DOE/EA-1339-A 

 

Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site 

December 2003 

U. S. Department of Energy 

Oak Ridge Operations 

Oak Ridge, Tennessee 
DOE/EA-1339-A 

Disposition of Additional Waste at the Paducah Site 

Environmental Assessment Addendum 

December 2003 

U. S. Department of Energy 

Oak Ridge Operations 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Table of Contents 

Table of Contents............................................................................................................................ v 

Acronyms....................................................................................................................................... vi 

1.0 Introduction.............................................................................................................................. 1 

1.1 Purpose and Need for Agency Action .................................................................................. 1 

1.2 Scope of this Assessment...................................................................................................... 2 

2.0 Proposed Action........................................................................................................................ 2 

2.1 No Action Alternative........................................................................................................... 3 

2.2 Enhanced Storage Alternative............................................................................................... 3 

2.3 Alternatives Considered but Dismissed................................................................................ 3 

2.3.1 Onsite Disposal of all Waste.......................................................................................... 3 

3.0 Affected Environment............................................................................................................... 3 

4.0 Environmental Consequences................................................................................................... 4 

4.1 Proposed Action Impacts ...................................................................................................... 4 

4.1.1 Land Use ........................................................................................................................ 4 

4.1.2 Socioeconomics and Environmental Justice.................................................................. 4 

4.1.3 Transportation Impacts .................................................................................................. 5

4.1.3 Ecological Resources Impacts ....................................................................................... 9 

4.2 No Action Impacts .............................................................................................................. 10 

4.3 Enhanced Storage Impacts.................................................................................................. 10 

5.0 Cumulative Impacts ................................................................................................................ 11 

6.0 References............................................................................................................................... 11 

Appendix A Persons and Agencies Contacted 

Appendix B Consultation Letters and Responses 

Appendix C Biological Assessment 

Appendix D Draft EA Comments Received and Responses 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Acronyms 

CERCLA Comprehensive Environmental Response, Compensation and Liability Act of 1980 

CFR Code of Federal Regulations 

D&D Decontamination and Decommissioning 

DMSA DOE Material Storage Area 

DOE U.S. Department of Energy 

EA Environmental Assessment 

g Grams 

HDDV Heavy Duty Diesel-Powered Vehicle 

LCF Latent Cancer Fatality 

m3

 Cubic Meters 

MEI Maximally Exposed Individual 

NCS Nuclear Criticality Safety 

NEPA National Environmental Policy Act of 1969 

PM10 Particulate Matter Smaller than 10 Micrometers 

ROD Record of Decision 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 1 

1.0 Introduction 

The U.S. Department of Energy (DOE) proposes disposition activities for waste from the Paducah Site in 

Paducah, Kentucky. As a federal agency, DOE must comply with the National Environmental Policy Act 

of 1969 (NEPA) by considering, in the decision-making process, potential environmental impacts 

associated with its proposed action. The Council on Environmental Quality promulgated regulations to 

implement NEPA [40 Code of Federal Regulations (CFR) 1500 et seq.] and directed federal agencies to 

develop their own implementing regulations. DOE regulations (10 CFR 1021) provide additional 

direction for conducting NEPA reviews of proposed DOE activities. This environmental assessment (EA) 

addendum for the disposition of DOE waste stored and/or generated at the Paducah Site has been 

prepared in accordance with both Council on Environmental Quality and DOE regulations and with DOE 

orders and guidance regarding these waste types. 

1.1 Purpose and Need for Agency Action 

DOE must continue to manage (i.e., treat, store, and dispose) its waste and material safely, efficiently, and 

cost effectively in compliance with applicable federal and state laws and in a manner protective of human 

health and the environment. 

DOE is required by the Atomic Energy Act (42 United States Code 2011 et seq.) and DOE Order 

435.1A to manage the radioactive wastes that it generates. DOE has determined that it will dispose lowlevel radioactive waste at the DOE Hanford Site in Washington and at the DOE Nevada Test Site, as 

documented in the Record of Decision (ROD) for the Department of Energy’s Waste Management 

Program: Treatment and Disposal of Low-Level Waste and Mixed Low-Level Waste (January 1998, 63 

Federal Register 3629). This decision does not preclude treatment or disposal of low-level waste at 

commercial facilities in accordance with DOE policy. 

DOE completed an Environmental Assessment for Waste Disposition Activities at the Paducah Site 

Paducah Kentucky (DOE/EA-1339 - Waste Disposition EA) and issued a Finding of No Significant 

Impact on November 4, 2002. The Waste Disposition EA analyzed disposition of approximately 11,000 

m3

 of various wastes. At the time of issuance of the Waste Disposition EA, DOE anticipated that the 

removal of remaining waste stored on-site (estimated at 20,000 m3

 in that EA) would be conducted as part 

of decontamination and decommissioning (D&D) activities under the Comprehensive Environmental 

Response, Compensation and Liability Act of 1980 (CERCLA). Consequently, the Waste Disposition 

EA included the characterization of these wastes but did not include these additional wastes in the 

evaluation of off-site disposition activities. 

DOE has subsequently decided to propose proceeding with disposition of additional materials and wastes 

as part of its recently funded accelerated cleanup plan rather than waiting until facility D&D. Much of 

the additional material and waste is stored outdoors where there is a risk of spread of contamination to the 

environment. Also, DOE would experience a long-term cost savings through reduction of surveillance 

and maintenance costs that would be necessary for continued on-site storage. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 2 

1.2 Scope of this Assessment 

DOE proposes to disposition approximately 17,600 m3

 of material in addition to the 11,000 m3 of waste 

analyzed in the Waste Disposition EA for a total of 28,600 m3

 of waste and material. The majority of 

these materials are currently stored in approximately 160 DOE Material Storage Areas (DMSAs) at the 

Paducah Site. All of these materials will be characterized to determine if they are wastes and, if so, how 

they are to be dispositioned (i.e., categorized, managed, and treated or disposed). 

DOE anticipates that a substantial portion of the 

material will be characterized as waste. DOE 

further anticipates that approximately 45% (7,900 

m3

) of the material will be waste that meets the 

permit conditions and Waste Acceptance Criteria 

for on-site disposal in the C-746-U Landfill. No 

low-level radioactive or hazardous waste would be 

put in the landfill. On-site disposal of waste, which 

may include authorized limits material, is evaluated 

in the Environmental Assessment for the 

Construction, Operation, and Closure of the Solid 

Waste Landfill at the Paducah Gaseous Diffusion 

Plant, Paducah, Kentucky (DOE/EA-1046) and 

The Environmental Assessment on the 

Implementation of the Authorized Limits Process 

for Waste Acceptance at the C-746-U Landfill 

Paducah Gaseous Diffusion Plant, Paducah, 

Kentucky (DOE/EA-1414) and is not further 

evaluated in this EA Addendum. 

This EA Addendum evaluates the potential impacts to human health and the environment that would 

result from the Proposed Action and alternatives and it is intended as a supplement to the Waste 

Disposition EA. Evaluation of impacts from the operation of off-site waste treatment and disposal 

facilities is discussed in the Waste Disposition EA (p. 6) and, consequently, is not further evaluated in this 

EA Addendum. 

2.0 Proposed Action

DOE proposes to disposition 11,000 m3

 of waste as described in the Waste Disposition EA and 

approximately 17,600 m3

 of additional material currently stored at the Paducah Site for a total of 28,600 

m3

 of waste and material. Disposition activities for the additional material include characterization, 

storage, packaging, loading, and shipping wastes to disposal locations. 

For purposes of impact evaluation, DOE has established a “worst-case scenario” for the Proposed Action 

whereas all 28,600 m3

 is considered low-level radioactive waste requiring transportation off-site for 

treatment or disposal. The additional waste would be transported in the same timeframe, same manner, 

same representative locations, and same representative routes as described in the Waste Disposition EA. 

DOE currently anticipates that the waste would be disposed primarily at the DOE Nevada Test Site 

although disposition at the Hanford Site and commercial facilities, such as Envirocare of Utah, Inc. and 

Waste Control Specialists, LLC in Texas, are also analyzed as possible locations. 

Low-level Waste – Radioactive waste that is not 

high-level radioactive waste, spent nuclear fuel, 

transuranic waste, byproduct material (as defined 

in section 11e.(2) of the Atomic Energy Act of 

1954, as amended), or naturally occurring 

radioactive material (DOE G 435.1-1). ). Lowlevel waste can be evaluated to determine if the 

material meets the requirements of the approved 

authorized limits. 

Authorized Limits Material – Residual 

radioactive material that meets the requirements of 

the approved authorized limits developed in 

accordance with DOE Standard 5506-99 (Guide to 

Good Practice for Establishing Authorized Limits 

for the Release of Waste Containing Residual 

Radioactivity) and DOE Order 5400.5 (Radiation 

Protection of the Public and the Environment).
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 3 

Most of the additional material is currently stored in approximately 160 DMSAs at the Paducah Site. Due 

to the undetermined nature of a majority of the DMSA wastes, Nuclear Criticality Safety (NCS) 

characterization must first be performed. NCS characterization provides the information necessary to 

move or manage materials safely without the threat of uncontrolled nuclear criticality. The material must 

also be examined to determine if any Resource Conservation and Recovery Act or Toxic Substances 

Control Act regulated wastes are present. Material would not be available for disposition until DMSA 

characterization activities are completed. DOE anticipates this characterization could occur over a 10-

year period. Material would be disposed throughout the 10 years as portions of the characterization are 

completed. 

2.1 No Action Alternative 

Under this alternative, the additional low-level waste would be stored on-site until removed during D&D 

activities. The activities associated with the continued storage of the low-level waste are the same as 

those described in the Proposed Action in the Waste Disposition EA. 

2.2 Enhanced Storage Alternative 

The activities associated with enhanced storage would be similar to those described in Enhanced Storage 

Alternative in the Waste Disposition EA. 

2.3 Alternatives Considered but Dismissed 

2.3.1 Onsite Disposal of all Waste 

DOE considered the option to dispose all wastes on-site. This action would result in the need to build a 

new landfill or landfill cells for disposal of low-level waste. This alternative was not considered 

reasonable. Based on the Record of Decision for the Department of Energy’s Waste Management 

Program: Treatment and Disposal of Low-Level Waste and Mixed Waste (January 1998, 63 Federal 

Register 3629), DOE has determined that low-level waste should be disposed either at the Nevada Test 

Site or the Hanford Site rather than constructing new landfills or landfill cells. (The Record of Decision 

did not preclude disposal at commercial facilities.) 

3.0 Affected Environment 

The affected environment description in the Waste Disposition EA is still valid and has not changed. The 

additional 17,600 m3

 of low-level waste are currently stored both outdoors and indoors at the Paducah 

Site. The only on-site activities planned for the additional low-level waste would be storage, surveillance, 

characterization, packaging, repackaging, and loading onto transport carriers. All of these activities are 

analyzed in the Waste Disposition EA. Therefore, the affected environment is the same for this EA 

Addendum as for the Waste Disposition EA. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 4 

4.0 Environmental Consequences 

4.1 Proposed Action Impacts 

Potential environmental impacts that could result from the Proposed Action (using the worst-case 

scenario described above) were evaluated for the following: land use, geology and seismicity, soils and 

prime farmland, water resources and water quality, groundwater, floodplains, wetlands, ecological 

resources, threatened and endangered species, noise, cultural resources, archaeological resources, Native 

American resources, air quality, socioeconomics and environmental justice, on-site accidents, 

transportation, and transportation accidents. 

Potential impacts identified were compared with the impacts identified in the Waste Disposition EA. 

There would be no change for impacts to: geology and seismicity, soils and prime farmland, water 

resources and water quality, groundwater, floodplains, wetlands, noise, cultural resources, archaeological 

resources, Native American resources, air quality, and on-site accidents. These impacts were not 

analyzed further in this EA Addendum. 

