ML18019A919

DOE-2011 - TN4888 - DOE 2011 EA-1640 - Fea and Fonsi

ML18019A919
Person / Time
Site:	Clinch River
Issue date:	10/31/2011
From:	US Dept of Energy, Oak Ridge Operations Office
To:	Office of New Reactors
Fetter A
References
DOE/EA-1640
Download: ML18019A919 (126)

Text

DOE/EA-1640 FINAL Environmental Assessment Transfer of Land and Facilities within the East Tennessee Technology Park and Surrounding Area, Oak Ridge, Tennessee Date IssuedOctober 2011 U. S. Department of Energy Oak Ridge Office Oak Ridge, Tennessee 09-033(E)/100511

FINDING OF NO SIGNIFICANT IMPACT TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA OAK RIDGE, TENNESSEE AGENCY: U. S. Department of Energy ACTION: Finding of No Significant Impact.

SUMMARY

The U. S. Department of Energy (DOE) has completed an Environmental Assessment (EA) (DOE/EA-1640) for the conveyance (lease, easement, and/or title transfer) of DOE property located at the East Tennessee Technology Park (ETTP) and surrounding area for mixed use economic development. Leases, easements, and/or title transfers could be entered into with the Community Reuse Organization of East Tennessee (CROET), city of Oak Ridge, other agencies, or private entities. Leasing and title transfers for economic development are allowed under 10 Code of Federal Regulations (CFR) 770, Transfer of Real Property at Defense Nuclear Facilities for Economic Development. Also, 10 CFR 770 gives DOE the discretion to lease or sell (title transfer) property at less than fair market value if the property requires considerable infrastructure improvements to make it economically viable, or if conveyance at less than market value would, in the DOEs judgment, further the public policy objectives of the laws governing the downsizing of defense nuclear facilities.

DOEs action is needed to reduce or eliminate landlord costs, which could include the cost of eventual building demolition within the study area. This is consistent with the goals of the Presidents Memorandum Disposing of Unneeded Federal Real EstateIncreasing Sales Proceeds, Cutting Operating Costs, and Improving Energy Efficiency (June 10, 2010) and helps to free money for reinvestment in cleanup projects to further reduce risks at the site. The conveyance of unneeded property can also help offset economic losses resulting from continued DOE downsizing, facility closures, and workforce restructuring.

Based on the results of the analysis reported in the EA, DOE has determined that the proposed action is not a major federal action that would significantly affect the quality of the human environment within the meaning of the National Environmental Policy Act (NEPA) of 1969. Therefore, the preparation of an Environmental Impact Statement (EIS) is not necessary, and DOE is issuing this Finding of No Significant Impact (FONSI).

PUBLIC AVAILABILITY: The EA and FONSI may be reviewed at and copies of the documents obtained from:

U. S. Department of Energy Information Center 475 Oak Ridge Turnpike Oak Ridge, Tennessee 37830 Phone: (865) 241-4780 FURTHER INFORMATION ON THE NEPA PROCESS: For further information on the NEPA process, contact:

Gary S. Hartman NEPA Compliance Officer U. S. Department of Energy P.O. Box 2001, SE-32 Oak Ridge, Tennessee 37831 Phone: (865) 576-0273

DESCRIPTION OF PROPOSED ACTION: DOE proposes to convey up to approximately 1,800 acres of property located within and surrounding the ETTP. This property includes the majority of the main ETTP plant area, Duct Island, a portion of the former K-25 Powerhouse Area, the K-1251 Barge Loading Area and the land adjacent to it, and land identified as Parcel ED-3. Areas that would not be conveyed include non-development areas and DOE-retained property (retained for a variety of uses or purposes). A large portion of the non-development area is already part of the Black Oak Ridge Conservation Easement (BORCE). The remaining non-development areas have limited development potential because of various constraints such as steep slopes, wetland and floodplain issues, existing infrastructure, and sensitive ecological resources. The DOE-retained property includes the K-1650 Central Control Facility, K-1039 and K-1039-1 Telecommunications Buildings, K-1070-C/D Burial Ground, K-806 and K-814 McKinney Ridge Radio Repeater Stations, and the Transportation Safeguards Division Facility (a National Nuclear Security Administration facility). DOE would also retain custody, control, and maintenance of the cemeteries that are located within the area.

Conveyance of the property would be phased with the option of fee title transfer, easements, or leasing. Upon the completion of the conveyance, the developable portions of the property would be marketed, sold, leased, or utilized by CROET or other owners. The proposed action assumes that the conveyed property would be developed for a mixed use, including but not limited to, industrial, commercial, recreation, tourism (including historic preservation), and open space. In addition to the construction of new facilities or reuse of existing facilities, development activities would also include placement and compaction of earth backfill to establish required building elevations, excavation for the installation of concrete foundations/footings, and infrastructure development including, but not limited to, utility connections. Construction activities would also include vehicle access roads, parking lots, pedestrian walkways, and fire protection facilities and equipment.

Because specific uses may not be known prior to the fee title conveyance or until proposals for leases are developed and reviewed by DOE, reasonably foreseeable uses were developed to bound the analysis in the EA. Industrial uses considered are the permitted principal uses and uses requiring a Board of Zoning Appeals permit in the City of Oak Ridge Zoning Ordinance for IND-1, IND-2, and IND-3, Industrial Districts. Additional commercial and recreational uses are those included in the Zoning Ordinance for UB-2, Unified General Business Districts. The bounding analysis also assumed that the potential uses would be compatible with non-DOE uses in the surrounding area and other ongoing DOE missions and activities. If portions of the parcel are leased prior to being conveyed, DOE would review each proposal to ensure that proposed activities fall within the bounding analysis in this EA. If the proposed uses and their potential impacts were not consistent with the uses and bounding analysis evaluated in the EA, DOE would determine the appropriate level of additional review that would be required prior to implementation.

Although the EA analyzed several potential reuse scenarios for the property being evaluated; it does not eliminate the need for the transferee to complete any required environmental analysis, permits, or consultations, if appropriate, for their proposed future actions. If a transferee would require a federal permit or license, for example, the federal agency, working on behalf of the transferee, would need to complete the required additional processes (e.g., additional NEPA review).

In accordance with the Federal Facility Agreement (FFA) between the DOE-Oak Ridge Office (ORO), the U. S. Environmental Protection Agency (EPA), and the Tennessee Department of Environment and Conservation (TDEC), conveyances would have to comply with the CERCLA Sect. 120(h) requirements. To comply with the CERCLA requirements, a report is prepared that details the baseline environmental condition of the property and requires the identification of hazardous materials that are present, stored, or have been released on the property proposed for transfer. The report also includes information on prior property ownership, past and present property use, as well as past and present activities on adjacent properties and controls identified in remedial action documents. Depending upon the review of historic records, environmental sampling may be conducted, including radiological

surveys, if needed. The resultant data may be used in a risk analysis, if appropriate. The information collected provides the environmental risk management basis for DOEs lease or title transfer decision, notwithstanding the policy-level decision-making that is achieved via the NEPA process.

ALTERNATIVES: In addition to the proposed action, impacts were also evaluated for two additional action alternatives and the no action alternative. Under Alternative 1(Heavy Industrial), DOE would convey the same property that is included in the proposed action. However, instead of the property being developed for mixed uses, it would be developed to support heavy industrial operations only. Alternative 2 (UB-2 Unified General Business Districts) also included the same property as the proposed action. The property would be developed for mixed uses except for industrial. Under the no action alternative, no additional property within the EA study area would be leased or sold for development unless it has already been reviewed under a previous NEPA evaluation. Title transfer activities presently underway at ETTP for all facilities and land areas included in previous NEPA decision documents would continue.

The remainder of the property within the study area would continue to be retained by DOE. Ongoing environmental restoration and waste management activities at ETTP would also continue.

Three other alternatives to the proposed action were considered but eliminated from further analysis.

These included conveyance by lease only, transfer of additional land near the ETTP, and transfer of other ORR land. Transfer of land via lease only did not meet the stated purpose and need for the proposed action because DOE has a programmatic need to reduce its footprint and reduce or eliminate landlord costs at ETTP. DOE also had previously considered additional property located along Bear Creek Road, land located east of Parcel ED-3, and areas along Blair Road. The property along Bear Creek Road was eliminated from further consideration for development due to the power line ROW, sensitive ecological areas, and topography. The additional land along Blair Road and east of Parcel ED-3 was eliminated primarily because of the adverse impact that it would have on the remnants of the historic Wheat Community.

ENVIRONMENTAL IMPACTS: The EA assessed the potential impacts of the proposed action and no action alternatives on the following resources: land use, air quality, noise, geology, soils, water resources, ecological resources, cultural resources, socioeconomics, infrastructure, waste management, and human health and safety. Potential cumulative impacts were also assessed.

Land Use The existing land use of the areas leased and/or transferred would change over time as development occurs. This would be most evident in the areas that have had limited development or presently area primarily undeveloped (e.g., Duct Island, Parcel ED-3). Extensive industrial or commercial development would have the greatest change on the visual character of the property. In the highly disturbed main portion of ETTP, development would not change the existing land use, which has been and is currently industrial in nature. Not all of the areas proposed for conveyance are equally developable because of various constraints such as existing power lines and utility ROWs, floodplains, and cemeteries.

Acceptable land uses will also be based on the results of the CERCLA 120(h) reviews, applicable city of Oak Ridge zoning requirements, and the ability to obtain construction and operating permits and licenses.

Air Quality Since not all of the land parcels would be transferred all at once, construction activities would be phased and air emissions from site development would be short-term, sporadic, and localized. Fugitive dust would be controlled to minimize emissions. The types of commercial businesses and industries that are anticipated to be recruited could produce air emissions (e.g., volatile organic compounds, particulates, etc.) typical of standard industrial and research operations. Minor emissions are typically controlled within the facility using conventional treatment technologies like scrubber systems and particulate filters, and external effects are negligible. New facility operations that have minor air contaminant sources would

be required to obtain air quality construction and operating permits (non-Title V) from TDEC. Major sources of air emissions typical of heavy industries could be subject to a Title V operating permit. A Title V permit is required for any facility operations with the potential to emit more than 100 tons per year of any regulated air pollutant, 10 tons per year of any hazardous air pollutant, and/or 25 tons per year of any combination of hazardous air pollutants.

Noise Other than temporary noise from construction activities, noise levels should remain close to existing levels, and no adverse noise impacts are anticipated. Workers associated with the construction activities would be expected to wear appropriate hearing protection as required by the Occupational Safety and Health Administration (OSHA). Noise compatibility should be a consideration when putting together development plans and may be a factor in obtaining the appropriate building/construction permits, licenses, etc., as part of applicable zoning regulations or ordinances that the private owners/developers would be subject to.

Geology and Soils Many of the affected areas are within currently or previously disturbed areas used for industrial applications. Potentially affected geology and soils are generally stable and acceptable for standard construction requirements. Geotechnical investigations conducted prior to construction would likely identify any significant karst conditions, if present. If appropriate, shallow footings, micro piles, etc.,

would be used to minimize any potential disturbance of underlying geological resources. Ground disturbance would be conducted incrementally to limit the potential for soil erosion and best management practices (i.e., erosion prevention and sediment control) would be implemented. No significant impacts to geology or soils would occur. The Excavation/Penetration Permit Program is a DOE control for operations and ongoing cleanup activities. Deed restrictions could be included that require the property owner to obtain an excavation/penetration permit from DOE, as long as DOEs program is in place. The Zone 1 and Zone 2 Records of Decision have a current restriction on excavation below 10 ft without proper controls. Similar restrictions would be placed in Covenant Deferral Requests, as necessary.

Water Resources Erosion and sedimentation controls would limit potential impacts on surface water. No significant adverse impacts on surface water or groundwater are anticipated from construction and normal facility operations. Use of groundwater would be prohibited via a lease restriction or condition of the deed for title transfer. The restriction is to ensure the protection of human health by preventing exposure to known groundwater contamination in certain areas. The addition of new impervious surfaces would increase the rate and volume of storm water runoff within the affected area. Increases in surface water runoff as a result of new construction would be attenuated through the use of temporary or permanent storm water controls, such as detention or retention basins and other structures, use of permeable pavement, and stabilization of disturbed areas through landscaping and vegetation. The use of these measures would also increase groundwater recharge through direct percolation, offsetting the loss of pervious surface due to construction and minimizing downstream effects. Storm water runoff after construction activities are completed and any discharge from facility operations to surface water would be in accordance with limitations established under the applicable TDEC NPDES permit. Applicable federal, state, and local laws and regulations would apply to any activities that could potentially affect a floodplain or wetlands.

Ecological Resources Adverse environmental impacts to existing habitat or wildlife would be limited because construction activities would primarily occur within existing or previously disturbed areas. Development would result

in the removal of native vegetation and minor habitat fragmentation in some previously developed and undeveloped areas. However, the actual footprint of disturbance in these areas would be relatively small, and there are large areas of similar habitat adjacent to these sites. Normal facility operations would not have any adverse impacts to wildlife or pose any unacceptable ecological risk. The potentially affected areas are primarily industrialized, fragmented, and disturbed; no rare, threatened, and endangered plant and animal species are known to occur, therefore adverse impacts are not anticipated. The DOE license to the Tennessee Wildlife Resources Agency for operating and maintaining the Oak Ridge Wildlife Management Area would need to be amended to exclude those areas that are conveyed. Also, additional safety zones would need to be posted around the perimeter of any new development areas. This could reduce the number of deer harvested from the ORR by a very small percentage; however, the loss of hunting area could possibly be offset by changes in other management parameters, such as permitting an additional hunt or increasing the harvest quota.

Cultural Resources Other than the Happy Valley area within Parcel ED-3, no other prehistoric or historic archaeological resources would be affected by the proposed action. Potential impacts could be indirect or direct, depending upon future development proposals. Known prehistoric sites located along Poplar Creek and the Clinch River are located in DOE-designated non-development areas or they would be protected from development through lease and/or deed restrictions based on consultation with the Tennessee SHPO.

Likewise, the six cemeteries located within the EA study area would remain under DOE control. They would also be protected from any future development activities through the establishment of appropriate buffers around each cemetery. A portion of the Parcel ED-3 area is directly adjacent to the Wheat Historic District, but development would not have any direct adverse impacts on the area, and the view of the George Jones Memorial Baptist Church would not be obscured. Two Happy Valley archaeological sites (40RE233 and 40RE577) have been recommended as eligible for listing in the National Register of Historic Places. Lease and/or deed restrictions would require that if an unanticipated discovery of cultural materials (e.g., human remains, pottery, weapon projectiles, and tools) or sites is made during any development activities, all ground-disturbing activities in the vicinity of the discovery would be halted immediately. The lessee would be responsible for contacting DOE and property owners would be responsible for contacting the Tennessee SHPO, prior to any further disturbance of the discovery-site area. DOE has completed the Section 106 process in consultation with the Tennessee State Historic Preservation Office and the consulting parties.

Socioeconomics The proposed action would have a minor, positive employment and income impact and could generate up to 2,500 new, direct jobs and 3,300 indirect jobs over a 13-year period. Beneficial fiscal impacts would include increased revenue from real estate or sales taxes. Based on the small number of new jobs that would be created, no impact on population is anticipated, and no disproportionate adverse health or environmental impacts would occur to any low-income or minority populations. DOE would not continue the in-lieu-of-tax payments on the property that is conveyed.

Infrastructure Existing utilities have adequate capacity to support additional development, but minor upgrades and modifications would be needed. Electricity would be purchased from the city of Oak Ridge, and natural gas would be purchased from the Oak Ridge Utility District. Telecommunication services could be provided from the fiber-optic system that serves the ETTP. Existing water and sewer lines currently exist along SR 58. In the long-term, the city of Oak Ridge, along with other public and private organizations, is working on completing the extension of utility services to the western portion of the city corporate limits to serve proposed future developments. Transport of construction materials would be over regional and local roadways and would have a negligible effect on existing traffic. Employee traffic could increase

over current levels but would not exceed historic levels. A minor increase in the amount of traffic should also not substantially increase the chance of accidents occurring. Installing turn lanes, additional traffic signals, and frontage roads could mitigate these types of potential impacts, if necessary.

Waste Management Specific details about the wastes that may be generated by companies locating on property that is conveyed and developed are not available; however, the types of uses that are anticipated would produce wastes typical of other industrial, research, and office park operations in the region. These wastes would be handled by the individual companies or by contracted waste management services providers. Solid non-hazardous waste would be recycled or transported to an appropriate licensed landfill for disposal.

Minor quantities of hazardous or radioactive waste may be generated. These wastes would be handled and stored according to applicable state and federal regulations and transported to an approved, licensed, off-site facility for further treatment and/or disposal. It is also possible that some companies may stabilize, test, and treat these wastes on-site as part of their operations. For NRC-licensed facilities, radioactive materials and wastes would be handled according to the conditions of the license. This might include returning the materials and waste to the manufacturer, when required, or stabilizing, testing, and transporting them to a licensed off-site facility for disposal. Impacts from accidental spills would be addressed by individual operating entities through the use of safety procedures and spill prevention plans.

If required by state/federal law, companies locating within the development would have a spill prevention, control, and countermeasures plan and/or an emergency response plan, should a release of hazardous materials (to any environmental mediumair, surface water, groundwater, or soils) occur.

Human Health and Safety Construction workers would be subject to typical hazards and occupational exposures faced at other industrial construction sites. Falls, spills, vehicle accidents, confined-space incidents, and injuries from tool and machinery operation could occur; similar accidents could occur at facilities during operation. No unique occupational health and safety hazards are expected, and it would be the responsibility of each company to operate in a safe and protective manner. Issues related to public and worker exposures to effluents and emissions from industrial operations would be addressed by permits and regulations under the state of Tennessee. It is expected that resources would be available for response to an event such as a fire, release or spill through agreements with ETTP emergency response units and surrounding communities.

Intentional Destructive Acts The likelihood of sabotage and terrorism is extremely low. However, it is possible but highly unlikely that random acts of vandalism could occur. A variety of measures to control access and maintain security would be used.

Cumulative Impacts Potential impacts on the various environmental resources from the proposed action when added with the impacts of other past, present, and reasonably foreseeable future action in the Oak Ridge area would not be significant.

DETERMINATION: Based on the findings of this FONSI, and after careful consideration of all public and agency comments, DOE has determined that the proposed transfer of land and facilities within the EITP and surrounding area does not constitute a major federal action that would significantly affect the quality of the human environment within the context of NEPA. Therefore, preparation of an EIS is not required.

Issued at Oak Ridge, Te , ee, this ~day of October 2011.

John R. Eschenberg, Acting Manager U.S. Department of Energy Oak Ridge Office

DOE/EA-1640 FINAL Environmental Assessment Transfer of Land and Facilities within the East Tennessee Technology Park and Surrounding Area, Oak Ridge, Tennessee Date IssuedOctober 2011 U. S. Department of Energy Oak Ridge Office Oak Ridge, Tennessee 09-033(E)/100511

CONTENTS FIGURES...................................................................................................................................................... v TABLES ....................................................................................................................................................... v ACRONYMS..............................................................................................................................................vii

1. INTRODUCTION .............................................................................................................................1-1 1.1 PURPOSE AND NEED FOR ACTION ................................................................................1-1

1.2 BACKGROUND

....................................................................................................................1-1 1.3 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT......................................................1-2

2. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES..............................................2-1 2.1 PROPOSED ACTION ...........................................................................................................2-1 2.1.1 Land Use Scenarios and Assumptions ......................................................................2-2 2.1.2 CERCLA 120(h) Compliance ...................................................................................2-3 2.2 ALTERNATIVE 1 - HEAVY INDUSTRIAL ......................................................................2-4 2.3 ALTERNATIVE 2 - UB-2 UNIFIED GENERAL BUSINESS DISTRICTS.......................2-5 2.4 NO ACTION ALTERNATIVE .............................................................................................2-6 2.5 ALTERNATIVES CONSIDERED BUT ELIMINATED .....................................................2-6 2.5.1 Conveyance by Lease Only.......................................................................................2-6 2.5.2 Transfer of Additional Land Near the ETTP.............................................................2-6 2.5.3 Transfer of Other Oak Ridge Reservation Land........................................................2-6

3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ...........................3-1 3.1 LAND USE ............................................................................................................................3-1 3.1.1 Existing Conditions ...................................................................................................3-1 3.1.2 Environmental Consequences ...................................................................................3-3 3.2 AIR QUALITY AND NOISE ................................................................................................3-4 3.2.1 Existing Conditions ...................................................................................................3-4 3.2.2 Environmental Consequences ...................................................................................3-5 3.3 GEOLOGY AND SOILS .......................................................................................................3-7 3.3.1 Existing Conditions ...................................................................................................3-7 3.3.2 Environmental Consequences ...................................................................................3-9 3.4 WATER RESOURCES........................................................................................................3-10 3.4.1 Existing Conditions .................................................................................................3-10 3.4.2 Environmental Consequences .................................................................................3-14 3.5 ECOLOGICAL RESOURCES ............................................................................................3-16 3.5.1 Existing Conditions .................................................................................................3-16 3.5.2 Environmental Consequences .................................................................................3-21 3.6 CULTURAL RESOURCES.................................................................................................3-22 3.6.1 Existing Conditions .................................................................................................3-22 3.6.2 Environmental Consequences .................................................................................3-24 3.7 SOCIOECONOMICS ..........................................................................................................3-25 3.7.1 Existing Conditions .................................................................................................3-25 3.7.2 Environmental Consequences .................................................................................3-27 3.8 INFRASTRUCTURE...........................................................................................................3-31 3.8.1 Existing Conditions .................................................................................................3-31 3.8.2 Environmental Consequences .................................................................................3-32 09-033(E)/100511 iii

3.9 WASTE MANAGEMENT ..................................................................................................3-33 3.9.1 Existing Conditions .................................................................................................3-33 3.9.2 Environmental Consequences .................................................................................3-34 3.10 HUMAN HEALTH AND SAFETY ....................................................................................3-35 3.10.1 Existing Conditions .................................................................................................3-35 3.10.2 Environmental Consequences .................................................................................3-37 3.11 INTENTIONAL DESTRUCTIVE ACTS............................................................................3-38 3.12

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES ...............................................3-38

4. CUMULATIVE IMPACTS...............................................................................................................4-1 4.1 POTENTIALLY CUMULATIVE ACTIONS .......................................................................4-1 4.2 CUMULATIVE IMPACTS BY RESOURCE AREA ...........................................................4-4

5. REFERENCES ..................................................................................................................................5-1 APPENDIX A - CORRESPONDENCE .................................................................................................. A-1 APPENDIX B - COMMENTS AND RESPONSES TO THE DRAFT ENVIRONMENTAL ASSESSMENT................................................................................................................................. B-1 09-033(E)/100511 iv

FIGURES 1.1 EA study area.....................................................................................................................................1-3 3.1 Zone 1 and Zone 2 at ETTP...............................................................................................................3-2 3.2 Geologic map of ETTP. .....................................................................................................................3-8 3.3 The 100-year and 500-year floodplain and surveyed wetlands in the ETTP area. ..........................3-13 3.4 Natural areas and sensitive terrestrial and aquatic habitats in the ETTP area. ................................3-20 4.1 Location of actions contributing to cumulative impacts. ...................................................................4-2 TABLES 3.1 Roane County emissions for 2002 .....................................................................................................3-4 3.2 Animal species of concern reported from the ORR.........................................................................3-18 3.3 Currently known or previously reported vascular plant species reported from the ORR listed by state or federal agencies ..............................................................................................................3-19 3.4 Demographic and economic characteristics: Oak Ridge Region of Influence ................................3-26 3.5 Race or ethnic distribution for Oak Ridge City population: 2010 ...................................................3-26 3.6 City of Oak Ridge revenues and expenditures, FY 2010 and budgeted FY 2012 ($)......................3-27 3.7 Summary of impacts by resource.....................................................................................................3-39 09-033(E)/100511 v

ACRONYMS AMSL above mean sea level ASER Annual Site Environmental Report BORCE Black Oak Ridge Conservation Easement C&D construction and demolition CDR covenant deferral request CEQ Council on Environmental Quality CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CFR Code of Federal Regulations CNF Central Neutralization Facility CPD clean parcel determination CRMP Cultural Resource Management Plan CRO community reuse organization CROET Community Reuse Organization of East Tennessee D&D decontamination and decommissioning dBA A-weighted decibels DCG derived concentration guideline DOE U. S. Department of Energy EA Environmental Assessment EDE effective dose equivalent EIS Environmental Impact Statement EM Environmental Management EPA U. S. Environmental Protection Agency EPCRA Emergency Planning and Community Right-To-Know Act ES&H environmental safety and health ETTP East Tennessee Technology Park FFA Federal Facility Agreement FONSI Finding of No Significant Impact FY fiscal year GPD gallons per day HI hazard index HQ hazard quotient IFDP Integrated Facility Disposition Project LLW Low-level (radioactive) waste MEI maximally exposed individual MGD million gallons per day MOA Memorandum of Agreement mrem millirem MVA megavolt-ampere NA natural area NAAQS National Ambient Air Quality Standards NEI National Emissions Inventory NEPA National Environmental Policy Act of 1969 NERP National Environmental Research Park NESHAP National Emission Standards for Hazardous Air Pollutants NPDES National Pollutant Discharge Elimination System NPS National Park Service NRC U. S. Nuclear Regulatory Commission NRHP National Register of Historic Places09-033(E)/100511 vii

OMB Office of Management and Budget ORNL Oak Ridge National Laboratory ORO Oak Ridge Office ORR Oak Ridge Reservation ORSTP Oak Ridge Science and Technology Project ORWMA Oak Ridge Wildlife Management Area OSHA Occupational Safety and Health Administration PCB polychlorinated biphenyl PIF Partners in Flight PILT payment in lieu of taxes POTW Publicly Owned Treatment Works R&D research and development RCRA Resource Conservation and Recovery Act of 1976 ROD Record of Decision ROI region of influence ROW right-of-way S&M surveillance and maintenance SHPO State Historic Preservation Officer SR state route STP Sewage Treatment Plant TDEC Tennessee Department of Environment and Conservation TSCA Toxic Substances Control Act of 1976 TVA Tennessee Valley Authority TWRA Tennessee Wildlife Resources Agency USACE U. S. Army Corps of Engineers VOC volatile organic compound 09-033(E)/100511 viii

1. INTRODUCTION 1.1 PURPOSE AND NEED FOR ACTION The proposed action evaluated in this Environmental Assessment (EA) is the conveyance (lease, easement, and/or title transfer) of U. S. Department of Energy (DOE) property located at the East Tennessee Technology Park (ETTP) and surrounding area for mixed use economic development.

Leases, easements, and/or title transfers could be entered into with the Community Reuse Organization of East Tennessee (CROET), city of Oak Ridge, other agencies, or private entities. Leasing and title transfers for economic development are allowed under 10 Code of Federal Regulations (CFR) 770, Transfer of Real Property at Defense Nuclear Facilities for Economic Development. Also, 10 CFR 770 gives DOE the discretion to lease or sell (title transfer) property at less than fair market value if the property requires considerable infrastructure improvements to make it economically viable, or if conveyance at less than market value would, in the DOEs judgment, further the public policy objectives of the laws governing the downsizing of defense nuclear facilities.

DOEs action is needed to reduce or eliminate landlord costs, which could include the cost of eventual building demolition within the study area. This also helps to free money for reinvestment in cleanup projects to further reduce risks at the site. The conveyance of unneeded property can also help offset economic losses resulting from continued DOE downsizing, facility closures, and workforce restructuring.

