EA-0812; Environmental Assessment for Interim Storage of Plutonium Components at Pantex and

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DOE/EA-0812
Environmental Assessment for Interim Storage of Plutonium Components at Pantex
and
Department of Energy Response to Comments Received from the State of Texas
Volume I
January 1994
U.S. Department of Energy
Albuquerque Operations Office
Amarillo Area Office
Pantex Plant
P.O. Box 30030
Amarillo, Texas 79120
ABBREVIATIONS
ft foot (feet)
ft/s feet per second
ft/s2 feet per second per second
gpm gallons per minute
in/hr inch per hour
ksi kilopounds per square inch
km kilometer
lb(s) pound(s)
mg milligram
mg/L milligram per Liter
mi mile
uCi microCurie
uCi/m2 microCuries per square meter
mph miles per hour
mrem millirem
pH (pouvoir hydrogine) - term to describe the acidity or alkalinity of a solution
psi pounds per square inch
psf pounds per square foot
rem Roentgen equivalent man
U.S. United States
yr year

Section I Environmental Assessments

EXECUTIVE SUMMARY

The primary mission of the Department of Energy Pantex Plant is the assembly and disassembly
of nuclear weapons. Historically, weapons were returned to the Pantex Plant from the Department
of Defense, disassembled, and the plutonium components (pits) were temporarily held (staged)
at the Pantex Plant until they were recycled to make new weapons. The Department is now
proposing to expand the capability to hold pits at Pantex and to store them there on an interim
basis pending implementation of decisions on long-term storage and disposition.
This Environmental Assessment evaluates the environmental impacts of additional interim storage
of pits at the Pantex Plant in Amarillo, Texas. Two factors combine to create the need for
increased interim storage of pits. First, pits are no longer being shipped to the Rocky Flats Plant
from Pantex to be recycled. This function was temporarily halted at the Rocky Flats Plant in 1989
to make improvements in the operations and facilities. In January 1992, pit recycle operations
were suspended indefinitely. Subsequently, the Department has decided to no longer maintain
a nuclear component production capability at Rocky Flats Plant.
Second, decisions to reduce the size of the nuclear weapons stockpile have accelerated the
accumulation of pits. These pits need to be stored on an interim basis until decisions can be
implemented on the long-term storage of plutonium required for national security purposes and
on the disposition of surplus plutonium. Long-term storage is being considered in the Nuclear
Weapons Complex Reconfiguration Programmatic Environmental Impact Statement, currently in
preparation. The Programmatic Environmental Impact Statement will analyze environmental
impacts, costs and technical considerations of the various alternatives. In addition, the
Department will prepare a new site-wide Environmental Impact Statement for the Pantex site to
update the information and analysis contained in the 1983 Pantex Site statement. This
Environmental Impact Statement will examine all aspects of current and foreseeable operations
at the Pantex Plant. This will include all dismantlement and storage-related issues at the Pantex
Plant.
In regard to the disposition of plutonium, on September 27, 1993, President Clinton established
an interagency task force to determine the disposition of plutonium surplus to national defense
requirements. This task force is being led by the National Security Council and the Office of
Science and Technology Policy. The Department is committed to prepare an EIS to underpin its
implementation of actions it proposes to take in conjunction with the task force recommendations
on the disposition of surplus plutonium.
The proposed action analyzed in this Environmental Assessment is to provide additional storage
beyond the present pit storage capacity (6,800 pits) for up to 20,000 pits for an interim time
period. The number of pits that could be held within each of the 18 Modified-Richmond
magazines (western portion of Zone 4) would increase from approximately 370 to a maximum of
440. In addition, each of the existing 42 Steel Arch Construction magazines, also located in the
western portion of Zone 4, could be used to hold up to 392 pits. The increase in storage capacity
for each Modified-Richmond magazine involves utilizing a multiple stacking configuration of the
pits within the magazine. Steel Arch Construction magazines have not been used previously for
holding pits, and the multiple stacking configuration has not been used previously in Steel Arch
Construction or Modified-Richmond magazines. Eighteen Modified-Richmond and 42 Steel Arch
Construction magazines (in either multiple- or single-layer storage configuration) could be used
for pit storage. However, some of these will continue to be used for assembled weapon and
component staging activities. The practice of segregating weapons from components will
continue. Pits stored on an interim basis will be segregated from other stored weapon
components.
The proposed action is immediately available, would not require new facility construction or
demolition of existing structures, and would result in negligible additional generation or
management of wastes. Environmental impacts of the proposed action from routine operations
would be limited to radiation exposure of workers which would be controlled, as currently is done,
with procedures and personnel monitoring to ensure that the Department of Energy's "As Low
As Reasonably Achievable" objectives are achieved and the current worker dose limits maintained.
Therefore, no adverse health effects among workers would be expected. There would be no
measurable increase in direct radiation above natural background radiation at the Pantex Plant
boundary. The potential for plutonium release from various types of accidents and abnormal
events (including aircraft crashes) was examined. The analysis concluded that the initiating
events were so improbable that they are not credible. Additionally, it was determined from the
analysis of potential accidents that no significant plutonium release would occur.
A number of alternatives to increased interim pit storage at the Pantex Plant were considered.
These included interim storage at other Department of Energy facilities (the Los Alamos National
Laboratory, the Savannah River Site, and the Hanford Plant) and Department of Defense sites
as well as a No-Action Alternative. None of the alternatives (alone or in combination) has been
shown to meet the programmatic objective to provide sufficient increased interim storage capacity
while continuing disassembly operations at the anticipated rate.
The No-Action Alternative does not meet the weapon disassembly goals in support of weapons
reduction initiatives and would negatively affect ongoing efforts by the Department of Defense to
streamline its operations and to meet its commitments to receive and store munitions and
equipment currently outside the continental United States. The benefits of totally dismantling the
weapon, eliminating the potential for accidental or unauthorized detonation and reducing the
number of highly attractive terrorist targets, would also not be realized.
For each of the other alternatives there would be additional costs, transportation requirements,
potential requirements for facility modifications (for pit storage, support structures or security
enhancements), and additional time would be required to establish the infrastructure in order to
implement interim storage at an alternative site. Impacts of the Proposed Action were found to
be limited to worker exposures to radiation. No environmental benefit would be gained in
packaging and shipping some or all of the pits to any other location for interim storage purposes
and there would be increased worker exposure due to the additional handling that would be
required.
The Department of Energy provided a Pre-Approval copy of the Environmental Assessment to the
State of Texas in Texas in December 1992. Subsequently, the State provided the Pre-Approval
Environmental Assessment to interested and affected members of the public. State and public
comments were submitted to the Department for consideration during February and March, 1993.
In response to these comments, the Department reviewed and revised the Environmental
Assessment, adding a Comment Response Document (See Volume I, Section II, Response to
Comments on the Pre-Approval Environmental Assessment Received From the State of Texas).
The revised Pre-Approval Environmental Assessment was issued on November 11, 1993.
The Department then held a public meeting on December 6, 1993 in Amarillo, Texas to review the
revised Environmental Assessment and Comment Response Document. Following the public
meeting, the Department accepted written comments beginning December 6, 1993 and
concluding December 20, 1993. The Environmental Assessment was expanded to include the
Department's response to the comments received during the two-week period (See Volume I,
YSection III, Response to Comments on the Revised Pre-Approval Environmental Assessment and
Public Meeting).

1.0 INTRODUCTION AND BACKGROUND

In three recent nuclear weapons policy declarations (September 27,
1991, January 28, 1992, and June 16, 1992), the United States'
initiated efforts to reduce its nuclear weapons arsenal. These
reductions, made possible by the end of the Cold War and the
associated changes in United States national security needs, were
defined and directed through joint Department of Energy/ Department
of Defense actions.  The Nuclear Weapons Stockpile Memoranda and
corresponding Planning and Production Documents direct the
retirement of, and establish retirement rates for, weapons held in
the custody of the Department of Defense.  The Department of Energy
establishes a schedule for the return and dismantlement of weapons
in support of these retirement rates.  The outcome of the three
policy declarations is the commitment to reduce the nuclear weapons
stockpile from more than 20,000 warheads to fewer than 10,000
warheads before the end of the century.  To meet this stockpile
reduction initiative, the Department of Energy has established a
goal of maintaining a disassembly rate of 2,000 weapons per year for
the near-term.  This level of activity at the Pantex Plant for
weapons disassembly would be similar to that experienced in the past
for all assembly/disassembly operations.
Historically, the Department of Energy's national security mission
has included the assembly and disassembly of nuclear weapons.  A
nuclear weapon is comprised of a physics package, containing special
nuclear material (i.e., plutonium or highly enriched uranium) and
other materials and components.  Most nuclear weapon physics
packages contain a primary assembly that consists of a detonator
system and a ball-shaped composite of either high explosive or
insensitive high explosive surrounding a component called a pit. 
The pit is comprised of a hermetically sealed metallic outer shell
and an inner shell of solid plutonium metal.
The primary mission of the Pantex Plant is the assembly and
disassembly of nuclear weapons. The Pantex Plant has conducted
these activities in a safe and responsible fashion for more than 40
years.  Newly assembled weapons are transported and transferred to
the Department of Defense for deployment.  Retired weapons are
returned to the Pantex Plant for disassembly.  The pits from the
disassembled weapons were typically staged at the Pantex Plant.
Until 1989, Pantex Plant activities were closely coupled to the
operations at the Rocky Flats Plant near Denver, Colorado.  Two of
the Rocky Flats Plant's primary missions were:  1) manufacture of
pits which were eventually transported to the Pantex Plant for
final assembly into nuclear weapons, and 2) receipt of pits from
the Pantex Plant from disassembled weapons for recovery,
reprocessing, and fabrication of the special nuclear material into
new pits.
In December 1989, plutonium processing and pit fabrication
operations at the Rocky Flats Plant were curtailed by the
Department of Energy pending resolution of safety and environmental
issues.  The Pantex Plant continued to disassemble weapons, but
shipments of pits from dismantled weapons between the Pantex Plant
and Rocky Flats Plant were suspended.  The pits from those weapons
were staged in Zone 4 for later shipment to the Rocky Flats Plant. 
The Department of Energy had anticipated that shipments of pits to
the Rocky Flats Plant would be reinitiated when processing
activities in support of new weapons programs were resumed. 
Efforts to restart plutonium processing operations continued until
January 1992 when they were terminated by the Department of Energy
because of reduced requirements for nuclear weapons production in
support of the national defense. Consequently, pits from weapons
disassembled at the Pantex Plant have been placed in interim
storage in Zone 4.
The activities necessary to carry out the Pantex assembly and
disassembly mission (including staging of pits) were analyzed in
the Final Environmental Impact Statement, Pantex Plant Site
(DOE/EIS-0098, October 1983).  The Department of Energy has
prepared this Environmental Assessment to focus on the proposed
activities necessary to accommodate the interim storage of the pits
from the weapons disassembled as a result of the arms reduction
commitments discussed above.  The Department also will prepare a
new site-wide environmental impact statement to update the 1983
document.

