EA-0976; Environmental Assessment and (FONSI) of Corrective Action at the Northeast Site

                                                               DOE/EA-0976
          Environmental Restoration Program
          ENVIRONMENTAL ASSESSMENT OF CORRECTIVE
          ACTION AT THE NORTHEAST SITE
          PINELLAS PLANT
          LARGO, FLORIDA
          February 1995
          Draft
          Prepared by:
          U.S. Department of Energy
          Albuquerque Operations Office
          With the technical assistance of:
          Environmental Restoration Program
          Technical Support Office
          Los Alamos National Laboratory

ACRONYMS

      AQI             Air Quality Index
      CEC             cation exchange capacity
      CERCLA          Comprehensive Environmental Response, Compensation and Liability Act
      CFR             Code of Federal Regulations
      CMA             corrective measure alternative
      CMS             corrective measure study
      COC             contaminant of concern
      DOE             U.S. Department of Energy
      EA              environmental assessment
      EPA             U.S. Environmental Protection Agency
      EPI             Emergency Prediction Information (model)
      FDEP            Florida Department of Environmental Protection
      FWS             Fish and Wildlife Service
      HSWA            Hazardous and Solid Waste Amendments
      ISC             Industrial Source Complex
      MCL             maximum contaminant level
      MCS             media cleanup standard
      MSL             mean sea level
      NAAQS           National Ambient Air Quality Standards
      NEPA            National Environmental Policy Act
      NTL             no-threat level
      PCAQD           Pinellas County Department of Environmental Management Air Quality Division
      PVC             polyvinyl chloride
      RCRA            Resource Conservation and Recoverv Act
      RFl             RCRA facility investigation
      SDWA            Safe Drinking Water Act
      SSC             species of special concern
      SVOC            semivolatile organic compound
      SWCFGWB         Southern West-Central Florida Groundwater Basin
      SWMU            solid waste management unit
      TLV-C           threshold limit value-ceiling
      TLV-TWA         threshold limit valuee-time-weighted average
      USGS            U.S Geological Survey
      UV              ultraviolet
      VOC             volatile organic compound

1. BACKGROUND

1.1. INTRODUCTION

The National Environmental Policy Act (NEPA) requires federal agencies to assess the
impacts that major federal actions may have on the quality of the human environment.
The U.S. Department of Energy (DOE) procedures for implementing the NEPA are
contained in the Code of Federal Regulations (CFR), Title 10, Part 1021 (10 CFR
1021) and DOE Order 5440.1E.
This document constitutes an environmental assessment (EA) of the proposed corrective
action for the Northeast Site at the DOE Pinellas Plant (Figure 1.1). It examines
the short- and long-term environmental effects of the proposed corrective action and
the reasonable alternatives. The information and analyses presented here will be
used to determine whether the proposed corrective action would have a significant
impact on the environment. If the impact is determined to be significant, an
environmental impact statement will be prepared for the proposed corrective action.
If the impact is judged not to be significant, a Finding of No Significant Impact
will be issued, and the proposed corrective action will be implemented. These
procedures and documents are defined in regulations issued by the Council on
Environmental Quality in 40 CFR 1500 through 1508, as well as in 10 CFR 1021.
Section 1 of this EA describes the Pinellas Plant and the Northeast Site, and Section
2 states the need for the DOE action. Section 3 describes the proposed corrective
action and the reasonable alternatives to it. Section 4 describes the present
condition of the environment, and Section 5 assesses the environmental impacts of
the proposed corrective action and the reasonable alternatives. This EA does not
contain all of the details of the studies on which it is based. The details are
contained in the referenced supporting documents.

1.2. PINELLAS PLANT

The Pinellas Plant (Figure 1.1) is on approximately 99 acres in Section 13, Township
30 South, Range 15 East (Tallahassee Meridian), in the center of Pinellas County,
Florida (Latitude 27 52' 30" North, Longitude 82 45' 00" West). The city of Tampa is
approximately 20 miles east of the Pinellas Plant, and the city of St. Petersburg is
about 6 miles to the south. Building 100 (Figure 1.2) is the most notable feature of
the Pinellas Plant and houses the DOE Pinellas Area Office and most of the plant
laboratory and production facilities. Numerous other structures function as storage,
utility, and testing facilities throughout the plant.
Figure (Page 1-2)
Figure 1.1 Pinellas Plant Location.
Figure (Page 1-3)
Figure 1.2 Pinellas Plant Site Map.
Figure (Page 1-3)
Figure 1.2 Pinellas Plant Site Map.
The Pinellas Plant is a government-owned facility that is administered by the DOE
Albuquerque Operations Office and operated by a DOE contractor. The plant was
constructed in 1956 and 1957 as part of the nuclear weapons production complex, and
the original products of the plant were neutron generators, a principal component of
nuclear weapons. The production of these devices required the development of several
uniquely specialized areas of competence and supporting facilities which led to the
manufacture of other weapons application products. The plant also maintains the
capability for applied research that is necessary for the manufacture of plant
products. In 1993, the DOE decided to phase out the Pinellas Plant and has proposed
leasing all or portions of the plant to commercial enterprises. It is anticipated
that the commercial enterprises would involve manufacturing processes identical or
similar to the processes currently used at the Pinellas Plant (DOE 1994d).
The types of waste generated at the Pinellas Plant have been fairly consistent
throughout the plant's history. Solid, liquid, and gaseous wastes generated at the
plant are both radioactive and nonradioactive. These wastes are stringently
controlled by a variety of treatment, control, and monitoring systems. Currently,
all hazardous wastes are either treated onsite to render them nonhazardous or are
shipped offsite to permitted waste treatment or disposal facilities.
Under the provisions of the Resource Conservation and Recovery Act (RCRA), as amended
by the Hazardous and Solid Waste Amendments (HSWA), the U.S. Environmental
Protection Agency (EPA) issued the Pinellas Plant a HSWA Permit in 1990 (EPA 1990a).
The HSWA Permit, in conjunction with the Hazardous Waste Management Permit issued by
the Florida Department of Environmental Protection (FDEP) (FDEP 1994), authorizes the
Pinellas Plant to operate as a hazardous waste storage and treatment facility. The
HSWA Permit also sets forth the conditions and requirements for RCRA corrective
actions at the plant. A corrective action is a measure or measures taken to protect
human health and the environment from all releases of hazardous waste or
constituents from any solid waste management unit (SWMU).
In 1988, the EPA identified 14 SWMUs at the Pinellas Plant (PIN02 through PIN15 on
Figure 1.2) (EPA 1988a), and the DOE identified an additional SWMU (PIN16 on Figure
1.2) in 1990 (DOE 1990c). To satisfy the requirements of the HSWA Permit, an RCRA
facility investigation (RFI) was completed in 1991 to address contaminant releases
and environmental conditions at the 15 SWMUs (DOE 1991b; 1992a; 1993b). The EPA
concurred with the DOE's recommendations that 11 of the SWMUs did not require any
further action because they did not present a threat to human health and the
environment. The EPA also concurred that corrective measures studies (CMSs) would be
conducted for the remaining four SWMUs (Hammond 1992). Three of these SWMUs are the
Northeast Site, Building 100 Industrial Drain Leaks, and Old Drum Storage Site, all
of which have contaminated groundwater in the surficial aquifer. The fourth SWMU, the
Pistol Range, had lead contamination in surface soils which has been cleaned up. In
1993, the DOE identified another SWMU at the Pinellas Plant (PIN17 on Figure 1.2)
(DOE 1993a). This SWMU, the West Fenceline Area, also has contaminated groundwater
in the surficial aquifer, and the EPA has concurred with the DOE's recommendation
that a CMS be conducted (DOE 1993e; Franzmathes 1993).

1.3. NORTHEAST SITE

EPA Region IV has designated the Northeast Site (approximately 20 acres) to include
all of the northeast section of the Pinellas Plant located within the perimeter
fence and bounded by the Spray Irrigation Site on the west and a parking lot to the
south (Figure 1.2). The concerns with the Northeast Site are the former drum storage
and disposal activities conducted at the site and the past discharge of industrial
waste to the East Pond (DOE 1991b).
The East Pond was constructed in 1968 next to a naturally swampy area. The East Pond
was deepened in late 1972, and the removed soil was used to cover the swampy area
and reportedly to build the backstop at the former Pistol Range. The East Pond
currently has a capacity of 3.25 million gallons (CH2M Hill 1987). From 1968 until
1972, the East Pond received storm water runoff and pH-neutralized wastewater; in
1972, the industrial wastewater was redirected to the West Pond. Liquid waste from
the West Pond was discharged through a spray irrigation system that was equipped with
a drainage system for intercepting infiltrating water and diverting it to the East
Pond. These operations continued until 1982 when the spray irrigation system was
abandoned. The East Pond currently receives only storm water runoff from the area
between the Northeast Site and Building 100 and is connected through a closed
underground piping system to the South Pond (DOE 1987). East Pond overflow
discharges through a county drainage pipe, south along Belcher Road, and then east
along Bryan Dairy Road until it empties into a county drainage ditch. Flow continues
southward, entering Cross Bayou Canal, Cross Bayou, and finally Boca Ciega Bay
(Figure 1.1). For an undetermined period of time between 1968 and 1972, the East
Pond discharge reportedly flowed north along Belcher Road; Pinellas County rerouted
the flow south when the area north of the Pinellas Plant became residential (DOE
1991b).
Before 1968, the naturally swampy area west of the East Pond was used as a staging
area for drums of waste solvents and construction debris. All of the waste drums
were to have been removed when the East Pond was constructed. However, three drums
buried near the East Pond were found in October 1984. Two of these drums were empty,
and one drum contained construction debris and rebar (DOE 1987). Partially due to
this discovery, investigations of the Northeast Site and East Pond were conducted in
1985 and 1987 (Fernandez 1985; DOE 1987; CH2M Hill 1987). These investigations
consisted of electromagnetic surveys, trenching, soil sampling, test borings,
monitoring well installation, groundwater sampling of new and existing monitoring
wells, and surface water sampling of the East Pond. A VOC groundwater plume was
identified west of the East Pond.
The RFI (DOE 1991b) confirmed that surficial aquifer groundwater in Northeast Site
monitoring wells contained concentrations of VOCs and SVOCs that exceeded Safe
Drinking Water Act (SDWA) maximum contaminant levels (MCLs) and FDEP drinking water
standards. The RFI also indicated the presence of mercury in the East Pond. The
potential contaminants of concern (COCs) in groundwater were identified as
dichloromethane (methylene chloride), 1,2-trans-dichloroethene, benzene,
4-methylphenol (p-cresol), trichloroethene, chloroethene (vinyl chloride), and
phenol. Therefore, the DOE recommended, and the EPA concurred (Hammond 1992), that a
CMS of the surficial aquifer groundwater and surface water pathways be conducted for
the Northeast Site. The CMS for the Northeast Site (DOE 1993c; 1993d; 1994b)
identified corrective action objectives and screened corrective measure technologies
that would meet those objectives. Corrective measure technologies that were found to
be feasible were then combined to form corrective measure alternatives (CMAs), which
were evaluated against technical, environmental, human health, and institutional
criteria as required by the HSWA Permit. The CMS resulted in a recommendation that
pump and treat with air stripping be implemented as the corrective action for the
contaminated surficial aquifer groundwater at the Northeast Site. Implementation of
the proposed corrective action for the Northeast Site is pending regulatory approval
by the EPA and FDEP.
Additional groundwater sampling was performed for the CMS. The concentrations of
contaminants in CMS groundwater samples were generally higher than those measured in
the RFI samples, and two distinct contaminant plumes were identified in the surficial
aquifer. The two separate contaminant plumes are just west of the northern and
southern portions of the East Pond, and the vertical extent of the contamination is
from approximately 16 to 26 ft below the ground surface. Low concentrations of
contaminants were also detected in monitoring wells along the eastern boundary of the
Pinellas Plant. For the purpose of this EA, the two contaminant plumes in the
surficial aquifer were considered to be one, as shown in Figure 1.3 (DOE 1993b).
Surface water samples taken from the East Pond during the RFI contained mercury
concentrations slightly above the SDWA MCL and FDEP drinking water standard (DOE
1991b). Supplemental RFI sampling of surface water in the East Pond was approved by
the EPA (Hammond 1992; Ingle 1992a,b), and was conducted to confirm or refute the
presence of mercury. This sampling indicated that mercury was not present above the
SDWA MCL and FDEP drinking water standard. Mercury is, therefore, no longer
considered to be a potential COC for the Northeast Site, and the CMS Report
recommends that the surface water pathway be deleted from the CMS for the Northeast
Site. The CMS also resulted in a recommendation that phenol be eliminated as a COC
because phenol does not have an appreciable influence on human health risks (DOE
1993c). Soil and sediment sampling did not identify any COCs for these media, and the
RFI Report concluded that no measurable contaminant mass remained in the vadose zone
at the Northeast Site (DOE 1991b).
Figure (Page 1-7)
Figure 1.3 Extent of Groundwater contamination at the Northeast Site (June 1992)
Figure (Page 1-7)
Figure 1.3 Extent of Groundwater contamination at the Northeast Site (June 1992)

1.4. CORRECTIVE ACTIONS

As stated in subsection 1.2, four SWMUs at the Pinellas Plant have contaminated
groundwater in the surficial aquifer. These SWMUs are the Northeast Site, Building
100 Industrial Drain Leaks, Old Drum Storage Site, and the West Fenceline Area
(Figure 1.2). In addition, there is contaminated surficial aquifer groundwater at
the 4.5-Acre Site, which is just outside the northwest corner of the Pinellas Plant
(Figure 1.2). Corrective actions are either ongoing or proposed for these SWMUs and
the 4.5-Acre Site, and all of the corrective actions together could have cumulative
environmental impacts (e.g., the withdrawal of groundwater from the surficial
aquifer).
After the 1987 investigation of the Northeast Site (CH2M Hill 1987), a preliminary
CMS (CH2M Hill 1989b) was prepared in 1989 as an internal document until the RFI
process was completed. Efforts associated with this preliminary CMS were concerned
primarily with groundwater conditions in the surficial aquifer west of the East Pond
and with the surface water quality of the East Pond. In 1991, an interim CMS (CH2M
Hill 1991) was prepared for the Northeast Site in response to concern that the areal
extent of the contaminant plume was potentially increasing and could migrate
offsite. This CMS recommended a groundwater recovery system consisting of four
recovery wells, use of an existing water treatment facility, discharge of treated
groundwater to the Pinellas County Sewer System, and a groundwater monitoring system
as an interim corrective measure for the Northeast Site. A review of the interim
groundwater recovery system resulted in a determination that the system was
categorically excluded from further NEPA review and documentation (i.e., did not
require the preparation of an EA or an environmental impact statement), and the
system was installed in January 1992.
The four recovery wells for the interim groundwater recovery system were installed
west of the East Pond (Figure 1.4). Each well is 24 to 30 ft deep and cased with
polyvinylchloride (PVC) plastic. The wells were equipped with pneumatic pumps, and
contaminated groundwater from the surficial aquifer is being pumped from each well
through underground piping to a holding tank north of the wells. The contaminated
groundwater is then pumped from the holding tank through underground piping to the
4.5-Acre Site groundwater treatment facility in the northwest corner of the Pinellas
Plant (Figure 1.4). This groundwater treatment facility uses an air stripper to
remove VOCs and SVOCs from the contaminated groundwater, and the effluent from the
treatment system is pumped to the Pinellas Plant wastewater neutralization facility
for further treatment and eventual discharge with sanitary wastewater into the
Pinellas County Sewer System (CH2M Hill 1989a; DOE 1992b).
Figure (Page 1-9)
Figure 1.4
Figure (Page 1-9)
Figure 1.4
Interim corrective action for contaminated surficial aquifer groundwater is also
underway at the 4.5-Acre Site. The 4.5-Acre Site is at the northwest corner of the
Pinellas Plant (Figures 1.2 and 1.4) and was previously part of the plant. The site
was sold to a private individual in 1972, and in 1984 it was discovered that the
area had been used to bury drums of solvent and resinous waste in the 1960s. The
buried drums were removed, and an assessment of the contamination began in 1985 and
has continued to date. In 1985, three contaminated groundwater plumes were identified
at depths of 0, 10, and 30 ft; monitoring data from 1987 indicated plume migration
offsite (CH2M Hill 1991). The COCs at the 4.5-Acre Site are 1,1-dichloroethane,
1,1-dichloroethene, 1,2-trans-dichloroethene, benzene, bromodichloromethane,
dichloromethane, ethylbenzene, tetrachloroethene, toluene, trichloroethene,
trichlorofluoromethane, chloroethane, xylene, arsenic, chromium, and manganese (DOE
1992c). A contamination assessment report (S&ME 1986) and a subsequent interim
corrective action plan (S&ME 1987) were approved by the FDEP in 1988, and a
groundwater recovery and treatment system was put into operation in December 1990.
The groundwater treatment system uses an air stripper to remove the VOCs and SVOCs,
and the treated groundwater is then pumped to the Pinellas Plant wastewater
neutralization facility for final discharge into the Pinellas County Sewer System.
The groundwater treatment system for the 4.5-Acre Site currently operates at its
design water inflow capacity of 20 gallons per minute because the system is treating
contaminated groundwater from both the 4.5-Acre and Northeast Sites. The DOE
proposes to increase the treatment capacity of the system to 50 gallons per minute to
provide sufficient capacity for the final corrective action at the 4.5-Acre Site, the
interim corrective action at the Northeast Site, and other possible corrective
actions (e.g., Building 100 area). Based on past and projected performance of the
groundwater recovery and treatment system, it is estimated that the corrective
action for the 4.5-Acre Site will be completed by 1999. This ongoing corrective
action at the 4.5-Acre Site constitutes a voluntary action under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA).
The Building 100 Industrial Drain Leaks and the Old Drum Storage Site adjacent to
Building 100 (Figure 1.2) are collectively called the Building 100 Area. Because of
the proximity and the similar groundwater contamination at these SWMUs, one CMS was
conducted for the Building 100 Area (DOE 1994a). The potential COCs at the Building
100 Area are the VOCs benzene, chloroethane, chloroethene, 1,1- dichloroethane,
1,1-dichloroethene, 1,2-dichloroethene (total), tetrachloroethene,
1,1,1-trichloroethane, and trichloroethene. The contaminants are concentrated around
the northwest corner of Building 100, but the contaminant plume has the potential to
migrate. The CMS resulted in the recommendation of groundwater recovery and
treatment as the preferred corrective action. The groundwater treatment would be
accomplished by routing the recovered groundwater to the groundwater treatment system
for the 4.5-Acre Site. The implementation of corrective action for the Building 100
Area is pending regulatory approval by the EPA and FDEP, and it is estimated that the
corrective action would be completed in 20 years.
The West Fenceline Area is a new SWMU that was identified by regular groundwater
monitoring at the plant. It is located at the western Pinellas Plant boundary west
of Building 100 (Figure 1.2). A RCRA facility assessment of the West Fenceline Area
revealed chloroethene in the surficial aquifer. The contamination is confined to an
area approximately 150 ft by 225 ft, but it was detected beyond the Pinellas Plant
boundary. The contamination may be the result of past waste disposal practices and
may be associated with a nearby former storage area (DOE 1993a). An interim
corrective measures work plan (DOE 1994c) has been prepared, and implementation of
the interim corrective action air sparging with soil vapor extraction has been
approved by the EPA and FDEP (Franzmathes 1994; Nuzie 1994; Ingle 1994). Using these
techniques, pressurized air would be injected into the saturated zone at high flow
rates to volatize the contaminant, and oxygen would be added to the air to enhance
the rate of biological degradation of organic contaminants by naturally occurring
microbes. Vapor extraction wells would be installed in the unsaturated zone to
recover the sparged vapors, which would be treated prior to discharge. If air
sparging with soil vapor extraction is not successful in removing the VOC
contamination, a groundwater recovery system could be installed at the West Fenceline
Area, and the contaminated surficial aquifer groundwater would be routed to the
groundwater treatment system for the 4.5-Acre Site.

