>> Mercury Storage EIS Questions and Answers
What are DOE's objectives in the Mercury Storage EIS/SEIS?
DOE developed this EIS/SEIS to evaluate the potential impacts of the proposed action, i.e., to designate a facility(ies) for the long-term management and storage of mercury. In accomplishing this, DOE is committed to the following overall objectives for its mercury storage program:
Protect human health and the environment and ensure the safety of workers and the public.
Meet the requirements of the Mercury Export Ban Act of 2008.
Comply with applicable Federal, state, and local laws and regulations.
What would the DOE mercury storage facility(ies) include?
The DOE mercury storage facility(ies) would include the following characteristics:
RCRA-regulated/permitted design with proper spill containment features and emergency response procedures;
Security and access control;
Fire suppression systems;
Ventilated storage area(s);
Fully enclosed weather-protected building(s);
Reinforced-concrete floors able to accommodate mercury storage.
Where would the mercury come from?
Potential sources of mercury that may require long-term storage include:
four chlor-alkali plants expected to still be using mercury-cell technology beyond 2010;
gold mining in the state of Nevada, which produces the majority of U.S. byproduct mercury and to a lesser extent South Dakota;
six companies that account for most of the secondary mercury waste reclamation and recycling; and
potentially, some or all of the mercury currently stored at the Y-12 National Security Complex in Oak Ridge, TN.
What decisions will be made?
In making long-term mercury management decisions, DOE will consider the results of this EIS/SEIS, public comments, and other relevant factors. DOE intends to make the following decisions:
Where to locate the mercury storage facility(ies)
Whether to use existing buildings, new buildings, or a combination of existing and new buildings for mercury storage.
What is analyzed in this EIS/SEIS?
Areas analyzed for each candidate mercury storage site include: land use and visual resources; geology, soils, and geologic hazards; water resources; meteorology, air quality, and noise; ecological resources; cultural and paleontological resources; site infrastructure; waste management; occupational and public health and safety; ecological risk; socioeconomics; and environmental justice.
How were potential mercury storage sites identified?
To begin the process of identifying potential mercury storage sites, DOE published a Request for Expressions of Interest in Federal Business Opportunities and the Federal Register in March 2009. DOE also issued an internal memorandum asking offices within DOE to determine whether they have facilities that could be used for mercury storage, as well as the feasibility of new construction.
A number of positive responses were received, including responses from the seven Government sites and private companies:
DOE also developed the following criteria for identifying candidate sites:
The facility(ies) will not create significant conflict with any existing DOE site mission and will not interfere with future mission compatibility.
The candidate location has an existing facility(ies) suitable for mercury storage with the capability and flexibility for operational expansion, if necessary.
The facility(ies) is, or potentially will be, capable of complying with RCRA permitting requirements, including siting requirements.
The facility(ies) has supporting infrastructure and a capability or potential capability for flooring that would support mercury loadings.
Storage of mercury at the facility(ies) is compatible with local and regional land use plans, and new construction would be feasible, as may be required.
The facility(ies) is accessible to major transportation routes.
The candidate location has sufficient information on hand to adequately characterize the site.
Which sites are considered in the Mercury Storage EIS/SEIS?
DOE identified seven sites as potential locations to be evaluated in the January 2011 EIS:
DOE-Grand Junction Disposal Site, near Grand Junction, Colorado
DOE-Hanford Site, near Richland, Washington
DOE-Idaho National Laboratory, near Idaho Falls, Idaho
DOE-Kansas City Plant, Kansas City, Missouri
DOE-Savannah River Site, near Aiken, South Carolina
Hawthorne Army Depot, near Hawthorne, Nevada
Waste Control Specialists, near Andrews, Texas
DOE identified three locations in the vicinity of the Waste Isolation Pilot Plant, near Carlsbad, New Mexico as potential candidate sites to be analyzed in a Supplemental EIS.
What are the impacts identified in the EIS/SEIS?
The impacts on the various resource areas at each site from construction and operation of a mercury storage facility(ies) would range from none to minor. No resource area at any site evaluated was predicted to be subject to impacts greater than minor. The analyses in this EIS include the following conclusions, among others:
Impacts on land use and visual resources are expected to range from negligible to minor at all candidate sites.
