Chapter 7
MITIGATION MEASURES This section presents the mitigation measures that would be implemented by the DOE to reduce potentially adverse impacts to the environment. The four alternatives analyzed in this EIS represent a wide range of projects and activities that have associated with them a corresponding range of potentially adverse environmental impacts. There are, therefore, a range of mitigation measures that would be implemented and that are designed to ameliorate the potentially adverse impacts associated with specific activities. The mitigation measures presented in this chapter comprise a series of actions which address the full range of potential impacts likely to occur under the identified alternatives. They are summarized below by resource category. Where impacts and mitigation measures vary across alternatives, measures specific to each alternative are described. Under Alternative 2, closure of the NTS would include the development and implementation of monitoring programs necessary to protect human health and the natural environment. Under all alternatives, DOE will continue to maintain the Waste Minimization/Pollution Prevention Program as described in Appendix C, Section 6 . Throughout the history of the NTS, the DOE, the State of Nevada, Nye, Esmeralda, Clark, and Lincoln counties, and local communities have contributed to the success of the NTS. As Nye County encompasses most of the NTS land area, DOE has worked closely with Nye County as activities have changed over the years. In accordance with 10 CFR Part 1021.331 and in the interest of continuing this relationship with the state, counties, and communities, the DOE will prepare a Mitigation Action Plan. This document will describe the actions to implement commitments made in this EIS and its associated Record of Decision (ROD) to mitigate adverse environmental impacts associated with the alternative adopted through the ROD. The Mitigation Action Plan will be as complete as possible commensurate with information available regarding the course of action directed by the ROD. The DOE may revise the planas more specific and detailed information becomes available.
7.1 Land Use
Impacts to land use in areas surrounding the NTS under Alternatives 1, 2, and 3, and at the off-site locations under Alternatives 1 and 2 would be minimal and require no mitigation. Under Alternative 4, there is a possibility that a portion of currently withdrawn lands would be relinquished to the U.S. Bureau of Land Management. Should this land be found suitable for return to the public domain, the U.S. Bureau of Land Management would determine the ultimate land management and use policies. The land-use impact under this scenario would be an increase in lands available for use by the public, and mitigation measures appropriate to the use designation would be developed and implemented by the U.S. Bureau of Land Management. Land-use impacts on the NTS under Alternative 1, the continuation of current activities, and Alternative 3, expanded use, would be generally consistent with existing site and zone designations. Although certain activities would intensify and others would expand under Alternative 3, additional mitigation measures beyond those presently employed would not be required. Under Alternative 2, all activities would cease at the NTS and no new activities would be allowed. Access to, and use of, the lands would be restricted. Minimal monitoring and security operations would continue, and no mitigation would be required under this non-use scenario. Activities that would occur outside the NTS boundaries under Alternatives 3 and 4, e.g., Solar Enterprise Zone facility development, have the potential to result in land-use impacts. Projects that are located on federal land or are funded by agencies of the U.S. Government will be subject to additional review under provisions of the National Environmental Policy Act. This review will requirethe identification of significant environmental impacts, including land-use mpacts, and the formulation of measures to mitigate these impacts to the extent practicable. No adverse impacts to airspace are identified requiring mitigation under any of the alternatives at any project location.
7.2 Transportation
The following sections contain the discussion on the mitigation measures for transportation.
7.2.1 On-Site Traffic
It is anticipated that no on-site roadway segments would degrade to unacceptable levels of service under any of the alternatives at any project site; therefore, no mitigation measures would be required.
7.2.2 Off-Site Traffic
Should Alternatives 1, 2, or 4 be implemented, no substantial adverse impacts to traffic conditions are expected near the NTS at the access highway State Route 433, the ramp roadways at the Mercury Highway interchange, at U.S. Highway 95, or at any other project site; therefore, no mitigation measures, other than the continuing busing program, would be necessary. Under Alternative 3, the highway that accesses the NTS (State Route 433) would drop to a level of service D (acceptable) between the years 2000 and 2005. The NTS-related traffic contributes minimally to the Las Vegas area traffic demands. Similarly, no mitigation measures would be necessary for roadways in the immediate vicinity of the NTS. Ongoing and future development in the Las Vegas metropolitan area would result in an increase in traffic volumes and congestion on key roadway segments (namely, on Interstate 15, U.S. Highway 95, and U.S. Highway 93). These key segments already operate at an unacceptable level of service F at peak hours, and their conditions could continue to deteriorate even without theactivities associated with all alternatives. Currently, roadway improvements are being undertaken along Interstate 15 in downtown Las Vegas and at other locations. With the improvements planned under the Regional Transportation Plan of Clark County, the highway conditions are expected to improve. No additional mitigation measures are needed.
