Record of Decision, Shutdown of the River Water System at the Savannah River Site, Savannah River Operations Office, Aiken, South Carolina

DEPARTMENT OF ENERGY

Record of Decision, Shutdown of the River Water System at the

Savannah River Site, Savannah River Operations Office, Aiken, South

Carolina

AGENCY: U.S. Department of Energy.

ACTION: Record of Decision.

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SUMMARY: The U.S. DOE has decided to implement the No Action

alternative identified in the Final Environmental Impact Statement for

the Shutdown of the River Water System (RWEIS) at the Savannah River

Site (SRS). Under this alternative, DOE will continue to operate and

maintain the system and maintain the water level of L-Lake.

DOE will assess the need for future environmental remediation

alternatives for L-Lake under existing Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA) commitments.

Characterization activities associated with CERCLA closure are expected

to begin in the year 2000 and be completed in several years. This

characterization will inform any required remedial action. Pending

these activities, DOE will continue to operate the RWS. If during

continued operation of the RWS a system component fails, DOE will take

appropriate emergency actions. DOE will then determine if the system is

too costly to repair (by comparing this cost to estimated shutdown

costs and future possible remediation costs under the CERCLA). If DOE

determines that the RWS is too costly to repair, it will reevaluate all

relevant commitments and the information in the RWEIS, to determine

necessary actions to shut down the RWS. However, the RWS is in good

condition and not expected to fail over this period of time.

This RWEIS evaluates three alternatives for the disposition of the

RWS at the SRS. The RWS is a 50-mile underground concrete piping

structure and pumping system that was built in the early 1950s to

provide cooling water for the SRS' five nuclear production reactors.

The RWEIS alternatives cover the spectrum of reasonable options as

follows:

(1) Continue operation of the RWS (No Action Alternative);

(2) Shut down and maintain the RWS for potential restart (Preferred

Alternative); and

(3) Shut down and deactivate the RWS with no maintenance for

potential restart.

Based on the RWEIS evaluation of the potential environmental

impacts, as well as the costs, energy consumption, and regulatory

implications of the alternatives, DOE has selected the No Action

alternative and will continue to operate the RWS. Other than potential

CERCLA remediation activities, if DOE continued to operate and maintain

the RWS indefinitely the No-Action Alternative would require the

greatest commitment of money and energy resources. The RWS would

continue to supply 5,000 gpm to L-Lake from the Savannah River. To do

so, DOE would spend approximately $1,084,000 annually to provide RWS

surveillance and maintenance and $494,000 annually for electrical

energy to pump the water uphill from the river. Finally, DOE would

continue to dredge the RWS intake canal to keep it clear of debris.

However, there is great uncertainty regarding the cost of remedial

action under CERCLA. Therefore, until characterization is completed, it

will not be evident whether shutting down or continuing to operate and

maintain the RWS is economically the most prudent course of action.

In its present configuration, the RWS circulates water from the

Savannah River to a 1000 acre man-made lake known as L-Lake. L-Lake no

longer serves to mitigate thermal effluents from L-Reactor because it

no longer operates. RWS flow is necessary to maintain the full pool

water level of L-Lake.

[[Page 4237]]

Low-levels of radionuclides were released to Steel Creek before L-

Lake was constructed. As a result, contaminated sediments are largely

confined to the former Steel Creek stream bed and floodplain that

exists under L-Lake. The methods for any needed environmental

remediation of these low-level radionuclide releases to Steel Creek, as

well as those to other SRS streams, will be determined under the

Federal Facility Agreement (FFA). This agreement, between DOE, the U.S.

Environmental Protection Agency (EPA), and the South Carolina

Department of Health and Environmental Control (SCDHEC), provides a

commitment and schedule for the comprehensive remediation of

contamination at the SRS, including SRS streams and lakes.

In accordance with the present FFA schedule, DOE will begin

characterization of the L-Lake CERCLA unit in fiscal year 2000. DOE

anticipates that this process will lead to an Interim Record of

Decision (IROD) in Fiscal Year 2001. At that time DOE will decide

whether L-Lake should be drawn down to facilitate characterization of

future risks to human health and the environment. The characterization

process and risk evaluation will lead to the selection of a preferred

remedial alternative.

During these future draw down and characterization activities, DOE

expects to stabilize exposed sediments and address the ``reasonable and

prudent'' measures for protection of threatened and endangered species

that the U. S. Fish and Wildlife Service (USFWS) has recommended as a

result of the Endangered Species Act Section 7 consultation process.

FOR FURTHER INFORMATION CONTACT: For RWEIS information: Andrew R.

Grainger, NEPA Compliance Officer, U.S. Department of Energy, Savannah

River Operations Office, Building 773-42A, Rm. 212, Aiken, South

Carolina 29802, Telephone: (800) 881-7292, Attention: RWEIS, E-mail:

[email protected]

For general information on the DOE National Environmental Policy

Act (NEPA) process: Ms. Carol M. Borgstrom, Director, Office of NEPA

Policy and Assistance (EH-42), U.S. Department of Energy, 1000

Independence Avenue, S.W., Washington, D.C. 20585, Telephone: (202)

586-4600, or leave a message at (800) 472-2756.

SUPPLEMENTARY INFORMATION:

Background

Located in southwest South Carolina, the SRS occupies an area of

approximately 300 square miles (800 square kilometers). The Savannah

River forms the SRS's southwestern boundary for approximately twenty-

seven miles (forty-three kilometers) on the South Carolina-Georgia

border. The SRS is approximately twenty-five miles (forty kilometers)

southeast of Augusta, Georgia and twenty miles (thirty-two kilometers)

south of Aiken, South Carolina, the nearest major population centers.