In the areas of geology, soils, and geologic hazards, construction of a new storage facility would expose surface soil for up to six months. Although unlikely to occur over the 40-year analysis period, geologic hazards such as earthquakes could potentially have an adverse effect on a mercury storage facility(ies).
Under all alternatives, best management practices, including adherence to an integrated contingency plan and spill prevention, control, and countermeasures plan for mercury storage, would be employed to prevent spills and releases, including the use of spill trays under mercury containers, spill containment features, and regular inspections.
Did DOE consider a multiple-site strategy?
DOE considered the possibility of using a "hybrid" or multiple-site strategy composed of candidate sites being evaluated in this Mercury Storage EIS. DOE eliminated such a strategy from further evaluation because the duplicative resources that would be required would not be cost-effective.
Did DOE consider treatment alternatives?
The EPA has not yet established treatment and disposal standards for the elemental mercury waste DOE would store. Therefore, DOE did not consider treatment and storage or disposal for detailed evaluation.
What is the Department of Energy's Preferred Alternative?
DOE's preferred alternative is Waste Control Specialists, LLC, (WCS). WCS is a commercial entity that owns and operates a 541-hectare (1,338-acre) site for the treatment, storage, and landfill disposal of various hazardous and radioactive wastes.
The site is located approximately 50 kilometers (31 miles) west of Andrews, Texas, and 10 kilometers (6 miles) east of Eunice, New Mexico. It is surrounded by a 13,500-acre tract of land also owned by Waste Control Specialists. The facility is currently permitted under the Resource Conservation and Recovery Act (RCRA) for storage of hazardous waste. Under this alternative, a new facility would be constructed either north or south of the existing commercial hazardous waste storage facilities. The existing Container Storage Building, within the Waste Control Specialists site, is covered under the existing RCRA permit and could be considered for storage of mercury on an interim basis until the new storage facility could be constructed. The Container Storage Building is configured to store hazardous waste, would be suitable for storage of mercury, and could provide up to approximately 28,500 square feet of storage space. Truck and rail access are available at the site.
Why was WCS selected as the Preferred Alternative?
The WCS site is located in a remote, lightly populated area that has been extensively characterized and studied due to the wide range of waste management activities carried on there. The storage of mercury would be compatible with existing waste management activities, land use plans, and regulatory agreements. It has a RCRA permit to handle hazardous waste and access to a rail line that runs through the property. There are no nearby major bodies of surface water.
How can a non-DOE site be considered for this mission?
Section 5(a)(1) of the Act requires the Secretary of Energy to "designate a facility or facilities of the Department of Energy... for the purpose of long-term management and storage of elemental mercury generated within the United States." DOE has interpreted the Act to authorize DOE to designate either existing and/or new storage facilities at property either owned or leased by DOE. Accordingly, if DOE decides to designate a facility that currently is owned by a commercial entity or by another Federal agency, DOE would acquire an appropriate ownership or leasehold interest in that facility in order to comply with section 5(a)(1) of the Act. DOE would ensure that any such facility currently owned by a commercial entity or by another Federal agency would afford the Department the same level of responsibility and control over stored mercury as a facility owned by DOE.
What is mercury?
It is a dense, silver-colored metallic element that is liquid at room temperature.
Sometimes called quicksilver.
Mercury is widespread in the U.S. and global environment.
Mercury occurs naturally in the environment in three forms: elemental, inorganic mercury compounds, and organic mercury compounds.
Properties enable mercury to conduct electricity, react to temperature changes, and to alloy with other metals.
For more information please consult the EPA Mercury homepage at http://www.epa.gov/mercury/about.htm
What was mercury historically used for?
Mercury has been used extensively in various manufacturing processes.
Common uses include:
blood pressure monitors
hood and trunk light switches in vehicles
gas flow metering
How does mercury enter the environment?
Mercury is released into the air, water, and soil by a
wide variety of natural processes and human activities.
Elemental mercury is released as a gas from rocks and
Manmade sources include mining operations, manufacturing
processes, incineration, and fuel combustion.
Long-range transport of gases can occur in the atmosphere.
For more information please consult the EPA Mercury
homepage at http://www.epa.gov/mercury/eco.htm
Which manufacturing and mining processes result in mercury emissions?
combustion of fossil fuel such as coal
mining and smelting of metal ores
medical and municipal waste incineration
mercury cell chlor-alkali plants
Less common sources of atmospheric mercury include waste
oil combustion, geothermal energy plants, and diffuse emissions from dental procedures.