7.2.3 Transportation of Materials and Waste
Under Alternatives 1, 3, and 4, the routes used for truck shipments would be chosen using U.S. Department of Transportation routing guidelines. These guidelines are designed to reduce the radiological risks associated with transportation. According to the guidelines, primary factors include (1) the radiation exposure from incident-free transport, (2) the risk to public health from an accidental release of radioactive material, and (3) the economic risk from an accidental release of radioactive material. Secondary factors, according to the guidelines, include (1) emergency response effectiveness, (2) evacuation capability, (3) location of special facilities such as schools or hospitals, and (4) traffic fatalities and injuries unrelated to the radioactive nature of the cargo. The EPA has developed protective action guides and protective actions that are designed to limit doses in the event of a nuclear incident. Use of these guides and actions under Alternatives 1, 3, and 4 will minimize the impacts of transportation accidents involving radioactive material. In addition, the DOE will take the following actions:
- Conduct full government-to-government consultation with American Indian tribes that would be affected by the transportation of low-level waste and low-level mixed waste to the NTS
- Conduct a comprehensive study of the potential social and cultural effects of low-level waste and low-level mixed waste transportation on affected American Indian tribes
- Meet with the Transportation Protocol Working Group regularly to discuss low-levelwaste and low-level mixed waste transportation issues
- Respond to transportation concerns between meetings by phone calls, faxes, or personal meetings
- Continue to provide First Response and other emergency response training to all Nevada emergency response personnel
- Allow low-level waste and mixed waste shipments arriving at the NTS during off-hours to park in a secure area inside the gate
- Work with local emergency response agencies to determine their needs with regard to responding to emergencies involving low-level waste and low-level mixed waste and to help fulfill those needs as far as practicable
- Provide information to stakeholders concerning waste shipments
- Distribute surplus federal equipment to local agencies to the extent possible under current regulations concerning federal surplus disposition.
7.2.4 Other Transportation
All other transportation modes will follow guidelines established by the Department of Transportation, the Federal Aviation Administration, and all federal, state, and local laws and regulations under each alternative.
7.3 Socioeconomics
No long-term adverse impacts are associated with implementation of any alternative over the 10-year period of this EIS for any socioeconomic issue: economic activity, population, housing, public finance, or public service. The loss of employment and personal income and the increase in unemployment associated with Alternative 2 would result in substantial short-term adverse effects to the regional economy; however, economic and natural growth in the region of influence is expected to compensate for these reductions over time. Reductions in employment at the NTS relative tohistorical NTS employment levels are also inherent in Alternatives 1 and 4. While no long-term mitigation measures are required, the following supportive measures could be undertaken to the level appropriate for the alternative selected:
- Continue to extend economic adjustment efforts to reduce the impact of NTS downsizing on workers and small and medium sized companies. The DOE economic adjustment efforts could include actions such as enhanced coordination of DOE downsizing actions and employee assistance programs with public agencies and small and medium-sized companies who are current suppliers of goods and services (Alternatives 1, 2, and 4)
- Sponsor a joint local, state, and federal conference to promote a national and international environmental technology development center (Alternative 4)
- Act as a catalyst to develop joint proposals for research activities (Alternatives 1, 3, and 4).
7.4 Geology and Soils
Impacts to geologic media by activities under Alternatives 1 and 3 can be generally categorized as disturbance, contamination, excavation, or instability. The magnitude of these impacts largely depends on the nature of the activities resulting in these impacts. Disturbance to surface and subsurface geologic media and radioactive contamination of subsurface geologic media resulting from testing of conventional or nuclear weapons are inherent with the tests. Surface disturbance and the dispersion of contamination are mitigated by implementing containment practices. Containment practices also mitigate radioactive contamination of surface geologic media.
