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FINAL VOLUME I Prepared by the
INTENDED FOR PUBLIC RELEASE This report has been reproduced from the best available copy. Available in paper copy and microfiche. Number of pages in this report: 314 DOE and DOE contractors can obtain copies of this report from: Office of Scientific and Technical Information
This report is publicly available from: National Technical Information Service FINAL VOLUME I September 1996
Prepared by Section 1.0 INTRODUCTION 2.0 ALTERNATIVES 3.0 AFFECTED ENVIRONMENT 4.0 ENVIRONMENTAL
IMPACTS 5.0 UNAVOIDABLE
ADVERSE ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION 6.0 SHORT-TERM USES AND LONG-TERM PRODUCTIVITY 7.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES 10.0 ABBREVIATIONS AND ACRONYMS 11.0 PREPARERS OF THE FINAL PEIS 12.0 ORGANIZATIONS CONSULTED DURING PEIS PREPARATION 13.0 AGENCIES, ORGANIZATIONS, AND PERSONS RECEIVING COPIES OF THE PEIS APPENDIX A STANDARDS: HEALTH AND ENVIRONMENTAL PROTECTION STANDARDS FOR URANIUM AND THORIUM MILL TAILINGS PROPOSED STANDARDS FOR REMEDIAL ACTIONS AT INACTIVE URANIUM PROCESSING SITES GROUND WATER STANDARDS FOR REMEDIAL ACTIONS AT INACTIVE URANIUM PROCESSING SITES, FINAL RULE APPENDIX B HUMAN HEALTH AND ECOLOGICAL RISK ASSESSMENT METHODOLOGIES FOR THE UMTRA GROUND WATER PROJECT APPENDIX C GROUND WATER REMEDIATION METHODS
LIST OF FIGURES Figure 1 Relationship between alternatives
and impacts for Project-specific environmental impact statements
and the Ground Water Project PEIS LIST OF TABLES Table 1. Ground
water compliance strategies that apply under each alternative
On November 8, 1978, Congress enacted the Uranium Mill Tailings Radiation Control Act (UMTRCA) of 1978, Public Law, codified as 42 USC §7901 et seq. Congress found that uranium mill tailings ". . . may pose a potential and significant radiation health hazard to the public, and that every reasonable effort should be made to provide for stabilization, disposal, and control in a safe, and environmentally sound manner of such tailings in order to prevent or minimize other environmental hazards from such tailings." Congress authorized the Secretary of Energy to designate inactive uranium processing sites for remedial action by the U.S. Department of Energy (DOE). Congress also directed the U.S. Environmental Protection Agency (EPA) to set the standards to be followed by the DOE for this process of stabilization, disposal, and control. On January 5, 1983, EPA published final standards for the disposal and cleanup of the inactive mill tailings site under UMTRCA. These standards were challenged in the Tenth Circuit Court of Appeals by several parties. On September 3, 1985, the court dismissed all challenges except one: it set aside and remanded the ground water provisions of the regulations. On September 24, 1987, EPA proposed new ground water standards to replace those remanded. The final EPA ground water standards were published on January 11, 1995 (60 FR 2854). DOE is responsible for bringing the designated processing sites into compliance with the EPA ground water standards and complying with all other applicable standards and requirements. The U.S. Nuclear Regulatory Commission (NRC) must concur with DOE's proposed actions. States that pay for a part of the cost of the compliance action are full participants in the process. DOE also must consult with any affected Indian tribes and the Bureau of Indian Affairs. Uranium processing activities at most of the inactive mill sites resulted in the contamination of ground water beneath and, in some cases, downgradient of the sites. This contaminated ground water often has elevated levels of constituents such as but not limited to uranium and nitrate. The purpose of the Uranium Mill Tailings Remedial Action (UMTRA) Ground Water Project is to eliminate or reduce to acceptable levels the potential health and environmental consequences of milling activities by meeting the EPA ground water standards. The first step in the UMTRA Ground Water Project is the preparation of this programmatic environmental impact statement (PEIS). This document analyzes the potential impacts of four alternatives for conducting the Ground Water Project. One of these alternatives is the proposed action. These alternatives do not address site-specific ground water compliance strategies because the PEIS is a planning document only. It assesses the potential programmatic impacts of conducting the Ground Water Project, provides a method for determining the site-specific ground water compliance strategies, and provides data and information that can be used to prepare site-specific environmental impacts analyses more efficiently. This PEIS differs substantially from a site-specific environmental impact statement because multiple ground water compliance strategies, each with its own set of potential impacts, could be used to implement all the alternatives except the no action alternative. In a traditional environmental impact statement, an impacts analysis leads directly to the defined alternatives. The impacts analysis for implementing alternatives in this PEIS first involves evaluating a ground water compliance strategy or strategies (Figure 1), the use of which will result in site-specific impacts. This PEIS impacts analysis assesses only the potential impacts of the various ground water compliance strategies, then relates them to the alternatives to provide a comparison of impacts. DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES The PEIS considers four programmatic alternatives for implementing the UMTRA Ground Water Project: 1) the proposed action, 2) no action, 3) active remediation to background levels, and 4) passive remediation. A Record of Decision will identify the alternative that will become the programmatic foundation for conducting the Ground Water Project at all sites. All the alternatives listed except the no action alternative would use one or more ground water compliance strategies to meet the EPA ground water standards. Table 1 shows the alternatives and the strategies that are described below. 1) Proposed action (Preferred Alternative) The proposed action provides a consistent approach to implementing the UMTRA Ground Water Project and to determining an appropriate ground water compliance strategy at each former processing site. The success of the proposed action in determining these strategies would depend on the analysis of site-specific data to characterize site hydrogeological conditions and determine the potential human health and environmental risks. The proposed action is flexible because it would
provide a framework for the Ground Water Project decision-making
process if new ground water cleanup methods become available.
