DOE/EA-0937; Environmental Assessment and (FONSI) for the Construction and Operation of Waste Storage
Facilities at the Paducah Gaseous Diffusion Plant Paducah, Kentucky
TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS
SUMMARY
1.0 INTRODUCTION
1.1 PROPOSED ACTION
1.2 BACKGROUND
1.3 PURPOSE AND NEED
1.4 LOCATION
1.5 SCOPE
1.6 RELATIONSHIP TO OTHER ACTIONS
2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES
2.1 ALTERNATIVE 1: NO ACTION
2.2 ALTERNATIVE 2: PROPOSED ACTION - CONSTRUCT AND OPERATE NEW WSFs
2.2.1 Location, Site Preparation, and Construction of the PGDP WSFs
2.2.1.1 WSFs
2.2.1.2 MWSF
2.2.2 Operation of the PGDP WSFs
2.2.2.1 PGDP WSFs
2.2.2.2 MWSF
2.3 ALTERNATIVE 3: ALTERNATE LOCATIONS
2.4 ALTERNATIVE 4: ALTERNATIVES CONSIDERED AND DISMISSED
2.4.1 Upgrade Existing Facilities
2.4.2 Off-Site Shipment of Waste
3.0 DESCRIPTION OF THE EXISTING ENVIRONMENT
3.1 GEOLOGY
3.2 HYDROLOGY
3.2.1 Surface Water
3.2.2 Groundwater
3.2.3 Floodplains
3.2.4 Wetlands
3.3 SOILS
3.4 CLIMATE, AIR QUALITY, AND NOISE
3.4.1 Climate
3.4.2 Air Quality
3.4.3 Noise
3.5 BIOLOGICAL RESOURCES
3.5.1 Vegetation
3.5.2 Wildlife
3.5.3 Threatened and Endangered Species
3.6 LAND USE
3.7 CULTURAL RESOURCES
3.8 SOCIAL AND ECONOMIC CONDITIONS
3.8.1 Demography
3.8.2 Economic Activities
3.9 TRANSPORTATION
4.0 ENVIRONMENTAL IMPACTS
4.1 IMPACTS FROM THE PROPOSED ACTION: CONSTRUCT AND OPERATE NEW PGDP WSFs
4.1.1 Geology
4.1.2 Hydrology
4.1.2.1 Surface Water
4.1.2.2 Groundwater
4.1.2.3 Floodplains
4.1.2.4 Wetlands
4.1.3 Soils
4.1.4 Air Quality and Noise
4.1.5 Biological Resources
4.1.6 Land Use
4.1.7 Cultural Resources
4.1.8 Social and Economic Conditions
4.1.9 Transportation
4.1.10 Health and Safety
4.1.11 Cumulative Impacts
4.2 IMPACTS FROM NO ACTION ALTERNATIVE
4.2.1 Geology and Soils
4.2.2 Hydrology
4.2.3 Air Quality and Noise
4.2.4 Biological Resources
4.2.5 Land Use and Cultural Resources
4.2.6 Social and Economic Conditions
4.2.7 Human Health and Safety
4.3 ALTERNATE LOCATIONS
5.0 PERMITS AND REGULATORY REQUIREMENTS
5.1 RCRA AND TSCA
5.2 CLEAN AIR ACT
5.3 CLEAN WATER ACT
5.3.1 CWA - Section 404 (Dredge and Fill Permitting)
5.3.2 CWA - Part 112 (Oil Pollution Prevention)
5.4 EXECUTIVE ORDERS 11990 (PROTECTION OF WETLANDS) AND 11988 (FLOODPLAIN MANAGEMENT)
5.5 ENDANGERED SPECIES ACT
5.6 NATIONAL HISTORIC PRESERVATION ACT
5.7 FARMLAND PROTECTION POLICY ACT
5.8 HAZARDOUS MATERIALS TRANSPORTATION ACT
5.9 OCCUPATIONAL SAFETY AND HeaLTH ADMINISTRATION
6.0 AGENCIES AND PERSONS CONTACTED
7.0 LIST OF PREPARERS
REFERENCES
APPENDIX A WETLANDS ASSESSMENT
TABLE OF CONTENTS
ACRONYMS
1. INTRODUCTION
1.1 PROJECT DESCRIPTION
2. METHODS
2.1 BACKGROUND
2.2 WETLANDS
3. WETLANDS IMPACTS
3.1 ARea DESCRIPTION
3.2 DELINeaTED JURISDICTIONAL WETLANDS
3.2.1 Wetland 1
3.2.2 Wetland 2
3.3 WETLAND FUNCTIONS AND VALUES
3.4 OTHER AQUATIC RESOURCES
4. CONCLUSIONS
5.0 REFERENCES
Letter from Ronny J. Sadri Project Manager DEPARTMENT OF THE ARMY to Ms. Nancy Hendrix-Ward NEPA Program Manager DOE Dateed May 25, 1993
ADDRESS FOR COORDINATING AGENCY
Nationwide Permit Conditions
Section 404 Only Conditions
Letter from James Dee CDM Federal Programs Corporation to Mr. Charlie Logsdon Dated December 11, 1992
Letter from Margaret Shea Botanist KENTUCKY STATE NATURE PRESERVES COMMISSION to Jim Dee CDM, Federal Programs Corp. Dated November 30, 1992
NATURAL COMMUNITIES OF KENTUCKY: PRAIRIES (enclosure)
INTERPRETATION KEY TO DATA REPORTS FROM THE KENTUCKY STATE NATURE RESOURCES COMMISSION
ENDANGERED-THReaTENED, AND SPECIAL CONCERN SPECIES REPORTED AS OCCURRING IN THE ARea IN MCCRACKEN COUNTY, KENTUCKY
Status List of T&E Species Known to Occur in Joppa. KY-IL Quad -- 08 OCT 1992
List of T&E Species KNOWN to OCCUR in PADUCAH E. Quad -- 02 OCT 1992
Letter form R. J. Connor, P. E. Chief, Engineering-Planning Division to DEPARTMENT OF THE ARMY to Ms. Nancy Hendrix DOE dated FEB 19 1992
MEMORANDUM FOR RECORD 17 February 1993
Letter from Marc Evans Acting Director KENTUCKY STATE NATURE PRESERVES COMMISSION to Mr. James Dee CDM Federal Programs Corporation dated October 21, 1992
Letter from James P. Groton, Jr. Environ mental Scientist Science Applications International Corporation to Mr. Jerry Sparks U.S. Army Corps of Engineers dated April 6, 1993
Enclosure
APPENDIX B AGENCY LETTERS/CORRESPONDENCE
Letter from David L. Morgan, Director KENTUCKY HERITAGE COUNCIL to Mr. John D. Young, Project Manager CDM Federal Programs Corporation dated November 16, 1992
Letter to DAVID POLLACK Kentucky Heritage Council dated November 16, 1992
Letter form Douglas B. Winford Acting Field Supervisor FISH AND WILDLIFE SERVICE to Mr. Donald C. Booher Site manager, Paducah Site Office dated April 28, 1993
Letter from David W. Pelren DEPARTMENT OF FISH AND WILDLIFE RESOURCES COMMONWeaLTH OF KENTUCKY to Mr. James Dee CDM Federal Programs dated October 12. 1992
Letter from David W. Pelren DEPARTMENT OF FISH AND WILDLIFE RESOURCES COMMONWeaLTH OF KENTUCKY to Mr. Jim Dee CDM Federal Programs dated October 8, 1992
Letter from RON FROEDGE DISTRICT CONSERVATIONIST DOA SOIL CONSERVATION SERVICE to NANCY HENDRIX NEPA PROGRAM MANAGER dated FEBRUARY 22, 1993
Letter from Lee A. Barclay Ph.D. Field Supervisor DOI FISH AND WILDLIFE SERVICE to Mr. James Dee CDM Federal Programs Corporation dated October 6, 1992
Letter from Lee A. Barcley, Ph.D. Field Supervisor DOI FISH AND WILDLIFE SERVICE to Mr. James P. Groton. Jr.. Environmental scientist science applications International Corp. dated February 10, 1993
An Assessment of Potential Summer Habitat of the Federally Endangered Indiana Bat Myotis sodalis by Hal D. Bryan 8 April 1993
I. INTRODUCTION
II.SPECIES STATUS
III. SURVEY METHODS
IV. SURVEY RESULTS
V. SUMMARY AND RECOMMENDATIONS
VI. LITERATURE CITED
Finding of No Significant Impact (FONSI) Construction, Operation, and Closure of Waste Storage Facilities at the Paducah Gaseous Diffusion Plant (PGDP), Paducah, Kentucky
LIST OF FIGURES (Not available in electronic format)
Figure No. Page
1-1 Location Map, PGDP, Paducah, Kentucky 6
1-2 Location Plan for the WSFs, PGDP, Paducah, Kentucky 8
2-1 Alternate Locations for the PGDP WSFs 19
3-1 Regional Surface Water Features in the Vicinity of PGDP 23
3-2 Local Surface Water Features in the Vicinity of PGDP 24
3-3 MWSF Proposed Location Major Topographical Features, PGDP 27
3-4 On-site Well Locations, PGDP 28
3-5 Off-site Well Locations, PGDP 29
3-6 Soils Map, PGDP 31
3-7 Current Land Ownership Map for PGDP 42
4-1 Location Plan for Proposed Actions at PGDP 55
LIST OF TABLES
Table No. Page
1-1 Available Waste Storage Space 5
2-1 Estimated Annual PGDP Waste Generation 12
2-2 MWSF Characterized Waste Hazard Level 17
3-1 Commonwealth of Kentucky, Threatened, Endangered, and "Special
Concern" Animal Species Known from McCracken County, Kentucky 38
3-2 Commonwealth of Kentucky, Threatened, Endangered, and "Special
Concern" Plant Species Known from McCracken County, Kentucky 39
4-1 Accepted Waste Types 50
4-2 Summary of Annual Dose from Radiological Contaminants 53
DOE/ea-0937; ENVIRONMENTAL ASSESSMENT AND (FONSI) FOR THE CONSTRUCTION AND OPERATION OF WASTE STORAGE
FACILITIES AT THE PADUCAH GASEOUS DIFFUSION PLANT PADUCAH, KENTUCKY
DOE/ea-0937
ENVIRONMENTAL ASSESSMENT
FOR THE CONSTRUCTION AND OPERATION OF WASTE STORAGE FACILITIES
AT THE PADUCAH GASEOUS DIFFUSION PLANT PADUCAH, KENTUCKY
U.S. DEPARTMENT OF ENERGY
PADUCAH GASEOUS DIFFUSION PLANT
Paducah, Kentucky
June 1994
ACRONYMS AND ABBREVIATIONS
Aea Atomic Energy Act
AEC U.S. Atomic Energy Commission
ANSI American National Standards Institute
ASCE American Society of Civil Engineers
ASTM American Society for Testing and Materials
BMP Best Management Practice
CAA CLEAN Air Act
CDM Federal CDM Federal Programs Corporation
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
CWA CLEAN Water Act
DOD U.S. Department of Defense
DOE U.S. Department of Energy
DOT U.S. Department of Transportation
ea environmental assessment
EPA Environmental Protection Agency
ER Environmental Restoration
FONSI Finding of No Significant Impact
FPPA Farmland Protection Policy Act
FY fiscal year
HEPA high-efficiency particulate air
HVAC heating ventilating and air conditioning
KAR Kentucky Administrative Regulations
KDEP Kentucky Department for Environmental Protection
KDFWR Kentucky Department of Fish and Wildlife Resources
KOW Kentucky Ordnance Works
KPDES Kentucky Pollutant Discharge Elimination System
KSNPC Kentucky State Nature Preservation Commission
LCD Lower Continental Deposits
LLW low-level radioactive waste
Energy Systems Martin Marietta Energy Systems, Inc.
MSL mean sea level
MWSF mixed waste storage facility
NEPA National Environmental Policy Act
NFPA National Fire Protection Association
NRHP National Registry of Historic Places
OSHA Occupational Safety and Health Administration
PCB polychlorinated biphenyl
PGDP Paducah Gaseous Diffusion Plant
RCRA Resource Conservation and Recovery Act
RGA Regional Gravel Aquifer
SAIC Science Applications International Corporation
SCS U.S. Soil Conservation Service
SHPO State Historic Preservation Officer
SOP Standard Operating Procedure
SWL solid waste landfill
TSCA Toxic Substances Control Act
TSD treatment, storage, and disposal
TVA Tennessee Valley Authority
UCD Upper Continental Deposits
UCRL University of California Radiation Laboratory
UCRS Upper Continental Recharge System
UE uranium enrichment
UF6 uranium hexafluoride
USC United States Code
USEC U.S. Enrichment Corporation
USFWS U.S. Fish and Wildlife Service
WKWMA West Kentucky Wildlife Management Area
WSF waste storage facility
SUMMARY
The Paducah Gaseous Diffusion Plant (PGDP) was constructed by the U.S. Atomic Energy
Commission (AEC) in the early 1950s and has operated continuously since 1952. The plant
enriches uranium for use in commercial nuclear power reactors in the United States and
abroad. The plant is currently operated by Martin Marietta Energy Systems, Inc. (Energy
Systems) for the United States Enrichment Corporation (USEC). USEC, a government
corporation, leased the United States Department of Energy (DOE) Gaseous Diffusion Plant
facility on July 1, 1993. DOE continues to own the facilities and is responsible for the
decontamination and decommissioning, response actions, and/or corrective actions for
conditions existing before the transition date. Under the lease agreement, DOE is
temporarily responsible for the construction and operation of facilities which handle waste
resulting from USEC uranium enrichment (UE) operations.
The operation of the Paducah facility results in the generation of considerable quantities of
UE process-derived waste which must be properly managed per federal and state
regulations and DOE Orders. PGDP operations require approximately 6746 ft^2/year for
storage of Toxic Substances Control Act (TSCA) waste and 2972 ft^2/year for storage of
Resource Conservation and Recovery Act (RCRA) waste (Beach 1992). Approximations
based on the current TSCA waste generation rate suggest that PGDP will be out of TSCA
waste storage space in August 1994. Projections indicate approximately 4354 ft^2 of TSCA
waste storage space is currently available. A projection of available RCRA waste storage
space shows 9100 ft^2 remaining. Based on this projection, RCRA waste storage space will
not be available after Fiscal Year (FY) 1996. Estimates based on projected generation rates
indicate that, beginning in FY 1995, an additional 200,000 ft^2 of waste storage space that
meets TSCA and RCRA regulatory requirements will be necessary to provide storage
capacity until the year 2000. Failure to provide adequate permitted waste storage space
could require PGDP to either cease the generation of waste or be in violation of federal and
state waste management regulations and agreements.
To meet this need, DOE is proposing to construct and operate two RCRA/TSCA waste
storage facilities (WSFs) and one mixed waste storage facility (MWSF) at PGDP for the
storage of waste generated through future environmental restoration (ER) activities. ER and
operation wastes would be clearly marked and stored in separate areas. The facilities
(buildings) would meet applicable regulatory requirements of either TSCA or RCRA, or the
more stringent of these regulations, dependent on the wastes to be stored within the
facilities. The construction and operation of these waste storage buildings would provide
adequate regulatory waste storage space until the year 2000, based on current projections.
The proposed action consists of the following: constructing and operating two identical,
approximately 42,000-ft^2 WSFs within the existing PGDP security fence, and one 200,000-
ft^2 MWSF on a site adjacent to the existing security area near the northwest corner of the
PGDP facility. Alternatives considered included: (1) no action; and (2) alternate locations.
Analysis conducted during the preparation of the environmental assessment (ea) resulted in
the following findings for the WSFs and the MWSF:
Air Quality: Short-term, minor air quality degradation in the immediate area of
construction activities would be expected. These activities would result in slightly
increased ambient concentrations of airborne particulates (fugitive dust) from
construction activities and sulfur dioxide, nitrogen oxides, and hydrocarbons from
construction vehicle exhaust. Dilution and dispersion of the pollutants in the
atmosphere would reduce ambient concentrations to immeasurable levels outside the
immediate area of activity. No permanent air emission sources would be created by
the proposed facilities.
Cultural Resources: Cultural resources or areas of archaeological significance do
not exist in the areas proposed for construction.
Geology and Soils: The geology of the area would not be affected by construction
of the proposed facilities. All areas have been previously disturbed and no soils that
are considered to be prime farmland would be disturbed.
Land Use: The areas proposed for construction are owned by DOE and are not
readily available for public access or recreational activities. Development of these
areas as industrial sites is consistent with adjacent site development, operations,
management practices, and agreements.
Socioeconomics: Construction of the proposed facilities is not expected to affect the
local economy on a long-term basis. The facilities would be operated by existing
PGDP personnel and only short-term construction employment would be created.
Transportation requirements would not change since all facilities would ultimately be
located within the PGDP security fence.
Water Resources: Big Bayou Creek may be affected by a temporary increase in
siltation due to construction activities and the proximity of the construction site to
Kentucky Pollutant Discharge Elimination System (KPDES) outfalls 001 and 015.
Siltation would not be expected to affect local biota and would be controlled by
standard construction management practices such as silt fences or hay bales. During
operation, engineering controls would minimize the potential for spills of hazardous
substances from the waste storage facilities to enter the outfalls, and ultimately, Big
Bayou Creek.
Floodplains: The 100-year flood elevation for Big Bayou Creek nearest the
proposed location ranges from about 365 to 366 feet above mean sea level (MSL).
The 500-year flood elevation ranges from about 366 to 367 feet above MSL (Cross
1993). The WSFs would be built at base elevations of at least 370 feet above MSL,
out of the 100- and 500-year floodplains.
Wetlands: Two approximately wetlands (less than 0.5 acre combined) that meet
federal jurisdictional requirements would be filled by construction activities. These
wetlands are considered to be isolated, non-headwaters wetlands, and a U.S. Army
Corps of Engineers Nationwide Permit has been received. A notice of wetlands
involvement was published on October 5, 1993 in the Federal Register per DOE
regulations (10 Code of Federal Regulations [CFR] 1022). The wetlands assessment
concluded that none of the potentially affected wetlands is of high ecological value
in a regional context (Appendix A).
Threatened and Endangered Species: Two acres of the 20-acre site for the PGDP
MWSF are considered potential summer habitat for the Indiana bat (Myotis sodalis),
a federally listed endangered species, due to the presence of shagbark hickory
(Carya ovata). The shagbark hickory (or other trees with loose bark) may provide
habitat for this bat during summer reproductive activities. A Biological Assessment
was conducted according to Section 7 of the Endangered Species Act and submitted
to the U.S. Fish and Wildlife Service (USFWS) for a biological opinion. The
USFWS concurs that the removal of approximately 2 acres of potential habitat
would not affect the status of the Indiana bat. Additionally, to ensure that no
individuals of the species are affected, construction activities would be initiated
outside of the known maternity season.
Cumulative Impacts: Cumulative impacts associated with other proposed actions
potentially coinciding with the proposed action would be minimal. These activities
include construction of a proposed 40 acre solid waste landfill, and an expansion of
the uranium hexafluoride (UF6) tails cylinder storage yards. The potential cumulative
impacts associated with the proposed actions are discussed in Section 4.1.11.
This ea was prepared pursuant to the National Environmental Policy Act (NEPA) of 1969,
the Council on Environmental Quality regulations for the implementation of NEPA (Title
40 CFR Parts 1500-1508) and DOE's NEPA regulations 10 CFR Part 1021 [57 Federal
Register 15122 (April 24, 1992)], DOE Order 5440.1E, and Recommendations for the
Preparation of Environmental Assessments and Environmental Impact Statements, by the
Office of NEPA Oversight, U.S. Department of Energy, May 1993.
This ea describes the need for agency action, the existing environment at the proposed site,
the proposed action, and the potential impacts of the proposed action. Based on the
potential for impacts described herein, DOE will either publish a Finding of No Significant
Impact (FONSI) or prepare an Environmental Impact Statement.
1.0 INTRODUCTION
1.1 PROPOSED ACTION
DOE is proposing to construct and operate three Waste Storage Facilities (WSFs) at PGDP
for the storage of process-derived waste, including waste generated from associated PGDP
activities (e.g., routine maintenance, housekeeping, health and safety activities, project
wastes). These wastes are regulated under RCRA, TSCA, Atomic Energy Act (Aea), and
DOE Order 5820.2A. The proposed action would result in the construction and operation
of two approximately 42,000 ft^2 WSFs (primarily for RCRA/TSCA wastes) and one
200,000 ft^2 MWSF (primarily for RCRA and mixed waste). All of the PGDP WSFs would
be designed to TSCA specifications for containment, which are more stringent than RCRA
specifications. The PGDP MWSF would be RCRA permitted. The proposed WSFs
represent the first facilities to be constructed at the plant for the sole purpose of storing
waste.
1.2 BACKGROUND
PGDP was built by the AEC in the early 1950s on the former site of the Kentucky
Ordnance Works (KOW) and has operated continuously since then. The plant enriches
uranium for use in commercial nuclear power reactors in the United States and abroad. The
plant is operated by Energy Systems for the USEC, a government corporation established
July 1, 1993, which leases the gaseous diffusion plant from DOE. PGDP occupies 748
acres of a 3423 acre DOE reservation 10 miles west of Paducah, Kentucky (Figure 1-1).
Operation of this facility results in the generation of considerable quantities of RCRA- and
TSCA-regulated wastes. With the addition of wastes generated as a result of the ER
Program, available storage space is quickly being exhausted. DOE has established, as part
of its operating mission, the objective of managing its waste in a safe manner and within
regulatory requirements. The goals of the waste management program are to handle wastes
in a manner that will protect the health and safety of on-site personnel and the public, and
protect the environment. To meet this goal, the potential for releases of waste to the
environment must be minimized.
DOE policy requires all its operations to be conducted in compliance with all federal, state,
and local laws and regulations in addition to DOE Orders. The PGDP Program is driven
by several different laws and regulations. These include the National Environmental Policy
Act (NEPA), DOE's NEPA Regulations 10 CFR 1021 [57 Federal Register 15122 (April
24, 1992)], RCRA, TSCA, CLEAN Water Act (CWA), CLEAN Air Act (CAA), DOE Order
5440.1E, DOE Order 5820.2A, DOE Order 5480.3, and the Occupational Safety and Health
Act (OSHA). The specific regulatory citations are discussed further in Section 5.0 of this
document.
1.3 PURPOSE AND NEED
The purpose of this action is to provide additional storage capacity for waste that are
classified as toxic substances under TSCA, and hazardous and mixed waste under RCRA.
The need for this action is driven by the shortage of waste storage space. PGDP operations
require approximately 6746 ft^2/year for storage of Toxic Substances Control Act (TSCA)
waste and 2972 ft^2/year for storage of Resource Conservation and Recovery Act (RCRA)
waste (Beach 1992). Based on the TSCA waste generation rate, PGDP will be out of
TSCA waste storage space around August 1994, as projections indicate that only
approximately 4354 ft^2 of TSCA waste storage space is currently available. A projection of
available RCRA waste storage space shows that only 9100 ft^2 currently remain. Based on
this projection, RCRA waste storage space will not be available after FY 1996. A
breakdown of available storage space is provided in Table 1-1.
TABLE 1-1: AVAILABLE WASTE STORAGE SPACE
TOTAL OCCUPIED AVAILABLE
WASTE BUILDING STORAGE CAPACITY CAPACITY
TYPE CAPACITY (FT2) (FT2)
(FT2) (as of 1/1/93) (as of 1/1/93)
______________________________________________________________
C-764-B 15,588 14,404 1184
TSCA C-337 12,797 9627 3170
TOTAL 28,385 24,031 4354
______________________________________________________________
C-733 1520 1156 364
C-746-R 400 372 28
RCRA C-746-Q 8974 7987 987
C-746-A 14,880 7118 7762
TOTAL 25,774 16,633 9141
______________________________________________________________
SOURCE: Comprehensive Waste Storage Plan Revision 1, April 1992
Figure 1-1 Location Map Paducah Gaseous Diffusion Plant (Not available in electronic format.)
1.4 LOCATION
Two identical, approximately 42,000 ft^2 buildings (WSFs) would be built on a 3-acre site
inside the PGDP security fence on previously disturbed land that is mowed and maintained
by PGDP personnel (Figure 1-2). These facilities would be used to store RCRA/TSCA and
RCRA/TSCA-mixed waste (i.e., RCRA or TSCA waste which may also contain radioactive
waste). Two buildings, rather than one large building, are being constructed because the
time required to build a single large building would prevent it from being constructed
before present waste storage is exhausted. The first PGDP WSF would be constructed and
brought on-line followed by the second PGDP WSF. For the purposes of this ea, the two
PGDP WSFs will be addressed as a single unit or operation, since the facilities represent
adjacent buildings and it would be redundant to identify potential impacts associated with
an individual building given the similarities in structure, purpose, and location.
The third facility would be a 200,000 ft^2 building (MWSF) that would be used to store
hazardous and mixed waste as defined by RCRA. The MWSF would be constructed on a
20-acre site, 50% wooded and 50% grassy fields, adjacent to the PGDP security area at the
northwest corner of the plant (Figure 1-2). Although planned facilities would not occupy
the entire 20-acre site, the entire area will be cleared and fenced for security purposes and
to allow for the construction of future waste storage facilities, as needed. For the purposes
of this ea, it will be assumed that construction of the MWSF would disturb approximately
10 acres of the 20 acre site. The combined impacts of all storage facilities within the 20-
acre site will be addressed under the cumulative impacts section (Section 4.1.11) of this
report.
1.5 SCOPE
This ea evaluates the potential impacts of the construction and operation of twoPGDP
WSFs and a MWSF on wetlands, threatened and endangered species, water resources, and
worker health and safety. Areas presented in this document but discussed in less detail due
to the minimal potential for impacts to occur to these resources are: socioeconomics, noise,
historic preservation and cultural resources, floodplains, geology, and topography.
Figure 1-2 Location Plan for the WSPs, PGDP, Paducah, Kentucky (Not available in electronic format.)
1.6 RELATIONSHIP TO OTHER ACTIONS
Other proposed actions related by location (all are on the PGDP reservation), time (all
could occur within similar time frames), and purpose (all are necessary to support continued
uranium enrichment operations at PGDP) are discussed in the cumulative impacts section.
