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5.3 MODIFICATION OF OPERATIONS

This alternative would modify LLNL and SNL, Livermore operations, including near-term (within 5 to 10 years) proposed projects, in order to reduce adverse environmental impacts. Modification of operations is broadly defined as the scale-down of operations and/or the application of alternative technologies and management strategies (formerly described as two alternatives in the Notice of Intent, 55 Fed. Reg. 41048).

The first step in assessing this alternative was to identify those operations at LLNL and SNL, Livermore where environmental impacts could be reduced through a modification of operations. The primary criteria for selection were:

• Operations with a history of, or a potential for, the greatest worker exposure to hazardous or radiological materials (see Appendix C).
• Operations, based on accident analyses, with the greatest potential impact to the public health and safety (see Appendix D).
• Operations that have historically generated the greatest quantities of transuranic waste, low-level waste, mixed waste, or waste restricted from land disposal (see Appendix B).

On the basis of the selection criteria and a review of facility operations, the following options for modification of operations were identified:

• Operations in LLNL's plating shop, Building 322, could be modified and the building structurally reinforced to prevent the accidental mixing of incompatible chemicals. This would minimize or eliminate offsite impacts during a severe earthquake.
• Waste management operations at the two Laboratories could be consolidated at LLNL's waste management complex. This might be accomplished if regulatory approval is obtained allowing LLNL and SNL, Livermore to apply for the same EPA identification number or by LLNL's modifying its RCRA Part B permit to accept SNL, Livermore wastes. This would allow transfer of wastes between sites for possible treatment and packaging in compliance with DOT regulatory requirements before wastes are shipped offsite. Under this alternative, more efficient methods of waste treatment could also be evaluated at a centralized waste management complex.
• At various facilities, notably LLNL's Building 332, plutonium and other Special Nuclear Materials are stored in excess of current needs. Removal of this material and storage elsewhere could reduce worker exposures. LLNL is currently reducing the plutonium administrative limit for the combined Buildings 332 and 334 from 700 kg to 200 kg, with the inventory (actual inventory quantities are classified) being reduced accordingly. The reduction would be accomplished by shipping inventory to an offsite DOE facility and is targeted for completion during FY 1993.
• Buffer zones to the east of the LLNL Livermore site and SNL, Livermore might be acquired to reduce fenceline exposures and to preclude the development of residential and/or industrial areas immediately downwind of the two Laboratories.

These examples are illustrative of possible modifications being considered. If this alternative were selected, however, more detailed engineering and environmental evaluations would be undertaken to select facilities and operations for modification. The implementation of any of these modifications is not precluded, however, if the proposed action is adopted.

5.3.1 LAND USES AND APPLICABLE PLANS

LLNL Livermore Site and SNL, Livermore

The modification of operations alternative would not alter the types of land uses at the LLNL Livermore site or SNL, Livermore. As discussed earlier, this alternative considers the acquisition of an unspecified amount of additional land east of the current boundaries of the LLNL Livermore site and SNL, Livermore as additional buffer area. The area is used for grazing and rural residential uses, and is zoned for agricultural uses. The area has an agricultural land use designation in the Alameda County General Plan and is included in the county's South Livermore Valley General Plan Amendment planning area.

If acquisition of additional buffer area were implemented, there would be the potential for a change to the existing residential and agricultural uses and a possible inconsistency with approved land use plans for the affected area.

LLNL Site 300

This alternative would neither alter the types of land uses at LLNL Site 300 nor require acquisition of any additional land. Thus, no impacts to land uses at or near LLNL Site 300 would result.

5.3.2 SOCIOECONOMIC CHARACTERISTICS

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

Impacts under the modification of operations alternative would be similar to those described for the proposed action. Consistent with the proposed action, this alternative assumes an increase in employment levels at LLNL and SNL, Livermore. Increased employment would result in population increases and an increased demand for housing in the region. The modification of operations alternative would also result in increases in the amount of goods and services purchased by the Laboratories at levels similar to those estimated for the proposed action.

5.3.3 COMMUNITY SERVICES

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

Impacts as a result of the modification of operations alternative would be similar to those described for the proposed action. Increases in the need for onsite fire protection and security services or in the interaction of these forces with offsite fire and police protection agencies would be required. It is also assumed that the employment increase associated with the modification of operations alternative would be the same as for the proposed action. Thus, increases in student enrollment and nonhazardous solid waste generation, based on the same increase in employment, are assumed to be the same as for the proposed action.

