Yucca Mountain NEPA Documents

Jason was contracted in 1996 to prepare NEPA documentation for the proposed geologic repository for spent nuclear fuel and high-level radioactive waste at Yucca Mountain in Nevada.  Under this original contract, Jason prepared a draft, supplement to the draft, and Final EIS. 

In 2002, Jason completed the development, preparation, and issuance of the Yucca Mountain Repository Final EIS. This EIS analyzed the Proposed Action of construction, operation and monitoring, and eventual closure of a geologic repository at Yucca Mountain in Nevada, and a No-Action Alternative of continued storage of spent nuclear fuel and high-level waste at generator sites across the country.  The EIS analyses included an assessment of the impacts related to land use, radiological and non-radiological air quality, surface water and groundwater, biological resources and soils, cultural resources, socioeconomics, occupational and public health and safety, accidents, noise and ground vibration, aesthetics, utilities and energy, waste management, and environmental justice.  Jason staff also provided technical support for all public meetings and participated in consultations with Federal agencies and Tribal organizations.

In addition to the repository analysis, Jason evaluated the environmental impacts of the transport of spent nuclear fuel and high-level radioactive waste from 77 sites across the country to the repository, considering both a mostly rail and mostly legal-weight truck scenario. Included in this evaluation was an assessment of potential impacts that would occur in Nevada from transportation either by legal-weight truck, heavy-haul truck (involving the construction and operation of an intermodal transfer facility in Nevada), or rail (requiring the construction and operation of a branch rail line in one of five potential rail corridors).

In 2006, Jason was again contracted to prepare a supplemental EIS to evaluate changes in the overall design and operational plans and to mirror the proposal being included in DOE’s license application to the Nuclear Regulatory Commission.  The Final Supplemental EIS was prepared and issued in June 2008 in parallel and integrated with an EIS to evaluate the impacts of construction and operation of a railroad in Nevada to connect to the Yucca Mountain site.  This integration included coordination with the Bureau of Land Management and Surface Transportation Board as cooperating agencies.

Yuma Proving Ground Onsite Environmental Support Contractor

Jason was the environmental support services contractor for the U.S. Department of Army’s Yuma Proving Ground Environmental Sciences Office for 10 years (1999 through 2009).  The tasks (over 300 task orders) covered the wide range of material testing activities performed at the Yuma Proving Ground facilities and involved all of the regulatory and resource areas.

Jason prepared over 40 EAs for projects to be undertaken within the 9,000-acre site outside of Yuma, Arizona.  Additionally, Jason prepared the Range-Wide Environmental Impact Statement, which formed the basis from which most of these EAs were tiered.  Routinely, these projects analyzed cultural and natural resources, air quality, hazardous and/or solid waste, surface and groundwater quality, noise, and wetlands.  The assessments resulted in additional environmental activities such as developing storm water control plans, completing Clean Water Act Section 404 permit applications, conducting storm water management inspections, and performing cultural resources surveys and reports.

Jason, as part of JAD Environmental, subcontracted to New West Technologies to provide in-depth NEPA support services to the DOE Golden Field Office and EERE’s Environmental Stewardship Group (ESG) at DOE Headquarters. This support included providing services to assist the Federal NEPA Document Managers in managing or preparing EAs for a wide variety of renewable energy projects  funded under the American Reinvestment and Recovery Act of 2009. This support became necessary because the Federal Government had awarded billions of dollars of renewable energy grants as a result of the Recovery Act, which triggered a significant increase in the number of NEPA determinations and evaluations.

For projects managed by Jason personnel, our “shadow document managers” work directly with the DOE Document Managers, grant recipients, and their EA contractor to ensure that the EAs were prepared consistent with DOE’s requirements and expectations and that all of the peripheral activities (i.e., scoping, consultation letters, project schedules, internal DOE reviews) occurred in the most efficient manner possible, were consistent in terms of language and analysis methodology, and adequately documented the process in a defensible Administrative Record.

In many cases, DOE management determined it would be more efficient for our personnel to prepare the EAs “in-house” as opposed to waiting on recipients to obtain their own EA contractor. In these instances, our staff prepared the EAs on a rigorous schedule (typically less than 4 months from initiation to Final EA/Finding of No Significant Impact).

Under this contract vehicle, JAD personnel shadow managed 42 projects that had NEPA conditions requiring the preparation of an EA. Additionally, JAD personnel prepared another 31 EAs over the past two years for Recovery Act-funded projects. These projects included a variety of technologies including wind energy projects (single turbine and wind farms), biomass cogeneration facilities, solar projects, combined heat and power facilities, anaerobic digesters, and landfill methane collection and transmission systems. The projects were implemented in various regions across the country, including U.S. territories.