These activities include the construction of a solid waste landfill proposed for a 40 acre
area north of the plant site and a 13 acre expansion to the existing UF6 tails cylinder
storage yards in the south-east corner of the plant site. Each of these proposed activities
are also addressed in separate eas.
This ea was prepared pursuant to the National Environmental Policy Act (NEPA) of 1969,
the Council on Environmental Quality regulations for the implementation of NEPA (Title
40 CFR Parts 1500-1508) and DOE's NEPA Implementing Regulations 10 CFR Part 1021
[57 Federal Register 15122 (April 24, 1992)], DOE Order 5440.1E, and Recommendations
for the Preparation of Environmental Assessments and Environmental Impact Statements,
by the Office of NEPA Oversight, U.S. Department of Energy, May 1993. Based on the
potential for impacts described herein, DOE will either publish a FONSI and proceed with
the proposed action or prepare an Environmental Impact Statement.
2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES
2.1 ALTERNATIVE 1: NO ACTION
The no-action alternative is considered in accordance with NEPA regulations and provides a
baseline for comparison with the proposed action and alternatives. By definition, the no-
action alternative would consist of DOE taking no action to construct new PGDP WSFs,
but continuing to manage and store RCRA- and TSCA-regulated wastes at existing on-site
waste storage facilities. The no-action alternative would also include continued
implementation of waste minimization practices in accordance with site and program waste
minimization plans, which include segregation and recycling where possible. All PGDP-
generated waste would be stored on-site until storage capacity is reached and would need to
cease generating waste or be in violation of federal and state waste management regulations
and agreements. Previously generated waste would remain in existing on-site storage
facilities until alternative waste disposal or treatment options became available.
Included in the no action alternative would be continued shipment of some wastes to an
off-site facility. DOE Order 5820.2A specifies a preference for radioactive waste generated
at a DOE facility to also be managed at a DOE facility, although not necessarily the same
one at which the waste was generated.
On May 17, 1991, DOE imposed a moratorium on off-site shipments of RCRA- and TSCA-
regulated wastes to commercial treatment, storage, and disposal (TSD) facilities (U.S.
House of Representatives 1992). This moratorium was imposed to prevent the inadvertent
transfer of radioactive waste to a facility not specifically authorized to manage the wastes.
The policy does make a provision for lifting the moratorium on a site-specific basis if the
site procedures for defining, classifying, and characterizing the waste are approved by DOE.
Although this approval has not yet been obtained by PGDP, it is anticipated that at some
time in the future, shipments to commercial TSD facilities could be resumed. Under the no
action alternative, shipments of specified wastes to DOE's Hanford, Washington Facility
and the K-25 TSCA Incinerator facility in Oak Ridge, Tennessee would continue under
existing agreements.
The majority of the waste generated at PGDP is solid TSCA mixed waste and, to date, no
off-site facilities have been identified to accept these wastes. Liquid TSCA mixed waste
may be disposed of at the DOE TSCA incinerator in Oak Ridge, Tennessee, but solid
TSCA waste is not currently accepted. Wastes capable of being shipped to the DOE TSCA
incinerator represent only 6.3% of the total TSCA waste stream. Shipping liquid waste to
the TSCA incinerator would solve a small part of the storage space problem at PGDP, but
additional storage facilities would still be necessary.
2.2 ALTERNATIVE 2: PROPOSED ACTION - CONSTRUCT AND OPERATE
NEW WSFs
The proposed WSFs consist of three buildings to be located and constructed at PGDP. The
two PGDP WSFs would contain approximately 42,000 ft^2 of waste storage space each and
would be identical in design. The third WSF, the MWSF, would contain 200,000 ft^2 of
waste storage space. These WSFs would be designed to contain PGDP-generated wastes.
The types of waste generated through PGDP activities include: hazardous waste regulated
under RCRA; toxic waste regulated under TSCA; radioactive waste regulated under Aea;
and mixed waste, defined as TSCA and/or RCRA waste contaminated with radioactive
waste. Table 2-1 depicts the waste types, the RCRA/TSCA constituents in the waste, and
the estimated annual quantity of waste generated [in drums and required storage space (ft^2)].
These values reflect continued implementation of waste minimization practices in
accordance with site and program waste minimization plans.
These facilities would be designed to survive until plant closure and would support future
facility decontamination and decommissioning activities. Closure of the PGDP WSFs
would be conducted according to future site decommissioning plans.
2.2.1 Location, Site Preparation, and Construction of the PGDP WSFs
The PGDP WSFs would be located and constructed in phases. Each WSF is discussed
separately.
2.2.1.1 WSFs
The two WSFs would be located on a 3-acre site inside the PGDP security fence, in a
previously disturbed, mowed, grassy area south of Building C-746-B, west of railroad track
#6, and east of C-745-C Cylinder Yard (Figure 1-2). Soil surveys have been performed at
the site, and the soil within the construction area is free of contaminants
that would require any remedial action. Only minor grading and excavation in the area
would be required to support construction of the facilities. Utilities for sanitary/fire water
and electrical supply would be extended to the site from existing distribution systems.
Paved or concrete surface areas and roof drainage would be routed to existing ditches via
underground storm drains and by positive surface drainage from the buildings.
One PGDP WSF would be constructed in FY 1994 and the other in FY 1995. Each
approximately 42,000-ft^2 WSF would provide space equivalent to approximately 18,000 ft^2
of useable waste storage space, based on three tier stacking (three drums high) of U.S.
Department of Transportation (DOT) approved 55-gallon drums. The WSFs would also
provide space for inspection and vehicle access requirements. No office, administrative, or
sampling areas will be included within the WSFs.
TABLE 2-1: ESTIMATED ANNUAL PGDP WASTE GENERATION
TSCA/RCRA ESTIMATED ANNUAL
WASTE TYPE CONSTITUENTS IN QUANTITY OF WASTE
WASTE (required storage, ft^2)
__________________________________________________________________
Solid TSCA PCBs 373 drums
(746 ft^2)
__________________________________________________________________
Solid TSCA-MW PCBs, Radionuclides, 3000 drums
Hazardous Substances (6000 ft^2)
__________________________________________________________________
Liquid TSCA-MW PCBs, Radionuclides, 227 drums
Hazardous Substances (454 ft^2)
__________________________________________________________________
Liquid RCRA-MW Hazardous Substances, 114 drums
Radionuclides (228 ft^2)
__________________________________________________________________
RCRA Hazardous Substances 1486 drums
(2972 ft^2)
__________________________________________________________________
SOURCE: Comprehensive Waste Storage Plan Revision 1, April 1992
Construction of the PGDP WSFs and the MWSF would be in compliance with
following:
DOE Order 5700.6C, Quality Assurance, August 21, 1991
DOE Order 5820.2A, Radioactive Waste Management, September 26, 1988
DOE Order 6430.1A, General Design Criteria, April 6, 1989
Energy Systems Y/EF-538 Rev. 6, General Design Criteria, March 18, 1992
Title 29 Code of Federal Regulations Part 1910 (OSHA), 1992
American National Standards Institute (ANSI), 1992
American Society for Testing and Materials (ASTM), 1992
National Fire Protection Association (NFPA) 101, Life Safety Code, 1992
Title 40 Code of Federal Regulations Part 261 (RCRA), 1992
Title 40 Code of Federal Regulations Part 761 (TSCA), 1992
The PGDP WSFs and the MWSF would not be considered special facilities or nuclear
facilities as defined in DOE Order 6430.1A, General Design Criteria, because of the low
levels of radioactivity allowed in the wastes received (discussed further in Section 2.2.2
"Operation of the PGDP WSFs"); therefore, no special safety or environmental protection
systems would be necessary. The buildings would be constructed to withstand live loads
(wind, snow, movement of equipment, and variable weight) and dead loads (weight of the
structure and building materials) as specified in ASCE 7-88, Minimum Design Loads for
Buildings and Other Structures. The buildings would be constructed for seismic loading in
accordance with the 1991 Uniform Building Code or University of California Radiation
Laboratory (UCRL) 15910, Design and Evaluation Guidelines for DOE Facilities Subjected
to Natural Phenomena Hazards, whichever is more stringent. The buildings would also be
classified as low hazard facilities in accordance with UCRL 15910.
Both of the PGDP WSFs would be one-story, pre-engineered, metal buildings with pre-
finished metal siding and standing-seam metal rooves and gutters, and would be completely
insulated. The foundation would have cast-in-place concrete footings for the metal building
columns and continuous grade beams around the perimeter. A motorized, roll-up, overhead
door as well as a hollow, metal, personnel access door would be furnished at both the north
and south ends of the PGDP WSFs. Additional personnel doors would be installed along
the length of the buildings as required.
The waste would be stored within concrete diked areas designed as part of the floor. The
floors would be coated with a sealant (e.g., Carboline Starglaze) impermeable to
polychlorinated biphenyls (PCBs) and easily decontaminated, if necessary. Drums would
be stored within the diked areas of the facility that meet TSCA waste storage requirements
(40 CFR 761.65). TSCA regulations require that a minimum of a 6-inch dike be provided
and that the floor and dike must provide a containment volume equal to at least two times
the internal volume of the largest container stored therein or 25% of the total internal
volume of all containers stored therein, whichever is greater. In addition, the dikes would
be designed to contain all fire water released during a design basis fire (Lockwood Greene
1991). Portable fire extinguishers would also be provided as required by NFPA 10.
Vehicle access (trucks, forklifts) would be provided by the roll-up doors at each end of the
facility and by reinforced concrete driveways. Concrete ramps would be installed inside the
PGDP WSFs to provide for safe movement of forklifts carrying pallets of drums.
2.2.1.2 MWSF
The MWSF would be located on a 20-acre area adjacent to and outside of the PGDP
northwest security fence (Figure 1-2) which is part of the DOE owned buffer zone. The
20-acre area consists primarily of grassy fields with approximately 10 wooded acres. Soil
surveys have been performed at the site and the soil is free of contaminants that would
require any remedial action. Of the 20 acres, a total of 10 acres would be developed and 6
acres would contain the building footprint and associated paved or concrete driving/parking
areas. The remaining 10 acres are reserved for future waste storage facilities.
The MWSF would be constructed in FY 1996, and after construction, the security fence
would be relocated to encompass the MWSF site. Utilities such as gas, water, electricity,
sanitary sewer, and storm water service would be connected to existing plant services.
Paved or concrete surface areas and roof drainage would be routed to existing ditches via
underground storm drains and by positive surface drainage from the building.
The MWSF consists of one building providing approximately 200,000 ft^2 of waste storage
space, based on two tier stacking (two drums high) of DOT-approved 55-gallon drums.
The MWSF would also provide areas for inspection and vehicle access. An administration
area is included as part of the MWSF to house offices and related support facilities as well
as changehouses for use by waste management personnel. The administration area would
be completely segregated from the waste storage area. Appropriate boundary control and
monitoring stations between regulated and non-regulated areas would be provided.
Receiving, sampling, repackaging, and drum crushing areas would be included as part of
the MWSF, and would be enclosed, regulated areas. The receiving area would provide
facilities for the receiving of wastes generated at PGDP. Sampling and staging would be
conducted to prepare those wastes for long-term storage within the MWSF.
Construction of the facility would incorporate all applicable requireme
TSCA, OSHA, state and federal regulations as well as all applicable DOE Orders for the
handling and storage of mixed waste. Where there is regulatory overlap, the most stringent
of the regulations would be instituted. Construction of the MWSF would be in compliance
with the regulations previously listed.
The building would be one-story, pre-engineered metal, with pre-finished metal siding and a
metal deck on steel joists for the roof and gutters, and would be completely insulated. The
foundation would have cast-in-place concrete footings for the metal building columns and
continuous grade beams around the perimeter. Motorized, roll-up, overhead doors would be
furnished as required, as well as hollow, metal, personnel access doors. Paved or concrete
parking areas would also be provided.
Inside the MWSF, a total of 28 pads, having nominal dimensions of 52 ft. by 102.5 ft.,
would be required to store the wastes. Pads would be constructed as monolithic pours, and
the floors and dikes in the entire waste storage area would receive a coating (e.g., Carboline
Starglaze) that is resistant to both chemical attack and abrasion. The enclosed arrays of
concrete pads would be recessed 9 inches below forklift aisles and would provide spill
containment. All storage areas would have perimeter dikes along with the internal diking
systems which would provide additional containment if necessary.
The receiving, sampling, repackaging, and drum crusher areas would be heated and
ventilated through a duct work system. Air would be exhausted from hoods in the
sampling, repackaging, and drum crusher areas through a high-efficiency particulate air
(HEPA) filter system to prevent any possible airborne hazardous or radioactive particulates
from being released during normal or emergency operations. Air would flow into the
hoods through wall openings equipped with transfer grilles and back flow preventers. All
air supply ducts would also be equipped with transfer grilles and back flow preventers and
the regulated areas would be maintained at negative pressure to prevent the potential spread
of hazardous materials to unregulated areas of the facility.
Approximately 15% of the MWSF drum storage area would have a heating system. The
heated area of the building would be used for storage of liquid waste that could freeze.
The rest of the building would store waste not affected by temperatures below freezing.
The entire building would have a ventilation system to provide cooling by using roof
exhausters with motorized, smoke-tight dampers.
2.2.2 Operation of the PGDP WSFs
The PGDP WSFs would have different operational capabilities. Each WSF is discussed
separately.
2.2.2.1 PGDP WSFs
Operation of the first PGDP WSF would be expected to begin in FY 1994. The second
WSF would be operating in FY 1995 or FY 1996. Waste generated by activities within
PGDP would be transported by trucks or trailers to the PGDP WSFs in either DOT-
approved 55-gallon drums or 85-gallon overpacks. Drum packaging, sampling, and labeling
would be accomplished at the waste generator site prior to its being transported for storage.
Classified waste would not be accepted for storage (Walker, 1991), and only the following
waste would be accepted at the PGDP WSFs:
1. Physical state: The waste would consist of liquids, sludges, and solids in varying
combinations. Pressurized vessels, including gas cylinders, would not be accepted
for storage.
2. Chemical composition: TSCA (e.g., PCB laden) or RCRA (e.g., hazardous) wastes.
3. Radionuclides:
Uranium: Content - No limit on the total uranium per container.
Assay - Limited to less than 1% 235U or less than 0.0875 kg
235U per container in accordance with PGDP Criticality Safety
Requirements.
Transuranics*: Disintegration measurement readings would be limited t
than 100 nCi/g per container (soil matrix).
Technetium-99: Disintegration measurement readings would be limited to less
than 3 Ci/m3 (aqueous).
4. Scrap metals would be accepted for storage if containerized.
*Transuranic elements are elements that have atomic numbers greater than 92; all
are radioactive and are products of artificial nuclear reactions (nuclear reactors).
These elements were introduced to PGDP during the reprocessing of spent nuclear
fuels and are not produced by PGDP. PGDP no longer reprocesses spent fuels and
transuranic wastes are the result of decontamination measures.
All packaging would be in good condition before storage. The 55-gallon drums would be
placed on 4 ft. by 4 ft. pallets, with four drums to a pallet, and the 85-gallon drums would
be placed in similar numbers on 5 ft. by 5 ft. pallets. Pallets would be moved to the proper
storage area by 5000-pound capacity fork trucks. The pallets would be arranged in single
rows and drums would be stacked a maximum of three high within the storage areas
(Walker 1991). A minimum of 2 ft. of aisle space would be placed between the stacks of
pallets for inspection. Additionally, other approved waste storage containers (e.g. B-25
boxes) may be placed in the facility. Inspection procedures would comply with RCRA or
TSCA requirements and inspection activities would occur every 30 days.
All waste containers placed in storage would be appropriately marked and designated
according to the waste that is stored in each container. All markings and designations
would be located in a visible location for inspection purposes.
The PGDP WSFs would be considered non-regulated waste storage areas requiring standard
PGDP issued work clothing. In the event of a spill from a damaged or leaking drum, a
Chemical Operations Spill Response Team would wear appropriate personal protective gear
and CLEAN-up the spill area. Damaged or leaking drums would be repackaged or
overpacked, as necessary.
Operations personnel would provide their own portable eyewashers, and in addition,
combination emergency showers and eye/face wash units would be installed at each end of
the building within the diked area. The units would be equipped for back draining to the
supply pipes to prevent freezing.
2.2.2.2 MWSF
Operation of the MWSF would be expected to begin in FY 1996. Generated waste from
activities within PGDP would be transported by trucks or trailers to the MWSF in either
DOT-approved 55-gallon drums or 85-gallon overpacks. The waste acceptance criteria are
similar to the PGDP WSFs with one exception: the MWSF would also accept RCRA
mixed waste. Wastes accepted by the facility would be segregated by waste type and
characterized as low, medium, or high hazard wastes as shown in Table 2-2. These
projections include waste streams from environmental restoration and decontamination and
decommissioning in addition to operations.
TABLE 2-2: MWSF CHARACTERIZED WASTE HAZARD LEVEL
___________________________________________________________________
HAZARDOUS AND STORAGE SPACE
HAZARDOUS MIXED (FT2) HAZARD LEVEL*
SOLIDS (5-year projection)
___________________________________________________________________
Lead 500 Medium
___________________________________________________________________
Potassium Dichromate 140 Medium
Filter Cake
___________________________________________________________________
Brass Chips 100 Medium
___________________________________________________________________
Trichloroethylene 8000 Medium
___________________________________________________________________
Hot Water Rinse Tank 3000 Medium
Sludge
___________________________________________________________________
Magnesium Fluoride Pellets 1000 Medium
___________________________________________________________________
Technetium** 200 High
___________________________________________________________________
Transuranic** 200 High
___________________________________________________________________
Uranium Precipitate 3000 Medium
___________________________________________________________________
Pesticides** 1000 High
___________________________________________________________________
Excess Chemicals 3000*** High
___________________________________________________________________
Ash Receivers** 5000 Medium
___________________________________________________________________
Hazardous/Hazardous 4000 High
Mixed Liquids
___________________________________________________________________
LLW-Solid 54,360 Low
___________________________________________________________________
LLW-Liquid 500 High
___________________________________________________________________
+PCB/PCB Mixed Liquid 10,000 High
___________________________________________________________________
+PCB/PCB Mixed Solid 100,000 Low
___________________________________________________________________
Asbestos (with PCB/RCRA 6000 Medium
and/or LLW)
___________________________________________________________________
* Hazard levels are based on exposures in the event of a spill or similar accident.
** Previously generated but require storage.
*** Excess chemical room to be separated from other high hazard areas. Smaller
individual dikes will separate flammables, oxidizers, organics, combustibles.
+ Facility designed to more stringent TSCA specifications.
The MWSF would be divided into low, medium, and high hazard characterized waste
receiving and storage areas. Physical requirements for the low and medium hazard waste
receiving and storage areas would be the same except for posting. The main receiving area
would be an enclosed, non-regulated dock capable of receiving low and medium hazard
characterized wastes from a maximum of three trucks. High hazard wastes would be
received at a separate and dedicated dock to reduce the possibility of mixing/storing high
hazard materials with low and medium hazard materials and to reduce fire hazards. All
high hazard areas will be separately enclosed from the low and medium hazard areas by a
4-hour fire-resistant enclosure.
Drum repackaging, sampling, and crushing activities would be in enclosed and regulated
areas. All exits from these areas would include a boundary control station for
contamination control purposes, and HVAC would be supplied from a system completely
dedicated to these areas. Damaged drums would be repackaged or overpacked, as
necessary, and potential spills or leaks would be CLEANed-up by an on-site Chemical
Operations Spill Response Team (Bell, 1991).
2.3 ALTERNATIVE 3: ALTERNATE LOCATIONS
Several sites were screened as potential sites for the proposed waste storage facilities. All
of the alternate sites evaluated are located on DOE property outside the security fence
(Figure 2-1).
Alternate Site 1 This site is located to the east-southeast of the existing solid waste
landfill (SWL) between major power line corridors. Highway 358 transects the site, and
the intersection of Ogden Landing Road and Dyke Road is to the south. Alternate Site 1 is
essentially an open area with little topographical relief, located approximately 1200 ft west
of Little Bayou Creek. Main power transmission lines also bound this location.
Alternate Site 2 This site is located adjacent to the northeast corner of PGDP on a ridge
that extends toward Little Bayou Creek. It is bordered by Little Bayou Creek on the
southeast and KPDES Outfall 002 on the south. The intersection of Highway 358 and
Ogden Landing Road is to the north of the site. This site has equal amounts of grasslands
and woodlands, and it is located near the edge of the DOE property boundary. Residences
are located approximately 1/4 mile east of this alternate location.
Alternate Site 3 This site is located east of PGDP and is bordered by McCaw Road on the
north and Little Bayou Creek on the northwest. The area is 60% open grassland and 40%
hardwood forest. Alternate Site 3 is also near the DOE property boundary line with
residences located approximately 300 ft to the east.
Figure 2-1 Alternate Locations (Not available in electronic format)
2.4 ALTERNATIVE 4: ALTERNATIVES CONSIDERED AND DISMISSED
Upgrading existing facilities and the off-site shipment of waste were considered as
alternatives but, for reasons outlined below, were dismissed from further evaluation as not
viable. They are not discussed further in this document.
2.4.1 Upgrade Existing Facilities
Upgrading and utilizing existing unoccupied buildings, or areas in process buildings, to
store waste to meet RCRA and TSCA regulations and DOE Orders was considered as an
alternative. Limited space is available within some facilities, but collectively these facilities
could not provide the total waste storage space necessary considering projected waste
generation rates. Additionally, storage of waste in some of the existing buildings would
require major retrofitting and decontamination, which would result in generating substantial
amounts of waste which would require storage. Existing waste storage facilities are nearing
capacity and will not be able to adequately accommodate future generated PGDP wastes.
Therefore, given the amount of time required to renovate a building or area for waste
storage, the quantities of waste that would be generated as a result of renovation activities,
and the present need for waste storage space, this alternative is not considered viable.
2.4.2 Off-Site Shipment of Waste
Based on the DOE Moratorium placed on off-site waste shipments to commercial TSD
facilities as explained in Section 2.1, shipment of all wastes generated by PGDP operations
is not feasible at this time (U.S. House of Representatives 1992).
3.0 DESCRIPTION OF THE EXISTING ENVIRONMENT
PGDP is located within the Jackson Purchase Region of western Kentucky in McCracken
County, approximately 3.5 miles south of the Ohio River and 20 miles east of the
confluence of the Ohio and Mississippi rivers. The city of Paducah is the closest
municipality to PGDP, located approximately 10 miles to the east. Several small
communities are situated within a 5-mile radius of the DOE property boundaries, including
Heath and Grahamville to the east and Kevil to the southwest. Bordering the DOE property
to the northeast is the Shawnee Steam Plant, which is owned and operated by the Tennessee
Valley Authority (TVA). The area surrounding PGDP is predominately rural, with
residences and farms surrounding the plant. Figure 1-1 shows the location of PGDP with
respect to features described above.
The existing environmental features of PGDP are addressed in this section with respect to
the following resources: geology; hydrology; soils; climate, air quality, and noise;
biological resources; land use; cultural resources; and social and economic conditions.
3.1 GEOLOGY
The geology at PGDP consists of clastic continental and marine deposits. The Continental
Deposits are represented by two sedimentary sequences from two distinct depositional
periods (Olive 1980). The younger sequence, known as the Upper Continental Deposits
(UCD), frequently contains perched water zones that comprise the Upper Continental
Recharge System (UCRS). The UCD varies in thickness up to about 65 ft. The older
sequence, known as the Lower Continental Deposits (LCD), contains the gravel facies that
forms the Regional Gravel Aquifer (RGA), which is the primary source of drinking water
north of PGDP.
PGDP is located in an area with a seismic risk rating of 3, on a scale of 1 to 3, with 3
being the most severe rating (Murray State University, 1990). Several minor seismic
tremors have been recorded at PGDP since the early 1950s; the largest, in 1962, measured
5.5 on the Richter scale; however, there has never been a release or accident as the result of
seismic activity. Analysis of PGDP critical facilities indicates that, based on a 237 year
seismic event producing a ground acceleration of 0.18g, the only damage during an
earthquake would be to nonreinforced concrete block walls (Energy Systems, 1985). The
potential for releases from PGDP resulting from seismic events has not been quantified
(Murray State University 1990), but this potential is being analyzed under a final safety
analysis report for PGDP.
3.2 HYDROLOGY
3.2.1 Surface Water
PGDP is located in the western part of the Ohio River Basin. The confluence of the Ohio
and Tennessee rivers is approximately 15 miles upstream of the site. The confluence of the
Ohio and Mississippi rivers is approximately 20 miles downstream of the site.
PGDP is located on a local drainage divide; surface flow is to the east and northeast toward
Little Bayou Creek and to the west and northwest toward Big Bayou Creek. The
confluence of the creeks is approximately 3 miles north of the site (Figures 3-1 and 3-2).
Big Bayou Creek is a perennial stream; its drainage basin extends from approximately 2.5
miles south of PGDP to the Ohio River. Big Bayou Creek flows north toward the Ohio
River along a 9-mile course that passes along the western boundary of the plant. Little
Bayou Creek originates in the West Kentucky Wildlife Management Area (WKWMA) and
flows north toward the Ohio River along a 6.5-mile course that includes parts of the eastern
boundary of the plant. The 11,910-acre drainage basin of Big Bayou Creek is about twice
that of Little Bayou Creek (about 6,000 acres). Natural runoff makes up a small portion of
the flow in Big Bayou and Little Bayou creeks during the dry periods. Big Bayou Creek
and Little Bayou Creek have not been formally classified by the Kentucky Department for
Environmental Protection (KDEP); however, according to state regulations (401 KAR
5:026) any waters not specifically classified by the KDEP are otherwise designated for the
following uses: warm water aquatic habitat, primary contact recreation, secondary contact
recreation, and domestic water supply (KDEP 1990). Thus, by default, Big Bayou Creek
and Little Bayou Creek are classified for these uses.
Both Little Bayou and Big Bayou creeks receive effluent discharge from PGDP. Big
Bayou Creek receives process effluent, treated sewage, and storm water discharge from
PGDP under Kentucky Pollutant Discharge Elimination System (KPDES) permit
KY0004049 dated October 22, 1986, and an Agreed Order with the Commonwealth of
Kentucky dated October 12, 1987, which adjudicates the KPDES permit. The most current
KPDES Permit was effective in November 1992, with an expiration date of November
1997, but is not yet in full effect, as several parameters are being adjudicated and an agreed
order developed. Effluent from the outfall ditches constitutes approximately 85% of the
normal flow in Big Bayou Creek and 100% of the normal flow in Little Bayou Creek. The
plant effluent was in compliance with KPDES Agreed Order limits 99.5% of the time
during 1991 (Energy Systems 1992). Radiological monitoring of plant effluent during 1990
indicates uranium and technetium values below the Derived Concentration Guides stated in
DOE Orders 4400.4 and 5400.6 (Energy Systems 1991).
