|
Programmatic Environmental Impact Statement
For The This section analyzes the potential impacts associated with the alternatives for implementing the Ground Water Project. These alternatives, except the no action alternative, implement one or more of three strategies for complying with the EPA ground water standards Alternative
aAnalysis of the no action alternative is required by CEQ and DOE. bActive remediation methods would not be used at sites where contamination does not exceed background and likely would not be used at sites that qualify for supplemental standards based on the existence of limited use ground water. c"No remediation" at sites that do not exceed maximum concentration limits or background levels is not the same as "no action" because these sites would require activities such as site characterization to show that no remediation is warranted.
These strategies are described below:
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 4.1), the use of which would 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. The potential impacts of site characterization are analyzed in Section 4.1. Site characterization is used to help determine the site-specific ground water compliance strategies for the alternatives being evaluated. Impacts analyses for the ground water compliance strategies are presented in Section 4.2, followed by the potential impacts of the no action alternative in Section 4.3. The comparison of alternatives (Section 4.4) and the cumulative impacts analysis (Section 4.5) follow the analysis of the no action alternative. The following categories were analyzed for potential impacts:
Figure 4.1 Relationship Between Alternatives And Impacts For Project-Specific Environmental Impact Statements And The Ground Water Project PEIS
Mitigation of the potential impacts analyzed in this section are discussed under each appropriate resource category subheading. Descriptions of the mitigation measures are general. For example, contaminated wastewater produced during ground water remediation would be treated to meet the requirements of a National Pollutant Discharge Elimination System (NPDES) Permit before the water is released into the environment. Other examples are mitigation plans for impacts that may occur to archeological resources or threatened and endangered species. Under all the alternatives except no action, when a site-specific ground water compliance strategy is proposed, its environmental impacts would be assessed in the site-specific environmental documents and specific mitigation measures would be recommended. 4.1 SITE CHARACTERIZATION AND MONITORING IMPACTS ANALYSES
Ground water characterization would be performed to describe the ground water characteristics at the UMTRA Project sites. This characterization would take place under all the alternatives except the no action alternative. Site characterization data would also be used to prepare the site-specific risk assessments. These risk assessments, ground water characterization, and input from affected tribes, states, and public would be used to determine the appropriate ground water compliance strategy. Monitoring would take place to determine the effectiveness of the ground water compliance strategy and to protect human health. Field site characterization activities would consist primarily of drilling boreholes and installing monitor wells; sampling ground water, surface water, soil, and other media; and conducting geophysical surveys and aquifer tests. Some of these activities, such as drilling boreholes, would require clearing small amounts of land (e.g., less than 1 ac [0.4 ha]) and developing or improving access roads to site areas (if necessary), while other activities such as collecting surface water samples would not result in any environmental disturbance. The potential environmental impacts associated with these types of field activities discussed below are based on the descriptions of site characterization activities in Section 2.8. Table 4.2 summarizes field activities that could affect the environment. No disproportionally high or adverse human health or environmental
effects would occur to minority or low-income populations
due to site characterization or monitoring because the impacts
of site characterization are minor or nonexistent.
Table 4.3 summarizes the potential impacts
of site characterization and monitoring activities. Impacts
associated with these activities are minor and generally short-term.
The construction and use of access roads may generate dust,
which may require the use of dust suppressants. Site characterization
aquifer tests may pull contaminated ground water into uncontaminated
areas; these tests would be conducted in areas where the possibility
of such an impact is remote. Potential impacts on ecological
or cultural/traditional resources would also be unlikely because
site characterization facilities would be located away from
sensitive areas such as wetlands or archaeological sites.
Potential visual impacts may arise from the long-term use
of monitor wells. However, the potential for the active remediation
to background levels alternative would have a greater chance
of affecting resources in the floodplain of rivers due to
its reliance on the active ground water remediation strategy.
The potential for site characterization activities to impact
the remaining resources listed in Table
4.3 is also unlikely. 4.2 GROUND WATER COMPLIANCE STRATEGY IMPACTS This section addresses the potential impacts associated with
the ground water compliance strategies. Some or all of these
strategies would be used in three alternatives: the proposed
action, the active remediation to background levels alternative,
and the passive remediation alternative (Section
2.0). Information collected during the Surface Project
pertains to some of the resources analyzed below (e.g., wetlands
and cultural/traditional resources). This information is used,
where appropriate, to indicate the potential impacts of the
Ground Water Project. The actual site-specific impacts of
applying these strategies would be addressed in the site-specific
NEPA documents. 4.2.1Active ground water remediation methods impacts As summarized in Section 2.8.2 and provided in detail in Appendix C, active ground water remediation methods include ground water extraction, gradient manipulation, and in situ treatment. Currently, there is insufficient information to predict how many sites would require active ground water remediation under the proposed action, although it is expected that a few sites would. Under the alternative of active remediation to background levels, active ground water remediation would be the major ground water compliance strategy. Active ground water remediation would not be used under the passive remediation alternative. Active methods would involve ground disturbance activities such as constructing wells and access roads or installing utilities and water treatment facilities. The following sections identify the potential impacts of active ground water remediation methods. Certain active ground water remediation methods could generate contaminated water or sludge. If the contaminated water were discharged to a surface water body, an NPDES permit or other types of permits may be required to protect human health and the environment. Contaminated sludge would be handled so as to reduce risk of worker exposure and would be disposed of in accordance with applicable regulations. The management of potential waste streams is discussed in more detail in Section 2.9. A risk assessment would be performed to assess the potential effects to human health of applying nitrogen-rich ground water to agricultural crops. This method involves adding high-nitrate ground water directly on the land or to irrigation water. This water could be treated prior to land application if it contained high levels of undesirable constituents, such as heavy metals or salts. Furthermore, if the risk assessment indicated that land application was not protective of human health, this method would not be used. The use of active ground water remediation methods could result in injury to workers. This risk would be greatest when workers would be using heavy equipment. The potential for worker injury is minimal because of the short construction period (up to a few months) and the small number of worker-years of labor required (5 to 10 worker-years). Following construction, the potential for these types of impacts would exist but be reduced during operation of the active ground water remediation facilities because workers would be trained in health and safety procedures and only a small staff would be needed to operate remediation facilities and equipment. Active ground water remediation could take many years and a potential exists for the use of contaminated ground water. This potential risk would be minimized because monitoring would likely identify potential