The U.S. Atomic Energy Commission (AEC), a DOE predecessor agency,

established the SRS in the early 1950s for the production of nuclear

materials to support the United States' national defense, research, and

medical programs.

SRS produced these materials by irradiating nuclear fuel and

targets in SRS' five production reactors (C-, K-, L-, P-, and R-

Reactors). In the reactors, closed pipe loops contained water to cool

the fuel assemblies by passing water directly across them. The water in

this closed loop was then pumped to heat exchangers where heat was

transferred from the closed system to a secondary-cooling system. This

arrangement of closed loops minimized contamination of the environment.

The water for the secondary-cooling system was provided by the RWS.

The RWS pumped river water from the Savannah River using intake canals

and pumps to the heat exchangers in the reactor areas (C-, K-, L-, P-,

and R-Reactor areas) by way of distribution piping and water-storage

basins.\1\ The RWS also pumped water to Par Pond, which was used to

store additional secondary-cooling water for P- and R-Reactors.

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\1\ The water-storage basins are also known as 186-Basins.

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After passing through the heat exchangers and absorbing the heat

from the primary closed-loop cooling system, the heated water in the

secondary-cooling system was returned to the Savannah River by way of

several discharge canals and streams. After 1985, when construction of

L-Lake was completed, heated secondary-cooling water was also returned

to the Savannah River by way of L-Lake which dissipated the heat from

the thermal effluent (hot water) from L-Reactor. Thus, in all, the RWS

is composed of river water intake canals, intake pumps, distribution

piping to the reactor areas, 186-Basins, discharge canals, receiving

streams, and lakes (Par Pond and L-Lake).

At the end of the Cold War in 1992, SRS' mission emphasis shifted

from the production of nuclear materials to cleanup and environmental

restoration. Consequently, SRS' reactors were shut down, thereby

decreasing the demand for RWS flow. From 1988 to 1996, demand for RWS

flow and flow discharged to onsite streams decreased from 380,000

gallons per minute (gpm) to 5,000 gpm. Therefore, reflecting decreased

water needs and DOE's mandate to reduce operating costs, a 5,000 gpm

pump was installed in 1997 to replace a larger, and more costly to

operate, 28,000 gpm pump.\2\ Further, because of reduced RWS demand,

and because SRS' reactors will not operate again, DOE identified the

RWS as excess infrastructure, costly to operate and maintain, but with

limited application. Accordingly, DOE prepared the RWEIS to examine the

environmental impacts of RWS shutdown with the preference of

eliminating the operational costs of this infrastructure, now only

marginally useful.

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\2\ In the RWEIS, the No-Action Alternative impacts are assessed

against the baseline provided by operation of the 5,000 gpm pump.

DOE reviewed installation of the 5,000 gpm pump as a categorical

exclusion (EEC-SS-G-96-003) in accordance with DOE's NEPA

regulations. 10 CFR 1021. During assessment of the categorical

exclusion, DOE determined that a 5,000 gpm pump would be sufficient

to maintain L-Lake at 190 feet MSL and to provide the minimum

operating needs of K- and L-Reactor areas without violating any SRS

permits. Accordingly, the categorical exclusion was approved on June

6, 1996, and the pump installed thereafter.

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NEPA Process

DOE prepared this Record of Decision pursuant to the regulations of

the Council on Environmental Quality for implementing the National

Environmental Policy Act (NEPA), 40 CFR Parts 1500-1508, and DOE's NEPA

Implementing Procedures, 10 CFR Part 1021. This Record of Decision is

based on DOE's Final RWEIS for the Shutdown of the River Water System

at the Savannah River Site, Aiken, South Carolina (DOE/EIS-0268), for

which DOE published a Notice of Intent to prepare on June 12, 1996, in

the Federal Register, 61 Fed. Reg. 29744. The notice announced a public

scoping period, ending on July 12, 1996, and solicited comments and

suggestions on the EIS' scope. DOE held scoping meetings in North

Augusta, South Carolina on June 27, 1996. Comments received during the

scoping period and DOE's responses thereto were used to prepare an

action plan, issued in August 1996, defining the scope and approach of

the RWEIS. The action plan and reference materials cited in the RWEIS

were made available for review in the DOE Public Reading Room, located

at the University of South Carolina-Aiken Campus, Gregg-Graniteville

Library, 2nd Floor,

[[Page 4238]]

University Parkway, Aiken, South Carolina at (803) 641-3320.

DOE completed the draft RWEIS in November 1996, and on November 15,

1996, EPA published a Notice of Availability for the document in the

Federal Register, 61 Fed. Reg. 58548. This notice started the public

comment period for the draft RWEIS, which extended through December 30,

1996. DOE received comments by letter, electronic mail, and statements

made during public hearings held in North Augusta, South Carolina on

December 4, 1996, all of which were considered in preparing the final

RWEIS. DOE completed distribution of the final RWEIS in May 1997, and

on May 16, 1997, EPA published a Notice of Availability in the Federal

Register, 61 Fed. Reg. 27024. This ROD is the culmination of and final

step in the NEPA process for action on the RWS and announces DOE's

selection of an alternative.

Alternatives Considered in Final RWEIS

No-Action Alternative

The No-Action Alternative does not change the current status quo

and involves continued operation of the RWS using a 5,000 gpm pump.

Under this alternative, L-Lake would maintain its water level at 190

feet MSL with makeup water provided by the RWS. Par Pond water level

would continue to fluctuate naturally between 195 feet and 200 feet

MSL. Under severe drought conditions, and if necessary, the RWS could

be used to maintain Par Pond water level.

