CHAPTER 5. FEDERAL AND STATE LAWS, CONSULTATIONS, AND REQUIREMENTS
This chapter identifies regulatory requirements and evaluates their applicability to the alternatives considered in this environmental impact statement (eis). These requirements are established by major federal statutes that impose requirements on the U.S. Department of Energy (DOE). In addition, there are other federal and state laws, Executive Orders, DOE Orders, regulations, and other compliance orders and agreements applicable to the management of waste at the Savannah River Site (SRS). More detailed information on SRS regulatory requirements for waste management is available in Final Environmental Impact Statement, Waste Management Activities for GroundwaterProtection (DOE 1987). Existing environmental permits at SRS are listed in Appendix B of the Savannah River Site Environmental Report for 1993 (Arnett, Karapatakis, and Mamatey 1994). Table 5-1 summarizes the permit and approval status of SRS waste management facilities.
Section 5.1 discusses regulatory requirements applicable to the no-action alternative. Section 5.2 addresses differences in the regulatory requirements that apply to the no-action alternative and the other alternatives, and any differences related to the waste volumes. A number of requirements apply to all the alternatives. When that is the case, Section 5.1 includes a discussion of the requirement, which is not repeated in Section 5.2.
5.1 No-Action Alternative
5.1.1 NATIONAL ENVIRONMENTAL POLICY ACT
The National Environmental Policy Act (NEPA) of 1969 (42 USC §4321 et seq.) requires federal agencies to evaluate the effect proposed actions would have on the quality of the human environment and to document this evaluation with a detailed statement. NEPA requires consideration of environmental impacts of an action during the planning and decisionmaking stages of a project.
The Council on Environmental Quality has issued regulations that federal agencies must follow (40 CFR 1500 - 1508); agencies were also directed to develop their own regulations to ensure compliance with NEPA requirements. DOE's regulations can be found at 10 CFR 1021. An agency is required to prepare an eis when it proposes a major federal action that may significantly affect the environment.
Status - Analyses presented in this eis describe the environmental impacts of the alternatives. Additional NEPA analyses may be required before some facilities could be constructed.
5.1.2 ATOMIC ENERGY ACT
The Atomic Energy Act of 1954 (42 USC § 201 et seq.) makes the federal government responsible for regulatory control of the production, possession, and use of three types of radioactive material: source, special nuclear, and byproducts. The Atomic Energy Act also requires DOE to establish standards that protect health and minimize dangers to life or property from activities under DOE's jurisdiction. Pursuant to the Atomic Energy Act, DOE established an extensive system of standards and requirements, called DOE Orders, to ensure compliance with the Atomic Energy Act. The Atomic Energy Act and the Reorganization Plan No. 3 of 1970 [5 USC (app. at 1343)] and other related statutes gave the U.S. Environmental Protection Agency (EPA) responsibility and authority for developing generally applicable environmental standards for protecting the environment from radioactive material. EPA has promulgated several regulations under this authority, including "Environmental Radiation Protection Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes" (40 CFR 191).
In response to public comments during the scoping period, DOE presents in Appendix H a comparison of alternative regulatory approaches for the disposal of low-level waste. The appendix presents an analysis of the similarities and differences in requirements established by DOE and the Nuclear Regulatory Commission for the disposal of low-level waste. Table H-1 correlates specific DOE and Nuclear Regulatory Commission requirements. The conclusion of the analysis is that DOE regulations are substantially equivalent to Nuclear Regulatory Commission regulations.
Appendix H also provides a comparative analysis of DOE and Nuclear Regulatory Commission lowlevel waste disposal requirements with EPA requirements for a hazardous waste landfill. The analysis indicates that the vaults proposed for disposal of low-level waste at SRS (discussed in Appendix B.8) exceed the EPA hazardous waste landfill requirements.
Status - Construction, prestartup evaluations, and operation of radioactive waste management facilities will meet the requirements in DOE Orders and other applicable regulations.
5.1.3 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT
The Comprehensive Environmental Response, Compensation, and Liability Act (42 USC §9601 et seq.) (CERCLA; also called the Superfund Act) is administered by EPA. It provides a statutory framework for the cleanup of waste sites containing hazardous substances and requires that facilities have an emergency response program in the event of a release (or threat of release) of a hazardous substance to the environment. CERCLA also includes requirements of reporting to state and federal agencies releases of certain hazardous substances in excess of specified amounts. CERCLA and Executive Order 12580, "Superfund Implementation," require that federal facilities comply with the Act. Releases of hazardous substances occurring during cleanups at waste management facilities are subject to both CERCLA's requirements and to the requirements of DOE Order 5000.3B, "Occurrence Reporting and Processing of Operations Information."
