formation along which vertical, horizontal, 

or transverse slippage has occurred. A normal 

fault occurs when the hanging wall has been 

depressed in relation to the footwall. A reverse 

fault occurs when the hanging wall has been 

raised in relation to the footwall. 

Finding of No Significant Impact – A public 

document issued by a Federal agency briefly 

presenting the reasons why an action for which 

the agency has prepared an environmental 

assessment has no potential to have a significant 

effect on the human environment and, thus, will 

not require preparation of an environmental 

impact statement. (See environmental 

assessment and environmental impact 

statement.)

flask – A container used to store mercury. 

Mercury storage flasks, typically made of 

0.5-centimeter-thick (0.2-inch-thick) low-carbon 

steel, can hold 34.6 kilograms (76 pounds) of 

mercury and are sealed with a threaded plug. A 

typical mercury storage flask is similar in size 

and dimensions to a 3-liter soda bottle.

floodplain – The lowlands and relatively flat 

areas adjoining inland and coastal waters and the 

flood-prone areas of offshore islands. 

Floodplains include, at a minimum, that area 

with at least a 1.0 percent chance of being 

inundated by a flood in any given year.

The base floodplain is defined as the area that

has a 1.0 percent or greater chance of being 

flooded in any given year. Such a flood is 

known as a 100-year flood.

The critical action floodplain is defined as the 

area that has at least a 0.2 percent chance of 

being flooded in any given year. Such a flood is 

known as a 500-year flood.
Glossary

6–7

The probable maximum flood is the hypothetical 

flood considered to be the most severe 

reasonably possible flood, based on the 

comprehensive hydrometeorological application 

of maximum precipitation and other 

hydrological factors favorable for maximum 

flood runoff (e.g., sequential storms and 

snowmelts). It is usually several times larger 

than the maximum recorded flood.

formation – In geology, the primary unit of 

formal stratigraphic mapping or description. 

Most formations possess certain distinctive 

features.

fracture – Any break in rock along which no 

significant movement has occurred.

geology – The science that deals with the Earth: 

the materials, processes, environments, and 

history of the planet, including rocks and their 

formation and structure.

global climate change – Changes in the Earth’s 

surface temperature thought to be caused by the 

greenhouse effect and responsible for changes in 

global climate patterns. The greenhouse effect 

is the trapping and buildup of heat in the 

atmosphere (troposphere) near the Earth’s 

surface. Some of the heat flowing back toward 

space from the Earth’s surface is absorbed by 

water vapor, carbon dioxide, ozone, and several 

other gases in the atmosphere and then 

reradiated back toward the Earth’s surface.

greater-than-Class C (GTCC) low-level

radioactive waste (LLW) – LLW generated by 

the commercial sector that exceeds U.S. Nuclear 

Regulatory Commission (NRC) concentration 

limits for Class C LLW, as specified in 

“Licensing Requirements for Land Disposal of 

Radioactive Waste” (Title 10 of the Code of 

Federal Regulations, Part 61).

In addition to the GTCC LLW generated as a 

result of NRC-licensed or agreement-statelicensed activities, the U.S. Department of 

Energy (DOE) generates waste containing 

concentrations of radionuclides that are similar 

to GTCC LLW. This waste is referred to as 

“DOE GTCC-like waste.”

groundwater – Water below the ground surface 

in a zone of saturation. It usually occurs in 

aquifers that may supply wells and springs, as 

well as baseflow, to major streams and rivers.

Hazard Index – (ecological definition) The sum 

of the individual Hazard Quotients of 

constituents within a class that exert effects with 

the same toxicological mechanism or endpoint 

and are additive in effect.

Hazard Index – (human health definition) A 

summation of the Hazard Quotients for all

chemicals now being used at a site, as well as 

those proposed to be added, to yield the 

cumulative levels for the site. A Hazard Index 

value of 1.0 or less means that no adverse 

human health effects (noncancer) are expected 

to occur. (See Hazard Quotient.)

Hazard Quotient – The value used as an 

assessment of non-cancer-associated toxic 

effects of chemicals, e.g., kidney or liver 

dysfunction. It is a ratio of the estimated 

exposure to that level of exposure at which it is 

expected that adverse health effects would begin 

to be produced. It is independent of a cancer 

risk, which is calculated for only those 

chemicals identified as carcinogens.

hazardous air pollutants – Air pollutants not 

covered by National Ambient Air Quality 

Standards but which may present a threat of 

adverse human health or environmental effects. 

Those specifically listed in Title 40 of the Code 

of Federal Regulations, Section 61.01, are 

asbestos, benzene, beryllium, coke oven 

emissions, inorganic arsenic, mercury, 

radionuclides, and vinyl chloride. More broadly, 

hazardous air pollutants are any of the 

188 pollutants to be regulated or reviewed under 

Section 112(b) of the Clean Air Act. Very 

generally, hazardous air pollutants are any air 

pollutants that may realistically be expected to 

pose a threat to human health or welfare.

hazardous chemical – Under Title 29 of the 

Code of Federal Regulations, Part 1910, 

Subpart Z, hazardous chemicals are defined as 

“any chemical that is a physical hazard or a 

health hazard.” Physical hazards include 

combustible liquids, compressed gases, 

explosives, flammables, organic peroxides, 
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oxidizers, pyrophorics, and reactives. A health 

hazard is any chemical for which there is good 

evidence that acute or chronic health effects 

occur in exposed employees. Hazardous 

chemicals include carcinogens, toxic or highly 

toxic agents, reproductive toxins, irritants, 

corrosives, sensitizers, hepatotoxins, 

nephrotoxins, agents that act on the 

hematopoietic system, and agents that damage 

the lungs, skin, eyes, or mucous membranes.

hazardous material – A material, including a 

hazardous substance as defined by Title 49 of 

the Code of Federal Regulations, Section 171.8, 

that poses a risk to health, safety, and property 

when transported or handled.

hazardous waste – A category of waste 

regulated under the Resource Conservation and 

Recovery Act (RCRA). To be considered 

hazardous, a waste must be a solid waste under 

RCRA and must exhibit at least one of four 

characteristics described in Title 40 of the Code 

of Federal Regulations, Sections 261.20 through 

261.24 (i.e., ignitability, corrosivity, reactivity, 

or toxicity) or be specifically listed by the 

U.S. Environmental Protection Agency in 

Sections 261.31 through 261.33.

historic resources – Archaeological sites, 

architectural structures, and objects dating from 

1492 or later, after the arrival of the first 

Europeans to the Americas.

infrastructure – The basic facilities, services, 

and utilities needed for the functioning of an 

industrial facility. Transportation and electrical 

systems are part of the infrastructure.

interbedded – Occurring between beds (layers) 

or lying in a bed parallel to other beds of a 

different material.

interim status – Period during which treatment, 

storage, and disposal facilities subject to the 

Resource Conservation and Recovery Act are 

temporarily allowed to operate while awaiting 

the issuance or denial of a permanent permit.

labor force – All persons of a defined 

geographic area classified as employed or 

unemployed.

land use – A characterization of land surface in 

terms of its potential utility for various activities.

land withdrawal boundary (LWB) – A

4,146-hectare (10,240-acre) area that delineates 

the perimeter of the Waste Isolation Pilot Plant 

site.

limestone – A sedimentary rock composed 

mostly of the mineral calcite, CaCO3. (See 

carbonate.)

loam – Soil material that is composed of 7 to 

27 percent clay particles, 28 to 50 percent silt 

particles, and less than 52 percent sand particles.

local magnitude – See magnitude.

low-income individuals/persons – Individuals 

whose income is less than the poverty threshold 

defined in the U.S. Bureau of the Census’ 

Current Population Reports, Series P-60 on 

Income and Poverty.

low-income population – Low-income 

populations, defined in terms of U.S. Census 

Bureau annual statistical poverty levels (Current 

Population Reports, Series P-60 on Income and 

Poverty), may consist of groups or individuals 

who live in geographic proximity to one another 

or who are geographically dispersed or transient 

(such as migrant workers or American Indians), 

where either type of group experiences common 

conditions of environmental exposure or effect. 

(See environmental justice and minority 

population.)

magnitude – A number that reflects the relative 

strength or size of an earthquake. Magnitude is 

based on the logarithmic measurement of the 

maximum motion recorded by a seismograph. 

An increase of one unit of magnitude (for 

example, from 4.6 to 5.6) represents a 10-fold 

increase in wave amplitude on a seismograph 

recording or approximately a 30-fold increase in 

the energy released. Several scales have been 

defined, but the most commonly used are 

(1) local magnitude (ML), commonly referred to 

as “Richter magnitude,” (2) surface-wave 

magnitude (Ms), and (3) body-wave magnitude 

(Mb). Each is valid for a particular type of 

seismic signal varying by such factors as 

frequency and distance. These magnitude scales 
Glossary

6–9

will yield approximately the same value for any 

given earthquake within each scale’s respective 

range of validity. A fourth scale (moment 

magnitude [Mw]) is the latest to be applied that 

better estimates the size of very large 

earthquakes that the other scales underestimate 

by varying degrees.

megawatt – A unit of power equal to 

1 million watts. Megawatt-thermal is commonly 

used to define heat produced, while megawattelectric defines electricity produced.

mercury (elemental) – Elemental mercury is a 

dense, naturally occurring, silver-colored 

metallic element that is liquid at room 

temperature. Sometimes called “quicksilver,” 

liquid mercury has been used extensively in 

manufacturing processes because it conducts 

electricity, reacts to temperature changes, and 

alloys with many other metals.

mercury (primary) – Unused, ‘virgin’ mercury 

that has been produced as the main product of 

mining activities.

mercury (secondary) – Mercury recycled from 

the dismantling of used products or equipment.

meteorology – The science dealing with the 

atmosphere and its phenomena, especially as 

relating to weather.

migration – The natural movement of a material 

through the air, soil, or groundwater; also, 

seasonal movement of animals from one area to 

another.

minority individuals – Individuals who identify 

themselves as a member of the following 

population groups: American Indian or Alaska 

Native; Asian; black or African American; 

Hispanic or Latino; Native Hawaiian or other 

Pacific Islander; or multiracial minority (two or 

more races, at least one of which is a minority 

race under Council on Environmental Quality 

guidelines). This definition is similar to that 

given in the Council on Environmental Quality’s 

environmental justice guidance; however, it has 

been modified to reflect revisions to the 

Standards for the Classification of Federal Data 

on Race and Ethnicity (62 FR 58782 through 

58790), which is published by the Office of 

Management and Budget.

minority population – Minority populations 

exist where either: (a) the minority population of 

the affected area exceeds 50 percent or (b) the 

minority population percentage of the affected 

area is meaningfully greater than in the general 

population or other appropriate unit of 

geographic analysis (such as a governing body’s 

jurisdiction, a neighborhood, census tract, or 

other similar unit). Minority populations include 

either a single minority group or the total of all 

minority persons in the affected area. They may 

consist of groups of individuals living in 

geographic proximity to one another or a 

geographically dispersed/transient set of 

individuals (such as migrant workers or 

American Indians), where either type of group 

experiences common conditions of 

environmental exposure or effect. 

(See environmental justice and low-income 

population.)

mitigation – Actions taken to lessen the impacts 

of a proposed action, including (1) avoiding an 

impact altogether by not taking a certain action 

or parts of an action; (2) minimizing impacts by 

limiting the degree or magnitude of an action 

and its implementation; (3) rectifying an impact 

by repairing, rehabilitating, or restoring the 

affected environment; (4) reducing or 

eliminating the impact over time by preservation 

and maintenance operations during the life of an 

action; or (5) compensating for an impact by 

replacing or providing substitute resources or 

environments.

Modified Mercalli Intensity – A level on the 

modified Mercalli scale. A measure of the 

perceived intensity of earthquake ground 

shaking with 12 divisions, from I (not felt by 

people) to XII (damage nearly total). It is a 

unitless expression of observed effects.

mudstone – A detrital sedimentary rock 

composed of clay-sized particles.
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National Ambient Air Quality Standards –

Standards defining the highest allowable levels 

of certain pollutants in the ambient air (i.e., the 

outdoor air to which the public has access). 

Because the U.S. Environmental Protection 

Agency must establish the criteria for setting 

these standards, the regulated pollutants are 

called criteria pollutants. Criteria pollutants 

include sulfur dioxide, nitrogen dioxide, carbon 

monoxide, ozone, lead, and two size classes of 

particulate matter, less than 10 micrometers 

(0.0004 inches) in diameter, and less than 

2.5 micrometers (0.0001 inches) in diameter. 

Primary standards are established to protect 

public health; secondary standards are 

established to protect public welfare 

(e.g., visibility, crops, animals, buildings). 

(See criteria pollutant.)

National Emission Standards for Hazardous 

Air Pollutants (NESHAPs) – Emission 

standards set by the U.S. Environmental 

Protection Agency for air pollutants that are not 

covered by the National Ambient Air Quality 

Standards and may, at sufficiently high levels, 

cause increased fatalities, irreversible health 

effects, or incapacitating illness. These 

standards are given in Title 40 of the Code 

of Federal Regulations, Parts 61 and 63. 

NESHAPs are given for many specific 

categories of sources (e.g., equipment leaks, 

industrial process cooling towers, drycleaning, 

facilities, petroleum refineries).

National Environmental Policy Act of 1969

(NEPA) – NEPA is the basic national charter for 

protection of the environment. It establishes 

policy, sets goals (in Section 101), and provides 

means (in Section 102) for carrying out the 

policy. Section 102(2) contains action-forcing 

provisions to ensure that Federal agencies follow 

the letter and spirit of the Act. For major 

Federal actions significantly affecting the quality 

of the human environment, Section 102(2)(C) of 

NEPA requires Federal agencies to prepare a 

detailed statement that includes the 

environmental impacts of the proposed action 

and other specified information.

National Pollutant Discharge Elimination 

System (NPDES) – A provision of the Clean 

Water Act that prohibits discharge of pollutants 

into waters of the United States unless a special 

permit is issued by the U.S. Environmental 

Protection Agency, a state, or, where delegated, 

a tribal government on an American Indian 

reservation. The NPDES permit lists either 

permissible discharges, the level of cleanup 

technology required for wastewater, or both.

National Register of Historic Places

(NRHP) – The official list of the Nation’s 

cultural resources that are worthy of 

preservation. The National Park Service 

maintains the list under direction of the 

Secretary of the Interior. Buildings, structures, 

objects, sites, and districts are included in the 

NRHP for their importance in American history, 

architecture, archaeology, culture, or 

engineering. Properties included in the NRHP 

range from large-scale, monumentally 

proportioned buildings to smaller-scale, 

regionally distinctive buildings. The listed 

properties are not just of nationwide importance; 

most are significant primarily at the state or 

local level. Procedures for listing properties in 

the NRHP are found in Title 36 of the Code of 

Federal Regulations, Part 60.

natural phenomena hazard – A category of 

events (e.g., earthquake, wind, flood, and 

lightning) that must be considered in the 

U.S. Department of Energy (DOE) facility 

design, construction, and operations, as specified 

in DOE Order 420.1B.

nitrogen oxides – The oxides of nitrogen, 

primarily nitrogen oxide and nitrogen dioxide, 

produced in the combustion of fossil fuels. 

Nitrogen dioxide emissions constitute an air 

pollution problem, as they contribute to acid 

deposition and the formation of atmospheric 

ozone.

noise – Undesirable sound that interferes or 

interacts negatively with the human or natural 

environment. Noise may disrupt normal 

activities (e.g., hearing, sleep), damage hearing, 

or diminish the quality of the environment.
Glossary

6–11

nonattainment area – An area that the 

U.S. Environmental Protection Agency has 

designated as not meeting (i.e., not being in 

attainment of) one or more of the National 

Ambient Air Quality Standards for sulfur 

dioxide, nitrogen dioxide, carbon monoxide, 

ozone, lead, and particulate matter. An area may 

be in attainment for some pollutants, but not for 

others.

Off-Limits Area – A 588-hectare (1,454-acre) 

area at the Waste Isolation Pilot Plant site where 

unauthorized entry and introduction of weapons 

and/or dangerous materials are prohibited. 

Prohibition signs are posted at consistent 

intervals along its perimeter. Unless they pose a 

threat to security, safety, or the environmental 

quality of the WIPP site, grazing and public 

thoroughfares can occur in this area. This area 

is patrolled by WIPP security personnel to 

prevent unauthorized activities or use.

ozone – The triatomic form of oxygen; in the 

stratosphere, ozone protects the Earth from the 

sun’s ultraviolet rays, but in lower levels of the 

atmosphere, ozone is considered an air pollutant.

pallet – A small platform on which material is 

stored. Pallets are often constructed of wood 

and serve to lift the material off the ground to 

keep it dry. Pallets also enable the material to be 

easily lifted with a forklift.

particulate matter (PM) – Any finely divided 

solid or liquid material, other than uncombined 

(i.e., pure) water. A subscript denotes the upper 

limit of the diameter of particles included. Thus, 

PM10 includes only those particles equal to or 

less than 10 micrometers (0.0004 inches) in 

diameter; PM2.5 includes only those particles 

equal to or less than 2.5 micrometers 

(0.0001 inches) in diameter. Total suspended 

particulates were first used as the indicator of 

particulate concentrations.

peak ground acceleration – A measure of the 

maximum horizontal acceleration (as a 

percentage of the acceleration due to Earth’s 

gravity) experienced by a particle on the surface 

of the Earth during the course of earthquake 

motion.

percent g – In measuring earthquake ground 

motion, the acceleration (the rate of change in 

velocity) experienced relative to that due to 

Earth’s gravity (i.e., 9.8 meters per square 

second).

perched aquifer/groundwater – A body of 

groundwater of small lateral dimensions 

separated from an underlying body of 

groundwater by an unsaturated zone.

permeability – The ability of a rock, soil, or 

other material to allow water to flow through its 

interconnected spaces.

persistence – The resistance to degradation as 

measured by the period of time required for 

complete decomposition of a material.

pH – A numeric value that indicates the relative 

acidity or alkalinity of a substance on a scale 

of 0 to 14, with the neutral point at 7.0. Acid 

solutions have pH values lower than 7.0, and 

basic (alkaline) solutions have values higher 

than 7.0.

plume – The elongated pattern of contaminated 

air or water originating at a point source such as 

a smokestack or hazardous waste disposal site.

PM2.5 and PM10 – See particulate matter.

potable water – Water that is fit to drink.

potash – Potassium compounds or 

potassium-containing materials, especially 

those with potassium in a water soluble form. 

Commonly mined or manufactured as 

potassium-bearing salts and primarily used as a 

fertilizer.

prehistoric – Predating written history; in North 

America, also predating contact with Europeans.

Prevention of Significant Deterioration –

Regulations required by the 1977 Clean Air Act 

amendments to limit increases in criteria air 

pollutant concentrations above baseline in areas 

that already meet the National Ambient Air 

Quality Standards. Cumulative increases in 

pollutant levels after specified baseline dates 

must not exceed specified maximum allowable 

amounts. These allowable increases, also 

known as increments, are especially stringent in 
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areas designated as Class I areas (e.g., national 

parks, wilderness areas) where the preservation 

of clean air is particularly important. All areas 

not designated as Class I are currently 

designated as Class II. Maximum increments in 

pollutant levels are also given in Title 40 of the 

Code of Federal Regulations, Section 51.166,

for Class III areas, if any such areas should be so 

designated by the U.S. Environmental Protection 

Agency. Class III increments are less stringent 

than those for Class I or Class II areas. 

(See National Ambient Air Quality Standards.)

Property Protection Area – A 14-hectare 

(35-acre) interior core of the Waste Isolation 

Pilot Plant site that is surrounded by a chain-link 

fence and is under 24-hour security.

Protective Action Criteria (PACs) – These are 

protective criteria introduced by the U.S. 

Department of Energy for use in the planning of 

emergency response to accidental releases of 

chemicals. There are three levels, PAC-1, 

PAC-2, and PAC-3. These are equal to the 

1-hour Acute Exposure Guideline Levels

(AEGL-1, -2, and -3, respectively), if available; 

otherwise, they are equal to the Emergency 

Response Planning Guidelines (ERPG-1, -2, 

and -3, respectively). If neither AEGLs nor 

ERPGs are available, PACs are equal to 

Temporary Emergency Exposure Limits 

(TEEL-1, -2, and -3, respectively).

Quaternary – The second geologic period of 

the Cenozoic Era, dating from about 1.6 million 

years ago to the present. It contains two epochs: 

the Pleistocene and the Holocene. It is 

characterized by the first appearance of human 

beings on Earth.

Record of Decision – A document providing a 

concise public record of an agency’s decision on 

a proposed action for which an environmental 

impact statement was prepared. Prepared in 

accordance with Title 40 of the Code of Federal 

Regulations, Section 1505.2, the Record of 

Decision identifies the alternatives considered in 

reaching the decision, the environmentally 

preferable alternative, factors balanced by the 

agency in making the decision, whether all 

practicable means to avoid or minimize 

environmental harm have been adopted, and if 

not, why they were not.

reference concentration – The chronic

exposure concentration for a given hazardous 

chemical at which or below which adverse 

human noncancer health effects are not expected 

to occur. (See exposure limit and reference 

dose.)

reference dose – The chronic exposure dose for 

a given hazardous chemical at which or below 

which adverse human noncancer health effects

are not expected to occur. (See exposure limit

and reference concentration.)

reflasking – The transfer of mercury from 

aging, damaged, or leaking 34.6-kilogram 

(76-pound) flasks to new 34.6-kilogram 

(76-pound) steel flasks.

region of influence – A site-specific geographic 

area. The regions of influence for different 

resources can vary widely in extent. For 

example, the region of influence for ecological 

resources would generally be confined to the site 

and nearby adjacent areas, whereas the 

socioeconomic region of influence would 

include the cities and counties surrounding each 

site that could be affected by the proposed 

action.

Resource Conservation and Recovery Act 

(RCRA), as amended – This law gives the 

U.S. Environmental Protection Agency the 

authority to control hazardous waste from 

“cradle to grave” (i.e., from the point of 

generation to the point of ultimate disposal), 

including its minimization, generation, 

transportation, treatment, storage, and disposal. 

RCRA also sets forth a framework for 

management of nonhazardous solid waste. 

(See hazardous waste.) 

Richter magnitude – See magnitude.

rift – A valley caused by extension of the 

Earth’s crust. Its floor forms as a portion of the 

crust moves downward along normal faults.

risk – The probability of a detrimental effect 

from exposure to a hazard. Risk is often 

expressed quantitatively as the probability of an 

adverse event occurring multiplied by the 

consequence of that event (i.e., the product 
Glossary

6–13

of these two factors). However, separate 

presentation of probability and consequence is 

often more informative.

risk assessment (chemical) – The qualitative 

and quantitative evaluation performed to define 

the risk posed to human health and/or the 

environment by the presence or potential 

presence and/or use of specific chemical 

materials.

runoff – The portion of rainfall, melted snow, or 

irrigation water that flows across the ground and 

which may eventually enter surface waters. 

sand – Loose grains of rock or mineral sediment 

formed by weathering that range in size from 

0.0625 to 2.0 millimeters (0.0025 to 0.08 inches)

in diameter and often consist of quartz particles.

sandstone – A sedimentary rock composed 

mostly of sand-size particles cemented usually 

by calcite, silica, or iron oxide.

sanitary waste (wastewater) – Wastes 

generated by normal housekeeping activities, 

liquid or solid (includes sludge), that are not 

hazardous or radioactive.

scoping – An early and open process for 

determining the scope of issues to be addressed 

in an environmental impact statement and for 

identifying the significant issues related to a 

proposed action.

sedimentary rock – Rock formed from the 

accumulation of sediment, which may consist of 

fragments and mineral grains of varying sizes 

from pre-existing rocks, remains or products of 

animals and plants, products of chemical action, 

or mixtures of these. Sedimentary rocks often 

have distinctive layering or bedding.

seismic – Pertaining to any earth vibration, 

especially that of an earthquake.

seismicity – The frequency and distribution of 

earthquakes.

sewage – The total nonhazardous organic waste 

and wastewater generated by an industrial 

establishment or a community.

sewer – A pipe or conduit (sewer) intended to 

carry wastewater or waterborne wastes from 

homes, businesses, and industries to a treatment 

facility.

shale – Sedimentary rock derived from mud,

commonly finely laminated (bedded). Particles 

in shale are commonly clay minerals mixed with 

tiny grains of quartz eroded from pre-existing 

rocks. “Shaley” means like a shale or having 

some shale component, as in shaley sandstone.

silt – Loose particles of rock or mineral 

sediment that range in size from about 0.002 to 

0.0625 millimeters (0.00008 to 0.0025 inches) in 

diameter. Silt is finer than sand, but coarser than 

clay.

siltstone – A fine-grained sedimentary rock 

composed mostly of silt-sized grains.

socioeconomics – Demographic and economic 

characteristics of a defined geographic area.

soils – All unconsolidated materials above 

bedrock. Natural earthy materials on the Earth’s 

surface, in places modified or even made by 

human activity, containing living matter, and 

supporting or capable of supporting plants.

sole-source aquifer – A designation granted by 

the U.S. Environmental Protection Agency 

when groundwater from a specific aquifer 

supplies at least 50 percent of the drinking water 

for the area overlying the aquifer. Sole-source 

aquifers have no alternative source or 

combination of sources that could physically, 

legally, and economically supply all those who 

obtain their drinking water from the aquifer.

solid waste – In general, solid wastes are 

non-liquid, non-soluble discarded materials 

ranging from municipal garbage to industrial 

wastes that contain complex and sometimes 

hazardous substances. Solid wastes include 

sewage sludge, agricultural refuse, demolition 

wastes, and mining residues.

For purposes of regulation under the Resource 

Conservation and Recovery Act, solid waste is 

any garbage; refuse; sludge from a waste 

treatment plant, water supply treatment plant, or 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

6–14

air pollution control facility; and other discarded 

material. Solid waste includes solid, liquid, 

semisolid, or contained gaseous material 

resulting from industrial, commercial, mining, 

and agricultural operations and from community 

activities. A more-detailed regulatory definition 

of solid waste can be found in Title 40 of the 

Code of Federal Regulations, Section 261.2.

(See hazardous waste and Resource 

Conservation and Recovery Act.)

spill prevention, control, and 

countermeasures plan – A plan prepared by a 

facility to minimize the likelihood of a spill and 

to expedite control and cleanup activities should 

a spill occur.

stabilize – To convert a compound, mixture, or 

solution to a nonreactive form.

State Historic Preservation Officer – The state 

officer charged with the identification and 

protection of prehistoric and historic resources 

in accordance with the National Historic 

Preservation Act.

stormwater – Stormwater runoff, snowmelt 

runoff, and surface runoff and drainage.

subsistence consumption of fish and wildlife –

Dependence by a minority population, lowincome population, American Indian tribe, or 

subgroup of such populations on indigenous 

fish, vegetation, and/or wildlife as the principal 

portion of their diet.

sulfur oxides – Common air pollutants, 

primarily sulfur dioxide, a heavy, pungent, 

colorless gas (formed in the combustion of fossil 

fuels, considered a major air pollutant), and 

sulfur trioxide. Sulfur dioxide is involved in the 

formation of acid rain. It can also irritate the 

upper respiratory tract and cause lung damage.

surface water – All bodies of water on the 

surface of the Earth and open to the atmosphere, 

such as rivers, lakes, reservoirs, ponds, seas, and 

estuaries.

tectonic – Of or relating to motion in the Earth’s 

crust and occurring on geologic faults.

Temporary Emergency Exposure Limits 

(TEELs) – Values developed by the 

U.S. Department of Energy (DOE) for use in 

DOE facility hazard analyses and emergency 

planning and response for chemicals lacking 

Acute Exposure Guideline Levels or Emergency 

Response Planning Guidelines. TEEL values 

are applied to the peak 15-minute time-weighted 

average concentration at the point of interest and 

are defined for varying degrees of severity of 

toxic effects, as follows:

TEEL-1: The maximum concentration in air 

below which it is believed nearly all 

individuals could be exposed without 

experiencing other than mild transient 

adverse health effects or perceiving a clearly 

defined objectionable odor. 

TEEL-2: The maximum concentration in air 

below which it is believed nearly all 

individuals could be exposed without 

experiencing or developing irreversible or 

other serious health effects or symptoms that 

could impair their abilities to take protective 

action.

TEEL-3: The maximum concentration in air 

below which it is believed nearly all 

individuals could be exposed without 

experiencing or developing life-threatening 

health effects.

threatened species – Any plants or animals that 

are likely to become endangered species within 

the foreseeable future throughout all or a 

significant portion of their ranges and that have 

been listed as threatened by the U.S. Fish and 

Wildlife Service or the National Marine 

Fisheries Service, following the procedures set 

out in the Endangered Species Act and its 

implementing regulations (50 CFR 424). 

(See endangered species.) The lists of threatened 

species can be found in Title 50 of the Code of 

Federal Regulations, Sections 17.11 (wildlife), 

17.12 (plants), and 227.4 (marine organisms). 

Note: Some states also list species as threatened. 

Thus, in certain cases a state definition would 

also be appropriate.
Glossary

6–15

threshold limit values – The recommended 

highest concentrations of contaminants to which 

workers may be exposed according to the 

American Conference of Governmental 

Industrial Hygienists.

toxic – Poisonous (to living organisms); capable 

of producing disease or otherwise harmful to 

human health when taken into the body. 

Mercury is toxic.

Toxic Substances Control Act (TSCA) – This 

law requires that the health and environmental 

effects of all new chemicals be reviewed by the 

U.S. Environmental Protection Agency before 

they are manufactured for commercial purposes. 

This act also imposes strict limitations on the 

use and disposal of polychlorinated biphenyls, 

chlorofluorocarbons, asbestos, dioxins, certain 

metal-working fluids, and hexavalent chromium. 

In addition, the provisions of the Mercury 

Export Ban Act relating to the prohibition on 

sale, distribution, or transfer of elemental 

mercury by Federal agencies, and to the 

prohibition on the export of elemental mercury, 

amended Sections 6 and 12, respectively, of 

TSCA.

toxicity reference value – An exposure level 

from a valid scientific study that represents a 

threshold for some level of ecological effect.

traditional cultural property – A property or 

place that is eligible for inclusion in the National 

Register of Historic Places because of its 

association with cultural practices and beliefs 

that are (1) rooted in the history of a community 

and (2) important to maintaining the continuity 

of that community’s traditional beliefs and 

practices.

transuranic (TRU) waste – Radioactive waste 

containing more than 100 nanocuries 

(3,700 becquerels) of alpha-emitting TRU 

isotopes per gram of waste, with half-lives 

greater than 20 years, except for: (1) high-level 

radioactive waste; (2) waste that the Secretary of 

Energy has determined, with the concurrence of 

the Administrator of the U.S. Environmental 

Protection Agency, does not need the degree of 

isolation required by Title 40 of the Code of 

Federal Regulations (CFR), Part 191, disposal 

regulations; or (3) waste that the U.S. Nuclear 

Regulatory Commission has approved for 

disposal on a case-by-case basis in accordance 

with 10 CFR Part 61.

treatment – Under the Resource Conservation 

and Recovery Act, any method, technique, or 

process designed to change the physical, 

chemical, or biological character or composition 

of any hazardous waste.

unemployment rate – The number of 

unemployed persons as a percentage of the labor

force.

viewshed – The extent of the area that may be 

viewed from a particular location. Viewsheds 

are generally bounded by topographic features 

such as hills or mountains.

visual resource management – A process 

devised by the U.S. Bureau of Land 

Management to assess the aesthetic quality of a 

landscape, and, consistent with the results of that 

analysis, to so design proposed activities as to 

minimize their visual impact on the landscape. 

The process consists of a rating of visual quality 

followed by a measurement of the degree of 

contrast between proposed development 

activities and the existing landscape. Four 

classifications are employed to describe different

degrees of modification to landscape elements: 

Class I, areas where the natural landscape is 

preserved, including national wilderness areas 

and the wild sections of national wild and scenic 

rivers; Class II, areas with very limited land 

development activity, resulting in visual 

contrasts that are seen but do not attract 

attention; Class III, areas in which development 

may attract attention, but the natural landscape 

still dominates; and Class IV, areas in which 

development activities may dominate the view 

and may be the major focus in the landscape.

volatile organic compound – Any of a broad 

range of organic compounds, often halogenated, 

that vaporize at ambient or relatively low 

temperatures, such as benzene, chloroform, and 

methyl alcohol. In regard to air pollution, any 

organic compound that participates in 

atmospheric photochemical reaction, except for 

those determined by the U.S. Environmental 

Protection Agency Administrator to have 

negligible photochemical reactivity.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

6–16

Waste Isolation Pilot Plant (WIPP) – WIPP is 

the Nation’s only underground repository for the 

permanent disposal of defense-generated 

transuranic waste. The WIPP site is located in 

Eddy County in the Chihuahuan Desert of 

southeastern New Mexico. The site is about 

42 kilometers (26 miles) east of Carlsbad in a 

region known as Los Medaños, a relatively 

flat, sparsely inhabited plateau with little 

surface water. The WIPP site encompasses 

approximately 41 square kilometers (16 square 

miles) under the jurisdiction of the 

U.S. Department of Energy pursuant to the 

Waste Isolation Pilot Plant Land 

Withdrawal Act (P.L. 102-579). (See Waste 

Isolation Pilot Plant Land Withdrawal Act 

[WIPP LWA].)

Waste Isolation Pilot Plant Land Withdrawal 

Act (WIPP LWA) – An act that transferred 

responsibility of the Waste Isolation Pilot 

Plant withdrawal area from the Secretary of 

the Interior to the Secretary of Energy 

(P.L. 102-579).

wastewater – Water originating from human 

sanitary water use (domestic wastewater) and 

from a variety of industrial processes (industrial 

wastewater).

water quality standards and criteria – Limits 

on the concentrations of specific constituents or 

on the characteristics of water, often based on 

water use classifications (for example, drinking 

water, recreation, propagation of fish and 

aquatic life, agricultural and industrial use). 

Water quality standards are legally enforceable, 

whereas water quality criteria are 

nonenforceable recommendations based on 

biotic impacts.

water table – The boundary between the 

unsaturated zone and the deeper, saturated zone. 

The upper surface of an unconfined aquifer.

wetlands – Areas that are inundated or saturated 

by surface water or groundwater and that 

typically support vegetation adapted for life in 

saturated soils. Wetlands generally include 

swamps, marshes, bogs, and similar areas 

(e.g., sloughs, potholes, wet meadows, river 

overflow areas, mudflats, natural ponds).

WIPP Vicinity Section 10 – Section 10, 

Township 22 South, Range 31 East, 

approximately 5.6 kilometers (3.5 miles) north 

of the Waste Isolation Pilot Plant facility.

WIPP Vicinity Section 20 – Section 20, 

Township 22 South, Range 31 East, across the 

Waste Isolation Pilot Plant access road to the 

west of the Waste Isolation Pilot Plant facility.

WIPP Vicinity Section 35 – Section 35, 

Township 22 South, Range 31 East, 

approximately 5.6 kilometers (3.5 miles) 

southeast of the Waste Isolation Pilot Plant 

facility.
CHAPTER 7

LIST OF PREPARERS

7–1

CHAPTER 7

LIST OF PREPARERS

U.S. DEPARTMENT OF ENERGY

Levenstein, David

EIS Responsibilities: Document Manager

Education: B.S., Entomology, University of Georgia

A.A.S., Biotechnology, Farmingdale State College

Experience: 27 years

Loving, Jeannie

EIS Responsibilities: Chapter 1, “Introduction and Purpose and Need for Agency Action”

Education: B.S., Biology, George Washington University

Experience: 40 years

Edelman, Arnie

EIS Responsibilities: Chapter 3, “Affected Environment,” Chapter 5, “Environmental Laws, 

Regulations, Permits, and Other Potentially Applicable Requirements”

Education: M.A., Physical Geography/Geomorphology, University of Arizona

B.A., Physical Geography/Geomorphology, University of Maryland

Experience: 40 years

SCIENCE APPLICATIONS INTERNATIONAL CORPORATION

Cavanaugh, Sydel

EIS Responsibilities: Public Outreach Coordinator

Education: B.A., Interdisciplinary Studies-Personnel and Sociology, University of Maryland, 

Baltimore County

Experience: 27 years

DiMarzio, John

EIS Responsibilities: Geology, Soils, and Geologic Hazards Lead

Education: M.S., Geology, George Washington University

B.S., Geology, University of Maryland

Experience: 31 years

Dixon, Sharay

EIS Responsibilities: Meteorology, Air Quality, and Noise Analysis

Education: B.S., Environmental Management, University of Maryland University College

A.S., Applied Science, Weather Technology

Experience: 14 years

Gagne, Roger

EIS Responsibilities: Website Manager

Education: A.A., Computer Science/Business Programming, Montgomery Community 

College

Experience: 21 years
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

7–2

Gorden, Milton

EIS Responsibilities: Transportation Risk Lead, Site Infrastructure Lead, Waste Management Lead

Education: B.S., Nuclear Engineering, North Carolina State University

Experience: 22 years

Greene, Aaron

EIS Responsibilities: Ecological Resources Lead; Appendix F, “Common and Scientific Names of 

Plant and Animal Species”

Education: M.S., Environmental Science, Indiana University

B.S., Environmental Science, Mansfield University

Experience: 10 years

Heiser, Scott

EIS Responsibilities: Project Manager; Land Use and Visual Resources Lead; Chapter 2, “Facility 

Description, Alternatives, and Comparison of Environmental Consequences,” 

Chapter 4, “Environmental Consequences,” Appendix C, “Storage Facility 

Construction and Operations Data”

Education: M.S., Engineering Management, University of Maryland

B.S., Mechanical Engineering, Virginia Polytechnic Institute and State 

University

Experience: 21 years

Hoffman, Robert

EIS Responsibilities: Summary and Guide for Stakeholders

Education: B.S., Environmental Resource Management, The Pennsylvania State University

Experience: 27 years

Kaiser, Geoffrey

EIS Responsibilities: Occupational and Public Health and Safety Lead; Ecological Risk Lead; 

Appendix B, “Impact Assessment Methodology,” Appendix D, “Human Health 

and Ecological Risk Assessment Analysis,” Appendix E, “Updates to the 

January 2011 Mercury Storage EIS”

Education: Ph.D., Theoretical Elementary Particle Physics, Cavendish Laboratory, 

Cambridge, United Kingdom

M.A., Natural Sciences, University of Cambridge, United Kingdom

B.A., Natural Sciences, University of Cambridge, United Kingdom

Experience: 44 years

Mielke, Matthew

EIS Responsibilities: Socioeconomics Analysis; Environmental Justice Analysis

Education: B.S., Environmental Science and Policy, University of Maryland, College Park

Experience: 2 years

Mirsky, Steve

EIS Responsibilities: Occupational and Public Health and Safety Accident and Intentional Destructive 

Acts Analyses

Education: M.S., Nuclear Engineering, The Pennsylvania State University

B.S., Mechanical Engineering, Cooper Union

Experience: 36 years
List of Preparers

7–3

Preston, Margaret (Peggy)

EIS Responsibilities: Water Resources Lead

Education: B.S., Environmental Science, University of Maryland, Baltimore County

Experience: 7 years

Rhone, Jacquelyn

EIS Responsibilities: Document Production Manager; Appendix A, “The Mercury Export Ban Act 

of 2008, Federal Register Notices, and Other Public Notices,” Appendix G, 

“Cooperating Agency Agreements,” Appendix H, “Contractor National 

Environmental Policy Act Disclosure Statement”

Education: A.Sc., Radiological Health Technology, Central Florida Community College

Experience: 40 years

Riley, Elizabeth

EIS Responsibilities: Document Production; Appendix A, “The Mercury Export Ban Act of 2008, 

Federal Register Notices, and Other Public Notices,” Appendix G, “Cooperating 

Agency Agreements,” Appendix H, “Contractor National Environmental Policy 

Act Disclosure Statement,” Appendix I, “Responses to Consultation Requests”

Education: B.A., Psychology, The Catholic University of America

Experience: 2 years

Robinson, Linda

EIS Responsibilities: Project Quality Advisor

Education: Executive M.B.A., Loyola College

B.S. Ed., Earth Sciences, Texas Christian University

Experience: 39 years

Schatzel, Sean

EIS Responsibilities: Socioeconomics Lead; Environmental Justice Lead; Appendix B, “Impact 

Assessment Methodology,” Appendix E, “Updates to the January 2011 Mercury 

Storage EIS”

Education: B.A., Political Economics/Public Administration, Bloomsburg University

Experience: 5 years

Schinner, James

EIS Responsibilities: Cumulative Impacts Lead

Education: Ph.D., Wildlife Management, Michigan State University

M.S., Zoology, University of Cincinnati

B.S., Zoology, University of Cincinnati

Experience: 40 years

Smith, Alison

EIS Responsibilities: Technical Editor Lead; Chapter 6, “Glossary,” Chapter 9, “Index”

Education: B.A., English Language and Literature, University of Maryland, College Park

Experience: 5 years

Smith, Charlotte

EIS Responsibilities: Public Outreach Support

Experience: 14 years
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

7–4

Soverow, Walter

EIS Responsibilities: Administrative Record Coordinator; Public Outreach Support; Chapter 7, “List 

of Preparers,” Chapter 8, “Distribution List”

Education: B.S., Business Administration, Rochester Institute of Technology

Experience: 18 years

Upchurch, Audra

EIS Responsibilities: Cultural and Paleontological Resources Lead; Chapter 3, “Affected 

Environment,” Chapter 5, “Environmental Laws, Regulations, Permits, and Other 

Potentially Applicable Requirements”

Education: M.N.R., Natural Resources, Virginia Polytechnic Institute and State University 

Graduate Certificate, Natural Resources, Virginia Polytechnic Institute and State 

University

B.S., Forestry; Minor: Environmental Science, Virginia Polytechnic Institute and 

State University

Experience: 10 years

Werth, Robert

EIS Responsibilities: Meteorology, Air Quality, and Noise Lead

Education: B.A., Physics, Gordon College

Experience: 38 years
CHAPTER 8

DISTRIBUTION LIST

8–1

CHAPTER 8

DISTRIBUTION LIST

The U.S. Department of Energy provided copies of this Draft Long-Term Management and Storage of 

Elemental Mercury Supplemental Environmental Impact Statement (Draft Mercury Storage SEIS) to 

members of Congress, American Indian tribal governments, state and local governments, other Federal 

agencies, and organizations and individuals listed in this chapter. Approximately 400 compact disk or 

hard copies of the complete Draft Mercury Storage SEIS were distributed, along with a compact disk of 

the complete January 2011 Final Long-Term Management and Storage of Elemental Mercury 

Environmental Impact Statement (Mercury Storage EIS). Additionally, all stakeholders of record for the 

January 2011 Mercury Storage EIS were sent postcard notification that this Draft Mercury Storage SEIS

was available for public comment and where the document could be found online and in reading rooms. 

Stakeholders of record for this Draft Mercury Storage SEIS that did not request a copy of this document

were also sent postcard notification. Copies of the January 2011 Mercury Storage EIS or this Draft

Mercury Storage SEIS will be provided upon request.

UNITED STATES CONGRESS

U.S. Senate

Colorado

The Honorable Michael Bennet

The Honorable Mark Udall

Georgia

The Honorable Saxby Chambliss

The Honorable Johnny Isakson

Idaho

The Honorable James Risch

The Honorable Mike Crapo

Kansas

The Honorable Jerry Moran

The Honorable Pat Roberts

Missouri

The Honorable Roy Blunt

The Honorable Claire McCaskill

Nevada

The Honorable Dean Heller

The Honorable Harry Reid

New Mexico

The Honorable Martin Heinrich

The Honorable Tom Udall

Oregon

The Honorable Jeff Merkley

The Honorable Ron Wyden

South Carolina

The Honorable Tim Scott

The Honorable Lindsey Graham
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–2

Tennessee

The Honorable Lamar Alexander

The Honorable Bob Corker

Texas

The Honorable John Cornyn

The Honorable Ted Cruz

Washington

The Honorable Maria Cantwell

The Honorable Patty Murray

U.S. Senate Committees

Committee on Appropriations, Subcommittee on Energy and Water Development

The Honorable Dianne Feinstein, Chairman

The Honorable Lamar Alexander, Ranking Member

Committee on Armed Services

The Honorable Carl Levin, Chairman

The Honorable James Inhofe, Ranking Member

Committee on Energy and Natural Resources

The Honorable Ron Wyden, Chairman

The Honorable Lisa Murkowski, Ranking Member

Committee on Environment and Public Works

The Honorable Barbara Boxer, Chairman

The Honorable David Vitter, Ranking Member 

U.S. House of Representatives

Colorado

The Honorable Scott Tipton, District 3

Georgia

The Honorable Paul Broun, District 10

The Honorable John Barrow, District 12

Idaho

The Honorable Raul Labrador, District 1

The Honorable Mike Simpson, District 2

Kansas

The Honorable Kevin Yoder, District 3 

Missouri

The Honorable Vicky Hartzler, District 4

The Honorable Emanuel Cleaver, District 5

The Honorable Sam Graves, District 6

Nevada

The Honorable Mark Amodei, District 2

New Mexico

The Honorable Michelle Lujan Grisham, District 1

The Honorable Steve Pearce, District 2

The Honorable Ben Ray Lujan, District 3
Distribution List

8–3

Oregon

The Honorable Suzanne Bonamici, District 1

The Honorable Greg Walden, District 2

The Honorable Earl Blumenauer, District 3

The Honorable Peter DeFazio, District 4

The Honorable Kurt Schrader, District 5

South Carolina

The Honorable Joe Wilson, District 2

The Honorable Jeff Duncan, District 3

The Honorable Mick Mulvaney, District 5

The Honorable James E. Clyburn, District 6

Tennessee

The Honorable John Duncan, Jr., District 2

The Honorable Chuck Fleischmann, District 3

The Honorable Scott DesJarlais, District 4

Texas

The Honorable Mike Conaway, District 11

Washington

The Honorable Doc Hastings, District 4

U.S. House of Representatives Committees

Committee on Appropriations, Subcommittee on Energy and Water Development

The Honorable Rodney Frelinghuysen, Chairman

The Honorable Marcy Kaptur, Ranking Member

Committee on Armed Services

The Honorable Howard P. “Buck” McKeon, Chairman

The Honorable Adam Smith, Ranking Member

Committee on Energy and Commerce

The Honorable Fred Upton, Chairman

The Honorable Henry A. Waxman, Ranking Member

Committee on Science, Space, and Technology

The Honorable Lamar Smith, Chairman

The Honorable Eddie Bernice Johnson, Ranking Member

FEDERAL AGENCIES

Advisory Council on Historic Preservation

Defense Logistics Agency

U.S. Bureau of Land Management

U.S. Department of the Army

U.S. Department of the Interior

U.S. Department of Transportation 

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

U.S. General Services Administration

U.S. Government Accountability Office
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–4

STATE GOVERNMENT

Colorado

Colorado Governor

John W. Hickenlooper

Senators

Steve King, District 7

Representatives

Ray Scott, District 55

Colorado Department of Natural Resources

Jim Pokrandt, Chair, Colorado Basin Roundtable

Ron Velarde, NW Regional Manager, Division of Wildlife

Colorado Department of Public Health and Environment

Martha Rudolph, Executive Director

Michael Cosby, UMTRA Property Specialist

Tammy Ottmer, WIPP Program Manager

Howard Roitman, Acting Director of Environmental Programs

Joe Schieffelin, Manager, Hazardous Materials & Solid Waste Program

Warren Smith, Community Involvement Manager

Colorado Historical Society

Edward C. Nichols, State Historic Preservation Officer

Georgia

Georgia Governor

Nathan Deal

Georgia Department of Natural Resources

Albert J. Frazier, Jr., Manager, ERT/RMP/EPCRA Programs, Environmental Protection Division

Idaho

State Officials

C.L. “Butch” Otter, Governor

Bonnie Butler, Special Assistant to the Governor, Office of the Governor

Senators

Dean Cameron, District 27

Jim Guthrie, District 28

Steve Bair, District 31

John H. Tippets, District 32

Bart M. Davis, District 33

Jeff C. Siddoway, District 35

Representatives

Robert Anderst, District 12, Seat A

Gary E. Collins, District 13, Seat B

Scott Bedke, District 27, Seat A

Fred Wood, District 27, Seat B
Distribution List

8–5

Representatives (continued)

Ken Andrus, District 28, Seat A

Kelly Packer, District 28, Seat B

Carolyn Meline, District 29, Seat A

Neal A. Anderson, District 31, Seat A

Julie VanOrden, District 31, Seat B

Marc Gibbs, District 32, Seat A

Tom Loertscher, District 32, Seat B

Linda B. Bateman, District 33, Seat B

Janet Trujillo, District 33, Seat A

Paul Romrell, District 35, Seat B

JoAn E. Wood, District 35, Seat A

Idaho Department of Environmental Quality

Robert E. Bullock, Hazardous Waste Permits Manager

Jess Byrne, Deputy Director

Craig Halverson, Program Manager

Curt Fransen, Director

Erick Neher, Regional Administrator

Idaho Department of Labor

Roger B. Madsen, Director

Idaho Fish and Game 

Jeff Gould, Chief, Wildlife Bureau 

Idaho Office of Energy Resources 

John Chatburn, Energy Policy Analyst

Idaho State Historical Society

Janet Gallimore, Executive Director

Kansas

Governor

Sam Brownback

Missouri

Governor

Jay Nixon

Senators

S. Kiki Curls, District 9

Representatives

Chris Kelly, District 45

Office of Environmental Quality, Environmental Management Commission of Kansas City, Missouri

Carol T. Adams, Co-chair

Bob Berkebile, Co-chair

Missouri Department of Conservation

Doyle Brown, Policy Coordinator

Missouri Department of Health and Senior Services

Jonathan Garoutte, Environmental Specialist
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–6

Missouri Department of Natural Resources

Keith Bertels, Environmental Specialist, Hazardous Waste Program, Department of Environmental 

Quality

Mark A. Miles, State Historic Preservation Officer

Mark Templeton, Director 

Nevada

Governor

Brian Sandoval

Senators

Mike McGinness, Central Nevada Senatorial District

Representatives

James Oscarson, District 36

Nevada Agency for Nuclear Projects 

Robert J. Halstead, Executive Director

Joe Strolin

Nevada Department of Conservation and Natural Resources

Allen Biaggi, Director

Jennifer Newmark, Program Manager, Nevada Natural Heritage Program 

Nevada Division of Environmental Protection

Colleen Cripps, Deputy Administrator

Eric Noack, Chief, Bureau of Waste Management

Nevada State Historic Preservation Office

Rebecca L. Palmer, Acting State Historic Preservation Officer

New Mexico

Governor

Susana Martinez

Keith Gardner, Chief of Staff

John A. Sanchez, Lieutenant Governor

Senators

Stuart Ingle, District 27

Cliff R. Pirtie, District 32

William F. Burt, District 33

Ron Griggs, District 34

Carroll Leavell, District 41

Gay Kernan, District 42

Representatives

William Gray, District 54

Cathrynn N. Brown, District 55

Jason C. Harper, District 57

Candy Spence Ezzell, District 58

Nora Espinoza, District 59

David M. Gallegos, District 61

Don Bratton, District 62
Distribution List

8–7

New Mexico Department of Cultural Affairs Historic Preservation Division

Jan Biella, Historic Preservation Officer

Norman B. Nelson, Archaeologist, Planning and Review 

New Mexico Energy, Minerals and Natural Resources

John A. Bemis, Secretary

Anne DeLain W. Clark, Coordinator, WIPP Transportation Safety Program

Tony Delfin, State Forester, Forestry Division

Daniela Roth, Botany Coordinator

Todd Wilson, Coordinator, WIPP Route Safety

New Mexico Environment Department

F. David Martin, Secretary

Butch Tongate, Deputy Secretary

John E. Kieling, Acting Chief Hazardous Waste

Thomas Skibitski, Chief DOE Oversight

New Mexico Department of Game and Fish

Matthew Wunder, Division Chief, Conservation Services

New Mexico Department of Public Safety

Alvin Dominque

New Mexico Attorney General

Gary King

Oregon

Governor

John Kitzhaber

Senators

Jackie Dingfleder, District 23

Bill Hansell, District 29

Ted Ferrioli, District 30

Representatives

Alissa Kerry-Guyer, District 46

Mark Johnson, District 52

Greg Smith, District 57

Bob Jenson, District 58

Oregon Department of Energy, Nuclear Safety Division

Dirk Dunning, Nuclear Material Specialist

Ken Niles, Division Administrator

Oregon Department of Environmental Quality

Neil Mullane, Water Quality Division Administrator

Mitch Wolgamott, Regional Administrator

South Carolina

Governor

Nikki Haley

Senators

Tom Young, District 24

A. Shane Massey, District 25
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–8

Representatives

Don Wells, District 81

William Clyburn, District 82

Bill Hixon, District 83

James Smith, District 84

William Taylor, District 86

South Carolina Department of Archives & History

Eric Emerson, State Historic Preservation Officer

South Carolina Department of Natural Resources 

D. Breck Carmichael, Jr., Deputy Director, Wildlife and Freshwater Fisheries Division

Bob Perry, Director, Office of Environmental Programs

Tennessee

Governor

Bill Haslam

Tennessee Department of Environment and Conservation

John A. Wojtowicz

Texas

Governor

Rick Perry

Senators

Kel Seliger, District 31

Representatives

Tryon D. Lewis, District 81

Texas Commission on Environmental Quality

Jim Harrison, Director, Intergovernmental Relations Division

Earl Lott, Director, Waste Permits Division

Amie Dutta Richardson, Attorney, Environmental Law Division

Mark R. Vickery, P.G., Executive Director

Texas Historical Commission

Mark S. Wolfe, State Historic Preservation Officer

Texas Parks and Wildlife Department 

Clay Brewer, Director 

Ross Melinchuk, Deputy Executive Director

Texas State Energy Conservation Office 

Roger Mulder

Washington

Governor

Jay Inslee

Mark Rupp, Director, Governor’s Washington, DC, Office
Distribution List

8–9

Senators

Jerome Delvin, District 8

Mark Schoesler, District 9

Janéa Holmquist, District 13

Curtis King, District 14

Jim Honeyford, District 15

Mike Hewitt, District 16

Representatives

Larry Haler, District 8, Seat B

Brad Klippert, District 8, Seat A

Susan Fagan, District 9, Seat A

Joe Schmick, District 9, Seat B

Cary Condotta, District 12, Seat A

Matt Manweller, District 13, Seat B

Judith Warnick, District 13, Seat A

Norm Johnson, District 14, Seat A

Charles Ross, District 14, Seat B

Bruce Chandler, District 15, Seat A

David Taylor, District 15, Seat B

Maureen Walsh, District 16, Seat A

Washington State Department of Ecology

Madeleine Brown, SEPA

Maria Victoria Peeler, Senior Policy Specialist 

Ron Skinnarland, Waste Management Sector Manager

Ted Sturdevant, Director

Washington State Department of Fish and Wildlife

John Carleton

Jeff Tayer, Regional Program Director

Washington State Department of Health

John Martell, Manager, Division of Environmental Health, Office of Radiation Protection

Washington State Department of Natural Resources

Sandy Swope Moody, Environmental Review Coordinator, Washington Natural Heritage Program

Washington State Office of Archaeology and Historic Preservation

Allyson Brooks, Ph.D., State Historic Preservation Officer

NATIONAL ENVIRONMENTAL POLICY ACT STATE POINTS OF CONTACT

Erick Neher, Department of Environmental Quality, Idaho National Laboratory Oversight Program

Susan Burke, Department of Environmental Quality, Idaho National Laboratory Oversight Program

Robert Stout, Missouri Department of Natural Resources

Skip Canfield, Nevada State Clearinghouse, Nevada Division of State Lands

Shelly Wilson, South Carolina Department of Health and Environmental Control

Mary Parkman, Tennessee Department of Environment and Conservation

Chudi Nwangwa, Tennessee Department of Environment and Conservation

Toby Baker, Governor’s Advisor, Natural Resources and Agriculture, Texas

Terry Zrubek, Governor’s Advisor, Natural Resources, Texas

Annie Szvetecz, SEPA Policy Lead, Washington State Department of Ecology
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–10

LOCAL GOVERNMENT

Colorado

Delta County Officials

Rob Fiedler, Emergency Manager, Sheriff’s Office

Grand Junction Officials

Bill Pitts, Mayor

Rich Englehart, City Manager

Drew Reekie, Hazmat Coordinator, Fire Department

Mesa County Officials

Steve Acquafresca, District 2, Board of County Commissioners

Steve DeFeyter, Director of Environmental Health, Mesa County Health Department

Dave Frankel, Mesa County Attorney’s Office

James Grady, Mesa County Board of Health

Kurt Larsen, Director of Planning and Economic Development

Craig Meis, District 1, Board of County Commissioners

John Rodwick, Ph.D., Mesa County Board of Health

Donna Ross, Development Services Director, Mesa County Planning

Pitkin County, Board of County Commissioners

George Newman, Chairman

Georgia

Mayor

Deke Copenhaver, Augusta

Idaho

Mayor

Jared Fuhriman, Idaho Falls

Butte County Commissioner

Seth E. Beal, Chairman

Missouri

Kansas City Officials

Sly James, Mayor

Troy Schulte, City Manager

Scott Taylor, District 6, City Council

Dennis Murphey, Chief Environmental Officer, Office of Environmental Quality

John A. Sharp, District 6, City Council

Nevada

Mineral County, Board of County Commissioners

Jerrie C. Tipton, Chair
Distribution List

8–11

New Mexico

Artesia Officials

Phillip Burch, Mayor

Carlsbad Officials

Dale W. Janway, Mayor

John Tully, City Administrator

Eunice Officials

Matt White, Mayor

Martin Moore, City Manager

Hobbs Officials

Sam Cobb, Mayor

J.J. Murphy, City Manager

Lea County Officials

Mike Gallagher, County Manager

Gregory H. Fulfer, Chairman, Board of County Commissioners

Village of Loving Officials

Pete Estrada, Mayor

Roswell Officials

Del Jurney, Mayor

Oregon

Portland Officials

Charlie Hales, Mayor

Susan Anderson, Director, Bureau of Planning and Sustainability

South Carolina

Aiken City Officials

Fred Cavanaugh, Mayor

Richard Pearce, City Manager

Aiken County Officials

J. Clay Killian, County Administrator

Ronnie Young, Chairman, County Council

Texas

Andrews Officials

Robert Zap, Mayor

Wesley Burnett, Director, Economic Development

Danny Griffin, Plant Manager

Glen E. Hackler, City Manager

Dolphus Bud Jones, Chief of Police, Department of Public Safety

Richard H. Dolgener, County Judge
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–12

Washington

Benton City Officials 

Lloyd Carnahan, Mayor

Benton County Officials 

James Beaver, Chairman, Benton County Commissioners

Rick Garza, Deputy Director, Benton County Emergency Management 

Hans Kwast, Director, Benton County Emergency Services

Gwen Luper, Executive Director, Benton-Franklin Council of Governments 

Scott D. Keller, Executive Director, Port of Benton

Franklin County Officials

Brad Peck, Chairman, Board of County Commissioners

Kennewick Officials

Marie Mosely, City Manager

Steve Young, Mayor 

Pasco Officials

Gary Crutchfield, City Manager 

Matt Watkins, Mayor 

Port of Benton (Benton County) Board of Commissioners

Robert D. Larson, President

Port of Pasco (Franklin County) Board of Commissioners

Bill Clark, President

Prosser Officials

Paul Warden, Mayor

Richland Officials

John Fox, Mayor

Cindy Johnson, City Manager

David Rose, Mayor Pro Tem 

West Richland Officials 

Donna Noski, Mayor

ADVISORY BOARDS

Environmental Management Site-Specific Advisory Boards (SSAB)

AMERICAN INDIAN TRIBAL REPRESENTATIVES

Colorado

No American Indian tribal representatives have been identified.