2.0 PURPOSE AND NEED FOR THE PROPOSED ACTION

The proposed action is to provide interim storage of pits removed
from nuclear weapons in response to recent nuclear weapons
reduction initiatives.  The proposed action is required to enable
these reductions, and it also maintains the benefits that accrue
from dismantling weapons, which is to eliminate the potential for
accidental or unauthorized detonation.  Further, it reduces the
number of highly attractive terrorist targets, and it permits more
cost-effective operations for the Department of Defense.
The proposed action analyzed in this document has evolved as a
result of recent developments in the areas of national security and
foreign policy.  As originally envisioned, the proposed action was
to provide additional storage for up to 20,000 pits at Pantex for
a period of approximately six to ten years.  The anticipated
duration of the interim storage was based on the December 1994
expected completion of the Department's Reconfiguration
Programmatic EIS, allowing  sufficient time to implement the
decision regarding the future nuclear weapons complex that would be
made on the basis of that Programmatic Environmental Impact
Statement.  lt was expected that one of the elements of the future
weapons complex would be a new long-term storage facility, to be
constructed within the six to ten year time frame.
President Clinton, on September 27, 1993 established an interagency
task force to determine the disposition of plutonium surplus to
national defense requirements.  This task force is being led by the
National Security Council and the Office of Science and Technology
Policy with the participation of the Arms Control and Disarmament
Agency, the Central Intelligence Agency, the Office of Management
and Budget, and the Departments of State, Defense and Energy.  The
public and certain foreign nations will also be invited to
participate in the task force.  The results and implementation of
its recommendations are likely to have significant impact on both
the number of pits requiring long-term storage, and the duration of
any storage period.  It is likely that a substantial majority of
the pits proposed to be stored at Pantex, which are surplus to the
nation's defense needs, will be affected by decisions resulting
from the work of the task force.  Because the task force was so
recently chartered, however, it is impossible to now predict the
timing of its recommendations or their implementation.
In addition to its participation in this task force, the Department
is conducting or will shortly commence the following National
Environmental Policy Act reviews which also will address the
storage of plutonium:
First, as noted above, the Reconfiguration Programmatic
Environmental Impact Statement is examining the alternatives for
the long-term storage of all Department of Energy owned plutonium. 
The alternatives being considered for long-term storage include
"no-action," which, if selected in the Record of Decision on that
Environmental Impact Statement, would continue the storage of the
pits at Pantex in the existing facilities.  Another alternative
being considered is to upgrade the existing facilities.  If this
alternative is selected in the Record of Decision, upgrades to the
existing storage facilities, including Pantex, would occur
following a likely additional project specific review under the
National Environmental Policy Act.  The final alternative under
consideration is the siting and construction of a new consolidated
________________________________________________
3 President Bush's remark's to the Nation from the Oval Office on September 27, 
  1991: "I am therefore directing that the United States eliminate its entire 
  worldwide inventory of ground-launched short-range, that is, threaten nuclear 
  weapons. We will bring home and destroy all of our nuclear artillery shells 
  and short-range ballistic missile warheads."
* Many of these land and sea-based warheads will be dismantled and distroyed.
  Those remaining will be secured in central areas where they would be available
  if necessary in a future crisis."
________________________________________________________________________________
long-term storage facility which, if selected in the Record of
Decision, would result in the pits stored at Pantex being moved to
that facility, at 1 of 5 candidate sites.  The Record of Decision
is expected to be issued in 1995.  It should be noted that the
Pantex site is among five sites under consideration for the
location of a new long-term storage facility.
Second, the Department is commencing the preparation of a new site-
wide Environmental Impact Statement for the Pantex site.  This
Environmental Impact Statement will examine all aspects of current
and foreseeable activities and operations of the Pantex Plant,
including all dismantlement and storage-related issues.  This
Environmental Impact Statement will include analysis of measures to
further mitigate the impacts of Pantex operations.  While the scope
of the Environmental Impact Statement cannot be defined precisely
until the public scoping process has been completed, the Department
of Energy expects that alternatives to the continued storage of
pits at Pantex will be considered.  This review will take 2-3 years
to complete.  The public will be invited to help both scope the
appropriate review and provide comments on the draft Environmental
Impact Statement when completed.
Third, the Department is committed to include in an Environmental
Impact Statement appropriate major federal actions it proposes to
take in conjunction with the task force on the disposition of
surplus plutonium.  This will help ensure meaningful public
involvement in the examination of alternative means of disposition.
The resolution of all these uncertainties and the preparation of
these documents will require time, making it less likely to site
and construct a new long-term storage facility on the schedule
previously indicated and which would have led to storage relief at
Pantex in six to ten years.  Because of the national security and
foreign policy considerations previously described, which
highlights the importance of the  continued disassembly of nuclear
weapons and the consequent interim storage of the fissile material
they contain, the Department cannot wait for these longer-term
programmatic decisions.  If the proposed action is not adopted,
shipment of nuclear weapons to Pantex for dismantlement will likely
cease in the first quarter of 1994 and actual dismantlement will
cease shortly thereafter, given the current disassembly rate.
Accordingly, the Department is proposing to provide storage for up
to 20,000 pits in the Pantex facility on an interim basis until the
longer-term decisions on storage/disposition are made and
implemented.  The Department is now contemplating that the new
site-wide Environmental Impact Statement for the Pantex site will
consider the environmental impacts for a period of 5-10 years
associated with continued operation of the Pantex Facility,
including storage.  The long-term decisions regarding the
storage/disposition of plutonium will be made following the
completion of the Reconfiguration Programmatic Environmental Impact
Statement now scheduled for late 1994, and the work of the task
force on plutonium disposition.  These decisions will be made on
the basis of the various activities and analyses described above.
The proposed action is consistent with storage activities currently
conducted at the Pantex Plant site, but will result in:
 1.   An increase in pit storage capacity, from 6,800 to a
maximum of 20,000;
___________________________
 4.   The 6,800 value is based on the maximum packing configuration in Modified-
  Richmond magazines. This configuration is not currently the operationally
  preferred configuration, but serves to provide the most conservative
  bounding parameters for the safety and environmental analyses.
__________________________________________________________________________
 2.   A reallocation of the number and type of magazines to be
      employed for interim storage; and
 3.   A change in the historical staging/storage configuration
      to allow increased operational flexibility and efficiency
      (multiple stacking);
Unless interim storage capacity is increased in the near-term, the
Department of Energy will likely be forced to cease disassembly
activities in the first quarter of 1994, given the current
disassembly rate.  (Figure 2.1).
Figure (Page 2-4 Figure 2.1 Near-Term Projected Storage Capacity Requirements)

3.0 PROPOSED ACTION

The proposed action is to provide interim storage for up to 20,000
pits in the Pantex facility until decisions can be implemented on
the long-term storage of plutonium required for national security
purposes and on the disposition of surplus plutonium. These
decisions will be made on the basis of the various activities and
analyses described in Section 2.0.
Implementation of the proposed action requires an increase in the
interim storage capacity of the Pantex Plant. This increase in
capacity would involve an increase in both the number of storage
magazines allocated for storing pits and the number of pits stored
within each magazine. Currently, up to 6,800 pits could be held in
18 Modified-Richmond magazines located in the western portion of
Zone 4 (Figures 3.1 and 3.5). However, to facilitate measures to
reduce worker exposures to radiation during safeguards and security
activities, an alternative storage configuration (Figure 3.2) is
being employed. This storage configuration permits storage of a
nominal 6,000 pits.
Under the proposed action, the number of pits held within each of
the 18 Modified-Richmond magazines would increase from 378 pits to
a maximum of 440. This is accomplished by using a horizontal
palletized multiple stacking configuration. In addition, each of
the existing 42 Steel Arch Construction magazines also located in
the western portion of Zone 4 could be used to hold up to 384 or
392 pits, using the single-layer vertical or horizontal palletized
multiple stacking configurations respectively. Steel Arch
Construction magazines have not been used previously for holding
pits, and the horizontal palletized multiple stacking configuration
has not been utilized previously in either Modified-Richmond or
Steel Arch Construction magazines. (See Table 3-1.) Although
designation of 18 Modified-Richmond and 42 Steel Arch Construction
magazines for storage (in either multiple or single-layer storage
configuration) would provide for more than 20,000 storage spaces,
this designation allows for operational flexibility and facilitates
security and safeguards by not specifying specific magazines.
Furthermore, some Steel Arch Construction magazines would be
reserved for assembled weapon and component staging activities that
have historically taken place, and will continue to take place, in
these facilities. The practice of segregating weapons from
components would continue, and interim stored pits would be
segregated from other staged weapon components.
The Department of Energy Orders and procedures for ensuring safe
and secure storage of the pits would continue to be followed
rigorously. The majority of the pits in Zone 4 will continue to be
packaged in AL-R8 containers (RFE-8801, 1988), but other approved
containers such as Type B containers may be used. Type B
containers are certified for off-site transportation of pits under
the Department of Energy performance criteria adopted from Title 10
Code of Federal Regulations Part 71 whereas the AL-R8 container is
not. While both container types adequately meet the design safety
requirements necessary for interim storage of plutonium components,
pits packaged in the AL-R8 container would have to be repackaged
into a certified shipping container for shipment off-site. The AL-
R8 container utilizes the pit structure for containment whereas a
Type B certified shipping container has two independent seals for
containment. The AL-R8 container is constructed of 18-gauge carbon
steel, and the container is internally lined with Celotex-
fiberboard to provide impact and thermal protection wherein the pit
is suspended within the fiberboard using a steel clamping device.
The outer containment of a Type B shipping container is 16-gauge
stainless steel and the inner containment drum (within which the
__________________
5 The steel Arch Construction magazine operational limit for pits
stored in the vertical single-layer configuration. actual maximum
packed capacity of 406 pits/Steel Arch Construction magazine will
not be considered for use.
_____________________________________________________________________________________________________________
pit is located) is constructed of 12-gauge stainless steel.
Celotex- packaging material is used between the inner and outer
containment drums and also around the pit inside the inner
containment drum.
Table (Page 3-2 Table 3-1 - Pit Storage Capacity)
In either type of magazine, the pit, in its approved container,
would be stored in one of two configurations: multiple stacking of
containers placed horizontally on pallets (Figures 3.3 and 3.4),
and/or a single layer of containers placed vertically on the floor
(Figures 3.5 and 3.6). The pallets for the multiple stacking
configuration have been designed to ensure structural integrity
and stability. Final Safety Analysis Report, Pantex Plant Zone 4
Magazines (Issue D, April 1993) concluded that the multiple
stacking configuration would be stable in a maximum credible
earthquake scenario. These two configurations represent the
bounding cases for the numbers of pits that would be held in a
single Modified-Richmond or Steel Arch Construction magazine.
Variations and/or a combination of these arrangements may be used.
Individual pit containers could rest on casters rather than on the
concrete floor of magazines, and aisles may also be used. This
would facilitate inventory operations, ensure worker safety, and
accommodate operational needs.
An electric forklift with shielding for radiation protection would
be used for storage, retrieval, and inventory operations for
palletized stacking configurations or individual container
handling. The shielded forklift will have a passive guidance
system (e.g., rail guides, wire guides, etc.) for the palletized
stacking configuration that will prevent the forklift from veering
from the aisle. The forklift will be equipped with a lateral
motion, turret-type fork assembly that allows palletized pit
containers to be stacked and retrieved without having the forklift
itself turn. The shielded forklift system is an example of the
emphasis at the Pantex Plant to reduce and then maintain worker
radiation exposure. Efforts are currently under way to develop
Automated Guided Vehicles that could be used both to place pits in
magazines and to assist in taking inventories using barcode
readers. The use of Automated Guided Vehicles could further reduce
worker exposure to external radiation associated with pit interim
storage and inventory activities. Only the shielded forklift
operator will be inside the magazine during the operations.
Shielding on the forklift should provide a dose reduction factor of
at least 20 over current inventory methods.
Implementation of the proposed action would not involve new
facility construction, demolition, additional generation or
management of wastes, uncontained plutonium handling or processing,
long-term or permanent storage, or disposal of plutonium components
at the Pantex Plant.
Figure (Page 3-3 Figure 3.1 - Layout of Zone 4 West and 18 Modified-Richmond Magazines)
Figure (Page 3-4 Figure 3.2 - Modified-Richmond Magazine Vertical Single-Layer Configuration)
Figure (Page 3-5 Figure 3.3 - Modified-Richmond Magazine Proposed Horizontal Palletized Multiple Stacking Configuration)
Figure (Page 3-6 Figure 3.4 - Steel Arch Construction Magazine Proposed Horizontal Palletized Multiple Stacking Configuration)
Figure (Page 3-7 Figure 3.5 - Modified-Richmond Magazine Vertical Single-Layer Configuration)
Figure (Page 3-8 Figure 3.6 - Steel Arch Construction Magazine Vertical Single-Layer Configuration)

4.0 ALTERNATIVES TO THE PROPOSED ACTION

Alternatives to the Proposed Action are described in the following
subsections.  None of the alternatives have been shown to meet the
programmatic goal of providing sufficient increased interim storage
capacity for pits while continuing disassembly operations at the
anticipated rate.  Also none would meet the other programmatic
objective; namely, an approach that is timely, cost-effective, and
utilizes to the maximum extent practicable existing facilities and
infrastructure taking into account protection of the environment
along with worker and public's health and safety.  These
alternatives include consideration of Department of Defense
installations and assessing availability of storage facilities at
Department of Energy facilities such as the Los Alamos National
Laboratory, the Savannah River Site, and the Hanford Plant.  The
No-Action Alternative does not meet the weapons disassembly goals
in support of weapons reduction initiatives.  For the other
alternatives, in each case there were additional costs,
transportation requirements, and facility modifications or
infrastructure requirements that precluded the alternatives
availability to meet the programmatic goal.  The only potential
environmental impacts associated with implementation of the
proposed action are worker exposures.  There is no environmental
benefit while radiation exposures could increase as a result of
packaging and shipping some or all of the pits to any other
location for interim storage purposes.  Table 4-1 compares the
proposed action to the alternatives described below.