Status - DOE, the South Carolina Department of Health and Environmental Control (SCDHEC), and EPA have signed a Federal Facility Agreement to coordinate cleanups at SRS, as required by Section 120 of CERCLA. Since 1989, SRS has conducted cleanup activities under the framework established in the draft Federal Facility Agreement. The comprehensive remediation of SRS will continue as directed by the Federal Facility Agreement.
5.1.4 EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT
The Emergency Planning and Community Right-to-Know Act of 1986 (42 USC §11001 et seq.) requires emergency planning and notice to communities and government agencies of the presence and release of specific chemicals. EPA implements the Act under regulations found at 40 CFR 355, 370, and 372. Under Subtitle A of this Act, federal facilities, including those owned by DOE, provide a variety of information (such as inventories of specific chemicals used or stored, and releases that occur from these facilities) to state emergency response commissions and local emergency planning committees to ensure that emergency plans are ready to respond to accidental releases of hazardous substances. Executive Order 12856, "Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements," requires federal agencies to comply with the Act.
Status - Each year SRS submits hazardous chemical inventory and toxic release inventory reports to SCDHEC and to local emergency planning organizations in Aiken, Allendale, and Barnwell Counties, South Carolina. Changes in facility operating status will lead to changes in chemical inventories and use of toxic chemicals; the hazardous chemical inventory and toxic release inventory reports will reflect these changes.
5.1.5 RESOURCE CONSERVATION AND RECOVERY ACT
The Resource Conservation and Recovery Act (RCRA) regulates the treatment, storage, and disposal of hazardous and solid waste. RCRA and Executive Order 12088, "Federal Compliance with Pollution Control Standards," require federal facilities to comply with RCRA's requirements. Any state that wants to administer and enforce a hazardous waste program under the requirements of RCRA may apply to EPA for authorization of its program. EPA regulations implementing RCRA are found at 40 CFR 260 280. These regulations define hazardous wastes and set forth requirements governing transporting, handling, treating, storing, and disposing of hazardous wastes.
The regulations imposed on managing hazardous wastes vary according to the type and quantity of waste. The method of treatment, storage, and disposal also impacts the extent and complexity of the requirements. RCRA establishes three distinct regulatory programs for different types of waste:
Hazardous and Mixed Waste - EPA has delegated regulatory responsibility over hazardous and mixed (containing both radioactive and hazardous components) wastes to SCDHEC. EPA retains authority to restrict storage and disposal of certain kinds of hazardous wastes, which are referred to as "land disposal restriction wastes." Under the authority of the South Carolina Hazardous Waste Management Act, SCDHEC has established a program for regulating hazardous waste management (South Carolina Hazardous Waste Management Regulations R.61-79.260 through 270). SCDHEC is currently developing programs that will allow EPA to delegate authority over land-disposal-restriction wastes.
DOE and EPA signed a Federal Facility Compliance Agreement regarding land disposal restriction mixed wastes. Among other things, the Agreement requires SRS to provide status reports on construction and operation of various waste management facilities and to obtain permits for the construction and operation of additional facilities to meet SRS's treatment needs for mixed waste. SRS has provided, and will continue to provide, these reports and is preparing the required permit applications.
Underground Storage Tanks - Requirements under RCRA for underground storage tanks apply to tanks containing hazardous substances or petroleum products. Under the South Carolina Underground Storage Tank Act, SCDHEC established a program for implementing RCRA requirements and has issued permits for diesel fuel storage tanks at several SRS waste management facilities. Tanks with high-level radioactive waste are not regulated under RCRA; they are regulated under the Clean Water Act. Below-grade hazardous waste storage tanks are not regulated as underground storage tanks but as hazardous waste.
Nonhazardous Solid Waste - Under the authority of the
South Carolina Pollution Control Act and the South Carolina Solid Waste Policy
and Management Act, SCDHEC established a program for regulating
nonhazardous solid waste disposal units. South Carolina Municipal Solid Waste
Landfill Regulations (R.61-107.258) implement RCRA regulations. South Carolina
Construction, Demolition, and Land Clearing Debris Landfill Regulations
(R.61-107.11) regulate landfills for the disposal of construction debris. South
Carolina Industrial Landfill Regulations (R.61-66) regulate industrial
landfills. Nonhazardous solid waste is not within the scope of this eis.