The site of the PGDP WSFs is located approximately 100 feet west of a ditch that flows to
KPDES outfall 003. KPDES outfall 003 drains into a tributary of Little Bayou Creek
approximately 2,500 feet from the site.
Figure 3-1 Regional Surface Water Features in the Vicinity of PGDP (Not available in electronic format)
Figure 3-2 Local Surface Water Features in the Vicinity of PGDP (Not available in electronic format)
Another ditch, approximately 100 feet north of the site of the PGDP WSFs, drains to
KPDES outfall 001. KPDES outfall 001 discharges to Big Bayou Creek, which is
approximately 3700 feet from the proposed site of the PGDP WSF. Both of the KPDES
outfalls are located on the opposite side of a roadway from the site of the PGDP WSFs.
The site of the MWSF is approximately 100 feet from KPDES outfalls 001 and 015, which
are located north and south of the proposed site, respectively. Both of these KPDES
outfalls discharge into Big Bayou Creek, which is approximately 750 feet west of the site
of the MWSF (Figure 3-3).
Alternate Site 1. Alternate Site 1 is located approximately 1200 ft west of Little Bayou
Creek. Also, a small tributary of Little Bayou Creek extends into the northeast corner of
the site. A small intermittent wet area exists in the center of the site, adjacent to Route
358. Sufficient space is available that meets the siting requirements for the proposed action
to construct a landfill at this site.
Alternate Site 2. Alternate Site 2 is bordered by Little Bayou Creek on the southeast and
KPDES Outfall 002 on the south. Two small intermittent wet areas are located within the
site boundaries.
Alternate Site 3. Little Bayou Creek borders approximately 300 ft of this site on the
northwest. Several small intermittent wet areas are located within the site boundaries.
3.2.2 Groundwater
The Upper Continental Recharge System (UCRS) that underlies PGDP is composed of
heterogeneous silt and clay layers with interbedded or interlensed layers of sand and gravel.
The distribution and depth of the sand and gravel layers determines the location of the
water table within this recharge system. The discontinuous sandy horizons interbedded
with finer grained units result in perched groundwater throughout the UCRS. Perched
groundwater levels in the immediate vicinity of the proposed sites are located 17 feet below
ground, with groundwater levels ranging from 37 to 51 feet below ground surface (Geotech,
1980).
The RGA lies within the gravel facies of the Lower Continental Deposits. It serves as the
primary source of drinking water for residents north of PGDP. The closest drinking water
well is approximately one mile north of the sites. However, this well is no longer in use
due to groundwater contamination. The RGA has a north to northeasterly flow direction
toward the Ohio River. The RGA exits as a semiconfined to confined aquifer, depending
on the composition of the Upper Continental Deposits, which serves as the upper confining
unit for the RGA. Recharge to the RGA is provided by infiltration from overlying deposits
(UCRS) and surficial water bodies (Big Bayou and Little Bayou creeks). Groundwater
conditions at the alternate locations are similar to those described for the proposed location
and overall site conditions.
PGDP currently has a groundwater monitoring and protection program as required by state
and federal regulations and DOE Orders (Figure 3-4 and 3-5). Technetium has been
detected in many plant and off-site wells; other contaminants such as heavy metals and
Americium have been detected in varying concentrations (Energy Systems 1991).
3.2.3 Floodplains
Flooding in the vicinity of the proposed location for the WSFs is causes by headwater
flooding from Big Bayou Creek and is not affected by backwater flooding from the Ohio
River for a 500-year or lesser flood (Cross 1993). The 100-year flood elevation for Big
Bayou Creek nearest these locations ranges from about 365 to 366 feet above mean sea
level (MSL). The 500-year flood elevation ranges from about 366 to 367 feet above MSL
(Cross 1993). The WSFs would be built at base elevations of at least 370 feet above MSL,
out of the 100- and 500-year floodplains.
3.2.4 Wetlands
No large wetlands exist at the sites of the PGDP WSFs and MWSF (USFWS 1983).
However, field observations at the site of the MWSF indicate the existence of two isolated,
non-headwaters wetlands with less than 0.5 acre total area that meet the requirements of a
jurisdictional wetland. Consultation with the U.S. Army Corps of Engineers (COE)
confirmed the delineation of these wetlands. A wetlands assessment was prepared for DOE
in accordance with 10 CFR 1022. The wetlands assessment concluded that none of the
potentially affected wetlands is of high ecological value in a regional context (Appendix A).
Figure 3-3 MWSF Proposed Location Major Topographical Features, PGDP (Not available in electronic format)
Figure 3-4 On-site Well Locations, PGDP (Not available in electronic format)
Figure 3-5 Off-site Well Locations, PGDP (Not available in electronic format)
3.3 SOILS
The soils in the vicinity of PGDP consist of silty loam and silty clay loam lying above the
loess and alluvium surficial deposits. Five soil series are mapped in close proximity to
PGDP (Humphrey 1976). These soil series include the Calloway silt loam, Grenada silt
loam, Loring silt loam, Vicksburg silt loam, and the Henry silt loam. The Calloway-Henry
association is the predominant soil association found in the vicinity of PGDP.
The soils at the proposed site of the PGDP WSFs consist of disturbed Henry silt loam.
Henry soils are nearly level, poorly drained soils with a fragipan that formed in thick
deposits of loess or alluvium (Humphrey 1976). Henry soils have moderate permeability
(0.63 to 2.0 in/hr) above the fragipan, which forms between 17 and 26 inches from the
surface, and slow permeability (<0.2 in/hr) within and below the fragipan. The water table
is perched above the fragipan and extends to the surface during wet seasons (Humphrey
1976).
At the proposed location of the MWSF, disturbed Henry silt loam, Calloway silt loam, and
Vicksburg silt loam (Figure 3-6) are present. The Henry silt loam comprises 50-60% of the
area potentially to be developed. Calloway, Grenada and Vicksburg silt loams comprise the
remaining 40-50% of the area.
Calloway silt loam is somewhat poorly drained with a fragipan that formed in loess
(Humphrey 1976). These soils have moderate permeability (0.63 - 2.0 in/hr) above the
fragipan, which is between 26 and 50 inches below the surface, and slow permeability (<0.2
in/hr) within and below the fragipan. These soils have perched water tables which are 6 to
18 inches below the surface during wet season (Humphrey 1976). Slopes range from 0 to
6% (Humphrey 1976).
Soils in the Grenada series are moderately well drained soils formed in loess on relatively
smooth uplands and in alluvium washed mostly from loess on stream terraces (Humphrey
1976). Grenada soils at the proposed MWSF site are severely eroded with 6 to 12% slopes.
The depth to the fragipan ranges from 12 to 24 inches, with an average depth of 14 inches
(Humphrey 1976). The soil above the fragipan is moderately permeable (0.63 - 2.0 in/hr),
while the fragipan is relatively impermeable (<0.2 in/hr). Soils below the fragipan have
moderately slow permeability (0.2 - 0.63 in/hr)(Humphrey 1976). The water table is
perched above the fragipan during wet periods (Humphrey 1976).
The Vicksburg series consists of well-drained, nearly level soils on flood plains of branches
and creeks. These soils formed in sediments washed mainly from loess (Humphrey 1976).
These soils has moderate permeability (0.63 - 2.0 in/hr). The water table is generally 2 to 3
ft below ground surface (Humphrey 1976). Some soils are subject to flooding, but the
floods are generally for short duration and the erosion hazard is slight (Humphrey 1976).
Figure 3-6 Soils Map, PGDP (Not available in electronic format)
Prime Farmlands
The following soil series, located in the vicinity of PGDP, are considered to be
representative of prime farmland: Calloway silt loam, Falaya-Collins silt loam, Grenada silt
loam, Loring silt loam, and Vicksburg silt loam. None of these soil types are found at the
PGDP WSF site.
Calloway, Grenada and Vicksburg soils are present at the MWSF site. However, the soils
at the site have been disturbed as a result of construction and maintenance activities at
PGDP since the early 1950s. For this reason, U.S. Soil Conservation Service (SCS) has
determined that none of the soils present at the site of the MWSF are prime farmland (SCS,
Appendix B, "Agency Letters/Correspondence").
Alternate Site 1. The Henry, Calloway, and Grenada soil associations are represented at
this location. Approximately 75% of the soils at this location have the potential to be
classified as prime farmland.
Alternate Site 2. The Henry silt loam, Calloway silt loam, and Falaya-Collins silt loam are
represented at this location. Sixty to seventy percent of the soils at this location have the
potential to be classified as prime farmland.
Alternate Site 3. Alternate Site 3 is primarily covered by the Henry silt loam with the
remaining being Calloway silt loam. Ten percent of the soils at this site have the potential
to be classified as prime farmland.
3.4 CLIMATE, AIR QUALITY, AND NOISE
3.4.1 Climate
PGDP is located in the humid continental climate zone, which is characterized by
moderately cold winters and warm summers (Energy Systems 1991). The average monthly
temperature is 57.6o F, ranging from a low monthly average of 32.6o F in January to a high
monthly average of 79.1o F in July. On average, the maximum daily temperature is below
32o F 14 days of the year. Summers are typically warm and humid, with the maximum
daily temperature exceeding 90o F an average of 40 days per year. The relative humidity
varies between 60 and 85% throughout the year.
Precipitation averages 50.3 inches annually, with the greatest volumes occurring during the
periods of March-July and November-December. Thunderstorm activity is common in the
summer months. On average, a precipitation event of up to 3.6 inches within 24 hours
occurs every 2 years, and a precipitation event of up to 6.6 inches occurs every 50 years.
The driest period of the year is August through October. Approximately 2% of the
precipitation occurs in the form of snow, with an annual average of 13.1 inches.
The prevailing wind direction is from the south to southwest with an average speed of
approximately 10 miles/hour. Stronger winds occur in the late fall and winter, and are
generally associated with weather fronts originating from the southwest and northwest.
3.4.2 Air Quality
McCracken County (which includes PGDP and the city of Paducah) is an attainment area
for National Ambient Air Quality Standards. The Kentucky Division for Air Quality
(KDAQ) measures particulate matter, sulfur dioxide, carbon monoxide, ozone, nitrogen
dioxide, and lead. Measurements are taken to establish values for annual arithmetic means,
maximum 24-hour averages, and maximum 3-hour averages. In 1991, none of these
standards (primary or secondary) were exceeded at any of the McCracken County
monitoring stations (KDAQ, 404 KAR 51:010).
PGDP collects air samples from 12 different locations to determine if there is an off-site
migration of airborne contaminants (Energy Systems 1991). Gaseous fluorides and
radioactive particles are sampled continuously via filters treated with sodium carbonate.
Weekly analyses are performed on the samples for fluoride concentrations, and alpha and
beta activity. Off-site concentrations of air-borne radionuclides and fluorides are well
within the federal standards (40 CFR 61.92) and the Kentucky ambient air quality standards
(401 KAR 53:010) (Energy Systems 1992).
3.4.3 Noise
Noise levels are not measured at PGDP or at any nearby facilities. There are currently no
local ordinances concerning noise regulation. The Commonwealth of Kentucky has a law
concerning noise regulation, but no enforcement or monitoring program has been created
and no regulations governing the implementation of this law have been promulgated. Noise
from industrial processes taking place at the plant are generally restricted to the interior of
the plant buildings. Noise levels at the plant security fence are generally the result of
vehicular traffic moving through the area, and not from activities occurring at the plant.
3.5 BIOLOGICAL RESOURCES
3.5.1 Vegetation
Hardwood forests and herbaceous plant communities comprise the predominant vegetation
types in the vicinity of PGDP. Mature hardwood forests dominate the riparian communities
on the banks of Little Bayou and Big Bayou creeks. Forests above the streams and over
the remainder of the area in the vicinity of PGDP are dominated by upland communities.
Virtually all non-forested areas within the PGDP boundary are managed by personnel from
either the PGDP or the WKWMA for wildlife habitat and food supply. Management
practices are primarily limited to mowing, planting, and controlled burning. This practice
maintains grasses as the dominant vegetation, although numerous other types of vegetation
exist in these areas.
Vegetation communities within the proposed PGDP WSF site reflect a history of persistent
surface disturbance from plant activities and frequent mowing. Vegetation consists
primarily of grasses and broad-leafed herbaceous species. No trees or shrubs are present.
Vegetation at the MWSF site represents plant communities in various stages of regrowth.
The site is covered by a mixture of woodlands and mowed fields, with upland mixed
hardwoods covering approximately 50% of the area. Woodland species include various
oaks (Quercus sp.), shagbark hickory (Carya ovata), maples (Acer sp.), American elm
(Ulmus americana), sweetgum (Liquidambar styraciflua), and sugarberry (Celtis laevigata).
The woodlands are edged by a field scrub-shrub community consisting of black locust
(Robinia pseudoacacia), sumac (Rhus sp.), and persimmon (Diospyros virginiana). Mowed
fields consist of commercial grasses (e.g., fescue, timothy grass, orchard grass, etc.) and
ruderal vegetation. These vegetation communities are commonly found throughout the area.
Alternate Site 1. This site is located between two high tension power line easements. The
area consists of managed open grasslands with scattered stands of trees. Approximately
10% of the area consists of mixed hardwood and scrub-shrub communities. These
communities are interspersed throughout the site.
Alternate Site 2. The vegetation at this site consists of equal amounts of area covered by
open grasslands and woodlands. The woodlands at this location consist of an upland mixed
hardwood community. The northern portion of the woodlands consists primarily of
overstory trees with little ground cover. Toward the edges of the woodlands the understory
is dominated by various types of common shrubs and thickets.
Alternate Site 3. The vegetation at this site consists of approximately 60% managed open
grasslands and 40% upland mixed hardwood forest. The forest understory consists of
common shrubs and thickets.
3.5.2 Wildlife
Wildlife species indigenous to hardwood forests and open, grassland communities occur in
the vicinity of PGDP. The most abundant species is the house mouse (Mus musculus).
Deer, cottontail, and the white-footed mouse are also common to the area (Birge 1990).
Wildlife habitat at the PGDP WSF site is highly disturbed and is considered poor quality
for support of a variety of terrestrial wildlife species. Because the site is within the PGDP
security fence and is surrounded by buildings and other structures associated with industrial
operations, animals visiting or inhabiting the site would be limited to those that are adapted
to living within areas of high human activity. These animals include opossum (Didelphis
virginiana), raccoon (Procyon lotor), various types of rodents (e.g., voles and mice) and
songbirds.
At the MWSF site, wooded areas with open fields are frequented by deer, rabbits, mice,
songbirds, and a variety of small mammals and birds. Small mammals commonly found at
the site include opossum, vole (Microtus sp.), mole (Scalopus sp.), raccoon, and gray
squirrel (Sciurus carolinensis). Typical birds include killdeer (Charadrius rociferus),
bluejay (Cyanocitta cristata), red-winged blackbird (Agelaius phoeniceus), bluebird (Sialia
sp.), cardinal (Cardinalis cardinalis), mourning dove (Zenaida macroura), shrikes (Lanius
sp.), bobwhite quail (Colinus virginianus), meadow larks (Sturnella sp.), sparrows, and
predators such as hawks and owls (Birge 1990). The Ohio River serves as a major flyway
for migratory birds (Birge 1990); therefore, migratory birds and transient residents are
occasionally present at the site.
Amphibians and reptiles are common throughout the DOE reservation (Birge 1990).
Amphibians likely to occur at the MWSF site include American (Bufo americanus) and
Woodhouse's (Bufo woodhousei) toad. Reptiles include the eastern box turtle (Terrapene
carolina) and several species of snakes (Birge 1990).
Big Bayou Creek is located approximately 600 feet west of the MWSF site. These waters
are not considered to be outstanding resource waters, that is, they are not ecologically
unique nor do they support federally listed endangered or threatened species (KDEP 1990).
The fish populations within the section of Big Bayou Creek adjacent to the site is
dominated by bluegill (Lepomis macrochirus), creek chub (Semotilus atromaculatus),
stoneroller (Campostoma anomalum), and various species of sunfish (Birge 1990).
Alternative Sites. The alternative sites consist of disturbed areas covered with a
combination of grassy fields and woodlands. Wildlife found within these different habitats
has been previously described above. The Ohio River serves as a major flyway for
migratory birds (Birge 1990); therefore, migratory birds and transient residents are
occasionally at these sites.
Amphibians and reptiles are common throughout the reservation and would be present at
each of the potential sites (Birge 1990). Amphibians likely to occur at all of the sites
include American (Bufo americanus) and Woodhouse's toad (Bufo woodhousei). Reptiles
include the eastern box turtle (Terrapene carolinia) and several species of snakes (Birge
1990).
All of the potential sites contain small ephemeral ponds (i.e., less than 0.5 acres). These
ponds do not support any visible fish life. Because of the ephemeral nature of these ponds,
aquatic populations are likely to include insect larvae and amphibians.
All of the sites either border Little Bayou Creek or have tributaries on the site that feed into
the creek (Sect. 3.2.1). The waters of Little Bayou Creek are not considered outstanding
resource waters, that is, they are not ecologically unique nor do they support federally listed
endangered or threatened species (KDEP 1990). The fish populations within the creek are
numerically dominated by various species of sunfish (CH2M HILL 1991).
3.5.3 Threatened and Endangered Species
To identify the presence of threatened and endangered species at the affected sites, the
USFWS, Kentucky Department of Fish and Wildlife Resources (KDFWR), and the
Kentucky State Nature Preservation Commission (KSNPC) were consulted. Responses
from these agencies are given in Appendix B.
Federally Listed Animal Species
The bald eagle (Haliaeetus leucocephalus) and the Indiana bat (Myotis sodalis) are federally
listed endangered species that may be found in McCracken County (Barclay 1992).
Indiana bats winter in caves, but during reproductive season (normally May 15 to August
15), the bats will form colonies in mature trees with loose bark, such as shagbark hickory,
especially near water (Birge 1990). A single male individual was identified during mist
netting surveys conducted on the WKWMA near the Ohio River in June, 1991. Subsequent
mist netting surveys in similar habitats during the summer of 1992 did not capture a
representative of the species.
Bald eagles are known to nest at sites 25 to 40 miles southeast and west of PGDP and in
the Ballard County Wildlife Management Area, which is in the flight path between these
wintering areas (Birge 1990).
Commonwealth of Kentucky Listed Animal Species
Of the state-listed birds for the area; the endangered hooded merganser (Lophodytes
cucullatus), the fish crow (Corvus assifragus) and Bell's vireo (Vireo Bellii), all of which
are species of special concern (Evans 1992); only Bell's vireo has been observed in recent
years on the DOE reservation (Birge 1990). Commonwealth-listed mammals potentially
occurring in the area include the evening bat (Nycticeius humeralis) and the northern long-
eared bat (Myotis septentrionalis) (Evans 1992). None of the mammals have been observed
on the DOE reservation. The KDFWR data base lists the northern crawfish frog (Rana
areolata circulosa), a species of special concern, as occurring within the Heath quadrangle,
which contains the proposed sites (Pelren 1992).
Additional animal species noted by other investigators as occurring within the area but not
listed by the KDFWR or the KSNPC as occurring in McCracken County include the lake
chubsucker (Erimyzon sucetta), a state threatened species, and the great blue heron (Ardea
herodias), a species of special concern. The lake chubsucker has been found in Big Bayou
Creek (CH2M HILL 1991), and the great blue heron has been observed during site
reconnaissance in an KPDES outfall 001 adjacent to the MWSF site (CDM Federal 1992a)
and in other plant industrial ponds. Commonwealth listed animal species known from
McCracken county are presented in Table 3-1, however, not all of these species are known
from the vicinity of PGDP.
Commonwealth of Kentucky Listed Plant Species
Commonwealth-listed endangered and threatened plants that may occur in the area include
the endangered Carolina silverbell (Halesia carolina), and the threatened compass plant
(Silphium laciniatum). The Carolina silverbell occurs in moist or hydric areas, often
associated with floodplains or other low lying areas in which water collects (White 1992).
The compass plant occurs within open fields and sometimes along road sides (White 1992).
Commonwealth listed plant species known from McCracken County are listed in Table 3-2,
however, not all of these species are known from the vicinity of PGDP.
Commonwealth of Kentucky listed species are not afforded any special protection, but
should be monitored for location and abundance if possible.
Potential Occurrence of Threatened and Endangered Species
No commonwealth or federally listed plant species are known or are likely to occur at the
PGDP WSF site located within the PGDP security fence. Habitat at the PGDP WSF site
has been previously disturbed, is mowed on a regular basis, and is unlikely to support any
of the listed species described above.
Because of the availability of suitable habitat at the MWSF site, three Commonwealth of
Kentucky listed species may occur. The presence of wooded area along KPDES outfalls
adjacent to the MWSF site may provide habitat for the Bell's vireo; however, this species
has not been sighted near PGDP recently. The great blue heron has also been observed
near the MWSF site, in the adjacent KPDES outfall 001. The carolina silverbell may be
present due to the moist woodlands on the site. However, thorough evaluations of this area
have not identified this species.
Shagbark hickories and elms, known to occur in the wooded area, may provide
approximately one to two acres of suitable habitat for the federally listed Indiana bat
(Bryan, Appendix B). Given the close proximity to industrial operations, it is unlikely that
Indiana bats would select this area for colonization, especially when other more suitable
areas (i.e., more secluded and mature woodlands) are readily available in the vicinity. A
Biological Assessment was prepared for the proposed location and submitted to the USFWS
for a Biological Opinion according to the Endangered Species Act. The USFWS concurred
that removal of this potential habitat would have minimal impact on the species due to the
presence of significant amounts of similar, and in some cases, more suitable habitat
(Appendix B).
TABLE 3-1
Commonwealth of Kentucky
Threatened, Endangered, and "Special Concern" Animal Species
Known from McCracken County, Kentucky
____________________________________________________________________________
Threatened Species
____________________________________________________________________________
Erimyzon sucetta Lake Chubsucker
Hyla avivoca Bird Voiced Treefrog
Lepomis punctatus Spotted Sunfish
Macroclemys temminckii Alligator Snapping Turtle
Notropis maculatus Taillight Shiner
Nycticeius humeralis Evening Bat
____________________________________________________________________________
Endangered Species
____________________________________________________________________________
Acipenser fulvescens Lake Sturgeon
Hialaeetus leucocephalus* Bald Eagle
Hybognathus hayi Cypress Minnow
Lampsilis abrupta* Pink Mucket (mussel)
Lepisosteus spatula Alligator Gar
Lophodytes cucullatus Hooded Merganser
Myotis sodalis* Indiana Bat
Orconectes lancifer Crayfish
Plethobasus cooperianus* Orange Foot Pimpleback (mussel)
______________________________________________________________________________
"Special Concern" Species
______________________________________________________________________________
Ardea herodias Great Blue Heron
Corvus ossifragus Fish Crow
Esox niger Chain Pickerel
Hyla cinerea Green Tree Frog
Ichthyomyzon castaneus Chestnut Lamprey
Ictiopis niger Black Buffalo (fish)
Lota lota Burbot (Fresh Water Cod)
Myotis septentrionalis Northern Long-ear Bat
Nerodia erythrogaster Copperbelly Water Snake
Notropis venustus Blacktail Shiner
Noturus stigmosus Northern Madtom (fish)
Rana areolata Northern Crawfish Frog
Riparia riparia Bank Swallow
Vireo bellii Bell's Vireo (bird)
_______________________________________________________________________________
* Also federally listed endangered species
TABLE 3-2
Commonwealth of Kentucky
Threatened, Endangered, and "Special Concern" Plant Species
Known from McCracken County, Kentucky
_______________________________________________________________________________
Threatened Species
_______________________________________________________________________________
Halesia carolina Carolina Silverbell
Rudbeckia subtomentosa Sweet Coneflower
Silphium laciniatum Compass Plant
_______________________________________________________________________________
Endangered Species
_______________________________________________________________________________
Hypericum adpressum Creeping St. John's-wort
Prenanthes aspera Rough Rattlesnake-root
_______________________________________________________________________________
"Special Concern" Species
_______________________________________________________________________________
Baptisia leucophaea Cream Wild Indigo
Carex triangularis Fox Sedge
Carya aquatica Water Hickory
Heterotheca latifolia Broad-leaf Golden Aster
Lathyrus palustris Vetchling Peavine
Malus angustifolia Southern Crabapple
Muhlenbergia glabriflora Hair Grass
Solidago buckleyi Buckley's Goldenrod
_______________________________________________________________________________
Habitat for the Bachmans sparrow (Aimophila aestivalis), a federal candidate species,
includes pasture, old field habitat, short shrub or fence row ecotones, or previously
disturbed grassland areas. Such habitat does exist in the vicinity. No formal information
related to sightings of this species in the vicinity of the MWSF is available; however, this
species is not afforded any special protection and Section 7 requirements of the Endangered
Species Act do not apply.
Alternate Site 1. This site has a small intermittent stream on the northeastern end of the
site, with sparse woodlands surrounding it. This area may serve as potential vireo habitat;
however, it is unlikely because of the limited amount of woodlands surrounding the stream,
especially given that more suitable habitats are easily found within the area of PGDP.
Compass plants may be found in the fields that dominate this site. Carolina silverbells may
be found within the area of the stream and the intermittent wet area.
Alternate Site 2. Because of the availability of suitable habitat at this alternate site, three
listed species may potentially occur. The presence of a wooded area along Little Bayou
Creek may provide habitat for the Bell's vireo. Shagbark hickories, known to occur in the
wooded area, may provide suitable habitat for the Indiana bat. The compass plant may
occur within the open fields. Carolina silverbell may be found within the area of the Little
Bayou Creek and the intermittent wet area.
Alternate Site 3. Three listed species of animals may be present at this alternative site.
The presence of woodlands along Little Bayou Creek along the northwestern boundary of
the site may serve as Bell's vireo habitat. The three ponds present on the site may serve as
habitat for the northern crawfish frog and the green treefrog. The compass plant may occur
within the open fields. Carolina silverbell may be found within the area of Little Bayou
Creek and the intermittent wet areas.