risks before they occur and institutional controls could be used to limit access to contaminated ground water. Dust could be generated from heavy equipment and earth-moving activities as remediation facilities and access roads are constructed. An air quality permit may be required for some construction activities. An air quality permit would provide information on the potential for generating dust and on mitigation measures to keep dust emissions below air quality standards (such as applying water or other dust suppressants). The potential for dust emissions to exceed the standards is unlikely because the construction activities would be temporary and mitigation measures would be used, if necessary, to reduce fugitive dust. This impact would be short-term, occurring during construction activities. Dust would be minimal during facility operations because there would be no dirt-moving activities. Some fugitive dust could be generated by workers driving on unimproved access roads. Water or some other dust suppressant would be applied, if necessary, to control dust. The EPA's priority air pollutants, including sulfur oxides and nitrogen oxides, would be emitted from construction equipment during construction of ground water remediation facilities. Studies for the UMTRA Surface Project show that these emissions form a small portion of the total emissions inventory and that the air quality standards are not exceeded (DOE, 1987b). Therefore, the operation of active ground water remediation facilities is not expected to result in exceedance of the EPA standards for these air pollutants. The potential for extracted contaminants to become airborne from the treatment processes is minimal because the contaminants at the UMTRA Project sites are not volatile, and any solid waste would be disposed of in an approved disposal facility. During ground water remediation, potential impacts to surface water could occur but would be reduced or eliminated by implementing best management practices. Ground water remediation facilities would produce water that may be discharged into a nearby stream or river after the water is treated to remove contaminants. If plans called for this type of discharge, an NPDES permit would be obtained that would stipulate appropriate treatment, monitoring, and reporting requirements. This permit would ensure that the water discharged into a surface water body would have minimal impacts. In addition, a storm water permit may be required. Active remediation methods that extract contaminated ground water may cause lateral ground water flow. Lateral flow could mix contaminated ground water with uncontaminated ground water, reducing contaminant concentrations (thus expediting the achievement of remedial goals) but increasing the total volume of contaminated water. Ground water extraction could have a negative impact by depleting an aquifer that is or has the potential to be a ground water resource. Ground water extracted from contaminated aquifers may be treated, then reinjected into deeper aquifers or in the same aquifer upgradient of the contaminant plume. The quality of the treated ground water would be monitored prior to injection to reduce or eliminate potential adverse affects on the quality of the ground water into which it is injected. At some sites, an NPDES permit would be required to discharge this treated water into an aquifer. Site-related contaminants in ground water are known to be entering the surface water at some sites. During active ground water remediation, contaminants from this ground water would continue to enter the aquatic and terrestrial ecosystems, negatively impacting the resources. In the long term, active ground water remediation would reduce or eliminate this source of contaminated ground water entering the environment. Under some active methods, treated ground water could be discharged to the land (e.g., water with high nitrate concentrations). The potential risks of discharging this water into the environment would be determined to ensure there is no unacceptable ecological risk. Construction of ground water remediation facilities would have a short-term adverse impact, resulting in the clearing of plant communities and wildlife habitat. The amount of habitat that would be cleared at a site typically would be small (up to 20 ac [8 ha]), and active cleanup would last from a few months to 10 years or more. Once ground water cleanup activities were complete, most of the facilities and access roads would be revegetated with native species and returned to their approximate pre-remedial action conditions. Revegetation back to a grassland or grassland-shrub plant community would take approximately 2 to 5 years, depending on the plant community type and climate conditions. As can be seen by the annual precipitation statistics shown in Table 3.2, most UMTRA Project sites are in arid and semiarid climates. Revegetation at sites with these types of climates would likely need mulch and irrigation to be successful. Construction and operation of ground water remediation facilities could create dust, noise, and human activity, which could indirectly affect habitat adjacent to the direct impact area. However, these impacts would be minor due to the low level of human activity (only a few personnel would be at the site) and the low intensity of operational activities. Active ground water remediation could negatively impact sensitive habitats such as wetlands, riparian areas, and aquatic habitat. These types of habitats are common at and near the UMTRA Project sites, as documented in Section 3.2; 22 of the sites are near aquatic habitat, while wetlands occur at 18 of the sites (Table 3.2). Placement and construction of facilities could affect these sensitive areas, and pumping ground water may dry up wetlands and lower water levels in other aquatic habitat. Usually, remediation facilities could be placed away from sensitive habitats to reduce potential adverse effects. If sensitive areas such as floodplains or wetlands would be affected, the disturbed area would likely be small and the duration of the impact would be short-term (during construction and remediation). These areas would be returned to preconstruction conditions after ground water remediation is complete. A floodplain/wetlands assessment would be prepared consistent with 10 CFR Part 1022, Compliance With Floodplains/Wetlands Environmental Review Requirements, and a U.S. Army Corps of Engineers Section 404 Permit application would be prepared if wetlands under the jurisdiction of the Corps of Engineers were affected. Ground water characterization and data analysis would be used to determine whether ground water extraction would lower the water levels in aquatic habitats. If such an impact were predicted, the active ground water remediation would be altered to avoid this impact. In addition, monitoring during remediation would ensure that drawdowns in sensitive habitats would be detected and corrective action taken. Threatened and endangered species or other species of concern occur at or near 14 of the UMTRA Project sites (Table 3.2). Active ground water remediation methods could adversely affect these species directly through habitat destruction or indirectly through human activity adjacent to the direct impact zone. In addition, pumping water from aquifers that are hydrologically connected to rivers could adversely affect threatened or endangered fish and/or their critical habitat. The DOE would consult with the Fish and Wildlife Service during the preparation of the site-specific NEPA documents. If impacts to threatened and endangered species were unavoidable, formal consultation with the Fish and Wildlife Service would be initiated and a biological assessment would be prepared. Construction of ground water restoration facilities, possibly resulting in sediment runoff into surface waters, could adversely affect aquatic resources. Increased sedimentation in surface waters would degrade water clarity, thereby affecting the aquatic food chain. The potential for this type of impact would be slight because erosion protection measures would be implemented, where required, to prevent sediment runoff. Active ground water remediation methods would require that land be used to construct facilities such as water treatment plants and retention ponds. This would preclude use of the land for other purposes during remediation. This potential negative impact could be short-term (a few months to a year) or long-term (up to 10 years), depending on the ground water remediation objectives and the method used. In certain cases, the contaminant plume may extend outside the active ground water remediation work zone, and it would be necessary to restrict human access to contaminated ground water during active remediation. These controls could limit the uses of the land to such activities as grazing and prevent other uses such as home construction. In