How does mercury contaminate the environment?
Mercury released into the environment stays there for a long time.
It pollutes the environment by changing forms and entering
our soil and water. For example, some released inorganic mercury slowly changes into methylmercury in soil and water.
Methylmercury can build up in certain fish. For this
reason, rather low levels of mercury in the ocean and lakes can contaminate these fish.
Is mercury toxic?
The three forms of mercury are toxic and each form produces different health
effects in humans.
Elemental (also called metallic) mercury is the least toxic of the three forms.
How are people exposed to mercury?
According to the Agency for Toxic Substances and Disease Registry (ATSDR), mercury can enter the body by the following pathways:
air when mercury vapor is inhaled.
food when ingested by eating contaminated fish or other
foods. People who eat large amounts of fish such as tuna and swordfish may be exposed to mercury because these fish can have elevated levels of organic
mercury compared with other foods.
water it can also enter the body when water contaminated with mercury is consumed.
skin mercury may also enter the body directly through the skin.
Once mercury has entered the body, it may be months before
most of it leaves. It leaves the body mostly through the urine and feces.
For example, workplace exposure can occur in medical,
dental, and other health services, and in chemical, metal processing, electrical equipment, and automotive industries.
What risks to the public health are associated with mercury?
Risks to the public are minimal when elemental mercury is stored correctly.
Mercury is a toxic substance and is, therefore, subject to
strict controls to prevent or reduce exposure or release to the environment.
According to the ATSDR, both short and long-term exposure
to elemental mercury can cause health problems. At high exposure levels,
elemental mercury can affect the nervous system; other forms of mercury can
damage other organs. The United States
Environmental Protection Agency (EPA) has concluded that available data does
not support classification of elemental mercury as a human carcinogen.
What measures has the federal government undertaken to protect human health from mercury exposure?
EPA requires that any releases to the environment of more
than 1 pound (0.454 kg) of mercury must be reported (i.e., the National Response Center must be notified).
EPA currently recommends that the level of inorganic
mercury in rivers, lakes, and streams not exceed 144 parts per trillion (ppt).
EPA estimates that for an adult of average weight,
exposure up to 0.021 milligrams (mg) of inorganic or organic mercury per day in food or water will not result in any harm to health.
The Food and Drug Administration (FDA) limits levels of
mercury to no more than 2 parts per billion (ppb) (0.002 milligrams of mercury
per liter of water [mg/L]) in bottled water. EPA drinking water standards are the same for public water systems.
The Occupational Safety and Health Administration (OSHA) has set a limit of 1.2 ppb of organic mercury vapor in workroom air (equal to
0.01 milligrams of mercury per cubic meter of air [mg/m3]) and 6.1 ppb (0.05 mg/m3) for inorganic mercury vapor to protect workers during an 8-hour shift.
Is there a medical test to determine if I have been exposed to mercury?
There are reliable, accurate, tests that can be performed
in doctors offices or health clinics to determine exposure levels and the likelihood of health effects.
Blood or urine samples can be taken in a doctor's office
and tested using special equipment in a laboratory. Levels found in blood and
urine may indicate possible health effects.
What form of mercury will be stored by DOE?
Elemental (also called metallic) mercury, the least toxic of the three forms.
Is the elemental mercury to be stored by DOE a hazardous waste under RCRA?
Elemental mercury shipped to the DOE mercury storage facility may or may not be classified (by the generator or originator
of the elemental mercury) as a RCRA hazardous waste; however, once the elemental mercury is received by DOE it will be managed as RCRA hazardous waste
and stored in a facility operated in accordance with RCRA hazardous waste facility requirements (i.e., pursuant to RCRA interim status standards and
ultimately a RCRA hazardous waste facility permit).
A RCRA hazardous waste is a waste that is listed as such or that exhibits at least one of four characteristics: ignitability,
corrosivity, reactivity, or toxicity.
Why is DOE now responsible for mercury storage?
The Mercury Export Ban Act of 2008 prohibits export of elemental mercury beginning Jan. 1, 2013.
