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By: Todd Haagenstad, Los Alamos National Laboratory Ecology Group; Carl Sykes, Office of NEPA Policy and Compliance 

Under DOE NEPA regulations, after the completion of each Final Environmental Impact Statement (EIS) and its associated Record of Decision (ROD), DOE must prepare a Mitigation Action Plan (MAP) that addresses any mitigation commitments expressed in the ROD and explains how the mitigation commitments will be planned and implemented (10 CFR 1021.331). At Los Alamos National Laboratory (LANL), the MAP for the Dual Axis Radiographic Hydrodynamic Test (DARHT) facility has been successfully implemented for about six years a notable example of how a MAP can be effectively institutionalized at a DOE site. 

The DARHT MAP, issued in January 1996, provides direction for implementing measures to reduce or avoid the potential adverse environmental impacts of the selected alternative. It also establishes Action Plans to carry out each mitigation commitment in the DARHT ROD (60 FR 53588; October 16, 1995). The status of implementation is managed through a tracking system and reported to the public and stakeholders via a MAP Annual Report issued in January. 

Integrate with Project Management

The steps that led to successfully institutionalizing the DARHT MAP began early in the NEPA process. All members of the EIS team understood that a MAP would be needed, and the project staff were able to incorporate mitigation measures directly into project management documents and plans for DARHT facility design, construction, and operation even before the MAP was issued. 

Because of this close integration of the NEPA process with project management, the project design team addressed many of the mitigation commitments early in the DARHT project-planning phase. For example, in consultation with tribal representatives and the State Historic Preservation Office, a sensitive archaeological site in the project area was left in place and capped to prevent adverse effects from construction of the facility. Another site was protected from shrapnel by orientation of the DARHT facility. Completion of these commitments helped the project team gain approval for the final design and authorization to begin construction.

Potential Impacts Addressed in the DARHT Mitigation Action Plan
Area of Concern Example of Mitigation Action 
Cultural Resources, especially a particular archaeological siteDesigning the physical orientation of the DARHT facility to ensure that shrapnel would not adversely affect the important nearby Nake’muu archaeological structure, and monitoring the condition of Nake’muu over time to ensure that DARHT operations are not causing changes to the structure.
Human Health Construction of an earthen berm over and around the accelerator tunnel to minimize radiation exposure to involved and collocated workers.
Soils, especially soil loss and contaminationRevegetation with native plants and reforestation of land disturbed by construction activities.
Biota, including threatened and endangered speciesDevelopment of a Habitat Management Plan, which serves all of LANL as well as the DARHT facility. (See Lessons Learned Quarterly Report, June 1999, page 1.)
General Environment, including air and waterAnnual environmental contaminant monitoring of soils, vegetation, invertebrates, small mammals, birds, and large mammals around the DARHT facility site.

Other mitigation measures from the NEPA process particularly for construction-related impacts were incorporated into the project construction documents. For example, the DARHT facility required an exclusion fence for worker safety and operations security; however, a standard security fence would adversely affect elk movement across the relatively narrow mesa top. After further study, including agency consultation and field studies, the fence design was modified to allow elk movement while still meeting security and safety requirements. 

MAP Implementation Continues While DARHT Operates

Initially, the DARHT MAP was designated as a formal, line-item task during the design and construction phases. The roles and responsibilities of all parties were defined through formal work agreements updated for each fiscal year funding cycle. 

After completion of DARHT construction in 1999, LANL transferred day-to-day management and operation of the facility from its DARHT project office to a facility manager. DOE staff, the DARHT MAP project leader, and project office staff had been thoroughly discussing the scope, schedule, and implications of the DARHT MAP with the facility manager a year before the transition. This allowed for a smooth transition to facility operation and guaranteed long-term implementation of the MAP. In the present operations phase of the project, the facility manager remains closely involved in MAP activities by reviewing all mitigation-related results and documents. Because he understands the MAP, the facility manager has directly assisted DOE and the DARHT MAP project leader in modifying and adapting the mitigation measures to new conditions, where needed. 

A well-managed mitigation program like this helps ensure that adverse impacts are minimized, that mitigation measures can change over time if necessary, and that the environment is protected over the long term. All this can happen when a MAP is “baked” right into the design and long-term management plans for a project and is not just the “frosting” on the top. 

Recommendations

  • Have NEPA Document Managers work directly with project design staff to incorporate MAP activities into project design documents. 
  • Fund and implement MAPs through a project’s facility management group to ensure long-term ownership of mitigation activities. 
  • When developing a MAP, provide means by which mitigation measures may be fine-tuned based on future experience and periodic review. 

For more information, contact Todd Haagenstad at hth@lanl.gov or 505-665-2936, or Elizabeth Withers, Los Alamos Area Office NEPA Compliance Officer, at ewithers@doeal.gov or 505-667-8690.