5.3.4 PREHISTORIC AND HISTORIC CULTURAL RESOURCES

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

The Area of Potential Effect for the LLNL Livermore site and SNL, Livermore under the modification of operations alternative would be expanded to encompass any newly acquired lands to the east of the sites. These lands would require an evaluation for the presence of cultural resources before impacts to prehistoric and historic resources could be determined. The Area of Potential Effect for LLNL Site 300 would be the same as for the proposed action. Impacts to prehistoric and historic resources at the LLNL Livermore site, LLNL Site 300, and SNL, Livermore would be similar to those described for the proposed action. Until structures and facilities have been evaluated as to their historic significance, the exact nature of impacts would remain unknown.

This evaluation would be done through the Section 106 process of the National Historic Preservation Act, which would be required regardless of whether or not the modification of operations alternative is chosen for implementation.

5.3.5 AESTHETIC AND SCENIC RESOURCES

LLNL Livermore Site and SNL, Livermore

The modification of operations alternative would have effects on visual resources at the LLNL Livermore site and SNL, Livermore consistent with the proposed action, with the exception of potential effects of the possible acquisition of land east of the LLNL Livermore site and SNL, Livermore as additional buffer area. Depending on the disposition of Greenville Road within this buffer zone, and the land use changes (if any) within the buffer zone, the County of Alameda scenic corridor status of the portion of Greenville Road between Patterson Pass Road and Tesla Road could be affected. The relative significance of this would depend on the accessibility of the roadway to the public and the possible changes to visual features (landscaping and vegetation) along the road. Until such an evaluation can be made, a potentially significant impact is identified.

LLNL Site 300

The modification of operations alternative would not substantially alter visual features at LLNL Site 300 nor would it affect scenic resources policies for roadways or land uses in the vicinity of the site. Thus, effects on aesthetics or scenic resources at or near LLNL Site 300 would be less than significant under this alternative.

5.3.6 GEOLOGIC RESOURCES AND HAZARDS

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

No known geologic resources are close enough to the LLNL Livermore site, LLNL Site 300, or SNL, Livermore to be affected by activities of the modification of operations alternative. Similarly, modification of operations would not initiate any geologic hazard (earthquake, landslide, or liquefaction). On the other hand, any construction needed for any particular modification of operations would have to adhere to the building codes that embody seismic-resistant design presented in section 5.1.6. The potential impacts of modification of operations on geologic resources and hazards would not be significant.

5.3.7 ECOLOGY (Vegetation, Wildlife, Sensitive Species, and Wetlands)

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

It is anticipated that the same land disturbance activities described for the no action alternative (e.g., the LLNL Site 300 revitalization plan) and for the proposed action (e.g., the Contained Firing Facility, the Cheap Access to Orbit Facility, and elimination of surface water runoff at LLNL Site 300) would occur under the modification of operations alternative. Therefore, the impacts of this alternative on vegetation, wildlife, sensitive species, and wetlands would be equivalent to the impacts of the proposed action on these biological resources.

5.3.8 AIR QUALITY

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

The modification of operations alternative may result in a small decrease in air emissions over those estimated for the proposed action. Given the changes in operations and facilities described above and in section 3.2.1, it is estimated that annual stationary source emissions could be reduced by up to 1 percent relative to the emissions contribution from the remainder of the facilities at LLNL and SNL, Livermore. A similar reduction would be expected for toxic air pollutants. Emissions from vehicular traffic and construction activities at the Laboratories would remain unchanged from those of the proposed action since growth in employment along with construction activity is estimated to be the same as for the proposed action. This reduction would be considered less than significant, except that any emissions into a nonattainment area are considered to be a significant impact.

If a buffer zone to the east of the LLNL Livermore site and SNL, Livermore were acquired, the radiation dose at the fenceline would be reduced by about 6 percent for each 100 m of distance from the existing boundary. This would result in a reduction in the radiation dose to the hypothetical maximum-exposed individual. However, because of the small number of persons living in this area, there would be no change in the calculated collective dose for the current population distribution. The acquisition would be of value for reducing collective radiation dose only if it prevented future development of the area for residential use. Even in this case, the contribution to the collective radiation dose would be less than significant.

5.3.9 WATER

The modification of operations alternative would not change the anticipated impacts on water resources from the proposed action.

5.3.10 NOISE

LLNL Livermore Site and SNL, Livermore

Noise characteristics at or in the vicinity of the LLNL Livermore site and SNL, Livermore would be the same as those under the proposed action.

LLNL Site 300

Noise characteristics at or near LLNL Site 300 would be the same as those identified for the proposed action.

5.3.11 TRAFFIC

LLNL Livermore Site and SNL, Livermore

Traffic conditions and levels of service at intersections studied would be essentially the same as those described for the proposed action. No project-specific traffic impacts are identified.