some cases, restriction could preclude any use of the land until compliance with EPA standards is achieved. This impact could be short- or long-term, depending on the goals and methods of ground water remediation. The potential adverse impacts of institutional controls are discussed in greater detail in Section 4.2.2.6. There is the potential for long-term positive impacts because once the ground water meets the EPA standards, there may be opportunities for more land uses. 4.2.1.7 Cultural/traditional resources Construction of active ground water remediation facilities could affect cultural resources (for example, archaeological, historic, or Native American traditional areas). The potential for such resources in the area of the UMTRA Project sites is high; during the Surface Project it was determined that there are cultural resources at 11 sites (Table 3.2). The DOE would conduct additional surveys for cultural resources before site-disturbing activities took place in areas that have not been surveyed. Appropriate tribal groups would be contacted regarding the existence of traditional-use areas. Efforts would be made to avoid placing facilities at or near identified cultural/traditional resources. If a site were considered significant (that is, eligible for inclusion on the National Register of Historic Places) and disturbance could not be avoided, the DOE would consult with the State Historic Preservation Officer or tribal officials and other applicable agencies to identify appropriate mitigation. Water resources, ground water, and seeps have religious significance to many Native Americans. These resources often have ceremonial significance or may be associated with traditional, symbolic plants. The contamination of these resources at the UMTRA Project sites is a negative impact. The remediation of contaminated ground water quality would be a positive benefit. Noise from heavy equipment would occur during construction of facilities. If warranted, noise prediction models would be used to determine any increase above background noise. If noise levels were determined to be unacceptable (that is, above EPA hearing protection levels), mitigation measures would be implemented (EPA, 1974). However, potential impacts associated with higher noise levels likely would be minor, given the small scale of the construction operations, and would last only during construction of remediation facilities. Facilities such as ground water extraction wells and water treatment plants would emit noise. Water treatment facilities and retention ponds could be visible from a few months to decades. Impacts on visual resources depend on the extent to which the landscape would be changed by new structures, the scenic value of the landscape, and the potential number of viewers. Facilities constructed in urban areas would be seen by more people; however, urban facilities would be less likely to contrast with the surrounding area. In rural areas, new facilities would be more obtrusive but, in general, fewer people would see the landscape change. Significant visual resource impacts from remediation facilities are not expected because most facilities would be located on or near a processing site that was already disturbed. Once ground water remediation activities were complete, remediation facilities would be removed and the land would be recontoured and revegetated to approximate preoperational conditions. Monitor wells used during site characterization, ground water remediation, and monitoring may have a visual impact, particularly on residents near the sites. The DOE would work with local landowners, residents, tribes, and states as necessary to reduce potential visual impact, using such measures as flush-mounted monitor wells or landscaping. Construction of ground water remediation facilities would involve movement of heavy equipment and increases in traffic from commuting workers. Most of the heavy equipment movement would be on the site and would not increase traffic on local roads. The occasional off-site trip and worker commuting trips would increase traffic levels on local roads. The level of impact would depend on current traffic volumes in the area, load capacity, and the number of additional trips that would result from facility construction. Significant impacts on local traffic patterns are not expected because the construction work force would be small and construction activities would be temporary. Traffic control measures could be implemented if necessary to reduce transportation impacts (for example, traffic lights or turn lanes). During facility operation, the work force would be smaller and potential transportation impacts would be less than during construction. 4.2.1.11 Social and economic resources Social and economic impacts typically derive from increased employment and circulation of additional monies into local and regional economies as a result of UMTRA Project development. The extent of these impacts depends on the type and level of employment generated by a project. Often these impacts are beneficial, particularly in rural areas with lower employment levels and less diverse economies because Project development offers opportunities for local hiring and an expansion of the local economy. Negative impacts occur when there is a demand for a large work force but few workers are available locally, causing a large, abrupt influx of workers and their families into a community. Social and economic impacts generally occur in four interrelated categories: demographics, employment, economy, and community facilities and services. Construction and operation of the ground water remediation facilities would minimally increase employment and opportunities for local hiring, particularly during construction. Data from UMTRA Surface Project sites show about 80 percent of the remedial action work force commutes from within 60 mi (100 km). This increased employment would last only during the construction phase. It is expected that fewer, more technically skilled people would be required during facility operation. Workers who relocated during facility operation would be more likely to bring families than construction workers whose employment duration is shorter. The level and extent of impacts on housing, community services, and facilities would depend on the number of workers who relocated with their families and the ability of communities to absorb them. Because operation work force requirements would be small (less than five workers), local communities probably could accommodate their needs for housing, community services, and facilities (for example, schools, fire, and police protection). Facility construction and operation would temporarily benefit the local and regional economies. This would result from UMTRA Project purchases of goods and services (for example, construction supplies, gasoline, and automotive service contracts); wages paid to employees that are recirculated; and income from employment created by direct and indirect Project-generated monies (that is, as more project money was spent on goods and services, additional employment would be generated to provide these goods and services). The extent of these economic benefits depends on the number of workers required and the extent to which Project-related materials, supplies, and services are available locally. These beneficial impacts would primarily occur during construction, when there would be a larger work force and greater material/supply requirements. The use of land for active ground water remediation facilities and land use restrictions from institutional controls may reduce the property values of the affected land or limit the types of activities that can take place on the land. These impacts would last for the duration of the active remediation. However, when the ground water is cleaned up, property values that had been devalued due to contamination or construction could be restored and higher or more intense land uses may be possible. Extracting ground water from aquifers that are a ground water resource has the potential to impinge on the water rights of the users of the aquifer. This could affect uses for agricultural, industrial, and other purposes. During the preparation of the site-specific environmental assessment, the DOE would consult with the tribal water authority or state engineer to determine if such an impact exists. 4.2.1.12 Environmental justice No disproportionately high or adverse human health or environmental effects to minority or low-income populations would be expected under the active ground water compliance strategy because ground water would likely meet regulatory standards. 