Impacts of land use, socioeconomics, environmental justice, transportation, and ecological resources may 

change from the Waste Disposition EA as a result of disposition of the additional material, and are 

evaluated further in this EA Addendum. The biological assessment prepared for the Waste Disposition 

EA to evaluate potential impacts on federally listed species was revised to fully incorporate the Proposed 

Action. The revised biological assessment concludes that there will be no adverse affect on federally 

listed species or critical habitat of these species (Appendix C). 

4.1.1 Land Use 

Potential impacts identified were compared with the impacts identified in the Waste Disposition EA. The 

additional low-level waste is currently stored on property that is owned by DOE. Most of the land would 

continue to be used by DOE for storage or other undetermined uses. A portion of the waste is stored in 

DMSAs located in buildings leased to the U.S. Enrichment Corporation. DOE anticipates that when the 

material is removed from these DMSAs the areas may be used for other purposes by the U.S. Enrichment 

Corporation. 

4.1.2 Socioeconomics and Environmental Justice 

The Waste Disposition EA (November 2002) estimated a total employment increase of 45 jobs resulting 

from disposition of 11, 000 m3

 of waste. The disposition of 28,600 m3 of waste and material is estimated 

to increase employment by 117 full-time-equivalent jobs per year. This would represent less than a 3% 

change from 1997 employment in McCracken County, which does not constitute a notable impact. 

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations and 

Low Income Populations,” requires agencies to identify and address disproportionately high and adverse 

human health or environmental effects that their activities may have on minority and low-income 

populations. For the on-site activities considered in this EA Addendum, populations considered are those 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 5 

that live within 80 km (50 miles) of the Paducah Site. For transportation alternatives, populations 

considered are those that live along the highways or rail lines where transport of packaged waste would 

occur and people using the highways and/or stopping at rest stops. Individual access and use of public 

highways or rest stops that would be used by trucks shipping waste are not limited or restricted to any 

particular population group, economically disadvantaged or advantaged. Because it is expected that the 

percentage of minority or low-income households within the potentially exposed population would vary 

along the highway routes used for the Proposed Action, no disproportionate effects to those minority or 

low-income households located along the routes can be identified. These groups would be subject to the 

same negligible impacts as the general population. 

4.1.3 Transportation Impacts 

For purposes of impact evaluation, DOE has established a “worst-case scenario” for the Proposed Action 

whereas all 28,600 m3 is considered low-level radioactive waste requiring transportation off-site for 

treatment or disposal. 

4.1.3.1 Highway Transport 

Air Quality Impacts from Truck Transport 

The Waste Disposition EA identified impacts based on the rate trucks pass through major metropolitan 

areas. The shipment rate used for the analysis was 762 shipments per year. The Proposed Action would 

have a higher shipment rate per year. The 17,600 m3

 of additional waste would be transported in 

shipments of 18.2 m3

 each, or a total of 967 shipments. If the removal of additional waste takes place 

uniformly over 10 years this would result in a shipment rate of 97 additional shipments per year. 

Therefore the annual shipment rate for all waste shipments would be 762 shipments originally proposed 

and 97 additional shipments resulting in 859 shipments per year. (Note that this is a worst-case scenario 

as the actual shipment rate would be less than 859 shipments per year because of the waste anticipated to 

be disposed on-site and the conservative rate used for analysis in the Waste Disposition EA.) 

Analysis was undertaken to determine the impact of the proposed shipments relative to the threshold 

emission levels in nonattainment areas described by EPA in its air conformity regulations [40 CFR 

93.153(b)(1)]. The EPA general conformity rule (58 Federal Register 63214, November 30, 1993) 

requires federal agencies to prepare a written conformity analysis and determination for proposed 

activities only in those cases where total emissions of an activity exceed the threshold emission levels. 

Where it can be demonstrated that emissions from a proposed new activity fall below the thresholds, these 

emissions are considered to be de minimus and require no formal analysis. 

The Waste Disposition EA proposed routes were evaluated for the road miles proposed to be traveled for 

each criteria pollutant. Carbon monoxide, ozone, and particulate matter smaller than 10 micrometers 

(PM10) were the criteria pollutants used. The maximum road miles traveled through a nonattainment area 

would be approximately 150 miles (includes return trip) through the Dallas-Fort Worth, Texas, area 

(Atlanta and St. Louis areas are nearly as large). This distance conservatively includes a return truck trip 

even though the return trip is not part of the Proposed Action (no waste on the truck), and it is likely that 

commercial vehicles would not return by the same route if they were able to contract a load for the return 

trip. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 6 

The EPA threshold for carbon monoxide for all nonattainment and maintenance areas is 200,000 lb (100 

tons)/year for any new proposed activity. The EPA threshold for ozone (measured by its precursor, NOx

for “ozone attainment areas outside an ozone transport region” such as Dallas-Fort Worth) is 200,000 lb 

(100 tons)/year. The EPA threshold for PM10 for all moderate nonattainment areas is 200,000 lb (100 

tons)/year for any new proposed activity. Emission factors for carbon monoxide and ozone for various 

motor vehicle types have been modeled for the year 1990. Emission factors for PM10 have been 

calculated using EPA’s February 1995 model for that criteria pollutant. Heavy duty diesel-powered 

vehicles (HDDVs) are defined as any diesel-powered motor vehicle designated primarily for the 

transportation of property and rated at more than 8500 lb of gross vehicle weight. For HDDVs, including 

the standard commercial semi-tractor vehicles that would be used for pulling waste shipments, the 

average emission for carbon monoxide is estimated as 11.03 g/mile, while the NOx (an ozone precursor) 

emission rate is 22.91 g/mile. Finally, the emission factor for PM10 is 14.87 g/mile. 

Using a maximum of 859 shipments (truck round trips)/year, the carbon monoxide emission rate was 

estimated for the maximum distance traveled through a nonattainment area (Dallas-Fort Worth). This 

emission rate was approximately 3140 lb of carbon monoxide/year. This amount of emissions is below 

the threshold standard of 100 tons/year and is clearly a de minimus amount. Therefore, the deduction is 

made that the Proposed Action of 859 shipments per year would also be de minimus. 

Using a maximum of 859 shipments/year (truck round trips), an ozone emission rate was established for 

the maximum distance traveled within a nonattainment area (Dallas-Fort Worth area). This emission rate 

was approximately 6503 lbs of NOx/year (NOx is a precursor to ozone). This amount of emissions is 

below the threshold standard of 100 tons/year and clearly a de minimus amount. Therefore, the deduction 

is made that the Proposed Action of 859 shipments per year would also be de minimus. 

Finally, using a rate of 859 shipments/year, a PM10 rule was established for the maximum distance within 

a nonattainment area (Dallas-Fort Worth). The emission rate was 4225 lb of PM10/year. This amount is 

below the threshold standard of 100 tons/year and is clearly a de minimus amount. Therefore, the 

deduction is made that the Proposed Action of 859 shipments per year would also be de minimus. 

Because the Dallas-Fort Worth area example maximizes road miles traveled through a nonattainment area 

and also conservatively estimates emission factors, it is assumed that this example “bounds” the impacts 

within other nonattainment areas for the Proposed Action. Therefore, air emissions within all 

nonattainment areas along shipment routes are well below the EPA threshold emission levels, and thus 

require no formal conformity analysis. 

Human Risk Associated with Truck Transport 

The Waste Disposition EA estimated human risk impacts from truck transport on the basis of 762 

shipments per year. The impacts with the additional waste are based on 859 total shipments per year. 

The impacts would be proportional to the ratio of the increase in shipments or 859 shipments (EA 

Addendum) / 762 shipments (Waste Disposition EA) = 1.13. Therefore the Waste Disposition EA 

quantified transportation impacts were multiplied by 1.13. 

The radiological effects of the shipments are estimated by the potential latent cancer fatalities. Table 4.1 

lists Waste Disposition EA impacts and the proportional cumulative impacts. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 7 

Table 4.1 Worst Case Radiological Impacts for Truck Shipments

Annual Impacts Total for 10-year life cycle 

Waste 

Disposition EA EA Addendum Waste Disposition EA EA Addendum Risk 

Group

LCF LCF LCF LCF 

Crew 2.4 x 10-3 2.7 x 10-3 2.4 x 10-2 2.7 x 10-2

Population 1.2 x 10-3 1.4 x 10-3 1.2 x 10-2 1.4 x 10-2

MEIa (rem) 1.7 x 10-3 1.9 x 10-3 1.7 x 10-7 1.9 x 10-7

a MEI latent cancer fatality represents the probability of a latent cancer fatality occurrence 

LCF = latent cancer fatality 

MEI = maximally exposed individual 

All latent cancer fatalities are less than one, therefore no fatalities would be anticipated. 

Cargo-Related Radiological Impacts during a Highway Accident 

The probability of a highway accident occurring during waste transportation by truck was evaluated for 

each of the receiving locations evaluated in the Waste Disposition EA. In addition, the radiological dose 

resulting from these accidents was calculated and the risk of latent cancer fatalities to the general public 

was also calculated. These results are summarized in Table 4.2. 

Table 4.2 Cargo-Related Radiological Impacts from Truck Transportation Accident 

Waste 

Disposition 

EA 

EA 

Addendum 

Population Dose (person-rem) 4.9 5.5 

Latent Cancer Fatalities 2.5 x 10-3 2.8 x 10-3

All latent cancer fatalities are less than one, therefore no fatalities would be anticipated. 

Vehicle-Related Impacts 

Potential vehicle-related impacts, including expected accidents, expected fatalities from accidents, and 

impacts from vehicle emissions were evaluated. The results of the evaluation are summarized in Table 

4.3. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 8 

Table 4.3 Estimated Fatalities from Truck Emissions and Accidents 

(Vehicle-Related Impacts) 

Waste 

Disposition 

EA 

EA 

Addendum 

Total Accidents 1.89 2.14 

Total Fatalities 0.08 0.09 

Latent fatalities from emissions 0.43 0.49 

All latent fatalities and accident fatalities are less than one, therefore no fatalities would be anticipated. 

4.1.3.2 Rail Transport 

Potential rail-related impacts, including expected accidents, expected fatalities from accidents, and 

impacts from vehicle emissions were evaluated. The results of the evaluation are summarized in Table 

4.4 

Table 4.4 Radiological Impacts from Rail Shipments 

Annual Impacts Total for 10-year life cycle 

Waste 

Disposition 

EA 

EA 

Addendum 

Waste 

Disposition 

EA 

EA 

Addendum 

Risk 

Group

LCF LCF LCF LCF 

Crew 1.1 x 10-3 1.2 x 10-3 1.1 x 10-2 1.2 x 10-2

Population 4.1 x 10-3 4.6 x 10-3 4.1 x 10-2 4.6 x 10-2

MEIa (rem) 3.7 x 10-8 4.2 x 10-8 3.7 x 10-7 4.2 x 10-7

a MEI latent cancer fatality represents the probability of a latent cancer fatality occurrence 

LCF = latent cancer fatality 

MEI = maximally exposed individual 

All latent cancer fatalities are less than one, therefore no fatalities would be anticipated. 

Cargo-Related Radiological Impacts during a Rail Accident

The probability of a railroad accident occurring during waste transportation was evaluated for each of the 

receiving locations evaluated in the Waste Disposition EA. In addition, the radiological dose resulting 

from these accidents was calculated and the risk of latent cancer fatalities to the general public was also 

calculated. These results are summarized in Table 4.5. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 9 

Table 4.5 Cargo-Related Radiological Impacts from Rail Transportation Accidents 

Waste 

Disposition 

EA 

EA 

Addendum 

Total Population Dose (person-rem) 5.51 6.2 

Latent Cancer Fatalities 2.8 x 10-3 3.2 x 10-3

All latent cancer fatalities are less than one, therefore no fatalities would be anticipated. 