Proposed Action--Shut Down and Maintain Alternative

The Proposed Action--and Preferred Alternative, the Shut Down and

Maintain Alternative--provides for shutdown and maintenance of the RWS

in a standby condition that would allow restart. RWS shutdown would

result in the L-Lake water level returning to the original Steel Creek

stream bed over a ten year period. RWS shutdown would not change the

status quo regarding Par Pond's water level; it would continue to

fluctuate naturally between 195 feet and 200 feet MSL.

Under the Shut Down and Maintain Alternative, the RWS operational

capacity would be preserved in a standby mode to account for unforeseen

events, mission changes, or remedial action decisions. Maintaining the

RWS in a standby condition \3\ requires draining the system of water

and placing the equipment in a protective state minimizing

degradation.\4\ Under this alternative, the RWS operation could be

restored to provide water for future missions or, if necessary, to

maintain Par Pond water level above 195 feet MSL in the unlikely event

of a severe drought. In addition, the RWS could be restarted if the

final outcome of the FFA process recommends refilling L-Lake with water

to manage risk from contaminated sediments in the Steel Creek stream

bed. During the interim, or in the event none of these potentialities

are realized, shutdown of the RWS would eliminate operational costs

associated with this system.

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\3\ This standby condition is also referred to as ``lay-up.''

\4\ Placing the RWS in lay-up also allows maintaining portions

of the system in a higher state of readiness in order to restore

pumping capability more rapidly. Maintenance of certain portions of

the RWS in such a condition might be warranted (1) where those

portions are likely to be needed for future missions; (2) where they

might be necessary to maintain Par Pond water levels in the event of

a severe drought; or (3) where they might be necessary to refill L-

Lake in the event of determination to do so as a result of the FFA

process.

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Shut Down and Deactivate Alternative

The Shut Down and Deactivate Alternative provides for the permanent

cessation of RWS operation and does not preserve system capabilities,

even in the most marginal state, for restart. DOE would shut down and

deactivate the system in a secure, environmentally satisfactory

condition and isolate all the intake pipes to prevent river water

intrusion into the RWS. DOE would conduct no maintenance or

surveillance on the RWS, with the exception of the L-Lake dam, which

would be maintained until the Lake's water level returned to the

original Steel Creek stream bed in approximately 10 years.

Under this alternative, L-Lake water level would return to the

original Steel Creek stream bed. Par Pond water level would continue to

fluctuate naturally between 195 feet and 200 feet MSL. Under severe

drought conditions, the RWS could not be used to maintain Par Pond

water level, even if necessary. Furthermore, the RWS could not be

restarted if the final outcome of the FFA process recommended refilling

L-Lake with water to manage risk from contaminated sediments in the

Steel Creek stream bed.

Environmental Impacts of the Alternatives

Environmental Impacts of No Action Alternative

The No Action alternative would preserve the status quo and

continue current operation of the RWS through a 5,000 gpm pump.\5\

Under the No Action Alternative, L-Lake would remain at its normal

water level of 190 feet MSL. Par Pond water level would continue to

fluctuate naturally between 195 feet and 200 feet MSL.

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\5\ As previously noted, the environmental impacts of the 5,000

gpm pump were evaluated under a categorical exclusion. On December

30, 1996, EPA provided comments on the Draft RWEIS and questioned

the appropriateness of this categorical exclusion. EPA requested DOE

to describe more thoroughly the impacts associated with the 5,000

gpm pump. In response to EPA's comment, those impacts were included

in the Final RWEIS. A discussion demonstrating the appropriateness

of the categorical exclusion may be found in the RWEIS at page E-61.

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Environmental Impacts of Shut Down and Maintain & Shut Down and

Deactivate Alternatives

The environmental impacts of the Proposed Action--and Preferred

Alternative, the Shut Down and Maintain Alternative--are the same as

those of the Shut Down and Deactivate Alternative. Both alternatives

call for DOE to shutdown the RWS. While the Proposed Action calls for

DOE to preserve the RWS in a standby condition, the actions necessary

to accomplish that goal do not entail environmental impacts beyond

those associated with the shutdown action. Accordingly, the

environmental impacts of either alternative are the same and DOE

considers them together in the following paragraphs.

L-Lake

Under either the Shut Down and Maintain Alternative or the Shut

Down and Deactivate Alternative, DOE would not augment water flow to L-

Lake. L-Lake cannot maintain a water level of 190 feet MSL, its normal

full pool water level, without flow augmentation from the RWS.

Consequently, it would recede to the original Steel Creek stream bed

conditions over a ten-year period.

As L-Lake recedes to the Steel Creek stream bed as a consequence of

either shutdown alternative, habitat for amphibians, reptiles, semi-

aquatic mammals, wading birds, and waterfowl would be gradually reduced

and eliminated. Consequently, these species would be more vulnerable to

predation. Eventually, alligators would be displaced due to the loss of

habitat. Drawdown of L-Lake would result in the loss of nests, eggs, or

hatchlings.

In addition, the reversion of L-Lake water level to the former

Steel Creek stream bed would uncover lake bed sediments. As a result,

these sediments could be susceptible to the forces of erosion,

especially during storm events. In addition, the reversion of L-Lake

[[Page 4239]]

water level to the original Steel Creek stream bed could expose some

sediments, primarily in the Steel Creek stream bed, that could contain

low levels of contamination, primarily cesium-137.\6\ Animals foraging

in the L-Lake lake bed or Steel Creek stream bed could be exposed to

these sediments via inhalation, ingestion, direct radiation exposure,

and/or skin contact. Similarly, an on-site human working in the L-Lake

bed lake could be exposed to the contaminants in sediments via

inhalation, incidental ingestion, direct radiation exposure and/or skin

contact. An off-site human could be exposed to contaminants in

sediments through atmospheric or aqueous pathways via inhalation or

ingestion from sediments that have been re-suspended in air or water.