4.2.1.13 Utilities and energy resources It is expected that local utilities would supply electricity, gas, and telephone services during the construction and operation of ground water remediation facilities. In urban areas, water needed during construction likely would come from existing water supply systems; in rural areas, water likely would come from wells or rivers. Because ground water remediation methods are relatively small-scale operations, local utilities probably could meet these short-term Project needs. Construction equipment would use petroleum products during construction. For example, fuel-powered generators may be used during facility operations. The greatest amount of energy would be used during construction because heavy equipment would be needed to build the facility. Impacts would be minimal, due to the short construction period and the operation's small scale. Energy use during operation would also be minimal due to the low level of activity that would take place. The following contaminated materials could be generated during site characterization, operations, and monitoring under the active remediation strategy: well development water, drill cuttings and drilling muds, purge water, sludge and brine, and contaminated ground water and soils. These materials would be analyzed. Based on this analysis, solid material such as mud or soil would be applied to the land or disposed of in a disposal facility such as an existing open UMTRA Project cell capable of accepting these materials. Contaminated water would be treated, if necessary, and applied to the land, reinjected to the ground water, or discharged to surface water, after permits are received. Section 2.9 provides more details on the management of contaminated materials. Potential adverse impacts on human health or the environment from the generation, treatment, storage, or disposal of contaminated materials are not expected because all such activities would be performed in compliance with applicable regulations and guidelines that were developed to be protective of human health and the environment. However, human error could result in environmental impacts. As indicated in Section 2.10, activities such as the preparation of baseline risk assessments, site observational work plans, and NEPA documents would be prepared for most UMTRA Project sites, regardless of the proposed ground water compliance strategies. The active remediation compliance strategy also would include site characterization, monitoring, and revisions to site observational work plans; field management, capital equipment, and operations costs associated with implementing an active remediation method; and program support throughout the remediation period. Estimated costs for active remediation to background levels range from $86 million to $162 million per site (escalated dollars) and include all generic cost elements plus costs associated with field management and operation (Foskey, 1995). These cost elements include utility installation, number of wells required, collection systems, installation of water treatment plants, plant operations, testing, land application of water, closure, demobilization, and site restoration. The plant size and length of operations are generated on a site-specific basis using current assumptions of the technical parameters of the plume, soil, and contaminants. 4.2.2 Natural flushing impacts Natural flushing in conjunction with institutional controls is a potential strategy for meeting the EPA ground water standards. Sections 1.4.1 and 2.8 summarize the natural flushing process and institutional controls. Natural flushing would likely be the principal ground water compliance strategy used under the passive remediation alternative. Natural flushing would also be used under the proposed action, either alone or in conjunction with active ground water remediation. This strategy would not be available under the active remediation to background levels alternative because this alternative would rely principally on active ground water remediation. This impact analysis assumes that the criteria required to implement natural flushing are met. However, under the passive remediation alternative, the use of natural flushing at certain sites may not be protective of human health or the environment; compliance may not be accomplished within 100 years as required by the EPA ground water standards; or required institutional controls may not be viable. In these cases, the standards would not be met and the potential for human health or environmental harm exists. At sites that would not comply with the standards within 100 years, institutional controls and monitoring would be required for more than 100 years; this would not meet the EPA ground water standards and would increase the uncertainty in protecting human health and the environment. In addition, natural flushing may not be protective of beneficial uses of the ground water, such as irrigation or livestock watering. The potential impacts on resources of applying natural flushing under these circumstances are discussed in Section 4.4. Ground water remediation using natural flushing may result in human exposure to contaminated ground and/or surface water. However, the probability of such an exposure is remote because the following conditions must be met before natural flushing can be used: To ensure continued protection, ground and surface water monitoring, as needed, would take place during the natural flushing period. The installation of monitor wells or construction of institutional control structures such as perimeter fences could generate small amounts of dust. This impact would be minor and short-term, lasting only during construction or installation. The potential for air quality impacts from other priority pollutants would be remote, given the limited use of construction equipment needed for establishing and maintaining institutional controls. During the natural flushing period, contaminated ground water could discharge into surface water bodies such as springs and wetlands. Before implementing natural flushing, the DOE would evaluate the potential for such a discharge. If it were determined that such a discharge may take place and threaten human health and the environment, natural flushing probably would not be a viable ground water compliance strategy. If it were determined that the potential for such a discharge would be remote, this strategy may be viable. However, because the natural flushing period could last up to 100 years, there would be an increased potential for surface water bodies to be affected within this time period. Monitoring would take place during natural flushing, and if monitoring indicated that surface water bodies were being contaminated, an additional risk assessment may be performed. If the contamination levels were not protective of human health or the environment, active remedial action may be undertaken. Institutional controls would be required to control access to areas where surface waters were contaminated. Ground water remediation from natural flushing would most likely be slower than active remediation methods. Hazardous constituent concentrations in the plume that exceed the standards would be reduced to meet background levels, maximum concentration limits, or alternate concentration limits during the natural flushing period. The potential for contaminated ground water to affect uncontaminated areas is site-specific. There are three general cases: 1) geochemical attenuation limits plume migration and additional ground water contamination is unlikely or would be minimal, 2) the plume has already reached a discharge point and thus the maximum extent of ground water contamination has already occurred, and 3) the plume is migrating and dispersing through the aquifer system with potential for additional ground water contamination. Ground water monitoring would identify any expansion of the ground water plume. Corrective measures, such as expanding the institutional controls area, may be required. Natural flushing would have minimal impact on wildlife and aquatic and sensitive habitats. The major activity associated with this method is the application of institutional controls. Fencing to supplement other controls could positively impact wildlife and aquatic habitat because activities such as grazing, which can degrade these habitats, may be prevented. However, fencing could negatively impact certain species of wildlife by blocking migration corridors and improperly constructed fences could cause wildlife mortality. These impacts could be minimized by installing fences designed to accommodate wildlife needs. The low levels of human activity are not likely to result in a negative impact on threatened and endangered species. However, the DOE would consult with the Fish and Wildlife Service during preparation of the site-specific NEPA documents to determine whether threatened and endangered species are known to occur in the area. The potential for contaminated ground water to be released into the environment during the natural flushing period would be evaluated in an ecological risk assessment to determine