2. PURPOSE AND NEED FOR ACTION

     The RFI (DOE 1991b; 1992a; 1993b) and subsequent investigations (DOE 1993c,d; 1994b)
     have confirmed that groundwater in the surficial aquifer at the Northeast Site is
     contaminated with VOCs and SVOCs. These contaminants pose a potential threat to human
     health and the environment. The DOE needs to manage this groundwater contamination
     in accordance with the EPA's HSWA Permit (EPA 1990a) and the FDEP's Hazardous Waste
     Management Permit (FDEP 1994).

3. CORRECTIVE ACTION ALTERNATIVES

3.1. THE PROPOSED CORRECTIVE ACTION

The proposed corrective action for the Northeast Site is pump-and-treat with air
stripping and includes the installation of a groundwater containment measure and
groundwater monitoring. The conceptual design for the proposed corrective action was
developed to satisfy the requirements of the HSWA and Hazardous Waste Management
Permits for the Pinellas Plant (EPA 1990a; FDEP 1994) and to meet the established
corrective action objectives. The design for the corrective action may be modified to
reflect technological advances or site- specific conditions. All design
modifications would be approved by the EPA and FDEP prior to implementation. Details
of the conceptual design for the proposed corrective action are provided in the CMS
Report for the Northeast Site (DOE 1993c,d; 1994b), and the major features of the
conceptual design are summarized below.
A staging area would be located at the west boundary of the Northeast Site, and a
groundwater containment measure (i.e., a slurry wall, infiltration gallery, or
shallow well injection) would be installed along the northern boundary of the
Northeast Site (Figure 3.1). This groundwater containment measure would limit the
volume of clean water recovered and would limit the recovery well capture zone to
within the Pinellas Plant property to prevent contamination migration from possible
unknown sources on adjacent properties. A slurry wall would consist of a trench keyed
into the Hawthorn Formation and filled with a soil/bentonite slurry. Almost all of
the material excavated from the slurry wall trench would be backfilled into the
trench as the soil/bentonite slurry; any excavation material remaining would be used
to cover the slurry wall and restore the disturbed area along the slurry wall. An
infiltration gallery or shallow well injection would consist of perforated PVC pipe
buried a certain distance below the ground surface or a line of shallow injection
wells along the northern boundary of the Northeast Site, respectively. Treated
groundwater from the proposed corrective action would be recirculated into the
surficial aquifer through the infiltration gallery or shallow well injection. For
the purpose of this EA, a slurry wall was assumed to be the proposed groundwater
containment measure because the slurry wall would remain permanently at the
Northeast Site. An infiltration gallery or shallow well injection would be removed
upon completion of the corrective action.
During installation of the slurry wall, five groundwater recovery wells would be
completed in the surficial aquifer for the removal of the contaminated groundwater.
The anticipated locations of these recovery wells are shown on Figure 3.1, but the
exact number and locations of these wells would be determined during the final
design of the corrective action. The drill cuttings produced from the completion of
the recovery wells would be managed according to the applicable federal and state
regulations.
Figure (Page 3-2)
Figure 3.1
Figure (Page 3-2)
Figure 3.1
Each groundwater recovery well would be approximately 37 ft deep to fully penetrate
the entire thickness of the surficial aquifer and to extend into the Hawthorn
Formation approximately 5 ft to provide a sump. Each well would also be completed
with stainless steel casing, a fully penetrating stainless steel well screen, and a
stainless steel, submersible, variable-speed pump. The fully penetrating well screen
and sump would allow the contaminated groundwater to be withdrawn from the entire
saturated thickness of the surficial aquifer. Each recovery well would be
individually controlled to optimize the well capture zone, and all of the recovery
wells would be equipped with flow meters to accurately measure the volume of
groundwater recovered. Each recovery well would also include a piezometer to monitor
the groundwater level in the well. After completion of the corrective action, all of
the recovery wells would be sealed and abandoned as required by the applicable
regulations.
A groundwater treatment system would be installed in an area just north of Building
1400 at the southern boundary of the Northeast Site (Figure 3.1). This treatment
system would have a capacity of 25 gallons per minute and would use an air stripper
to remove the VOCs and SVOCs from the contaminated groundwater. The groundwater
treatment system would be installed on a concrete pad that would be constructed with
appropriate slopes, sumps, and catchment basins to contain any potential leaks or
spills.
The groundwater recovery wells would be connected to the groundwater treatment system
by underground PVC pipe. Contaminated groundwater would be pumped from the recovery
wells to the treatment system where it would be placed in the influent storage tank
(Figure 3.2). Water from the influent storage tank would be pumped into the
pretreatment portion of the treatment system to remove naturally occurring iron and
suspended solids. The pretreatment unit would consist of a clarifier and sand filter,
and a flocculent would be added to the water in the clarifier to precipitate the
iron out of solution. Effluent from the clarifier would flow by gravity through the
sand filter and into a storage tank. Rejected water from the sand filter would flow
back to the clarifier. Sediment from the clarifier would be pumped to a sludge tank,
and the contents of the sludge tank would be manually pumped through a plate and
frame filter press. Effluent from the filter press would be routed to the storage
tank. The spent sand and filter cake from the sand filter and filter press would be
collected in 55-gallon drums, analyzed by the Toxicity Characteristic Leaching
Procedure, and then disposed of as solid or hazardous waste in accordance with the
applicable regulations. Water from the storage tank would be pumped to the air
stripper where the VOCs and SVOCs would be removed. Treated groundwater from the air
stripper would be pumped to the effluent storage tank and then to the Pinellas Plant
wastewater neutralization facility for final discharge into the Pinellas County
Sewer System.
Figure (Page 3-4)
Figure 3.2
The proposed corrective action would reduce the concentrations of the COCs in the
surficial aquifer groundwater to the media cleanup standards. The media cleanup
standards are the concentrations of the COCs that the EPA and FDEP approve as
acceptable for completion of the corrective action. For the Northeast Site, it has
been determined that the media cleanup standards will be the SDWA MCLs or the FDEP
drinking water standards for the COCs, whichever are more stringent (DOE 1993c,d;
1994b). For this EA, the media cleanup standards, SDWA MCLs, and the FDEP drinking
water standards for the COCs are collectively called the MCLs. Groundwater monitoring
would provide data to verify the achievement of the MCLs in the surficial aquifer,
to evaluate the efficiency and effectiveness of the corrective action, and to detect
contaminant migration resulting from the corrective action. Therefore, groundwater
monitoring would be conducted during the start-up and long-term operation of the
corrective action and for at least one year after completion of the corrective
action. During start-up and long-term operation, groundwater would be monitored in
15 monitoring wells located within and along the boundaries of the contaminant plume
and along the perimeter of the Northeast Site (Figure 3.1). Groundwater monitoring
after completion of the corrective action would be performed using 10 wells along
the perimeter of the Northeast Site (Figure 3.1). All of these monitoring wells were
installed for the Pinellas Plant RFI. The need for additional monitoring wells would
be identified during the final design or long-term operation of the corrective
action. If additional monitoring wells become necessary, they would be installed and
completed in a manner similar to the groundwater recovery wells except that they
would not be equipped with pumps. The need for and extent of long-term groundwater
monitoring after completion of the corrective action would be determined in the EPA-
and FDEP-approved Final Closure Report for the Northeast Site.
Most, if not all, of the areas to be disturbed during the corrective action
activities have been previously disturbed by Pinellas Plant operations and by the
various investigations of the Northeast Site, including the RFI. However, these
disturbed areas would be restored to their original conditions or as close to their
original conditions as possible. The disturbed areas would be graded to conform to
the surrounding land surface and to avoid the ponding of surface runoff. The areas
would then be revegetated with plant species that are common to the Pinellas Plant
(e.g., St. Augustine grass).
Once implementation of the proposed corrective action was approved and contracted
for, construction and installation of the slurry wall and the groundwater recovery
and treatment systems would take a maximum of 6 months. Most, if not all, of these
construction and installation activities would be performed concurrently. After the
construction and installation, the corrective action would be operated for a 1-year
start-up period, after which long-term operation would begin. Groundwater modeling of
the corrective action indicates that long-term operation would continue for 29 years
in order to meet the corrective action objectives and achieve the MCLs. During the 30
years of corrective action, approximately 70 million gallons of groundwater would be
recovered, treated, and discharged to the Pinellas County Sewer System. Total capital
costs (direct and indirect) for installation of the proposed corrective action would
be approximately $4.5 million, and the first-year operation and maintenance costs
would approximate $750,000. The total estimated cost for 30 years of operation and
maintenance of the proposed corrective action is $22.5 million (1992 dollars).
The corrective action would be performed in accordance with the HSWA and Hazardous
Waste Management Permits for the Pinellas Plant (EPA 1990a; FDEP 1994) and the EPA-
and FDEP-approved Corrective Measure Implementation Plan. Implementation of the
corrective action would require permits for the groundwater recovery and monitoring
wells and for the air stripper. The completion of each groundwater recovery and
monitoring well would require a "Permit to Construct, Repair, Modify or Abandon Well"
issued by the Southwest Florida Water Management District. Installation and
operation of the air stripper would require a "Permit to Operate/Construct Air
Pollution Sources" issued by the FDEP. Other Federal, state, and local permits
required for the proposed corrective action would be identified during the final
design and would be obtained prior to implementation of the proposed corrective
action.
The treated groundwater from the Northeast Site would be routed to the Pinellas Plant
wastewater neutralization facility for final discharge into the Pinellas County
Sewer System. The Pinellas Plant's discharge of wastewater to the sewer system is
subject to the Industrial Wastewater Discharge Permit, Permit Number 153-IE, issued
to the plant in 1994 by the Pinellas County Sewer System (PCSS 1994). The Pinellas
County Sewer Use Ordinance of April 1991 specifies standards for discharge to the
sewer system, but the ordinance does not specify any standards for organics. The
Pinellas Plant is required to meet the metals finishing industry standards for
organics, and the EPA standards (40 CFR 433) specify a pretreatment limit of 2.13
milligrams per liter (mg/L) for total toxic organics. Toxic organics, as defined by
the EPA, include dichloromethane, trichloroethene, toluene, and chloroethene.
Therefore, the limit for total toxic organics in the total Pinellas Plant discharge
is 2.13 mg/L (CH2M Hill 1989a; DOE 1992b).
In addition to the required permits, the following standard operating procedures were
incorporated into the proposed corrective action to reduce environmental impacts:
- Construction equipment used in the corrective action (e.g., backhoe and front-end
loader) would be equipped with appropriate emissions control devices to control
combustion emissions.
- Fugitive dust generated by corrective action activities (e.g., installation of the
soil/bentonite slurry wall) would be controlled with water sprays.
- All areas disturbed during the corrective action would be restored (graded and
revegetated) as soon as possible.
- The water level in the East Pond would be monitored during corrective action to
determine if and how much the water level is being lowered and to assess any adverse
effects on vegetation or wildlife in the East Pond. If the lowering of the water
level is appreciable or if any adverse effects on vegetation or wildlife are
observed, the DOE would develop and implement appropriate measures in consultation
with the appropriate regulatory agency or other authority. The DOE would also
evaluate the need for additional NEPA review and would conduct this review if
necessary.
Workers involved in the proposed corrective action would be subject to potential
exposure to contaminated groundwater and air emissions from the air stripper.
Workers would also be exposed to the physical hazards associated with installation,
operation, and maintenance of the corrective action (e.g., operating heavy
construction equipment). The corrective action would be performed in compliance with
all of the applicable health and safety requirements of the Occupational Health and
Safety Administration, as set forth in 29 CFR 1900-1910 and 1926, as well as all
applicable DOE and Pinellas Plant health and safety requirements. In addition, the
corrective action would be performed in compliance with a site health and safety
plan, as required by 29 CFR 1910.120; 29 CFR 1910.120 governs all work at
uncontrolled hazardous waste sites including worker training and medical monitoring.

3.2. OTHER ALTERNATIVES

3.2.1. No Action

The no action alternative would consist of continuing the interim corrective action
for the Northeast Site (subsection 1.4). The contaminated groundwater in the
surficial aquifer would continue to be recovered using existing recovery wells and
pumped to the existing groundwater treatment facility for the 4.5-Acre Site in the
northwest corner of the Pinellas Plant (Figure 1.4). This groundwater treatment
facility uses an air stripper to remove VOCs and SVOCs from contaminated
groundwater, and the effluent from this facility is pumped to the Pinellas Plant's
wastewater neutralization facility for eventual discharge into the Pinellas County
Sewer System. The interim corrective action includes a groundwater monitoring system
(CH2M Hill 1989a, 1991; DOE 1992b).
This alternative was evaluated during the CMS process. At the time the Northeast Site
was recommended for interim corrective measures, excess groundwater treatment
capacity was available at the 4.5-Acre Site facility because it was under interim
status and the facility had been designed with enough capacity for its anticipated
final corrective action. The 4.5-Acre Site will soon be proposed for final corrective
action; therefore, at the time when the Northeast Site is ready for its final
corrective measure, it is anticipated that the excess groundwater treatment capacity
at the 4.5-Acre Site facility will not be available (DOE 1993c). If the groundwater
treatment facility for the 4.5-Acre Site was used for the final corrective actions
for both the 4.5-Acre and Northeast Sites, one or both of the corrective actions
would have to operate at less than an optimum groundwater recovery rate. This could
extend the time necessary for completion of a corrective action and could present the
potential for offsite migration of contaminated groundwater.
During the CMS process for the Northeast Site, two other no action alternatives were
evaluated. The first no action alternative would consist of taking no corrective
action. The groundwater contaminant plume would remain in its present location and
condition, and the potential for offsite migration of the plume would continue to
exist for an indefinite period of time. The second no action alternative would
consist of taking no corrective action, but various institutional controls (e.g.,
deed restrictions) and groundwater monitoring would be implemented to prohibit or
restrict access to the contaminated groundwater and to detect any future migration of
the contaminant plume. These no action alternatives would not satisfy the
requirements of the HSWA Permit for the Pinellas Plant and would not meet the
established corrective action objectives for the Northeast Site (DOE 1993c).
Therefore, neither of these alternatives were considered in this EA.

3.2.2. Ultraviolet Oxidation

     The ultraviolet (UV) oxidation alternative for corrective action at the Northeast
     Site would be the same as the proposed action except that UV oxidation would be the
     primary groundwater treatment system instead of air stripping. The air stripper
     (Figure 3.2) would be replaced with a UV oxidation tank and a hydrogen peroxide
     tank. Hydrogen peroxide would be added to the contaminated groundwater to begin the
     destruction of the organic contaminants. The contaminated groundwater would then be
     exposed to UV light from a series of UV lamps in the UV oxidation tank which would
     complete the destruction of the majority of the organic contaminants. The
     contaminants would be oxidized to carbon dioxide, water, and inorganic salts.
     Partially oxidized or unoxidized contaminants, such as dichloromethane, could require
     additional treatment, and controls could be required for emissions created by the UV
     oxidation process depending on the type of system used. The UV oxidation alternative
     could be more expensive than pump-and-treat with air stripping, especially over 30
     years of corrective action (DOE 1993c).

3.3. ALTERNATIVES DISMISSED FROM FURTHER CONSIDERATION

     As stated in subsection 1.3, the CMS identified corrective action technologies that
     were screened to eliminate technologies that were not feasible to implement, were
     unlikely to perform satisfactorily or reliably, or may not achieve corrective action
     objectives with a reasonable period of time. Thirty-nine preliminary corrective
     action technologies were identified and screened for groundwater containment,
     collection, treatment, and disposal and for the disposal of solid wastes from
     groundwater treatment. These technologies included a slurry wall, sheet piling, and
     grout curtains for groundwater containment; recovery well and trench collection
     systems for groundwater collection; enhanced bioremediation, air stripping, UV
     oxidation, and filtration for groundwater treatment; an evaporation pond, shallow and
     deep well injection, and surface irrigation for groundwater disposal; and onsite and
     offsite landfill disposal of solid wastes from groundwater treatment. Eleven of the
     technologies were retained as feasible and, when combined, formed a number of
     technology options. From the technology options, pump-and-treat with air stripping
     and pump-and-treat with UV oxidation were identified as CMAs for the contaminated
     surficial aquifer groundwater at the Northeast Site. The CMAs were then evaluated
     against technical, environmental, human health, and institutional criteria according
     to the requirements of the HSWA Permit for the Pinellas Plant. Details on the
     screening of preliminary corrective action technologies and the CMA evaluations are
     provided in the CMS Report (DOE 1993c,d; 1994b).

4. AFFECTED ENVIRONMENT

4.1. WEATHER AND AIR QUALITY

4.1.1. Weather

The discussion below is based on data for Tampa, Florida, which is approximately 20
miles east of the Pinellas Plant. These data were provided primarily by the U.S.
Department of Commerce (NOAA 1991); the Pinellas County Department of Environmental
Management, Air Quality Division (PCAQD) (PCAQD 1989); and Trinity Consultants, Inc.
(Trinity 1990).
The weather of central Florida can be characterized as a subtropical savanna climate
with a primary wet season during the summer (June through September) and a secondary
wet season during the winter (December through February) (PCAQD 1989). Winters are
mild, and summers are long, rather warm, and humid. For the period 1961 through
1990, the average annual temperature was 72.3 F, and the average minimum and maximum
temperatures were 63.3 and 81.2 F, respectively (NOAA 1991). Median rainfall during
the primary wet season varies from 6 to 8 inches per month while median rainfall
during the winter ranges from 1.8 to 3 inches per month (PCAQD 1989). For the period
1961 through 1990, the average annual precipitation was 48.38 inches (NOAA 1991).
The 1990 wind rose for Tampa shows that the prevailing winds are from the east and
east-northeast. Winds from these directions occurred 29 percent of the year. The
next most prevalent winds are from the northeast, east-southeast, and west almost 24
percent of the year. The wind rose is omnidirectional, and wind from any direction
occurs no less than 2 percent of the year. The most common wind speeds are from 4.6
to 6.9 miles per hour (mph) and from 8.1 to 11.5 mph (Trinity 1990). The average wind
speed at the Tampa International Airport in 1988 was 7.9 mph, and average wind
speeds greater than 14 mph occur less than 1 percent of the year (PCAQD 1989). Winds
exceeding 25 mph are not common and usually occur only with thunderstorms or
tropical disturbances (NOAA 1991). Calm conditions with wind speeds less than 3 mph
occur only 5.8 percent of the time (Trinity 1990), while wind speeds less than 1 mph
occur less than 1 percent of the time (PCAQD 1989).
The potential for hurricanes and tropical storms exists in Pinellas County. The peak
hurricane frequency occurs in September with 3.4 storms per decade, and the
frequency of tropical storms is generally about the same as the frequency of
hurricanes (PCAQD 1989). Based on records from 1866 through 1982, the average
occurrence of a hurricane passing within a 50-nautical-mile radius of Tampa is 1 in
every 8.4 years. From 1950 to 1980, 50 tornado-like events occurred in Pinellas
County. Thirty-seven of these events were classified as tornadoes and 13 as
waterspouts coming ashore; most of these events (74 percent) occurred during April
through September. The probability of a tornado striking the Pinellas Plant is 1
chance in 2,326. Waterspouts moving ashore typically dissipate soon after reaching
land and would have very little potential for causing any damage at the plant (DOE
1983, 1990b).