The off-site human would not be exposed to direct radiation.

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\6\ Cesium-137 is an external radiation hazard from direct

exposure to gamma radiation which penetrates clothing and skin.

Measurements taken under the surface of L-Lake show that cesium in

the Lake sediments is largely concentrated in the original Steel

Creek floodplain, currently beneath the surface of L-Lake. These

measurements also show that a maximum (24-hour per day) radiation

dose received by a human would be approximately 180 mrem per year

above the typical radiation dose to which Americans are routinely

exposed (approximately 360 mrem per year). The occupational dose

limit for adults is 5,000 mrem per year, and this additional dose

would not exceed that limit. 10 CFR Sec. 20.1201.

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Exposure to L-Lake lake bed contaminants is unlikely to pose a

significant risk to SRS workers, the public, or the environment. The L-

Lake lake bed contaminants would be unlikely to pose a significant risk

to SRS workers because the concentration of the contaminants in the

sediments is low and the amount of time that an SRS worker would be

expected to spend in the lake bed would not yield an annual dose above

DOE administrative limits (700 mrem). For example, an SRS worker

spending eight hours per days for 250 days a year over a twenty-five

year period would receive an annual dose of 41 mrem. The 41 mrem dose

is well below DOE's 700 mrem administrative limit.

The L-Lake lake bed contaminants would be unlikely to pose a

significant risk to the public because the public would not be exposed

to direct radiation, which is the primary hazard associated with

cesium-137. The probability of the maximally-exposed individual,

located at the SRS site boundary, developing a fatal cancer as a result

of 70 years exposure would be less than one in a million (5.6 X 10E-7).

In DOE's judgment this risk is extremely small.

Finally, the L-Lake lake bed contaminants would be unlikely to pose

a significant risk to the environment because erosion would be

controlled and contaminated sediments would not pose a significant risk

to foraging animals. Erosion would be controlled because, based on

DOE's historic hydrologic data and models, L-Lake would probably recede

during the growing season. As the Lake's water level slowly receded,

wetland plants growing in the shore zone would recede down slope with

the water. Seed banks along the shoreline would germinate and stabilize

sediments in portions of the newly exposed shoreline. In addition, DOE

would artificially seed the exposed L-Lake lake bed with appropriate

vegetation in order to further stabilize the sediment. Thus, exposure

to contaminants in the L-Lake due to erosion or resuspension of lake

bed sediment would be minimized because the sediments would be

protected from wave or wind agitation.

Furthermore, erosion and transport of contaminated L-Lake lake bed

sediments would be reduced by the slow drawdown of the water level in

the Lake, occurring over a ten year period, and by the resulting growth

of stabilizing vegetation. Because of this slow drawdown and growth of

stabilizing vegetation, suspension of sediments in the water column

would be minimized. Further, DOE would maintain the Steel Creek dam

during the drawdown to impede the transport of those sediments that

became suspended in the water column. The Steel Creek dam would

minimize the movement of contaminants suspended in the water column by

creating a stilling basin to still the water and allow sediments to

settle out of the water column.

Contaminants in L-Lake lake bed would not pose a significant risk

to foraging animals either from radiological or non-radiological

sources. As described in the RWEIS, radiological contaminants were

screened against known background contaminant concentrations yielding

estimated radiation dose rates, which were then compared to applicable

standards. This comparison indicated that two radionuclides exceeded

twice the background level, namely cesium-137 and Co-60. Cs-137 and Co-

60 in L-Lake lake bed sediments would primarily cause risk from the

direct exposure of penetrating gamma radiation. The concentrations of

these radiological sources was used to estimate a dose rate to selected

receptor species. The estimated radiation dose rates to selected

receptor species are well below the applicable standards.

For non-radiological sources, it was recognized that L-Lake lake

bed sediments would be exposed and that the sediments could become

surface soil or facilitate vegetative growth. All samples detected in

sediments were compared to screening levels for sediments, surface

soils, and terrestrial plants. No sediment contaminants were present in

average concentrations that exceeded available screening levels.

Screening levels were not available for four non-radiological samples

found in L-Lake sediment--beryllium, cobalt, thallium, and vanadium--

which had an average concentration between two and three times their

background levels. The potential risk of these contaminants (as well as

all contaminants that were detected) were assessed by screening their

respective concentrations against surface soil screening levels.

Assuming the sediments became surface soils, the average

concentrations of beryllium, thallium, chromium, and vanadium were

between two and three times their average background levels. Thallium

was detected in five of forty-four samples and beryllium, chromium, and

vanadium slightly exceeded twice its background screening level. This

indicated that these contaminants either are not present in high

concentrations or are not widespread because of the few occurrences in

samples. Accordingly, they would not represent an unacceptable risk.

The average concentration of cobalt was below its associated screening

level.

Assuming the detected sediment concentrations were found in

terrestrial plants, chromium, thallium and vanadium were between two

and three times their background screening levels. Again, thallium was

detected in five of 44 samples. It should also be noted that plants

absorb chromium, thallium, and vanadium minimally from soils. Because

of this fact and that L-Lake currently supports a healthy, diverse

ecological community, it does not appear that effects to L-Lake plants

from contaminants are occurring or would occur under the Proposed

Action.

The screening process is discussed in greater detail in Appendix B

of the RWEIS.