1.2 BACKGROUND

The study area for the EA includes approximately 5,000 acres located in the northwestern portion of the Oak Ridge Reservation (ORR) and includes the developed portion of the ETTP (Fig. 1.1). In 1996, DOE began a Reindustrialization Program to make land, facilities, and equipment at ETTP available for use by private-sector businesses and industries. As part of the reindustrialization effort, DOE and CROET are transitioning the former gaseous diffusion plant to a private industrial/business park known as the Heritage Center.

CROET is the DOE-recognized community reuse organization (CRO) engaged in furtherance of economic development for Oak Ridge, including the ORR. DOE has made some of its underutilized facilities and land parcels at ETTP available for lease or title transfer and, in turn, they have been subleased or sold to private-sector firms. DOE has also been transferring facilities and utility infrastructure to the city of Oak Ridge. More information about DOEs Reindustrialization Program at ETTP is available on the web at: http://www.ettpreuse.com.

Commercial use of the ETTP main plant area does not constitute a change of the primary use of the property, which has been industrial for over 60 years. Other portions of the area (e.g., Parcel ED-3) have been previously developed but have been relatively undisturbed for more than 50 years. The remainder of the study area, which is not being considered for transfer consists of large, open tracts of undeveloped land [e.g., Black Oak Ridge Conservation Easement (BORCE) area] and various other uses [i.e., some DOE facilities, utility rights-of-way (ROWs) and infrastructure, roads, etc.].

The study area has been the subject of previous National Environmental Policy Act of 1969 (NEPA) decisions and land use planning efforts. NEPA decisions include the Final Environmental Assessment for the Lease of Land and Facilities Within the East Tennessee Technology Park, DOE/EA-1175 (DOE 1997) and the Final Environmental Assessment Addendum for the Title Transfer of ETTP Land and Facilities,09-033(E)/100511 1-1

DOE/EA-1175-A (DOE 2003). Land use planning efforts include the Oak Ridge Reservation Ten-Year Site Plan (DOE 2007) and the land use planning process conducted in 2001 documented in the Final Report of the Oak Ridge Land Use Planning Focus Group (2002) and Land Use Technical Report (ORNL 2002).

The 2001 land use planning effort took place to develop suggestions for the utilization of land in the northwest portion of the ORR. As part of the process, four land use scenarios were developed and analyzed in the technical report prepared for the process (ORNL 2002). Land uses that were considered for the four scenarios included greenspace, conservation, and research; industrial/commercial; office; residential; and open space. Additional information on the land use planning process is also available on the web at: http://landuseplanning.ornl.gov.

For the four land use scenarios considered, there was general agreement on the use of approximately 87% of the land under consideration. The Focus Group1 did not reach a consensus on the preferred use for the remaining land, which included the area designated as Parcel ED-3 and former city of Oak Ridge self-sufficiency Land Parcel 8 located along the west end of Bear Creek Road (Fig. 1.1). Based on the results of the land use planning process, DOE reconfigured Parcel ED-3. Due to the physical attributes not being suited for development, the property along Bear Creek Road is no longer being considered for transfer.

DOE is using its Reindustrialization Program experience, information from CROET, and results of the previous land use planning efforts to perform this EA, which primarily covers additional mixed uses within ETTP and the surrounding area that were not considered in previous NEPA decisions. The areas proposed for conveyance are not needed for mission purposes and, therefore, are consistent with the 2001 land use planning process.

1.3 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT DOE has prepared this EA to assess the potential consequences of the proposed action on the human environment in accordance with the Council on Environmental Quality (CEQ) regulations (40 CFR Parts 15001508) implementing NEPA and the DOE NEPA Implementing Procedures (10 CFR 1021). If the impacts associated with the proposed action are not identified as significant as a result of this EA, DOE may issue a Finding of No Significant Impact (FONSI) and proceed with the action. If impacts are identified as potentially significant, an Environmental Impact Statement (EIS) will be prepared.

This EA (1) describes the existing environment within the EA study area relevant to potential impacts of the proposed action and alternatives; (2) analyzes potential environmental impacts that could result from the proposed action and alternatives; and (3) identifies and characterizes cumulative impacts that could result from the conveyance of DOE property in relation to other ongoing or proposed activities within the surrounding area.

Certain aspects of the proposed action have a greater potential for creating adverse environmental impacts than others. For this reason, CEQ regulations (40 CFR 1502.1 and 1502.2) recommend a sliding-scale approach so that those actions with greater potential effect can be discussed in greater detail in NEPA documents than those that have little potential for impact.

1 The Focus Group was comprised of a broad cross-section of the community, as well as representatives from agencies and organizations having an interest in the future of Oak Ridge Reservation land.09-033(E)/100511 1-2

PRIVATE OWNERSHIP BLACK OAK RIDGE CONSERVATION EASEMENT TVA PROPERTY BLACK OAK RIDGE CONSERVATION EASEMENT K-806/K-814 DUCT ISLAND K-1650 K-1070 C/D FORMER POWERHOUSE PARCEL ED-3 AREA K-1039 RARITY K-1039-1 RIDGE DEVELOPMENT TRANSPORTATION SAFEGUARDS DIVISION PARCEL ED-3 K-1251 BARGE LOADING AREA TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA OAK RIDGE, TENNESSEE INDUSTRIAL PARK Fig. 1.1. EA study area.

1-3

Because the actual future uses of the property are not currently known, a bounding analysis was used to estimate potential impacts. A bounding analysis is prepared when no specific activity has been identified for analysis. Because of the lack of detail of a future use or uses, especially in the case of a land transfer for development purposes, the bounding analysis typically uses conservative assumptions and analytical methods to estimate (i.e., bound) the maximum value of a potential environmental impact. In this EA, reasonably foreseeable land uses and their associated environmental effects are addressed. The bounding analysis is based on the various types of industrial, commercial, and recreational uses that would be compatible for the property. This assumption is based on the types of businesses that are currently operating at ETTP, in nearby industrial parks (e.g., Bethel Valley Industrial Park), and those proposed for the Horizon Center, which is an industrial/business park located adjacent to the EA study area. The proposed uses would complement the industrial base being developed at the ETTP and the Horizon Center by providing related business-support needs. Based on information about these uses, assumptions were developed regarding potential emissions, effluents, waste streams, services, and infrastructure. Finally, technical experts analyzed the potential for adverse impacts and defined commonly used measures that could be used to reduce or mitigate potential impacts.09-033(E)/100511 1-5

2. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES 2.1 PROPOSED ACTION Under the proposed action, DOE could convey up to approximately 1,800 acres of property located within the EA study area (Fig. 1.1). This property includes the majority of the main ETTP plant area, Duct Island, a portion of the former K-25 Powerhouse Area, the K-1251 Barge Loading Area and the land adjacent to it, and land identified as Parcel ED-3.

Areas that would not be conveyed include non-development areas and DOE-retained property (retained for a variety of uses or purposes). These areas are also shown on Fig. 1.1. A large portion of the non-development area is already part of the BORCE. The remaining non-development areas have limited development potential because of various constraints such as steep slopes, wetland and floodplain issues, existing infrastructure, and sensitive ecological resources. The DOE-retained property includes the K-1650 Central Control Facility, K-1039 and K-1039-1 Telecommunications Buildings, K-1070-C/D Burial Ground, K-806 and K-814 McKinney Ridge Radio Repeater Stations, and the Transportation Safeguards Division Facility (a National Nuclear Security Administration facility). DOE would also retain custody, control, and maintenance of the cemeteries that are located within the area.

Conveyance of the property would be phased with the option of fee title transfer, easements, or leasing. Under 10 CFR 770, DOE has the discretion to lease or sell (title transfer) property for economic development at less than fair market value if the property requires considerable infrastructure improvements to make it economically viable, or if conveyance at less than market value would, in the DOEs judgment, further the public policy objectives of the laws governing the downsizing of defense nuclear facilities.

Upon the completion of the conveyance, the developable portions of the property would be marketed, sold, leased, or utilized by CROET or other owners. The proposed action assumes that the conveyed property would be developed for a mixed use, including but not limited to, industrial, commercial, recreation, tourism (including historic preservation), and open space. In addition to the construction of new facilities or reuse of existing facilities, development activities would also include placement and compaction of earth backfill to establish required building elevations, excavation for the installation of concrete foundations/footings, and infrastructure development including, but not limited to, utility connections. Construction activities would also include vehicle access roads, parking lots, pedestrian walkways, and fire protection facilities and equipment.

DOE acknowledges that the Metropolitan Knoxville Airport Authority is performing a preliminary feasibility study to evaluate locations on the ORR for a general aviation airport. However, the decision on an airport is not ripe for analysis at this time. Once that study is complete, it is possible that an area within or outside the study area could be found suitable for the airport. If that happens, additional NEPA review would be necessary.

The National Park Service (NPS) completed a Special Resource Study/EA and issued a FONSI for the preservation and interpretation of historic sites of the Manhattan Project for potential inclusion in the National Park system. The EA and FONSI were adopted by DOE in February 2011 (DOE/EA-1868).

DOE recognizes that the NPS concluded in the FONSI that an interpretive component of an NPS unit would be located in Oak Ridge. Final details of the decision have not been determined as of this writing, nor has funding been appropriated. However, as indicated above, historic preservation is included as a component of tourism in the proposed action.09-033(E)/100511 2-1

2.1.1 Land Use Scenarios and Assumptions Because specific uses may not be known prior to the fee title conveyance or until proposals for leases are developed and reviewed by DOE, reasonably foreseeable uses have been developed to bound the analysis in this EA. Industrial uses considered are the permitted principal uses and uses requiring a Board of Zoning Appeals permit in the City of Oak Ridge Zoning Ordinance for IND-1, IND-2, and IND-3, Industrial Districts. Additional commercial and recreational uses are those included in the Zoning Ordinance for UB-2, Unified General Business Districts. These uses could include, but are not limited to, the following:

• Light to heavy processing, manufacturing, assembly, and fabrication plants, excluding slaughtering plants and paper or pulp mills.

• Public utility facilities with or without storage yards.

• Storage; wholesaling; distribution; warehousing, including shipping and freight terminals; and related facilities.

• Research and testing facilities, including renewable and advanced energy, industrial, and scientific research laboratories that include incidental pilot plant processing operations.

• Administrative, technical, and professional offices.

• Storage facilities for materials such as, but not limited to, salt, switchgrass, other alternative fuel feedstocks, coal, coke, building material, sand, gravel, stone, lumber, and enclosed or open storage of construction contractors equipment and supplies.

• Waste treatment facilities, including nonhazardous waste recycling centers, hazardous and mixed waste treatment for shipment to off-site storage and disposal facilities.

• Recycling operations, including those for radioactively contaminated materials and those associated with metal and other material treatment and processing.

• Bulk oil and gasoline storage or bulk storage of natural gas.

• Power plants, including renewable energy generation.

• Broadcasting, publishing, recording, and telecommunications.

• Food processing such as dairy products, bakery products, and beverage products (all activities are conducted in an enclosed building).

• Airports.

• Commercial uses, including restaurants and service establishments such as: gas station/convenience store, bank, post office/mailing/shipping center, copying/printing, bulk cleaning and laundry, cold storage lockers, furniture and carpet warehouses, car washes, equipment and appliance repair, vehicle service centers etc.

• Public recreation uses such as parks, historic legacy interpretation, playgrounds, golf courses, athletic fields, and stadiums.09-033(E)/100511 2-2

The bounding analysis used in this EA assumes that the potential uses would be compatible with other non-DOE uses in the surrounding area. The uses would also be compatible with other ongoing DOE missions and activities. If portions of the parcel are leased prior to being conveyed, DOE would review each proposal to ensure that proposed activities fall within the bounding analysis in this EA. If the proposed uses and their potential impacts were not consistent with the uses and bounding analysis evaluated in the EA, DOE would determine the appropriate level of additional review that would be required prior to implementation.

DOE has also based the bounding analysis in this EA on the following assumptions:

• The city of Oak Ridge would review development plans to ensure compliance with all applicable zoning ordinance requirements and other engineering-related ordinances and standards.

• Construction activities involving ground disturbance would be conducted incrementally to limit the potential for soil erosion.

• Sensitive resources, including cultural resources, would be protected as necessary through the use of deed restrictions and compliance with all applicable local, state, and federal regulations.

• State and federal storm water regulations to minimize erosion and sedimentation would be met. As applicable, notification of any disturbance would be made to the appropriate authorities prior to construction activities.

• Future owners and/or occupants would be responsible for seeking and obtaining any applicable federal, state, and/or local permits and licenses for activities and operations at their facilities.

Examples include building permits, permits for air emissions, industrial wastewater discharge permits, Resource Conservation and Recovery Act of 1976 (RCRA) permits, etc.

• Future occupants of the property proposed for transfer may include companies engaged in the handling or use of radioactive materials and other radiological operations. The company or companies would be required to obtain all necessary permits and licenses, including radiological licenses from the U. S. Nuclear Regulatory Commission (NRC). This would entail the required analyses to ensure that members of the public are protected, including DOE and contractor employees.

• Certain uses, especially those that would require additional permits or licenses for construction and/or operation (e.g., airport, power plant), could require a more detailed environmental review that would be performed by the applicable permitting agency.

• Conveyances would comply with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) Sect. 120(h) requirements and any applicable land use controls identified in Zone 1 and Zone 2 remedial action documents.

2.1.2 CERCLA 120(h) Compliance In accordance with the Federal Facility Agreement (FFA) between the DOE-Oak Ridge Office (ORO), the U. S. Environmental Protection Agency (EPA), and the Tennessee Department of Environment and Conservation (TDEC), conveyances would have to comply with the CERCLA Sect.

120(h) requirements. To comply with the CERCLA requirements, a report is prepared that details the baseline environmental condition of the property and requires the identification of hazardous materials that are present, stored, or have been released on the property proposed for transfer. The report also 09-033(E)/100511 2-3

includes information on prior property ownership, past and present property use, as well as past and present activities on adjacent properties and controls identified in remedial action documents. Depending upon the review of historic records, environmental sampling may be conducted, including radiological surveys, if needed. The resultant data may be used in a risk analysis, if appropriate. The information collected provides the environmental risk management basis for DOEs lease or title transfer decision, notwithstanding the policy-level decision-making that is achieved via the NEPA process. Once a deed has been executed, the DOE Realty Office files the pertinent CERCLA 120(h) documentation, including a Notice of Contamination, if applicable, with the appropriate county courthouse.

In accordance with CERCLA Sect. 120(h), for any real property on which any hazardous substance was stored for one year or more, known to have been released, or disposed of, each deed entered into for the transfer of such property by the United States to any other person or entity, shall contain a covenant warranting that all remedial action necessary to protect human health and the environment has been taken before the date of such transfer. However, CERCLA Sect. 120(h) also provides that the EPA Regional Administrator, with concurrence from the Governor of the State in which the facility is located, may defer the requirement for the covenant in the deed warranting that all necessary remedial actions have been completed if the deed contains assurances that (1) provide for any necessary restrictions on the use of the property for the protection of human health and the environment; (2) provide that there will be restrictions on use necessary to ensure that required remedial investigations, response actions, and oversight activities will not be disrupted; (3) provide that all necessary response actions will be taken; and (4) provide that the responsible Federal agency will submit a budget request to the Director of the Office of Management and Budget that adequately addresses schedules for investigation and completion of all necessary response actions. This covenant deferral request (CDR) is submitted by DOE, along with the information supporting the environmental risk management for the property, to the EPA Region 4 Administrator and the Governor of the State of Tennessee for approval. Property determined to be uncontaminated based on a clean parcel determination (CPD) does not require a covenant warranting that all remedial action necessary to protect human health and the environment has been taken before the date of transfer. EPA has concurred with DOEs determination that several parcels at ETTP (e.g., Parcel ED-3 and ED-4) satisfy the statutory criteria for identification as uncontaminated and that the transfer of those parcels could be achieved by a CPD per CERCLA Sect. 120(h)(4).

2.2 ALTERNATIVE 1 - HEAVY INDUSTRIAL Under Alternative 1, DOE would convey the same property that is included in the proposed action.

However, instead of the property being developed for mixed uses, it would be developed to support heavy industrial operations only. Permitted principal uses and uses requiring a Board of Zoning Appeals permit are included in the City of Oak Ridge Zoning Ordinance for IND-3, Industrial Districts. These uses could include, but are not limited to, the following:

• heavy manufacturing, excluding slaughtering plants and paper or pulp mills;

• warehousing and wholesaling facilities, including truck and rail service terminals;

• public utility facilities with or without storage yards;

• research and development (R&D) with or without outside storage or operations;

• nonhazardous waste recycling centers;

• hazardous and nuclear material collection, recycling, treatment, or disposal and storage areas;

• bulk oil and gasoline storage or bulk storage of natural gas;

• airports; and

• power plants.09-033(E)/100511 2-4

Like the proposed action, conveyance of the property would be phased with the option of fee title transfer, easement, or leasing. The balance of the area includes the land and facilities covered by previous NEPA decisions, non-development areas, and DOE-retained property (see Sect. 2.1). The bounding analysis assumptions presented in Sect. 2.1.1 would also apply to this alternative as well as the CERCLA 120(h) compliance requirements and any applicable land use controls identified in Zone 1 and Zone 2 remedial action documents.

2.3 ALTERNATIVE 2 - UB-2 UNIFIED GENERAL BUSINESS DISTRICTS Under Alternative 2, DOE would convey the same property that is included in the proposed action.

Like the proposed action, the property would be developed for mixed uses except for industrial. Permitted principal uses and uses requiring a Board of Zoning Appeals permit are included in the City of Oak Ridge Zoning Ordinance for UB-2, Unified General Business Districts. These uses could include, but are not limited to, the following:

• Any retail business, whose principal activity is the sale of merchandise in an enclosed building.

• Administrative, technical, and professional offices.

• Commercial uses, including restaurants and service establishments such as: gas station/convenience store, bank, post office/mailing/shipping center, copying/printing, bulk cleaning and laundry, cold storage lockers, furniture and carpet warehouses, car washes, equipment and appliance repair, vehicle service centers etc.

• Theaters, radio and television studio, assembly hall, concert hall, dance hall, bowling alley, skating rink, or similar recreation use or place of assembly.

• Church, school, or public library.

• Public utility facilities without storage yards.

• Research laboratory, including incidental pilot plant processing operations.

• Commercial greenhouse or nursery.

• Family day care home, childcare center, and private education institution.

• Hospital or clinic, excluding animal hospital, penal or correctional institution.

• Mortuary establishment or cemetery.

• Public recreation uses such as parks, playgrounds, golf courses, athletic fields, and stadiums.

Like the proposed action, conveyance of the property would be phased with the option of fee title transfer or leasing. The balance of the EA study area includes the land and facilities covered by previous NEPA decisions (see Sect. 1.2), non-development areas, and DOE-retained property (see Sect. 2.1). The bounding analysis assumptions presented in Sect. 2.1.1 would also apply to this alternative as well as the CERCLA 120(h) compliance requirements and any applicable land use controls identified in Zone 1 and Zone 2 remedial action documents.09-033(E)/100511 2-5

2.4 NO ACTION ALTERNATIVE The no action alternative provides an environmental baseline with which impacts of the proposed action and alternatives can be compared, and is required by the DOE NEPA regulations.

Under the no action alternative, no additional property within the EA study area would be leased or sold for development unless it has already been reviewed under a previous NEPA evaluation. Title transfer activities presently underway at ETTP for all facilities and land areas included in previous NEPA decision documents would continue. The remainder of the property within the study area would continue to be retained by DOE. Ongoing environmental restoration and waste management activities at ETTP would also continue.

2.5 ALTERNATIVES CONSIDERED BUT ELIMINATED 2.5.1 Conveyance by Lease Only Transfer of land via lease only would not meet the stated purpose and need for the proposed action because DOE has a programmatic need to reduce its footprint to help foster economic development. A lease-only program would introduce marginally higher costs to DOE because personnel would need to be kept in place to manage the leases. Furthermore, CROET or other entities need to own the property in order to market it effectively. It is difficult for a CRO, or any organization, to market property they do not own, and especially for an interested tenant or purchaser to obtain financing for land they cannot own. A lease-only program would also not meet the need for DOE to reduce or eliminate landlord costs at ETTP.

Thus, this alternative was eliminated from further analysis.

2.5.2 Transfer of Additional Land Near the ETTP The land use planning process conducted in 2001 (see Sect. 2.1) also evaluated land use scenarios that included development of DOE property located along Bear Creek Road and additional land located east of Parcel ED-3 and along Blair Road. The property along Bear Creek Road was eliminated from further consideration for development due to the power line ROW, sensitive ecological areas, and topography. The additional land along Blair Road and east of Parcel ED-3 was eliminated primarily because of the adverse impact that it would have on the remnants of the historic Wheat Community. Thus, this alternative was eliminated from further analysis.

2.5.3 Transfer of Other Oak Ridge Reservation Land At the present time, DOE has not identified any other large consolidated areas of the ORR as underutilized, surplus, or excess that would qualify as being eligible for transfer for economic development. Thus, this alternative was dismissed from detailed consideration and further analysis.09-033(E)/100511 2-6

3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES This chapter provides the existing conditions and background information for evaluating the potential environmental impacts of the proposed action and alternatives. This chapter also includes the impact analysis and discussion of project attributes that could have the potential for significant impacts.

3.1 LAND USE 3.1.1 Existing Conditions The EA study area consists of approximately 5,000 acres. Areas that have been impacted by DOE activities in the past account for roughly 2,200 of the 5,000 acres. As part of the cleanup of ETTP, DOEs Environmental Management (EM) Program has divided the potentially impacted area of ETTP into two areas: outside the main fence (Zone 1 - 1,400 acres) and inside the main fence (Zone 2 - 800 acres).

Historically, Zone 1 was used for light industrial purposes and has some open areas and some areas of waste disposal. Zone 2 is the main plant area and has historically had a heavy industrial use (Fig. 3.1).

Major changes to the land use within ETTP have not occurred since the completion of the Final Environmental Assessment for the Lease of Land and Facilities Within the East Tennessee Technology Park, DOE/EA-1175 (DOE 1997). The ETTP mission has been to remediate the site, as well as reindustrialize and reuse site assets through leasing and title transfer of underutilized facilities and land parcels. EM Program projects at ETTP have included both remedial action and decontamination and decommissioning (D&D) activities. Remedial action projects typically address contaminant releases to the environment by addressing contaminated soil, water, sediment, or biota. Remedial action projects are based on land use goals and the associated exposure risks as analyzed in a Record of Decision (ROD) document. In many instances, remediation efforts result in long-term controls on the use of land. D&D projects address contamination in facilities and structures and can also include demolition. Additional information on the ongoing environmental restoration and waste management activities at ETTP can be found in the 2009 ORR Annual Site Environmental Report (ASER) [DOE 2010a], fiscal year (FY) 2009 Cleanup Progress Report (DOE 2010b), and the 2010 Remediation Effectiveness Report (DOE 2010c).

Areas outside of Zone 1 within the EA study area include a large portion of McKinney Ridge east of Blair Road, Pine Ridge between state route (SR) 58 and Bear Creek Road, and Parcel ED-3. Except for a few roads, utility easements, and water tanks, much of the McKinney Ridge and Pine Ridge area is relatively undeveloped and is primarily used for a facility buffer, wildlife management, forestry, and environmental monitoring and research. The majority of Parcel ED-3 has been previously disturbed (see Sect. 3.6.1). Parcel ED-3 is currently being used for roads and utility easements, facility buffer, and wildlife management. The temporary Haul Road, currently used for truck transport of waste materials from ETTP, transects the eastern portion of the parcel from north to south. Currently, the only activities conducted at Parcel ED-3 occur at the trailers and sheds located in the northeastern corner of the parcel.

These facilities are used for office space and equipment storage by Restoration Services, Inc., in support of ongoing EM activities.09-033(E)/100511 3-1

TVA PROPERTY DUCT ISLAND FORMER POWERHOUSE AREA LEGEND: TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA OAK RIDGE, TENNESSEE Fig. 3.1. Zone 1 and Zone 2 at ETTP.

3-2

3.1.2 Environmental Consequences 3.1.2.1 Proposed action Within the area proposed for lease and/or title transfer, the present land use of the parcel would change over time as development occurs. This would be most evident in the areas that have had limited development or presently are primarily undeveloped (e.g., Duct Island, Parcel ED-3). In these areas, the visual character of the property could change from a more natural to a more man-made-looking environment. This change would only occur for those uses that would require extensive industrial or commercial development. In the highly disturbed main portion of ETTP, development would not change the existing land use, which has been and is currently industrial in nature. Under the proposed action, recreation, tourism (including historic preservation), and open space uses would add to the future land use mix. Land use and visual impacts would be minimized if heavier industrial uses are sited on previously disturbed areas that have historically been used for industrial operations. Similarly, while lighter industrial, commercial, and recreational uses would be located in the other areas proposed for transfer.

Additionally, not all of the area proposed for conveyance is equally developable because of various constraints such as existing power lines and utility ROWs, floodplains, and cemeteries. Acceptable land uses will also be based on the results of the CERCLA 120(h) reviews, applicable city of Oak Ridge zoning requirements, and the ability to obtain construction and operating permits and licenses.

3.1.2.2 Alternative 1 Potential land use impacts under Alternative 1 are expected to be similar to those described for the proposed action. However, since this alternative assumes greater industrial development, it is assumed that a larger portion of the area proposed for conveyance could be developed. This could result in greater adverse visual impacts for those areas that are presently undeveloped or only contain limited development. However, the overall impact would depend on the density of the industrial development determined through the applicable regulatory process (i.e., licensing, permitting) and any specific requirements of the Oak Ridge Zoning Ordinance.

3.1.2.3 Alternative 2 Land use impacts under Alternative 2 are expected to be similar to those described for the proposed action. However, since industrial uses would not be permitted under the City of Oak Ridge Zoning Ordinance for UB-2, Unified General Business Districts, potential adverse visual impacts typically associated with heavy industrial development would not occur. Development plans that incorporate appropriate buffers and landscaping, as well as modern building architecture that is designed to blend in with the surrounding environment, would also help to minimize adverse impacts.

3.1.2.4 No action Under the no action alternative, the existing land use would continue, and the land would remain as DOE property until any future disposition could be decided. Ongoing and planned remedial actions and reindustrialization activities would continue.09-033(E)/100511 3-3

3.2 AIR QUALITY AND NOISE 3.2.1 Existing Conditions 3.2.1.1 Air quality Air quality is determined by the type and amount of pollutants emitted into the atmosphere, the size and topography of the air basin, and the prevailing meteorological conditions. The levels of pollutants are generally expressed in terms of concentration, either in units of parts per million or micrograms per cubic meter.

The baseline standards for pollutant concentrations are the National Ambient Air Quality Standards (NAAQS) and state air quality standards. These standards represent the maximum allowable atmospheric concentration that may occur and still protect public health and welfare. The state of Tennessee has adopted NAAQS (TDEC 1200-3-3).

Based on measured ambient air pollutant concentrations, the EPA designates whether areas of the United States meet NAAQS. Those areas demonstrating compliance with NAAQS are considered attainment areas, while those that are not are known as non-attainment areas. Those areas that cannot be classified on the basis of available information for a particular pollutant are unclassifiable and are treated as attainment areas until proven otherwise.

The proposed action would occur in Roane County, which is used as the region of influence (ROI) for this analysis. For comparison purposes, Table 3.1 presents EPAs 2002 National Emissions Inventory (NEI) data for Roane County (EPA 2002). The county data include emissions data from point sources, area sources, and mobile sources. Point sources are stationary sources that can be identified by name and location. Area sources are point sources whose emissions are too small to track individually, such as a home or small office building, or a diffuse stationary source, such as wildfires or agricultural tilling.