Idaho

Nez Perce Tribe

Silas Whitman, Chairman, Nez Perce Tribal Executive Committee

John Stanfill, Hanford Coordinator
Distribution List

8–13

Shoshone-Bannock Tribes 

Nathan Small, Chairman, Fort Hall Business Council

Tino Batt, Treasurer, Fort Hall Business Council

Willie Preacher, Tribal Department of Energy Director

Roger Turner, Air Quality Manager

Kansas

No American Indian tribal representatives have been identified.

Missouri

No American Indian tribal representatives have been identified.

Nevada

Walker River Paiute Tribe

Lorren Sammaripa, Chairman

New Mexico

Pueblo of Acoma

Randall Vincente, Governor

Pueblo of Laguna

Richard Luarkie, Governor

Pueblo of Nambe

Phillip A. Perez, Governor

Pueblo of Pojoaque

George Rivera, Governor

Pueblo of San Ildelfonso

Terry Aguilar, Governor

Oregon

Confederated Tribes of the Umatilla Indian Reservation

Les Minthorn, Chairman, Board of Trustees

Thomas Bailor, Program Manager, Professional Services and Outreach, Department of Science and 

Engineering

Stuart Harris, Director, Department of Science and Engineering

South Carolina

Catawba Indian Nation 

Bill Harris, Chief

Tennessee

No American Indian tribal representatives have been identified.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–14

Texas

No American Indian tribal representatives have been identified.

Washington

Confederated Tribes and Bands of the Yakama Nation

Harry Smiskin, Chairman, Yakama Nation Tribal Council

Russell Jim, Manager, Yakama Nation Environmental Restoration and Waste Management Program

Confederated Tribes of the Colville Reservation

John E. Sirois, Chairman, Colville Business Council

Wanapum People

Rex Buck, Leader

READING ROOMS AND LIBRARIES

Colorado

U.S. Department of Energy

Office of Legacy Management

2597 Legacy Way

Grand Junction, CO 81503

(970) 248-6089

Mesa County Library

530 Grand Avenue

Grand Junction, CO 81502

(970) 243-4442

Georgia

Reese Library

Augusta State University

2500 Walton Way 

Augusta, GA 30904

(706) 737-1745

Asa H. Gordon Library

Savannah State University

2200 Tompkins Road

Savannah, GA 31404

(912) 356-2183

Idaho

U.S. Department of Energy

Public Reading Room

1776 Science Center Drive

Idaho Falls, ID 83402

(208) 526-5190

Missouri

Mid-Continent Public Library

Blue Ridge Branch

9253 Blue Ridge Boulevard

Kansas City, MO 64138

(816) 761-3382

Nevada

Mineral County Library

First & “A” Street

Hawthorne, NV 89415

(775) 945-2778

New Mexico

Eunice Public Library

1003 Avenue N

Eunice, NM 88231

(575) 394-2336

Zimmerman Library

Government Information Department

1 University of New Mexico

Albuquerque, NM 87131

(505) 277-5441

WIPP Information Center

4021 National Parks Highway

Carlsbad, NM 88220

(505) 234-7200
Distribution List

8–15

Oregon

Portland State University

Government Information

Branford Price Millar Library

1875 SW Park Avenue

Portland, OR 97207

(503) 725-5874

South Carolina

Gregg-Graniteville Library

University of South Carolina-Aiken

471 University Parkway

Aiken, SC 29801

(803) 641-3320

South Carolina State Library

1500 Senate Street

Columbia, SC 29211

(803) 734-8026

Texas

Andrews County Library

109 NW 1st Street

Andrews, TX 79714

(432) 523-9819

Washington

U.S. Department of Energy

Public Reading Room

Consolidated Information Center

2770 University Drive, Room 101L

Richland, WA 99352

(509) 372-7443

University of Washington

Suzzallo-Allen Library

Government Publications

Seattle, WA 98195

(206) 543-4164

Gonzaga University

Foley Center Library

101-L East 502 Boone

Spokane, WA 99258

(509) 313-5931

Washington, DC

U.S. Department of Energy

Freedom of Information Reading Room

1000 Independence Avenue, SW, 1G-033

Washington, DC 20585

(202) 586-5955

ORGANIZATIONS/PUBLIC INTEREST GROUPS

Lesley Weinstock, Agua es Vida Action Team

Alan S. Caldwell, A. S. Caldwell and Associates

Tom Clements, Alliance for Nuclear Accountability

Robert J. Simon, American Chemistry Council

Bruce Lawrence, Bethlehem Apparatus Company

A. Turner Shipman, Bridlespur Homes Association

Jody Knox, Carlsbad Department of Development

Janet Greenwald, Citizens for Alternatives to Radioactive Dumping

Deborah Reade, Citizens for Alternatives to Radioactive Dumping

Michael Crisenberry, Clean Harbors Environmental Services, Inc.

John Tanner, Coalition 21

Dana S. Kimbal, Coeur Rochester, Inc.

David Foy, Colorado Counties, Inc.

Penelope McMullen, Community of Loretto

Joni Arends, Concerned Citizens for Nuclear Safety

Yvonne Downs, DZHC

Lisa Hardison, Economic Development Corporation of Lea County New Mexico

Charlie Smith, Economic Development Corporation of Lea County New Mexico

Matthew C. Jones, Environmental Council of the States

Louis Clark, Government Accountability Project

Mark Cohen, Government Accountability Project
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

8–16

Bill Keller, Greenpeace

Gerald Pollet, Heart of America Northwest

Grant Taylor, Hobbs Chamber of Commerce

Oscar Gonzales, Hobbs Hispano Chamber of Commerce

Sara Navarro, Hobbs Hispano Chamber of Commerce

T.J. Parks, Hobbs Municipal Schools District

Lance Wiseman, Hobbs Municipal Schools District Board

Judy Hanna, Hobbs News Sun

Levi Hill, Hobbs News Sun

Arjun Makhijani, Institute for Energy & Environmental Research

Robert Reid, JF Maddox Energy

Hermilo Ojeda, KLMA

Russ Ptacek, KSHB

Brenda Brooks, LES Enrichment Facility

Sharon Duncan, Linden Hill Homes and Center Planning & Development Council

Michael Bender, Mercury Policy Project

Jim Hattler, Mercury Waste Solutions

Karen Bennett, National Mining Association

Tawny A. Bridgeford, National Mining Association

Sydney Gordon, National Securities Technologies

Thomas Cochran, Natural Resources Defense Council

Susan Egan Keane, Natural Resources Defense Council

Geoff Fettus, Natural Resources Defense Council

David Goldstein, Natural Resources Defense Council

David Lennett, Natural Resources Defense Council

Robert Caudle, New Mexico Junior College

Jeff White, Newmont Mining Corporation

Jay Coghlan, Nuclear Watch New Mexico

Scott Kovac, Nuclear Watch New Mexico

Norman A. Mulvenon, Oak Ridge Reservation Local Oversight Committee

John R. Parish, Oil Operation

Elaine K. Patterson, Olin Chlor Alkali Products

Madeline Riley, Physicians for Social Responsibility

Ann Suellentrop, Physicians for Social Responsibility

Tom Smith, Public Citizen Texas

C. Mark Smith, Quicksilver Caucus

Sandy Baranich, S.M. Stoller Corporation

Darlene DePinho, S.M. Stoller Corporation

Linda Sheader, S.M. Stoller Corporation

Dan Weaks, Shoats and Weaks Inc.

Ed Hopkins, Sierra Club, Washington, DC, Office

Niki Widmayer, Sierra Club

Don Hancock, Southwest Research and Information Center

Stephanie Lindsay, Stinson Morrison Hecker, LLP

Karen Hadden, Sustainable Energy and Economic Development Coalition

Sandra Carroll, Tetra Tech

Frank Reiner, The Chlorine Institute, Inc.