Rail-Related Impacts 

Potential rail-related impacts, including expected accidents and expected fatalities from accidents were 

evaluated. The results of the evaluation are summarized in Table 4.6. 

Table 4.6 Estimated Fatalities from Accidents 

(Rail Related Impacts) 

Waste 

Disposition 

EA 

EA 

Addendum 

Total Accidents 0.08 0.09 

Total Fatalities 0.02 0.02 

All fatalities are less than one, therefore no fatalities would be anticipated. 

4.1.3 Ecological Resources Impacts 

Impacts to ecological resources were compared to the analysis in the Waste Disposition EA (DOE/EA1339). The only potential change in impacts identified was for threatened and endangered species. 

A Biological Assessment of impacts to threatened and endangered species prepared for the original Waste 

Disposition EA proposed action was revised for the proposed action of this environmental assessment 

addendum. The revised assessment is attached in Appendix C. The revised biological assessment 

concluded that the proposed action would be unlikely to adversely affect the Indiana bat or any mussel 

species of concern because: 

• A potential for exposure of the bat and mussel species to waste as a result of an accident during 

implementation of the revised proposed action would be small and impacts would be negligible or 

nonexistent; 

• Waste disposition activities are currently being performed at the Paducah Site with no known 

detriment to the local Indiana bat or mussel populations; 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 10 

• No bat foraging or roosting habitat is present where waste handling activities would occur or 

along any proposed transportation routes. Therefore, no bat foraging or roosting habitat would be 

affected by routine waste disposition operations; 

• The majority of mussel habitat in the area has been identified upstream from the Paducah site; no 

mussel habitat exists inside the site fence therefore no habitats would be affected by the revised 

proposed action; 

• Bat foraging habitat (riparian vegetation along intermittent tributaries) present near the site of the 

revised proposed action is unlikely to become contaminated; 

• Routine waste management operating procedures would provide minimal opportunity for direct 

exposure of local biota, including Indiana bats and their prey, to wastes. Procedure 

implementation would also decrease the probability of accidents; and 

• No critical bat or mussel habitats are present at the Paducah Site. Therefore, no habitat alteration 

or destruction would occur as a result of the revised proposed action. 

4.2 No Action Impacts 

If DOE decides to take no action on the 17,600 m3

 of additional material, then it would remain on-site 

until disposition during D&D of each area that contains the material. These activities were analyzed as 

the Proposed Action in the Waste Disposition EA. Since the impacts have not changed it is not analyzed 

further. 

4.3 Enhanced Storage Impacts 

Under the Enhanced Storage Alternative, the additional material would remain on-site, be characterized to 

determine what portion is waste, and the waste would be stored in new or upgraded buildings designed to 

withstand earthquakes or other disasters. Storage of up to 28,600 m3

 of waste was included in the 

Enhanced Storage Alternative analysis in the Waste Disposition EA. Since the impacts have not changed 

it is not analyzed further. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 11 

5.0 Cumulative Impacts 

Potential environmental cumulative impacts that could result from the proposed disposition of waste were 

compared with the impacts identified in the Waste Disposition EA. The disposition of all of the material 

as waste was included in the original analysis of cumulative impacts. Therefore, the cumulative impacts 

have not changed from those described in the Waste Disposition EA and are not addressed any further. 

6.0 References 

Final Environmental Assessment of Waste Disposition Activities at the Paducah Site Paducah Kentucky, 

DOE/EA-1339, November 2002. 

Record of Decision (ROD) for the Department of Energy’s Waste Management Program: Treatment and 

Disposal of Low-Level Waste and Mixed Low-Level Waste, January 1998, 63 Federal Register 3629. 

Environmental Assessment for the Construction, Operation, and Closure of the Solid Waste Landfill at 

the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/EA-1046, March 1995. 

The Environmental Assessment on the Implementation of the Authorized Limits Process for Waste 

Acceptance at the C-746-U landfill Paducah Gaseous Diffusion Plant, Paducah, Kentucky, 

DOE/EA-1414, August 2002. 

DOE G 435.1-1, Implementation Guide for use with DOE M 435.1-1, Chapter IV Low-Level Waste 

Requirements, July 9, 1999. 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Appendix A 

Persons and Agencies Contacted 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Federal Agencies 

U.S. Fish and Wildlife Service 

Dr. Lee A. Barclay 

Field Supervisor 

Fish and Wildlife Service 

United States Department of the Interior 

446 Neal Street 

Cookeville, Tennessee 38501 

U.S. Department of Transportation 

Camille Mittleholtz 

Environmental Team Leader 

Office of Transportation Policy 

U.S. Department of Transportation 

Room 10309 

400 7th Street, SW Room 10309 

Washington DC 20590-0001 

Potentially Affected States 

Arkansas 

Tracy L. Copeland 

Manager, Arkansas State Clearinghouse 

Office of Intergovernmental Services 

Department of Finance and Administration 

1515 W. 7th Street, Room 412 

Little Rock, AR 72203 

Colorado 

The Honorable Bill Owens 

Governor of Colorado 

136 State Capitol Building 

Denver, CO 80203-1792 

Idaho 

Kathleen Trever 

Coordinator-Manager 

INEEL Oversight Program 

1410 North Hilton 

Boise, ID 83706 

Illinois 

The Honorable Rod Blagojevich 

Governor of Illinois 

207 State Capitol Building 

Springfield, IL 62706 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Kansas 

Ronald Hammerschmidt 

Director, Division of Environment 

Kansas Department of Health and Environment 

1000 Southwest Jackson Street 

Curtis Building, Suite 400 

Topeka, KS 66612-1367 

Kentucky 

Alex Barber 

KY Division for Environmental Protection 

14 Reilly Road, Frankfort Office Park 

Frankfort, KY 40601 

Mississippi 

Charles Chisolm 

Executive Director 

Mississippi Department of Environmental Quality 

P.O. Box 20305 

Jackson, MS 39289-1305 

Missouri 

Tom Lange 

NEPA Coordinator 

Missouri Department of Natural Resources 

205 Jefferson Street 

Jefferson City, MO 65101 

Nebraska 

Jay Ingenberg 

Deputy Director, Programs 

Department of Environmental Quality 

P.O. Box 98922 

Lincoln, NE 68509-8922 

Nevada 

Heather K. Elliott 

Clearinghouse Coordinator 

Department of Administration 

Nevada State Clearinghouse 

209 East Musser Street, Room 200 

Carson City, NV 89701-4298 

Oregon 

The Honorable John A. Kitzhaber, M.D. 

Governor of Oregon 

900 Court Street, NE, Room 254 

Salem, OR 97310-4047 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Tennessee 

The Honorable Phil Bredesen 

Governor of Tennessee 

Tennessee State Capital 

Nashville, TN 37243-0001 

Texas 

Denise S. Francis 

State Single Point of Contact 

Texas Governor's Office of Budget and Planning 

State Insurance Building 

1100 San Jacinto, Room 2.114 

P.O. Box 12428 

Austin, TX 78711 

Utah 

Carolyn Wright 

Department of Natural Resources 

Center for Policy and Planning 

1594 West North Temple, Suite 3710 

PO Box 145610 

Salt Lake City, UT 84114-5610 

Washington 

Barbara Ritchie 

SEPA Unit Supervisor 

Washington Department of Ecology 

P.O. Box 47703 

Olympia, WA 98504-7703 

Wyoming 

Julie Hamilton 

State Clearinghouse Coordinator, 

Wyoming Federal Land Policy Office 

Herschler Building 

First Floor, West Wing 

Cheyenne, WY 82002 

Paducah Area Public 

Bill Paxton 

Mayor of Paducah 

PO Box 2267 

Paducah, KY 42002 

Danny Orazine 

McCracken County Judge Executive 

301 South 6th 

Paducah, KY 42003 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Wayne L. Davis 

Kentucky Department of Fish and Wildlife Resources 

#1 Game Farm Road 

Frankfort, KY 40601 

Tim Kreher 

West KY Wildlife Management Area 

10535 Ogden Landing Road 

Kevil, KY 42053 

Leon Owens 

PACE International Union Local 50550 

315 Palisades Circle 

Paducah KY 42001

Carl Froede Jr., Remedial Project Manager 

U.S. Environmental Protection Agency, Region 4 

61 Forsythe Street 

Atlanta, GA 30303 

Paducah Public Library 

555 Washington Street 

Paducah, KY 42001 

Tuss Taylor 

KY Division for Waste Management 

14 Reilly Road, Frankfort Office Park 

Frankfort, KY 40601 

Ms. Amanda Hawes 

Envirocare of Utah, Inc. 

46 West Broadway, Suite 116 

Salt Lake City, Utah 84101 

Mr. Scott Schneider 

Hanford Nuclear Services, Inc. 

28 Court Square 

West Plains Missouri 65775 

Mr. Christopher S. Pugsley, Esq. 

Law Offices of Anthony J. Thompson, P.C. 

1225 19th Street, NW 

2nd Floor 

Washington D.C. 20036 

Mr. Kenneth P. Brooks 

7255 State Route 13 

Erin, Tennessee 37061 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Mr. Andrew Smith 

1755 Garland Road 

Knoxville Tennessee 37922 

Mr. Eric Scott 

Radiation Health and Toxics Agents Branch 

Cabinet for Health Services 

MS HS2E-D 

275 East Main Street 

Frankfort, Kentucky 40621 

Mr. Budd Haemer 

Shaw Pittman LLP 

2300 N Street Northwest 

Washington DC 20037 

Mr. Daniel Horner 

McGraw-Hill Nuclear Publications 

1200 G Street Suite 1100 

Washington DC 20005 

Mr. Jay Coghlan 

Director 

Nuclear Watch of New Mexico 

551 West Cordova Road, Number 808 

Santa Fe, New Mexico 87505-4100 

Mr. Douglas S. Huston 

Oregon Office of Energy 

625 Marion Street, Northeast, Suite 1 

Salem, Oregon 97301-3742 

Ms. Susan K. Krenzien 

NNSA/NV 

Mailstop 505 

Post Office Box 98518 

Las Vegas, Nevada 89193-8518 

Merryman Kemp 

Paducah Citizens Advisory Board 

309 N. 8th St. 

Paducah, Kentucky 42001 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Appendix B 

Consultation Letters and Responses 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Appendix C 

Biological Assessment
Endangered Species Act 

BIOLOGICAL ASSESSMENT 

For 

Waste Disposition Activities at the Paducah Site 

McCracken County, Kentucky 

August 1, 2003

U.S. Department of Energy 

Oak Ridge Operations Office 

Oak Ridge, TN 
i

SUMMARY 

The U.S. Department of Energy (DOE) completed an Environmental Assessment for Waste 

Disposition Activities at the Paducah Site, Paducah, Kentucky, (DOE 2002) (Waste Disposition 

EA), including a Biological Assessment for Waste Disposition Activities in Appendix F of the 

document, and issued a Finding of No Significant Impact on November 4, 2002. The Waste 

Disposition EA analyzed disposition of approximately 11,000 m3 of various wastes. At the time 

of issuance of the Waste Disposition EA, DOE anticipated that the removal of remaining waste 

and materials stored on-site would be conducted as decontamination and decommissioning 

(D&D) activities under the Comprehensive Environmental Response, Compensation, and 

Liability Act of 1980. 

DOE subsequently decided to proceed with disposition of additional waste and materials in a 

timelier manner under the authority of the Atomic Energy Act, rather than waiting until D&D 

occurs. To support this decision, DOE has prepared an Environmental Assessment Addendum 

for Disposition of Additional Waste at the Paducah Site (DOE 2003) (Waste Disposition EA 

Addendum) to supplement the previously prepared Waste Disposition EA. This Biological 

Assessment for Waste Disposition Activities at the Paducah Site (Waste Disposition BA) has 

been prepared to assess impacts to federally listed species from activities in the EA and EA 

addendum. 