4.1.2. Air Quality

The EPA has established the National Ambient Air Quality Standards (NAAQS) to protect
public health and welfare (40 CFR 50). The primary standards are designed to protect
the public health, and the secondary standards are designed to protect the public
welfare, including the effects of air pollution on visibility, materials, and
vegetation. The ambient air quality standards for the state of Florida and Pinellas
County are the same as the NAAQS (PC 1992a).
Stagnation does not occur in the Tampa Bay area because land-water temperature
differences always induce a wind circulation even if the large-scale wind gradient
is flat or zero. Consequently, the air quality in Pinellas County is among the best
in the nation for urban areas of similar size and density. Pinellas County continued
to meet the NAAQS for all pollutants during 1987 and 1988. For these two years, the
PCAQD reported 455 days with an Air Quality Index (AQI) of "Good" and 274 days with a
"Moderate" AQI; only 1 day was in the "Unhealthful" AQI level. The AQI is a
nation-wide standard method developed by the EPA for reporting daily air quality to
the public in a health-related manner. Data for 1989 and 1990 show horizontal trends
in the AQI and for all pollutants except for carbon monoxide, nitrogen dioxide, and
particulates. Carbon monoxide and particulates had nominally to moderately decreasing
trends. Nitrogen dioxide had a nominally increasing trend which is expected to
continue due to the growth in vehicle miles traveled in the county (PCAQD 1989,
1991).
The Pinellas Plant is a high-technology facility, and VOCs are exhausted from
approximately 200 chemical stacks and vents distributed over the roof of Building
100 (DOE 1991a). The Florida Air Toxics Permitting Strategy establishes a strategy
for controlling toxic air emissions from stationary sources to levels that will not
endanger public health. This policy includes the Florida Air Toxics Working List,
which establishes conservative 8-hour, 24-hour, and annual no-threat levels (NTLs)
for toxic chemicals and which is used by the FDEP and industry to determine air
toxics permitting needs. The strategy is based on comparing the predicted ambient
impact of individual toxic air contaminants with an estimate of the ambient exposure
level of each chemical that is not likely to cause appreciable health risks. The
policy has not been adopted as rule, but it is used as a guideline to identify
emission sources for air permit applications (FDEP 1991).
An air quality permit application for the Pinellas Plant (DOE 1992d) was prepared in
1992, and the FDEP issued an Air Emissions Permit, Permit Number A052-233355, in
1993 (FDEP 1993). Air contaminants that could be of concern are dichloromethane
(methylene chloride), trichloroethene, and 2,4,6-trichlorophenol. The ambient
concentrations of these contaminants at various plant boundary locations were
calculated using the Industrial Source Complex (ISC-2) dispersion model for
short-term applications (EPA 1992), a commercially available Gaussian plume model.
The highest calculated annual concentration of dichloromethane from Pinellas Plant
emissions was 0.0009 (9.0E-04) milligrams per cubic meter (mg/m3) at the south
property boundary. The north plant boundary is the boundary closest to the location
of the proposed groundwater treatment system; the calculated annual concentration of
dichloromethane at the north property boundary was less than 2.0E-04 mg/m3. The
annual NTL for dichloromethane is 2.1E-03 mg/m3. The calculated concentrations for
trichloroethene and 2,4,6- trichlorophenol were well below their respective NTLs at
all plant boundary locations (2,4,6-trichlorophenol does not have an established NTL,
so the NTL for phenol was used for comparison).

4.2. GEOLOGY

4.2.1. Soils

     The soil types at the Pinellas Plant are the Myakka Fine Sand, Wabasso Fine Sand, and
     Made-Land soils. These soils range in thickness from 5 to 50 ft across Pinellas
     County. The Myakka Fine Sands are gently sloping, moderately well drained soils that
     contain layers weakly cemented with organic matter at depths of 40 inches or less.
     The Myakka soils cover approximately 45 percent of the plant in the western half of
     the site. The Wabasso Fine Sands are nearly level, poorly drained soils, some of
     which have layers weakly cemented with organic matter. Light gray sands mixed with
     shell fragments are commonly found in the Wabasso soils between depths of about 50 to
     62 inches. The Wabasso soils are found in the far east portion of the plant,
     covering approximately 25 percent of the site. Made-Land soils consist of mixed sand,
     clay, hard rock, shells, and shell fragments that have been transported, reworked,
     and leveled during earth-moving activities. Made-Land soils are nearly level and
     excessively altered by man and are found beneath and north of Building 100 and west
     of the East Pond (SCS 1972).

4.2.2. Geology

Figure 4.1 shows a generalized geologic cross section in the vicinity of the Pinellas
Plant. Surficial deposits are terrace deposits consisting primarily of sands and
shelly sands that are classified as the Myakka and Wabasso soils. The Tampa Formation
has two parts: the lower part is known as the Tampa Limestone and is the uppermost
carbonate unit of the upper Floridan aquifer that totals several thousand feet in
thickness; the upper part of the Tampa Formation has a higher clay content and, with
the Hawthorn Formation, acts as a confining bed above the upper Floridan aquifer in
the immediate area of the Pinellas Plant. Well logs for the Pinellas Plant show that
the Hawthorn Formation and the clays of the upper Tampa Formation range from 55 to
78 ft in thickness. This variation in thickness is probably due to gradational
contact between the strata (i.e., the exact contact between the strata is not
clearly defined). Therefore, the confining bed consisting of the Hawthorn Formation
and the upper part of the Tampa Formation is collectively called the Hawthorn
Formation (DOE 1991b).
Figure (Page 4-4)
Figure 4.1
Sinkhole formation is common in Florida, and two types of sinkhole formation are
observed in Pinellas County. Cover-collapse sinkholes occur when a subsurface void
grows larger over time until the overlying sediment cannot support its own weight.
Cover-subsidence sinkholes develop gradually as limestone is removed through
dissolution and the overlying soil continuously fills the void. The depression
created at the surface is also slowly filled, and cover-subsidence sinkholes are
therefore more difficult to identify. The majority of sinkholes occur in northern
Pinellas County where the sediments mantling the limestone are 25 to 50 ft thick. Six
reported sinkholes are within a 5-mile radius of the Pinellas Plant; two of these
are classified as cover-subsidence sinkholes and could not be confirmed. The
probability of a sinkhole occurring at the Pinellas Plant is once every 1,340 years
(Beck and Sayed 1991).
Earthquakes have occurred in Florida. The earliest recorded and most severe
earthquake was on January 12, 1879, near St. Augustine; the only damage was minor
and in St. Augustine. Several other events of less intensity have been reported since
that time. There is no reasonable expectancy for damaging earthquakes at the
Pinellas Plant. The seismic risk map of the United States shows central and southern
Florida to be in Zone 0, which is defined as a "no damage" zone (Algermissen 1969).

4.3. HYDROLOGY

4.3.1. Surface Water

The terrain at the Pinellas Plant is generally flat. The total elevation difference
over the plant area is approximately 2 ft, and most of this variation is associated
with man-made structures. There is a slight downward slope in the southeast corner of
the plant area, but there are no topographic high points or lineaments that would
affect surface drainage. The plant is on the surface water divide of two drainage
subbasins. Flow in the northwestern half of the plant is to the west, and flow in the
southeastern half of the plant is to the southeast. Both of the subbasins drain into
Boca Ciega Bay and eventually into the Gulf of Mexico (Figure 1.1) (DOE 1991b).
No natural surface waters exist at the Pinellas Plant, but three man-made ponds, with
a combined surface area of approximately 5 acres, have been excavated initially as
borrow pits or for storm water retention. The East and West Ponds (Figure 1.2) were
excavated primarily as borrow pits and have capacities of 10 and 8 acre-ft,
respectively. The East and West Ponds have received various waste in the past and are
RCRA SWMUs (DOE 1991b). Both ponds were converted to storm water retention ponds and
now receive only storm water runoff (DOE 1987). Overflow from the East Pond
discharges through a county drainage pipe, south along Belcher Road, and then east
along Bryan Dairy Road until it empties into a county drainage ditch. Flow continues
southward, entering Cross Bayou Canal, Cross Bayou, and finally Boca Ciega Bay
(Figure 1.1). There is no discharge from the West Pond. The South Pond (Figure 1.2)
was constructed for storm water retention and has a capacity of 6 acre-ft. The
concrete-lined South Pond is connected to the East Pond by a closed underground
piping system that, if needed, would allow overflow from the East Pond to drain to
the South Pond. There is no evidence that any overflow drainage ever occurred, and
the South Pond is not a RCRA SWMU (DOE 1991b). Therefore, the South Pond is not
considered further in this EA.
The water in the East and West Ponds has been sampled at various times, including
during the RFI. Water quality investigations of the East and West Ponds in 1985 and
1987 indicated the presence of various contaminants including cadmium, chromium,
lead, manganese, mercury, pesticides, PCBs, and organic solvents (Fernandez 1985;
CH2M Hill 1987). RFI samples from the East Pond indicated mercury concentrations
slightly above the SDWA MCL and FDEP drinking water standard (DOE 1991b);
supplemental RFI sampling (Hammond 1992; Ingle 1992a,b) indicated that mercury was
not present above standards (DOE 1993b). RFI samples from the West Pond did not
contain concentrations of contaminants above SDWA MCLs and FDEP drinking water
standards. Based on surface water samples taken during the RFI, the East and West
Ponds have oxygen levels above the FDEP standard of 3.00 mg/L, which is sufficient to
support aerobic life. Most of the oxygen profiles of the ponds ranged from 7 to 10
mg/L, and this range is considered able to support healthy aquatic biological
conditions. Only oxygen levels 1 ft from the bottoms of the ponds showed any
depletion (DOE 1991b).
The Pinellas Plant is not in a floodplain, which is defined as an area having a 1 in
100 chance on average of being inundated due to rainfall in any year (DOE 1988; PCDP
1991a). The greatest amount of flood damage would be caused by hurricane tidal
flooding, and the U.S. Army Corps of Engineers has examined the Pinellas Plant in
relation to the design hurricane for the area. The design hurricane is the hurricane
that would occur in this area in 100 or more years. The maximum anticipated high
tide associated with the design hurricane would be approximately 14 ft above mean sea
level (MSL). The plant is several miles inland and has a minimum floor elevation of
18.5 ft above MSL; therefore, no damage from tidal flooding would be expected to
occur (DOE 1991a).
No municipal water supplies in Pinellas County are supplied by surface water due to
the limited dependable amount of surface water that is available and the high cost
of treatment to meet drinking water standards (SWFWMD 1988).

4.3.2. Groundwater

Pinellas County is in the west-central portion of the 7,300-square-mile Southern
West-Central Florida Groundwater Basin (SWCFGWB). The SWCFGWB contains a
multi-layered aquifer system that includes the surficial, intermediate, and Floridan
aquifers (SWFWMD 1988). In Pinellas County, the multi-layered, freshwater aquifer
system consists of the surficial and Floridan aquifers. The intermediate aquifer does
not exist in the county. Throughout the county, the surficial aquifer is unconfined
and close to the ground surface and, therefore, susceptible to contamination.
Infiltration to the surficial aquifer in Pinellas County is estimated to be 22 inches
per year. The surficial aquifer will not sustain adequate well yields, and the
surficial aquifer groundwater quality is generally poor due to high naturally
occurring concentrations of chloride, iron, and organic constituents. Consequently,
no municipal water supplies are taken from the surficial aquifer (SWFWMD 1988;
Fernandez and Barr 1983; DOE 1993c).
The Floridan aquifer can be divided into the lower and upper Floridan aquifers. The
lower Floridan aquifer does not contain potable water and is not considered further
in this EA. The upper Floridan aquifer is the principal and most productive source of
potable groundwater in Pinellas County, but withdrawal from the aquifer is
restricted due to the available amount of good quality water and the aquifer's
sensitivity to saltwater encroachment. Recharge rates to this aquifer in Pinellas
County have been estimated to be from zero to less than 2 inches per year (Geraghty
and Miller 1976; Stewart 1980; SWFWMD 1988).
The strata of concern underlying the Pinellas Plant are, in ascending order, the
Tampa Limestone (upper Floridan aquifer), Hawthorn Formation, and surficial aquifer.
The Tampa Limestone is the main source of water for Pinellas County and surrounding
counties; however, the fresh water zone in the upper Floridan aquifer is thin. The
Hawthorn Formation is an effective aquitard in most areas of Pinellas County but, if
breached, could allow flow from the surficial aquifer to the Tampa Limestone. The
surficial aquifer is not currently used to supply municipal water; it is unconfined,
shallow, and susceptible to contamination (DOE 1991b; SWFWMD 1988).
At the Pinellas Plant, the top of the surficial aquifer is from 0 to 4 ft below the
ground surface, and the aquifer has an average thickness of 32 ft. Horizontal and
vertical hydraulic conductivities determined during the RFI suggest that
stratigraphic control of groundwater flow in the aquifer is not a dominant process,
and the ability of water to flow horizontally and vertically in the surficial aquifer
is approximately the same. Storage coefficients for the surficial aquifer are also
small compared to expected values for an unconfined aquifer, indicating that the
effective porosity of the aquifer is low (DOE 1991b). A recharge area for the
surficial aquifer is east of the West Pond, corresponding to a drainage basin divide.
This divide is historically documented and is considered to be a natural groundwater
divide (Fernandez 1985). Data collected for the RFI suggest that the direction of
groundwater flow does not vary appreciably during the year, and the groundwater flow
pattern across the plant site is expected to remain relatively constant throughout
the year. Groundwater in the surficial aquifer flows east, southeast, and northwest
from the groundwater divide. The gradient to the northwest seems to have increased,
possibly due to the withdrawal of groundwater for the pump-and-treat project at the
4.5-Acre Site that is adjacent to the plant to the northwest. Other man-made
influences, including nearby drainage channels, may periodically act as zones of
recharge or discharge. The depth to the water table during the RFI ranged from less
than 0.5 to approximately 6 ft (DOE 1991b).
The Hawthorn Formation is approximately 70 ft thick in the wells drilled through it
at the Pinellas Plant. The Hawthorn Formation has a hydraulic conductivity that is
several orders of magnitude less than that of the surficial aquifer or upper Floridan
aquifer; therefore, the Hawthorn Formation is considered to act as an aquitard in
the area of the Pinellas Plant (DOE 1991b). Slow vertical movement of water through
the Hawthorn Formation has also been predicted by the U.S.Geological Survey (USGS).
The USGS estimated that the vertical movement of water through 37 ft of the Hawthorn
Formation would take 7,000 years (Hickey 1982).
The hydraulic properties of the upper Floridan aquifer have not been measured at the
Pinellas Plant. Regional potentiometric surface data indicate that there is little
variation in the potentiometric surface on a seasonal or annual basis and that
groundwater flow in the aquifer in the vicinity of the plant is primarily
east-northeast toward Tampa Bay (Barr and Schiner 1984; Barr 1984, 1985; Barr and
Lewelling 1986; Lewelling 1987). Recharge to the upper Floridan aquifer is very low
where the aquifer is overlain by thick, impermeable strata. Estimates of the recharge
rate to the aquifer at the Pinellas Plant are in the range of zero to less than 2
inches per year (SWFWMD 1988; Stewart 1980).
Since the upper Floridan aquifer is the primary source of drinking water in Pinellas
County, the vertical flow of water from the surficial aquifer through the Hawthorn
Formation is a concern. Potentiometric data collected during the RFI show that there
is a potential for the downward movement of water from the surficial aquifer to the
upper Floridan aquifer. The estimated recharge from the Hawthorn Formation to the
upper Floridan aquifer ranges from 0.36 to 0.52 inch per year (DOE 1991b), which is
consistent with other estimates for Pinellas County that range from zero to less than
2 inches per year (SWFWMD 1988; Stewart 1980). With the flow-restricting properties
of the Hawthorn Formation, appreciable migration through competent sections of the
Formation is unlikely. However, features such as sinkholes and abandoned water wells
that may breach the Formation could become hydraulic pathways from the surficial
aquifer through the Hawthorn Formation. No recent sinkholes have been found at the
Pinellas Plant, and the probability that a sinkhole will occur at the plant is
considered to be very low (see subsection 4.2.2). Two wells are known to have been
completed in the upper Floridan aquifer beneath Building 100. The well under the
north-central portion of the building is documented as grouted and sealed (DOE
1991b). There is no documentation on the abandonment of the other well, but
interviews of Pinellas Plant employees indicate that the well was sealed with
concrete.
Due to the potential head difference between the surficial aquifer and the upper
Floridan aquifer, the existence of a conduit or breach through the Hawthorn
Formation would be evident in the surficial aquifer as a cone of depression in the
water table surface. An examination of water levels measured at the Pinellas Plant
during four RFI sampling events indicate no areas of localized water table depression
at the plant. Furthermore, the Hawthorn Formation has a fairly high cation exchange
capacity (CEC) and a very low permeability, and positively charged metal ions are not
expected to migrate through the Hawthorn Formation due to this high CEC. Any
brecciated zone associated with a sinkhole would be expected to have geochemical
properties similar to the Hawthorn Formation, such as a high CEC. Therefore, downward
contaminant migration through the Hawthorn Formation to the upper Floridan aquifer
is considered to be unlikely. Three upper Floridan aquifer wells were sampled in 1988
and during the RFI and were consistently free of any contamination. These wells are
downgradient from the contaminated groundwater plume at the Northeast Site (DOE
1991b).
Pinellas County is one of 16 counties in the Southwest Florida Water Management
District, and groundwater from the Floridan aquifer provides over 95 percent of the
water used in the district (DOE 1991a). Some small private and commercial users
operate wells in permeable portions of the Hawthorn Formation, and available
information indicates that there are no permitted production wells completed in the
surficial aquifer (DOE 1991b). There are several municipal well fields in northern
Pinellas County. The closest well field is approximately 5 miles northwest of the
Pinellas Plant and has an average yield of 1.1 million gallons per day (SWFWMD 1988).
There are no municipal well fields in southern Pinellas County due to saltwater
intrusion in the upper Floridan aquifer. Pinellas County does not have adequate
freshwater resources within its boundaries to support current and future demands.
Consequently, about 90 percent of the municipal water supply is imported from
adjacent counties (Geraghty and Miller 1976; SWFWMD 1988).
An inventory of all wells within a 1-mile radius of the Pinellas Plant was compiled
from Southwest Florida Water Management District records. About 240 wells, ranging
from 1 inch to 10 inches in diameter, were identified for the nine land sections in
the vicinity of the plant, not including observation, test, or abandoned wells (CH2M
Hill 1987; DOE 1990a). Based on the reported screen depths for the wells, all of the
wells have been completed in the upper Floridan aquifer or in a permeable section of
the Hawthorn Formation. The wells are used primarily for agricultural (irrigation)
purposes, but domestic and recreational uses (e.g., lawn irrigation and swimming
pools) are common (DOE 1991b).
In 1990, the water usage in Pinellas County was approximately 102 million gallons per
day. Of this usage, 85.4 million gallons per day were for potable uses, 16.5 million
gallons per day were for agriculture, and 0.02 million gallons per day were for
industrial pumpage. The projected water demands for Pinellas County are 110 million
gallons per day in 1995 and 118 million gallons per day in the year 2000, which
represent increases of approximately 8 percent and 16 percent over the 1990 usage,
respectively (PCDP 1991b). The water used at the Pinellas Plant is provided by the
Pinellas County Water System, and the plant used a total of 74 million gallons of
potable water during 1990 (DOE 1991a). In the future, the greater demands for water
resources in the Pinellas County region will be met primarily by expanding well
fields tapping the upper Floridan aquifer. The surficial aquifer is not capable of
sustaining adequate well yields, and this aquifer is therefore not expected to
experience any increased usage (DOE 1991b).