whether natural flushing would be protective of the environment. This assessment would consider existing and potential future releases of contaminated ground water into the environment. If there were no risk or there were acceptable risks, natural flushing could be implemented if all other requirements were also met. However, as the length of a natural flushing period increases, so does the potential for contaminated ground water to enter the environment. A ground water and surface water monitoring program would be conducted during the natural flushing period, and any releases of contaminated ground water into the environment would be detected. If contaminated ground water were released into the environment, an ecological risk assessment may be performed. If the risks from such a release were unacceptable, active remedial action may be initiated. The EPA ground water standards require that institutional controls be implemented to limit access to a contaminated aquifer during natural flushing. Such controls must be able to be maintained and be effective throughout the period of natural flushing. The types of institutional controls used depend in part on the extent of the ground water contamination and the potential for future ground water use. These controls could involve purchasing the land or imposing land or water use restrictions. Other measures such as warning signs could be used to supplement controls that could be enforced (see Section 1.4.1). Institutional controls that restrict land use could result in significant impacts if these controls precluded any use of the land or require current uses to be discontinued. The extent of these impacts depends on current and potential future land use, land ownership, the type and duration of controls, and the extent of contamination. These impacts would be less at UMTRA Project processing sites that currently have restricted uses, that are publicly owned (e.g., by federal, state, or local governments), or that are managed for public purposes. Potentially greater impacts could occur in areas where contamination extends beyond the processing site boundaries and restrictions on land use would impact private property owners. It is possible that, as ground water contamination is reduced over time, restrictiveness of controls may be reduced. Restrictions on land use could result in decreased property values. Private landowners and state and local governments could be affected if restricted land use diminished property values and resulted in reduced property taxes levied (see Section 4.2.2.11). The use of an alternate water supply may enhance land use opportunities and increase property values. 4.2.2.7 Cultural/traditional resources Potential impacts to surface cultural resources would be minor because little if any site-disturbing activity would take place. Installation of fencing or monuments (institutional controls) would likely be the most intensive activity. Cultural resource surveys would be performed prior to site-disturbing activities and appropriate tribal officials would be contacted to identify and evaluate cultural or traditional resources that may be affected. In most cases, fencing and monuments could be located to avoid cultural resource sites. Water is a traditional resource of significance to many Native Americans. These resources often have ceremonial significance, and surficial expressions such as seeps may be associated with traditional, symbolic plants. Remediation of contaminated ground water by natural flushing would have a positive impact on this resource. Impacts to this Native American traditional resource would be reduced as natural flushing progressed. Natural flushing would not affect background noise levels in the site area because no noise-generating activities would occur except for brief periods during the construction of some types of institutional control features. Natural flushing could result in the use of signs, monuments, or fences to control human land use above the contaminated aquifer. These measures typically would be unobtrusive (small and low to the ground), resulting in minor (if any) impact on visual resources. In areas of scenic beauty, structures used to implement institutional controls (such as fences) could negatively impact visual resources. Monitor wells used during site characterization, ground water remediation, and monitoring may have a visual impact, particularly on residents near the sites. The DOE would work with local landowners, residents, tribes, and states where necessary to reduce this potential visual impact through the use of such measures as flush-mounted monitor wells or landscaping. During the operational phase, the only traffic would be for water quality monitoring and monitoring to verify that institutional controls were working as planned. There would be no transportation impacts from these activities. 4.2.2.11 Social and economic resources No impacts on demography, employment, community services, or facilities would be expected if natural flushing were implemented because essentially no activities associated with this strategy would require a work force. Institutional controls may require occasional maintenance and monitoring. Institutional controls that restrict land use could represent an economic loss to a property owner by precluding a higher use of the land. For example, grazing might be allowed within an area of institutional control, but a more intense (and potentially profitable) use of the land, such as crop production or residential use, may not be allowed. In some cases, the land could be restricted from any use during the period of natural flushing. Restrictions on land use also could decrease property values and significantly affect private landowners. Restricted land use and lower property values reduce the amount of property taxes available to state and local governments that are funded primarily by property taxes (e.g., schools). Furthermore, institutional controls that preclude current land uses such as agricultural activities could result in unemployment of the affected landowners and agricultural workers. The extent of the potential adverse economic impact would depend on the type and duration of the land use restrictions, the current use and ownership of the land, and the reasonable alternative uses of the land that could be precluded because of the institutional controls. Another potential impact of institutional controls could be to users of the aquifer who own the water rights. These controls could prevent the user from accessing the ground water. As with active ground water remediation, the potential for such an impact would be determined during preparation of the site-specific environmental assessment. 4.2.2.12 Environmental justice Minority or low-income populations would not experience disproportionately high or adverse environmental impacts if criteria for natural flushing are met. However, under the passive remediation alternative, it is possible that the criteria would not be met and that natural flushing would not be protective of human health and the environment at some sites (Section 4.2.2). For sites that have minority or low-income populations, there would be a potential for disproportionately higher impacts to human health and the environment. DOE will analyze such impacts in site-specific NEPA documents before making decisions to implement specific actions under the Ground Water Project. 4.2.2.13 Utilities and energy resources Natural flushing would not affect utilities or energy resources because no activities would occur that would require the use of these resources. 4.2.2.14 Waste management Contaminated materials that could be generated during site characterization and monitoring under the natural flushing strategy include well development water, drill cuttings and drilling muds, purge water, sludge and brine, and contaminated ground water and soils. These materials would be analyzed. Based on this analysis, solid material such as mud or soil would be applied to the land or disposed of in a disposal facility such as an existing open UMTRA Project cell capable of receiving these materials. Contaminated water would be treated, if necessary, and applied to the land, reinjected to the ground water, or discharged to surface water, after permits are received. Section 2.9 provides more details on the management of contaminated materials. Potential adverse impacts on human health or the environment are not expected from the generation, treatment, storage, or disposal of contaminated materials because all such activities would be performed in full compliance with applicable regulations and guidelines that were developed to be protective of human health and the environment. However, human error could result in environmental impacts. Activities associated with natural flushing include all the generic activities, additional site characterization, new wells, and revisions to site observational work plans. Natural flushing would likely require the use of institutional controls. This strategy would likely result in a longer monitoring period than the other two strategies. Estimated costs for the natural flushing compliance strategy range from $14 million to $24 million per site (escalated dollars) and include all generic costs associated with this strategy. 