The Waste Disposition BA evaluates potential impacts on federally listed animal species 

that could result from the implementation of the revised proposed action. The species considered 

in this Waste Disposition BA are the endangered Indiana bat and the following mussel species: 

orangefoot pimpleback, pink mucket, ring pink, and fat pocketbook as identified in a letter from 

the U.S. Fish and Wildlife Service (FWS) to the DOE, dated June 17, 2003 (FWS 2003). 

DOE concludes, for the reasons described in the main text of this Waste Disposition BA, 

that the revised proposed action is not likely to affect these species adversely. In addition, since 

no proposed or designated critical habitats are present on, or near, the locations where activities 

would occur, none would be affected. 
ii

CONTENTS 

SUMMARY..................................................................................................................................... i 

ACRONYMS................................................................................................................................. iii 

1. INTRODUCTION AND PROJECT DESCRIPTION...............................................................1 

1.1 WASTE STORAGE...........................................................................................................1 

1.2 WASTE TREATMENT – ONSITE...................................................................................1 

1.3 WASTE TREATMENT – OFFSITE .................................................................................2 

1.4 WASTE TRANSPORTATION .........................................................................................2 

1.5 WASTE DISPOSAL ..........................................................................................................3 

1.6 SUPPORTING ACTIVITIES ............................................................................................3 

2. STATUS AND BIOLOGY OF THE LISTED SPECIES..........................................................4 

2.1 INDIANA BAT (MYOTIS SODALIS) ...............................................................................5 

2.2 PINK MUCKET PEARLY MUSSEL (LAMPSILIS ARBRUPTA SAY-1831; 

ALSO CALLED L. ORBICULATA HILDRETH-1828)....................................................6 

2.3 ORANGEFOOT PIMPLEBACK (PLETHOBASUS COOPERIANUS) (IDNR 

2001) ..................................................................................................................................7 

2.4 RING PINK (OBOVARIA RETUSA) .................................................................................8 

2.5 FAT POCKETBOOK (POTAMILIS CAPAX) (Earth’s Endangered Creatures 

2001, IDNR 2001)..............................................................................................................9 

3. ECOLOGICAL DESCRIPTION OF THE SITE.....................................................................10 

4. POTENTIAL IMPACTS TO INDIANA BAT........................................................................11 

5. POTENTIAL IMPACTS TO MUSSELS................................................................................11 

6. CONCLUSIONS......................................................................................................................12 

7. REFERENCES ........................................................................................................................14 
iii

ACRONYMS 

BA Biological Assessment 

BJC Bechtel Jacobs Company LLC 

DMSA DOE Material Storage Area 

DOE U.S. Department of Energy 

EA Environmental Assessment 

FWS U.S. Fish and Wildlife Service 

KDFWR Kentucky Department of Fish and Wildlife Resources 

KPDES Kentucky Pollutant Discharge Elimination System 

KSNPC Kentucky State Nature Preserves Commission 

LLW low-level waste 

MLLW mixed low-level waste 

NFA no further action 

PCB polychlorinated biphenyl 

RCRA Resource Conservation and Recovery Act of 1976 

TRU transuranic 

WKWMA West Kentucky Wildlife Management Area 
1

1. INTRODUCTION AND PROJECT DESCRIPTION 

The U.S. Department of Energy (DOE)-Oak Ridge Operations has various waste 

types located at the Paducah Site that must undergo disposition activities. Disposition 

activities evaluated in the Waste Disposition EA include waste storage, sampling, 

characterization, packaging, surveillance, on-site and/or off-site treatment, transportation, 

and disposal, as well as other activities performed to support these tasks. Examples of 

supporting activities include vehicle fueling, facility maintenance, and storage container 

inspections. 

The Waste Disposition EA Addendum describes and evaluates potential impacts 

associated with the revised proposed action. The revised proposed action description 

states that DOE proposes to disposition 17,600 m3 of additional waste. This volume is in 

addition to the 11,000 m3 of various waste types analyzed in the Waste Disposition EA 

and results in a total of 28,600 m3 of waste and material. Disposition activities for the 

additional waste and material are identical to the disposition activities defined and 

analyzed in the Waste Disposition EA and include characterization, storage, packaging, 

handling, and shipping wastes to disposal locations. No new on-site activities are 

anticipated for the revised proposed action. All waste would be transported in the same 

timeframe, same manner, same representative locations, and same representative routes 

as described in the Waste Disposition EA. 

Most of the additional waste and material described in the revised proposed action is 

currently stored in approximately 160 DOE Material Storage Areas (DMSAs) at the 

Paducah Site. DOE anticipates that characterization of the waste and material would 

occur over a 10-year period. Upon completion of characterization, wastes would be 

dispositioned intermittently throughout the 10 years. 

1.1 WASTE STORAGE 

Under the revised proposed action, all waste and material would be stored at the 

Paducah Site until scheduled for treatment, disposal, or transport. Existing facilities will 

be used for waste storage. 

1.2 WASTE TREATMENT – ONSITE 

On-site treatment applies to approximately 200 m3

 (7060 ft3) of the total waste 

volume. Onsite treatment includes up to 120 m3 (4238 ft3) of mixed low-level waste 

(MLLW) solids, 12 m3

 (424 ft2) of 99Tc-contaminated MLLW, and 10 m3 (353 ft2) of 

TRU waste. On-site treatment technologies are limited by the Paducah Site Resource 

Conservation and Recovery Act of 1976 (RCRA) Part B permit. RCRA-permitted on-site 

treatment technologies include sedimentation, precipitation, oxidation, reduction, 

neutralization, cementation/solidification, carbon adsorption, photocatalytic conversion, 

and lime precipitation. Currently, only neutralization, stabilization, carbon adsorption, 

and photocatalytic conversion are planned on-site. These are the only technologies 

discussed in subsequent sections because they are the ones applicable to the waste types 

presented. Building C-752-A has been proposed as the site for processing any on-site 
2

waste that needs to be treated indoors. Building C-746A is the proposed location for light 

bulb crushing. 

Approximately 52 m3 (1836 ft3)/year of low-level waste (LLW) wastewater would 

also be treated on-site. Wastewater would be treated on-site by carbon adsorption, 

photocatylic conversion, and/or lime precipitation. These treatment activities would be 

compliant with the applicable Kentucky Pollutant Discharge Elimination System 

(KPDES) permit(s). 

1.3 WASTE TREATMENT – OFFSITE 

DOE’s revised proposed action for off-site treatment varies by waste type. The 

characteristics of the waste govern where and how each waste type may be treated. The 

preferred treatment scenario for each type of currently known waste is listed below. 

Fifty metric tons of capacitors containing polychlorinated biphenyls (PCBs) are 

proposed for shipment to Deer Park, Texas, for treatment and disposal. The capacitors 

would be shipped in 23 7A, Type A containers. Thirteen empty transformers weighing 78 

metric tons would be shipped for off-site treatment and disposal as well. These 

transformers contain some residual PCB contamination. 

The 5355 m3

 (189,110 ft3) of MLLW addressed in the revised proposed action 

represents a very heterogeneous grouping of wastes; most of this waste will be treated 

and disposed at off-site, permitted facilities. A small portion contains PCBs, metals, and 

organics, and it is proposed that they be treated at the DOE Toxic Substances Control Act 

of 1976 Incinerator in Oak Ridge, Tennessee. 

1.4 WASTE TRANSPORTATION 

The representative truck and rail routes previously identified in the Waste 

Disposition EA are applicable to the revised proposed action. However, the projected 

number of waste shipments has changed from the previously analyzed shipment rate of 

762 shipments per year. The 17,600 m3

 of additional waste and materials would be 

transported in shipments of 18.2m3 each. Assuming the disposition of additional waste 

takes place over 10 years, which is consistent with the Waste Disposition EA analysis 

assumptions, a resulting additional shipment rate of 97 shipments per year is projected. 

Therefore, the revised annual shipment rate for waste shipments would include the 

original 762 shipments analyzed in the Waste Disposition EA, and the 97 additional 

shipments included in the Waste Disposition EA Addendum, resulting in 859 waste 

shipments per year for 10 years. 

Waste will generally be transported by truck but may also be transported by rail or 

intermodal carrier when advantageous. DOE currently anticipates that the waste would 

be disposed primarily at the DOE Nevada Test Site although disposition at the Hanford 

Site and commercial facilities, such as Envirocare of Utah, Inc. and Waste Control 

Specialists, LLC in Texas, are also analyzed as possible locations. 
3

1.5 WASTE DISPOSAL 

DOE’s revised proposed action for waste disposal varies by waste type. The 

characteristics of the waste govern where and how each waste type may be disposed. The 

volume of wastes to be transported from the Paducah Site to each proposed receiving 

facility represents only a small portion of the total waste each facility receives annually. 

For example, it has been proposed that approximately 3750 m3

 (132,430 ft3) of 

radiological PCB wastes be shipped to the Envirocare facility in Utah over the 10-year 

evaluation period resulting in an average of 375 m3 (13,243 ft3) per year. The Envirocare 

facility annually receives 9061 m3 (320,000 ft3) of waste; therefore, the annual Paducah 

Site shipment will represent less than 5 percent of the facility’s capacity in any given 

year. The preferred alternative for each waste type is listed below. 

Capacitors containing PCBs are proposed for shipment to Deer Park, Texas, for 

treatment and disposal. Thirteen empty transformers would be shipped for off-site 

treatment and disposal as well. These transformers contain some residual PCB 

contamination. 

Approximately 4600 m3

 (60,166 yd3) of LLW would be disposed, primarily at the 

Nevada Test Site. Only the LLW water waste stream consisting of 52 m3 (1836 ft3) of 

waste would be treated and disposed on-site. The wastewater, which has some uranium 

contamination, would be treated until the KPDES limits had been met; this waste would 

then be discharged at a permitted on-site outfall. In addition to these wastes, there are 

22 T-Hoppers (5-ton containers) of UF4 stored at the site. If it is determined that this 

material is a waste, it would likely be shipped as a LLW to the Nevada Test Site. 

Some MLLW would be shipped to Envirocare for treatment and disposal. 

Approximately 160 m3 (5650 ft3) would be shipped to one or more of the Broad 

Spectrum Contractors (i.e., Waste Control Specialists LLC, Andrews, Texas; Allied 

Technology Group, Richland, Washington; Materials and Energy/Waste Control 

Specialists, Oak Ridge, Tennessee). 

Approximately 10 m3

 of transuranic (TRU) liquids and solids are proposed for 

treatment on-site and shipment to the TRU Waste Program at Oak Ridge National 

Laboratory for ultimate disposition. Impacts associated with further processing and 

shipment to the Waste Isolation Pilot Plant near Carlsbad, New Mexico, are addressed in 

the final environmental impact statement for treating TRU and alpha LLW (DOE 2001a). 

1.6 SUPPORTING ACTIVITIES 

The revised proposed action for supporting waste disposition activities is to perform 

these activities in accordance with DOE orders, federal and state regulations, and 

approved Bechtel Jacobs Company LLC (BJC) or BJC subcontractor procedures. These 

activities are performed mainly during waste management and maintenance at the 

Paducah Site. Applicable procedures are implemented to ensure that activities are 

performed in a safe and accountable manner. Examples of supporting activities include, 

but are not limited to, the following: 
4

• waste staging, 

• on-site waste movement, 

• packaging/repackaging, 

• sorting, 

• waste container decontamination, 

• inspection, 

• marking/labeling, 

• characterization, and 

• facility modifications or upgrades. 