Mobile sources are any kind of vehicle or equipment with gasoline or diesel engine, an airplane, or a ship.

Two types of mobile sources are considered: on-road and non-road. On-road mobile sources consist of vehicles such as cars, light trucks, heavy trucks, buses, and motorcycles. Non-road sources are aircraft, locomotives, diesel and gasoline boats and ships, personal watercraft, lawn and garden equipment, agricultural and construction equipment, and recreational vehicles (EPA 2005).

Table 3.1. Roane County emissions for 2002 Emissions (tons/year)

Source Type CO NOx PM10 PM2.5 SO2 VOC Area source 648 116 3,516 845 149 1,209 Non-road mobile 3,703 1,167 2,092 624 124 827 On-road mobile 21,386 4,381 2,175 620 106 1,548 Point source 1,150 26,280 4,394 3,583 77,882 240 Total 26,887 31,943 12,177 5,672 78,262 3,824 Source: EPA 2002.

CO = carbon monoxide; NOx = nitrogen oxide; PM10 and PM2.5 = particulate matter with an aerodynamic diameter less than 10 microns and 2.5 microns, respectively; SOx = sulfur oxide; and VOC = volatile organic compound.

TDEC operates air quality monitors in various counties throughout the state (TDEC 2008). There is a particulate matter with an aerodynamic diameter less than 2.5 microns (PM2.5) monitor in Roane County and an ozone monitor in the neighboring Anderson County; Oak Ridge area air quality is relatively good 09-033(E)/100511 3-4

compared to nearby Knox County. Part of Roane County [census block that includes the Tennessee Valley Authority (TVA) Kingston Steam Plant] is designated partial non-attainment for the new, stricter federal PM2.5. The neighboring county, Anderson County, is non-attainment for the 8-hr ozone and PM2.5 standard.

3.2.1.2 Noise Noise sources within the ETTP can be categorized into two major groups: transportation and stationary. Transportation noise sources are associated with moving vehicles that generally result in fluctuating noise levels above ambient noise levels for a short period of time. Stationary noise sources are those that do not move or that move relatively short distances. Stationary noise sources include ventilation systems, air compressors, generators, power transformers, and construction equipment. These stationary sources are primarily associated with the ongoing activities within the industrialized central portion of ETTP. During peak hours, traffic along SR 58 is a major contributor to traffic noise levels in the area. Background noise levels at the ETTP are mostly from local traffic and are comparable to noise levels in an urban residential area. Noise levels 200 ft from main thoroughfares serving the ETTP have been estimated from traffic counts during rush hour to be between 58 and 66 A-weighted decibels (dBA). Noise levels at relatively isolated sites or farther from the highway may be lower than 55 dBA. No sensitive receptor sites such as picnic areas, recreation areas, playgrounds, active sports areas, parks, residences, motels, or hotels are presently located in the immediate ETTP vicinity.

3.2.2 Environmental Consequences 3.2.2.1 Proposed action Air Quality During site preparation and construction, the use of heavy equipment would generate engine exhaust containing air pollutants associated with diesel combustion. Similar air emissions would be generated from delivery vehicles bringing supplies and equipment to the construction site and from construction workers commuting in their personal vehicles. These emissions would be short-term, sporadic, and localized (except for emissions associated with the personal vehicles of construction workers and vehicles transporting construction materials and equipment). Dispersion would decrease concentrations of pollutants in the ambient air as distance from the construction site increased. The quantities of air pollutants produced by vehicles and equipment associated with construction would not be a substantial contribution to the total emissions from mobile sources already operating in the area and would not be expected to adversely affect local air quality.

In addition, construction activities could generate an increase in fugitive dust (i.e., airborne particulate matter that escapes from a construction site) from earthmoving and other construction vehicle operation. Not all of the area available for construction would be under construction at any one time.

Rather, earthwork would likely be undertaken in increments. Increases in fugitive dust concentrations would probably be noticeable on the site and in the immediate vicinity, and ambient concentrations of particulate matter could rise in the short-term. However, control measures for lowering fugitive dust emissions (i.e., covers and water or chemical dust suppressants) would minimize these emissions.

Specific details about atmospheric pollutants that may be emitted by companies locating within the proposed development are not available. However, the types of commercial businesses and industries that are anticipated to be recruited could produce air emissions [e.g., volatile organic compounds (VOCs),

particulates, etc.] typical of standard industrial and research operations. Minor emissions are typically controlled within the facility using conventional treatment technologies like scrubber systems and 09-033(E)/100511 3-5

particulate filters, and external effects are negligible. New facility operations that have minor air contaminant sources would be required to obtain air quality construction and operating permits (non-Title V) from TDEC. The terms and conditions of the permits would include emission limits and outline specific monitoring, operating conditions, and recordkeeping requirements for the source.

Major sources of air emissions typical of heavy industries could be subject to a Title V operating permit. A Title V permit is required for any facility operations with the potential to emit more than 100 tons per year of any regulated air pollutant, 10 tons per year of any hazardous air pollutant, and/or 25 tons per year of any combination of hazardous air pollutants. If required, the appropriate permits would be obtained. This regulatory process would prevent violations of air quality standards and mitigate the potential for adverse air quality impacts.

Noise Construction noise associated with any future development would cause a temporary and short-term increase to the ambient sound environment. Workers associated with the construction activities would be expected to wear appropriate hearing protection as required by the Occupational Safety and Health Administration (OSHA). Construction activities would occur in active industrialized areas and in areas where no sensitive receptors are located. As a result, noise from construction would have no adverse effects.

Noise generated from new industrial or commercial businesses after construction would depend on the actual uses within the developed areas. Industrial uses involving heavy processing, manufacturing, assembly, and fabrication plants would be expected to generate more noise than commercial uses such as offices, service establishments, and storage/warehousing facilities. Uses that require outside material storage facilities or shipping and freight terminals would generate noise from the operation of heavy equipment and trucks. Public recreation uses such as parks, playgrounds, athletic fields, etc.,

generate even less noise. Noise compatibility should be a consideration when putting together development plans and may be a factor in obtaining the appropriate building/construction permits, licenses, etc., as part of applicable zoning regulations or ordinances that the private owners/developers would be subject to.

3.2.2.2 Alternative 1 Under Alternative 1, the types of potential air quality and noise impacts are expected to be similar to those for the proposed action. However, since the conveyed property would be primary for heavy industrial development, the potential for adverse impacts could be greater. The potential for major adverse impacts would be somewhat mitigated by the City of Oak Ridge Zoning requirements and the regulatory permitting process. It is unlikely that the state of Tennessee would issue several Title V air quality permits for new sources in the ETTP area because of the likelihood that the higher density of heavy industries would adversely impact both local and regional air quality.

3.2.2.3 Alternative 2 Under Alternative 2, the types of potential air quality and noise impacts are expected to be similar to those for the proposed action. Since industrial uses are not permitted under the City of Oak Ridge Zoning Ordinance for UB-2, Unified General Business Districts, potential adverse air quality impacts typically associated with heavy industrial development would not occur. However, it is possible that some commercial uses would still be required to obtain air quality construction and operating permits for their minor sources. Adverse noise impacts are not expected.09-033(E)/100511 3-6

3.2.2.4 No action Under the no action alternative, air quality in the area would continue to be influenced primarily by DOE activities at ETTP and emissions from mobile sources associated with vehicles travelling on existing roads and highways. Emissions currently meet permitting regulations and DOE and EPA standards. Ambient noise levels are also expected to remain close to existing conditions.

3.3 GEOLOGY AND SOILS 3.3.1 Existing Conditions A detailed description of the geology of the ETTP area is presented in the Final Environmental Assessment for the Lease of Land and Facilities Within the East Tennessee Technology Park, DOE/EA-1175 (DOE 1997) and is summarized here.

In general, the ETTP area is underlain by bedrock that can be broadly characterized as carbonate (Chickamauga Group and Knox Group) or clastic (Rome Formation). Figure 3.2 provides a geologic map of the ETTP area.

The geology is complex as a result of extensive faults, fractures, and folds and the presence of karst features in the bedrock underlying the site (Lemiszki 1994). The principal faults include the Whiteoak Mountain Fault, a major regional thrust fault that closely parallels the Oak Ridge Turnpike at the base of Pine Ridge, and the K-25 Fault that trends north-northwest through the eastern portion of the ETTP. Both of these faults have placed rocks of the Rome Formation over rocks of the Chickamauga Group and have also juxtaposed rocks of the Knox Group in the northeastern portion of the ETTP.

Clastic rocks of the Rome Formation underlie the easternmost portion of the main ETTP plant area, the K-1251 Barge Loading Area, and land tract identified as Parcel ED-3. The Rome Formation generally consists of thin-bedded shale and siltstone with interbedded sandstones. A limestone unit is present in the lower Rome in some areas of East Tennessee. The Rome bedrock is extremely contorted, with complex fracturing and folding in the vicinity of the K-25 Fault. Available exposures of the weathered Rome in the eastern portion of the ETTP reveal numerous tight, highly fractured folds with widely ranging bedding orientations.

The Knox Group is predominantly made up of dolostone that is highly siliceous, which makes it a ridge-former in this region (Blackoak Ridge and McKinney Ridge locally), and is found only in the northernmost portion of the proposed action. Dolostones in the Knox Group commonly consist of stacks of thick-to-massive beds. Within some of these beds, there are highly siliceous zones containing pods and lenses of chert, which are commonly intensely fractured.

The Chickamauga Group, which underlies the majority of the main ETTP plant area, Duct Island, and the former K-25 Powerhouse Area, is primarily composed of limestones, but there are also distinct calcareous shale beds, mud-rich limestones, and thin mud seams and stringers. Structurally, these formations have been significantly folded within the main plant area of the ETTP producing a diverse range of bedding orientations. The carbonates of the Chickamauga commonly weather in situ and turn completely to clay and silty clay. The transition from weathered material to competent bedrock is generally distinct and occurs over a short interval.09-033(E)/100511 3-7

K-25 FAULT 3-8 WHITEOAK MOUNTAIN FAULT LEGEND: GEOLOGY:

TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA OAK RIDGE, TENNESSEE Fig. 3.2. Geologic map of ETTP.

There is abundant evidence of karst within the Knox Group and Chickamauga Group formations, but the degree and style of karstification varies between these two groups, largely due to the different lithologic and mechanical characteristics of each unit. Karst development is of much greater extent in the Knox Group; however, it is also commonly present in the Chickamauga Group, which underlies the majority of the property included in the proposed action.

Despite the presence of numerous faults in the ETTP area, these faults are no longer active. The most recent significant movement of these faults likely occurred over 200 million years ago (Stearns and Miller 1977).

With few exceptions, bedrock at ETTP is mantled by unconsolidated overburden materials that range in thickness up to 70 ft. The heterogeneous soils overlying bedrock at the ETTP include a mixture of fill, reworked soils, native residual soils, and alluvium. These materials are products of either progressive in situ weathering of the underlying parent bedrock, depositional processes, or anthropogenic activities.

During construction of the ETTP, soils were extensively modified by excavation and refilling of areas throughout the site, and few areas of undisturbed soils remain. Although the soils have largely been reworked, for the most part, soils at the ETTP are fine-grained and generally consist of silty clay materials. Coarser-grained soils are present in the Powerhouse area and in some fill areas.

3.3.2 Environmental Consequences 3.3.2.1 Proposed action Site clearing, grading, and contouring would alter the topography of the property in the areas that would be developed, but the geologic formations underlying those sites should not be adversely affected.

The potentially affected bedrock is generally stable and adequate to support structures using standard construction techniques. However, geotechnical studies would most likely be conducted prior to construction. If necessary, low geological impact foundations (e.g., shallow footings, micro piles, etc.)

could be used to minimize excavation. Seismic hazards are relatively low in the ETTP area, and structures should be designed to conform to appropriate seismic standards.

Construction would disturb soils, and some topsoil might be removed in the process. However, construction activities involving ground disturbance would be conducted incrementally to limit the potential for soil erosion. Construction projects that disturb one acre or more of land require a storm water permit under the National Pollutant Discharge Elimination System (NPDES) program from TDEC. The permit process also requires a storm water pollution prevention plan for the site. This plan includes erosion, sediment, and storm water management controls to minimize the potential for adverse impacts.

Examples include silt fences, sediment basins, erosion control mattings and blankets, etc. It is also expected that topsoil would be replaced as construction activities are completed, and disturbed areas would be revegetated.

The Excavation/Penetration Permit Program is a DOE control for operations and ongoing cleanup activities. Deed restrictions could be included that require the property owner to obtain an excavation/penetration permit from DOE, as long as DOEs program is in place. The Zone 1 and Zone 2 RODs have a current restriction on excavation below 10 ft without proper controls. Similar restrictions would be placed in Covenant Deferral Requests, as necessary.09-033(E)/100511 3-9

3.3.2.2 Alternative 1 Potential geology and soils impacts under this alternative would be similar to those described for the proposed action. However, a greater density of heavy industrial development could increase the potential for adverse impacts.

3.3.2.3 Alternative 2 Potential geology and soils impacts under this alternative would be similar to those described for the proposed action.

3.3.2.4 No action Under the no action alternative, the property would not be conveyed and would remain under DOE control. Ongoing environmental restoration, waste management, and reindustrialization activities at ETTP would continue. Potential geology and soil impacts are addressed by approved NEPA studies or other applicable regulatory documents.

3.4 WATER RESOURCES 3.4.1 Existing Conditions 3.4.1.1 Groundwater Groundwater occurs in both the unconsolidated overburden and bedrock at the ETTP, primarily as a single, unconfined, water table aquifer. Over most of the site, the water table occurs within the unconsolidated zone above bedrock. However, in several areas of the site, typically in areas of thin overburden where bedrock relief is high and/or the depth to water is greater, the water table occurs below the top of bedrock (DOE 1996). Depth to groundwater ranges from 1 to 65 ft below ground surface, largely depending on topographic position, with groundwater occurring at greater depths in the higher elevation portions of the ETTP. The water table is generally a subdued replica of topography implying radial flow from elevated areas within the plant to the adjacent surface water features, including Mitchell Branch, the K-1007-P Ponds, K-901-A Pond, Poplar Creek, and the Clinch River. Fluctuations in Clinch River and Poplar Creek stage directly impact groundwater hydraulic gradients in areas adjacent to these features (DOE 1996).

Over most of the ETTP, the water table occurs in the overburden, and groundwater flow in the overburden would be expected to follow hydraulic gradients with radial flow from higher topographic position within the site to adjacent surface water features, as described above. Depending on the specific overburden material (residual soil, fill materials, reworked soils, or alluvium), discrete flow zones may alter the flow directions slightly on a local scale, though overall flow would still be expected to follow the general hydraulic gradients. The ORR conceptual model (Solomon et al. 1992) suggests that the most active interval for groundwater flow on the ORR is the interface between bedrock and the unconsolidated zone and the uppermost surface of the bedrock. This is likely to be the case at the ETTP, as well.

In areas of the site where the water table occurs below the top of bedrock, groundwater flow would be controlled by both hydraulic gradient and bedrock structural features (including cavities). These flowpaths would be generally oriented parallel to bedrock strike in the carbonates, but highly unpredictable in areas of the site underlain by the Rome Formation. Groundwater at ETTP typically 09-033(E)/100511 3-10

follows short flowpaths to discharge to local surface water features, including existing Clinch River, Poplar Creek, K-1007-P Ponds, K-901-A Pond, and various seeps and springs.

Extensive groundwater monitoring at the ETTP has identified VOCs as the most significant groundwater contaminant on site. Several distinct areas having significant VOC contamination in groundwater have been identified in both Zone 1 (the K-901 area) and Zone 2 (Mitchell Branch area, K-1004 and K-1200 area, and K-27/K-29 area), Multiple plume source areas have been identified within the regions of the highest VOC concentrations in Zone 2. In the identified plumes in both Zone 1 and Zone 2, the parent VOCs have been present for decades and mature contaminant plumes have evolved.

The degree of transformation, or degradation, of the parent VOCs is highly variable across the ETTP. In some areas, a high degree of degradation has occurred, producing significant concentrations of the degradation daughter compounds, while in others, transformation processes are weak or inconsistent with little transformation of the parent VOCs observed in the existing groundwater plumes.

A plume of groundwater contaminated with VOCs from degreasing and other maintenance operations is present near the location of the former K-1401 building footprint. In 2009, a treatability study to assess treatment options for this plume, which could subsequently be applied to other similar plumes at ETTP, began with the installation of seven monitoring wells. Groundwater and soil samples were collected from these locations to characterize the nature and extent of the VOCs in this plume.

Additional data collection will be conducted in FY 2011 for the treatability study, and once the data collection and evaluation is complete, the appropriate groundwater treatment options will be determined.

In response to hexavalent chromium releases to Mitchell Branch, DOE completed a time-critical removal action in 2008 to extract the contaminated groundwater. Since completion of this removal action, the concentration of chromium in Mitchell Branch has been reduced to ambient water quality criteria.

DOE has also proposed a non-time critical removal action for a long-term solution to the release of hexavalent chromium (DOE 2010b).

Routine monitoring of groundwater quality at ETTP is conducted to evaluate effectiveness of DOEs remediation activities at the ETTP. The results of this monitoring are reported in the annual DOE Remediation Effectiveness Report. A final decision on the approach for cleanup of groundwater contamination in Zone 1 and Zone 2 at ETTP has not been made to date. DOE will retain responsibility for remediation of any site-related groundwater contamination within the ETTP and surrounding area.

Current land use controls prohibit the use of groundwater within Zone 1 and Zone 2 of the ETTP.

3.4.1.2 Surface water The ETTP is directly adjacent to the Clinch River along the northwest boundary of the ORR. The Clinch River is considered a run-of-the-river impoundment, forming a portion of Watts Bar Reservoir.

The Clinch River enters East Fork Valley through a water gap in Pine Ridge just upstream of the ETTP and flows across the valley before turning southwest to flow along the axis of the valley toward Watts Bar Dam. The Clinch River is up to 490 ft wide adjacent to the ETTP and, based on bathymetric surveys, typical water depths have been observed to range from 25 to 35 ft along the channel [i.e., the river bottom elevation is typically 705 to 710 ft above mean sea level (AMSL)]. However, extreme water depths in excess of 50 ft have been observed within the river channel adjacent to the K-901-A Pond outfall.

Poplar Creek enters the north side of the ETTP and flows approximately 5.5 miles through the site, from the upstream confluence of the east and west forks of Poplar Creek to the confluence with the Clinch River at River Mile 12. At high pool stage, Poplar Creek is up to 290 ft wide, with water depths ranging up to 23 ft (bottom elevation = 718 ft AMSL). Backflow conditions persist upstream to above the confluence with East Fork Poplar Creek.09-033(E)/100511 3-11

Clinch River flow rates are regulated by the TVA through operations at downstream Watts Bar and upstream Melton Hill Dams. Consequently, stage elevations fluctuate daily, weekly, and seasonally in response to TVA operations. Fluctuations of up to 5 ft may occur in both the Clinch River and Poplar Creek. Additionally, as a result of power generation schedules at the two dams, there are periods during the day when river flow can reverse upstream.

Tributary streams to Poplar Creek at the ETTP include Mitchell Branch, which originates on McKinney Ridge above ETTP and flows through the northeastern portion of the ETTP to discharge to Poplar Creek. The primary surface water feature within Parcel ED-3 is the unnamed stream along the south side of SR 58. This stream originates on Pine Ridge east of Parcel ED-3, flows west adjacent to SR 58, and passes under SR 58 through a culvert before it enters the K-1007-P5 Pond. Much of the stream was channelized during the widening of SR 58. An unnamed drainage west of Flannagans Loop Road and small springs and seeps on the flanks of Pine Ridge also contribute to the flow in the stream. A small portion of surface water flow directly adjacent to the western boundary of Parcel ED-3 flows directly to the K-1007-P3 Pond. The K-1007-P3 Pond also receives runoff from a seep area and wet-weather drainage that flows down Pine Ridge further west of Parcel ED-3. Discharges from these ponds enter Poplar Creek, which is part of the Clinch River watershed.

The ETTP NPDES permit regulates the discharge from ETTP of storm water runoff, groundwater infiltration, and groundwater from sumps to Mitchell Branch, Poplar Creek, and the Clinch River. Unless otherwise stated, all storm water outfall groups also receive general site runoff, which may include storm water runoff from grassy areas, roads, and paved areas within ETTP. There are 121 permitted storm water outfalls at ETTP regulated under NPDES Permit No. TN0002950. Of the 121 total outfalls, 38 representative outfalls are required to be sampled. The outfalls are grouped into four categories based on the type of flow being discharged through the outfalls (DOE 2010a). Many permitted outfalls will be eliminated as cleanup progresses. No final decision has been made on who would be the final site-wide permit holder.

Routine monitoring is conducted at ETTP at 11 locations (DOE 2010a). These locations monitor groundwater, storm water runoff or ambient stream conditions. Depending on the location, samples may be collected and analyzed for radionuclides and nonradiological parameters. Results of radiological monitoring are compared to DOE derived concentration guidelines (DCGs) and nonradiological results are compared to appropriate water quality standards. In general, monitoring results at all of the surveillance locations have remained less than 1% of the allowable DCG (DOE 2010).

3.4.1.3 Floodplains Some areas of the proposed action lie within the existing 100-year and 500-year floodplains adjacent to the Clinch River and Poplar Creek (Fig. 3.3). In addition, the floodplain for Poplar Creek extends up the Mitchell Branch drainage area within the northeastern portion of the site.

3.4.1.4 Wetlands The U. S. Army Corps of Engineers (USACE) defines wetlands as those areas that are inundated or saturated by surface water or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions (Environmental Laboratory 1987). Wetlands usually include swamps, marshes, bogs, and similar areas. In identifying a wetland, three characteristics should be met. First is the presence of hydrophytic vegetation that has morphological or physiological adaptations to grow, compete, or persist in anaerobic soil conditions. Second, hydric soils are present and possess characteristics that are associated with reducing soil conditions. Third, site hydrology, meaning the area is inundated or saturated to the surface at 09-033(E)/100511 3-12

PRIVATE OWNERSHIP K-901-A TVA PROPERTY MI TC HE LL CH AN BR K-1007-P1 RARITY RIDGE K-1007-P4 DEVELOPMENT IKE K-1007-P5 URNP AK RIDGE T O 58 K-1007-P3 HWY.

TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA OAK RIDGE, TENNESSEE INDUSTRIAL PARK Fig. 3.3. The 100-year and 500-year floodplain and surveyed wetlands in the ETTP area.

3-13

some time during the growing season of the prevalent vegetation, must be present (Environmental Laboratory 1987).

Surveys to identify wetlands were conducted in the summer of 1994 in selected areas of the ETTP area (Fig. 3.3). A total of 47 wetland areas that range in size from 0.3 to 10.7 acres were identified in the surveys (Rosensteel and Awl 1995). These wetlands occur in association with springs and seeps along stream bottomlands, in areas of seasonally high groundwater tables and surface water levels on the alluvial islands and floodplains of Poplar Creek and the Clinch River, in association with a beaver dam, and in and adjacent to areas of human impact (including utility line ROWs and channelized streams).

The recent habitat assessment of Parcel ED-3 conducted by MRW Environmental LLC (2009) recorded 10 jurisdictional wetlands totaling approximately 1.6 acres. All of the wetlands identified were classified as slope wetlands with the exception of two. One was considered an isolated depression and the other a lacustrine fringe wetland. The overall size of the wetlands was small, with the average wetland size being 0.16 acre.

3.4.2 Environmental Consequences 3.4.2.1 Proposed action No impacts to groundwater quality are anticipated from any construction activities or normal facility operations. However, local groundwater flow directions may be impacted by subsurface disturbances such as construction of basements and/or installation and operation of building sumps. Use of groundwater would be prohibited via a lease restriction or condition of the deed for title transfer. The restriction is to ensure the protection of human health by preventing exposure to known groundwater contamination that underlies large portions of Zone 2, but is less widespread in Zone 1. Impacts to groundwater quality could occur as a result of a fuel or hazardous material spill and subsequent migration of contaminants through the soil profile to the groundwater table. In addition, the presence of karst features throughout the ETTP and surrounding areas can provide rapid transport pathways for contaminants to reach groundwater resources. However, it is expected that the quantities of materials with the potential to affect groundwater would be transported or stored on-site in the proper containers and according to all applicable regulations.

The use of local, state, or federal permits, safety procedures, spill prevention plans, and spill response plans in accordance with applicable laws would minimize the severity of potential impacts from accidents. Although a final groundwater decision has not been determined for the existing groundwater plumes present within Zone 1 and Zone 2, ongoing soil investigations under the RODs for Zone 1 and Zone2 would also serve to protect groundwater resources through the identification and removal of soils exhibiting the potential to leach contaminants to groundwater.

Potential adverse impacts to surface water resources are expected to be minimal. Construction activities would be required to follow the appropriate regulatory process, including obtaining a construction storm water NPDES permit from TDEC. The use of best management practices, including appropriate erosion prevention and sediment control measures, would minimize indirect impacts to adjacent surface waters. The potential for adverse impacts to occur would exist until disturbed areas were stabilized. Work within or near surface waters could also require that an Aquatic Resources Alteration Permit be obtained from TDEC. Spills of fuel and/or hazardous material could also have an adverse impact on surface waters if not controlled or contained. DOE will retain responsibility for remediation of any site-related surface water contamination at the ETTP.

The addition of new impervious surfaces would increase the rate and volume of storm water runoff within the affected area. Increases in surface water runoff as a result of new construction would be attenuated through the use of temporary or permanent storm water controls, such as detention or retention 09-033(E)/100511 3-14

basins and other structures, use of permeable pavement, and stabilization of disturbed areas through landscaping and vegetation. The use of these measures would also increase groundwater recharge through direct percolation, offsetting the loss of pervious surface due to construction and minimizing downstream effects. Storm water runoff after construction activities are completed and any discharge from facility operations to surface water would be in accordance with limitations established under the applicable TDEC NPDES permit.

New construction within the existing Clinch River and Poplar Creek floodplains is not anticipated.

However, any and all construction, which may occur within any floodplain or floodway or that might affect a floodplain, must comply with applicable federal and state laws with respect to such construction.

The potential for, and degree of, potential wetland impacts would depend upon how the future owners and/or occupants develop and use the property. Activities associated with development could have beneficial effects or adverse effects on wetlands. Beneficial impacts would include any actions that would improve the quality of wetlands or actions that would enhance the ability of wetlands to perform wetland functions. Adverse impacts would include any activity that would adversely affect the survival, quality, and natural and beneficial values of wetlands. Effects on wetlands might result from activities occurring directly in wetlands or might result indirectly from activities that occur in areas adjacent to wetlands. The consequences of wetland alteration might last for decades (long-term effects) or be minor enough that wetlands could recover in a few years (short-term effects).

TDEC and the USACE jointly regulate wetlands-related activities. If any portion of transferred property is deemed to be jurisdictional wetlands as determined by the Nashville District USACE, development activities would need to comply with the USACE wetlands construction restrictions contained in 33 CFR, Sections 320 through 330, as amended, and any other applicable federal, state, or local wetlands regulations. Work within or near wetlands could also require that an Aquatic Resources Alteration Permit be obtained from TDEC. It would be the responsibility of the new owners and/or occupants to secure these permits prior to initiating work in any wetlands. Permit conditions would stipulate which activities could occur in or around the affected wetlands. Regulatory permits would also specify all required mitigative measures, including potential compensation.