Leslie Huddleston, U.S. Senate - Office of Senator Crapo

Gary Dill, University of the Southwest

Jude Van Buren, University of Washington Environmental Health Safety

Hemut Engebrecht, URENCO, Ltd.
Distribution List

8–17

Amy Taylor, U.S. Senate - Office of Senator James Risch

Nancy Bobbitt, U.S. Senate - Office of Senator Johnny Isakson

Phillip G. Ditter, Veolia ES Technical Solutions

Donavan Mager, Washington TRU Solutions

Samuel Alexander, Jr., Waste Control Specialists

Jay Britten, Waste Control Specialists, LLC

John Browder, Waste Control Specialists, LLC

Michael Burney, Waste Control Specialists, LLC

Juan Garza, Waste Control Specialists, LLC

Tom Jones, Waste Control Specialists, LLC

Karl Klotz, Waste Control Specialists, LLC

Jack Kraus, Waste Control Specialists, LLC

Sheila Parker, Waste Control Specialists, LLC

Charles E. Taylor, Waste Control Specialists, LLC

Ben Jaime, Xcel Energy

INDIVIDUALS

Sally Cordova

Patricia Dominguez

Morgan Drewmiany

Susan Kamat

Judy Kaul

Christopher Miller

Rebecca Mitchell

Lilly K. Rendt

Greg M. Sehoen

CHAPTER 9

INDEX

9–1

CHAPTER 9 

INDEX

A 

accidents, S–2, S–12, 1–5, 2–15, 2–18, 2–19, 2–26, 

2–28, 4–1, 4–5, 4–7, 4–15, 4–16, 4–17, 4–18, 

4–19, 4–20, 4–23, 4–24, 4–25, 4–26, 4–27, 

4–28, 4–29, 4–30, 4–31, 4–46

facility, 2–16, 2–18, 2–25, 2–26, 3–26, 3–27, 4–2, 

4–16, 4–47

transportation, 1–7, 2–19, 2–26, 2–28, 4–23, 4–47

active fault, 4–4 

Acute Exposure Guideline Level (AEGL), 4–25, 

4–26, 4–30

affected environment, S–2, S–5, 1–5, 1–10, 2–15, 

3–1, 3–2, 4–46

air pollutant, S–10, 3–2, 4–8, 4–44, 5–5 

air quality, S–5, S–10, S–13, S–14, 1–8, 1–10, 2–16, 

2–18, 2–23, 2–29, 2–30, 3–1, 3–2, 3–17, 3–18, 

3–20, 4–1, 4–7, 4–8, 4–9, 4–42, 4–43, 4–44, 

4–46, 4–48, 5–2, 5–3, 5–4, 5–5 

ambient, 2–23, 3–18, 3–19, 4–44, 4–48

alluvium, 3–12

American Indian, 1–10, 2–24, 3–23, 3–28, 4–11, 5–5 

American robin, 2–19, 2–28, 4–31, 4–32, 4–34, 4–35, 

4–36, 4–37, 4–38, 4–39

animals, S–2, 1–11, 2–24

aquatic biota, 2–19, 2–28, 4–31, 4–32, 4–34, 4–35, 

4–36, 4–37, 4–38, 4–39

aquatic resource, 3–21, 4–10, 4–45

aquatic species, 2–24, 3–21

aquifer, 3–14, 3–15, 3–25

aquitard, 3–14

archaeological site, 3–22, 3–23, 4–12, 5–5 

artifact, 3–23, 5–5 

attainment, 3–19, 3–20

B 

bedrock, 3–11

best management practice, S–10, 2–3, 2–22, 2–23, 

4–4, 4–5 

Bethlehem Apparatus Company, 2–2 

bird, 3–5, 3–21

block group, 2–17, 2–29, 4–40, 4–41

Burlington Northern Santa Fe (BNSF) Railroad, 

3–24, 3–28

C 

cancer, 3–27

candidate sites, S–4, S–5, S–6, S–7, S–9, S–10, S–11, 

S–12, S–13, S–15, 1–6, 1–7, 1–8, 1–10, 2–1, 

2–3, 2–9, 2–10, 2–16, 2–17, 2–22, 2–29, 3–1, 

3–13, 3–29, 4–1, 4–2, 4–16, 4–17, 4–23, 4–35, 

4–36, 4–37, 4–47, 4–48, 4–49, 5–1, 5–2, 5–3, 

5–5 

candidate species, 3–21

carbon dioxide, S–10, 2–18, 2–23, 4–8

carbon monoxide, 2–23, 3–18, 3–19, 4–8

carbon tetrachloride, 3–27

carbonate, 3–6, 3–9, 3–10, 3–12, 3–16, 4–4 

Carlsbad Caverns National Park, 3–20

Carlsbad, New Mexico, S–1, S–4, S–5, S–15, S–17, 

1–5, 1–7, 1–8, 1–9, 2–11, 3–2, 3–5, 3–9, 3–19, 

3–20, 3–24, 3–25, 3–28, 3–32, 4–2 

census, S–2, S–13, 1–5, 2–15, 2–17, 2–19, 2–29, 3–1, 

3–28, 3–29, 3–30, 3–31, 3–32, 4–1 

census block, 2–17, 2–29, 3–30, 3–31, 3–32

Central Waste Complex (CWC), 2–10

Chihuahuan Desert, 2–11, 3–2, 3–17, 3–21, 4–2 

children, 3–28

chlor-alkali, S–3, 1–4, 2–1, 2–2, 2–4, 2–7 

closure, 1–3, 1–4, 1–7, 1–10, 2–1, 2–7, 4–1, 4–2, 

4–41, 4–48, 5–5 

Code of Federal Regulations (CFR), S–1, 1–1, 1–7, 

2–4, 2–15, 2–29, 3–20, 3–26, 3–27, 4–6, 4–7, 

4–11, 4–41, 4–42, 4–46, 5–1 

commitments of resources, 1–10

irreversible and irretrievable, 1–10, 4–47, 4–48

commodity, 2–2, 2–10, 2–21

comparison of alternatives, 2–15

Congress, S–2, 1–4 

construction, S–4, S–5, S–6, S–7, S–8, S–9, S–10, 

S–11, S–13, 1–6, 1–11, 2–4, 2–6, 2–9, 2–11, 

2–14, 2–16, 2–17, 2–18, 2–19, 2–21, 2–22, 

2–23, 2–24, 2–25, 2–29, 3–18, 3–20, 3–25, 

4–2, 4–3, 4–4, 4–5, 4–6, 4–7, 4–8, 4–9, 4–10, 

4–11, 4–12, 4–13, 4–14, 4–15, 4–16, 4–21, 

4–39, 4–40, 4–43, 4–44, 4–45, 4–46, 4–47, 

4–48, 4–49, 5–1, 5–3, 5–4, 5–5 

debris, 2–25, 3–23, 3–25, 4–14, 4–41

site, S–1, S–5, S–6, S–8, S–9, S–10, S–11, S–13, 

S–14, 1–1, 1–5, 1–6, 1–8, 1–9, 1–10, 2–3, 2–6, 

2–8, 2–9, 2–10, 2–11, 2–14, 2–17, 2–18, 2–19, 

2–22, 2–23, 2–24, 2–25, 2–26, 2–29, 3–1, 3–2, 

3–3, 3–4, 3–5, 3–6, 3–7, 3–8, 3–9, 3–10, 3–11, 

3–12, 3–13, 3–14, 3–15, 3–16, 3–17, 3–18, 

3–19, 3–20, 3–21, 3–22, 3–23, 3–24, 3–25, 

3–26, 3–27, 3–28, 4–1, 4–2, 4–3, 4–4, 4–5, 

4–6, 4–7, 4–8, 4–9, 4–10, 4–11, 4–12, 4–13, 

4–14, 4–15, 4–16, 4–17, 4–18, 4–21, 4–22, 

4–23, 4–26, 4–29, 4–37, 4–40, 4–41, 4–42, 

4–43, 4–45, 4–46, 4–47, 4–48, 4–49, 5–3

consultation, 1–11, 3–21, 4–10, 4–11, 5–5, 5–6 

Container Storage Building (CSB), S–8, 2–11

contamination, S–10, 1–7, 2–8, 2–25, 4–6, 4–7, 4–33, 

4–41, 4–44

costs, 2–1, 4–41
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

9–2

critical habitat, 2–24, 3–21, 4–10, 4–45, 5–5 

cultural and paleontological resources, S–5, 1–8, 

2–15, 2–24, 3–1, 3–2, 3–22, 4–1, 4–11, 4–12, 

4–42, 4–43

cumulative impacts, S–13, S–14, 1–9, 1–10, 2–29, 

2–30, 4–1, 4–42, 4–43, 4–44, 4–45

D 

damage, 2–22, 3–17, 4–4, 4–7, 4–17, 4–19

death, 4–22, 4–23

decommissioning, 1–9, 4–10

Defense Logistics Agency (DLA), 1–3, 2–3, 2–10, 

4–2, 4–20

Defense National Stockpile Center (DNSC), 2–3, 

2–10

Delaware Basin, 3–7, 3–9, 3–10

dental, S–2, 1–1 

deposition, S–12, 1–1, 2–18, 2–19, 2–27, 2–28, 4–22, 

4–26, 4–27, 4–28, 4–31, 4–33, 4–34, 4–35, 

4–37, 4–38

dry, 1–1, 2–19, 2–27, 2–28, 3–5, 3–14, 4–22, 

4–23, 4–26, 4–27, 4–28, 4–31, 4–34, 4–35, 

4–37, 4–38

wet, 1–1, 2–27, 2–28, 4–22, 4–23, 4–26, 4–27, 

4–28, 4–31, 4–35, 4–38

design, S–2, S–7, S–8, S–10, 2–1, 2–6, 2–22, 2–27, 

4–4, 4–5, 4–6, 4–7, 4–15, 4–17, 4–29, 4–46, 

5–3 

Dewey Lake Formation, 3–10, 3–14, 3–16

diesel fuel, 2–24, 2–25, 4–12, 4–13, 4–48

dose, 3–26, 3–27

Draft Long-Term Management and Storage of 

Elemental Mercury Supplemental 

Environmental Impact Statement 

(Draft Mercury Storage SEIS), S–1, S–6, 

S–16, 1–1, 1–3, 1–4, 2–1, 2–2, 2–9, 3–1, 4–1, 

5–1 

E 

earthquake, 2–17, 2–23, 2–26, 3–12, 4–4, 4–17, 

4–18, 4–19, 4–20, 4–21, 4–22

magnitude, S–2, 1–5, 2–15, 2–19, 3–12, 3–13, 

3–16, 3–20, 4–1, 4–15, 4–16, 4–46, 4–49

peak ground acceleration, 2–22, 3–13, 4–4, 4–17

seismic, S–10, 2–6, 2–17, 2–22, 2–23, 3–6, 3–12, 

3–13, 4–4, 4–16, 4–17, 4–46

ecological receptor, 2–19, 2–28, 4–24, 4–31, 4–32, 

4–33, 4–34, 4–35, 4–36, 4–37, 4–38, 4–39

ecological resource, S–5, S–11, S–13, S–14, 1–8, 

2–15, 2–16, 2–24, 2–29, 2–30, 3–1, 3–2, 3–21, 

4–1, 4–10, 4–39, 4–42, 4–43, 4–45, 5–5, 5–6 

ecological risk, S–2, S–5, 1–6, 1–8, 1–11, 2–19, 

2–28, 4–2, 4–31, 4–33

economic characteristics, 3–28

Eddy County, New Mexico, S–6, 3–3, 3–11, 3–18

electricity, S–2, S–11, 1–1, 1–5, 2–6, 2–24, 2–25, 

3–24, 4–12, 4–13, 4–14, 4–45, 4–48, 4–49

emergency, S–7, S–9, S–10, 2–3, 2–8, 2–18, 2–23, 

3–5, 3–20, 3–24, 4–7, 4–9, 4–13, 4–47, 4–48, 

5–4, 5–5 

generator, 1–3, 2–8, 2–24, 3–20, 3–25, 4–9, 4–12, 

4–13, 4–45

planning, 1–3, 3–5, 4–2, 4–3, 4–47, 5–2 

response, S–7, S–9, S–16, 1–8, 1–9, 2–3, 2–7, 

2–8, 2–25, 4–11, 4–14, 4–47, 5–5 

emission, 3–18, 4–8, 4–44, 5–5 

employee vehicles, S–10, 2–18, 2–23, 2–24, 4–7, 

4–9, 4–40, 4–48

employment, S–5, S–13, 1–6, 2–16, 2–17, 2–29, 

4–39

Energy Policy Act of 2005, 1–9 

environmental consequences, S–5, S–9, 1–10, 2–1, 

2–15, 2–16, 2–17, 2–18, 2–19, 2–21, 3–1, 4–1, 

4–5 

environmental impact, S–2, S–5, S–16, 1–1, 1–2, 

1–3, 1–4, 1–6, 1–7, 1–9, 1–10, 1–11, 2–3, 

2–19, 3–1, 3–2, 4–1, 4–2, 4–5, 4–11, 4–12, 

4–17, 4–20, 4–46, 4–47, 4–48, 4–49, 5–5 

environmental impact statement (EIS), S–1, S–2, 

S–7, S–8, S–9, S–10, S–13, S–14, 1–1, 1–2, 

1–3, 1–4, 1–5, 1–6, 1–7, 1–8, 1–9, 1–10, 1–11, 

2–1, 2–3, 2–9, 2–10, 2–11, 2–14, 2–15, 2–19, 

2–21, 2–23, 3–1, 3–2, 4–1, 4–2, 4–4, 4–8, 

4–15, 4–17, 4–20, 4–21, 4–23, 4–25, 4–26, 

4–28, 4–29, 4–32, 4–46, 5–1, 5–2 

Environmental Impact Statement for the Disposal of 

Greater-Than-Class C (GTCC) Low-Level 

Radioactive Waste and GTCC-Like Waste 

(GTCC EIS), 1–9, 3–1 

environmental justice, S–2, S–5, S–13, 1–5, 1–8, 

2–15, 2–16, 2–17, 2–19, 2–29, 3–1, 3–2, 3–28, 

4–1, 4–2, 4–40, 4–43

epoxy, S–8, 2–6 

erosion, 2–22, 3–10, 3–12, 4–4, 4–5, 4–47

Exclusive Use Area, 2–11, 2–14, 3–3, 3–4, 3–5 

Executive Order, 3–28

exhaust, S–10, 2–7, 2–8, 2–23

explosion, 4–19

exposure, S–12, 2–19, 2–26, 2–27, 2–28, 3–26, 3–27, 

4–8, 4–15, 4–16, 4–23, 4–26, 4–27, 4–28, 

4–30, 4–32, 4–34, 4–36, 4–38, 4–39

acute, S–2, S–11, 1–5, 2–15, 2–18, 2–19, 4–1, 

4–15, 4–25, 4–26, 4–27, 4–30

chronic, 2–25, 4–8, 4–16, 4–31

pathway, S–11, S–12, 1–8, 2–28, 3–15, 3–26, 

4–26, 4–28, 4–30, 4–32

F 

facility accidents, 2–16, 2–18, 2–25, 2–26, 3–26, 

3–27, 4–2, 4–16

fatality, S–11, 2–19, 2–27, 4–23
Index 

9–3

Federal Register (FR), S–1, S–4, S–14, S–15, S–16, 

1–5, 1–7, 1–9, 1–11, 2–3, 2–14, 5–1 

fence, 2–11, 3–3, 3–4, 3–20, 3–26

filter, S–10, 2–7, 2–8, 2–23

fire, S–7, S–8, S–12, 1–3, 2–3, 2–6, 2–27, 2–28, 

3–24, 4–16, 4–17, 4–19, 4–20, 4–22, 4–23, 

4–24, 4–25, 4–26, 4–27, 4–28, 4–29, 4–30, 

4–31, 4–34, 4–35, 4–36, 4–37, 4–38, 4–39

building, S–6, S–7, S–8, 1–7, 2–3, 2–6, 2–7, 2–9, 

2–10, 2–11, 2–18, 2–22, 2–25, 2–26, 3–20, 

4–3, 4–4, 4–7, 4–8, 4–16, 4–17, 4–18, 4–19, 

4–20, 4–21, 4–22, 4–23, 4–46, 5–6 

department, S–1, S–7, S–15, S–16, S–17, 1–1, 

1–2, 1–4, 1–7, 2–1, 2–3, 2–17, 3–1, 4–1, 4–15, 

4–20, 4–43, 5–1, 5–6 

forklift, 2–26, 4–19, 4–20

suppression, S–7, S–8, 1–3, 2–3, 2–6, 2–23, 4–19

transportation accident with, 2–28

fish, S–12, 2–18, 2–19, 2–27, 2–28, 4–27, 4–28, 

4–30, 4–31, 4–47

flask, 2–4, 4–19, 4–20, 4–22

flood, 2–17, 2–26, 4–5, 4–19

flood protection, 2–17

floodplain, 2–17

forklift, 2–26, 4–19, 4–20

fossil fuel, 2–23, 3–6, 4–46, 4–48, 4–49

G 

gasoline, 2–27, 3–24, 4–13, 4–29, 4–38

gasoline tanker, 2–27, 4–29, 4–38

geology, S–2, S–5, S–10, 1–8, 2–15, 2–18, 2–22, 

3–1, 3–2, 3–6, 4–1, 4–4, 4–5, 4–42, 4–43

global climate change, S–10, 2–23, 4–8 

gold, S–3, 1–4, 2–1, 2–2 

gold mining, S–3, 1–4 

Grand Junction Disposal Site (GJDS), S–1, S–6, 

S–11, 1–5, 2–9, 2–10, 2–17, 2–18, 2–19

gravel, 2–22, 4–4, 4–49

great blue heron, 2–19, 2–28, 4–31, 4–32, 4–34, 

4–35, 4–36, 4–37, 4–38, 4–39

groundwater, S–10, 2–15, 3–2, 3–8, 3–10, 3–12, 

3–14, 3–15, 3–16, 3–25, 3–26, 4–6, 4–7 

GTCC EIS, 1–9, 3–1 

Guadalupe Mountains National Park, 3–20

gypsum, 3–9, 3–10, 3–11, 3–16, 3–21, 3–22

H 

habitat, S–14, 1–8, 2–30, 3–21, 4–10, 4–45

hail, 3–17

Handling Area, S–8, S–10, 2–3, 2–6, 2–7, 2–8, 2–23, 

4–14

Hanford Site (Hanford), S–1, S–6, S–13, 1–5, 1–9, 

2–9, 2–10, 2–17, 2–18, 2–19, 2–23

hawk, 2–19, 2–28, 4–31, 4–32, 4–34, 4–35, 4–36, 

4–37, 4–38, 4–39

Hawthorne Army Depot, S–1, S–6, S–8, S–13, 1–5, 

2–3, 2–9, 2–10, 4–17, 4–23

hazardous chemical, 3–26, 3–27

hazardous material, S–8, 2–4, 4–22, 4–29

hazardous waste, 2–8, 2–11, 2–25, 3–20, 3–25, 4–14, 

4–41, 4–46, 4–49, 5–2, 5–3, 5–4, 5–5 

health effect, S–11, 1–6, 4–28, 4–47

Hispanic, 3–28, 3–29

historic resources, S–5, 3–1, 3–23, 4–11, 4–12, 5–5 

housing, S–2, 3–28

human health, S–2, S–3, S–5, S–11, S–12, 1–5, 1–6, 

1–9, 1–11, 2–18, 2–19, 2–25, 2–26, 3–1, 3–28, 

4–1, 4–28, 4–29, 4–34, 4–41

risk, S–5, 2–18, 2–19, 3–1, 4–28, 

4–34, 4–41

hydrocarbon, 3–9, 3–11

I 

Idaho Falls, S–1, S–16, 1–5 

Idaho National Laboratory (INL), S–1, S–6, S–8, 

1–5, 1–9, 2–9, 2–10, 2–17, 2–18, 2–19

Idaho Nuclear Technology and Engineering Center 

(INTEC), S–6, 1–5, 2–9, 2–10, 2–17, 2–18, 

2–19

infrastructure, S–5, S–11, S–13, S–14, 1–5, 1–6, 1–8, 

2–14, 2–16, 2–18, 2–24, 2–25, 2–29, 2–30, 

3–1, 3–2, 3–24, 3–25, 4–1, 4–4, 4–12, 4–13, 

4–42, 4–43, 4–45, 4–49

inhalation, 4–26, 4–27

integrated contingency plan, S–10, 4–6 

intentional destructive act (IDA), 2–25, 2–27, 2–28, 

4–29, 4–30, 4–31, 4–38, 4–39

Interim Guidance, 2–3, 2–8, 4–15, 4–25

interim storage, S–8 

K 

Kansas City Plant (KCP), S–1, S–6, S–8, S–13, 1–5, 

2–9, 2–10, 2–17, 2–18, 2–19, 4–17

L 

land disturbance, S–5, 1–6, 2–15, 2–22, 2–29, 4–42, 

4–47 

land use, S–5, S–10, S–13, S–14, 1–6, 1–8, 2–11, 

2–15, 2–16, 2–17, 2–18, 2–22, 2–29, 2–30, 

3–1, 3–2, 3–3, 3–5, 4–1, 4–3, 4–42, 4–43, 

4–47, 4–48, 5–2 

Land Withdrawal Act (LWA), S–6, 1–5, 1–8, 2–11, 

2–17, 3–2, 4–2, 5–3 

land withdrawal boundary (LWB), S–6, 1–8, 1–9, 

2–11, 2–17, 2–22, 3–1, 3–4, 3–5, 3–6, 3–11, 

3–13, 3–14, 3–21, 3–22, 3–23, 4–3, 4–11, 

4–12, 4–13, 4–14, 4–15, 4–16, 4–21, 4–31, 

4–43, 5–1, 5–3 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

9–4

landfill, 2–11, 3–25, 4–14, 4–48, 4–49

limestone, 3–11, 3–12

liquid waste, 2–25, 4–6, 4–14, 4–15

Long-Term Management and Storage of Elemental 

Mercury Environmental Impact Statement 

(Mercury Storage EIS), S–1, S–2, S–3, S–4, 

S–6, S–7, S–8, S–9, S–10, S–12, S–13, S–14, 

S–15, 1–1, 1–3, 1–4, 1–5, 1–6, 1–8, 1–10, 

1–11, 2–1, 2–3, 2–7, 2–9, 2–10, 2–14, 2–15, 

2–17, 2–19, 2–21, 2–23, 3–1, 3–13, 3–30, 4–1, 

4–2, 4–3, 4–4, 4–6, 4–7, 4–8, 4–15, 4–16, 

4–17, 4–18, 4–20, 4–21, 4–23, 4–24, 4–25, 

4–26, 4–27, 4–28, 4–29, 4–30, 4–31, 4–33, 

4–34, 4–35, 4–38, 4–47, 4–48, 5–1, 5–5 

Long-Term Management and Storage of Elemental 

Mercury Supplemental Environmental Impact 

Statement (Mercury Storage SEIS), S–1, S–4, 

S–14, S–15, S–16, 1–1, 1–3, 1–4, 1–5, 1–10, 

2–1, 2–9, 2–14, 3–1, 4–1 

Loving, New Mexico, 3–5 

M 

Maroon Cliffs Archaeological District, 3–23

Memorandum of Understanding, 2–17

mercury, S–1, S–2, S–3, S–4, S–5, S–6, S–7, S–8, 

S–9, S–10, S–11, S–12, S–13, S–14, S–15, 

S–16, 1–1, 1–2, 1–3, 1–4, 1–5, 1–6, 1–7, 1–8, 

1–10, 1–11, 2–1, 2–2, 2–3, 2–4, 2–5, 2–6, 2–7, 

2–8, 2–9, 2–10, 2–11, 2–14, 2–15, 2–16, 2–17, 

2–18, 2–19, 2–21, 2–22, 2–23, 2–24, 2–25, 

2–26, 2–27, 2–28, 2–29, 3–1, 3–13, 3–27, 

3–28, 3–29, 3–30, 4–1, 4–2, 4–3, 4–4, 4–5, 

4–6, 4–7, 4–8, 4–9, 4–10, 4–11, 4–12, 4–13, 

4–14, 4–15, 4–16, 4–17, 4–18, 4–19, 4–20, 

4–21, 4–22, 4–23, 4–24, 4–25, 4–26, 4–27, 

4–28, 4–29, 4–30, 4–31, 4–32, 4–33, 4–34, 

4–35, 4–37, 4–38, 4–40, 4–41, 4–42, 4–43, 

4–44, 4–45, 4–46, 4–47, 4–48, 4–49, 5–1, 5–2, 

5–3, 5–5 

acceptance criteria, 1–4 

byproduct, S–3, 1–4, 2–1, 2–2 

compounds, S–2, 1–4, 3–11, 3–20, 3–27, 4–24, 

4–33

cycle, S–3, 1–2, 1–7 

divalent, 1–1, 4–26, 4–33

elemental, S–1, S–2, S–5, S–6, S–9, S–14, 1–1, 

1–2, 1–3, 1–4, 1–7, 1–8, 2–1, 2–2, 2–3, 2–4, 

2–9, 2–10, 2–11, 2–21, 2–22, 3–1, 4–1, 4–2, 

4–3, 4–4, 4–6, 4–7, 4–8, 4–9, 4–15, 4–22, 

4–23, 4–24, 4–25, 4–28, 4–31, 4–33, 4–41, 

4–47, 4–48, 4–49, 5–1, 5–2, 5–3 

evaporation, 2–18, 2–19, 3–17, 3–21, 3–25, 4–21, 

4–23, 4–24, 4–25

export, S–2, S–5, S–9, 1–1, 1–2, 1–4, 1–5, 1–10, 

1–11, 2–21, 5–2 

inorganic, 1–1, 4–24, 4–26, 4–30, 4–32, 4–33

inventory, S–2, S–3, 1–2, 1–3, 1–4, 1–10, 3–18, 

3–23, 4–12

methylmercury, S–12, 1–1, 1–2, 2–27, 2–28, 

4–24, 4–28, 4–30, 4–32, 4–33, 4–47

poisoning, 3–28

purity, 2–1, 2–8, 4–2 

release, S–11, 1–1, 2–25, 2–28, 4–6, 4–7, 4–16, 

4–17, 4–19, 4–20, 4–21, 4–23, 4–24, 4–25, 

4–28, 4–29, 4–30, 4–32, 4–41, 4–47

retorting, 2–1 

roasting, 2–1 

source, 1–4, 1–6, 3–10, 3–14, 3–16, 3–18, 3–19, 

3–22, 3–25, 4–6, 4–8, 4–16, 4–17, 4–18, 4–24, 

4–26, 4–29, 4–49, 5–5 

storage, S–1, S–2, S–3, S–4, S–5, S–6, S–7, S–8, 

S–9, S–10, S–13, S–14, 1–1, 1–2, 1–3, 1–4, 

1–5, 1–6, 1–7, 1–8, 1–10, 1–11, 2–1, 2–2, 2–3, 

2–4, 2–6, 2–7, 2–8, 2–9, 2–10, 2–11, 2–14, 

2–15, 2–16, 2–17, 2–18, 2–19, 2–21, 2–22, 

2–23, 2–24, 2–25, 2–26, 2–27, 2–28, 2–29, 

3–1, 3–13, 3–16, 3–25, 3–27, 3–29, 3–31, 

3–32, 3–33, 4–1, 4–2, 4–3, 4–4, 4–5, 4–6, 4–7, 

4–8, 4–9, 4–10, 4–11, 4–12, 4–13, 4–14, 4–15, 

4–16, 4–17, 4–18, 4–19, 4–20, 4–21, 4–23, 

4–25, 4–26, 4–28, 4–29, 4–31, 4–32, 4–33, 

4–34, 4–35, 4–40, 4–41, 4–42, 4–43, 4–44, 

4–45, 4–46, 4–47, 4–48, 4–49, 4–50, 5–1, 5–2, 

5–3, 5–4, 5–5 

toxicity, 1–8, 4–2 

vapor, S–10, 2–8, 2–23, 2–25, 4–7, 4–14, 4–15, 

4–16, 4–25, 4–44, 4–46

Mercury Export Ban Act of 2008, S–1, S–3, S–9, 

S–15, 1–1, 1–2, 1–5, 1–10, 1–11, 2–1, 2–10, 

2–21, 4–2, 5–1, 5–2 

Mercury Storage EIS, S–1, S–2, S–3, S–4, S–6, S–7, 

S–8, S–9, S–10, S–12, S–13, S–14, S–15, 1–1, 

1–3, 1–5, 1–6, 1–8, 1–10, 1–11, 2–1, 2–3, 2–7, 

2–9, 2–10, 2–14, 2–15, 2–21, 2–23, 3–1, 3–13, 

3–30, 4–1, 4–2, 4–3, 4–4, 4–6, 4–7, 4–8, 4–15, 

4–16, 4–17, 4–18, 4–20, 4–21, 4–23, 4–24, 

4–25, 4–26, 4–27, 4–28, 4–29, 4–30, 4–31, 

4–33, 4–34, 4–35, 4–38, 4–47, 4–48, 5–1, 5–5 

mercury storage facility(ies), S–1, S–3, S–4, S–5, 

S–7, S–8, S–9, S–10, S–11, S–13, 1–3, 1–5, 

1–6, 1–7, 1–8, 1–10, 2–1, 2–3, 2–4, 2–5, 2–6, 

2–7, 2–8, 2–14, 2–16, 2–17, 2–18, 2–21, 2–22, 

2–23, 2–24, 2–25, 2–29, 3–27, 4–1, 4–2, 4–3, 

4–4, 4–5, 4–6, 4–7, 4–8, 4–9, 4–10, 4–11, 

4–12, 4–13, 4–14, 4–15, 4–29, 4–41, 4–42, 

4–43, 4–44, 4–45, 4–46, 4–47, 4–48, 4–49, 

5–3 

closure, 1–3, 1–7, 1–10, 2–1, 4–1, 4–41, 4–48, 

5–5 

construction, S–4, S–5, S–6, S–7, S–8, S–9, S–10, 

S–11, S–13, 1–6, 1–11, 2–4, 2–6, 2–9, 2–11, 

2–14, 2–16, 2–17, 2–18, 2–19, 2–21, 2–22, 

2–23, 2–24, 2–25, 2–29, 3–18, 3–20, 3–25, 

4–2, 4–3, 4–4, 4–5, 4–6, 4–7, 4–8, 4–9, 4–10, 
Index 

9–5

4–11, 4–12, 4–13, 4–14, 4–15, 4–16, 4–21, 

4–39, 4–40, 4–43, 4–44, 4–45, 4–46, 4–47, 

4–48, 4–49, 5–1, 5–3, 5–4, 5–5 

design, S–2, S–7, S–8, S–10, 2–1, 2–6, 2–22, 

2–27, 4–4, 4–5, 4–6, 4–7, 4–15, 4–17, 4–29, 

4–46, 5–3 

modification, S–5, S–7, S–8, S–10, 1–3, 2–15, 

2–18, 2–22, 2–23, 3–5, 4–6, 4–49, 5–3, 5–4, 

5–5 

module, 2–6 

operations, S–4, S–8, S–9, S–10, S–11, S–13, 

1–4, 1–6, 1–9, 2–1, 2–4, 2–7, 2–18, 2–23, 

2–24, 2–25, 2–29, 3–5, 3–25, 3–26, 4–2, 4–3, 

4–5, 4–6, 4–7, 4–9, 4–10, 4–11, 4–12, 4–13, 

4–14, 4–15, 4–39, 4–40, 4–44, 4–45, 4–48, 

4–49, 5–1, 5–4, 5–5 

Mercury Storage SEIS, S–1, S–4, S–14, S–15, S–16, 

1–1, 1–3, 1–5, 1–10, 2–1, 2–9, 2–14, 3–1, 4–1 

miles, S–13, 2–11, 2–17, 2–29, 3–1, 3–3, 3–4, 3–6, 

3–11, 3–12, 3–25, 3–28, 3–29, 3–30, 3–31, 

4–23, 4–40, 4–41, 4–42, 4–43

railcar, 2–7, 2–8, 2–19, 2–27, 2–28, 4–23, 4–24, 

4–25, 4–26, 4–27, 4–28, 4–29, 4–30, 4–34, 

4–37, 4–38, 4–39

truck, S–4, S–10, S–12, 1–7, 2–6, 2–7, 2–8, 2–14, 

2–18, 2–19, 2–23, 2–24, 2–26, 2–27, 2–28, 

3–27, 4–8, 4–9, 4–13, 4–22, 4–23, 4–24, 4–25, 

4–26, 4–27, 4–28, 4–29, 4–30, 4–34, 4–35, 

4–36, 4–37, 4–38, 4–40, 4–41, 4–45, 4–48

mining, S–13, 1–1, 1–4, 1–8, 2–1, 2–2, 2–4, 2–7, 

2–11, 2–17, 2–22, 3–3, 3–5, 3–11, 3–13, 3–14, 

4–3, 4–5, 4–43

MM EIS, 2–3, 4–20

Modified Mercalli Intensity (MMI), 3–12, 4–4 

mudstone, 3–9 

N 

National Ambient Air Quality Standards (NAAQS), 

3–18, 3–19

National Environmental Policy Act (NEPA), S–1, 

S–2, S–3, S–5, S–16, 1–1, 1–3, 1–7, 1–8, 1–

10, 1–11, 2–1, 2–29, 4–2, 4–42, 4–46, 5–1, 5–

2, 5–5 

National Pollutant Discharge Elimination System, 

4–5, 5–4 

National Register of Historic Places, 2–24, 3–23, 

4–12

natural gas, 1–4, 4–17

New Mexico Department of Game and Fish, 2–24, 

4–10, 5–6 

nitrate, 1–4 

nitrogen, 2–23, 3–18, 3–19, 4–8

dioxide, S–10, 2–18, 2–23, 3–18, 3–19, 4–8

No Action Alternative, S–1, S–4, S–5, S–9, 2–10, 

2–15, 2–16, 2–17, 2–19, 2–21, 4–1, 4–41, 

4–48, 4–49

noise, S–5, S–11, 1–8, 2–15, 2–23, 2–24, 3–1, 3–2, 

3–17, 3–20, 4–1, 4–7, 4–9, 4–42, 4–47

background level, S–11, 2–24, 3–19

nonhazardous waste, 3–26, 4–14, 4–15

normal operations, S–11, S–13, 2–18, 2–25, 3–20, 

3–26, 4–2, 4–15, 4–16, 4–33, 4–46, 4–47

Notice of Availability, S–4, S–14, S–15, S–16, 1–5, 

2–14

Notice of Intent (NOI), S–1, S–14, 1–7, 1–8, 2–11, 

5–1 

O 

Office Administration Area, 2–3, 2–7, 2–8 

Off-Limits Area, 2–11, 2–14, 3–3, 3–4, 3–24, 4–43

ozone, 3–18, 3–19, 3–20

P 

paleontological resource, S–11, 1–8, 2–24, 3–24, 

4–11

pallet, 2–26, 2–28, 4–16, 4–19, 4–20, 4–22, 4–25, 

4–34, 4–35, 4–36, 4–37

fire, S–7, S–8, S–12, 1–3, 2–3, 2–6, 2–27, 2–28, 

3–24, 4–16, 4–17, 4–19, 4–20, 4–22, 4–23, 

4–24, 4–25, 4–26, 4–27, 4–28, 4–29, 4–30, 

4–31, 4–34, 4–35, 4–36, 4–37, 4–38, 4–39

metal, 1–1, 2–6, 4–25

particulate matter (PM), 2–23, 3–18, 3–19, 4–8 

PM10, 3–18, 3–19, 3–20, 4–8 

PM2.5, 3–18, 3–19, 3–20, 4–8 

Pecos Valley, 3–6 

permit, 1–10, 2–6, 2–7, 2–17, 3–18, 3–20, 3–25, 

3–27, 4–5, 5–1, 5–3, 5–4, 5–5

plants, S–3, 1–1, 1–4, 2–1, 2–2, 2–7, 2–19, 2–28, 

3–2, 3–6, 3–21, 3–22, 3–23, 3–24, 4–31, 4–32, 

4–34, 4–35, 4–36, 4–37, 4–38, 4–39

pollutant, S–2, 4–8 

pollution prevention, 3–25, 5–2 

population, S–13, 2–17, 2–19, 2–29, 3–5, 3–20, 3–22, 

3–26, 3–28, 3–29, 3–30, 3–31, 3–32, 4–29, 

4–40

low-income, S–2, S–13, 2–19, 2–29, 3–28, 3–29, 

3–30, 3–31, 3–32, 4–40, 4–41

minority, 2–19, 3–29, 3–30, 3–31, 3–32

population density, 3–5, 3–20, 4–29

total population, 3–29, 3–32

Preferred Alternative, S–4, S–14, 2–14

pregnant women, 3–28

prehistoric resource, 3–22, 4–11

Prevention of Significant Deterioration (PSD), 3–20

propane, 4–17

Property Protection Area, 2–11, 3–3, 3–4, 3–5, 3–24, 

4–10

proposed action, S–2, S–3, S–4, S–5, S–13, S–14, 

1–1, 1–3, 1–5, 1–7, 1–10, 2–15, 2–30, 3–1, 

4–1, 4–42, 4–47, 5–1, 5–5 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

9–6

public hearings, S–15

public scoping meetings, S–15, 1–7 

purpose and need, 1–1, 1–2, 1–10, 2–1, 2–15

R 

radioactive waste, S–6, S–8, 1–5, 1–9, 2–9, 2–10, 

2–11, 2–17, 2–19, 3–1, 4–43

Radioactive Waste Management Complex (RWMC), 

S–6, S–8, 1–5, 2–9, 2–10, 2–17, 2–18, 2–19

railroad, 3–24, 3–28

Receiving and Shipping Area, 2–3, 2–6 

reclamation and recycling, S–3, 1–4, 2–2, 2–4, 2–7 

Record of Decision (ROD), S–4, S–14, S–16, 1–1, 

1–5, 1–9, 2–3, 2–14, 4–46

record-keeping, S–8, S–9, 2–6, 2–7, 2–8 

recreation, 3–5 

reference concentration, 4–16

region of influence (ROI), S–13, S–14, 1–8, 2–29, 

2–30, 3–2, 3–28, 4–2, 4–39, 4–40, 4–42, 4–43, 

4–44, 4–45

reptile, 3–21

residence, 3–20, 4–9 

Resource Conservation and Recovery Act (RCRA), 

S–7, S–8, S–9, 1–3, 1–6, 2–1, 2–3, 2–6, 2–8, 

2–10, 2–16, 2–17, 2–21, 2–23, 3–25, 4–6, 4–7, 

4–14, 4–46

risk assessment, 1–11, 2–19

runoff, 3–7, 3–13, 4–5, 4–41

S 

Salado Formation, 3–7, 3–8, 3–9, 3–11, 3–14, 3–15

sandstone, 3–9, 3–10, 3–14, 3–16

sanitary waste, 4–6, 4–14, 4–48, 4–49

Savannah River Site (SRS), S–1, S–6, S–13, 1–5, 

1–9, 2–9, 2–11, 2–17, 2–18, 2–19, 4–23

scoping, S–1, S–4, S–14, S–15, 1–7, 1–8, 2–11

security, S–7, S–8, S–9, 1–3, 1–4, 1–9, 1–10, 2–3, 

2–6, 2–7, 2–8, 2–10, 2–27, 3–4, 3–5, 4–3, 4–

29

sediment control, 2–22, 4–4, 4–5 

sediment-dwelling biota, 2–19, 2–28, 4–32, 4–34, 

4–35, 4–36, 4–37, 4–38, 4–39

seismic event, 2–22, 3–13, 4–16, 4–17

seismic risk, 2–17, 2–22, 2–23

seismicity, 4–4 

sensitive species, 5–5 

severity level (SL), S–2, S–11, S–12, 1–5, 2–15, 

2–18, 2–19, 2–25, 2–26, 2–27, 2–28, 4–1, 

4–15, 4–16, 4–18, 4–21, 4–22, 4–24, 4–25, 

4–26, 4–27, 4–28, 4–30, 4–32, 4–34, 4–35, 

4–36, 4–37, 4–38, 4–39

sewage, 3–14, 3–25, 4–6, 4–48

sewer, 4–48

shipment, S–4, 2–7, 2–8, 4–29, 4–41, 4–45

rail, S–4, S–10, S–12, 1–7, 2–14, 2–18, 2–19, 

2–23, 2–24, 2–26, 2–27, 3–24, 3–28, 4–8, 4–9, 

4–22, 4–23, 4–28, 4–29, 4–37

truck, S–4, S–10, S–12, 1–7, 2–6, 2–7, 2–8, 2–14, 

2–18, 2–19, 2–23, 2–24, 2–26, 2–27, 2–28, 

3–27, 4–8, 4–9, 4–13, 4–22, 4–23, 4–24, 4–25, 

4–26, 4–27, 4–28, 4–29, 4–30, 4–34, 4–35, 

4–36, 4–37, 4–38, 4–40, 4–41, 4–45, 4–48

volume, 1–4, 1–9, 1–10, 2–1, 2–6, 2–7, 2–8, 2–25, 

3–14, 3–24, 3–28, 4–2, 4–6, 4–14, 4–40, 4–41

siltstone, 3–10, 3–16

snow, 3–17, 4–16, 4–20 

socioeconomics, S–2, S–5, 1–5, 1–8, 2–15, 2–16, 

2–29, 3–1, 3–2, 3–28, 4–1, 4–2, 4–39, 4–42, 

4–43

soil, S–10, S–12, 1–1, 2–18, 2–19, 2–22, 2–27, 2–28, 

3–6, 3–10, 3–11, 3–12, 4–4, 4–5, 4–6, 4–13, 

4–31, 4–32, 4–33, 4–34, 4–35, 4–36, 4–37, 

4–38, 4–39, 4–41, 4–47

farmland, 3–5 

soil invertebrates, 2–19, 2–28, 4–31, 4–32, 4–34, 

4–35, 4–36, 4–37, 4–38, 4–39

solid waste, 1–3, 2–1, 2–25, 3–25, 4–14, 4–49, 5–2, 

5–5 

Solid Waste Disposal Act (SWDA), 1–3, 2–1, 5–2, 

5–3 

special status species, 3–21

spill, S–7, S–8, S–9, S–10, 2–3, 2–6, 2–7, 2–8, 2–23, 

2–25, 2–26, 2–27, 4–5, 4–6, 4–14, 4–16, 4–17, 

4–19, 4–20, 4–22, 4–23, 4–24, 4–25, 4–28, 

4–33, 4–34, 4–36, 4–38, 4–39

cleanup, 1–8, 4–24, 4–33, 4–41, 5–5 

containment, S–7, S–8, S–10, 2–3, 2–6, 2–23, 

4–6, 4–41

tray, 2–6, 4–16, 4–22

spill prevention, control, and countermeasures 

(SPCC) plan, S–10, 4–6 

stacked 

double-stacked, S–7, 2–6 

triple-stacked, S–7, 2–6 

State Historic Preservation Officer (SHPO), 4–11, 

4–12

Storage Area, S–7, 2–3, 2–6, 2–7, 2–8, 2–10, 2–21, 

2–23, 2–25, 4–46

stormwater, 2–22, 4–5, 5–4 

stormwater pollution prevention plan, 2–22

strontium, 3–13

sulfur dioxide, 2–23, 3–18, 3–19, 4–8 

supplemental environmental impact statement 

(SEIS), S–1, S–2, S–3, S–4, S–5, S–6, S–8, 

S–9, S–10, S–11, S–13, S–14, S–15, S–16, 

1–1, 1–2, 1–3, 1–4, 1–5, 1–6, 1–7, 1–8, 1–9, 

1–10, 2–1, 2–9, 2–11, 2–14, 2–15, 2–19, 2–21, 

2–29, 3–1, 3–13, 3–20, 3–30, 4–1, 4–2, 4–15, 

4–17, 4–21, 4–25, 4–26, 4–27, 4–29, 4–47, 

4–48, 5–1, 5–2 

surface water, 2–11, 3–2, 3–13, 4–2, 4–5, 4–6, 4–32, 

4–41, 4–46
Index 

9–7

T 

temperature, 1–1, 3–17, 4–25, 4–46

terrestrial, S–14, 2–24, 2–30, 3–21, 4–10, 4–45

plants, S–3, 1–1, 1–4, 2–1, 2–2, 2–7, 2–19, 2–28, 

3–2, 3–6, 3–21, 3–22, 3–23, 3–24, 4–31, 4–32, 

4–34, 4–35, 4–36, 4–37, 4–38, 4–39

threatened and/or endangered species, 1–8, 2–24, 

3–21, 4–10, 4–45, 5–5 

threshold limit value (TLV), 2–8, 4–15, 4–30

tornado, 3–17, 4–17, 4–18

toxic air pollutant, 2–18, 2–23, 4–7 

Toxic Substances Control Act (TSCA), 3–27, 5–2 

traffic, S–13, 2–24, 2–29, 3–20, 3–24, 3–27, 3–28, 

4–9, 4–12, 4–13, 4–40, 4–42, 4–47

transient, 4–40

transmission line, 3–24

transportation, S–4, S–5, S–9, S–12, 1–6, 1–8, 1–9, 

2–3, 2–7, 2–8, 2–16, 2–18, 2–19, 2–21, 2–23, 

2–24, 2–25, 2–26, 2–27, 2–28, 2–29, 3–2, 

3–26, 3–27, 4–2, 4–8, 4–15, 4–20, 4–22, 4–23, 

4–24, 4–25, 4–26, 4–27, 4–28, 4–29, 4–33, 

4–40, 4–42, 4–44, 4–45, 4–47, 4–49

air, S–2, S–5, S–10, S–13, S–14, 1–6, 1–8, 1–10, 

2–7, 2–8, 2–16, 2–18, 2–23, 2–29, 2–30, 3–1, 

3–2, 3–17, 3–18, 3–20, 3–26, 4–1, 4–7, 4–8, 

4–9, 4–15, 4–17, 4–18, 4–21, 4–25, 4–41, 

4–43, 4–44, 4–46, 4–48, 5–2, 5–3, 5–4, 5–5 

ground, 3–24, 4–12, 4–13

impact, S–5, S–12, 1–6, 2–19, 2–27, 2–28, 4–40

local, 3–28

rail, S–4, S–10, S–12, 1–7, 2–14, 2–18, 2–19, 

2–23, 2–24, 2–26, 2–27, 3–24, 3–28, 4–8, 4–9, 

4–22, 4–23, 4–28, 4–29, 4–37

route, 1–6, 2–19, 3–27, 4–23, 4–24, 4–27, 4–29, 

4–33

truck, S–4, S–10, S–12, 1–7, 2–6, 2–7, 2–8, 2–14, 

2–18, 2–19, 2–23, 2–24, 2–26, 2–27, 2–28, 

3–27, 4–8, 4–9, 4–13, 4–22, 4–23, 4–24, 4–25, 

4–26, 4–27, 4–28, 4–29, 4–30, 4–34, 4–35, 

4–36, 4–37, 4–38, 4–40, 4–41, 4–45, 4–48

transuranic (TRU) waste, S–2, S–6, S–13, 1–5, 1–8, 

1–9, 2–10, 2–11, 3–2, 3–25, 3–26, 3–27, 4–2, 

4–45, 5–3, 5–4 

treatment, storage, and disposal (TSD) facilities, 

4–41, 4–46, 5–3 

U 

U.S. Bureau of Land Management (BLM), S–1, 1–1, 

2–17, 2–22, 3–5, 3–6, 3–21, 3–22, 3–23, 3–24, 

3–28, 4–3, 4–10, 4–12, 4–43, 5–2, 5–3 

U.S. Department of Defense (DoD), 2–3, 2–10, 2–17

U.S. Department of Transportation (DOT), 2–4 

U.S. Environmental Protection Agency (EPA), S–1, 

S–4, S–11, S–14, S–16, 1–1, 1–2, 1–3, 1–4, 

1–5, 2–1, 2–2, 2–14, 3–16, 3–18, 3–19, 3–20, 

3–27, 4–2, 4–5, 4–8, 4–16, 4–28, 4–41, 4–48, 

5–1, 5–2, 5–3 

U.S. Fish and Wildlife Service (USFWS), 2–24, 

3–22, 4–10, 5–6 

U.S. Geological Survey (USGS), 1–2, 2–2, 3–12, 

3–13, 4–17

uncertainty, S–12, 1–3, 1–4, 2–1, 2–6, 2–18, 2–19, 

2–27, 4–2, 4–24, 4–25, 4–28, 4–33, 4–34, 

4–36, 4–38, 4–39, 5–3 

unemployment, 3–28

utility resource, 2–24, 4–48

V 

vegetation, 3–7 

nonnative, 3–21

ventilation, S–8, 2–6, 4–13, 4–15

viewshed, 4–3 

Visual Resource Management (VRM), 3–5, 3–6 

visual resources, S–5, S–10, 1–8, 2–15, 2–16, 2–18, 

2–22, 3–1, 3–2, 3–5, 4–1, 4–3, 4–42, 4–43

volatile organic compound (VOC), 2–23, 3–18, 3–20, 

3–27, 4–8

W

waste acceptance criteria, 2–3, 2–8, 3–26

waste activities 

characterization, 2–10

classification, 1–9 

generation, 2–2, 2–18, 2–25, 4–14, 4–15, 4–47, 

4–48

inventories, 1–2, 2–4, 2–7, 4–29

remediation, 2–10

Waste Control Specialists, LLC (WCS), S–1, S–6, 

S–8, S–13, S–14, 1–5, 2–9, 2–11, 2–14, 2–17, 

2–18, 2–19

Waste Isolation Pilot Plant (WIPP), S–1, S–4, S–5, 

S–6, S–8, S–9, S–10, S–11, S–12, S–13, S–14, 

S–15, S–17, 1–5, 1–6, 1–7, 1–8, 1–9, 1–10, 

2–9, 2–11, 2–12, 2–13, 2–14, 2–17, 2–18, 

2–19, 2–21, 2–22, 2–23, 2–24, 2–25, 2–26, 

2–27, 2–29, 2–30, 3–1, 3–2, 3–3, 3–4, 3–5, 

3–6, 3–7, 3–8, 3–9, 3–10, 3–11, 3–12, 3–13, 

3–14, 3–15, 3–16, 3–17, 3–18, 3–19, 3–20, 

3–21, 3–22, 3–23, 3–24, 3–25, 3–26, 3–27, 

3–28, 3–29, 3–30, 3–31, 3–32, 3–33, 4–1, 4–2, 

4–3, 4–4, 4–5, 4–6, 4–7, 4–8, 4–9, 4–10, 4–11, 

4–12, 4–13, 4–14, 4–15, 4–16, 4–17, 4–18, 

4–21, 4–22, 4–23, 4–24, 4–25, 4–27, 4–28, 

4–29, 4–31, 4–39, 4–40, 4–41, 4–42, 4–43, 

4–44, 4–45, 5–1, 5–3, 5–4, 5–5, 5–6 

Waste Isolation Pilot Plant Land Withdrawal Act 

(WIPP LWA), S–6, 2–11, 2–17, 2–22, 3–2, 

4–2, 4–3, 5–1, 5–3 

water, S–2, S–5, S–10, S–11, S–12, 1–1, 1–6, 1–8, 

1–10, 2–6, 2–15, 2–17, 2–18, 2–19, 2–22, 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

9–8

2–23, 2–24, 2–25, 2–27, 3–1, 3–2, 3–7, 3–9, 

3–12, 3–13, 3–14, 3–15, 3–16, 3–22, 3–24, 

3–25, 3–26, 4–1, 4–4, 4–5, 4–6, 4–7, 4–12, 

4–13, 4–14, 4–22, 4–24, 4–25, 4–28, 4–30, 

4–32, 4–33, 4–41, 4–43, 4–45, 4–47, 4–48, 

4–49, 5–2, 5–3, 5–4, 5–5 

potable, 3–14, 4–13, 4–45

raw, 4–13

resource, S–5, 1–8, 1–10, 2–15, 2–22, 3–1, 3–2, 

3–13, 4–1, 4–5, 4–42, 4–43

table, 3–13

use, 3–25, 4–6, 4–13, 4–28, 4–45, 4–47

wetland, 4–33

windspeed, 4–21, 4–24, 4–25, 4–26, 4–27, 4–30, 

4–31, 4–34, 4–36, 4–38, 4–39

WIPP Vicinity Section 10, S–5, S–6, S–14, 1–8, 2–9, 

2–11, 2–14, 2–19, 2–22, 2–24, 2–25, 2–27, 

2–29, 2–30, 3–11, 3–22, 3–30, 4–3, 4–4, 4–5, 

4–7, 4–8, 4–9, 4–10, 4–11, 4–12, 4–13, 4–14, 

4–15, 4–21, 4–29, 4–31, 4–39, 4–40, 4–43, 

5–1 

WIPP Vicinity Section 20, S–5, S–6, 2–9, 2–11, 

2–14, 2–22, 2–24, 2–25, 2–29, 3–22, 3–31, 

4–3, 4–5, 4–6, 4–9, 4–10, 4–11, 4–13, 4–14, 

4–31, 4–39, 4–40, 5–1 

WIPP Vicinity Section 35, S–5, S–6, S–14, 1–8, 2–9, 

2–11, 2–14, 2–22, 2–24, 2–25, 2–29, 2–30, 

3–5, 3–7, 3–11, 3–22, 3–32, 4–3, 4–5, 4–7, 

4–9, 4–10, 4–12, 4–13, 4–15, 4–31, 4–39, 

4–40, 4–41, 4–43, 5–1 

wood, 4–25, 4–49

worker, 2–7, 3–26, 3–27, 4–3, 4–15

involved, 2–18, 2–25, 2–26, 4–15, 4–18, 4–22

noninvolved, S–12, 2–18, 2–25, 2–26, 4–7, 4–16, 

4–21, 4–22, 4–31

Y 

Y–12 National Security Complex (Y–12), S–3, S–5, 

S–9, 1–3, 1–4, 1–6, 1–10, 2–1, 2–4, 2–7, 2–10, 

2–16, 2–21, 4–17, 4–48, 4–49
APPENDIX A 

THE MERCURY EXPORT BAN ACT OF 2008 

AND FEDERAL REGISTER NOTICES 

APPENDIX A
 

THE MERCURY EXPORT BAN ACT OF 2008
 

AND FEDERAL REGISTER NOTICES
 

 

 

 

 

 

This appendix provides a copy of the Mercury Export Ban Act of 2008 and Federal Register notices 

associated with this Draft Long-Term Management and Storage of Elemental Mercury Supplemental 

Environmental Impact Statement. Federal Register notices and other public notices associated with 

the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact 

Statement (Mercury Storage EIS) are provided in Appendix A of the January 2011 Mercury Storage 

EIS and have not been reproduced here. 

A–1 
u.s. AUTHENTICATE INFORMATION 

GOVERNMENT ~ 

GPO 

A.1 PUBLIC LAW 110-414: MERCURY EXPORT BAN ACT—OCTOBER 14, 2008
 

PUBLIC LAW 1l0--414-0CT. 14,2008 122 STAT. 4341 

Public Law 110--414 

110th Congress 

An Act 

To prohibit the sale, distribution, transfer, and export of elemental mercury, and Oct. 14, 2008 

for other purposes. [S.906] 

Be it enacted by the Senate and House of Representatives of 

the United States of America in Congress assembled, Mercury Export 

Ban Act of 2008. 

SECTION 1. SHORT TITLE. 15 USC 2601 

note. This Act may be cited as the "Mercury Export Ban Act of 

2008". 

SEC. 2. FINDINGS. 15 USC 2611 

note. Congress finds that-

(1) mercury is highly toxic to humans, ecosystems, and 

wildlife; 

(2) as many as 10 percent of women in the United States 

of childbearing age have mercury in the blood at a level that 

could put a baby at risk; 

(3) as many as 630,000 children born annually in the 

United States are at risk of neurological problems related to 

mercury; 

(4) the most significant source of mercury exposure to 

people in the United States is ingestion of mercury-contaminated fish; 

(5) the Environmental Protection Agency reports that, as 

of 2004-

(A) 44 States have fish advisories covering over 

13,000,000 lake acres and over 750,000 river miles; 

(B) in 21 States the freshwater advisories are statewide; and 

(C) in 12 States the coastal advisories are statewide; 

(6) the long-term solution to mercury pollution is to minimize global mercury use and releases to eventually achieve 

reduced contamination levels in the environment, rather than 

reducing fish consumption since uncontaminated fish represents a critical and healthy source of nutrition worldwide; 

(7) mercury pollution is a transboundary pollutant, depositing locally, regionally, and globally, and affecting water bodies 

near industrial sources (including the Great Lakes) and remote 

areas (including the Arctic Circle); 

(8) the free trade of elemental mercury on the world 

market, at relatively low prices and in ready supply, encourages 

the continued use of elemental mercury outside of the United 

States, often involving highly dispersive activities such as 

artisinal gold mining; 

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

A–2 
 

122 STAT. 4342 PUBLIC LAW 1l0--414-0CT. 14, 2008 

(9) the intentional use of mercury is declining in the United 

States as a consequence of process changes to manufactured 

products (including batteries, paints, switches, and measuring 

devices), but those uses remain substantial in the developing 

world where releases from the products are extremely likely 

due to the limited pollution control and waste management 

infrastructures in those countries; 

(10) the member countries of the European Union collectively are the largest source of elemental mercury exports globally; 

(11) the European Commission has proposed to the European Parliament and to the Council of the European Union 

a regulation to ban exports of elemental mercury from the 

European Union by 2011; 

(12) the United States is a net exporter of elemental mercury and, according to the United States Geological Survey, 

exported 506 metric tons of elemental mercury more than the 

United States imported during the period of 2000 through 

2004; and 

(13) banning exports of elemental mercury from the United 

States will have a notable effect on the market availability 

of elemental mercury and switching to affordable mercury alternatives in the developing world. 

SEC. 3. PROHIBITION ON SALE, DISTRIBUTION, OR TRANSFER OF ELEMENTAL MERCURY. 

Section 6 of the Toxic Substances Control Act (15 U.S.C. 2605) 

is amended by adding at the end the following: 

"(t) MERCURY.-

"(1) PROHIBITION ON SALE, DISTRIBUTION, OR TRANSFER OF 

Effective date. ELEMENTAL MERCURY BY FEDERAL AGENCIES.-Except as provided in paragraph (2), effective beginning on the date of enactment of this subsection, no Federal agency shall convey, sell, 

or distribute to any other Federal agency, any State or local 

government agency, or any private individual or entity any 

elemental mercury under the control or jurisdiction of the Federal agency. 

"(2) EXCEPTIONS.-Paragraph (1) shall not apply to-

"(A) a transfer between Federal agencies of elemental 

mercury for the sole purpose of facilitating storage of mercury to carry out this Act; or 

"CB) a conveyance, sale, distribution, or transfer of 

coal. 

"(3) LEASES OF FEDERAL COAL.-Nothing in this subsection 

prohibits the leasing of coal.". 

SEC. 4. PROHIBITION ON EXPORT OF ELEMENTAL MERCURY. 

Section 12 of the Toxic Substances Control Act (15 U.S.C. 

2611) is amended-

(1) in subsection (a) by striking "subsection (b)" and 

inserting "subsections (b) and (c)"; and 

(2) by adding at the end the following: 

"(c) PROHIBITION ON EXPORT OF ELEMENTAL MERCURY.-

Effective date. "(1) PROHIBITION.-Effective January 1, 2013, the export 

of elemental mercury from the United States is prohibited. 

"(2) INAPPLICABILITY OF SUBSECTION (a).-Subsection (a) 

shall not apply to this subsection. 

"(3) REPORT TO CONGRESS ON MERCURY COMPOUNDS.-

The Mercury Export Ban Act of 2008 and Federal Register Notices 

A–3 
PUBLIC LAW 1l0--414-0CT. 14, 2008 122 STAT. 4343 

"(A) REPORT.-Not later than one year after the date Publication. 

of enactment of the Mercury Export Ban Act of 2008, 

the Administrator shall publish and submit to Congress 

a report on mercuric chloride, mercurous chloride or calomel, mercuric oxide, and other mercury compounds, if 

any, that may currently be used in significant quantities 

in products or processes. Such report shall include an analysis of-

"(i) the sources and amounts of each of the mercury 

compounds imported into the United States or manufactured in the United States annually; 

"(ii) the purposes for which each of these compounds are used domestically, the amount of these 

compounds currently consumed annually for each purpose, and the estimated amounts to be consumed for 

each purpose in 2010 and beyond; 

"(iii) the sources and amounts of each mercury 

compound exported from the United States annually 

in each of the last three years; 

"(iv) the potential for these compounds to be processed into elemental mercury after export from the 

United States; and 

"Cv) other relevant information that Congress 

should consider in determining whether to extend the 

export prohibition to include one or more of these mercury compounds. 

"(B) PROCEDURE.-For the purpose of preparing the 

report under this paragraph, the Administrator may utilize 

the information gathering authorities of this title, including 

sections 10 and 11. 

"(4) ESSENTIAL USE EXEMPTION.--{A) Any person residing 

in the United States may petition the Administrator for an 

exemption from the prohibition in paragraph (1), and the 

Administrator may grant by rule, after notice and opportunity 

for comment, an exemption for a specified use at an identified 

foreign facility if the Administrator finds that-

"(i) nonmercury alternatives for the specified use are 

not available in the country where the facility is located; 

"(ii) there is no other source of elemental mercury 

available from domestic supplies (not including new mercury mines) in the country where the elemental mercury 

will be used; 

"(iii) the country where the elemental mercury will 

be used certifies its support for the exemption; 

"(iv) the export will be conducted in such a manner 

as to ensure the elemental mercury will be used at the 

identified facility as described in the petition, and not 

otherwise diverted for other uses for any reason; 

"(v) the elemental mercury will be used in a manner 

that will protect human health and the environment, taking 

into account local, regional, and global human health and 

environmental impacts; 

"(vi) the elemental mercury will be handled and managed in a manner that will protect human health and 

the environment, taking into account local, regional, and 

global human health and environmental impacts; and 

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

A–4 
 

122 STAT. 4344 PUBLIC LAW 1l0--414-0CT. 14, 2008 

"(vii) the export of elemental mercury for the specified 

use is consistent with international obligations of the 

United States intended to reduce global mercury supply, 

use, and pollution. 

"(B) Each exemption issued by the Administrator pursuant 

to this paragraph shall contain such terms and conditions as 

are necessary to minimize the export of elemental mercury 

and ensure that the conditions for granting the exemption 

will be fully met, and shall contain such other terms and 

conditions as the Administrator may prescribe. No exemption 

granted pursuant to this paragraph shall exceed three years 

in duration and no such exemption shall exceed 10 metric 

tons of elemental mercury. 

"(C) The Administrator may by order suspend or cancel 

an exemption under this paragraph in the case of a violation 

described in subparagraph (D). 

"(D) A violation of this subsection or the terms and conditions of an exemption, or the submission of false information 

in connection therewith, shall be considered a prohibited act 

under section 15, and shall be subject to penalties under section 

16, injunctive relief under section 17, and citizen suits under 

section 20. 

"(5) CONSISTENCY WITH TRADE OBLIGATIONS.-Nothing in 

this subsection affects, replaces, or amends prior law relating 

to the need for consistency with international trade obligations. 

"(6) EXPORT OF COAL.-Nothing in this subsection shall 

be construed to prohibit the export of coal.". 

Deadline. SEC. 5. LONG-TERM STORAGE. 

42 USC 6939f. (a) DESIGNATION OF FACILITY.-

(1) IN GENERAL.-Not later than January 1, 2010, the Secretary of Energy (referred to in this section as the "Secretary") 

shall designate a facility or facilities of the Department of 

Energy, which shall not include the Y -12 National Security 

Complex or any other portion or facility of the Oak Ridge 

Reservation of the Department of Energy, for the purpose of 

long-term management and storage of elemental mercury generated within the United States. 

(2) OPERATION OF FACILITY.-Not later than January 1, 

2013, the facility designated in paragraph (1) shall be operational and shall accept custody, for the purpose of long-term 

management and storage, of elemental mercury generated 

within the United States and delivered to such facility. 

(b) FEES.-

(1) IN GENERAL.-After consultation with persons who are 

likely to deliver elemental mercury to a designated facility 

for long-term management and storage under the program prescribed in subsection (a), and with other interested persons, 

the Secretary shall assess and collect a fee at the time of 

delivery for providing such management and storage, based 

on the pro rata cost of long-term management and storage 

of elemental mercury delivered to the facility. The amount 

of such feesPublic (A) shall be made public ally available not later than 

information. October 1, 2012; 

(B) may be adjusted annually; and 

The Mercury Export Ban Act of 2008 and Federal Register Notices 

A–5 
PUBLIC LAW 1l0--414-0CT. 14, 2008 122 STAT. 4345 

(C) shall be set in an amount sufficient to cover the 

costs described in paragraph (2). 

(2) CosTs.-The costs referred to in paragraph (l)(C) are 

the costs to the Department of Energy of providing such 

management and storage, including facility operation and 

maintenance, security, monitoring, reporting, personnel, 

administration, inspections, training, fire suppression, closure, 

and other costs required for compliance with applicable law. 

Such costs shall not include costs associated with land acquisition or permitting of a designated facility under the Solid 

Waste Disposal Act or other applicable law. Building design 

and building construction costs shall only be included to the 

extent that the Secretary finds that the management and storage of elemental mercury accepted under the program under 

this section cannot be accomplished without construction of 

a new building or buildings. 

(c) REPORT.-Not later than 60 days after the end of each 

Federal fiscal year, the Secretary shall transmit to the Committee 

on Energy and Commerce of the House of Representatives and 

the Committee on Environment and Public Works of the Senate 

a report on all of the costs incurred in the previous fiscal year 

associated with the long-term management and storage of elemental 

mercury. Such report shall set forth separately the costs associated 

with activities taken under this section. 

(d) MANAGEMENT STANDARDS FOR A FACILITY.-

(1) GUIDANCE.-Not later than October 1, 2009, the Sec- Procedures. 

retary, after consultation with the Administrator of the Standards. 

Environmental Protection Agency and all appropriate State 

agencies in affected States, shall make available, including 

to potential users of the long-term management and storage 

program established under subsection (a), guidance that establishes procedures and standards for the receipt, management, 

and long-term storage of elemental mercury at a designated 

facility or facilities, including requirements to ensure appropriate use of flasks or other suitable shipping containers. Such 

procedures and standards shall be protective of human health 

and the environment and shall ensure that the elemental mercury is stored in a safe, secure, and effective manner. In addition to such procedures and standards, elemental mercury managed and stored under this section at a designated facility 

shall be subject to the requirements of the Solid Waste Disposal 

Act, including the requirements of subtitle C of that Act, except 

as provided in subsection (g)(2) of this section. A designated 

facility in existence on or before January 1, 2013, is authorized 

to operate under interim status pursuant to section 3005( e) 

of the Solid Waste Disposal Act until a final decision on a 

permit application is made pursuant to section 3005(c) of the 

Solid Waste Disposal Act. Not later than January 1, 2015, Deadline. 

the Administrator of the Environmental Protection Agency (or 

an authorized State) shall issue a final decision on the permit 

application. 

(2) TRAINING.-The Secretary shall conduct operational 

training and emergency training for all staff that have responsibilities related to elemental mercury management, transfer, 

storage, monitoring, or response. 

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

A–6 
 

122 STAT. 4346 PUBLIC LAW 1l0--414-0CT. 14, 2008 

(3) EQUIPMENT.-The Secretary shall ensure that each designated facility has all equipment necessary for routine operations, emergencies, monitoring, checking inventory, loading, 

and storing elemental mercury at the facility. 

(4) FIRE DETECTION AND SUPPRESSION SYSTEMS.-The Secretary shall-

(A) ensure the installation of fire detection systems 

at each designated facility, including smoke detectors and 

heat detectors; and 

(B) ensure the installation of a permanent fire suppression system, unless the Secretary determines that a permanent fire suppression system is not necessary to protect 

human health and the environment. 

(e) INDEMNIFICATION OF PERSONS DELIVERING ELEMENTAL MERCURY.-

(1) IN GENERAL.--{A) Except as provided in subparagraph 

(B) and subject to paragraph (2), the Secretary shall hold harmless, defend, and indemnifY in full any person who delivers 

elemental mercury to a designated facility under the program 

established under subsection (a) from and against any suit, 

claim, demand or action, liability, judgment, cost, or other 

fee arising out of any claim for personal injury or property 

damage (including death, illness, or loss of or damage to property or economic loss) that results from, or is in any manner 

predicated upon, the release or threatened release of elemental 

mercury as a result of acts or omissions occurring after such 

mercury is delivered to a designated facility descnbed in subsection (a). 

(B) To the extent that a person described in subparagraph 

(A) contributed to any such release or threatened release, 

subparagraph (A) shall not apply. 

Records. (2) CONDITIONS.-No indemnification may be afforded 

under this subsection unless the person seeking indemnificationNotification. (A) notifies the Secretary in writing within 30 days 

Deadline. after receiving written notice of the claim for which indemnification is sought; 

(B) furnishes to the Secretary copies of pertinent 

papers the person receives; 

(C) furnishes evidence or proof of any claim, loss, or 

damage covered by this subsection; and 

(D) provides, upon request by the Secretary, access 

to the records and personnel of the person for purposes 

of defending or settling the claim or action. 

(3) AUTHORITY OF SECRETARY.-(A) In any case in which 

the Secretary determines that the Department of Energy may 

be required to make indemnification payments to a person 

under this subsection for any suit, claim, demand or action, 

liability, judgment, cost, or other fee arising out of any claim 

for personal mjury or property damage referred to in paragraph 

(l)(A), the Secretary may settle or defend, on behalf of that 

person, the claim for personal injury or property damage. 

(B) In any case described in subparagraph (A), if the person 

to whom the Department of Energy may be required to make 

indemnification payments does not allow the Secretary to settle 

or defend the claim, the person may not be afforded indemnification with respect to that claim under this subsection. 

The Mercury Export Ban Act of 2008 and Federal Register Notices 

A–7 
PUBLIC LAW 1l0--414-0CT. 14, 2008 122 STAT. 4347 

(I) TERMS, CONDITIONS, AND PROCEDURES.-The Secretary is 

authorized to establish such terms, conditions, and procedures as 

are necessary to carry out this section. 

(g) EFFECT ON OTHER LAW.-

(1) IN GENERAL.-Except as provided in paragraph (2), 

nothing in this section changes or affects any Federal, State, 

or local law or the obligation of any person to comply with 

such law. 

(2) EXCEPrION.-(A) Elemental mercury that the Secretary 

is storing on a long-term basis shall not be subject to the 

storage prohibition of section 3004(j) of the Solid Waste Disposal 

Act (42 U.S.C. 6924(j)). For the purposes of section 3004(j) 

of the Solid Waste Disposal Act, a €(enerator accumulating 

elemental mercury destined for a facIlity designated by the 

Secretary under subsection (a) for 90 days or less shall be 

deemed to be accumulating the mercury to facilitate proper 

treatment, recovery, or disposal. 

(B) Elemental mercury may be stored at a facility with Certification. 

respect to which any permit has been issued under section 

3005(c) of the Solid Waste Disposal Act (42 U.S.C. 6925(c)), 

and shall not be subject to the storage prohibition of section 

3004(j) of the Solid Waste Disposal Act (42 U.S.C. 6924(j)) 

if-

(i) the Secretary is unable to accept the mercury at 

a facility designated by the Secretary under subsection 

(a) for reasons beyond the control of the owner or operator 

of the permitted facility; 

(ii) the owner or operator of the permitted facility 

certifies in writing to the Secretary that it will ship the 

mercury to the designated facility when the Secretary is 

able to accept the mercury; and 

(iii) the owner or operator of the permitted facility 

certifies in writing to the Secretary that it will not sell, 

or otherwise place into commerce, the mercury. 

This subparagraph shall not apply to mercury with respect 

to which the owner or operator of the permitted facility fails 

to comply with a certification provided under clause (ii) or 

(iii). 

(h) STUDY.-Not later than July 1, 2014, the Secretary shall Deadline. 

transmit to the Congress the results of a study, conducted in consultation with the Administrator of the Environmental Protection 

Agency, that-

(1) determines the impact of the long-term storage program 

under this section on mercury recycling; and 

(2) includes proposals, if necessary, to mitigate any negative 

impact identified under paragraph (1). 

SEC. 6. REPORT TO CONGRESS. 

At least 3 years after the effective date of the prohibition 

on export of elemental mercury under section 12(c) of the Toxic 

Substances Control Act (15 U.S.C. 2611(c)), as added by section 

4 of this Act, but not later than January 1, 2017, the Administrator 

of the Environmental Protection Agency shall transmit to the Committee on Energy and Commerce of the House of Representatives 

and the Committee on Environment and Public Works of the Senate 

a report on the global supply and trade of elemental mercury, 

including but not limited to the amount of elemental mercury 

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

A–8 
 

122 STAT. 4348 PUBLIC LAW 1l0--414-0CT. 14, 2008 

traded globally that originates from primary mining, where such 

primary mining is conducted, and whether additional primary 

mining has occurred as a consequence of this Act. 

Approved October 14,2008. 

LEGISLATIvE HISTORY-S. 906: 

SENATE REPORTS: No. 110-477 (Comm. on Environment and Public Works). 

CONGRESSIONAL RECORD, vol. 154 (2008): 

Sept. 26, considered and passed Senate. 

Sept. 27,29, considered and passed House. 

The Mercury Export Ban Act of 2008 and Federal Register Notices 

A–9 
A.2 NOTICE OF INTENT TO PREPARE A SUPPLEMENTAL ENVIRONMENTAL 

IMPACT STATEMENT FOR THE LONG-TERM MANAGEMENT AND 

STORAGE OF ELEMENTAL MERCURY (77 FR 33204, JUNE 5, 2012) 

33204 Federal Register /Vol. 77, No. lOB /Tuesday, June 5, 2012/Notices 

20202. Email: equitycommission@ed. 

gov. Telephone: (202) 453-6567. 

John DiPaolo, 

Chief of Staff, Assistant Secretary for Civil 

Rights. Office forCivif Rights. 

[FR Doc. 2012-13499 Filed 6-4-12: 8:45 am i 

BILLING CODE 4QOO-Ol-P 

DEPARTMENT OF ENERGY 

Notice of Intent To Prepare a 

Supplemental Environmental Impact 

Statement for the Long-Term 

Management and Storage of Elemental 

Mercury 

AGENCY: Department of Energy. 

ACTION: Notice of intent. 

SUMMARY: As required by the Mercury 

Export Ban Act of 2008 (the Act), the 

De partment of Energy (DOE) plans to 

identify a facility or faci li ties for the 

long-term management ond storage of 

elemental mercury generated in the 

United States. To this end, DOE intends 

to pre pare a supplement to the January 

201 1 Environmental Impact Statement 

for the Long-Term Management and 

Storage of Elemental Mercwy to anolyze 

odditional alternatives, in accordance 

with the Notional Environmental Policy 

Act (NEPA). This supplemental EIS 

(SEIS) will evaluate alternatives for a 

facility at and in the vicinity ofthe 

Waste Isolation Pilot Plant (WIPP) near 

Carlsbad, New Mexico. 

DATES: DOE invites public comment on 

the scope ofthis SEIS until July 5, 2012. 

The first scoping meeting will be held 

on June 26, 2012, from 5:30 p.m.-8 p.m.,

at the Skeen-Whit lock Buildi ng 

auditori um at the U.S. DOE, Carlsbad 

Field Office, 4021 National Parks 

Highway, Carlsbad, New Mexico 88220. 

An open house will be held on the same 

day at the same location from 4:30 p.m.-

5:30 p.m. A second scoping meeting 

will be held on June 28, 2012, from 6 

p.m.-8:30 p.m. at the Crowne Plaza 

Albuquerque, 1901 University Blvd. 

NE., Albuquerque, New Mexico 87102. 

An open house will be he ld on the same 

day at the same location from 4:30 p.m.-

6p.m. 

ADDRESSES: Written comments on the 

scope of the SEIS should be sent to: Mr. 

David Levenstein, Document Manager, 

Office of Environmental Compliance 

(EM-11J. U.S. Department of Energy, 

Post Office Box 2612, Germantown, 

Maryland 20874; to the Mercury Storage 

EIS Web site at http:// 

mercurystorageeis.com/; or via email to 

David.Levenstein@em.doe.gov. 

This Notice will be available on the 

Internet at http://www.energy.gov/ 

NEPA/ and on the project Web site at 

http://mercurystorageei s. com/. 

FOR FURTHER INFORMATION CONTACT: To 

request fu rther information about the 

SEIS or the Mercury Storage EIS, or to 

be placed on the SEIS distribution list, 

use any of the methods (mail, Web site, 

or email) listed under ADDRESSES above. 

In requesting a copy of the Draft SElS, 

please specify a request for a paper copy 

of the Summary only; a paper copy of 

the full SElS; the full SElS on a 

computer CD; or any combination 

thereof. 

For general information concerning 

DOE's NEPA process, please contact: 

Ms. Carol M. Borgstrom, Director, Office 

ofNEPA Poli cy and Compliance (GC54). U.S. Department of Energy, 1000 

Independence Avenue SW., 

Washi ngton, DC 20585, either by 

telephone at (202) 586-4600, by fax at 

(202) 586-7031, or leave a message at 1-

800-472-2756. 

SUPPLEMENTARY INFORMATION: 

Background 

The Mercury Export Ban Act of 2008 

(Pub. L. 110-414) amends the Toxic 

Substances Control Act (TSCA) (15 

U.S.c. 2605(f)) to prohibit the sa le, 

distribution, or transfer by Federal 

agencies to any other Federa l agency, 

any state or local government agency, or 

any private individual or entity, of any 

elemental mercury under the control or 

jurisdiction of a Federal agency (with 

certain limited exceptions). It also 

amends TSCA (15 U.S.c. 2611(c)) to 

prohibit the export of elemental 

mercury from the U.S. effective January 

1, 2013 (subject to certain essential use 

exemptions). Section 5 of the Act, LongTerm Storage, directs DOE to designate 

a facility or facilities for the long-t erm 

management and storage of elemental 

mercury generated within the U.S. 

Pursuant to this law, th is facility is 

required to be operational and ready to 

accept custody of any elemental 

mercury generated within th e U.S. by 

January 1, 2013. The Act also requires 

DOE to assess fees based upon the pro 

rata costs of long-term management and 

storage of elementa l mercury delivered 

to the facility or faci lities. 

The sources of elemental mercury in 

the U.S. include mercury used in the 

chlorine and caustic soda 

manufacturing process (i.e., chlor-alkali 

industry), reclaimed from recycling and 

waste recovery activities, and generated 

as a byproduct ofthe gold mining 

process. In addition, DOE's National 

Nuclear Security Administration stores 

approximately 1,200 metric tons of 

elemental mercury at the Oak Ridge 

Reservation in Tennessee. 

To evaluate the range of reasonable 

alternatives for siting, constructing and 

operating a faci lity or facilities to meet 

its obligations under the Act, DOE 

prepared the Mercury Storage EIS (DOEI 

EIS-{)423) in accordance with NEPA 

and its implementing regulations (40 

CFR parts 1500-1508 and 10 CFR part 

1021) and issued the Mercury Storage 

Final EIS in January 2011 (76 FR 5156). 

DOE estimated that up to approximate ly 

10,000 metric tons of elemental mercury 

would need to be managed and stored 

at the DOE facility during the 40-year 

period of analysis. These estimates do 

not incl ude approximately 4,400 metric 

tons of elemental mercury that the 

Department of Defense (DOD) stores at 

its facility in Hawthorne, Nevada. 

Purpose and Need for Action 

As indicated in the Mercury Storage 

EIS, DOE needs to designate a facility 

for the long-term management and 

storage of elemental mercury generated 

within the U.S., as required by the Act. 

Proposed Action 

As also indicated in the Mercury 

Storage EIS, DOE proposes to construct 

one or more new facilities andlor se lect 

one or more existing fa cilities (including 

modi fic ation as needed) for the longterm management and storage of 

elemental mercury in accordance with 

the Act. Facilities to be constructed as 

well as existing or modified facilities 

must comply with applicable 

requirements of section 5(d) ofthe Act, 

Management Standards for a Facility, 

includi ng the req uirements of the Solid 

Waste Disposal Act as amended by the 

Resource Conservation and Recovery 

Act (42 U.S.c. 6901 et seq.), and other 

permitting requirements. 

Proposed Alternatives 

The Mercury Storage EIS evaluated 

seven candidate locations for the 

elemental mercury storage facility, as 

we ll as the No Action Alte rnative. 

Those candidate locations are: DOE 

Grand Junction Disposal site near Grand 

Junction, Colorado; DOE Hanford site 

near Richland, Washington; Hawthorne 

Army Depot near Hawthorne, Nevada; 

DOE Idaho National Laboratory near 

Idaho Falls, Idaho: DOE Kansas City 

Plant in Ka nsas City, Missouri; DOE 

Savannah River Site near Aiken, South 

Carolina; and Waste Control Specialists, 

LLC, site near Andrews, Texas. 

Since publication of the Final 

Mercury Storage EIS, DOE has 

reconsidered the range of reasonable 

alternatives evaluated in that EIS. 

Accordingly, DOE now proposes to 

evaluate two additional locations for a 

long-term mercury storage facility, both 

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

A–10 
 

Federal Register /Vol. 77, No. l OB/Tuesday, June 5, 2012/Notices 33205 

near the Waste Isolation Pilot Plant 

(WIPP), which DOE operates for 

d isposal of defe nse tronsuranic woste. 

One of the odditionollocotions to be 

evaluated is in Section 20, Township 22 

South, Range 31 East within the land 

subject to the WIPP Land Withdrawal 

Act (Pub. L. 102-579) as ame nded (Act), 

ocross the WIPP access road from the 

WIPP faci lity. The second is in the 

vicinity ofWIPP, but outside of the 

lands withdrawn by the Act, in Section 

10, Township 22 South, Range 31 East, 

approximately 3V~ miles north of the 

WlPP faci lity. Through development of 

the SEIS, DOE will evaluate the 

cumulative impocts of constructing and 

operating 0 facility for long-term 

management ond storage of elemental 

mercury with the ongoing and planned 

operations of WIPP for disposal of 

defense transuranic waste, as well as the 

potentia l disposal of greater-than-Class 

C waste (Draft Environmental Impact 

Statement for the Disposal of GreaterThan-Class C (GTCC) Low-level 

Radioactive Woste and GTCC-Like 

Waste (GTCC EIS, 00E/EI5-0375, 

February 2011). The locations to be 

evaluated in the SElS would be suitable 

for an above-ground storage facility. 

Identification of Environmental Issues 

DOE proposes to analyze the potentia l 

environmental impacts of the two 

additional altern atives for monogement 

and storage of elemental mercury as 

they apply to the following: 

• Land use and visual resources. 

• Geology, soils, and geologic 

hazards, including seismicity. 

• Water resources (surface water and 

groundwater). 

• Meteorology, air quality and noise. 

• Ecological resources (terrestrial 

resources, wetlands and aquatic 

resources, and species that are Federalor state-listed os threatened, 

endongered, or of specia l concern). 

• Cultural ond paleontologica l 

resources such as prehistoric, historic, 

or Native American sites. 

Site infrastructure. 

• Waste management. • Occupational and public health and 

safety, including from construction, 

operations, faci lity accidents, 

transportation, and intentional 

destructive octs. 

• Ecologico l risk. 

• Socioeconomic impacts on 

potentially affected communities. 

• Environmental Justice (i.e., whether 

long-term mercury management and 

storage activities have a 

disproportionately high and adverse 

effect on minority and low-income 

populations). 

• Facility closure. 

• Cumulative impacts, including 

global commons cumulotive impocts, 

i.e., ozone deplet ion an d ci imote 

chonge. 

• Potential mitigation measures. 

• Unavoidable adverse environmental 

impacts. 

• Irreversible and irretrievable 

commitments of resources. 

• Relationship between short-term 

uses of the environment and 

maintenance and enhancement of longterm productivity. 

Public Participation in the SEIS Process 

NEPA implementi ng regulations 

require on early and open process for 

determi ning the scope of an EIS (or 

SEIS) and for identifying the significant 

issues related to the proposed action. To 

ensure that the full range of issues 

related to the proposed action are 

addressed, DOE invites Federal 

agencies, state, local, and tribal 

governments, and the general public to 

comment on the scope of the SEIS, 

including identifica tion of reasonable 

alternatives and specific issues to be 

addressed. DOE will hold a public 

scoping meeting in Carlsbad, New 

Mexico, on June 26, 2012, and in 

Albuquerque, New Mexico, on June 28, 

2012, as previously described (see 

DATES). 

Issued in Washington, DC, on May 24, 

2012. 

Mark A. Gilbertson, 

Deputy Assistant Secretary for Site .~toration. 

IFR Doc. 2012- 13614 Filed &--4- 12: 8:45 ami 

BILLING CODE 64S0-0t- P 

DEPARTMENT OF ENERGY 

Federal Energy Regulatory 

Commission 

Combined Notice of Filings 

May 30. 201 2. 

Take notice that the Commission has 

received the following Natural Gas 

Pi peline Rate and Refund Report fili ngs: 

Filings Instituting Proceedings 

Docket Numbers: RP12-754-o00. 

Applicants: Arkansas Electric 

Cooperative Corp., Hot Spring Power 

Company, LLC. 

Description: Petition for Waiver of Gas 

Regulations of Arkansas Electric 

Cooperative Corporation and Hot Spring 

Power Company, LLC in RP1 2-754. 

Filed Dale: 5/25/12. 

Accession Number: 20120525-5153. 

Comments Due: 5 p.m. ET 6/6/12. 

Docket Numbers: RP1 2-755-o00. 

Applicants: MarkWest Pioneer, LLC. 

Description: MarkWest PioneerQuorterly FRP Filing to be effective 71 

1/20 12. 

Filed Date: 5/29/12. 

Accession Numbe r: 20120529-5201. 

Comments Due: 5 p.m. ET 6/ 11 /12. 

Any person desiring to intervene or 

protest in any of the above proceedings 

must file in accordance with Ru les 211 

and 214 of the Commission's 

Regulations (18 CFR 385.211 and 

385 .214) on or before 5:00 p.m. Eastern 

time on the specified comment date. 

Protests may be considered, but 

intervention is necessary to become a 

party to the proceeding. 

Filings in Existing Proceedings 

Docket Numbers: CPI 0-16-001. 

Applicants: Cadeville Gas Storage 

LLC. 

Description: Abbreviated amendment 

of Codevi lie Gos Storage LLC under 

CP10-16. 

Filed Date: 5/15/12. 

Accession Number: 20120515-5240. 

Comments Due: 5 p.m. ET 6/4/12. 

Any person desiring to protest in any 

the above proceedings must file in 

accordance with Rule 211 of the 

Commission's Regula tions (18 CFR 

385.211) on or before 5:00 p.m. Eastern 

time on the specified comment date. 

The filings are accessible in the 

Commission's eLi brary system by 

clicking on the li nks or querying the 

docket number. 

eFiling is encouroged. More deta iled 

information re lating to filing 

requirements, interventions, protests, 

and service can be found at: http://www. 

ferc.gov/docs-filing/efiling/filing-l'eq. 

pdf. For other informa ti on, call (866) 

208-3676 (toll free). For TIY, call (202) 

502-8659. 

Nathaniel J. Davis, Sr., 

Deputy Secretary. 

[FR Doc. 2012- 13552 Filod &--4- 12: 8:45 ami 

BILLING CODE 67t7-<lt- P 

DEPARTMENT OF ENERGY 

Federal Energy Regulatory 

Commission 

Combined Notice of Filings 

Take notice that the Commission has 

received the following Natural Gas 

Pipeline Rate and Refund Report filings: 

Filings Instituting Proceedings 

Docket Numbers: RP1 2-748-o00. 

Applicants: Algonquin Gas 

Transmission, LLC. 

Description: AGT Negotiated RateTaunton 66667 to be effective 6/1/20 12. 

Filed Date: 5/24112. 

The Mercury Export Ban Act of 2008 and Federal Register Notices 

A–11 

APPENDIX B

IMPACT ASSESSMENT METHODOLOGY

B–1

APPENDIX B

IMPACT ASSESSMENT METHODOLOGY

Appendix B of the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental 

Impact Statement (Mercury Storage EIS) briefly described the methods used to assess the potential direct, 

indirect, and cumulative effects of the alternatives for long-term management and storage of elemental mercury. 

Included were impact assessment methods for land use and visual resources; geology and soils; water resources; 

meteorology, air quality, and noise; ecological resources; cultural and paleontological resources; site infrastructure; 

waste management; socioeconomics; environmental justice; and cumulative impacts. Appendix D of the 

January 2011 Mercury Storage EIS described the methodology used to assess occupational and public health and 

safety impacts and ecological risk. The analyses presented in the January 2011 Mercury Storage EIS remain valid 

and are incorporated into this Draft Long-Term Management and Storage of Elemental Mercury Supplemental 

Environmental Impact Statement (Draft Mercury Storage SEIS) with two exceptions: (1) the occupational and 

public health and safety analysis; and (2) the socioeconomics and environmental justice analysis. This Draft 

Mercury Storage SEIS includes updates to the occupational and public health and safety analysis resulting from 

changes to the definition of severity levels (i.e., magnitude of impacts) for acute-inhalation exposures to the public 

under certain accident scenarios. This Draft Mercury Storage SEIS also includes updates to the socioeconomics 

and environmental justice analyses to incorporate 2010 decennial census information that was not available at 

the time the January 2011 Mercury Storage EIS was published. This appendix updates the methodology for 

conducting impacts analysis on these resource areas. Additional details of the methods for the evaluation of 

occupational and public health and safety and ecological risk from normal operations, facility accidents, and 

mercury transportation are presented separately in Appendix D of this Draft Mercury Storage SEIS.

B.1 INTRODUCTION

Methods for assessing environmental impacts vary for each resource area (discipline). In addition, 

disciplines are analyzed in a manner commensurate with their importance and the expected level of 

impact on them under a specific alternative—the sliding-scale assessment approach. This is consistent 

with U.S. Department of Energy (DOE) guidance contained in its Recommendations for the Preparation 

of Environmental Assessments and Environmental Impact Statements (known as The Green Book) 

(DOE 2004:1, 2, 19, 20), in which DOE expands on Council on Environmental Quality instructions for 

preparing environmental impact statements (40 CFR 1502.2) by stating that impacts should be discussed 

in proportion to their significance and specifically recommending the use of the sliding scale for impact 

identification and quantification.

For air quality, for example, pollutant emissions from the mercury1storage activities were evaluated for 

their effect on ambient concentrations and compliance with ambient air quality standards. Comparison 

with regulatory standards is a commonly used method for benchmarking environmental impacts and is 

conducted—where appropriate—to provide perspective on the magnitude of identified impacts. Impacts 

in all resource areas were analyzed consistently; that is, the impact values were estimated using a 

consistent set of input variables and computations. Moreover, efforts were made to ensure that 

calculations in all areas used accepted protocols and up-to-date models.

 

1 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this supplemental 

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

B–2

In this Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental 

Impact Statement (Draft Mercury Storage SEIS), impacts are typically described in terms of intensity and 

duration. The term “impact,” when used in this draft SEIS, refers to adverse, long-term impacts, unless 

otherwise stated. A set of standardized impacts terminology was developed for use. Beneficial impacts 

are those that would improve current conditions, while adverse impacts would degrade current conditions. 

Intensities are categorized as negligible, minor, moderate, or major, with durations classified as either 

short term (less than or equal to 5 years) or long term. These categories are defined as follows:

Negligible: There would be little or no impact on the resource in the region of influence (ROI). 

Where slight impacts occur, they would be relatively short term, and/or the impacts would not be 

of any perceptible consequence over the long term.

Minor: Impacts on the resource in the ROI would be detectable, although localized, relatively 

small, and of little long-term consequence to the overall makeup of the ROI. Resource loss, 

consumption, or change would be a small percentage (i.e., generally between 1 and 10 percent) of 

the resource or resource indicator in the ROI. There would be no loss, damage, or alteration of 

any rare, unique, special status, or other legally protected resources (e.g., threatened and 

endangered species or critical habitat).

Moderate: Impacts on the resource in the ROI would be readily detectable, generally long term, 

and localized. Resource loss, consumption, or change would be a sizable percentage 

(i.e., generally between 10 and 40 percent) of the resource or resource indicator in the ROI. Such 

impacts may prompt consideration of specific project design changes and/or compensatory 

mitigation for resource loss. Moderate effects may also denote resource conditions that are not 

expected to affect or impair project implementation but that could prompt consideration of special 

design or construction mitigation.

Major: Impacts on the resource in the ROI would be obvious and long term and would have 

substantial consequences. Either substantial project design changes and/or compensatory 

mitigation for resource loss would be evaluated. Major effects may also denote resource 

conditions (e.g., presence of active geologic fault) prompting consideration of substantial changes 

in project implementation in terms of location and/or special design or construction mitigation.

These terms are used for the analysis of impacts for all resources areas, exclusive of occupational and 

public health and safety and ecological risk, which are presented separately in Appendix D of this draft 

SEIS.

DOE evaluated the environmental impacts of the proposed action within defined ROIs specific to each 

resource area and site evaluated. ROIs encompass the geographic areas within which any meaningful 

impact is expected to occur, and can include the area within which the proposed action would take place, 

the site as a whole, or nearby offsite areas. ROIs that are defined with the term “nearby offsite areas” 

may be different for each site depending on the extent to which meaningful impacts are expected to occur. 

For example, impacts on historic resources were evaluated at specific facility locations within each site, 

whereas human health risks to the general public were assessed for an area within a 16-kilometer 

(10-mile) radius of the facility location. Brief descriptions of the ROIs for each resource area are 

presented in Table B–1. Detailed definitions of the various ROIs can be found in Appendix B of the 

January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact 

Statement (Mercury Storage EIS).
Impact Assessment Methodology

B–3

Table B–1. General Regions of Influence

Environmental Resource Area Region of Influence

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

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

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

and groundwater

Meteorology, air quality, and noise For meteorology and air quality, the site and nearby offsite areas 

potentially affected by air pollutant emissions; for noise, the 

project location, the site, and surrounding areas, including 

transportation corridors where proposed activities might increase 

noise levels

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

Cultural and paleontological resources The project location and adjacent areas

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

Waste management Site waste management facilities 

Occupational and public health and safety

and ecological risk

The site, offsite areas, and the transportation corridors 

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

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

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

16-kilometer (10-mile) area

B.2 UPDATES TO OCCUPATIONAL AND PUBLIC HEALTH AND SAFETY 

METHODOLOGY

The occupational and public health and safety analysis presented in the January 2011 Mercury 

Storage EIS is based on DOE’s Protective Action Criteria, Revision 25, published in August 2009 

(DOE 2009). Since the publication of the January 2011 Mercury Storage EIS, DOE has published 

Revision 27 of the Protective Action Criteria in February 2012 (DOE 2012). This has resulted in changes 

to the definition of severity levels (i.e., magnitude of impacts) for assessing acute-inhalation exposures to 

the public under certain accident scenarios, as discussed below. Accordingly, Appendix E, Section E.2,

of this draft SEIS updates the occupational and public health and safety analysis for the candidate sites 

previously analyzed in the January 2011 Mercury Storage EIS using these revised exposure criteria;

otherwise, the methodology remains the same. The analysis for the Waste Isolation Pilot Plant Vicinity 

reference locations presented in Chapter 4, Section 4.2.9, and Appendix D of this draft SEIS uses the 

revised exposure criteria.