Par Pond

Par Pond water level would not be impacted by any of the

alternatives considered in the RWEIS. Par Pond has not received makeup

water from the RWS since January 1996, and has been allowed to

fluctuate naturally between 195 feet and 200 feet MSL. Accordingly,

ceasing operation of the RWS could not effect Par Pond water level

because it is not currently receiving make-up water from the RWS.

[[Page 4240]]

Allowing Par Pond to fluctuate naturally was the product of prior

analysis and decisions conducted under authority of NEPA and the

Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA). In response to safety concerns presented by a 1992 leak in

the Par Pond dam, DOE prepared a NEPA document called a Special

Environmental Analysis (SEA) to assess the environmental impacts of an

emergency drawdown of the Par Pond water level from 200 feet MSL, its

normal water level, to 181 feet MSL. The SEA reviewed the anticipated

and observed environmental impacts of drawing down, repairing, and

refilling Par Pond, including potential health and ecological impacts

resulting from the possible exposure to radiocesium contaminated

sediment. It concluded that ``consideration would be given to begin

refilling operations as soon as possible, perhaps before dam repairs

are completed, to minimize impacts on the Par Pond ecosystem.'' DOE,

Special Environmental Analysis for Par Pond at the Savannah River Site,

page 4, (April, 1992). In addition, the SEA summarized consequences of

possible future repair, remedial, and refilling actions, and developed

a Mitigation Action Plan (MAP) to reduce the impacts of the repair

activity. Under authority of the SEA, DOE proceeded with the Par Pond

drawdown and repair project.

Following the repair action, DOE prepared a Par Pond Interim Record

of Decision (IROD) to provide a CERCLA remedial action to address the

interim period following the dam repair until a final remedial action

could be studied and selected. The IROD's selected remedy consisted of

refilling and maintaining Par Pond to 200 +/-1 feet until a NEPA

evaluation could be accomplished to evaluate the environmental impacts

from reduced flow to Lower Three Runs Creek (the creek below Par Pond

dam), fluctuating reservoir water level, and discontinuing of river

water pumping to the reservoir. DOE, Interim Action Record of Decision,

Remedial Alternative Selection, Par Pond Unit, WSRC-RP-93-1549 (January

26, 1995). EPA and SCDHEC approved the IROD in February 1995, and Par

Pond was completely refilled by March 15, 1995.

In 1995, DOE prepared a NEPA Environmental Assessment (EA), Natural

Fluctuation of Water Level in Par Pond and Reduced Water Flow in Steel

Creek Below L-Lake at the SRS (DOE/EA-1070). The EA analysis showed

that no significant impacts would likely result to the Par Pond

ecosystem if the Pond's water level were maintained at 195 feet MSL or

above. Hydrological models analyzed in the EA showed that even without

RWS flow augmentation, the Par Pond water level is not likely to

decrease below 196 feet MSL, even in drought conditions. Further, the

EA analysis showed that elimination of RWS water flow and the

accompanying reduction of Savannah River nutrients flowing through Par

Pond would cause the Pond's ecosystem to revert to that typically found

in reservoirs in the southeastern United States. Based on the analysis

in the EA, DOE issued a Finding of No Significant Impact (FONSI) in

August 1995 under which RWS water flow to Par Pond was eliminated.

Under the FONSI, if Par Pond water level decreases to 195 feet MSL or

below, DOE will resume water flow augmentation through the RWS. Since

issuance of the FONSI, natural water flow into Par Pond has maintained

the Pond above 199 feet MSL.

Under either of the RWEIS shutdown alternatives, the status quo

would not be changed and RWS water would not augment natural water flow

into Par Pond. Under the Shut Down and Maintain Alternative DOE would

be able to restart the RWS and resume pumping to Par Pond if the water

level drops below 195 feet MSL, as called for in the FONSI and

consistent with the IROD. However, under the Shut Down and Deactivate

Alternative, DOE would not have the capability to restart the RWS to

augment water flow to Par Pond in the event a severe drought demanded

such an action.

Other Impacts

Under either of the shutdown alternatives, DOE would need to find

an alternate water supply for auxiliary equipment cooling and for fire

protection water reserves. The alternate water supply would be

approximately 400 gpm and be drawn from groundwater. This groundwater

would be provided by existing wells at rates much less than was

historically provided by these same wells during reactor operations.

RWS shutdown would result in increased survival of Savannah River

larval fish and fish eggs because they would no longer be entrained at

the RWS intake structures. In addition, RWS shutdown would return 225

acres of original wetlands inundated by the damming of Steel Creek and

creation of L-Lake. This acreage is approximately the same amount of

wetlands that exists along the present shoreline of L-Lake that would

be lost as L-Lake water level recedes to the original Steel Creek

stream bed.

Environmentally Preferable Alternative

The proposed action in this instance presents a situation where the

environmentally preferable action is different based on whether a

short-term or long-term period of reference is used. Based on the

analysis in the RWEIS, DOE finds that in the short-term, the

environmentally preferable alternative is the No-Action Alternative to

preserve the status quo and continue current operation of the RWS

through a 5,000 gpm pump. The No-Action Alternative would preserve L-

Lake and prevent the return of the Lake's water level to the original

Steel Creek stream bed. The preservation of the Lake would, in turn,

preserve up to 1000 acres of aquatic habitat formed by it, and

forestall the transition of this habitat to uplands and wetlands

habitat.

However, in the long-term, the Shut Down and Maintain Alternative

is the environmentally preferable alternative. Under this alternative,

L-Lake water level would return to the original Steel Creek stream bed

over a ten year period, which would allow for the gradual restoration

of a more stable ecosystem, such as that in existence prior to

construction of L-Lake. The pre-Lake ecosystem would be more stable

because it is the indigenous ecosystem, and because it would not be

susceptible to potential imbalances, such as those introduced by

changes in L-Lake water level associated with repair or renovation of

the Steel Creek dam.