- Contamination of surface and subsurface geologic media from release of radionuclides from disposed waste is mitigated by administrative and physical controls. Siting, design, operation, and monitoring of waste management facilities on the NTS and NAFR Complex are conducted in accordance with relevant regulations. Physical controls include the various disposal and closure configurations. Contamination of surface and subsurface geologic media resulting from accidental spills is also mitigated by administrative and physical controls. Administrative controls include occurrence reporting, emergency response plans, and training. Physical controls include secondary containment and response equipment.
- Excavation includes boreholes and tunnels for testing of conventional and nuclear weapons, grading for roads and facilities, borrow pits, boreholes and trenches for waste disposal, and grading for environmental restoration. Excavation for other purposes is mitigated by minimizing the area disturbed.
- Surface disturbances will be mitigated on a site-specific basis, depending on various factors such as the size of the area, future use, nature of soils, annual precipitation, slope aspect, and site location. Following the removal of soils and vegetation, the site will be immediately stabilized using water or commercial-available soil stabilizers, such as polymers. Options to be considered for mitigation include natural revegetation, gravel rearmoring, chemical stabilization, seeding, planting, and irrigating. Where intensive revegetation techniques are necessary, subsoils may be amended and irrigations may be used. At drier sites, irrigation could be used to encourage germination and plant establishment. Instability of slopes resulting from excavation is mitigated as necessary to protect the environment or to ensure employee health and safety. The mitigation measures include administrative controls and physical controls such as shoring, bolting, and grouting.
7.5 Hydrology
Discussions of mitigation actions for surface hydrology and groundwater are presented in the following sections.
7.5.1 Surface Hydrology
Impacts to the surface hydrologic environment by activities under Alternatives 1 and 3 can be categorized generally as alteration of natural drainage, which potentially results in erosion or deposition of sediments, ponding of water, or inundation, and contamination. The extent of these impacts largely depends on the nature of the activities resulting in these impacts. Surface water quality impacts may result from the Environmental Restoration Program cleanup of plutonium-contaminated soils.
- The effects of altering natural drainage are mitigated by preactivity analysis of the flood potential and recommendations for minimizing direct and indirect flood hazards, followed by implementation of the recommendations. Typically, recommendations for minimizing direct and indirect flood hazards include construction of flood diversion structures
- Contamination may be mitigated by avoidance of surface water or groundwater contamination through lined storage/settlement ponds and environmental restoration of the affected area. Restoration typically might be excavation of contaminated geologic media, followed by grading and stabilization by revegetation
- With regard to the remediation of soils contaminated with plutonium, surface water controls will be implemented as part of the cleanup effort. However, there could be some breaching of control features resulting in the migration of contamination into downgradient areas. Such releases can be mitigated by expanding the soils media corrective action unit to include the area of release. The impacts would then be mitigated through the excavation of contaminated soils, removal of the plutonium, and return of the treated soils.
7.5.2 Groundwater
Potential adverse impacts on groundwater availability may be anticipated as a result of Alternatives 1, 3, and 4 actions. Large-scale groundwater withdrawals may be implemented to ensure there are no releases beyond the controlled NTS and NAFR Complex areas and other potentially affected areas via the flow of groundwater during Environmental Restoration Program activities. Any significant impacts on groundwater quality would be related to the underground testing program.
- Mitigation of groundwater availability impacts may be achieved through adjustments in the overall production of water from the well field and the drilling of new water supply wells, as required, and through the management of recharge and discharge areas in conjunction with the remedial action
- Under the Environmental Restoration Program, large-scale groundwater withdrawals may be implemented to ensure that no releases beyond the boundary of the site occur via the flow of groundwater. The potentially adverse impacts of such actions could be mitigated through the careful management of recharge and discharge areas in conjunction with the remedial action. These activities would occur as part of the underground test area corrective action unit.
7.6 Biology
The Framework for the Resource Management Plan, Volume 2 of this document, defines the ecosystem management principles which would be used to mitigate impacts related to biological resources:
- All reasonable and prudent measures required by the U.S. Fish and Wildlife Service to mitigate incidental taking of endangered or threatened species will be implemented.
- Habitat disturbance may be partially mitigated by implementing a habitat reclamation program.