4.4. FLORA AND FAUNA

4.4.1. Flora and Fauna

The Pinellas Plant is in an area that is classified as pine flatwoods, which is the
most extensive forest community in Pinellas County (PCDP 1991b). Pine flatwoods and
remnant or disturbed pine flatwoods occur outside and along the western,
northwestern, and southwestern boundaries of the Pinellas Plant (BDA 1992).
The pine flatwoods outside the western, northwestern, and southwestern boundaries of
the Pinellas Plant are dominated by slash pine with wax myrtle, saw palmetto, shrub
verbena, broomsedge, groundsel tree, blackberry, live oak, hat pins, Virginia
creeper, laurel oak, muscadine, gallberry, bracken fern, pawpaw, false goldenrod,
winged sumac, blueberry, blackroot, St. Johns wort, fetterbush, popcorn tree,
catbrier, and Chapman's oak. Wildlife observed using the pine flatwoods include the
osprey, mourning dove, fish crow, mockingbird, pine warbler, rufous-sided towhee, box
turtle, eastern black racer, armadillo, red-bellied woodpecker, and marsh rabbit (BDA
1992).
The majority of the Pinellas Plant has been developed. Undeveloped areas of the plant
are a large, maintained grass area and the East and West Ponds in the northern
portion of the plant and a maintained grass area and the South Pond along the
southern boundary of the plant. The grasses in the maintained areas are primarily
St. Augustine and crabgrass. Wildlife observed in the northern grass area include
mourning dove, boat-tailed grackle, mockingbird, starling, meadowlark, fish crow,
mottled duck, and killdeer. Monk parakeets were also observed flying over the
maintained grass areas, and there is a nesting colony in the Florida Power electrical
substation in the western portion of the plant (BDA 1992).
The periphery of the East Pond is dominated by cattails. Other vegetation at the edge
and on the bank of the East Pond includes pennywort, groundsel tree, Brazilian
pepper, dog fennel, hempweed, crabgrass, carpet-weed, Carolina willow, beggar ticks,
marsh fleabane, and ragweed. Wildlife using the East Pond include the common
moorhen, boat-tailed grackle, red-winged blackbird, common tern, snipe, green-backed
heron, Florida water snake, and laughing gull. Common plants such as pennywort,
hempweed, Carolina willow, and cattails were observed at the West Pond. Wildlife
associated with the West Pond include the great egret, common tern, double-crested
cormorant, little blue heron, red-winged blackbird, boat-tailed grackle, mourning
dove, Savannah sparrow, and marsh rabbit. There is an osprey nest at the top of a
light pole west of the West Pond (BDA 1992).
Environmental surveys of the East and West Ponds were conducted in 1989. Aquatic
species identified during the surveys included 19 species of phytoplankton and
zooplankton. Only two species of fish were identified. Neither of these species was a
game fish, and all of the fish captured were less than 5 centimeters in size. A
smooth softshell turtle was also captured (MEE 1989). During the RFI, turtles were
commonly observed in the East and West Ponds (DOE 1991b).

4.4.2. Threatened and Endangered Species

On July 17, 1991, the Fish and Wildlife Service (FWS) was consulted regarding
federally listed, threatened or endangered species that may be present at the
Pinellas Plant (Appendix A). According to the FWS, the Pinellas Plant is within the
historic range of the endangered Florida golden aster. If no pine scrub vegetation
exists at the plant, it is unlikely that this species is present. The threatened
Eastern indigo snake may inhabit the Pinellas Plant, and the endangered southern
bald eagle and wood stork may potentially feed in the storm water retention ponds at
the plant. The nearest bald eagle nest is about 2 miles southwest of the plant near
Cross Bayou. The eagles could feed as far north as the storm water retention ponds,
but their feeding is most likely concentrated in Cross Bayou. Contaminants from the
plant entering the Cross Bayou watershed could have some adverse effect on the
eagles, but other activities within the plant site are not likely to have a direct
effect on the nesting eagles (Carroll 1991). In 1992, the FWS stated that there had
been no change in the federally listed, threatened or endangered species potentially
present at the Pinellas Plant (PC 1992b).
The state of Florida provides endangered or threatened species protection and also
provides protection for species of special concern (SSC). SSC are those species
that, although relatively abundant and/or widespread in the state, may be especially
vulnerable to certain types of environmental change and/or have experienced
long-term population declines and could become threatened or endangered if not
protected. State-listed species (endangered, threatened, or SSC) with a potential for
occurring at the Pinellas Plant include the gopher tortoise, tricolored heron,
little blue heron, snowy egret, Florida burrowing owl, Sanibel lovegrass, Tampa
vervain, and scrub palmetto (BDA 1992).
No federally listed, threatened or endangered species were observed at the Pinellas
Plant. One little blue heron was observed foraging in the West Pond. This
medium-sized wading bird is state-listed as SSC due to the decrease in its numbers
over the past few decades and the recent loss of wetlands habitat throughout
Florida. Although the little blue heron was observed at the Pinellas Plant, no
habitat for rookeries (i.e., nesting and breeding areas) for these or other wading
birds occur at the plant. Several wading birds and waterfowl, including the little
blue heron, snowy egret, and tricolored heron, could occasionally use the storm water
retention ponds at any time of the year for foraging; however, there is a higher
potential for smaller wading birds to use these ponds. No bald eagles or wood storks
were observed at the plant, but these species may also forage in the storm water
retention ponds. Listed plant species are not expected to occur at the Pinellas
Plant, because the majority of the site has been disturbed, and because appropriate
habitat for the Florida golden aster does not exist at the plant (BDA 1992).

4.4.3. Wetlands

     The FWS has designated the East and West Ponds as wetlands (DOI n.d.). Public access
     to all of the ponds is restricted. Employees of the Pinellas Plant have access to
     the ponds, but the ponds are not used in any recreational capacity. There are no
     plans to use the ponds in the foreseeable future for any purpose other than storm
     water retention (DOE 1991b).

4.5. CULTURAL RESOURCES

     There are a number of sites of historical and archaeological significance in Pinellas
     County, but none of these sites is close to the Pinellas Plant. The closest cultural
     resource sites are the Long Bayou temple and burial mound and the Oakhurst Mound
     burial mound (archaeological sites), approximately 3 miles southwest of the plant
     (DOE 1983; PCDP 1991a). Consultation with the Florida State Historic Preservation
     Officer confirmed that no historical or archaeological sites listed or eligible for
     listing in the National Register of Historic Places are recorded or considered
     likely to be present within the Pinellas Plant boundaries (Percy 1991).

5. ENVIRONMENTAL IMPACTS

The environmental impacts of the proposed corrective action and the reasonable
alternatives to it are discussed in this section. The environmental components
(e.g., human health and groundwater) addressed in this section are limited to those
that may be affected by the corrective action alternatives. The environmental
impacts are based on conservative assumptions and impact assessment procedures and
thereby represent a realistic upper limit on the severity of the impacts that may
occur. The actual impacts that would occur would probably be less severe than those
identified here.
The cumulative environmental impacts of the proposed corrective action and other
actions at the Pinellas Plant are also discussed in this section. Other corrective
actions for contaminated surficial aquifer groundwater (i.e., for the 4.5-Acre Site
and Building 100 and West Fenceline Areas) would result in the same or similar
environmental impacts as would the proposed action, such as the temporary disturbance
of soils and the withdrawal of surficial aquifer groundwater. These impacts are
discussed in this section. Leasing all or portions of the Pinellas Plant to
commercial enterprises may also have environmental impacts. The impacts of commercial
leasing on human health, soils, surface water, flora and fauna, and cultural
resources were determined to be negligible and are not addressed in this section. The
impacts of commercial leasing on air quality, the withdrawal of surficial aquifer
groundwater, and the discharge of treated groundwater to the Pinellas County Sewer
System are of concern and are discussed in this section.

5.1. HUMAN HEALTH EFFECTS

     The average and maximum carcinogenic and noncarcinogenic risks for a future resident
     of the Northeast Site, in the absence of any corrective action (including the
     interim corrective action), were estimated to evaluate the human health risks from
     the contaminated groundwater at the Northeast Site. The estimates were performed in
     accordance with CERCLA guidance for the evaluation of human health (EPA 1989) and
     focused on the exposure to contaminants in surficial aquifer groundwater, which is
     not a primary drinking water source. The average and maximum observed concentrations
     of the COCs in surficial aquifer groundwater were used, and it was assumed that the
     future resident uses water from a contaminated onsite well for domestic purposes
     such as irrigation, swimming, and general cleaning. Due to the naturally poor quality
     of the surficial aquifer groundwater, it was further assumed that the future resident
     receives uncontaminated drinking water from a municipal supply. In this scenario,
     the future resident would be exposed to the COCs by the inhalation of COCs from
     contaminated groundwater and direct contact (dermal absorption) with contaminated
     groundwater.
     The estimated average carcinogenic risk from exposure during the childhood and adult
     years is 6 excess cancers in an exposed population of 100,000 persons (6E-05). The
     estimated maximum carcinogenic risk from exposure during the childhood and adult
     years is 2 excess cancers in an exposed population of 10 persons (2E-01). The actual
     risk would be below the maximum risk, but the maximum risk is of potential concern
     because it exceeds the EPA upperbound target carcinogenic risk of no more than 1
     excess cancer observed in a population of 10,000 people exposed (1E-04) (EPA 1988b)
     and the FDEP acceptable target carcinogenic risk of no more than 1 excess cancer
     observed in a population of 1,000,000 people exposed (1E-06). Exposure to the
     average observed concentrations of COCs would not result in the potential for
     noncarcinogenic public health risks (e.g., liver degeneration), but exposure to the
     maximum observed concentrations would have the potential for noncarcinogenic risks.
     As with the carcinogenic risk, the actual noncarcinogenic risk would be below the
     maximum risk.

5.1.1. Proposed Corrective Action

     The proposed corrective action would be complete in 30 years and would lower the
     concentrations of the COCs in the surficial aquifer groundwater to the MCLs for the
     Northeast Site. The MCLs for the Northeast Site are the SDWA MCLs or the FDEP
     drinking water standards for the COCs, whichever are more stringent (subsection
     3.1). The SDWA MCLs or the FDEP drinking water standards for the COCs are equal to or
     less than the contaminant concentrations that would achieve the EPA upperbound target
     carcinogenic risk of no more than 1E-04 excess cancer (EPA 1988b) or the FDEP
     acceptable target carcinogenic risk of no more than 1E-06 excess cancer. Therefore,
     1E-04 represents a realistic upper limit for the carcinogenic public health risks
     from drinking groundwater from the surficial aquifer after the proposed corrective
     action at the Northeast Site. The proposed corrective action would similarly reduce
     the potential for noncarcinogenic public health risks, and other corrective actions
     for contaminated surficial aquifer groundwater would further reduce public health
     risks. Again, use of the surficial aquifer as a drinking water supply is very
     unlikely due to the limited availability and naturally poor quality of the
     groundwater in the aquifer.

5.1.2. No Action

     The no action alternative would also lower the concentrations of the COCs in the
     surficial aquifer groundwater to the MCLs for the Northeast Site because the interim
     corrective measure would be continued. This would lower the public health risks from
     the contaminated groundwater to or below the EPA upperbound and FDEP acceptable
     target carcinogenic risks. However, the interim corrective measure probably could not
     withdraw groundwater at as large a rate as the proposed corrective action because it
     would share the groundwater treatment facility with the corrective measure for the
     4.5-Acre Site. This would result in a longer corrective action which would prolong
     the potential for public health risks. In addition, a less than optimum groundwater
     withdrawal rate for the interim corrective measure could present the potential for an
     increasing contaminant plume and possibly for offsite migration of the contaminant
     plume. This could increase the potential for public health risks from the
     contaminated surficial aquifer groundwater.

5.1.3. UV Oxidation

     The alternative action of pump-and-treat with UV oxidation would also lower the
     concentrations of the COCs in the surficial aquifer groundwater to the MCLs for the
     Northeast Site. This would lower the public health risks from the contaminated
     groundwater to or below the EPA upperbound and FDEP acceptable target carcinogenic
     risks within approximately the same time period as the proposed corrective action.
     Groundwater treatment with UV oxidation would involve the use of hydrogen peroxide
     and UV light. Due to this, there would be an extremely small potential for public
     exposure to hydrogen peroxide and UV light which could result in a very small
     increase in the public health risks from this alternative corrective action.

5.1.4. Corrective Action Worker Health

     The average and maximum carcinogenic and noncarcinogenic risks to a corrective action
     worker were also estimated for the proposed action. Again, the average and maximum
     observed concentrations of COCs were used. Corrective action workers could be exposed
     to the inhalation of the volatile and semivolatile COCs and to direct contact with
     the contaminated groundwater while working on the proposed corrective action (e.g.,
     performing maintenance on the groundwater treatment system). The estimated maximum
     carcinogenic risk is 5 excess cancers in an exposed population of 100 workers
     (5E-02); the estimated average carcinogenic risk is 5 excess cancers in an exposed
     population of 100,000 workers (5E-05). Only the estimated maximum carcinogenic risk
     exceeds the EPA upperbound carcinogenic risk of 1E-04 (EPA 1988b), but both the
     estimated maximum and average carcinogenic risks exceed the FDEP acceptable target
     carcinogenic risk of 1E-06. Exposure to the maximum observed concentrations of COCs
     would also have the potential for noncarcinogenic risks to corrective action workers.
     The actual carcinogenic and noncarcinogenic risks to corrective action workers would
     be below the maximum risks due to measures implemented as part of the site health
     and safety plan (e.g., the use of personal protective equipment).
     The no action and pump-and-treat with UV oxidation alternatives could also expose
     corrective action workers to inhalation of and direct contact with the same COCs at
     the same concentrations. Therefore, health risks to corrective action workers for
     these alternatives would be very similar to those for the proposed corrective
     action. The potential for health risks to corrective action workers would be
     prolonged for the no action alternative because the interim corrective measure might
     have to be performed longer due to a reduced groundwater recovery rate. The health
     risks to corrective action workers could be slightly increased for the UV oxidation
     alternative action because there would also be a potential for exposure of the
     workers to hydrogen peroxide and UV light.
     The potential exposure of corrective action workers to contaminants are and would be
     controlled by performing all corrective actions (e.g., 4.5-Acre Site and Building
     100 Area) in accordance with all applicable health and safety requirements and by
     implementing a site health and safety plan. Additional details on the applicable
     health and safety requirements and a site health and safety plan are provided in
     subsection 3.1.

5.2. AIR QUALITY

5.2.1. Proposed Corrective Action

     The proposed corrective action would result in combustion emissions from construction
     equipment and possibly fugitive dust from surface disturbing activities such as the
     installation of the groundwater treatment system. The combustion emissions from the
     construction equipment (e.g., hydrocarbons and carbon monoxide) would be temporary
     in duration (three weeks maximum) and small in amount due to the small quantity of
     equipment involved. The construction equipment would be equipped with the appropriate
     emissions controls. The amount of fugitive dust generated by the corrective action
     would also be small due to the nature of the soils and the small areas that would be
     disturbed. If necessary, fugitive dust would be controlled with water sprays. The
     future installation of new groundwater recovery and monitoring wells and associated
     piping for the proposed corrective action and other corrective actions (e.g.,
     Building 100 Area) would also result in combustion emissions and possible fugitive
     dust. These activities would be isolated incidents of very short duration, and the
     emissions and dust would be controlled with appropriate emissions controls and water
     sprays. Based on the existing air quality and wind circulation in Pinellas County
     (subsection 4.1), combustion emissions and fugitive dust from the proposed corrective
     action and other corrective actions would not be expected to result in any
     violations of air quality standards or any adverse effect on the AQI.
     The major air quality concern for the proposed corrective action would be the
     emission of VOCs and SVOCs from the air stripper in the Northeast Site groundwater
     treatment system. These emissions would occur in conjunction with the same type of
     emissions from the 4.5-Acre Site groundwater treatment system. This concern was
     evaluated by first examining the two operational scenarios for the groundwater
     treatment systems for the Northeast and 4.5-Acre Sites.
     The first operational scenario would be the operation of one groundwater treatment
     system at the 4.5-Acre Site for all of the corrective actions. This treatment system
     would operate at a capacity of 50 gallons per minute. The Northeast Site would
     contribute approximately 25 gallons per minute (the amount proposed for the separate
     Northeast Site groundwater treatment system), and the 4.5-Acre Site would contribute
     approximately 20 gallons per minute (the design capacity for the 4.5-Acre Site
     treatment system before the interim corrective action at the Northeast Site). The
     Building 100 and West Fenceline Areas could contribute 1 to 5 gallons per minute. The
     concentrations of the COCs in the groundwater at the Northeast Site are
     substantially higher than the concentrations of the COCs in the groundwater at the
     4.5-Acre Site and the Building 100 and West Fenceline Areas. Therefore, the
     contaminant concentrations entering the treatment system in this scenario would be
     less than those in the Northeast Site groundwater due to the dilution of the COCs by
     groundwater from the 4.5- Acre Site. The treatment of contaminated groundwater from
     the Building 100 and West Fenceline Areas would result in further dilution of the
     contaminants. Table V.1 shows the estimated concentrations of the COCs in the
     influent to the groundwater treatment system that is proposed for the final
     corrective action at the Northeast Site (DOE 1993c,d; 1994b). These estimated
     concentrations reflect dilution of the COCs in the Northeast Site groundwater by the
     simultaneous recovery of uncontaminated groundwater during the corrective action, but
     they do not reflect the additional dilution that would be caused by the groundwater
     from the 4.5-Acre Site and the Building 100 and West Fenceline Areas. For this
     operational scenario, the concentrations of the COCs in the influent to the 4.5-Acre
     Site treatment system would be expected to be less than those shown in Table V.1.