Furthermore, the restored L-Lake ecosystem would benefit from the

reemergence of 225 acres of wetlands inundated by the creation of L-

Lake, an amount that approximately equals the amount of wetland acreage

that would be lost along the shoreline of L-Lake as it gradually

recedes. After these areas are exposed, they would naturally

reestablish wetland characteristics with cycles of drying and flooding

typical of other hardwood swamps on the SRS and in the southeast. As

typical wetlands they would support diverse ecological communities.

In addition, while a decrease in aquatic productivity would be

expected as a consequence of the return of L-Lake water level to the

original Steel Creek stream bed, an increase in terrestrial

productivity would occur concomitantly. As the L-Lake water level

receded, grasses, forbs, shrubs, and trees indigenous to the ecosystem

would re-colonize the L-Lake lake bed over time. In addition to flora,

indigenous fauna would return to the ecosystem, and a variety of

terrestrial and semi-aquatic animal species would inhabit

[[Page 4241]]

the area as L-Lake gradually receded to the original Steel Creek stream

bed.

Other than potential CERCLA remediation activities, if DOE

continued to operate and maintain the RWS indefinitely the No-Action

Alternative would require the greatest commitment of money and energy

resources. The RWS would continue to supply 5,000 gpm to L-Lake from

the Savannah River. To do so, DOE would spend approximately $1,084,000

annually to provide RWS surveillance and maintenance and $494,000

annually for electrical energy to pump the water uphill from the river.

Finally, DOE would continue to dredge the RWS intake canal to keep it

clear of debris. However, there is great uncertainty regarding the cost

of remedial action under CERCLA. Therefore, until characterization is

completed, it will not be evident whether shutting down or continuing

to operate and maintain the RWS is economically the most prudent course

of action.

Associated Actions

DOE considered a number of actions that affect the selection of an

alternative for the RWS, as well as the timing of implementing a

selected alternative. The actions are described in the following

paragraphs.

Remedial Action Process for L-Lake

Through the FFA, DOE, EPA, and SCDHEC established the procedure for

environmental restoration activities at the SRS. The FFA integrates DOE

responsibilities under the Resource Conservation and Recovery Act

(RCRA) and CERCLA. In response to EPA and SCDHEC comments on the Draft

RWEIS, DOE recommends further assessment of L-Lake under the FFA,

possibly resulting in a Baseline Risk Assessment (BRA) and a Remedial

Investigation/ Feasibility Study (RI/FS).

A BRA will assess the risk associated with the contaminants

identified in the L-Lake sediment, primarily located in the original

Steel Creek stream bed, and it will provide a quantified expression of

risk for key receptors, such as humans or wildlife, which may be

exposed to the contaminants. An RI/FS will gather data necessary to

determine more exactly the nature and extent of contamination in L-Lake

sediment, establish criteria for remediating the Lake, identify the

preliminary alternatives for remedial actions, and support the

technical and cost analyses of the remedial alternatives.

DOE believes that the analysis and data collection necessary to

prepare a BRA and RI/FS is more accurately, easily, and economically

obtained once L-Lake has returned to its original Steel Creek stream

bed. This is because there are inherent difficulties in taking sediment

samples while L-Lake is filled if additional samples are needed.

Because shutdown of the RWS will present no unreasonable risk to human

health or the environment, and because analysis of L-Lake sediment is

more appropriate after the Lake has returned to the original Steel

Creek stream bed, DOE anticipates that this process will be

accomplished under an Interim Record of Decision (IROD). In accordance

with the present FFA schedule, DOE will begin characterization of the

L-Lake CERCLA unit in fiscal year 2000 and begin L-Lake draw down in

Fiscal Year 2001. The characterization process and risk evaluation will

lead to the selection of a preferred remedial alternative. It is DOE's

intention to incorporate National Environmental Policy Act values in

the IROD and supporting documents.

Remedial Action Process for Onsite Streams

Steel Creek, Four Mile Branch, Pen Branch, and Lower Three Runs,

are listed in the FFA as RCRA/CERCLA units because each stream received

contaminants from past operations. EPA and SCDHEC expressed concern

about the effect on these units due to the installation of the 5,000

gpm pump because the installation of that pump reduced water flow

capacity through the streams from 28,000 gpm to 5,000 gpm. The

reduction in water flow through the SRS streams has increased the

concentration of tritium transported to SRS streams from the seepage

basins.

Increased tritium concentrations in site streams are the

consequence of two factors. First, tritium from the seepage basins is

carried with rainwater to site streams as it percolates through the

soil at a fairly constant rate. Second, the RWS flow formerly diluted

the tritium-containing rainwater as it percolated to the streams.

Installation of the 5,000 gpm pump reduced RWS flow contribution to the

streams and removed this dilution water. Consequently, installation of

the 5,000 gpm pump had the effect of increasing tritium concentrations.

To respond to comments on the draft RWEIS, the Final RWEIS

evaluated the impacts to workers, ecosystems, and the public due to the

installation of the 5,000 gpm pump from the resulting increase in

tritium concentrations. Workers and ecological receptors would be at

risk due to increased tritium exposure through incidental ingestion and

skin contact. The public could be at risk due to ingestion of increased

concentrations of tritium in drinking water. However, the RWEIS risk

assessment showed that a hypothetical future worker's annual dose would

be below 1 mrem. The RWEIS environmental risk assessment showed that

the highest annual dose to an ecological receptor would be 92 mrem.

Both of these dose rates are well below accepted standards.