3.6 LAND USE
PGDP is on a 3,423-acre site owned by DOE. The main plant facilities (with the exception
of the C-746-K landfill, the C-611 water treatment plant, and a few other sites) lie within a
fenced security area of 748 acres. DOE maintains a buffer zone of approximately 585 acres
surrounding the security area, which is used for support services including the wastewater
treatment plant, lagoons for process wastewater, and residential and inert landfills. The
remaining 2,324 acres are deeded or leased to the Commonwealth of Kentucky for the
purposes of wildlife management. The KDFWR manages this area for the purpose of
establishing or maintaining viable wildlife habitat. The property within the buffer zone is
not deeded or leased to the Commonwealth of Kentucky but solely managed by KDFWR
with the permission of DOE. DOE maintains the right to assume possession of any
property within the buffer zone immediately if deemed necessary. There are no local or
county comprehensive land-use plans in this area. Figure 3-7 illustrates the current land
ownership in the vicinity of PGDP. Both of the preferred locations proposed for
development are on property owned by DOE and are not available for recreational use or
public access.
Alternate Site 1. The site currently consists of 90% managed open grassland. The area is
part of Tract 7A of the WKWMA and is open to the public for deer and small game
hunting, field trials, and as a training area for hunting dogs. This area is extensively
managed for native prairie grasses by the WKWMA.
Alternate Site 2. This site currently consists of 50% open grassland and 50% mixed
hardwood forest and is owned by DOE and managed by the WKWMA. This area, even
though owned by DOE, is used extensively by the public for dog trials (competitions).
Alternate Site 3. The land is currently leased by the Commonwealth of Kentucky as part of
the WKWMA. Bowhunting for deer, small game hunting, field trials, and dog training are
permitted in the area. Alternative Site 3 currently consists of 60% managed grassland and
40% mixed hardwood forest, which may provide habitat for the Indiana bat. This site is
also extensively managed for native prairie grasses by the WKWMA.
3.7 CULTURAL RESOURCES
The site of the proposed PGDP WSFs is located inside the security fence at the PGDP and
was disturbed during the construction of the plant, therefore there are no intact cultural
resources present on the site. The buildings within PGDP are less than 50 years old, and
therefore are not eligible for listing on the National Register of Historic Places (NRHP).
The site of the proposed MWSF lies on 20 acres just outside the existing security fence on
the northwest corner of the plant. This area has a railroad spur transecting it, a fence and
road along the eastern border, and a road running diagonally along the western border. The
disturbance of the area due to these construction events suggest that no intact cultural
resources remain that could be eligible for the National Register of Historic Places. A
walkover survey of the MWSF site by an archaeologist and a member of the Kentucky
Heritage Council (KHC) confirmed that there would be no effect on any property listed in
or eligible for listing in the National Register of Historic Places (Granger 1992). A letter
from the State Historic Preservation Officer (SHPO) confirming the above conclusions is
provided in Appendix B.
Alternate Site 1. Consultations with the KHC indicate that no historic structures or
prehistoric artifacts have been recorded for this site. This area has a low potential for
archaeological sites because the disturbance of the area (i.e., construction activities,
maintenance of power lines, etc.) would have significantly altered any sites that may have
been of archaeological significance.
Figure 3-7 Current Land Ownership Map for PGDP (Not available in electronic format)
Alternate Site 2. The KHC indicates that no historic structures or prehistoric artifacts have
been recorded in this area. Based on a preliminary archaeological review by ARCS, Inc., a
moderate potential exists for archaeological resources to be present at this site. Further
survey efforts would be required before any site development (Appendix B).
Alternate Site 3. According to the KHC, no historic structures or prehistoric artifacts have
been recorded from this area in the past. Again, based on a preliminary archaeological
review by ARCS, Inc., the potential for any archaeological resources to be present at this
site is very low (Appendix B).
3.8 SOCIAL AND ECONOMIC CONDITIONS
3.8.1 Demography
The location of PGDP in relation to surrounding communities in McCracken and Ballard
counties, Kentucky and Massac County, Illinois, across the Ohio River is shown in
Figure 1-1. The small communities of Grahamville, Heath, and Kevil are within 3 miles of
the DOE property boundary, and the municipalities of Paducah and La Center, Kentucky
and Joppa and Metropolis, Illinois, are within a 10- to 20-mile radius of the site.
The 1990 census population for McCracken County was 62,879 persons with 27,256
persons residing in Paducah. Ballard County reported a population of approximately 7,920
persons; La Center's population was 1042; and 337 persons live in Kevil. Massac County,
Illinois, reported 14,752 persons, with 6,734 living in Metropolis and 492 living in Joppa.
Total population within a 50-mile radius of the plant is approximately 500,000 with
approximately 66,000 people residing within 10 miles of PGDP (U.S. Department of the
Interior, 1990).
3.8.2 Economic Activities
The total labor force for McCracken County in July 1991 was recorded at
(Slater and Hall 1992). Total employment was recorded at 27,063 persons and 1,621
persons registered as unemployed (Slater and Hall 1992). Unemployment in the county
was 5.7% at that time as compared to 6.7% for the Commonwealth of Kentucky and 7.7%
for the United States as a whole (Hayghe 1992). Construction and retail sales account for
almost 50% of all employment (24% and 23%, respectively). Fifteen percent of
employment is concentrated in manufacturing and 13% in mining (Dunning 1992). PGDP
employs approximately 1,800 workers, and the TVA Shawnee Steam Plant employs 500
workers. The average 1992 per capita income in McCracken County was $17,450 as
compared with an average income of $14,992 per capita in Kentucky and an average
income of $18,692 in the entire United States.
3.9 TRANSPORTATION
Interstate I-24 passes through Paducah, Kentucky, and approximately 10 miles east of
PGDP. Four federal highways (U.S. 45, 60, 62, and 68) and many state highways
transverse the area. Main access to the plant is via US Highway 60. Because PGDP is
located in a secured area, traffic is minimal within the plant and the surrounding area and is
generally limited to government or construction vehicles traveling into or out of two
secured gates. Vehicles are screened by security before entering the security or fenced area
of the plant. Traffic within the plant is generally limited to trucks and service vehicles that
must move equipment and supplies within the facility. Employees generally park their cars
within designated parking areas outside the plant facilities and walk to their respective
workplaces.
4.0 ENVIRONMENTAL IMPACTS
The environmental impacts associated with the proposed action and alternatives are
discussed in this section. The potential health and safety impacts from routine operation are
discussed, followed by a comparison of the alternative actions that include no action,
shipment of waste off-site, and upgrading and utilizing existing buildings or areas as WSFs.
Cumulative effects of the proposed action and PGDP operations are summarized.
Unavoidable adverse effects and irreversible and irretrievable commitment of resources are
discussed.
4.1 IMPACTS FROM THE PROPOSED ACTION: CONSTRUCT AND
OPERATE NEW PGDP WSFs
The environmental impacts related to geology; hydrology; soils; air quality; noise;
biological resources; land use; cultural resources; social and economic conditions; and
health and safety are addressed. For the purposes of this ea, potential impacts to each
resource will be addressed separately for construction and operation of the facilities, if the
potential impacts for construction and operation are significantly different.
4.1.1 Geology
There are no geologic resources that would be impacted at the sites of the PGDP WSFs or
the MWSF. The waste storage facilities are designed to withstand a 1000-year seismic
event. The potential for release during a seismic event is currently being analyzed under
the final safety analysis report for PGDP.
4.1.2 Hydrology
4.1.2.1 Surface Water
Construction. The PGDP WSFs are located near KPDES outfalls 001 and 003. There is a
potential for a temporary increase of silt in the surface runoff during construction activities;
however, the site is level and the drainage ditches are located on the opposite sides of
roadways. Best Management Practices (BMPs) such as silt fences would be used to
minimize possible siltation. Given the topography of the site, the physical barriers present,
and the use of BMPs, it is unlikely that construction activities at this site would impact
surface waters.
The MWSF site is located between two KPDES outfalls (001 and 015), which feed into Big
Bayou Creek. This site is level, and BMPs would be used to control siltation. Given the
relative distance of the site to the outfall ditches, there may be a temporary increase in
siltation; however, given the level topography of the site and the use of BMPs, siltation
entering the creek is expected to be minimal.
Operation. An increase in the volume of surface runoff may result after construction
activities are completed because much of the area once covered with vegetation would be
covered with concrete and asphalt. A large portion of the runoff from both the PGDP
WSFs and the MWSF would either be captured by the storm water collection system or
would enter the KPDES outfalls directly. Engineering controls such as spill containment
dikes and floor sealants have been included in the design of the PGDP WSF and MWSF to
minimize potential release of chemicals from the facilities. Given that the buildings are
designed to contain any accidental chemical spills, and the PGDP Spill Prevention, Control,
Countermeasures, and Contingency Plan for Oils, Chemicals, and Hazardous Wastes (Bell
1991), which specifies procedures for the rapid and efficient handling of chemical spills, it
is unlikely that wastes accidentally spilled will migrate into surface waters.
4.1.2.2 Groundwater
Construction. Groundwater would not be affected during construction or operation of the
facilities. The construction plans for neither the PGDP WSFs nor the MWSF include deep
excavation which would result in the removal of soils down into the water table; therefore,
no impacts to groundwater are expected as a result of construction activities.
Operation. Engineering controls such as dikes, floor sealants, and spill containment have
been included in the design of the PGDP WSFs to minimize potential impact on the
environment from accidents, spills, and fires which may occur within the facilities. PGDP
has protocols for rapid and efficient CLEAN-up of spills (Bell, 1991), and these protocols
should ensure that chemical spills would be remediated before any hazardous constituents
could migrate into the groundwater.
4.1.2.3 Floodplains
The WSFs would be built at base elevations of at least 370 feet above MSL. Therefore, no
100-year or 500-year floodplains would be affected by the proposed action.
4.1.2.4 Wetlands
No wetlands exist on the PGDP WSFs site. Two small (<0.5 acre total area), isolated, non-
headwaters wetlands are located on the MWSF site. Construction of the MWSF would
result in the loss of approximately 0.5 acre of jurisdictional wetland as identified by the
COE (Appendix A). A wetlands assessment has been conducted (Appendix A) which
indicates that the effects of the loss of 0.5 acres of wetlands would be minimal based on the
availability of similar habitat in the vicinity. Additionally, a Nationwide Permit has been
received from the COE.
4.1.3 Soils
Construction. The proposed sites of the WSFs are located in areas that have been
previously disturbed by activities associated with the construction and operation of the
PGDP and former KOW. The topography of the sites is relatively flat, which would
minimize the amount of grading required to level the sites in preparation for building.
Construction of the facilities may increase the potential for localized soil erosion due to the
removal of existing vegetation and subsequent excavation and grading of the construction
site. Runoff from precipitation and wind are the two mechanisms by which soil erosion
may take place. Implementation of construction management techniques (i.e., BMPs such
as silt fences, vegetative controls such as a green belt, surface wetting, etc.), would
minimize the amount of soil erosion anticipated from wind and runoff.
Impacts to surface soils would be limited primarily to reworking of surface soils and, to a
lesser extent, subsurface soils in areas where excavation for utilities are needed. Excavated
soil would be used for site leveling and no soils would be removed from the sites. Impacts
to soils would be localized and short-term.
Operation. The three WSFs would cover approximately 8 acres of soils (PGDP WSFs - 2
acres, MWSF - 6 acres) with structures and pavement. Long-term erosional impacts due to
increased runoff from impervious surfaces, such as parking lots, paved access roads, and
roof drainage are not anticipated because the sites will be landscaped and exposed soils
would be covered with vegetation. The storm water collection system and reclamation of
disturbed surface areas would minimize this impact. Information received from the SCS
indicates that no prime farmland exists at either of the sites (Appendix B).
4.1.4 Air Quality and Noise
Construction. Construction activities would temporarily increase fugitive emissions in the
vicinity of the proposed waste storage sites. In addition, smoke, carbon monoxide, and
other pollutants discharged as exhaust from combustion-powered heavy equipment would
result in a temporary degradation of the site air quality. Techniques such as wetting the
ground surface would minimize much of the impact from fugitive particulate matter. There
would be a short-term increase in noise levels in the immediate vicinity of the sites due to
construction activities.
Operation. Operation of the facilities should not require air quality permits because there
would be no emissions from the facility under normal operating conditions. There would
be no long-term increase in noise levels due to operation of the facilities.
4.1.5 Biological Resources
The construction of the PGDP WSFs would result in the initial loss of 3 acres of habitat
(i.e. mowed, grassy area within an industrial complex). Once construction is completed, an
acre of land would be seeded and converted back into a lawn.
The construction of the MWSF would result in the long term removal of up to
approximately 10 acres of woodlands and 5 acres of grassy fields. These habitats are not
unique to the area. Once construction is completed, 4 acres of the land would be seeded
and maintained as a grassy field, similar to the grass habitat which is presently found at the
site. Given that the WKWMA consists of 4,157 acres of land and that an additional 2,323
acres of adjacent DOE property is managed by the KDFWR, the construction of the MWSF
represents the loss of less than 0.1% of the local acreage managed for wildlife habitat.
Migratory and wetland birds, such as the great blue heron, may occasionally visit the
MWSF site because of the waterways present near the site (i.e., Big Bayou Creek and the
drainage ditches). The increased presence of human activity associated with the
construction and operation of the facility is likely to limit the number of visits these birds
make to the site (Battelle 1982). Given the extensive habitat found along the Ohio River
and within the WKWMA, construction of the proposed WSFs is not expected to have an
impact upon these species.
Threatened and Endangered Species
The habitat at the PGDP WSF site has been previously disturbed, is mowed on a regular
basis, and does not support any state or federally listed species.
Approximately 2 acres of mixed woodlands containing shagbark hickory (Bryan, 1993
[Appendix B]), which is considered potential habitat for the Indiana bat, would be lost by
construction of the MWSF. A Biological Assessment was prepared for the proposed
location and submitted to the USFWS for a Biological Opinion according to the
Endangered Species Act. The USFWS concurred that removal of this potential habitat
would have minimal impact on the species due to the presence of significant amounts of
similar, and in some cases more suitable, habitat (Appendix B). Additionally, land clearing
activities conducted outside of the known maternity season would prevent the loss of any
member of the species that may be inhabiting the area.
Impacts to the lake chubsucker, a state-listed threatened species found in Big Bayou Creek,
are not anticipated if all construction BMPs, such as silt fences and vegetative controls, are
properly instituted and maintained. Overall impacts to surface water from facility
operations are expected to be minimal and should not affect the ecology of Big or Little
Bayou Creeks. The Northern Crawfish Frog and Carolina Silverbell, both state of
Kentucky species of special concern, have not been identified in the area proposed for
construction.
Bachmans sparrow, a federal candidate species, has not been observed in the area even
though suitable habitat exists. Impacts to this species are unlikely due to an abundance of
suitable habitat in the area.
Should any state or federal listed or candidate species be identified in the vicinity, all work
would immediately cease and consultation with the appropriate agency would be initiated to
determine appropriate mitigative measures.
4.1.6 Land Use
The land used for construction and operation of the PGDP WSFs would not be available for
any other use. No property transfer would be required because the property is owned by
DOE and is within the fenced security area.
The MWSF site is not presently in use for either PGDP operations or recreational purposes
for the general public. Development of the site as an industrial facility is consistent with
adjacent site development, operations, management practices, and agreements for the DOE-
owned buffer zone. The loss of this acreage is not expected to have a significant impact on
the availability of land because an abundance of similar land is available near the site.
4.1.7 Cultural Resources
Information provided by the SHPO indicates that no cultural or archeological resources are
present within the construction areas of the WSFs or MWSF (Morgan 1992). A letter to
this effect is included in Appendix B.
4.1.8 Social and Economic Conditions
Construction. The proposed action would be expected to have a positive short-term impact
on the local economy because the WSFs would probably be constructed by a local firm,
creating a short-term increase in the construction work force.
Operation. The proposed action would not be expected to result in any permanent increase
in local employment as existing PGDP personnel would operate the WSFs. In the event of
a spill, trained PGDP personnel would be used to isolate and remediate any such incident in
accordance with the procedures listed in the Spill Prevention, Control, Countermeasures,
and Contingency Plan for Oils, Chemicals, and Hazardous Waste (Bell 1991).
4.1.9 Transportation
Construction. Construction at the sites of the WSFs would be expected to create a small
increase in traffic flow within the facility, primarily from movement of construction
materials. Minor disturbances in traffic flow may result from the need to locate or park
equipment and vehicles on the road adjacent to the site. No road closures are expecting to
result from construction activity.
Operation. Operation of the WSFs would be expected to result in a slight increase in
traffic in the areas of the facilities. However, this increased traffic is not expected to
disrupt the normal flow of traffic within PGDP.
4.1.10 Health and Safety
In this section, the potential effects from operation of the WSFs on workers and the public
are qualitatively addressed. A qualitative discussion is being presented in the absence of
quantitative information on waste streams and source terms (per DOE memorandum from
E. Baynard dated June 10, 1988). According to Walker (1991) and PGDP (1992), the
waste types accepted into the WSFs are shown in Table 4-1.
Because of the low levels of radioactivity allowed in wastes received, the storage areas
would not be considered a "special facility" or a "nuclear facility" as defined in DOE Order
6430.1A. In addition, the facilities would not be considered a "critical facility" as defined
in Energy Systems engineering procedure EP-E-09. This would eliminate the need for any
special safety or environmental protection systems. A Facility Safety Screening completed
for the PGDP WSFs concluded that no DOE Order 5481.1B-type hazards exist, and that no
further safety documentation is required (Walker 1991).
TABLE 4-1: ACCEPTED WASTE TYPES
______________________________________________________________________________
Waste MWSF PGDP WSFs
______________________________________________________________________________
Chemicals PCB laden, PCB laden,
RCRA characteristic RCRA characteristic
______________________________________________________________________________
Radionuclides Uranium, <1% U-235 or Uranium, <1% U-235 or
0.0875 Kg/container 0.0875 Kg/container
_________________________________________________
TRU, <100 nCi/g TRU, <100 nCi/g
(soils matrix) (soils matrix)
_________________________________________________
Technetium-99, <3 Ci/m3 Technetium-99, <3 Ci/m3
(aqueous) (aqueous)
______________________________________________________________________________
No Facility Safety Screening for the MWSF has been completed; therefore, DOE Order
5481.1B may apply (PGDP 1992). The design, construction, and operation of these
facilities would comply with all applicable Energy Systems standards and procedures, state
and federal regulations and codes, and DOE Orders (Walker 1991; PGDP 1992). There
would be no routine releases of hazardous materials from either the PGDP WSFs or
MWSF. Institutional controls (e.g., strict waste acceptance criteria, limits on drum stacking,
use of DOT-approved containers for storage) and engineering controls (e.g., secondary
containment, fire alarms, and suppression system, HEPA filters, portable ventilation control
systems, segregation of highly hazardous materials) are designed to prevent accidental
releases. In addition, dikes constructed within the facilities would be designed to contain
all fire water released during a design basis fire (Lockwood Greene 1991).
Effects from Routine Operations. The PGDP WSFs and MWSF would primarily be
waste storage facilities. The MWSF would have some limited repackaging capabilities. No
gaseous radionuclides would be accepted for storage in the PGDP WSFs or the MWSF.
The primary hazards to workers in the facilities would be: (1) potential inhalation of
radioactive particles during repackaging, (2) exposure to gamma radiation emanating from
packages, and (3) exposure to RCRA-listed wastes in the PGDP WSFs or MWSF (e.g.,
inhalation of volatiles). For normal operations, facility worker exposures to radiation would
be controlled via existing dosimetry controls, contamination control procedures, and
compliance with Standard Operating Procedures (SOPs) to less than the DOE administrative
control level of 2 rem/year (DOE 1988). Historically, average worker exposure has been
less than 0.1 rem/year. Worker exposures to chemicals, noise, and other non-radiological
materials would be controlled to below threshold limit value/time-weighted average levels
established by institutional and administrative controls (PGDP, OSHA, DOE Orders).
The WSFs will store only those wastes for which it is designed, and only in areas
compatible with the wastes to be stored. Operation of the WSFs would result in a single
pathway for exposure to occupational personnel: direct radiation. Operational procedures
limit the direct radiation dose rate at the surface of each container to 0.9 mrem/h. This
classification limits annual doses to occupational personnel engaged in waste management,
other personnel on-site, and members of the public. The hazardous waste component of
individual operations at the proposed facilities would not pose a threat because the
quantities would be sufficiently small, and any health hazards would be overshadowed by
radiological concerns.
Measures taken to control radiological hazards would also protect workers from the small
amounts of hazardous constituents in the mixed waste. In 1992, the cumulative annual skin
dose to 39 waste operations workers was 496 person-mrem (4.96 person-mSv). Waste
workers received an average skin dose of 12.7 mrem (0.13 mSv), and the maximum
recorded was 140 mrem (1.4 mSv), considerably less than the DOE administrative control
level of 2 rem/year. The penetrating dose to the workers was 33 person-mrem (0.33
person-mSv), with an average penetrating dose of 0.8 mrem (0.008 mSv) per person
(Osburn 1993). Radiation exposures are not anticipated to exceed these levels from
person-rem, workers engaged in this proposed project would not be expected to incur anyr
harmful effects from radiation exposures they receive during normal operations. Direct
radiation dose to the public from normal operations would be negligible.
Effects from Accidents. Additional hazards to workers include possible
handling and common industrial operations. Transfer of containers represents the greatest
potential for accidents. No accidents are currently on record at PGDP resulting directly
from waste management or handling activities. SOPs would be prepared and approved
before the facilities become operational and strictly followed to ensure compliance with
health and safety requirements and procedures. Facility construction and operations are
designed with safety in mind (see Section 2.2). The PGDP Safety Analysis Department has
determined that no DOE Order 5481.1B type safety hazards exist for this project (Energy
Systems 1992). A facility risk analysis/safety assessment will be prepared for the MWSF,
but is not available at this time. Training programs would be instituted to ensure workers'
awareness of these requirements and procedures.
Standard construction practices involve some degree of hazards around the job site.
However, with DOE's high emphasis on safety, procedures, and oversight activities, this
type of risk will be kept to a minimum. Application of established standard procedures and
enforcement of health and safety, as well as environmental regulations in all project
activities, will assure minimum exposure to the normal risks associated with the types of
work involved in this project.
The new facilities may actually decrease the potential for accidents or
since the wastes would be stored in facilities designed for ease of storage and inspections,
resulting in less time spent during inspection and handling procedures.
Closure. Closure of the WSFs at the time of site decontamination and decommissioning is
not expected to contribute to any environmental degradation. The facilities are designed for
ease of decontamination and would support site-wide efforts.
Potential Radiation Dose to the Public. Table 4-2, below, summarizes the current annual
dose from radiological contaminants that could potentially be received by a member of the
public living near PGDP, assuming the worst-case exposure from all major pathways. The
calculated maximum combined dose is 6.2 mrem/year. The DOE annual dose limit for the
public is 100 mrem/year. With institutional and engineering controls in place, operation of
the PGDP WSFs should not generate any release above existing plant emissions.
TABLE 4-2
SUMMARY OF ANNUAL DOSE FROM RADIOLOGICAL CONTAMINANTS
Worst-Case Combined Exposure Pathways
____________________________________________________________________________
Pathway Dose (mrem/year) Percent of Total
____________________________________________________________________________
Ingestion of groundwater 0.024 0.4
Ingestion of sediments 0.65 10.5
Ingestion of food crops 1.15 18.5
Ingestion of deer meat 0.22 3.5
Direct external gamma-
Little Bayou Creek 4.15 67.0
Atmospheric releases 0.00018 <0.1
Total annual dose all pathways 6.20 100.0
____________________________________________________________________________
(Note: 1000 mrem = 1 rem)
Source: Martin Marietta Energy Systems, Inc. 1991. Paducah Gaseous Diffusion Plant
Environmental Report for 1990, pp. 87-91.
4.1.11 Cumulative Impacts
Cumulative impacts are the effects of the proposed action considered in
connected, cumulative and similar actions. Activities at PGDP potentially coinciding with
the proposed action are the construction of a solid waste landfill and expansion of the
PGDP process tails cylinders storage yards (Figure 4-1). Each of these proposed activities
are also addressed in separate eas. The potential cumulative effects of the proposed action
in conjunction with these other activities follows.
Surface Water and Groundwater. The BMPs used during construction of th
would minimize impacts upon surrounding surface waters. The presence of additional
buildings and pavement covering the soils will increase surface runoff through permitted
outfalls from the areas of the WSFs. All stormwater from construction of the solid waste
landfill would also be directed through a permitted outfall and all BMPs would be
applicable to this project. Operational stormwater runoff would be directed through a
sedimentation basin prior to release to the outfall in accordance with the Best Management
Practices Plan for the Control of Suspended Solids (Energy Systems 1991). Minimal
runoff is expected from construction of the cylinder yards. Overall impacts to surface water
are expected to be minimal and should not affect the ecology of Big or Little Bayou creeks.
Groundwater would not be impacted by any of the WSFs or the cylinder yard project. The
solid waste landfill is also expected to have minimal impacts to groundwater due to the dual
liner required by Commonwealth of Kentucky regulations.
Wetlands and Floodplains. Construction in the area of the WSFs, the solid waste landfill,
or the cylinder yards would not impact wetlands. There are approximately 0.5 acres of
isolated, non-headwaters wetlands in the area of the 20-acre site, and construction on this
site would result in filling of the described wetlands. There would be no impacts to
floodplains from any of the proposed projects.
Soils. At most, a total of approximately 80 acres, which is approximately 3% of available
DOE acreage, would ultimately be disturbed by construction of all the proposed projects:
25 acres for the WSFs, 40 acres for the solid waste landfill, and approximately 15 acres for
the cylinder yard expansion project. Approximately 7 acres of prime farmland would be
disturbed by the proposed actions as a result of construction of the proposed solid waste
landfill. This acreage represents approximately 0.007% of the available prime farmland in
the region. The overall impacts to soils in the area by the proposed projects is expected to
be minimal.