- The DOE will conduct preactivity surveys to locate protected species such as candidates for listing under the Endangered Species Act, state-protected species, nests and eggs of migratory birds, individuals of a species that are locally rare (e.g. an isolated stand of Joshua trees on a bajada), references upon which these species may depend (e.g. free-standing water, burrows, nests), and other important biological resources such as Species of Concern. Project activities will be altered whenever possible to avoid harm.
- Migratory birds or other wildlife may drown or be exposed to drill-mud additives or could ingest chemicals in drill-fluid sumps, or evaporative tanks. These problems may be mitigated by placing flag lines that repel wildlife over the water sources, or by fencing or covering them.
- Impacts arising from military training exercises and other land-disturbing activities that have not yet been sited can be partially mitigated by developing and implementing a Resource Management Plan, which would be based on the principles of ecosystem management; identify sensitive areas, such as springs or habitats of rare species; and regulate harmful activities in those areas. This plan also would guide the collection of additional information needed to protect biological resources and the health and the ecosystem on the NTS. Volume 2 describes the DOE’s framework for developing this Resource Management Plan.
- All reasonable and prudent measures required by the U.S. Fish and Wildlife Service to mitigate incidental taking of endangered or threatened species will be implemented.
7.7 Air Quality
Air quality mitigation measures under Alternatives 1, 3 and 4 at the NTS include the following:
- Continue the use of a central parking facility to transport workers to and from construction sites. Pooling the transportation of workers to remote sites from central parking localities would lower dust and carbon monoxide levels because fewer vehicle trips would be involved.
- Properly maintain construction vehicle engines requiring air pollution control equipment. Properly tuned equipment would emit fewer harmful pollutants. This measure is highly effective in minimizing local air degradation.
- Place speed restrictions for vehicles on unpaved roads. Dust levels generated by moving vehicles on unpaved roads are substantially reduced at low speeds. Imposing appropriate speed limits on these roads could effectively reduce fugitive dust.
- Continue to control fugitive dust by regularly watering the construction areas, as needed, thereby achieving a 50-percent reduction in emissions. This measure would be included in future construction contract specifications to minimize construction-phase emissions.
7.8 Noise
No mitigation measures under any of the alternatives would be required at any of the project locations. However, should site activities exceed Occupational Safety and Health Administration noise level requirements, mandatory hearing protection for people working in the areas would be implemented.
7.9 Visual Resources
There would be no significant adverse impacts to visual resources under any of the alternatives. However, under those alternatives involving environmental restoration activities, areas would be revegetated with indigenous plants to return the sites to as natural an appearance as possible and to prevent excessive erosion and dust that could result in more serious, long-term adverse impacts. This measure would apply to all the project sites. Construction areas would be watered, as needed, to reduce dust.
7.10 Cultural Resources
Sites potentially eligible for listing in the National Register of Historic Places have been identified in numerous areas within which development associated with activities proposed under Alternatives 1, 3, and 4 may take place. Some of the prehistoric sites have the potential to provide information that will contribute to the understanding of hunter-gatherer settlement and subsistence patterns typical of the central Great Basin, while sites dating to the later historic period can contribute to a clearer understanding of the nuclear era (Cold War Era). Sites also have been identifiedon the NTS that are important to the economic or religious practices of American Indian people. Section 106 of the National Historic Preservation Act of 1966, as amended, requires that federal agencies take into account the effects undertakings may have on historic properties (i.e., sites eligible for the National Register of Historic Places). The most effective mitigation measure is avoidance; however, avoidance is not always possible. Mitigation of adverse impacts to cultural resources would be handled on a case-by-case basis through consultation with the State Historic Preservation Office (SHPO) and through a programmatic agreement initiated by the SHPO and the DOE. Any archaeological sites eligible for the National Register of Historic Places that cannot be avoided would be mitigated through the