Final Site-Wide Environmental Impact Statement for the Continued
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APPENDIX I MAJOR MATERIAL DISPOSAL AREA REMEDIATION, CANYON CLEANUPS, AND OTHER CONSENT ORDER ACTIONS APPENDIX I MAJOR MATERIAL DISPOSAL AREA REMEDIATION, CANYON CLEANUPS, AND OTHER CONSENT ORDER ACTIONS Los Alamos National Laboratory (LANL) conducts operations in support of the National Nuclear Security Administration (NNSA), a semi-autonomous administration within the U.S. Department of Energy (DOE). This appendix addresses possible environmental impacts associated with investigations and corrective measures being conducted at LANL in accordance with the Atomic Energy Act of 1954, as amended, and the Resource Conservation and Recovery Act (RCRA) and related legislation, particularly the Hazardous and Solid Waste Amendments (HSWA). RCRA- related investigations and corrective actions will be conducted in accordance with a Compliance Order on Consent1 (Consent Order) entered into by DOE, the University of California as the management and operating contractor, and the State of New Mexico on March 1, 2005. The Consent Order includes schedules for Implementing the Consent Order completion of investigations and corrective NNSA intends to implement actions measures by the end of 2015. This appendix necessary to comply with the Compliance accordingly addresses environmental Order on Consent (Consent Order) regardless of decisions it makes on other consequences through fiscal year (FY) 2016. actions analyzed in the LANL SWEIS. Actions associated with implementing the The analyses performed for this Site-Wide Consent Order are included in the Environmental Impact Statement (SWEIS) Expanded Operations Alternative; mainly consider levels of operations and new however, their implementation is not contingent on other actions that are part of projects proposed for 2007 through about 2011; that alternative. the analyses in this appendix consider environmental restoration activities through FY 2016. However, these analyses are applicable to actions that may be taken during this period of time, and if necessary beyond, as long as the actions are bounded by the analytical results presented in this appendix. I.1 Introduction I.1.1 Need for Agency Action In accordance with statutes such as RCRA and the Atomic Energy Act, LANL staff has conducted an environmental restoration project to identify locations where radioactive and hazardous constituents may have been released into the environment and to conduct corrective action. These potential release sites (PRSs)2 include: • Material disposal areas (MDAs), where radioactive or hazardous constituents have been disposed of, generally by burial within soil or underlying tuff 1 The Consent Order can be viewed at http://www.nmenv.state.nm.us/hwb/lanl/OrderConsent/03-01-05/Order_on_Consent_ 2-24-05.pdf. 2 For this SWEIS, a potential release site (PRS) means a site suspected of releasing or having the potential to release contaminants (radioactive, chemical, or both). PRS is a general term that includes solid waste management units and areas of concern that are cited and defined in the March 2005 Consent Order. I-1 Final Site-Wide EIS for Continued Operation of Los Alamos National Laboratory, Los Alamos, New Mexico • Firing sites, where radioactive or hazardous constituents have been explosively dispersed • Outfalls, where soils, sediments, water bodies, or aquifers have become contaminated with radioactive or hazardous constituents contained in discharged effluents • Other areas of possible surface, subsurface, or groundwater contamination Correction action activities at LANL are regulated primarily by DOE pursuant to the Atomic Energy Act, and by the New Mexico Environment Department (NMED) pursuant to RCRA, HSWA, and the New Mexico Hazardous Waste Act. For activities regulated by NMED, since 1990, LANL has conducted investigations and corrective measures in accordance with its Hazardous Waste Facility Permit. But as of March 1, 2005, the corrective action program specified in the permit was replaced by the Consent Order. The Consent Order prescribes investigation programs for LANL PRSs subject to RCRA and HSWA requirements. From the investigation program results, a determination may be made that no further action is required, or that corrective measures may be needed. If the latter, interim measures may be performed as directed by NMED or as proposed by DOE and approved by NMED. (Emergency interim measures may be implemented without prior NMED approval). As needed and as directed by NMED, alternative corrective measures may be evaluated. After NMED selects the corrective measures to be implemented at the PRSs, the selected corrective measures are implemented and completions of the corrective measures are documented. Activities to