The proposed action would use ground water compliance strategies
tailored for each site to achieve conditions that are protective
of human health and the environment. The proposed action would
consider ground water compliance in a step-by-step approach, beginning
with the no remediation strategy and ending with a more complex,
active ground water cleanup strategy. For example, under the proposed
action, if a site risk assessment and site observational work
plan indicate the strategy of no remediation would still be protective
of human health and the environment, a more expensive strategy
involving active cleanup methods would not be necessary. Table 1. Ground water compliance strategies that apply under each alternative
aThe analysis of the no action alternative
is required by the CEQ and DOE. 2) No action alternative The Council on Environmental Quality (CEQ) regulations
for implementing the National Environmental Policy Act (NEPA)
require assessment of the no action alternative (40 CFR §1502.14(d)),
even if the agency is under a legislative mandate to act (51 FR
15618). The analysis of the no action alternative "provides
a benchmark, enabling decision-makers to compare the magnitude
of environmental effects of the action alternatives" (51
FR 15618). Under the no action alternative, no further activities
would be carried out to comply with EPA standards at the inactive
UMTRA Project former processing sites. Under this alternative, ground water at the former processing sites would be restored to background levels or to levels as close to background as possible using active ground water remediation methods. The rationale behind this alternative is that ground water at most of the former uranium processing sites was of better quality before uranium processing activities occurred and that the ground water should be restored to its preprocessing quality. If this alternative were implemented, most of the UMTRA Project sites would require the use of active ground water remediation methods such as gradient manipulation, ground water extraction and treatment, or in situ ground water treatment, regardless of the quality of the unaffected background ground water. 4) Passive remediation compliance alternative Under this alternative, only passive remediation strategies would be used to meet the EPA ground water standards. The passive remediation strategies are 1) performing no remediation at sites that qualify for supplemental standards or alternate concentration limits or that are below maximum concentration limits, and 2) relying on natural flushing. Active ground water remediation methods would not be used. "Natural flushing" means allowing the natural ground water movement and geochemical processes to decrease contaminant concentrations. EXISTING CONDITIONS The designated UMTRA Project processing sites were active for varying lengths of time from the 1940s into the 1970s. These sites, the surrounding areas, and the underlying ground water constitute the affected environment for this PEIS. Communities near some of the sites include minority and low-income populations. Land contaminated by uranium mill tailings and other contaminants ranged from a low of 21 acres (ac) (8 hectares [ha]) at the Spook, Wyoming, site to a maximum of 612 ac (248 ha) at the Ambrosia Lake, New Mexico, site. The amount of contaminated materials ranged from 85,000 cubic yards (yd3) (65,000 cubic meters [m3]) at the North Continent Slick Rock, Colorado, site to 5,764,000 yd3 (4,407,000 m3) at the Falls City, Texas, site. The total amount of contaminated material at the sites is 39,000,000 yd3 (30,000,000 m3). As a result of uranium processing, contaminants have entered the ground water at most of the UMTRA Project sites. Some of the more common hazardous constituents that exceed maximum concentration limits at UMTRA sites include but are not limited to net gross alpha, molybdenum, nitrate, selenium, and uranium. DOE currently estimates that approximately 10 billion gallons (gal) (39 million m3) of ground water are contaminated. One site (Lowman, Idaho) shows no sign of contamination related to processing activities. The site with the largest amount of contamination, Gunnison, Colorado, has an estimated 1.9 billion gal (7 million m3) of contaminated ground water. Surface remediation of the designated sites has been in progress since the mid-1980s; surface remediation is complete at 18 sites and under way at 4 sites. Belfield and Bowman, North Dakota, are not scheduled for surface remediation due to DOE and state funding issues. Table 2 summarizes the environmental resources that are present at the former processing sites. IMPACTS ANALYSIS To evaluate the impacts of alternatives, a qualitative
analysis of potential impacts of the ground water compliance strategies
is used in this PEIS. This qualitative analysis compares one alternative
to another alternative rather than a numerical standard. For example,
if the no action alternative is said to have a high potential
for ecological risk, this potential impact is high only in relation
to the other alternatives' potential for such an impact. These
comparisons are not site-specific; that type of assessment would
be provided in the site-specific NEPA documents that tier off
the PEIS. (Tiering is the process in which broad environmental
issues are analyzed to facilitate subsequent site-specific decision-making.)