Several of the projects for which JAD prepared EAs included the installation of pipelines as an integral element of the proposed action. For instance: (1) the Richland Center for Renewable Energy Project involved installation of a 1.5-mile-long pipeline to transfer waste solids to an anaerobic digester in Richland, Wisconsin, that also had to be routed under the local Pine River; (2) the EA written for the County of Spartanburg, South Carolina, included the evaluation of a 6-mile-long pipeline that carried captured methane from a landfill under a narrow inlet of a lake to a local power plant; and (3) the Ridgewood Renewable Power Project in Yorba Linda, California, included a pipeline to carry captured methane from a local landfill. JAD personnel worked closely with DOE to accomplish the required consultations with the U.S. Army Corps of Engineers, State Historic Preservation Offices, and the U.S. Fish and Wildlife Service.

In addition to the direct EA support, JAD personnel have supported the ESG in revising/updating EERE’s NEPA implementing procedures, interfacing directly with the Office of NEPA Policy and Compliance (GC-54), developing an approach for NEPA monitoring of mitigation commitments, and developing a Renewable Energy Environmental Report for ground-source heat pumps as a pilot project for the Council on Environmental Quality.

Abengoa Biorefinery Project EIS

Jason was contracted to assist Abengoa Bioenergy Biorefinery of Kansas (ABBK) and the DOE with NEPA analysis for a proposed cellulosic ethanol production plant and cogeneration facility near Hugoton, Kansas.  DOE is providing partial funding and oversight for this project as part of America’s Biofuels Initiative goal of wide-scale use of non-food-based biomass in the production of transportation fuels, electricity, and other products.  The Department of Agriculture was a cooperating agency.

Jason prepared an EIS that evaluated the proposed construction and operation of the bioenergy facility, which would produce 16 to 18 million gallons of ethanol annually.  The ethanol will be produced from lignocellulosic material such as corn and/or milo stover, wheat straw, and switchgrass as a feedstock.  Cellulosic crop residue will also be used as boiler fuel for steam energy production.  The cogeneration facility will produce enough energy to power the biorefinery and sell 70 megawatts of electricity to the regional power grid.

The EIS describes and analyzes the affected environment and potential environmental impacts of the proposed project on numerous resources, including land use; air quality; surface and groundwater hydrology; biological (such as flora, fauna, threatened and endangered species, and critical habitat); utilities, energy, and materials; wastes and hazardous materials; transportation; aesthetics (specifically, odor, visual, and noise); socioeconomics; cultural; health and safety; facility accidents and sabotage; and environmental justice.  The Draft EIS was issued in September 2009 and Final EIS in August 2010.  A Supplement Analysis was prepared that covered project design changes and was issued on July 2011. 

NETL Section 216 NEPA Reviews

In order to prepare for the increased workload and the aggressive schedule of Recovery Act programs and projects, the DOE National Energy Technology Laboratory (NETL) awarded a contract to Jason to obtain support for completion of section 216 Reviews in compliance with DOE’s NEPA Regulations, specifically 10 CFR 1021.216.  These regulations apply to situations where there is a competitive solicitation for proposals, and the agency intends to select those proposals that best meet the goals of the program and that are within the funding constraints.  By satisfying the requirements of section 216, the Department can also satisfy its NEPA obligation to consider alternatives by evaluating the potential environmental impacts of proposals in the “competitive range,” reviewing the potential impacts of each qualified proposal in comparative form, and considering these during the selection process.

The section 216 review process consists of five primary steps:  (1) the solicitation requires that the applicants submit specified types of environmental data and analyses as part of their application for financial assistance; (2) DOE (Jason in this case) independently evaluates and verifies the accuracy of the environmental information submitted; (3) applications (proposals) received are subjected to an initial review to eliminate those proposals that are not in the “competitive range”; (4) DOE (Jason) prepares an environmental critique that focuses on the potential environmental issues that are pertinent to a selection of applications for subsequent negotiation and agreement award; and (5) DOE (Jason) prepares a publicly available environmental synopsis, based on the environmental critique, to document the consideration given to environmental factors and to record that the relevant environmental consequences of reasonable alternatives had been considered in the selection process.

The first task awarded under this contract required Jason to evaluate 135 applications for funding under DE-FOA-0000036, Smart Grid Demonstrations.  The reviews, preparation of the environmental critique for two separate areas of interest, and the environmental synopsis were all completed ahead of an extremely aggressive schedule to allow the Department to make its scheduled funding selections.

As a result of good performance under the first contract, Jason was competitively awarded a second contract to prepare section 216 Reviews for small-scale injection of carbon sequestration in geologic reservoirs.  Jason subsequently prepared an environmental critique and environmental synopsis that evaluated 22 proposals DOE received under DE-FOA-0000441, Small Scale Field Test of Geologic Reservoir Classes for Geologic Storage.

Environmental Report for Avera Motors

Jason was contracted by Avera Motors (Mainstream Engineering) in Rockledge, Florida to prepare an environmental report to support Avera’s application for financial assistance under DOE’s Advanced Technology Vehicle Manufacturing Incentive Program, which provides grants and loans to eligible automotive manufacturers and component suppliers for projects that promote improved fuel economy in light-duty vehicles.