            Table V.1. Influent Contaminant Concentrations and Maximum Emissions Rates for
                                   the 4.5-Acre Site Air Strippers(a)
                                               Influent Concentration            Maximum Emission Rates
           Contaminant of Concern                  (ug/L)2                          (pounds per hour)(b)
       Benzene                                        50                            0.00125
       Dichloromethane                             3,000                            0.075
       Chloroethene                                1,000                            0.025
       1 ,2.trans.dichloroethene                     100                            0.0025
       Trichloroethene                             1,300                            0.0325
       4-methylphenol                              1,700                            0.0425
        a The influent contaminant concentrations are the estimated concentrations of the COCs in the 
          influent to the groundwater treatment system that is proposed for the final corrective 
          action at the Northeast Site.  The influent contaminant concentrations in micrograms per 
          liter (ug/L) were estimated by computer modeling used to simulate groundwater conditions 
          for the proposed Northeast Site corrective actions(subsection 5.4.2) (DOE 1993c, d; 1994b). 
          The influent contaminant concentrations reflect dilution of the contaminants by 
          uncontaminated groundwater but do not reflect additional dilution by groundwater from the 
          4.5-Acre Site and Building 100 and West Fenceline Areas.
        b it was assumed that the 50 gallons par minute capacity of the 4.5-Acre Site groundwater 
          treatment system would be provided by two air strippers operating in series. The maximum 
          emission rates were ceIculated asauming complete volatilization of all COCs.
     The second operational scenario would be the operation of two groundwater treatment
     systems for the corrective actions. One treatment system would be at the 4.5-Acre
     Site, and the other treatment system would be at the Northeast Site. The treatment
     system at the Northeast Site would also use an air stripper which would have a
     capacity of 25 gallons per minute. The concentrations of the COCs in the influent to
     the Northeast Site treatment system would be expected to be the same as or very
     similar to those shown in Table V.1. The 4.5-Acre Site treatment system would
     continue to treat contaminated groundwater from the 4.5-Acre Site and possibly from
     the Building 100 and West Fenceline Areas. The treatment system would operate at
     less than 50 gallons per minute (estimated maximum of 25 gallons per minute), and the
     concentrations of the COCs in the influent to the system would be substantially lower
     than those shown in Table V.1.
     Both of the operational scenarios described above would result in the emission of
     VOCs and SVOCs from air strippers in the groundwater treatment systems. The first
     scenario would create emissions from a single groundwater treatment system based on a
     system capacity of 50 gallons per minute and influent contaminant concentrations
     somewhat less than those shown in Table V.1. The second scenario would include two
     separate groundwater treatment systems which would have a combined capacity of
     approximately 50 gallons per minute. The concentrations of the COCs in the influent
     to one treatment system would be the same as or very similar to those shown in Table
     V.1, and the influent contaminant concentrations for the other treatment system
     would be less than those shown in Table V.1. Based on the treatment system capacities
     and the influent contaminant concentrations for the two scenarios, the emission of
     VOCs and SVOCs by the first operational scenario would be expected to be greater
     than that by the second scenario. Furthermore, the first scenario would have a single
     point source of emissions while the second scenario would have two separate point
     sources of emissions. Two separate point sources of emissions would result in lower
     concentrations of contaminants in the ambient air due to increased dispersion of the
     contaminants, the orientation of the point sources relative to the Pinellas Plant
     boundary, and the prevailing wind pattern at the Pinellas Plant. To be conservative
     in the assessment of air quality impacts, the first operational scenario was analyzed
     using a groundwater treatment system capacity of 50 gallons per minute and the
     influent contaminant concentrations shown in Table V.1.
     The air quality impacts of the first operational scenario were analyzed using the
     ISC-2 dispersion model (EPA 1992) to calculate the concentrations of the COCs that
     would occur at various Pinellas Plant boundary locations due to the air stripper
     emissions. Table V.1 shows the concentrations of the COCs in the treatment system
     influent and the maximum air stripper emission rates that were used in the emissions
     calculations. It was assumed that the 50 gallons per minute capacity of the 4.5-Acre
     Site groundwater treatment system would be provided by two air strippers operating
     in series. It was also assumed that the COCs volatilized completely in the air
     strippers and that each air stripper was equipped with an emissions tower 42.5 ft in
     height, which is the height of the existing 4.5-Acre Site air stripper tower. Other
     assumptions and model inputs were as follows:
     - Meteorological data from the Tampa International Airport for 1982 through 1986 were
       used to establish a meteorological data file for input to the model.
     - Emissions from the air strippers are continuous (8,760 hours per year). A generic
       emission rate of one gram per second was used.
     - The diameter of the air stripper towers (2 ft) and flow rate (400 standard cubic ft
       per minute) were used to calculate the exit velocities of the emissions in meters
       per second. Due to the 4.5-Acre Site's characteristics, the effects of buildings
       (i.e., downwash) was not considered, and the modeling was performed in the urban
       mode.
     - The height of the concentration calculations was ground level.
     - The modeling output was placed on a 330-ft, two-dimensional grid for the
       determination of critical receptor locations and the concentration at the south
       Pinellas Plant boundary location.
     The ISC-2 modeling was used to establish the location of the critical receptor, which
     would be the receptor that would receive the maximum impact from the 4.5-Acre Site
     air stripper emissions. For the annual and 24-hour contaminant concentrations, the
     critical receptor was approximately 330 ft due west of the 4.5-Acre Site air
     strippers; the critical receptor for the 8-hour contaminant concentrations was
     approximately 330 ft northwest of the air strippers. These critical receptor
     locations are within the 4.5-Acre Site, which is leased and is therefore not
     considered to be DOE property. Due to the heights of the air stripper towers and the
     exit velocities of the emissions, the maximum contaminant concentrations would not
     occur closer to the 4.5-Acre Site air strippers than approximately 330 ft and would
     therefore not occur at actual Pinellas Plant boundary locations. The ISC-2 modeling
     was also used to establish the approximate area of the emissions impacts.
     Contaminant concentrations would be less than the respective NTLs up to approximately
     2970 ft to the west, approximately 1980 ft to the north, approximately 1650 ft to
     the east, and approximately 3300 ft to the south of the 4.5-Acre Site air strippers.
     Contaminant concentrations beyond this impact area would be essentially zero. The
     geometry of the air emissions impact area would be due primarily to the relative
     frequencies of the omnidirectional winds at the Pinellas Plant (subsection 4.1.1).

Table V.2.  Calculated Contaminant Concentrations at the Critical Receptor Locations Versus No Threat Levelsa
     Contaminant of Concern       8-Hour            8-Hour NTL     24-Hour           24-Hour NTL     Annual            Annual NTL
                                  Concentration                    Concentration                     Concentration     
     Benzene                      4.7E-05           0.03           2.3E-05           0.0072          3.8E-06           0.00012
     Dichloromethaneb             3.0E-03           1.74           1.4E-03           0.4176          2.3E-04           0.0021
     Chloroetheneb                9.5-04            0.13           4.6E-04           0.0312          7.8E-05           0.00014
     1,2-trans-dichloroethene     9.5E-05           7.93           4.6E-05           1.9             7.8E-06           NAc
     Trichloroethene              1.2E-03           2.69           6.0E-04           0.6456          1.0E-04           NAc
     4-methylphenold              1.6E-03           0.19           7.9E-04           0.0456          1.3E-04           0.003
a The contaminant concentrations are due to emissions from the 4.5-Acre Site air strippers only.  The contaminant concentrations 
  were calculated using the ISC-2 dispersion model (EPA 1992).  The NTLs are from the Florida Air Toxics Working List (FDEP 1991).  
  All contaminant concentrations and NTLs are in mg/m3.  The critical receptor for the annual and 24-hour contaminant 
  concentrations is approximately 330 ft west of the 4.5-Acre Site air strippers.  The critical receptor for the 8-hour 
  contaminant concentrations is approximately 330 ft northwest of the 4.5-Acre Site strippers.  
b Dichloromethane is methylene chloride.  Chloroethene is vinyl chloride.  
c There is no annual NTL for 1,2-trans-dichloroethene or trichloroethene.
d 4-methylphenol was evaluated as phenol because there are no NTLs for 4-methylphenol.
NTL - no threat level
ISC-2 - Industrial Source Complex dispersion model 
     Table V.2 shows that all of the calculated contaminant concentrations at the critical
     receptor locations would be below their respective NTLs. The calculated annual
     concentration of dichloromethane (methylene chloride) is 2.3E-04 mg/m3, which is
     slightly greater than the same concentration calculated for emissions from the
     Pinellas Plant (Building 100) itself (2.0E-04 mg/m3 in subsection 4.1.2) (DOE 1992d).
     Combined annual dichloromethane concentrations at the western critical receptor
     location and south Pinellas Plant boundary location due to emissions from the
     Pinellas Plant (Building 100) and the 4.5-Acre Site air strippers are shown in Table
     V.3. The combined dichloromethane concentrations at these two locations are below
     the respective NTLs. The highest combined concentration, 9.0E-04 mg/m3, is at the
     south Pinellas Plant boundary location, which also has the highest calculated
     dichloromethane concentration due to Pinellas Plant (Building 100) emissions
     (subsection 4.1.2) (DOE 1992d). The combined concentration at this location is
     approximately two times greater than the combined concentration at the western
     critical receptor location (less than 4.3E-04 mg/m3). The 4.5-Acre Site air strippers
     would contribute essentially nothing to the combined dichloromethane concentration
     at the south Pinellas Plant boundary location.
     If all or portions of the Pinellas Plant were leased to commercial enterprises, these
     enterprises may involve processes that create air emissions, including emissions of
     VOCs and SVOCs. These air emissions would be documented and regulated under the
     plant's existing Air Emissions Permit (FDEP 1993), and the responsible enterprises
     would obtain any necessary permit modifications or additional permits that would be
     required by the FDEP or PCAQD to demonstrate compliance with air missions
     requirements and to ensure compliance with the NAAQS and the Florida State
     Implementation Plan. Enterprises that might be located at the Pinellas Plant would be
     reviewed by the DOE with respect to their impacts on air emissions, and the DOE
     would conduct additional NEPA review if necessary. Enterprises that would warrant
     substantial permit modifications or new permits would be closely monitored or would
     not be allowed at the plant (DOE 1994d).

5.2.2. No Action

     The no action alternative would consist of continuing the interim corrective action
     for the Northeast Site. Contaminated surficial aquifer groundwater would continue to
     be recovered and treated in the groundwater treatment system for the 4.5-Acre Site.
     Contaminated groundwater from the 4.5-Acre Site, and possibly from the Building 100
     and West Fenceline Areas, would also be treated in this system. The treatment system
     uses an air stripper to remove VOCs and SVOCs from the contaminated groundwater, and
     the air stripper emits VOCs and SVOCs, primarily dichloromethane and chloroethene.
     The existing groundwater treatment system for the 4.5-Acre Site has a water inflow
     capacity of 20 gallons per minute, and the DOE proposes to increase this capacity to
     50 gallons per minute to provide sufficient capacity for the final corrective action
     at the 4.5-Acre Site, the interim corrective action at the Northeast Site, and other
     possible corrective actions (e.g., Building 100 Area). Based on the previous
     analysis of contaminant emissions from two air strippers operating at 50 gallons per
     minute, the use of the 4.5-Acre Site groundwater treatment system for continuing the
     interim corrective action and other corrective actions would not result in
     exceedances of the NTLs for the COCs in the surficial aquifer groundwater.

                      Table V.3. Combined Annual Dichloromethane Concentrations(a)
                                              Concentration at Critical Concentration at
                                                 Property Boundary        South-Property
                  Contamination Source                Location(b)       Boundary Location(c)
       Pinellas Plant (Building 100)                 <2.0E-04               9.0E-04
       4.5-Acre Site air strippers                    2.3E-04               0(d)
       Combined sources                              <4.3E-04               9.0E-04
       a Dichloromethane is methylene chloride. All concentrations are in mg/m3.
       b The critical receptor for the annual contaminant concentrations is approximately 
         330 ft west of the 4.5-Acre Site air strippers.
       c The south Pinellas Plant boundary location has the highest calculated dichloromethane 
         concentration due to Pinellas Plant (Building 100) emissions (subsection 4.1.2) 
         (DOE 1992d).
       d presentation of the air dispersion modeling results on a 330-ft grid shows that there 
         is essentially no dichloromethane contribution from the 4.5-Acre Site air strippers 
         at the south Pinellas Plant boundary location.
       < less than

5.2.3. UV Oxidation

The alternative action of pump-and-treat with UV oxidation would use UV oxidation
instead of air stripping to remove the volatile and semivolatile COCs from the
contaminated surficial aquifer groundwater. Ideally, the UV oxidation process would
degrade the COCs to carbon dioxide, water, and inorganic salts, and there would be
no air emissions depending on the type of UV oxidation system used. However, studies
have shown that certain organic contaminants such as 1,1-dichloroethane are difficult
to oxidize and are removed from the groundwater by air stripping during the UV
oxidation treatment (EPA 1990b). Several of the COCs in Northeast Site groundwater
(e.g., benzene and trichloroethene) would be readily oxidized and easily removed by
UV oxidation. The COC dichloromethane is very similar to 1,1-dichloroethane, and it
is believed that this contaminant would be removed from the surficial aquifer
groundwater by air stripping during the UV oxidation process. Therefore, a
groundwater treatment system with UV oxidation would be expected to produce some air
emissions (DOE 1993c). These air emissions should be less than those produced by air
stripping and should not result in exceedances of the NTLs for the COCs in Northeast
Site groundwater. Depending on the type of UV oxidation system used, the UV oxidation
process could also create emissions such as hydrogen chloride which would require
the use of emissions controls.

5.3. SOILS

5.3.1. Proposed Corrective Action

     The proposed corrective action would result in the temporary disturbance of
     approximately 1.5 acres of soils from the installation of the staging area, a
     groundwater containment measure, groundwater recovery wells, piping, and groundwater
     treatment system. Most of the affected soils would be Made-Land soils, but a small
     area of Myakka Fine Sands would be affected in the western portion of the Northeast
     Site. All of these soils have been disturbed previously by the early dairy farm
     activities, normal Pinellas Plant operations, and by the RFI and interim corrective
     action activities. Additional small areas of soils could be temporarily disturbed in
     the future for the installation of new groundwater recovery and monitoring wells
     (0.01 acre per well) and piping from new recovery wells to the groundwater treatment
     systems (0.03 acre per 100 ft of piping) for the proposed corrective action and
     other corrective actions (e.g., Building 100 Area). All areas disturbed during the
     corrective actions would be restored to as close to their original condition as
     possible and revegetated.

5.3.2. No Action

     The no action alternative would not result in any new disturbance of soils because
     the recovery wells, piping, and groundwater treatment system for the Northeast Site
     interim corrective measure have already been installed. Small areas of soils could be
     temporarily disturbed in the future for the installation of additional groundwater
     recovery and monitoring wells and any associated piping. All disturbed areas would be
     restored to as close to their original condition as possible and revegetated.

5.3.3. UV Oxidation

     This alternative action would require the same equipment and facilities as the
     proposed corrective action except that a UV oxidation unit would be used in the
     groundwater treatment system instead of an air stripper. Therefore, this alternative
     would result in the same temporary disturbance of soils as the proposed corrective
     action. Additional small areas of soils could be temporarily disturbed in the future
     for the installation of new groundwater recovery and monitoring wells and associated
     piping. All disturbed areas would be restored to as close to their original condition
     as possible and revegetated.

5.4. HYDROLOGY

5.4.1. Surface Water

     The proposed corrective action, no action, the UV oxidation alternative action, or
     other corrective actions (e.g., Building 100 Area) would have very little effect on
     surface water at the Northeast Site or Pinellas Plant. Surface disturbance associated
     with corrective action activities (e.g., installation of the groundwater containment
     measure) could cause a slight increase in erosion during heavy precipitation.
     However, the terrain at the Pinellas Plant is generally flat, and the areas disturbed
     during the corrective actions would be restored as soon as possible. The disturbed
     areas would be graded to conform to the surrounding land surface and to avoid the
     ponding of surface runoff, and the areas would then be revegetated with plant
     species common to the Pinellas Plant.
     Groundwater modeling of the proposed corrective action indicates that pumping of the
     surficial aquifer could potentially lower the level of the water in the East Pond.
     This potential surface water impact could therefore result with the proposed action,
     no action, the UV oxidation alternative action, or other corrective actions (e.g.,
     Building 100 Area). The potential lowering of the water level in the East Pond is
     discussed further in subsection 5.5.3.

