As DOE and the Los Alamos region cope with the effects of last month’s devastating fire, the 1999 Los Alamos National Laboratory (LANL) Sitewide EIS has proved to be a valuable reference document. In fact, the NEPA process had earlier focused DOE attention on the risks of wildfire at LANL and prompted mitigation actions within the past year that reduced the severity of impacts of the fire. Moreover, the analyses in the Site-wide EIS will be useful in planning recovery programs.
The LANL Site-wide EIS (DOE/EIS-0238) included an accident scenario – an extensive wildfire initiated to the southwest of LANL near the border with the Bandelier National Monument – that closely mirrored the actual Cerro Grande Fire. That fire, ignited as a “prescribed burn” by the National Park Service on May 4, 2000, went out of control and burned about 50,000 acres of forest and residential land, including about 9,000 acres (approximately 30 percent) of the LANL site.
During the fire, DOE relied upon the EIS analyses to answer public inquiries and concerns, particularly regarding the potential adverse affects from the fire burning over contaminated areas. According to Elizabeth Withers, Los Alamos Area Office NEPA Compliance Officer, the EIS was “an extremely valuable tool for public relations credibility in a very emotional and difficult time.” The completeness of the assessment in the EIS, coupled with the onsite air monitoring, “helped to establish early on that there was no imminent danger to people resulting from the fire,” she said.
The detailed accident analysis (Appendix G of the EIS, which is posted on the DOE NEPA Web at tis.eh.doe/ nepa/docs/docs.htm) covered the immediate impacts of such a wildfire on workers, the public and the environment. The analysis assumed that about 8,000 acres on LANL would be burned as well as portions of the Los Alamos townsite. “These scenarios are quite credible, in view of the present density and structure of fuel surrounding and within LANL and the townsite, as well as the occurrence of three major fires in the past 21 years,” the EIS stated. In considering the combined probability of fire-favorable conditions, the EIS concluded “that a major fire moving up to the edge of LANL is not only credible, but likely . . ."
Comments Focused Attention on Wildfire
The Draft LANL Site-wide EIS did not analyze a wildfire accident because under the initial screening methodology that scenario had not been considered plausible. However, comments at the public hearing on the Draft EIS from a forester at the nearby Santa Fe National Forest and written comments from the Department of the Interior focused attention on the issue. The commenters referenced a recent Forest Service report about the threat of wildfire. The Final EIS estimated that the frequency of this type of fire is 1 in 10 years.
Based on this high chance of fire identified in the EIS analysis, actions were begun immediately to reduce the wildfire risks at certain key facilities, including TA-54 (waste facility) and TA-16 (Weapons Engineering Tritium Facility). Trees were cut and wooden pallets on which waste drums were stacked were replaced with aluminum pallets.
With the completion of these actions, the Final EIS stated (conservatively) that the population dose from a site-wide fire would be reduced from an estimated 675 person-rem to 50 person-rem, thereby avoiding a potential for approximately 0.3 latent cancer fatalities.
The EIS also addressed the longer-term environmental impacts resulting from a fire, e.g., loss of protective cover, runoff, soil erosion and sedimentation, effects on legacy contaminants, effects on biological systems, and effects on cultural resources. As stated in the EIS, “The consequences of a wildfire are diverse, continuing through time and space, and frequently having significant changes in geomorphology and biological communities and processes . . . Loss of vegetative cover will create a setting that can have pronounced effects on flow dynamics, soil erosion and sediment deposition.”
Mitigation Reduces Hazard
In the LANL Site-wide EIS Record of Decision (September 1999), DOE committed to develop by December 1999 a preliminary program plan for comprehensive wildfire mitigation, including construction and maintenance of strategic fire roads and fire breaks, creation of defensible space surrounding key facilities, and active forest management to reduce fuel loadings. The Mitigation Action Plan, October 1999, states that the wildfire hazard at LANL was currently being reduced by thinning trees, maintaining fire roads and fire breaks, and other measures.
The Los Alamos Area Office was about to issue a Wildfire Management Plan Programmatic EA for preapproval review when the fire forced a change in plans. That EA is now being revised in light of the fire and will be issued shortly.
An interagency Burned Area Emergency Rehabilitation Team is working onsite to address immediate recovery actions. The Team has a NEPA unit, which has initiated an informal consultation with the Council on Environmental Quality regarding emergency NEPA procedures.
According to John Ordaz, Defense Programs project manager for the LANL Site-wide EIS, the NEPA process worked well in this case because the EIS team “was determined from the outset to prepare a useful document.” When the EIS team heard the concerns about wildfire at the public hearing, “we investigated the claims and the science behind the analysis.” Then the team found ways to reduce the fire load for the high risk areas. “It was the dedication of the EIS team that got the mitigations implemented,” Mr. Ordaz said.