implementation of a data recovery plan formulated to address research goals important to an understanding of Nevada prehistory and history (Lyneis, 1982). Data recovery for prehistoric and historic archaeological sites may include, but not be limited to archival research, surface collection, photodocumentation, site evacuation, feature and artifact analyses, and specialized analysis such as radiocarbon dating, and obsidian sourcing and hydration. Any historic or Cold War Era architectural sites eligible for the National Register of Historic Places that cannot be avoided would be mitigated through the implementation of data recovery plans formulated to address research goals important to understanding Nevada history and Cold War Era technology. Data recovery for historic and Cold War Era architectural sites may include, but not be limited to, archival research, photodocumentation, architectural recordation including the study of as-built plans, and implementing Historic American Building Survey/Historic American Engineering Record documentation standards. All mitigation measures for cultural resources including data recovery would be conducted within established health and safety guidelines. Data recovery for prehistoric and historic archaeological sites may include, but not be limited to archival research, surface collection, photodocumentation, site excavation, feature andartifact analyses, and specialized analyses such as radiocarbon dating, and obsidian sourcing and hydration. The CGTO recommends that mitigation programs implemented at the NTS fully incorporate the assistance of American Indian people so that adverse impacts on American Indian resources can be efficiently averted. American Indian people know the NTS landscape in great depth and thus can help scientists with the identification of plants, animals, geography, archaeological sites, and traditional cultural properties that have been or will be adversely impacted by NTS programs and activities. The CGTO considers that the natural and spiritual balance of the NTS landscape has been profoundly upset by prolonged nuclear testing activities and that the land must be purified and the spirits appeased in order to fully restore the environment to its previous condition. Through ceremonies, prayers, and offerings, American Indian people will contribute to increase the benefits of mitigation and will aid in restoring the spiritual harmony of impacted landscapes. There are a number of proposed NTS actions that are of great concern to Indian people because of their adverse impact on the American Indian landscape. To avert or mitigate such impacts, the CGTO recommends that the DOE/NV fund systematic American Indian studies to:
- Identify those areas/resources that are irreparably damaged, as well as areas/resources that can be restored for human use
- Avoid further ground-disturbing activities
- Make mitigation of restorable areas a top priority
- Replace lost plant and animal species
- Avert or minimize damage to geological formations
- Implement environmental restoration techniques that require minimum
ground-disturbing activities
- Develop systematic consultation with American Indians so that potentially impacted resources can be identified, alternative solutions discussed, and adverse impacts averted
- Give American Indian people access to adversely impacted areas so that they can contribute their knowledge, purification ceremonies, prayers, and offerings to the restoration of the natural and spiritual harmony of the NTS landscape.
- Consultation with the CGTO does not relieve the DOE/NV of its obligation to maintain a government-to-government relationship with American Indian tribes
- The DOE/NV must consult with all culturally affiliated tribes and organizations belonging to the CGTO
- The DOE/NV should incorporate other American Indian tribes and organizations when considering activities away from (i.e., outside the American Indian region of influence) the NTS
- The CGTO recommends that the DOE/NV incorporate wherever possible in the NTS EIS the "Final Tribal Recommendations to DOE" prepared at the second mitigation meeting, Nevada Test Site American Indian Religious Freedom Act, October 1-3, 1993
- The CGTO recommends that DOE/NV incorporate wherever possible in the NTS EIS all former American Indian recommendations made by the CGTO to the DOE
- The CGTO recommends the continuance and expansion of the American Indian consultation program
- The CGTO recommends that they be actively involved in the planning, developing, and monitoring of all future DOE/NV ground-disturbing activities
- Public meetings are not the proper way to consult with tribes and organizations. They should not be considered quot;stakeholders" as defined by the DOE.
- Responses to the various NTS EIS alternatives:
The CGTO recommends that lands set aside for exclusive Indian use continue to be kept free, secure, and monitored for contamination of radioactivity and hazardous waste.