4.2.3 Impacts from applying supplemental standards or alternate concentration limits at no remediation sites Ground water at some UMTRA Project sites may exceed maximum concentration limits or background levels and yet require no remediation because the sites would qualify for supplemental standards or alternate concentration limits. Supplemental standards or alternate concentration limits could be used in combination with active ground water remediation methods and/or natural flushing to achieve compliance with the EPA ground water standards. For example, active remediation methods may be used to protect beneficial uses at a site that would otherwise qualify for supplemental standards. However, the analysis in this section considers only potential impacts from applying these standards at the no remediation sites; refer to Sections 4.2.1 and 4.2.2 for discussions of potential impacts of active ground water remediation methods and natural flushing. Supplemental standards and alternate concentration limits are described in Section 1.4.1. Eight criteria are available for applying supplemental standards. The occurrence of limited use ground water is the criterion that likely would be used most frequently to justify the application of supplemental standards for the UMTRA Ground Water Project. However, site-specific uses of ground water from limited use wells, if any, would be carefully evaluated when a supplemental standards application is prepared. Limited use ground water refers to water from units that have poor background quality or low yield (less than 150 gal [570 L] per day). Supplemental standards based on limited use ground water would not involve ground-disturbing activities. Other criteria for applying supplemental standards that may be used on the UMTRA Ground Water Project include 1) protection of the environment from excessive harm, and 2) inability to perform remedial action because it is technically impracticable. The use of supplemental standards may require monitoring or the use of some form of institutional controls to prevent access to contaminated ground water. The DOE UMTRA Ground Water Project would likely not use the remaining criteria listed in Section 1.4.1. A risk evaluation would be performed to determine whether the amount of contamination in the ground water would be protective of human health and the environment. In all cases, a supplemental standards application would be prepared that would require NRC concurrence, state participation, and consultation with Indian tribes to become effective. The use of alternate concentration limits would also require an application that would need NRC concurrence, state participation, and consultation with Indian tribes. A risk evaluation would have been performed to demonstrate that an alternate concentration limit would be protective of human health and the environment. This analysis also assumes that potential environmental impacts may be associated with using alternate concentration limits. The no remediation ground water compliance strategy would likely be used under all the alternatives except the no action alternative. There are two categories of no remediation sites. One category refers to sites where there is no ground water contamination above maximum concentration limits and/or background levels. Under the proposed action and the passive remediation alternative, this no remediation strategy would be appropriate at such sites. Under the active remediation to background levels alternative, this strategy may be appropriate if all the constituents are at background levels. It would not be appropriate for constituents below the maximum concentration limits but above background levels. The second category under the no remediation ground water compliance strategy refers to sites that have contamination above background levels and/or maximum concentration limits but are eligible for supplemental standards or alternate concentration limits. The sites that would be eligible for this no remediation strategy under the proposed action would also be eligible under the passive remediation alternative. In addition, some of these sites would be eligible for the no remediation strategy under the active remediation to background levels alternative. At some sites, no remediation in the form of supplemental standards based on the existence of limited use ground water could be part of the active remediation to background levels alternative. The following analysis includes the potential impacts of applying supplemental standards (based on the environmental harm and technical impracticability criteria) and of applying alternate concentration limits. For successful application of supplemental standards or alternate concentration limits, a risk evaluation must show that these standards would be protective of human health and the environment. Monitoring or institutional controls may be required if alternate concentration limits or supplemental standards are used. Monitoring may be required to assess the degree and extent of ground water contamination to ensure that supplemental standards and alternate concentration limits remained protective of human health and the environment. Institutional controls may be used if, for example, it were technically impracticable to clean contaminated ground water, but controls were required to prevent its inadvertent use. Consequently, the likelihood of human exposure to contaminated ground water and the surface expression of this water at sites that met supplemental standards or alternate concentration limits would be remote. Dust and priority pollutant emissions would not result from the application of supplemental standards or alternate concentration limits because few or no ground-disturbing activities would occur. The potential for discharge of contaminated ground water into surface water bodies would be unlikely. As indicated in Section 4.2.3.1, a monitoring program may be required for the use of some supplemental standards and for alternate concentration limits, that may include sampling surface water bodies. If contamination were discovered, further evaluation would be undertaken and remedial action performed if required. The application of supplemental standards would have little or no impact on ground water at sites that qualify for supplemental standards based on the presence of limited use ground water. Contaminated ground water at sites that qualify for supplemental standards based on other criteria or alternate concentration limits could contaminate less contaminated or noncontaminated ground water. Ground water monitoring may be required to assess this possibility under these supplemental standard criteria or alternate concentration limits. If supplemental standards or alternate concentration limits were applied, terrestrial and aquatic ecological habitat disturbance would be minimal because few or no ground-disturbing activities would occur. As part of the supplemental standards and alternate concentration limits application processes, an ecological risk evaluation may be updated to determine the potential for contaminated ground water to result in ecological risk. If unacceptable ecological risks could occur, supplemental standards or alternate concentration limits likely would not be proposed. If there were no ecological risks or the risks were acceptable, these standards could be applied if no other factors precluded their use. As indicated in Section 4.2.3.1, a monitoring program may be implemented as part of the supplemental standards and alternate concentration limits applications. If monitoring indicated contaminated ground water from the UMTRA Project site had been released into aquatic habitats such as wetlands and springs, another ecological risk evaluation may be performed. If the results of this evaluation indicated unacceptable risk, remedial action might be required. Little or no ground-disturbing activity would occur if supplemental standards or alternate concentration limits were applied. The only activity that would potentially affect land use would be the use of institutional controls. Institutional controls may be implemented if the limited use criterion were used to apply for supplemental standards. These types of controls also may be required if another criterion (such as excessive environmental harm or the technical impracticability of ground water remediation) were used, or if alternate concentration limits were applied. The potential impacts on land use associated with the use of institutional controls are discussed in Section 4.2.2.6. 