4.1 No-Action

The No-Action Alternative would preserve the present practice of
receiving and disassembling weapons and the interim storage of
plutonium components in the 18 Modified-Richmond magazines located
in Zone 4. Only configurations involving a single layer of
vertical containers would be utilized. These configurations are
bounded by the maximum packing arrangement discussed in Section 3
and illustrated in Figure 3.5. The capacity of this alternative
would provide interim storage for 6,800 pits. Actual best
management practice to facilitate required safeguards and security
activities and reduce worker exposure to radiation could dictate
use of other storage configurations that would provide less pit
storage capacity. One such configuration is shown in Figure 3.2
and allows for interim storage of a nominal 6,000 pits. Once
capacity is reached, dismantlement activities at Pantex would
cease. In order for weapon dismantlement to resume, additional pit
storage facilities would have to be identified, approved, and made
operational. In addition, the weapons already in Department of
Energy custody at the Pantex Plant would remain staged in Zone 4,
and weapons in Department of Defense custody would remain at
Department of Defense facilities. This particular result,
deferring dismantlement and holding weapons in Department of
Defense facilities, is not as sound as continued dismantlement,
principally, because it maintains the potential for accidental or
unauthorized detonations; and it does not reduce the number of
highly attractive terrorist targets. Additionally, deferring
dismantlement and holding weapons in Department of Defense
facilities forecloses opportunities for streamlining Department of
Defense operations. The Army and the Navy would be forced to
maintain nuclear weapons storage capacity currently planned for
alternative uses or scheduled to be closed. In the case of the
Army, nuclear weapons storage capacity slated to be used for the
storage of conventional munitions and equipment returning from
Europe and the Persian Gulf would be required to be maintained for
nuclear weapons storage. This change in plans would cost the Army
approximately $28 million per year beginning in July 1995, the date
beyond which Army nuclear depot operations was not planned. For
________________________
6 The 6800 value is based on the maximum packing configuration. This configuration is not currently
the operationally preferred configuration, but serves to provide the most conservative bounding
parameters for the safety and environmental analysis.
_________________________________________________________________________________________________
the Navy, holding weapons in lieu of dismantlement will mean
postponement of the closure of a weapons storage facility currently
slated for September, 1994 at a cost of $21 million per year. Also
deferring dismantlement and holding weapons in Department of
Defense facilities will affect current planning regarding actions
to be taken to meet START I and START II objectives. Specifically,
Air Force Material Command would have to exercise an existing
Memorandum of Agreement with Air Combat Command to convert an
existing weapons storage area into a weapons storage depot. This
conversion can be done at small cost. The only significant cost to
the Air Force, which cannot be quantified at this time, would be
the cost of relocating the munitions currently stored in this
facility.
The START accords, while not yet ratified, represent the direction
the past and present United States leadership wishes to take with
regards to arms control. This intent has been further codified
with the January 19, 1993 issuance of a Nuclear Weapons Stockpile
Plan. In this Plan, only those stockpile levels which support the
intent of the START accords were approved. A new stockpile plan is
currently in the final stages of development. This Plan is slated
for submission for the President's approval late 1993. This Plan
also complies with the stockpile levels specified by the START
accords.

4.2 Combination of Proposed Action Storage at Pantex with Storage at Other Department of Energy Sites

Potential pit storage capability has been identified at three
Department of Energy sites: the Savannah River Site, the Los
Alamos National Laboratory, and the Hanford Plant. The Rocky Flats
Plant was not considered because there is no additional storage
space for pits. Because sufficient pit storage capacity at these
three sites would not provide the needed capacity in a timely
manner, this alternative would require utilizing the proposed
storage configuration and facilities for near-term needs at the
Pantex Plant. The Department of Energy would need to further
evaluate use of existing or potential pit storage capacity at these
other Department of Energy sites. If such evaluation demonstrated
that decentralized interim pit storage would provide additional
environmental and programmatic benefit, actions to provide funding,
modify facilities (if required), conduct safety evaluations, etc.,
would have to be completed before shipment of pits to the other
Department of Energy site(s).
The following is a brief description of relevant features of the
Savannah River Site, the Los Alamos National Laboratory, and the
Hanford Plant:
The Savannah River Site, located near Aiken, South Carolina,
has five vaults that have the capacity to store plutonium.
The 235-F and 247-F vaults and the Plutonium Storage Facility
are able to store pits in AL-R8 storage containers. They
could accommodate about 1,100 AL-R8 pit storage containers.
The 247-F vault is expected to become available later in
Fiscal Year 1993 or early Fiscal Year 1994. The Plutonium
Storage Facility is expected to become operational in Fiscal
Year 1995. Currently, two vaults (309 and 410) are used to
store in-process plutonium in cans and five-gallon canisters.
The 309 and 410 vaults do not have the drum storage capability
to store pits. While some of these facilities may be suitable
for pit storage, the Savannah River Site has various
quantities of plutonium compounds within its own processing
facilities that will be stored in the aforementioned vaults.
The Los Alamos National Laboratory is located in Los Alamos,
New Mexico. Pits have been stored at TA-41 and TA-55. TA-55
is at approximately 90 percent capacity and over committed for
Los Alamos National Laboratory's stated pit storage needs.
The total storage capacity can accommodate approximately 60
pits. The facility at TA-41 is inactive because it does not
meet current Department of Energy requirements for
environment, safety and health, security, and conduct of
operations. Furthermore, Los Alamos National Laboratory's
programmatic requirements did not justify the costs required
to make needed changes to maintain TA-41. A third facility,
the Nuclear Materials Storage Facility which is under
construction, is not operational. If funding is provided by
the Department of Energy, this facility could be operational
in 1997 and with current planned design modifications could
provide storage for up to 200 pits.
The Hanford Plant is located in south-central Washington
State, near the city of Richland. The primary mission at the
Hanford Plant is environmental restoration. Several studies
have considered pit storage capabilities for the Hanford
Plant. Special Nuclear Material is stored in vaults and
vault-type rooms located within the Plutonium Finishing Plant.
Many of the storage positions located in these areas are not
suitable for pit storage because they are configured to accept
smaller storage containers. Facility enhancements to maximize
pit storage within the Plutonium Finishing Plant were
estimated to cost approximately $7 million. These
modifications would allow suitable storage of approximately
3,000 pits, some in their shipping containers and others in
storage containers. Additional storage space is available
within the Fuel and Materials Examination Facility.
Construction of this facility was completed in 1984 and was
intended to support the Liquid Metal Fast Breeder Reactor
Program. However, it has not yet been involved in any hot-
cell operations or any plutonium processing operations. The
Fuel and Materials Examination Facility consists of six
levels, comprised of process cells, rooms, and one Special
Nuclear Material vault. The vault, one process cell, and four
other rooms have been evaluated for pit storage. It is
estimated that more than 7,000 pits could be stored if
appropriate modifications were made to these areas. Facility
modifications include plugging cell penetrations, moving
doors, installing vault doors, and electronic equipment.
These modifications were estimated in 1989 to cost
approximately $20 million. The nuclear weapons complex
mission at the Hanford Plant was terminated by the Department
of Energy in 1989. The site was transitioned to the Office of
Environmental Restoration and Waste Management and dedicated
to environmental restoration activities. Given the
termination of the defense mission and the commitment of
Department of Energy to clean up of the site, the
reintroduction of a Defense Programs mission would not be
reasonable or appropriate.
The Rocky Flats Plant is not included in this alternative
because there is no additional storage capacity for pits
received from other sites. The Rocky Flats Plant currently
stores pits that were awaiting reprocessing when operations
were curtailed. The Rocky Flats Plant is consolidating all
pits and other Special Nuclear Material from Buildings 991 and
996 tunnel (Corridor C) and other plant locations to vault-
type storage in Building 371. This action is necessary due to
facility aging, the structural uncertainties of Buildings 991
and 996, and a desire to reduce the safeguards and security
requirements for other portions of the plant where Special
Nuclear Material is currently stored. Special Nuclear
Material would be consolidated for interim storage pending the
implementation of the Record of Decision of the Nuclear
Weapons Complex Reconfiguration Programmatic Environmental
Impact Statement. Capacity limits in Building 371 would be
reached when all Special Nuclear Material at the Rocky Flats
Plant has been consolidated.
In summary, this alternative to the proposed action considers the
possibility of combining the storage capacity at Pantex with
storage capacity at other Department of Energy sites in the near-
term. Additional requirements for environmental, safety, and pre-
operational documentation, staffing, and training would delay
making these facilities available in the near-term.
In addition, the following would have to be considered:
a) The nuclear weapons complex is undergoing numerous
changes to include environmental restoration and
consolidation of its nuclear material to facilitate
restoration and to enhance safeguards and security. The
complex has limited storage capacity, and each site's
capability to store material (pits and Special Nuclear
Material in various other forms) must be maximized.
There are many ongoing programs under which the storage
capability at the above sites is currently being
assessed. Consolidation of material and subsequent
inventory reduction at the Rocky Flats Plant, reduction
of the inventory at Lawrence Livermore National
Laboratory, and clean out of processing canyons at the
Savannah River Site are a few that vie for the existing
or potential storage capacity at the Savannah River Site,
the Los Alamos National Laboratory, and the Hanford
Plant. Cleanup of most sites will increase the amount of
material to be stored. Efficient use of resources would
require evaluation of competing storage requirements for
other plutonium material at the candidate site as well as
from other sites before a decision can be made to ship
pits for interim storage. For example, uniqueness of
facilities makes it inappropriate to send other Special
Nuclear Material forms (e.g., plutonium oxide) to Pantex
for storage where currently only pits can be stored
safely. Likewise, storing pits at a facility designed to
accommodate other Special Nuclear Material forms would be
prudent only if the benefits derived justify such use.
b) Interim storage of pits would be subject to subsequent
Department of Energy complex-wide evaluations regarding
long-term storage or disposition of plutonium surplus to
national security needs. These evaluations are being
pursued in the ongoing Nuclear Weapons Complex
Reconfiguration Programmatic Environmental Impact
Statement activities, implementation actions derived from
the task force on the disposition of surplus plutonium,
and the new site-wide Environmental Impact Statement for
the Pantex site.
c) On the basis of the analyses presented in this
Environmental Assessment, the environmental impacts of
the proposed action were determined to be limited
principally to radiation exposure of workers. This
suggests that no environmental benefit would be derived
by storing pits at up to four separate facilities (the
Pantex Plant, the Savannah River Site, the Los Alamos
National Laboratory, and the Hanford Plant).
Decentralization of storage could effect a net increase
in the expected radiological worker exposure over the
proposed action by reducing the efficiency afforded in a
large scale interim storage operation versus several
smaller scale storage operations. Additional personnel
exposure would be expected if the pits were packaged in
containers (Type B) certified for shipment and then
repackaged for storage in the more readily available and
more inexpensive AL-R8 containers, which are suitable for
storage but not certified for shipping. The exposure
from the repackaging operation is estimated to range from
0.014 to 0.051 person-rem per container for robotic and
_______________________
7 The type B container is certified for off-site transportation of pits under the Department of Energy
performance criteria adopted from Nuclear Regulatory Commission criteria found in Title 10 Code of
Federal Regulations Part 71 whereas the AL-R8 container is not so certified.
_____________________________________________________________________________________________________
manual repackaging respectively. Therefore, total dose
to repackage 2,000 pit containers, a year's work of
dismantlement, would range from 28 to 102 person-rem
total cumulative dose. This additional dose could be
avoided if pits were stored in the Type B shipping
container. A sufficient inventory of Type B containers
should be able to be procured/purchased and available for
use as storage containers in 1995.

4.3 Supplement No-Action Alternative Storage Capacity with Storage at Other Department of Energy Sites

This alternative is to supplement the No-Action Alternative at
Pantex with storage at the Savannah River Site, the Los Alamos
National Laboratory, and the Hanford Plant.  The existing capacity
at the Pantex Plant would be reached between during the first
quarter 1994.  Assuming that a total of approximately 1,100 pits
could be stored at the Savannah River Site in the near-term,
capacity at the Pantex Plant and the Savannah River Site would be
approximately 7,100 to 7,900.  This would result in a storage
deficit of approximately one year, assuming disassembly rates that
met stockpile reduction initiatives (see Figure 4.1).  Disassembly
would have to cease until other interim or a permanent storage
facility could be made available.  Because of the reasons stated in
Section 4.2 above, and because these facilities must be available
even earlier for this alternative, it cannot be assured that this
alternative could  meet the need for near-term interim storage.