2. STATUS AND BIOLOGY OF THE LISTED SPECIES 

As reported in the Biological Assessment (BA) for the Paducah C-746-U Landfill 

Implementation of the Authorized Limits Process (DOE 2001), informal consultations 

regarding the Indiana bat (Myotis sodalis) were conducted in May 2001 with the U.S. 

Fish and Wildlife Service (FWS), Kentucky Department of Fish and Wildlife Resources 

(KDFWR), and the Kentucky State Nature Preserves Commission (KSNPC) to ascertain 

the potential presence of any listed species. The FWS identified the Indiana bat as a 

Federally endangered species that could potentially occur near the site (FWS 2001). The 

Indiana bat is also listed as an endangered species by the Commonwealth of Kentucky. 

The KSNPC reported an occurrence of the Indiana bat in McCracken County (2000), but 

not at the Paducah site (DOE 2001a). This reported occurrence in McCracken County, a 

result of mist netting, was made in June 1991 and was on West Kentucky Wildlife 

Management Area (WKWMA) land in the Joppa Quadrangle near the Shawnee Steam 

Plant (Hines 2001). More recently, five individuals of the Indiana bat, Myotis sodalis, 

were captured in riparian hardwood habitat of the lower downstream reaches of Bayou 

Creek in the WKWMA during mist netting surveys in 1999 (KDFWR 2000). These 

locations were to the north of the Paducah Site. No mist net surveys have been conducted 

within the Paducah Site fence. 

The KSNPC also reported the presence of the orange-footed pimpleback 

(Plethobasus cooperianus), pink mucket pearly mussel (Lampsilis arbrupta), ring pink 

(Obovaria retusa), fat pocketbook (Potamilis capax) in the vicinity of Ohio River miles 

945 through 949. Most recent observations of these species in the area occurred between 

1992 and 1999 (KSNPC 2000). 

As a result of these sightings, DOE has prepared this BA considering potential 

impacts of the revised proposed action to the Indiana bat, orange-footed pimpleback, pink 

mucket pearly mussel, ring pink, and fat pocketbook. 
5

2.1 INDIANA BAT (MYOTIS SODALIS) 

The general ecology of the Indiana bat is summarized as follows. Unless otherwise 

noted or referenced, general biological information on the species is derived from Harvey 

(1992 and 1999) and Webb (2000). 

The range of the endangered Indiana bat is the eastern United States from Oklahoma, 

Iowa, and Wisconsin east to Vermont and south to northwestern Florida. Distribution is 

associated with major cave regions and areas north of cave regions. The present total 

population is estimated at ca. 352,000 with more than 85 percent hibernating at only nine 

locations - two caves and a mine in Missouri, three caves in Indiana, and three caves in 

Kentucky. 

Indiana bats forage in and around tree canopies of floodplain, riparian, and upland 

forest. In riparian areas, Indiana bats primarily forage around and near riparian and 

floodplain trees (e.g., sycamore, cottonwood, black walnut, black willow, and oaks), and 

solitary trees and the forest edge on the floodplain. Streams, associated floodplain forests, 

and impounded bodies of water (e.g., ponds, wetlands, and reservoirs) are the preferred 

foraging habitat for pregnant and lactating Indiana bats, some of which may fly up to 1.5 

miles from upland roosts. Indiana bats also forage within the canopy of upland forests, 

over clearings with early successional vegetation (e.g., old fields), along the borders of 

croplands, along wooded fencerows, and over farm ponds in pastures. Indiana bats return 

nightly to their foraging areas. Indiana bats feed strictly on flying insects and their 

selection of prey items reflects the environment in which they forage. Both aquatic and 

terrestrial insects are consumed. Moths, caddisflies, flies, mosquitoes, and midges are 

major prey items. Other prey include bees, wasps, flying ants, beetles, leafhoppers, and 

treehoppers. 

Indiana bats hibernate in limestone caves from October to April, depending upon 

climatic conditions. Indiana bats usually hibernate in large, dense clusters of up to several 

thousand individuals in sections of the hibernation cave where temperatures average 38 to 

43°F and with relative humidities of 66 to 95 percent. Bat clusters may contain 300 to 

384 bats per square foot. The bats leave the caves and migrate to summer roosts in midspring. 

Summer roosting-habitat criteria for Indiana bats are frequently revised as more is 

discovered about this species’ habits. The most recent information applicable for the 

region is available from the FWS Cookeville Office (Components of Suitable Habitat for 

the Endangered Indiana Bat). In general, Indiana bats establish summer maternity and 

sometimes male night roosts or bachelor colonies under the loose bark of large, usually 

hardwood trees (> 20 cm diameter). Indiana bats have been observed to return to the 

same roosting and foraging habitat year after year. Indiana bats forage at night and feed 

on insects. 

Female Indiana bats depart the caves before the males and arrive at summer 

maternity roosts in mid-May. A single offspring, born in June, is raised by the mother 

under loose tree bark, primarily in wooded streamside habitat. Mothers and babies reside 
6

in maternity colonies that use multiple, primary roost trees throughout most of the 

summer. Secondary roosts are used intermittently by some of the bats, particularly during 

periods of extreme precipitation or extreme temperatures. Thus, there may be more than a 

dozen roosts used by some Indiana bat colonies. Kurta et al. (1996) found that female 

Indiana bats may change roosts about every three days, and a group of these bats may use 

more than 17 different trees in a single maternity season. They depart the summer roosts 

for hibernation caves in September. The summer roost of the adult males is often near the 

maternity roost, although a few males do stay in caves over the summer. 

In 1974 the first maternity colony was discovered under the loose bark of a dead 

butternut hickory tree in east-central Indiana. The colony numbered about 50 individuals 

and also used an alternate roost under the bark of a living shagbark hickory tree. The total 

foraging range of the colony consisted of a linear strip along approximately 0.5 miles of 

creek. Foraging habitat was confined to air space from 6 ft to ca. 95 ft high near the 

foliage of streamside and floodplain trees. Two additional colonies were discovered 

during subsequent summers, also in east-central Indiana. These had estimated populations 

of 100 and 91 respectively, including females and pups. Habitat and foraging areas were 

similar to the first colony discovered. Evidence gathered during recent years indicates 

that, during summer, Indiana bats are widely dispersed in suitable habitat throughout a 

large portion of their range. Additional maternity colonies have been discovered using 

radiotelemetry techniques in more recent years. Data thus far reinforce the belief that 

floodplain forest is an important habitat for Indiana bat summer populations. However, 

colonies have been located in upland and in coniferous habitats as well. 

A longevity record of 13 years and 10 months has been recorded for the Indiana bat. 

Hibernating bats leave little evidence of their past numbers; thus, it is difficult to 

calculate a realistic estimate of the population decline for this species. However, 

population estimates at major hibernacula indicated a 34 percent decline in the total 

Indiana bat population from 1983 to 1989. 

2.2 PINK MUCKET PEARLY MUSSEL (LAMPSILIS ARBRUPTA SAY-1831; 

ALSO CALLED L. ORBICULATA HILDRETH-1828) (Conservation 

Management Institute 2001, EPA 2001) 

The Federally endangered pink mucket pearly mussel (41 FR 24062; June 14, 1976) 

is a bivalve aquatic mollusk in the Unionidae family with an elliptical-shaped shell. The 

species is generally about 10.2 cm (4 inches) long, 6.1 cm (2.4 inches) wide, and 7.6 cm 

(3 inches) high. The valves are heavy and thick. The species is sexually dimorphic, with 

both males and females having rounded anterior margins, but males having a pointed 

posterior margin and females a truncated, expanded posterior to accommodate the gravid 

condition. Young mussels have a yellow to brown shell that is smooth and glossy with 

green rays, while older specimens are dull brown. The nacre color varies from white to 

pink, with the posterior margin being iridescent. 

The early life stage of the mussel, glochidium, is an obligate parasite on the gills or 

fins of fish, but the required fish host species are unknown. The adult mussels are filter 

feeders and consume particulate matter that is suspended in the water column. 
7

Identifiable stomach contents from mussels invariably include mud, desmids, diatoms, 

protozoa, and zooplankton. However, studies on the food habits for this species have not 

been conducted, so its specific food requirements are not known. The species has no 

known commercial value. The reproductive cycle of the pink mucket is presumed to be 

similar to that of other freshwater mussels. Males release sperm into the water column, 

which is then taken up by the females during siphoning and results in the eggs being 

fertilized. The embryos develop into the glochidia inside the female and are then released 

into the water column. The glochidia must then attach to suitable fish hosts for 

metamorphosis to the free-living juvenile stage. There is no information on the 

population biology of this species. 

The pink mucket is found in medium to large rivers. It seems to prefer larger rivers 

with moderate- to fast-flowing water, at depths from 0.5 to 8.0 m (1.6 to 26.2 ft). The 

species has been found in substrates including gravel, cobble, sand, or boulders. Silt clogs 

the species’ siphon, so silty substrates and water columns are not conducive to the species 

being present. Habitat of the glochidia is initially within the gills of the female, then in the 

water column, and finally attached to a suitable fish host. Habitat requirements for the 

juvenile stage are unknown. Any alteration of the life-stage-specific habitats during the 

pink mucket’s lifecycle would likely affect the long-term success of a population. In 

addition, impoundments and surface water contaminants are known to adversely affect 

this species and contribute to its decline in numbers. 

Currently, the pink mucket is known in 16 rivers and tributaries from seven states, 

with the greatest concentrations in the Tennessee (Tennessee, Alabama) and Cumberland 

(Tennessee, Kentucky) rivers and in the Osage and Meramec rivers in Missouri. Smaller 

populations have been found in the Clinch River (Tennessee); Green River (Kentucky); 

Ohio River (Illinois); Kwanawha River (West Virginia); Big Black, Little Black, and 

Gasconde rivers (Missouri); and Current and Spring rivers (Arkansas). 

2.3 ORANGEFOOT PIMPLEBACK (PLETHOBASUS COOPERIANUS) (IDNR 

2001) 

The Federally endangered orangefoot pimpleback mussel (a.k.a orangefoot pearly 

mussel) is a bivalve aquatic mussel in the Unionidae family with a round-shaped shell. 

The shell is thick, moderately inflated to compressed, and contains pustules on the 

posterior three-fourths of the shell. The anterior end of the shell is rounded whereas the 

posterior end is rounded to bluntly pointed. The mussel is light brown in color in small 

specimens, becoming chestnut or dark brown in color in larger individuals. The beak 

cavity is very deep. The nacre is white, usually with pink or salmon tinge near the beak 

cavity. Length ranges up to 4 inches (10.2 cm). The foot of living specimens is orange in 

color. 

Specific reproductive or other life history information for this species was not found 

in the literature. However, the reproductive cycle is presumed to be similar to that of 

other freshwater Unionidae mussels, as previously described for the pink mucket pearly 

mussel. 
8

The orangefoot pimpleback mussel prefers large rivers with gravel or mixed sand 

and gravel substrates. This species does not tolerate silty conditions. 

Information on this species’ historical range was not found in the literature by 

searching the Internet using the keywords “orangefoot pimpleback.” Current range of this 

species includes the Ohio River in reaches adjacent to Ohio, Indiana, Illinois, and 

Kentucky. 

2.4 RING PINK (OBOVARIA RETUSA) 

 The ring pink mussel was listed as an endangered species without critical habitat 

on September 29, 1989 (54 FR 40109). The FWS (FWS 1991) formerly referred to this 

mussel as the golf stick pearly mussel. The ring pink mussel is one of the most 

endangered mussels because all of the known populations are apparently too old to 

reproduce. The ring pink has a medium to large shell that is ovate to subquadrate in 

outline. The exterior of the shell lacks rays and is yellow-green to brown in color, while 

older specimens are usually darker brown or black. The nacre of the shell is usually 

salmon to deep purple in color surrounded by a white border. 