Appendix D, Section D.3.1, of this draft SEIS defines four severity levels (SL-I through SL-IV) varying 

from negligible-to-very-low exposure at SL-I, the possibility of reversible health effects at SL-II, the 

possibility of irreversible health effects at SL-III, and up to the potential for fatality at SL-IV. In the 

January 2011 Mercury Storage EIS, the boundary between exposures at SL-III and SL-IV was taken to be 

the U.S. Environmental Protection Agency’s (EPA’s) Acute Exposure Guideline Level 3 (AEGL-3). For 

the definition of AEGLs, see Appendix D, Section D.3.1, of this draft SEIS. The boundary between SL-II 

and SL-III was taken to be EPA’s AEGL-2. It would be logical to assume that the boundary between 

SL-I and SL-II should be AEGL-1. However, EPA has not defined an AEGL-1 for mercury vapor. In the 

January 2011 Mercury Storage EIS, it was judged that the following is conservative as a “surrogate 

AEGL-1:”

2

the boundary between SL-I and SL-II is equal to DOE’s Protective Action Criterion 1

(PAC-1) of 0.3 milligrams per cubic meter for durations of exposure up to 1 hour and equal to 

 

2 The use of TEEL-0 and PAC-1 in the definition of a “surrogate AEGL-1” should not be taken as having any justification or 

validity beyond use in this SEIS.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

B–4

DOE’s Temporary Emergency Exposure Limit 0 (TEEL-0) of 0.025 milligrams per cubic meter for 

durations of exposure exceeding 1 hour (DOE 2009). This latter assumption is highly conservative.

Since the publication of the January 2011 Mercury Storage EIS, there have been changes to the 

DOE PAC-1 and TEEL-0 guidance that warrant reconsideration of the above assumptions. First, the 

value of the PAC-1 for mercury has decreased from 0.3 to 0.15 milligrams per cubic meter (DOE 2012). 

This has necessitated reexamination of all accident scenarios with acute-inhalation exposures to the public 

with durations of release up to 1 hour. Second, DOE has discontinued the publication of TEEL-0 values 

as part of the ongoing effort to more sharply focus on those hazards that may lead to operational 

emergencies (DOE 2012). There are no comparable values published by DOE. Therefore, TEEL-0 

cannot be referenced for the analysis in this draft SEIS. However, the American Conference of 

Governmental Industrial Hygienists (ACGIH) publishes a time-weighted average (TWA) for exposures of 

up to 8 hours in the workplace. For mercury vapor, this is 0.025 milligrams per cubic meter

(OSHA 2012), identical to the previously published TEEL-0 value. The TWA is a level of exposure 

below which workers can be exposed for 8 hours a day and 40 hours a week without adverse health 

effects. The longest exposure of any accident scenario considered in the analysis is 3 hours. Therefore, it

is judged that continuing to use a value of 0.025 milligrams per cubic meter for durations of exposure 

exceeding 1 hour remains conservative as a “surrogate AEGL-1.” Because only the source reference 

changed and not the value used as a “surrogate AEGL-1” for acute-inhalation exposure exceeding 1 hour,

the analyses carried out in the January 2011 Mercury Storage EIS remain unchanged.

B.3 UPDATES TO SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE 

METHODOLOGY

The socioeconomics and environmental justice analyses presented in the January 2011 Mercury 

Storage EIS are based on 2000 census data. Since the publication of the January 2011 Mercury 

Storage EIS, 2010 decennial census data have been published. Accordingly, Appendix E, Section E.3, of 

this draft SEIS updates the socioeconomics and environmental justice analyses for the candidate sites 

previously analyzed in the January 2011 Mercury Storage EIS using these 2010 census data. 

Furthermore, the tables shown below have been updated using 2010 census data and supersede those that 

were presented in Appendix B of the January 2011 Mercury Storage EIS; otherwise, the methodology for 

evaluating socioeconomics and environmental justice impacts remains the same.

The environmental justice analysis focused on potential health risks resulting from normal operations and 

accidents that could occur during activities associated with implementation of the alternatives for mercury 

storage. Environmental justice impacts are determined based on the results from the occupational and 

public health and safety risk analysis, as well as land use, cultural and paleontological resources, 

socioeconomics, and other resource area impact analyses where impacts on resources may be high 

and adverse.

Tables B–2, B–3, and B–4 below update Tables B–13, B–14, and B–15, respectively, in Appendix B of 

the January 2011 Mercury Storage EIS.
B

–5

Impact Assessment Methodology

Table B–2. Site-Specific Thresholds for Identification of Minority and Low-Income

Communities Within the 16-Kilometer (10-Mile) Region of Influence (percentage)

Population

Grand 

Junction 

Disposal 

Site

Hanford 

Site

Hawthorne 

Army

Depot

Idaho 

National 

Laboratory

Kansas City 

Plant

Savannah 

River

Site

Waste 

Control 

Specialists, 

LLC, Site

WIPP 

Vicinity 

Reference 

Locations

Y–12 

National 

Security 

Complex

Minority 

Population 36.9a 47.5b 50.0a 36.0b 39.9b 50.0b 50.0a 50.0a 33.6a

Low-Income 

Population 32.2b 32.1b 31.9b 33.6b 32.0a 35.9b 36.9b 35.8a 34.2a

a Indicates the county(ies) as the lower general population percentage.

b Indicates the state(s) as the lower general population percentage.

Key: WIPP=Waste Isolation Pilot Plant.

Table B–3. Site-Specific Thresholds for Identification of Minority and Low-Income

Communities Within the 3.2-Kilometer (2-Mile) Region of Influence (percentage)

Population

Grand 

Junction

Disposal 

Site

Hawthorne 

Army 

Depot

Kansas City

Plant

Waste 

Control

Specialists, 

LLC, Site

WIPP 

Vicinity 

Reference 

Locations

Y–12 

National

Security 

Complex

Minority 

Population 36.9a 50.0a 39.0b 50.0b 50.0a 29.3a

Low-Income 

Population 32.2b 31.9b 34.0b 36.9b 33.6a 36.5a

a Indicates the county(ies) as the lower general population percentage.

b Indicates the state(s) as the lower general population percentage.

Key: WIPP=Waste Isolation Pilot Plant.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

B–6

Table B–4. Environmental Justice Impact Assessment Protocol

Resource

Required Data

Affected Environment Alternative Measure of Impact

Minority 

Populations

Baseline demographic data 

relative to race and ethnicity of 

all populations reported at the 

block group level of spatial 

resolution from the 2010 

decennial census, Summary 

File 1, Table P5, Hispanic or 

Latino Origin by Race -

Universe: Total Population 

(DOC 2011a).

Location of 

proposed 

facility.

Impacts are determined based on the results

from the occupational and public health and 

safety risk analysis, land use, cultural and 

paleontological resources, socioeconomics, 

and other resource area impact analyses, as 

appropriate.

For a proposed action to impose 

disproportionately high and adverse impacts 

upon minority and low-income 

communities, first high and adverse impacts 

must be identified as a result of the 

proposed action. For resource areas with 

no or negligible impacts, additional 

environmental justice analysis is not 

warranted. For resource areas where there 

may be the potential for high and adverse 

impacts, additional analysis is performed 

to determine if conditions exist that would 

result in those impacts being borne 

disproportionately by minority or 

low-income communities.

Low-Income 

Populations

Baseline demographic data 

relative to income reported at the 

block group level of spatial 

resolution from the 2006–2010 

American Community Survey 

5-Year Estimates, Table C17002, 

Ratio of Income to Poverty Level 

in the Past 12 Months - Universe: 

Population for Whom Poverty 

Status is Determined 

(DOC 2011b).

Data relative to race and ethnicity from the 2010 decennial census, Summary File 1, Table P5, Hispanic 

or Latino Origin by Race (DOC 2011a), are used to identify block groups that contain disproportionately 

high minority populations surrounding the candidate sites for mercury storage. Table P5 provides 

sufficient detail to determine baseline demographic data relative to race and ethnicity for all minority 

populations reported at the block group level.

There are no data relative to income available from the 2010 census. The Census Bureau’s American 

Community Survey (ACS) 5-year estimates is the only data set that publishes current data relative to

income at the block group level of spatial resolution. The geographic boundaries from the 2006–2010

ACS 5-Year Estimates data set are consistent with those used during the 2010 census. Therefore, data 

relative to income from the 2006–2010 ACS 5-Year Estimates data set, Table C17002, Ratio of Income to 

Poverty Level in the Past 12 Months (DOC 2011b), are used to identify block groups that contain 

disproportionately high low-income populations surrounding the candidate sites for mercury storage.

B.4 REFERENCES

DOC (U.S. Department of Commerce), 2011a, U.S. Census Bureau, 2010 Decennial Census, Summary 

File 1, Table P5: Hispanic or Latino Origin by Race - Universe: Total Population, accessed through 

http://factfinder2.census.gov/faces/nav/jsf/pages/index.xhtml.

DOC (U.S. Department of Commerce), 2011b, U.S. Census Bureau, 2006–2010 American Community 

Survey 5-Year Estimates, Table C17002: Ratio of Income to Poverty Level in the Past 12 Months -

Universe: Population for Whom Poverty Status is Determined, accessed through 

http://www2.census.gov/acs2010_5yr/summaryfile/UserTools/.

DOE (U.S. Department of Energy), 2004, Recommendations for the Preparation of Environmental 

Assessments and Environmental Impact Statements, 2nd ed., Office of NEPA Policy and Compliance, 

Washington, DC, December.
Impact Assessment Methodology

B–7

DOE (U.S. Department of Energy), 2009, Protective Action Criteria (PAC): Chemicals with AEGLs,

ERPGs, & TEELs, Rev. 25, accessed through http://www.atlintl.com/DOE/teels/teel/teel_archives.html. 

August.

DOE (U.S. Department of Energy), 2012, Protective Action Criteria (PAC): Chemicals with AEGLs, 

ERPGs, & TEELs, Rev. 27, accessed through http://www.atlintl.com/DOE/teels/teel/teel_pdf.html. 

February.

OSHA (Occupational Safety and Health Administration), 2012, Occupational Safety and Health 

Guideline for Mercury Vapor, U.S. Department of Labor, accessed through http://www.osha.gov/SLTC/

healthguidelines/mercuryvapor/recognition.html, November 12.

Code of Federal Regulations

40 CFR 1502.2, U.S. Environmental Protection Agency, “Environmental Impact Statement: 

Implementation.”

APPENDIX C

STORAGE FACILITY

CONSTRUCTION AND OPERATIONS DATA

C–1

APPENDIX C 

STORAGE FACILITY CONSTRUCTION AND OPERATIONS DATA 

This appendix presents data on construction and operations of a new mercury storage facility analyzed in this Draft 

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

Mercury Storage SEIS). Section C.1 provides data related to the transportation of elemental mercury to the 

storage facility. Section C.2 provides background information regarding design criteria, a general description 

of physical characteristics, and construction and operations data for a new facility that would be used to 

store mercury. Appendix C of the January 2011 Long-Term Management and Storage of Elemental Mercury 

Environmental Impact Statement (Mercury Storage EIS) presented data on construction and operations of a new 

mercury storage facility, as well as data on modification of existing buildings, as appropriate to each of the seven 

candidate sites analyzed in the January 2011 Mercury Storage EIS that are still under consideration for the 

long-term storage of mercury. The data from the January 2011 Mercury Storage EIS Appendix C related to 

construction and operations of a new facility are applicable to the Waste Isolation Pilot Plant Vicinity reference 

locations considered in this Draft Mercury Storage SEIS, and are reproduced in this appendix for convenience.

C.1 TRANSPORTATION REQUIREMENTS 

Two acceptable container types for the mercury storage facility are 3-liter (3-L) (34.6-kilogram 

[76-pound]) flasks and 1-metric-ton (1-MT) (1.1-ton) containers. Figure C–1 illustrates the dimensions 

of a typical 3-L flask and Figure C–2 illustrates the dimensions of a typical 1-MT container. Other 

containers may be accepted for storage on a case-by-case basis. All containers are subject to 

U.S. Department of Transportation regulations regarding the transportation of elemental mercury.1

1

 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this supplemental 

environmental impact statement. 

Figure C–1. Dimensions of a Typical 3-Liter Flask 

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

C–2

Figure C–2. Dimensions of a Typical 1-Metric-Ton Container 

The 3-L flasks would be transported in pallets; such pallets may have a built-in spill tray. Each pallet 

would contain up to a maximum of 49 3-L flasks in a 7- by 7-flask configuration, not to exceed 1.4 meters 

(4.7 feet) on a side. The 3-L flasks could also be shipped in quantities of less than 49 per pallet. Full-size 

pallets (containing 49 3-L flasks) would be shipped “ready” for storage upon passing inspection and 

satisfying acceptance criteria. Smaller loads (pallets containing less than 49 3-L flasks) would be 

consolidated in the Handling Area at the U.S. Department of Energy (DOE) facility for efficient storage. 

Noncombustible (i.e., metal) or fire-resistant wooden pallets are recommended as a best management 

practice over non-fire-resistant wooden pallets (DOE 2009). An example of typical shipment of a 

full-size pallet of 49 3-L flasks is provided in Figure C–3.

The 1-MT containers would also be shipped on box pallets; however, there would be only one container 

per pallet. Each pallet would be constructed of wood or metal, similar to the 3-L flask pallets. Once 

received and visually inspected for integrity, the 1-MT containers would be removed from their shipping 

pallets and placed in a spill tray in long-term storage. The transportation pallets would be returned to the 

generator for reuse, if requested. Each spill tray would accommodate eight 1-MT containers in a 

2-container by 4-container configuration (DOE 2009). 
Storage Facility Construction and Operations Data 

C–3

Figure C–3. Example Box Pallet for Shipping 3-Liter Flasks 

in a 7-Flask by 7-Flask Configuration 

Consistent with the estimated amount of potentially available mercury discussed in Chapter 1, 

Section 1.3.1, of this Draft Long-Term Management and Storage of Elemental Mercury Supplemental 

Environmental Impact Statement (Draft Mercury Storage SEIS), DOE makes the following assumptions 

regarding the availability of surplus mercury for storage: 

All or a portion of DOE’s surplus mercury inventory of approximately 1,200 metric tons 

(1,300 tons) currently in storage at the Y–12 National Security Complex (Y–12) is being 

considered for transfer to the long-term mercury storage facility. 

The remaining chlor-alkali facilities would close by 2020, yielding approximately 

1,100 metric tons (1,210 tons) of mercury that would be shipped to the long-term mercury storage 

facility over the first 7 years of operation.2

Mining would yield approximately 4,900 metric tons (5,400 tons) of mercury during the 40-year 

period of analysis that would be shipped to the long-term mercury storage facility. 

Reclamation and recycling facilities would yield approximately 2,800 metric tons (3,090 tons) of 

mercury during the 40-year period of analysis that would be shipped to the long-term mercury 

storage facility. 

 

2

 Olin Corporation has announced that its chlor-alkali plants in Tennessee and Georgia will be consolidated and converted to 

mercury-free technology by the end of 2012 (Pavey 2012). The fate of this mercury is uncertain and may still be eventually 

shipped to a DOE facility(ies) for long-term management and storage; therefore, the quantities of mercury analyzed in this 

Draft Mercury Storage SEIS remain unchanged. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

C–4

DOE makes the following assumptions regarding the quantities of mercury and when this mercury would 

be shipped to the long-term mercury storage facility:3

First 2 Years of Operation: A total of approximately 950 metric tons (1,050 tons) would be 

delivered per year from Y–12 (if the decision is made to transfer the Y–12 mercury inventory to 

the new storage facility), chlor-alkali facilities, mines, and reclamation and recycling facilities. 

Third Through Seventh Year of Operation: A total of approximately 350 metric tons (390 tons) 

would be delivered per year from chlor-alkali facilities, mines, and reclamation and recycling 

facilities. 

Eighth Through Fortieth Year of Operation: A total of approximately 190 metric tons (210 tons) 

would be delivered per year from mines and reclamation and recycling facilities. 

DOE makes the following assumptions regarding the transportation of mercury: 

A fully loaded truck can carry 9 pallets of 49 3-L flasks or 14 1-MT containers, and a fully loaded 

railcar can carry 24 pallets of 49 3-L flasks or 54 1-MT containers. 

Mercury from Y–12 would be shipped in 3-L flasks, mercury from chlor-alkali facilities would be 

shipped in 1-MT containers, and mercury from mines and reclamation and recycling facilities 

would be shipped in 3-L flasks and/or 1-MT containers. 

Based on the above-mentioned assumptions and assuming fully loaded trucks or railcars, the number of 

shipments that would be required for each transportation scenario is listed below. However, it can be 

reasonably expected that some shipments would be smaller and not necessarily on fully loaded trucks. 

Truck Scenarios 1 and 2 and the Railcar Scenario are defined in Appendix D, Section D.2.2, of this Draft 

Mercury Storage SEIS. These scenarios are summarized below. 

3

 For purposes of analysis, the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact 

Statement assumes a 40-year operational period with the first year starting in 2013 and the fortieth year, in 2052. An 

operational start date is not known at this time; however, the period of analysis remains 40 years. For example, if the mercury 

storage facility(ies) were to start operations in 2014, the last year of operations would likewise shift to 2053, and so forth. 

Truck Scenario 1: Fully loaded trucks. 

First 2 Years of Operation: It is expected that 66 truck deliveries would be made per year from 

Y–12, chlor-alkali facilities, mines, and reclamation and recycling facilities. 

Third Through Seventh Year of Operation: It is expected that 26 truck deliveries would be made 

per year from chlor-alkali facilities, mines, and reclamation and recycling facilities. 

Eighth Through Fortieth Year of Operation: It is expected that 14 truck deliveries would be made 

per year from mines and reclamation and recycling facilities. 

Truck Scenario 2: Partially loaded trucks. 

First 2 Years of Operation: It is expected that 79 truck deliveries would be made per year from 

Y–12, chlor-alkali facilities, mines, and reclamation and recycling facilities. 

Third Through Seventh Year of Operation: It is expected that 39 truck deliveries would be made 

per year from chlor-alkali facilities, mines, and reclamation and recycling facilities. 

Eighth Through Fortieth Year of Operation: It is expected that 27 truck deliveries would be made 

per year from mines and reclamation and recycling facilities. 

 
Storage Facility Construction and Operations Data 

C–5

Railcar Scenario: Fully loaded railcars. 

First 2 Years of Operation: It is expected that 23 rail deliveries would be made per year from 

Y–12, chlor-alkali facilities, mines, and reclamation and recycling facilities. 

Third Through Seventh Year of Operation: It is expected that 8 rail deliveries would be made per 

year from chlor-alkali facilities, mines, and reclamation and recycling facilities. 

Eighth Through Fortieth Year of Operation: It is expected that 5 rail deliveries would be made per 

year from mines and reclamation and recycling facilities. 

C.2 MERCURY STORAGE FACILITY 

C.2.1 Introduction 

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

and Long-Term Storage of Elemental Mercury (DOE 2009) serves as a basis for developing the design 

and operational parameters for a new mercury storage facility. For some criteria, construction and 

operations data for similar storage facilities were used to supplement the information taken from DOE 

(2009). 

The DOE mercury storage facility would include the following four major physical areas that would 

provide the necessary functions for receipt, inspection, and long-term storage of mercury (DOE 2009): 

Receiving and Shipping Area. This area would include dedicated space(s) for the receipt, 

inspection, and handling of mercury containers. It would allow for truck docking, offloading, 

inspection, and transfer of received mercury to the facility. It would also allow for inspection, 

packaging, marking, manifesting, and truck docking and loading for shipments of secondary 

waste out of the DOE storage facility. It would be adjacent to the Handling and Storage Areas. 

Handling Area. This area would include dedicated space(s) for acceptance/verification of 

incoming containers and for work involving potential contamination, including (1) safely 

handling and cleaning palletized or individual containers that have external mercury 

contamination, and/or (2) repackaging mercury from containers that have failed inspection. This 

area is needed for non-routine and emergency response activities for leaking flasks and/or 

containers. The area would be enclosed and have filtered ventilation. All exhausted air would 

pass through a sulfur filter to remove mercury vapors. 

Storage Area. This area would include dedicated space for the storage of mercury containers. 

Composing the bulk of the facility, this enclosed area would have ample storage and aisle space 

for careful, tracked placement and retrieval of all containers (e.g., 3-L and 1-MT capacity). The 

area would be well lit, with appropriate ventilation, spill containment, and fire protection 

measures. Although sufficient forced ventilation would be provided in all Storage Areas, 

conditioned air would not be required. Note that the Storage Area(s) may be constructed in a 

modular fashion to accommodate mercury inventories as they become available for storage. 

Office Administration Area. This area would include the management, operations, training, and 

all other administration functions supporting the overall mercury program. Examples include the 

storage and maintenance of records, waste verification documents, shipping papers, and 

databases. It should not be located within a hazardous area and would preferably be separated 

from the other three facility areas. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

C–6

Key features of a Resource Conservation and Recovery Act–permitted facility used for the storage of 

elemental mercury include the following: 

Location and Siting. The selection of siting for construction of a new facility or evaluation of an 

existing facility would consider environmentally sensitive locations or conditions such as the 

existence of floodplains, wetlands, groundwater, seismic zones, karst soils or other unstable 

terrain, local weather phenomena, or incompatible land use. 

Security. At a minimum, facility security would meet the requirements for a DOE Property 

Protected Area, as outlined in DOE Manual 470.4-2A, Physical Protection. The facility would be 

located in an area under the control and authority of DOE and would prevent inadvertent or 

deliberate unauthorized access to the facility and the Storage Area(s). The facility would have a 

perimeter barbed-wired fence to control unauthorized access. Remote surveillance may also be 

employed, where necessary. 

Containment. The Storage Areas of the facility would be designed to properly contain any 

release of mercury. This would include the use of spill trays, properly sloped floors, and floors 

constructed to be impervious to liquid mercury releases. The facility walls and ceiling would be 

constructed of sufficient quality and design to shield the stored mercury from weather elements 

and ensure that mercury is not entrained in stormwater runoff. 

Ventilation. The Handling Area would be ventilated through the use of a high-negative draw 

system for removing high-concentration vapors from mercury “sources” (e.g., container residues, 

open containers, small spills). The exhaust air would pass through a sulfur filter to remove 

mercury vapor and be discharged to the outside. A wall-mounted air conditioning unit would be 

available for maintaining interior temperatures below 70 degrees Fahrenheit during times when 

mercury is being handled to keep its volatility low. The Storage Area would be ventilated using 

low-vacuum, high-volume, industrial-sized roof- or wall-mounted fans sized to provide multiple 

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

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

to and during occupancy. 

Fire Protection. The facility would be outfitted with fire detection systems such as smoke and 

heat detectors, as well as a permanent fire suppression system. The fire suppression system 

would be a conventional wet- or dry-charge water sprinkler system augmented with readily 

accessible fire extinguishers. 

Emergency Response. The Handling Area would be designed for responding to small spills that 

might occur or for transferring mercury from corroding or leaking containers or from containers 

that have failed inspection upon arrival at the facility to new containers prior to placing them in 

storage. Emergency response procedures would be developed for larger releases of mercury. 

Monitoring. The facility would conduct mercury vapor monitoring for the detection of any 

unplanned releases of mercury or deterioration of flask or container integrity. Weekly inspections 

of containers in long-term storage would incorporate air sampling. 

Record-Keeping. Training records, waste receipts, inspection reports, laboratory analysis, 

response plans, monitoring data, etc., would be maintained in the Office Administration Area. 
Storage Facility Construction and Operations Data 

C–7

C.2.2 Physical Description 

Construction of a new storage facility is being evaluated at all Waste Isolation Pilot Plant (WIPP) 

Vicinity reference locations considered in this Draft Mercury Storage SEIS. Figure C–4 provides a 

potential conceptual layout for a generic, full-size new mercury storage facility. Figure C–5 provides 

detail for the Receiving and Shipping Area and Handling Area. The WIPP Vicinity reference locations 

would require new permits for the construction and operation of a long-term mercury storage facility. 

These permits would be subject to approval by the applicable regulatory agency. 

Figure C–4. Conceptual Layout for a New Mercury Storage Facility 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

C–8

Figure C–5. Conceptual Schematic for Receiving and Shipping Area and 

Handling Area of a New Mercury Storage Facility 
Storage Facility Construction and Operations Data 

C–9

Table C–1 provides general physical data for the construction of a generic, new facility for the storage of 

elemental mercury. 

Table C–1. Data for a Mercury Storage Facility – New Construction 

Parameter New Facilitya

Facility Footprint 20,500 square meters

(220,600 square feet)

Permitted for Storage of Hazardous Waste Under 

Resource Conservation and Recovery Act

Yes; would be permitted.

Building Dimensions 

(length × width)

154×102 meters

(506×336 feet)

Ceiling Height 6.1 meters

(20 feet)

Number of Buildings 1

Total Space Dedicated to Storage 13,610 square meters

(146,500 square feet)

Building Construction Structural steel frame on reinforced-concrete slab and 

sheet metal shell; epoxy-sealed floor.

Floor Thickness 30 centimeters

(12 inches)

Rail Access Yes, with exception of Grand Junction Disposal Site 

location.

Access/Security Security measures would prevent inadvertent or deliberate 

unauthorized access to the facility and Storage Area(s). 

Examples would include physical barriers such as 

perimeter barbed-wire fence, remote interior and 

exterior surveillance, and/or security personnel.

Potentially Required Building Modifications New facility would be designed and built to desired 

specifications.

a Data for new facility construction would be similar regardless of location. 

Source: DOE 2009. 

C.2.3 Construction Data 

Resource commitments for new facility construction would be similar regardless of location and are 

presented in Table C–2. DOE expects that construction of a new mercury storage facility would require 

approximately 6 months to complete. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

C–10

Table C–2. Resource Commitments for Construction of a New Mercury Storage Facilitya

Resource Quantity

Land Use

Land disturbance 3.1 hectares (7.6 acres)

Labor

Man hours 18,500

Materials

Concrete 4,755 cubic meters (6,220 cubic yards)

Gravel (crushed stone) 3,875 cubic meters (5.070 cubic yards)

Asphalt 670 cubic meters (872 cubic yards)

Steel 2,700 metric tons (2,970 tons)

Epoxy sealant 2,400 liters (6,330 gallons)

Utilities

Water (non-potable) 1,230,000 liters (325,000 gallons)

Water (potable) 40,900 liters (10,800 gallons)

Diesel 193,000 liters (51,000 gallons)

Gasoline 0 liters (0 gallons)

Electricity 0 megawatt-hours

Waste

Nonhazardous construction debris 270 cubic meters (355 cubic yards)

Nonhazardous liquid waste (sanitary wastewater) 9,850 liters (2,600 gallons)

a Duration of construction would be 6 months.

Source: DOE 2009.

The construction of a new facility would generate air emissions from the use of heavy equipment and the 

disturbance of soils from grading and site preparation. Typical heavy equipment that might be used 

would include dump trucks, cement trucks, dozers, graders, spreaders, compactors, cranes, etc. Air 

emissions from vehicle exhaust would be dependent on frequency of use, fuel efficiency, and fuel type. 

Particulate air emissions would be dependent on the amount of exposed land and the duration of 

exposure. Based on the relevant factors and an estimated construction period of 6 months, expected air 

emissions are listed in Table C–3.

Table C–3. Air Emissions During Construction of a New Mercury Storage Facilitya

Pollutant Total Emissions (metric tons) Total Emissions (tons)

Carbon monoxide 3.01 3.32

Nitrogen dioxide 14.0 15.4

Sulfur dioxide 0.00475 0.00524

Particulate matter 

(with a diameter of 10 micrometers or less)

16.6 18.3

Carbon dioxide 520 573

Total organic compounds 1.14 1.26

Ammonia 0.022 0.0242

Benzene 0.00296 0.00326

1,3-Butadiene 0.0001124 0.000137

Formaldehyde 0.00374 0.00412

Toluene 0.00130 0.00143

Xylene 0.000903 0.000995

a Duration of construction would be 6 months.

Source: EPA 1995; USACE 2007.
Storage Facility Construction and Operations Data 

C–11

Minimal site excavation would be required for the construction of a new facility. Excavation up to 

60 centimeters (24 inches) may be required for site preparation and pouring the concrete foundation. 

Small trenches may also be required for installation of utilities or connection with existing utilities and 

installation of concrete footers; depths for this could be 0.6 meters (2 feet) wide and 1.2 meters (4 feet) 

deep. Any excess soil would be incorporated and contoured into the existing landscape. It is assumed 

that any new construction would take place in an uncontaminated area. 

C.2.4 Operations Data 

Resource commitments for operations of a mercury storage facility for the storage of up to 

10,000 metric tons (11,000 tons) of elemental mercury are presented in Table C–4. It is conservatively 

assumed that security personnel would guard the facility 24 hours per day, 7 days per week, although this 

level of security may not be necessary. Based on this assumption, site security for a standalone facility is 

estimated to be 350,400 man hours over the 40-year period of analysis. Considering a full-time 

equivalent worker works 2,080 hours per year, security would be 4 1/4 full-time equivalents. Security 

personnel would only be required during normal working hours for receipt and handling of mercury 

shipments and would be reduced to 83,200 man hours over the 40-year period of analysis. Other 

operations personnel would include administrative staff, labor for the receipt, inspection, and handling of 

incoming mercury shipments, facility maintenance, and industrial hygiene and occupational safety 

experts. This required operations staff would be 3 3/4 full-time equivalents for the first 7 years and 

1 1/8 full-time equivalents thereafter. 

Table C–4. Resource Commitments for Operation of a 

New Mercury Storage Facilitya

Resource Quantity

Land Use

Land occupied 3.1 hectares (7.6 acres)

Labor

Man hours 482,220 (215,020)b

Utilities

Water (non-potable) Negligible

Water (potable) 3,540,000 liters (935,000 gallons)

Diesel 24,200 liters (6,400 gallons)

Gasoline Negligible

Electricity 10,100 megawatt-hours

Waste

Hazardous solid waste

(55-gallon drums)

910

Nonhazardous liquid waste 

(sanitary wastewater)

2,360,000 liters (623,000 gallons)

a Values presented are totals for the 40-year period of analysis. 

b Parenthetical value represents reduced security personnel for those candidate sites that already 

reside within a secure Federal complex (i.e., the Hanford Site, Hawthorne Army Depot, Idaho 

National Laboratory, and the Savannah River Site).

Source: DOE 2009. 

The long-term mercury storage facility will not treat or process mercury. The facility will only be 

designed to store mercury in high-integrity, tight containers. However, it may become necessary to 

respond to small spills or repackage mercury from failed containers. The Handling Area, where 

repackaging mercury into new containers would be performed, would be negatively ventilated and the 

exhaust air would be filtered to remove airborne mercury emissions. The binding chemical that would 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

C–12

most likely be used to remove mercury from the air would be sulfur. Filters would be replaced on a 

regular schedule to maintain optimum mercury removal efficiency. Therefore, air emissions vented from 

the Handling Area to the outside air are expected to be negligible. Mercury vapor might accumulate in 

the Storage Area(s) during normal operations from storage containers or residual surface contamination 

and could subsequently be vented to the outside air through the exhaust fans. However, as discussed in 

Chapter 4, Section 4.2.9, and Appendix D, air emissions from normal operations are projected to remain 

well below actionable concentrations for human health exposure. 

C.3 REFERENCES 

DOE (U.S. Department of Energy), 2009, U.S. Department of Energy Interim Guidance on Packaging, 

Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, Office of 

Environmental Management, Washington, DC, November 13. 

EPA (U.S. Environmental Protection Agency), 1995, Compilation of Air Pollutant Emission Factors, 

Volume I: Stationary Point and Area Sources, 5th ed., Research Triangle Park, North Carolina, January. 

Pavey, R., 2012, “Olin Prepares for Mercury Free Future After 47 Years,” The Augusta Chronicle, 

July 15. 

USACE (U.S. Army Corps of Engineers), 2007, Construction Equipment Ownership and Operating 

Expense Schedule, Region I, EP 11110-1-8, Vol. I, July. 

U.S. Department of Energy Directives 

DOE Manual 470.4-2A, Physical Protection, July 23, 2009. 
APPENDIX D

HUMAN HEALTH AND ECOLOGICAL RISK

ASSESSMENT ANALYSIS

D–1

APPENDIX D 

HUMAN HEALTH AND

ECOLOGICAL RISK ASSESSMENT ANALYSIS 

This appendix provides a summary of the discussion presented in Chapter 4, Section 4.2.9, and Appendix D of the 

January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement and 

includes new data specific to conducting the risk assessments for the Waste Isolation Pilot Plant Vicinity reference 

locations. This summary includes an overview of input data, assumptions, toxicity of mercury, and the approach to 

evaluating risk.

D.1 INTRODUCTION 

As described in Chapter 1 of this Draft Long-Term Management and Storage of Elemental Mercury 

Supplemental Environmental Impact Statement (Draft Mercury Storage SEIS), the Mercury Export Ban 

Act of 2008 (P.L. 110-414) requires that the Secretary of Energy designate a facility or facilities of the 

U.S. Department of Energy (DOE) (which shall not include the Y–12 National Security Complex [Y–12] 

or any other portion or facility of the DOE Oak Ridge Reservation) for the purpose of long-term 

management and storage of elemental mercury1generated within the United States. 

The alternatives that are analyzed in this appendix are listed below. 

Waste Isolation Pilot Plant (WIPP) Vicinity Section 10 

WIPP Vicinity Section 20 

WIPP Vicinity Section 35 

For further description of these alternatives, see Chapter 2, Section 2.3, and Appendix C of this 

supplemental environmental impact statement (SEIS). 

1

 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this supplemental 

environmental impact statement. 

2

 Since publication of the January 2011 Mercury Storage EIS, DOE has published revised Protective Action Criteria for 

exposure to mercury vapor. This has resulted in changes to the definition of severity levels (i.e., magnitude of impacts) for 

assessing acute-inhalation exposures to the public under certain accident scenarios. Appendices B and E of this SEIS update 

parts of Chapter 4 and Appendix D of the January 2011 Mercury Storage EIS. The impact analyses for the WIPP Vicinity 

reference locations discussed in this SEIS have incorporated the revised criteria. 

D.2 OVERVIEW OF INPUT DATA AND ASSUMPTIONS 

The input data and assumptions are described in Appendix D of the January 2011 Long-Term 

Management and Storage of Elemental Mercury Environmental Impact Statement (Mercury Storage EIS), 

as updated in Appendices B and E of this SEIS.2 Some of those input data and assumptions are restated 

here for the convenience of the reader and augmented where appropriate with data specific to the WIPP 

Vicinity reference locations. 

D.2.1 Quantity of Mercury to Be Shipped 

Mercury would be received as 99.5 percent or greater pure elemental mercury from a variety of sources, 

tabulated in Table D–1. 

Additional detail on the estimated quantities of elemental mercury is provided in Appendix D, 

Section D.1, of the January 2011 Mercury Storage EIS. The starting point for Table D–1 is Chapter 1, 

Table 1–1, which provides an estimate of between 8,500 and 9,700 metric tons (8,000 and 10,700 tons) 

for the total amount of mercury that may be shipped to the chosen receiving site based 

on a 40-year period of analysis. For the purposes of this analysis, the amount was rounded up to 

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

D–2

10,000 metric tons (11,000 tons). This is consistent with the U.S. Department of Energy Interim 

Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of Elemental 

Mercury (Interim Guidance) (DOE 2009).3 However, the data in Table 1–1 should not be interpreted as 

commitments on DOE’s part (e.g., to accept mercury from Peru via New York or to move mercury from 

Y–12 or to the exact dates of shipments from Y–12 and the chlor-alkali facilities). They are merely 

intended to be a reasonable set of numbers that can be used in a screening risk assessment. Changes since 

the publication of the January 2011 Mercury Storage EIS may mean that less mercury than was 

contemplated at the time would actually be shipped to the mercury storage facility. However, 

10,000 metric tons remains an upper bound that is kept in this Draft Mercury Storage SEIS to facilitate 

comparisons with the other sites that are analyzed in the January 2011 Mercury Storage EIS.

Table D–1. Dispatching Sites, Years, and Quantities of Elemental Mercury

Site

Years of 

Shipmentsa

Total Mass 

(metric tons)

Y–12 National Security Complex 1st – 2nd 1,206

Chlor-Alkali Facilities

Ashta Chemical, Ashtabula, Ohio 1st – 7th 108

PPG, New Martinsville, West Virginia 1st – 7th 244

Olin, Charleston, Tennesseeb 1st – 7th 478

Olin, Augusta, Georgiab 1st – 7th 271

Reclamation and Recycling Facilities, Mining, Shipments into Port of New York

Mining (Carlin, Nevada) 1st – 40th 3,687

Mining (from Peru via Port of New York) 1st – 40th 1,236

Philadelphia region (Bethlehem Apparatus) 1st – 40th 1,939

Chicago region (D.F. Goldsmith) 1st – 40th 831

Total 1st – 40th 10,000

a For purposes of analysis, the January 2011 Long-Term Management and Storage of Elemental Mercury 

Environmental Impact Statement assumes a 40-year operational period with the first year starting in 2013 

and the fortieth year, in 2052. An operational start date is not known at this time; however, the period of 

analysis remains 40 years. For example, if the mercury storage facility(ies) were to start operations in 

2014, the last year of operations would likewise shift to 2053, and so forth.

b Olin Corporation has announced that its chlor-alkali plants in Tennessee and Georgia will be consolidated 

and converted to mercury-free technology by the end of 2012 (Pavey 2012). The fate of this mercury is 

uncertain and may still be eventually shipped to a DOE facility(ies) for long-term management and 

storage; therefore, the quantities of mercury analyzed in this Long-Term Management and Storage of 

Elemental Mercury Supplemental Environmental Impact Statement remain unchanged.

Note: To convert metric tons to tons, multiply by 1.1023.

Key: Bethlehem Apparatus=Bethlehem Apparatus Company, Inc.; D.F. Goldsmith=D.F. Goldsmith Chemical 

and Metal Corporation.

 

3 The analysis in this appendix is intended to be consistent with the Interim Guidance.
Human Health and Ecological Risk Assessment Analysis 

D.2.2 Assumptions About Transportation Analysis 

D–3

Offsite accidents could occur during transportation to the chosen storage site. The following are the 

assumptions governing the transportation analysis (some of these assumptions overlap those about the 

facility): 

The following three transportation scenarios are considered: 

Truck Scenario 1: Full truck shipments. 

Truck Scenario 2: Truck shipments are at 50 percent capacity (doubling the number of truck 

shipments) from reclamation and recycling (R&R) facilities, gold mines, and the Port of 

New York, but full truck loads from Y–12 and chlor-alkali facilities; Truck Scenario 2 also 

accommodates the possibility that there may be shipments of pallets containing less than 

49 flasks. 

Railcar Scenario: Shipments by full railcars. 

No transportation scenarios other than by rail or truck are considered. 

All mercury from Y–12 would be transported in 3-liter (3-L) (0.8-gallon) (34.6-kilogram 

[76-pound]) flasks. Mercury from chlor-alkali facilities would be transported in 1-metric-ton 

(1-MT) containers. The overall proportion of mercury in 1-MT containers to that in 3-L flasks 

would be 60:40 (DOE 2009). Mercury from mining or R&R facilities in the United States could 

be transported in either 3-L flasks or 1-MT containers. Mercury from mining in Peru would be 

transported in 3-L flasks (Brooks et al. 2007). 

Packaging of the mercury at the point of origin, transportation to the R&R facilities or to a 

U.S. port, any processing and repackaging at the R&R facilities, and subsequent loading onto 

trucks or railcars are not analyzed in this Draft Mercury Storage SEIS on the grounds that all of 

these activities would be carried out anyway, irrespective of the final disposition of the elemental 

mercury. Elemental mercury would be transported either by road or rail. No other mode of 

transportation would be considered. 

Y–12 shipments would occur in the first 2 years of operations. Chlor-alkali shipments would be 

spread across the first 7 years of operations. R&R shipments would be spread across the entire 

40 years of operations.4

 Shipments from Peru would be imported through the Port of New York 

and would also be spread across 40 years. For the purposes of analysis, it is assumed that all 

mercury from mining in the United States would be shipped from Carlin, Nevada, also over a 

period of 40 years. Carlin is located near most of the major gold mines in northern Nevada; the 

state generates approximately 80 percent of U.S.-mined gold. 

As stated above, mercury from Y–12 would be shipped to the DOE storage facility in 3-L 

(0.8-gallon) flasks containing 34.6 kilograms (76 pounds) of elemental mercury. In total, 

1,208,000 kilograms in 34,906 flasks would be shipped. 

As noted above, each flask would contain 34.6 kilograms (76 pounds) of elemental mercury. In 

addition, the total mass of the empty flask could vary with flask type. The Interim Guidance, for 

example, lists flasks varying in weight from 3.4 to 6.3 kilograms (7.5 to 13.9 pounds). For the 

purposes of this analysis, container type T-13, with a mass of 4.1 kilograms (9.0 pounds), is taken 

to be representative. Therefore, the weight of a loaded flask would be 34.6 + 4.1, or 

 

4

 The results of the risk analysis are not sensitive to the precise details of the temporal distribution of shipments. The analysis 

makes use of the annual average over 40 years only.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

D–4

38.7 kilograms (about 85 pounds). For a discussion of the sensitivity of the analysis to this 

assumption, see Appendix D, Section D.6.1.3, of the January 2011 Mercury Storage EIS.

Flasks would be transported in box pallets that each contains an array of 7 × 7 flasks. The 

dimensions of each pallet would be 1.44 by 1.44 meters (56 by 56 inches) (DOE 2009). One

pallet would contain 34.6 × 49, or 1,695 kilograms (approximately 3,738 pounds), of elemental 

mercury. The total mass of the loaded flasks in a pallet would be 38.7 kilograms per 

flask × 49 flasks, or 1,896 kilograms (approximately 4,181 pounds). The mass of the pallet and a 

spill tray must be added to this figure. It is assumed that these would add 100 kilograms (about 

220 pounds) to the weight of the flasks, so the total weight of a loaded pallet would be 

1,996 kilograms, rounded up to 2,000 kilograms (4,400 pounds) or 2 metric tons (2.2 tons).

A 1-MT container should not weigh more than 1,250 kilograms (2,750 pounds) when loaded with 

1,100 kilograms (2,400 pounds) of mercury (DOE 2009). Therefore, when loaded with 1 metric 

ton (about 1.1 tons) (about 1,000 kilograms [2,200 pounds]), it should not weigh more than 

1,160 kilograms (2,550 pounds). During transportation, it would be sitting in a spill tray that can 

contain the full 1 metric ton of mercury; this tray would be approximately 10 centimeters 

(4 inches) less than the height of the container so that a forklift would be able to remove the 

1-MT container using the lifts on top of it. The approximate dimensions of such a container are 

0.62 by 0.62 by 0.41 meters (24 by 24 by 16 inches). The assembly of 1-MT container, spill tray, 

and pallet is assumed to weigh 100 kilograms (about 220 pounds) more than the container itself, 

i.e., 1,260 kilograms (2,770 pounds).

It is assumed that the capacity of a truck is 18,180 kilograms (40,000 pounds) 

(DLA 2004a: Section 2.3.1.1). Therefore, one truck could ship either (18,180 kilograms/ 

2,000 kilograms per pallet) = 9.09 (rounded down to 9) pallets of 49 flasks or (18,180 kilograms/ 

1,260 kilograms per 1-MT container) = 14.4 (rounded down to 14) 1-MT containers. The 

effective floor area of a truck is 2.4 meters (8 feet) wide by 15 meters (48 feet) long. A pallet’s 

dimensions (1.44 by 1.44 meters [56 by 56 inches or 4.67 by 4.67 feet]) would allow a row of 

pallets 1 wide and 10 long to be loaded into the truck, which is more than the weight limit of 

9 pallets. The total of 14 1-MT containers that the truck would accommodate is also limited by 

weight rather than by area.

The capacity of a railcar is approximately 68 metric tons (75 tons) (DLA 2004b). Therefore, the 

railcar could, in principle, ship up to (68,000 kilograms/2,000 kilograms per pallet) = 34 pallets of 

49 flasks. However, the Defense Logistics Agency’s (DLA’s) Final Mercury Management 

Environmental Impact Statement (DLA 2004a:Section 2.3.1.1) shows that the effective usable 

floor area is 3 meters (10 feet) wide by 18 meters (59 feet) long, sufficient to accommodate two 

rows, each row with 12 pallets of 49 flasks, i.e., 24 pallets. Therefore, the railcar is limited by 

area to 24 pallets of 49 flasks. The railcar can accommodate (68,000 kilograms/1,260 kilograms 

per 1-MT container) = 54 1-MT containers; in this case, the total is not limited by available space.

It is assumed that 70 percent of R&R mercury would be shipped from the greater Philadelphia 

region (assuming geographic coordinates of Bethlehem Apparatus Company, Inc.) and 30 percent 

from the greater Chicago region (assuming geographic coordinates for D.F. Goldsmith Chemical 

and Metal Corporation) to a DOE facility. See Section D.1 of the January 2011 Mercury Storage 

EIS for an explanation of these percentages.

Table D–2 summarizes the amounts of mercury that would be transported from each of the locations

listed in the assumptions above, with the corresponding total expected numbers of 7- by 7-pallets and 

1-MT containers transported over 40 years.
Human Health and Ecological Risk Assessment Analysis

D–5

Table D–2. Estimate of Amounts of Mercury to be Transported

Site

Years of 

Shipmentsa

Total Mass 

(metric tons)b

Number of 

Palletsc

Number of 

1-Metric-Ton 

Containersd

Number of 

Truckse

Number of 

Railcarsf

Y–12 National Security Complex 1st – 2nd 1,206 713 0 80 30

Chlor-Alkali Facilities

Ashta Chemical, Ashtabula, Ohio 1st – 7th 108 0 108 8 2

PPG, New Martinsville, 

West Virginia

1st – 7th 244 0 244 18 5

Olin, Charleston, Tennessee 1st – 7th 478 0 478 35 9

Olin, Augusta, Georgia 1st – 7th 271 0 271 20 6

Reclamation and Recycling Facilities, Mining, Shipments into Port of New York – Truck Scenario 1 

(full truck shipments)

Mining (Carlin, Nevada) 1st – 40th 3,687 526 2,798 259 74

Mining (via Port of New York) 1st – 40th 1,236 731 0 82 31

Philadelphia region 

(Bethlehem Apparatus)

1st – 40th 1,939 277 1,472 137 40

Chicago region (D.F. Goldsmith) 1st – 40th 831 119 631 60 17

Reclamation and Recycling Facilities, Mining, Shipments into Port of New York – Truck Scenario 2 

(50 percent capacity truck shipments), Railcar Scenario (full rail car shipments)

Mining (Carlin, Nevada) 1st – 40th 3,687 526 2,798 518 74

Mining (via Port of New York) 1st – 40th 1,236 731 0 164 31

Philadelphia region 

(Bethlehem Apparatus)

1st – 40th 1,939 277 1,472 274 40

Chicago region (D.F. Goldsmith) 1st – 40th 831 119 631 120 17

a For purposes of analysis, the January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

assumes a 40-year operational period with the first year starting in 2013 and the fortieth year, in 2052. An operational start date is not known 

at this time; however, the period of analysis remains 40 years. For example, if the mercury storage facility(ies) were to start operations in 

2014, the last year of operations would likewise shift to 2053, and so forth.

b Average mass transported per year during the 40-year period of analysis: 250 metric tons.

c Average number of pallets shipped per year during the 40-year period of analysis: 59.

d Average number of 1-metric-ton containers shipped per year during the 40-year period of analysis: 150.

e Average number of trucks per year during the 40-year period of analysis: approximately 18 (Truck Scenario 1) or 31 (Truck Scenario 2).

f Average number of railcars per year during the 40-year period of analysis: approximately 5.

Note: To convert metric tons to tons, multiply by 1.1023.

Key: Bethlehem Apparatus=Bethlehem Apparatus Company, Inc.; D.F. Goldsmith=D.F. Goldsmith Chemical and Metal Corporation.

In general, the probability of a transportation accident or fatality during a specified operation (such as 

transportation from one site to another) is calculated by multiplying the number of miles traveled during 

the operation by a standard factor derived from empirical statistics, which is expressed in terms of the 

number of accidents per mile, the number of fatalities per mile, or the number of releases of hazardous 

material per mile. This transportation risk assessment considers a series of assumptions for three types of 

accidents:

Accidents that cause a spill of mercury that subsequently evaporates (no fire): The frequency of 

such accidents is derived from the above-mentioned empirical factor of releases per mile.

Accidents that cause a major fire that is sufficient to evaporate some of the mercury: The 

frequency of such accidents is derived from the above-mentioned empirical factor of accidents 

per mile, multiplied by the probability that, given an accident, a major fire would occur.

Accidents that cause fatalities due to mechanical impact (i.e., accidents that are unrelated to the 

fact that the cargo is mercury): The predicted frequency of such accidents is derived from the 

above-mentioned empirical factor of fatalities per mile.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

D–6

To calculate the frequency of occurrence of transportation accidents, certain input data are required. The 

input data include the definition of the transportation route, the estimation of the number of miles 

traveled, and the empirical accident factors and conditional probabilities discussed above. 

The basic probabilities applied in the transportation risk analysis for accident, fatality, and release rates 

for truck and rail were calculated using data obtained from the U.S. Department of Transportation Federal 

Motor Carrier Safety Administration and the Federal Railroad Administration, respectively. Both the 

truck and rail data are from the years 2004 to 2007. The rates calculated for rail are in terms of railcar 

miles. The conditional probability of a fire, given a truck accident, is less than 1 percent, and given a rail 

accident, is 1 percent; therefore, the bounding conditional probability for both of these cases is assumed to 

be 1 percent (Fischer et al. 1987). Table D–3 summarizes the basic probabilities used in the 

transportation analysis. 

Table D–3. Basic Probabilities Used in the Transportation Risk Analysis 

Description Value

Truck accident with no mercury spill and no fire 6.5 10-7

per truck mile

Truck accident with mercury spill (no fire) 8.5 10-8

per truck mile

Probability of fire after truck accident 0.01a

Truck accident with fire and release of mercury 6.5 10-9

per truck mile

Truck accident with mechanically induced fatality (no fire) 2.3 10-8

per truck mile

Rail accident with no mercury spill and no fire 2.6 10-7

per railcar mile

Rail accident with mercury spill (no fire) 1.2 10-9

per railcar mile

Probability of fire after rail accident 0.01

Rail accident with fire and release of mercury 2.6 10-9

per railcar mile

Rail accident with mechanically induced fatality 1.6 10-8

per railcar mile

a To obtain the probability per mile of a mercury spill with fire, this factor of 0.01 is applied to the 

probability per mile of a truck accident with no mercury spill and no fire, not to the probability per mile of 

a truck accident with mercury spill (no fire). This is likely conservative. 

Source: Fischer et al. 1987; FMCSA 2006:39, 2007, 2008:49, 2009a, 2009b; FRA 2009; Saricks and 

Tompkins 1999. 

D.2.3 Assumptions About the Mercury Storage Facility 

If one of the WIPP Vicinity reference locations is the chosen site, a new storage facility will be built on 

one of three plots, as described in Chapter 2, Section 2.3, and shown in Figures 2–6 and 2–7. 

The Mercury Export Ban Act of 2008 does not indicate specific features required for the storage facility 

(or facilities) that would be used to store elemental mercury. Such buildings may be either newly 

constructed or existing structures. If one of the WIPP Vicinity reference locations is the chosen site, 

there will be new construction. However, the Interim Guidance (DOE 2009) establishes the basic 

requirements for safe storage of mercury, including preliminary design elements of a suitable new facility. 

The analysis in this Draft Mercury Storage SEIS assumes that such a facility would be constructed or 

modified so as to be consistent with the Interim Guidance, which envisages that a storage facility would 

consist of the following four areas (not necessarily all in the same building): 

Receiving and Shipping Area—this physical area would include dedicated space(s) for the 

receipt, inspection, acceptance, handling, and shipment of containers. 
Human Health and Ecological Risk Assessment Analysis

D–7

Handling Area—this physical area would include dedicated space(s) for work involving potential 

contamination, including (1) safely handling and cleaning palletized or individual flasks that have 

external mercury contamination and/or leaking mercury, (2) reflasking failed 3-L flasks identified 

during the inspections for acceptance, and (3) safely managing leaking 1-MT containers 

(see Section D.2.4 for a discussion of mercury containers). This area is needed for non-routine 

and emergency response activities in the event of leaking flasks and containers.

Storage Area—this physical area would include dedicated space(s) for the storage and monitoring 

of mercury containers.

Office Administration Area—this physical area would include dedicated space(s) for the storage 

and maintenance of records, waste acceptance criteria, accountability criteria, shipping papers, 

and databases.

The Interim Guidance further assumes that any DOE mercury storage facility (or facilities) would have 

the following characteristics:

Resource Conservation and Recovery Act–regulated and –permitted to receive discarded 

elemental mercury generated in the United States

Naturally ventilated (that is, not air conditioned)

Adaptable to a modular design

Operated for DOE by a contractor

The Interim Guidance also provides the following: (1) a conceptual scale view of the overall operational 

area needed for storage of up to 10,000 metric tons (11,000 tons) of elemental mercury, based on a rough 

assessment of a 60:40 percent breakdown by approximately 6,000 1-MT and 116,000 3-L flasks, 

respectively, with 3-L flasks on pallets and racks and (2) an estimate of up to 14,000 square meters 

(150,000 square feet) for a “comfortably-sized layout.”