Status - The
SRS RCRA Part B permit was issued in 1987 and modified in 1992. The permit
covers storage of wastes at four buildings, treatment at the Consolidated
Incineration Facility,
and maintenance and groundwater remediation at three closed
waste units. Other waste management facilities at SRS are presently operating
under interim status: SRS submitted to SCDHEC a permit application
that covers those facilities' activities and they can continue to operate in
conformance with regulatory requirements while applications are reviewed by the
regulatory agencies and a final permit decision is issued. Additional waste
management facilities (e.g., F- and H-Area tank farms, Replacement HighLevel
Waste Evaporator) are currently operating under or will operate under Clean
Water Act permits. Although these facilities manage
hazardous wastes, they are exempt from RCRA permitting
requirements under its exclusion for wastewater treatment
facilities.
Under the no-action alternative, commitments under the Land
Disposal Restrictions Federal Facility Compliance Agreement to treat mixed waste would not be met because only ongoing waste management activities
(primarily storage) would be continued.
The no-action alternative includes continued storage and
limited ongoing treatment activities at existing waste management facilities
that are permitted or operating under interim status. The noaction
alternative includes several additional waste management activities that have
not yet occurred, but for which NEPA reviews have been completed or will be
completed prior to issuing a Record of Decision for this eis. These activities
include retrieval, sampling, and overpacking of transuranic waste drums from mounded storage pads; preparation of waste (size reduction
and repackaging) in anticipation of treatment; construction and operation of the
MArea Vendor Treatment Facility; and operation of the Mixed Waste Storage
Buildings.
5.1.6 FEDERAL FACILITY COMPLIANCE ACT
The Federal Facility Compliance Act, enacted on October 6, 1992, waives sovereign immunity for fines and penalties for violations of RCRA at federal facilities. However, DOE's immunity continues if DOE prepares plans for developing the treatment capacity for mixed waste stored or generated at its facilities. The appropriate state agency or EPA must then issue a consent order requiring compliance with the plan. DOE is not subject to fines and penalties for RCRA violations involving mixed waste as long as it is in compliance with an approved plan and meets all other applicable regulations.
Status - DOE published the Interim Mixed Waste Inventory Report in April 1993, annual updates, and periodic updates since, describing its inventory of mixed wastes and treatment capabilities. SRS prepared a site treatment plan (WSRC 1995), which identifies DOE's preferred approach for treating mixed waste at SRS. Under the no-action alternative, commitments under the site treatment plan would not be met because only ongoing waste management activities would be continued. The treatment capacity required by SRS's plan would not be available and SRS would probably lose its immunity from fines and penalties.
5.1.7 CLeaN WATER ACT
The objectives of the Clean Water Act
are to restore and maintain the chemical, physical, and biological integrity of
the nation waters. The Clean Water Act prohibits the "discharge
of toxic pollutants in toxic amounts" to navigable waters of the United
States. Section 313 requires all branches of the federal government to comply
with federal, state, interstate, and local requirements.
In addition to setting water quality standards for the nation's waterways, the Clean Water Act establishes guidelines and limitations for discharges from point-sources and a permitting program known as the National Pollutant Discharge Elimination System. The National Pollutant Discharge Elimination System program is administered by the Water Management Division of EPA pursuant to regulations at 40 CFR 122 et seq.
The Clean Water Act also requires that EPA establish regulations for permits for stormwater discharges associated with industrial activity. Although such discharges require National Pollutant Discharge Elimination System permits, regulations for separate stormwater permits have not yet been issued by EPA.
EPA has overall responsibility for enforcing the Clean Water
Act, but has delegated to SCDHEC primary
enforcement authority for waters located within South Carolina. Under the South
Carolina Pollution Control Act, SCDHEC operates a permitting program. The Clean
Water Act and state regulations do not apply to DOE discharges of radionuclides,
which are subject to the Atomic Energy Act.
Status -
SCDHEC has issued Clean Water Act permits for
the F- and H-Area tank farms, Defense Waste Processing Facility, ZArea Saltstone Facility, Replacement High-Level
Waste Evaporator, F/H-Area Effluent Treatment Facility, and M-Area Liquid
Effluent Treatment Facility. SCDHEC
approved certain discharges from the outfalls at these facilities. DOE has
submitted an industrial wastewater treatment permit application
for the M-Area Vendor Treatment Facility. SRS is currently in compliance with
Clean Water Act requirements.