The food habits of this species are unknown, but it likely feeds on detritus, diatoms, 

phytoplankton, and zooplankton. These food items are common for most freshwater 

mussels (FWS 1991). 

The reproductive biology for the ring pink is essentially unknown, but it likely 

reproduces similarly to other freshwater Unionidae mussels as described above for the 

pink mucket pearly mussel. The fish host(s) for the ring pink and habitat utilized by the 

juvenile mussels are unknown. 

This mussel is characterized as a large-river species (FWS 1991). The mussel 

inhabits the sandy and gravelly but silt-free bottoms of large rivers and prefers rather 

shallow water depths (2 ft deep). 

Historically, this mussel was widely distributed and found in several major 

tributaries of the Ohio River, including those that stretched into Alabama, Kentucky, 

Illinois, Indiana, Ohio, Pennsylvania, and West Virginia. However, the species was last 

taken in Pennsylvania in 1908, and in Ohio in 1938 (FWS 1991). According to records, 

this species has not been collected in Indiana in decades, and has not been collected from 

Illinois in over 30 years (FWS 1991). Most of the historically known ring pink mussel 

populations were apparently lost due to conversion of many sections of the large rivers to 

a series of large impoundments. The ring pink mussel does not survive in impounded 

water habitats. 

The ring pink mussel is presently known from only five river reaches, including two 

in Kentucky, two in Tennessee, and one in West Virginia. In Kentucky, the ring pink 

mussel in recent years has only been taken from the Tennessee River in McCracken, 

Livingston, and Marshall Counties, and from the Green River in Hart and Edmonson 

Counties. Only two live specimens have been collected from the Tennessee River 
9

population in recent years; one in 1985 and one in 1986. The last live specimen from the 

Green River was collected in the mid-1960s. Two fresh-dead specimens were collected in 

the Green River (one in 1987, the other in 1989) in the reach between Munfordville and 

Mammoth Cave National Park. 

According to the Recovery Plan for Ring Pink Mussel (FWS 1991), total recovery of 

this species is considered unlikely because none of the five extant populations are known 

to be reproducing. Therefore, unless reproducing populations can be found or methods 

can be developed to maintain or create new populations, the species will be lost in the 

foreseeable future. 

2.5 FAT POCKETBOOK (POTAMILIS CAPAX) (Earth’s Endangered Creatures 

2001, IDNR 2001) 

The fat pocketbook mussel was listed as a Federally endangered species in 1976 (41 

FR 24064). Green first described the mussel in 1832 under the name Unio capax. The 

genus was changed to Lampsilis by Smith (1899), then moved to the genus Proptera

Ortman (1914). In 1969, Morrison noted that Rafinesque (1818) has named this genus 

Potamilus. Since 1988, the genus name for this species has been Potamilus. 

The fat pocketbook mussel has a quite rounded and inflated shell that is thin to 

moderately thick. The shell is shiny and smooth, yellow to brown in color, and lacks any 

distinctive markings. It has an S-shaped hinge line that distinguishes it from similar 

species. The beak cavity is very deep. The nacre is white, sometimes tinged with pink or 

salmon color. Shell length is up to 5 inches (12.7 cm). 

The reproductive biology for the fat pocketbook is essentially unknown, but it is 

likely similar to that of other members of the Unionidae as described above for the pink 

mucket pearly mussel. The fat pocketbook mussel is probably a long-term breeder and is 

reported gravid in June, July, August, and October (FWS 1989). The fish host species are 

not known but are likely large river species. Fish hosts known for other mussels of this 

genus include freshwater drum (Aplodinotus grunniens), white crappie (Pomoxis 

annularis), and blackstripe topminnow (Fundulus notatus). 

The fat pocketbook mussel inhabits rivers and streams with sand, mud, or gravel 

substrates. It prefers slow-flowing water where depths range from a few inches to 8 ft. 

The mussel buries itself in these substrates with only the edge of its shell and its feeding 

siphons exposed. 

There are few published records on the historical distribution of this species for the 

period prior to 1970. Museum records indicated that most fat pocketbook occurrences 

were from three areas; the upper Mississippi River (above St. Louis, Missouri), the 

Wabash River in Indiana, and the St. Francis River in Arkansas. There are a few historic 

records of this species occurring in the Illinois River, but is has not been found in recent 

years (FWS 1989). 
10

Currently, the fat pocketbook in the mid-west is found only in the lower Wabash 

River in Indiana, the Ohio River adjacent to Kentucky, Indiana, and Illinois, and in the 

lower Cumberland River in Kentucky. Farther south, this species is known to exist in the 

St. Francis floodway (west of the flood control levee) from the confluence with the St. 

Francis River upstream to the confluence of Iron Mines Creek, and numerous drainage 

ditches associated with these streams in Arkansas (FWS 1989). 

3. ECOLOGICAL DESCRIPTION OF THE SITE 

The Paducah Site consists of existing industrialized areas of the Paducah Gaseous 

Diffusion Plant and is near the WKWMA on the site’s western side. The majority of the 

fenced site has been cleared and, where vegetative cover is present, is maintained by 

mowing. Vegetation on the site consists of grasses and other herbaceous ground cover, 

which provides no foraging or roosting habitat for the Indiana bat. 

The Paducah Site is located in the western part of the Ohio River Basin. The 

confluence of the Ohio and Tennessee rivers is approximately 16 km (10 miles) upstream 

of the site. The confluence of the Ohio River with the Mississippi River is approximately 

32 km (20 miles) downstream of the site. All mussel species listed in the FWS letter are 

present in the Ohio River, upstream of the Paducah Site. 

The Paducah Site is located on a local drainage divide; surface flow is to the east and 

northeast toward Little Bayou Creek and to the west and northwest toward Bayou Creek. 

The confluence of the creeks is approximately 5 km (3 miles) north of the site. Little 

Bayou Creek originates in the WKWMA and flows north toward the Ohio River along a 

10.5-km (6.5-mile) course through the eastern portion of the DOE reservation. These 

tributaries are partially bordered by a thin riparian zone of plants. Trees, when present in 

close proximity to the site, mainly occur along the two tributaries, and are generally less 

than 20 cm in diameter at breast height and do not have loose bark as required by 

roosting Indiana bats. The riparian area could provide foraging habitat but no roosting 

habitat for the Indiana bat. No mussel species of concern have been identified in the 

tributaries. 

Although the site has no hibernating, roosting, or foraging habitat as described above, 

the creeks within an expanded area around the site do provide Indiana bat summer foraging 

habitat. No maternity roosts have been located on the WKWMA, but five individuals, 

including three juveniles, were captured in the WKWMA during mist netting surveys in 

1999 (KDFWS 2000) and a single specimen was reported in 1991 (KSNPC 2000). 

The nearby WKWMA consists primarily of stands of bottomland hardwoods 

interspersed with upland hardwoods and old fields. Potential summer roosting and 

foraging habitats for the Indiana bat are present in the WKWMA, although most trees are 

less than 20 cm in diameter (see reported identifications below). The Bayou Creek 

(formerly known as Big Bayou Creek) is the nearest blue-line stream in the area; the 

nearest of its tributaries to the site are on the western side of the WKWMA. 
11

4. POTENTIAL IMPACTS TO INDIANA BAT 

 The revised proposed action would not entail alteration or loss of bat habitat 

because it would take place at an existing site using existing buildings. Opportunities for 

bats to come into contact with the waste, either directly or indirectly, are virtually 

nonexistent since the wastes are contained within storage facilities. During waste 

disposition activities that would occur outside, such as transport, waste handling procedures 

would be followed and the waste would be properly packaged and covered; thus, not 

providing access to bats or insects on which the bats may feed. 

The only scenario that could result in exposure of bats to the wastes would be an 

accidental release of wastes into the environment. Risks to terrestrial biota resulting from 

site accidents are addressed in the Waste Disposition EA and are summarized as follows. 

The scenario for chronic radionuclide exposure as a result of the modeled worst-case 

spill indicated that the sum of chronic terrestrial exposures would be about 7 × 10-10 of 

the tolerable daily radiation dose as indicated by no-further-action (NFA) levels; 

therefore, in even this worst-case accident scenario, long-term radiation effects to soil 

biota would be negligible. 

Two organics (PCB and 1,2,4-trichlorobenzene) and two inorganics (cadmium and 

chromium) have modeled concentrations that exceed the NFA benchmarks. This 

indicates that these constituents would likely pose adverse impacts to soil biota if the 

worst-case spill accident occurred. However, any insects that the bats may eat could only 

ingest or come into contact with the waste if they were present on the exact location 

where the accident occurred. These insects would then need to be available as prey for 

the bats, or as prey for other insects that the bats forage on, in order for radioactivity from 

waste to be ingested by an Indiana bat. 

With the increase in traffic associated with the revised proposed action there is an 

increase in the potential risk of bat exposure to emissions and vehicle accidents resulting 

in animal fatalities. However, these potential impacts are estimated to be de minimus

given that bat foraging habitat (around tree canopies of riparian and upland forest) and 

roosting-habitat (under the loose bark of large hardwood trees) occur in wooded areas not 

likely to be present near proposed transportation routes. 

5. POTENTIAL IMPACTS TO MUSSELS 

Potential impacts of the revised proposed action were evaluated for the orangefoot 

pearly mussel, as well as for aquatic biota, and presented in the Waste Disposition EA. 

The Waste Disposition EA concluded that none of the seven radionuclide or nine 

chemical contaminants exceeded radiological or toxicological benchmarks for aquatic 

biota as a result of any waste storage, water treatment, waste disposal, or supporting 

activities associated with the revised proposed action. The Waste Disposition EA stated 

that during a worst-case accident scenario (earthquake), sufficient PCBs potentially could 

reach the Ohio River and slightly exceed the toxicological benchmark for aquatic biota. 
12

However, the modeled PCB concentration for the earthquake accident scenario was very 

conservative because it assumed that all of the PCB released during the accident made its 

way from the Paducah site into the Ohio River, which is nearly 5 miles downstream along 

Bayou Creek. In addition, the contaminants would be diluted and represent a negligible 

addition to those already in the Ohio River. The Waste Disposition EA concluded that the 

addition of contaminants from the worst-case accident would result in sediment 

concentrations within the measured variability reported for Ohio River sediments. As a 

result, the Waste Disposition EA concluded that the contaminants reaching the Ohio River 

from the Revised proposed action and the worst-case accident scenario would cause 

negligible adverse impacts to the orangefoot pearly mussel as well as other aquatic biota. 

Additional evidence indicates that the four endangered mussels addressed in this BA 

are at a negligible risk of adverse impact from the revised proposed action. None of the 

four endangered mussels are known to occur on the Paducah Site where the revised 

proposed action activities would take place. In addition, none of the endangered mussels 

occur in Bayou Creek or Little Bayou Creek because these creeks are too small to 

provide the necessary habitat requirements for the mussels. The only water body that 

potentially could harbor the four endangered mussels and potentially be impacted from 

the revised proposed action is the Ohio River. As previously stated, the Waste 

Disposition EA (DOE 2002) indicated that potential adverse impacts to the orangefoot 

pearly mussel in the Ohio River downstream of the confluence of Bayou Creek should be 

negligible to non-existent. Thus, the similarity of the known life history and habitat 

requirements for the four Unionidae endangered mussels makes it reasonable to conclude 

that the pink mucket, ring pink, and fat pocketbook mussels are also not at risk of adverse 

impacts from the revised proposed action. 

The revised proposed action may raise the potential risk of mussel exposure to waste 

resulting from increased vehicle traffic and a corresponding potential increase in 

vehicular accidents. This potential increase in accidents could result in a release of the 

waste volume being transported on the truck. However, when compared to the potential 

impacts evaluated in the worse case accident scenario, in which the release was based on 

the entire volume of wastes stored on the site, these impacts are deemed negligible. 

