By: Paul Bayer, NEPA Document Manager, and Clarence Hickey, NEPA Compliance Officer, Office of Science
The high costs and long times frequently needed to clean up contaminated Department of Energy (DOE) sites have created a demand for better and cheaper cleanup technologies. A promising new method for cleaning up subsurface contamination is bioremediation. However, field experience to validate laboratory results is lacking. Preparing an environmental assessment (EA) helped DOE’s Office of Science plan an effective field-based research program to better understand bioremediation processes. The EA process also helped ensure that actual field studies would not have significant environmental impacts.
Researchers need small-scale field sites for studies of basic biological and chemical processes associated with bioremediation of subsurface soil and water contaminated with metals and radionuclides. Therefore, the Office of Science needed to add a field component to its existing Natural and Accelerated Bioremediation Research (NABIR, pronounced “neighbor”) Program.
Bioremediation the use of microorganisms to degrade or transform contaminants to environmentally acceptable levels in soils, subsurface sediments, groundwater, surface water, and sludge. NABIR Primer
Established in 1997, the NABIR Program funds and coordinates research by universities, private industry, and the DOE national laboratories.
EA Process Aids Site Selection and Design of Bioremediation Field Studies
The NABIR Program proposed a Field Research Center to test laboratory results. (“Center” refers to the research location and includes only temporary support structures and equipment, not new construction.) An EA (DOE/ EA-1196, April 2000) helped identify and evaluate two alternative sites: an area (under Oak Ridge National Laboratory management) near the West End Tank Farm of the Y-12 National Security Complex at the Oak Ridge Reservation in Tennessee, and the 100-H Area (under Pacific Northwest National Laboratory management) of the Hanford Site near Richland, Washington. These locations met the Office of Science’s preferred characteristics, including:
- Availability, at a DOE site, of a contaminated area and an uncontaminated (control) area, with comparable hydrology and geology and of sufficient size to accommodate anticipated research projects for the remainder of the NABIR Program.
- Presence of heavy metals and radionuclides at levels high enough to require eventual cleanup but low enough to pose small risk during research activities.
- Expected stability of any active contamination sources for the remainder of the program.
- Ability to control public access while allowing year-round access for researchers and equipment.
The EA analyzes the potential environmental impacts of the No Action alternative – not establishing a Field Research Center – and the alternatives of locating the Center at Oak Ridge or Hanford. To analyze environmental impacts, the Office of Science had to determine the physical and biological parameters for reasonably foreseeable research activities. After broad consultations in the scientific community, the Office decided that research must meet certain criteria:
- Projects would be small-scale – involving less than 1 acre and a subsurface depth less than 75 feet.
- The NABIR Program would limit the type of research material; injection of genetically engineered microorganisms, human pathogens, and radioactive materials would be excluded.
Given the above constraints, the analysis found no potentially significant environmental impacts. The research activities would not affect environmentally sensitive resources, such as wetlands, floodplains, and endangered species. Contamination levels at each site were low enough to pose no health risks to workers or visiting scientists, even from inadvertent consumption of or contact with soil and groundwater samples.
Based on site visits, scientific and technical peer review of the proposals, and the environmental analysis – which included comment by Federal, State, and local agencies – DOE selected the Oak Ridge location, consisting of a 243-acre contaminated area and a 404-acre background area.
The EA and the finding that there would be no significant impacts apply only to actions that meet specified limitations. To help enforce these constraints on future research activities, the constraints were incorporated in the NABIR Program Management Plan, which was included in the EA as an appendix. The Plan specifies that before a research project receives funding and may begin field activities, the responsible DOE Operations Office must complete an environmental, safety and health review, including whether the project requires further NEPA review. The Program Plan also requires a Field Research Center Management Plan and tiered plans to address health and safety, waste control, environmental compliance, contingencies for potential offsite migration of contaminants, and site closure.
Authors’ Vision: NABIR Serves NEPA’s Goals
The NABIR Program’s goal – to validate laboratory experiments and test the effectiveness of potential new approaches for safe, efficient cleanup of DOE’s legacy waste – is aligned with a broad goal of NEPA: to “attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences” (Section 101(b)(3)). Promoting remediation of wastes in-place may reduce the need to excavate and disturb land, and may lessen the risks to workers from construction-related accidents and exposures to radiological and chemical hazards. Through the NABIR Program, DOE is a better trustee of the environment.
The authors believe that DOE should strengthen the links between the analysis process for DOE proposals (under NEPA Section 102) and the decisions DOE makes to support the goals NEPA sets for the Nation (under Section 101). Without this connection, in the authors’ opinion, the NEPA process is just process.
For more information on the NABIR Program, see “NABIR Primer: Bioremediation of Metals and Radionuclides … What It Is and How It Works,” at www.lbl.gov/NABIR/primer/primer.html, or contact Paul Bayer at firstname.lastname@example.org or 301-903-5324. Innovative Field Research The background (uncontaminated) area of the Field Research Center contains groundwater-monitoring wellheads.