5.1.8 SAFE DRINKING WATER ACT
The Safe Drinking Water Act protects the quality of public water supplies and other sources of drinking water. It establishes drinking water quality standards that must be met. The Act and Executive Order 12088 direct federal facilities to comply with the Safe Drinking Water Act. EPA has promulgated regulations implementing the Safe Drinking Water Act at 40 CFR 100 - 149. The regulations specify that the average annual concentration of man-made radionuclides in drinking water as delivered to the user shall not produce a dose equivalent to the total body or an internal organ greater than 4 millirem of beta activity per year. EPA has overall regulatory responsibility for the Safe Drinking Water Act, but has delegated primary enforcement responsibility to SCDHEC for public water systems in South Carolina. Under the authority of the South Carolina Safe Drinking Water Act, SCDHEC has established a drinking water regulatory program. At SRS, Westinghouse Savannah River Company operates under the SCDHEC permit program for construction of water supplies. Under this program, Westinghouse Savannah River Company may construct water line extensions that are less than or equal to 2,500 feet long without obtaining construction and operating permits; water line extensions longer than 2,500 feet require formal construction and operating permits.
Status -
Westinghouse Savannah River Company obtained a construction
permit for the water line extension that will serve the Consolidated
Incineration Facility.
5.1.9 CLeaN AIR ACT
The Clean Air Act establishes a national program to protect
air quality and regulates sources of air pollution.
Requirements include permits, emissions and operating standards, and monitoring.
The Act is intended to "protect and enhance the quality of the Nation's
air resources so as to promote the public health and welfare
and the productive capacity of its population." Section 118
of the Act and Executive Order 12028 require that each federal agency, such
as DOE, with jurisdiction over any property or facility that might result in the
discharge of air pollutants, comply with "all federal, state, interstate,
and local requirements" with regard to the control and abatement of air
pollution.
The Act requires EPA to establish National Ambient Air Quality Standards as necessary to protect public health, with an adequate margin of safety, from any known or anticipated effect of a regulated pollutant. It also requires establishment of national standards of performance for new or modified stationary sources of air pollutants (42 USC §7411) and requires specific emission increases to be evaluated to prevent significant deteriorations in air quality. Hazardous air pollutants, including radionuclides, are regulated separately. Air emissions are regulated by EPA in 40 CFR 50 - 99. In particular, radionuclide emissions are regulated under the National Emission Standard for Hazardous Air Pollutants program (40 CFR 61).
EPA has overall enforcement responsibility through a
regulatory program (40 CFR 50 - 87); it can delegate primary authority to
states. For facilities located within South Carolina, EPA has retained
authority over DOE radionuclide emissions (40 CFR 61) and has delegated to
SCDHEC lead responsibility for the rest of the regulated pollutants
and other requirements. Under the authority of the South Carolina Pollution
Control Act, SCDHEC established the state's air pollution control program.
SCDHEC issues construction permits for construction and testing of facilities,
and operating permits after satisfactory startup testing and inspection.
Status - The
Air Quality Control construction permit for the Consolidated Incineration
Facility was granted by SCDHEC
on November 25, 1992. Emergency power diesel generators are covered under this
permit. The M-Area Vendor Treatment Facility emergency diesel generator is
exempt from permitting requirements because of its limited capacity and expected
use. SCDHEC has granted a permitting exemption for the emergency diesel
generator at the Replacement HighLevel Waste Evaporator. SRS is currently
in compliance with the requirements of the Clean Air Act.
5.1.10 ENDANGERED SPECIES ACT AND OTHER STATUTES
The Endangered Species Act is intended to prevent the
further decline of endangered and threatened species and to restore these
species and their habitats. The Endangered Species Act also promotes
biodiversity of genes, communities, and ecosystems. The U.S. Department of
Commerce (National Marine Fisheries Service) and the U.S. Department of the
Interior (U.S. Fish and Wildlife Service) jointly administer the Act. Section 7
of the Act requires federal agencies to consult with the National Marine
Fisheries Service or the U.S. Fish and Wildlife Service, as appropriate, to
ensure that any action it authorizes, funds, or performs is not likely to
jeopardize the continued existence of any endangered or threatened species or to
result in the destruction or adverse modification of any critical habitat of
such species unless the agency receives an exemption in accordance with Section
7(h).