6. CONCLUSIONS 

The revised proposed action would be unlikely to adversely affect the Indiana bat or 

any mussel species of concern because: 

• A potential for exposure of the bat and mussel species to waste as a result of an 

accident during implementation of the revised proposed action would be small and 

impacts would be negligible or nonexistent; 

• Waste disposition activities are currently being performed at the Paducah Site with 

no known detriment to the local Indiana bat or mussel populations; 

• No bat foraging or roosting habitat is present where waste handling activities would 

occur or along any proposed transportation routes. Therefore, no bat foraging or 

roosting habitat would be affected by routine waste disposition operations; 
13

• The majority of mussel habitat in the area has been identified upstream from the 

Paducah site; no mussel habitat exists inside the site fence therefore no habitats 

would be affected by the revised proposed action; 

• Bat foraging habitat (riparian vegetation along intermittent tributaries) present near 

the site of the revised proposed action is unlikely to become contaminated; 

• Routine waste management operating procedures would provide minimal 

opportunity for direct exposure of local biota, including Indiana bats and their prey, 

to wastes. Procedure implementation would also decrease the probability of 

accidents; and 

• No critical bat or mussel habitats are present at the Paducah Site. Therefore, no 

habitat alteration or destruction would occur as a result of the revised proposed 

action. 
14

7. REFERENCES 

Conservation Management Institute 2001. 

http://fwie.fw.vt.edu/WWW/esis/lists/e404009.htm 

DOE 2001. Environmental Assessment on the Implementation of the Authorized limits 

Process for Waste Acceptance at the C-746-U Landfill, Paducah Gaseous Diffusion 

Plant, Paducah, Kentucky, March. 

DOE 2002. Environmental Assessment for Waste Disposition Activities at the Paducah 

Site Paducah, Kentucky, DOE/EA-1339, Office of Environmental Management, Oak 

Ridge, TN. 

DOE 2003. Environmental Assessment Addendum for Disposition of Additional Wastes at 

the Paducah Site Paducah, Kentucky, DOE/EA-1339-A, Office of Environmental 

Management, Oak Ridge, TN. 

Earth’s Endangered Creatures 2001. 

wysiwyg://65/http://www.geocites.com/endangeredsp/NAmericaFSO10.html 

EPA (U.S. Environmental Protection Agency) 2000. 

http://www/epa/gov/espp/arkansas/seviert.htm 

FWS (U.S. Fish and Wildlife Service) 1989. Recovery Plan for the Fat Pocketbook 

Pearly Mussel Pink Mussel (Potamilus capax) (Green 1832), Atlanta, GA, 22 pp. 

FWS 1991. Ring Pink Mussel Recovery Plan, Atlanta, GA, 24 pp. 

FWS 2003. Letter from Dr. Lee A. Barclay, FWS, to Dr. James L. Elmore, DOE, June 

17. 

Harvey, M. J., J. S. Altenbach, and T. L. Best 1999. Bats of the United States, Arkansas 

Game and Fish Commission and U.S. Fish and Wildlife Service, 64 pp. 

Harvey, Michael J. 1992. Bats of the Eastern United States. Arkansas Game and Fish 

Commission and U.S. Fish and Wildlife Service, 46 pp, February. 

Hines, Sarah 2001. Personal communication regarding a reported sighting of Myotis 

sodalis between Sarah Hines, Data Specialist, Kentucky State Nature Preserves 

Commission and Anne Dickie, Scientist, Tetra Tech, Inc., July 9. 

IDNR (Illinois Department of Natural Resources) 2001. 

http://www.inhs.uiuc.edu/cbd/musselmanual/page54_5.html 
15

KDFWR (Kentucky Department of Fish and Wildlife Resources) 2000. James S. Lane, 

Jr., Author. Mist Net Surveys for the Indiana Bat (Myotis sodalis) at West Kentucky 

Wildlife Management Area Paducah, Kentucky, February. 

KSNPC (Kentucky State Nature Preserves Commission) 2000. Monitored Species of 

McCracken County Kentucky. Online reports at http://www.kynaturepreserves.org

accessed June 25, 2001. 

KSNPC 2000, Kentucky State Nature Preserves Commission. Response to Data Services 

Request from SAIC. Request number 01-078. November, 14, 2000. 

Kurta et al. 1996. Ecological, Behavioral, and Thermal Observations of a Peripheral 

Population of Indiana Bats (Myotis sodalis). Pages 102-117 in R. M. R. Barclay and R. 

M. Brigham, editors, Bats and Forests Symposium, Research Branch, Ministry of 

Forests, Province of British Columbia, Victoria, British Columbia. 

Webb, Warren 2000. Biological Assessment NABIR Project, Selection and Operation of 

the Proposed Field Research Center on the Oak Ridge Reservation
U.S. Department of Energy Paducah Site 

DOE/EA-1339A 

Appendix D 

Draft EA Comments Received and Responses 
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

Comment 

No. 

Page/ 

Section Comment DOE 

Robert A. Carson, Illinois Environmental Protection Agency 

1. General The Department of Energy should contact the Illinois Department of Nuclear Safety 

at least five working days prior to initiating any radioactive waste shipping campaign that will involve transport through the State of Illinois. This notification should include waste description, container type, vehicle type, route and expected dates of shipment. The notification should be provided to: Gary N Wright, Director Illinois Department of Nuclear Safety 1035 Outer Park Drive Springfield, Illinois 62704 217-785-9868 Illinois DNS requests this information so that their duty officers and potential responders will have essential information in the case of a shipment problem. 

DOE will provide the 

2. The Waste Disposition EA identified one of the roads to be utilized for waste 

transport through Illinois as I-65. This should be corrected to “I-64”. 

Transportation documthis correction. This nWaste Disposition EA document was not mo
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

Ruby English, Neighbor and ACT Chairman (Active Citizens for Truth)

3. General With the decision to proceed with disposition of additional low-level waste now 

rather than waiting until D&D occurs, I would like to know more about the 17,600 m3 of low-level waste and the 11,000 m3 of various waste types in the Waste Disposition DOE/EA-1339. 

The 17,600 m3 of matDOE Material Storage the site. This material process equipment (e.discarded furniture, an

polychlorinated bipheradioactive waste (LLitems. The text of the EnviroAddendum will be revm3 of additional materadioactive waste. Thcharacterized and displow-level radioactive C-746-U Landfill. 
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

4. General When you talk about on-site disposal, I am concerned about the C-746-U Landfill for 

the additional 7,900 m3 to be put in this landfill. As a neighbor, what guarantee do I have that no hazardous waste of any kind will go in this landfill. The contamination from previous dumping has not been cleaned up and this only makes me think that the Paducah Gaseous Plant will only become a dumping ground for more locations in the near future. 

The process for waste Landfill, as well as the disposal, are evaluated assessments – EnvironConstruction, OperatiWaste Landfill at the PPlant, Paducah, Kentuin March 1995 and Thon the Implementation Process for Waste AccLandfill Paducah GasPaducah, Kentucky (DAugust 2002. Materiathe C-746-U Landfill discussed in these EAof the landfill permit aacceptance criteria, wWaste Management (Koversight responsibilitradioactive, or mixed this landfill. 

5. General Would you furnish more information as to the types of waste the 45% (7,900 m3) 

would be put into the C-746-U Landfill. Since, this is a Subtitle D Landfill and not a Subtitle C Landfill, I am concerned about what the 45% waste would consist of that would be stored in this landfill. 

As the materials are chdisposition will be detlandfill permit and wadisposed in the C-746level radioactive, or min this landfill. 

6. General In reference to the 7,900 m3 going into the C-746-U Landfill I am really concerned 

that more hazardous waste will be put in this landfill. Two cells already contain 

hazardous waste, supposedly put there by error. Notice of Violations issued to Bechtel Jacobs for this hazardous waste being put there has not remedied the 

problem I have with more waste going to this landfill by mistake. Maybe, people who do not reside in this area of the plant think that everything is okay and there is no harm to the neighbors or community, but, I disagree with these assumptions that are put out to the public. 

See response to Comm
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

7. General This additional waste should be figured in and included in the original scope instead 

of being overlooked. Since, the Environmental Assessment (DOE/EA-1339) has already been finalized, there should not be an addendum to this assessment. Let the 17,600 m3 stay where it is until the D&D is started. 

DOE recently funded affecting the Paducah materials is part of thaanalyzes the environm

activities involving th

8. General In the Final Environmental Assessment DOE/EA-1414, (Waste Acceptance at the C746-U Landfill) of July, 2002, it states that the determination of whether to place 

CERCLA-derived materials in the landfill is beyond the scope of the proposed action, potential impacts associated with the potential disposition of CERCLAderived materials are properly considered within the scope of this cumulative impacts analysis since such disposition may in fact occur. My opinion is that no CERCLA-derived materials should be allowed in the C-746-U Landfill. Will this Subtitle D Landfill permit be adhered to or will this addendum open the way for such materials to be put in this landfill? 

The EA Addendum doderived wastes. DOE permit and waste accebe disposed in the C-7

9. General Thank you for taking the time to read these comments and questions. I do expect a 

copy of the final assessment DOE/EA-1339-A when it is completed. 

Comment noted. Youdistribution list for the 

Charles Jurka and Vicki Jurka 

10. General This document, the Draft Environmental Assessment Addendum (for) Disposition of 

Additional Waste at the Paducah Site, May 2003 (DOE/EA-1339-A) clearly states DOE’s intention to dispose low-level waste on-site in the C-746-U landfill. The Final Environmental Assessment for Waste Disposition Activities at the Paducah Site Paducah, Kentucky November 2002 (DOE/EA-1339-Final), which this addendum amends, clearly states (pg. 15) that “... on-site disposal of all wastes ... was not considered reasonable.” Even though the draft version contained the same language regarding on-site disposal, we requested as part of the public comment process, that “particular attention ... be given the future impact of long-term on-site disposal (i.e. landfills).” The response in the Final EA stated “no on-site disposal is considered within the proposed action of this document.” (K,pg. 10-#1) However, this addendum (pg 2-1.2) says even though 45% (4,900 m3) of the additional waste may be sent to the C-746-U landfill for disposal, now the only issue 

a reviewer can consider is the “potential transportation of all 28,600 m3 of low-level waste offsite for disposal” because on-site disposal is considered elsewhere and “not within the scope of this EA Addendum”. The Final EA (pg. 15) clearly shows transportation was not the only issue causing the DOE to find on-site disposal an 

unreasonable alternative. “The need for new landfill cells” as well as opposition “by 

DOE completed DOEto evaluate what waste disposal in the C-746-Addendum (DOE/EAwaste that meets the clandfill will be placed waste do not meet the Addendum will be revDOE recently funded affecting the Paducah materials is part of thaanalyzes the environm

activities involving thenvironmental impact746-U Landfill were eand DOE/EA-1046, anthe EA Addendum. 
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

local residents” were important components of DOE’s decision not to further evaluate on-site disposal. (EA Final, Pg. 12-2.1.7) Under the proposed action 20,000 m3 of DOE Material Storage Area (DMSA) waste required Nuclear Criticality Safety (NCS) characterization. “DOE’s proposed action includes (d) this type of characterization” (NCS) but did not include the environmental impact of the additional 20,000 m3 of DMSA waste. Now, approximately six months later, this addendum attempts to incorporate 17,600 m3 of the 20,000 m3 of DMSA waste even though the NCS characterization is still incomplete (EA Addendum pg.2-1.2: “until characterization of the waste is complete”). In the final EA the figures used to determine risk should be adjusted upward by approximately 200% because only approximately 1/3 of the waste identified as “disposition waste” was included in all types of analysis. Additionally it is our concern that much of the waste will ultimately be improperly characterized; as happened with past shipments of waste to NTS and Envirocare. 