Figure 4-1 Location Plan for Proposed Actions at PGDP (Not available in electronic format)
Air Quality and Noise. There would be no long-term increase in air emissions due to
construction or operation of the WSFs or from other proposed activities. Impacts to air
quality would be temporary and result from fugitive emissions (dirt) from construction
activities and equipment exhaust emissions.
Any increase in noise levels would be due to construction activities and would terminate
upon completion of construction. Local traffic would increase, but the noise generated
would be equivalent to normal plant operations occurring immediately adjacent to this site.
Biological Resources. Construction of all of the WSFs would result in the long-term loss
of approximately 20 acres of wildlife habitat, while the solid waste landfill would ultimately
affect an additional 40 acres of farmland and wildlife habitat. This represents a loss of
approximately 0.6% of the local acreage managed for wildlife habitat.
Operation of all of the WSFs and the landfill would result in increased human activity at
the 60-acre areas. The human activity would discourage wildlife that may visit the area.
However, given the extensive surrounding habitat available in the area (approximately 7,000
acres), removal of 60-acres is not expected to have an impact upon wildlife found in the
region.
Approximately 2 acres of mixed hardwoods containing shagbark hickory, which is
considered potential habitat for the Indiana bat, would be lost by construction of the WSFs.
Significant acreage of denser woodlands that may provide more suitable habitat for the
Indiana bat is available in the immediate vicinity. Scheduling land clearing activities
around the maternity season would prevent the accidental loss of individuals of the species.
No potential Indiana bat habitat would be disturbed by the other proposed actions.
Land Use. The proposed actions would utilize land owned by DOE, which has been
reserved for industrial use by PGDP. Therefore, there will be no impacts to land use.
Cultural Resources. There would be no impacts to cultural resources (i.e., buildings on
the NRHP or archeological significant sites) from either construction of the PGDP WSFs or
from construction of the cylinder yards. An archaeological investigation is scheduled for
the proposed landfill site; however, no cultural resources are expected to be found at this
location.
Social and Economic Conditions. The increased construction activity at the sites would
result in a temporary increase in the number of individuals working within the construction
industry. There would be no long-term impact upon employment. In the event of a spill,
trained PGDP personnel would be used to isolate and remediate any release.
4.2 IMPACTS FROM NO ACTION ALTERNATIVE
4.2.1 Geology and Soils
No impacts to geology or soils should result from the no action alternative.
4.2.2 Hydrology
No additional impacts to groundwater or surface water would result from this alternative
unless the wastes were stored in a non-compliant facility, which would increase the
potential for waste to escape into the environment from a spill or other accident. Chemicals
which escape into the environment may either leach into groundwater or may enter nearby
surface waters. Activities currently in progress to characterize and remediate groundwater
and surface water contamination from past plant activities would continue (Energy Systems
1992).
4.2.3 Air Quality and Noise
There would be no increased impact to air quality or noise under the no action alternative.
4.2.4 Biological Resources
There would be no increased impact to biological resources. If the waste is not stored in an
appropriate manner, there is an increased potential for release of chemicals into the
environment. This would result in the potential exposure of environmental receptors.
4.2.5 Land Use and Cultural Resources
There would be no impacts to land use or cultural resources should this alternative be
implemented.
4.2.6 Social and Economic Conditions
The no action alternative would not increase temporary construction employment nor would
it increase long-term employment opportunities at PGDP.
4.2.7 Human Health and Safety
Human health and safety would be placed at an increased potential risk if wastes are stored
in a non-compliant manner.
4.3 ALTERNATE LOCATIONS
Although all locations investigated are available for development, potential impacts to these
areas would be greater than those at the preferred locations. These areas, especially
alternate locations 1 and 3, have been intensively managed by the WKWMA and exhibit
either extensive native prairie grass vegetative characteristics or a good potential for prairie
grass regrowth via management. Alternate location 2 not only exhibits potential for prairie
grass regrowth, but is used extensively by the general public for field dog trials
(competitions), and development of this area for a landfill would disrupt nationally
recognized competitions. Alternate site 3 also has one field trial course (Logsdon,
Appendix B) and consists of approximately 40% woodlands, which may provide habitat for
the Indiana bat, a federally listed endangered species. The alternate sites also contain more
acreage of potential wetland than the preferred location. Finally, traffic patterns to the
alternate sites would require additional transportation of wastes to the east of the plant.
5.0 PERMITS AND REGULATORY REQUIREMENTS
DOE policy requires all of its operations to comply with all existing applicable federal,
state, and local laws and regulations, and DOE Orders. This section discusses the major
regulatory permit programs that would be applicable to the proposed action.
5.1 RCRA AND TSCA
RCRA (Subtitle C, Sect 3004) defines the requirements for operators of RCRA waste
storage facilities. A RCRA Part B permit would be required for operation of the WSFs.
TSCA [40 CFR 761.65(b)(1)(i to v)] designates required designs for the storage of wastes
containing PCBs. All storage areas within either facility will be designed to TSCA
standards, which are more stringent than RCRA requirements for secondary containment.
DOE Order 5820.2A, Radioactive Waste Management, designates building and storage
design requirements for facilities handling or storing LLW. These regulations establish
standards and design requirements for facilities which handle or store RCRA, PCB-
containing, and LLW, respectively. The design and construction of all the WSFs would
follow the most stringent of the design requirements specified in RCRA and TSCA
regulations and DOE Orders.
5.2 CLEAN AIR ACT
The CLEAN Air Act requirements have been adopted and are administered by the Kentucky
Division for Air Quality. Air emissions during construction and operation of the storage
facilities are expected to be limited to fugitive emissions, which are not regulated under the
National Emission Standards for Hazardous Air Pollutants. Regulation 401 KAR 63:010,
Section 3(1), "Fugitive Emissions," pertains to air contaminants emitted into the open air
other than from a stack or air pollution control equipment exhaust. This regulation
establishes standards and requirements to take reasonable precautions to prevent particulate
matter from becoming airborne. Section 4(3) of the same regulation states that the
provision of Sect. 3(1) shall not be applicable to temporary blasting or construction
operations. Additional guidance is found in Chapter 11, "Miscellaneous Sources," of EPA
publication AP-42, which establishes recommended controls and emission factors to
estimate particulate emissions during construction and for the use of paved and unpaved
roads. Emissions from the facilities would be limited to fugitive particulates and are
expected to be negligible (i.e., below visible concentrations). Fugitive emissions regulations
prohibit the "discharge of visible fugitive dust emissions beyond the lot line of the property
on which the emissions originate [401 KAR 63:010, Section 3(2)].
5.3 CLEAN WATER ACT
The Commonwealth of Kentucky is a delegated state under the CLEAN Water Act (CWA)
and has a general storm water permit program. Construction operations at the site would
require that a Notice of Intent be submitted to the state at least 48 hours before construction
operations begin. A stormwater permit is not required since any discharge would be
through an existing permitted KPDES outfall. An erosion control plan, Best Management
Practices Plan for the Control of Suspended Solids (Energy Systems 1991), was prepared;
however, this is not to be submitted to the state. Storm water and sewer discharges would
be tied into the current systems. The current KPDES permits would be modified to account
for the increased input into the sewer systems from the additional facilities.
5.3.1 CWA - Section 404 (Dredge and Fill Permitting)
Section 404 of the CWA requires permitting for activities which involve dredging or filling
wetlands. A small (i.e., less than one acre) jurisdictional wetland has been identified at the
proposed MWSF site. Under the Nationwide Permit Program (33 CFR 330) Appendix A,
Section B.26, discharges which result in filling less than one acre of isolated wetlands (i.e.,
wetlands which are the result of ponding within an area and not connecting with another
major water system) do not require formal notification to the District Engineer, Corps of
Engineers, if all nationwide permit conditions are met. A Notice of Intent has been filed
concerning the possible filling of a jurisdictional wetland. A permit may be needed before
construction of the MWSF can begin.
5.3.2 CWA - Part 112 (Oil Pollution Prevention)
Part 112 of the CWA (Oil Pollution Prevention) establishes procedures, methods, and
equipment requirements to prevent the discharge of oil from non-transportation-related
facilities into or upon navigable waters. This regulation requires that any facility which
stores oil or oil products have a Spill Prevention Control and Countermeasures (SPCC)
Plan. PGDP presently has a Spill Prevention, Control, Countermeasures, and Contingency
Plan for Oils, Chemicals, and Hazardous Waste, which serves as a site-wide SPCC Plan
(Bell 1991). This Plan would be revised to include the PGDP WSFs and the MWSF.
5.4 EXECUTIVE ORDERS 11990 (PROTECTION OF WETLANDS) AND 11988
(FLOODPLAIN MANAGEMENT)
Two Executive Orders (E.O.s) were issued in 1977 requiring federal agencies to consider
the effects of proposed actions upon floodplains (E.O. 11988 Floodplain Management) and
wetlands (E.O. 11990 Protection of Wetlands). The Orders require federal agencies to
avoid, to the extent possible, adverse impacts associated with the occupancy and
modification of floodplains, and the destruction and modification of wetlands, and to avoid
direct or indirect support of floodplain and wetlands development whenever there is a
practicable alternative. Agencies must determine whether floodplains or wetlands are
present which may be affected by an action, assess the impacts on such floodplains or
wetlands, and consider alternatives to the action. DOE regulations (10 CFR Part 1022,
Compliance with Floodplains/Wetlands Environmental Review Requirements) state that the
potential impacts of DOE actions upon floodplains and wetlands should be evaluated as part
of an ea. This has been done in Section 4 and Appendix A, respectively.
5.5 ENDANGERED SPECIES ACT
Section 7(a)(2) of the Endangered Species Act (16 USC 1531 et seq.) requires that federal
agencies, "in consultation with and with the assistance of" USFWS, ensure that actions are
"not likely to jeopardize the continued existence of any endangered species or threatened
species or result in the destruction or adverse modification of the critical habitat of such
species..." This also includes species which are being considered for listing as endangered
or threatened species. Habitat for the Indiana bat exists at the proposed MWSF site. A
Biological Assessment was prepared for the proposed location and submitted to the USFWS
for a Biological Opinion according to the Endangered Species Act. The USFWS concurred
that removal of this potential habitat would have minimal impact on the species due to the
presence of significant amounts of similar, and in some cases, more suitable habitat
(Appendix B).
5.6 NATIONAL HISTORIC PRESERVATION ACT
Section 106 of the National Historic Preservation Act [16 USC 470(f)] requires federal
agencies to take into account the effects of their proposed actions on properties listed on or
eligible for the National Register of Historic Places (NRHP). Prior to approval of an
action, federal agencies must give the Advisory Council on Historic Preservation a
reasonable opportunity to comment on the proposed action. PGDP does not contain any
structures greater than 50 years old, and the area within the plant has been disturbed as a
result of the construction and operation of the plant; therefore, there are no sites within the
plant area that are eligible for listing on the NRHP or that would represent significant
archaeological resources. A surface survey of the proposed MWSF site by an
archaeologist and a member of the Kentucky Heritage Council confirms that the proposed
site has been previously disturbed by construction of KOW and/or PGDP, and there are no
sites present that would represent significant archaeological resources.
5.7 FARMLAND PROTECTION POLICY ACT
The Farmland Protection Policy Act (FPPA) requires federal agencies to consider the
effects of their proposed actions on high-quality agricultural lands. Such lands include
prime farmland, unique farmland, and other farmland of statewide or local importance for
the production of food, feed fiber, forage or oilseed crops. Specific criteria for prime
farmland categorization are provided in 7 CFR Part 658. Unique farmlands are more
generally defined to include land other than prime farmland that is used for production of
specific high value food and fiber crops. The SCS has promulgated a final rule which
implements provisions of the FPPA. All proposed sites of the WSFs are within an
industrial area; therefore no prime farmlands are present. The SCS concurs with this
conclusion.
5.8 HAZARDOUS MATERIALS TRANSPORTATION ACT
On-site transportation of waste material does not require permitting under DOT regulations.
Such transportation would be in accordance with applicable regulations, including DOE
Order 5480.3, Safety Requirements for the Packaging and Transportation of Hazardous
Materials, Hazardous Substances, and Hazardous Wastes. Off-site transport of waste
would come under the Hazardous Materials Transportation Act (49 CFR 171-178), which
regulates PCB waste and LLW and applicable requirements of the Nuclear Regulatory
Commission (10 CFR Part 71, Packaging and Transportation of Radioactive Material),
which regulates LLW which is above 0.002 microcurie/gram. It is unlikely that the TSCA
waste which may be shipped to the Oak Ridge incinerator will exceed this activity and
would not be regulated under 10 CFR Part 71. The Hazardous Materials Table (49 CFR
172.101) classifies each hazardous material and specifies requirements pertaining to its
packaging, labeling and transportation.
5.9 OCCUPATIONAL SAFETY AND HeaLTH ADMINISTRATION
All construction activities and practices would conform with OSHA Safety and Health
Standards (29 CFR 1926 and 1910). OSHA requires that a personnel training program
must be developed for any facility which stores hazardous waste (29 CFR 1910.120).
Personnel working at the WSFs would be trained in accordance with the OSHA
requirements.
6.0 AGENCIES AND PERSONS CONTACTED
The following agencies and persons were contacted during preparation of this ea.
Hal Bryan, President
ECO-TECH, Inc.
Frankfort, Kentucky 40602
Kentucky Department of Employment Services
Paducah, Kentucky
David Dunning
Kentucky Department of Fish and Wildlife Resources
Frankfort, Kentucky
David W. Pelren
Kentucky Heritage Council
Frankfort, Kentucky
David Pollack
Kentucky State Nature Preserves Commission
Frankfort, Kentucky
Brainard Palmer-Bell
Debbie White
U. S. Army Corps of Engineers
Louisville District
Louisville, KY
Dan Evans
U.S. Bureau of Labor Statistics
Washington, D.C.
Howard Hayghe
U.S. Department of Agriculture
Soil Conservation Service
Paducah, Kentucky 42001
Ron Froedge
U.S. Department of Commerce
Bureau of Economic Analysis
Washington, D.C.
Susan Trevathen
U.S. Department of the Interior
Fish and Wildlife Service
Cookeville, Tennessee
Lee A. Barclay
7.0 LIST OF PREPARERS
This ea was prepared by CDM Federal (Oak Ridge, TN) for Martin Marietta Energy
Systems, Inc. (Paducah, KY). The following personnel contributed to its preparation:
______________________________________________________________________________
NAME DEGREE YeaRS EXPERIENCE
______________________________________________________________________________
W. Michael Arendale M.S., Chemical Engineering 8
B.S., Chemical Engineering
______________________________________________________________________________
Del Baird M.S., Civil Engineering 7
B.S., Agricultural Engr.
A.S, Engineering Science
______________________________________________________________________________
Anne Bolling B.A., Environmental 3
Studies/Biology
______________________________________________________________________________
Constance Braun M.S., Ecology 19
B.S., Biology
______________________________________________________________________________
Linda Brown Ph.D., Envr. Biology 10
M.A., Envr. Biology
B.S., Biology
______________________________________________________________________________
James Dee MSPH, Environmental 12
Health Science
B.S., Biology and
Environmental Science
______________________________________________________________________________
Robert Harvey B.S., Chemical Engineering 6
______________________________________________________________________________
Brian Jenks Masters Business 7
Administration
B.S., Geology
______________________________________________________________________________
Mary Leslie M.S., Environmental 12
Engineering Sciences
B.S., Microbiology
______________________________________________________________________________
Angie Luckie B.C.E., Civil Engineering 1
______________________________________________________________________________
Cecilia Masson M.A., Economics 12
B.A., Economics
______________________________________________________________________________
John Young M.S., Geology 14
B.S., Geology
______________________________________________________________________________
REFERENCES
American National Standards Institute (ANSI), 1992.
American Society for Testing and Materials (ASTM), 1992.
Barclay, Lee October 6, 1992. Personal communication, U.S. Fish and Wildlife Service,
Cookeville, Tn.
Beach, L. J., and Redfield, W. F. 1992. Comprehensive Waste Storage Plan, Revision 1.
PGDP Waste Management Department, Chemical and Waste Services Division,
Report KY-W2, pp. 49.
Bell, Brian. 1991. Spill Prevention, Control, Countermeasures, and Contingency Plan for
Oils, Chemicals, and Hazardous Waste. Energy Systems Report KY/B-249.
Birge, W. J.; Short, T. M.; and Lauth, J. R., December, 1990. Biological Monitoring
Program for the Paducah Gaseous Diffusion Plant, Three-Year Report. Prepared for
Environmental Science Division, Oak Ridge National Laboratory. Lexington:
University of Kentucky.
CH2M HILL 1989. Phase I Site Investigation Work Plan for Paducah Gaseous Diffusion
Plant, Paducah, Kentucky, Oak Ridge, Tn.
CH2M HILL 1991. Results of the Site Investigation, Phase II, at the Paducah Gaseous
Diffusion Plant, Paducah, Kentucky, Document Number KY/SUB/13B-9888CP-
03/1991/1.
Clausen, J. L., Davis, K. R., Douthitt, J. W., and Phillips, B. E. January 1992. Paducah
Gaseous Diffusion Plant, Groundwater Protection Program Plan, KY-ER-2, Martin
Marietta Energy Systems, Inc.
Code of Federal Regulations. 29 CFR Parts 1910 and 1926, "OSHA Safety and Health
Standards."
Code of Federal Regulations. 49 CFR Parts 175-178, "Hazardous Materials Transportation
Act."
Code of Federal Regulations. 40 CFR Part 261, "Resource Conservation and Recovery
Act."
Code of Federal Regulations. 40 CFR Part 761, "Toxic Substances Control Act."
Cross, Kim September 23, 1993. Personal communication with Brian Bowers, U.S. Army
Corps of Engineers, Nashville District.
Dunning, David October 1992. Personal communication, Department for Employment
Services, Paducah, Ky.
Endangered Species Act, Section 7(a)(2), (16 USC 1531 et seq.)
ERC/EDGe 1989. The Geologic Setting of the DOE Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, ERC/EDGe, Inc., Knoxville, Tn., p. 16.
Evans, Marc October 19, 1992. Personal communication, Kentucky State Nature Preserves
Commission, Frankfort, Ky.
Executive Order 11988, "Floodplain Management."
Executive Order 11990, "Protection of Wetlands."
Federal Interagency Committee for Wetland Delineation 1989. Federal Manual for
Identifying and Delineating Jurisdictional Wetlands, U.S. Army Corps of Engineers,
U.S. Environmental Protection Agency, U.S. Fish and Wildlife Service, and
U.S.D.A. Soil Conservation Service, Washington, D.C., Cooperative Technical
Publication, p. 76 plus appendices.
Froedge, Ron 1991. Prime Farmland in McCracken County, U.S. Soil Conservation
Service, McCracken County, Ky.
Geotechnical Engineering. 1980. Subsurface Investigation For PGDP Hazardous Waste
Landfill. Report No. 86B-24700V. Knoxville, Tn.
Granger, Joseph E. November 16, 1992. Personal communication, ARCS, Inc.,
Louisville, Ky.
Hayghe, Howard October 1992. Personal communication, U.S. Bureau of Labor Statistics,
Washington, D.C.
Kentucky Department for Environmental Protection (KDEP) 1990. Kentucky Water
Quality Standards, Division of Water.
Lockwood-Greene March 1991. Conceptual Design Report for Mixed Waste Storage
Facility PGDP, Vol. I.
Martin Marietta Energy Systems, Inc. KY/E-106 Rev. 1, Best Management Practices Plan
for the Control of Suspended Solids, September, 1991.
Martin Marietta Energy Systems, Inc. September 1991. Paducah Gaseous Diffusion Plant
Environmental Report for 1990, ES/ESH-18/V3.
Martin Marietta Energy Systems, Inc. October 1992. Paducah Gaseous Diffusion Plant
Environmental Report for 1991, ES/ESH-22/V3
Martin Marietta Energy Systems, Inc. Y/EF-538 Rev. 6, General Design Criteria, March
18, 1992
Martin Marietta Energy Systems, Inc. FY 92-512 Rev. 1, System Requirements Document
for the Mixed Waste Storage Facility, February 28, 1992.
Martin Marietta Energy Systems, Inc. FY 92-840 Rev. 1, System Requirements Document
for the ER Waste Storage Facility, September 28, 1992.
Morgan, David L. November 16, 1992. Personal communication, Kentucky Heritage
Council, Frankfort, Ky.
Murray State University 1990. Paducah Gaseous Diffusion Plant Comprehensive
Earthquake Emergency Management Program, prepared for Martin Marietta Energy
Systems, Inc., Contract No. 19P-IV649V.
National Archaeological and Historic Preservation Act, Section 106 [16 USC 470(f)].
National Fire Protection Association (NFPA) 101, Life Safety Code, 1992.
Oakes, T. W., et. al. April 1987. Environmental Surveillance of the U.S. Department of
Energy Paducah Reservation and Surrounding Environs During 1986, ES/ESH-
1/V3, Martin Marietta Energy Systems, Inc./PGDP, Paducah, Ky.
Olive, W. W. 1980. Geological Maps of the Jackson Purchase Region, Kentucky. U.S.
Geological Survey Miscellaneous Investigations Series Map I-1217.
Osburn, W. L. September 27, 1993. Personal communication, Kenny Duncan, PGDP,
Paducah, Ky.
Paducah Gaseous Diffusion Plant May 1992. System Requirements Document for the ER
Mixed Waste Storage Facility, ESO-18104.
Pelren, David October 12, 1992. Personal communication, Kentucky Department of Fish
and Wildlife Resources, Frankfort, Ky.
Science Applications International Corporation (SAIC) 1992. Draft Environmental
Assessment: Construction and Operation of Residential Landfill Cell No. 3 at the
Paducah Gaseous Diffusion Plant, Paducah, Kentucky (Rev 2), Oak Ridge, Tn.
Slater, C. M. and G. D. Hall, eds. 1992. 1992 County and City Extra, Annual Metro, City
and County Data Book, Bernan Press, Lanham, Md.
Trevathen, Susan October 1992. Personal communication, U.S. Department of Commerce,
Bureau of Economic Analysis, Washington, D.C.
U.S. Army Corps of Engineers (COE) May 1993. An Identification of Floodplains Within
the Paducah Gaseous Diffusion Plant Study Area. McCracken County, Kentucky,
Interagency Agreement No. DE-A105-92OR 22026.
U.S. Army Corps of Engineers (COE) October 1993. Environmental Investigations at the
Paducah Gaseous Diffusion Plant and Surrounding Area, McCracken County,
Kentucky (Draft), Vicksburg, MS.
U.S. Department of Agriculture (USDA) 1976. Soil Survey of Ballard and McCracken
Counties, Kentucky. USDA Soil Conservation Service, in cooperation with the
Kentucky Agricultural Experiment Station.
U.S. Department of Energy (DOE) 1986. Transuranic Waste Transportation Assessment
and Guidance Report, DOE/JIP-002 Rev. 1, U.S. DOE, Joint Integration Office.
U.S. Department of Energy (DOE) August 21, 1991. Quality Assurance, DOE Order
5700.6C, U.S. DOE, Washington, D.C.
U.S. Department of Energy (DOE) September 26, 1988. Radioactive Waste Management,
DOE Order 5820.2A, U.S. DOE, Washington, D.C.
U.S. Department Of Energy (DOE) April 6, 1989. General Design Criteria, DOE Order
6430.1A, U.S. DOE, Washington, D.C.
U.S. Department of the Interior, Bureau of the Census. 1990 Census of the Population,
Washington, D.C.
U.S. Fish and Wildlife Service (USFWS) 1983. National Wetlands Inventory Map, Joppa
and Heath Quadrants.
U.S. House of Representatives Committee on Interior and Insular Affairs September 30,
1992. The Department of Energy's Failure to Police Standards for Radioactivity in
Hazardous Waste.
University of California Radiation Laboratory (UCRL) 15910, Design and Evaluation
Guidelines for DOE Facilities Subjected to Natural Phenomena Hazards.
Walker, T.A. November 1991. Systems Requirements Document for Waste Storage Area,
ESO 17549, Paducah Gaseous Diffusion Plant, Paducah, Ky.
White, Debbie October 16, 1992. Personal communication, Kentucky Nature Preserve
Commission, Frankfort, Ky.
APPENDIX A
WETLANDS ASSESSMENT
DRAFT
WETLAND ASSESSMENT
FOR THE
PROPOSED WATERSTORAGE FACILITIES
AT THE
PADUCAH GASEOUS DIFFUSION PLANT
PADUCAH, KENTUCKY
PREPARED FOR
MARTIN MARIETTA ENERGY SYSTEMS
PADUCAH GASEOUS DIFFUSION PLANT
PADUCAH, KENTUCKY
BY
SCIENCE APPLICATIONS INTERNATIONAL CORPORATION
APRIL 1993
TABLE OF CONTENTS
Page
List of Figures iv
Acronyms iv
1. INTRODUCTION 1
1.1 PROJECT DESCRIPTION 1
2. METHODS 2
2.1 BACKGROUND 2
2.2 WETLANDS 3
3. WETLANDS IMPACTS 6
3.1 ARea DESCRIPTION 6
3.2 DELINeaTED JURISDICTIONAL WETLANDS 6
3.2.1 Wetland 1 7
3.2.2 Wetland 2 7
3.3 WETLAND FUNCTIONS AND VALUES 7
3.4 OTHER AQUATIC RESOURCES 8
4. CONCLUSIONS 9
5. REFERENCES 10
APPENDIX A: U.S. Army Corps of Engineers, Nashville District,
Memorandum for the Record
B: Field Data Sheets
LIST OF FIGURES
Page
Fig. 1. Location of Waste Storage Facilities at PGDP 2
Fig. 2. Location of Wetlands 1 and 2 3
ACRONYMS
CFR Code of Federal Regulations
COE U.S. Army Corps of Engineers
CWA CLEAN Water Act
DOE U.S. Department of Energy
ea Environmental Assessment
EPA U.S. Environmental Protection Agency
KPDES Kentucky Pollution Discharge Elimination Systems
NEPA National Environmental Policy Act
PGDP Paducah Gaseous Diffusion Plant
RCRA Resource Conservation and Recovery Act
SAIC Science Applications International Corporation
SCS Soil Conservation Service
TSCA Toxic Substances Control Act
WSF Water Storage Facility
1. INTRODUCTION
1.1 PROJECT DESCRIPTION
The U.S. Department of Energy (DOE) proposes to design, construct, and operate three
waste storage facilities (WSF) at DOE's Paducah Gaseous Diffusion Plant (PGDP) located in
Paducah, Kentucky (fig. 1). The facilities would be designed, constructed, and operated for
the storage of hazardous waste regulated under the Resource Conservation and Recovery Act
(RCRA); waste regulated under the Toxic Substances Control Act (TSCA); low-level radioactive
waste regulated under the Atomic Energy Act and managed under DOE Order 5820.2A; mixed
waste (radioactively contaminated RCRA waste); and radioactive contaminated with TSCA-
regulated materials. This proposed project would result in the construction and operation of
two 3780-m2 (42,000-ft2) WSFs and one 18,900-m2 (210,000-ft2) mixed waste storage facility
(MWSF). Two 3780-m2 (42,000-ft2) WSFs would be constructed within the PGDP security
fence; the remaining 18,000-m (210,000-ft2) MWSF would be constructed outside the security
fence west of the plant. The WSFs and MWSF are needed to store waste generated through
Environmental Restoration remedial action at PGDP.