3.4.2.2 Alternative 1 Under Alternative 1, water resource impacts are expected to be similar to those for the proposed action. However, a greater density of heavy industrial development could increase the potential for adverse impacts.

3.4.2.3 Alternative 2 Under Alternative 2, water resource impacts are expected to be similar to those for the proposed action.

3.4.2.4 No action Under the no action alternative, ongoing and planned reindustrialization and cleanup activities would continue. Potential impacts to groundwater, surface waters, or wetlands are addressed by approved NEPA studies or other applicable regulatory documents.09-033(E)/100511 3-15

3.5 ECOLOGICAL RESOURCES 3.5.1 Existing Conditions 3.5.1.1 Vegetation Vegetation within the fenced industrialized area of ETTP includes a mixture of mowed grasses with a few shrubs and trees (especially around buildings), small areas of mixed tree/shrub/grass associations, or mixed evergreen-deciduous vegetation. Many of the shrubs and trees have been planted as landscaping, although some native species are found in unmowed areas around ponds and along waterways. The Duct Island area and the former K-25 Powerhouse area include planted pine trees, second-growth mixed coniferous-deciduous vegetation, and open areas, particularly with transmission line ROWs (DOE 1997).

A habitat assessment recently conducted for the area identified as Parcel ED-3 identified a total of 15 different plant communities (MRW Environmental LLC 2009). These 15 plant communities can be grouped within the following cover types:

Mixed forestland Hardwood forest types dominated by oaks and hickories.

Transitional Secondary early successional sites, often grassland to grassland/shrub mix; generally mowed within utility ROWs.

Pine plantation Areas of row-planted pine trees of a uniform age.

Urban land Buildings, parking lots, lawns, and ornamental plantings.

Some of the areas on Parcel ED-3 are in an intermediate stage of succession, whereas others are composed of trees in older age classes that have not been subject to severe disturbance for many years.

The steeper portions of the site in the western portion of the parcel have the largest diameter hardwood trees and a composition that reflects little recent disturbance. The lowest portion of the site adjacent to the stream/floodplain/wetland complex supports a mixed hardwood community characteristic of riparian areas. Areas that were affected by the Southern pine beetle, and formerly open areas that have been planted with pines, have undergone normal successional processes. These areas are generally characterized by a dense growth of small-diameter trees or shrubs. The remainder of the site includes areas along roads dominated by planted vegetation (e.g., tall fescue, Lespedeza spp.) and the small portion of the parcel that is developed and currently contains offices and parking lots (MRW Environmental LLC 2009).

The remainder of the EA study area consists of relatively undeveloped areas along and adjacent to Blackoak Ridge, Pine Ridge, and McKinney Ridge. These areas are dominated by deciduous forestland, mixed forestland, and to a lesser extent evergreen forestland and transitional areas. The least fragmented of these areas also contains interior forest habitat. Interior forest habitat is defined as a forested area that possesses more than 70% canopy cover with a minimum acreage of 50 contiguous acres (ORNL 2002).

Interior forest habitat is important for many forest species, especially neo-tropical migratory songbirds whose populations have been declining.

The occurrence of invasive plants on the ORR has been recognized for many years. About 168 of the 1,100 vascular plants on the ORR are not native. Of these, 54 have been identified as aggressive. Drake et al (2002) identified 18 of these non-native plants that pose the greatest threat for natural areas (NAs)

[i.e., ORR habitats with rare plants or wildlife]. Invasive plants on the ORR have spread from old home site plantings, past erosion control efforts, forage enhancement projects, and adjacent farm or residential 09-033(E)/100511 3-16

property. Common exotic species include privet (Ligustrum spp.), Nepalese stiltgrass (Microstegium vimineum), Japanese honeysuckle (Lonicera japonica), kudzu (Pueraria lobata), Johnsongrass (Sorgham halepense), bushclover (Lespedeza spp.), tree of heaven (Ailanthus altissima), tall fescue (Festuca arundinacea), and periwinkle (Vinca spp.).

3.5.1.2 Wildlife The large, relatively unfragmented area of mature eastern deciduous hardwood forest on the ORR provides a variety of other habitats for numerous wildlife species (Parr and Hughes 2006). The resulting diversity of wildlife species ranges from common species found in urban and suburban areas of eastern Tennessee to species with more restrictive requirements, such as interior forest bird species. The ORR hosts more than 70 species of fish; about 45 species of reptiles and amphibians; more than 200 species of migratory, transient, and resident birds; and more than 30 species of mammals, as well as innumerable invertebrate species. Current lists of the fish; reptiles, amphibians, and mammals; and birds can be found on the ORR National Environmental Research Park (NERP) website at http://www.esd.ornl.gov/facilities/nerp/data.html.

Limited habitat is available for native animals within the industrialized main ETTP area. These areas host urbanized species that adapt well to disturbance and the presence of humans. These include small rodents, groundhogs (Marmota monax), birds such as starlings (Sturnus vulgaris), pigeons (Columba livia), Canada geese (Branta canadensis), and small reptiles. Large wildlife such as white-tailed deer (Odocoileus virginianus) are frequently seen in the vicinity. Other common mammals that are present within the lesser-developed areas of the study area include the Virginia opossum (Didelphis virginiana),

gray squirrel (Sciurus carolinensis), eastern chipmunk (Tamias striatus), eastern cottontail rabbit (Sylvilagus floridanus), and raccoon (Procyon lotor).

The recent habitat assessment of Parcel ED-3 conducted by MRW Environmental LLC (2009) observed 40 bird species within the parcel, including year-round residents, short-distance migrants, and neo-tropical migrants. Although the bird species observed on Parcel ED-3 are probably representative of the EA study area, it is likely that numerous species not identified during the assessment are present at varying times of the year (e.g., during migration). Many of the species noted and potential species not documented during the assessment are listed by Partners in Flight (PIF) as being of high priority (scores of 20 or greater) for protection in Tennessee. Examples include the cerulean warbler (Dendroica cerulean), wood thrush (Hylocichla mustelina), Kentucky warbler (Oporornis formosus), and indigo bunting (Passerina cyanea).

3.5.1.3 Aquatic resources Aquatic habitats in and directly adjacent to the EA study area include the Clinch River, Poplar Creek, small streams, and ponds. Section 3.4.1.2 provides a description of these surface waters. Five major biotic communities occur in waters adjacent to the ETTP: phytoplankton, periphyton, zooplankton, benthic macroinvertebrates, and fish. Information on aquatic biological monitoring at and in the vicinity of ETTP can be found in the 2010 Remediation Effectiveness Report (DOE 2010c).

3.5.1.4 Threatened and endangered species A list of the animal species of concern that have been reported from the ORR is presented, along with their federal and state status, in Table 3.2.

The state endangered peregrine falcon and the state threatened northern saw-whet owl are only very rare transients. Similarly, several state-listed bird species, such as the anhinga, olive-sided flycatcher, and little blue heron, are currently uncommon migrants or visitors to the ORR; however, the little blue heron 09-033(E)/100511 3-17

is probably increasing in numbers. The cerulean warbler, listed by the state as in need of management, has been recorded during the breeding season; however, this species is not actually known to breed on the ORR. The bald eagle, also listed by the state as in need of management, is increasingly seen in winter and, in 2011, was confirmed to be nesting at ETTP. Others, such as the northern harrier, great egret, and yellow-bellied sapsucker, are migrants or winter residents that do not nest on the ORR. The golden-winged warbler, listed by the state as in need of management, has been sighted once. Barn owls have been known to nest on the ORR in the past. One federal and state threatened species, the spotfin chub (Cyprinella monacha), has been sighted and collected in the city of Oak Ridge and is possibly present on the ORR. The Tennessee dace (Phoxinus tennesseensis) has been found in some sections of Grassy Creek and other streams on the ORR (DOE 2008).

Table 3.2. Animal species of concern reported from the ORRa Legal statusb Species Federal State Fish Tennessee dace (Phoxinus tennesseensis) NM Amphibians and reptiles Four-toed salamander (Hemidactylium scutatum) NM Northern pine snake (Pituophis melanoleucus melanoleucus) T Birds Sharp-shinned hawk (Accipiter striatus) NM Northern saw-whet owl (Aegolius acadicus) MC T Anhinga (Anhinga anhinga) NM Great egret (Casmerodius alba) NM Northern harrier (Circus cyaneus) NM Olive-sided flycatcher (Contopus borealis) NM Cerulean warbler (Dendroica cerulea) NM Little blue heron (Egretta caerulea) NM Snowy egret (Egretta thula) NM Peregrine falcon (Falco peregrinusc) E Bald eagle (Haliaeetus leucocephalusd) NM Loggerhead shrike (Lanius ludovicianus) MC NM Vesper sparrow (Pooecetes gramineus) NM Yellow-bellied sapsucker (Sphyrapicus varius) MC NM Barn owl (Tyto alba) NM Golden-winged warbler (Vermivora chrysoptera) MC NM Mammals Gray bat (Myotis grisescens) E E Southeastern shrew (Sorex longirostris) NM a

Land and surface waters of the Oak Ridge Reservation (ORR) exclusive of the Clinch River, which borders the ORR.

b E = endangered, T = threatened, MC = management concern, NM = in need of management.

c The Peregrine falcon was federally delisted on August 25, 1999.

d The Bald eagle was federally delisted on August 8, 2007.

The northern pine snake (Pituophis melanoleucus melanoleucus) and the gray bat (Myotis grisescens) are the only federal- and/or state-listed threatened or endangered animals to have been documented as occurring in the vicinity of the EA study area. Tennessee Natural Heritage Inventory Program records document that the northern pine snake has been found within a one-mile radius of Parcel ED-3. A survey was conducted for the northern pine snake, during the recently conducted Parcel ED-3 habitat assessment (MRW Environmental LLC 2009), but none were observed even though potential habitat for the species is09-033(E)/100511 3-18

present within portions of the parcel. Echolocation calls of the gray bat were identified at Freels Bend on Melton Hill Lake in 2003, and in 2004 at the K-1007-P1 Pond at ETTP (Harvey and Britzke 2004). In 2006, during a bat survey of four caves on the ORR, an adult male gray bat and two juvenile males were captured (ORNL 2006). In 2007, BHE Environmental Inc. conducted a mist net survey for the Indiana bat and the gray bat within Parcel ED-3. The survey resulted in no captures of either bat species. In 2008, BHE Environmental Inc. conducted an additional survey at four sites within the western portion of the ETTP area that included mist netting and acoustic sampling using Anabat technology. One potential Indiana bat recording occurred at one location; however, there were no mist net captures or additional recordings for that species during the 2008 survey season. No gray bats were captured or recorded. It should also be noted that no caves are known to exist within the area proposed for lease and/or title transfer.

Nesting bald eagles have been recently observed in the vicinity of ETTP within the proposed study area. Although the bald eagle was federally delisted in 2007, it is still protected under the Bald and Golden Eagle Protection Act, Migratory Bird Treaty Act, and the Lacey Act.

Listed vascular plant species that currently occur on the ORR are given, along with their status, in Table 3.3. At least five of these sensitive plant species have been identified, or were evaluated as having the potential to exist, in the ETTP vicinity (Fig. 3.4). Spreading false-foxglove (Aureolaria patula) has been observed in the K-25 Filtration Plant Wetland (NA 33) and northeast of Parcel ED-3 in the McKinney Ridge Hemlocks (NA 45). Goldenseal (Hydrastis canadensis) and ginseng (Panax quinquifolius) probably occur on Pine Ridge, south of Parcel ED-3, in Potential Habitat 2 (Water Tank Table 3.3. Currently known or previously reported vascular plant species reported from the ORR listed by state or federal agencies Species Habitat on ORR Status codea Spreading false-foxglove (Aureolaria patula) River bluff FSC, S Heavy sedge (Carex gravida) Varied S Hairy sharp-scaled sedge (Carex oxylepis var. pubescensb) Shaded wetlands S Appalachian bugbane (Cimicifuga rubifolia) River slope FSC, T Pink lands-slipper (Cypripedium acaule) Dry to rich woods E, CE Tall larkspur (Delphinium exaltatum) Barrens and woods FSC, E Northern bush-honeysuckle (Diervilla lonicera) River bluff T Branching whitlow-grass (Draba ramosissima) Limestone cliff S Nuttall waterweed (Elodea nuttallii) Pond, embayment S Mountain witch-alder (Fothergilla major) Woods T Golden seal (Hydrastis canadensis) Rich woods S, CE Butternut (Juglans cinerea) Slope near stream FSC, T Small-head rush (Juncus brachycephalus) Open wetland S Canada lily (Lilium canadense) Moist woods T Michigan lily (Lilium michiganensec) Moist woods T Fen orchid (Liparis loeselii) Forested wetland E Ginseng (Panax quinquifolius) Rich woods S, CE Tubercled rein-orchid (Platanthera flava var. herbiola) Forested wetland T Pushs wild-petunia (Ruellia purshiana) Dry, open woods S River bulrush (Scirpus fluviatilis) Wetland S Shinning ladies-tresses (Spiranthes lucida) Boggy wetland T Northern white cedar (Thuja occidentalis) Rocky river bluffs S Three-parted violet (Viola tripartita var. tripartita) Rocky woods S a

FSC = Federal Special Concern; formerly designated as C2. More information needed to determine status, E =

endangered in Tennessee, T = threatened in Tennessee, S = special concern in Tennessee, CE = status due to commercial exploitation.

b Carex oxylepis var. pubescens has not been observed during recent surveys.

c Lilium michiganense is no longer found on the Oak Ridge Reservation (ORR).09-033(E)/100511 3-19

NA20 NA47 RA23 NA1 RA30 NA45 ETTP ARA1 3-20 NA49 RA24 NA48 PH2 ARA2 NA33 LEGEND:

TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA OAK RIDGE, TENNESSEE Fig. 3.4. Natural areas and sensitive terrestrial and aquatic habitats in the ETTP area.

Road Forest). Pink lady-slipper (Cypripedium acaule) also has the potential to occur on Pine Ridge in Potential Habitat 2. Shining ladies tresses (Spiranthes lucida) has been positively identified in NA 33 (DOE 1997a). In addition to these species, the assessment of Parcel ED-3 conducted by MRW Environmental LLC (2009) listed the tubercled rein-orchid (Platanthera flava var. herbiola) as having been documented within a mile radius of the parcel.

3.5.1.5 Special uses and designations The Tennessee Wildlife Resources Agency (TWRA) has been granted a license by DOE for the purpose of operating and maintaining TWRAs designated Oak Ridge Wildlife Management Area (ORWMA).

The ORWMA provides wildlife management, research, and species protection opportunities on the ORR.

A major goal in the management of the deer herd on the ORR is public highway safety in the form of reduced automobile-deer collisions. The ORWMA covers much of the ORR, including much of the EA study area. Information on the deer and turkey hunts that take place within the ORWMA can be found at http://www.ornl.gov/rmal/huntinfo.htm.

3.5.2 Environmental Consequences 3.5.2.1 Proposed action Development of conveyed property would have direct or indirect impacts on plants and animals.

Construction impacts would include direct mortality or injury to biota and the elimination or further fragmentation of the existing habitat. Potentially affected wildlife and plants are common to the area and some animal species would be able to relocate to other nearby areas that offer the same type of habitat mix. Impacts would be greater in those areas that are relatively undeveloped and have a greater diversity of undisturbed habitat (e.g., portions of the former K-25 Powerhouse Area, Duct Island, and Parcel ED-3). Impacts within the main industrialized portion of ETTP would be negligible because of the heavily disturbed nature of the area and lack of suitable habitat. Direct adverse impacts to aquatic resources would be unlikely.

Adverse impacts, especially to sensitive migratory birds, would be mitigated because DOE has designated large areas containing higher quality habitat including relatively unfragmented native forest as non-development areas. These areas include the Blackoak Ridge and McKinney Ridge areas that are within the BORCE, much of Pine Ridge within the EA study area, and a large piece of land adjacent to the Clinch River near SR 58. Additionally, no designated aquatic or terrestrial sensitive areas, state NAs, or Nature Conservancy biodiversity ranked areas are within the areas identified for potential conveyance (Fig. 3.3).

Minimizing the amount of disturbance and blending development with the natural setting of the area would reduce the impacts to biological resources. Natural habitat around areas of development should be left as a buffer zone between the developed areas and other undeveloped portions of the site. Areas disturbed during development, but not used for new facilities, should be revegetated after construction is completed. The use of native species for revegetation would have a positive impact. Normal facility operations should not have any adverse impacts to wildlife or pose any unacceptable ecological risk.

Potential, marginal habitat exists for Indiana and gray bats within the EA study area. However, mist netting and acoustic sampling conducted in 2007 and 2008 resulted in no captures or positive recordings of either species. Additionally, no caves are known to exist on the property proposed for conveyance. No adverse impacts to either species are expected from the proposed action.09-033(E)/100511 3-21

The northern pine snake has been documented as occurring in the vicinity of the EA study area and potential habitat for the species is present within portions of Parcel ED-3. No recent observations of the snake in the area have been reported and no individuals were captured or observed during the 2009 Parcel ED-3 habitat assessment. It is unlikely that the northern pine snake is still present, and no adverse impacts are expected.

At least one pair of nesting bald eagles has been recently identified within the EA study area. Eagle responses to human activity are most influenced by visibility of the activity from the nest, and the degree to which similar activities already occur near the nest. The U.S. Fish and Wildlife Service and TWRA have issued recommendations to avoid disturbing bald eagles. These include maintaining a distance buffer between activity and the nest, maintaining natural forested or vegetative buffer between activity and nest tree (landscape buffer), avoiding certain activities during nesting season (timing buffer), etc. DOE would review all requests for property proposed for conveyance to determine if the conveyance would have the potential to disturb the nest area. Appropriate restrictions could also be written into any lease or title transfer agreements.

The DOE license to TWRA for operating and maintaining the ORWMA would need to be amended to exclude those areas that are conveyed. Also, additional safety zones would need to be posted around the perimeter of any new development areas. This could reduce the number of deer harvested from the ORR by a very small percentage; however, the loss of hunting area could possibly be offset by changes in other management parameters, such as permitting an additional hunt or increasing the harvest quota.

3.5.2.2 Alternative 1 Under Alternative 1, impacts to ecological resources are expected to be similar to those for the proposed action. However, a greater density of heavy industrial development could increase the potential for adverse impacts.

3.5.2.3 Alternative 2 Under Alternative 2, impacts to ecological resource are expected to be similar to those for the proposed action.

3.5.2.4 No action Although the potential exists for a spill or leak from normal ongoing operations and traffic, which could adversely affect ecological resources within the area, no additional impacts would result from no action.

3.6 CULTURAL RESOURCES 3.6.1 Existing Conditions Cultural resources are defined as any prehistoric or historic district, site, building, structure, or object considered important to a culture, subculture, or community for scientific, traditional, religious, or any other reason. When these resources meet any one of the National Register Criteria for Evaluation (36 CFR Part 60.4), they may be termed historic properties and thereby are potentially eligible for inclusion on the National Register of Historic Places (NRHP).09-033(E)/100511 3-22

Members of the Jacobs Environmental Restoration (EM) Team conducted a cultural resource survey for the Oak Ridge K-25 Site in 1994. The survey included an architectural survey in the plant area proper and an archaeological survey of the adjacent areas outside the plant boundaries (Morris 1998). The purpose of the architectural survey was to inventory and evaluate the properties in the project area to determine those that might be eligible for inclusion in the NRHP. The archaeological survey evaluated the condition of previously reviewed sites and made recommendations for those sites that may require further investigation. Recommendations were provided to DOE for use in the DOE Cultural Resource Management Plan (CRMP) for the ORR (DOE 2001a).

No known prehistoric archaeological resources are known to exist within the area proposed for conveyance. Because of the massive cut and fill operations causing extensive disturbance during the construction of the former K-25 Site, there are likely no intact archaeological sites to be found within the ETTP security fences (Morris 1998). Six prehistoric archaeological sites are located within the EA study area. The sites are located along Poplar Creek and the Clinch River. Four of the sites have been determined to be eligible for inclusion in the NRHP (DOE 2001a).

Based on the architectural survey conducted in 1994, the Jacobs EM Team, in conjunction with the DOE-ORO and ETTP staff and in consultation with the Site Historical Preservation Officer (SHPO),

concluded that the following properties at the ETTP are eligible for inclusion in the NRHP: (1) the ETTP Main Plant Historic District, which includes facilities within the main plant area and contains 120 contributing structures and 37 noncontributing structures, and (2) 11 structures that are not contiguous with the historic district (DOE 2001a). Since the CRMP was issued, several of these structures have been demolished or are in the process of being demolished as part of the ongoing environmental restoration activities at ETTP. A series of Memorandums of Agreement (MOAs) between DOE and the consulting parties were executed since 2003 when the first MOA for the K-25 Cooling Tower Demolition Project. A Bridge MOA was issued in June 2010 to address remaining Section 106 actions.

Consultation is presently ongoing between the signatory parties to execute a new MOA.

Six cemeteries are located within the study area. These include the Gallaher and Welcker Cemeteries near the former K-25 Powerhouse Area; Wheat Community African Burial Ground (formerly #2 Slave Cemetery) near SR 58, south of the visitors overlook; George Jones Memorial Cemetery located within the Wheat Community Historic District; and the Ellis and Shelton Cemeteries located near the Blair Road crossing of Poplar Creek.

The Wheat Community Historic District, located adjacent to Blair Road on the north side of SR 58, is also located within the EA study area. Named for its first postmaster, Frank Wheat, the 19th-century community was a thriving center of local and regional trade. A 1942 inventory recorded a Masonic lodge, Robinsons School, Wheat High School (formerly Roane College and Poplar Creek Seminary), Adams Store, a post office, and several frame residences. The community also included a Methodist church, Mt. Zion Baptist Church, Cumberland Presbyterian Church, and George Jones Memorial Baptist Church (the only standing building from the Wheat Community). The Wheat Community properties were purchased by the federal government in late 1942 as part of the Manhattan Project.

The Parcel ED-3 area was surveyed (2008-2009) for archaeological resources, and subsequent archaeological test excavations were conducted (New South Associates 2011). The objectives of the surveys and test excavations were to identify any archaeological remains associated with the Happy Valley Worker Camp (Happy Valley) and any additional sites on the property, and to assess these sites for National Register eligibility. Happy Valley was a temporary worker housing area occupied from 1943 to 1947 during the construction of the K-25 Oak Ridge Gaseous Diffusion Plant. Happy Valley accommodated a population of approximately 15,000. The temporary town included hutments, central washing facilities, a mess hall, barracks, trailers, a school, commercial center, theater, three recreation 09-033(E)/100511 3-23

halls, and other buildings (Gosling 1990, Hewlett and Anderson 1962). Demolition of the site began in 1947, and by the mid-1950s all buildings within the area had been torn down. Demolition of the buildings consisted of salvaging usable material and bulldozing or burning the remainder of the material in place.

During the three surveys, 21 artifact concentrations, 13 isolated finds, and 98 surface features were located.

Because of their strong association with the Manhattan Project and the presence of intact archaeological deposits, two large Happy Valley archaeological sites (40RE233 and 40RE577) were identified and recommended as eligible for the NRHP. These two sites were distinctive housing areas for workers supporting construction of the K-25 facilities. The Wheat Community African Burial Ground (40RE219) is also located in the Happy Valley survey area, but it is not considered eligible for listing on the NRHP (New South Associates 2011).

3.6.2 Environmental Consequences 3.6.2.1 Proposed action Other than the Happy Valley area within Parcel ED-3, no other prehistoric or historic archaeological resources would be affected by the proposed action. Potential impacts could be indirect or direct, depending upon future development proposals. Known prehistoric sites located along Poplar Creek and the Clinch River are located in DOE-designated non-development areas or they would be protected from development through lease and/or deed restrictions based on consultation with the Tennessee SHPO.

Likewise, the six cemeteries located within the EA study area would remain under DOE control. They would also be protected from any future development activities through the establishment of appropriate buffers around each cemetery. A portion of the Parcel ED-3 area is directly adjacent to the Wheat Historic District, but development would not have any direct adverse impacts on the area, and the view of the George Jones Memorial Baptist Church would not be obscured. Lease and/or deed restrictions would require that if an unanticipated discovery of cultural materials (e.g., human remains, pottery, weapon projectiles, and tools) or sites is made during any development activities, all ground-disturbing activities in the vicinity of the discovery would be halted immediately. The lessee would be responsible for contacting DOE and property owners would be responsible for contacting the Tennessee SHPO, prior to any further disturbance of the discovery-site area.

DOE has determined, in accordance with Sect. 800.3 of the Advisory Council on Historic Preservation (Council) regulations for the protection of historic properties, that the proposed action (1) is an undertaking, as defined in 36 CFR 800.1(y); and (2) is the type of activity that has the potential to cause effects on historic properties. In accordance with Sect. 800.8(c) of the Councils regulations, DOE notified the State and the Council of the proposed undertaking. The Tennessee SHPO reviewed the final Happy Valley archaeology report and found that it meets the Tennessee SHPO Standards and Guidelines for Archaeological Resource Management Studies. Unless project plans are changed or there is an unanticipated discovery of archaeological remains, the Section 106 process has been completed. Copies of the correspondence between DOE and the SHPO are included in Appendix A.

3.6.2.2 Alternative 1 Potential cultural resource impacts, under Alternative 1, would be similar to those described for the proposed action.09-033(E)/100511 3-24

3.6.2.3 Alternative 2 Potential cultural resource impacts, under Alternative 2, would be similar to those described for the proposed action.

3.6.2.4 No action Under the no action alternative, there would be no changes or additional impacts to cultural resources within the EA study area beyond those being addressed for current activities.

3.7 SOCIOECONOMICS 3.7.1 Existing Conditions The ROI for this analysis includes Anderson, Knox, Loudon, and Roane counties. The region includes the cities of Clinton, Oak Ridge, Knoxville, Loudon, Lenoir City, Harriman, and Kingston.

3.7.1.1 Demographic and economic characteristics Table 3.4 summarizes population, per capita income, and wage and salary employment from 2004 to 2009, the latest year for which county data are available. Population has increased slightly over the 6-year period, with Knox County accounting for most of the growth. Employment for the region increased from 377,014 in 2004 to 390,857 in 2009. Per capita income grew from $30,952 to $34,877 over the same period, generating a total regional income of $21.3 billion in 2009 (Bureau of Economic Analysis 2011a).

Based on the 2010 Census, minorities represent 9.2% of the population in Anderson County, 16.0%

in Knox County, 9.7% in Loudon County, and 6.3% in Roane County (Census 2010). This represents a limited change from the corresponding figures from the 2000 Census. For comparison, minorities represented an estimated 36.1% of the national population and 24.3% of the Tennessee population in 2010. No federally recognized Native American groups live within 50 miles of the study area.

Table 3.5 shows Census estimates of the distribution of minority populations in the city of Oak Ridge based on the 2010 Census. Within the city, the minority population is estimated at 18.1% of the total population. Minorities include individuals classified by the U.S. Bureau of the Census as Black or African-American, American Indian and Alaska Native, Asian, Native Hawaiian and Other Pacific Islander, and Hispanic or Latino, and those classified under Two or more races. This provides a conservative estimate consistent with the Office of Management and Budget (OMB) and Census guidance (Census 2003). Hispanics may be of any race and are excluded from the totals for individual races to avoid double counting.

Tract data are not yet available for Oak Ridge from the 2010 Census, but as discussed above, the population changes between 2000 and 2010 have been small, and tracts are also likely to be similar between 2000 and 2010. Of the Census tracts surrounding the ORR in 2000, only the Scarboro Community in tract 201 included a minority population greater than the national average.