The 17,600 m3 is a rem3 reported in DOE/EYour concerns regardiand shipment of wastenoted. Additional actiincluding the modificaimprove the characterto prevent improper w

11. It is our opinion that in the Final EA DOE misleads stakeholders as to the actual 

disposition of large quantities of LLW and MLLW. This is demonstrated in table 1.1 (pg. 1) where under the proposed disposal option LLW and MLLW are cited X

(LLW) and X (MLLW) for on-site disposal and X (LLW) and X (MLLW) for offsite disposal; leaving only the reader to discern what X signifies as that symbol is not 

otherwise in the table. Stakeholders are also mislead (EA Final pg. 9-2.1.1) when under the proposed action they are assured “DMSA wastes that are not characterized as RCRA/TSCA waste would remain in storage until analyzed during D & D CERCLA actions.” Then, approximately six months later DOE decides (EA Addendum, pg.1-last para.) “to proceed with disposition of additional low-level waste in a timelier manner under the authority of the Atomic Energy Act, rather than waiting until D & D occurs.” It is our opinion that at the time of issuance of the Final EA, DOE knew the Atomic Energy Act allowed them to dispose DMSA waste, generally characterized as RCRA waste contaminated with low-level material in the C-746-U Landfill as well as send it to other approved sites. Lengthy and contentious litigation between DOE and the State of Kentucky had established what DOE could and could not do in that regard (United States v Kentucky-NO.00-5247, 6th Cir., June 

5, 2001). Yet, DOE chose to misrepresent on-site disposal and disposition of DMSA 

The character X is an 

out. The character shothe document but was However, the table coMLLW are to be dispoAt this time, 58% of thin DMSAs has been cless than 0.1% has beehazardous. No RCRAmixed wastes will be dlandfill. 
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

waste in the EA Final where the proposed action and alternatives were considered in the total scheme rather that under the single issue of transportation as in the EA Addendum. 

12. (EA Final, Pg. 5-Aquatic Biota) Further, the determination that “long-term impacts 

to aquatic biota would be beneficial after implementation of the proposed action, because much of the on-site waste would be removed reducing the amount stored onsite” becomes a very false premise when (EA Addendum, pg.5-4.1.3.1, 1st para.) “a 

large portion of the additional (DMSA) waste may be disposed on site.” To move stored and monitored waste to a leaky landfill in a wet environment would have anegative rather than positive affect. Additionally it is a false premise (EA Addendum, pg. 1-1.1, last para.) that DOE would “experience cost savings through reduction of surveillance and maintenance costs” if the waste is dispositioned to the on-site C-746-U landfill. The expense would still be Paducah Site expense shifted to leachate control, landfill monitoring and surveillance, etc. It is also false that (EA Final, pg.49-4.1.1.1, WD) “no (land use) impacts are anticipated at the Paducah site “because all of the wastes are proposed to be disposed off-site...” (EA Addendum, Pg. 1-1.0) “DOE must comply with ..NEPA by considering .... potential environmental impacts.” It is obviously the intent of Kentucky regulators to limit the amount of radioactively contaminated waste entering the C-746-U landfill as a means of protecting public health and the environment. By deferring to the AEA and not attempting to endorse or include more stringent environmental and health protective measures, DOE demonstrates a callous disregard for the protective measures provided under NEPA. Further, if DOE was indeed concerned about the “risk of spread of contamination to the environment” they would not transport approximately 7,900 m3 of low-level waste to the on-site C-746-U Landfill where, 

within the 10 year timeframe for waste disposition activities, that risk will become a reality. And finally, (EA final, pg. 30-3.9.2, 2nd. Para.) “because any adverse health or environmental impacts are likely to fall most heavily on the individuals nearest the Paducah facility” we oppose the proposed action and tentatively support the 2.2 Enhanced Storage Alternative for the 17,600 m3 of lo-level waste added to disposition activities via this addendum. 

DOE checked the statAddendum, that “DOE savings through reducmaintenance costs” anaccurate statement. Section 4.1.1 of the EA use impacts from the palternatives. Comment noted regarEnhanced Storage Alt
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

13. 4.1.1 “Land use may change from analysis.” Please clarify what is meant by this sentence. Text has been revised 

change from that analysome of the DMSAs wthe U.S. Enrichment Cmaterials from the DM

14. 1.2 (pg.2) Paragraph one states 17,600 m3 is low-level waste and 11,000 m3 is various types of 

waste. Paragraph two states all of the 28,600 m3 of waste is low-level. 

Text has been revised m3 is material being cdispositioned and is n

15. General Because the addendum introduces the shipment of low-level waste the EA should 

include a “definition” of what constitutes low-level waste. This definition should include a limit for alpha-emitters. 

Low-level waste is deAction, paragraph 2. 

16. General How was the risk of low-level beta-gamma activity incorporated into the handling, 

packing, and shipping of low-level waste? 

All radiological exposSection 4.1.3. 

17. General The on-site C-746-U landfill is in a humid region in a wet location. It should not be 

considered an acceptable site for low-level waste disposal. 

The EA Addendum (Donly waste that meets C-746-U Landfill will low-level waste do nothe EA Addendum wi

18. General If the 17,600 m3 of DMSA waste is no longer classified or considered CERCLA 

regulated waste does DOE order 5820.2A still apply to that waste? 

DOE Order 5820.2A w435.1 applies to the poto be radioactive wast

19. General The manifesting of all waste shipments should include data on “waste physical and 

chemical characteristics, quantity of each major radionuclide present, weight of the waste, volume of the waste, other data for compliance with waste acceptance criteria.” (DOE order 5820.2A) 

Waste shipments will accordance with U.S. Transportation regulat
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

20. General We did not receive a copy of the Final EA until May 28, 2003 even though we 

submitted written comments on the Draft version. Beginning in November 2002, Ruby English of Active Citizens for Truth (ACT) made numerous attempts to obtain copies of this document for review by ACT members and other local residents. On May 15, 2003 during a brief presentation on the EA Addendum at the Site Specific Advisory Board meeting, Vicki Jurka requested a copy of the final EA. Twelve days later, on May 27, Ruby English and Vicki Jurka visited the DOE Information Center and the SSAB office still seeking a copy of the Final EA (as well as other documents previously requested). On the evening of May 27, 2003, two copies of the Final EA were delivered to the English home allowing us one week to read the document and prepare comments. 

Comment noted. 

21. General The date and time of the public hearing for the EA Addendum was held exactly on 

the date and time of a previously announced community health seminar cosponsored by ACT and the University of Kentucky as well as on the same date and time of the local Audubon meeting. Consequently, community members who were involved in the Draft EA process and environmentalist who are interested in protecting the environment were unable to attend the public hearing. 

Comment noted. For tbriefing on the EA AdAdvisory Board meeti

22. General Copies of the Addendum did not include the date the comment period closed or the 

address for submittal of comments. 

The stakeholder letter Addendum clearly stasubmitted to David Alto June 4, 2003. 

23. General Review of several C-746-U landfill documents already show more waste slated for 

disposal there than the permitted capacity of the landfill. 

DOE and Kentucky Omonitor permitted capcompliance. 

Michael V. Welch, Manager Hazardous Waste Branch, Kentucky Department for Environmental Protecti

24. General The Division strongly opposes use of the C-746-U Landfill for the disposal of lowlevel radioactive waste. Text has been revised 

m3 is material to be chdispositioned and is nwaste that meets the c746-U Landfill will be low-level waste do nothe EA Addendum wi
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

25. General DOE’s primary exposure scenario envisions a rural resident drilling a groundwater 

well at the DOE property boundary near the landfill and subsequently being exposed to contaminated groundwater sourced from the landfill. DOE should also consider the possibility that a resident might construct a home and drinking water well directly on top of the landfill. While perhaps a remote possibility, the likelihood of this occurring at sometime in the future is not out of the question, especially when one considers the geologic timeframes associated with the decay of U-238 and other radionuclides of concern. What provisions will DOE make to insure that the landfill is not compromised in this way? 

Text has been revised m3 is material to be chdispositioned and is nwaste that meets the c746-U Landfill will be low-level waste do nothe EA Addendum wi

26. General DOE’s addendum is deficient in that it fails to incorporate any land use control 

language. It would appear that DOE is preparing to place low-level radioactive waste into the C-746-U Landfill without first spelling out the controls that will insure 

that the landfill remains protective of human health and the environment. With regards to potential direct exposure to these wastes in the future, how does the DOE intend to insure that such exposures do not occur? At present the DOE has not committed to long-term stewardship of this facility. DOE must implement and maintain controls to insure that direct contact exposure is prevented. 

Text has been revised m3 is material to be chdispositioned and is nwaste that meets the c746-U Landfill will be low-level waste do nothe EA Addendum wi

27. General If low-level waste is eventually deposited in the landfill, the typical thirty (30) year 

postclosure groundwater-monitoring period required for a solid waste facility is no longer appropriate. In order to insure that the landfill remains protective of human health and the environment, monitoring should continue until such time as the radioactive materials stored in the landfill no longer pose a significant threat if released into the groundwater. Given the nature of these contaminants, groundwater monitoring may be required in perpetuity. 

Text has been revised m3 is material to be chdispositioned and is nwaste that meets the c746-U Landfill will be low-level waste do nothe EA Addendum wi

28. General The document is confusing in regards to the term “low-level waste”. The document 

proposes that an additional 17,600 m3 of low-level waste be disposed in the C-746-U Landfill. However in Section 2.3.1 the following statement is made: “Based on the Record of Decision for the Department of Energy’s Waste management program: Treatment and Disposal of Low-Level Waste and Mixed Waste, (January 1998, 63 Federal Register 3629), DOE has determined that low-level waste should be disposed at the Nevada Test Site or the Hanford Site rather than constructing new landfills or landfill cells.” DOE should clearly differentiate between the low-level waste proposed for disposition in the C-746-U Landfill and the low-level wastes proposed for disposition at the Nevada Test Site or the Hanford Site. 

Text has been revised m3 is material to be chdispositioned and is nwaste that meets the c746-U Landfill will be low-level waste do nothe EA Addendum wiThe EA Addendum antransportation of low-Site, Nevada Test Site
Stakeholder Comments and DOE Responses for the Draft Environmental Assessment Addendum 

Disposition of Additional Waste at the Paducah Site (DOE/EA-1339-A) 

29. General Finally, the long term stewardship costs associated with the disposition of low-level 

wastes in the C-746-U Landfill have not been assessed. Additionally, DOE did not 

consider the alternative of dispositioning all low level wastes in existing low-level repositories at Hanford and the Nevada Test Site. The long-term stewardship costs and the alternative of off-site disposition of low-level wastes need to be rigorously evaluated within an Environmental Impact Statement and should include full public participation. The Environmental Impact Statement should also clearly differentiate between the low-level waste proposed for disposition in the C-746-U Landfill and the low-level wastes proposed for disposition at the Nevada Test Site or the Hanford Site. 

Text has been revised m3 is material to be chdispositioned and is nwaste that meets the c746-U Landfill will be low-level waste do nothe EA Addendum wi

Mark Donham, Verbal Comments Received at Citizens Advisory Board meeting

28. General When you’re determining whether or not an action is significant, the CEQ 

regulations guide you to the ten significance criteria in 1508.27, one of those is cumulative impacts. There has never been a sitewide EIS looking at the cumulative impacts involved with cleanup activities at one time, done for the Paducah Site. 

The cumulative impacvalid for the EA Addethe impacts analysis is Environmental Policy 

29. General I don’t believe this EA looks at the impacts on the environment of waste disposal 

itself and the transportation. 

The EA Addendum Sethe impacts associated and alternatives.