Several other statutes require federal and state agencies to
consider impacts that their actions would have on biological resources. These
acts include the Fish and Wildlife Coordination Act, the Anadromous Fish
Conservation Act, the Migratory Bird Treaty Act, the Bald Eagle Protection Act,
and the South Carolina Nongame and Endangered Species Conservation Act.
Status - Prior
to disturbing undeveloped land, DOE would consult with the U.S. Fish and
Wildlife Service to determine the type and scope of a required biological
assessment. This consultation would provide DOE with the information necessary
to avoid or mitigate impacts to threatened and endangered species. Appendix J documents DOE's consultation with the
U.S. Fish and Wildlife Service.
5.1.11 EXECUTIVE ORDERS 11990 AND 11988
Executive Order 11990, "Protection of Wetlands,"
requires government agencies to avoid short- and long-term adverse impacts to
wetlands whenever a practicable alternative exists. Executive
Order 11988, "Floodplain Management," directs federal agencies to
establish procedures to ensure that the potential effects of flood hazards and
floodplain management are considered for any action undertaken. Impacts to
floodplains are to be avoided to the extent practicable. DOE issued regulations
(10 CFR 1022) that establish procedures for compliance with these Executive
Orders.
Status - Because no activities in wetlands would occur under the no-action alternative, no wetlands would be destroyed.
5.1.12 EXECUTIVE ORDER 12898
Executive Order 12898, "Environmental Justice in Minority and Low-Income Populations," requires
that each federal agency "make environmental justice part of its mission by identifying and addressing, as appropriate,
disproportionately high and adverse human health or environmental effects due to
its programs, policies, or activities on minority or low-income
populations."
Status - This
eis incorporates environmental justice into its
analyses of the no-action alternative.
5.1.13 CULTURAL RESOURCES
Cultural resources on SRS are
subject to the American Indian Religious Freedom Act (42 USC § 1996),
the Native American Graves Protection and Repatriation Act (25 USC § 3001),
and the National Historic Preservation Act (16 USC § 470 et seq.).
The American Indian Religious Freedom Act of 1978 reaffirms Native American
religious freedom under the First Amendment and protects and preserves the
inherent and constitutional right of American Indians to believe, express, and
exercise their traditional religions. The Act requires that federal actions
avoid interfering with access to sacred locations and traditional resources that
are integral to the practice of those religions. The Native American Graves
Protection and Repatriation Act of 1990 directs the Secretary of the Interior to
promote repatriation of federal archaeological collections and collections held
by museums receiving federal funding that are culturally affiliated with Native
American tribes. The American Indian Religious Freedom Act and the Native
American Graves Protection and Repatriation Act require DOE to notify affected
tribes if sites and items of religious importance or human remains and other
objects belonging to Native Americans are discovered on SRS.
Construction of waste management facilities might unearth
artifacts and destroy historic sites regulated by these statutes. Upon
discovery (and before excavation) of human remains, the affiliated tribe(s)
would be consulted to ensure the appropriate disposition of the human remains
and any other objects. DOE has committed to providing the Yuchi Tribal
Organization, Inc., the National Council of the Muskogee Creek, and the Indian
People's Muskogee Tribal Town Confederacy copies of environmental impact
documentation for DOE activities in the Central Savannah River
Valley.
The National Historic Preservation Act, as amended, provides
that sites with significant national historic value be placed on the National
Register of Historic Places. There are no permits or certifications required
under the Act. However, if a particular federal activity may impact a historic
property, consultation with the Advisory Council on Historic Preservation is
required and will usually lead to a Memorandum of Agreement containing
stipulations that must be followed to minimize adverse impacts. Coordination
with the State Historic Preservation Officer also ensures that potentially
significant sites are properly identified and appropriate mitigation actions are
implemented.
Status - DOE
will comply with these Acts with regard to artifacts discovered during
implementation of the no-action alternative.
5.2 Other Alternatives
This section discusses the permit status for the
construction and operation of waste management facilities that would be
implemented under the moderate treatment configuration (alternative B). It also
applies to facilities that would be implemented under the limited treatment
(alternative A) and extensive treatment (alternative C) configurations.
5.2.1 EXPECTED WASTE FORECAST
National Environmental Policy Act - No change from the no-action alternative.
Atomic Energy Act -
No change from the no-action alternative.
Comprehensive Environmental Response, Compensation,
and Liability Act - No change from the
no-action alternative.
Emergency Planning and Community Right-to-Know Act - No change from the no-action alternative.