4.4 Interim Storage at a Department of Defense Facility

As an alternative to the Proposed Action, interim storage of pits
at a Department of Defense facility was assessed.  Candidate sites
were identified and then the analysis focused on potential impacts,
timing, and resource requirements.  Department of Energy staff has
been working with the staff of the Department of Defense/Department
of Energy Nuclear Weapons Council to consider the feasibility and
practicality of interim storage at a Department of Defense
facility.  The potential for retention of weapons by Department of
Defense, instead of dismantlement and the required storage of pits,
is discussed as part of the No Action Alternative.
Background
The Department of Defense is in the process of restructuring its
forces to reflect troop reductions and base closures.  Some
Department of Defense bases are being configured to accommodate
only conventional forces and their weapons, which are being moved
from overseas bases and United States facilities designated for
closure.  The requirement for additional continental United States
storage capacity at Department of Defense sites is further
complicated by consolidation of active nuclear weapon storage and
the backlog of retired weapons.  Several factors were considered
for identifying potential candidate interim storage sites at
Department of Defense facilities.  To be considered as a candidate
for an alternative interim storage site for pits, a Department of
Defense site must:
      1)    have existing storage facilities that meet all Department
            of Energy Special Nuclear Material storage requirements
            with minimal modification; and
      2)    offer potential for transfer to or sharing of the site
            with Department of Energy.  (If the site is to be shared,
            the Department of Defense mission should be compatible
            with the Department of Energy's mission for interim
            storage of pits.)
A preliminary candidate list of potentially available Department of
Defense storage facilities was prepared by the Department of
Defense.  As a matter of Department of Defense policy, the presence
of nuclear weapons at specific sites cannot be confirmed or denied
for security reasons.  Therefore, a discussion of specific
Department of Defense sites is not presented in this document.  The
facilities fall into the following categories:
      .     active Department of Defense nuclear weapons storage
            facilities;
      .     inactive (currently or in the near future) Department of
            Defense nuclear weapons storage facilities; and
      .     inactive (currently or in the near future) conventional
            weapon storage facilities.
The following information provides an overview of potential
environmental and operational impacts, the time required for
implementation, and resource and cost requirements for interim
storage of pits at a Department of Defense facility.  These
requirements would be dependent on the facility category.
Environmental and Operational Impacts
Environmental impacts from use of any Department of Defense
facility for interim storage are similar to  those identified for
the Proposed Action.  However, additional personnel radiation
exposure would be expected if the pits were packaged in containers
certified9 (Type B) for shipment and then repackaged for storage in
the more readily available and more inexpensive AL-R8 containers,
which are suitable for storage but not certified for shipping.  The
exposure from the repackaging operation is estimated to range from
0.014 to 0.051 person-rem per container for robotic and manual
repackaging10 respectively.  Therefore, total dose to repackage
2,000 pit containers, a year's worth of dismantlement, would range
from 28 to 102 person-rem total cumulative dose.  This additional
dose could be avoided if pits were stored in the Type B shipping
container.  A sufficient inventory of Type B containers should be
able to be procured/purchased and available for use as storage
containers in 1995.
_______________________
9  It is not practical to consider Department of Defence sites that do not have existing munitions 
   storage facilities capable of being modified and upgraded to meet Department of Energy storage requirements
   for Special Nuclear Materials, because of the time needed to construct those facilities, the additional
   environmental impacts, and the extra cost compared to that needed to modify existing facilities.
10 Only one facility has been identified in the Department of Defense draft candidate list.
11 Active conventional weapons storage facilities are not reasonable because the Department of Defence
   mission would not be compatible with Department of Energy's mission.
________________________________________________________________________________________________________________
There is potential for some added environmental impacts at the
candidate Department of Defense sites for construction or facility
modification that could be required to support safety, security and
operational requirements.  The magnitude of these impacts would
depend on the extent of the modification or construction required. 
For example, impacts from the construction of high security
fencing, guard towers, and barriers would be expected if an
inactive conventional weapons storage facilities were to be
selected.  Alternatively, minimal impacts would be expected from
the utilization of the existing facilities at an active nuclear
weapons storage facility.
Transportation of the pits to a Department of Defense facility
would result in minor added energy costs and some added, although
minimal, risk inherent in the transportation of Special Nuclear
Material.  Pit containers must be transported by Safe-Secure
Trailer.  Using an authorized convoy configuration, 45 trips would
be required per year to transport 2,000 pits annually from Pantex
to an alternative interim storage site.
Timing
Any proposal to use a portion of a site's capacity for interim
storage of pits would require negotiation of site-sharing or
transfer agreements for space and support accommodations consistent
with the Department of Defense mission and requirements for the
facility.  Since restructuring of Department of Defense forces and
base closures could take several years, not all the candidate sites
would be immediately available.  In addition, planning (including
National Environmental Policy Act requirements) and identification
of necessary modifications and acquisition of appropriate resources
would have to be completed, which would require additional time. 
Before any Department of Defense site could receive any pits, at a
minimum the following would need to be accomplished:
      1)    completed facility modifications (if required) for
            security (i.e., security fencing, vehicle barriers, guard
            towers, intrusion detection devices), support facilities
            (for shipping/receiving, repackaging, or surveillance
            inspection), or operations (i.e., shielded forklift, pit
            surveillance instrumentation);
      2)    acquisition of a trained and qualified staff to conduct
            interim storage operations; and
      3)    a validated readiness posture that would include safety
            analysis reports, operations procedures, training and
            qualification program.
An optimistic estimate of the timing required to set up interim
storage at a Department of Defense facility is illustrated in the
following timeline.
Active       Site Utilization                Equipment       Operations          
Nuclear      Decision-Making & Negotiation   Procurement &   Certification 
Weapons                                      Staffing 
Storage   |--------------------------------|---------------|--------------|
Facilities   2 years                         1 year          6 months
Inactive     Site Utilization                Modifications, Equipment                   Operations 
Nuclear      Decision-Making &               Procurement & Staffing                     Certification 
Weapons      Negotiation(14)   
Storage   |--------------------------------|------------------------------------------|---------------|
Facilities   2 years                         2 years                                     6 months
                                                 
Inactive      Site Utilization                Modifications, Equipment Procurement &          Operations 
Conventiona   Decision-Making &               Staffing                                       
l Weapons     Negotiation14                                                                   Certification 
Storage   |--------------------------------|-------------------------------------------------|--------------|
Facilities    2 years                         3 years                                         6 months
Resource Requirements and Cost
Resources and costs associated with use of the three Department of
Defense site categories (i.e., active nuclear weapons storage
facility, inactive nuclear weapons storage facilities, and inactive
conventional weapons storage facilities) were estimated.  Use of
such Department of Defense site categories provides a basis for the
assumptions used to estimate modification and operational
requirements necessary to permit interim pit storage.  Table 4-2
provides a breakdown of estimated costs (recurring as well as one-
time) for implementing interim storage at a Department of Defense
facility.
Environmental impacts (radiation dose) and costs related to using
a Department of Defense site would be minimized by using storage
facilities at an active nuclear weapons storage facilities and
storing the pits in the Type B shipping containers.  This option
could result in an estimated additional expenditure of $7.5 million
per year to conduct interim storage operations at a Department of
Defense site instead of at Pantex, slightly less than if AL-R8
storage containers are used.  These reduced impacts and costs would
be somewhat offset by the $36 million needed to purchase the extra
Type B containers to accommodate all of the pits during the period
of interim storage.  Additionally, a one-time cost of approximately
one million dollars for equipment necessary for monitoring,
surveillance and calibration would be required.  The one time costs
do not include the administrative costs associated with preparing
the necessary environmental, safety analysis and operational
procedures documentation nor the cost of training qualified staff.
In summary, implementation of this alternative instead of interim
storage at Pantex:
     .    offers no environmental benefit;
     .    is not as timely; and
     .    would cost more.
___________________________
12 Negotiations with Department of Defense regarding site utilization would involve formulation of appropriate
   memorandum of Understanding/Memorandum of Agreement. Decision-making regarding site utilization includes
   National Environmental Policy Act analysis and preliminary safety analysis considerations. Because the 
   National Environmental Policy Act analysis would have to be a jointly sponsored by Department of Energy and
   Department of Defence, the time required to coordinate completion of the analyses could be more lengthy.
13 Lower bound of $4 million assumes procurement of 2000 Type B Model HE-400A shipping containers (at $2,00 each),
   which would be used for transporting pits to interim or long-term storage. The upper bound of $40 million 
   assumes all 20,000 pits require Type B shipping containers for interim or long-term storage.
_________________________________________________________________________________________________________________

Table 4-1  -  Comparison of Proposed and Alternative Actions 
              Sectio Site for Storage/                        Capacity        Specific           Stacking        Comments 
              n      Potential Pit Capacity                   (meets          Facilities         Configuration 
                                                              goals) 
Proposed Act- 3.0    Pantex Plant        up to 20,000         Yes             - 18 Modified-     Multiple-        
ion                                                                           Richmond           Layer and/or 
                                                                              - up to 42 Steel   Single-Layer 
                                                                              Arch 
                                                                                Construction 
No-Action     4.1    Pantex Plant        *6,000-6,800         No              - 18 Modified-     Single-Layer    Does not meet 
                                                                              Richmond                           President's 
                                                                                                                 dismantlement 
                                                                                                                 objectives 
Combination of4.2    Pantex Plant        up to 20,000         Yes             - 18 Modified-     Proposed        . Resolution of 
Proposed Action                                                               Richmond           Action            programmatic & 
Storage at                               Depending on Availability            - up to 42 Steel   configuration     institutional 
Pantex with          of:                                                      Arch               at Pantex and     issues required. 
Storage at                                                                      Construction     configuration   . Requirement for 
other                Savannah River      1,100                                - Savannah River   at other          environmental, 
Department of        Hanford (Potential) 10,000+                              Site               sites TBD         safety, pre-
Energy Sites         Los Alamos (Potential) 200                               - Hanford                          operational 
                                                                              - Los Alamos                         documentation, & 
                                                                              National                             for modifications 
                                                                                Laboratory                         could delay 
                                                                                                                   availability in the 
                                                                                                                   near-term 
Supplement No-4.3    Pantex Plant        *6,000-6,800         No              - 18 Modified-     No-Action       Does not meet 
Action                                                                        Richmond           Alternative     President's weapons 
Alternative          Savannah River      1,100                                - Savannah River   configuration   reduction initiatives 
Storage with         Hanford (Potential) 10,000+                              Site               at Pantex and 
Storage at           Los Alamos (Potential) 200                               - Hanford          configuration 
other                                                                         - Los Alamos       at other 
Department of                                                                 National           sites TBD 
Energy sites                                                                    Laboratory 
Interim Storag4.4    Department of Defense                    No              None Currently     Not             No acceptable 
at a Department      Facilities                                               Available          Applicable      Department of Defense 
of Defense                                                                                                       facility is currently 
Facility                                                                                                         available for use as 
                                                                                                                 an interim storage 
                                                                                                                 facility
* 6,800 is the maximum magazine capacity value used to provide bounding parameters for the safety and environmental analyses. 
  The actual maximum magazine capacity could be less based on a best management practice decision to use an alternate (less
  dense) storage configuration (nominal 6,000).

Table 4-2 - Resource/Facility/Equipment Requirements and Estimated Costs (in millions)
               for Interim Storage at a Department of Defense Site.
                                                               Active Nuclear Weapons Storage                Inactive Nuclear Weapons Storage                      Inactive Conventional Weapons 
                                                               Facilities                                    Facilities                                            Storage Facilities 
                                                               AL-R8                            Type B       AL-R8 Storage                      Type B             AL-R8 Storage                   Type B  
                                                               Storage                          Shipping     Container                          Shipping           Container                       Shipping 
                                                               Container                        Container                                       Container                                          Container 
RECURRING COSTS 
Transportation                                                 2.4                              2.4          2.4                                2.4                2.4                             2.4 
Receiving & Packaging Operations                               0.1                              0            0.1                                0                  0.1                             0 
Operations                                                     4.1                              4.1          5.4                                5.4                5.4                             5.4 
Management/Administration                                      1.0                              1.0          1.0                                1.0                1.0                             1.0 
                                     TOTAL ANNUAL OPERATING COS7.60                             7.50         8.90                               8.80               8.90                            8.80 
ONE-TIME COSTS 
Modification                                                   0.0                              0.0          3.3                                3.3                16.5                            16.5 
Additional Type B Containers                                   4.0                              40.0         4.0                                40.0               4.0                             40.0 
Equipment                                                      1.0                              1.0          1.0                                1.0                1.0                             1.0 
                                     ONE-TIME "SET-UP" COSTS   5.00                             41.00        8.3                                44.3               21.5                            57.5
                                     (not including maintenance)
       Assumptions:
       General: - Dismantlement rate -- 2,000 weapons per year
                - 6,800 pits will remain at Pantex -- the current authorized capacity
       Modifications:
       -        No modifications needed for storage magazines
                - Modifications at inactive nuclear weapons storage facilities and Conventional Weapons Storage Facilities
                  to upgrade receiving and pit handling area (for repackaging and pit/container
                  surveillance program)
                - Active nuclear weapons storage facilities need no security upgrades and assumes that security personnel
                  provided by Department of Defense
                - Inactive nuclear weapons storage facilities needs refurbished or upgraded security systems
                - Type B Shipping Containers (model HE-400A) costed at $2,000 each
                - Inactive conventional weapons storage facilities needs completely new security system (fencing and
                  upgrades)
       Transportation:
       -        45 pits moved per Safe-Secure Trailer convoy trip; to move 2,000 pits requires 45 trips; cost per 1,000
                mile trip calculated at $54/mile
       Operations: - 100 persons needed to operate facility (includes security, materials handling, inventory, materials
                     control/accountability, surveillance testing, environment, safety, and health personnel,
                  other support) -- for Active Nuclear Weapons Storage Facility, assumes security personnel provide by
Department of Defense
                - Receiving/Packaging Operations assumes 3 persons needed
                - Equipment to be procured includes:
                  2 shielded forklifts, gamma spectrometer, radiation inspection/monitoring, equipment calibration
Figure 4.1 - Near-Term Projected Storage Capacity Requirements
Figure (Page 4-11 Figure 4.1 - Near-Term Projected Storage Capacity Requirements)

5.0 EXISTING ENVIRONMENT

The proposed action would involve use of existing facilities and no
new construction would be required.  Consequently, the description
of the existing environment is focused on those aspects of the
environment which potentially may be affected by the proposed
action.  Additional information on the Pantex Plant and its
existing environment may be found in the Final Environmental Impact
Statement, Pantex Plant Site (Department of Energy, 1983) and in
the Pantex Plant Site Environmental Report for Calendar Year 1990
(Mason & Hanger-Silas Mason Co., Inc., 1991).