Drinking water taken from the Savannah River would not be impacted

because installation of the 5,000 gpm did not increase the total amount

of tritium released to the River. Because the flow rate of water in the

Savannah River is typically over 10,000 cubic feet per second (compared

to the 45 cubic feet per second reduction of flow from installation of

the 5,000 gpm pump) and because the nearest domestic water plant intake

is approximately 40 miles downstream from SRS, the on-site increased

concentrations have an insignificant health impact to the public. In

summary, the increased concentrations of tritium in site streams were

determined to be acceptable because these concentrations did not pose

an unacceptable risk to workers, the ecosystems or the public.

Steel Creek, Four Mile Branch, Pen Branch, and Lower Three Runs, as

well as other SRS streams have received low-levels of radionuclides,

including tritium, from past SRS operations. Therefore, all of them

will be evaluated in accordance with the FFA and be the subject of a

risk analysis based on hypothetical future residents and industrial

workers.7 DOE is scheduled to provide information to EPA and

SCDHEC, which will assist in the characterization of each stream and

the selection of a remedial alternative.

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\7\ These two hypothetical future groups could be at risk

because the risk analysis assumes that they drink water from SRS

streams before it is mixed with the Savannah River. A down stream

receptor is not at risk because the Savannah River flow rate is

significantly higher than SRS streams and, in effect, dilutes

tritium to concentrations which do not pose a risk to human health.

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Water Requirements for Alternatives

Under the No-Action Alternative, the RWS would continue to supply

existing operational cooling and make-up water requirements for the

reactor areas and maintain L-Lake at 190 feet MSL. For either of the

shutdown alternatives, DOE must supply 400 gpm of groundwater to

replace that provided by the RWS to cool auxiliary equipment and to

provide make-up water for fire protection reserves.

[[Page 4242]]

L-Area Sanitary Wastewater Treatment Plant

The L-Area sanitary wastewater effluent mixes with RWS flow before

reaching L-Lake. The L-Area Sanitary Wastewater Treatment Plant

wastewater permit took credit for RWS blending flow in determining the

extent of treatment necessary before the wastewater was discharged to

L-Lake. To stop RWS flow, DOE must implement an alternate compliance

method to manage L-Area sanitary wastewater.

Reactor 186-Basins Alternative Uses Study

In 1994, DOE analyzed the feasibility of using the SRS C-, L-, P-,

and R-Reactor 186-Basins 8 and 904-Retention Basins

9 for aquacultural purposes. In March 1995 DOE advertised

the availability of the Reactor 186-Basins for commercial use. DOE

accepted one fish farming proposal that would have relied on ground

water for make-up water, although this proposal was later withdrawn. At

the present time, no future uses of the 186-Basins or the 904-Retention

Basins are planned. DOE could accept similar proposals in the future

regardless of the RWEIS alternative selected because the basins do not

rely on the RWS for make-up water.

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\8\ 186-Basins are water storage basins which are not

contaminated.

\9\ 904-Retention Basins are 50 million gallon basins that were

designed to receive emergency cooling water in the event of a

reactor accident.

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Decision

DOE selects the No Action Alternative of the RWEIS--Continue to

Operate the RWS. Under this alternative, DOE will continue to operate

and maintain the system as well as maintain the water level of L-Lake

at its full pool water level of 190 feet MSL.

DOE will assess the need for future environmental remediation

alternatives for L-Lake under existing CERCLA commitments.

Characterization activities associated with CERCLA closure are expected

to begin in the year 2000 and be completed in several years. This

characterization will inform any required remedial action. Pending

these activities, DOE will continue to operate the RWS. If during

continued operation of the RWS a system component fails, DOE will take

appropriate emergency actions. DOE will then determine if the system is

too costly to repair (by comparing this cost to estimated shutdown

costs and future possible remediation costs under CERCLA). If DOE

determines that the RWS is too costly to repair, it will reevaluate all

relevant commitments and the information in the RWEIS, to determine

necessary actions to shut down the RWS. However, the RWS is in good

condition and not expected to fail over this period of time.

In accordance with the present FFA schedule, DOE will begin

characterization of the L-Lake CERCLA unit in fiscal year 2000. DOE

anticipates that this process will lead to an Interim Record of

Decision (IROD) in Fiscal Year 2001. At that time DOE will decide

whether L-Lake should be drawn down to facilitate characterization of

future risks to human health and the environment. The characterization

process and risk evaluation will lead to the selection of a preferred

remedial alternative. Not withstanding a major system failure, DOE has

decided to operate and maintain the RWS until a preferred remedial

alternative is selected.

DOE made this decision after considering the most recent operating

and maintenance costs and estimated shutdown implementation costs. DOE

has concluded the amount and uncertainty in shutdown implementation

costs suggest the RWS should continue to be operated while DOE monitors

RWS operating and maintenance costs to determine when continued

operation becomes too costly. For example, if a portion of the system

failed, DOE may elect to take an emergency action in accordance with 40

CFR 1506.11, if appropriate, and then determine if repair was too

costly. If DOE determines that repair is too costly it will announce

this decision in a future Record of Decision under the requirements of

NEPA and CERCLA, as necessary.

Prior to drawdown, DOE will notify the USFWS to ensure all

``reasonable and prudent'' measures, which were recommended by USFWS

during the Endangered Species Action consultation process to protection

of threatened and endangered species, are still adequate and

appropriate. DOE will also negotiate a schedule with USFWS for the

review and completion of these measures.

During any future draw down and characterization activities DOE

expects to stabilize exposed sediments and address the ``reasonable and

prudent'' measures, discussed above.