The storage facility would have features that would reduce the risk to the environment and maximize the 

efficiency of container inspection, including at least three boundaries between the mercury and the 

environment, including the following:

The container: all containers accepted into the facility would meet DOE acceptance criteria to 

ensure structural integrity. 

The spill containment tray that is under all the containers (see Section D.2.4 for details). If a 

container fails, the mercury would be contained and should be quickly discovered and cleaned up.

The solid concrete floor, which would be coated so as to be impermeable to mercury and water. 

Therefore, there is negligible risk that spillages inside the storage building would penetrate the 

floor and sink into the ground.

Perimeter curbing or other building design features that would prevent spilled mercury from 

flowing out of the building.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

D–8

Table D–4 summarizes the data used for new construction at the WIPP Vicinity reference locations. 

Table D–4. Physical Data for a Mercury Storage Facility – New Construction 

Parameter New Facility

Facility footprint 205,536 square feet

Dimensions (length × width) 506 × 336 feet

Building height 20 feet

Number of buildings 1

Total storage space 146,496 square feet

Building construction Structural steel frame on reinforced-concrete 

slab and sheet metal shell; epoxy-sealed floor.

Access/security Manned security 24 hours per day, 7 days per 

week, with perimeter barbed-wire fence; 

remote interior and exterior surveillance.

Note: To convert square feet to square meters, multiply by 0.092903; feet to meters, by 0.3048. 

D.2.4 Assumptions About Mercury Containers 

Upon arrival at the mercury storage facility(ies), a visual inspection would be performed to detect any 

obvious problems that may have occurred while on the truck or railcar. If the initial inspections and 

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

Area, where additional visual inspections would be performed to check for leaks, structural integrity of 

pallets and containers, approved container types, corrosion, etc. The mercury would then be moved to the 

Handling Area for any additional verification that it meets waste acceptance criteria (e.g., 99.5 percent 

purity). The containers and pallets that pass the acceptance/verification process would be placed into 

long-term storage and location data would be recorded. Mercury received into the storage facility would 

be in elemental form with a purity of 99.5 volume percent or greater. The mercury would be free of any 

radiological components. The remaining 0.5 percent content should not be capable of corroding carbon 

steel or stainless steel (elemental mercury has been proven not to corrode carbon steel or stainless steel) 

(DOE 2009). 

The mercury is expected to arrive at the facility in either 3-L (0.8-gallon) (34.6-kilogram [76-pound]) or 

1-MT (1.1-ton) containers. The following are assumptions about the storage containers: 

After the containers are accepted, they would be separated in the facility by size (3-L or 1-MT). 

The 3-L flasks would each contain 34.6 kilograms (76 pounds) of elemental mercury. 

Although the Interim Guidance discusses several different types of 3-L flasks, varying in 

empty mass between 3.4 and 6.3 kilograms (7.5 and 13.9 pounds), a representative mass 

of 4.1 kilograms (9.0 pounds) has been assumed for the present analysis. Appendix D, 

Section D.6.1.3, of the January 2011 Mercury Storage EIS provides a discussion of the sensitivity 

of the results to this assumption. If the heaviest flasks were used, estimated frequencies of 

crashes under Truck Scenario 1 would increase by about 12.5 percent (heavier pallets would 

mean fewer pallets per trip and therefore more truck trips). This increase means that there would 

be a slight non-conservatism in the calculations. However, since it is unlikely that all of the 

elemental mercury would be shipped in the heaviest flasks, this non-conservatism is not further 

investigated here. The effect on rail transportation would be much smaller and there would be no 

effect on Truck Scenario 2, in which the truck would be only half full. 
Human Health and Ecological Risk Assessment Analysis 

D–9

The 3-L flasks would be both transported and stored in box pallets that contain an array 

of 7 by 7 flasks, as shown in Figure D–1; the dimensions of each pallet would be 

1.44 by 1.44 meters (56 by 56 inches). 

Figure D–1. 7- by 7-Array of 3-Liter Flasks 

The Interim Guidance states, “The 3-L containers are preferred to be sent in box pallets that 

comply with the following: ...(4) the pallet may be constructed of painted steel, untreated 

hardwood with fire protective paint applied, treated hardwood, or other materials that have 

equivalent load capacity, fire resistance, degradation rate (e.g., expected life), and would not 

require disposal as hazardous waste.” The case chosen for study in this Draft Mercury 

Storage SEIS is use of wooden pallets because this case conservatively maximizes the amount of 

flammable material that would be available to vaporize elemental mercury in the event of a fire. 

The 7- by 7-pallets of 3-L flasks would stand in a metal spill tray capable of holding the contents 

of 10 percent (approximately five) of the flasks in the pallet. 

In the facility, the 3-L flasks in box pallets may be placed onto seismically rated storage racks and 

stacked two or three high. The height of the rack would not exceed 3.7 meters (12 feet). See 

Figure D–2. 

The racks would require a 3-degree slope toward the aisle to allow leaked mercury to flow toward 

the edge of the spill tray to assist in quickly locating failed flasks. The walls of the spill tray 

would be sufficiently high to contain the contents of five flasks at the indicated angle. The 

Interim Guidance states that overpacking the 3-L flasks into drums is not recommended for 

transportation or long-term storage. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

D–10

Figure D–2. 3-Liter Flasks in Box Pallets on a Seismically Rated Rack 

The 1-MT container should not be filled with more than approximately 1.1 metric tons (1.2 tons) 

(1,090 kilograms [2,400 pounds]) of liquid mercury and must provide a minimum head space of 

15 percent after maximum fill. The gross weight of the full container should not exceed 

1.25 metric tons (1.4 tons) (1,250 kilograms [2,750 pounds]). For the purposes of this analysis, it 

is assumed that each 1-MT container contains exactly 1 metric ton (about 1.1 tons) (about 

1,000 kilograms [2,200 pounds]) of elemental mercury and weighs 1.16 metric tons (about 

1.3 tons) (1,160 kilograms [2,550 pounds]). A typical 1-MT container with Resource 

Conservation and Recovery Act labeling is shown in Figure D–3.

Figure D–3. 1-Metric-Ton Container 
Human Health and Ecological Risk Assessment Analysis 

D–11

The 1-MT containers are expected to be sent on pallets, one container per pallet. The pallet 

should have a built-in spill tray capable of containing 1 metric ton of mercury. The spill tray side 

walls should be approximately 10 centimeters (4 inches) lower than the height of the container to 

allow for a forklift to remove the container. 

Upon arrival at the storage facility, the 1-MT containers would be removed from their pallets and 

set into spill trays on the floor of the facility. 

The 1-MT containers could be stored single or double stacked on the floor in spill trays; 

Figure D–4 shows a single-stack configuration with eight 1-MT containers. The spill tray would 

be designed to contain the full contents of one 1-MT container. The single-stack configuration 

was assumed for the purposes of analysis. 

Figure D–4. 1-Metric-Ton Containers in a Spill Tray 

D.3 OVERVIEW OF MERCURY TOXICITY AND RISK 

The methodology and approach for conducting the risk analyses are described in Appendix D of the 

January 2011 Mercury Storage EIS, as updated in Appendices B and E of this SEIS.5 The methodology 

and approach are summarized here for the convenience of the reader and augmented where appropriate 

with data specific to the WIPP Vicinity reference locations. 

 

5

 Since publication of the January 2011 Mercury Storage EIS, DOE has published revised Protective Action Criteria for 

exposure to mercury vapor. This has resulted in changes to the definition of severity levels (i.e., magnitude of impacts) for 

assessing acute-inhalation exposures to the public under certain accident scenarios. Appendices B and E of this SEIS update 

parts of Chapter 4 and Appendix D of the January 2011 Mercury Storage EIS. The impact analyses for the WIPP Vicinity 

reference locations discussed in this SEIS have incorporated the revised criteria. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

D–12

D.3.1 Toxic Effects of Mercury

This study considers three forms of mercury:6(a) elemental mercury, which is the form in which 

mercury would be stored and transported; (b) inorganic/divalent mercury,7 which is the form into which 

elemental mercury can be converted if it is involved in a fire;8and (c) methylmercury, which can 

potentially be formed if elemental mercury or inorganic mercury becomes mixed with soil or sediment.9 

The U.S. Environmental Protection Agency (EPA) , in its Mercury Study Report to Congress

(EPA 1997a, 1997b, 1997c), provides exhaustive descriptions of the potential effects of these forms of 

mercury on humans. Appendix D, Sections D.3.1 through D.3.3, of the January 2011 Mercury Storage 

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

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

it is readily distributed throughout the body and may cause 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.

 

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

January 2011 Mercury Storage EIS, for further discussion. For a more-detailed primer on the forms of mercury, see 

GreenFacts (2004).

7 Mercury can exist in three oxidation states (EPA 1997a:2-2): elemental (Hg0

), mercurous (Hg2

2+), and mercuric (Hg2+). 

Mercurous compounds are unstable in the environment. In this SEIS, 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, of the 

January 2011 Mercury Storage EIS for further discussion.

8 The potential formation of divalent mercury in a fire is extremely important for the assessment of risk in this SEIS. 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 SEIS that lead to 

deposition on the ground from a vapor cloud are the fire scenarios. See Appendix D, Section D.7.3.3, of the January 2011

Mercury Storage EIS for further discussion.

9 Methylmercury is used as a surrogate for all organomercuric compounds, as is the case in the U.S. Environmental Protection 

Agency’s Mercury Study Report to Congress (EPA 1997b). See Appendix D, Section D.1.1.2, of the January 2011 Mercury

Storage EIS for further discussion.
Human Health and Ecological Risk Assessment Analysis 

D–13

Human Receptors

The purpose of the human health analysis in this SEIS 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/public receptors 

Assessment of Risk

Risk under any specific accident scenario is generally expressed as a function of two quantities: 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 D–5 was used to assess the magnitude of the risk. 

Figure D–5. Risk (Frequency and Consequence) Ranking Matrix 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

D–14

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, of the January 2011 Mercury Storage EIS. 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 ≥ 10-2per year)

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

> f ≥ 10-4per year)

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

> f ≥ 10-6per year)

FL-I (negligible) – less than once in 1 million years (f < 10-6per year)

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, of the January 2011 Mercury Storage EIS (as updated in Appendix E, 

Section E.2, of this Draft Mercury Storage SEIS). 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, (d) exposures to mercury deposited on the 

ground, and (e) consumption of methylmercury in fish. How these SLs are assigned is discussed in 

Section D.1.1.2 of the January 2011 Mercury Storage EIS (as updated in Appendix E, Section E.2, of this 

Draft Mercury Storage SEIS).

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 of the January 2011 Mercury Storage EIS (as 

updated in Appendix E, Section E.2, of this Draft Mercury Storage SEIS). The SLs are related to EPA’s 

Acute Exposure Guideline Levels (AEGLs), DOE’s Protective Action Criteria (PACs) and Temporary 

Emergency Exposure Limits (TEELs), and the American Conference of Governmental Industrial 

Hygienists’ (ACGIH’s) threshold limit values, as summarized in Table D–5.

Table D–5. 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 (see Table D–6) Potential for lethality as 

concentration increases 

above AEGL-3

Inhalation Severity Level III < AEGL-3 and ≥ AEGL-2 (see Table D–6) Potential for severe, sublethal, 

irreversible health effects

Inhalation Severity Level II < AEGL-2 and 

(a) ≥ PAC-1 (td ≤ 1 hour)

(b) ≥ ACGIH TLV 8-hour TWA

(td > 1 hour)

Potential for transient health 

effects, reversible on cessation 

of exposure

Inhalation Severity Level I (a) < PAC-1 (td ≤ 1 hour)

(b) < ACGIH TLV 8-hour TWA

(td > 1 hour)

Negligible-to-very-low 

consequences

a Exposure period up to 8 hours. 

b PAC-1=0.15 mg/m3

(DOE 2012); ACGIH-0=0.025 mg/m3(OSHA 2012).

Key: ≥ =greater than or equal to; <=less than; ACGIH=American Conference of Governmental Industrial Hygienists; 

AEGL=Acute Exposure Guideline Level; mg/m3=milligrams per cubic meter; PAC=Protective Action Criterion; td=duration of 

exposure; TLV=threshold limit value; TWA=time-weighted average.
Human Health and Ecological Risk Assessment Analysis

D–15

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 D–6.

Table D–6. 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/m32.1 mg/m31.7 mg/m30.67 mg/m30.33 mg/m3

AEGL-3 16 mg/m311 mg/m38.9 mg/m32.2 mg/m32.2 mg/m3

a Table D–5 uses Protective Action Criterion 1 and the American Conference of Governmental Industrial Hygienists’ threshold 

limit value for 8-hour time-weighted average as a surrogate AEGL-1. The reasons for doing so are described in Appendix B, 

Section B.2, of this SEIS. In short, EPA has yet to publish values for the AEGL-1 for elemental mercury.

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 for mercury. In such cases, DOE recommends the use of PACs, 

otherwise known as TEELs (DOE 2008). There are three levels of PACs and three levels of TEELs:

PAC-3/TEEL-3 is the airborne concentration (expressed as parts per million [ppm] or milligrams per 

cubic meter) of a substance above which it is predicted that the general population, including 

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

PAC-2/TEEL-2 is the airborne concentration (expressed as ppm or milligrams per cubic meter) of a 

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

D–16

PAC-1/TEEL-1 is the airborne concentration (expressed as ppm or milligrams per cubic meter) of a 

substance above which it is predicted that the general population, including susceptible individuals, 

could experience discomfort, irritation, or certain asymptomatic, nonsensory effects. However, these 

effects are not disabling and are transient and reversible upon cessation of exposure.

Each PAC or TEEL is assigned a single concentration for a single exposure time (1 hour). PACs or 

TEELs are intended to be used when AEGLs or their predecessors, Emergency Response Planning 

Guidelines (ERPGs), are not available. As discussed in Appendix B, it was judged that the following is 

conservative as a “surrogate AEGL-1:” the boundary between SL-II and SL-I is equal to the PAC-1 

(TEEL-1) of 0.15 milligrams per cubic meter for durations of exposure up to 1 hour and equal to the 

ACGIH threshold limit value for an 8-hour time-weighted average of 0.025 milligrams per cubic meter 

for durations of exposure exceeding 1 hour. This latter assumption is highly conservative.

Appendix D, Section D.1.1.2.3, of the January 2011 Mercury Storage EIS also explains why Table D–5 

applies to inorganic/divalent mercury as well as to elemental mercury. AEGLs and PACs/TEELs for 

methylmercury were not used in this study because the accident scenarios considered are such that they 

can only lead to inhalation of elemental mercury or inorganic mercury. Methylmercury can only be 

formed after deposition of the inorganic mercury on the ground or on water and mixing with 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, of the January 2011 Mercury Storage EIS (as updated in 

Appendix E, Section E.2, of this Draft Mercury Storage SEIS) 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, even taking into account the revised PAC-1 of 

0.15 milligrams per cubic meter; this issue is not discussed further in this SEIS.

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–19, of the January 2011 Mercury Storage 

EIS). 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 D–5. 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 D–6). 

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 D–5 

applies to workers as well as to the public.

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

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

the ACGIH’s time-weighted average/threshold limit value (TWA/TLV) of 0.025 milligrams per cubic 

meter of mercury vapor (OSHA 2012). Referring to Figure D–5, this defines the threshold between 

SL-I and SL-II. The analysis performed for this SEIS shows that involved worker exposures would 

always be below this threshold, assuming a combination of ventilation, inspection, monitoring, and use of 

personal protective equipment, as recommended by the Interim Guidance (DOE 2009). Therefore, there 

is no need to define the thresholds for SL-III and SL-IV.
Human Health and Ecological Risk Assessment Analysis

D–17

In addition, measurements taken at facilities in which the DLA has stored mercury for many decades 

show that, under the storage conditions expected at the candidate sites, mercury vapor concentrations 

inside the building would not exceed the TWA/TLV. Appendix D, Section D.4.1.1, of the January 2011

Mercury Storage EIS reports on mercury vapor concentrations observed over several months in 2001 and 

2002 in mercury storage warehouses at the DLA’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 of the proposed new storage building. 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 concentration10 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 chronic-inhalation exposures to humans outside buildings, EPA has published a reference 

concentration (RfC) of 0.0003 milligrams per cubic meter (EPA 2002). The consequences of exposures 

below this level are negligible, so, in terms of the SLs in Figure D–5, the RfC marks the boundary 

between SL-I and SL-II. The analysis performed for this SEIS 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 SL-IV.

Appendix D, Section D.4.1.2, of the January 2011 Mercury Storage EIS reviews observed concentrations 

near DLA 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.

Appendix D, Section D.1.1.2.6, of the January 2011 Mercury Storage EIS discusses a value for the level 

of deposited mercury that can be used to define the boundary between SL-I and SL-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 operations involving 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 SL-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 SEIS 

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 SL-IV.

 

10 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.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

D–18

One highly publicized concern is that of the accumulation of methylmercury in fish, which would be 

subsequently consumed by humans. The EPA criterion for methylmercury in fish is 0.3 milligrams of 

methylmercury per kilogram of fish tissue, wet weight (EPA 2009b). This is the concentration in fish 

tissue that should not be exceeded based on a total fish and shellfish consumption-weighted rate of 

0.0175 kilograms of fish per day (EPA 2001), which is essentially a national average. Consumption of 

methylmercury in amounts less than this criterion is expected to have negligible effects on human health. 

Therefore, the EPA criterion is taken to be the boundary between SL-I and SL-II for health effects 

resulting from the average American’s consumption of fish.

There are certain individuals or communities that would consume more fish than 0.0175 kilograms per 

day. According to EPA (1997d), a subsistence fisherman would on average consume 0.059 kilograms per 

day, while the 95th percentile of fish consumption for subsistence fishermen is 0.170 kilograms per day 

(approximately 62 kilograms per year). These consumption amounts could be relevant, for example, to 

certain scenarios in which mercury is spilled near or within tribal reservations where fish is an important 

part of the diet. These higher consumption rates would require lower concentrations of 0.09 and 

0.03 milligrams of methylmercury per kilogram of fish tissue, wet weight, for the respective boundaries 

between SL-I and SL-II.

No information is available that would provide a basis for a choice of boundaries between SL-II and 

SL-III and between SL-III and SL-IV.

The definitions of consequence SLs are summarized in Table D–7.
D

–19

Human Health and Ecological Risk Assessment Analysis

Table D–7. Summary of Definitions of Consequence Severity Levels

Severity 

Level

Acute-Inhalation Exposures –

Involved and Noninvolved 

Workers and Public Receptorsa

Chronic-Inhalation 

Exposures – Involved 

Workersb

Chronic-Inhalation Exposures 

– Noninvolved Workers and 

Public Receptorsb

Exposure to Deposited 

Mercury – All Human 

Receptors

Exposure to Methylmercury 

Accumulated in Fish – All 

Human Receptors

Level 

Definition Consequence

Level 

Definition Consequence

Level 

Definition Consequence

Level 

Definition Consequence

Level 

Definition Consequence

IV ≥ AEGL-3 Potential for 

lethality as 

concentration 

increases above 

AEGL-3

N/A N/A N/A N/A N/A N/A N/A N/A

III < AEGL-3 and 

≥ AEGL-2

Potential for 

severe, sublethal, 

irreversible health 

effects

N/A N/A N/A N/A N/A N/A N/A N/A

II < AEGL-2 and

≥ PAC-1

(td ≤ 1 hour) or 

≥ACGIH TLV 

8-hour TWA

(td > 1 hour)

Potential for 

reversible health 

effects

N/A N/A N/A N/A N/A N/A N/A N/A

I <PAC-1

(td ≤ 1 hour) or 

<ACGIH TLV 

8-hour TWA

(td > 1 hour)

Potential for 

negligible-tovery-low health 

consequences

< ACGIH’s 

8-hour 

TWA/TLV

0.025 mg/m3

Negligible < EPA RfC 

0.0003 mg/m3

Negligible < ATSDRapproved 

cleanup level 

(180 mg/kg) 

for East Fork 

Poplar Creek

Negligible Methylmercury limit 

in fish tissue 

(mg/kg)

< 0.3 

<0.09

<0.03

Negligible

National average

Average, 

subsistence 

fisherman

95th percentile, 

subsistence 

fisherman

a Applies to both elemental mercury vapor and inorganic mercury.

b Elemental mercury vapor inhalation.

Key: ≥ =greater than or equal to; < =less than; ≤ =less than or equal to; ACGIH=American Conference of Governmental Industrial Hygienists; AEGL=Acute Exposure Guideline Level; ATSDR=Agency 

for Toxic Substances and Disease Registry; EPA=U.S. Environmental Protection Agency; mg/kg=milligrams per kilogram; mg/m3=milligrams per cubic meter; N/A=not applicable; PAC=Protective 

Action Criterion; RfC=reference concentration; td=duration of exposure; TLV=threshold limit value; TWA=time-weighted average.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

D–20

D.3.2 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. Up until 

February 2012, 4,436 metric tons (4,890 tons) were safely stored 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 (BWXTymes 2005). DLA completed 

the successful transfer of all 4,436 metric tons (4,890 tons) of defense-related elementary mercury to 

Hawthorne Army Depot, in Hawthorne, Nevada, for long-term management and storage; the last 

shipment was completed in February 2012 (DLA 2012). 

In the course of preparation of the DLA 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 can 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 2009). 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, of the January 2011 Mercury Storage EIS, 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.11 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 100,000 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 rate12 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, of the 

January 2011 Mercury Storage EIS). Therefore, for spills of elemental mercury with no accompanying 

 

11 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. 

12 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, of the January 2011 Mercury Storage EIS. 
Human Health and Ecological Risk Assessment Analysis 

D–21

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. 

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

nearby, there is substantial dilution in the building wake.

13

 New construction such as that envisaged 

at the WIPP Vicinity reference locations is sufficiently large that mixing in the turbulent building 

wake would dilute the elemental mercury concentrations to levels well below PAC-1/TEEL-0 

(see Appendix D, Section D.7.2.1, of the January 2011 Mercury Storage EIS).

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. 

D.4 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/pha.asp?docid=13608.pg=0.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. 

Brooks, W.E., E. Sandoval, M.A. Yepez, and H. Howard, 2007, Peru Mercury Inventory 2006, Open File 

Report 2007-1252, U.S. Geological Survey, Reston, Virginia. 

BWXTymes, 2005, “National Stockpile Mercury Is Relocated,” Vol. 5, No. 5, p. 5, September. 

CDC (Centers for Disease Control and Prevention), 2009, Documentation for Immediately Dangerous to 

Life or Health Concentrations (IDLH), and 1998 OSHA PEL Project Documentation, accessed through 

http://www.cdc.gov/niosh/database.html, June 11. 

DLA (Defense Logistics Agency), 2004a, Final Mercury Management Environmental Impact Statement, 

Defense National Stockpile Center, Fort Belvoir, Virginia, March. 

DLA (Defense Logistics Agency), 2004b, Human Health and Ecological Risk Assessment Report for the 

Mercury Management EIS, Defense National Stockpile Center, Fort Belvoir, Virginia, March. 

DLA (Defense Logistics Agency), 2012, Mercury Management Environmental Impact Statement –

Mercury Consolidation Update, Strategic Materials, accessed through https://www.dnsc.dla.mil/eis/, 

October. 

DOE (U.S. Department of Energy), 2008, Final Site-Wide Environmental Impact Statement for the 

Continued Operation of Los Alamos National Laboratory, Los Alamos, New Mexico, DOE/EIS-0380, 

National Nuclear Security Administration, May. 

 

13 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, of the January 2011 Mercury Storage EIS describes how to calculate concentrations in the wake. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

D–22

DOE (U.S. Department of Energy), 2009, U.S. Department of Energy Interim Guidance on Packaging, 

Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, Office of 

Environmental Management, Washington, DC, November 13.

DOE (U.S. Department of Energy), 2012, Protective Action Criteria (PAC): Chemicals with AEGLs, 

ERPGs, & TEELs, Rev. 27, accessed through http://www.atlintl.com/DOE/teels/teel/teel_pdf.html,

February.

EPA (U.S. Environmental Protection Agency), 1997a, Mercury Study Report to Congress, Vol. III, Fate 

and Transport of Mercury in the Environment, EPA-452/R-97-005, Office of Air Quality Planning and 

Standards and Office of Research and Development, December, Washington, DC.

EPA (U.S. Environmental Protection Agency), 1997b, Mercury Study Report to Congress, Vol. V, Health 

Effects of Mercury and Mercury Compounds, EPA-452/R-97-07, Office of Air Quality Planning and 

Standards and Office of Research and Development, December, Washington, DC.

EPA (U.S. Environmental Protection Agency), 1997c, Mercury Study Report to Congress, Vol. I,

Executive Summary, EPA-452/R-97-003, Office of Air Quality Planning and Standards and Office of 

Research and Development, December.

EPA (U.S. Environmental Protection Agency), 1997d, Exposure Factors Handbook, National Center for 

Environmental Assessment, Office of Research and Development, Washington, DC, August.

EPA (U.S. Environmental Protection Agency), 2001, Water Quality Criterion for the Protection of 

Human Health: Methylmercury, EPA-823-R-01-001, Office of Science and Technology, Office of Water, 

Washington, DC, January.

EPA (U.S. Environmental Protection Agency), 2002, Integrated Risk Information System Mercury, 

Elemental (CASRN 7439-97-6), accessed through http://www.epa.gov/ncea/iris/subst/0370.htm,

December 3.

EPA (U.S. Environmental Protection Agency), 2009a, Graphical Arrays of Chemical-Specific Health 

Effect Reference Values for Inhalation Exposures, EPA/600/R-09/061, Washington, DC, September, 

includes errata sheet dated April 6, 2010.

EPA (U.S. Environmental Protection Agency), 2009b, Guidance for Implementing the January 2001 

Methylmercury Water Quality Criterion, Office of Science and Technology, Washington, DC, January.

Fischer, L.E., C.K. Chou, M.A. Gerhard, C.Y. Kimura, R.W. Martin, R.W. Mensing, M.E. Mount, and 

M.C. Witte, 1987, Shipping Container Response to Severe Highway and Railway Accident Conditions, 

NUREG/CR-4829, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, 

Division of Reactor System Safety, Washington, DC, February.

FMCSA (Federal Motor Carrier Safety Administration), 2006, Large Truck Crash Facts 2004, 

FMCSA-RI-06-040, Analysis Division, March.

FMCSA (Federal Motor Carrier Safety Administration), 2007, 2005 Large Truck Crash Facts Overview, 

FMCSA-RI-07-045, Analysis Division, January.

FMCSA (Federal Motor Carrier Safety Administration), 2008, Large Truck Crash Facts 2006, 

FMCSA-RI-08-001, Analysis Division, January.

FMCSA (Federal Motor Carrier Safety Administration), 2009a, Crash Statistics: National Overview, 

accessed through http://ai.fmcsa.dot.gov/CrashProfile/n_overview.asp, March.
Human Health and Ecological Risk Assessment Analysis

D–23

FMCSA (Federal Motor Carrier Safety Administration), 2009b, Large Truck and Bus Crash Facts 2007, 

FMCSA-RRA-09-029, Analysis Division, January.

FRA (Federal Railroad Administration), 2009, Table 1.01 - Accident/Incident Overview, Office of Safety 

Analysis, accessed through http://safetydata.fra.dot.gov/officeofsafety/, August.

GreenFacts, 2004, Scientific Facts on Mercury, accessed through http://www.greenfacts.org/en/

mercury/l-3/mercury-1.htm.

ORNL (Oak Ridge National Laboratory), 2009, East Fork Poplar Creek, Signs of Ecological Recovery, 

accessed through http://www.ornl.gov/info/ornlreview/rev27-3/text/envside1.htm, November 12.

OSHA (Occupational Safety and Health Administration), 2012, Occupational Safety and Health 

Guideline for Mercury Vapor, U.S. Department of Labor, accessed through http://www.osha.gov/SLTC/

healthguidelines/mercuryvapor/recognition.html, November 12.

Pavey, R., 2012, “Olin Prepares for Mercury Free Future After 47 Years,” The Augusta Chronicle, 

July 15.

Saricks, C., and M.M. Tompkins, 1999, State-Level Accident Rates of Surface Freight Transportation: 

A Reexamination, ANL/ESD/TM-150, Argonne National Laboratory, Argonne, Illinois, April.

Shim, J.S., H-N. Hsieh, and D. Watts, 2002, Mercury Vapor Monitoring at Somerville Depot, 

New Jersey, U.S. Army Engineering and Support Center, Huntsville, Alabama, December.

U.S. Department of Energy Directives

DOE Standard 3009-94, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility 

Documented Safety Analyses, July 1994.

U.S. Public Laws

P.L. 110-414, Mercury Export Ban Act of 2008.

APPENDIX E

UPDATES TO THE

JANUARY 2011 MERCURY STORAGE EIS

E–1

APPENDIX E 

UPDATES TO THE JANUARY 2011 MERCURY STORAGE EIS

This appendix updates the occupational and public health and safety, socioeconomics, and environmental justice 

data and analysis presented in the January 2011 Long-Term Management and Storage of Elemental Mercury 

Environmental Impact Statement (Mercury Storage EIS). The data and analysis for occupational and public health 

and safety presented in the January 2011 Mercury Storage EIS were based on Protective Action Criteria that have 

been revised. The data and analysis for socioeconomics and environmental justice presented in the January 2011 

Mercury Storage EIS in Chapter 3, “Affected Environment,” and Chapter 4, “Environmental Consequences,” were

based on 2000 census data, whereas the data and analysis presented in this appendix are based on 2010 census 

data. These updates are provided to ensure an appropriate comparison between the seven candidate sites 

evaluated in the January 2011 Mercury Storage EIS and the three additional candidate sites evaluated in this Draft 

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

Environmental documentation that has become available since publication of the January 2011 Mercury 

Storage EIS has been reviewed, and no other changes to the affected environment as presented in the 

January 2011 Mercury Storage EIS were found to be necessary. Therefore, the environmental impact analyses for 

all other resource areas at the seven candidate sites evaluated in the January 2011 Mercury Storage EIS, as well 

as the No Action Alternative, remain unchanged.

E.1 INTRODUCTION 

This appendix updates data and analysis on occupational and public health and safety, socioeconomics, 

and environmental justice associated with implementation of each of the alternatives considered in the 

January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact 

Statement (Mercury Storage EIS). As presented in Chapter 1 of this Draft Long-Term Management and 

Storage of Elemental Mercury Supplemental Environmental Impact Statement (Draft Mercury 

Storage SEIS), 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 in the January 2011 Mercury Storage EIS as alternatives for long-term 

mercury1

 storage are as follows: 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, site (WCS). Additionally, the Y–12 National Security 

Complex (Y–12) at the Oak Ridge Reservation is evaluated as a No Action Alternative. Section E.2 of 

this appendix updates the occupational and public health and safety analysis for the candidate sites in the 

January 2011 Mercury Storage EIS. Section E.3 of this appendix updates the socioeconomic and 

environmental justice analysis for the candidate sites in the January 2011 Mercury Storage EIS. 

Section E.4 of this appendix lists the available environmental documentation that has been reviewed to 

ascertain that no changes have occurred to other resource areas at the candidate sites since the 

January 2011 Mercury Storage EIS was published that would necessitate additional updates to the 

affected environment descriptions or analyses. 

1

 Unless the context indicates otherwise, elemental mercury is referred to hereafter simply as “mercury” in this supplemental 

environmental impact statement. 

E.2 UPDATES TO OCCUPATIONAL AND PUBLIC HEALTH AND SAFETY 

ANALYSIS 

The updated occupational and public health and safety analysis in this appendix supersedes parts of the 

analysis in the January 2011 Mercury Storage EIS. As discussed in Appendix B, Section B.2, of this draft 

SEIS, the definition of severity levels (SLs) (i.e., magnitude of impacts) for assessing acute-inhalation 

exposures to the public under certain accident scenarios has changed; however, the methodology and 

approach to conducting occupational and public health and safety analysis remain otherwise unchanged 

and are described in Appendix D of the January 2011 Mercury Storage EIS.

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

E–2

The environmental consequences for the Waste Isolation Pilot Plant (WIPP) Vicinity reference locations 

for occupational and public health and safety incorporate the changes to the definition of SLs and are

presented in this draft SEIS in Chapter 4, Section 4.2.9.

Changes to occupational and public health and safety analyses associated with the candidate sites in the 

January 2011 Mercury Storage EIS are as follows: (1) references to the Protective Action Criterion 1 

(PAC-1) value of 0.3 milligrams per cubic meter and Temporary Emergency Exposure Limit 0 (TEEL-0); 

(2) definition of SLs; (3) the earthquake with a building collapse; (4) transportation accidents without fire; 

(5) transportation accidents with fire; (6) multiple exposures; and (7) intentional destructive acts with fire. 

In summary, the revised PAC-1 value only affects the calculated distances to which SL-II may impact 

members of the public for exposures of 1 hour or less. The risks associated with all accident scenarios 

affected by the revised PAC-1 value, including those on site and during transportation and those with and 

without fire, remain unchanged for all of the candidate sites. Since the American Conference of 

Governmental Industrial Hygienists’ (ACGIH’s) threshold limit value (TLV) for an 8-hour time-weighted 

average (TWA) of 0.025 milligrams per cubic meter is the same as the value previously used as a 

surrogate value for TEEL-0, the impact analyses for exposures exceeding 1 hour also remain unchanged.

Updated tables and text for Chapter 4 and Appendix D of the January 2011 Mercury Storage EIS are as 

follows, with changes indicated in bold type.

References to PAC-1 and TEEL-0:

The PAC-1 value of “0.3 milligrams per cubic meter” is now “0.15 milligrams per cubic meter” and 

“TEEL-0” is now “ACGIH TLV 8-hour TWA” (value remains the same as 0.025 milligrams per cubic 

meter); the original text is found in Chapter 4 on page 4–10 and in Appendix D on pages D–10 and D–58

of the January 2011 Mercury Storage EIS.

Definition of Severity Levels:

Table E–1, below, updates Table 4–1 on page 4–9 and Table D–2 on page D–11 of the January 2011 

Mercury Storage EIS.

Table E–1. Definition of Consequence Severity Bands for

Acute Inhalation of Elemental Mercury, Public Receptorsa

Acute-Inhalation Consequence 

Severity Level

Corresponding Airborne 

Concentrations of Elemental Mercury Expected Health Effects

Inhalation Severity Level IV ≥ AEGL-3 (see Table D–5) Potential for lethality as 

concentration increases above 

AEGL-3

Inhalation Severity Level III < AEGL-3 and ≥ AEGL-2 

(see Table D–5)

Potential for severe, sublethal, 

irreversible health effects

Inhalation Severity Level II < AEGL-2 and 

(a) ≥ PAC-1b (td ≤ 1 hour)

(b) ≥ ACGIH TLV 8-hour TWAb

(td > 1 hour)

Potential for transient health 

effects, reversible on cessation 

of exposure

Inhalation Severity Level I (a) < PAC-1 (td ≤ 1 hour)

(b) < ACGIH TLV 8-hour TWA

(td > 1 hour)

Negligible-to-very low 

consequences

a Exposure period up to 8 hours.

b PAC-1 = 0.15 mg/m3

(DOE 2012a); ACGIH TLV 8-hour TWA = 0.025 mg/m3(OSHA 2012).

Key: ≥=greater than or equal to; >=greater than; <=less than; ACGIH=American Conference of Governmental Industrial 

Hygienists; AEGL=Acute Exposure Guideline Level; mg/m3=milligrams per cubic meter; PAC=Protective Action Criterion; 

td=duration of exposure; TLV=threshold limit value; TWA=time-weighted average.
Updates to the January 2011 Mercury Storage EIS

E–3

Earthquake with Building Collapse:

Updated text to revise that found in Appendix D, Section D.4.2.4, on page D–60 of the January 2011

Mercury Storage EIS is as follows, and Table E–2 updates Table D–27 on page D–61 of the January 2011

Mercury Storage EIS.

This calculation predicts that the maximum downwind distance from new construction to which a 

concentration could exceed SL-IV would be less than 100 meters (330 feet); SL-III could be 

exceeded to a distance of about 200 meters (660 feet); and SL-II could be exceeded to a distance 

of about 790 meters (2,600 feet). There are similar results for existing buildings. Distances for 

all sites are shown in Table D–27 (as updated by Table E–2).

Table E–2. Distances to the Closest Site Boundary or Public Receptor

Compared with Calculated Distances – Outdoor Earthquake Scenario

Site Distance Direction Notes

Predicted Distance (meters)

SL-II SL-III SL-IV

GJDSa 30 meters North and west Fence line 790 200 <100

Nearest resident to GJDS 4 kilometers away.

Hanford Site 

(200 Areas)a

3.5 km West Site boundary 790 200 <100

Hawthorne 

Army Depotb

3.7 km Southwest Site boundary 1,010 250 <100

INL (INTEC)a 13.4 km South Site boundary 

U.S. Routes 20 and 26

790 200 <100

INL (RWMC)b 5.8 km South Site boundary 

U.S. Routes 20 and 26

860 210 <100

KCPc 350 meters South Site boundary 200 <100 <100

Nearest resident to KCP 350 meters away.

SRS (E Area)a 8 km West South Carolina 

Highway 125

790 200 <100

WCSa 67 meters East Fence line 790 200 <100

Nearest resident to WCS 5.4 kilometers away.

Y–12b 360 meters North Fence line 250 <100 <100

Nearest resident to Y–12 890 meters away.

a New construction in predicted distances calculation. Rural site.

b Existing building in predicted distances calculation. Rural site.

c Existing building in predicted distances calculation. Urban site.

Note: To convert meters to feet, multiply by 3.281; kilometers to miles, by 0.6214.

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

Center; KCP=Kansas City Plant; km=kilometer; RWMC=Radioactive Waste Management Complex; SL=severity level; SRS=Savannah River 

Site; WCS=Waste Control Specialists, LLC, site; Y–12=Y–12 National Security Complex.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

E–4

Transportation Accidents Without Fire:

Updated text to revise that found in Chapter 4, Section 4.2.9.1.5, on pages 4–17 and 4–18 and in 

Appendix D, Section D.4.3.1, on pages D–62 and D–63 of the January 2011 Mercury Storage EIS is as 

follows:

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 flasks or all 1-MT 

[1-metric-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 (so conservative as to be essentially 

inconceivable in an outdoor spill), the predicted rate of evaporation given a windspeed u of 

4.5 m/s [meters per second] would be 7.35 × 10-5kg/s [kilograms per second], with the 

evaporation rates for a different windspeed u being scaled by the factor (u/4.5)0.8

(see Section D.7.1.2). 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 for GJDS (for example) are as follows: SL-IV, less than 

100 meters (330 feet); SL-III, less than 100 meters (330 feet); and SL-II, about 230 meters

(750 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 about 230 meters (750 feet) from a crash. 

Conservatively, that specific individual could only be exposed above SL-I if the crash occurs 

along a 460-meter (1,500-foot) stretch of road, and then only if he or she lives by the roadside. 

The length of roadway on which a crash could occur and affect a specific individual is estimated 

by drawing a circle with a 230-meter (750-foot) radius centered on the individual. The relevant 

length of roadway is that which lies inside the circle. The maximum possible relevant length is 

two radii (i.e., 460 meters or 1,500 feet) if the individual lives immediately next to the roadway. 

This is a small fraction of any of the routes. For GJDS, the average length of a truck trip is 

2,000 kilometers (1,260 miles); 460 meters (1,500 feet) is approximately 0.00023 of this. The 

frequency of occurrence of a truck crash with spill on the routes to GJDS is 0.0031 per year; 

see Table D–14 (Scenario 2). The product of the function of the route and the frequency of the 

occurrence is approximately 7.1 × 10-7per year, a negligible frequency. Under Truck Scenario 1 

and the Railcar Scenario, the corresponding frequencies would also be negligible. Therefore, the 

risk to an individual member of the public from transportation spills onto the ground en route to 

GJDS without a fire would be negligible under all transportation scenarios. The same results 

apply to all of the other sites.
Updates to the January 2011 Mercury Storage EIS

E–5

Transportation Accidents with Fire:

Table E–3 updates Table 4–5 on page 4–20 and Table D–31 on page D–66 of the January 2011 Mercury 

Storage EIS.

Table E–3. Predicted Range of Distances (meters) Downwind to Which

Acute Airborne Severity Levels Are Exceeded – Crashes with Fires

Type of Accident

Atmospheric Stability 

Class/Windspeed

PAC-1 

(SL-II)

AEGL-2

(SL-III)

AEGL-3 

(SL-IV)

Truck crash

A/1.5 m/s <100–3,500 <100–130 Nowhere

D/4.5 m/s <100–25,000 Nowhere Nowhere

F/1.5 m/s <100–>40,000a 500–1,200 Nowhere

Railcar crash

A/1.5 m/s <100–3,700 130–830 Nowhere

D/4.5 m/s <100–30,000 550–2,300 Nowhere

F/1.5 m/s <100–>40,000a 350–2,050 Nowhere

a The limit of validity of the dispersion model is 40,000 meters (approximately 25 miles).

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

Key: <=less than; >=greater than; AEGL=Acute Exposure Guideline Level; m/s=meters per second; PAC=Protective Action

Criterion; SL=severity level.

Multiple Exposures:

Updated text to revise that found in Appendix D, Section D.4.6, on page D–72 of the January 2011 

Mercury Storage EIS is as follows:

The highest frequency of truck accidents with spills and no fires is 0.0041 per year 

(see Table D–14). The corresponding value of P(2:40) is 0.0114, where P(2:40) is the 

probability of two accidents in 40 years. It is conceivable that two exposures in the SL-I range 

could add up to an exposure in the SL-II range. From Section E.2.1.3, the distance to which an 

exposure at the SL-II level might occur is 230 meters (750 feet). Additional calculations show 

that the corresponding distance to which an exposure at the SL-II/2 level might occur is 

330 meters (1,080 feet). Using the same reasoning as in Section D.4.3.1, the probability that a 

second crash will occur within 330 meters of an individual who was affected at the PAC-1/2 and 

potentially bring the total exposure level up to PAC-1 or more is 0.00033 (taking GJDS as a 

representative example). Therefore, the probability with which a second crash might take place 

within 330 meters of an individual affected at level PAC-1/2 or higher is 0.0114 × 0.00033 = 

approximately 3.8 × 10-6over a period of 40 years. To apply this probability to the risk matrix, it 

is necessary to establish the relationship between a frequency, such as 10-6per year – the upper 

boundary of the FL-I [Frequency Level I] range – and the corresponding probability over a 

period of 40 years. By simple multiplication by 40, the upper bound on the FL-I range over a 

period of 40 years is 4.0 × 10-5, so that the probability of 3.8 × 10-6over 40 years calculated 

above is in the FL-I range and the corresponding risk would be negligible. Similar reasoning 

leads to negligible risk of two accidents with exposure in the SL-II range leading to a cumulative 

exposure in the SL-III range, and two accidents with exposures in the SL-III range leading to a 

cumulative exposure in the SL-IV range.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

E–6

Intentional Destructive Acts with Fire:

Table E–4 updates Table 4–8 on page 4–23 and Table D–34 on page D–73 of the January 2011 Mercury 

Storage EIS.

Table E–4. Predicted Range of Distances (meters) Downwind to Which 

Acute Airborne Severity Levels Are Exceeded – IDA Fires

Atmospheric Stability 

Class/Windspeed

ACGIH TLV 

8-hour TWA

(SL-II)

AEGL-2

(SL-III)

AEGL-3 

(SL-IV)

A/1.5 m/s <100–9,000 370–780 Nowhere

D/4.5 m/s <100–>40,000a Nowhere Nowhere

F/1.5 m/s <100–>40,000a 100–5,700 680–870

a The limit of validity of the dispersion model is 40,000 meters (approximately 25 miles).

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

Key: <=less than; >=greater than; ACGIH=American Conference of Governmental Industrial 

Hygienists; AEGL=Acute Exposure Guideline Level; IDA=intentional destructive act; m/s=meters per 

second; SL=severity level; TLV=threshold limit value; TWA=time-weighted average.

Other Changes:

Updated text to revise that found in Chapter 4, Section 4.3.9.2.2, on page 4–45 of the January 2011 

Mercury Storage EIS for the GJDS location is as follows:

The maximum downwind distance to which a concentration greater than AEGL-3 [Acute 

Exposure Guideline Level 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 200 meters (660 feet); and PAC-1 could be 

exceeded to a distance of about 790 meters (2,600 feet).

Updated text to revise that found in Chapter 4, Section 4.4.9.2, on page 4–62 of the January 2011 

Mercury Storage EIS for the Hanford location is as follows:

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 200 meters 

(660 feet); and for PAC-1, it is 790 meters (2,600 feet).

Updated text to revise that found in Chapter 4, Section 4.5.9.2, on page 4–78 of the January 2011 

Mercury Storage EIS for the Hawthorne Army Depot location is as follows:

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 250 meters (820 feet); 

and for PAC-1, it is approximately 1,010 meters (3,310 feet).

Updated text to revise that found in Chapter 4, Section 4.6.9.2, on page 4–97 of the January 2011 

Mercury Storage EIS for the INL location is as follows:

For a member of the public in the case of an outside earthquake spill at RWMC [Radioactive 

Waste Management Complex], 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 210 meters (690 feet); 

and for PAC-1, it is approximately 860 meters (2,820 feet). At INTEC [Idaho Nuclear 
Updates to the January 2011 Mercury Storage EIS

E–7 

Technology and Engineering Center], 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 200 meters (660 feet); and for PAC-1, it is 790 meters 

(2,600 feet). 

Updated text to revise that found in Chapter 4, Section 4.7.9.2, on page 4–113 of the January 2011 

Mercury Storage EIS for the KCP location is as follows: 

For a member of the public in the case of an outside earthquake spill, 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 also less than 100 meters (330 feet); and for PAC-1, it is about 200 meters (660 feet). 

Updated text to revise that found in Chapter 4, Section 4.8.9.2, on page 4–130 of the January 2011 

Mercury Storage EIS for the SRS location is as follows: 

For a member of the public in the case of an outside earthquake spill, 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 200 meters (660 feet); and for PAC-1, it is 790 meters (2,600 feet). 

Updated text to revise that found in Chapter 4, Section 4.9.9.2, on page 4–147 of the January 2011 

Mercury Storage EIS for the WCS location is as follows:

For a member of the public in the case of an outside earthquake spill, 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 200 meters (660 feet); and for PAC-1, it is 790 meters (2,600 feet). 

E.3 UPDATES TO SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE 

ANALYSIS 

The updated socioeconomics and environmental justice analysis in this appendix supersedes the analysis 

in the January 2011 Mercury Storage EIS, as indicated in Table E–5. The methodology and approach to 

conducting socioeconomics and environmental justice analysis remain otherwise unchanged and are 

described in Appendix B, Sections B.10 and B.11, of the January 2011 Mercury Storage EIS; however, 

updates to Tables B–13, B–14, and B–15 from the January 2011 Mercury Storage EIS were prepared 

based upon the 2010 census data. Updated tables are presented in Appendix B of this draft SEIS. 

The affected environment for the WIPP Vicinity reference locations for socioeconomics and 

environmental justice is presented in this draft SEIS in Chapter 3, Sections 3.2.10 and 3.2.11. The 

environmental consequences for the WIPP Vicinity reference locations for socioeconomics and 

environmental justice are presented in this draft SEIS in Chapter 4, Sections 4.2.11 and 4.2.12. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–8

Table E–5. Section Updates for Socioeconomics and Environmental Justice Analyses 

Candidate Site

January 2011 

Mercury Storage 

EIS Section

Mercury Storage 

SEIS Updated

Section

Y–12 National Security 

Complex (No Action)

Tennessee

Affected Environment

3.9.10 E.3.2.1.1

3.9.11 E.3.2.1.2

Environmental Consequences

4.2.11 E.3.2.2.1

4.2.12 E.3.2.2.2

Grand Junction Disposal Site

Colorado

Affected Environment

3.2.10 E.3.3.1.1

3.2.11 E.3.3.1.2

Environmental Consequences

4.3.11 E.3.3.2.1

4.3.12 E.3.3.2.2

Hanford Site 200-West Area

Washington

Affected Environment

3.3.10 E.3.4.1.1

3.3.11 E.3.4.1.2

Environmental Consequences

4.4.11 E.3.4.2.1

4.4.12 E.3.4.2.2

Hawthorne Army Depot

Nevada

Affected Environment

3.4.10 E.3.5.1.1

3.4.11 E.3.5.1.2

Environmental Consequences

4.5.11 E.3.5.2.1

4.5.12 E.3.5.2.2

Idaho National Laboratory

INTEC and RWMC

Idaho

Affected Environment

3.5.10 E.3.6.1.1

3.5.11 E.3.6.1.2

Environmental Consequences

4.6.11 E.3.6.2.1

4.6.12 E.3.6.2.2

Kansas City Plant

Missouri

Affected Environment

3.6.10 E.3.7.1.1

3.6.11 E.3.7.1.2

Environmental Consequences

4.7.11 E.3.7.2.1

4.7.12 E.3.7.2.2

Savannah River Site E Area

South Carolina

Affected Environment

3.7.10 E.3.8.1.1

3.7.11 E.3.8.1.2

Environmental Consequences

4.8.11 E.3.8.2.1

4.8.12 E.3.8.2.2

Waste Control Specialists, LLC

Texas

Affected Environment

3.8.10 E.3.9.1.1

3.8.11 E.3.9.1.2

Environmental Consequences

4.9.11 E.3.9.2.1

4.9.12 E.3.9.2.2

Key: INTEC=Idaho Nuclear Technology and Engineering Center; RWMC=Radioactive Waste Management Complex. 

E.3.1 Summary Comparison of Candidate Site Updates 

Updating the environmental justice analysis previously presented in the January 2011 Mercury 

Storage EIS from 2000 to 2010 census data resulted in some changes to the data associated with those 

candidate sites previously analyzed. Specifically, residential populations within the 16-kilometer 

(10-mile) and 3.2-kilometer (2-mile) regions of influence (ROIs) changed, as well as the number of 

census blocks that contain either a minority or low-income population for some of the candidate sites 

within these ROIs. Table E–6 provides a summary comparison of changes to environmental justice data 

presented in the January 2011 Mercury Storage EIS as updated in this appendix. 
Updates to the January 2011 Mercury Storage EIS

E

–9

Table E–6. Summary Comparison of Changes to Environmental Justice Data

Candidate Site

Census 

Data

Residential Population

16-km (10-mile)

Minority or Low-Income 

Populations Within

16-km (10-mile) ROI

Residential 

Population

3.2-km (2-mile)

Minority or Low-Income 

Populations Within

3.2-km (2-mile) ROI

Y–12 National Security 

Complex (No Action)

Tennessee

2000

101,939

(7.6% minority)

(7.9% low-income)

1 minority and 1 low-income 

census block group 

(out of 89 blocks).

3,093

(27% minority)

(14% low-income)

3 minority and no low-income 

census block groups

(out of 9 blocks).

2010

117,490

(11% minority)

(9.5% low-income)

1 minority only, 2 low-income 

only, and 1 that is both a minority 

and low-income census block 

group (out of 92 blocks).

3,862

(33% minority)

(28% low-income)

1 minority only and 1 that is 

both a minority and 

low-income census block 

group (out of 7 blocks).

Grand Junction 

Disposal Site

Colorado

2000

2,119

(15% minority)

(11% low-income)

No minority or low-income 

census block groups.

138

(13% minority)

(12% low-income)

No minority or low-income 

census block groups.

2010

2,823

(14% minority)

(11% low-income)

No minority or low-income 

census block groups.

194

(12% minority)

(10% low-income)

No minority or low-income 

census block groups.

Hanford Site 

200-West Area

Washington

2000 0

No minority or low-income 

census block groups. 0

No minority or low-income 

census block groups.

2010

147

(38% minority)

(18% low-income)

2 minority only census block 

groups and 1 that is both a

minority and low-income census 

block group (out of 4 blocks).

0

No minority or low-income 

census block groups.

Hawthorne Army Depot

Nevada

2000

3,561

(20% minority)

(10% low-income)

No minority or low-income 

census block groups. 0

No minority or low-income 

census block groups.

2010

2,583

(23% minority)

(15% low-income)

1 that is both a minority and 

low-income census block group 

(out of 4 blocks).

169

(23% minority)

(20% low-income)

1 that is both a minority and 

low-income census block 

group (out of 2 blocks).

Idaho National 

Laboratory – INTEC

Idaho

2000

201

(13% minority)

(19% low-income)

No minority or low-income 

census block groups. 0

No minority or low-income 

census block groups.

2010

205

(11% minority)

(15% low-income)

No minority or low-income 

census block groups. 0

No minority or low-income 

census block groups.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

E

–10

Table E–6. Summary Comparison of Changes to Environmental Justice Data (continued)

Candidate Site

Census 

Data

Residential Population

16-km (10-mile)

Minority or Low-Income 

Populations Within

16-km (10-mile) ROI

Residential 

Population

3.2-km (2-mile)

Minority or Low-Income 

Populations Within

3.2-km (2-mile) ROI

Idaho National 

Laboratory – RWMC

Idaho

2000

255

(12% minority)

(25% low-income)

No minority or low-income 

census block groups. 0

No minority or low-income 

census block groups.

2010

175

(9.8% minority)

(18% low-income)

No minority or low-income 

census block groups. 0

No minority or low-income 

census block groups.

Kansas City Plant

Missouri

2000

700,041

(31% minority)

(10% low-income)

172 minority only, 2 low-income 

only, and 74 that are both 

minority and low-income census 

block groups (out of 671 blocks).

28,184

(42% minority)

(11% low-income)

16 minority only and 1 that is 

both a minority and 

low-income census block 

group (out of 41 blocks).

2010

705,513

(36% minority)

(13% low-income)

157 minority only, 5 low-income 

only, and 88 that are both 

minority and low-income census 

block groups (out of 659 blocks).

26,192

(52% minority)

(20% low-income)

16 minority only and 6 that 

are both minority and 

low-income census block 

groups (out of 39 blocks).