African-Americans comprised 29.6% of the population in tract 201, and other minorities (including two or more races) comprised 10.5%. For all other tracts in the area, minorities comprised 20% or less of the population. For comparison, minorities represented 21.0% of the population in Tennessee (Bureau of the Census 2000).09-033(E)/100511 3-25

Table 3.4. Demographic and economic characteristics: Oak Ridge Region of Influence Annual 2009 growth 20042009 County 2004 2005 2006 2007 2008 (%)

Anderson Population 71,338 71,747 72,810 73,322 74,182 74,849 0.77%

Per capita income ($) 29,282 30,141 31,447 32,800 33,367 33,851 2.85%

Total employment 51,471 52,140 52,511 52,753 54,212 51,308 0.99%

Knox Population 403,432 409,530 417,230 424,716 431,072 435,725 1.55%

Per capita income ($) 31,890 32,844 34,675 35,792 36,342 35,278 3.53%

Total employment 286,885 291,699 299,548 308,426 314,761 296,618 2.67%

Loudon Population 42,139 43,228 44,363 45,346 46,216 46,725 1.86%

Per capita income ($) 30,134 31,071 32,628 34,835 35,546 34,888 3.36%

Total employment 17,762 18,408 19,002 19,726 20,402 18,870 2.81%

Roane Population 52,624 52,556 53,084 53,309 53,473 53,508 0.40%

Per capita income ($) 26,655 28,247 29,532 31,230 32,260 33,015 5.15%

Total employment 20,896 21,777 21,944 22,062 22,731 22,061 1.79%

Region Totals Population 569,533 577,061 587,487 596,693 604,943 610,807 1.40%

Per capita income ($) 30,950 31,958 33,655 34,944 35,555 34,877 3.68%

Total employment 377,014 384,024 393,005 402,967 412,106 390,857 2.42%

Source: Bureau of Economic Analysis 2011a.

Table 3.5. Race or ethnic distribution for Oak Ridge City population: 2010 Race or ethnic group Number Percent Not Hispanic or Latino White 23,978 81.8 Black or African American 2,362 8.1 American Indian or Alaska Native 87 0.3 Asian 725 2.5 Native Hawaiian and Other Pacific Islander 8 0.0 Some other race 34 0.1 Two or more races 788 2.7 Hispanic or Latinoa 1,348 4.6 Total 29,330 100.0 a

May be of any race. Those classified as Hispanic or Latino are excluded from other categories to avoid double counting.

Source: U.S. Census Bureau 2010.

According to the 2009 American Community Survey, 13.5% of the U. S. population and 16.1% of the Tennessee population had incomes below the poverty level in 2008 (Census 2009). Comparable figures from the 2010 Census are not yet available. In this analysis, a low-income population consists of any geographic area in which the proportion of individuals below the poverty level exceeds the national average. Within Oak Ridge, 15.3% of the population had incomes below the poverty level in the previous year. At the time of the 2000 Census, there were only two low-income populations located near the ORR,09-033(E)/100511 3-26

in census tracts 201 (15.8% below poverty level) and 205 (27.9%). Tract 201 roughly corresponds to the Scarboro community, and tract 205 includes the area between Oak Ridge Turnpike and West Outer Drive, bounded on the west by Louisiana Avenue and on the east by Highland Avenue and Robertsville Road. In other nearby census tracts, the percentages ranged from 12.1% in tract 204 to 1.9% in tract 301 (Census 2000).

3.7.1.2 Fiscal characteristics Oak Ridge City general fund revenues and expenditures for FY 2010 and anticipated revenues and expenditures for FY 2012 are presented in Table 3.6. The general fund supports the ongoing operations of local governments as well as community services, such as police protection and parks and recreation. The largest revenue sources have traditionally been local taxes (which include taxes on property, real estate, hotel/motel receipts, and sales) and intergovernmental transfers from the federal or state government.

Roughly 95% of the 2010 general fund revenue came from these combined sources (City of Oak Ridge 2011). For FY 2012, the property tax rate is $2.49 per $100 of assessed value. The assessment rate is 40%

for industrial and commercial property and 25% for residential property (City of Oak Ridge 2008, 2009).

The city also receives a payment-in-lieu-of-tax (PILT) for ORR acreage that falls within the city limits. The payment is based on its value as farmland, and assessed at the farmland rate of 25% (City of Oak Ridge 2010). In 2012, the city expects to receive a payment of approximately $1,476,000 (City of Oak Ridge 2011).

Roane County reassessed property values in 2011, and adjusted the tax rate to $1.9051 per $100 of assessed value (City of Oak Ridge 2011).

Table 3.6. City of Oak Ridge revenues and expenditures, FY 2010 and budgeted FY 2012 ($)

2010 Actual 2012 Budgeted Revenues Taxes 31,567,744 33,644,345 Licenses and permits 243,947 203,000 Intergovernmental revenues 3,085,662 3,153,426 Charges for services 308,894 341,070 Fines and forfeitures 1,325,167 362,000 Other revenues 514,109 508,000 Total revenues 37,045,523 38,211,841 Expenditures and other financing Expenditures (18,437,381) (19,453,250)

Other financing usesa (16,774,842) (20,275,322)

Total expenditures and other financing (35,212,223) (39,728,572) a Includes items such as capital projects fund, solid waste fund, economic diversification fund, debt service, and schools.

Source: City of Oak Ridge 2011.

FY = Fiscal year.

3.7.2 Environmental Consequences This section addresses the potential socioeconomic impacts of the proposed action and its alternatives. Socioeconomic impacts are not only important in themselves, but also for the secondary environmental or distributional effects they may have. For example, economic growth can sometimes attract enough new people to an area that it places pressure on housing, schools, water supply, and other infrastructure. Environmental effects of any new construction, facility improvements required, or 09-033(E)/100511 3-27

infrastructure overloads that result from such a population increase should also be evaluated as induced effects of the development. For this reason, the analysis below uses bounding assumptions to identify the range of potential impacts. The purpose here is not to forecast economic activity but to make sure that reasonably foreseeable indirect effects are appropriately identified and considered.

3.7.2.1 Proposed action Environmental Justice Executive Order 12898, Federal Action to Address Environmental Justice in Minority Populations and Low Income Populations, requires agencies to identify and address disproportionately high and adverse human health or environmental effects its activities may have on minority and low-income populations. Although current assumptions suggest that there would be no high and adverse human health or environmental impacts, the actual circumstances would depend on specific choices made at the time of development. As discussed above in Sect. 3.7.1, of the census tracts near the proposed site, only tract 201 includes a higher proportion of minorities in the population than the national average. Other tracts are also located closer to the proposed site, and in the event that adverse impacts occur, they are likely to have at least as much effect on these closer populations as on the residents of tract 201.

Similarly, some low-income populations are located near the proposed site. However, these populations are scattered among higher income populations. Any adverse impacts that affect the low-income tracts are also likely to affect the higher income populations. Therefore, any adverse health or environmental impacts that may occur are not expected to have a disproportionate effect on low-income or minority populations.

Employment and Income In the 1997 EA, it was estimated that developing the proposed acreage could generate up to 2,500 new, direct jobs over the 13-year period from 1997 to 2010 (DOE 1997). Since the current proposed action incorporates only small changes in acreage and in the parcels considered, it was determined that this estimate was still valid as a bounding assumption (Biloski 2009). The 1997 EA also estimated that the new, direct employment could generate up to 3,300 indirect jobs to provide the goods and services demanded by the new workers and the enterprises that employ them. Under these assumptions, as an upper bound the proposed action could create a total of 5,800 new jobs, or an increase of 1.5% in employment for the ROI compared to 2009. Over 13 years, this represents an annual growth rate of roughly 0.1%, well within the historic growth rate for the region. Based on experience to date, actual development may be spread over a longer period of time, resulting in a smaller impact in any one year.

The impact on regional income is expected to be similar to the employment impact. Assuming that the new employees earned the 2009 average wage for Tennessee of $39,684, then regional income would increase by $230 million (5,800 x 39,684), a 1.1% increase compared to 2009. The actual impact on income will depend on the final mix of industries and their individual wage levels. For example, the state average manufacturing wage in 2009 was higher than the state average at $48,695, while the average wage for accommodation and food services is much lower at $17,103 (BEA 2011b).

Population Based on the limited employment impact, no change in population is anticipated as a result of the proposed action.09-033(E)/100511 3-28

Fiscal Impacts There are two potential changes in local revenue as a result of development: (1) additional tax revenue as property or improvements on property become taxable, and (2) loss of DOE PILT on any acreage transferred. While DOE owns the land and buildings, they are not taxable, but leasehold improvements made by tenants are taxable (Young 2002). With title transfer, facilities could be sold and both the property and improvements by the new owners would be subject to property and sales taxes.

However, the value of improvements is usually much greater than the land itself, and therefore tax revenues are likely to be similar whether the land is leased or transferred (ORNL 2002). Moreover, only land eventually sold to private corporations is likely to become taxable; transfer to Heritage Center LLC or other nonprofit entity may not change the propertys tax status (Young 2002). As a result, the net change in revenue to the city and Roane County would be the tax collected on land and improvements sold to for-profit organizations, minus any lost revenues from discontinued PILT.

The total amount of land that could be sold is unknown at this time. Nationwide experience with Brownfields suggests that even after remediation, these sites are more difficult to market and develop than comparable sites with no history of contamination (United States Conference of Mayors 2000). The Conference of Mayors defines a Brownfield site as one in which redevelopment is complicated by either real or perceived environmental contamination. The amount of land sold would depend on the final size of the parcels transferred, the proportion of the land considered developable after remediation, and on other market factors.

For the purposes of this analysis, the assumptions developed for the ETTP EA Addendum in 2003 are used, which assumed that approximately 1,600 acres would be transferred. The analysis also assumed that the entire 1,600 acres would be transferred at one time. However, the actual transfers would likely be phased over a yet to be determined time period. If Heritage Center LLC or a similar non-profit entity retains ownership of all of the land and existing buildings, then there would be no change in the tax status, and the net result of the transfer is the annual loss of the PILT. For 1,600 acres, this would amount to roughly $64,200 in 2012 (1,600 acres valued at $6,450/acre x 25% assessment rate x $2.49 per

$100 assessed value) [Finn 2009; City of Oak Ridge 2010; 2011]. The amount for Roane County would be approximately $49,200 at the 2011 tax rate of $1.9051 per $100 assessed value (City of Oak Ridge 2011). It should be noted that tax revenue would be generated on improvements made to the property regardless of whether it is leased or the title is transferred.

The analysis also assumed that about 500 out of the 1,600 acres potentially transferred would eventually be suitable for development. The city and county would collect maximum tax revenue if all of the 500 acres is eventually sold to tax-paying corporations. Unimproved Oak Ridge industrial land has been valued from $17,000 to $35,000 per acre (FLUOR 2001). The total land value for 500 acres would then fall between $8.5 million and $17.5 million, and the assessed value between $3.4 million and

$7.0 million. At $2.49 per $100 assessed value, that would result in roughly $85,000 to $174,000 in annual tax revenue for the city of Oak Ridge. Subtracting the $64,200 in lost revenue from discontinued DOE PILT suggests that net new annual city revenue could range from $20,800 to $110,100 ($85,000 minus $64,200 to $174,000 minus $64,200).

Using the same assumptions and the 2011 tax rate of 1.0951 per $100 assessed value, Roane County could receive $37,200 to $133,400 in annual tax revenue. Subtracting roughly $49,200 in lost PILT revenues suggests that net new annual revenue for Roane County could range from a loss of $12,000 to a gain of $84,200. Any improvements made to the land would further increase the net gain to both the city and the county. The Oak Ridge National Laboratory (ORNL) land use planning document estimated that the value of improved industrial land can range from 8 to 15 times its unimproved value, and commercial land values are likely to be much higher (ORNL 2002).09-033(E)/100511 3-29

In addition, commercial development can also increase local government revenues through sales taxes, although the size of those revenues depends on too many factors to predict in advance. Actual revenues would depend on the acreage transferred, the amount of property sold, the types of improvements made, and on future land valuations, assessments, and tax rates.

3.7.2.2 Alternative 1 Under Alternative 1, employment impacts are expected to be similar to those for the proposed action.

Since manufacturing wages are higher than the Tennessee average wage, income impacts may be slightly higher than for the proposed alternative, but the total change in income would still be within the historic growth rate for the region. Property tax impacts would be similar to those discussed for the proposed action. Because purchases of raw materials for manufacturing are usually not taxable, sales tax revenues would be limited.

3.7.2.3 Alternative 2 Under Alternative 2, employment impacts are expected to be similar to those for the proposed action.

Income impacts will depend on the actual mix of businesses that locate in the site, since wages for the potential businesses vary widely. For example, the average annual wage for Professional, scientific, and technical services in Tennessee was $61,672 in 2009, compared to $30,930 for Administrative and waste services, and $17,103 for Accommodation and food services.

Assuming all development efforts succeed, fiscal impacts may be somewhat greater for unified business development than for the proposed action because both property tax and sales tax revenues are likely to be greater. Historically, property values in Oak Ridge have been higher for commercial property, ranging from $50,000 to over $100,000 per acre. The total land value for 500 acres would then fall between $25 million and $50 million, and the assessed value between $10 million and $20 million. At

$2.49 per $100 assessed value, that would result in roughly $249,000 to $498,000 in annual tax revenue for the city of Oak Ridge. Subtracting the $64,200 in lost revenue from discontinued DOE PILT suggests that net new annual city revenue could range from $184,800 to $433,800 ($249,000 minus $64,200 to

$498,000 minus $64,200).

Using the same assumptions, Roane County could receive approximately $190,500 to $381,000 in annual tax revenue. Subtracting $49,200 in lost PILT revenues suggests that net new annual revenue for Roane County could range from $141,300 to $331,800. Any improvements made to the land would further increase the net gain to both the city and the county. The ORNL land use planning document estimated that the value of improved industrial land can range from 8 to 15 times its unimproved value, and commercial land values are likely to be much higher (ORNL 2002).

Unified business development may also include a higher proportion of retail establishments, with some associated increase in sales tax revenue. Actual revenues would depend on the acreage developed, the amount of property sold, the types of improvements made, actual mix of businesses, and on future land valuations, assessments, and tax rates.

3.7.2.4 No action Under the no action alternative, no change in employment, income, population or local government revenues is anticipated beyond that which is generated through the current and planned reindustrialization activities.09-033(E)/100511 3-30

3.8 INFRASTRUCTURE 3.8.1 Existing Conditions 3.8.1.1 Utilities Most of the developed area of the ETTP has available utilities or existing utility infrastructure is located in the nearby vicinity.

Electricity and Natural Gas TVA generates electric power for the region. TVA presently transmits power directly to the ETTP, but most residences and businesses receive their power through distribution companies that purchase wholesale power from TVA. The city of Oak Ridge operates its own electric utility, providing electricity to about 15,000 metered customers. The electrical lines that run through Parcel ED-3 are owned by the city of Oak Ridge. Peak system demand in the city is approximately 120 megavolt-amperes (MVA),

while the systems base capacity is just over 200 MVA.

Natural gas is distributed to houses and other buildings in the region by a number of different companies, including Empiregas, Inc., of Clinton; Harriman Utility Board; Oak Ridge Utility District; and the PowellClinch Utility District. East Tennessee Natural Gas Company is the major pipeline transmission system for the area. The Oak Ridge Utility District has a right-of-easement with DOE for a 6-in. natural gas pipeline from the K-720-A Gas Metering Station on the East Tennessee Natural Gas Companys transmission line (east of Flannagans Loop Road) that parallels the south side of SR 58, within Parcel ED-3, and then runs underneath the Clinch River.

Potable Water Water supply for the Oak Ridge area is obtained from the Clinch River. DOE transferred ownership of its water treatment plant to the city of Oak Ridge effective May 1, 2000. This plant is located on Pine Ridge near the Y-12 Complex. The plant produces about 12 million gallons per day (MGD) and has the capacity to produce up to 28 MGD.

The ETTP has a pumping station (K-1513) on the Clinch River located at the west end of Bear Creek Road. The sanitary water system also includes a filtration and treatment plant (K-1515), water storage tanks (K-1529 and K-1530), and about 19 miles of water distribution pipe (MMES 1994). The ETTP water treatment plant is currently producing 800,000 gallons per day (GPD) to 1.4 MGD of potable water, with an average production of about 1.2 MGD. Its capacity is estimated at 4.1 MGD (Bowman 1999).

The water distribution system is made up of 10-in. and 12-in. cast-iron mains. The water distribution system is in fair condition although it is more than 45 years old. DOE transferred these facilities to the city of Oak Ridge in May 2008. The city also owns the water main running through Parcel ED-3. The city of Oak Ridge plans to abandon the ETTP water intake and treatment system once new water lines are in place to serve this area along with the rest of the city from the Pine Ridge water plant.

Wastewater Treatment Facilities for the treatment of domestic and industrial wastewater are available at the city of Oak Ridge Publicly Owned Treatment Works (POTW) and the package wastewater treatment plant located at the Rarity Ridge development. The sewage treatment plant that was located at ETTP has been shut down and is no longer in operation. Design capacity at the city of Oak Ridge POTW is about 5.9 MGD. The plant currently processes between 5.1 and 5.3 MGD (Currier 1999). The city recently 09-033(E)/100511 3-31

completed upgrading the POTW to increase the capacity to about 30 MGD. CROET, in May 2008, installed a new lift station and force main at ETTP to accommodate other nearby areas (i.e., the ETTP and Parcel ED-3) and send wastewater from ETTP to the Rarity Ridge plant.

3.8.1.2 Transportation Major transportation routes to the ORR are via two interstate highways, I-40 and I-75, and U. S. highways 11, 25W, and 70. I-40 is located almost directly west of the ETTP site. DOE has transferred some roads at the ETTP to the city of Oak Ridge to provide access to property that has already been transferred.

Motorists utilize four roadway segments within and near the EA study area:

• SR 95 (Oak Ridge Turnpike) from the SR 95/58 interchange to Wisconsin Avenue,

• SR 95 (White Wing Road) from the SR 95/58 interchange to Bear Creek Road,

• SR 327 (Blair Road) from Poplar Creek Road to SR 58, and

• SR 58 from Gallaher Road to the SR 95/58 interchange.

Annual average daily traffic for roadways near the study site ranges from 3,280 to 12,050 vehicles a day, which is considered light compared to other roadways in Oak Ridge (which range from 17,040 to 30,360 vehicles a day). The majority of the ETTP commuting traffic (88%) comes from the east on SR 58, and the remaining 12% comes from the west. Of the east side traffic, 62% comes from the Oak Ridge Turnpike, 8% comes from Blair Road, and 18% comes from SR 95 (White Wing Road)

(DOE 1997). Construction to widen SR 95 from the intersection with SR 62 (Illinois Avenue) to near Westover Drive has been completed. Widening of SR 95 from near Wisconsin Avenue west to the SR95/58 interchange is presently underway.

3.8.2 Environmental Consequences 3.8.2.1 Proposed action Utilities Under the proposed action, utility impacts would be expected to be minimal. Commercial or industrial facilities could connect to the existing utility systems that serve the ETTP and the surrounding area. Excess service capacity exists at the city of Oak Ridge facilities and is large enough to accommodate additional development within the EA study area. Construction of new utility infrastructure would be limited. Electricity would be purchased from the city of Oak Ridge, and natural gas would be purchased from the Oak Ridge Utility District. Telecommunication services could be provided from the fiber-optic system that serves the ETTP. Existing water and sewer lines currently exist along SR 58. In the long-term, the city of Oak Ridge, along with other public and private organizations, is working on extending utility service to the western portion of the city corporate limits to serve proposed future developments.

Transportation The transport of materials and equipment associated with any construction activities to accomplish the development of any property that is conveyed would be over regional and local roadways to the site.

Additionally, the development would be phased over time, and no adverse impacts are expected. The additional amount of vehicle and truck traffic from operations associated with the new development would have a negligible effect on existing traffic since the affected roadways presently have sufficient design capacity. It should be noted that although commercial and industrial development for the ETTP 09-033(E)/100511 3-32

area could slightly increase traffic, the volume of traffic is not expected to exceed historic traffic volumes that occurred between 19931996 during large employment periods at the ETTP. A minor increase in the amount of traffic should also not substantially increase the chance of accidents occurring. Installing turn lanes, additional traffic signals, and frontage roads could mitigate these types of potential impacts, if necessary.

3.8.2.2 Alternative 1 Potential utility and transportation impacts under Alternative 1 are expected to be similar to those described for the proposed action. However, since this alternative assumes greater industrial development, it is assumed that utility demand and use would be greater and the percentage of additional truck traffic would likely be greater.

3.8.2.3 Alternative 2 Utility impacts under Alternative 2 are expected to be similar to those described for the proposed action. However, since industrial uses would not be permitted under the City of Oak Ridge Zoning Ordinance for UB-2, Unified General Business Districts, potential utility demand and use are assumed to be less. Transportation impacts under Alternative 2 are expected to be similar to those described for the proposed action.

3.8.2.4 No action There would be no changes to utilities under the no action alternative beyond the utility easements and improvements that are taking place as part of ongoing and planned reindustrialization activities.

There would be little change from the baseline level of vehicle trips or the potential for accidents involving vehicles. At the baseline level of activity, traffic volume is considered to be within the existing transportation infrastructures capacity.

3.9 WASTE MANAGEMENT 3.9.1 Existing Conditions Waste management from ongoing environmental restoration activities at ETTP is currently managed by the DOE-ORO EM Program and Bechtel Jacobs Company LLC. Waste management facilities at ETTP include the Toxic Substances Control Act of 1976 (TSCA) Incinerator and the Central Neutralization Facility (CNF). On December 2, 2009, the TSCA Incinerator ceased operations as a waste incinerator and transitioned to a facility closure and decommissioning mode. The CNF will be shut down in FY 2011 for decommissioning after establishing a smaller chromate water treatment unit that will sit within the existing CNF footprint. Additional information on the ongoing environmental restoration and waste management activities at ETTP can be found in the 2009 ORR ASER (DOE 2010), FY 2010 Cleanup Progress Report (DOE 2011a), and the 2011 Remediation Effectiveness Report (DOE 2011b). Tenants operating at the Heritage Center, within the ETTP, contract with private waste haulers for solid and hazardous waste disposal (e.g., Waste Management).

The major waste types that would be generated from the proposed action and alternatives are described below.

Sanitary/industrial solid wastes consist of paper, garbage, wood, metal, glass, plastic, construction and demolition (C&D) debris, food wastes, sludge from water and air treatment, and other special wastes.09-033(E)/100511 3-33

The Solid Waste Management Program in Tennessee was implemented in 1971 with the promulgation of the Regulations Governing Solid Waste Processing and Disposal. Within the state of Tennessee, there are four distinct classes of solid waste landfills that are permitted by TDEC for disposal of various types of solid waste generated within the state. The four classes of landfills and wastes that may be disposed of within the various classes of landfills include:

• Class I landfills - municipal solid waste, household waste, shredded/waste tires, etc.;

• Class II landfills - industrial waste;

• Class III landfills - farming wastes, landscaping and land clearing wastes, etc.; and

• Class IV landfills - C&D waste.

Solid waste landfills are governed by federal and state environmental regulations that are found at 40 CFR Part 258 (governs only municipal solid waste landfills) and Rules of the TDEC Chap. 1200-1-7.

These provisions specify the operational and permit requirements for disposal of solid waste within the state of Tennessee. The nearest commercial Class I landfill to the ORR is the Chestnut Ridge Landfill and Recycling Center in Anderson County operated by Waste Management, Inc., of Tennessee.

Hazardous waste is a waste or surplus material with negligible value that may cause or contribute to an increase in mortality or to an increase in serious irreversible illness, or pose a substantial present or potential hazard to human health or the environment when improperly stored, treated, disposed of, or transported. These wastes are regulated pursuant to RCRA. Hazardous wastes are defined and regulated by RCRA regulations by specific source lists, non-specific source lists, characteristic hazards, and discarded commercial chemical product lists. The regulations generally divide hazardous wastes into two categories: characteristic hazardous wastes and listed hazardous wastes. Characteristic hazardous wastes are those that exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity, as defined in 40 CFR 261, Subpart C. Listed hazardous wastes are those found within the specific waste listings provided at 40 CFR Part 261, Subpart D. Tennessees Hazardous Waste Program is managed by TDECs Division of Solid and Hazardous Waste Management.

Low-level radioactive waste (LLW) is waste that contains radioactivity but is not classified as high-level waste, TRU waste, spent nuclear fuel, or byproduct material, as defined by DOE Order 435.1, Radioactive Waste Management. LLW does not contain hazardous waste as regulated by RCRA and as defined in 40 CFR 260268 (or state of Tennessee equivalent standards). Some polychlorinated biphenyl (PCB)-contaminated or PCB-detectable waste as regulated by TSCA, and as defined in 40 CFR 761, may be accepted and handled as LLW. DOE Order 435.1 and the Atomic Energy Act, as amended, provide the primary regulatory guidance and requirements for the management of LLW.

3.9.2 Environmental Consequences 3.9.2.1 Proposed action Specific details about the wastes that may be generated by companies locating on property that is conveyed and developed are not available; however, the types of uses that are anticipated would produce wastes typical of other industrial, research, and office park operations in the region. These wastes would be handled by the individual companies or by contracted waste management services providers and would not enter into existing ETTP waste management systems, except for possibly wastewater. It is also expected that the companies would practice waste minimization, source reduction, recycling, etc. Air and water discharges containing hazardous and/or radioactive constituents can also be associated with waste management activities. However, it should be noted that some industrial operations may have the same or greater impacts (e.g., chlorine release from a municipal water plant).09-033(E)/100511 3-34

Quantities of solid, non-hazardous waste generated would most likely be recycled or transported to the Chestnut Ridge Landfill for disposal. This solid waste could also include C&D debris such as construction materials for buildings, concrete and asphalt rubble, and land-clearing debris. It is anticipated that only minor quantities of hazardous waste and hazardous materials would be handled or generated. In the event that individual companies generate sufficient quantities to require reporting status, they would likely qualify as conditionally exempt, small-quantity generators. These wastes would be handled and stored according to applicable state and federal regulations and transported to an approved, licensed, off-site facility for further treatment and/or disposal. It is also possible that some companies may stabilize, test, and treat these wastes on-site as part of their operations. Petroleum, oils, lubricants, and chemicals would be managed in accordance with permits or licenses issued by the state of Tennessee, and in a way that would minimize the potential for contamination and adverse environmental impacts.

For NRC-licensed facilities, radioactive materials and wastes would be handled according to the conditions of the license. This might include returning the materials and waste to the manufacturer, when required, or stabilizing, testing, and transporting them to a licensed off-site facility for disposal. Persons who transport radioactive waste or have radioactive waste transported into or within the state of Tennessee to a disposal/processing facility are required to obtain a License-for-Delivery from the TDEC Division of Radiological Health. Persons whose activities result in the generation of radioactive waste have the primary responsibility to ensure that a License-for-Delivery is obtained.

Impacts from accidental spills would be addressed by individual operating entities through the use of safety procedures and spill prevention plans. If required by state/federal law, companies locating within the development would have a spill prevention, control, and countermeasures plan and/or an emergency response plan, should a release of hazardous materials (to any environmental mediumair, surface water, groundwater, or soils) occur.

3.9.2.2 Alternative 1 Potential waste management impacts under Alternative 1 are expected to be similar to those described for the proposed action. However, since this alternative assumes greater industrial development, the amount of waste generated would likely be greater.