5.4.2. Groundwater

     Proposed Corrective Action
     During the CMS, groundwater conditions at the Northeast Site were simulated by
     computer modeling to evaluate the fate of the contaminant plume during the proposed
     corrective action. Two COCs, dichloromethane and chloroethene, were chosen for the
     computer modeling due to their detected concentrations during groundwater sampling
     in 1991 and 1992. The concentrations of these COCs greatly exceed the concentrations
     of the other COCs identified for the Northeast Site and their use in the computer
     modeling provides conservative estimates of the fate of the contaminant plume. The
     assumptions and procedures for the groundwater modeling are described in detail in
     the CMS Report (DOE 1993c,d; 1994b).
     The results of the groundwater modeling indicate that four groundwater recovery wells
     could be pumped at a total rate equal to or less than 6,358 gallons per day to keep
     any well from going dry. At this rate, the total volumes of contaminated groundwater
     recovered from the surficial aquifer in 20 and 30 years of corrective action would
     be approximately 46 and 70 million gallons, respectively. These volumes of
     groundwater are approximately 10 percent to 12 percent less than those that would be
     recovered if the soil/bentonite slurry wall was not installed at the northern
     boundary of the Northeast Site. The recovered groundwater would be treated and then
     discharged to the Pinellas County Sewer System (DOE 1993c,d; 1994b). However, no
     municipal water supplies are taken from the surficial aquifer because the groundwater
     is of limited availability and generally of poor quality due to naturally occurring
     constituents (SWFWMD 1988; Fernandez and Barr 1983; DOE 1993c).
     Within the Northeast Site, the recovery of contaminated groundwater would lower the
     water level in the surficial aquifer approximately 15 to 19 ft. This lowering of the
     groundwater level would extend beyond the boundaries of the Northeast Site and the
     Pinellas Plant, but the soil/bentonite slurry wall would minimize the drawdown
     beyond the northern plant boundary. The recovery of contaminated groundwater and
     installation of the slurry wall would also change the direction of groundwater flow
     in the surficial aquifer. The direction of groundwater flow in the surficial aquifer
     is generally to the east, but this direction would be reversed as flow components
     from the north, south, and west would be added as pumping of the recovery wells
     progressed. The slurry wall would minimize the flow component from the north and
     would thereby lessen the volume of groundwater recovered during the corrective
     action by approximately 10 percent to 12 percent (DOE 1993c,d, 1994b).
     Steady-state groundwater flow conditions were used in the computer modeling to
     calculate the movement of the contaminant plume with the soil/bentonite slurry wall
     installed and five recovery wells being pumped. The peak combined model concentration
     of 3,150,000 g/L of dichloromethane and chloroethene was reduced to 10,314 g/L after
     10 years of pumping, and the highest combined concentrations of these COCs after 20
     and 30 years of pumping were calculated to be 2,018 and 1,396 g/L, respectively. The
     combined concentration of 1,396 g/L after 30 years of pumping is distorted due to
     the way the computer modeling simulates dispersion of the contamination into the
     slurry wall. In reality, the slurry wall would act as a barrier to groundwater flow
     and contaminant transport, so the predicted combined concentration of
     dichloromethane and chloroethene after 30 years of pumping would likely be less than
     1,396 g/L (DOE 1993c,d, 1994b).
     After completion of the proposed corrective action, recharge of the surficial aquifer
     would restore the groundwater level and flow direction to previous conditions.
     Infiltration to the surficial aquifer in Pinellas County is estimated to be 22 inches
     per year (SWFWMD 1988; Fernandez and Barr 1983). Based on the groundwater modeling,
     which showed the surficial aquifer reaching steady state within 4 to 6 years of
     pumping, it is estimated that the groundwater level and flow direction in the
     surficial aquifer would be restored to previous conditions in less than 10 years. The
     soil/bentonite slurry wall would remain permanently at the northern boundary of the
     Northeast Site and could slightly alter future groundwater flow from or to the
     north. However, it is anticipated that the general direction of groundwater flow to
     the east would be restored (DOE 1993c,d, 1994b).
     As stated in subsection 3.1, a slurry wall was assumed to be the proposed groundwater
     containment measure for this EA because it would remain permanently at the Northeast
     Site. If an infiltration gallery or shallow well injection were implemented as the
     groundwater containment measure, the impacts to groundwater conditions at the
     Northeast Site would be slightly different from those from the slurry wall. Treated
     groundwater from the corrective action would be recirculated into the surficial
     aquifer through the infiltration gallery or shallow well injection. This could
     preclude or minimize the lowering of the groundwater level and changes in the
     direction of groundwater flow in the surficial aquifer. The recirculation of treated
     groundwater into the aquifer could also increase flushing of the aquifer and thereby
     decrease the time needed to reduce the concentrations of the COCs to the MCLs.
     However, an infiltration gallery or shallow well injection may not be as effective as
     a slurry wall in preventing contaminant migration from possible unknown sources on
     adjacent properties. The infiltration gallery or shallow well injection would be
     removed upon completion of the corrective action, and recharge of the surficial
     aquifer would restore the groundwater level and flow direction to previous
     conditions.
     If no corrective action were taken at the Northeast Site, the contaminant plume would
     remain in its present location and condition, and the potential for offsite
     migration of the plume would continue to exist for an indefinite period of time. This
     scenario was also simulated using the computer modeling to estimate the contaminant
     movement over a period of 30 years. With no corrective action, the peak model
     concentration of dichloromethane and chloroethene would be reduced to 1,260,300 and
     587,520 g/L after 10 and 30 years, respectively. After 50 years, the peak model
     concentration would have decreased to 3,056 g/L. These decreases in the
     concentrations of the COCs would be the result of natural dispersion of the
     contamination within the surficial aquifer. However, after 30 years, the groundwater
     contamination would have spread both north and south within the Northeast Site and
     would encroach upon the East Pond. The combined concentration of dichloromethane and
     chloroethene at the northern boundary of the Northeast Site would have increased from
     the present concentration of less than 1 g/L to 8 g/L during this 30-year period
     (DOE 1993c,d, 1994b).
     Corrective action at the 4.5-Acre Site involves the surficial aquifer as would other
     corrective actions at the Pinellas Plant (e.g., Building 100 Area). These corrective
     actions do and would increase the amount of groundwater withdrawn from the aquifer
     which would increase or alter the changes in the groundwater conditions that would
     result from the proposed corrective action (i.e., lowering the water level and
     changing the groundwater flow direction). No municipal water supplies are taken from
     the surficial aquifer because the groundwater is of limited availability and
     generally of poor quality due to naturally occurring constituents (SWFWMD 1988;
     Fernandez and Barr 1983; DOE 1993c). After completion of the corrective actions,
     recharge of the surficial aquifer would restore the groundwater level and flow
     direction to previous conditions. Other corrective actions for contaminated
     surficial aquifer groundwater at the Pinellas Plant would reduce the concentrations
     of contaminants in the groundwater faster than natural dispersion.
     The treated groundwater from the proposed corrective action would be pumped to the
     Pinellas Plant wastewater neutralization facility for final discharge into the
     Pinellas Country Sewer System. In 1991, 1992, and 1993, the total wastewater
     discharges from the Pinellas Plant into the sewer system were approximately 250, 90,
     and 78 million gallons, respectively. The decrease in discharged wastewater from 1991
     to 1993 was due to decreased production activities at the plant. The volumes of
     groundwater treated in the 4.5-Acre Site treatment system during these same years
     were approximately 2.5, 3.4, and 8.7 million gallons, respectively. The 1992 and 1993
     volumes of treated groundwater included surficial aquifer groundwater from both the
     Northeast and 4.5-Acre Sites. If the groundwater treatment system for the Northeast
     Site was operating at 25 gallons per minute and if the capacity of the 4.5-Acre site
     treatment system was increased to 50 gallons per minute, the total volume of treated
     groundwater pumped to the wastewater neutralization facility would be approximately
     39.4 million gallons per year. This volume of treated groundwater would represent
     more than a 400-percent increase in the volume of treated groundwater discharged in
     1993 (8.7 million gallons) and would represent approximately 50 percent of the total
     Pinellas Plant wastewater discharge in 1993 (78 million gallons). It is very
     unlikely that both of the groundwater treatment systems for the Northeast and
     4.5-Acre Sites would operate at maximum capacities for 365 days per year. The
     groundwater treatment system for the 4.5-Acre Site would probably operate at a
     maximum capacity of only 30 gallons per minute even if contaminated groundwater from
     the Building 100 and West Fenceline Areas were being treated in the system. There
     would be periodic shutdowns of each system for maintenance and fluctuations in the
     treatment flow rates of each system because the groundwater recovery wells do not
     pump continuously. Each groundwater recovery well automatically stops pumping when
     the groundwater in the well is lowered to a certain level. If the volume of treated
     groundwater to be discharged to the sewer system would increase the total Pinellas
     Plant wastewater discharge by more than 10 percent, the Pinellas County Sewer System
     would be notified 30 days prior to the increase in accordance with the requirements
     of the plant's Industrial Wastewater Discharge Permit (PCSS 1994).
     If all or portions of the Pinellas Plant were leased to commercial enterprises, these
     enterprises may involve processes that create wastewater that would be discharged
     into the Pinellas County Sewer System. These discharges would be subject to the
     plant's existing Industrial Wastewater Discharge Permit (PCSS 1994), and potential
     commercial enterprises would be required to demonstrate that any wastewater
     discharges would meet the existing discharge standards. The DOE provides information
     to the Pinellas County Sewer System before initiating additional processes at the
     plant, and separate information would be provided for each potential enterprise or
     new process. If any potential process were substantially different than ongoing
     processes, the Industrial Wastewater Discharge Permit may require modification. Any
     modifications of the existing permit would be coordinated with the Pinellas County
     Sewer System and Pinellas County Water Quality Division, and the DOE would conduct
     additional NEPA review if necessary. If any potential process would increase the
     total Pinellas Plant wastewater discharge by more than 10 percent, the Pinellas
     County Sewer System would be notified 30 days prior to the increase in accordance
     with the Industrial Wastewater Discharge Permit (DOE 1994d).
     No Action
     The no action alternative would continue the interim corrective action for the
     Northeast Site, and groundwater would continue to be recovered from the surficial
     aquifer and treated. Therefore, no action would have impacts on groundwater very
     similar to those of the proposed corrective action. The no action alternative would
     require the use of the groundwater treatment system that is being used for the
     4.5-Acre Site corrective action. This treatment system does not have enough capacity
     for the optimum groundwater recovery rates of both corrective actions; therefore,
     one or both of the corrective actions would have to be operated at less than the
     optimum groundwater recovery rate. This would extend the time required for one or
     both of the corrective actions to be completed and could present the potential for
     offsite migration of contaminated groundwater. It is anticipated that a less then
     optimum groundwater recovery rate for either corrective action would still permit
     onsite containment of the contaminated groundwater and thereby preclude or minimize
     this potential.
     UV Oxidation
     This alternative action would involve the same recovery and treatment of surficial
     aquifer groundwater as the proposed corrective action. Therefore, the groundwater
     impacts of this alternative action would be the same as the proposed action. Due to
     the types and concentrations of COCs in the surficial aquifer groundwater, it is
     possible that some of the COCs would not be completely removed by the UV oxidation
     process. This could require additional treatment processes or careful and continued
     manipulation of the operating parameters for the groundwater treatment system. This
     could, in turn, increase the time required for completion of the corrective action
     and prolong the environmental impacts of the corrective action.

5.5. FLORA AND FAUNA

5.5.1. Flora and Fauna

Proposed Corrective Action
The proposed corrective action would temporarily disturb approximately 1.5 acres of
land for the installation of the staging area, soil/bentonite slurry wall, and the
groundwater recovery wells and treatment system and associated piping. Additional
small areas of land could be similarly disturbed in the future for the installation
of new groundwater recovery and monitoring wells and associated piping for the
proposed corrective action and other corrective actions (e.g., Building 100 Area).
Most, if not all, of the land that would be disturbed has been previously disturbed
but has been revegetated and supports grasses (BDA 1992). All areas disturbed by the
corrective actions would be restored and revegetated with plant species common to
the Pinellas Plant, such as St. Augustine grass.
Most of the wildlife observed at the Northeast Site and East Pond were different
species of birds and waterfowl, and it is doubtful that many, if any, of these
species are permanent residents of the Northeast Site (BDA 1992). The noise, land
disturbance, and human activity associated with the installation of the proposed
corrective action would temporarily disturb wildlife at the Northeast Site and East
Pond; however, these activities would occur for only 3 weeks. Similar disturbance of
wildlife species at the Northeast Site could occur in the future during the
installation of new groundwater recovery and monitoring wells and associated piping.
These activities would be performed infrequently and would be of very short
duration. Long-term operation of the corrective action could result in the
disturbance of wildlife species at the Northeast Site and could possibly cause the
permanent displacement of any resident wildlife species. Any displaced species would
probably relocate to other areas of the Pinellas Plant or to nearby similar habitat.
Any disturbance or permanent displacement of wildlife species during long-term
operation of the corrective action would be doubtful, because wildlife species at the
Pinellas Plant seem to adapt to normal plant operations, as evidenced by the osprey
nest on the light pole west of the West Pond (BDA 1992).
The installation and long-term operation of multiple corrective actions for
contaminated surficial aquifer groundwater could disturb or permanently displace
wildlife species at the Pinellas Plant. Displaced species would probably relocate to
other areas of the plant or to nearby similar habitat. Permanent displacement of any
wildlife species is doubtful. It is doubtful that many, if any, of the wildlife
species observed at the plant are permanent residents, and wildlife species at the
plant seem to adapt to normal plant operations.
No Action
No action would not result in any new temporary disturbance of vegetation and
wildlife because the equipment and facilities required for this alternative have
already been installed. The future installation of new or additional groundwater
recovery and monitoring wells and associated piping could temporarily disturb
vegetation and wildlife. These activities would be performed infrequently and would
be of short duration. All disturbed areas would be restored and revegetated with
plant species common to the Pinellas Plant. Due to a less than optimum groundwater
recovery rate, completion of the interim corrective measure for the Northeast Site
could take longer than the proposed corrective action. This would extend the
long-term disturbance of wildlife species and possible permanent displacement of any
resident wildlife.
UV Oxidation
This alternative action would have the same impacts on vegetation and wildlife as the
proposed corrective action. All disturbed areas would be restored and revegetated
with plant species common to the Pinellas Plant.

5.5.2. Threatened and Endangered Species

     No federally or state-listed, threatened or endangered plant or wildlife species were
     observed at the Pinellas Plant. One little blue heron, a state-listed SSC, was
     observed at the West Pond. Wading birds and bald eagles could forage in the storm
     water retention ponds at any time, but these species are most likely transient at
     the Pinellas Plant (BDA 1992). Installation and long-term operation of the proposed
     corrective action, no action, the alternative action, or other corrective actions for
     contaminated surficial aquifer groundwater (e.g., Building 100 Area) could
     temporarily disturb any wading birds and bald eagles foraging in the storm water
     retention ponds, but there are adequate nearby feeding locations, such as Cross
     Bayou. Therefore, the proposed action, no action, the alternative action, or other
     corrective actions for contaminated surficial aquifer groundwater would not have any
     effect on any threatened or endangered species.

5.5.3. Wetlands

The East Pond has a maximum depth of approximately 6 ft. When the water level in the
pond reaches approximately 14 ft above MSL, the water discharges into a county
drainage ditch and eventually into Boca Ciega Bay. The water level in the East Pond
fluctuates depending on the frequency and amount of precipitation received at the
Pinellas Plant, and water level measurements taken during the RFI indicate that the
maximum fluctuation is less than 1 ft (DOE 1991b). This fluctuation of the water
level does not seem to affect the vegetation or wildlife in the East Pond. The
periphery of the East Pond is dominated by cattails, and vegetation on the bank
includes pennywort, Brazilian pepper, hempweed, crabgrass, Carolina willow, and
ragweed. Wildlife using the East Pond include common moorhen, red-winged blackbird,
common tern, green-backed heron, laughing gull, and Florida water snake (BDA 1992).
Groundwater modeling performed for the CMS Report (DOE 1993c,d; 1994b) indicates that
pumping of the groundwater recovery wells for the proposed corrective action, no
action, or the UV oxidation alternative action could lower the water level in the
East Pond. Other corrective actions for contaminated surficial aquifer groundwater
(e.g., Building 100 Area) could have a similar impact. The amount of this decline is
not known, but it is not expected to be substantial. Furthermore, due to the amount
of precipitation received at the Pinellas Plant, it is anticipated that inflow into
the East Pond would frequently replace this water loss. The lowering of the water
level due to groundwater pumping would not be expected to adversely affect
vegetation or wildlife in the East Pond, but it could reduce or eliminate discharge
from the pond after heavy precipitation. During any corrective action for
contaminated surficial aquifer groundwater, the water level in the East Pond would
be monitored to determine the amount of lowering and to assess any adverse effects.
If the lowering of the water level was substantial or if any adverse effects were
observed, appropriate measures would be developed and implemented by the DOE in
consultation with the appropriate regulatory agency or other authority. The DOE would
also evaluate the need for additional NEPA review and would conduct this review if
necessary. The most likely measure would be to supplement inflow into the East Pond
with water from an uncontaminated source such as the South or West Pond or with
treated effluent water from the groundwater treatment system.

5.6. CULTURAL RESOURCES

     As stated in subsection 4.6, there are no cultural resource sites within
     approximately 3 miles of the Pinellas Plant. Therefore, the proposed corrective
     action, no action, the alternative action, or other corrective actions would have no
     effect on cultural resources.