Also the Act requires DOE to provide storage and long-term
management of elemental mercury generated in the U.S. and delivered to such a facility.
How much mercury will be stored at the DOE storage facility and where will it come from?
There are several sources of elemental mercury in the United States, including mercury used in the mercury cell process for the manufacture of
chlorine and caustic soda (i.e., chlor-alkali industry), reclaimed from recycling and waste recovery activities, and generated as a byproduct of the
gold mining process. In addition, DOE stores approximately 1,200 metric tons of elemental mercury at its Oak Ridge Reservation in Oak Ridge, Tennessee.
An EPA report, Mercury Storage Cost Estimates (2007), estimates the total amount of elemental mercury from nongovernmental sources that would be eligible for DOE storage is between 7,500
and 10,000 metric tons over a 40-year period. DOE plans to use such estimates and other credible sources of information to develop an annual and long-term inventory estimate for EIS evaluation.
The Department of Defense, Defense Logistics Agency (DLA) has made a determination to locate a permanent storage
facility for their stockpile of approximately 4,400 metric tons of elemental mercury at the Hawthorne Army Depot in Hawthorne, Nevada.
Who will pay for its storage?
Congress stated in the Mercury Export Ban Act that those who send their elemental mercury
to the DOE facility will pay a fee for storage.
What is an Environmental Impact Statement (EIS/SEIS)?
An EIS/SEIS is a detailed, written statement that is required by Section 102(2)(C) of the National Environmental Policy Act (NEPA) for a proposed major
Federal action significantly affecting the quality of the human environment. A DOE EIS/SEIS is prepared in accordance with applicable requirements of the Council
on Environmental Quality NEPA regulations in 40 CFR 1500-1508, and DOE NEPA regulations in 10 CFR Part 1021.
Process includes input from Federal agencies, states, local governments, Tribal governments, non-governmental organizations and other
interested parties on scope of the EIS/SEIS and content of the EIS/SEIS.
What is the National Environmental Policy Act (NEPA)?
The National Environmental Policy Act is the basic national charter for protection of the environment. It establishes policy, set goals (in Section
101), and provides means (in Section 102) for carrying out the policy. Section 102(2) contains action-forcing provisions to ensure that Federal agencies follow the letter and spirit of the
Act. For major Federal actions significantly affecting the quality of the human environment, Section 102(2)(C) of NEPA requires Federal agencies to prepare a detailed statement that includes
the environmental impacts of the proposed action and other specified information.
No decision can be made until the NEPA process is complete.
What is the purpose of the Mercury Storage EIS/SEIS?
NEPA requires Federal agencies to conduct an EIS/SEIS for major actions that may significantly affect the environment.
DOE needs to develop a capability for the safe and secure long-term management and storage
of elemental mercury as required by the Act. Accordingly, DOE needs to identify an appropriate facility or facilities to host this activity.
The EIS/SEIS will inform decisionmakers and the public about the environmental impacts of alternatives for mercury storage.
What impacts does the Mercury Storage EIS/SEIS consider?
Potential effects on the public health under routine and credible accident scenarios.
Impacts on surface and groundwater, floodplains and wetlands, water use and quality.
Impacts on air quality (including global climate change).
Impacts on plants and animals and their habitats.
Impacts on geology and soils.
Impacts on cultural resources.
Socioeconomic impacts on potentially affected communities.
Potential impacts on land-use and visual resources.
Pollution prevention and waste management activities.
Unavoidable adverse impacts, and irreversible and irretrievable commitments of resources.
Potential cumulative environmental effects of past, present and foreseeable future actions.
Status of compliance with applicable Federal, state and local laws and regulations,
international agreements, and required environmental permits.
Potential impacts of intentional destructive acts, including sabotage and terrorism.
Was the movement of elemental mercury analyzed in the EIS/SEIS?
Yes, the EIS/SEIS includes analyses of transportation
issues related to the movement of elemental mercury from the generator/originator sites to the DOE storage facility.
Will DOE make public its intentions to move mercury so that local officials and the public can be forewarned?
DOE will comply with all requirements for notification of state and local officials and emergency response personnel.
Does the EIS/SEIS consider terrorist possibilities?
Although a mercury storage site is not considered an
attractive target for terrorists, such issues were considered in the risk analysis completed in conjunction with the Mercury Storage EIS/SEIS.