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SECTION 6 UNAVOIDABLE ADVERSE ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

Significant and unavoidable impacts constitute a substantial adverse change to existing environmental conditions that cannot be fully mitigated by implementing mitigation measures. The potential significant and unavoidable adverse impacts that could arise from implementation of the proposed action discussed in section 5.1 are summarized below. Where appropriate, significant and unavoidable impacts are identified by site (i.e., LLNL Livermore site, LLNL Site 300, or SNL, Livermore). Although CEQA does not apply to SNL, Livermore, discussions in this EIS/EIR, where appropriate because of their proximity, include activities and impacts at both LLNL and SNL, Livermore. To provide consistency in this section, both LLNL and SNL, Livermore are included in the following discussion.

LLNL Livermore Site and SNL, Livermore

• The increase in housing demand in the region created by the proposed action in the near term (5 to 10 years) would result in a potentially significant and unavoidable impact. Projected demand due to an increase in employees cannot be accommodated by the existing Livermore housing market and other markets in the region. This impact is made more severe by increased demand due to cumulative growth in addition to the Laboratories' growth. Mitigation measures impacting housing availability are beyond the authority of DOE and UC.
• The increase in employees under the proposed action could impact school services provided by the Livermore Valley Joint Unified School District and other districts in the region. The addition of an estimated 800 students to the existing facilities would result in a potentially significant and unavoidable adverse impact due to an existing shortage of school capacity at the Livermore Valley Joint Unified School District and some other school districts in the region. To partially mitigate this impact, DOE will continue to participate in the federal government's Impact Aid Program, which provides funds to the district.
• The increase in nitrogen dioxide, volatile organic compounds, and fugitive dust emissions from Laboratory facilities and vehicles under the proposed action contribute to an existing nonattainment condition for ozone and particulate standards. The Laboratories' emissions of these pollutants are in addition to those from other area sources. Although the individual contributions are low, because the area is in nonattainment for ozone and particulate standards these emissions constitute a significant and unavoidable adverse impact.
• As a result of LLNL and SNL, Livermore and surrounding future development, cumulative roadway noise will increase substantially in the future along a number of roads near the Livermore sites, resulting in a significant and unavoidable adverse impact. Mitigation measures in the surrounding area that might reduce this impact to less than significant are beyond the control of DOE and UC.
• The proposed action, along with planned and proposed development near the LLNL Livermore site and SNL, Livermore, would result in a cumulative increase in traffic congestion at certain intersections. This increase is primarily due to the development of surrounding future land uses. Mitigation measures would be needed in the surrounding area to reduce this impact to less than significant; such measures are beyond the control of DOE and UC.
• Water usage by the Laboratories can be mitigated to a less than significant impact. However, cumulative development would increase demand for and consumption of water at a time of continuing drought in the state, and thus would be a significant and unavoidable adverse impact. Mitigation measures, beyond those proposed by DOE and UC, would be necessary to reduce this cumulative impact to less than significant.
• Both LLNL and SNL, Livermore generate mixed waste, almost all of which is prohibited from land disposal under RCRA without first being treated to meet defined standards. Currently, no treatment or disposal options are available for most of these wastes. Extended storage of these wastes may violate RCRA storage regulations (42 U.S.C. section 3004 (j)). The EPA recognizes that "generators and storers of these wastes may find it impossible to comply with the . . . storage prohibition if there are no available options for treatment or disposal of the wastes." The EPA suggests that "responsible management practices should minimize the environmental risks from these section 3004 (j) storage violations" (56 Fed. Reg. 42731).
• Assumed growth at LLNL and SNL, Livermore may contribute to significant and unavoidable cumulative impacts resulting from increased waste generation and waste shipments in the region. Measures to fully mitigate these impacts are beyond the control of DOE and UC.

LLNL Site 300

• The proposed action, along with planned and proposed development in the vicinity of LLNL Site 300, would result in a cumulative increase in traffic congestion at the Corral Hollow Road/I-580 interchange. Measures that would reduce this impact to a less than significant level are beyond the control of DOE and UC.
• Currently, solid waste from LLNL Site 300 is sent to the Corral Hollow Sanitary Landfill for disposal. This landfill is slated to close in 1995 and, as yet, the county has not identified an alternative landfill location. Under the proposed action, the anticipated increase in solid waste generation from LLNL Site 300 is approximately 500 cu yd per year. This increase, plus the cumulative contributions from other sources in the region, would constitute a significant and unavoidable impact until another landfill location is identified.
• The proposed action in conjunction with anticipated cumulative regional development could result in significant and unavoidable cumulative impacts to wetlands in the vicinity of LLNL Site 300. The full extent of wetlands within this study area is not known. Identifying these resources is also beyond the scope of this EIS/EIR. It is known, however, that at least four developments, totaling approximately 10,000 acres, could be constructed in the area of LLNL Site 300. The impacts to wetlands by other projects within the study area cannot be mitigated by DOE or UC.
• Increases in criteria pollutant emissions associated with stationary and mobile sources at LLNL Site 300 in addition from other regional sources of emissions would contribute to cumulative impacts on regional air quality. Although LLNL Site 300 contribution to area emissions is small, because the area is in nonattainment for ozone and particulate standards these emissions constitute a significant and unavoidable impact.
• The demand for and consumption of water at LLNL Site 300 together with cumulative demand from other users in the vicinity could contribute to a potentially significant and unavoidable impact on available water supplies. Population in San Joaquin County is projected to increase by 47.7 percent by the year 2010. Added to the assumed 9 percent increase in water usage at LLNL Site 300, this could constitute a significant and unavoidable cumulative impact if drought and other limiting factors continue. Despite LLNL conservation measures, all steps to mitigate this impact are not available to DOE or UC.

National

• The projected increase in waste generation at the Laboratories under the proposed action implies an increased need for treatment and disposal facilities for these wastes. A similar need may exist for waste generators elsewhere in the country. In order to evaluate the cumulative impact of this widespread waste generation, the problem must be addressed on a national scale. DOE is evaluating the national capacity for and cumulative impact on waste treatment and disposal facilities as part of the Programmatic Environmental Impact Statement for Environmental Restoration and Management. The Laboratories can and will minimize their rate of waste generation and treat what wastes they can to reduce waste quantities requiring offsite treatment and disposal; however, the general problem is beyond the scope of this EIS/EIR.