Savannah River Site

E Area

South Carolina

2000

8,178

(36% minority)

(17% low-income)

4 minority and no low-income 

census block groups 

(out of 14 blocks).

0

No minority or low-income 

census block groups.

2010

6,691

(38% minority)

(20% low-income)

4 minority and 1 low-income 

census block groups 

(out of 15 blocks).

0

No minority or low-income 

census block groups.

Waste Control 

Specialists, LLC

Texas

2000

2,900

(40% minority)

(17% low-income)

1 minority and no low-income 

census block groups 

(out of 8 blocks).

20

(27% minority)

(6% low-income)

No minority or low-income 

census block groups.

2010

3,322

(47% minority)

(12% low-income)

2 minority and no low-income 

census block groups 

(out of 8 blocks).

27

(35% minority)

(7.8% low-income)

No minority or low-income 

census block groups.

Key: INTEC=Idaho Nuclear Technology and Engineering Center; km=kilometer; ROI=region of influence; RWMC=Radioactive Waste Management Complex.
Updates to the January 2011 Mercury Storage EIS

E–11

E.3.2 Y–12 National Security Complex 

E.3.2.1 Affected Environment 

E.3.2.1.1 Socioeconomics 

Socioeconomic variables at Y–12 are associated with community growth and development within the 

Y–12 ROI that could potentially be affected, directly or indirectly, by project-related changes. Included 

are economic characteristics, the region’s demography, housing, and local transportation.

Y–12 is located on the Oak Ridge Reservation in eastern Tennessee, approximately 29 kilometers 

(18 miles) west of the city of Knoxville. Approximately 90 percent of people employed at Y–12 reside in 

four counties: Anderson, Knox, Loudon, and Roane (DOE 2008:4-404). Therefore, these four counties 

are identified as the ROI in this socioeconomics analysis. Y–12 employs approximately 6,000 persons 

(DOE 2009).

E.3.2.1.1.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the ROI increased by approximately 16.9 percent from 280,986 to 

328,363. During this period, the unemployment rate of the ROI increased from 3.4 percent to 7.3 percent. 

The unemployment rate in the ROI peaked during 2009, at 8.5 percent. By July 2012, the unemployment 

rate of the ROI was 7.1 percent, which was lower than the unemployment rate for Tennessee (8.3 percent) 

(BLS 2012). 

E.3.2.1.1.2 Demographic and Housing Characteristics 

In 2010, the estimated population of the four-county ROI was 610,092. From 2000 to 2010, the ROI 

population grew by 12 percent, compared with 11.5 percent growth throughout the state of Tennessee 

(DOC 2001a, 2011a). Young children and pregnant women are considered to be among the most 

vulnerable populations to mercury poisoning. The percentage of the ROI population under the age of 18 

was 22 percent; women ages 18 to 39 composed 15 percent (DOC 2011a). There were 277,107 housing 

units in the ROI in 2010 (DOC 2011b), 62 percent of which were owner-occupied, 29 percent were 

renter-occupied, and 9.5 percent were vacant (DOC 2011b, 2011c). 

E.3.2.1.1.3 Environmental Justice 

Under Executive Order 12898, DOE is responsible for identifying and addressing any disproportionately 

high and adverse impacts on minority and low-income populations. Minority persons are those who 

identify themselves as American Indian or Alaska Native, Asian, Black or African American, Hispanic or 

Latino (of any race), Native Hawaiian or other Pacific Islander, or multiracial (CEQ 1997). Persons who 

report that their income is less than the Federal poverty threshold are designated as low-income. 

A 16-kilometer (10-mile) radius was chosen as the ROI for this analysis to provide a reasonable estimate 

of the potentially affected population surrounding the facility. An additional ROI of those residing within 

an approximately 3.2-kilometer (2-mile) radius of each candidate site was used as a subset of the 

16-kilometer ROI to guard against inadvertently diluting represented minority and low-income 

populations most likely to experience any potentially adverse impacts associated with mercury storage. 

The 16-kilometer (10-mile) radius surrounding Y–12 encompasses parts of five Tennessee counties: 

Anderson, Knox, Loudon, Morgan, and Roane. Figure E–1 shows populations residing in the five-county 

area, as reported in the 2000 and 2010 censuses (DOC 2001a, 2011d). In this figure, lightly shaded bars 

show populations in 2000, and the darker bars show those in 2010. From 2000 to 2010, the population of 

the five-county area increased by approximately 12 percent to 632,079. Over this period, the total 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–12

minority population increased by approximately 47 percent to 86,199, and the low-income population 

increased by approximately 23 percent to 85,461 (DOC 2001a, 2001b, 2011d, 2011e). 

Figure E–1. Populations Residing Within the Five-County Area Surrounding 

Y–12 National Security Complex 

Demographic data from the 2010 census show that the total minority population residing in the 

five-county area composed approximately 14 percent of the total population. The Black or African 

American population residing in the five-county area composed approximately 51 percent of the area’s

total minority population, while those self-identified as “two or more races” composed approximately 

13 percent of the area’s total minority population. Persons who declared that they are of Hispanic or 

Latino origin are included in the “total Hispanic” population, regardless of race. They composed 

approximately 3.3 percent of the total population and approximately 24 percent of the total minority 

population residing in the five-county area in 2010 (DOC 2011d). 

In 2010, 117,490 people lived within 16 kilometers (10 miles) of Y–12 (DOC 2011d). This area included 

an estimated 11 percent minority and 9.5 percent low-income population. By comparison, the five-county 

area included a 14 percent minority and 14 percent low-income population, and the state included a 

24 percent minority and 17 percent low-income population. There are 92 census block groups located 

within the 16-kilometer radius surrounding Y–12. Of this total, one contained a minority population, two 

contained a low-income population, and one contained both a minority and low-income population. As 

described in Appendix B, Section B.11.1, of the January 2011 Mercury Storage EIS and updated in 

Appendix B of this draft SEIS, minority and low-income populations or communities are identified by 
Updates to the January 2011 Mercury Storage EIS

E–13

comparing block-group data to the surrounding state- and county-level data to determine if the minority 

or low-income population percentage is meaningfully greater than that of the general population.

In 2010, 3,862 people lived within approximately 3.2 kilometers (2 miles) of Y–12 (DOC 2011d). This 

area included an estimated 33 percent minority and 28 percent low-income population. There are seven 

census block groups located within this ROI; one contained a minority population, none contained a 

low-income population, and one contained both a minority and a low-income population.

Figure E–2 shows the proximity of the identified minority and low-income communities to Y–12.

Figure E–3 shows the cumulative populations living at a given distance from Y–12.

E.3.2.2 Environmental Consequences

Under the No Action Alternative, DOE would not designate and operate a facility(ies) 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, of the January 2011 Mercury Storage EIS. Elemental mercury would continue 

to be generated, including from chlor-alkali facilities, the gold-mining industry, and waste reclamation 

and recycling facilities. As identified in Chapter 1, Table 1–1, of this draft SEIS, the vast majority of 

mercury 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 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 management of 

this material in one centralized location, 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.

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

(34.6-kilogram [76-pound]) flasks at Y–12 would continue to be managed and stored in this location. No 

new construction would be required.

E.3.2.2.1 Socioeconomics

The No Action Alternative is discussed in Chapter 4, Section 4.2, of the January 2011 Mercury 

Storage EIS. Under the No Action Alternative, some non-DOE storage sites may require new 

construction or need to modify their storage capacity by constructing additional storage space. Any 

analysis of impacts on socioeconomics at non-DOE storage sites would be highly speculative at this time. 

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 2004:4-26). Therefore, no 

incremental socioeconomic or related transportation impacts would occur at Y–12.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–14

Figure E–2. Block Groups Containing Minority and Low-Income Populations 

Surrounding Y–12 National Security Complex 
Updates to the January 2011 Mercury Storage EIS

0 2 4 6 8 10 12 14 16

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

Population

Figure E–3. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Y–12 National Security Complex 

E–15

E.3.2.2.2 Environmental Justice 

The population of one of the block groups within the 16-kilometer (10-mile) radius surrounding Y–12 

was identified as minority, the population of two of the block groups was identified as low-income, and 

the population of one block group was identified as both minority and low-income. The population of 

one of the block groups within the 3.2-kilometer (2-mile) radius surrounding Y–12 was identified as a 

minority population and the population of one block group was identified as both minority and 

low-income (see Figure E–2). 

As discussed in Chapter 4, Section 4.2, of the January 2011 Mercury Storage EIS, 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. 

E.3.3 Grand Junction Disposal Site 

E.3.3.1 Affected Environment 

E.3.3.1.1 Socioeconomics 

GJDS is located approximately 29 kilometers (18 miles) southeast of the city of Grand Junction, 

Colorado. Approximately 90 percent of people employed in this area are assumed to reside in Mesa 

County based on the local employment data compiled by the U.S. Census Bureau (DOC 2009). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

E–16

Therefore, Mesa County has been identified as the ROI in this socioeconomics analysis. The disposal site 

employs approximately seven people during the several weeks every year that it is open to receive 

uranium mill tailings. During the remainder of the year, routine inspections are expected to require less 

than one full-time employee (GJDS 2009).

E.3.3.1.1.1 Regional Economic Characteristics

From 2000 to 2011, the labor force of Mesa County increased by approximately 34 percent from 59,016 

to 79,048. During this period, the unemployment rate of the ROI increased from 3.3 percent to 

9.6 percent. The unemployment rate in the ROI peaked during 2010 at 10.7 percent. By July 2012, the 

unemployment rate for the county was 9.3 percent, which was higher than the unemployment rate for 

Colorado (7.8 percent) (BLS 2012).

E.3.3.1.1.2 Demographic and Housing Characteristics

In 2010, the estimated population of Mesa County was 146,723. From 2000 to 2010, the population of 

the county grew by 26 percent, compared with 17 percent growth in Colorado (DOC 2001a, 2011a). 

Young children and pregnant women are considered to be among the most vulnerable populations to 

mercury poisoning. The percentage of the population within the county under the age of 18 was 

24 percent; women ages 18 to 39 composed 14 percent (DOC 2011a). There were 62,644 housing units 

in the county in 2010 (DOC 2011b), 66 percent of which were owner-occupied, 27 percent were 

renter-occupied, and 7.3 percent were vacant (DOC 2011b, 2011c).

E.3.3.1.2 Environmental Justice

A 16-kilometer (10-mile) radius was chosen as the ROI for this analysis to provide a reasonable estimate 

of the potentially affected population surrounding the facility. An additional ROI of those residing within 

an approximately 3.2-kilometer (2-mile) radius of each candidate site was used as a subset of the 

16-kilometer (10-mile) ROI to guard against inadvertently diluting represented minority and low-income 

populations most likely to experience any potentially adverse impacts associated with mercury storage.

The 16-kilometer (10-mile) radius surrounding the candidate storage location at GJDS encompasses parts 

of two counties in Colorado: Mesa and Delta. Figure E–4 shows populations residing in the two-county 

area, as reported in the 2000 and 2010 censuses (DOC 2001a, 2011d). In this figure, lightly shaded bars 

show populations in 2000, and the darker bars show those in 2010. From 2000 to 2010, the population of 

the two-county area increased by approximately 23 percent to 177,675. Over this period, the total 

minority population increased by approximately 58 percent to 30,046, and the low-income population 

increased by approximately 42 percent to 21,252 (DOC 2001a, 2001b, 2011d, 2011e).

Demographic data from the 2010 census show that the total minority population residing in the 

two-county area composed approximately 17 percent of the total population. The White Hispanic 

population residing in the two-county area composed approximately 38 percent of the area’s total 

minority population, while those self-identified as “some other race” (meaning those who provided 

write-in entries such as Mexican, Puerto Rican, or Cuban) composed approximately 32 percent of the 

ROI’s total minority population. Persons who declared that they are of Hispanic or Latino origin are 

included in the “total Hispanic” population, regardless of race. They composed approximately 13 percent

of the total population and approximately 80 percent of the total minority population residing in the 

two-county area in 2010 (DOC 2011d).

In 2010, approximately 2,823 people lived within 16 kilometers (10 miles) of GJDS. This area included 

an estimated 14 percent minority and 11 percent low-income population. By comparison, Mesa and Delta 

Counties included a 17 percent minority and 13 percent low-income population, and Colorado included a 

30 percent minority and 12 percent low-income population (DOC 2011d, 2011e). There are five census 
Updates to the January 2011 Mercury Storage EIS

E–17

block groups located within the 16-kilometer radius surrounding GJDS, none of which contained a 

minority or low-income population. As described in Appendix B, Section B.11.1, of the January 2011 

Mercury Storage EIS and updated in Appendix B of this draft SEIS, minority and low-income 

populations or communities are identified by comparing block-group data to the surrounding state- and 

county-level data to determine if the minority or low-income population percentage is meaningfully 

greater than that of the general population. 

Figure E–4. Populations Residing Within the Two-County Area 

Surrounding the Grand Junction Disposal Site 

In 2010, 194 people lived within approximately 3.2 kilometers (2 miles) of GJDS. This area included an 

estimated 12 percent minority and 10 percent low-income population (DOC 2011d, 2011e). There is only 

one census block group located within this ROI, and it did not contain a minority or low-income 

population. 

Figure E–5 shows the cumulative populations living at a given distance from the site. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

0 2 4 6 8 10 12 14 16

0

500

1,000

1,500

2,000

2,500

3,000

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

E–18

Figure E–5. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Grand Junction Disposal Site 

E.3.3.2 Environmental Consequences 

Under this alternative, a new mercury storage facility would be constructed at DOE’s GJDS. GJDS 

occupies 146 hectares (360 acres) located in Mesa County, Colorado, 29 kilometers (18 miles) southeast 

of Grand Junction, Colorado, as further described in Chapter 2, Section 2.4.2, of the January 2011

Mercury Storage EIS. 

E.3.3.2.1 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 to 6 individuals thereafter, resulting in an increase of the full-time equivalent workforce 

at GJDS by a factor of 3 to 4 during construction and roughly doubling the workforce at GJDS during 

operations. In spite of this projected increase in jobs supporting construction and operations at GJDS and 

associated indirect employment, this alternative would have a negligible impact on socioeconomic 

conditions (i.e., overall employment and population trends) 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 
Updates to the January 2011 Mercury Storage EIS

E–19

could increase the average annual daily traffic count on U.S. Route 50 by less than 0.5 percent. Impacts 

on traffic during construction would be negligible. 

Transportation impacts during the operations phase would include employee vehicle trips and shipments 

of elemental mercury for storage. Appendix C, Section C.1, of this draft SEIS 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. At the peak of 

operations, it is estimated that up to 79 shipments of elemental mercury would be made in a year. 

Approximately 96 percent of the additional vehicles would be attributed to employee transportation. 

Impacts on traffic during operations would be negligible. 

E.3.3.2.2 Environmental Justice 

None of the block groups within either the 16-kilometer (10-mile) or the 3.2-kilometer (2-mile) radius 

surrounding GJDS contain a minority or low-income population. Therefore, no disproportionately high 

and adverse effects on minority or low-income populations are expected. 

E.3.4 Hanford Site 

E.3.4.1 Affected Environment 

E.3.4.1.1 Socioeconomics 

Hanford is located along the Columbia River in southeastern Washington. Approximately 90 percent of 

the people employed at Hanford reside in Franklin and Benton Counties (Duncan 2007). Therefore, 

Franklin and Benton Counties have been identified as the ROI in this socioeconomics analysis. In fiscal 

year 2006, Hanford employed 9,759 persons. 

E.3.4.1.1.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the ROI increased by approximately 36 percent from 99,026 

to 134,627. During this period, the unemployment rate of the ROI increased from 5.5 percent to 

7.9 percent. By July 2012, the unemployment rate for the ROI was 8.2 percent, which was lower than the 

unemployment rate for Washington State (8.5 percent) (BLS 2012). 

E.3.4.1.1.2 Demographic and Housing Characteristics 

In 2010, the estimated population of the two-county ROI was 253,340. From 2000 to 2010, the 

ROI population grew by 32 percent, compared with 14 percent growth throughout the state of Washington 

(DOC 2001a, 2011a). Young children and pregnant women are considered to be among the most 

vulnerable populations to mercury poisoning. The percentage of the ROI population under the age of 18 

was 29 percent; women ages 18 to 39 composed 15 percent (DOC 2011a). There were 93,041 housing 

units in the ROI in 2010 (DOC 2011b), 64 percent of which were owner-occupied, 31 percent were 

renter-occupied, and 4.8 percent were vacant (DOC 2011b, 2011c). 

E.3.4.1.2 Environmental Justice 

The 16-kilometer (10-mile) radius surrounding the candidate storage location in the 200-West Area at 

Hanford encompasses parts of two counties in Washington: Benton and Grant. Figure E–6 shows 

populations residing in the two-county area, as reported in the 2000 and 2010 censuses. In this figure, 

lightly shaded bars show populations in 2000, and the darker bars show those in 2010. In the decade 

between 2000 and 2010, the total population of Benton and Grant Counties increased by approximately 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–20

18 percent to 264,297; the minority population increased by approximately 37 percent to 82,794; and the 

low-income population increased by 38 percent to 38,082 (DOC 2001a, 2001b, 2011d, 2011e). 

Figure E–6. Populations Residing Within the Two-County Area 

Surrounding the 200-West Area at the Hanford Site 

Demographic data from the 2010 census show that the total minority population residing in the 

two-county area composed approximately 31 percent of the total population. The White Hispanic 

population residing in the two-county area composed approximately 34 percent of the area’s total 

minority population, while those self-identified as “some other race” (meaning those who provided 

write-in entries such as Mexican, Puerto Rican, or Cuban) composed approximately 41 percent of the 

area’s total minority population. Persons who declared that they are of Hispanic or Latino origin are 

included in the “total Hispanic” population, regardless of race. They composed approximately 81 percent 

of the total minority population and approximately 25 percent of the total population residing in the 

two-county area around Hanford in 2010 (DOC 2011d). 

In 2010, 147 people lived within 16 kilometers (10 miles) of the 200-West Area at Hanford 

(DOC 2011d). This area included an estimated 38 percent minority and 18 percent low-income 

population. By comparison, the two-county area included a 31 percent minority and 15 percent 

low-income population, and Washington included a 27 percent minority and 12 percent low-income 

population (DOC 2011d, 2011e). There are four census block groups located within the 16-kilometer 

(10-mile) radius surrounding the 200-West Area at Hanford, two of which contained a minority 
Updates to the January 2011 Mercury Storage EIS

E–21

population only and one that contained both a minority and low-income population. As described in 

Appendix B, Section B.11.1, of the January 2011 Mercury Storage EIS and updated in Appendix B of this 

draft SEIS, the minority and low-income populations or communities are identified by comparing blockgroup data to the surrounding state- and county-level data to determine if the minority or low-income 

population percentage is meaningfully greater than that of the general population. No one resides within 

approximately 3.2 kilometers (2 miles) of the 200-West Area at Hanford.

Figure E–7 shows the proximity of the identified minority and low-income communities to the 200-West 

Area at Hanford.

Figure E–8 shows the cumulative populations living at a given distance from the 200-West Area at 

Hanford.

There are two American Indian reservations in proximity to the Hanford region. The Yakama 

Reservation is located approximately 48 kilometers (30 miles) southwest of the 200-West Area, and the 

Umatilla Reservation is located 113 kilometers (70 miles) southeast of the 200-West Area.

E.3.4.2 Environmental Consequences

Under this alternative, a new mercury storage facility would be constructed at DOE’s Hanford Site. 

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, as further described in Chapter 2, 

Section 2.4.3, of the January 2011 Mercury Storage EIS.

E.3.4.2.1 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 to 6 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 

0.004 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 and population trends) 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. Impacts on traffic 

during construction would be minor.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–22

Figure E–7. Block Groups Containing Minority and Low-Income Populations 

Surrounding the 200-West Area at the Hanford Site 
Updates to the January 2011 Mercury Storage EIS

E–23

0 2 4 6 8 1 0 1 2 1 4 1 6

0

2 0

4 0

6 0

8 0

100

120

140

160

0 1 2 3 4 5 6 7 8 9 1 0

Distance from Storage Location (kilometers) Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

Figure E–8. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

200-West Area at the Hanford Site 

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, of this draft SEIS 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 0.2 percent, if utilizing State Route 240, to 

slightly over 1 percent, if utilizing State Route 24. At the peak of operations, it is estimated that up to 

79 shipments of elemental mercury would be made in a year. Approximately 96 percent of the additional 

vehicles would be attributed to employee transportation. Impacts on traffic during operations would be 

negligible to minor. 

E.3.4.2.2 Environmental Justice 

Two of the block groups within the 16-kilometer (10-mile) radius surrounding the proposed storage site at 

Hanford contain a minority population only and one of the block groups contains both a minority and 

low-income population. There are no populations identified within the 3.2-kilometer (2-mile) radius 

surrounding the storage site. As discussed in Chapter 3, Section 3.3.1.1, and Chapter 4, Section 4.4.1, of 

the January 2011 Mercury Storage EIS, the land use designations surrounding the 200-West Area include 

Preservation, Conservation (Mining), Recreation, Industrial-Exclusive, and Research and Development 

(see Figure 3–3 of the January 2011 Mercury Storage EIS); there would be no impacts on land use as a 

result of implementing the Hanford alternative. Impacts on air quality under this alternative would be 

negligible, as discussed in Section 4.4.4.2 of the January 2011 Mercury Storage EIS. No impacts on 

ecological resources would occur under this alternative, as discussed in Section 4.4.5 of the January 2011 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

E–24

Mercury Storage EIS. Construction of a new storage facility would occur in previously disturbed lands 

and there are no known traditional cultural properties located within the 200 Areas; therefore, the 

probability of discovering American Indian archaeological sites would be negligible. Thus, there would 

be negligible impacts on American Indian cultural resources, as discussed in Section 4.4.6.3 of the 

January 2011 Mercury Storage EIS. A negligible change in socioeconomic conditions would result under 

this alternative, as discussed above in Section E.3.4.2.1. As discussed in Section 4.4.9 of the 

January 2011 Mercury Storage EIS, implementing the Hanford alternative would result in negligible 

offsite human health risks from mercury emissions during normal operations and facility accidents. As 

discussed in Section 4.4.9.3 of the January 2011 Mercury Storage EIS, transportation accidents are 

predicted to pose a negligible-to-low human health risk following dry deposition onto the ground or into 

water bodies. The 200 Area at Hanford is located in an area proximal to block groups identified as both 

minority and low-income communities, as described in Section E.3.4.1.2. The analysis of the Hanford 

alternative identified the presence of minority and low-income communities adjacent to potential 

transportation routes. The transportation accident analysis is discussed in Section 4.4.9.3 and 

Appendix D, Section D.4.5, of the January 2011 Mercury Storage EIS.

In addition, under transportation accident scenarios in which a fire occurs, it is possible for nearby 

downwind surface-water bodies to become contaminated, raising concerns for populations where fish 

is an important part of the diet. Chapter 4, Section 4.5.9.3.3, of the January 2011 Mercury Storage EIS

discusses the possibility of accumulation of mercury in fish under such scenarios. Three fish 

consumption rates were analyzed: the national average consumption rate, the average subsistence 

fisherman consumption rate, and the 95th percentile subsistence fisherman consumption rate 

(see Section 4.2.9.1.1 of the January 2011 Mercury Storage EIS). Such consumption rates could be 

representative of a low-income or American Indian subsistence fishing population. Under the Truck 

Scenarios, the risks to human receptors that consume fish at one of the three rates would be negligible. 

Under the Railcar Scenario, the risk to the 95th percentile subsistence fisherman would be negligible to 

low. American Indian reservations have not been identified within the 16-kilometer (10-mile) ROI 

surrounding the 200-West Area of Hanford; however, as discussed in Section E.3.4.1.2, there are 

low-income and minority communities present in the ROI. Although the risk is negligible to low, if a 

transportation accident that resulted in fish contamination were to occur, it would be advisable as a 

mitigation measure to monitor the levels of methylmercury in fish to ensure that subsistence fishermen do 

not consume amounts of methylmercury that might cause adverse health effects. Subsequent to mandated 

reporting of any such release by the shipper of the elemental mercury, the appropriate state environmental 

agency would be responsible for determining appropriate fish consumption advisories and monitoring 

requirements for mercury concentrations in waters and fish stocks.
Updates to the January 2011 Mercury Storage EIS

E–25

E.3.5 Hawthorne Army Depot 

E.3.5.1 Affected Environment 

E.3.5.1.1 Socioeconomics 

Based on the local employment data compiled by the Census Bureau, approximately 90 percent of people 

employed in the Hawthorne area are assumed to reside in three Nevada counties: Mineral, Lyon, and 

Churchill (DOC 2009). Therefore, these three counties have been identified as the ROI in this 

socioeconomics analysis. In 2010, the Hawthorne Army Depot employed approximately 550 to 

650 persons. 

E.3.5.1.1.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the ROI increased by approximately 21 percent from 32,259 to 

39,096. During this period, the unemployment rate of the ROI increased from 6.2 percent to 15.0 percent. 

The unemployment rate in the ROI peaked during 2010 at 15.1 percent. By July 2012, the unemployment 

rate of the ROI was 13.5 percent, which was higher than the unemployment rate for Nevada 

(12.0 percent) (BLS 2012). 

E.3.5.1.1.2 Demographic and Housing Characteristics 

In 2010, the estimated population of the three-county ROI was 81,629. From 2000 to 2010, the ROI 

population grew by 28 percent, which was lower than the growth rate throughout the entire state of 

Nevada (35.1 percent) (DOC 2001a, 2011a). Young children and pregnant women are considered to be 

among the most vulnerable populations to mercury poisoning. In 2010, the percentage of the ROI 

population under the age of 18 was 25 percent; women ages 18 to 39 composed 12 percent (DOC 2011a). 

There were 36,203 housing units in the ROI in 2010, 61 percent of which were owner-occupied, 

27 percent were renter-occupied, and 12 percent were vacant (DOC 2011b, 2011c). 

E.3.5.1.2 Environmental Justice 

The 16-kilometer (10-mile) radius surrounding the candidate storage location at the Hawthorne Army 

Depot encompasses part of Mineral County, Nevada. Figure E–9 shows populations residing in Mineral 

County, as reported in the 2000 and 2010 censuses (DOC 2001b, 2011d). In this figure, lightly shaded 

bars show populations in 2000, and the darker bars show those in 2010. In the decade between 2000 and 

2010, the total population of Mineral County declined by approximately 5.9 percent from 5,071 to 4,772; 

the minority population decreased by approximately 1 percent from 1,516 to 1501; and the low-income 

population increased by 17 percent from 761 to 887 (DOC 2001a, 2001b, 2011d, 2011e). Demographic 

data from the 2010 census show that the total minority population accounted for approximately 31 percent 

of the total population. The American Indian and Alaska Native populations residing in Mineral County 

composed approximately 49 percent of the county’s total minority population. Persons who declared that 

they are of Hispanic or Latino origin are included in the “total Hispanic” population, regardless of race. 

They composed approximately 9.1 percent of the total population and approximately 29 percent of the 

total minority population residing in Mineral County in 2010 (DOC 2011d). 

In 2010, 2,583 people lived within 16 kilometers (10 miles) of the Hawthorne Army Depot. This area 

included an estimated 23 percent minority and 15 percent low-income population. By comparison, 

Mineral County included a 31 percent minority and 19 percent low-income population, and Nevada 

included a 46 percent minority and 12 percent low-income population (DOC 2011d, 2011e). There are 

four census block groups located within the 16-kilometer radius surrounding the Hawthorne Army Depot, 

one of which contained both a minority and low-income population. As described in Appendix B, 

Section B.11.1, of the January 2011 Mercury Storage EIS and updated in Appendix B of this draft SEIS, 

minority and low-income populations or communities are identified by comparing block-group data to the 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–26

surrounding state- and county-level data to determine if the minority or low-income population 

percentage is meaningfully greater than that of the general population. 

Figure E–9. Populations Residing Within Mineral County, Nevada, 

Surrounding the Hawthorne Army Depot 

In 2010, 169 people lived within approximately 3.2 kilometers (2 miles) of the Hawthorne Army Depot. 

This area included an estimated 23 percent minority and 20 percent low-income population 

(DOC 2011d, 2011e). There are two census block groups located within this ROI, one of which 

contained both a minority and low-income population. Differences in the results of the population 

analysis within the 3.2-kilometer (2-mile) ROI calculated using data from the 2000 census 

(i.e., population=0) and the 2010 census (i.e., population=169) are primarily due to changes to the 

boundaries of block groups associated with the respective data sets and the methodology involved in 

estimating populations within specific radii. During each decennial census, the boundaries of geographic 

units at finer spatial resolution (such as census tracts, block groups, and blocks) are typically redrawn to 

more accurately reflect the dispersion of the population in a given area, which aids local communities in 

the redistricting process. 

Figure E–10 shows the proximity of the identified minority and low-income communities to the 

Hawthorne Army Depot. 
Updates to the January 2011 Mercury Storage EIS

E–27

Figure E–10. Block Group Containing Minority and Low-Income Populations 

Surrounding the Hawthorne Army Depot 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–28

Figure E–11 shows the cumulative populations living at a given distance from the Hawthorne 

Army Depot. 

0 2 4 6 8 10 12 14 16

0

500

1,000

1,500

2,000

2,500

3,000

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

Figure E–11. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Hawthorne Army Depot 

E.3.5.2 Environmental Consequences 

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, of the January 2011 Mercury Storage EIS. 

E.3.5.2.1 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 

renovations is expected to be less than that estimated for constructing a new facility, as described in 

Chapter 4, Section 4.5.11, of the January 2011 Mercury Storage EIS. Appendix C, Table C–1, of this 

draft SEIS summarizes the necessary modifications to bring the existing storage buildings at the 

Hawthorne Army Depot up to specifications to support mercury storage. Operation of the existing 

buildings for mercury storage 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 to six individuals thereafter, resulting in a possible increase in the 

depot’s workforce of approximately 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 

and population trends) in the ROI would result from implementing this alternative. 
Updates to the January 2011 Mercury Storage EIS

E–29

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

Chapter 4, Section 4.5.11, of the January 2011 Mercury Storage EIS). 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. Impacts on traffic during construction would be minor.

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, of this draft SEIS 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. At the peak of operations, it 

is estimated that up to 79 shipments would be made in a year. Approximately 96 percent of the additional 

vehicles would be attributed to employee transportation. Impacts on traffic during operations would be 

negligible.

E.3.5.2.2 Environmental Justice

One of the block groups within the 16-kilometer (10-mile) radius surrounding the proposed storage site at 

the Hawthorne Army Depot contains both a minority and low-income population. The same block group 

has been identified within the 3.2-kilometer (2-mile) radius surrounding the storage site. As discussed in 

Chapter 3, Section 3.4.1.1, and Chapter 4, Section 4.5.1, of the January 2011 Mercury Storage EIS, the 

surrounding area includes light industrial land use; there would be no offsite impacts on land use as a 

result of implementing the Hawthorne Army Depot alternative. Impacts on air quality under this 

alternative would be negligible, as discussed in Chapter 4, Section 4.5.4.2, of the January 2011 Mercury 

Storage EIS. No impacts on ecological resources would occur under this alternative, as discussed in 

Section 4.5.5 of the January 2011 Mercury Storage EIS. Modification of existing storage buildings would 

not require any additional land to be disturbed and the probability of discovering American Indian 

archaeological sites would be negligible; thus, there would be negligible impacts on American Indian 

cultural resources, as discussed in Chapter 3, Section 3.4.6.3, and Chapter 4, Section 4.5.6.3, of the 

January 2011 Mercury Storage EIS. A negligible change in socioeconomic conditions would result under 

this alternative, as discussed above in Section E.3.5.2.1. As discussed in Section 4.5.9 of the 

January 2011 Mercury Storage EIS, implementing the Hawthorne Army Depot alternative would result in 

negligible offsite human health risks from mercury emissions during normal operations and facility 

accidents. As discussed in Section 4.5.9.3 of the January 2011 Mercury Storage EIS, transportation 

accidents are predicted to pose a negligible-to-low human health risk following dry deposition onto the 

ground or into water bodies. The Hawthorne Army Depot is located in an area proximal to a block group 

identified as both a minority and low-income community, as described in Section E.3.5.1.2. The analysis 

of the Hawthorne Army Depot alternative identified the presence of minority and low-income 

communities adjacent to potential transportation routes. The transportation accident analysis is discussed 

in Section 4.2.9.3 and Appendix D, Section D.4.5, of the January 2011 Mercury Storage EIS.

In addition, under transportation accident scenarios in which a fire occurs, it is possible for nearby 

downwind surface-water bodies to become contaminated, raising concerns for populations where fish 

is an important part of the diet. Chapter 4, Section 4.5.9.3.3, of the January 2011 Mercury Storage EIS

discusses the possibility of accumulation of mercury in fish under such scenarios. Three fish 

consumption rates were analyzed: the national average consumption rate, the average subsistence 

fisherman consumption rate, and the 95th percentile subsistence fisherman consumption rate 

(see Section 4.2.9.1.1 of the January 2011 Mercury Storage EIS). Such consumption rates could be 

representative of a low-income or American Indian subsistence fishing population. Under the Truck 

Scenarios, the risks to human receptors that consume fish at one of the three rates would be negligible. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–30

Under the Railcar Scenario, the risk to the 95th percentile subsistence fisherman would be negligible to 

low. American Indian reservations have not been identified within the 16-kilometer (10-mile) ROI 

surrounding the Hawthorne Army Depot; however, as discussed in Section E.3.5.1.2, there are lowincome and minority communities present in the ROI. The Walker River Indian Reservation lies outside 

the 16-kilometer radius of the proposed storage site; however, transportation of mercury through the 

reservation is a consideration. Although the risk is negligible to low, if a transportation accident that 

resulted in fish contamination were to occur, it would be advisable as a mitigation measure to monitor the 

levels of methylmercury in fish to ensure that subsistence fishermen do not consume amounts of 

methylmercury that might cause adverse health effects. Subsequent to mandated reporting of any such 

release by the shipper of the elemental mercury, the appropriate state environmental agency would be 

responsible for determining appropriate fish consumption advisories and monitoring requirements for 

mercury concentrations in waters and fish stocks. 

E.3.6 Idaho National Laboratory 

E.3.6.1 Affected Environment 

E.3.6.1.1 Socioeconomics 

INL is located in southeastern Idaho, approximately 39 kilometers (24 miles) west of Idaho Falls. Over 

90 percent of people employed at INL reside in four counties: Bannock, Bingham, Bonneville, and 

Jefferson. Therefore, these four counties are identified as the ROI in this socioeconomics analysis. 

In 2008, INL employed 8,485 persons (Wiser 2008). 

E.3.6.1.1.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the ROI increased by approximately 17 percent from 108,820 to 

126,982. During this period, the unemployment rate of the ROI increased from 4.0 percent to 7.4 percent. 

The unemployment rate in the ROI peaked during 2010 at 7.2 percent. By July 2012, the unemployment 

rate of the ROI was 6.2 percent, which was lower than the unemployment rate for Idaho (6.9 percent) 

(BLS 2012). 

E.3.6.1.1.2 Demographic and Housing Characteristics 

In 2010, the estimated population of the four-county ROI was 258,820. From 2000 to 2010, the ROI 

population grew by 18 percent, compared with 21 percent growth throughout the state of Idaho 

(DOC 2001a, 2011a). Young children and pregnant women are considered to be among the most 

vulnerable populations to mercury poisoning. The percentage of the ROI population under the age of 18 

was 31 percent; women ages 18 to 39 composed 15 percent (DOC 2011a). There were 97,785 housing 

units in the ROI in 2010 (DOC 2011b), 67 percent of which were owner-occupied, 26 percent were 

renter-occupied, and 7.5 percent were vacant (DOC 2011b, 2011c). 

E.3.6.1.2 Environmental Justice 

The 16-kilometer (10-mile) radius surrounding the candidate storage locations at INL encompasses parts 

of two counties in Idaho: Bingham and Butte. Figure E–12 shows populations residing in the two-county 

area, as reported in the 2000 and 2010 censuses (DOC 2001a, 2011d). In this figure, lightly shaded bars 

show populations in 2000, and the darker bars show those in 2010. In the decade between 2000 and 

2010, the total population of Bingham and Butte Counties increased by approximately 8.7 percent to 

48,498; the minority population increased by approximately 28 percent to 11,609; and the low-income 

population increased by 22 percent to 6,879 (DOC 2001a, 2001b, 2011d, 2011e). Demographic data from 

the 2010 census show that the total minority population accounted for approximately 24 percent of the 

total population. The population self-identified as “some other race” (meaning those who provided 

write-in entries such as Mexican, Puerto Rican, or Cuban) residing in the two-county area composed 
Updates to the January 2011 Mercury Storage EIS

E–31

approximately 39 percent of the area’s total minority population, while those identified as American 

Indian and Alaska Native composed 26 percent of the total minority population. Persons who declared 

that they are of Hispanic or Latino origin are included in the “total Hispanic” population, regardless of 

race. They composed approximately 69 percent of the total minority population residing in Bingham and 

Butte Counties in 2010 (DOC 2011d). 

Figure E–12. Populations Residing Within the Two-County Area 

Surrounding Idaho National Laboratory 

Radioactive Waste Management Complex Option 

In 2010, 175 people lived within 16 kilometers (10 miles) of the Radioactive Waste Management 

Complex (RWMC). This area included an estimated 9.8 percent minority and 19 percent low-income 

population. By comparison, Bingham and Butte Counties included a 24 percent minority and 15 percent 

low-income population, and Idaho included a 16 percent minority and 14 percent low-income population 

(DOC 2001a, 2001b, 2011d, 2011e). There are three census block groups located within the 16-kilometer 

radius surrounding the RWMC, none of which contained a minority or low-income population. As 

described in Appendix B, Section B.11.1, of the January 2011 Mercury Storage EIS and updated in 

Appendix B of this draft SEIS, minority and low-income populations or communities are identified by 

comparing block-group data to the surrounding state- and county-level data to determine if the minority 

or low-income population percentage is meaningfully greater than that of the general population. No one 

resides within approximately 3.2 kilometers (2 miles) of the RWMC (DOC 2011d). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–32

The Fort Hall Reservation is located approximately 71 kilometers (44 miles) southeast of the RWMC. 

Figure E–13 shows the cumulative populations living at a given distance from the RWMC. 

0 2 4 6 8 10 12 14 16

0

20

40

60

80

100

120

140

160

180

200

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

Figure E–13. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Radioactive Waste Management Complex 

Idaho Nuclear Technology and Engineering Center Option 

In 2010, 205 people lived within 16 kilometers (10 miles) of the Idaho Nuclear Technology and 

Engineering Center (INTEC). This area included an estimated 11 percent minority and 15 percent 

low-income population. By comparison, Bingham and Butte Counties included a 24 percent minority and 

15 percent low-income population, and Idaho included a 16 percent minority and 14 percent low-income 

population (DOC 2001a, 2001b, 2011d, 2011e). There are three census block groups located within the 

16-kilometer radius surrounding INTEC, none of which contained a minority or low-income population. 

No one resides within approximately 3.2 kilometers (2 miles) of INTEC (DOC 2011d). 

The Fort Hall Reservation is located approximately 69 kilometers (43 miles) southeast of INTEC. 
Updates to the January 2011 Mercury Storage EIS

E–33

Figure E–14 shows the cumulative populations living at a given distance from INTEC. 

- 2 4 6 8 10 12 14 16 

0

50

100

150

200

250

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

Figure E–14. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Idaho Nuclear Technology and Engineering Center 

E.3.6.2 Environmental Consequences 

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 INTEC, or (2) modification of existing 

waste storage facilities at the RWMC to accommodate mercury storage. These options are further 

described in Chapter 2, Section 2.4.5, of the January 2011 Mercury Storage EIS. In the following 

sections, differences in potential impacts between the options are identified, where appropriate. 

E.3.6.2.1 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 

expected, and approximately 5 to 6 individuals thereafter, resulting in a possible increase of the INL 

workforce of less than 0.1 percent and an increase in the ROI of 0.005 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 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–34

expected to generate substantial direct or indirect employment. Thus, negligible impacts on 

socioeconomic conditions (i.e., overall employment and population trends) 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 Idaho State Route 33 by approximately 6 percent. 

Fifty-three percent of these vehicles would be attributed to employee transportation. Impacts on traffic 

during construction would be minor. 

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, of this draft SEIS 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. At the peak of operations, it 

is estimated that up to 79 shipments would be made in a year. Approximately 96 percent of the additional 

vehicles would be attributed to employee transportation. Impacts on traffic during operations would be 

minor. 

Radioactive Waste Management Complex Option 

Modifications of the existing RWMC storage modules and subsequent operations for storage of elemental 

mercury under the RWMC Option would result in substantially smaller socioeconomic impacts than those 

described above for the INTEC Option. The total impact on socioeconomic and traffic conditions in the 

ROI surrounding INL would be negligible to minor. Appendix C, Table C–1, of the January 2011 

Mercury Storage EIS summarizes the necessary modifications to the RWMC storage modules to meet the 

specifications for mercury storage. 

E.3.6.2.2 Environmental Justice 

Idaho Nuclear Technology and Engineering Center Option 

None of the block groups within either the 16-kilometer (10-mile) radius or the 3.2-kilometer (2-mile) 

radius surrounding INTEC contain a minority or low-income population. 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. 

Radioactive Waste Management Complex Option 

None of the block groups within either the 16-kilometer (10-mile) radius or the 3.2-kilometer (2-mile) 

radius surrounding the RWMC contain a minority or low-income population. 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 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. 
Updates to the January 2011 Mercury Storage EIS

E–35

E.3.7 Kansas City Plant 

E.3.7.1 Affected Environment 

E.3.7.1.1 Socioeconomics 

KCP is located in Kansas City, Missouri, approximately 13 kilometers (8 miles) south of the city center. 

KCP employs approximately 2,400 persons. Approximately 90 percent of the people employed at KCP 

reside in four counties: Cass, Clay, and Jackson in Missouri and Johnson in Kansas. Therefore, these 

four counties are identified as the ROI in this socioeconomics analysis (GSA and NNSA 2008:22). 

E.3.7.1.1.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the four-county ROI increased by approximately 6.5 percent from 

763,352 to 813,127. During this period, the unemployment rate of the ROI increased from 3.1 percent to 

7.9 percent. The unemployment rate in the ROI peaked during 2009 at 8.8 percent and remained at that 

level through 2010. By July 2012, the unemployment rate of the ROI was 7.3 percent, which was higher 

than the unemployment rate across the two-state area of Missouri and Kansas (6.8 percent) (BLS 2012). 

E.3.7.1.1.2 Demographic and Housing Characteristics 

In 2010, the estimated population of the four-county ROI was 1,539,754. From 2000 to 2010, the ROI 

population grew by 12 percent, compared with 6.7 percent growth throughout the two-state region of 

Missouri and Kansas (DOC 2001a, 2011a). Young children and pregnant women are considered to be 

among the most vulnerable populations to mercury poisoning. The percentage of the ROI population 

under the age of 18 was 26 percent; women ages 18 to 39 composed 15 percent of the population 

(DOC 2011a). There were 672,624 housing units in the ROI in 2010 (DOC 2011b), 61 percent 

of which were owner-occupied, 30 percent were renter-occupied, and 9.0 percent were vacant 

(DOC 2011b, 2011c). 

E.3.7.1.2 Environmental Justice 

The 16-kilometer (10-mile) radius surrounding the candidate storage location at KCP encompasses parts 

of four counties: Cass and Jackson in Missouri and Johnson and Wyandotte in Kansas. Figure E–15

shows populations residing in the four-county area, as reported in the 2000 and 2010 censuses 

(DOC 2001a, 2011d). In this figure, lightly shaded bars show populations in 2000, and the darker bars 

show those in 2010. In the decade between 2000 and 2010, the total population of Cass, Jackson, 

Johnson, and Wyandotte Counties increased by approximately 9.6 percent to 1,475,320; the minority 

population increased by approximately 30 percent to 445,453; and the low-income population increased 

by 40 percent to 172,177 (DOC 2001a, 2001b, 2011d, 2011e). Demographic data from the 2010 census 

show that the total minority population accounted for approximately 30 percent of the total population. 

The Black or African American population residing in the four-county area accounted for approximately 

51 percent of the area’s total minority population. Persons who declared that they are of Hispanic or 

Latino origin are included in the “total Hispanic” population, regardless of race. They composed 

approximately 9.6 percent of the total population and approximately 32 percent of the total minority 

population residing in Cass, Jackson, Johnson, and Wyandotte Counties in 2010 (DOC 2011d). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–36

Figure E–15. Populations Residing Within the Four-County Area 

Surrounding the Kansas City Plant 

In 2010, 705,513 people lived within 16 kilometers (10 miles) of KCP. This area included an estimated 

36 percent minority and 13 percent low-income population. By comparison, the four-county area 

included a 30 percent minority and 12 percent low-income population, and the two-state area included a 

19 percent minority and 14 percent low-income population (DOC 2011d, 2011e). There are 659 census 

block groups located within the 16-kilometer radius surrounding KCP; of this total, 157 contained a 

minority population, 5 contained a low-income population, and 88 contained both a minority and 

low-income population. A total of 409 block groups did not contain a low-income or minority 

population. As described in Appendix B, Section B.11.1, of the January 2011 Mercury Storage EIS and 

updated in Appendix B of this draft SEIS, minority and low-income populations or communities are 

identified by comparing block-group data to the surrounding state- and county-level data to determine if 

the minority or low-income population percentage is meaningfully greater than that of the general 

population. 

In 2010, 26,192 people lived within approximately 3.2 kilometers (2 miles) of KCP. This area included 

an estimated 52 percent minority and 20 percent low-income population (DOC 2011d, 2011e). There are 

39 census block groups located within this ROI; of this total, 16 contained a minority population, none 

contained a low-income population, and 6 contained both a minority and low-income population. 

Seventeen block groups did not contain a minority or low-income population. 

Figure E–16 displays the proximity of minority and low-income communities to KCP. 
Updates to the January 2011 Mercury Storage EIS

E–37

Figure E–16. Block Groups Containing Minority and Low-Income Populations 

Surrounding the Kansas City Plant 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–38

Figure E–17 shows the cumulative populations living at a given distance from the site. 

0 2 4 6 8 10 12 14 16

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

Figure E–17. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Kansas City Plant 

E.3.7.2 Environmental Consequences 

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), as further described in 

Chapter 2, Section 2.4.6, of the January 2011 Mercury Storage EIS. 

E.3.7.2.1 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. Appendix C, Table C–1, of the January 2011 Mercury Storage EIS 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 

to six individuals thereafter. 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 and population trends) in the ROI would result from implementing this alternative. 
Updates to the January 2011 Mercury Storage EIS

E–39

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. Therefore, 

construction-related transportation is expected to increase the average annual daily traffic count on 

Bannister Road by no more than 0.3 percent. Impacts on traffic during construction would be negligible. 

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, of this draft SEIS 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. At the peak of 

operations, it is estimated that up to 79 shipments would be made in a year. Approximately 96 percent of 

the additional vehicles would be attributed to employee transportation. Impacts on traffic during 

operations would be negligible. 

E.3.7.2.2 Environmental Justice 

An analysis of populations in census block groups found that, of the 659 block groups within the 

16-kilometer (10-mile) radius of KCP, 157 contained only a minority population, 5 contained only a 

low-income population, and 88 contained both minority and low-income populations. A total of 

409 block groups did not contain minority or low-income populations. Of the 39 census block groups 

within the 3.2-kilometer (2-mile) radius of KCP, 16 contained only a minority population and 6 contained 

both minority and low-income populations. Seventeen block groups within this ROI did not contain a 

minority or low-income population. 

As discussed in Chapter 3, Section 3.6.1.1, and Chapter 4, Section 4.7.1, of the January 2011 Mercury 

Storage EIS, 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 of the January 2011 Mercury 

Storage EIS. No impacts on ecological resources would occur under this alternative, as discussed in 

Section 4.7.5 of the January 2011 Mercury Storage EIS. 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 Sections 3.6.6.3 and 4.7.6.3 of the January 2011 

Mercury Storage EIS. A negligible change in socioeconomic conditions would result under this 

alternative, as discussed above in Section E.3.7.2.1. 

As discussed in Chapter 4, Section 4.7.9, of the January 2011 Mercury Storage EIS, 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 of the January 2011 Mercury 

Storage EIS, transportation accidents are predicted to pose a negligible-to-low human health risk 

following dry deposition onto the ground or into water bodies. KCP is located in an area proximal to both 

minority and low-income communities, as described in Section E.3.7.1.2. The analysis of the KCP 

alternative identified minority and low-income communities adjacent to potential transportation routes. 

The transportation accident analysis is discussed in Section 4.2.9.1.5 and Appendix D, Section D.4.5, of 

the January 2011 Mercury Storage EIS. 

In addition, under transportation accident scenarios in which a fire occurs, it is possible for nearby 

downwind surface-water bodies to become contaminated, raising concerns for populations where fish 

is an important part of the diet. Chapter 4, Section 4.7.9.3.3, of the January 2011 Mercury Storage EIS

discusses the possibility of accumulation of mercury in fish under such scenarios. Three fish 

consumption rates were analyzed: the national average consumption rate, the average subsistence 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–40

fisherman consumption rate, and the 95th percentile subsistence fisherman consumption rate (see 

Section 4.2.9.1.1 of the January 2011 Mercury Storage EIS). Such consumption rates could be 

representative of a low-income or American Indian subsistence fishing population. Under the Truck 

Scenarios, the risks to human receptors that consume fish at one of the three rates would be negligible. 

Under the Railcar Scenario, the risk to the 95th percentile subsistence fisherman would be negligible to 

low. American Indian reservations have not been identified within the 16-kilometer (10-mile) ROI 

surrounding KCP; however, as discussed above in Section E.3.7.1.2, there are several low-income and 

minority communities present within the ROI, including communities immediately adjacent to the 

Bannister Federal Complex. Although the risk is negligible to low, if a transportation accident that 

resulted in fish contamination were to occur, it would be advisable as a mitigation measure to monitor the 

levels of methylmercury in fish to ensure that subsistence fishermen do not consume amounts of 

methylmercury that might cause adverse health effects. Subsequent to mandated reporting of any such 

release by the shipper of the elemental mercury, the appropriate state environmental agency would be 

responsible for determining appropriate fish consumption advisories and monitoring requirements for 

mercury concentrations in waters and fish stocks. 

E.3.8 Savannah River Site 

E.3.8.1 Affected Environment 

E.3.8.1.1 Socioeconomics 

SRS is located approximately 19 kilometers (12 miles) south of Aiken, South Carolina, and 24 kilometers 

(15 miles) southeast of Augusta, Georgia. Based on local employment data compiled by the Census 

Bureau, it is assumed that approximately 90 percent of the people employed at SRS reside in four 

counties: Aiken and Barnwell in South Carolina and Columbia and Richmond in Georgia (DOC 2009). 

Therefore, these four counties are identified as the ROI in this socioeconomics analysis. As of 

April 2009, SRS employed approximately 11,000 persons (SRNS 2009). 

E.3.8.1.1.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the four-county ROI increased by 10 percent from 215,077 to 

236,490. During this period, the unemployment rate of the ROI increased from 3.8 percent to 9.2 percent. 

As of July 2012, the unemployment rate of the ROI had increased to 9.8 percent, which was higher than 

the unemployment rate across the two-state area of South Carolina and Georgia (9.2 percent) (BLS 2012). 

E.3.8.1.1.2 Demographic and Housing Characteristics 

In 2010, the estimated population of the four-county ROI was 507,322. From 2000 to 2010, the ROI 

population grew by 11 percent, compared with 17 percent growth throughout the two-state area of 

Georgia and South Carolina (DOC 2001a, 2011a). Young children and pregnant women are considered 

to be among the most vulnerable populations to mercury poisoning. The percentage of the ROI 

population under the age of 18 was 25 percent; women ages 18 to 39 composed 15 percent (DOC 2011a). 

There were 217,690 housing units in the ROI in 2010 (DOC 2011b), 60 percent of which were 

owner-occupied, 30 percent were renter-occupied, and 10 percent were vacant (DOC 2011b, 2011c). 

E.3.8.1.2 Environmental Justice 

The 16-kilometer (10-mile) radius surrounding the candidate storage location at SRS encompasses parts 

of four counties: Aiken and Barnwell in South Carolina and Burke and Richmond in Georgia. 

Figure E–18 shows populations residing in the four-county area, as reported in the 2000 and 2010 

censuses (DOC 2001a, 2011d). In this figure, lightly shaded bars show populations in 2000, and the 

darker bars show those in 2010. In the decade between 2000 and 2010, the total population of Aiken, 

Barnwell, Burke, and Richmond Counties increased by approximately 4.8 percent to 406,585; the 
Updates to the January 2011 Mercury Storage EIS

E–41

minority population increased by approximately 13 percent to 199,224; and the low-income population 

increased by approximately 19 percent to 80,813 (DOC 2001a, 2001b, 2011d, 2011e). Demographic data 

from the 2010 census show that the total minority population accounted for approximately 49 percent of 

the total population. The Black or African American population residing in the four-county area 

accounted for approximately 85 percent of the total minority population. Persons who declared that they 

are of Hispanic or Latino origin are included in the “total Hispanic” population, regardless of race. They 

composed approximately 4.2 percent of the total population and approximately 8.6 percent of the total 

minority population residing in the four-county region (DOC 2011d). 

Figure E–18. Populations Residing Within the Four-County Area 

Surrounding the Savannah River Site 

In 2010, 6,691 people lived within 16 kilometers (10 miles) of E Area at SRS (DOC 2011d). This area 

included an estimated 38 percent minority and 20 percent low-income population. By comparison, the 

four-county area included a 49 percent minority and 21 percent low-income population, and the two-state 

region of South Carolina and Georgia included a 41 percent minority and 16 percent low-income 

population (DOC 2011d, 2011e). There are 15 census block groups located within the 16-kilometer 

radius surrounding E Area, 4 of which contained a minority population and 1 contained a low-income 

population. As described in Appendix B, Section B.11.1, of the January 2011 Mercury Storage EIS and 

updated in Appendix B of this draft SEIS, minority and low-income populations or communities are 

identified by comparing block-group data to the surrounding state- and county-level data to determine if 

the minority or low-income population percentage is meaningfully greater than that of the general 

population. No one resides within approximately 3.2 kilometers (2 miles) of E Area. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–42

Figure E–19 shows the proximity of the identified minority communities to E Area. 