The MWSF proposed for construction outside the security fence would disturb about 2.8
ha (7 acres) of land. This site contains about 1.42 ha (3.5 acres) of second-growth hardwood
forest that has not been appreciably disturbed since about 1950. Two small wetlands totaling
0.19 ha (0.47 acres) are present on the site (fig. 2).
Figure (App 2)
Figure 1. Location of waste storage facilities at PGDP (Not available in electronic format)
Figure (App 3)
Figure 2. Location of wetland 1 and 2 (Not available in electronic format)
2. METHODS
2.1 BACKGROUND
The U.S. Army Corps of Engineers (COE) and the U.S. Environmental Protection
Agency (EPA) are responsible for making jurisdictional determinations of wetlands under
Section 404(a) of the CLEAN Water Act (CWA) (Code of Federal Regulations (CFR) 320 et
seq.]. Under Section 404 the COE has the authority to issue permits for the discharge
dredged or fill material into waters of the United States, including wetlands, with program
oversight by EPA. EPA has the authority to make final determinations on the extent of
CWA jurisdiction.
In February 1993, DOE prepared an Environmental Assessment (ea) for the
proposed WSFs project in compliance with the requirements of the National Environmental
Policy Act (NEPA). During the preparation of the ea, it became apparent that wetlands
may be present within the proposed project area that could be impacted by construction of
the proposed WSFs. In January 1993, DOE investigated the applicability of the
requirements of CWA Section 404 to the proposed project and enlisted a qualified soil
scientist to evaluate the potential wetland areas. On February 4, 1993, Science Applications
International Corporation (SAIC), the environmental contractor to Martin Marietta Energy
Systems, evaluated and delineated two wetlands located in the proposed project site area.
A representative from the COE's Nashville district office was present during the February
delineation (See Appendix A: COE Memorandum for Record).
Pursuant to 10 CFR 1022 (DOE's "Compliance With Floodplains/wetlands
Environmental Review Requirements"), as a result of the field sampling, DOE has
determined that this proposed project will involve activities within wetlands. Two areas
meeting all three wetlands criteria were identified and delineated during site reconnaissance.
Soil, hydrologic, and vegetation data at the delineated wetlands were recorded consistent
with COE wetland delineation guidelines (Environmental Laboratory 1987).
This report discusses impacts to wetlands directly associated with construction of the
WSFs at PGDP.
2.2 WETLANDS
Wetlands are those areas inundated or saturated by surface or ground water at a
frequency and duration sufficient to support, and that under normal circumstances do
support, a prevalence of vegetation typically adapted for life in saturated soil conditions
(40 CFR 230.3 and 33 CFR 328.3). Wetlands generally include swamps, marshes, bogs, and
similar areas.
4
Wetlands were inventoried during February 1993. The delineation was performed
using procedures detailed in Corps of Engineers Wetlands Delineation Manual (Environmental
Laboratory 1987). The purpose of the delineation was to identify potential jurisdictional
wetlands that may be affected by the proposed construction of the WSFs at PGDP.
Wetlands possess three basic attributes: wetland hydrology, hydrophytic vegetation,
and hydric soils. All the criteria must be present for an area to be defined as a wetland.
The presence of hydrophytic vegetation was determined by identifying the relative
abundance of plant species in each stratum (trees, saplings/shrubs, herbs, woody vines, and
bryophytes) at a site and recording their indicator status as defined in National List of Plant
Species That Occur In Wetlands (Reed 1988). If the total abundance of obligate, facultative
wetland, or facultative species is greater than or equal to 50%, the hydrophytic vegetation
criteria is met. Obligate plants almost always occur in wetlands (probability > 99%),
facultative wetland species usually occur in wetlands (probability 67 to 99%), and facultative
plants have a similar probability (33 to 67%) of occurring in wetlands or nonwetlands.
The presence of hydric soils was determined by examining and describing soil samples
from each site. If soils are gleyed with a chroma of 1 or less, or are mottled and the matrix
color has a chroma of 2 or less, the soil is considered to be hydric (Environmental
Laboratory 1987).
Wetland hydrology was determined by studying field indicators, such as inundation,
saturation, water marks, drift lines, sediment deposits on plants, and oxidized root channels
with live roots. A more detailed discussion of field indicators of the three criteria is found
in Corps of Engineers Wetlands Delineation Manual (Environmental Laboratory 1987).
To initiate the wetland inventory, National Wetland Inventory maps, Soil
Conservation Service (SCS) soil surveys, U.S. Geological Survey topographic maps,
Geographic Information System maps, and other available, pertinent information sources
were studied to determine the locations of possible wetlands. Each site was visited and
thoroughly examined for indicators of the thee wetlands criteria. When indicators of one
of the criteria were observed, evidence of the remaining criteria were sought. Soil
morphology was described using Munsell Color Charts (Kollmorgen Instruments
Corp. 1992). Dominant vegetation was described in each stratum and recorded. All
indicators of wetland hydrology were noted. Wetland boundaries were drawn on maps and
flagged in the field with surveyor's flagging.
5
3. WETLANDS IMPACTS
3.1 ARea DESCRIPTION
The general environmental and hydrologic settings of the wetlands within the
proposed project site area are described below, followed by a description of each wetland
and a discussion of the regulatory ramifications associated with altering each wetland. A
detailed description of the site, including geology and biotic resources at PGDP, is contained
in the Draft Environmental Assessment for the Proposed Construction and Operation of Three
Waste Storage Facilities at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky (SAIC
1993). The WSFs site is bounded on the west by Big Bayou Creek, on the north by
Kentucky Pollution Discharge Elimination System (KPDES) Outfall ditch 001, on the south
by KPDES Outfall Ditch 015, and on the east by the PGDP security fence (Fig. 2).
Topography in the area surrounding PGDP is relatively level to gently sloping. Soils
at the proposed WSFs site includes the Henry, Calloway, Grenada, and Vicksburg series
(Humphrey 1976). The wetlands at the site occur in an area mapped as Henry silt loam.
Henry soils are nearly level, poorly drained soils with a fragipan that formed in thick
deposits of loess or alluvium (Humphrey 1976). The depth to a seasonal high water table
is 0 to 0.3 ft. The water table is often perched above the fragipan and extends to or above
the soil surface in wet periods. Soil permeability is moderate (0.6 - 2.0 in./hr) in the upper
18 in. and slow (<0.2 in./hr) between 18 and 70 in. Henry soils are classified as hydric soils,
fulfilling one of the three criteria defining wetlands (Soil Conservation Service 1991).
The two wetlands subject to alteration by WSFs project development are immediately
west of the existing security fence between ditches 001 and 015. This area was once cleared
and regraded earlier during construction of either the Kentucky Ordnance Works or the
PGDP and has since returned to a hardwood forest community. Vegetation diversity is
highly variable and density is typically moderate to low in the forested areas. Each
delineated jurisdictional wetland is described below.
3.2 DELINeaTED JURISDICTIONAL WETLANDS
Two small isolated wetlands were identified in the wooded area at the proposed WSF
site (Fig. 2). Both wetlands appeared to have formed from construction activities within the
last 40 or 30 years. Both wetland areas are surrounded by an upland plant community
dominated by post oak (Quercus stellata), southern red oak (Q. falcata var. falcata),
cherrybark oak (Q. falcata var. pagodaefolia), and shagbark hickory (Carya ovata). The
combined area occupied by the two wetlands is about 0.47 acre. Field data sheets for
Wetlands 1 and 2 and one nonwetland area are in Appendix B.
6
3.2.1 Wetland 1
Wetland 1 is located in a topographic depression near several piles of soil, rubble,
and rusted drums about 50 ft northeast of the abandoned railroad track (Fig. 1). It is
roughly elliptic in shape and is about 150 ft long and 50 ft wide, covering about 0.19 acre.
The depression appears to have been created when the railroad bed was built. Water may
have drained out to the west at one time, but the piles of soil and rubble have effectively
dammed this area.
Vegetation within Wetland 1 is dominated by pin oak (Quercus palustris) and
American elm (Ulmus americana) in the tree layer and American elm in the sapling layer.
No other strata were evident during the February 1993 site visit. Soils around the outer
margin of the wetland were mottled with a matrix color of 10 YR 5/2; mottles were
10 YR 5/4. Soils within the center of the wetland had a matrix color of 10 YR 6/1.
Concretions of iron or manganese and oxidized root channels with live roots were also
present in the soil. At the time of the site visit the wetland was inundated; water was 1 to
1.5 ft deep. Water marks on the trees inside the wetland indicated the site is frequently
inundated for long periods. Mr. Mark Walter, an Energy Systems employee at PGDP,
reported having observed standing water on the surface of the site for extended periods (of
more than 1 week) as late in the season as June and July.
3.2.2 Wetland 2
Wetland 2 is located about 75 ft southeast of Wetland 1 adjacent to the abandoned
railroad track (Fig. 2). This wetland may have formed in a drainage ditch along the tracks
that was created when the railroad bed was built. The ditch may have emptied at one time
into what is now Ditch 015, but this outlet appears to have been closed when the tracks
leading into the plant were removed and the area was regraded.
Wetland 2 is roughly elliptic in shape and is about 330 ft long and 20 ft wide (Fig.
1). It covers approximately 0.28 acre. Very little perennial vegetation was evident in the
wetland at the time of the February 1993 site visit. American elm dominated the sapling
layer around the margin of the wetland with lesser amount of persimmon (Diospyros
virginica). An unidentified grass dominated the herbaceous layer. Soils within the wetland
were mottled with a matrix color of 10 YR 6/1 and mottles that were 7.5 YR 4/6. Iron or
manganese concretions were present in the soil. The site was inundated to a depth of about
1.5 to 2 ft and oxidized root channels with live roots were present in the soil. During a site
visit in September 1992, in one of the driest months of the year, a portion of the wetland
had standing water on it.
3.3 WETLAND FUNCTIONS AND VALUES
Because the two wetlands are very small, isolated from free-flowing streams and
other water bodies, and occur on highly impervious substrate, the potential function and
7
value of these wetlands for groundwater recharge or discharge, floodflow alteration,
sediment stabilization, sediment/toxicant retention, nutrient removal/transformation, and
production export is low. Recreation opportunities in these wetlands are low because of
their proximity to the PGDP. The abundance and diversity of aquatic habitat is low because
hydrologic regime is limited by the seasonal nature of inundation. These small palustrine
wetlands are typical of many other wetlands in the vicinity of the PGDP and they do not
represent unique resources. The primary function and value of these wetlands lies in their
suitability as habitat for nearby wildlife populations, particularly whitetail deer. The loss of
the wetlands and the surrounding woodland area would constitute a minor impact to the
deer and other wildlife species.
3.4 OTHER AQUATIC RESOURCES
One WSF will be located about 500 ft from Big Bayou Creek, 250 ft from KPDES
Outfall Ditch 001, and 300 ft from KPDES Outfall Ditch 015. Construction will not disturb
these aquatic resources.
8
4. CONCLUSIONS
Small isolated wetlands are common in the vicinity of the proposed WSFs at PGDP.
Two jurisdictional wetlands occur within an area potentially affected by the project (Fig. 2).
None of the potentially affected wetlands, however, is of high ecological value in a regional
context. No unique natural resources occur in any of the delineated wetlands. The area
appears to be heavily used by wildlife, especially whitetail deer.
The total area of wetlands delineated in areas potentially affected by the project is
approximately 0.19 ha (0.47 acre), all of which will be disturbed as a direct result of the
proposed action. Nationwide Permit #26 (isolated wetlands) would apply to the
construction of the WSF because the total area of wetlands disturbed by construction would
be less than 1 acre.
9
5. REFERENCES
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual.
Technical Report Y~87-1, U.S. Army Engineers Waterways Experiment Station,
Vicksburg, Miss.
Humphrey, Maurice E. 1976. Soil Survey of Ballard and McCracken Counties, Kentucky.
United State Department of Agriculture Soil Conservation Service.
Kollmorgen Instruments Corp. 1992. Munsell Soil Color Charts. Newburgh, N.Y.
Reed, P.B., Jr. 1988. National List of Plant Species That Occur In Wetlands: Northeast
(Region 1). U.S. Fish and Wildlife Service, Washington, D.C. Biol. Rpt. 88(26.1).
Science Applications International Corporation (SAIC). 1993. Draft Environmental
Assessment for the Proposed Construction and Operation of Three Waste Storage
Facilities at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky.
Soil Conservation Service (SCS). 1991. Hydric Soils of the United States. Third Edition.
USDA-SCS Miscellaneous Publication 1491.
10
MAY 25 `93 14:12 PAGE:002
DEPARTMENT OF THE ARMY
U.S. ARMY ENGINEER DISTRICT, LOUISVILLE
CORPS OF ENGINEERS
P.O. BOX.
LOUISVILLE. KENTUCKY 40201-0059
May 25, 1993
Operations and Readness Division
Regulatory Branch (South)
ID No. 199300516-rjs
Ms. Nancy Hendrix-Ward
NEPA Program Manager
Department of Energy
Oak Ridge Field Office
P.O. Box 2001
Oak Ridge, Tennessee 37831
Dear Ms. Hendrix-Ward:
This is in response to your request for authorization to fill two
small wetland areas for the U.S. Department of Energy' S (DOE) Proposed
Environmental restoration Waste storage facilities at DOE's Gaseous
Diffusion plant located in Paducah, Kentucky. We have reviewed the
submitted Material to determine whether a Department of the Army (DA)
Permit. would be required under the provisions of Section 404 of the
CLEAN Water Act (cWA). An onsite inspection of the property was made on
March 30. 1993, by Mr. Jerry Sparks of our newburgh field office. His
inspection Confirmed the presence of two jurisdictional areas estimated
to be 0.47 acre.
Since less than 1 acre of "waters Of the United States" (wetlands)
would be affected, and the proposed work Site is above the headwaters
Point of Big Bayou Creek, the proposed work is authorized by Nationwide
Permit (NWP) under the provisions of 33 CFR Section 330, Appendix A
(NWP No 26). However, the Commonwealth of. Kentucky has denied the
required Water Quality Certification (WQC) subject to Section 401 of the
CNA for this particular NWP for activities which involve:
a discharges into, and causing or resulting in the loss of or
adverse impact (impoundment, excavation or drainage) to 1 acre
or more of wetlands,
b. discharges into 200 linear feet or more Of any stream of
stream bank (below ordinary high water) depicted as an
intermittent or solid blue line on a U.S.G.S. 7.5 minute
(1:24,000) topographic map.
Should your plans change and you would need to exceed the limit
Specified in "a." then you would need to apply for a DA permit before
beginning work.
MAY 25 `93 14:14 PAGE:003
Should this activity exceed the limit specified in "b." you must
apply for and receive the necessary WQC from the Division of Water,
Kentucky Natural Resources and Environmental Protection Cabinet (KNREPC)
prior to the start of work. You may write to the KNREPC at:
Natural Resources and Environmental
Protection Cabinet
Division of Water
18 Reilly Road, Ash Building
Frankfort, Kentucky 40601
If KNREPC fails to respond to your request for authorization
within 60 calendar days, the WQC is considered waived. The
responsibility for obtaining the state WQC rests With you. Once you
ob%ain your certification or waiver and provided the proposed work has
not been modified, you may proceed with construction without further
contact or verification from us. This verification is only valid for
2 years from the date of this letter.
whether you receive the required water Certification or meet the
exceptions, you are also required to perform the work in accordance
with the enclosed General Conditions for Nationwide Permits and
Section 404 Only Conditions, and if issued, all conditions imposed by
the WQC.
If you have any questions, please contact mw by Writing to the
above address, ATTN: CEORL-OR-FS, or by calling (502) 5a2~5452. Any
correspondence should reference the assigned ID Number indicated
above A copy of this letter is being sent to the Division of water,
KNREPC for their information.
Sincerely,
Ronny J. Sadri
Project Manager
Regulatory Branch
Enclosures
2
MAY 25 `93 14:14 PAGE:004
ADDRESS FOR COORDINATING AGENCY
Mr. Jack A. Wilson
Director
Division of Water
Natura1 Resources and Environmental
Protection Cabinet
18 Reilly Road, Ash Building
Frankfort, Kentucky 40601
MAY 25 `93 14:14 PAGE:005
Nationwide Permit Conditions
General Conditions: The following general conditions must be followed in order for any authorization by a
corresponds permit to be valid:
1. Navigation. No activity may cause more that a minimal adverse effect on navigation.
2. Proper maintenance. Any structure fill authorized shal be properly maintained, including maintenance to
to ensure public safety.
3. Erosion and siltation control. Appropriate erosion and siltation controls must be used and maintained in
effective operation condition during construction, and all exposed soil and other fills permanently
stabilized at the earlist practicable date.
4. Aquatic life movements. No activity may substantially disrupt the movement of those species of aquatic
life in????? to the waterbody, including those species which normally migrate through the area, unless
the activity's primary purpose is to impound water.
5. Equipment. Heavy equipment working in wetlands must be placed on mats other measures must be taken to
minimize sod disturbance.
6. Regional and case-by-case conditions. The activity must comply with regional conditions which may have
been added by the division manager (See 33 CRF 330.4 (e)) and any case specific conditions added by
the Corps.
7. Wild and Scenic Rivers. No activity may occur in a component of the National Wild and Scenic River
system; or in a river officially designated Congress as a "study river" for possible inclusion in
in the system while the river is in the official study status. Information on Wild and Scenic Rivers
may be obtained from the national Park Service and the U.S. Forest Service.
8. Tribal rights. No activity or its operation may impair reserved tribal rights, including, but not
limited to reserved water rights and treaty fishing and hunting rights.
9. Water quality certification. In certain states, an individual states water quality certification must
be obtained or waived (See 33 CRF 330.4 (c)).
10. Endangered species. No activity is authorized under any NWP which is likely to jeopardize the
continued existence of a threatened or endangered species or a species proposed for such designation,
as identified under the Federal Endangered Species Act, or which is likely to destroy or adversely
modify the critical habitat of such species. Non-federal permitees shall notify the district engineer
if any listed species or critical habitat might be affected or is in the vicinity of the project and
shall not begin work on the activity until notified by the district engineer that the requirements
of the Endangered Species Act have been satisfied and that the activity is authorized. Information
on the location of threatened and endangered species and their critical habitat can be obtained from
the U.S. Fish and Wildlife Service and National Marine Fishenes Service. (See 33 CFR 330.4(f))
11. Historic properties. No activity which may affect Historic Properties listed, or eligible for listing,
in the National Register of Historic Places is authorized, until the DE has complied with the
provisions of 33 CFR 325, Appendix C. The prospective permitee must notify the district engineer if
the authorized activity may affect any historic properties listed, determined to be eligible, or
which the prospective permitee has reason to believe may be eligible for listing on the National
Register of Historic Places (See 33 CFR 330.4(g)).
(The above page is hardly recognized from a very unclear fax-page. To avoid mistake of
interpretation of the original material a image page is included in the following)
Figure (appa 4) (Not available in electronic format)
Nationwide Permit Conditions
MAY 25 `93 14:14 PAGE.006
Section 404 Only Conditions
In addition to the General Conditions, the following conditions apply only to activities that involve
the discharge of dredged or fill material and must be followed in order for authorization by the nationwide
permit to be valid:
1. Water supply intake. No discharge of dredged or fill material may occur in the proximity of a
public water supply intake except where the discharge is for repair of the public water supply
intake structures or adjacent bank ????????.
2. Shellfish production. No discharge of dredged or fill material may occur in areas of concentrated
shellfish production, unless the discharge is directly related to shellfish harvesting activity
authorized by nationwide permit 4.
3. Suitable material. No discharge of dredged or fill material may consist of unsuitable material
(e.g. trash, ????. car bodies, etc.) and material discharged must be free from toxic pollutants
in toxic amounts (See section 307 of the CLEAN Water Act).
4. Migration. Discharge of dredged or fill material into waters of the United States must be minimized
or restricted to the maximum extent practicable at the project site (i.e. on-site), unless the DE
has approved a compensation migration plan for the specific regulated activity.
5. Spawning areas. Discharges in spawning areas during spawning seasons must be avoided to the maximum
extent practicable.
6. Obstruction of high flows. To the maximum extent practicable, discharges must not permanently
restrict or impacts the passage of normal or expected high flows or cause the relocation of the
water (unless the primary purpose of the fill is to expend waters).
7. Adverse impacts from impoundments. If the discharge creates an impoundment of water, adverse
impacts on the aquatic system caused by the accelerated passage of water and/or the restriction
of the flow should be minimized to the maximum extent practicable.
8. Waterfowl breeding areas. Discharge into breeding areas for migratory waterfowl must be avoided
to the maximum extent practicable.
9. Removal of temporary fills. Any temporary fills must be removed in their entirety and the affected
areas restored to their preexisting elevation.
(The above page is hardly recognized from a very unclear fax-page. To avoid mistake of
interpretation of the original material a image page is included in the following)
Figure (appa 5) (Not available in electronic format)
Nationwide Permit Conditions
C D M F E D E R A L P R O G R A M S C O R P O R A T I 0 N
a subsidiary of Camp Dresser & McKee Inc.
December 11, 1992 Post-It brand fax transmittal memo 7671 # of pages 4
Mr. Charlie Logsdon
10535 Ogden Landing Rd.
Kevil, KY 42053
Subject: Environmental Assessments at the Paducah Gaseous
Diffusion Plant, Kentucky
Document Control No. 7905~005-CO-BBLY
Dear Mr Logsdon:
Per our telephone conversation, I am sending you two maps which indicate the locations of each
of the potential landfill sites. They are numbered 1 - 4. 1 would appreciate if you could visit
these sites and determine if any native prairie grasses are present on these sites and the relative
abundance of these grasses (i.e. estimated percent coverage If possible or a simple qualitative
descriptor). I would also appreciate any information concerning the potential impacts these sites
may have upon recreational use of the the area.
We are on an extremely short deadline, so 1 would greatly appreciate it if you could fax your
findings to me at (615) 481-3835. If this does not appear feasible, then you can phone me at
(615) 482-1065. I have enclosed my business card ior your convenience.
Thank you in advance for your cooperation.
Sincerely,
CDM Federal Programs Corporation
James Dee
Enclosures
cc: File
800 Oak Ridge Turnpike Suite 500 Oak Ridge, TN 37830 615 482-1065
Figure (f16) (Not available in electronic format)
(a page of hand writing)
Figure (f17) (Not available in electronic format)
JOPPA, ILL, -KY.
RICHARD HANNAN Brereton C. Jones
DIRECTOR GOVERNOR
COMMONWeaLTH OF KENTUCKY
KENTUCKY STATE NATURE PRESERVES COMMISSION
407 Broadway
FRANKFORT KENTUCKY 40601
(502) 564-2886
November 30, 1992
Jim Dee
CDM, Federal Programs Corp
800 Oak Ridge Turnpike
Suite 500
Oak Ridge, Tennessee 37830
Dear Mr. Dee:
I am sending you the information you requested on prairies in Kentucky. The
article includes typical prairie grass species. I hope that this helps with your project.
Please let me known if you need additional information.
Sincerely
Margaret Shea
Botanist
enclosure
An Equal Opportunity Employer M/F/H
Figure (f18)
HeaTH QUADRANGLE KENTUCKY
NATURAL COMMUNITIES OF KENTUCKY: PRAIRIES
by Marc Evans
A Natural Community is an assembledge of native plants and animals that are
interrelated with each other and their environment. Natural Communities are usually
differentiated based upon a number of criteria including vegetation structure, indicative
plant and animal species, soil moisture, geologic substrate and topographic position.
Kentucky, because of its diverse topography, varied geology and geographic location, has
a wide variety of Natural Communities. Some examples of types of Natural Communities
in Kentucky could include Dry Upland Forest, Limestone Savanna, Wet Bottomland Forest,
Forested Acid Seep, Mesic Prairie, Marsh and Swamp.
Prairies are a type of Natural Community that have, unfortunately, essentially
disappeared from the Kentucky landscape. In fact, most Kentuckians today do not even
realize that prairies once covered thousands of square miles of the commonwealth and
were an important part of Kentucky's rich natural heritage.
Basically, prairies are native grasslands with a relatively simple vegetative
structure dominated by a layer of grasses intermixed with prairie forbs. Trees and shrubs
are either absent or occur as scattered individuals or in groves. In Kentucky prairies
occurred mainly on deep but sometimes shallow soil which usually overlies limestone
bedrock. They required periodic fires to maintain their integrity and to control
encroachment by trees and shrubs. In Kentucky they ranged in size from over one
thousand square miles to small 1 acre or less openings in the forest. They usually
occurred on relatively flat plains but also occurred (and a few still do) on steep slopes
(often called hill prairies).
It is well documented that at the time of settlement in the late 18th century,
Kentucky had a considerable amount of non-forested lands, mainly in the western part of
the state (4, 5, 10, 11, 13). Early pioneers, emigrating from the east, encountered the
first large grasslands they had ever seen. Not knowing the French word "prairie," they
called these grasslands the "barrens" because of the lack of trees (13).
The main prairie region of the state, known as the "Big Barrens" occupied a large
part of the Mississippian Plateau (Pennyroyal Plain) and extended in a crescent-shaped
belt from near the Ohio River in Meade County south to Barren County then west to
Christian County and then northwest to Caldweil County. Another large area of prairies
also occurred further west in the Jackson Purchase (Gulf Coastal Plain). Other smaller
prairie areas occurred in parts of Crittenden and Livingston Counties, Bullitt County, and
Pulaski and Wayne Counties. Additionally, a number of small prairie openings were
scattered throughout parts of Kentucky (2, 5, 6, 7, 8, 9, 10, 11, 12, 18).