be performed in compliance with the Consent Order are similar to those that have taken place for years at LANL (such as drilling exploratory wells or performing removals). But the timing and extent of some activities may be different from those previously anticipated. The Consent Order provides schedules for all An aggregate area is an area within a single subject PRS remedy completion. Some watershed or canyon made up of one or schedules are explicitly stated, but most are more solid waste management units prescribed through aggregate area schedules for (SWMUs) and areas of concern (AOCs) and the media affected or potentially affected by remediation completion. That is, there is a SWMUs or AOCs releases and for which schedule for completing remedies in each investigation or remediation, in part or in aggregate area, and every subject PRS is in an entirety, is conducted for the area as a whole aggregate area. If regulatory delays occur in the to address area-wide contamination, ecological risk assessment, and other factors investigations or corrective measure selection (NMED 2005). processes, then the remedy completion schedules are adjusted to account for these delays. The majority of investigations and corrective measures that will occur under the Consent Order will probably not be environmentally significant. For example, if a sump formerly used for drainage of liquids containing hazardous constituents is decontaminated, and a small amount of waste products are properly disposed of, then these corrective measures may be of such a short- term nature that they do not require a detailed National Environmental Policy Act (NEPA) analysis. But if a large number of small-scale corrective measures take place, then there may be concerns about the cumulative impacts of all actions. In addition, some corrective measures for some PRSs may be of larger significance in terms of cost, time to complete, and possible short- and long-term environmental impacts. I-2 Appendix I – Major Material Disposal Area Remediation, Canyon Cleanups, and Other Consent Order Actions I.1.2 Purpose and Approach The purpose of this appendix is to address Consent Order NEPA implications on LANL operations. The following approach is used: • Review the Consent Order to identify and describe those PRSs that may require investigation or remediation through FY 2016 (Section I.2). • Address in detail a limited number of large MDAs that may require significant efforts to remediate (Section I.3). • Aggregate the remaining MDAs and other PRSs where remediation efforts will probably be more significant in totality than individually (Section I.3). • Analyze a bounding range of remediation options (Section I.3). • Review the environmental setting, emphasizing site-wide variations (Section I.4). • Assess environmental impacts of the bounding range of options (Section I.5). The analysis in this appendix is being conducted in advance of all information to be collected from the LANL corrective measure investigation program and is not meant to circumvent remediation decisions about any PRS. Work being performed to characterize, assess, and provide recommendations for corrective measures at all LANL PRSs may require several years to complete, and decisions will be made in accordance with prescribed regulatory processes. After a decision is reached on an MDA or PRS alternative, implementing that decision may require detailed engineering and safety assessments. Therefore, options in this appendix are meant to bound possible environmental impacts. The analysis is intended to provide information that could be used to develop mitigative measures, if needed, if a particular option is implemented. If it is determined that implementing an option may result in impacts that exceed those considered in this appendix, then additional NEPA review may be needed. For this appendix, the PRSs that will be investigated and may be remediated through FY 2016 are grouped into large MDAs, small MDAs, and additional PRSs. MDAs are emphasized because decisions about their remediation may significantly affect site- wide operations and the environment. Because MDAs contain contamination mainly in the subsurface, two broad-scope remediation options are envisioned: stabilization in place or removal (see Section I.1.3). Although several variations or suboptions may be addressed in future analyses, these two options should bound possible environmental impacts. The large MDAs addressed in this appendix are listed in Table I–1. Schedules for submittal of corrective measure reports for these MDAs are presented in Table I–2. These MDAs generally contain larger inventories of hazardous and radioactive constituents compared with other MDAs and PRSs. A second group of smaller MDAs is listed in Table I–3. I-3 Final Site-Wide EIS for Continued Operation of Los