The CGTO recommends that the Gold Meadow area be set aside for exclusive Indian use because the area contains a concentration of important cultural resources. Alternative 4, (Alternate Use of Withdrawn Lands). The CGTO tentatively supports Alternative 4 with reservations regarding certain components of this alternative. The following statements are specifically adapted from the first CGTO meeting by the AIWS to reflect new information compiled during the work of the AIWS. The recommendation of mitigation by the AIWS does not imply they support the alterative; it merely is the best way of responding to impacts on American Indian cultural resources. If Alternative 1 is chosen, the following measures are recommended for DOE implementation: continue the American Indian Religious Freedom Act Compliance Program, expand American Indian ethnographic studies, provide access to the CGTO to culturally sensitive areas to conduct land restoration ceremonies, limit non-Native personnel access to culturally sensitive areas, continue to give access to American Indian monitors needed for cultural resources investigations, and provide for American Indian monitors needed for oversight of land and DOE activities. If Alternative 2 is chosen, the following measures are recommended for DOE implementation: continue the American Indian Religious Freedom Act Compliance Program, turn back the land to the CGTO, provide for American Indian Monitors needed for oversight of the land and DOE activities, and provide access to the CGTO to conduct land restoration ceremonies. If Alternative 3 is chosen, the measures recommended for this Alternative are the same as for Alternative 1. If Alternative 4 is chosen, the following measures are recommended for DOE implementation: continue the American Indian Religious Freedom Act Compliance Program, limit non-Native personnel access to culturally sensitive areas, and designate joint-use areas for three ethnic groups. Subject to funding, scheduling, and the requirements of existing agreements with state, federal, and local agencies, the DOE will continue to consult on a government-to-government basis and will evaluate study proposals to fund those studies which would:
- Identify those areas and resources that are irreparably damaged, as well as areas and resources that can be restored for human use
- To the extent practicable, avoid further ground disturbing activities
- Make mitigation of restorable areas a top priority
- Replace lost plant and animal species
- Avoid or minimize damage to geological formations
- Implement environment restoration techniques that require minimum ground disturbance.
7.11 Occupational and Public Health and Safety
The areas of concern are risks associated with occupational injuries and fatalities, traffic accidents resulting in injuries and fatalities, and exposures to ionizing radiation. Implementation of activities proposed under Alternatives 1, 3, and 4 would not result in significant adverse impacts to the general public. Additionally, risks to which workers at the sites are exposed (attributable to both work-related activities and traffic activities) do not exceed those experienced by their respective occupational groups. No adverse impacts are anticipated with implementation of Alternative 2. Hazards will be minimized by the best management practices and occupational and radiological safety programs operating under the same regulatory standards and limits that currently apply at the NTS. Emergency response programs will be employed to mitigate impacts of accidents to workers and the public in accordance with the 5500 series of DOE orders. These programs typically involve emergency planning, emergency preparedness, and emergency response. Each plan uses resources specifically dedicated to assist the facility in emergency management. These include a warningcommunications center, fire departments, facility emergency command centers, a DOE emergency operations center, county and state emergency command centers, medical and industrial hygiene specialists, and protective clothing and equipment, such as respirators and breathing air supplies. The radiation doses estimated in this EIS for the various radiological accident scenarios are the doses that would be received by the population if only limited protective actions were taken. The NTS has detailed plans for responding to accidents of the type described here, and the response activities would be closely coordinated with state and local officials. NTS personnel are trained and drilled in the protective actions to be taken if a release of radioactive or otherwise toxic materials occur. Even though this training may result in personnel receiving lower exposures should an accident occur, limited credit is taken for this training in estimating the exposure durations for workers. For the off-site population, the need for any protective action would be based on the predicted radiation doses. The emergency response would be based on the guidance provided in the protective action guides developed by the EPA. The underlying principle for the protective action guides is that, under emergency conditions, all reasonable measures would be taken to minimize the radiation exposure to the general public and emergency workers. In the absence of significant constraints, protective actions may be implemented whenprojected doses are lower than the ranges given in the protective action guides.
7.12 Environmental Justice
The following supportive measures should be undertaken to mitigate Environmental Justice impacts:
- Continue to expand opportunities for low-income and minority communities to provide input within the public involvement process by seeking the constructive involvement of affected stakeholders
- Set in motion an Environmental Justice Strategy Implementation Plan, incorporating concerns expressed in Appendix G
- Continue to encourage the participation of the Consolidated Group of Tribes and Organizations in DOE-sponsored cultural resources investigations, including those associated with ground-disturbing activities such as environmental restoration
- Encourage Consolidated Group of Tribes and Organizations participation when developing educational programs, so that students and researchers receive proper guidance regarding how to interact with the physical environment and cultural landscape.
7.13 References
| REGULATION, ORDER, LAW | |
| 10 CFR Part 1021.331 | U.S. Department of Energy, "Energy: Mitigation Action Plans," Code of Federal Regulations, Office of Federal Register, National Archives and Records Administration, U.S. Government Printing Office, Washington, DC, 1995. |
| GENERAL | |
| Lyneis, 1982 | Lyneis, M.M., An Archaeological Element for the Nevada Historic Preservation Plan, Nevada Division of Historic Preservation and Archaeology, University of Nevada, Las Vegas, NV, 1982. |
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