It has been estimated that the major prairies of Kentucky occupied from 2 to 3.8
million acres (3-6,000 square miles) or roughly ten percent of the state (3, 11, 12, 13).
The size of some of the larger prairies were estimated to be 60 miles by 25 miles,
between the Green and Little Barren River, 90 miles by 15 miles, south of Russellville and
40 square miles northwest of the Rolling Fork (3, 11, 12). Today, most of the Barrens area
is utilized for agricultural purposes, and only a few small scattered remnants remain that
support prairie communities.
The origin and age of the Kentucky barrens, as well as its exact character and
species composition, is not known. A number of authors have written on the subject
expressing various theories as to the origin and age (2, 4, 3, 11, 12, 13, 18). Several
factors, mainly climate, fire, grazing animals, soils and geology, have been attributed to
9
the origin of the barrens, and the age has been estimated from about 7,000 to 2,000 years
old (1, 5, 6, 12, 13, 17, 19). it is known, however, that at the time of settlement the
prairies were well established and were maintained by burning (either natural or Indian
set) and by the extensive herds of grazing bison, elk, and deer.
With settlement came the rapid destruction of the prairies through elimination of
the grazing herds, control of wild fires, and the conversion of prairie to crop and pasture
lands. Areas that were not plowed or grazed were reported to have reverted to an oak-
hickory woods, supporting the evidence that the prairies were fire maintained (3, 6, 13,
16) and not a climatic or edaphic climax community.
Unfortunately, no detailed descriptions or floristic lists were compiled before the
elimination of the prairie. The early travelers through the prairie gave, at best, only
general descriptions with little detail. The character of Kentucky's barrens was quite
varied and, based on early descriptions, ranged from tall grass prairie to shrub prairie to
Savanna-woodland with a grassy understory (5, 6, 11, 13, 15, 16). Prairie natural
communities and their species composition varied based upon soil depth, character, and
moisture and ranged from wet to mesic to dry prairie. Few large streams or rivers flowed
through the barrens; however, scattered sinkhole ponds and intermittent lakes occurred in
parts of the prairie region.
Although prairie communities are very rare in Kentucky today, many of the prairie
plants are still fairly common. They can be found scattered along roadsides and railroad
rights-of-way, in old fields and other neglected, out of the way places. Like the tall grass
prairies to the north and west of Kentucky, the dominant grasses in the barrens were Big
bluestem (Andropogon gerardii), Little bluestem (Schizachyrium scoparium), and Indian
grass (Sorghastrum nutans). Wetter prairies contained Switch grass (Panicum virgatum)
and Prairie cordgrass (Spartina pectinata). Numerous prairie wildflowers also occurred
such as Prairie dock (SilPhium terebinthinaceum). Blazing stars (Liatris sp.), Rosinweed
(Silphium integrifolium), Tall tickseed (Coreopsis tripteris), Prairie phlox (Phlox pilosa),
and many sunflowers (Helianthus sp.), Asters (Aster sp.) and Goldenrods (Solidago sp.)
A number of prairie plants are considered endangered or rare in Kentucky because
of their limited distribution or few known occurrences. The Kentucky Academy of
Science-Kentucky Nature Preserves Commission's list of Endangered, Threatened, and
Special Concern plants include 47 or so species that occur or occurred in prairies. Some
of these include White heath aster (Aster pilosos var. priceae), Creame wild indigo
(Baptisia Leucophaea), Side-oats gramma (Bouteloua curtipendula), June grass (Koeleria
cristata), Prairie blazing-star (Liatris pycnostachya), Dotted monarda (Monarda unctata),
Sundrops (Oenothera triloba and O. linifolia, Sweet cone flowers (Rudbeckia
subtomentosa), Royal catchfly (Silene regia), Compass plant (Silphium laciniatum),
Buffalo clover (Trifolium reflexum) and many others.
The beauty of tall grasses waving in the wind, brightly colored wildflowers scattered
about and an endless horizon is a sight Kentuckians will probably never see again in the
state. Prairies were a distinctive part of Kentucky's natural heritage and added
considerably to our states natural diversity. The few scattered remnants which remain
are in urgent need of protection and management. Much of the prairie regions of
Kentucky have not yet been thoroughly inventoried so a chance still remains that other
prairie remnants may exist, waiting to be discovered and protected. The Kentucky
Nature Preserves Commission and The Nature Conservancy are working together to assure
these areas remain as a reminder of our rich and varied natural heritage.
10
Figure (f19) (Not available in electronic format)
Figure 3-3 MWSF Proposed Location Major Topographical Features
Figure (f20) (Not available in electronic format)
Alternate sites for the proposed WSFs PADUCAH GASEOUS DIFFUSION PLANT
SELECTED REFERENCES ON KENTUCKY'S BARRENS (PRAIRIES)
I. 8askin, J. M. and C. C. Baskin. 1981. The Big Barrens of Kentucky not a part of
Transeau's Prairie Peninsula, In Stuckey, R. L. and K. J. Reese, editors. The
Prairie Peninsula-In the `Shadow' of Transeau: Proceedings of the Sixth North
American Prairie Conference, Ohio State University, Columbus, Ohio, August
12-17, 1978. Ohio Biol. Serv. Biol. Notes. No. 15.
2. Braun, E. L. 1950. Deciduous Forests of Eastern North America. Hafner Press,
New York, New York. pp.151-156.
3. Brown, Samuel R 1817. Western Gazeteer; or emigrants directory. H. C.
Southwick, Auburn, New York.
4. Cotterill, R. S. 1917. History of Pioneer Kentucky. Johnson & Hardin, Cincinnati,
Ohio.
5. Dickens, S. N. 1935. The Kentucky Barrens. Bull. Geogr. Soc. Phila, 43:42-51, illus.
6. Garman, H. 1925. The Vegetation of the Barrens. Trans. Ky. Acad. Sci. 2:107-111.
7. Gorin, F. Times of Long Ago. Barren County, Kentucky. (Reprint of series
published in Glasgow Times 1876) Published by L. H. Gorin, Louisville,
Kentucky. 1929.
8. Haycraft, S. 1921. A History of Elizabethtown, Kentucky, and its Surroundings.
(Written in 1869). Published by the Woman's Club of Elizabethtown, Kentucky.
9. Hussey, J. 1876. Report of the botany of Barren and Edmonson Counties...
Ky.Geol. Sur. 1:27-38.
10. Jillson, W. R. 1930. Filson's Kentucke - A Facsimile Reproduction of the Original
Wilmington Edition of 1784. John P. Morton and Company, Louisville,
Kentucky.
11. Loughbridge, R. H. 1888. Report on the Geological and Economic Features of the
Jackson Purchase Region. Kentucky Geological Survey, Frankfort, Kentucky.
12. McInteer, B. B. 1942. The Barrens of Kentucky. Trans. Ky. Acad. Sci. 10:7-12.
13. ________. 1946. A Change from Grassland to Forest Vegetation in the `Big
Barrens" of Kentucky. Amer. Midl. Nat. 33:276-282.
14. Mengel, R. M. 1963. The Birds of Kentucky. Ornithological Monographs No. 3, the
American Ornithologists Union. The Allen Press, Lawrence, Kansas.
15. Michaux, F. A. 1805. Travels to the Westward of the Alleghany Mountains in the
States of Ohio, Kentucky and Tennessee.. . Undertaken in the year 1802...
Transl. from original French by B. Lambert, London. Printed for Richard
Phillips.
16. Sauer, C. 0. 1927. (Assisted by John B. Leighly, Kenneth McMurry and Clarence W.
Newman) Geography of the Pennyroyal. . . Series VI, Vol. 23. Kentucky
Geological Survey, Frankfort, Kentucky.
17. Shaler, N. S. 1885. Kentucky; a pioneer Commonwealth. Houghton, Mifflin and
Company. New York.
18. Transeau, E. N. 1935. The Prairie Peninsula. Ecology 16:423-437.
19. Wilkins, G. R. 1983. Late-Quaternary Vegetational History at Jackson Pond, LaRue
County, Kentucky. M.S. Thesis, University of Tennessee, Knoxville,
Tennessee.
11
INTERPRETATION KEY TO DATA REPORTS FROM THE
KENTUCKY STATE NATURE RESOURCES COMMISSION
Revised October. 1992
Many of the data fields on the enclosed report are easily understood. Other fields.
however, use abbreviations and formats that are not always self-explanatory. A key to these fields
follows. Your report may contain some or all of the following data fields
BESTSOURCE: Best available reference to the element occurrence: literature citation.
collector. collection number. museum or herbarium code, etc.
COMMENTS: Additional information: duplicate records, validity of record. comment on
taxonomy or date of occurrence, etc.
EOCODE: Element (species) code and occurrence number (last three digits).
EODATA: Element occurrence data: number of individuals. health. size of colony,
flowering data. etc.
EORANK: Judgement of element occurrence quality: A = excellent. B = good, C =
marginal, D = poor, E = verified extant but quality not judged. O = obscure
(not found at reported site but more searching needed), H - historically
known from site but no known observation or collection since 1970, X =
extirpated from site.
FIRSTOBS: Year of first known observation or collection.
GENDESC: General description of habitat.
GRANK: Estimate of element abundance on a global scale: G1 - extremely rare G2
= rare. G3 = uncommon. G4 - common, G5 - very common. GH =
historically known and expected to be rediscovered, GU - uncertain, GX =
extinct.
IDENT: whether the identification has been checked by a reliable individual and is
believed to be correctly identified: Y - identification confirmed and believed
correct N = No, identification determined to be wrong despite reports to the
contrary,? = whether identification is correct or not is confusing or disput-
ed, blank or U = unknown whether identification correct or not.
KSNPC: Kentucky State Nature Preserves Commission status N = none. E =
endangered. T = threatened. S = special concern. H = historic.
LASTOBS: Year (-month~date) of most recent known observation or collection.
LAT: Latitude
LONG: Longitude
MARGNUM: Number used to location the element on KSNPC Heritage maps.
PREC: Precision of the plotted location: SC = location accurate to within one
second of latitude-longitude and confirmed by KSNPC staff. S = same as
previous code but not confirmed by KSNPC staff. M = location accurate to
within one minute of latitude-longitude. G = location plotted according to
general locality information and accurate to one USGS 7.5 minute quadran-
gle. U or blank = accuracy of location unknown or not specified.
SPROT: See KSNPC.
SRANK: Estimate of element abundance in Kentucky: S1 = extremely rare. S2 = rare,
S3 = uncommon. S4 = many occurrences. S5 = very common. SA = acciden-
tal in state. SE = exotic. SH = historically known in state, SN = migratory or
nonbreeding, SR = reported but without persuasive documentation, SRF =
reported falsely in literature. SU - uncertain. SX = extirpated.
USESA or US: U.S. Fish and Wildlife Service status: N = none. C1 - category 1 status
review, C2 = category 2 status review, 3A = considered to be extinct. 3B =
not considered a species under the Endangered Species Act. 3C = considered
to be more abundant than previously thought, LT - listed as threatened, LE
= listed as endangered. PT = proposed as threatened, PE = proposed as
endangered.
ENDANGERED-THReaTENED, AND SPECIAL CONCERN SPECIES REPORTED AS OCCURRING IN
THE ARea IN MCCRACKEN COUNTY, KENTUCKY
KENTUCKY STATE NATURE PRESERVES COMMISSION
KENTUCKY NATRUAL HERITAGE PROGRAM
OCT 1992 PAGE 1
CODE SCIENTIFIC COMMON
NAME NAME IDENT LASTOBS EORANK SPROT USESA SRANK GRANK
.$ VASCULAR PLANTS
JUG01010$002 CARYA AQUATICA WATER HICKORY 0000-00-00 H S S2S3 G5
STY01010$015 HALESIA CAROLINA CAROLINA SILVERBELL Y 1991-06-20 A E S1S2 G4G3
AST8L091$017 SILPHIUM LACINIATUM VAR COMPASS PLANT Y 1991-06-21 C T S2 G5
LACINIATUM
AST8L081$016 SILPHIUM LACINIATUM VAR COMPASS PLANT Y 1991-06-21 D T S2 G5
LACINIATUM
.$ CRUSTACeaNS
MAL11060$004 ORCONECTES LACIFER A CRAYFISH Y 1975-04-26 A E S1 G3
.$ FISH
FCHD01040$003 ESOX NIGER CHAIN PICKEREL 1972-05-28 C S S3S4 G5
FCJB16030$004 HYBOGNATHUS HAYI CYPRESS MINNOW Y 1968-09-10 H E S1 G5?
FCQB11100$007 LEPOMIS PUNCTATUS SPOTTED SUNFISH Y 1988-05-24 A T S2 G5
FCJB28650$002 NOTROPIS MACULATUS TAILLIGHT SHINER Y 1986-07-22 A T S2S3 G5
.$ AMPHIBIANS
AABC02060$035 HYLA CINERea GREEN TREEFROG Y 1991-06-28 E S S3S4 G5
AABC02060$034 HYLA CINERea GREEN TREEFROG Y 1991-06-25 E S S3S4 G5
AABH01014$009 RANA AREOLATA CIRCULOSA NORTHERN CRAWFISH FROG Y 1991-03-18 E S S3 G4
AABH01014$010 RANA AREOLATA CIRCULOSA NORTHERN CRAWFISH FROG Y 1991-03-28 E S S3 G4
AABH01014$014 RANA AREOLATA CIRCULOSA NORTHERN CRAWFISH FROG Y 1991-03-18 E S S3 G4
AABH01014$008 RANA AREOLATA CIRCULOSA NORTHERN CRAWFISH FROG Y 1991-03-20 E S S3 G4
AABH01014$015 RANA AREOLATA CIRCULOSA NORTHERN CRAWFISH FROG Y 1991-03-21 E S S3 G4
$$ REPTILES
RADB22023$013 NERODIA ERYTHRO6ASTER COPPERBELLY WATER SNAKE ? 1987-05-28 O S C2 S2S3 G5T2
NEGLECTA
$$ BIRDS
BPAV10080$003 CORVUS OSSIFRAGUS FISK CROW Y 1988-06-27 E S S3 G5
BNJB20010$004 LOPHODYTES CUCULLATUS HOODED MERGANSER Y 1988-05-08 B E S1S2 G5
BPBW01110$001 VIRED BELLII BELL'S VIRED Y 1988-06-27 B S S2S3 G5
BPBW01110$002 VIRED BELLII BELL'S VIRED Y 1985-05-26 B S S2S3 G5
$$ MAMMALS
MACC01150$078 MYOTIS SEPTENTRIONALIS NORTHERN LONG-eaRED Y 1991-06-25 E S S3S4 64
MYOTIS
MACC01150$079 MYOTIS SEPTENTRIONALIS NORTHERN LONG-eaRED Y 1991-06-27 E S S3S4 64
MYOTIS
MACC01100$010 MYOTIS SEPTENTRIONALIS INDIANA MYOTIS Y 1991-06-25 E S S1S2 G2
MACC06010$015 NYCTICEIUS HUMERALIS EVERING BAT Y 1991-06-27 E T S2S3 G5
MACC06010$017 NYCTICEIUS HUMERALIS EVERING BAT Y 1991-06-25 E T S2S3 G5
(The above table is hardly recognized from the fax-page image. The image file is included in the following
for reference)
Figure (f21) (Not available in electronic format)
Status List of T&E Species Known to Occur in Joppa. KY-IL Quad -- 08 OCT 1992
ID NAME SCIENTIFIC NAME FEDERALLY FEDERALLY FEDERALLY STATE STATE SPECIAL
END. THReaT. CANDIDATE. END. THReaT. CONCERN
xxxx Vireo. Bell's Vireo bellii - - - - - X
xxxx Lamprey, Chestnut Ichihyoxyzon castaneus - - - - - X
0706 Gar, alligator Lepisosteus spatula - - - X - -
0725 Picherel, chain Esox niger - - - - - X
0735 Minnow, cypress Hybognathus hayi - - - X - -
0768 shiner taillight Notropis maculatus - - - - X -
0801 chubsucker, lake Krixyzon sucatta - - - - X -
0805 buffalo, black Ichiobus niger - - - - - X
0833 Madtox, northern Noturus stignosus - - - - - X
0865 Sunfish, spotted Lepomis punctatus - - - - X -
1595 Frog, northern crawfish Rana areolata circulosa - - - - - -
(The above table is hardly recognized from the fax-page image. The image file is included in the following
for reference)
Figure (f22) (Not available in electronic format)
List of T&E Species KNOWN to OCCUR in PADUCAH E. Quad -- 02 OCT 1992
Figure (f23) (Not available in electronic format)
(The table is almost unrecognizable)
DEPARTMENT OF THE ARMY
NASHVILLE DISTRICT CORPS OF ENGINEERS
P.O. Box 1070
NASHVILLE. TENNESSEE 37202.1070
IN REPLY REFER TO FEB 19 1992
Environmental Resources Branch
Ms. Nancy Hendrix
U. S. Department of Energy
P.O. Box 2001
Oak Ridge, Tennessee 37831-8541
Dear Ms. Hendrix:
During recent telephone conservations with Messrs. Tom Swor
and Ray Hedrick of my Environmental Resources staff, you requested
that early wetlands and floodplain information be developed for a
priority site at the Paducah Gaseous Diffusion Plant under Inter-
agency Agreement No. DE-AI05-920R22026. On February 4, 1993, Mr.
Hedrick visited the proposed mixed waste storage site with Mr.
James P. Groton of Science Applications International Corporation,
who is preparing the Environmental Assessment for the proposal.
Enclosed is a memorandum presenting Mr. Hedrick's observations
concerning wetlands on the site. My Hydraulics and Hydrology
staff is continuing to work with Mr. Groton concerning the flood-
plain issues.
I am pleased that we have the flexibility to accommodate your
needs in this instance. If other situations arise whereby we may
be of assistance, do not hesitate to ask.
Sincerely,
R. J. Connor, P. E.
Chief, Engineering-Planning
Division
Enclosure
CF:
Mr. Jimmy Groton
SAIC
P.O. Box 2501
800 Oak Ridge Turnpike
Oak Ridge, TN 37830
CEORN-EP-E 17 February 1993
MEMORANDUM FOR RECORD
SUBJECT: Wetland Delineation on Proposed Site of ERWM Mixed
Waste Storage Facility at Paducah Gaseous Diffusion
Plant, Paducah, Kentucky.
1. On 4 February 1993, 1 accompanied Messrs. Jimmy Groton and
Mike Deacon of Science Applications International Corporation
(SAIC) to the subject site. The purpose of the field
investigation was to determine whether any of the proposed site
is occupied by wetlands.
2. Two small areas (less than 1 acre, combined) were identified
as potentially meeting the Corps of Engineers and Environmental
Protection Agency joint wetland definition (Federal Register 1982
and 1980, respectively). The Level 2 routine wetland determina-
tion procedure presented in Technical Report Y-87~l, Corps of
Engineers Wetlands Delineation Manual (commonly known as the "87
Manual"), was applied to both areas. The "87 Manual" is the
currently recognized authority for identifying and delineating
wetlands for purposes of Section 404 of the CLEAN Water Act.
3. The two areas of concern are marked on the attached map.
Both appear to have resulted from alteration of localized
drainage associated with an abandoned railway fill. Area A
appears to have formed 30 to 40 years ago, when construction of
the railway caused water to pond in a swale extending into the
adjacent bottomland hardwood forest. Area B was apparently
formed much more recently, possibly 3 to 5 years ago, when
bulldozer work to breach the railway blocked the drainage swale
at the toe of the railway fill. Similar wetlands commonly form
where highway or railway fills alter localized drainage.
4. My observation is that Mr. Groton correctly applied the
provisions of the "87 Manual", and I concur that both areas are
wetlands. It appears, however, that work in these wetlands would
fall under authority of Nationwide Permit No. 26 (33 CFR, 330.5)
since the wetlands potentially lost are less than 1 acre in size
and are above the headwaters or isolated. Nevertheless, DOE is
encouraged to avoid or minimize impact to the wetlands, to the
extent practicable, through alteration of the layout. Mitigation
of any unavoidable wetland losses would, then, be provided in
accordance with DOE's wetland policies and NEPA responsibilities.
5. I informally discussed the regulatory issues of the proposal
with Mr. Dan Evans (Louisville District Regulatory Branch
502/582-5452). Mr. Evans agreed that the CLEANest way to handle
the regulatory aspects of this proposal is for DOE or its
authorized agent to furnish him a copy of SAIC's report which
includes the wetland delineation, and request that he confirm the
applicability of Nationwide Permit No. 26 to this work.
Encl Ray D. Hedrick, Ecologist
Environmental Resources
Branch
CF: SWOR/EP-E
Dan Evans
CEORL-OR-L
P.O. Box 59
Louisville, KY 40201-0059
Figure (f24) (Not available in electronic format)
(A map)
MARC EVANS BRERETON C. JONE
ACTING DIRECTOR GOVERNOR
COMMONWeaLTH OF KENTUCKY
KENTUCKY STATE NATURE PRESERVES COMMISSION
407 BROADWAY
FRANKFORT, KENTUCKY 40601
(502) 564-28B6
October 21, 1992
Mr. James Dee
CDM Federal Programs Corporation
800 Oak Ridge Turnpike. Suite 500
Oak Ridge, Tennessee 37830
Re: Environmental Review 306
Dear Mr. Dee:
This letter is in response to your request of October 5, 1992 for environmental
review of the vicinity of the Paducah Gaseous Diffusion Plant in McCracken County,
Kentucky. We have reviewed our Natural Heritage Database to determine if any of
the rare or endangered species monitored by the Kentucky State Nature Preserves
Commission (KSNPC) or unique and sensitive areas occur near the project area
Based on our most current information, we have determined that sixteen of the
species of plants and/or animals that are listed for monitoring by the KSNPC are
known to occur in the vicinity of the plant (see attached printout).
Please note that the quantity and quality of data collected by the Kentucky
Natural Heritage Program are dependent on the research and observations of many
individuals and organizations. In most cases, this information is not the result of
comprehensive or site-specific field surveys; many natural areas in Kentucky have
never been thoroughly surveyed, and new species of plants and animals are still being
discovered For these reasons, the Kentucky Natural Heritage Program cannot
provide a definitive statement on the presence absence, or condition of biological
elements in any part of Kentucky. Heritage reports summarize the existing
information known to the Kentucky Natural Heritage Program at the time of the
request regarding the biological elements or locations in question. They should never
be regarded as final statements on the elements or areas being considered, nor
should they be substituted for on-site surveys required for environmental assessments.
An Equal Opportunity Employer M/F/H
J. Dee. CDM Federal Programs Corp.
October 21, 1992
Page Two
An invoice for the foregoing environmental review service is enclosed. if you
have any questions or I can be of further assistance, please do not hesitate to contact
me.
Sincerely,
Marc Evans
Acting Director
ME/BPB
SAIC
Science Applications International Corporation
An Employee-Owned Company
April 6, 1993
Mr. Jerry Sparks
U.S. Army Corps of Engineers
P.O. Box 489
Newburgh, IN 47629
SUBJECT: Report on Wetlands at Proposed PGDP Waste Storage Facilities Sites
Dear Mr. Sparks:
SAIC is pleased to submit a copy of the wetlands report for the proposed waste storage
facilities at the Paducah Gaseous Diffusion Plant. The report describes wetlands present
at the sites. I hope this report will be of service to you in preparing your report to the
District Engineer for a Nationwide Permit #26 for the proposed project.
If you have any questions about this report, I can be reached at (615) 481-8732. Thank you
for your help and advice on how to proceed in this matter.
Sincerely,
SCIENCE APPLICATIONS INTERNATIONAL CORPORATION
James P. Groton, Jr.
Environ mental Scientist
cc:
C. Pergler (SMC)
D. Wright (MMES)
M. Walter (MMES)
301 Laboratory Road. P.O. Box 2501. Oak Ridge. Tennessee 37831 (615) 482-9031
other SAIC Offices Albuquerque Boston Colorado Springs Dayton Huntsville Las Vegas Los Angels MCLEAN Palo Alto San Diego Seattle xxxxx
NOV-17-92 TUE 9:53 ARCS P.03
Granger to Pollack
Page Two
Alternate 1 (Location B ~- This alternate tract located between major power
lines is one of very low potential for archaeological sites. It is an essentially open
area situated well away from any stream and has no relief. Consultations with the
local Fish and Wildlife personnel indicate no historic structures or prehistoric
artifact findings on this tract. Only very low order on-the-ground survey might he
necessary here.
Alternate 2 (Location C)-This alternate tract is located on a hogback terrace
ridge which extends toward Little Bayou Creek. It is one of moderate potential for
archaeological sites being an area which is essentially open between ridge tops
which are wooded Consultations with the local Fish and Wildlife personnel
indicate no historic structures or prehistoric artifact findings on this tract. Survey
of this tract might be of the shovel Test Pit variety on 20 meter intervals.
Alternate 3 (Location D)-This alternate tract is located between a road and
powerlines and is one of very low potential for archaeological sites. It is an
essentially open area which extends to the south away from Little Bayou Creek and
it has no relief Consultations with the local Fish and Wildlife personnel indicate
no historic structures or prehistoric artifact findings on this tract. Only very low
order on-the-ground survey might be necessary here.
We have enclosed Maps for these areas and would appreciate your review of the findings Of the
on-site meeting.
Thanks for your willingness to endure the long ride to come to the on-site meeting at the Paducah
Gaseous Diffusion Plant-
Sincerely,
Joseph E. Granger, PhD, SOPA
President & principal Investigator
CC: John Young, Project Manager, cDM Federal Programs Corporation. Oak Ridge,
Tennessee
Vernon L. Wimberly, Subcontracts Administrator. CDM Federal Programs Corporation,
Fairfax Virginia
J. Anne Bolling, CDM Federal Programs Corporation. Atlanta Georgia
APPENDIX B
AGENCY LETTERS/CORRESPONDENCE
Education and Humanities Cabinet
KENTUCKY HERITAGE COUNCIL
Brereton C. Jones The State Historic Preservation Office David L. Morgan
Governor Executive Director
Sherry K. Jelsma and SHPO
Cabinet Secretary November 16, 1992
Mr. John D. Young, Project Manager
CDM Federal Programs Corporation
800 Oak Ridge Turnpike. Suite 500
Oak Ridge, Tennessee 37830
Re: Mixed Waste Storage Facilities at the Paducah Gaseous Diffusion Plant
McCracken County, Kentucky
Dear Mr. Young:
Thank you for your letter concerning the above referenced project. Our review of this
project indicates that an archaeological survey will not be required. The proposed project will
have no effect on any property listed in or eligible for listing in the National Register of Historic
Places. Therefore, I have no objections.