3.9.2.3 Alternative 2 Potential waste management impacts under Alternative 2 are expected to be similar to those described for the proposed action. However, since industrial uses are not permitted under the City of Oak Ridge Zoning Ordinance for UB-2, Unified General Business Districts, the amount of waste generated would likely be less, especially the generation of hazardous and LLW.

3.9.2.4 No action Under the no action alternative, there would be no waste management impacts beyond those associated with ongoing DOE and contractor activities.

3.10 HUMAN HEALTH AND SAFETY 3.10.1 Existing Conditions Past activities at ETTP have resulted in releases of radionuclides and chemicals to the environment.

Such releases combine with natural sources and can augment the exposure to humans both on- and 09-033(E)/100511 3-35

off-site. Natural background sources include cosmic radiation and uranium and thorium in native soil.

Inorganic elements, such as arsenic, beryllium, and manganese, are also found in native soil on the ORR.

These naturally existing sources of radiological and chemical exposures become the background exposure to which the effects of the man-made releases would be added. The ORR ASER for 2009 (DOE 2010a) summarizes releases of environmental contamination levels of chemicals and radiation and resulting exposures for calendar year 2009. In general, human exposure pathways include direct contact, inhalation, and ingestion. Radiation exposure is commonly categorized as either external (exposure to penetrating radiation) or internal (ingestion and inhalation). Ingestion of radionuclides can be through the intake of water or foodstuffs (e.g., vegetation and fish).

DOE Order 5400.5, Radiation Protection of the Public and the Environment, limits the effective dose equivalent (EDE) that an off-site individual may receive from all exposure pathways and all radionuclides released from the ORR during 1 year to no more than 100 millirem (mrem). DOE regulations (10 CFR 835, Occupational Radiation Protection) establish radiation protection standards and program requirements for DOE and DOE contractor operations with respect to the protection of workers from ionizing radiation. DOEs limiting control value for a workers radiation dose is 5,000 mrem/year total EDE from combined internal and external sources.

3.10.1.1 Radiation exposure to the public The average annual background radiological EDE from natural and man-made sources to an individual residing in the United States is approximately 360 mrem. Approximately 300 mrem of the 360 mrem are from natural sources (e.g., radon and cosmic radiation) and about 55 mrem of which are from natural external radiation sources (i.e., cosmic and terrestrial radiation) [National Council on Radiation Protection and Measurements 1987]. External radiation exposure rates from background sources have been measured in Tennessee. The measured rates are equivalent to an average annual EDE of 42 mrem, ranging between 19 and 72 mrem (Myrick et al. 1981). This average is less than the United States annual average of 55 mrem.

DOE (2010a) provides estimates of radiological doses from the ETTP; information from this report is summarized here. The calculated radiation dose to the maximally exposed off-site individual resulting from airborne releases from the ETTP was about 0.06 mrem during 2009, which is less than 1% of the natural external radiation background EDE to an average Tennessee resident. The maximally exposed individual (MEI) is assumed to be located 0.6 miles southwest of the TSCA incinerator stack (K-1435).

A hypothetical MEI could have received a total EDE of about 0.3 mrem from radionuclides emitted to the atmosphere from all of the sources on the ORR in 2009; this is well below the National Emission Standards for Hazardous Air Pollutants (NESHAP) standard of 10 mrem for protection of the public and is about 0.1% of the 300 mrem that the average individual receives from natural sources of radiation. The calculated collective EDE to the entire population within 50 miles of the ORR (about 1,040,041 persons) was 17 person-rem, which is approximately 0.005% of the 312,012 person-rem that this population received from natural sources of radiation (DOE 2010a).

3.10.1.2 Public chemical exposures Health effects attributed to chemical exposures can be categorized as carcinogenic or non-carcinogenic. Chemical carcinogenic risks are reported here as a lifetime probability of developing an excess cancer. EPA defines a target cancer risk range of 10-4 (1 in 10,000) to 10-6 (1 in 1,000,000), which defines when cleanup actions are to be considered under CERCLA. Non-carcinogenic hazards are reported as hazard quotients (HQs) where unity (1) or greater represents a potential for adverse health effects. An HQ less than unity indicates an unlikely potential for adverse health effects. The sum of more 09-033(E)/100511 3-36

than one HQ for multiple toxicants and/or multiple exposure pathways is called a hazard index (HI).

Pathways of concern for non-carcinogens are defined as those with an HI greater than 1.

DOE (2010a) estimates the human health risks from chemicals found in the environs of the ORR.

The primary exposure pathways considered are ingestion of drinking water and fish. For ingestion of drinking water, HQs were estimated upstream and downstream of ORR discharge points. HQs were less than 1 for detected chemical analytes for which there are reference doses or maximum contaminant levels (i.e., barium, manganese, zinc, etc.). Acceptable risk levels for carcinogens typically range from 10-4 to 10-6. Risk values greater than 10-5 were calculated for the intake of arsenic in water at both upstream and downstream locations.

TDEC has issued a fish advisory that states that catfish should not be consumed from Melton Hill Reservoir (in its entirety) because of PCB contamination and has issued a precautionary fish consumption advisory for catfish in the Clinch River arm of Watts Bar Reservoir (DOE 2010a). PCBs (Aroclor-154 and Aroclor-1260) and mercury were detected in both sunfish and catfish at all three Clinch River sample locations. Aroclor-1260 was detected in both species at all locations while Aroclor-1254 was observed in catfish samples from each location. The results are consistent with the TDEC advisories. Radionuclide concentrations in the fish samples indicated that DOE activities on the ORR are not a significant contributor to public radiological dose from fish consumption.

3.10.2 Environmental Consequences 3.10.2.1 Proposed action Construction workers would be subject to typical hazards and occupational exposures faced at other industrial construction sites. Falls, spills, vehicle accidents, confined-space incidents, and injuries from tool and machinery operation could occur. Similar accidents could occur at facilities during operation.

Accidents could result from operator error, equipment malfunction, or from natural phenomena (e.g., earthquakes, tornadoes, flooding, fire, etc.). Potential hazards from the operation of facilities could include electrical energy, flammable materials, toxic/corrosive/reactive materials, and radiation sources.

Other hazards include kinetic energy and stored energy. Examples of kinetic energy hazards include moving ventilation system components, forklifts, and other drum- or box-handling equipment. Stored energy hazards include elevated structures and equipment, stacked drums, and boxes. Workers would receive applicable training, be protected through appropriate controls and oversight, and be afforded the same level of safety and health protection found at similar developments. The property developers and the individual companies that would operate would also be required to follow applicable OSHA requirements.

The potential for fires and any resulting adverse impacts would likely be mitigated by the following:

(1) most new building construction would consist of steel frames, concrete floors, noncombustible exterior walls, and metal roofs; (2) building design and materials would comply with all applicable National Fire Protection Association codes and standards; (3) buildings would be equipped with fire detection systems and fire-suppression equipment as applicable (e.g., fire alarms, portable fire extinguishers, and sprinkler systems); and (4) appropriate fire safety and emergency policies and procedures, including proper training, would be implemented.

No unique occupational health and safety hazards are expected, and it would be the responsibility of each company to operate in a safe and protective manner. Issues related to public and worker exposures to effluents and emissions from industrial operations would be addressed by permits and regulations under the state of Tennessee. If required by state and federal law, companies would be required to have an emergency response plan for the accidental release of hazardous materials. The Emergency Planning and 09-033(E)/100511 3-37

Community Right-To-Know Act (EPCRA) of 1986, also referred to as the Superfund Amendments and Reauthorization Act Title III, requires reporting of emergency planning information, hazardous chemical inventories, and releases to the environment. EPCRA reports (if required) would be submitted to federal, state, and local authorities. Section 304 of the EPCRA requires reporting of off-site reportable quantity releases to state and local authorities. It is expected that resources would be available for response to an event such as a release or spill through agreements with ETTP emergency response units and surrounding communities. It is anticipated that most of the facility operations would not result in radiological exposures. However, if a company did handle radioactive material or wastes, they would be regulated by the NRC or the state of Tennessee. These facilities would be required to comply with the terms and conditions of their radioactive materials license, if applicable.

3.10.2.2 Alternative 1 Potential human health and safety impacts under Alternative 1 are expected to be similar to those described for the proposed action. However, since this alternative assumes heavy industrial development, the potential for accidents and occupational exposures to physical, chemical, and radiological hazards would likely be greater.

3.10.2.3 Alternative 2 Potential human health and safety impacts under Alternative 2 are expected to be similar to those described for the proposed action. However, since industrial uses are not permitted under the City of Oak Ridge Zoning Ordinance for UB-2, Unified General Business Districts, the likelihood for accidents and hazardous occupational exposures would be less.

3.10.2.4 No action Under the no action alternative, there would be no human health and safety impacts beyond those associated with ongoing DOE and contractor activities.

3.11 INTENTIONAL DESTRUCTIVE ACTS DOE is required to consider intentional destructive acts, such as sabotage and terrorism, in each EIS or EA that it prepares. After review, it was determined that the likelihood of such acts for the proposed action is extremely low. It is possible that random acts of vandalism could happen as in any other location. It is also anticipated that security measures typical of small industrial parks and other commercial developments would be implemented.

3.12

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES Table 3.7 provides a comparative summary of the potential environmental consequences that could result from implementing the proposed action or alternatives.09-033(E)/100511 3-38

Table 3.7. Summary of impacts by resource Environmental impact Proposed action Alternative 1 Alternative 2 No action alternative Land use Land use would change Land use impacts Land use impacts No changes to the over time as development would be similar to would be similar existing land use or occurs. In less developed the proposed to the proposed visual resources would areas, the visual character action. Heavier action. Adverse occur. Ongoing and would change from a more industrial visual impacts planned remedial natural to a more man- development could associated with actions and made looking environment. have a greater heavy industrial reindustrialization visual impact. development activities would would not occur. continue.

Air quality and Construction would be Impacts would be Impacts would Air pollutants would noise phased and air emissions similar to the be similar to the continue to be emitted would be short-term, proposed action. proposed action. at current rates in the sporadic, and localized. Heavy industries Industrial uses vicinity of ETTP, and Fugitive dust would be could be required would not be no adverse effects to controlled to minimize to obtain a Title V permitted and air air quality are emissions. Minor air air quality permit. quality impacts predicted.

emissions from operations would be less.

could require air quality Noise impacts No changes in existing construction and operating would be similar to Adverse noise noise levels are permits (non-Title V). the proposed impacts are not expected. Noise levels action. expected. within the area are Other than temporary noise associated with from construction activities, ongoing uses and noise levels should remain adjacent traffic.

close to existing levels, and no adverse noise impacts are anticipated.

Geology and soils Adverse impacts on site Impacts would be Impacts would No impacts on geology are not expected. similar to the be similar to the geology and soils Geotechnical studies would proposed action. proposed action. would occur, and be conducted if required. existing site conditions Affected soils are generally would continue.

stable and acceptable for standard construction requirements. Karst areas should be avoided if practicable. Erosion prevention and sedimentation control measures would be implemented to minimize the potential for soil erosion.09-033(E)/100511 3-39

Table 3.7. Summary of impacts by resource (continued)

Environmental impact Proposed action Alternative 1 Alternative 2 No action alternative Water resources Erosion and sedimentation A greater density Impacts would No additional impacts controls would limit of heavy industrial be similar to the to any water resources potential impacts on surface development could proposed action. are expected. Ongoing water. No impacts on increase the surface and surface water or potential for groundwater groundwater are anticipated adverse impacts. monitoring and, where from construction and appropriate, normal facility operations. remediation would Groundwater use would be continue at the ETTP.

prohibited. Applicable federal, state, and local laws and regulations would apply to any activities that could potentially affect a floodplain or wetlands.

Ecological Vegetation and habitats in Impacts would be Impacts would Existing biological resources affected areas would be similar to the be similar to the resources would be permanently changed to an proposed action. proposed action. unaffected because no urban/industrial cover type. new development Some wildlife would be would occur in the destroyed and displaced area. Absent active during development. No management, natural state or federally listed succession of threatened and endangered vegetation would species have been identified, continue to occur and no adverse impacts within existing would occur. habitats.

Cultural resources Cemeteries and known Impacts would be Impacts would There would be no prehistoric sites would be similar to the be similar to the changes or additional protected. Section 106 proposed action. proposed action. impacts.

process with Tennessee State Historic Preservation Officer completed. No adverse impacts would occur.09-033(E)/100511 3-40

Table 3.7. Summary of impacts by resource (continued)

Environmental impact Proposed action Alternative 1 Alternative 2 No action alternative Socioeconomics Positive employment and Impacts would be Impacts would No change in income impacts. No impact similar to the be similar to the employment, income, on population. Positive proposed action. proposed action. population, or local fiscal impacts include government revenues increased revenue from is anticipated beyond real estate or sales taxes. that which is generated DOE would not continue through current and the in-lieu-of-tax payments planned on the property that is reindustrialization conveyed. activities.

No disproportionate adverse health or environmental impacts would occur to any low-income or minority population.

Infrastructure Existing utilities have Utility impacts Utility impacts There would be no adequate capacity to would be similar to would be similar impacts on existing support additional the proposed to the proposed utilities. Traffic would development, but minor action. Demand action. likely continue to upgrades and modifications could be higher remain close to current would be needed. from increased Transportation levels, and no impacts heavy industrial impacts would are anticipated.

Transport of construction development. be similar to the materials would be over proposed action.

regional and local Transportation roadways and would have impacts would be a negligible effect on similar to the existing traffic. Employee proposed action, traffic could increase over but there could be a current levels but would greater volume of not exceed historic levels. truck traffic.

Waste Solid non-hazardous waste Impacts would be Impacts would Ongoing waste management would be recycled or similar to the be similar to the management activities transported to an proposed action. proposed action. would continue appropriate licensed Heavy industrial unchanged.

landfill for disposal. Minor development could quantities of hazardous or increase the radioactive waste may be amount of waste generated. Companies generated.

would use existing licensed and/or permitted treatment, storage, and disposal facilities.09-033(E)/100511 3-41

Table 3.7. Summary of impacts by resource (continued)

Environmental impact Proposed action Alternative 1 Alternative 2 No action alternative Human health and Construction workers Heavy industrial Impacts would No additional impacts safety would be subject to typical development could be similar to the on the environment hazards and occupational increase the proposed action. within or adjacent to exposures. No unique potential for the proposed locations occupational health and accidents and beyond the scope of safety hazards would be occupational normal conditions and posed by development. exposures to influences in the area.

physical, chemical, and radiological hazards.

Intentional The likelihood of sabotage Same as the Same as the Ongoing security Destructive Acts and terrorism is extremely proposed action. proposed action. measures and property low. However, it is access controls in the possible but highly area would continue.

unlikely that random acts of vandalism could occur.

A variety of measures to control access and maintain security would be used.

Cumulative The cumulative Similar to the Similar to the No additional impacts contribution of impacts proposed action. proposed action. cumulative impacts that the proposed action would occur.

would make on the various environmental resources is expected to be minor.

DOE = U. S. Department of Energy.

ETTP = East Tennessee Technology Park NRHP = National Register of Historic Places.09-033(E)/100511 3-42

4. CUMULATIVE IMPACTS Cumulative impacts are those that may result from the incremental impacts of an action considered additively with the impacts of other past, present, and reasonably foreseeable future actions. Cumulative impacts are considered regardless of the agency or person undertaking the other actions (40 CFR 1508.7, CEQ 1997) and can result from the combined or synergistic effects of individually minor actions over a period of time. The actions are as follows and the location of the actions is shown on Fig. 4.1.

4.1 POTENTIALLY CUMULATIVE ACTIONS This section describes present actions as well as reasonably foreseeable future actions that are considered pertinent to the analysis of cumulative impacts for the proposed action.

ORNL Revitalization Program and Modernization Initiative. DOE is implementing a revitalization project at ORNL to consolidate staff on the main ORNL campus; vacate old, expensive to maintain space; and build new, and refurbish key facilities. The first phase included construction of up to 24 new facilities totaling approximately 1.2 million ft2 in Bethel Valley near the main ORNL entrance, near the West Portal in Bethel Valley, and within the footprint for the Spallation Neutron Source. Some of the new construction is being funded by the state of Tennessee and the private sector. About 20 acres of Brownfields property in Bethel Valley have been transferred from DOE to the private sector in support of this proposed action. The environmental consequences of this project were reviewed in an EA (DOE/EA-1362).

The ORNL Modernization Initiative includes additional upgrades and construction of new facilities at ORNL including, but not limited to, offices, laboratories, and maintenance and support facilities. In addition to the new facilities, the proposed action would include replacement of the existing wastewater treatment plant, upgrading the ORNL Steam Plant with a biomass gasification system, decentralizing a portion of the steam distribution system that serves several remote buildings, and the construction of a new small package steam plant. DOE completed an EA for the project (DOE/EA-1618).

Oak Ridge Science and Technology Project. DOE completed an EA (DOE/EA-1575) for the creation of the Oak Ridge Science and Technology Project (ORSTP) at ORNL. The proposed action would advance technology transfer and other missions at ORNL by supporting technology commercialization, creating new companies, and stimulating technology-based recruitment.

To establish the ORSTP, DOE will lease approximately 40 acres of underutilized facilities and land parcels at ORNL within the Central Campus area, which is located in the western portion of the Laboratory. ORSTP is intended primarily for R&D facilities, high-technology and science-based companies, engineering support services, technology commercialization incubation space, and prototype manufacturing facilities. Initially, ORSTP would be within the northwest quadrant of the Central Campus and includes approximately 12 acres of currently leased property along Bethel Valley Road where the new Pro2Serve National Security Engineering Center was constructed. New buildings would be constructed, but existing facilities could also be modified or renovated to accommodate new users. An example is the Halcyon Commercialization Center, formerly known as Bldg. 2033.09-033(E)/100511 4-1

4-2 LEGEND:

TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA OAK RIDGE, TENNESSEE Fig. 4.1. Location of actions contributing to cummulative impacts.

Integrated Facility Disposition Project (IFDP). IFDP integrates the cleanup scope resulting from modernization of ORNL and the Y-12 Complex with the existing Oak Ridge EM baseline. The scope for IFDP, among other activities, is to demolish excess facilities, dispose of legacy materials/waste, and address environmental cleanup, resulting in risk reduction, surveillance and maintenance (S&M) cost reduction, and release of strategic real estate for modernization initiatives. The IFDP estimated cost ranges from $4 to $8 billion and the duration ranges from 15 to 20 years. The IFDP scope includes:

• D&D of over 400 facilities;

• remedial actions;

• facility reconfiguration, adaptive re-use, and utility modifications;

• waste treatment and storage facilities operations;

• ORR Landfill operation;

• CERCLA Cell (Environmental Management Waste Management Facility) operation, expansion, and closure;

• S&M;

• legacy material/waste and remedial action and D&D waste disposition;

• associated regulatory and planning documentation, including final RODs; and

• project management, administration, and support.

Horizon Center. In 2003, DOE transferred title of the developable portion (approximately 491 acres) of what was previously referred to as Parcel ED-1 to Horizon Center LLC, a subsidiary of CROET, for the continued development as an industrial/business park for R&D, as well as manufacturing, distribution, and corporate headquarters office facilities. Subsequently Horizon Center was transferred to the Oak Ridge Industrial Development Board. DOE maintains ownership of the remainder of the parcel, which includes the NA.

Y-12 Complex Modernization Program. DOE issued a Final Site-Wide EIS and ROD on the operation of the Y-12 Complex and modernization of facilities (DOE 2001b). Major actions include construction of the Highly Enriched Uranium Materials Facility, which replaced multiple aging facilities within a single state-of-the-art storage facility; a Purification Facility, which was completed in 2004; a Uranium Processing Facility, which will replace current enriched uranium and other processing operations; an Enriched Uranium Manufacturing Facility to replace current enriched uranium and other processing operations; and the Beryllium Capability project, which will upgrade an existing facility, installing modern equipment that will protect workers from exposure to beryllium and improve efficiency and reliability. Many existing facilities have been demolished to prepare for the new construction that began in 2003. By 2013, when the Uranium Processing Facility becomes operational, the Y-12 Complex will have reduced its defense manufacturing footprint by almost one-half.

Roane Regional Business and Technology Park. This industrial park is located north of Interstate 40 in Roane County approximately 3 miles southwest of the ORSTP site. The 655-acre site includes areas for industrial development and greenbelt uses. The park is anchored by the H.T. Hackney Company distribution and service center. Other industries located at the site include instrumentation, light metalwork, ceramics, and materials handling. Additional types of industries expected to locate at the park include information technology, automotive transportation, and corporate administrative offices.09-033(E)/100511 4-3

Oak Ridge Industrial Center. The Oak Ridge Industrial Center is located at the site partially developed by TVA for the Clinch River Breeder Reactor prior to 1983. The 1,245-acre property has been considered for development by several manufacturing industries. TVA has graded a 150-acre tract on the property to <2% slope. The remaining land is rolling to rough terrain, having an 8 to 20% slope. The developable land contains tracts with hardwood forests and pine plantations impacted by the Southern pine beetle. The site also contains cultural resources. TVA has also designated a 103-acre tract bordering Grassy Creek as the Grassy Creek Habitat Protection Area to be reserved for protection of bugbane (Cimicifuga rubifolia) habitat (TVA 1988).

4.2 CUMULATIVE IMPACTS BY RESOURCE AREA Land Use. Of the original 58,582 acres of land acquired in 1942 by the federal government, 24,943 acres have been conveyed for residential, commercial, and community development; transportation easements; preservation and recreation; industrial development; and mission-related purposes, and approximately 33,639 acres remain within the ORR.

Current land outgrants (lease/license/permit areas) include:

• 2,966 acres for the BORCE,

• 2,920 acres for the Three Bend Scenic and Wildlife Management Refuge Area, and

• 466 acres for the Horizon Center NA.

Conveyance of additional land and facilities at ETTP under the proposed action could potentially remove additional land. However, the majority of the ETTP area being considered for conveyance has already been developed for industrial purposes or has been impacted in some other way. Further development would not result in substantial changes from this industrial land use. Additionally, DOE has designated large portions as non-development areas, and land use in these areas would remain as it presently is.

Soil. The most frequent effect of surface disturbance with regard to soil in this region is accelerated erosion. Implementation of past, current, and reasonably foreseeable future projects would add to the total acreage of soil disturbed and would permanently alter the soil within the footprint of the projects, adding to the overall loss of soil productivity. However, the majority of actions described within this document are within the areas where similar construction of roads and buildings has occurred or has been planned.

As long as all construction projects comply with state and federal laws and regulations, mitigations would be implemented to minimize erosion from construction activities and sediment delivery to nearby surface water. Additionally, landscaping after construction completion would serve to stabilize soil once the projects have been completed. These actions would minimize the cumulative impacts of construction projects in the region that may otherwise result in accelerated erosion.

Surface Water Resources. The most frequent effect of surface disturbance in this region associated with surface water is increased surface water runoff, all of which may affect downstream water bodies by contributing sediment or increasing flooding. The primary cumulative impacts on surface water would result from an increase in the acreage of earthmoving activities and increased impervious areas that have the potential to increase sediment delivery and surface water runoff downstream.

As long as all construction projects comply with state and federal laws and regulations, mitigations would be implemented to minimize erosion from construction activities and sediment delivery to nearby surface water. This would minimize the cumulative impacts of construction projects in the region that may otherwise result in increased sediment delivery.09-033(E)/100511 4-4

The addition of new impervious surfaces would likely result in a cumulative increase in the rate and volume of storm water runoff. The use of temporary or permanent storm water controls such as detention or retention basins and other structures, and stabilization of disturbed areas through landscaping and vegetation, would attenuate increases in surface water runoff and increase groundwater recharge through direct percolation, thus offsetting the loss of pervious surface due to construction in the region and minimizing downstream cumulative effects.

Air Quality. Additional C&D activities involved in the projects already in progress or expected in the foreseeable future would cause temporary increases in air pollutant emissions. The primary pollutant from construction activities would be particulate matter in the form of fugitive dust. This source of emissions is short-term and the impacts are localized to the immediate area. To minimize these emissions, application of wetting agents during dry periods may be used as mitigation. The increase in heavy industry, traffic, and population growth in the county could adversely impact air quality. Emissions from industrial development would be controlled by the required permitting process.

Ecological Resources. The greatest threat to reduced biodiversity of an area or region is conversion of cover types from natural systems to completely different and maintained systems. Growth and development in the region surrounding the ORR is putting increased pressure on the biodiversity of the Ridge and Valley Ecoregion. Development within the ORR has also removed additional land from the Reservation. However, much of the core area of the ORR and most sensitive areas have been avoided or potential impacts have been mitigated. Approximately 491 acres of the Horizon Center are not available for development and contain NA corridors and buffers for native vegetation and wildlife species. Also, much of the development and reindustrialization on the ORR is taking place within previously disturbed and/or developed areas within and surrounding the major plant areas. Actions such as the BORCE and the Three Bend Scenic and Wildlife Management Refuge have the potential to provide long-term protection for some of the most ecologically sensitive areas on the Reservation, and the ORR continues to be a biologically rich resource that provides protection for large land areas and the biodiversity found within those protected areas.

Cultural Resources. Many ongoing and planned activities on the ORR have the potential to impact cultural resources primarily associated with Oak Ridges participation in the Manhattan Project. The NPS, in September 2010, completed a Special Resource Study/EA for Manhattan Project sites in Oak Ridge, Hanford, Los Alamos, and Dayton, Ohio. The EA and FONSI were adopted by DOE in February 2011 (DOE/EA-1868). The study addressed the preservation and interpretation of historic sites of the Manhattan Project for potential inclusion in the National Park system. The DOE-ORO Cultural Resources Management Plan (DOE 2001a) addresses DOE-ORO compliance with cultural resources statutes, ensures that cultural resources are addressed in the early planning process of undertakings, and ensures that needed protection is provided or the appropriate documentation is prepared before an undertaking is initiated.

Socioeconomics. Major initiatives include reindustrialization of the ETTP-Heritage Center, development of the Horizon Center, ORNL revitalization, Roane Regional Business and Technology Park, and the potential development of the Oak Ridge Industrial Center. The cumulative impact of new development is likely to result in increased population, employment, and income. The proposed action is expected to represent a small part of the total acreage proposed for development, and its effect on the cumulative impacts is expected to be correspondingly small.

Actual employment and income impacts from cumulative development would depend on the success of each of these developments and the overall rate at which development proceeds, both of which are 09-033(E)/100511 4-5

uncertain. Some developers have scaled back plans for some of these projects based on market conditions (Huotari 2006). Property tax revenue would depend on the value of the properties, future tax rates, and any tax abatements that may be negotiated.

Utilities. Addition of the identified reasonably foreseeable future projects would result in incremental increases in utility usage. However, there is currently sufficient excess capacity to meet the demand, and continued upgrades and improvements in the local and regional utility systems would serve to offset/accommodate any potential utility use increases. Additionally, the individual projects described above would likely be implemented in phases over the course of several years, thus enabling the utilization of new, more energy-efficient technologies to minimize energy consumption and to provide utility systems sufficient opportunity to meet demand through upgrades and improvements. As a result, the cumulative impact on local and regional infrastructure is expected to be minimal.

Transportation. Cumulative transportation impacts in Roane and Anderson Counties could occur from increased development and growth. These potential impacts could be combined with ongoing environmental restoration and D&D activities on the ORR and with the planned expansion of the state highways by the Tennessee Department of Transportation. The main transportation impact of commercial and industrial development would be an increase in average daily traffic volumes.