4.2.3.7 Cultural/traditional resources There would be no impacts to surface cultural resources because no surface disturbance would take place. Minor surface disturbance would occur if institutional controls were used in conjunction with supplemental standards. The potential impacts of institutional controls on cultural resources are discussed in Section 4.2.2.7. With the application of supplemental standards or alternate concentration limits, contaminants associated with the UMTRA Project would most likely not be removed. Therefore, traditional resource impacts associated with ground water would not be mitigated. However, at sites where supplemental standards were applied using the limited use criterion, the surrounding background ground water quality is poor; therefore, the impact of leaving the contaminated ground water would be minor. The application of supplemental standards or alternate concentration limits would not affect ambient noise because no noise-generating activities would take place. Impacts on visual resources would be limited to those associated with site characterization activities (refer to Section 4.1) or the implementation of institutional controls. These potential impacts would be minor and temporary. Monitor wells used during site characterization, ground water remediation, and monitoring may have a visual impact, particularly on residents near the sites. The DOE would work with local landowners, residents, tribes, and states where necessary to reduce this potential visual impact through the use of such measures as flush-mounted monitor wells or landscaping. There would be no transportation impacts if supplemental standards or alternate concentration limits were instituted. 4.2.3.11 Social and economic resources Supplemental standards or alternate concentration limits would have little impact on socioeconomics because no ground water remediation activities would take place. Potential minor negative economic impacts could result from the implementation of institutional controls (refer to Section 4.2.2.11). 4.2.3.12 Environmental justice Disproportionately high or adverse effects to minority or low-income populations would not occur if application of supplemental standards or alternative concentration limits were protective of human health and the environment. 4.2.3.13 Utilities and energy resources Supplemental standards would not affect utilities or energy resources because no activities would occur that require these resources. The following contaminated materials may be generated during site characterization and monitoring under the no remediation strategy: well development water, drill cuttings and drilling muds, purge water, sludge and brine, and contaminated ground water and soils. These materials would be analyzed. Based on this analysis, solid material such as mud or soil would be applied to the land or disposed of in a disposal facility such as an existing open UMTRA Project cell capable of receiving these materials. Contaminated water would be treated, if necessary, and applied to the land, reinjected to the ground water, or discharged to surface water, after permits are received. Section 2.9 describes the management of contaminated materials. Potential negative impacts are not expected to human health and the environment from the generation, treatment, storage, or disposal of contaminated materials because all such activities would be performed in full compliance with applicable regulations and guidelines that were developed to be protective of human health and the environment. However, human error may result in environmental impacts. Activities associated with the no remediation compliance strategy include the general activities required for the other two strategies, including site characterization and possible revision of the site observational work plans. This strategy would also require the preparation of supplemental standards and/or alternate concentration limits applications and the concurrence of these applications by the NRC. The estimated cost of the no remediation compliance strategy is $1 million to $10.4 million per site, based on 1995 escalated dollars. 4.2.4 Impacts comparison and summary This summary compares the potential negative impacts of the ground water compliance strategies. How these potential impacts relate to the alternatives is presented in Section 4.4. The impacts analysis does not relate to the no action alternative because none of the strategies would be used under this alternative. The potential impacts of the no action alternative are assessed in Section 4.3. It is anticipated that the impacts that could occur for each
strategy (see Table 4.4) would be
the impacts analyzed in the site-specific NEPA documents.
Based on this analysis, the number of potential negative impacts
is highest for the active ground water remediation methods,
next highest for natural flushing, and lowest for no remediation
sites that meet the standards with supplemental standards
or alternate concentration limits (Table
4.4). Under the no action alternative, the UMTRA Project would end with the completion of surface remediation. The DOE would perform no ground water compliance or remediation activities. Evaluation of the no action alternative is required under the NEPA, as it provides a baseline against which impacts of other alternatives can be compared. The no action alternative could expose humans to contaminated ground water. Under this alternative, there would be no federally sponsored ground water compliance, remediation, monitoring, or controls over the contaminated aquifers. Although unlikely, exposure could occur in the following ways: There would be no air quality impacts because no ground-disturbing activities would occur. Under the no action alternative, the discharge of contaminated ground water to surface water bodies (streams, rivers, ponds, wetlands, springs, or arroyos) would continue. In addition, there is the potential for currently uncontaminated surface water bodies to become contaminated. The potential impacts to surface water bodies would be greater in areas of standing water because the hazardous constituents would concentrate in the sediments of ponds or wetlands. The accumulation of contaminants in these aquatic habitats could result in human health and ecological impacts, as discussed in Sections 4.3.1 and 4.3.5. Under the no action alternative, uncontaminated ground water in the same aquifer and other aquifers could become contaminated. This could result in adverse human health and environmental impacts. Under the no action alternative, the continued spread of contaminated ground water and surface water may reduce the beneficial uses of the water, such as drinking, irrigating, or stock watering. These impacts likely would be long-term because there would be no federal program to clean up the ground water; remediation would be accomplished by natural processes that could take decades or longer. The spread of ground water contamination also could result in negative impacts on land use (refer to Section 4.3.6) and to social and economic resources (Section 4.3.11). The no action alternative would not destroy wildlife or aquatic habitats and would not affect threatened and endangered species because site-disturbing activities would not occur. Habitats and protected species could be adversely affected if contaminated ground water were discharged to the surface or if plant roots took up contaminated ground water. Contaminant plumes could surface in sensitive areas such as ponds, lakes, and wetlands that may be hydrologically connected to a contaminated aquifer. Contaminants may accumulate in the sediments and be transported through the food chain and into the terrestrial ecosystems. These contaminants could be taken up by aquatic and/or terrestrial threatened or endangered species. Contaminants could also be ingested directly by humans drinking contaminated water or indirectly by consuming fish, wildlife, or livestock that have ingested contaminated material from the affected habitat. Since there would be no Ground Water Project under this alternative, DOE would not monitor the fate and transport of the contaminated ground water and would take no measures to mitigate potential contamination of sensitive habitats, threatened and endangered species, other biological resources, or livestock. The no action alternative could affect land uses because the potential for access to and use of contaminated water could spread contaminated ground water and surface water. Contamination could spread to wells currently used for agricultural purposes, causing farmers or ranchers to seek alternative water supplies. The no action alternative also could affect agricultural land use (e.g., crops and livestock grazing) due to the potential for plant uptake of contaminated water or if ground water discharged to the surface. More intense uses such as industrial, commercial, or residential development also would be affected. This impact would be long-term and could extend over larger land areas if the contaminated ground water plume expands over time. 4.3.7 Cultural/traditional resources The no action alternative could affect cultural and historic resources because contaminants associated with UMTRA Project sites would not be removed. Therefore, traditional Native American water resources would be adversely affected by the contaminated ground water. Some Native Americans already consider ground water a cultural/traditional resource that is adversely impacted. The no action alternative would not affect background noise levels near the sites because there would be no remediation activities. There would be no impact on visual resources from the no action alternative because there would be no remediation activities. The no action alternative would not affect traffic or transportation patterns because no traffic-generating activities would occur. 