If you have any questions concerning this project please feel free to contact David Pollack
of my staff at 502-564-7005.
Sincerely,
David L. Morgan, Director
Kentucky Heritage Council and
State Historic Preservation Officer
Telephone (502) 564-7005
300 Washington Street
Frankfort. Kentucky 40601 FAX (502) 564-582O
Printed on recycled paper
An equal opportunity employer M/F/H
NOV-17-92 TUE 9:52 ARCS 5022666789 P.02
November 16, 1992
DAVID POLLACK
Kentucky Heritage Council
300 Washington Street
Frankfort. Kentucky 40501
Dear Dave,
I am writing to you concerning several tracts at the Paducah Gaseous Diffusion Plant which
needed to be looked at for preparation of an Environmental Assessment. Our on-site meeting of
November 13, 1992 included you, myself, Mr Martin Evans of this firm, Ms. J. Anne Bolling of
CDM Federal Services Corporation and Mr Mark Walker of Martin-Marietta corporation. My
recollection of the On-Site meeting was that we all agreed that it was probably, necessary to
accomplish immediate Phase I Field Survey in order to develop an Environmental Assessment on
these tracks. I am therefore writing to summarize my views and recommendations concerning all
of the tracts which we reviewed by walkover Or drive-by during the term of that meeting.
As a background to the on-site meeting, I had a person from this firm review all of the data on the
area in the Office of State Archaeologist at University of Kentucky. In those records, 17 sites
from an earlier survey wore found within one mile of the plant site, but these wore clustered
northwest toward the Ohio River rather than back along Little Bayou Creek. We were also
cognizant that a prior survey of 55 aces within the Plant Site by Tom Sussenbach bad been
unproductive due to prior disturbance.
The first location for study has been labeled "Site 1" and it includes a circa 2.3 Acre TSCA Waste
Storage Facility tract (ESO-17549/ESO-18125) and a 20 Acre Mixed waste Storage Facility tract
(ESO-18003/ESO-18104). The 2-3 acre plot is within the plant perimeter and may arbitrarily be
assumed to be disturbed based upon Sussenbach's earlier work. The 20-acre location is directly
adjacent to the plant site to (he west and has been affected by a rail line, impacted wetland drainage
development and possible stripping along the side of a drainage ditch. Our walkover on this
section showed very little area to be unaffected. I believe our conclusion was that this area had no
potential to yield significant archaeological resources.
The second "Site" to be considered in the Environmental Assessment was a Solid Waste Landfill
(ESO 18007) consisting of 1 preferred site (Location A) and 3 alternate sites labeled Locations B,
C and D (Alternate 1, Alternate 2 and Alternate 3). Each of these was a circa 40-acre potential
solid waste landfill track generally located above the 100 floodline on Pleistocene terrace structures.
We inspected each of these tracts in turn with the following findings:
Preferred (Location A) On several hogback ridges or knolls which overlook
Little Bayou Creek there appears to be the potential for several archaeological sites.
The best survey technique for this area would be complete plowing and disking
with 5-10 meter interval walkover sampling of the ridges and/or knoll tops. If this
location is cleared by survey apparently, no further work will be necessary on
other alternate locations.
United States Department of the Interior
FISH AND WILDLIFE SERVICE
446 Neal Street
Cookeville, TN 38501
April 28, 1993
Mr. Donald C. Booher
Site manager, Paducah Site Office
Department of Energy
Oak Ridge Operations
P.O. Box 1410
Paducah, Kentucky 42001
Re: FWS # 93-1310
Dear Mr. Booher:
We have reviewed the biological assessment regarding the Indiana bat, for
the construction of three waste storage facilities at the Paducah Gaseous
Diffusion Plant in McCracken County, Kentucky, submitted April 27, 1993.
The biological assessment is adequate and supports the conclusion of no
effect with which we concur. In view of this, we believe that the
requirements of Section 7 of the Endangered Species Act have been satisfied.
However, obligations under Section 7 of the Act must be reconsidered if: (1)
new information reveals impacts of this identified action that may affect
listed species or critical habitat designed that may be affected by the
identified action.
Your interest and initiative in enhancing endangered, threatened, and
candidate species is greatly appreciated. If you have any questions, please
contact Jim Widlak of my staff at 615/528-6481.
Sincerely,
Douglas B. Winford
Acting Field Supervisor
Figure (f25) (Not available in electronic format)
PROPOSED MIXED-WASTE FACILITY OF THE PADUCAH GASEOUS DIFFUSION PLANT
FISH AND WILDLIFE COMMISSION
Mike Boatwright Paducah
Sam C> Potter. Jr., Bowling Green
George H. Forster. Louisville
Dr. James R. Angel, Campbellsville
Dr. James R. Rich Taylor Mill
??ic Chism Winchester
Paul Lyon. Salversville
Dr. Roland L. Borns. Rush COMMONWeaLTH OF KENTUCKY
David H. Codby. Somerset DEPARTMENT OF FISH AND WILDLIFE RESOURCES
Don R. McCormick. COMMISSIONER
October 12. 1992
Mr. James Dee
CDM Federal Programs
800 Oak Ridge Turnpike
Suite 500
Oak Ridge, TN 37830
Re: Endangered/threatened species. Paducah.
McCracken county, Kentucky.
Dear Mr. Dee:
I recently sent you special concern animal species lists for the Paducah
East and Joppa USGS topographic quadrangles. I was informed today that an
Indiana myotis (Myotis sodalis), a federally endangered bat species, we also
found within the Joppa quadrangle. The bat was located on the West Kentucky
Wildlife Management Area in 1991. You recently requested a list of special
concern animal species for the Heath quadrangle. That list is enclosed. I
regret that we cannot provide an endangered/threatened plant species list. The
Kentucky State Nature Preserves Commission (502/564-2656) should be able to
provide such a list for a fee.
Again. I hope this information is helpful. Feel free to contact the
Environmental Section at 502/564-5448 for further assistance.
Sincerely,
David W. Pelren
Environmental Section Fishery Biologist
Enclosure
Arnold L Mitchell Bldg. #1 Came Farm Road Frankfort. Ky 40601
An Equal Opportunity Employer M/F/D
Figure (f26) (Not available in electronic format)
(A very short list in a bad condition)
FISH AND WILDLIFE COMMISSION
Mike Boatwright Paducah
Sam C> Potter. Jr., Bowling Green
George H. Forster. Louisville
Dr. James R. Angel, Campbellsville
Dr. James R. Rich Taylor Mill
??ic Chism Winchester
Paul Lyon. Salversville
Dr. Roland L. Borns. Rush COMMONWeaLTH OF KENTUCKY
David H. Codby. Somerset DEPARTMENT OF FISH AND WILDLIFE RESOURCES
Don R. McCormick. COMMISSIONER
October 8, 1992
Mr. Jim Dee
CDM Federal Programs
800 Oak Ridge Turnpike
Suite 500
Oak Ridge, TN 37830
Re: Endangered/threatened species, Paducah,
McCracken county, Kentucky.
Dear Mr. Dee:
I am glad to provide rare animal species Lists for the quadrangles that you
specified. Please find the enclosed lists for the Paducah East and Joppa USGS
topographic quadrangles. Be aware that. because our database is frequently
revised, the lists may not include all species that have been reported for the
quadrangles.
I hope this information is helpful. Feel free to contact the Environmental
Section at 502/564-5448 for further assistance.
Sincerely,
David W. Pelren
Environmental Section Fishery Biologist
Enclosures
Arnold L. Mitchell Bldg #1 Game Farm Road Frankfort. Ky 40601
An Equal Opportunity Employer M/F/D
UNITED STATES SOIL ROUTE 8, BOX 229
DEPARTMENT OF CONSERVATION MAYFIELD, KENTUCKY 42066
AGRICULTURE SERVICE (502) 247-9529
FEBRUARY 22, 1993
NANCY HENDRIX
NEPA PROGRAM MANAGER FOR RESTORATION OF WASTE MANAGEMENT PROGRAMS
UNITED STATES DEPARTMENT OF ENERGY
105 BROADWAY
OAK RIDGE, TENNESSEE 37830
DeaR NANCY,
THIS LETTER EXPLAINS THE PRIME FARMLAND DETERMINATION THAT WAS CONDUCTED
AT PROPOSED SITES FOR THE MIXED WASTE STORAGE FACILITIES AT THE PADUCAH
GASEOUS DIFFUSION PLANT, ON DECEMBER 2, 1992. INDIVIDUALS PRESENT
DURING THE REVIEW WERE DAVID DOLLINS (PROGRAM MANAGER FOR ENVIRONMENTAL
RESTORATION --D.O.E.), NANCY HENDRIX (NEPA PROGRAM MANAGER FOR
RESTORATION OF WASTE MANAGEMENT PROGRAMS--D.O.E.), AND RON FROEDGE
(DISTRICT CONSERVATIONIST--USDA SOIL CONSERVATION SERVICE).
THE AReaS INVESTIGATED HAVE BEEN ALTERED FROM THEIR NATURAL STATE
AND ARE NO LONGER CONSIDERED PRIME FARMLAND. MOST AReaS WERE DISTURBED
BY EXCAVATION AND/OR FILLED WITH GRAVEL. THE AReaS APPeaRED TO HAVE
BEEN ALTERED MANY YeaRS AGO, AS EVIDENCED BY AN ABANDONED RAILROAD THAT
IS ADJACENT TO THE PROPOSED SITES.
NEGLIGIBLE AMOUNTS OF PRIME FARMLAND SOILS WERE FOUND IN ONE WOODED
ARea, BUT WERE NOT CONTIGUOUS TO ANY OTHER PRIME FARMLAND AReaS. IT IS
MY ASSESSMENT THAT THESE AReaS ARE NOT LARGE ENOUGH TO BE OF ANY
CONCERN.
PLeaSE CALL IF WE CAN BE OF FURTHER ASSISTANCE.
SINCERELY,
RON FROEDGE
DISTRICT CONSERVATIONIST
cc: ELIZABETH ARAMOWICZ, D.O.E., PADUCAH
Figure (f27) (Not available in electronic format)
CDM Federal Programs Corporation Record of Communication
Figure (f28) (Not available in electronic format)
ENDANGERED/THReaTENED, AND SPECIAL CONCERN SPECIES REPORTED AS OCCURRING
IN THE ARea IN MCCRACKEN COUNTY, KENTUCKY
United States Department of the Interior
FISH AND WILDLIFE SERVICE
October 6, 1992
NEW ADDRESS:
446 Neal Street
Cookeville. 38501
Mr. James Dee
CDM Federal Programs Corporation
800 Oak Ridge Turnpike. Suite 500
Oak Ridge, Tennessee 37830
Re: 4-C-92-839
Dear Mr. Dee:
This is in response to your letter of October 5. 1992. regarding the proposal for
potential landfill sites in McCracken County, Kentucky.
We have reviewed the information with regard to endangered and threatened
species. According to our records. the following listed species may occur in the
vicinity of the proposed projects:
Indiana bat (Myotis sodalis) (E)
Bald eagle (Haliaeetus leucocephalus) (E)
You should assess potential impacts to these species and determine if the
proposed project may affect them. A "may affect" finding may necessitate formal
consultation.
In addition to endangered and threatened species. there are species that.
although not officially listed or proposed, are being considered for listing in
the future. Status review (candidate) species that may occur in the vicinity of
the project sites are.
Bachman's sparrow (Aimophila aestivalis) (SR)
This species is not legally protected by the Endangered Species Act and Section
7 requirements do not apply to it. but it is under consideration for listing and
we would appreciate anything you might do to avoid impacting it.
These constitute the comments of the Fish and Wildlife Service in accordance with
the Endangered Species Act (87 Stat. 884. as amended: 16 U.S.C. 1531 et seq.).
Sincerely.
Lee A. Barclay Ph.D.
Field Supervisor
United States Department of the Interior
FISH AND WILDLIFE SERVICE
446 Neal Street
Cookeville, TN 38501
February 10, 1993
Mr. James P. Groton. Jr..
Environmental scientist
science applications International Corp.
P.O Box 2501
301 Laboratory Road
Oak Ridge. Tennessee 37831
Deer Mr. Groton:
This is In response to your letter and enclosures of January 29. 1993,
regarding a proposal for two waste storage facilities at the Paducah Gaseous
Diffusion Plant in McCracken County, Kentucky. The Fish and Wildlife Service
(services) has reviewed the information submitted and offers the following
comments.
Review of the Heath quadrangle of the Service's National Wetlands Inventory
maps reveals that there an no forested, emergent, or scrub-shrub wetlands in
the vicinity of the proposed relocation project. Therefore, the Service
anticipates that there will be no project-related adverse impacts to valuable
wetland resources.
We have also reviewed the proposed project with regard to endangered species.
according to our records, the following federally listed or proposed
endangered or threatened species may occur in the project impact area:
Indiana bat (Myotis sodalis) (E)
You should assess potential impacts to this species and determine if the
proposed project may affect it. We recommand that you submit a copy of your
assessment and finding to this office for review and concurrence.
Thank you for the opportunity to comment on this action. If you have any
questions. please contact Steve Carter of my staff at 615~528-64B1.
Sincerely.
Lee A. Barcley, Ph.D.
Field Supervisor
ECO-TECH, INC
313 Capital Avenue
P.O. Box 8
Frankfort, Kentucky Phone (502) 223-8136
40602.0008 FAX (502) 223-3499
An Assessment of Potential Summer Habitat
of the
Federally Endangered Indiana Bat
Myotis sodalis
Hal D. Bryan
8 April 1993
Prepared for: Paducah Gaseous Diffusion Plant
McCracken County, Kentucky
ECO-TECH, INC
313 Capital Avenue
P.O. Box 8
Frankfort, Kentucky Phone (502) 223-8136
40602.0008 FAX (502) 223-3499
Figure (f29) (Not available in electronic format)
(hand writing notes)
AN ASSESSMENT OF POTENTIAL SUMMER HABITAT
OF THE
FEDERALLY ENDANGERED INDIANA BAT
Myotis sodalis
PREPARED BY:
HAL BRYAN
PREPARED FOR:
PADUCAH GASEOUS DIFFUSION PLANT
McCRACKEN COUNTY, KENTUCKY
FEBRUARY 1993
Hal Bryan and Associates
I. INTRODUCTION
The consultant was contracted by the Paducah Gaseous
Diffusion Plant in McCracken County, Kentucky to provide an
assessment of potential habitat for the federally endangered
species, the Indiana bat, Myotis sodalis. The species was
identified by the Cookeville, Tennessee, Office of the U.S.
Fish and Wildlife Service as federally endangered species
which may occur in the impact area of the proposed project,
the construction of a mixed-waste facility which would
require a site of approximately ten acres.
II.SPECIES STATUS
The Indiana bat, Myotis sodalis [Miller and Allen], formally
attained endangered status March 11, 1967. Its distribution
is in the eastern and midwestern United States.
Bat Cave in Carter County and Coach Cave in Edmonson Count
Kentucky have been designated "critical habitat" for the
Indiana bat within the boundaries of the Commonwealth.
The Indiana bat uses caves in Kentucky as hibernacula
(Barbour and Davis, 1969]. Although some males will remain
In the caves in summer, most of the population travels north
and west of the hibernacula to their nursery sites (Humphrey
et al., 1977). Only a few areas in Kentucky have been
documented to be the sites of maternity colonies of Indiana
bats. Known locations of maternity colonies include Bullitt
County along Knob Creek (Kessler et al., 1981], Daviess
County along Martin Creek (Harvey and Kennedy, 1981], near
Mammoth Cave in Edmonson County (field notes of J.R.
MacGregor), two sites in Jefferson County, (field notes of
H.D. Bryan), and a site in Breckinridge County at Yellowbanks
Wildlife Management Area (personal communication with Wayne
Davis, KDFWR). There are also several recent records of
lactating Indiana bats in the Purchase area of Kentucky
collected by biologists working on an inventory of the area.
They are under contract to the Kentucky Department of Fish
and Wildlife Resources and the Kentucky Nature Preserves
Commission. These include records of lactating Indiana bats
along Little Bayou du Chien in Fulton County, along Mayfield
Creek on the Ballard~Carlisle County line. Male Indiana
bats were collected in 1992 near the project site in
McCracken County by these biologists (KNPC, 1991).
All of these Kentucky locations have been in or adjacent to
bottomland hardwood forests. In Illinois, Indiana bats'
summer roost trees (some as small as six inches in diameter)
occur in either lowland or upland hardwood forests, but
primary foraging habitats of the species are bottomland
hardwoods (personal communication with Gene Gardner, Illinois
Natural History Survey).
III. SURVEY METHODS
The study area of approximately twenty acres is mostly fields
of fescue and broomsedge. However, a small woodlot of less
than two acres also occurs in the impact area. On February
18, 1993, the author visited the project area to assess
potential habitat and, if deemed necessary, choose netting
locations. Habitat was assessed using published information
and personal knowledge of sites where lactating Indiana bats
had been previously collected. Specific habitat
characteristics sought include the presence of deciduous
trees with diameters at breast height (dbh) greater than six
inches and with some individuals having exfoliating bark.
IV. SURVEY RESULTS
There are no caves or mines in the project that could provide
hibernacula for any species of bats.
The two-acre lowland woodlot was dominated by hardwood tree
Species from six to twenty inches in diameter. Numerous
individuals of shagbark or shellbark hickory were present
that have exfoliating bark. Additionally Several other large
trees were dying and had sloughing bark. Therefore, the
potential habitat for maternity sites of Indiana bats was
subjectively rated fair to good.
V. SUMMARY AND RECOMMENDATIONS
Potential summer foraging and roosting habitat for the
federally endangered Indiana bat does occur in the project
area. Recommendations are to sample the area with mist nets
between early June and mid-August of 1993 when lactating
Indiana bats could be caught if they are present in the area.
If lactating Indiana bats are collected during this effort,
then a detailed search of the two acres of woodland to be
impacted could be undertaken in a search for roost trees.
Because of the limited area of impact this search could be
accomplished by careful field investigations and aided by the
use of bat detectors.
VI. LITERATURE CITED
Barbour, R.W. and W.H. Davis. 1969. Bats of America. Univ.
Press of Kentucky, Lexington, 286 pp
Harvey, M.J. and M.L. Kennedy. 1981. Field survey for the
Endangered Indiana bat, Myotis sodalis, in the impact area of
the solvent refined coal demonstration plant ESRC-l], Newman,
Kentucky. Unpublished report to the International Coal
Refining Co., and the U.S. Dept. of Energy.
Humphrey, S.R, A.R. Richter and J.B. Cope. 1977. Summer
habitat and ecology of the endangered Indiana bat, Myotis
sodalis. J. Mamm. 58:334-346.
KNPC. 1991. Biological Inventory of the Jackson Purchase
Region. Kentucky Nature Preserves Commission, Frankfort,
Kentucky.
Kessler, J.S., W.M. Turner, and L. Morgan. 1981. A Survey
for the Indiana bat, Myotis sodalis, on Knob Creek, Bullitt
County, Kentucky. Trans. Ky. Acad. Sci. 42:38-40.
Finding of No Significant Impact (FONSI)
Construction, Operation, and Closure of
Waste Storage Facilities at the
Paducah Gaseous Diffusion Plant (PGDP), Paducah, Kentucky
AGENCY: Department of Energy (DOE)
ACTION: Finding of No Significant Impact
SUMMARY: DOE has prepared an environmental assessment (ea) for the proposed
construction, operation and closure of two approximately 42,000 square foot (ft^2) Resource
Conservation and Recovery Act (RCRA)/Toxic Substances Control Act (TSCA) Waste Storage
Facilities (WSFs) and one Resource, Conservation and Recovery Act (RCRA) permitted 200,000 ft^2
Mixed Waste Storage Facility (MWSF) on the PGDP site. This action is necessary to provide
adequate, permitted, hazardous waste storage facilities meeting regulatory requirements for continued
PGDP operations and future decontamination and decommissioning projects at PGDP until adequate
disposal and/or treatment options can be developed. The ea evaluated the potential environmental
consequences of the proposed action and reasonable alternative actions. Based on the analysis in the
ea, DOE has determined that the proposed action does not constitute a major federal action which
will significantly affect the human environment within the meaning of the National Environmental
Policy Act of 1969 (NEPA), 42 USC 4321 et seq. Therefore, it is determined that an environmental
impact statement will not be prepared, and DOE is issuing this FONSI.
COPIES OF THIS ENVIRONMENTAL ASSESSMENT ARE AVAILABLE FROM:
U.S. Department of Energy
Information Resource Center
105 Broadway
Oak Ridge, Tennessee 37830
FOR FURTHER INFORMATION ABOUT THE NEPA PROCESS, PLeaSE CONTACT:
Ms. Carol M. Borgstrom, Director
Office of NEPA Oversight
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, D.C. 20585
(202) 586-4600
SUPPLEMENTAL INFORMATION:
Proposed Action. DOE is proposing to construct and operate three Waste Storage Facilities at
PGDP. The facilities would be constructed and operated for the storage of process-derived waste,
including waste generated from associated PGDP activities (e.g., routine maintenance, housekeeping,
health and safety activities, project wastes). These wastes are regulated under RCRA, TSCA, Atomic
Energy Act (Aea), and DOE Order 5820.2A. The proposed action would result in the construction
and operation of two approximately 42,000 ft^2 PGDP WSFs (primarily for RCRA and TSCA wastes)
and one 200,000 ft^2 MWSF (primarily for RCRA and mixed wastes). All of the WSFs would be
designed to TSCA specifications for containment which are more stringent than the RCRA
specifications. The MWSF would be RCRA permitted. The proposed PGDP WSFs represent the
first facilities to be constructed at the plant for the sole purpose of storing waste. The WSFs would
be located within the secured boundary of PGDP and the MWSF located on a 20 acre area
immediately adjacent to the secured PGDP boundary.
Alternatives. Alternatives to the proposed action are no-action and the use of alternate locations for
the facilities. The no-action alternative would consist of DOE taking no action to construct new
PGDP WSFs, but continuing to manage and store RCRA- and TSCA-regulated wastes at existing on-
site waste storage facilities. The no-action alternative would also include continued implementation of
waste minimization practices in accordance with site and program waste minimization plans. All
PGDP generated waste would be stored on-site until storage capacity is reached. At that time, PGDP
operations could result in the need to cease generation of waste or be in violation of Federal and state
waste management regulations and agreements. The alternate locations evaluated provided no
environmental advantage over the preferred location and are actually less disturbed areas than the
preferred location. Alternatives considered but not evaluated were to upgrade existing facilities or
ship these wastes off-site. Limited space is available within some facilities but collectively these
facilities could not provide the total waste storage space necessary under projected waste generation
rates. Additionally, storage of waste in some of the existing buildings would require major
retrofitting and decontamination which would result in generating substantial amounts of waste which
would require storage. Based on the DOE Moratorium placed on off-site waste shipments to
commercial treatment, storage and disposal facilities, shipment of all wastes generated by PGDP
operations is not feasible at this time.
Environmental Impacts. Based on the following findings, no significant adverse impacts are
expected to result from the proposed action.
- Cultural Resources: Cultural resources or areas of archaeological significance do not exist in
the areas proposed for construction.
- Geology and Soils: The geology of the area would not be affected by construction of the
proposed facilities. All areas have been previously disturbed and no soils that are considered
to be prime farmland would be disturbed.
- Land Use: The areas proposed for construction are owned by DOE and are not readily
available for public access or recreational activities. Development of these areas as industrial
sites is consistent with adjacent site development, operations, management practices, and
agreements.
Socioeconomics: Construction of the proposed facilities is not expected to affect the local
economy on a long-term basis. The facilities would be operated by existing PGDP personnel
and only short-term construction employment would be created. Transportation requirements
would not change since all facilities would ultimately be located within the PGDP security
fence.
Water Resources: Big Bayou Creek may be affected by a temporary increase in siltation due
to construction activities and the proximity of the construction site to Kentucky Pollutant
Discharge Elimination System outfalls 001 and 015. Siltation would not be expected to affect
local biota and would be controlled by standard construction management practices such as silt
fences or hay bales. During operation, engineering controls would minimize the potential for
spills of hazardous substances from the waste storage facilities to enter the outfalls and
ultimately, Big Bayou Creek.
Wetlands: Two wetlands, approximately 0.5 acre total, that meet Federal jurisdictional
requirements would be filled by construction activities. These wetlands are considered to be
isolated, non-headwaters wetlands, and a U.S. Army Corps of Engineers Nationwide Permit
has been received for the proposed action. A Notice of Involvement will be published in the
Federal Register per DOE regulations (10 CFR 1022). Evaluations conducted during the
preparation of this environmental assessment indicate that the impacts to wetlands by the
proposed action would be minimal based on the availability of similar habitat.
Threatened and Endangered Species: Two acres of the 20-acre site for the PGDP MWSF
is considered potential summer habitat for the Indiana Bat (Myotis sodalis) due to the presence
of shagbark hickory (Carya ovata). The shagbark hickory (or other trees with loose bark)
may provide habitat for this bat during summer reproductive activities. A Biological
Assessment has been conducted according to Section 7 of the Endangered Species Act and
was submitted to the U.S. Fish and Wildlife Service (USFWS) for a biological opinion.
Based on the availability of approximately 3,000 acres of similar or more suitable habitat, the
USFWS has concurred that loss of 2 acres of potential habitat would not significantly affect
the status of the Indiana Bat. Additionally, to prevent the potential loss of an individual(s) of
the species, land clearing activities would be conducted outside of the known maternity
season.
DETERMINATION: The construction, operation, and ultimate closure of the proposed Waste
Storage Facilities at PGDP does not constitute a major federal action that would significantly affect
the quality of the human environment within the meaning of NEPA. This finding is based on the
analyses presented in the ea. Therefore, an environmental impact statement will not be required.
ISSUED IN WASHINGTON, D.C., THIS , 1994
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