Resource Conservation and Recovery Act - Facilities required for implementation of the moderate
treatment alternative would be subject to RCRA, the South Carolina Hazardous
Waste Management Act, and the South Carolina Hazardous Waste Management Location
Standards.
All activities under the moderate treatment configuration
would have to be coordinated and compatible with requirements of the Land
Disposal Restrictions Federal Facility Compliance Agreement.
Treatment of low volume and one-time only waste streams in
accordance with generator accumulation requirements (South Carolina Code of Laws
of 1976, as amended, R.61-79.262.34) or via treatability studies is being
considered. RCRA permitting requirements would not apply to these situations.
Federal Facility Compliance Act - The SRS Proposed Site Treatment Plan (WSRC 1995),
which identifies DOE's preferred approach to treating mixed wastes
at SRS, was submitted to the state of South Carolina in accordance with
requirements of the Federal Facility Compliance Act. The site treatment plan addresses mixed wastes currently stored and those wastes SRS
anticipates will be generated in the next 5 years. All mixed waste
management activities would have to comply with the requirements of the approved
site treatment plan and its implementing order.
Clean Water Act - No change from the no-action alternative.
Safe Drinking Water Act - DOE does not know at this time which
permitting requirements would apply to proposed projects, because the precise
location and water supply requirements for these projects are unknown. Permits
may be required if water-line extensions are needed for additional waste
management facilities considered in the alternatives.
Clean Air Act -
The emission permit for construction of the Consolidated Incineration Facility was issued by SCDHEC
in November 1992. Before the Consolidated Incineration Facility can operate,
approval for startup must be granted. Air permits would be required for
emergency power diesel generators for proposed new waste management facilities.
At SRS, air quality permits must also be acquired before a
construction permit is granted.
Endangered Species Act and Other Statutes - The U.S. Fish and Wildlife Service has concurred with DOE's
conclusion that DOE's plans to construct and operate additional waste management
facilities within the uncleared portions of EArea should not affect any
threatened or endangered species. The concurrence letters are included in
Appendix J.
Executive Orders 11990 and 11988 - Facilities and activities considered under the three alternatives may affect wetlands or floodplains, but this cannot be determined until the precise location of any additional facilities is known. Impacts to any wetland that could not be avoided would need to be identified as an unavoidable and irretrievable loss in this eis. Under the alternatives, any impacts to wetlands would be lessened by mitigation as required by the Clean Water Act. Under 10 CFR 1022, floodplain and wetland assessments would be required for any proposed action in a floodplain or wetland.
Executive Order 12898 - No change from the no-action
alternative.
Cultural Resources -
No change from the no-action alternative.
5.2.2 MINIMUM WASTE FORECAST
The difference between the minimum and expected waste
forecasts is that certain facilities may not be needed. Since the waste volumes
anticipated in these configurations would require less treatment capacity, SRS
may be able to implement additional low-volume or one-time only waste management
options that would not require permit modifications (Clean Air Act, Clean Water
Act, RCRA). SRS would receive wastes that it had the best capability to treat
or dispose of, and would ship some of its own wastes to facilities better
equipped to manage them.
5.2.3 MAXIMUM WASTE FORECAST
Regulatory requirements for the maximum waste forecast are the same as those for the expected case. However, permit modifications (Clean Air Act, Clean Water Act, and RCRA) might be required to accommodate the larger volumes of waste. Waste volumes anticipated under this forecast would require additional treatment, storage, and disposal capacity. Under this forecast, the current SRS RCRA permit would need to be modified to increase permitted and/or interim status waste management process capacities. The potential exists to impact wetlands with this forecast. Any impacts to wetlands would be mitigated, as required by the Clean Water Act.
5.3 References
Arnett, M. W., L. K. Karapatakis, and A. R. Mamatey,
1994, Savannah River Site Environmental Report for 1993,
WSRC-TR-94-075, Westinghouse Savannah River Company, Aiken, South
Carolina.
DOE (U.S. Department of Energy), 1987, Final Environmental
Impact Statement, Waste Management Activities for Groundwater
Protection, Savannah River Plant, Aiken, South Carolina,
DOE/eis-0120, Savannah River Operations Office, Aiken, South
Carolina.
WSRC (Westinghouse Savannah River Company), 1995,
Savannah River Site Proposed Site Treatment Plant, Westinghouse
Savannah River Company, Aiken, South Carolina, WSRC-TR-94-0608.
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