5.1 Environment

The Pantex Plant is located in Carson County, about 17 miles
northeast of Amarillo, Texas, and central to the panhandle of Texas
(Figures 5.1 and 5.2).  There are 18 Modified-Richmond magazines
located in the western portion of Zone 4 of the Pantex Plant
(Figure 3.1) that are used for holding assembled weapons and other
components.  Assembled weapons and pits are not co-located in the
same magazine.  Each of the Modified-Richmond magazines consists of
an earth covered, concrete box-like structure (Figures 5.3 and
5.4).  To access these facilities, a forklift/tractor is used to
remove the concrete security blocks in front of each door.  These
blocks are in place whenever a magazine is not being accessed.  The
42 Steel Arch Construction magazines located in the western portion
of Zone 4 (Figure 5.5) are used for staging assembled weapons and
some components.  Currently, no pits are stored in any of the Steel
Arch Construction magazines.  Each of the Steel Arch Construction
magazines consists of an earth covered, steel-arch structure
(Figures 5.6 and 5.7).  Access to these facilities also requires a
forklift/tractor to remove concrete security blocks in front of
each door.  The only utility system that serves either the
Modified-Richmond or the Steel Arch Construction magazines is
electricity for security-related purposes.  Natural ventilation for
both types of magazines is provided through a steel pipe in the
ceiling of each magazine and small vents in the front wall on
either side of the magazine doors.
The Pantex Plant is situated in an area that has a semi-arid
continental climate.  Prevailing wind direction is from the south-
southwest with an average wind speed of 14 mph with occasional
gusts of up to 70 mph.  (Figure 5.8).  The Plant site is in
compliance with all applicable air emission standards.  The plant
lies within Zone 1 on the Seismic Risk Map.  This means that a Zone
1 earthquake may cause some minor damage (e.g., broken windows,
falling plaster, disturbance of tall objects).
The nearest major surface water source is the Canadian River,
approximately 14 miles north of the site.  The Canadian River flows
eastward into Lake Meredith, approximately 25 miles north of the
plant (Mason & Hanger-Silas Mason Co., Inc. 1991).  There are
several playas (natural land depressions) on the Plant site which
affect local drainage.  Surface runoff flows across the flat
terrain into these playas during periods of rainfall and forms
ephemeral lakes that dissipate through infiltration into the ground
or through evaporation enhanced by low humidity.  Playas 1, 2, and
3 (Figure 5.9) are on Department of Energy-owned property and
Playas 4 and 5 are on property leased by Department of Energy from
Texas Tech University.  Under unusual flooding conditions, storm
water runoff from the extreme northeastern section of the Pantex
Plant has the potential to flow off-site towards a playa north of
the site.  However, the northeastern section is mechanically pumped
to an on-site playa to retain and control potential off-site
runoff.  The United States Army Corps of Engineers has determined
that playas at the Pantex Plant site are "jurisdictional wetlands"
under Section 404 of the Clean Water Act and subject to the
provisions of the Act.  There are no areas on the Pantex Plant site
within a 100 year or 500 year floodplain.
There are two principal water-bearing units beneath the Pantex
Plant site and adjacent areas; the Ogallala Aquifer and the Dockum
Group Aquifer.  The unsaturated zone from the ground surface to the
Ogallala Aquifer consists of up to 460 feet of sediments.  A
perched water zone occurs discontinuously above the main zone of
saturation approximately in the middle of the Ogallala Formation. 
The city of Amarillo, Texas, has a municipal well field located
approximately 1 mile northeast of the Pantex Plant's well field. 
Both well fields access the Ogallala.  Water from the Ogallala
Aquifer is mixed with water from Lake Meredith and used for
municipal and industrial supplies in the area.  Water chemistry in
the Ogallala Aquifer and in the unsaturated zone beneath playas is
generally quite good, typically a mixed-cation/bicarbonate water
with 200-500 mg/L total dissolved solids and a pH of about 7.5. 
The Dockum Group Aquifer lies under the Ogallala Formation and is
believed to be semi-confined with respect to the overlying Ogallala
Aquifer.  The Dockum Group Aquifer, which has generally poor water
quality, supplies domestic and livestock wells south and southeast
of the Pantex Plant.

5.2 Radiological Environment

Radiation at the Pantex Plant consists of both natural background
radiation and radiation from plant operations.  Personnel exposure
to radiation at the Pantex Plant is maintained in accordance with
the principles of As Low As Reasonably Achievable.  The annual
whole body dose limit mandated by Federal regulations (52 Federal
Register 2822, January 27, 1987) and enforced by the Department of
Energy is 5 rem.  Time, distance and shielding are key elements in
the As Low As Reasonably Achievable program used to reduce
radiation exposure.  A personnel dosimetry program measures
radiation exposure and plant management uses the data to ensure
limits are not exceeded.
Collective worker dose from penetrating radiation for all Pantex
workers has varied over the years.  For instance, from January 1982
to December 1986, the annual collective dose averaged 115 person-
rem.  More recently, from January 1987 to December 1991, the annual
collective dose averaged 28 person-rem, a marked improvement. 
Naturally occurring radiation contributes to an average individual
dose of approximately 300 mrem/yr (National Council on Radiation
Protection, 1987).  Operations associated with the Pantex Plant
account for an average individual radiation worker dose of
approximately 70 mrem/yr additional dose.  The maximum radiation
dose to any Pantex Plant radiation worker was 0.53 rem in 1991
(Martin, J., 1992), well below the Pantex Plant administrative
operating limit of 1 rem/yr (established annually), and
substantially below the Federal limit of 5 rem/yr for occupational
workers.  The average radiation exposure for all other workers was
less than 10 mrem per person for calendar year 1991.  The
postulated dose to the maximally exposed off-site individual at the
fence line in 1990 was 0.16 mrem (Mason & Hanger-Silas Mason Co.,
Inc., 1991).  Such a dose is considered insignificant and no health
effects are expected.
Figure (Page 5-3 Figure 5.1 - Pantex Plant Location)
Figure 5.1 - Pantex Plant Location
Figure (Page 5-4 Figure 5.2 - Principal Features of the Pantex Plant)
Figure 5.2 - Principal Features of the Pantex Plant
Figure (Page 5-5 Figure 5.3 - Modified-Richmond Magazine Layout (Top View))
Figure 5.3 - Modified-Richmond Magazine Layout (Top View)
Figure (Page 5-6 Figure 5.4 - Modified-Richmond Magazine Layout (Front View))
Figure 5.4 - Modified-Richmond Magazine Layout (Front View)
(Security Blocks Omitted for Clarity)
Figure (Page 5-7 Figure 5.5 - Layout of Zone 4 West and 42 Steel Arch Construction Magazines)
Figure 5.5 - Layout of Zone 4 West and 42 Steel Arch Construction Magazines
Figure (Page 5-8 Figure 5.6 - Steel Arch Construction Magazine Layout (Top View))
Figure 5.6 - Steel Arch Construction Magazine Layout (Top View)
Figure (Page 5-9 Figure 5.7 - Steel Arch Construction Magazine Layout (Front View))
Figure 5.7 - Steel Arch Construction Magazine Layout (Front View)
(Security Barriers Omitted for Clarity)
Figure (Page 5-10 Figure 5.8 - Average Annual Wind Rose for Pantex Area)
Figure 5.8 - Average Annual Wind Rose for Pantex Area
Figure (Page 5-11 Figure 5.9 - Land Utilization Map - Pantex Plant Layout)
Figure 5.9 - Land Utilization Map - Pantex Plant Layout

6.0 ENVIRONMENTAL IMPACTS

6.1 Routine Operating Conditions

Potential environmental impacts associated with the Proposed Action
and the No-Action Alternative during routine operations are
discussed in the following subsections.
Because the proposed action would not require any construction
activities and because any facility modification would be inside
existing facilities, impacts to the natural environment would be
minimal.  Under normal operating conditions, there would be minor
releases of air pollutants associated with equipment engines and a
minor increase in particulate (dust) associated with operation of
forklifts used to move the security blocks and transport the pits
to the magazines.  There would be no impact to water resources,
flood plains, wetlands, cultural resources or other site features. 
Routine operations of the No-Action Alternative are similar to
those for the proposed action, differing only in the quantity of
materials held and number of magazines authorized for pit storage. 
The horizontal palletized multiple stacking configuration allows
the use of a forklift to lift and manipulate a group of containers
in a way that facilitates and speeds inspections.  In the vertical
configuration, the drums must be individually handled for the
inspection process.  This difference in how the drums must be
handled for inspection activities accounts for the difference in
inspection time between the No Action Alternative and the Proposed
Action configurations.

6.1.1 Radiological Impacts

The pit is comprised of a hermetically sealed metallic outer shell
and an inner shell of solid plutonium metal.  Each pit is clamped
in a holding fixture and inserted in a storage container comprised
of a carbon or stainless steel drum lined with a nominal three
inches of insulating and cushioning material.  No radiological
releases are associated with routine staging/ interim storage
operations for either the Proposed Action or the No-Action
Alternative.

6.1.1.1 Radiological Exposure to Workers Associated with the Proposed Action

Radiological impacts of routine operations would consist
principally of radiation exposure (neutron and gamma) to workers
involved in placement of pits into storage and periodic inspections
and inventories of pits stored on an interim basis.  Periodic
inspections and inventories are planned every 18 months, based upon
permanent variance to the prior requirement for a bimonthly
physical inventory for each Modified-Richmond or Steel Arch
Construction interim storage magazine.  Workers are required to
wear protective clothing (e.g., lead aprons), as directed by the
Radiation Safety Department at Pantex, when handling containerized
pits or when entering magazines.
Appendix F provides a detailed analysis for cumulative worker doses
attributed to the proposed interim storage activities.  A high
level of conservatism is used through dose rates and durations of
exposures; in addition, no credit is currently taken for personnel
shielding, i.e., lead aprons, remote inventorying equipment, or
other equipment shielding used or planned for future use.  Specific
assumptions used are tabulated in Table 6-1.

Table 6-1 - Assumptions Used to Calculate Radiological Exposure to
Workers Associated with the Proposed Action
Inventory Process:      
 Vertical Single-      Two people, 70 minutes for each side of a Modified-
Layer                  Richmond magazine.  Also assumes 140 minutes per Steel 
 Configuration         Arch Construction magazine.  Inventory of per each 
                       magazine once every 18 months (40 magazines/yr). 
 Horizontal            Two people, 45 minutes for each side of a Modified-
 Palletized            Richmond, and 1 person 90 minutes for each Steel Arch 
 Multiple Stacking     Construction magazine.  Inventory of each magazine once 
 Configuration         every 18 months (40 magazines/yr). 
Corrosion              100 percent container corrosion inspection for each 
Inspections:           magazine every 18 months (vertical single-layer 
                       configuration only).  Assume 1 minute per container for 
                       surveillance operations, 2 workers (100 percent 
                       inspection). 
Miscellaneous          One Steel Arch Construction magazine and one Modified-
Operations:            Richmond magazine opened every workday for 2 hours with 2 
                       workers. 
Magazine Capacities:   For the vertical single-layer configuration, 384 
                       containers is the operational maximum for Steel Arch 
                       Construction magazines and is used for both magazine types 
                       in the calculations.  For horizontal palletized stacking 
                       configuration, the maximum capacity is 440 containers in 
                       Modified-Richmond and 392 containers for Steel Arch 
                       Construction magazines. 
Radiation Dose         525 mrem/hr for the vertical single-layer configuration 
Rates:                 inventory process.  250 mrem/hr for the horizontal 
                       palletized stacking configuration inventory process.  60 
                       mrem/hr for corrosion inspection activities.  30 mrem/hr 
                       for miscellaneous operations.
The predicted cumulative worker doses are dependent on the amount
of americium in a plutonium pit, which varies with the age of a
pit.  Americium, the decay product of a plutonium isotope found in
weapons grade plutonium, reaches its maximum content in a pit in
approximately 73 years.  After this time, the americium content
decreases through  radioactive decay.  During decay, americium
emits alpha and gamma radiation.  The gamma radiation produced by
the decay of americium is more energetic than the radiation
produced by the plutonium present in fully aged pits (greater than
45 years from manufacture).  The resultant expected increase in
radiation field has been included in calculations presented in
Appendix F.  The exposure rates in the magazines will be at the
highest levels when the americium reaches equilibrium with the
plutonium, in approximately 45 years.  However, personnel exposure
will be mitigated through the use of the shielded forklift, the
self shielding attributed to the proposed horizontal storage and
use of personnel protective equipment such as lead aprons.  A more
detailed discussion of the effects of americium is found in the
Final Safety Analysis Report for Pantex Plant Zone 4 Magazines.
The annual collective dose attributed to the bounding case where
use of the single-layer vertical configuration is used, is
projected to be from 100 to 200 person-rem.  This range of exposure
is related to maintaining 60 magazines containing a total of up to
20,000 pits.  The annual collective dose attributed to the bounding
case where use of the horizontal palletized multiple stacking
configuration is used, is projected to be from 50 to 100 person-
rem.
In addition to individuals taking personal precautions such as the
mandatory use of lead aprons, shielded forklifts and Automated
Guided Vehicles (in the future) would be used both to place pits in
magazines and to assist in taking inventories using barcode
readers.  The use of such vehicles would further reduce worker
exposure to external radiation associated with pit storage and
inventory activities.  The typical individual worker radiation
doses would be maintained below the established Pantex annual
administrative operating limit (1 rem/yr for 1992).  Using a Latent
Cancer Fatality Rate of 4 to 5 fatal cancers per 10,000 person-rem,
a 1 rem exposure results in about 0.08 percent increased risk.  The
natural incidence of fatal cancer in the total population is about
20 percent.