DOE considers continued operation of the RWS to be environmentally

preferable in the short-term because L-Lake remain as a lake with its

ecology unaffected.

Comments on Final RWEIS

DOE received two letters commenting on the Final RWEIS. The first,

a letter from EPA, Region IV, dated June 12, 1997, expressed concern

that the RWEIS does not adequately consider injury or impacts to

endangered species. To consider injury or impacts to these species DOE

and USFWS entered into a formal consultation process regarding

endangered species. The USFWS recommended specific ``reasonable and

prudent'' measures to protect the bald eagle and wood stork during the

L-Lake water level return to the original Steel Creek stream bed. DOE

endorsed these reasonable and prudent measures. However, these measures

will not be implemented at this time because the draw down of L-Lake

will not occur as a result of this decision.

The letter from EPA, Region IV also expressed concern that the

RWEIS did not adequately consider the ecological risks associated with

shutdown of the RWS. However, as explained in the Environmental Impacts

section, the RWEIS ecological risk assessment (ERA) concluded that

significant potential risks to ecological receptors from contaminants

is not likely.

Finally, as a general statement, the letter from EPA, Region IV

stated that, ``This NEPA action should be coordinated to the fullest

extent possible with FFA activities''. The selection of the No Action

alternative has been made, in part, in response to this statement.

In addition, the RWEIS documented several measures that were taken

to coordinate the NEPA with the FFA process, which include the

following: (1) use of FFA criteria as contamination level screening

limits to estimate future potential remedial action decisions; (2)

movement of the L-Lake unit from Appendix G to Appendix C of the FFA in

order to avoid the unnecessary generation of a Site Evaluation Report

and expedite the FFA process; and (3) preservation of the ability to

refill L-Lake under the RWEIS shut down and maintain alternative in the

event that such action is determined to be necessary under the FFA.

The second letter, dated June 11, 1997, from the Office of

Environmental Policy and Compliance within the Department of the

Interior (DOI) addressed several concerns regarding the revised

ecological risk assessment (ERA) provided in the RWEIS. Specifically,

DOI commented that guidance DOE used to develop the RWEIS ERA ``is

inadequate and inconsistent with the US EPA's guidance on ecological

risk

[[Page 4243]]

assessment.'' To the contrary, DOE believes the RWEIS ERA was conducted

in accordance with the most current EPA guidance.

The objective of the RWEIS ERA was to determine, as accurately as

possible under the existing L-Lake characteristics, the probable

outcome of a CERCLA ERA.10 The RWEIS ERA is adequate because

it used maximum contaminant concentrations in its risk assessments. In

fact, all radiological risks were within dosimetry-based limits

acceptable to the International Atomic Energy Agency. Where the maximum

concentrations of some non-radiological contaminants showed a risk

potential, either the average concentration of the contaminant was

compared to background levels or, alternately, the contaminant

concentration was compared with more contaminant-specific information

available in accepted scientific literature. This procedure is part of

the typical process of interpreting the results and uncertainties of an

ERA and represents the general ERA approach recommended in the EPA

guidance for Superfund. EPA, Ecological Risk Assessment for Superfund:

Process for Designing and Conducting Ecological Risk Assessments,

Review Draft, (1996).

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\10\ The CERCLA ERA will be used to aid the determination of a

final remedial action at L-Lake. A final action is typically made

only after the lake bed is characterized in detail using information

such as groundwater hydrogeology, extent of groundwater

contamination, and existing burial area contamination profiles.

Presently, these areas are under as much as 50 feet of water and

cannot be adequately characterized. As a result, a complete risk

assessment cannot be performed and a final remedial alternative

cannot be selected until L-Lake returns to the original Steel Creek

stream bed.

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DOI also asserted that the ``[c]onclusions of no risk are

inconsistent with actual research findings.'' DOI cited specific DOE

studies sent to USFWS during the formal Endangered Species Act

consultation. The studies DOI cited assessed DNA changes found in blood

samples of various wildlife species present on the SRS. In response to

this assertion, DOE notes that, in no case did any of the studies

suggest that an observable change in a wildlife population would result

from the exposure to low levels of radionuclides found in L-Lake.

Accordingly, this supports the RWEIS ERA finding that significant

potential risks to ecological receptors from contaminants are not

likely.

Finally, DOI commented on various DOE studies showing the presence

of elevated mercury concentrations in the SRS environment. However,

DOI's comment does not reflect the fact that the presence of mercury in

the SRS environment is not the result of releases attendant to SRS

operations. Indeed, mercury is elevated throughout areas of the

southeastern United States due to atmospheric deposition, not due to

SRS operations. Reflecting and restating this fact, SCDHEC issued a

fish consumption advisory for numerous lakes and rivers in South

Carolina based on mercury concentrations in fish. Again, the presence

of this mercury was not and cannot be correlated to any SRS operations.

Accordingly, DOE has no control over and is not responsible for the

atmospheric deposition of mercury at SRS, or in other areas of the

southeastern United States. Consequently, a returning L-Lake water

level to the original Steel Creek stream bed would not exacerbate this

regional phenomenon or increase ecological risk.

Conclusion

After consideration of all relevant information and data, DOE

selects the No Action alternative as the most appropriate action for

the future of the River Water System at the Savannah River Site at this

time. This operational decision is made in recognition of all

beneficial and adverse environmental impacts, monetary costs,

regulatory implications and commitments under the FFA, and dictates of

relevant statutes.

Signed this 23rd day of December, 1997, at Aiken, South

Carolina.

Greg Rudy,

Acting Manager, Savannah River Operations Office.

[FR Doc. 98-1947 Filed 1-27-98; 8:45 am]

BILLING CODE 6450-01-P