5.7. ACCIDENT ANALYSIS

A natural event or an operational failure could adversely affect the operation of the
Northeast Site groundwater treatment system and associated groundwater recovery
systems and could thereby cause adverse environmental consequences. Accidents related
to the operation of the groundwater recovery and treatment systems could also cause
adverse environmental consequences.
The natural events evaluated in this analysis are a hurricane or tropical storm, a
tornado or tornado-like event (e.g., waterspout), the formation of a sinkhole, and
an earthquake. As stated in subsections 4.1.1, and 4.2.2, the probabilities of these
natural events occurring at the Pinellas Plant are very low. Operational failures
that could affect the proposed action include the rupture of a containment device
such as the influent storage tank (Figure 3.2) and a leaking valve. Examples of an
operational accident are the spillage of a chemical used in the groundwater treatment
system (e.g., the flocculent used in the pretreatment portion of the treatment
system) or the inadvertent cutting of the transfer piping between the groundwater
recovery and treatment systems. The primary adverse environmental consequence of any
of these natural events or operational failures and accidents would be the
uncontrolled release of contaminated groundwater or hazardous materials.
The tanks, piping, and other equipment that would comprise the groundwater recovery
and treatment systems for the Northeast Site would contain two primary hazardous
components that could be released. These components would be contaminated groundwater
and filter press sludge. It is expected that the flocculent that would be used in
the pretreatment portion of the groundwater treatment system would not be hazardous.
April 1994 groundwater sampling results indicated that the dominant contaminants in
the Northeast Site groundwater at that time were dichloroethene, trichloroethene,
dichloromethane, chloroethene, and toluene. Iron is the only metal that is regularly
detected above regulatory limits in the groundwater, and the detected concentrations
are only slightly above regulatory limits (Terra 1994). The iron is a natural
constituent of the surficial aquifer groundwater and is not a substantial health or
environmental concern.
Waste sludge would be generated by the filter press in the Northeast Site groundwater
treatment system (Figure 3.2). It is expected that this waste sludge would be
similar to the waste sludge generated by the 4.5-Acre Site groundwater treatment
system, which contains iron hydroxide and calcium hydroxide precipitates. The
4.5-Acre Site waste sludge is relatively inert and does not pose a serious health or
environmental hazard. Pending a final EPA categorization of the Northeast Site waste
sludge as either hazardous or nonhazardous, the Pinellas Plant would manage the
sludge as hazardous in accordance with the applicable Federal, state, and DOE
procedures. Drums of the sludge could be breached during a natural event or
operational accident, resulting in a spill; however, the spill would be contained
within the berms around the waste sludge storage area and would not result in
serious environmental consequences.
Natural events such as a hurricane or earthquake could overturn containment devices
or cause the rupture of containment devices and/or associated piping, resulting in
an uncontrolled release of contaminated groundwater. The majority of the transfer
piping associated with the groundwater recovery and treatment systems would be
underground and would therefore not be susceptible to rupture during a hurricane,
tornado, or tornado-like event. However, the piping could rupture due to the
formation of a sinkhole or an earthquake. An operational failure or accident such as
the rupture of a tank or a worker inadvertently cutting transfer piping during the
installation of utility lines could also result in the uncontrolled release of
contaminated groundwater. An operational accident is a likely event; operational
failures are less likely but are possible. The consequences of an operational
failure or accident would be essentially the same as the consequences of a similarly
destructive natural event. Therefore, the primary accident scenario would be a break
in the transfer piping. This accident scenario adequately characterizes the risks to
human health and the environment from both natural events and operational failures or
accidents.
A break in the transfer piping between the Northeast Site groundwater recovery and
treatment systems would result in an uncontrolled release of contaminated
groundwater. The contaminants in the groundwater are VOCs and SVOCs; therefore, the
release of the contaminated groundwater could result in the escape of organic
vapors. It is expected that a break in the transfer piping between the groundwater
recovery and treatment systems would occur where the piping enters the above-ground
influent storage tank. At this point, the piping would be exposed and more
susceptible to an operational accident. It was assumed that the closest potential
receptor would be 50 ft from the transfer piping break. This potential receptor
would likely be a contractor's trailer or comparable structure. It was also assumed
that the influent storage tank would be located no closer than 100 ft from the
northeast corner of Building 1400 (Figure 3.1). Building 1400 is separated from the
Northeast Site by a fence and therefore represents a potential receptor location
where access is not restricted by a physical boundary. The concentrations of organic
vapors resulting from the break in the transfer piping were modeled using the
Emergency Prediction Information (EPI) Gaussian plume model (Holmann Associates
1988). For modeling the release of contaminated groundwater, chloroethene was chosen
from the dominant groundwater contaminants due to its high vapor pressure and low
exposure limits. The other assumptions and inputs for the EPI modeling were as
follows:
- The chloroethene concentration is 12,000 fg/L (Terra 1994).
- The release is continuous, but the release area is restricted because the
groundwater treatment system is isolated after 15 minutes. The realistic response
time to shutdown the treatment system is 15 minutes.
- The release and receptor heights are ground level, and the atmospheric stability
class would result in maximum vapor concentrations at a given location. The wind
speed is 3.3 ft per second, and the terrain factor is standard and conservative.
- The treatment system inflow rate is 25 gallons per minute, and 375 gallons are
released (25 gallons per minute for 15 minutes).
- The release area is 1,548 square ft (375 gallons at a depth of 0.4 inch), and the
radius of the release area is 22 ft.
- The evaporation rate for 0.0012 percent of chloroethene in solution was calculated
with the EPI model equation (0.0010 pounds per minute). The vapor pressure of
chloroethene at 32 degrees C was calculated with the Antoine Equation, and the
partial pressure of the chloroethene and water solution was calculated with the
Reoult Equation.
Based on the relatively low initial concentration of chloroethene (a maximum of
0.0012 percent or 12,000 g/L), the release of contaminated groundwater would not be
expected to result in adverse effects on human health. The results of the EPI
modeling for the accident scenario indicate that the maximum concentrations of
chloroethene vapor at 50 and 100 feet would be 0.5 and 0.19 part per million (ppm),
respectively. Both of these concentrations are below the threshold limit value-time
weighted average (TLV-TWA) of 1 ppm and the threshold limit value-ceiling (TLV-C) of
5 ppm. The TLVs are the most conservative published exposure limits which have been
established by regulatory standards, industrial guidelines, and the consensus of
government agencies to assist in the control of health hazards. The TLV-TWA is the
time- weighted average concentration for a normal 8-hour workday and a 40-hour
workweek, to which nearly all workers may be repeatedly exposed, day after day,
without adverse effects. The TLV-C is the concentration that should not be exceeded
at any time (ACGIH 1992a, b; NIOSH 1990). The chloroethene vapor concentration at an
offsite receptor would be substantially less than the concentration of 0.19 ppm at
100 ft. The Pinellas Plant boundaries closest to the proposed location of the
groundwater treatment system are the north and east boundaries which are
approximately 460 and 520 ft away, respectively.
Personnel operating and maintaining the groundwater recovery and treatment systems
could be exposed to both physical and chemical hazards as a result of natural events
and operational failures or accidents. Corrective action personnel would be trained
to take appropriate actions at the time of such incidents to avoid potential
hazards. This training and the appropriate actions would be set forth in the site
health and safety plan that is required for the proposed corrective action by 29 CFR
1910.120. Additional information on protection from potential hazards would be
provided in procedural manuals for the proposed corrective action. For example, the
operation and maintenance manual for the pretreatment portion of the groundwater
treatment system would provide safety information about the flocculent and any other
chemicals that may be used. Subsection 3.1 provides more details on the health and
safety requirements applicable to the proposed corrective action for the Northeast
Site.
The groundwater treatment system for the Northeast Site would incorporate several
measures for both the prevention and mitigation of accidents. All tanks would be
contained within bermed areas that have sumps. The berms would be high enough to
contain a release from any tank within the bermed area. The bermed areas would drain
to sumps that could be used to pump the released liquid back into the treatment
system. A manual pump could also be used to pump released liquids out of the sumps
and into other containers for appropriate disposal. The sumps would be provided with
float switches that would shut down the groundwater treatment system when the water
in the sumps reached a certain level. If a float switch were activated, a red light
above the air stripper tower would be illuminated to signal a problem to plant
personnel. In addition, control wires would be installed for the full length of the
transfer piping between the groundwater recovery and treatment systems. If the
transfer piping were cut, the control wires would also be severed, and the
groundwater recovery pumps would be automatically deactivated.
Pinellas Plant personnel are on call 24 hours per day to respond to any incident
involving the groundwater recovery and treatment systems. If an uncontrolled release
of contaminated groundwater or hazardous materials were to occur, an on-site
hazardous materials team is available to respond. This team is equipped with
personal protective equipment, absorbent materials, containers, and other appropriate
equipment and materials to accomplish effective control and/or cleanup of a release.
The hazardous materials team coordinates its operations with local emergency response
organizations and can obtain support from local fire departments.
An uncontrolled release of contaminated groundwater or hazardous materials could
cause the contamination of soils, surface water, and groundwater at the plant. Both
natural events and operational failures and accidents may result in the shutdown of
the groundwater recovery and treatment systems which would delay the proposed
corrective action for the Northeast Site. The groundwater contaminant plume would
remain in its current location and condition until the damages to the groundwater
recovery and treatment systems were repaired and the systems were restarted. The
Northeast Site groundwater treatment system and waste sludge storage area would be
contained within berms, and the bermed areas would drain to sumps. These measures
would prevent uncontrolled releases to the environment. Therefore, the most severe
human health and environmental consequences would result from an accident that
involves a break in the transfer piping between the groundwater recovery and
treatment systems. Such a break could occur due to a natural event or operational
failure but would be much more likely to occur due to an operational accident.
All of the transfer piping between the Northeast Site groundwater recovery and
treatment systems would be located in an area that is already designated as a SWMU.
A break of the transfer piping in this area would simply transfer the contaminated
groundwater from one part of the SWMU to another part. Corrective action is already
being conducted in this area so the contaminated groundwater would eventually be
recovered and treated. If a break in the transfer piping released contaminated
groundwater into an area within the Pinellas Plant that is not designated as a SWMU,
the area of the release would be assessed for potential designation as a SWMU. If the
area was determined to be a SWMU, the area would be subject to the corrective action
requirements set forth in the Pinellas Plant HSWA Permit (EPA 1990). Corrective
action for this new SWMU could potentially expose corrective action workers, and the
health risks due to this exposure would be similar to those described in subsection
5.1.4.

6. AGENCIES, ORGANIZATIONS, AND PERSONS CONSULTED

     Agency/Organization                  Person             Subject
     Pinellas County Department of        Peter Hessling     Air quality
     Environmental Management             Don Moores         Surface water
     Clearwater, Florida                                     
     Florida Department of State,         George Percy       Cultural resources
     Division of Historical                                  
     Resources,                                              
     Tallahassee, Florida                                    
     U.S. Department of the Interior,     Joseph Carroll     Threatened and
     Fish and Wildlife Service,                              endangered
     Vero Beach, Florida                                     species

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     Albuquerque Field Office, Albuquerque, New Mexico. March 1992.
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     Energy, Albuquerque Field Office, Albuquerque, New Mexico. September 1992.
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     Fenceline Area, Pinellas Plant, Largo, Florida [DRAFT]." U.S. Department of Energy,
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     Energy, Albuquerque Field Office, Albuquerque, New Mexico. February 1993.
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     Northeast Site, Pinellas Plant, Largo, Florida [DRAFT]." U.S. Department of Energy,
     Albuquerque Field Office, Albuquerque, New Mexico. March 1993.
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     Study Report, Addendum, Pinellas Plant, Largo, Florida [DRAFT]." U.S. Department of
     Energy, Albuquerque Operations Office, Albuquerque, New Mexico. September 1993.
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     Study Report Addendum, Pinellas Plant, Largo, Florida [DRAFT]." U.S. Department of
     Energy, Albuquerque Operations Office, Albuquerque, New Mexico. March 1994.
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     Interim Measures Plan." U.S. Department of Energy, Albuquerque Operations Office,
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     U.S. Department of Energy, Pinellas Area Office, Largo, Florida. DOE/EA-0950. July
     11, 1994.
     DOI. n.d. "National Wetlands Inventory." U.S. Department of the Interior, Fish and
     Wildlife Service, Regional Director (ARDE) Region IV, Atlanta, Georgia. No date.
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     dated June 17, 1988.
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     Part A [INTERIM FINAL]." OERR9285.7-01A. U.S. Environmental Protection Agency,
     Office of Emergency and Remedial Response, Washington, D.C.
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     Pinellas Plant, EPA ID No. FL6-890-090-008." U.S. Environmental Protection Agency.
     February 9,1990.
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     Applications Analysis Report." Superfund Innovative Technology Evaluation,
     EPA/540/A5-89/012. U.S. Environmental Protection Agency, Office of Research and
     Development, Washington, D.C. September 1990.
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     Version 2, Revision 93109. U.S. Environmental Protection Agency Publication No.
     EPA-450/4-92-008A. Research Triangle Park, North Carolina.
     FDEP. 1991. "The Florida Air Toxics Permitting Strategy, Draft Version 1.0." Florida
     Department of Environmental Protection, Tallahassee, Florida. January 1991.
     FDEP. 1993. "Air Emissions Permit." Florida Department of Environmental Protection,
     Southwest District, Tampa, Florida. Permit Number A052-233355.
     FDEP. 1994. "Hazardous Waste Facility, I.D. Number FL6 890 090 008, Permit No.
     HO52-159339." Florida Department of Environmental Protection, Southwest District,
     Tampa, Florida. December 8, 1994.
     Fernandez, M., Jr., 1985. "Reconnaissance of Water Quality at a U.S. Department of
     Energy Site, Pinellas County, Florida." U.S. Geological Survey Water-Resources
     Investigation Report 85-4062.
     Fernandez, M., Jr., and G. L. Barr. 1983. "Chemical Quality of Landfill Leachate in
     Treatment Ponds and Migration of Leachate in the Surficial Aquifer, Pinellas County,
     Florida." U.S. Geological Survey Water-Resources Investigation Report 83-4193.
     Franzmathes, J. R. 1993. U.S. Environmental Protection Agency, Region IV, Atlanta,
     Georgia. Personal communication to D. S. Ingle, U.S. Department of Energy, Pinellas
     Plant, Largo, Florida. December 13, 1993.
     Franzmathes, J. R. 1994. U.S. Environmental Protection Agency, Region IV, Atlanta,
     Georgia. Personal communication to D. S. Ingle, U.S. Department of Energy, Pinellas
     Plant, Largo, Florida. April 11, 1994.
     Geraghty and Miller, Inc. 1976. "Management of Water Resources of the
     Pinellas-Anclote and Northwest Hillsborough Basins of West-Central Florida." Volumes
     1 and 2.
     Hammond, R. W. 1992. Letter from R. W. Hammond, U.S. Environmental Protection Agency,
     Region IV, Atlanta, Georgia, to G. W. Johnson, U.S. Department of Energy, Pinellas
     Plant, Largo, Florida. April 16, 1992.
     Hickey, J. J. 1982. "Hydrogeology and Results of Injection Tests at Waste-Injection
     Test Sites in Pinellas County, Florida." U.S. Geological Survey Water-Supply Paper
     2183.
     Holmann Associates. 1988. "Emergency Prediction Information (EPI) Code." Holmann
     Associates, Inc., Freemont, California.
     Ingle, D. S. 1992a. Letter from D. S. Ingle, U.S. Department of Energy, Albuquerque
     Field Office, Pinellas Area Office, Largo, Florida, to R. Hammond, U.S.
     Environmental Protection Agency, Office of RCRA and Federal Facilities, Waste
     Management Division, Atlanta, Georgia. February 5, 1992.
     Ingle, D. S. 1992b. Letter from D. S. Ingle, U.S. Department of Energy, Albuquerque
     Field Office, Pinellas Area Office, Largo, Florida, to R. Hammond, U.S.
     Environmental Protection Agency, Office of RCRA and Federal Facilities, Waste
     Management Division, Atlanta, Georgia. June 26, 1992.
     Ingle, D. S. 1994. U.S. Department of Energy, Pinellas Plant, Largo, Florida.
     Personal communication to J. R. Franzmathes, U.S. Environmental Protection Agency,
     Region IV, Atlanta, Georgia. August 1, 1994.
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     West-Central Florida." U.S. Geological Survey Open-File Report 87-451.
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     Storm Water Retention Ponds." Meryman Environmental Engineers. May 1, 1989.
     NIOSH. 1990. "Pocket Guide to Chemical Hazards." DHHS (NIOSH) Publication No. 90-117.
     U.S. Department of Health and Human Services, Public Health Service, Centers for
     Disease Control, National Institute for Occupational Safety and Health. June 1990.
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     Florida, 1990." U. S. Department of Commerce, National Oceanic and Atmospheric
     Administration, National Climatic Data Center, Asheville, North Carolina.
     Nuzie, E. S. 1994. Florida Department of Environmental Protection, Tallahassee,
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     Plant, Largo, Florida. July 20, 1994.
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     Environmental Management, Air Quality Division, Clearwater, Florida, and D. Jones,
     Roy F. Weston, Inc., Albuquerque, New Mexico.
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     Dallas, Texas.

APPENDIX A
CONSULTATION WITH THE U.S. DEPARTMENT OF THE INTERIOR, FISH AND WILDLIFE SERVICE

United States Department of the interior
FISH AND WILDLIFE SERVICE
P.O. BOX 2676
VERO BEACH. FLORIDA 32961-2676
July 25, 1991
Mr. Paul J. Bebrens
Senior Environmental Scientist
Systematic Management Services, Inc.
11701 Belcher Road
Suite 103
Largo, FL 34643
Dear Mr. Behrens:
This responds to your letter, dated July 17, 1991, regarding threatened or endangred
speces that may be present on the U.S. Department of Energy's Pinellas Plant in Largo,
Pinellas County, Florida.
The property is within the historic range of the endangered Florida golden aster
(Chrysopsis floridana). The species was recorded historically from St. Petersburg Beach
and from Seminole, but urban development has apparently extirpated the species from
those two sites. If a remnant of pine scrub vegetation is present on the property, it
should be thoroughly searched for the species. If sand pine scrub is not present on the
property, it is unlikely that the species is present there.
The nearest bald eagle nest (designated PI-19 by the Florida Game and Fresh Water Fish
Commission) is located about 2 miles southwest of the property, near Cross Bayou.
Although the eagles could feed as far north as the retention ponds onthe property, their
Feeding is most likely concentrated in Cross Bayou. If contaminants from the plant are
entering the Cross Bayou Watershed, some adverse effect on the eagles may occur.
Otherwise, activities within the property are not 1ike1y to have a direct effect on the
nesting pair
The threatened Eastern indigo snake may inhabit the property. Detailed study of the site
would be required to determine its presence or absence
The endatgered wood stork may feed seasonally in the retention ponds on the property.
No other Federally listed species are likely to occur near the property. You should
contact the Florida Game and Fresh Water Fish Commission regarding species lised by
the State.
If the Department of Energy determines that an action is like1y to adversely affect a
Federal1y listed species, they should notify this office in writing to request consultation
under Section 7 of the Endangered Species Act.
Thank you for the opportunity to comment
Sincerely yours,
Joseph D. Carroll
Acting Field Supervisor
cc:
FG&FWFC, Tallahassee, FL
FWS, Jacksonville, FL

DOE F 1325.8
(5-83)
United States Government Department of Energy
memorandum Pinellas Area Office
DATE: MAY 26 1995
REPLY TO
ATTN OF: PAO:SEH:ENV077
SUBJECT: Northeast Site Environmental Assessment
TO: S. Simpson, Office of NEPA Policy and Assistance, HQ/EH-421
Attached please find one set of electronic files of the Northeast Site
Environmental Assessment. If you have any questions, please call me at (813)
545-6139.
Sarah E. Hartson
NEPA Compliance Officer
Attachment
cc w/o attachment:
D. Ingle, PAO

Finding of No Significant Impact
Proposed Corrective Action for the Northeast Site at the Pinellas Plant in Largo, Florida