4.3.11 Social and economic resources The no action alternative could result in the contamination of ground water currently used for domestic purposes (refer to Section 4.3.1). Replacing domestic water sources that become contaminated could require drilling new wells, purchasing bottled water, or funding a domestic water supply line. The potential contamination of domestic and/or agricultural water supplies could adversely affect property values and sales of agricultural products grown in the area. Under no action, there is a potential for significant negative effects on human health and the environment as indicated above. Therefore, a potential exists for high or adverse disproportionate impacts at UMTRA Project sites on minority or low-income populations. For example, low-income or minority populations may not have the financial means to provide an alternate source of drinking water if ground water at the site does not meet compliance. 4.3.13 Utilities and energy resources The no action alternative would have no effect on utilities and energy resources because there would be no remediation activities. No contaminated materials associated with site characterization, monitoring, or remedial action would be generated under the no action alternative; therefore, there would be no impact. Fiscal impacts associated with the no action alternative
represent the costs expended on the Ground Water Project to
date (such as preparation of this PEIS) and estimated costs
to close down current ongoing activities associated with preliminary
Ground Water Project activities. Estimated total cost of the
no action alternative is $20.1 million, including an estimated
$6.6 million in 1995. 4.4 COMPARISON OF ALTERNATIVES The qualitative analysis of potential impacts of the ground water compliance strategies and the no action alternative as presented in Sections 4.2 and 4.3 are used below to compare the alternatives. This analysis compares one alternative to another alternative. For example, if the no action alternative is said to have a high potential for ecological risk, it is high only in relation to the other alternatives' potential for such an impact. These comparisons do not assess the type and degree of impacts at a given site; this type of assessment would be provided in the site-specific NEPA documents that would tier off the PEIS. Assumptions regarding the severity of potential impacts among alternatives for each impact category are based on the impact analyses in Sections 4.2 and 4.3. In comparing the potential impacts of the alternatives, technical specialists in each field were consulted. These comparisons are subjective because they are based on estimates of potential impacts, not measurements of actual impacts resulting from on-site remediation. Further, the comparisons treat all impacts equally so that, for example, potential impacts to human health are considered equal to potential impacts on cultural resources. To give more weight to potentially more severe impacts, long-term and short-term impacts were compared separately (Section 4.4.15). Long-term impacts would have the potential to be more severe because they would result from leaving contaminated ground water in place or using institutional controls for a long time. In general, short-term impacts would be potentially less severe because most relate to the effects of construction (such as habitat destruction, noise, and dust emissions) that are relatively minor and/or can be mitigated. While these effects are important, there is greater concern about the potential long-term health and environmental effects of leaving contaminated ground water in place. The potential short- and long-term health effects from contaminated ground water would be low for the proposed action and the active remediation to background levels alternative because they would result in compliance with EPA ground water standards at all UMTRA Project sites. In addition, institutional controls may be in place for sites under all alternatives except no action where contaminated ground water has migrated off the site. The passive remediation alternative would have some potential for adverse health effects because passive strategies and the duration of institutional controls may not protect human health at some sites. However, it would have less impact than the no action alternative because the viability of using the no remediation compliance strategy would be justified at some sites and the public would be protected from contaminated ground water at the remaining sites. The no action alternative would have the highest potential to result in adverse health effects from contaminated ground water because no federally sponsored ground water remediation, controls, or monitoring of the contaminated ground water would take place; this impact could be long-term. The potential for the Ground Water Project to affect air quality would be minimal, especially for the no action and passive remediation alternatives. Potential air quality impacts would be low for the proposed action alternative, which relies, at least partially, on passive ground water remediation strategies and methods. The active remediation to background levels alternative would have a short-term potential for minor air quality impacts because of its reliance on active ground water remediation methods; however, mitigation measures could be taken to ensure that no significant impact occurs. There would be no long-term air quality impacts. The proposed action and the active remediation to background levels alternative would have a low potential to result in the contamination of surface water bodies because ground water (the potential source for surface water contamination) would meet EPA ground water standards under these alternatives. Surface water monitoring would take place during ground water remediation activities at the sites and, if necessary, remedial action would be initiated. The passive remediation alternative would have more potential to result in the contamination of surface water bodies because, while passive measures could be adequate at some sites, active methods could be needed at other sites to control plume migration. Under this alternative, there would be no way to clean up contaminated surface water. However, the use of this water could be restricted, thereby reducing the potential impact of using contaminated surface water. The no action alternative would have the greatest potential to result in the contamination of surface water bodies because there would be no federally sponsored remediation. In addition, the use of the contaminated water would not be controlled. The proposed action and the active remediation to background levels alternative would have the least potential to result in contamination of uncontaminated ground water because these alternatives are expected to clean up the quality of contaminated ground water to at least the EPA ground water standards. Ground water monitoring would detect any expansion of the contamination so that appropriate controls could be implemented. Under the passive remediation and no action alternatives, the potential spread of ground water contamination could not be prevented or slowed because active remediation would not be possible. However, the passive remediation alternative would attempt to meet the standards, resulting in less of an impact than no action. The spread of this contaminated ground water would have a greater potential for negative impacts under the no action alternative because access to this water could not be controlled. In general, the impacts of surface disturbance activities associated with site characterization and active ground water remediation would be short-term. However, if active remediation took several years, these impacts could become long-term and significant. The potential ecological impacts of leaving contaminated |