6.1.1.2 Radiological Impacts Associated with the No-Action Alternative

A high level of conservatism is used as detailed in Appendix F.
Specific assumptions used to calculate the annual collective dose
for the No-Action Alternative are tabulated in Table 6-2.

Table 6-2 - Assumptions Used to Calculate Radiological Exposure to
Workers Associated with the No-Action Alternative
Inventory Process:
Vertical Single- Two people, 70 minutes for each side of a Modified-
Layer Richmond magazine. Inventory 2 sides each month.
Configuration Frequency is in accordance with current operations.
Corrosion 100 percent container corrosion inspection for each
Inspections: Modified-Richmond magazine every 18 months. Assume 1
minute per container for surveillance operations, 2
workers (100% inspection of 12 magazines/yr).
Miscellaneous One Modified-Richmond opened every workday for 2 hours
Operations: with 2 workers. Loading, unloading, use of forklifts,
continuous close exposure is limited.
Magazine Capacities: For the vertical single-layer configuration 384 containers
is used in the calculations.
Radiation Dose 525 mrem/hr for the vertical single-layer configuration
Rates: inventory process. 60 mrem/hr for corrosion inspection
activities. 30 mrem/hr for miscellaneous operations.
The annual collective dose attributed to the bounding case where
the use of single-layer vertical configuration is projected to be
from 50 to 100 person-rem. This range of exposure is related to
maintaining 18 Modified-Richmond magazines in the maximum packing
configuration containing up to 6,800 pits and is considered to be
conservative; for perspective, current dosimetry records for both
1991 and 1992 indicate that the collective dose rate for personnel
associated with all Zone 4 operations is less than 10 person-rem
per year. Lower individual and collective worker dose rates would
be expected from differing numbers of pits (i.e., use of preferred
storage configurations) in Zone 4 in comparison to the proposed
action.
The typical individual worker radiation doses would be maintained
below the established Pantex annual administrative operating limit
(1 rem/yr for 1992). Using a Latent Cancer Fatality Rate of 4 to
5 fatal cancers per 10,000 person-rem, a 1 rem exposure results in
about 0.08 percent increased risk. The natural incidence of fatal
cancer in the total population is about 20 percent. Under the No-
Action Alternative, the transportation of weapons for dismantlement
would diminish or cease entirely, eliminating the corresponding
potential exposure as documented in the Final Environmental Impact
Statement for the Pantex Plant.

6.1.2 Radiological Exposure to Public

For either the Proposed Action or the No-Action Alternative, the
expected level of penetrating radiation would result in no
measurable effect or exposure to an individual occupying a position
for an entire year at the nearest Pantex site boundary.  Such a
level would be indistinguishable from natural background radiation. 
No adverse health effects would be expected among the general
public as a result of normal operations from this action.

6.1.3 Cumulative Impacts for the Proposed Action

The only potential impact of the proposed action would be increased
worker radiation exposure.  For all operations at the Pantex Plant,
worker radiation doses are maintained below the annually
established Pantex administrative operating limit (1 rem/yr for
1992).  This limit is significantly below the Department of Energy
mandated limit of 5 rem/yr.  The Pantex personnel dosimetry program
measures radiation exposure, and plant management uses the data to
ensure limits are not exceeded.  Although the annual collective
worker dose may increase, the Federal individual worker exposure
limit would not be exceeded by the proposed action.

6.2 Abnormal Events/Accidents Associated with the Proposed Action

A series of potential accident initiating events were analyzed for
operations in Zone 4 (Department of Energy, 1992).  Impacts from
abnormal events having a probability greater than one in a million
(1 x 10-6), occurring as a result of implementing the proposed
action, are presented in this section (Department of Energy, 1988). 
The definitions of various events including an incredible event are
based upon a deliberate process of comparison between events having
various societal risks.  Ultimately the definition of an incredible
event is based upon the expectation that the event has a
sufficiently small likelihood of occurrence such that it need not
be further assessed.  In particular, it need not be further
assessed relative to other societal risks.
All events that are quantified are typically stated in efficiency
terms of annual probability of occurrence.  It is the standard
practice for consistency, efficiency and because it provides a
standard timeframe from which judgements on the acceptability of
risks originating from different events.
Facilities included in the analysis were the Modified-Richmond and
Steel Arch Construction magazines.  Results of these accidents are
summarized in Tables 6-3, 6-4A, and 6-4B.
Detailed discussions are provided in the appendices as follows:
      Screening of Potential Accident-Initiating Events Appendix A
      Blast Calculations                                Appendix B
      Structural Analysis                               Appendix C
      Forklift Operational Analysis                     Appendix D
      Aircraft Hazard Analysis                          Appendix E

6.2.1 Screening of Potential Accident Initiating Events

A list of potential accident-initiating events was prepared and a
qualitative assessment made to eliminate from further consideration
any event that posed little or no hazard to the magazines or their
contents.  This list and a brief statement of findings from the
assessment are provided in Appendix A.  Events that required a more
structured assessment were those initiated by earthquakes, external
explosions, missiles, tornados, forklift accident and aircraft
crash.

6.2.2 Potential Blast Hazards

An analysis was made of the effects that blasts from explosions
occurring in nearby facilities might have on the interim storage
facilities or their contents.  This analysis is described in
Appendix B.  Department of Energy determined that missiles could be
generated by a high explosive blast that could reach the magazines. 
The consequences, as described in Appendix C, were such that the
magazines and their contents would not be affected.

6.2.3 Structural Analysis

An analysis (summarized at Appendix C) was made of the effect
earthquakes would have on the magazines, and Department of Energy
concluded that no significant effect would occur.  An analysis was
also made of the effect of tornados and missiles propelled by
tornados or explosions on the magazines.  It was determined that no
significant effect would occur.

6.2.4 Forklift Operational Accident

In this analysis (see Appendix D), the single boom on a specially
designed forklift, traveling at 5 mph, strikes and punctures an
AL-R8 container.  The boom then crushes the pit within the
container and packing material, expelling plutonium dust. 
Essentially, all of the 20 mg of available plutonium dust becomes
airborne within the AL-R8 container; however, calculations, using
conservative assumptions, show that only 0.57 mg of the plutonium
actually escapes to the outside air.
The total activity released by 45-year old weapons grade plutonium,
which maximizes resultant activity levels, in the above accident is
calculated to be 92 -Ci.  Assuming that the plutonium is dispersed
uniformly and instantaneously, a worker present would receive
0.02 -Ci.  This is equivalent to the 50-year committed effective
dose equivalent (Committed Effective Dose Equivalent) for lungs of
24 rem, and the 50-year Committed Effective Dose Equivalent whole
body dose of 6.6 rem.  There would be no immediate or long-term
health effect to the worker as a result of an accident of this
type.  Workers in the immediate vicinity of the accident site could
receive a marginal radiation dose; negligible consequences to the
public or the environment are anticipated.

6.2.5 Aircraft Hazard Analysis

Appendix E, "Aircraft Hazard Analysis," presents a quantitative
analysis of the likelihood of any class (e.g., air carrier,
military) of aircraft striking a Modified-Richmond or Steel Arch
Construction magazine.  The results of the analysis (summarized by
aircraft class) are as follows:
Aircraft Class       Crash 
                     Probability/Year 
Air Carrier          2.78 x 10E-8 
Military             2.50 x 10E-7 
Aviation
General Aviation     1.52 x 10E-6 
Aerial               5.42 x 10E-8 
Application
TOTAL                1.86 x 10E-6
The analysis indicates that the likelihood of any class of
aircraft impacting into any of the 60 Zone 4 magazines
(regardless of the magnitude of that impact) is approximately
1.9 x 10-6 per year.  The overall estimated probability of impact
is greater than one in a million (1 x 10-6) per year.  However, it
must be observed that this estimate is dominated by the results for
general aviation in that approximately 82 percent of the total
probability comes from that source.  This arises from the fact that
general aviation clearly dominates the air traffic in the Amarillo
area.  As indicated in the Safety Analysis Report for Zone 4, 62
percent of the total traffic count is general aviation.  Given this
situation, and the fact that these single-engine aircraft are

Table 6-3 - Summary of Accident Analysis Results - Modified-
Richmond and Steel Arch Construction Magazines
Accident      Annual   Effect      Effect on   Effect on    Dollar Loss    Program    Risk 
Scenario      Probabil on          Environme    Plant       (2)            Interru    Leve 
              ity(1)    General    nt(2)       Workers(2)                  ption(2)   l(3) 
                       Public(2) 
Aircraft      Extremel Negligib    Negligibl   Negligible   Marginal -     Negligi    IV-C 
Crash(4)      .        le          e           (no          (minor         ble         
(General      Unlikely (no         (no         effect)      cracking of    (no 
Aviation,     (1.2E-6) effect)     effect)                  concrete)      effect) 
Single                              
Engine)
Design        Unlikely Negligib    Negligibl   Negligible   Marginal -     Negligi    IV-B 
Basis(4)      (1.0E-3) le          e           (no          (minor         ble 
Earthquakes            (no         (no         effect)      cracking or    (no 
(0.10g)                effect)     effect)                  spalling of    effect) 
                                                            concrete) 
Maximum       Extremel Negligib    Negligibl   Negligible   Marginal -     Negligi    IV-C 
Credible(4)   .        le          e           (no          (minor         ble 
Earthquakes   Unlikely (no         (no         effect)      cracking or    (no 
(0.33g)       (1.5E-5) effect)     effect)                  spalling of    effect) 
                                                            concrete) 
External      Unlikely Negligib    Negligibl   Marginal -   Negligible -   Negligi    III-
Explosion(5)  (1.7E-4) le          e           (personnel   (no dollar     ble        B 
(5.2psi                (no         (no         near Zone    loss)          (no 
overpressure;          effect)     effect)     4 MAA                       effect) 
Zone 4 East                                    magazines 
magazines)                                     slightly  
                                               injured) 
External      Likely   Negligib    Negligibl   Negligible   Marginal -     Negligi    IV-A 
Fires(5)      (2.5E-2) le          e           (no          (minor         ble 
(diesel fuel           (no         (no         effect)      damage to      (no 
fire)                  effect)     effect)                  doors and      effect) 
                                                            concrete 
                                                            front wall, 
                                                            loss of 
                                                            forklift) 
Missiles(5)   Extremel Negligib    Negligibl   Critical -   Marginal -     Negligi    II-C 
 (Explosion-  .        le          e           (personnel   (minor         ble 
Generated -   Unlikely (no         (no         near Zone    damage to      (no 
 40 lbs., 778  (1.6E-  effect)     effect)     4 MAA        security       effect) 
ft/sec)       6)                               magazines    barrier) 
                                               severely  
                                               injured) 
Missiles(4)   Extremel Negligib    Negligibl   Negligible   Negligible -   Negligi    IV-C 
(Tornado-     .        le          e           (no          (slight        ble 
Driven)       Unlikely (no         (no         effect)      damage to      (no 
              (2.0E-5) effect)     effect)                  security       effect) 
                                                            barrier) 
Design        Extremel Negligib    Negligibl   Negligible   Marginal -     Negligi    IV-C 
Basis(4)      .        le          e           (no          (minor         ble 
Tornados      Unlikely (no         (no         effect)      cracking  or   (no 
 (150 mph)    (2.0E-5) effect)     effect)                  spalling of    effect) 
                                                            concrete) 
Maximum(4)    Extremel Negligib    Negligibl   Negligible   Marginal -     Negligi    IV-C 
Credible      .        le          e           (no          (minor         ble 
Tornados (220 Unlikely (no         (no         effect)      cracking or    (no 
mph)          (1.0E-6) effect)     effect)                  spalling of    effect) 
                                                            concrete) 
Operational   Likely   Negligib    Negligibl   Marginal -   Marginal -     Negligi    III-
Accident(5) - (>1.0E-  le          e           (whole       (from          ble        A
(forklift     2)       (no         (no         body 50      decontaminat   (no 
puncture of            effect)     effect)     year CEDE    ion            effect) 
pit                                            <7 rem)      proceedings) 
container)
NOTES:
1.  Probability estimates are based on quantitative analysis or the qualitative
    description provided in the Zone 4 Safety Analysis Report.
2.  Consequence estimates are based on quantitative analysis and the qualitative
    description provided in the
    Zone 4 Safety Analysis Report.
3.  Risk is defined as the combination of the annual probability and the worst of
    the effects the event could produce on the general public, the plant workers,
    or the environment.  See Tables 6-4A and 6-4B.
4.  Tornado, Earthquake, and Aircraft Crash probabilities are for all Zone 4
    magazines.
5.  Fire, Explosion, and Operational Accident probabilities are for individual
    magazines.
 lightweight and fly at low speeds compared to the air carriers and
military aircraft, the vulnerability of the magazines in Zone 4 to impacts
from general aviation aircraft was examined.
Analysis (detailed in Appendix C) indicates that light aircraft (i.e.,
single-engine aircraft) moving at typical speeds will not penetrate or
collapse a Zone 4 magazine structure.  This analysis is summarized in
Appendix E.  Therefore, it is considered reasonable to exclude single-
engine aircraft from further consideration in the accident analysis and
to focus attention on those aircraft that have some potential for
penetration or destruction impact.  When the probability calculation was
reworked to reflect only aircraft crashes capable of damaging a Zone 4
magazine structure, the overall estimate of the probability of an aircraft
crash dropped below 1 x 10-6 per year.  The results by aircraft class are
as follows:
Aircraft Class         Crash 
                       Probability/Year 
Air Carrier            2.78 x 10E-8 
Military Aviation      2.50 x 10E-7 
General Aviation       3.31 x 10E-7 
Aerial Application     5.42 x 10E-8 
TOTAL                  6.63 x 10E-7
The above approach is considered conservative and, on the basis of the
analysis in Appendix E, an aircraft crash into a Zone 4 magazine
sufficient to cause damage and potential release of radioactive
material is considered beyond extremely unlikely.  The consequence of
this accident is bounded by the analyses conducted in the Final
Environmental Impact Statement for the Pantex Plant.