LLNL Site 300

Traffic conditions at or near LLNL Site 300 resulting from implementation of this alternative are assumed to be the same as those identified for the proposed action. No project-specific traffic impacts are identified.

5.3.12 UTILITIES AND ENERGY

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

The modification of operations alternative would not change the anticipated impacts on utility usage and energy resources from the proposed action.

5.3.13 MATERIALS AND WASTE MANAGEMENT

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

Because the modification of operations alternative aims to reduce the impacts of those activities with the largest potential exposures to workers and to the public, the amounts and uses of hazardous and radioactive materials are expected to be less than under the proposed action. The impacts associated with materials and waste management at LLNL and SNL, Livermore fall within those identified for the proposed action.

LLNL is currently reducing the plutonium administrative limit for the combined Buildings 332 and 334 from 700 kg to 200 kg, with the inventory (actual inventory quantities are classified) being reduced accordingly. The reduction would be accomplished by shipping inventory to an offsite DOE facility and is targeted for completion during FY 1993.

One potential modification option is the consolidation of SNL, Livermore waste management activities with the LLNL Livermore site waste management system. Consolidation of waste management activities in itself would not necessarily reduce the amount of wastes generated, but would provide for more efficient waste handling, treatment, packaging, and shipment. Consolidation of waste handling could potentially reduce the occupational exposure to waste management activities for SNL, Livermore workers. Other potential benefits that could be realized through consolidation include the need for fewer workers, less duplication of waste management equipment, reduced demands for emergency response capabilities, and fewer waste disposal shipments resulting from increased processing capabilities. However, this option would require a substantial regulatory approval process and result in the potential for increased liability to both site operators, increased exposure to LLNL workers, and increased demands on LLNL permitted capacities as a result of accepting SNL, Livermore waste.

Because the modification of operations alternative would reduce those activities at LLNL and SNL, Livermore with the greatest potential impacts, it is expected that the shipments of hazardous materials, particularly hazardous wastes, would fall within the range of transportation activity described for the proposed action. A possible exception could occur if LLNL and SNL, Livermore elected to consolidate some waste-handling facilities. This action might require the shipment of potentially contaminated waste-handling units from decommissioning of replaced waste-handling facilities to offsite treatment, storage, recycling, or disposal facilities. The transportation accident analysis and the level of transportation impacts identified for the proposed action, however, already encompass the hazardous waste transportation issues raised by consolidation.

5.3.14 OCCUPATIONAL PROTECTION

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

Modifications to the technical and management aspects of facilities and operations at LLNL and SNL, Livermore may reduce worker exposures under this alternative relative to the proposed action.

Consolidating SNL, Livermore waste management activities with LLNL waste management may result in an overall reduction in radiological and nonradiological exposures to workers over those of the proposed action, because of the need for fewer workers. The reduction in exposure of SNL, Livermore workers would be partially offset by an increase in exposure of LLNL workers.

LLNL is currently reducing the plutonium administrative limit for the combined Buildings 332 and 334 from 700 kg to 200 kg, with the inventory (actual inventory quantities are classified) being reduced accordingly. The reduction would be accomplished by shipping inventory to an offsite DOE facility and is targeted for completion during FY 1993.

5.3.15 SITE CONTAMINATION

LLNL Livermore Site, LLNL Site 300, and SNL, Livermore

The LLNL Livermore site has identified over 17 areas with known soil and sediment contamination. An additional 17 areas are currently under investigation for potential sources of contaminants. Contaminants in soils include volatile organic compounds, fuel hydrocarbons, pesticides, polychlorinated biphenyls, metals, and tritium.

LLNL Site 300 has identified 10 main areas of contaminated soil. Contaminants detected include volatile organic compounds, fuels, aromatic hydrocarbons, metals, radionuclides, and high explosive compounds.

SNL, Livermore has evaluated nine source areas for the presence of soil and sediment contamination. The contaminants detected include volatile organic compounds, fuel hydrocarbons, and metals. Regardless of whether the operations of the Laboratories are modified, the Environmental Restoration Programs will continue until remediation is completed. The net impacts are less than significant.

5.3.16 CUMULATIVE IMPACTS

The modification of operations alternative is a variation of the proposed action with additional emphasis on changing those operations at LLNL and SNL, Livermore with greatest impacts. The options for modification selected as examples in assessing this alternative were selected to reduce potential impacts to the environment, the public, and workers. Cumulative impacts, under this alternative, are therefore equivalent to or less than the cumulative impacts discussed under the proposed action.