Figure E–19. Block Groups Containing Minority and Low-Income Populations 

Surrounding the Savannah River Site 
Updates to the January 2011 Mercury Storage EIS

E–43

Figure E–20 shows the cumulative populations living at a given distance from the site. 

0 2 4 6 8 10 12 14 16

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

Figure E–20. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Savannah River Site 

E.3.8.2 Environmental Consequences 

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, of the January 2011 Mercury Storage EIS. 

E.3.8.2.1 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 to 6 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 new facility is expected to generate substantial direct or indirect employment. Thus, 

negligible impacts on socioeconomic conditions (i.e., overall employment and population trends) in the 

ROI would result from implementing this alternative. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–44

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 South Carolina 

Highway 19, to approximately 3 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. 

Impacts on traffic during construction would be minor. 

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, of this draft SEIS 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. At the peak of operations, it is 

estimated that up to 79 shipments would be made in a year. Approximately 96 percent of the additional 

vehicles would be attributed to employee transportation. Impacts on traffic during operations would be 

negligible to minor. 

E.3.8.2.2 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 minority population and 1 contained a 

low-income population. No populations have been identified within the 3.2-kilometer (2-mile) radius 

surrounding E Area. 

As discussed in Chapter 3, Section 3.7.1.1, and Chapter 4, Section 4.8.1, of the January 2011 Mercury 

Storage EIS, 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 of the January 2011 Mercury Storage EIS. 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 Sections 3.7.6.3 

and 4.8.6.3 of the January 2011 Mercury Storage EIS. A negligible change in socioeconomic conditions 

would result under this alternative, as discussed above in Section E.3.8.2.1. 

As discussed in Chapter 4, Section 4.8.9, of the January 2011 Mercury Storage EIS, 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 of the January 2011 Mercury 

Storage EIS, transportation accidents are predicted to pose 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 and the one block group 

identified that consists of a disproportionately high number of low-income individuals are located 

adjacent to one of the entrances into SRS located at South Carolina Highway 19 and adjoining 

U.S. Route 278. The transportation accident analysis is discussed in Section 4.2.9.1.5 and Appendix D, 

Section D.4.5, of the January 2011 Mercury Storage EIS. No minority or low-income populations have 

been identified adjacent to the other site entrances. Therefore, if a transportation accident were to occur 

at or near any of the other site entrances, it would be reasonable to conclude that the consequences to 

human health of the accident would not be borne by a minority or low-income community. 
Updates to the January 2011 Mercury Storage EIS

E–45

In addition, under transportation accident scenarios in which a fire occurs, it is possible for nearby 

downwind surface-water bodies to become contaminated, raising concerns for populations where fish 

is an important part of the diet. Chapter 4, Section 4.7.9.3.3, of the January 2011 Mercury Storage EIS

discusses the possibility of accumulation of mercury in fish under such scenarios. Three fish 

consumption rates were analyzed: the national average consumption rate, the average subsistence 

fisherman consumption rate, and the 95th percentile subsistence fisherman consumption rate 

(see Section 4.2.9.1.1 of the January 2011 Mercury Storage EIS). Such consumption rates could be 

representative of a low-income or American Indian subsistence fishing population. Under the Truck 

Scenarios, the risks to human receptors that consume fish at one of the three rates would be negligible. 

Under the Railcar Scenario, the risk to the 95th percentile subsistence fisherman would be negligible to 

low. American Indian reservations have not been identified within the 16-kilometer (10-mile) ROI 

surrounding SRS; however, as discussed above in Section E.3.8.1.2, there are several low-income or 

minority communities present within the ROI. Although the risk is negligible to low, if a transportation 

accident that resulted in fish contamination were to occur, it would be advisable as a mitigation measure 

to monitor the levels of methylmercury in fish to ensure that subsistence fishermen do not consume 

amounts of methylmercury that might cause adverse health effects. Subsequent to mandated reporting of 

any such release by the shipper of the elemental mercury, the appropriate state environmental agency 

would be responsible for determining appropriate fish consumption advisories and monitoring 

requirements for mercury concentrations in waters and fish stocks. 

E.3.9 Waste Control Specialists, LLC, Site 

E.3.9.1 Affected Environment 

E.3.9.1.1 Socioeconomics 

WCS is located approximately 50 kilometers (31 miles) west of Andrews, Texas, near the Texas–New 

Mexico state line. As of 2009, WCS employed approximately 150 persons. Approximately 90 percent of 

the people employed at WCS reside in two counties: Andrews in Texas and Lea in New Mexico 

(WCS 2009). Therefore, these two counties are identified as the ROI in this socioeconomics analysis. 

E.3.9.1.1.1 Regional Economic Characteristics 

From 2000 to 2011, the labor force of the two-county ROI increased by approximately 30 percent from 

28,277 to 36,788. During this period, the unemployment rate of the ROI experienced minor fluctuations 

both positive and negative, and by 2011 had returned to the 2000 rate of 5.2 percent. The unemployment 

rate in the ROI peaked during 2009 at 7.1 percent and remained at that level through 2010. By July 2012, 

the unemployment rate of the ROI was 4.6 percent, lower than the unemployment rate across the 

two-state region of Texas and New Mexico (7.0 percent) (BLS 2012). 

E.3.9.1.1.2 Demographic and Housing Characteristics 

In 2010, the estimated population of the two-county ROI was 79,513. From 2000 to 2010, the ROI 

population grew by approximately 16 percent, compared with 20 percent growth throughout the two-state 

region of Texas and New Mexico (DOC 2001a, 2011a). Young children and pregnant women are 

considered to be among the most vulnerable populations to mercury poisoning. In 2010, the percentage 

of the ROI population under the age of 18 was 29 percent; women ages 18 to 39 composed 15 percent 

(DOC 2011a). There were 30,733 housing units in the ROI in 2010, 63 percent of which were 

owner-occupied, 26 percent were renter-occupied, and 11 percent were vacant (DOC 2011b, 2011c). 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–46

E.3.9.1.2 Environmental Justice 

The 16-kilometer (10-mile) radius surrounding the candidate storage location at WCS encompasses 

parts of three counties: Andrews and Gaines in Texas and Lea in New Mexico. Figure E–21 

shows populations residing in the three-county area, as reported in the 2000 and 2010 censuses 

(DOC 2001b, 2011d). In this figure, lightly shaded bars show populations in 2000, and the darker bars 

show those in 2010. In the decade between 2000 and 2010, the total population of Andrews, Gaines, and 

Lea Counties decreased by approximately 17 percent to 97,039, while the minority population increased 

by approximately 40 percent to 51,483, and the low-income population decreased by approximately 

3.9 percent to 15,905 (DOC 2001a, 2001b, 2011d, 2011e). Demographic data from the 2010 census show 

that the total minority population accounts for approximately 53 percent of the total population. The 

White Hispanic population accounts for approximately 57 percent of the total minority population, while 

those people self-identified as “some other race” (meaning those who provided write-in entries such as 

Mexican, Puerto Rican, or Cuban) residing in the three-county area accounted for approximately 

29 percent of the total minority population. Persons who declared that they are of Hispanic or Latino 

origin are included in the “total Hispanic” population, regardless of race. They composed approximately 

48 percent of the total population and approximately 91 percent of the total minority population residing 

in Andrews, Gaines, and Lea Counties in 2010 (DOC 2011d). 

Figure E–21. Populations Residing Within the Three-County Area 

Surrounding the Waste Control Specialists Site 
Updates to the January 2011 Mercury Storage EIS

E–47

In 2010, 3,322 people lived within 16 kilometers (10 miles) of WCS. This area included an estimated 

47 percent minority and 12 percent low-income population. By comparison, the three-county area 

included a 53 percent minority and 18 percent low-income population and the two-state region of Texas 

and New Mexico included a 55 percent minority and 17 percent low-income population 

(DOC 2011d, 2011e). There are eight census block groups located within the 16-kilometer radius 

surrounding WCS, two of which contained a minority population; none contained a low-income 

population. As described in Appendix B, Section B.11.1, of the January 2011 Mercury Storage EIS and 

updated in Appendix B of this draft SEIS, minority and low-income populations or communities are 

identified by comparing block-group data to the surrounding state- and county-level data to determine if 

the minority or low-income population percentage is meaningfully greater than that of the general 

population.

Approximately 27 people lived within approximately 3.2 kilometers (2 miles) of WCS in 2010. This area 

included an estimated 35 percent minority and 7.8 percent low-income population (DOC 2011d, 2011e). 

There are two census block groups located within this ROI; of this total, none contained a minority or 

low-income population.

Figure E–22 shows the proximity of the identified minority communities to WCS.

Figure E–23 shows the cumulative populations living at a given distance from WCS.

E.3.9.2 Environmental Consequences

Under this alternative, elemental mercury would be stored at WCS. Waste Control Specialists, LLC, 

owns and 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 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 WCS, 

as further described in Chapter 2, Section 2.4.8, of the January 2011 Mercury Storage EIS. Consideration 

was given to the two locations at WCS where a new facility could be sited; no significant differences in 

potential impacts were identified.

E.3.9.2.1 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 to 6 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 0.02 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 and 

population trends) in the ROI would result from implementing this alternative.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–48

Figure E–22. Block Groups Containing Minority and Low-Income Populations 

Surrounding the Waste Control Specialists Site 
Updates to the January 2011 Mercury Storage EIS

0 2 4 6 8 10 12 14 16

0

500

1,000

1,500

2,000

2,500

3,000

3,500

0 1 2 3 4 5 6 7 8 9 10

Distance from Storage Location (kilometers)

Population

Distance from Storage Location (miles)

Total Population

Total Minority

Total Low-Income

E–49

Figure E–23. Populations Residing Within 16 Kilometers (10 Miles) of the Storage Location at the 

Waste Control Specialists Site 

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. Impacts on traffic during 

construction would be minor. 

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, of this draft SEIS 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. At the 

peak of operations, it is estimated that up to 79 shipments would be made in a year. Approximately 

96 percent of the additional vehicles would be attributed to employee transportation. Impacts on traffic 

during operations would be negligible. 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–50

E.3.9.2.2 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, two contained a minority population and none contained a 

low-income population. There are only two block groups within the 3.2-kilometer (2-mile) ROI, none 

of which contained a minority or low-income population. 

As discussed in Chapter 3, Section 3.8.1.1, and Chapter 4, Section 4.9.1, of the January 2011 Mercury 

Storage EIS, 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 of the January 2011 Mercury Storage EIS. Impacts on ecological resources are 

expected to be minimal under this alternative, as discussed in Section 4.9.5 of the January 2011 Mercury 

Storage EIS. There have been no American Indian resources identified on WCS; thus, there would be no 

impacts on American Indian cultural resources, as noted in Sections 3.8.6.2 and 4.9.6.3 of the 

January 2011 Mercury Storage EIS. A negligible change in socioeconomic conditions would result under 

this alternative, as discussed above in Section E.3.9.2.1. 

As discussed in Chapter 4, Section 4.9.9, of the January 2011 Mercury Storage EIS, 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 of the January 2011 Mercury 

Storage EIS, transportation accidents are predicted to pose a negligible-to-low human health risk 

following dry deposition onto the ground or into water bodies. The two block groups identified that 

consist of a disproportionately high number of minority individuals are located approximately 

10 kilometers (6 miles) to the west in the city of Eunice near potential transportation routes. Potential 

truck transportation routes include Texas State Highway 176 from points east, New Mexico State 

Highway 176 from points west, and New Mexico State Road 18 from points north. 

In addition, under transportation accident scenarios in which a fire occurs, it is possible for nearby 

downwind surface-water bodies to become contaminated, raising concerns for populations where fish 

is an important part of the diet. Chapter 4, Section 4.7.9.3.3, of the January 2011 Mercury Storage EIS

discusses the possibility of accumulation of mercury in fish under such scenarios. Three fish 

consumption rates were analyzed: the national average consumption rate, the average subsistence 

fisherman consumption rate, and the 95th percentile subsistence fisherman consumption rate 

(see Section 4.2.9.1.1 of the January 2011 Mercury Storage EIS). Such consumption rates could be 

representative of a low-income or American Indian subsistence fishing population. Under the Truck 

Scenarios, the risks to human receptors that consume fish at one of the three rates would be negligible. 

Under the Railcar Scenario, the risk to the 95th percentile subsistence fisherman would be negligible to 

low. American Indian reservations have not been identified within the 16-kilometer (10-mile) ROI 

surrounding WCS; however, as discussed above in Section E.3.9.1.2, there are minority communities 

present within the ROI. Although the risk is negligible to low, if a transportation accident that resulted in 

fish contamination were to occur, it would be advisable as a mitigation measure to monitor the levels of 

methylmercury in fish to ensure that subsistence fishermen do not consume amounts of methylmercury 

that might cause adverse health effects. Subsequent to mandated reporting of any such release by the 

shipper of the elemental mercury, the appropriate state environmental agency would be responsible for 

determining appropriate fish consumption advisories and monitoring requirements for mercury 

concentrations in waters and fish stocks. 

E.4 ENVIRONMENTAL DOCUMENTATION REVIEW 

This draft SEIS is being published approximately 2 years after the publication of the January 2011 

Mercury Storage EIS. As such, there was a possibility that some environmental data upon which the 

impact analyses rely for the seven candidate sites analyzed in the January 2011 Mercury Storage EIS may 
Updates to the January 2011 Mercury Storage EIS

E–51

have changed significantly, potentially affecting the analyses or comparison of alternatives. Previously in 

this appendix, updates to occupational and public health and safety, socioeconomics, and environmental 

justice were discussed. Most of the candidate sites publish annual site environment reports, periodic 

monitoring reports, or other environmental data. Environmental documentation that has become available 

since publication of the January 2011 Mercury Storage EIS has been reviewed, and no other changes to 

the affected environment or analyses as presented in the January 2011 Mercury Storage EIS were found to 

be necessary. The documents reviewed for each candidate site are listed below.

Grand Junction Disposal Site:

Data Validation Package – August 2012 Groundwater Sampling at the Grand Junction, 

Colorado, Disposal Site, October 2012 (DOE 2012b).

2011 Uranium Mill Tailings Radiation Control Act Title I Annual Report, January 2012 

(DOE 2012c).

200-West Area at the Hanford Site:

Final Tank Closure and Waste Management Environmental Impact Statement for the Hanford 

Site, Richland, Washington, November 2012 (DOE 2012d).

Hanford Site Environmental Report for Calendar Year 2009, September 2010 (Poston, Duncan, 

and Dirkes 2010).

Central Magazine Area at Hawthorne Army Depot:

Hawthorne Army Depot Webpage – The Nevada Division of Environmental Protection, 

http://ndep.nv.gov/hwad/haap02.htm, accessed in January 2013 (NDEP 2013).

Idaho National Laboratory’s Idaho Nuclear Technology and Engineering Center or the Radioactive Waste 

Management Complex:

Idaho National Laboratory Site Environmental Report, Calendar Year 2010, September 2011 

(DOE 2011a).

Bannister Federal Complex’s Kansas City Plant:

2010 Kansas City Plant Annual Injury and Illness Surveillance Report, 2011 (DOE 2011b).

E Area at the Savannah River Site:

Draft Surplus Plutonium Disposition Supplemental Environmental Impact Statement, July 2012 

(NNSA 2012).

Savannah River Site Environmental Report for 2011, 2012 (SRNS 2012).

Waste Control Specialists, LLC Site:

Waste Control Specialists, LLC, Homepage, http://www.wcstexas.com/, accessed in January 2013 

(WCS 2013).

Y–12 National Security Complex:

Oak Ridge Reservation Annual Site Environmental Report for 2011, September 2012 

(ORNL 2012).

Final Site-Wide Environmental Impact Statement for the Y–12 National Security Complex, 

February 2011 (NNSA 2011).
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

E–52

E.5 REFERENCES 

BLS (U.S. Bureau of Labor Statistics), 2012, Local Area Unemployment Statistics, 2000–2012 by 

Selected States and Counties, accessed through http://www.bls.gov/data/. 

CEQ (Council on Environmental Quality), 1997, Environmental Justice Guidance Under the National 

Environmental Policy Act, Executive Office of the President, Washington, DC, December 10. 

DLA (Defense Logistics Agency), 2004, Final Mercury Management Environmental Impact Statement, 

Defense National Stockpile Center, Fort Belvoir, Virginia, March. 

DOC (U.S. Department of Commerce), 2001a, U.S. Census Bureau, 2000 Decennial Census, Summary 

File 1, Detailed Tables, P008: Hispanic or Latino by Race - Universe: Total Population, accessed through 

http://factfinder2.census.gov/faces/nav/jsf/pages/index.xhtml. 

DOC (U.S. Department of Commerce), 2001b, U.S. Census Bureau, 2000 Decennial Census, Summary 

File 3, Detailed Tables, P088: Ratio of Income in 1999 to Poverty Level [10] - Universe: Population for 

Whom Poverty Status is Determined, accessed through http://factfinder2.census.gov/faces/nav/jsf/ 

pages/index.xhtml. 

DOC (U.S. Department of Commerce), 2009, U.S. Census Bureau, Local Employment Dynamics, Labor 

Shed Reports for Selected Regions Generate Using LED on the Map Version 3, accessed through 

http://lehdmap3.did.census.gov/themap3/, October 8. 

DOC (U.S. Department of Commerce), 2011a, U.S. Census Bureau, 2010 Decennial Census, Summary 

File 1, P12: Sex by Age - Universe: Total Population, accessed through http://factfinder2.census.gov/ 

faces/nav/jsf/pages/index.xhtml. 

DOC (U.S. Department of Commerce), 2011b, U.S. Census Bureau, 2010 Decennial Census, Summary 

File 1, Table H3: Occupancy Status - Universe: Housing Units, accessed through 

http://factfinder2.census.gov/faces/nav/jsf/pages/index.xhtml. 

DOC (U.S. Department of Commerce), 2011c, U.S. Census Bureau, 2010 Decennial Census, Summary 

File 1, Table H4: Tenure - Universe: Occupied Housing Units, accessed through 

http://factfinder2.census.gov/faces/nav/jsf/pages/index.xhtml. 

DOC (U.S. Department of Commerce), 2011d, U.S. Census Bureau, 2010 Decennial Census, Summary 

File 1, Table P5: Hispanic or Latino Origin by Race - Universe: Total Population, accessed through 

http://factfinder2.census.gov/faces/nav/jsf/pages/index.xhtml. 

DOC (U.S. Department of Commerce), 2011e, U.S. Census Bureau, 2006–2010 American Community 

Survey 5-Year Estimates, Table C17002: Ratio of Income to Poverty Level in the Past 12 Months - 

Universe: Population for Whom Poverty Status is Determined, accessed through 

http://www2.census.gov/acs2010_5yr/summaryfile/UserTools/. 

DOE (U.S. Department of Energy), 2008, Final Complex Transformation Supplemental Programmatic 

Environmental Impact Statement, DOE/EIS-0236-S4, National Nuclear Security Administration, 

Washington, DC, October. 

DOE (U.S. Department of Energy), 2009, Draft Site-Wide Environmental Impact Statement for the Y–12

National Security Complex, DOE/EIS-0387, National Nuclear Security Administration, Y–12 Site Office, 

Oak Ridge, Tennessee, October. 
Updates to the January 2011 Mercury Storage EIS

E–53

DOE (U.S. Department of Energy), 2011a, Idaho National Laboratory Site Environmental Report, 

Calendar Year 2010, DOE/ID-12082(10), Idaho Operations Office, Idaho Falls, Idaho, September.

DOE (U.S. Department of Energy), 2011b, 2010 Kansas City Plant Annual Injury and Illness 

Surveillance Report, 11-OEWH-0098, Office of Heath, Safety, and Security. 

DOE (U.S. Department of Energy), 2012a, Protective Action Criteria (PAC): Chemicals with AEGLs, 

ERPGs, & TEELs, Rev. 27, accessed through http://www.atlintl.com/DOE/teels/teel/teel_pdf.html, 

February.

DOE (U.S. Department of Energy), 2012b, Data Validation Package – August 2012 Groundwater 

Sampling at the Grand Junction, Colorado, Disposal Site, LMS/GRJ/S00812, Legacy Management, 

October.

DOE (U.S. Department of Energy), 2012c, 2011 Uranium Mill Tailings Radiation Control Act Title I 

Annual Report, Grand Junction, Colorado, January.

DOE (U.S. Department of Energy), 2012d, Final Tank Closure and Waste Management Environmental 

Impact Statement for the Hanford Site, Richland, Washington, DOE/EIS-0391, Office of River Protection, 

Richland, Washington, November.

Duncan, J.P., ed., 2007, Hanford Site National Environmental Policy Act (NEPA) Characterization, 

PNNL-6415, Rev. 18, Pacific Northwest National Laboratory, Richland, Washington, September.

GJDS (Grand Junction Disposal Site), 2009, “Mercury Storage EIS” Data Call Response.

GSA and NNSA (U.S. General Services Administration and National Nuclear Security Administration), 

2008, Environmental Assessment for the Modernization of Facilities and Infrastructure for the 

Non-nuclear Production Activities Conducted at the Kansas City Plant, DOE/EA-1592, Kansas City, 

Missouri, April 21.

NDEP (Nevada Division of Environmental Protection), 2013, Hawthorne Army Depot Webpage, accessed 

through http://ndep.nv.gov/hwad/haap02.htm, January.

NNSA (National Nuclear Security Administration), 2011, Final Site-Wide Environmental Impact 

Statement for the Y–12 National Security Complex, DOE/EIS-0387, Y–12 Site Office, Oak Ridge, 

Tennessee, February.

NNSA (National Nuclear Security Administration), 2012, Draft Surplus Plutonium Disposition 

Supplemental Environmental Impact Statement, DOE/EIS-0283-S2, July.

ORNL (Oak Ridge National Laboratory), 2012, Oak Ridge Reservation Annual Site Environmental 

Report for 2011, DOE/ORO/2418, Oak Ridge, Tennessee, September.

OSHA (Occupational Safety and Health Administration), 2012, Occupational Safety and Health 

Guideline for Mercury Vapor, U.S. Department of Labor, accessed through http://www.osha.gov/SLTC/

healthguidelines/mercuryvapor/recognition.html, November 12.

Poston, T.M., J.P. Duncan, and R.L. Dirkes, eds., 2010, Hanford Site Environmental Report for Calendar 

Year 2009 (Including Some Early 2010 Information), Pacific Northwest National Laboratory, Richland, 

Washington, September.

SRNS (Savannah River Nuclear Solutions), 2009, Facts about the Savannah River Site, accessed through 

http://www.srs.gov/general/news/factsheets/srs.pdf, June.
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

E–54

SRNS (Savannah River Nuclear Solutions), 2012, Savannah River Site Environmental Report for 2011,

SRNS-STI-2012-00200, Aiken, South Carolina.

WCS (Waste Control Specialists, LLC), 2009, “Mercury Storage EIS” Data Call Response.

WCS (Waste Control Specialists, LLC), 2013, Waste Control Specialists, LLC, Homepage, accessed 

through http://www.wcstexas.com/, January.

Wiser, T., 2008, Idaho National Laboratory, Idaho Falls, Idaho, personal communication (email) to 

T. Binder, Science Applications International Corporation, Germantown, Maryland, “INL Employee 

Residence Distribution,” March 5.
APPENDIX F

COMMON AND SCIENTIFIC NAMES OF

PLANT AND ANIMAL SPECIES

F–1

APPENDIX F

COMMON AND SCIENTIFIC NAMES OF

PLANT AND ANIMAL SPECIES

The scientific names of plant and animal species associated with the Waste Isolation Pilot Plant Vicinity reference 

locations as cited in Chapter 3 and throughout this Draft Long-Term Management and Storage of Elemental 

Mercury Supplemental Environmental Impact Statement are listed in Table F–1. Plant, bird, and mammal species 

are grouped by common name and listed in alphabetical order. The scientific names of plant and animal species 

associated with the other candidate sites previously analyzed, as cited in the January 2011 Long-Term 

Management and Storage of Elemental Mercury Environmental Impact Statement (Mercury Storage EIS), are 

provided in Appendix E of the January 2011 Mercury Storage EIS and have not been reproduced here.

Table F–1. List of Common and Scientific Names of

Plant and Animal Species

Common Name Scientific Name

Plants

Dune yucca Yucca campestris

Glass Mountain coral-root Hexalectris nitida

Guadalupe jewelflower Streptanthus sparsiflorus

Gypsum wild-buckwheat Eriogonum gypsophilum

Hershey’s cliff daisy Chaetopappa hersheyi

Kuenzler hedgehog cactus Echinocereus fendleri var. kuenzleri

Lee’s pincushion cactus Escobaria sneedii var. leei

Mesquite Prosopis glandulosa

Russian thistle Salsola kali

Sand sagebrush Artemisia filifolia

Shinnery oak Quercus havardii

Smallhead snakeweed Gutierrezia microcephala

Sneed pincushion cactus Coryphantha sneedii var. sneedii

Wright’s water-willow Justicia wrightii

Birds

American peregrine falcon Falco peregrinus anatum

Arctic peregrine falcon Falco peregrinus tundrius

Baird’s sparrow Ammodramus bairdi

Black-throated sparrow Amphispiza bilineata

Least tern (interior population) Sterna antillarum athalassos

Lesser prairie-chicken Tympanuchus pallidicinctus

Loggerhead shrike Lanius ludovicianus

Pyrrhuloxia Cardinalis sinuatus

Southwestern willow flycatcher Empidonax trallii extimus

Sprague’s pipit Anthus spragueii
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement

F–2

Table F–1. List of Common and Scientific Names of

Plant and Animal Species (continued)

Common Name Scientific Name

Mammals

Black-footed ferret Mustela nigripes

Coyote Canis latrans

Mule deer Odocoileus hemionus

Pronghorn Antilocapra americana
APPENDIX G 

COOPERATING AGENCY AGREEMENTS 

 

 

 

 

 

 

APPENDIX G
 

COOPERATING AGENCY AGREEMENTS
 

This appendix provides copies of invitation letters, responses, and final agreements between the 

U.S. Department of Energy and cooperating agencies associated with this Draft Long-Term 

Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement. 

Invitation letters, responses, and final cooperating agency agreements associated with the 

January 2011 Long-Term Management and Storage of Elemental Mercury Environmental Impact 

Statement (Mercury Storage EIS) are provided in Appendix F of the January 2011 Mercury 

Storage EIS and have not been reproduced here. 

G–1 
G.1 CORRESPONDENCE WITH THE U.S. DEPARTMENT OF THE INTERIOR 

G.1.1	 U.S. Department of Energy’s Correspondence to the U.S. Department of the 

Interior 

Department of Energy 

Washington, DC 20585 

Mr. James K. Stovall 

Field Manager 

U.S. Department of the Interior 

Bureau of Land Management 

Carlsbad Field Office 

620 E. Greene Street 

Carlsbad, NM 8822 1 

Dear Mr. Stovall: 

This letter is to invite the Bureau of Land Management (BLM) to participate as a 

cooperating agency in the Department of Energy's (DOE's) preparation ofa 

supplemental environmental impact statement (SEIS), pursuant to the National 

Environmental Policy Act (NEPA). on alternatives for ong~tel'ln management and 

storage of elemental mercury. Section 5 of the Mercury EXp0l1 Ban Act of 2008 (the 

Act), Pub. L. 110-414,122 Stat. 4341 , sets fMh requirements for DOE to establish and 

manage a facility for the purpose of long-term management and storage of elemental 

mercury generated within the United States. DOE prepared the final EIS (FEfS) for the 

Long-Term Management and Storage of Elemental Mercury (DOEIEIS-0423) in January 

2011. Since its publication, DOE has reconsidered the range of reasonable alternatives 

evaluated, and now proposes to analyze additional aitel'llatives in an SEIS. This SEIS 

will evaluate two additional locations for a long-term mercury storage facility, one within 

the boundary of the Waste Isolation Pilot Plant (WIPP) in New Mexico, and a second in 

the vicinity of WlPP. 

DOE published a Notice ofllltent (NOI) on June 5, 2012 in the Federal Register 

(77 FR 33204). BLM's participation as a cooperating agency is requested; we would 

appreciate your response to this invitation as snon as practicable. If you or your staff has 

any questions or issues concerning the SEIS and/or FElS, please contact David 

Levenstein of DOE's Office ofEnviroulllcntai Management at 301 -903-6500 or 

david.levenstein@em.doe.gov. Mr. Levenstein is the DOE NEPA Document Manager 

for the SEIS. If you have any questions about DOE's NEPA process, please contact me 

at 202-586-4600. 

~f P 1 9 lOll 

Sincerely, 

CtvwC~u~~ 

Carol M. Borgstrolll 

Director 

Omce ofNEPA Policy and Compliance 

@ Plinleo wilh sO'{ ink on recycled paper 

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

G–2 
 

cc: David Levenstein, EM-II 

Cooperating Agency Agreements 

G–3 
~~ . ~,~ 

•

£T 

G.1.2 Response from the U.S. Department of the Interior 

United States Department of the Interior 

BUREAU OF LAND MANAGEMENT 

Pecos Dislrict 

Carlsbad Field Office 

620 E. Greene 

Carlsbad, New Mexico 88220-6292 

www.blm gQv/nm 

Q ~ 

. S 

. -, 

]n Reply Refer To: 

1610 (P020)ol 

Ms. Carol M. Borgstrom 

Director of NEPA Policy and Compliance 

U.S. Department of Energy 

Washington Office 

Dear Ms. Borgstrom: 

This letter is in reference to your letter dated September 19,2012, inviting our office to become a 

Cooperating Agency in the preparation of the supplemental environmental impact statement for the LongTerm Management and Storage of Elemental Mercury (DOEJEIS-0423). Our office accepts the invitation 

and looks forward to working with you through this process. 

Please inform us as to the agreement that will follow to ratify the Cooperating Agency relationship. If you 

have any questions, please contact Owen Lofton of my staff at 575-234-5923 or email olofton@blm.gov. 

Sincerely, 

r--

h#~ Jim Stovall 

Field Manager 

Carlsbad Field Office 

Cc: David Levenstein, EM-II 

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

G–4 
 

G.2	 CORRESPONDENCE WITH THE U.S. ENVIRONMENTAL PROTECTION 

AGENCY 

G.2.1	 U.S. Department of Energy’s Correspondence to the U.S. Environmental 

Protection Agency 

Department of Energy 

Washington, DC 20585 

SEP 1 9 201~. 

Ms. Susan Bromm 

Director, Office of Federal Activities 

U,S. Environmental Protection Agency 

Mail Code 2251-A 

1200 Pennsylvania A venue, N\V 

Washington, DC 20460 

Dear Ms. BrotIDn: 

This letter is to invite the U.S. Environmental Protection Agency (EPA) to participate 

as a cooperating agency in the Department ofEncrgy's (DOE's) preparation of a 

supplemental environmental impact statement (SEIS), pursuant to the National 

Environmental Policy Act (NEPA), on alternatives for long-term management and 

storage of elemental mercury. Section 5 of the Mercury EXp0l1 Ban Act of 2008 (the 

Act), Pub. L 110-414, 122 StaL 4341, sets fOl1h requirements for DOE to establish and 

manage a facility for the pllrpose of long-term management and storage of elemental 

mercury generated within the United States. DOE prepared the final ErS (FEIS) for the 

Long-Term Management and Storage ofElcmental Mercury (DOElEIS-0423) in January 

201 J, and appreciates EPA's past participation as a cooperating agency (May 18.2009 

letter from Susan Bromm to Carol Borgstrom) on that FEIS. Since its publication, DOE 

has reconsidered tbe range of reasonable alternatives evaluated, and now proposes to 

analyze additional alternatives in an SEIS. This SEIS will evaluate (wo additional 

locations for a long-term mercury storage facility. one within the boundary of the Waste 

Isolation Pilot Plant (WIPP) in New Mexico, and a second in the vicinity of\VTPP. 

DOE published a Notice orIntent (NO!) on June 5, 2012 in the Federal Register 

(77 FR 33204). EPA's continued participation as a cooperating agency on the SEIS i, 

requested~ we would appreciate your response to tllis invitation as soon as practicable. If 

you or your staff has any questions or issues concerning the SEIS andlor FEIS, plcase 

contact David Levenstein of DOE's Onice of Environmental Management at 301-903-

6500 or david,levenstein@cm.doc.gQY, Mr. Levenstein is the DOE NEPA Document 

Manager for the SEIS. If you have any questions about DOE's NEPA process, please 

contact me at 202-586-4600. 

Sincerely, 

~0-.fU~wV 

Carol M, Borgstrom 

Director 

Office ofNEPA Policy and Compliance 

@ Printed with soy Ink on recycled paper 

Cooperating Agency Agreements 

G–5 
cc: David Levenstein) EM-II 

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

G–6 
 

G.2.2 Response from the U.S. Environmental Protection Agency 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

NOV 1 2012 

OFFICE OF 

ENFORCEMENT AND 

COMPLIANCE ASSURANce 

Ms. Carol M. Borgstrom 

Director, Office ofNEPA Policy and Compliance 

GC-20 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 29585-0103 

co.P 

Dear ~rgstrom: 

Thank you for your September 19, 2012 letter inviting the U.S. Environmental 

Protection Agency (EPA) to participate as a cooperating agency in the Department of 

Energy's preparation of a Supplemental Environmental Impact Statement (SEIS) on 

additional alternatives for long-term management and storage of mercury. EPA accepts 

this invitation, and as a cooperating agency, we look forward to providing early review 

and comment on select technical studies and reports concerning procedures and standards 

for storage, as well as preliminary drafts of the SEIS. We will also participate in 

cooperating agency conference calls. 

The extent to which EPA can assist with these efforts will be dependent upon the 

availability of Agency resources and the timeliness of information sharing. 

If you have any questions concerning this matter, please contact me or my staff point 

of contact, Marthea Rountree, at (202) 564-7141 . 

Sincerely. 

Susan E. Bromm 

Director 

Office of Federal Activities 

Jnternet Address (URl) . http:/twww.epa.gov 

Recyeled/Recyclable • Printed with Vegetable all Based Inq on Recycled Pa~r (Minimum 50% Postconsul1\er content) 

Cooperating Agency Agreements 

G–7 
G.3	 CORRESPONDENCE WITH THE NEW MEXICO ENVIRONMENT 

DEPARTMENT 

G.3.1	 U.S. Department of Energy’s Correspondence to the New Mexico Environment 

Department 

Department of Energy 

Washington, DC 20585 

SEP 1 9 2012 

MJ. David Ma11in 

Secretary 

New Mexico Environment Department 

1190 St. Francis Drive 

Room N4050 

Santa Fe, NM 87502 

Dear Mr. Mattin: 

This letter is to invite the New Mexico EnvirOlUl1Cnt Depar1ment to pal1icipate as a 

cooperating agency ill the Department ofEnergy's (DOE's) preparation of a 

supplemental environmental impact statement (SETS), pursuant to the National 

Environmental Policy Act (NEPA). on alternatives for long·term management and 

storage ofelemcntal mercury. Section 5 of the Mercury EXp0l1 Ban Act 0[2008 (the 

Act), Pub. L. 110-414, 122 Stat. 4341, sets forth requirements for DOE to establish and 

manage a facility for the purpose of long-term management and storage of elemental 

mercury generated within the United States. DOE prepared the final EIS (FEIS) for the 

Long-Term Management and Storage of Elemental Mercury (DOE/EIS-0423) in January 

201 J. Since its publication, DOE has reconsidered the range of rea SOil able f1lternatives 

evaluated, and now proposes to analyze additional alternatives in an SEIS. This SEIS 

will evaluate two additional locations for a long-term mercury storage facility. one within 

the boundary of the Waste Isolation Pilot Plant (WIPP) in New Mexico, and a second in 

the vicinity ofWIPP. 

DOE published a Notice ofilltent (N0l) to prepare the SEIS on June 5, 2012 in the 

Federal Register (77 FR 33204). The New Mexico Environment Department's 

participation as a cooperating agency is requested; we would appreciate your response to 

this invitation as soon as practicable. If you or your staff has any questions or isslies 

concerning the SElS flnd/or FEIS, please contact David Levenstein afDOE's Office of 

Environmental Management at 301-903-6500 or david ,levenstein@clll.doc.gov, 

Mr. Levenstein js the DOE NEPA Docllment Manager for the SElS. If you have any 

questions about DOE's NEl'A process, please cOlltactme at 202-586-4600. 

Sincerely, 

Cev~~~·YO 

Carol M. Borgstrom 

Director 

Office ofNEPA Polic), and Compliallce 

@ Prin1ed with soy Ink on recycled paper 

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

G–8 
 

cc: David Levenstein, EM- ll 

Cooperating Agency Agreements 

G–9 

APPENDIX H 

CONTRACTOR NATIONAL ENVIRONMENTAL POLICY ACT 

DISCLOSURE STATEMENT

NATIONAL ENVIRONMENTAL POLICY ACT DISCLOSURE STATEMENT FOR 

PREPARATION OF THE LONG-TERM MANAGEMENT AND STORAGE OF ELEMENTAL 

MERCURY SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT 

The Council of Environmental Quality (CEQ) Regulations at Title 40 of the Code of Federal Regulations

(CFR) Section 1506.5(c), which have been adopted by the U.S. Department of Energy (10 CFR 1021), 

require contractors and subcontractors who will prepare an environmental impact statement to execute a 

disclosure specifying that they have no financial or other interest in the outcome of the project. 

“Financial or other interest in the outcome of the project” is defined as any direct financial benefits such 

as a promise of future construction or design work in the project, as well as indirect financial benefits the 

contractor is aware of. 

In accordance with these requirements, the offeror and any proposed subcontractors hereby certify as 

follows, to the best of their actual knowledge as the date set forth below: 

 (a) X Offeror and any proposed subcontractors have no financial or other interest in the outcome of the 

project. 

 (b) Offeror and any proposed subcontractor have the following financial or other interest in the 

outcome of the project and hereby agree to divest themselves of such interest prior to award of 

this contract, or agree to the attached plan to mitigate, neutralize or avoid any such conflict of 

interest. 

 Financial or Other Interests

 1. 

 2. 

 3. 

Certified by: 

Signature 

Gil Olivas 

Name 

AVP, Operations Contracts Manager 

Title 

Science Applications International Corporation 

Company 

10 December 2012 

Date 

APPENDIX I 

RESPONSES TO CONSULTATION REQUESTS 

 

 

 

 

 

APPENDIX I
 

RESPONSES TO CONSULTATION REQUESTS
 

This appendix provides copies of consultation requests and agency responses associated with this 

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

Statement. Consultation requests and agency responses associated with the January 2011 

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

Storage EIS) are provided in Appendix H of the January 2011 Mercury Storage EIS and have not been 

reproduced here. 

I–1 
I.1	 CORRESPONDENCE WITH THE NEW MEXICO ECOLOGICAL SERVICES 

OFFICE 

I.1.1	 U.S. Department of Energy’s Correspondence to the New Mexico Ecological 

Services Office 

Department of Energy 

Washington, DC 20585 

AUG 24 2D1Z1 

Mr. Wally Mwphy, Field Supervisor 

U.S. Fish and Wildlife Service 

New Mexico Ecological Services Office 

2105 Osuna NE 

Albuquerque, New Mexico 871 I3 

Dear Mr. Mwphy: 

T.he purpose of this letter is to notify you that the Department of Energy (DOE) is 

preparing a Supplement to the Environmental Impact Statement (EIS) for the Long-Term 

Management and Storage of Elemental Mercury (see enclosed Notice ofIntent). 

Pursuant to the Mercury Export Ban Act of2008 (P.L. 110-414), DOE has been directed 

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

mercury generated within the United States. DOE is analyzing the stomge of up to 

10,000 metric tons (11 ,000 tons) of elemental mercury in a facility or facilities 

constructed and operated in accordance with the Solid Waste Disposal Act, as amended 

by the Resource Conservation and Recovery Act. T.o evaluate the range of reasonable 

alternatives for siting, constructing. and operating a facility or facilities to meet its 

obligations under the Act, DOE prepared the Mercury Storage EIS in accordance with the 

National Enviromnental.Policy Act and its implementing regulations (40 CFR Parts 

1500-1508 and 10 CFR Part 1021) and issued the Mercury Storage Final EIS in January 

2011. The Mercury Storage EIS evaluated seven candidate locations for the elemental 

mercury storage facility, as well as the No Action Alternative. Since publication of the 

Final Mercury Stomge EIS, DOE has reconsidered the range of reasonable alternatives 

evaluated in that EIS. Accordingly, DOE now proposes to evaluate two additional 

locations for a lorig-term mercury storage facility, both near the Waste Isolation Pilot 

Plant (WIPP), which DOE operates for disposal of defense transuranic waste. 

This Supplement to the Mercury Storage EIS will analyze the potential enviromnental, 

human beaJtb, and socioeconomic impacts of elemental mercury storage at two locations 

near WIPP. One of the additional locations to be evaluated is in Section 20, Township 22 

South, Range 31 East within the land subject to the WIPP Land Withdrawal Act (Act) 

(p.L. No. 102-579) as amended, across the WIPP access road from the WIPP facility. The 

second is in the vicinity ofWIPP, but outside of the lands withdrawn by the Act, in 

Section 10, Township 22 South, Range 31 East, approximately 3 miles north of the WIPP 

facility (see enclosed map). Mercury stomge at either location would require the . 

construction ofa new facility occupying approximately 3.1 hectares (7.7 acres). 

® Printed will! ",y in!: On =y~lod plIpt'T 

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

I–2 
 

In support of the preparation of this Supplement to the Mercury Storage EIS, DOE is 

requesting information on listed or sensitive species and critical habitat, if present, that 

may be affected by the proposed project. 

Please send the requested information to: 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 2612 

Germantown, Maryland 20874 

(301) 903-6500 

Sincerely, 

David Levenstein 

EIS Document Manager 

Enclosures: I. Notice of In/ent to Prepare a Supplemental Environmental Impact 

Statement for the Long-Term Management and Storage of Elemental 

Mercury (77 FR 33204). 

2. Map indicating potential mercury storage locations. 

2 

Responses to Consultation Requests 

I–3 
33204 Federal Register /Vol. 77, No. lOa /Tuesday, June 5, 20l2/Notices 

20202. Email: equitycommission@ed, 

gOY. Telephone: (202) 453- 6567. 

John DiPaolo, 

Chi8fof Staff, Assistant S8cretary for GivJl 

Rights. OffJCfJ !orCjvif Rights. 

!FR Doc. 2012-13499 Filed 6-4-12: 8:45 omJ 

BILLING CODE 4000~1-P 

DEPARTMENT OF ENERGY 

Notice of Intent To Prepare a Supplemental Environmental Impact 

Statement for the Long-Term Management and Storage 01 Elemental 

Mercury 

AGENCY: DeplU'tment of Energy. 

ACTION: Notice of intent. 

SUMMARY: As required by the Mercury 

Export Ban Act of 2008 (the Act), the 

Department of Energy (DOE) plans to 

identify a facility or facilities for the 

long-term management and storage of 

elemental mercury generated in the 

United States. To this end, DOE intends 

to prepare a supplement to the January 

2011 Environmental lmpact Statement 

for the Long- Term Management and 

Storage of Elemental MeI:Cury to analyze 

additional alternatives, in accordance 

with the National Bnvironmental Policy 

Act (NEPA). This supplemental EIS 

(SEIS) will evaluate alternatives for a 

fa cility at and in the vicinity of the 

Waste Isolation Pilot Plant (WlPPl near 

Carlsbad. New Mexico. 

DATES: DOE invites public comment on 

the scope of this SEIS until July 5,2012, 

The first scoping meeting will be held 

on June 26, 2012, from 5:30 p.m.-B PJm., 

at the Skeen-Whitlock Building . 

auditorium at the U,S. DOE, Carlsbad 

Field Office, 402] National Parks 

Highway. Carlsbad, New Mexico 88220. 

An open house will be held on the 'Same 

day at the same location from 4:30 p.m.-

5:30 p.m. A second scoping meeting 

will be held on June Z8, 2012 , from 6 

p.m.-8:30 p .. m, at the Crowne Plaza 

Albuquerque, 1901 University Blvd. 

NE.. Albuquerque, New Mexico 8710Z. 

An open house will be held on the same 

day at the same location from 4:30 p.m.-

6 p.m. 

ADDRESSES: 

scope of the SETS should be sent to; Mr. 

David Levenstein, Document Manager, 

Office of Environmental Compliance 

(EM-ll), U.S. Department of Energy, 

Post Office Box 261Z, Germantown, 

Maryland 20874; to the ·Mercury Storage 

EIS Web site at hHp:// 

mercul}'storogeeis.com/,· or via email to 

David.Levensteil1@em.doe.gov. 

This Notice will be available on the 

Internet at http://www.energy,gov/ 

NEPAl and on the project Web site at 

h Up:/ Imercurystorageei s. com/. 

FOR FUAlliER INFORMATION CONTACT: To 

request further information about the . 

SEIS or the Mercury Storage BIS, or to 

be placed on the SEIS distribution list, 

use any aftha methods (mail. Web site. 

or email) listed under ADDRESSES above, 

In requesting a copy of the Draft SEIS, 

please specify a request for a paper copy 

of the Summary only; a paper copy of 

the full SEIS; the full SEIS on a computer CD; or any combination 

thereof. 

I f ' 

For genera in ormahon concerning DOE's NEPA process, please1contact: 

Ms. Carol M. Borgstrom, Director, Office 

of NEP A Policy and Compliance (GC54}, U.S, Department of Energy, 1000 

Independence Avenue SW., 

Washington, DC 20585, either by 

telephone at (202) 586-4600, by fax at 

(Z02) 586-7031, or leave a message at 1-

800-47Z-Z756, 

. 

SUPPLEMENTARY INFORMATJON: 

Baokground . 

The Mercury Export Ban Act of 2008 

(Pub. L, I1D-414) amends the Toxic 

Substances Control Act (TSCA] (15 

U.S.C. ·Z605(f]) to proh ibit the sale, 

distribution, or transfer by Federal 

agencies to any other Federal agency, 

any stale or local government agency, or 

any private individual or entity, ·of any 

elemental mercury under the control or 

jurisdiction of a Federal agency (with 

certain limited exceptions). It'also 

amends TSCA (]S U.S.C, 2611(c)) to 

prohibit the export of elemental 

mercury from the U.S. effective January 

],2013 (subject to certain essential use 

exemptions). Section 5 ofthe Act, Long~ 

Term Storage, directs DOE to designate 

a facility or facilities for the long-term 

management and storago of elemental 

mercury generated within the U,S. 

Pursuant to this law. this facility is 

required to be operational and ready to 

accept custody of any elemental 

mercury generated within the U,S. by 

January 1, 2013. The Act also requires 

DOE to assess fees based up on the pro 

rata costs of long~term management and 

storage of elemental mercury delivered 

. to the facility or facilities, 

The sources of elemental mercury in 

the U.S, include mercury used in the 

chlorine and caustic soda 

manufacturing process (i.e" chlor-alkali 

industry), "reclaimed from recycling and 

waste recovery activities, and generated 

3$ a byproduct of the gold mining 

process. In addition, OOE's National 

Nuclear Security Administration stores 

approximately 1,200 metric tons of 

elemental mercury at the Oak Ridge 

Reservation in Tennessee. 

Written comments on the 

To evaluate the range of reasonable 

alternatives for siting, constructing and 

operating a facility or facilities to meet 

its obligations under the Act, DOE 

prepared the Mercury Storage EIS (DOE/ 

EI5-0423) in accordance with NEPA 

and its implementing regulations (40 

CFR parts 1500-1508 and 10 CFR part 

1021) and issued the Mercury Storage 

Final EIS ill January 2011 (76 FR 5156). 

DOE estimated that up to approximately 

10,000 metric tons of elemental mercury 

would need to be managed and stored 

at the DOE facility during the 40-year 

period of analysis. These estimates do 

not include approximately 4,400 metric 

tons of elemental mercury that the 

Department of Defense (DOD) stores at 

its facility in Hawthorne, Nevada. 

Purpose and Need for Action 

As indicated in the Mercury Storage 

£IS, DOE needs to designate a facUity 

for the long-tenn management and 

storage of elemental mercury generated 

within the I!.S. , as required by the Act. 

Proposed Action 

As also indicated in the Mercury 

Storage EIS, DOE proposes to construct 

one or more new facilities andlor select 

one or more existing fa cUities (including 

modification as needed) for the longterm management and storage of 

elemental mercury in accordance with 

the Act Facilities to be constructed as 

well as existing or modified facilities 

must comply with applit;:able 

requirements of section Sed) of the Act, 

.Management Standards for a Facility, 

including the requirements of the SaUd 

Waste Disposal Act as amended by the 

Resource ConserVation and Recovery 

Act (42 U.S.C. 6901 et seq.), and other 

permitting requirements. 

Proposed Alternatives 

The Mercury Storage EIS evaluated 

seven candidate locations for the 

elemental mercury storage fa cility, as 

wen as the No Action Alternative. 

Those candidate locations are: DOE 

Grand Junction Disposal site near Grand 

Junction, Colorado; DOE Hanford site 

near Richland, Washington; Hawthorne 

Army Depot near Hawthorne, Nevada; 

DOE Idaho National Laboratory ncar 

Idaho Falls, Idaho; DOE Kansas City 

Plant in Kansas City, Missouri; DOE 

Savannah River Site near Aiken, South 

Carolina; and Waste Control SpeCialists, 

LLC, site near Andrews: Texas, 

Since publication of the Final 

Mercury Storage EIS, DOE has 

reconsidered the range of reasonable 

alternatives evaluated In that EIS. 

Accordingly, DOE now proposes to 

evaluate two additional locations for a 

long-term mercury storage facility, both 

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

I–4 
 

Federal Register/Vol. 77, No. lOB /Tuesday, lune 5, 2012/Notices 33205 

near the Waste Isolation Pilot Plant 

(WIPP), which DOE operates for 

disposal of defense transuranic waste. 

One of the additional locations to be 

evaluated is in Section 20, To"wnship 22 

South, Range 31 East within the land 

subject to the WiPP Land Withdrawal 

Act (Pub. L.102-579) as amended (Act), 

across the WIPP access road from the 

WIPP facility. The second is in the 

vicinity of WlPP, but outside of the 

lands withdrawn by the Act, in Section 

10. Township 22 South, Range 31 East, 

approximately 31fz miles north or the 

WIPP facility. Through development of 

the SEIS, DOE will evaluate the 

cumulative impacts of constructing and 

operating a facility for long.tenn 

management and storage of e lemental 

mercury with the ongoing and ylanned 

operations of WIPP for disposa of 

defense transuranic waste, as well 8S the 

potentia1 disposal of greater-than-Class 

C waste (Droft Environmental Impact 

Statement for the Disposal of GreaterThan-Class C (GTCC) Low-level 

Radioactive Waste and GrCC-Uke 

Waste (GTCC EIS, DOEIEIS-0375, 

February 201 1). rhe locations to be 

evaluated in the SETS would be suitable 

for an above-ground storage facility. 

Identification of Environmental Issues 

DOE proposes to analyze the potential 

environmental impacts of the two 

additional alternatives for management 

and storage of elemental mercury as 

they apply to the following: 

• Land use ond visual resources. • Geology, soils. and geologic 

hazards, including seismicity. 

• Water resources (surface water and 

groundwater). 

• Meteorology. air quality and noise. 

• Ecological resources (terrestrial resources. wetlands and aquatic 

resources, Ilnd species that are Federal-­

or state-listed as threatened, 

endangered, or of special concern). 

• Cultural and paleontological 

resources such as prehistoric, historic, 

or Native American sites. 

• Site infrastructure. • Waste management. . • Occupational and public health and 

safety. including from construction, 

operations, facility accidents, 

transportation, and intentional 

destructive acts. 

• Ecological risk. • Socioeconomic impacts on 

potentially affected communities. 

• Environmental Justice (i.e., whether 

long-term mercury management and 

storage activities have a 

disproportionately high and adverse 

effect on minority and low· lncome 

populations). 

• Facility closure. 

• Cumulative impacts, including 

global commons. cumulative impacts, 

i.e., ozone depletion and climate 

change. 

• Potential mitigation measures. 

• Unavoidable adverse environmental

impacts. 

• Irreversible and irretrievable 

commitments of resources. 

• Relationship between short-term 

uses of the environment and 

maintenance and enhancement of longterm productivity. 

Public Participation in the SEIS Process 

NEPA implementing regulations 

require an early and open process for 

determining the scope of an EIS (or 

SEIS) and for identifying the significant 

issues related to the proposed action. To 

ensure that the full range of issues 

related to the proposed action arc 

addressed, DOE invites Federal 

agencies, state, local, and tribal 

governments, and the general public to 

comment on the scope of the SEIS, . 

including identification of reasonable 

alternatives and specific issues to be 

·addressed. DOE will hold a public 

scoping meeting in Carlsbad, New 

Mexico, on June 26. 2012, and in 

Albuquerque, New Mexico, on June 28, 

2012, as preViously described (see 

DATES). 

.Issued in Washington. DC. on May 24. 

2012. 

Mtlrk A. Gilbertson, 

Deputy Assistant S~cretary for Sit~ 

Restoration. 

'(FR Doc. 2012-1 3614 FUed 6-4-12: 8:45 ami 

BILLING CODE 8450-01-P 

DEPARTMENT OF ENERGY 

Federal Energy. Regulatory 

Commission 

Combined Notice of Filings 

Mey 30, 2012. 

Take notice that the Commission has 

received the following Natural Gas 

Pipeline Rate and Refund Report filings: 

Filinga instituting Proceedings 

Docket Numbers:RP12-754-000. 

Applicants: Arkansas Electric 

Coope.rative Corp., Hot Spring Power 

Company, LLC. 

Description: Petition for Waiver of Gas 

Regulations of Arkansas Electric 

Cooperative Corporation and Hot Spring 

Power Company, LLC in RP12-754, 

Filed Date: 5/25/12. 