Table 6-4A - Qualitative Consequence Categories
Category I -      An accident that may cause deaths, the total loss of the 
Catastrophic      facility or process, severe damage to the environment, extreme 
                  dollar loss or a long-term program interruption. 
Category II -     An accident that may cause severe injuries or occupational 
Critical          illnesses, major damage to the facility or process, major damage 
                  to the environment, large dollar loss, or moderate program 
                  interruption. 
Category III -    An accident that may cause minor injuries or occupational 
Marginal          illnesses, minor damage to the facility or process, minor damage 
                  to the environment, minor dollar loss, or a short-term program 
                  interruption. 
Category IV -     An accident that would not result in injuries or occupational 
Negligible        illnesses, damage to the facility or process, damage to the 
                  environment, dollar loss, or a program interruption.

Table 6-4B - Qualitative Likelihood Categories
Category                Estimated         Description 
                        Occurrence Rate 
                        (Per Year) 
Category A - Likely     > 1.0 x 10-2      The event is likely to occur 
                                          (possibly several times) during the 
                                          lifetime of the facility. 
Category B - Unlikely   1.0 x 10-2 to 1.0 The event is unlikely, but may 
                        10-4              reasonably be expected to occur 
                                          during the lifetime of the 
                                          facility. 
Category C - Extremely  1.0 x 10-4 to 1.0 The event is extremely unlikely and 
Unlikely                10-6              is not expected to occur during the 
                                          lifetime of the facility.

7.0 POTENTIAL IMPACTS ON THE OGALLALA AQUIFER

The Department of Energy could identify no accident or routine
operating condition with a probability greater than 1 x 10-6 per
year that could result in a plutonium release having an impact on
the Ogallala Aquifer.  However, in response to the expressed
interest of the State and public regarding possible contamination
of the aquifer, the Department of Energy directed the Los Alamos
National Laboratory to perform additional analyses (Turin, et al.,
1992).  The following summarizes those analyses.
As with all Federal agencies, the Department of Energy would be
responsible for cleanup of any contamination.  Emergency Response
Teams and decontamination crews would remove the plutonium
contaminated soil and it would be disposed of, as appropriate, in
a repository for radioactive contaminated waste.  Plutonium
contaminated soil would be removed to levels of plutonium in soil
that would not pose a significant threat to public health and
safety.  The Environmental Protection Agency proposed in 1977 that
for residual plutonium, 0.2 -Ci/m2 in the top centimeter of soil
would result in dose rates less than the guidance recommendations
for acceptably low risks from alpha radiation exposure - about 1
millirad per year to lung tissue.  This value was proposed by the
Environmental Protection Agency, but never officially adopted.  The
Final Environmental Impact Statement for the Pantex Plant
(Department of Energy, 1983) also used this value for the top
centimeter of soil as the level to which soil would be
decontaminated in the event of a release.  The Environmental Impact
Statement also references a study (Elder, 1982) that provides an
example of ground dispersion from an accident.  Analysis has shown
that the maximum calculated area that is expected to be
contaminated to a level above the proposed Environmental Protection
Agency guideline due to an accident in Zone 4 is 75 km2.  See
memorandum from Sandia National Laboratory, dated April 30, 1993
from Y.T. Lin, N.R. Grandjean, R.E. Smith to D.R. Rosson
(Department of Energy/Albuquerque) titled "Plutonium Dispersal
Deposition Area Estimates of a Hypothetical Aircraft Crash Into
Pantex Zone 4, (included in the Environmental Assessment Comment
Response, Appendix I).
The Department of Energy's previous experience with cleanup of
nuclear test sites indicates that a cleanup to the 0.2 -Ci/m2 level
is achievable.  1) See Palomares Summary Report.  Field Command,
Defense Nuclear Agency, Technology and Analysis Directorate,
Kirtland Air Force Base.  2) Thule.  United States Air Force
Nuclear Safety, AFRP 122, January/February/March 1970, No. 1,
Volume 65 (Part 2), Special Edition:  "Project Crested Ice".  3)
Johnston Island.  Thermo Analytical (Attention:  Nels Johnson/5635
Jefferson Street, N.E., Albuquerque, New Mexico 87109), Soil Clean
of Technologies.
If required, surface soil cleanup may be both expensive and time-
consuming.  However, a delay on the order of a few years would not
significantly change the Environmental Assessment's analyses
concerning the potential effects of a plutonium dispersal accident
on the Ogallala Aquifer.  Although there is uncertainty concerning
the long-term rate of plutonium transport, soil scientists
generally agree that it is relatively immobile and that it will not
migrate beyond remedial depths within the few years that could be
needed to complete a cleanup.
The Los Alamos National Laboratory analysis describes the potential
for aquifer contamination should plutonium be released to the
environment within an 80 km radius of the Pantex Plant (Elder,
1986).  The following assumptions were used in preparing the
groundwater impact analysis:
      .     Surface soils would be decontaminated to levels no
            greater than 0.2 -Ci/m2 following the hypothetical
            accident.  (Previous experience indicates this level is
            achievable.)
      .     Surface transport processes may increase soil
            concentrations ten-fold, to 2.0 -Ci/m2, before
            infiltration takes place.
      .     Recharge to the Ogallala Aquifer is focused at playa lake
            beds.  Playa lake recharge rates are approximately 3
            cm/year, ten times the High Plains average.
      .     The Ogallala Aquifer water table may be encountered as
            shallow as 50 feet beneath the land surface within the
            study area (located south of Pantex, directly opposite
            predominant wind directions).
      .     The entire unsaturated zone exhibits a plutonium sorption
            coefficient of 100 mL/g, approximating the sorption of
            clean Ogallala sand.
With these conservative assumptions in place, two analyses were
performed.  A non-dispersive piston-flow model indicated that
significant plutonium levels might be encountered in a 50-foot deep
aquifer after approximately 76,000 years (at depths of 200 and 400
feet, plutonium travel times are 305,000 and 610,000 years,
respectively).  A second, more realistic analysis incorporating
dispersion showed that even with unrealistically low dispersivity
values, peak plutonium concentrations in the 50-foot aquifer would
never exceed the most restrictive drinking water dose limits.  With
more realistic dispersivity values, or deeper water tables more
typical of the study area (i.e., approximately 400 feet directly
beneath the Pantex Facility), peak plutonium concentrations in the
aquifer would be orders of magnitude below dose limits.  Neither
analysis showed significant impacts to deeper aquifers.
Additional complicating factors have also been analyzed.  These
include colloidal plutonium transport, preferential flow, the
effects of perched aquifers, opportunities for short-circuit flow
through abandoned wells or other conduits, and the fate of daughter
products.  Although it is difficult to quantify these factors
accurately, they are expected to have little if any negative impact
on the Ogallala Aquifer.  Colloidal transport is perhaps the most
uncertain process in this category, but a field experiment at a
nearby location suggests that colloidal transport will not enhance
radionuclide transport enough to significantly affect groundwater
quality in the Ogallala Aquifer.
Sorption, preferential flow, and plutonium remediation technology
references are listed in Section 9.0 of this Environmental
Assessment.  Most of the sorption and preferential flow references
are also cited in Turin et al., 1992.  References for plutonium
remediation technologies regarding soil and aquifer material
cleanup were provided on Page 7-1 of this Environmental Assessment. 
Although there is very little in open literature concerning
plutonium remediation for water, the references provided in Section
9.0 of this Environmental Assessment may be helpful.
The conclusion of these analyses is that the hypothetical plutonium
dispersal accident does not pose a significant threat to the
Ogallala Aquifer.

8.0 EXTERNAL AGENCY AND STAKEHOLDER INVOLVEMENT

      Agencies contacted during preparation of this Environmental
      Assessment:
          .   Nuclear Weapons Council (Joint Department of
              Energy/Department of Defense Independent Organization
              Chartered by Congress)
          .   Department of Defense - Defense Nuclear Agency
          .   Department of State
          .   Federal Aviation Administration
      State and local governments, agencies, local citizens, private
      interest groups, and providing comments on this Environmental
      Assessment:
          State of Texas:
              .   Ann W. Richards, Governor
              .   Bob Bullock, Lt. Governor
              .   Senator Teel Bivins (District 31), The Senate of
                  The State of Texas
              .   Dan Morales, Attorney General, Office of the
                  Attorney General
              .   Boyd Deaver, Texas Water Commission
              .   Joseph A. Martillotti, Texas Department of Health,
                  Bureau of Radiation Control
              .   Alison A. Miller, Texas Air Control Board
              .   Tom Millwee, Chief, Texas Department of Public
                  Safety, Division of Emergency Management
              .   Thomas A. Griffy, University of Texas at Austin,
                  Department of Physics
              .   Auburn L. Mitchell, University of Texas at Austin,
                  Texas Bureau of Economic Geology
      Carson & Randall Counties and City of Amarillo:
          .   Jay R. Roselius, County Judge, Carson County
          .   Walt Kelley, City of Amarillo/Counties of Potter and
              Randall, Emergency Management
      Other Government Agencies:
          .   C. Ross Schulke, United States Department of
              Transportation, Federal Aviation Administration
          .   Benito J. Garcia, Chief, State of New Mexico,
              Environmental Department
      Local Citizens:
          .   48 signatures/form letter
          .   Betty E. Barnard
          .   Louise Daniel
          .   Portia Dees
          .   Boyd M. Foster, President Arrowhead Mills
          .   Margie K. Hazlett
          .   William and Mary Klingensmith
          .   Bishop Leroy T. Matthiesen Diocese of Amarillo
          .   Jeri & Jim Osborne & Family
          .   Judy Osborne
          .   Dana O. Porter
          .   Karen Son
          .   Norbert Schlegal
          .   Tamara Snodgrass
      Private Interest Groups:
          .   Operation Commonsense (W.H. O'Brien)
          .   Panhandle Area Neighbors and Landowners (PANAL) (Addis
              Charless, Jr.)
          .   Panhandle Area Neighbors and Landowners (PANAL) (Doris
              & Phillip Smith)
          .   Panhandle 2000 (Jerome W. Johnson)
          .   Save Texas Agriculture and Resources (STAR) (Beverly
              Gattis)
          .   Serious Texans Against Nuclear Dumping (STAND) of
              Amarillo, Inc. (Beverly Gattis)
          .   Texas Corn Growers Association (Carl L. King,
              President)
          .   The Peace Farm (Mavis Belisle, Director)
          .   The Texas Nuclear Waste Task Force (Tonya Kleuskens,
              Chairman)
          .   Hanford Education Action League (HEAL) (James Thomas)
          .   Institute for Energy & Environmental Research (Arjun
              Makhijani, Ph.D.) Military Production Network (Beverly
              Gattis)
          .   Nukewatch (Sam Day, Director)
          .   Physicians For Social Responsibility (Lawrence D.
              Egbert, MD)