The Incentive Program, governed by 10 CFR 611.106, requires the applicant (in this case Avera Motors) to submit a comprehensive environmental report.  This environmental report must provide substantial basis for any required EIS or EA and Finding of No Significant Impact, pursuant to the procedures set forth in 10 CFR 1021.215.  Jason prepared the environmental report for submittal to DOE with Avera’s application.  The report was completed on an aggressive schedule and supported changes in facility location on two separate occasions with minimal impacts to cost or schedule.

Battery Manufacturing Facility Environmental Assessments

As a result of selections made under DE-FOA-000026 under the Recovery Act, Electric Drive Vehicle Battery and Component Manufacturing Initiative, DOE awarded a contract to JAD Environmental to prepare five EAs. These EAs involved similar projects for cell and battery manufacturing facilities, as listed below:

• Saft America, Jacksonville, FL    
• EnerDel, Indianapolis, IN
• Exide Technologies, Bristol, TN and Columbus, GA  
• Dow Kokam, Midland, MI
• Compact Power, Holland, MI 

JAD Environmental prepared the preliminary Draft EAs in four weeks for DOE review in order to meet an aggressive DOE schedule for funding.  The Draft EAs were issued for a 30-day public comment period in an average of 6 weeks from project initiation.  Typically, the comment responses, revised Final EAs, and draft Findings of No Significant Impact were completed within two weeks of the close of the comment period.  JAD managed all consultations with the U.S. Fish and Wildlife Service and the State Historic Preservation Offices for each affected state.

Smart Grid Environmental Assessments

As a result of selections made under DE-FOA-000036 under the Recovery Act, Smart Grid Demonstrations (DOE 2009), Jason was competitively awarded a contract to prepare eight EAs for these selections.  Smart grid projects include advancements in grid-scale energy storage.  Electrical grid operators can utilize electricity storage devices to manage the amount of power required to supply customers at times when the need is greatest, which is during peak load.  Electricity storage devices can also help make renewable energy resources, whose power output cannot be controlled by grid operators, more manageable.  Such devices can also balance microgrids to achieve a good match between generation and load.  Storage devices can provide frequency regulation to maintain the balance between the network's load and power generated, increase asset utilization of both renewables and electrical systems, defer technology and development investments, and achieve a more reliable power supply for high-tech industrial facilities.

Projects to demonstrate energy storage technologies include battery storage for utility load shifting, wind farm diurnal operations, ramping control, frequency regulation services, distributed energy storage, compressed air energy storage, and demonstration of promising energy storage technologies.

The FOA included two program Areas of Interest:  (1) Smart Grid and (2) Energy Storage. The specific EAs prepared under this contract are listed below:

Combined Heat and Power Environmental Assessments

In February 2010, as a result of selections made under DE-FOA-000044 under the Recovery Act, Industrial Technologies Program, DOE awarded a contract to JAD Environmental to prepare six EAs for various projects related to Combined Heat and Power (CHP) and Waste Energy Recovery in support of EERE.  Under this contract, JAD prepared the EAs listed below:

Commercial Light Water Reactor Production of Tritium Supplemental EIS

JAD Environmental was contracted to prepare a Supplemental EIS for the production of tritium in a commercial light water reactor (CLWR) at reactors owned and operated by the Tennessee Valley Authority (TVA).  The original CLWR EIS evaluated the incremental radiological impact resulting from operation with up to 3,400 tritium-producing burnable absorber rods (TPBARs) per reactor unit compared to normal operation without TPBARs inserted into the reactor cores.

After several years of tritium production experience at Watts Bar Nuclear Plant, Unit 1, TVA determined that tritium permeation through TPBAR cladding and into the cooling water was approximately 3 to 4 times higher than originally projected. Therefore, a Supplemental EIS was required to evaluate potential radiological impacts of a higher tritium permeation rate for a smaller number of TPBARS per reactor.  Alternatives for this Supplemental EIS include operation at Watts Bar or Sequoyah Nuclear Plant reactors and also various tritium mitigation and management systems.

The CLWR Supplemental EIS is also expected to assess the technical feasibility and cost-effectiveness of these tritium mitigation options in reducing the impacts of tritium production in CLWRs. The CLWR Supplemental EIS will support agency deliberations regarding potential changes in the tritium production process at licensed TVA facilities in order to meet the requirements of TVA’s contract with DOE/NNSA. These changes are expected to lead to the need for an NRC license amendment. Accordingly, the CLWR Supplemental EIS will substantially meet NRC requirements for an environmental report necessary to support licensing amendments for tritium production at the Watts Bar and Sequoyah nuclear plants.

Bannister Federal Complex Disposition EIS

JAD Environmental was contracted to prepare an EIS for the Disposition of the Bannister Federal Complex at the Kansas City Plant (KCP).  The EIS is being prepared for the DOE National Nuclear Security Administration’s, Kansas City Site Office, with the General Services Administration as a cooperating agency.

The mission of the KCP is to produce or procure non-nuclear electrical and mechanical components for nuclear weapons. At present, the KCP occupies a large 1940s vintage industrial facility made up of thirty-five buildings or other structures in Kansas City, Missouri, and located on a site contiguous with GSA facilities, the sum of which is known as the Bannister Federal Complex.