AGENCY:  U.S. Department of Energy
ACTION:  Finding of No Significant Impact
SUMMARY: The U.S. Department of Energy
(DOE) has prepared an environmental assessment (EA) (DOE/EA-0976) of the proposed
corrective action for the Northeast Site at the Pinellas Plant in Largo, Florida. The
Northeast Site contains contaminated groundwater that would be removed, treated, and
discharged to the Pinellas County Sewer System. Based on the analyses in the EA, the
DOE has determined that the proposed action is not a major federal action
significantly affecting the quality of the human environment within the meaning of
the National Environmental Policy Act of 1969 (NEPA), 42 U.S.C. 4321 et. seq.
Therefore, the preparation of an environmental impact statement is not required and
the DOE is issuing this finding of no significant impact (FONSI).
SINGLE COPIES OF THE EA AND FONSI ARE AVAILABLE FROM:
Mr. Richard Glass, Area Manager
U.S. Department of Energy
Pinellas Area Office
P. O. Box 2900
Largo, Florida  34649
(813) 541-8692
FOR FURTHER INFORMATION ON THE NEPA PROCESS, PLEASE CONTACT:
Ms. Carol M. Borgstrom, Director
Office of NEPA Oversight, EH-25
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C.  20585
(202) 586-4600 or 1-800-472-2756
BACKGROUND: The Pinellas Plant encompasses approximately 99 acres in the center of 
Pinellas County, Florida. The plant is a government-owned facility administered by 
the DOE and operated by a DOE contractor. The plant was constructed in 1956 and 1957 
as part of the nuclear weapons production complex; the original products of the plant 
were neutron generators, a principal component of nuclear weapons. The production of
these devices led to the manufacture of other weapons application products. In 1993,
the DOE decided to phase out the Pinellas Plant and has proposed leasing all or
portions of the plant to commercial enterprises. It is anticipated that the
commercial enterprises would involve manufacturing processes identical or similar to
the processes currently used at the Pinellas Plant.
Under the provisions of the Resource Conservation and Recovery Act (RCRA), as amended
by the Hazardous and Solid Waste Amendments (HSWA), the U.S. Environmental
Protection Agency (EPA) issued the Pinellas Plant a HSWA Permit in 1990. The HSWA
Permit, in conjunction with the Hazardous Waste Management Permit issued by the
Florida Department of Environmental Protection (FDEP), authorizes the Pinellas Plant
to operate as a hazardous waste storage and treatment facility. The HSWA Permit also
sets forth the conditions and requirements for RCRA corrective actions at the plant.
A corrective action is a measure or measures taken to protect human health and the
environment from all releases of hazardous waste or constituents from any solid waste
management unit (SWMU). Through the RCRA corrective action process, the Northeast
Site has been identified as a SWMU needing corrective action.
SITE DESCRIPTION: The Pinellas Plant is located midway between the major
municipalities of Clearwater and St. Petersburg. The closest cities are Largo and
Pinellas Park. Light industry, including warehousing operations, is conducted in the
area immediately surrounding the plant. The closest residential area is
approximately 0.3 mile from the plant. The Northeast Site is entirely within the
boundaries of the Pinellas Plant; therefore, access to and use of the site are
strictly controlled.
The Northeast Site contains approximately 20 acres in the northeast corner of the
Pinellas Plant and includes the East Pond. Numerous investigations of the Northeast
Site, including a RCRA facility investigation in 1991, confirmed that groundwater in
the surficial aquifer at the site is contaminated with volatile and semivolatile
organic compounds. At the Pinellas Plant, the top of the surficial aquifer is from 0
to 4 ft below the ground surface, and the aquifer has an average thickness of 32 ft.
No municipal water supplies are taken from the surficial aquifer due to the limited
availability and naturally poor quality of the groundwater. The contaminated
groundwater plume has remained within the boundaries of the Northeast Site.
In 1992, an interim corrective measure was implemented for the Northeast Site,
primarily in response to the concern that the contaminant plume was potentially
increasing in areal extent and could migrate offsite. The interim corrective measure
consisted of withdrawing contaminated groundwater from the surficial aquifer through
recovery wells at the Northeast Site and treating the groundwater in the existing
4.5-Acre Site water treatment facility in the northwest corner of the Pinellas Plant.
This water treatment facility uses an air stripper to remove volatile and
semivolatile organic compounds from contaminated groundwater. The effluent from the
treatment facility is discharged into the Pinellas County Sewer System.
PROPOSED ACTION: The proposed corrective action for the Northeast Site is
pump-and-treat with air stripping. Groundwater recovery wells would be completed in
the surficial aquifer to withdraw contaminated groundwater from the aquifer. The
recovered groundwater would be piped to a groundwater treatment system that would be
constructed at the Northeast Site. This treatment system would use an air stripper
for the removal of the volatile and semivolatile organic compounds. The treated
groundwater would be discharged to the Pinellas County Sewer System. The corrective
action would also include the installation of a groundwater containment measure
(i.e., a slurry wall, infiltration gallery, or shallow well injection) at the
northern boundary of the Northeast Site. This groundwater containment measure would
limit the volume of clean groundwater recovered and would limit the groundwater
recovery zone to within the Pinellas Plant property. Groundwater monitoring would be
conducted during and after the corrective action to evaluate the efficiency and
effectiveness of the corrective action, to detect contaminant migration resulting
from the corrective action, and to verify that the contaminant concentrations have
been reduced to the media cleanup standards for the surficial aquifer at the
Northeast Site. The media cleanup standards for the Northeast Site are the Safe
Drinking Water Act (SDWA) maximum contaminant levels (MCLs) or the FDEP drinking
water standards for the contaminants, whichever are more stringent.
The corrective action would be performed in accordance with the HSWA and Hazardous
Waste Management Permits and an EPA- and FDEP-approved corrective measure
implementation plan. It is estimated that the corrective action would be conducted
for 30 years, and the total estimated cost for 30 years of corrective action is $22.5
million.
No Action
The no action alternative would consist of continuing the interim corrective measure
for the Northeast Site. Contaminated groundwater would continue to be withdrawn from
the surficial aquifer through existing recovery wells and treated in the existing
water treatment facility for the 4.5-Acre Site. The interim corrective measure
includes a groundwater monitoring system. The water treatment facility for the
4.5-Acre Site does not have enough capacity for both the 4.5-Acre Site and Northeast
Site corrective measures. Therefore, this alternative would result in one or both of
the corrective measures operating at less than an optimum groundwater withdrawal
rate. This would extend the time necessary for completion of a corrective action and
could present the potential for offsite migration of contaminated groundwater.
Other Corrective Action Alternatives
During the Corrective Measures Study for the Northeast Site, corrective action
technologies were identified and screened to eliminate technologies that are not
feasible. This screening resulted in the identification of corrective measure
alternatives; the corrective measure alternatives identified for the Northeast Site
were pump-and-treat with air stripping and pump-and-treat with ultraviolet (UV)
oxidation. Pump-and-treat with air stripping is the proposed corrective action for
the Northeast Site.
The UV oxidation alternative for corrective action at the Northeast Site would be the
same as the proposed corrective action except that UV oxidation would be the primary
groundwater treatment process instead of air stripping. Partially oxidized or
unoxidized contaminants in the groundwater could require additional treatment, and
controls could be required for emissions created by the UV oxidation process
depending on the type of system used. This alternative could be difficult to operate
due to the types of contaminants in the contaminated groundwater and could be more
expensive than the proposed corrective action, especially over 30 years of
corrective action.
ENVIRONMENTAL IMPACTS: The proposed corrective action would lower the contaminant
concentrations in the surficial aquifer to the SDWA MCLs or FDEP drinking water
standards for the contaminants, whichever are more stringent. The SDWA MCLs or the
FDEP drinking water standards for the contaminants are equal to or less than the
contaminant concentrations that would achieve the EPA's upperbound target
carcinogenic risk of no more than one excess cancer in a population of 10,000 people
exposed (i.e., drinking contaminated groundwater from the surficial aquifer) or the
FDEP acceptable target carcinogenic risk of no more than one excess cancer in a
population of 1,000,000 people exposed. The proposed corrective action would
similarly reduce the potential for noncarcinogenic public health risks (e.g., liver
degeneration). Without any corrective action, using contaminated groundwater from
the surficial aquifer for domestic purposes other than drinking could result in
public health effects ranging from six excess cancers in a population of 100,000
people exposed to two excess cancers in a population of 10 people exposed. Use of the
surficial aquifer as a drinking water supply is very unlikely due to the limited
availability and naturally poor quality of the groundwater in the aquifer.
To ensure worker protection, the proposed corrective action would be performed in
compliance with all of the applicable health and safety requirements of the
Occupational Health and Safety Administration as well as all applicable DOE and
Pinellas Plant health and safety requirements. The proposed corrective action would
also be performed in compliance with a site health and safety plan.
The air stripper in the proposed groundwater treatment system would exhaust volatile
and semivolatile organic compounds. These emissions would be regulated by the
Pinellas Plant's Air Emissions Permit (Permit Number AO52-233355). Emissions of
volatile and semivolatile organic compounds from the air stripper alone and combined
emissions from the air stripper and the Pinellas Plant itself would not exceed
no-threat levels established by the FDEP. A no-threat level is an estimate of a
chemical's ambient exposure level that is not likely to cause appreciable human
health risks.
Approximately 1.5 acres of soils would be temporarily disturbed by the proposed
corrective action, and additional small areas of soils could be disturbed in the
future for the installation of new groundwater recovery and monitoring wells and
associated piping. All areas disturbed during the proposed corrective action would
be graded to conform to the surrounding land surface and would be revegetated with
plant species common to the Pinellas Plant.
The proposed corrective action would lower the contaminant concentrations in
surficial aquifer groundwater to the media cleanup standards for the Northeast Site.
Approximately 70 million gallons of contaminated groundwater would be withdrawn from
the surficial aquifer during 30 years of the corrective action. The withdrawal of
groundwater from the surficial aquifer would lower the water level in the aquifer
and would slightly alter the direction of groundwater flow in the aquifer. It is
estimated that the groundwater level and flow direction in the surficial aquifer
would be restored to previous conditions in less than 10 years after completion of
the corrective action. No municipal water supplies are taken from the surficial
aquifer because the aquifer will not sustain adequate well yields and the
groundwater quality is generally poor due to high naturally occurring concentrations
of chloride, iron, and organic constituents.
The treated groundwater from the proposed action would be discharged to the Pinellas
County Sewer System in accordance with the Pinellas Plant's Industrial Wastewater
Discharge Permit (Permit Number 153-IE), the Pinellas County Sewer Use Ordinance of
April 1991, and the EPA's discharge standards for the metals finishing industry. If
the volume of treated groundwater to be discharged to the sewer system would
increase the total Pinellas Plant wastewater discharge by more than 10 percent, the
Pinellas County Sewer System would be notified 30 days prior to the increase as
required by the Industrial Wastewater Discharge Permit.
The East Pond has been designated as a wetlands by the Fish and Wildlife Service. The
proposed corrective action would be located outside the East Pond, but groundwater
modeling indicates that the withdrawal of groundwater from the surficial aquifer
could lower the water level in the East Pond. The water level in the East Pond would
be monitored during the corrective action. If the lowering of the water level was
appreciable or if any adverse effects were observed, appropriate measures would be
developed and implemented by the DOE in consultation with the appropriate regulatory
agency or other authority.
The environmental impacts of the proposed action combined with the environmental
impacts of other actions at the Pinellas Plant were also analyzed in the EA. The
other actions included the ongoing corrective action for contaminated surficial
aquifer groundwater at the 4.5-Acre Site, other proposed corrective actions for
contaminated surficial aquifer groundwater, and the proposed leasing of all or
portions of the Pinellas Plant to commercial enterprises. The major environmental
concerns were air quality, the withdrawal of groundwater from the surficial aquifer,
and the discharge of wastewater to the Pinellas County Sewer System.
The treatment of contaminated groundwater by air stripping would result in emissions
of volatile and semivolatile organic compounds. An air quality analysis indicated
that the greatest emissions of these compounds would occur if contaminated
groundwater from all corrective actions were being treated in the 4.5-Acre Site
treatment system at a rate of 50 gallons per minute. Dispersion modeling of these
emissions showed that the concentrations of the volatile and semivolatile organic
compounds at various locations would not exceed the FDEP no-threat levels. The
modeling also showed that emissions from the groundwater treatment system and the
Pinellas Plant itself would not result in exceedances of the FDEP no-threat levels.
Commercial enterprises leasing all or portions of the Pinellas Plant may create air
emissions, including emissions of volatile and semivolatile organic compounds. These
emissions would be documented and regulated under the plant's Air Emissions Permit,
and responsible enterprises would obtain any necessary permit modifications or
additional permits that would be required to demonstrate compliance with air
emissions requirements. Enterprises that would warrant substantial permit
modifications or new permits would be closely monitored or would not be allowed at
the plant.
Contaminated groundwater is currently withdrawn from the surficial aquifer for the
interim corrective actions at the 4.5-Acre and Northeast Sites. The final corrective
actions at these sites and corrective actions proposed for other areas at the
Pinellas Plant would increase the amount of groundwater withdrawn from the aquifer,
and this increase would result in additional lowering of the water level in the
aquifer and could alter the direction of groundwater flow in the aquifer. No
municipal water supplies are taken from the surficial aquifer because the
groundwater is of limited availability and generally of poor quality due to naturally
occurring constituents. After completion of the corrective actions, recharge of the
surficial aquifer would the restore the groundwater level and flow direction to
previous conditions.
The total amount of wastewater discharged from the Pinellas Plant into the Pinellas
County Sewer System has decreased since 1991 due to decreased production activities
at the plant. However, the amount of treated groundwater discharged from the 4.5-Acre
Site treatment system into the sewer system has increased during the same time
period. The final corrective actions for the 4.5-Acre and Northeast Sites and
corrective actions proposed for other areas at the Pinellas Plant could further
increase the amount of treated groundwater discharged into the sewer system, and
commercial enterprises leasing all or portions of the plant could also create
wastewater that would be discharged into the sewer system. All wastewater discharges
into the sewer system would be subject to the plant's Industrial Wastewater Discharge
Permit and would meet the existing discharge standards. If modifications of the
Industrial Wastewater Discharge Permit were necessary, the modifications would be
coordinated with the Pinellas County Sewer System and Pinellas County Water Quality
Division. If any action would increase the total Pinellas Plant wastewater discharge
by more than 10 percent, the Pinellas County Sewer System would be notified 30 days
prior to the increase in accordance with the Industrial Wastewater Discharge Permit.
An accident analysis of the proposed action indicated that an operational accident
would be the most likely event that could affect the proposed action and cause
adverse environmental consequences. An operational accident such as a break in the
transfer piping between the groundwater recovery and treatment systems would result
in the release of contaminated groundwater which, in turn, would result in the
emission of organic vapors. Dispersion modeling of this emission of organic vapors
showed that the concentrations of the vapors would not exceed the most conservative
published exposure limits, which have been established by regulatory standards,
industrial guidelines, and the consensus of government agencies to assist in the
control of health hazards. The contaminated groundwater would be released in an area
where an interim corrective action is already being conducted and a final corrective
action is proposed; therefore, the contaminated groundwater would eventually be
recovered and treated. The proposed action would incorporate several measures for
both the prevention and mitigation of operational failures and accidents, and
corrective action personnel would be trained to take appropriate actions at the time
of such incidents to avoid potential hazards.
The no action alternative would have environmental impacts similar to those of the
proposed corrective action because the interim corrective measure for the Northeast
Site would be continued. Contaminated groundwater would continue to be withdrawn from
the surficial aquifer and treated at an existing water treatment facility. Due to the
capacity of this water treatment facility, this alternative would take longer than
30 years to complete and could present the potential for offsite migration of
contaminated groundwater.
The UV oxidation alternative would have the same environmental impacts as the
proposed corrective action. However, there would also be a very low potential for
the exposure of the general public and corrective action workers to hydrogen peroxide
and UV light used in the UV oxidation process. Due to the types of contaminants in
the surficial aquifer groundwater, this alternative could also be difficult to
operate at the Northeast Site which could increase the time necessary to complete the
corrective action.
DETERMINATION: Based on the analyses in the EA, the DOE has determined that the
proposed action does not constitute a major federal action significantly affecting
the quality of the human environment within the meaning of the NEPA. Therefore, an
environmental impact statement for the proposed action is not required.
Issued at Largo, FL on this    15th     day of    May          , 1995.
                                                Richard E. Glass
                                                Area Manager
                                                Pinellas Area Office
(Issued at Washington, D.C., on this           day of                   , 1995.)
Peter N. Brush
Acting Assistant Secretary
Environment, Safety and Health

RESPONSES TO COMMENTS
ENVIRONMENTAL ASSESSMENT OF CORRECTIVE ACTION AT THE NORTHEAST SITE PINELLAS PLANT LARGO, FLORIDA

INTRODUCTION
Comments on
the Environmental Assessment of Corrective Action at the Northeast Site (EA) and
corresponding Finding of No Significant Impact (FONSI) were received from Martin
Marietta Specialty Components, Inc. (MMSC); the U.S. Department of Energy,
Headquarters (DOE/HQ); and the Pinellas Area Office (PAO). These comments are
attached, and WESTON's responses to these comments are provided below by comment
number. The comment numbers are the numbers to the left of the attached comments
(e.g., EH-2; page 1-8, line 22; and 1).
MARTIN MARIETTA SPECIALTY COMPONENTS, INC. COMMENTS
Draft FONSI
Page 7, paragraph 3, line 3. The EA and FONSI were revised as requested.
DOE Comments
EH-2. WESTON discussed this comment with MMSC, and MMSC agreed that the cumulative
impacts of commercialization of the Pinellas Plant were addressed in the EA
and FONSI where they were applicable (e.g., cumulative impacts on air quality).
In addition, an introductory paragraph regarding cumulative impacts was
incorporated in section 5.0 of the EA at page 5-1, line 7.
EH-3. The EA and FONSI were revised to include three possible groundwater containment
measures (i.e., a slurry wall, an infiltration gallery, and shallow well
injection).
EH-4. This comment was discussed with the PAO. The April 1993 telephone communication
with the Fish and Wildlife Service cannot be found. As instructed by the PAO, the
EA was not revised.
EH-33. WESTON has reviewed the pertinent information in the Northeast Site Interim
Measures Quarterly Progress Report, December 1994 and additional information
provided by MMSC. WESTON does not believe that this information is appropriate
for inclusion in the EA for the following reasons:
1) Previous comments indicate that the analysis in the EA is adequate to support
the finding that no adverse air quality impacts would occur. No further
information is necessary.
2) The maximum ambient concentrations (MACs) have been calculated using actual
influent and effluent concentrations and actual average flow rates for the
4.5-Acre Site treatment system. Based on the design capacity of the treatment
system (20 gallons per minute), it is assumed that these actual average flow rates
would be 20 to 25 gallons per minute or less. The EA addresses the treatment
system operating at a capacity of 50 gallons per minute, which is more
conservative for the assessment of air quality impacts.
3) WESTON has discussed acceptable ambient concentrations (AACs) with MMSC. The
AACs are related to threshold limit values (TLVs) and were the appropriate
regulatory guidelines when the Northeast Site interim corrective measure was
originally approved. The AACs are not related to no-threat levels (NTLs) which
are the current regulatory guidelines used in the EA. WESTON believes that
incorporating MACs and AACs in the EA at this time would further complicate the
air quality issue, especially for the layman.
Based on the above information, the EA was not revised.
EA Technical Content
Page 1-8, line 22. The EA was revised as requested.
Page 3-1, line 25. The EA was revised as requested.
Page 3-3, line 6. The EA was revised as requested.
Page 3-5, line 25. The EA was revised to include MMSC's estimate of 6 months.
Page 3-6, line 18. The EA and FONSI were revised as requested.
Page 5-7, line 14. The EA was revised as requested.
Page 5-7, line 19 to page 5-10, line 11. The EA was revised as requested. Metric
measurements were not used in the EA; therefore, the metric
measurements in subsection 5.2 were deleted.
U.S. DEPARTMENT OF ENERGY, HEADQUARTERS COMMENTS
1. The EA and FONSI were revised to provide a range in the depth of the surficial
aquifer at the Pinellas Plant (i.e., depth from the ground surface to the top
of the surficial aquifer). The average "thickness" of the surficial aquifer
was not changed because it is different than the "depth."
2. The FONSI was revised as requested. This mistake did not appear in the EA.
3. The EA and FONSI were revised as requested.
4. The EA and FONSI were revised as requested.
5. The EA and FONSI were revised as requested.
6. The EA and FONSI were revised as requested.
7. The PAO resolved this comment with the DOE/HQ. As instructed by the PAO,
the EA and FONSI were not revised.
8. The PAO resolved this comment with the DOE/HQ. As instructed by the PAO,
the EA and FONSI were not revised.
9. The PAO resolved this comment with the DOE/HQ. As instructed by the PAO,
the EA and FONSI were not revised.
10. The FONSI was revised to state that the most conservative exposure limits
"have been established by regulatory standards, industrial guidelines, and
the consensus of government agencies to assist in the control of health hazards."
This is consistent with the EA.
PINELLAS AREA OFFICE COMMENTS
1. The sentence cited in this comment was deleted from the EA. It was redundant
with Figure 1.1 and was not pertinent to the EA.
2. The EA and FONSI were revised as requested.
3. The EA was revised as requested.
4. The EA was revised as requested.
5. The EA was revised as requested.
6. The EA and FONSI were revised as requested.
7. The EA was revised as requested.
8. The EA was revised as requested.
9. The EA and FONSI were revised to reflect both the EPA upperbound and the FDEP
acceptable target carcinogenic risks.
10. The EA was revised as requested.
11. The EA was revised as requested. Metric measurements were not used in the EA;
therefore, the metric measurements in subsection 5.2 were deleted.
12. The EA was revised as requested.

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