Associated with increases in traffic is the potential for an increased number of accidents, additional noise and air pollution, and road deterioration and damage. The increase in average daily traffic volumes could result in inconveniences for other vehicles (personal and commercial) on affected routes and connecting roads. Commercial operations could suffer temporarily reduced business while customers avoid affected areas because of traffic delays. Increased pavement deterioration and damage could increase costs associated with maintaining or resurfacing roads and highways. Although noise associated with increases in traffic is normally not harmful to hearing, increased traffic noise is considered by the public to be a nuisance. Increased accidents put an additional strain on local emergency response personnel. Increased vehicular traffic also has the greatest potential to increase air pollution in the local area because emissions from motor vehicles are poorly regulated.

Solid Waste. Major projects and activities within the ROI are, or will, generate solid waste requiring disposal. Although additional construction, demolition, and/or renovation will occur under many of the projects in Sect. 4.1, specific quantities of C&D wastes cannot be estimated. Because the specific timing of each project is unknown, it is unclear the extent of project overlap that would occur between the potential cumulative actions and the proposed action in this EA. If the projects occur within the same timeframe, there could be a potential adverse cumulative impact on landfills in the ROI. However, it is anticipated that the projects would be phased over a 10-year period and landfill capacity is assumed to be adequate to handle the anticipated amounts of solid waste requiring disposal.

Human Health. Operations included under the proposed action could potentially increase worker or public exposure to physical, chemical, or radiological hazards. New or expanded facilities from development under the proposed action would be of modern design with engineered controls for improved environmental safety and health (ES&H) operation, thus resulting in improvements to the ES&H environment. It is likely that any new facilities developed, as described, under the reasonably foreseeable actions would follow the same principle of improvements in operational ES&H environments. Consequently, there would be no cumulative human health effects to workers or off-site populations.09-033(E)/100511 4-6

5. REFERENCES BEA (U. S. Bureau of Economic Analysis) 2011a. Regional Economic Information System, Table CA30.

Available at http://www.bea.gov/bea/regional/reis/. Accessed September 19, 2011.

BEA 2011b. Regional Economic Accounts. State Annual Personal Income, Tables SA07: Wage and Salary Disbursements by Industry, and Table SA27: Wage and Salary Employment by Industry.

Available at http://www.bea.gov/regional/spi/. Accessed September 20, 2011.

Biloski, W. J. 2009. Private communication from William J. Biloski, Bechtel Jacobs Company LLC, to Sharon Bell, SAIC, June 8, 2009.

Bowman, N. 1999. Personal communication from N. Bowman, Bechtel Jacobs Company LLC, to Mike Deacon, SAIC, June 9, 1999.

Census (Bureau of the Census) 2003. U. S. Census Bureau Guidance on the Presentation and Comparison of Race and Hispanic Origin Data. Available at http://www.census.gov/popest/counties/asrh/. Accessed May 12, 2009.

Census 2010. Available at http://factfinder2.census.gov/. Accessed September 19, 2011.

Census 2011a. Annual Estimates of the Resident Population by Sex, Race Alone, and Hispanic or Latino Origin for Counties: April 1, 2000, to July 1, 2009. Available at http://www.census.gov/popest/counties/asrh/. Accessed April 18, 2011.

Census 2011b. 20052009 American Community Survey 5-year Estimates: Detailed tables. Available at http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=ACS&_submenuId=datasets

_1&_lang=en&_ts=. Accessed May 13, 2009.

City of Oak Ridge 2010. Fiscal 2011 Budget: City of Oak Ridge, Tennessee, June.

City of Oak Ridge 2011. Proposed Budget, Fiscal 2012, May.

Currier, B. 1999. Personal communication from B. Currier, City of Oak Ridge, to Mike Deacon, SAIC, June 9, 1999.

DOE (U. S. Department of Energy) 1996. Groundwater Remedial Site Evaluation Report for the Oak Ridge K-25 Site, DOE/OR/01-1468V1&D1, Oak Ridge, TN.

DOE 1997. Final Environmental Assessment for Lease of Land and Facilities within the East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/EA-1175, U. S. Department of Energy, Oak Ridge, TN, November.

DOE 2001a. Cultural Resource Management Plan, Department of Energy-Oak Ridge Operations Office, Anderson and Roane Counties, Tennessee, DOE/ORO-2085, U. S. Department of Energy, Oak Ridge, TN, July.

DOE 2001b. Final Site-Wide Environmental Impact Statement for the Y-12 National Security Complex, Volume I, U. S. Department of Energy, Oak Ridge, TN, September.09-033(E)/100511 5-1

DOE 2003. Environmental Assessment Addendum for the Proposed Title Transfer of East Tennessee Technology Park Land and Facilities, DOE/EA-1175-A, U. S. Department of Energy, Oak Ridge, TN, July.

DOE 2007. Oak Ridge Reservation Ten-Year Site Plan: Integrating Multiple Land Use Needs, DOE/ORO-TYSP2007, U. S. Department of Energy, Oak Ridge, TN, July.

DOE 2010. Oak Ridge Reservation Annual Site Environmental Report for 2009, DOE/ORO/2327, U. S. Department of Energy, Oak Ridge, TN, September.

DOE 2011a. FY 2010 Cleanup Progress Annual Report to the Oak Ridge Community, DOE/ORO/2365, U. S. Department of Energy, Oak Ridge, TN.

DOE 2011b. 2011 Remediation Effectiveness Report for the U.S. Department of Energy Oak Ridge Reservation, Oak Ridge, Tennessee. DOE/OR/01-2505&D1, March.

Drake, S. J., Weltzin, J. F., and Parr, P. D. 2002. Assessment of Non-native Invasive Plants in the DOE Oak Ridge National Environmental Research Park, ORNL/M-2001/113, Oak Ridge, TN, October.

Environmental Laboratory 1987. Corps of Engineers Wetlands Delineation Manual, Technical Report Y-87-1, Department of the Army.

EPA (U. S. Environmental Protection Agency) 2002. 2002 National Emissions Inventory Microsoft Access Database, Accessed May 2006.

EPA 2005. Transportation and Air Quality, Retrieved from http://www.epa.gov/otaq/ on February 10, 2005.

Finn, C. 2009. Private communication from Cindy Finn, DOE ORO Realty Officer, to William J. Biloski, Bechtel Jacobs Company LLC, June 8, 2009.

FLUOR 2001. Oak Ridge, TN Final Reports: Economic Development Strategic Assessment, FLUOR Global Location Strategies, March.

Focus Group 2002. Final Report of the Oak Ridge Land Use Planning Focus Group, September.

Gosling, F. G. 1990. The Manhattan Project: Science in the Second War, prepared for the U. S. Department of Energy, Washington, D.C.

Harvey, M. J., and Britzke, E. R. 2004. Anabat Survey for Bats at Pond K-1007-P1 on the Oak Ridge Reservation, unpublished report to the Ecological Sciences Division, Oak Ridge National Laboratory, 21pp.

Hewlett, R. G., and Anderson, O. E. 1962. The New World, 19391946: Volume I, A History of the United States Atomic Energy Commission, Pennsylvania State University Press, University Park.

LMES (Lockheed Martin Energy Systems, Inc.) 1998. Baseline Environmental Analysis Report for the East Tennessee Technology Park Roads and Grounds - Phase I, K/EM-579, prepared for the U. S. Department of Energy, Oak Ridge, TN, February.09-033(E)/100511 5-2

Lemiszki, P. J. 1994. Geological Mapping of the Oak Ridge K-25 Site, Oak Ridge, Tennessee, K/ER-111, K-25 Environmental Restoration Program, Oak Ridge, TN, January.

MMES (Martin Marietta Energy Systems, Inc.) 1994. The Oak Ridge K-25 Site, Technical Site Information, K/EN/SFP-11, Oak Ridge, TN, September.

Morris, M. W. 1998. K-25 Site Cultural Resources Survey Archaeological Reconnaissance, Jacobs Environmental Management Team, Oak Ridge, TN, March.

MRW Environmental LLC 2009. Draft Habitat Assessment for Parcel ED-3, prepared for Bechtel Jacobs Company LLC, July.

Myrick, T. E., Berren, B. A., and Haywood, F. F. 1981. State Background Radiation Levels: Results of Measurements Taken During 19751979, ORNL/TM-7343, Oak Ridge National Laboratory, Oak Ridge, TN.

NCRP (National Council on Radiation Protection) 1987. Ionizing Radiation Exposure of the Population of the United States, NCRP Report No. 93, National Council on Radiation Protection and Measurements, Washington, D.C.

New South Associates 2011. Archaeological Survey and Testing of the Happy Valley Worker Camp Roane County, Tennessee, prepared for Bechtel Jacobs Company LLC, April.

ORNL (Oak Ridge National Laboratory) 2002. Land Use Technical Report, ORNL/TM-2002/132, Oak Ridge, TN, September.

ORNL 2006. Wildlife Management Activities on the Oak Ridge Reservation (ORR), presentation by Neil Giffen, ORR Wildlife Management Coordinator, to U. S. Department of Energy, September.

Available at http://www.esd.ornl.gov/facilities/nerp/ORR_wildlife_management_talk_2006.pdf.

Parr, P. D., and Hughes, J. F. 2006. Oak Ridge Reservation Physical Characteristics and Natural Resources, ORNL/TM-2006/110, Oak Ridge National Laboratory, Oak Ridge, TN.

Rosensteel, B. A., and Awl, D. J. 1995. Wetland Survey of Selected Areas in the K-25 Site Area of Responsibility, ORNL/TM-13033, Oak Ridge National Laboratory, Oak Ridge, TN.

Solomon, D. K., Moore, G. K., Toran, L. E., Drier, R. B., and McMaster, W. M. 1992. Status Report, A Hydrologic Framework for the Oak Ridge Reservation, ORNL/TM-12026, Environmental Sciences Division Publication No. 3815, Oak Ridge National Laboratory, Oak Ridge, TN, May.

Stearns, R. G., and Miller, R. A. 1977. Earthquake Hazards in Tennessee, Tennessee Division of Geology, Environmental Geology Series No. 4.

TDEC (Tennessee Department of Environment and Conservation) 2008. Tennessee Air Quality Forecasting Program, http://www.state.tn.us/environment/apc/ozone/, accessed on April 28, 2008.

TVA (Tennessee Valley Authority) 1988. Watts Bar Reservoir Land Management, August (reprinted September 1992).

Young, L. 2002. Private communication from Lawrence Young, Community Reuse Organization of East Tennessee, to Sharon Bell, SAIC. November 18.09-033(E)/100511 5-3

APPENDIX A - CORRESPONDENCE 09-033(E)/100511

A-3 A-4 A-5

A-7

A-9 A-10 A-11

Department of Energy Oak Ridge Office P.O. Box 2001 Oak Ridge, Tennessee 37831 June 10, 2011 Dr. Joseph Y. Garrison Tennessee Historical Commission Department of Environment and Conservation 2941 Lebanon Road Nashville, Tennessee 37243-0442

Dear Dr. Garrison:

ARCHAEOLOGICAL SURVEYAND TESTING OF THE HAPPY VALLEY WORKER CAMP, ROANE COUNTY, TENNESSEE On September 29, 2009, copies of the Phase I Archaeological Survey of Parcel ED-3 and Historic Assessment of the Happy Valley Worker Camp, Roane County, Tennessee, were transmitted to your office for review. Your office concurred on October 6, 2009, that the project area contains archaeological resources potentially eligible for listing in the National Register of Historic Places. In addition, you requested that copies of the survey report be transmitted to your office for review after the Phase II testing was completed.

The Phase II archaeological testing has been completed. As requested, and in accordance with Stipulation 4 of the June 25, 2001, Memorandum of Agreement (Memorandum of Agreement Between the U.S. Department of Energy Oak Ridge Operations Office and the Tennessee State Historic Preservation Office Submitted to the Advisory Council on Historic Preservation Pursuant to 36 CFR800.6(b) (1) Regarding Lease of Land Parcel ED-3 of the Oak Ridge Reservation to the Community Reuse Organization of East Tennessee Oak Ridge Reservation, Anderson County, Tennessee), enclosed are two copies of the Archaeological Survey and Testing of the Happy Valley Worker Camp for your review.

If you have any questions or need additional information, please contact me at (865) 576-0835.

Sincerely, tatra C. Vasquez Cultural Resources Management Coordinator Enclosures See page 2 for ccs A-13 PRINTED ON RECYCLED PAPER

Dr. Joseph Y. Garrison June 10, 2011 ARCHAEOLOGICAL SURVEYAND TESTING OF THE HAPPY VALLEY WORKER CAMP, ROANE COUNTY, TENNESSEE cc w/enclosure:

Jennifer M. Barnett, TDEC Division of Archaeology Thomas McCulloch, ACHP Skip Gosling, MA-75, HQJF0RS Terry Fehner, MA-75, HQ/FORS cc w/o enclosure:

Joe McBrearty, SC-3, HQJF0RS Brian Henry, NS-53, CR0 John Eschenberg, M-2, 0R0 Susan Cange, EM-90, ORC John Shewairy, M-4, CRC David Adler, EM-91, CRC Don Thress, CC-1O,CRC Larry Kelly, SE-30, CRC Rob James, CC-b, CRC Teresa Perry, SE-30, CRC Cohn Colverson, CC-b, CRC David Allen, SE-32, CRC J.T. Howell, NS-50, CRC Gary Hartman, SE-32, CR0 Larry Perkins, NS-50, CRC Katatra Vasquez, SE-32, CRC Lydia Birk, BJC A-14

TENNESSEE HISTORICAL COMMISSION DEPARTMENT OF ENVIRONMENT AND CONSERVATION 2941 LEBANON ROAD NASHVILLE. TN 37243-0442 (615) 532-1550 June 20, 2011 Ms. Katatra Vasquez Department of Energy Oak Ridge Office Post Office Box 2001 Oak Ridge, Tennessee 37831 RE: DOE, ARCHAEOLOGICAL ASSESSMENT, HAPPY VALLEY WORKER CAMP, OAK RIDGE, ROANE COUNTY

Dear Ms. Vasquez:

At your request, our office has reviewed the above-referenced archaeological survey final report in accordance with regulation~ codified at 36 CFR 800 (Federal Register, December 12, 2000, 77698-77739). We find that the report meets the Tennessee SHPO Standards and Guidelines For Archaeological Resource Management Studies.

If project plans are changed or archaeological remains are discovered during construction, please contact this office to determine what further action, if any, will be necessary to comply with Section 106 of the National Historic Preservation Act.

Your continued cooperation is appreciated.

Sincerely,

£.rP~~J' E. Patrick Mcintyre, Jr.

Executive Director and State Historic Preservation Officer AM~ESH EPM~mb

()fFtCIAL FILE COpy DOCS NO. H6ei~,)-rYE 6(V1~

DATE RECEIVED _ lP"c9tl-\\

FILE CODE ________ . ---

A-15

APPENDIX B - COMMENTS AND RESPONSES TO THE DRAFT ENVIRONMENTAL ASSESSMENT 09-033(E)/100511

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Norman A. Mulvenon Reviewer Agency/Organization: Chair, LOC Citizens Advisory Panel B-3 Page Line Comment # Number Number Comment Comment Response 1 The subject EA overly generalizes the impacts of possible The property being evaluated in this EA is part of the future land uses for a large land area, which currently former K-25 gaseous diffusion plant footprint, and has varies in condition from heavily industrialized to green been previously disturbed. The purpose of the EA is to field. The proposed land uses would have different evaluate potential impacts of leasing or transferring this impacts, depending on the different initial conditions of property, and because DOE does not know what the the various parcels. In addition, the analyses are overly specific uses will be, it has been decided that a generalized considering the variety of different land uses. bounding analysis will be performed. A bounding For example, impact from precipitation runoff from an analysis identifies and evaluates possible land uses that airport would be significantly greater than that from a would have the highest potential impacts. Depending series of office complexes interspersed with landscaping. on the outcome of this EA, DOE may lease or transfer Moreover, it would have relatively more impact if sited property. Once the specific property use is known, on the largely forested ED-3 parcel than if sited within DOE will compare the proposed use with the results of the heavily paved area of Heritage Center. Similarly, this EA. If the expected potential impacts of the known recreational uses might range from a car racetrack (a activity will not result in greater impacts than what has proposal by a private citizen) to a greenway, yet the air been evaluated in the EA, then no further action will be and noise analysis does not acknowledge what activities required. If the potential impacts are expected to be will have the higher impact. greater than what has been evaluated in this EA, then further NEPA analysis may need to be performed. It

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response The ultimate transfer decisions will need to be should be noted that the ultimate allowable uses for the customized to each parcel depending on its condition and property will be dependent on the results of this EA, as the proposed use. The EA should outline the process for well as on the appropriate ETTP Records of Decision, future public input regarding transfer decisions that may and on the CERCLA process for property transfers.

be controversial for a variety of reasons (historic properties, land use disagreements, remnant With regard to future input regarding transfer decisions, contamination, etc.). the opportunity for input on whether to transfer specific parcels of land is provided under CERCLA Considering that the land is proposed for transfer, the EA Section 120(h). Specifically, a 30-day public review should detail how DOE will enforce any explicit or period is held if DOE is transferring the land under a implicit (by omission from the proposed action)

Covenant Deferral Request. With regard to public input restrictions on land uses by future land owners. This issue on specific uses of property, those opportunities are has arisen with respect to Parcel ED-1 (Horizon Center).

provided by the city, state, or federal agency that is regulating the activities on the transferred property. It should be noted that once property has been transferred, there is no further action being taken by DOE. When transferring property DOE may include deed restrictions. Deed restrictions may be imposed for several reasons including, but not limited to, the B-4 presence of residual contamination, or potential effect to nearby DOE activities.

1 Page 1-4 ¶1 The Introduction references the 2001 land use planning The link: http://landuseplanning.ornl.gov was checked effort. However, the link does not take the reader to the and it still is active. The site also contains a complete final report. An online search of DOE documents finds the copy of the Final Land Use Technical Report, Final Land Use Technical Report (ORNL 2002) available; including the figures. The report should also be however with blanks where figures would be found. Thus available through the DOE Information Center.

it is impossible to determine how the EA follows the land use recommendations and how DOE has chosen to resolve The purpose of this EA is not to resolve issues or the areas of disagreement. The EA should give more detail areas identified in the land use focus group report that regarding this issue, and DOE should ensure a complete were not resolved by the group. The purpose is to copy of the Final Land Use Technical Report is available evaluate the transfer of additional DOE property. The online. potential land uses identified in the EA were to aid the analyses. The EA is not making a final decision on the Alternatives 1 and 2 each have a good deal of overlap with alternatives.

the proposed action. The EA should explicitly state which land uses are excluded in each of the three actions that are The differences between Alternatives 1 and 2 have evaluated. For example, the proposed action appears to been made clearer.

exclude bulk storage of oil, gasoline and natural gas.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response The decision to exclude power plants from the proposed The EA does not exclude the possibility that action should be reevaluated. The site is likely suitable renewable and other energy projects could be a future for renewable energy generation and may be suitable for use for any transferred property. It should be noted a small nuclear power plant. There is extensive electrical that if a renewable or energy project were proposed, it infrastructure already available. The CAP suggests that would likely be subject to additional NEPA power plants with low/no emissions, and that dont rely compliance by the permit- or license-granting agency on combustible fuel for primary power generation, be (e.g., the responsible federal agency for a nuclear included in the proposed action. power plant would be the Nuclear Regulatory Commission rather than DOE).

2 Page 2-3 ¶2 The EA states that certain uses would require additional The purpose of the EA is to evaluate the transfer of permits or licenses by a permitting agency. This does additional DOE property. The potential land uses not absolve DOE of doing additional analyses in the EA identified in the EA were to aid the analyses. The EA for an airport or other specialized uses that are not is not making a final decision on the alternatives.

typical of mixed industrial, commercial, and recreational use. It is likely that the airport would not The decision on an airport is not ripe for analysis at have been proposed for consideration under the this time. The Metropolitan Knoxville Airport proposed action if there had not been interest in one Authority is performing a feasibility study to evaluate expressed by the community reuse organization. locations on the ORR for an airport. Once that study is complete, it is possible that an area within the study B-5 area could be found suitable for the airport. If that happens, any additional NEPA compliance would be addressed by the project proponent and the responsible federal agency (e.g., Federal Aviation Administration).

3 Figure 3.3 should be made consistent with Figure 1.1. In The Horizon Center boundary has been added to Figure 3.3, the property line between DOE-OWNED Fig. 3.3 for consistency.

(labeled BLACK OAK RIDGE CONSERVATION EASEMENT on Figure 1.1) and Horizon Center is missing.

4 Section There are likely more potential impacts on the A statement has been added in Sect. 3.4 noting that 3.4.2.1 groundwater than stated in Section 3.4.2.1. The the presence of karst has the potential to provide rapid ubiquitous presence of karst provides an immediate transport pathways to groundwater resources beneath conduit to subsurface drainages. Typically petroleum- the ETTP.

contaminated runoff from paved areas (roads, parking lots) and accidental discharges of pollutants on to the ground can quickly find their way into the groundwater.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 5 Section 3.6 The Cultural Resources analysis (Section 3.6 and 1. Comment noted. DOE is using the NEPA process and Appendix A) raise two concerns: to comply with Section 106 of the NHPA per Appendix A 1. The proposed analysis of Happy Valley, the site of Advisory Council on Historic Preservation the worker community that built K-25, is regulations at Section 800.3. Therefore, by copy of unacceptable. The LOC is a consulting party for all the EA, the consulting parties have been included.

undertakings that affect historic properties on the Oak Ridge Reservation; however, we were not 2. Consultation is ongoing between the signatory copied on the letter to Joseph Garrison in parties to execute an MOA that addresses the Appendix A regarding the proposed undertaking, ETTP site. DOE will abide by the resulting and neither were other interested consulting parties agreement.

such as the Oak Ridge Heritage and Preservation Association. The CAP objects to the use of NEPA to comply with Section 106 of the National Historic Preservation Act (NHPA) for this undertaking. We request that DOE instead initiate the consulting process for this site, which is eligible for the National Register of Historic Places.

2. The K-25 building and footprint is currently undergoing the Section 106 NHPA consultation. The B-6 result has not been finalized. At this time it is premature to consider transferring this portion of ETTP. K-25 and other historic properties that have not yet undergone a complete consultation process should be removed from consideration of transfer.

6 Section 3.9 The Waste Management section (Section 3.9) should Additional text has been added in Sect. 3.9 mention that air and water discharges containing acknowledging that air and water discharges hazardous and/or radioactive components are typically containing hazardous and/or radioactive components associated with waste management activities. Although can be associated with waste management activities.

permits would be needed, these represent a potentially However, it should be noted that some industrial greater environmental/health impact (especially if an operations may have the same or greater impacts (e.g.,

uncontrolled release occurs) than permitted discharges chlorine release from a municipal water plant).

associated with other industrial operations. Therefore, the text does not conclude that these constituents pose a greater environmental/health impact.

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Darryl Bonner Reviewer Agency/Organization:

B-7 Page Line Comment # Number Number Comment Comment Response 1 The proposed actions could impact groundwater flows The fact that subsurface disturbances such as just as decontamination and decommissioning actions at construction of basements and/or sumps may impact ETTP have affected groundwater flow (e.g., Hexavalent local groundwater flow at ETTP has been added to the Chromium in groundwater into Mitchell Branch). document in Sect. 3.4.

2 The EA needs to evaluate whether revising the land use The EA acknowledges that transfers cannot be in the Alternatives 1 and 2 for Zone 1 and 2 requires executed if there is a conflict with the ROD. Potential reviewing the risk evaluated in the ROD based on the future property transfers and potential uses must be assumed land uses. consistent with the EA decision, appropriate CERCLA RODs, and the CERCLA transfer process.

Close coordination between DOE organizations and the regulators is required to ensure that land uses meet all requirements. An example of this coordination is going on right now where DOE is reviewing permissible land uses in the Zone 1 ROD in order to address potential inconsistencies between the ROD and the designation of some land for conservation purposes.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 3 Recommend that the non-development area adjacent to All areas not identified for transfer in the EA will the Parcel ED-3 and south of the Oak Ridge Turnpike remain non-development areas.

remain a non-developed area.

4 The bounding analysis should consider failure of The purpose of the EA is to evaluate the transfer of implementation the Land Use controls established in additional DOE property. The potential land uses regulatory decision documents. identified were to aid the analyses and the EA is not making a final decision on the alternatives. The CERCLA process will be used to address land use controls (LUCs) at the time of transfer. CERCLA provides for further remedial actions if LUCs are not protective.

1 Page 2-2, Line 19 Identify the organization that has responsibility to DOE has responsibility to ensure that this function is Section 2.1.1 review proposals to ensure proposed activities fall performed.

within the bounding analysis of the EA after parcels have been conveyed.

2 Page 2-4, Replace CERCLA 120(h) compliance requirements Text about the current LUCs for Zone 1 and Zone 2 Section 2.2 with land use controls identified in Zone 1 and Zone 2 has been added in Sect. 2.2 along with the CERCLA remedial action documents. 120(h) requirements. It should be noted that 120(h) is specific to transfers of property. As stated above, B-8 other CERCLA decision documents have been added.

3 Page 2-3, Line 19 Add and controls identified in remedial action Text has been added in Sect. 2.1.2 that acknowledges Section 2.1.2 documents. that DOE must comply with CERCLA decision documents.

4 Page 3-1, Line 20 Add a sentence that Remedial action projects are based Text has been added in Sect. 3.1.1.

Section 3.1.1 on land use goals and the associated exposure risks as analyzed in Records of Decision (ROD) documents. In many instances remediation efforts result in long-term controls on the use of the land.

5 Page 3-1, Line 23 Suggest replacing reference to ASER with a reference to In addition to citing the 2009 ASER, the RER Section 3.1.1 the Remedial Effectiveness Report, Volume 1 and reference has also been added in Sect. 3.1.1.

Volume 2.

6 Page 3-3, Line 12 Add slabs and filled basements after facilities. Development can occur on slabs and filled basements.

Section Therefore, the text has not been modified.

3.1.2.1

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 7 Page 3-9, Add sentences indicating The Excavation/Penetration The Excavation/Penetration Permit Program is a DOE Section Permit program is a land use control for Zone 1 and control for operations and ongoing cleanup activities 3.3.2.1 Zone 2. The responsible organization is responsible for and is not an LUC. Deed restrictions have been obtaining an excavation/penetration permit for ground- included that require the property owners to obtain disturbing activities. permits from DOE, as long as DOEs program is in place.

8 Page 3-9, This section needs to include a discussion of the Many permitted outfalls will be eliminated as cleanup Section existing storm drain system at ETTP and impacts (e.g., progresses. No final decision has been made on who 3.3.2.1 CROET would be the site-wide NPDES permit holder). would be the final site-wide permit holder.

9 Page 3-9, Identify the land use assumptions of the remedial action This is not the appropriate place to address land use Section document and the associated controls and reference the assumptions as the final CERCLA decision 3.3.2.1 remedial action documents for Zone 1 and Zone 2. documents are not complete.

10 Page 3-9, This section needs to evaluate the potential for the The purpose of the EA is to evaluate the transfer of Section proposed action to result in uncontrolled release of (i.e., additional DOE property. The potential land uses 3.3.2.2 failure of the remediation controls) the hazardous identified were to aid the analyses and the EA is not materials that will remain in the soil after remediation is making a final decision on the alternatives. The complete. CERCLA process will be used to address LUCs at the time of transfer. CERCLA provides for further remedial actions if LUCs are not protective.

B-9 11 Page 3-10, This section needs a description of the groundwater A summary of groundwater conditions at ETTP has Section plumes within Zone 1 and Zone 2 and an indication that been added to Sect. 3.4.1.1. It has been noted that 3.4.1.1 a final decision on the groundwater has not been made. final decisions on Zone 1 and Zone 2 groundwater have not been made.