Accession Number: 20120525-5153. 

Comments Due: 5 p.m. ET 6/6/12. 

Docket Numbers: RPl2-755-000. 

Applicants: MarkWest Pioneer, LLC. 

Description: MarkWest PioneerQuarterly FRP Filing to be effective 71 

1/ 2012. Filed Dote: 5/29/12. 

Accession Number: 20120529-5201. 

Comments Due: 5 p.m. ET 6/11/12. 

Any person desiring to intervene or 

protest in any of the above proceedings 

must file in accordance with Rules 211 

and 214 of the Commission's 

Regulations (18 eFR 385,211 and 

385.214) on or before 5:00 p .m. Eastern 

time on the' specified comment date. 

Protests may be considered, but 

intervention is necessary to become a 

party to the proceeding. 

Filings in Exisling Proceedings 

Docket Numbers: CPID-l£:HlOl. 

Applicants: Cadeville Gas Storage 

LLC. 

Description: Abbreviated amendment 

ofCadeville Gas Storage LLC under 

CPlO-16. 

Filed Date: 5/15/12. 

Accession Number: 20120515-5240. 

Comments Due: 5 p.m. ET 6/4/12. 

Any person desiring to protest in any 

the above proceedings must file in 

accordance with Rule 211 of the 

Commission's Regulations (18 ern 

385.211) on or before 5:00 p,m. Eastern 

time on the specified comment date. 

The filings are accessible in the 

Commission's eLibrary system by 

clicking on the links or querying the 

docket number, 

eFiling is encouraged. More detailed 

information relating to filing 

requIrements. interventions, protests, 

and service can be found at: http://www. 

ferc.govldocs-filingtefilinglfili1l$·req. 

pdf For other information. call (866) 

208-3676 (toll free). For TTY. call (202) 

502-8659. 

Nathaniel J. Davis, Sr., 

Deputy Secretary. 

(FR Doc. 2012-13552 Fi.led 6-4--12: 8:45 am) 

BILLING CODE 6717-o1- P 

DEPARTMENT OF ENERGY 

Federal Energy Regulatory 

Commission 

Combined Notice of Filings 

Take notice that the Commission has 

received the following Natural Gas 

Pipeline Rate and Refund Report filings: 

Filings In.~tituting Proceedings 

Docket Numbers: RP12-74S-000. 

Applicants: Algonquin Gas 

Transmission. LLC. 

Description: ACT Negotiated RateTaunton 66667 to be effective 6/1/2012. 

Filed Date: 5/24/12. 

Responses to Consultation Requests 

I–5 
r

-- - ,-- • :';1."", Long-Term Management and Storage 

of Elemental Mercury Supplemental Environmental 

Impact Statement (Mercury Storage SEIS) 

- ~ . , , 

. _J "t: / ,-

DOE's goal is to 

provide safe, secure, long-term 

mercury storage. 

AdditionaJ Cal1didate Mercury storage Sites 

to be Analyzed in a Supplemental S 

Since publication of the Final Mercury Storage EIS in January 2011, the U_S, Department 

of Energy (DOE) has reconsidered the range of reasonable alternatives evaluated in that 

EIS_ Accordingly, DOE now proposes to evaluate two additional locations for a long-term 

mercury storage facility, both near the Waste Isolation Pilot Plant (WIPP), which is located 

apprOximately 26 miles southeast of Cartsbad, New Mexico_ 

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.. =~ Ie ~ 2 • 

o EVlluated G, ... te,-Than-Clas..-C low LcowI r---- ..... ..... W~n.locatIonJ 

(T<>WMhIp llSouth,RoWl!)t 31 East, 2S 3J; " 28 27 2. 5f.cr:1on27 or 35) 2' 

.... 35 36 //31 32 33 'Y 35 ~ 36 

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

I–6 
 

Department of Energy 

Was hington, DC 20585 

JAN 152013 

Mr. Wally Murphy, Field Supervisor 

U.S. Fish and Wildlife Service 

New Mexico Ecological Services Office 

2 105 Osuna NE 

Albuquerque, New Mexico 87 113 

Dear Mr. Murphy: 

The purpose of this letter is to amend the U.S. Department of Energy's (DOE's) previous notification to you 

on August 24, 20 12, regarding the Supplement to the Environmental Impact Statement for the Long-Term 

Management and Storage of Elemental Mercury. In August, DOE informed you of its intent to develop the 

supplemental environmental impact statement (SElS) to evaluate two locations in the vicinity of the Waste 

Isolation Pilot Plant (WIPP): Sections 10 and 20, Township 22 South, Range 31 East. DOE received a 

response on January 10,20 13. 

However, as a resu lt of comments recei ved duri ng the SEIS scoping process, DOE has decided to evaluate a 

third location, also in the vicinity of WIPP. The Hdditional location is in Section 35, within the srlmc 

township and fringe as Sections 10 and 20 and outside of the lands withdrawn by the WIPP Land 

Withdrawal Act (P.L. No. 102-579), as amended. Section 35 is approximately 3.5 miles soulheast of the 

WfPP facility (see encloscd map). Construction and operation ofa long-term mercury storage fac ility wou ld 

be the same as described in the Augusl 241h correspondence, occupying approximately 3. 1 hectares (7.7 

acres). 

In support of the preparation of the Supplemcnt to the Mercury Storage EIS, DOE is requesting a review to 

dctennine if there is any additional information regarding listed or sensitive species and critical habitat 

specifi c 10 Section 3S that shou ld be considcred in our ana lyses or if the response received on January 10'h 

would apply equally to Section 35 as it docs for Sections 10 and 20. 

Please send the requested information to: 

Mr. David Lcvenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 26 12 

Germantown, Maryland 20874 

(30 I) 903-6500 

Sincerely. 

~vkd-- EIS Document Managcr 

Enclosures: I. lvlap indicating pote ntial me rcury storage locations. 

, @ Prinlod wilh soy ink on fOCyciod paper ... 

Responses to Consultation Requests 

I–7 
N 

w () ( 

moy co LEA (0 

2 6 5 4 3 2 

11 12 7 11 

14 13 18 14 

• Candidate Mercury Storage Locations 

(Township 22 South. Range 31 East. 24 23 Sections 10.20, or 35) 

26 25 27 26 

35 36 33 34 

2 4 3 

11 9 10 11 

Candidate Locations Evaluated in the 

Long-Term Managemen t and Storage of Elemental Mercury 

Supplemental Environmental Impact Statement 

J: 

12 

24 

25 

36 

12 

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

I–8 
 

• 

I.1.2 Response from the New Mexico Ecological Services Office 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

New Mexico Ecological Services Field Office 

2105 Osuna NE 

Albuquerque, New Mexico 87113 

Phone: (505) 346-2525 Fax: (505) 346-2542 

Thank you for your recent request for information on threatened or endangered species or 

important wildlife habitats that may occur in your project area. The New Mexico Ecological 

Services Field Office has posted lists of the endangered, threatened, proposed, candidate and 

species of concern occurring in all New Mexico Counties on the Internet Please refer to the 

following web page for species information in the county where your project occurs: 

http;//www.fws.gov/southwestleslNewMexico/SBC_intro.cfm. If you do not have access to the 

Internet or have difficulty obtaining a list, please contact our office and we will mail or fax you a 

list as soon as possible. 

After opening the web page, find New Mexico Listed and Sensitive Species Lists on the main 

page and click on the county of interest. Your project area may not necessarily include all or any 

of these species. This infonnation should assist you in determining which species mayor may 

not occur within your project area. 

Under the Endangered Species Act of 1973, as amended (Act), it is the responsibility of the 

Federal action agency or its designated representative to determine if a proposed action "may 

affect" endangered, threatened, or proposed species, or designated critical habitat, and if so, to 

consult with us further. Similarly, it is their responsibility to determine if a proposed action has 

no effect to endangered, threatened, or proposed species, or designated critical habitat. On 

December 16, 2008, we published a final rule concerning clarifications to section 7 consultations 

under the Act (73 FR 76272). One of the clarifications is that section 7 consultation is not 

required in fuose instances when the direct and indirect effects of an action pose no effect to 

listed species or critical habitat. As a result, we do not provide concurrence with project 

proponent's "no effect" detenninations. 

If your action area has suitable habitat for any of these species, we recommend that speciesspecific surveys be conducted during the flowering season for plants and at the appropriate time 

for wildlife to evaluate any possible project-related impacts. Please keep in mind that the scope 

of federally listed species compliance also includes any interrelated or interdependent project 

activities (e.g., equipment staging areas, off site borrow material areas, or utility relocations) and 

any indirect or cumulative effects. 

Responses to Consultation Requests 

I–9 
2 

Candidates and species of concern have no legal protection under the Act and are included on the 

web site for planning purposes only. We monitor the status of these species. If significant 

declines are detected, these species could potentially be listed as endangered or threatened. 

Therefore, actions that may contribute to their decline should be avoided. We recommend that 

candidates and species of concern be included in your surveys. 

Also on \he web site, we have included additional wildlife-related information that should be 

considered if your project is a specific type. These include communication towers, power line 

safety for raptors, road and highway improvements andlor construction, spring developments and 

livestock watering facilities, wastewater facilities, and trenching operations. 

Under Executive Orders 11988 and 11990, Federal agencies are required to minimize the 

destruction, loss, or degradation of wetlands and floodplains, and preserve and enhance their 

natural and beneficial values. We recommend you contact the U.S. Army Corps of Engineers for 

permitting requirements under section 404 oftbe Clean Water Act if your proposed action could 

impact floodplains or wetlands. These habitats should be conserved through avoidance, or 

mitigated to ensure no net loss of wetlands function and value. 

The Migratory Bird Treaty Act (MBTA) prohibits the taking of migratory birds, nests, and eggs, 

except as permitted by the U.S. Fish and Wildlife Service. To minimize the likelihood of 

adverse impacts to all birds protected under the MBTA, we recommend construction activities 

occur outside the general migratory bird nesting season of March through August, or that areas 

proposed for construction during the nesting season be surveyed, and when occupied, avoided 

until nesting is complete. 

We suggest you contact the New Mexico Department of Game and Fish, and the New Mexico 

Energy, Minerals, and Natural Resources Department, Forestry Division for information 

regarding fish, wildlife, and plants of State concern. 

Thank you for your concern for endangered and threatened species and New Mexico's wildlife 

habitats. We appreciate your efforts to identity and avoid impacts to listed and sensitive species 

in your project area. 

Sincerely, 

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

I–10 
 

ouf/L 

Department of Energy 

Washington, DC 20585 

AlE 24 2011 

RECEIVED 

IIUG 3 0 ZOIZ 

USFWS-NMESFO 

Mr. Wally Murphy, Field Supervisor 

U.S. Fish and Wildlife Service 

New Mexico Ecological Services Office 

2105 Osuna NE 

Albuquerque, New Mexico 87113 

Dear Mr. Murphy: 

, 

'The purpose of this letter is to notify you that the Department of Energy (DOE) is 

preparing a Supplement to the Environmental Impact Statement (EIS) for the Long-Term 

Management and Storage of Elemental Mercury (see enclosed Notice of Intent). 

Pursuant to the Mercury Export Ban Act of2008 (P.L. 110-414), DOE has been directed 

to designate a facility or facilities for the long-term management and storage of c1emental 

mercury generated within the United States. DOE is analyzing the storage of up to 

10,000 metric tons (11,000 tons) of c1emental mercury in a facility or facilities 

constructed and operated in accordance with the Solid Waste Disposal Act, as amended 

by the Resource Conservation and Recovery Act. To evaluate the range of reasonable 

alternatives for siting, constructing, and operating a facility or facilities to meet its .. 

obligations under the Act, DOE prepared the Mercury Storage EIS in accordancc with the 

National Environmental Policy Act and its implementing regulations (40 CFR Parts 

1500-1508 and 10 CFR Part 1021) and issued the Mercury Storage Final EIS in January 

2011. The Mercury Storage EIS evaluated seven candidate locations for the elemental 

mercury storage facility, as well as the No Action Alternative. Since publication of the 

Final Mercury Storage EIS, DOE has reconsidered the range of reasonable alterna(jlies 

evaluated in that EIS. Accordingly, DOE now proposes to evaluate two additional 

locations for a long-term mercury storage facility, both near the Waste Isolation Pilot 

Plant (WIPP), which DOE operates for disposal of defense transuranic waste. 

This Supplement to the Mercury Srorage EIS will analyze the potential environmental, 

human health, and socioeconomic impacts of elemental mercury storage at two locations 

ncar WIPP. One of the additional locations to be evaluated is in Section 20, Township 22 

South, Range 31 East within the land subject to the W[PP Land Withdrawal Act (Act) 

(P.L. No. 102-579) as amended, across the WIPP access road from the WIPP facility. The 

second is in the vicinity ofW[PP, but outside of the lands withdrawn by the Act, in 

Section 10, Township 22 South, Range 31 East, approximately 3 miles north oflhe WIPP 

facility (see enclosed map). Mercury storage at either location would require the 

construction of a new facility occupying approximately 3.1 hectares (7.7 acres). 

Responses to Consultation Requests 

I–11 
I,n support of the preparation of this Supplement to the Mercury Storage EIS, DOE is 

requesting information on listed or sensitive species and critical habitat, if present, that 

may be affected by the proposed project. 

Please send the requested information to: 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 2612 

Germantown, Maryland 20874 

(301) 903-6500 

'Vlun-<- S~;.. speW­

~~-fc 

-t~ e.tJ..~. 

~N.~ 

.-f.o fYY'<-. -

Sincerely, 

David Levenstein 

EIS Document Manager 

Enclosures: 1. Nolice olInlen/ to Prepare a Supplemental Environmental Impact 

Statement Jar the Long-Term Management and Storage olElemental 

Mercury (77 FR 33204). 

2. Map indicating potential mercury storage locations. 

2 

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

I–12 
 

* f>rinted with lOY ink OIl reeycled pllpe, 

Responses to Consultation Requests 

I.2	 CORRESPONDENCE WITH THE NEW MEXICO DEPARTMENT OF GAME 

AND FISH 

I.2.1	 U.S. Department of Energy’s Correspondence to the New Mexico Department 

of Game and Fish 

I–13 

Department of Energy 

Washlng,on, DC 20585 

AUG 24 2orz ' 

Mr. Matthew Wunder, Division Chief 

Conservation Services 

New Mexico Department of Game and Fish 

P.O. Box 25112 

Santa Fe, New Mexico 87504 

Dear Mr. Wunder: 

The purpose of this letter is to notify you that the Department of Energy (DOE) is 

preparing a Supplement to the Environmental Impact Statement (EIS) for the Long-Tern) 

Management and Storage of Elemental Mercury (see enclosed Notice ofIntent). 

Pursuant to the Mercury Export Ban Act of2008 (PL. 110-414), DOE has been directed 

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

mercury generated within the United States. DOE is analyzing the storage of up to 

10,000 metric tons ( 11 ,000 tons) of elcmental mercury in·a facility or facilities 

constructed and operated in accordance with the Solid Waste Disposal Act, as amended 

by the Resource Conservation and Recovery Act. To evaluate the range of reasonable 

alternatives for siting, constructing, and operating a facility or facilities to meet its 

obligations under the Act, DOE prepared the Mercury Storage EIS in accordance with the 

National Environmental Policy Act and its implementing regulations ( 40 CFR Parts 

1500-1508 and 10 CFR Part 1021) and jssued the Mercury Storage Final EIS in January 

2011. The Mercury Storage EIS evaluated seven candidate locations for the elemental 

mercury storage facility, as well as the No Action Alternative. Since publication of the 

Final Mercury Storage EIS, DOE has reconsidered the range of reasonable alternatives 

evaluated in that EIS. Accordingly, DOE now proposes to evaluate two additional 

locations for along-term mercury storage facility, both near the Waste Isolation Pilot 

Plant (WIPP), which DOE operates for disposal of defense transuranic waste. 

This Supplement to the Mercury Storage ElS will analyze the potential environmental, 

hwnan health, and socioeconomic impacts of elemental mercury storage at two locations 

near WIPP. One of the additional loeations to be evaluated is in Section 20, Township 22 

South, Range 31 East within the land subject to the WIPP Land Withdrawal Act (Act) 

(P.L. No. 102-579) as amended. across the WIPP access road from the WIPP facility. The 

second is in the vicinity of WIPP, but outside of the lands withdrawn by the Act, in 

Section 10, Township 22 South, Range 31 East, approximately 3 miles north of the WIPP 

facility (see enclosed map). Mercury storage at either location would require the 

construction of a new facility occupying approximately 3.1 hectares (7.7 acres). 
2 

In support of the preparation of this Supplement to the Mercury Storage EIS, DOE is 

requesting infonnation on state-listed or sensitive species, if present, that may be affected 

by the proposed project. 

Please send the requested infonnation to: 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 2612 

Gennantown, Maryland 20874 

(301) 903-6500 

Sincerely, 

David Levenstein 

EIS Document Manager 

Enclosures: 1. Notice oj Intent to Prepare a Supplemental Environmental Impact 

Stalementjor the Long-Term Management and Storage ojElemental 

Mercury (77 FR 33204). 

2. Map indicating potential mercury storage locations. 

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

I–14 
 

Department of Energy 

Washington, DC 20585 

JAN 151013 

Mr. Matthew Wunder, Division Chief 

Conservation Services 

New Mexico Department of Game and Fish 

P.O. Box25112 

Santa Fe, New Mexico 87504 

Dear Mr. Wunder: 

The purpose of this letter is to amend the U.S. Department of Energy's (DOE's) prev ious notification to you 

on August 24, 20 12, regarding the Supplement to the Environmental Impact Statement for the Long-Term 

Management and Storage of Elemental Mercury. In August, DOE in fo rmed you of its intent to develop the 

supplemental environmental impact statement (SEIS) to eva luate two locations in the vic inity of the Waste 

Isolation Pilot Plant (WIPP): Sections 10 and 20, Township 22 South, Range 3 1 East. 

However, as a result of comments received during the SEIS scoping process, DOE has decided to evaluate a 

third location, also in the vicinity of WIPP. The additional location is in Section 35. within the same 

township and range as Sections 10 and 20 and outside of the lands withd rawn by the WIPP Land 

Withdrawal Act (P.L. No. 102-579), as amended. Section 35 is approximately 3.5 miles southeast of the 

WIPP facility (see enclosed map). Construction and operation ofa long-term mercury storage facility would 

be the same as described in the August 241h correspondence, occupying approximately 3. 1 hectares (7.7 

acres). 

In support of the preparation of the Supplement to the Mercury Storage EIS, DOE is requesting that any 

information provided by your department regarding state-listed or sensitive species and critical habitat, if 

any, that may be affected by the proposed project also include Section 35, as well as Sections 10 and 20 

previously mentioned in the August 241h correspondence. 

Please send the requested informat ion to: 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 26 12 

Germantown, Maryland 20874 

(30 1) 903-6500 

Sincerely. 

David Levenstein 

EIS Document Manager 

Enclosures: I. Map indicating potential mercury storage locations. 

@ Prinled "",I" soy ink 01'1 ,0000cled paper 

Responses to Consultation Requests 

I–15 
I.2.2 Response from the New Mexico Department of Game and Fish 

GOVEP.NOR .. 

Susana Martinez 

DIRECTOR AND SECRETARY 

TO THE COMMISSION 

James S. Lane, Jr. 

Daniel E. Brooks, Deputy Director 

STATE OF NEW MEXICO 

DEPARTMENT OF GAME & FISH 

~ Wildltfe Way 

S;UlIH Fe, NM 87507 

l'oSI Office Box 2S 11 2 

~ll!a Fe. NM " SO", 

I'h<)ll~ : (SO~) 476-KOOB 

l'u. (S0 5)4J6-U 24 

Vis'l ollr website II ,,"ww ... ldlif aLc n", ~ 

For 1Ilfonrl8.ion t.lI: (UK) 24K·6166 

To order lice publi~alion 5 ull: (ROO) 1162·9) 10 

STATE GAME COMMISSION 

JIM McCLINTIC 

Chairman 

Albuquerque, NM 

THOMAS "OICK" SALOPEK 

Vice-Chairman 

Las Cruces, NM 

OR. TOM ARVAS 

Albuquerque, NM 

SCOTT BIOeGAIN 

Tucumcari, NM 

ROBERT eSPINOZA, SR. 

Farm ington, NM 

PAUL M. KIENZLE III 

Albuquerque, NM 

BILL MONTOYA 

Allo, NM 

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

I–16 

July 3, 2012 

David Levenstein, Document Manager 

Office of Environmental Compliance (EM-11) 

US Department of Energy 

P.O. Box 2612 

Germantown, MD 20874 

Long-Term Management and Storage of Elemental Mercury Supplemental Environmental 

Impact Statement Scoping; NMGF Project No.15156 

Dear Mr. Levenstein: 

In response to the Federal Register Notice of Intent dated 8 June 2012, the New Mexico Department of 

Game and Fish (Department) has reviewed information pertaining to the above referenced project. The 

Mercury Export Ban Act of 2008 requires the Department of Energy (DOE) to designate a facility for the 

long-term management and storage of elemental mercury generated within the U.S. DOE estimates a 

future need to manage and store up to 10,000 metric tons of elemental mercury during the 40-year 

period of analYSis. The project will comprise an aboveground storage and containment building with 

ancillary delivery facilities. An EIS issued in 2011 evaluated seven candidate locations in the states of 

Colorado, Washington, Nevada, Idaho, Missouri, South Carolina and Texas . This Supplemental EIS will 

evaluate two additional alternatives located at and in the vicinity of the Waste Isolation Pilot Plant, Eddy 

County, New Mexico. They are located in Sections 10 and 20, Township 22S, Range 31 E. Our 

comments pertain only to the locations in New Mexico. No site inspection was conducted by Department 

staff in connection with this consultation request. 

For your information we have enclosed a list of sensitive, threatened and endangered species occurring 

in Eddy County. For more information on listed and other species of concern, contact the following 

sources: 

1. BISON-M Species Accounts, Searches, and County lists: bison-m.org 

2. Habitat Handbook Project Guidelines: 

wildl ife. state. nm. uslconservationlhabitat handbook/index. htm 

3. For custom, site-specific database searches on plants and wildlife . Go to Data then to 

Free On-Line Data and follow the directions go to: nmnhp.unm.edu 

4. New Mexico State Forestry Division (505-827-5830) or nmrareplants.unm.edu/index.html 

for state-listed plants 

5. For the most current listing of federally listed species always check the U.S. Fish and 

Wildlife Service at (505-346-2525) or fws.gov/ifw2es/NewMexico/index.cfm. 
 

Long-Term Management and Page 2 - 2 July 3, 201 2 

Storage of Elemental Mercury 

The entire project area is within historic Lesser Prairie Chicken (LPC) habitat The proposed 

project location may intersect current occupied habitat in Section 10. The Southern Great Plains 

Critical Habitat Assessment Tool classifies LPC habitat in the project area as "significant " The 

Department recommends avoiding impacts to suitable LPC habitat. For more information, 

please contact Grant Beauprez, Department LPC biologist at 575-478-2460 or 

grant.beauprez@state.nm.us. 

The project area likely includes suitable habitat for Burrowing Owls. Please follow the survey 

and mitigation procedures recommended in the Department Habitat Handbook Burrowing Owl 

guideline, available at wildlife.state.nm.us/conservation/habitat handbook/index.htm. 

Ephemerally wet, low lying portions of the project area may support leopard frogs and other 

amphibians. The Department recommends avoiding construction in or disturbance of hydrologic

balance affecting ephemeral wet areas. No probable playa lakes are mapped by the Playa 

Lakes Joint Venture in the proposed project area. 

Thank you for the opportunity to comment on this Supplemental EIS. We look forward to the 

opportunity to review a Draft EIS for this project. If there are any questions, please contact 

Rachel Jankowitz, Mining Habitat Specialist at 505-476-8159 or rjankowitz@state.nm. us. 

Matt Wunder, Ph.D. 

Chief, Conservation Services Division 

MW/rj 

Encl: 1 

xc: USFWS NMES Field Office 

Leon Redman, SE Area Operations Chief, NMDGF 

George Farmer, SE Area Habitat Specialist, NMDGF 

Grant Beauprez, Lesser Prairie Chicken Biologist, NMDGF 

Responses to Consultation Requests 

I–17 
NEW MEXICO WILDLIFE OF CONCERN 

EDDY COUNTY 

For complete up-dated information on fedoral·listed species, Including plants, see the US Fish & Wildlife Service NM Ecological 

Services Field Office website at http://www.fws.gov/soulhwesUes/NewMoxicoISBC.cfm. For Information on state·llsted plants, 

contact the NM Energy, Minorals and Natural Resources Department, Division of Forestry, or go to http://nmrareplants.unm.edu/. 

If your prOject is on Bureau of Land Management. contact tho local BlM Field Office for Information on species of particu lar 

concern. If your project Is on a National Forest, contact the Forest Supervisor's offico for species Information. E:: Endangered; 

T = Threatened; s :: sensitive; SOC:: Species of Concern; C :: Candidate; Exp = Experimental non.ossenlial population; P = Proposed 

critical 

Common Name Scientific Name NMGF USFWS habitat 

Mexican Tetra Astyanax mexican us T 

Rio Grande Chub Gila pandora s 

Rio Grande Shiner Norropis jemezanus s SOC 

Pecos Bluntnose Shiner Notropis simus pecosensis E T Y 

Blue Sucker Cycleptus elongatus E SOC 

Gray Redhorse Moxostoma congestum T SOC 

Headwater Catfish Ictalurus lupus s SOC 

Pecos Pupfish Cyprinodon pecosensis T SOC 

Pecos Gambusia Gambusia nobilis E E 

Greenthroal Darter Etheostoma lepidum T SOC 

Bigscale Logperch Percina macrolepida (Native pop.) T 

Western River Cooter Pseudemys gorzugi T 

Sand Dune lizard Sceloporus arenicolus E P 

Gray·banded Kingsnake Lampropeltis alterna E 

Blotched Water Snake Nerodia erythrogaster transversa E 

Arid Land Ribbon Snake Thamnophis proximus diabolicus T 

Motlled Rock Rattlesnake Crotalus lepidus lepidus T 

Brown Pelican Pelecanus occidentalis E 

Neotropic Cormorant Phalacrocorax brasilianus T 

Bald Eagle Haliaeetus leucocephalus T 

Northern Goshawk Accipiter genlilis s SOC 

Common Black·Hawk Buleogallus anthracinus T SOC 

Aplomado Falcon Falco femoralis E Exp 

Peregrine Falcon Falco peregrinus T SOC 

lesser Prairie·Chicken Tympanuchus pallidicinctus s C 

Piping Plover Charadrius melodus circumcinctus T T 

Mountain Plover C haradrius montanus s SOC 

Least Tern Sterna antillarum E E 

Black Tern Chlidonias niger surinamensis SOC 

Common Ground-Dove Columbina passerina E 

Yellow-billed Cuckoo Coccyzus americanus s SOC 

Mexican Spotted Owl Strix occidentalis lucid a s T Y 

Burrowing Owl Alhene cunicularia SOC 

Broad-billed Hummingbird Cynanthus latirostris T 

Lucifer Hummingbird Calothorax lUCifer T 

Northern Beardless-Tyrannulet Camptostoma imberbe E 

Southwestern Willow Flycatcher Empidonax traillii extimus E E Y 

Thick·billed Kingbird Tyrannus crassirostris E 

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

I–18 
 

NEW MEXICO WILDLIFE OF CONCERN 

EDDY COUNTY 

For complete up-dated Information on federal-listed species, Including plants, see the US Fish & Wildlife Service NM Ecological 

Services Field Office website at http://www,fws.govfsouthwestlesfNewMexico/SBC.cfm. For information on state-listed plants, 

contact the NM Energy, Minerals and Natural Resources Department, Division of Forestry, or go to http://nmrareplants.unm.edul, 

If your project is on Bureau of Land Management, contact the local BlM Field Office for information on species of particular 

concern. If your project Is on a National Forest, contact the Forest Supervisor's office for species information. E '" Endangered; 

T '" Threatened; s = sensitive; SOC:: Species of Concern ; C = Candidate; Exp '" Experimental non-essential population; P '" 

Proposed 

critical 

Common Name Scientific Name NMGF USFWS habitat 

Loggerhead Shrike Lanius ludovicianus s 

Bell's Vireo Vireo bellii T SOC 

Gray Vireo Vireo vicinior T 

Baird's Sparrow Ammodramus bairdii T SOC 

Sprague's Pipit Anthus spragueii C 

Varied Bunting Passerina versicolor T 

Western Small-footed Myotis Bat Myotis ciJiolabrum melanorhinus s 

Yuma Myotis Bat Myotis yumanensis yumanensis s 

Cave Myotis Bat Myotis velifer s 

Long-legged Myolis Bal Myotis volans interior s 

Fringed Myotis Bat Myotis thysanodes thysanodes s 

Eastern Red Bat Lasiurus borealis s 

Pale Townsend's Big-eared Bat Corynorhinus townsendii pallescens s SOC 

Big Free-tailed Bat Nyctinomops macrotis s Black-tailed Prairie Dog Gynomys ludovicianus ludovicianus s SOC 

Guadalupe Pocket Gopher Thomomys bottae guadalupensis s SOC 

Nelson's Pocket Mouse Chaetodipus nelson; canescens s Pecos River Muskrat Ondatra zibethicus ripensis s SOC 

Swift Fox Vulpes velox velox s SOC 

Ringtail Bassariscus astutus s Western Spotted Skunk Spilogale gracilis s 

Common Hog-nosed Skunk C onepatus leuconotus s Texas Hornshell Popenaias popei; E C 

Pecos Springsnail Pyrgulopsis pecosensis T SOC 

Ovate Vertigo Snail Vertigo ovata T SOC 

Desert Viceroy Butterfly Limenitis archippus obsoleta SOC 

Responses to Consultation Requests 

I–19 
GOVERNOR 

Susana Martinez ST ATE OF NEW MEXICO 

DEPARTMENT OF GAME & FISH 

One Wildlire Way 

Santa Fe, NM S7S07 

Po .. Offi co 110"' H I 12 

5.",. Ft. NM 17SG4 

PhD"., (SO~) 476·BOOI 

Fu: (SOS) 476·I IH 

V"i1 our W.~,;1t.1 w ...... wildlir.. .. " •. nm. " $ 

For i"ronna<;on cI11. (138) HI·68M 

1'0 orde' fret po,bhc.,;"n< col i: (BOO) !62·9l10 

STATE GAME COMMISSION 

JIM M<;CLlNTIC 

Chairman 

Albuquerque, NM 

THOMAS ~ICK" SALOPEK 

Vica-Ch.lrmln 

LI'CN<;H, NM 

DR. TOM ARVAS 

Albuq uerque, NM 

SCOTT BIOEGAIN 

Tu<;um<;lrI, NM 

ROBERT ESPINOZA, SR. 

Farmington, NM 

PAUL M. KIENZLE III 

Albuquerque, NM 

BILL MONTOYA 

Alto, NM 

DIRECTOR AND SECRETARY 

TO THE COMMISSION 

James S. Lane, Jr, 

Daniel E, Brooks, Deputy Director 

February 5, 2013 

David Levenstein, Document Manager 

Office of Environmental Compliance (EM-11) 

US Dept. of Energy 

P.O. Sox 2612 

Germantown MD 20874 

Long-Term Management and Storage of Elemental Mercury Supplemental Environmental 

Impacf Statement Scoping; NMOGF Project No. 15434 

Dear Mr. Levenstein : 

In response to your letter dated January 15, 2013, the New Mexico Department of Game and Fish 

(Department) has reviewed information pertaining to the above referenced project. The Mercury Export 

San Act of 2008 requires the Department of Energy (DOE) to deSignate a facility for the long-term 

management and storage of elemental mercury generated within the US. The DOE estimates there will 

be a need to manage and store up to 10,000 metric tons of elemental mercury during the 40-year 

period of analysis. The project will comprise an aboveground storage/containment building with 

ancillary delivery facilities. An EIS issued in 201 1 evaluated seven candidate locations in the states of 

Colorado, Washington, Nevada, Idaho, Missouri, South Carolina and Texas. We previously responded 

to your request for information regarding two additional alternatives located at and in the vicinity of the 

Waste Isolation Pilot Plant (WIPP), Eddy County, New Mexico (NMDGF Project No. 15156, dated July 

2, 2012). A third alternative in the same vicinity is currently under evaluation. It is located in Section 35, 

Township 22S, Range 31 E, approximately 3.5 miles east of the WIPP. No site inspection was 

conducted by Department staff in connection with this consultation request. 

For your information, we have enclosed a list of sensitive, threatened and endangered species that 

occur in Eddy County. Included below are sources of additional information: 

1. For Biota Information System of New Mexico (BISON-M) species accounts, 

searches, and county lists go to bison-m.org . 

2. For the Department's Habitat Handbook Project guidelines go to 

wildlife.state.nm.us/conservation/habitat handbook/index.htm. 

3. For custom, site-specific database searches on plants and wildlife go to 

nhnm.unm.edu then go to Data, Free On-Line Data, and follow the directions. 

4. For state-listed plants contact the New Mexico State Forestry Division at (505) 476-

3334) or nmrareplants.unm.edu/index.html. 

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

I–20 
 

David Levenstein Page -2- February 5, 2012 

5. For the most current listing of federally listed species always check the U.S. Fish 

and Wildlife Service at (505) 346-2525 or 

fws.qov/southwesUes/NewMexico/SBC.cfm. 

Section 35 intersects current occup ied habitat for Lesser Prairie·Chicken (LPG). The Southern 

Great Plains Critical Habitat Assessment Tool classifies LPC habitat in this Section as 

"common." The Department recommends avoiding conversion of suitable LPC habitat. For 

more information, please contact Grant Beauprez, Department LPC biologist at 575·478-2460 

or qrant.beauprez@state .nm.us. 

The project area likely includes suitable habitat for Burrowing Owls. Please follow the survey 

and mitigation procedures recommended in the Department Habitat Handbook Burrowing Owl 

guideline, available at wiJdlife.state.nm.us/conservation/habitat handbook/index.htm. 

Ephemerally wet, low lying portions of the project area may support leopard frogs and other 

amphibians. The Department recommends avoiding construction in ephemeral wet areas or 

disturbance of the hydrologic balance affecting them. No playa lakes were mapped by the 

Playa Lakes Joint Venture in the proposed project area. The project area is a year-round 

concentration zone for Harris Hawk . The selected area should be surveyed for raptor nests 

prior to construction, and human activity, including noise, should be avoided within % mile of 

an active nest. There may also be important habitat for pronghorn antelope along the eastern 

edge of the section. 

Thank you for the opportunity to comment on this Supplemental EIS. We look forward to the 

opportunity to review a Draft EIS for this project. If there are any questions, please contact 

Rachel Jankowitz, Mining Habitat Specialist at 505-476-8159 or rjankowitz@state .nm.us. 

ince ' _ ,\ 

d\j4 '.£ 

atthew Wunder, Chief 

Conservation Services Division 

cc: USFWS NMES Field Office 

George Farmer, SE Reg ional Habital Biologist, NMDGF 

Grant Beauprez, Lesser Prairie-Chicken Biologist, NMDGF 

Responses to Consultation Requests 

I–21 
Draft Long-Term Management and Storage of Elemental Mercury Supplemental Environmental Impact Statement 

I.3	 CORRESPONDENCE WITH THE NEW MEXICO ENERGY, MINERALS AND 

NATURAL RESOURCES DEPARTMENT 

I.3.1	 U.S. Department of Energy’s Correspondence to the New Mexico Energy, 

Minerals and Natural Resources Department 

I–22 

Department of Energy 

Washington, DC 20585 

AUG .2 4 201Z 

Mr. Tony Delfin, State Forester 

Forestry Division 

New Mexico Energy, Minerals and Natural ReS9urces Department 

1220 SOUtll Saint Francis Drive 

Santa Fe, New Mexico 87505 

Dear Mr. Delfin: 

The purpose of this letter is to notify you that the Department of Energy (DOE) is 

preparing a Supplement to the Environmental Impact Statement (E[S) for the Long-Term 

Management and Storage of Elemental Mercury (see enclosed Notice of [ntent). 

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

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

mercury generated within the United States. DOE is analyzing the storage of up to 

10,000 metric tons (11,000 tons) of elemental mercury in a facility or facilities 

constructed and operated in accordance with the Solid Waste Disposal Act, as amended 

by the Resource Conservation and Recovery Act. To evaluate the range of reasonable 

alte~atives for siting, constructing, and operating a facility or facilities to meet its 

obligations under the Act, DOE prepared the Mercury Storage EIS in accordance with the 

National Environmental Policy Act and its implementing regulations (40 CFR Parts 

.1500-1508 and 10 CFR Part 1021) and issued the Mercury Storage Final EIS in January 

2011. The Mercury Storage EIS evaluated seven candidate locations for the elemental 

mercury storage facility, as well as the No Action Alternative. Since publication of the 

Final Mercury Storage EIS, DOE has reconsidered the range of reasonable alternatives 

evaluated in that EIS. Accordingly, DOE now proposes to evaluate two additional 

locations for a long-term mercury storage facility, both near the Waste Isolation Pilot 

Plant (WIPP), which DOE operates for disposal of defense transuranic waste. 

This Supplement to the Mercury Storage EIS will analyze the potential environmental, 

human health, and socioeconomic impacts of elemental mercury storage at two locations 

near WIPP. One of the additional locations to be evaluated is in Section 20, Township 22 

South, Range 31 East within the land subject to the WIPP Land Withdrawal Act (Act) 

(P.L. No. 102-579) as amended, across the WIPP access road from the WIPP facility. The 

second is in the vicinity ofWIPP, but outside of the lands withdrawn by the Act, in 

Section 10, Township 22 South, Range 31 East, approximately 3 miles north of the WIPP 

facility (see enclosed map). Mercury storage at either location would require the 

. construction of a new facility occupying approximately 3.1 hectares (7.7 acres). 
 

2 

In support of the preparation of this Supplement to the Mercury Storage EIS, DOE is 

requesting information on state-listed or sensitive species, if present, that may be affected 

by the proposed project. 

Please send the requested information to: 

Me. David Levenstein 

EIS Docwnent Manager 

U.S. Department of Energy 

P.O. Box 2612 

Germantown, Maryland 20874 

(301) 903-6500 

Sincerely, 

David Levenstein 

EIS Document Manager 

Enclosures: I. Notice of Intent to Prepare a Supplemental Environmental Impact 

Statement for the Long-Term Management and Storage of Elemimtal 

Mercury (77 FR 33204). 

2. Map indicating potential mercury storage locations. 

Responses to Consultation Requests 

I–23 
Mr. Tony Delfin, State Forester 

Forestry Division 

New Mexico Energy, Minerals and Natural Resources Department 

1220 South Saint Francis Drive 

Santa Fe, New Mex ico 87505 

Dear Mr. Delfin: 

The purpose of this letter is to amend the U.S. Department of Energy's (DOE's) previous notification to you 

on August 24, 2012, regard ing the Supplement to the Environmental Im pact Statement for the Long-Term 

Management and Storage of Elemental Mercury. In August, DOE informed you of its intent to develop the 

supplementa l environmental impact statement (SEIS) to eva luate two locations in the vicinity of the Waste 

Isolation Pilot Plant (WIPP): Sections 10 and 20, Townsh ip 22 South, Range 3 1 East. DOE received your 

response dated September 17,20 12. 

However, as a result of comments received during the SEIS scoping process, DOE has decided to evaluate a 

third location, also in the vicinity of \VIPP. The additional location is in Section 35, within the same 

township and range as Sections 10 and 20 and outside of the lands withdrawn by the WIPP Land 

Withdrawal Act (P.L. No. 102-579), as amended. Section 35 is approx imately 3.5 miles southeast of the 

WIPP facil ity (see enclosed map). Construction and operation ora long-term mercury storage facility would 

be the same as described in the August 241h correspondence, occupying approximately 3.1 hectares (7.7 

acres). 

In support of the preparation of the Supplement to the Mercury Storage EIS, DOE is requesting a review to 

detennine if there is any additional information regarding state-listed or sensitive species spec ific to Section 

35 that should be considered in our analyses or if the response dated September 17, 2012, would apply 

eq ually to Section 35 as it does for Sections 10 and 20. 

Please send the requested information to: 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 26 12 

Germantown, Maryland 20874 

(30 I) 903-6500 

Sincerely. 

Department of Energy 

Was hington , DC 20585 

IAI 152013 

\)~ David Levenste~ in 

EIS Docllment Manager 

Enclosures: I. Map indicating potential mercury storage locations. 

® Prinled wilh soy ink on rocyelod pllpor 

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

I–24 
 

I.3.2 Response from the New Mexico Energy, Minerals and Natural Resources 

Department 

State of New Mexico 

Energy, Minerals and Natural Resources Department 

Susana Martinez 

Govemor 

John H. Bemis Tony Delfin, Division Director 

Cabinet Secretary Slate Forestry Division 

Bren F. Woods, Ph.D. 

Deputy Cabinet Secretary 

September 17, 2012 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

Germantown, Maryland 20874 

RE: Supplemental Environmental Impact Statement for the Long-Term Storage of Elemental 

Mercury (77 FR 33204). 

Dear Mr. Levenstein: 

Thank for inquiring about a list of potential NM state-listed endangered plants that could 

potentially be impacted by the proposed proiect near Carlsbad in Eddy County, NM. The 

presence of potential habitat should be evaluated for the following plant species: 

Amsonia tharpii (Tharp's bluestar) 

Cirsium wrightii (Wright's marsh thistle) 

Coryphanta scheeri var. scheeri (Scheer's pincushion cactus) 

Echinocereus fendleri var. kuenzleri (Kuenzler's hedgehog cactus) 

Eriogonum gypsophilum (Gypsum wild buckwheat) 

Escobaria sneed;; var. leei (Lee's pincushion cactus) 

Additional information on these state-listed plants and other sensitive plants in Eddy County, 

NM, can be found at: http://nmrareplants.unm.edu/index.html 

If suitable habitat is found, clearance surveys should be conducted at the appropriate time of 

year, optimizing chances to detect potential plants within the project area. If plants are found 

within the project area minimization or avoidance measures will need to be developed to 

minimize impacts to the species. 

Please let me know if I can be of further help. 

Daniela Roth, Botany Coordinator 

505-476-3347 

1220 South 51. Francis Drive· Santa Fe, New Mexico 87505 

Phone (505) 476-3325 • Fax (505) 476-3330' www.emnrd.slate.nm.us/fd 

Responses to Consultation Requests 

I–25 
State of New Mexico 

Energy, Minerals and Natural Resources Department 

Susana Martinez 

Governor 

John H. Bemis Tony Dellin, Division Director 

Cabinet Secretary Siale Forestry Division 

Brett F. Woods, Ph.D. 

Deputy Cabinet SecretaI)' 

Mr. David Levenstein January 24, 2013 

EIS Document Manager 

U.S. Department of Energy 

Germantown, Maryland 20874 

RE: Additional site location for the Long-Term Management and Storage of Elemental Mercury 

Dear Mr. Levenstein: 

Thank for inquiring about NM state-listed endangered plants that could potentially be impacted 

by the proposed mercury storage project near Carlsbad in Eddy County, NM. As stated in my 

letter from September 17, 2012, the presence of potential habitat should be evaluated for the 

following plant species: 

Amsonia tharpii (Tharp's bluestar) 

Cirsium wrightii (Wright's marsh thistle) 

Coryphanta scheeri var. scheeri (Scheer's pincushion cactus) 

Echinocereus fendleri var. kuenzleri (Kuenzler's hedgehog cactus) 

Eriogonum gypsophilum (Gypsum wild buckwheat) 

Escobaria sneedii var. leei (Lee's pincushion cactus) 

No additional plants need to be considered for the third location, in Section 35, within the same 

township and range as the previously addressed locations. 

Additional information on these state-listed plants and other sensitive plants in Eddy County, 

NM, can be found at: http://nmrareplants.unm.edu/index.html 

If suitable habitat is found, clearance surveys should be conducted at the appropriate time of 

year, optimizing chances to detect potential plants within the project area. If plants are found 

within the project area minimization or avoidance measures will need to be developed to 

minimize impacts to the species. 

Please let me know if I can be of further help. 

Daniela Roth, 

;rG/?~ Botany Coordinator 

505-476-3347 

1220 South SI. Francis Drive ' Santa Fe, New Mexico 87505 

Phone (505) 476·3325 ' Fax (505) 476·3330' www.emnrd.stale.nm.ustfd 

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

I–26 
Responses to Consultation Requests 

I.4	 CORRESPONDENCE WITH THE NEW MEXICO HISTORIC PRESERVATION 

DIVISION 

I.4.1	 U.S. Department of Energy’s Correspondence to the New Mexico Historic 

Preservation Division 

I–27 

Department of Energy 

Washington, DC 20585 

AUG 24 lOIZ 

Ms. Jan Biella 

State Historic Preservation Officer 

New Mexico Historic Preservation Division 

Bataan Memorial Building 

407 Galisteo Street, Suite 236 

Santa Fe, New Mexico' 87501 

Dear Ms. Biella: 

The purpose ofthis letter is to notify you that the Department of Energy (DOE) is 

preparing a Supplement to the EnvironmentallJtlpact Statement (EIS) for the Long-Tel1ll 

Management and Storage of Elemental Mercury (see enclosed Notice of Intent). 

Pursuant to the Mercury Export Ban Act of2008 (p.L. 110-414), DOE has been directed 

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

mercury generated within the United' States. DOE is analyzing the storage of up to 

10,000 metric tons (11,000 tons) of elemental mercury in a facility or facilities 

constructed and operated in accordance with the Solid Waste Disposal Act, as amended 

by the Resource Conservation and Recovery Act. To evaluate the range of reasonable 

alternatives for siting. constructing, and operating a facility or facilities to meet its 

obligations under the Act, DOE prepared the Mercury Storage EIS in accordance with the 

National Environmental Policy Act (NEPA) and its implementing regulations (40 CFR 

Parts 1500-1508 and 10 CFR Part 1021) and issued the Mercury Storage Final EIS in 

January 2011. The Mercury Storage EIS evaluated seven candidate locations for the 

elemental mercury storage facility, as well as the No Action Alternative. Since 

publication of the Final Mercury Storage EIS, DOE has reconsidered the range of 

reasonable alternatives evaluated in that ElS. Accordingly, DOE now proposes to 

evaluate two additional locations for a 10ng-tel1ll mercury storage facility, both near the 

Waste Isolation Pilot Plant (WlPP), which DOE operates for disposal of defense 

transuranic waste. 

This Supplement to the' Mercury Storage EIS will analyze the potential environmental, 

human health, and socioeconomic impacts of elemental mercury storage at two locations 

near WIPP. One of the addiiionallocations to be evaluated is in Section 20, Township 22 

South, Range 31 East within the land subject to the WIPP Land Withdrawal Act (Act) 

(P.L. No. 102-579) as amended, across the WlPP access road from the WIPP facility. The 

second is in the vicinity ofWIPP, but outside of the lands withdrawn by the Act, in 

Section 10, Township 22 South, Range 31 East, approximately 3 miles north of the WlPP 

facility (see enclosed map). 

In preparing this Supplement to the Mercury Storage EIS, DOE has gathered and 

analyzed information regarding cultural resources at these locations near WIPP. 
This consultation is in accordance with NEPA and Section 106 of the National Historic 

Preservation Act. Preconstruction surveys and construction monitoring for previously 

unknown resources would be conducted if either ofthese locations is chosen for 

construction of the facility. 

In support of the preparation of this Supplement to the Mercury Storage EIS, DOE is 

soliciting any specific concerns you may have regarding cultural resources that may be 

affected by the proposed project. We would appreciate. reply to this letter within 30 

days of receipt. 

If you have any questions or concerns, please contact me at: 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 2612 

Germantown, Maryland 20874 

(301) 903-6500. 

Sincerely, 

David Levenstein 

EIS Document Manager 

Enclosures: 1. Notice of Intent to Prepare a Supplemental Environmental Impact 

Statement for the Long-Term Management and Storage of Elemental 

Mercury (77 FR 33204). 

2. Map indicating potential mercury storage locations. 

2 

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

I–28 
 

Ms. Jan Biella 

State Historic Preservation Officer 

New Mex ico Historic Preservation Division 

Bataan Memorial Building 

407 Galisteo Street, Su ite 236 

Santa Fe, NM 8750 I 

Dear Ms. Biella: 

The purpose of th is letter is to amend the U.S. Department of Energy's (DOE's) previous notification to you 

on August 24, 20 I 2, regarding the Supplement to the Env ironmental Impact Statement for the Long-Term 

Management and Storage of Elementa l Mercury. In August, DOE in formed you of its intent to develop the 

supplemental environmental impact statement (SEIS) to eva luate two locations in the vic inity o f the \Vaste 

Iso lation Pilot Plant (WIPP): Sections 10 and 20, Townsh ip 22 South, Range 3 I East. DOE received your 

response dated August 3 1,201 2. 

However. as a resu lt of comments rece ived during the SEIS scoping process, DOE has decided to evaluate a 

third location, also in the vicinity of WIPP. The additional location is in Section 35, with in the same 

township and range as Sections 10 and 20 and outside of the lands withdrawn by the WIPP Land 

Withdrawal Act (P.L. No. 102-579), as amended. Section 35 is approximate ly 3.5 miles southeast of the 

WIPP faci lity (see enclosed map). Construction and operation ofa long-term mercury storage fa cility would 

be the same as desc ri bed in the August 24th correspondence, occupying approximately 3.1 hectares (7.7 

ac res). 

In support of the preparation of the Supplement to the Mercury Storage EIS, DOE is requesting a review to 

determine if there is any additional in formatio n regarding cultural resources specific to Section 35 that 

should be considered in our analyses or if the response dated August 3 I, 20 I 2, wou ld apply equally to 

Section 35 as it does for Sections 10 and 20. 

Please send the requested in format ion to: 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 26 I 2 

Germantown, Maryland 20874 

(30 I ) 903-6500 

Sincerely. 

Department of Energy 

Washington, DC 20585 

JAN 152013 

EIS DoclIment 

s~ Manager 

Enclosures: I. Map indicating potential mercury storage locations. 

@ Printed WIth soy ink Of' recycled paper 

Responses to Consultation Requests 

I–29 
I.4.2 Response from the New Mexico Historic Preservation Division 

STATE OF NEW MEXICO 

DEPARTMENT OF CULTURAL AFFAIRS 

HISTORIC PRESERVATION DIVISION 

BATAAN MEMORIAL BUILDING 

407 GALISTEO STREET, SUITE 236 

SANTA FE, NEW MEXICO 87501 

PHONE (505) 827·6320 FAX (505) 827·6338 

Susana Martinez 

Governor 

August 31,2012 

Mr. David Levenstein 

EIS Document Manager 

U.S. -Department of Energy 

P.O. Box 2612 

Germantown, Maryland 20874 

Subject: Supplement to the Mercury Storage EIS 

Dear Mr. Levenstein: 

Thank you for your notification that the Department of Energy (DOE) is preparing a Supplement 

to the Environmental Impact Statement (EIS) for Long-Term Management and Storage of 

Elemental Mercury. We understand the supplement will analyze elemental mercury storage at 

two locations near WIPP, One of the locations to be evaluated is in Section 20, Township 22 

South, Range 31 East. This location is within lands withdrawn by the WIPP Land Withdrawal 

Act (Act), The second location is also in the vicinity ofWIPP but outside of the lands withdrawn 

by the ACT, This second location is in Section 10, Township 22 South, Range 31 East. 

We agree with preconstruction surveys of the proposed project and construction monitoring 

(when appropriate) if one of these two locations were to be selected. Assuming there would be 

underground mining, we would also point out the need for cultural resource surveys of off-site 

waste disposal areas and associated access roads, We thank you for the opportunity to comment. 

We look forward to further project related correspondence, 

Sincerely, 

1~D~v~ Norman B. Nelson 

Archaeologist 

Planning and Review 

Historic Preservation Division 

N ,M. Office of Cultural Affairs 

(505) 476-0255 

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

I–30 
 

ST/,rEOF NEW MEXICO 

DEPARTMENT OF CULTURAL AFFAIRS 

HISTORIC PRESERVATION DIVISION 

HArAAN M EMOR IALB UILDINCi 

407 GALISTEO STR EEr. SUITE 13(' 

SANTA FE. NEW MEXICO 8750 1 

PI-lONE (505) 827 6~20 FAX (505 ) 27 :l~ R 

Susana Martinez 

Gove rnor 

January 23. 20 13 

Mr. David Levenstein 

EIS Document Manager 

U.S. Department of Energy 

P.O. Box 26 12 

Germantown. Maryland 20874 

Subject: Supplement to the Mercury Storage EIS addi ng Secti on 35 

Dear Mr. Levenstein : 

Thank you for your notificatio n that the Department of Energy (DOE) is preparing a Supplement 

to the Environmenta l Impact Statement (E IS) for Long-Term Management and Storage of 

Elemental Mercury. We understand the supplement will analyze elemental mercury storage at 

th ree locati ons near WIPP. One of the locati ons to be evaluated is in Secti on 20, Township 22 

South. Range 3 1 East. This location is within lands withdrawn by the WIPP Land Withdrawa l 

Act (Act). The second location is also in the vicinity of WIPP but outside o f the lands withdrawn 

by the ACT. This second location is in Section 10. Township 22 South, Range 3 1 East. In 

addition a th ird locati on, Section 35 has been added since the August 31,20 12 reply from our 

office (your letter dated August 24, 20 12). 

We agree with preconstruction archaeo logica l surveys of the proposed project area(s) and 

construction monitoring (when appropriate) if one of these three locations were to be selected. 

Assuming there would be underground mining, we wo uld also point out the need for cultura l 

resource surveys of off-site waste disposal areas and for associated access roads. We thank you 

fo r the opportunity to comment. We look forward to further project related correspondence. 

Sincerely, 

/ If I(U~ jj/, . Ii ( (/I" ",~ 

Norman B. Nelson 

Archaeologist 

Planning and Review 

Historic Preservation Division 

N.M. Office of Cultural Affa irs 

(505) 476-0255 

Responses to Consultation Requests 

I–31