Further, this comparison treats all impacts equally so that, for
example, the significance of potential impacts to human health
are equated with potential impacts on cultural resources (Table
3). Table 2. Resources at UMTRA Project processing sites Site Characteristics
aFrom TAC, 1995. Table 3. Comparison of potential adverse environmental impacts of the alternatives Alternative
Notes: 1. High indicates high potential for negative impact
to the other alternatives.
To give more weight to impacts that may have more significant consequences (for example, human health), long-term and short-term impacts are compared separately. Long-term impacts are those that would occur from leaving contaminated ground water in place or from implementing institutional controls for an extended period of time. Short-term impacts would usually occur only during construction activities. In general, these impacts would be potentially less significant than long-term impacts, because most (for example, habitat destruction, noise, and dust emissions) would be relatively minor and temporary, and could be mitigated. While these impacts are of concern, there is a greater concern regarding potential long-term health and safety effects. Potential short-term impacts of the alternatives Potential short-term impacts to air quality, background noise levels, visual resources, transportation systems, utilities, and energy supplies would occur principally during site characterization, monitor well construction, and construction of ground water remediation facilities. There would be little or no impact on these resources due to the short duration and small scale of the ground-disturbing activities. Site characterization, monitoring, and construction activities have the potential to disturb sensitive habitats, species, and cultural/traditional resources. The probability of this disturbance would be remote because site characterization and construction activities can take place in areas away from these resources. In addition, if impacts to these resources occurred, their effects could be mitigated. Therefore, the potential for site characterization and construction activities to adversely affect these resources would be considered minor. Potential long-term impacts of the alternatives Potential long-term impacts could arise under the following circumstances:
Significant adverse impacts to human health and the environment could result under the no action alternative. Under this alternative, the public could be exposed to hazardous contaminants by drinking contaminated ground water or surface water that is a surface expression of contaminated ground water. Further, minority and/or low-income communities would be disproportionally impacted under no actions. Adverse impacts to the environment could potentially occur if contamination enters the food chain (such as through livestock or produce) or affects sensitive habitats (such as wetlands) or threatened and endangered species. These potentially significant adverse impacts probably would not occur under the proposed action or the active remediation to background levels alternative, because these alternatives would comply with EPA standards at all UMTRA Project sites. In addition, surface and ground water monitoring would take place before and during implementation of the proposed action and the active remediation to background levels alternatives to ensure the public is not exposed to existing or potential surface and ground water contamination. Implementation of the passive remediation alternative also could result in potential exposure of humans and the environment to hazardous contaminants. During the time required to implement the passive remediation alternative, contaminated ground water could reach potential receptors such as domestic wells or surface water features. Both the proposed action and active remediation to background levels alternatives would use hydrogeologic data and risk assessments to identify the need for implementing active remediation strategies, to remediate ground water quickly or divert the flow of contamination. Implementation of institutional controls could result in potentially significant long-term land use and social and economic impacts. The passive remediation alternative could result in the need for institutional controls for more than 100 years if protection of the public and the environment were necessary. The proposed action and the active remediation to background levels alternatives would implement strategies to achieve ground water compliance within 100 years. In summary, the proposed action and active remediation to background levels alternatives are most effective in protecting human health and the environment from the contaminated ground water at the UMTRA Project sites. When cost is factored in, the proposed action likely would be more cost-effective than the active remediation alternative, because it can rely on less costly passive ground water remediation strategies at sites where these strategies are shown to be protective of human health and the environment. Implementing the active remediation to background levels alternative would be the most costly because active ground water remediation methods would be used at most sites. In addition, both strategies would result in compliance with the EPA ground water standards so the active remediation to background levels without reliance on active ground water remediation would provide no additional benefits to human health and the environment. |