12 Page 3-10, Suggest also referencing the Treatability Study for the The ongoing Treatability Study has been noted in Section Hexavalent Chromium. Sect. 3.4.1.1.

3.4.1.1 13 Page 3-14, This section needs to indicate that implementation of the It has been noted in Sect. 3.4.2.1 that the actions Section controls identified in the soil remedial action documents required under future decision documents will address 3.4.2.1 is an underlying assumption for protection of the groundwater and that a final decision on groundwater groundwater. A final decision has not been made (i.e., has not been made.

and associated controls) has not been made for the Zone 1 and Zone 2 groundwater.

14 Page 3-17, This section should reference the results of the Aquatic The RER has been referenced in Sect. 3.5.1.3.

Section Resource Sampling program as described in the RER 3.5.1.3 Vol.2 for Zone 1 and Zone 2.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 15 Page 3-22, The existing MOA for preservation of the K-25 Building Reference to the Memorandum of Agreement (MOA)

Section 3.6.1 needs to be included in this section as it is the agreement of signed in March 2005 has not been added to the text record until superseded by a revised or new MOA. because consultation is ongoing between the signatory parties to execute a new MOA.

16 Page 3-31, The main roads within ETTP (e.g., Perimeter Road) Text has been added in Sect. 3.8.1.2 regarding the Section have been transitioned to the City of Oak Ridge. transfer of some roads to the city of Oak Ridge to 3.8.1.2 provide access to property that has been transferred.

17 Page 3-32, Waste management is currently contracted to Bechtel Text has been modified in Sect. 3.9.1 to acknowledge Section 3.9.1 Jacobs Company LLC until no later than December 31, that DOE and their contractor are responsible for 2011. waste management.

18 Page 3-32, The TSCA Incinerator shutdown operations in calendar This information has been incorporated in Sect. 3.9.1.

Section 3.9.1 year 2009 and is in process of RCRA closure. The TSCAI will be managed under surveillance &

maintenance until decontamination and decommissioning.

19 Page 3-32, Suggest replacing reference to ASER with the RER. In addition to citing the 2009 ASER, the RER Section 3.9.1 reference has also been added to Sect. 3.9.1.

20 Suggest adding correspondence relating to historic The suggested documentation has not been added B-10 preservation of the K-25 North Tower. because consultation is ongoing between the signatory parties to execute a new MOA.

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Sandra Goss Reviewer Agency/Organization: Tennessee Citizens for Wilderness Planning (TCWP)

B-11 Page Line Comment # Number Number Comment Comment Response 1 Appropriate portions of the 1,800 acres should be DOE anticipates that the area within the existing designated for heavy industry (Alternative 1), preferably Zone 2 would most likely be utilized for heavy including manufacturing of products needed for industry; however, the final decision regarding renewable-energy generation. Valuable industrial sites specific use of the property will not be made by DOE, would be lost if the area were to be used for haphazard since the property will have been transferred.

mixed-use development.

2 The 220-acre ED-3 development area is a prudent Comment noted.

choice for business locations along Route 58.

3 The Non-Development classification of land running Comment noted.

north from Bear Creek Road to ED-3 and Route 58, and the land from the Haul Road across Blair Road to the Black Oak Ridge Conservation Easement (BORCE) is a good designation in view of terrain, power lines, and other issues. This land will furnish a good buffer zone for the industrial park as well as a conservation area for wildlife.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 4 The 1,500-acre addition to BORCE will provide wildlife There is no intent at this time to add property to the habitat, as well as a top-of-the-line recreation area for BORCE. Property that is identified as non-hiking, bicycle riding, and hunting. development areas in the EA is not being considered for lease or transfer.

5 We continue to recommend strongly that a full-scale Comment noted.

Reservation-wide EIS be initiated to determine the present and future value of the forestland for climate research, wildlife habitat, and recreation.

6 We applaud your decision not to consider any additional Comment noted.

large consolidated areas for transfer at the present time; however, we continue to insist that the remaining, relatively undisturbed, unfragmented 20,000 acres of the ORR should not be utilized for development because of their value to future generations for biological and climate research.

B-12

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Gary M. Cinder, Interim City Manager Reviewer Agency/Organization: City of Oak Ridge B-13 Comment # Page Line Number Number Comment Comment Response 1 The City of Oak Ridge supports ongoing efforts to Comment noted.

productively reuse DOE property located at the ETTP, and to accelerate risk reduction at the site to enhance public safety and to facilitate mixed used of the property. The City encourages DOE and CROET to continue early consultation with regard to specific uses of the property to ensure compliance with city codes and regulations.

2 Section 1.2 of the draft EA briefly describes the 2001 Comment noted. However, suggested modifications to land use planning effort undertaken by DOE. While the the EA will not be made because the economic area now called the Black Oak Ridge Conservation impacts of past actions are not within the scope of this Easement (BORCE) was established in an agreement EA.

with the State of Tennessee in late 2002, an environmental assessment of this action was not undertaken; instead, DOE issued a categorical exclusion. Therefore, the final EA should analyze the economic impacts on Roane County and Oak Ridge

Comment # Page Line 11-042(E)/100511 Number Number Comment Comment Response associated with the absorption of more than half of the previously designated Self-Sufficiency Parcel D into the BORCE.

1 Sections Sections 3.4.1.1 pertaining to groundwater and 3.4.1.2 Text has been revised to reflect that under CERCLA, 3.4.1.1 and pertaining to surface water should acknowledge that DOE would remain responsible for site-related 3.4.1.2 DOE will retain responsibility for monitoring and contamination. However, it is possible that property remediation of water resources within the area covered proposed for transfer could obtain a Clean Parcel by the EA. Determination that would eliminate DOE responsibility for monitoring and remediating water resources within that particular area.

2 Section Section 3.7.1.2 can be updated with current information Text has been updated with available information as 3.7.1.2 regarding City revenues and expenditures; likewise, the applicable.

2001 FLUOR study cited on page 3-28 can be updated using current industrial land appraisals from the Roane County Property Assessor.

B-14

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Ron Murphree, Chair, PE, CPE Reviewer Agency/Organization: Oak Ridge Site Specific Advisory Board B-15 Page Line Comment # Number Number Comment Comment Response 1 In general the board agrees with the proposed transfer of Comment noted.

land and facilities at ETTP, with the exception of Parcel ED-3. The board believes it should remain undeveloped.

2 The EA needs to evaluate whether revising the land use The EA acknowledges that transfers cannot be Alternatives 1 and 2 for Zone 1 and 2 at ETTP requires executed if there is a conflict with the ROD. Potential reviewing the risk evaluated in the record of decision future property transfers and potential uses must be based on the assumed land uses. consistent with the EA decision, appropriate CERCLA RODs, and the CERCLA transfer process.

Close coordination between DOE organizations and the regulators is required to ensure that land uses meet all requirements. An example of this coordination is going on right now where DOE is reviewing permissible land uses in the Zone 1 ROD in order to address potential inconsistencies between the ROD and the designation of some land for conservation purposes.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 3 The bounding analysis should consider failure of The purpose of the EA is to evaluate the transfer of implementation of the land use controls established in additional DOE property. The potential land uses regulatory decision documents. identified were to aid the analyses and the EA is not making a final decision on the alternatives. The CERCLA process will be used to address land use controls at the time of transfer. CERCLA provides for further remedial actions if land use controls are not protective.

4 Independent verification of the identified parcels should DOE submits post-remedial action reports to be completed prior to transfer to assure that, cleanup regulators for review and approval. Information from requirements have been met. these reports is used to prepare the CERCLA documents that support transfer of property.

5 Complete and file Notices of Contamination with Roane Text has been added to Sect. 2.1.2 stating who, when County. and where Notices of Contamination are filed, if applicable.

6 Include land use restrictions in the Covenant Deferral Appropriate land use restrictions are identified in the Requests, as appropriate. Quit Claim Deed and included in the Covenant Deferral Request.

B-16 1 Page 2-2, Line19 Identify the organization that has responsibility to DOE has responsibility to ensure that this function is Section 2.1.1 review to ensure proposed activities fall within the performed.

bounding analysis of the EA after parcels have been conveyed.

2 Page 2-4, Replace CERCLA 120(h) compliance requirements Text about the current LUCs for Zone 1 and Zone 2 Section 2.2 with land use controls identified in Zone 1 and Zone 2 has been added in Sect. 2.2 along with the CERCLA remedial action documents. 120(h) requirements. It should be noted that 120(h) is specific to transfers of property. As stated above, other CERCLA decision documents have been added.

3 Page 2-3, Line 19 Add and controls identified in remedial action Text has been added in Sect. 2.1.2 that acknowledges Section 2.1.2 documents. that DOE must comply with CERCLA decision documents.

4 Page 3-1, Line 20 Add a sentence that Remedial action projects are based Text has been added in Sect. 3.1.1.

Section 3.1.1 on land use goals and the associated exposure risks as analyzed in Records of Decision (ROD) documents. In many instances remediation efforts result in long-term controls on the use of the land.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 5 Page 3-1, Line 23 Suggest replacing reference to Annual site In addition to citing the 2009 ASER, the RER Section 3.1.1 Environmental Report (ASER) with a reference to the reference has also been added in Sect. 3.1.1.

Remedial Effectiveness Report (RER), Volume 1 and Volume 2.

6 Page 3-3, Line 12 Add slabs and filled basements after facilities. Development can occur on slabs and filled basements.

Section Therefore, the text has not been modified.

3.1.2.1 7 Page 3-9, Add sentences indicating The Excavation/Penetration The Excavation/Penetration Permit Program is a DOE Section permit program is a land use control for Zone 1 and control for operations and ongoing cleanup activities 3.3.2.1 Zone 2. The responsible organization is responsible for and is not an LUC. Deed restrictions have been obtaining an excavation/penetration permit for ground included that require the property owners to obtain disturbing activities. permits from DOE, as long as DOEs program is in place.

8 Page 3-9, This section needs to include a discussion of the Many permitted outfalls will be eliminated as cleanup Section existing storm drain system at ETTP and impacts (e.g., progresses. No final decision has been made on who 3.3.2.1 CROET would be the site-wide National Pollutant would be the final site-wide permit holder.

Discharge Elimination System (NPDES) permit holder).

9 Page 3-9, Identify the land use assumptions of the remedial action This is not the appropriate place to address land use B-17 Section document and the associated controls and reference the assumptions as the final CERCLA decision 3.3.2.1 remedial action documents for Zone 1 and Zone 2. documents are not complete.

10 Page 3-9, This section needs to evaluate the potential for the The purpose of the EA is to evaluate the transfer of Section proposed action to result in uncontrolled release of (i.e., additional DOE property. The potential land uses 3.3.2.2 failure of the remediation controls) the hazardous identified were to aid the analyses and the EA is not materials that will remain in the soil after remediation is making a final decision on the alternatives. The complete. CERCLA process will be used to address LUCs at the time of transfer. CERCLA provides for further remedial actions if LUCs are not protective.

11 Page 3-10, This section needs a description of the groundwater A summary of groundwater conditions at ETTP will Section plumes within Zone 1 and Zone 2 and an indication that be added to Sect. 3.4.1.1. It will be noted that final 3.4.1.1 a final decision on the groundwater has not been made. decisions on Zone 1 and Zone 2 groundwater have not been made.

12 Page 3-10, Suggest also referencing the Treatability Study for the The ongoing Treatability Study has been noted in Section Hexavalent Chromium. Sect. 3.4.1.1.

3.4.1.1 13 Section 3.4 The proposed actions could impact groundwater flows The fact that subsurface disturbances such as just as decontamination and decommissioning actions at construction of basements and/or sumps may impact ETTP have affected groundwater flow (e.g., Hexavalent local groundwater flow at ETTP has been added to Chromium in groundwater into Mitchell Branch). Sect. 3.4.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 14 Page 3-14, This section needs to indicate that implementation of the It has been noted in Sect. 3.4.2.1 that the actions Section controls identified in the soil remedial action documents required under future decision documents will address 3.4.2.1 is an underlying assumption for protection of the groundwater and that a final decision on groundwater groundwater. A final decision has not been made (i.e., has not been made.

and associated controls for the Zone 1 and Zone 2 groundwater.

15 Page 3-17, This section should reference the results of the Aquatic The RER has been referenced in Sect. 3.5.1.3.

Section Resource Sampling program as described in the RER 3.5.1.3 Vol. 2 for Zone 1 and Zone 2 16 Page 3-22, The existing memorandum of agreement (MOA) for Reference to the MOA signed in March 2005 has not Section preservation of the K-25 Building needs to be included been added to the text because consultation is ongoing 3.6.11 in this section as it is the agreement of record until between the signatory parties to execute a new MOA.

superseded by a revised or new MOA.

17 Page 3-21, The main roads within ETTP (e.g., Perimeter Road) Text has been added in Sect. 3.8.1.2 regarding the Section have been transitioned to the City of Oak Ridge. transfer of some roads to the city of Oak Ridge to 3.8.1.2 provide access to property that has been transferred.

18 Page 3-32, Waste management is currently contracted to Bechtel Text has been modified in Sect. 3.9.1 to acknowledge Section 3.9.1 Jacobs Company, LLC, until no later than December 31, that DOE and their contractor are responsible for B-18 2011. waste management.

19 Page 3-32, The Toxic Substance Control Act Incinerator (TSCAI) This information has been incorporated in Sect. 3.9.1.

Section 3.9.1 shutdown operations in calendar year 2009 and is in process of Resource Conservation Recovery Act closure. The TSCAI will be managed under surveillance

& maintenance until decontamination and decommissioning.

20 Page 3-32, Suggest replacing reference to ASER with the RER. In addition to citing the 2009 ASER, the RER Section 3.9.1 reference has also been added to Sect. 3.9.1.

21 Suggest adding correspondence relating to historic The suggested documentation has not been added preservation of the K-25 North Tower. because consultation is ongoing between the signatory parties to execute a new MOA.

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Frank Hensley Reviewer Agency/Organization: Advocates For the Oak Ridge Reservation (AFORR)

B-19 Page Line Comment # Number Number Comment Comment Response 1 Desirable areas of the 1,800 acres should be made DOE anticipates that the area within the existing available for heavy industry (Alternative 1). These areas Zone 2 would most likely be utilized for heavy would be suitable for renewable energy generating industry; however, the final decision regarding facilities and manufacturing facilities for solar panels, specific use of the property will not be made by DOE, auto parts, nuclear generating components and many since the property will have been transferred.

other heavy industrial components. If a poorly planned development park produces haphazard mixed use development these areas will be lost forever.

2 The 220-acre ED-3 development area is a prudent Comment noted.

choice for business locations along Route 58.

3 The Non-Development classification of land running Comment noted.

north from Bear Creek Road to ED-3 and Route 58 and the land from the Haul Road across Blair Road to the Black Oak Ridge Conservation Easement (BORCE), is a good designation in view of terrain, power lines and other issues. This will furnish a good buffer zone for the industrial park as well as a conservation area for wildlife.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 4 The 1,500-acre BORCE will provide wildlife habitat as There is no intent, at this time, to add property to the well as a top-of-the-line recreation area for hiking, BORCE. Property that is identified as non-bicycle riding and hunting. development areas in the EA is not being considered for lease or transfer.

5 We continue to recommend that a full scale Comment noted.

Reservation-wide EIS be in initiated to determine the present and future value of the forest land for climate research, wildlife habitat and recreation.

6 We applaud your decision to not consider any more Comment noted.

large consolidated areas for transfer at the present time; however, we continue to insist that the remaining, relatively undisturbed 20,000 acres of the ORR should not be utilized for development because of its importance to future generations for biological and climate research.

B-20

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Dale Rector, Assistant Director Reviewer Agency/Organization: State of Tennessee, Department of Environment and Conservation, DOE Oversight Division B-21 Page Line Comment # Number Number Comment Comment Response 1 This EA barely acknowledges that there are ongoing The EA already contains some of this information but National Priority List (NPL) remediation activities additional information on the EM Program at ETTP onsite. It does mention limiting soil disturbance, but did has been added to Sect. 1.2.

not discuss the reasons, or explanations regarding the nature of the soil. Additional information on the existing contamination and the Zone 1 and 2 RODs has been added under the Furthermore, there is no mention of the existence of the appropriate resource areas.

Zone 1 or Zone 2 Records of Decision which were based on an industrial use scenario (potential exposure It is our intent to comply with land use restrictions to surface conditions down to 10 feet below ground in the CERCLA decision documents. However, surface for 2,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br />s/year for 25 years) and places there are areas under consideration for transfer that restrictions on excavation 10 feet below ground surface are outside of Zone 1 and 2. If a clean parcel (bgs).

determination is made then some land uses other Use of the property in a manner inconsistent with the than industrial may be appropriate. For example, a land use assumption of industrial use is prohibited. In use other than industrial use could be proposed within addition, residential use is specifically prohibited; this the Parcel ED-3 area, which is not within Zone 1 or includes residential housing, elementary and secondary Zone 2.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response schools, or any child care facility or childrens Additional information on groundwater, surface playgrounds. waters, and sediments has been added in the appropriate section(s).

Comprehensive Environmental Response Compensation and Liability Act (CERCLA) decisions on the Information on the LUCAP and on the Implementation groundwater, surface waters, and sediments at ETTP Plans for ETTP has been noted in the EA, as have not been made.

appropriate.

The Land Use Control Assurance Plan (LUCAP) and the Land Use Control Implementation Plans for ETTP As stated in the document, this EA evaluates the have not been negotiated by the Federal Facility potential transfer of property that was not previously Agreement (FFA) parties and could have impacts on the evaluated under NEPA (i.e., Parcel ED-3) and development of properties at ETTP. additional land uses including recreational and commercial that were not considered in the previous The purpose and intent of this EA is unclear. The NEPA documents.

subject has already been addressed in a previous EA and its addendum and a Finding Of No Significant Impact The protocol that is followed is CERCLA 120(h) and (FONSI) was issued.

is described in Sect. 2.1.2.

A protocol was developed that allows such transactions B-22 to occur by concurrence of FFA parties when sufficient This EA has been prepared to meet the NEPA information is presented to demonstrate that the requirements for this proposed action and is only one transaction meets the requirements of applicable laws part of the process to transfer property. DOE follows and agreements, does not present a risk to human health the regulator-approved protocol, including the or the environment, and does not significantly impede required CERCLA compliance.

the ongoing remediation at the site (BJC/OR-2829).

Characterization of contamination and evaluation of Since the protocol noted above is not referenced in this risk are accomplished on a parcel-by-parcel basis EA and the EA does not indicate the approval of U.S. through the CERCLA 120(h) process.

Environmental Protection Agency (EPA) or the state would be required, is it correct to assume that DOE is Extensive characterization and risk analysis is proposing to allow such transactions take place without performed and provided to the EPA and state for the concurrence of EPA and the state? If this is the case, review and approval prior to transfer. If there are DOE should be aware that it could face opposition of concerns to human health and safety, they can be these transactions/actions based on current laws and raised during the transfer process.

regulations.

This EA appears to advocate the conveyance of the property in question to private entities without taking into consideration the risk posed by contaminants known to be associated with property, the level of

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response characterization of these contaminants, and the ongoing remedial effort to reduce this risk allowing such transactions to occur unimpeded. In the end, this property is part of an NPL site that contains burial grounds, grossly contaminated facilities, and wide-spread contamination in soils, sediments, surface streams, and groundwater. While available data indicates this contamination is wide-spread across the property, the level of characterization currently available for most of the area has proven to be insufficient in locating and identifying all sources of contamination and much less accurately predicting the nature and extent of the contamination. This is evidenced by the conditions encountered during the remedial effort. Since the EA fails to address the above significant issues, it falls short of NEPA requirements and should be either amended to include consideration of the contamination and associated issues or remanded.

B-23 1 Page 2-3, Discussion of the covenant deferral request (CDR) and Text has been expanded to include additional Section 2.1.2 clean parcel determination (CPD) under CERCLA information.

120(h) should be included in this section.

2 Page 2-4, Use of the property in a manner inconsistent with the DOE agrees that property transfers and potential Section 2.3 land use assumption of industrial use is prohibited. future uses must be consistent with the EA decision, applicable RODs, and the CERCLA transfer process.

It should be noted that not all property evaluated in this EA is in Zone 1 or Zone 2. In addition, any uses other than what is specified in an existing ROD would have to be approved by EPA and the state, and proper documentation would have to be put in place.

3 Page 2-4 Line 17 and Schools and child day care centers are specifically The study area evaluated in the EA is larger than area Line 21 prohibited uses. covered by the CERCLA decision documents and therefore it is possible when complying with CERCLA 120(h) that a clean parcel determination will be made.

If a clean parcel determination is made, then these uses may be appropriate. For example, this type of use could be proposed within the Parcel ED-3 area, which has a clean parcel determination.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 4 Page 3-1, It should be mentioned that there are ongoing Additional information about ongoing EM projects Section 3.1.1 Environmental Management (EM) projects at ETTP. has been added.

5 Page 3-14, Line 19 Currently there is groundwater contamination over most Additional information on the existing conditions of Sections of the site. To imply that contaminants that could the groundwater in the affected area has been added.

3.4.2 and potentially be present in the groundwater is tantamount 3.4.2.1 to misrepresentation. The amounts of contamination are varied with some below drinking water levels or ambient Water Quality Criteria.

6 Section The assessment considers only the impacts of emissions DOE does not believe that the loss of mature 3.2.2.1 on air quality and ignores the impacts resulting from vegetation would constitute an adverse impact to air disturbance of mature vegetation within the 2,200 acres. quality requiring further analysis. The majority of the Forested land is a sink for C02 as well as airborne land that could be potentially transferred does not contaminants and the EA needs to look at loss of forest contain mature vegetation and the transfers and any impacts on air quality. subsequent development would be incremental.

What happens to the trees that will be removed for the It is anticipated that mature trees will be harvested for development? If the trees are stacked up and burned, an the timber and the remaining material would either be additional assessment of the air quality consequences of chipped/mulched or would be burned. Open burning that are needed including the release to the atmosphere B-24 would require that the developer obtain any applicable of the carbon stored in the trees.

permits.

7 Section Please provide a reference to the map that depicts the The existing figure (3.3) has been modified to show 3.4.1.2 features discussed in this section, e.g., Pine Ridge, K- these surface water features.

l007-P5 Pond, and the K-1007-P3 Pond. The discussion of the tributaries is meaningless without the features mentioned in the discussion being included in the map.

8 Section A fairly recent innovation to mitigate runoff from The use of permeable pavement has been added to the 3.4.2.1 impervious surfaces is the use of permeable pavement. text in Sect. 3.4.2.1 as a potential method of You might want to include this in your description of minimizing runoff.

attenuation measures.

9 Section How was it estimated that 2500 direct jobs would be The estimate of direct jobs was provided by CROET 3.7.2.1 generated? The Horizon and Heritage Center have so far and serves as an upper bound on the potential only been able to attract DOE sycophant industries. It socioeconomic impact.

seems the build it and they will come marketing philosophy of DOE/CROET is flawed.

10 Section 3.9.1 Waste management facilities at ETTP no longer include This has been noted in Sect. 3.9.1.

the TSCA Incinerator. It has shut down and is undergoing RCRA clean closure.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 11 Page 3-9, Restrictions on the excavation of soils below 10 feet bgs The current restriction on excavation below 10 ft in Section as per the Zone 1 and Zone 2 RODs should be Zones 1 and 2 without proper controls has been noted 3.3.2.1 mentioned in this section. in this section.

12 Page 3-10, There is no description of the known contamination A summary of groundwater conditions at ETTP has Section plumes that exist at ETTP. There are restrictions on the been added to this section, and it is noted that there 3.4.1.1 use of groundwater at the site. are restrictions on groundwater use.

B-25

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Ellen D. Smith Reviewer Agency/Organization:

B-26 Page Line Comment # Number Number Comment Comment Response 1 The EA should be revised to include an explicit The decision on an airport is not rife for analysis at assessment of the potential environmental impacts of this time. The Metropolitan Knoxville Airport constructing an airport on the land that would be Authority is performing a feasibility study to evaluate transferred under the proposed action. It is known that locations on the ORR for an airport. Once that study is CROET is seriously entertaining the possibility of complete, it is possible that an area within the study building a general aviation airport (to include jet area could be found suitable for the airport. If that aircraft) on this site. Impacts of airports are distinct happens, any additional NEPA compliance would be from the impacts of heavy industry, so they are not addressed by the project proponent and the effectively bounded by the analysis provided in the responsible federal agency (e.g., Federal Aviation current draft. (Mentioning airports in the description Administration).

of the proposed action and alternatives is not the same thing as assessing and discussing the potential impacts of an airport on air quality, noise conditions, and other environmental resources.) Since DOE is aware that an airport is a likely use, it should not transfer land without providing some additional analysis of this potential use.

Page Line 11-042(E)/100511 Comment # Number Number Comment Comment Response 2 The EA also should (a) acknowledge that the National The EA and FONSI from the National Park Service Park Service has been engaged for several years in a (NPS) were adopted by DOE in February 2011. In the study of the possibility of establishing a Manhattan FONSI, the NPS determined that an interpretive Project National Historic Park (or other historic component would be located in Oak Ridge as well as designation) to include an Oak Ridge unit, and (b) Hanford and Los Alamos.

discuss how the potential uses of this property (under the proposed action and alternatives) could affect or otherwise interact with the establishment and operation of a national park unit.

1 Page 1-1 Lines 10- This part of the statement of purpose and need for action DOE is demolishing buildings as a part of its 11 does not seem correct. It is not at all apparent that environmental cleanup responsibility. Transfer of transferring vacant land (much of whats included in the vacant land helps to reduce or eliminate landlord proposed action) can reduce the cost of building costs, which could include the cost of eventual demolition. Also, isnt DOE planning to demolish building demolition.

additional buildings on this property in order to be able to transfer the underlying land as vacant land?

2 Page 1-1 Lines 27- This statement (Commercial use of the area does not The existing text has been modified to more 28 constitute a change of the primary use of the property, accurately identify which property continues to be B-27 which has been industrial for over 60 years) is used for industrial purposes and which property has inaccurate and misleading. While some of the property been undisturbed for more than 50 years.

is in industrial use, and some other parts of the property were developed at one time (for example, the area south of Hwy. 58 that was used for temporary housing during World War II), substantial portions have been undisturbed for the past 60 years and have reverted to natural conditions.

3 Page 1-4 Line 24 Is the imperative word shall appropriate here (in The text has been modified.

DOE shall issue a Finding of No Significant Impact (FONSI) and will proceed with the action)? Wouldnt could or may be more appropriate?

4 Page 3-30 Lines 29- In this discussion of potable water, it would be useful to The existing information has been updated.

36 mention that the City of Oak Ridge plans to abandon the ETTP water intake and treatment systems described here. (After new water lines are in place, the City plans to serve the entire city, including this area, from the Pine Ridge water plant.)

COMMENT RESPONSE MATRIX 11-042(E)/100511 TRANSFER OF LAND AND FACILITIES WITHIN THE EAST TENNESSEE TECHNOLOGY PARK AND SURROUNDING AREA, OAK RIDGE, TENNESSEE ENVIRONMENTAL ASSESSMENT DRAFT Comment Form Reviewer: Parker Hardy Reviewer Agency/Organization: Oak Ridge Chamber of Commerce B-28 Page Line Comment # Number Number Comment Comment Response 1 The Oak Ridge Chamber of Commerce represents a Comment noted.

membership of approximately 600 area businesses. Our mission is to enhance the economic vitality of Oak Ridge. We strongly support allowing CROET to transfer the property in question for industrial, retail, and other economic development purposes.