9.0 REFERENCES

1.    (Aronovice 1972) United States Aronovice and A.D. Schneides, "Deep
      Percolation Through Pullman Soil in Southern High Plains," J. of
      Soil Water Conservation, Volume 27, No. 2 (March-April 1972).  (As
      cited in LA-9445-PNTX-I; Geohydrology, 12/82.)
2.    (Department of Energy, 1983) Department of Energy, Final
      Environmental Impact Statement, Pantex Plant Site, DOE/EIS-0098,
      October 1983.
3.    (Department of Energy, 1987) Department of Energy, Preliminary
      Draft, Environment, Safety, and Health Office of Environmental
      Audit, Environmental Survey Preliminary Report, Pantex Facility,
      Amarillo, Texas, September, 1987.
4.    (Department of Energy, 1988) DOE/AL Order 5481.1B, Safety Analysis
      and Review System, United States Department of Energy, Albuquerque
      Operations Office, January 27, 1988.
5.    (Department of Energy, 1993), Final Safety Analysis Report, Pantex
      Plant Zone 4 Magazines, Issue D, United States Department of Energy,
      April 1993.
6.    (Elder, 1986) J.C. Elder, et al., "A Guide to Radiological Accident
      Considerations for Siting and Design of Department of Energy Non-
      Reactor Facilities," LA-10294-MS, Los Alamos National Laboratory,
      January 1986.
7.    (Elder, 1982B) J.C. Elder, et al., "Supplementary Documentation for
      an Environmental Impact Statement Regarding the Pantex Plant: 
      Radiological Consequences of Immediate Inhalation of Plutonium
      Dispersed by Postulated Accidents," Los Alamos National Laboratory
      Report LA-9445-PNTX-F (1982).
8.    (Environmental Protection Agency, 1977), Proposed Guidance on Dose
      Limits for Persons Exposed to Transuranium Elements in the General
      Environment, EPA 520/4-77-016, Environmental Protection Agency,
      1977.
9.    (Gilbert et al., 1975) Gilbert, R.O., L.L. Eberhardt, E.B. Fowler,
      E.M. Romney, E.H. Essington, and J.E. Kinnear, "Statistical Analysis
      of 239-240Pu and 241Am Contamination of Soil and Vegetation on NAEG
      Study Sites." in The Radioecology of Plutonium and other
      Transuranics in Desert Environments.  NVO-153, Energy Research and
      Development Administration, Nevada Operations Office, Las Vegas,
      Nevada 1975.
10.   (Hughes and Speer, 1981) Hughes, J.T. and R.D. Speer, An
      Archaeological Survey of the Pantex Plant, Carson County, Texas,
      Submitted to:  Mason and Hangar-Silas Mason Co., Inc., July, 1991.
11.   (Martin, J., 1992) Martin, J., Annual As Low As Reasonably
      Achievable and Radiation Safety Program Review for Calendar Year
      1991, Rev. 1, Internal Memo from J. Martin, Radiation Safety
      Department Manager, Battelle Pantex to C.D. Alley, Plant Manager,
      Pantex Plant, September 16, 1992.
12.   (Mason and Hanger-Silas Mason Co., 1990) Mason and Hanger-Silas
      Mason Co., Inc., "Groundwater Protection Management Program Plan for
      the Department of Energy - Pantex Plant" Amarillo, Texas, May 1990.
13.   (Mason and Hanger-Silas Mason Co., 1990) Mason and Hanger-Silas
      Mason Co., Inc., Pantex Plant Site Environmental Report for Calendar
      Year 1990, MHSMP-91-06, July, 1991.
14.   National Council on Radiation Protection , 1987, 1987 Exposure of
      the Populations in the United States and Canada from Natural
      Background Radiation, NCRP Report No. 94, Bethesda, MD, December
      1987.
15.   (Price, 1991) Price, K.R., "The Depth Distribution of 90Sr, 137Cs, and
      239,240Pu in Soil Profile Samples", Radiochimica Acta 54 145-147
      (1991).
16.   (Purtymum and Becker 1982) W.D. Purtymum and N.M. Becker,
      "Supplemental Documentation for an Environmental Impact Statement
      Regarding Pantex Plant - Geohydrology", LA-9445-PNTX-1, Los Alamos
      National Laboratory, (1982).
17.   (RFE-8801, 1988) Rocky Flats Container, Model AL-R8 Safety Analysis
      Report for Packaging (SARP), SRD Document RFE-8801, April 1988
      (Revised September 1990).
18.   (Turin, et al., 1992) H.J. Turin, I.R. Triay, W.R. Hansen, W.J.
      Wenzel, "Potential Ogallala Aquifer Impacts of a Hypothetical
      Plutonium Dispersal Accident in Zone 4 of the Pantex Plant," Los
      Alamos National Laboratory Report, November 1992.
Actinide Sorption and Solubility
1.    Thomas, K.W., 1987, Summary of Sorption Measurements Performed with
      Yucca Mountain, Nevada, Tuff Samples and Water from Well J-13, Los
      Alamos National Laboratory Report LA-10960-MS.
2.    Canepa, J.A. (ed.), 1992, Proceedings of the DOE/Yucca Mountain Site
      Characterization Project Radionuclide Adsorption Workshop at Los
      Alamos National Laboratory, September 11-12, 1990, Los Alamos
      National Laboratory Report LA-12325-C.
3.    Nitsche, H. et al., 1993, Measured Solubilities and Speciations of
      Neptunium, Plutonium, and Americium in a Typical Groundwater (J-13)
      from the Yucca Mountain Region, Los Alamos National Laboratory
      Report LA-12562-MS.
Preferential Flow
1.    Biggar, J.W. and D.R. Nielsen, 1976, Spatial Variability of the
      Leaching Characteristics of a Field Soil, Water Res. Res. 12: 78-84.
2.    Bowman, R.S. and R.C. Rice, 1986, Transport of Conservative Tracers
      in the Field Under Intermittent Flood Irrigation, Water Res. Res.
      22: 1531-1536.
3.    Gish, T.J. and A. Shirmohammadi, (ed.), 1991, Preferential Flow: 
      Proceedings of a National Symposium, Chicago, IL, 16-17 December
      1991, ASAE, St. Joseph, MI.
4.    Jury, W.A., L.H. Stolzy and P. Shouse, 1982, A Field Test of the
      Transfer Function Model for Predicting Solute Transport, Water Res.
      Res. 18(2): 369-375.
5.    Rice, R.C., R.S. Bowman and D.B. Jaynes, 1986, Percolation of Water
      Below An Irrigated Field, Soil Sci. Soc. Am. J.50: 855-859.
6.    Turin, H.J., 1992, Non-Ideal Transport of Pesticides Through the
      Vadose Zone, Ph.D. Diss., New Mexico Institute of Mining and
      Technology.
7.    Van De Pol, R.M., P.J. Wierenga and D.R. Nielsen, 1977.  Solute
      Movement in a Field Soil.  Soil Sci. Soc. Am. J.41: 10-13.
Plutonium Remediation Technologies
1.    Barney, G.S., K.J. Lueck, and J.W. Green, 1992.  Removal of
      Plutonium from Low-Level Process Wastewaters by Adsorption, in
      Environmental Remediation:  Removing Organic and Metal Ion
      Pollutants.  ACS Symposium Series No. 509, pp. 34-46.
2.    Isotope and Nuclear Chemistry Division, n.d., Utilization of a
      Flocculation Technique to Remediate Surface Waters.  Los Alamos
      National Laboratory Report Prepared for Los Alamos Technology
      Office, Rocky Flats Plant.
3.    Triay, I.R. et al., n.d., Report on the Effectiveness of
      Flocculation for Removal of 239Pu at Concentrations of 1 pCi/L, and
      .1 pCi/L.  Los Alamos National Laboratory Internal Report.
4.    Triay, I.R., G.K. Bayhurst, and A.J. Mitchell, 1993.  Report on the
      Effectiveness of Flocculation for the Removal of 239Pu from the RFP
      Pond Water.  Los Alamos National Laboratory Report LA-UR-93-1550.

APPENDIX A
SCREENING OF POTENTIAL ACCIDENT-INITIATING EVENTS

This appendix presents the potential accident-initiating events
that were considered in the safety analysis of the Zone 4
magazines.  From this list of events, a qualitative assessment was
performed to eliminate from further consideration any of the events
that posed little or no hazard to the magazines or their contents.
Potential accident-initiating events were identified by reviewing
several prior risk and safety studies.  The prior studies that were
examined included environmental impact and safety analyses
performed for the Pantex Plant (References 1, 2, and 3), Department
of Energy-sponsored current guidelines for performing hazards
assessments (References 4, 5, and 6), recent safety and risk
analyses of another Department of Energy facility (References 7 and
8), and the recommended list of initiating events used to evaluate
commercial nuclear power plant risks (Reference 9).  In addition,
an attempt was made to identify any other potential external
initiating events unique to the Pantex Plant that had not been
considered in previous studies.
Table A-1 presents the events that were considered for the Zone 4
magazines.  The Status column in this table indicates how each
event was categorized in the screening process.  The four criteria
used in the screening process are as follows:
    1.  The event is impossible or highly improbable due to the size
        or location of the facility; the characteristics of the
        regional geography, topography, or hydrography; and the
        nature of the materials handled or the operations performed
        in the magazines.
    2.  The event produces stresses that are similar or obviously
        less severe than other events under consideration.
    3.  The event would not result in any potential for adverse
        consequences on the interim storage facilities.
    4.  The event could not be eliminated from consideration by
        screening; some level of quantitative analysis is required.
Many of the events listed in Table A-1 were eliminated from further
consideration by using this screening process.  However, six events
were not eliminated as follows: (1) earthquakes, (2) external
explosions, (3) forklift accidents, (4) missiles, (5) tornados, and
(6) aircraft crash.  Discussions of these events are provided in
Appendix B, C, D, and E of this Environmental Assessment.  All of
the events considered in this assessment, along with brief
descriptions of their screening rationale, are listed in Table A-1.

Table A-1 - Potential Accident-Initiating Events
Event                             Status(a)    
Avalanches/Landslides             1            
Coastal Erosion                   1            
Criticality Events                1\1          (a) Status Key 
                                              1 - Not possible or 
                                                  plausible at this site 
                                                  or facility. 
                                              2 - Less severe than other 
                                                  potential events. 
                                              3 - No potential for adverse 
                                                  consequences. 
                                              4 - Quantitative analysis 
                                                  required. 
Internal Explosions               1            
Internal Fires                    1\2           
Internal Floods                   1            
Meteor Strikes                    1            
Seiche                            1            
Tsunami                           1            
Volcanic Activity                 1            
Industrial or Military Facility   1, 2         
Accident
Forest/Grass Fires                2            
Hail                              2            
Ice                               2            
Snow                              2            
Straight Winds                    2            
Transportation Accidents          2            
Pipeline Accidents                2, 3        NOTES: 
                                              1 Criticality analysis 
                                                performed in the Zone 4 
                                                Safety Analysis Report 
                                                identified this event to 
                                                be incredible. 
                                              2 Internal Fire analysis 
                                                performed in the Zone 4 
                                                Safety Analysis Report 
                                                for pit storage indicates 
                                                that the absence of 
                                                combustibles would 
                                                preclude a sustained fire 
                                                having environmental 
                                                impacts.  
                                              3 External Fire analysis 
                                                performed in the Zone 4 
                                                Safety Analysis Report 
                                                concluded there would be 
                                                no impacts to magazines 
                                                or contents. 
                                               
Structural Interactions           2, 3         
Chemical/Toxic Gas Releases       3            
Corrosion                         3            
Drought                           3            
External Fires                    33           
External Floods                   3            
Fog                               3            
Frost                             3            
Lightning Strikes                 3            
Loss of Off-Site Power            3            
Low Lake or River Water Level     3            
River Diversions                  3            
Sandstorms/Dust Storms            3            
Temperature Extremes              3            
Aircraft Impacts                  4            
Earthquakes                       4            
External Explosions               4            
Forklift Accident                 4            
Tornados                          4            
Missiles                          4 
Aircraft Impacts
Detailed analysis in Appendix E, Aircraft Hazard Analysis, has
determined an aircraft impact with a Zone 4 magazine, resulting in
a radioactive release, as an incredible event (Reference 15).
Avalanches/Landslides
Due to the flat terrain around the Pantex Plant, avalanches and
landslides are not credible events.
Chemical/Toxic Gas Releases
Release of toxic gas would not result in any hazard to the contents
of the magazines.  Evacuation may be required in such an event, but
abandoning operations results in no hazard to the magazine
contents.
Coastal Erosion
The Pantex Plant is not subject to coastal erosion.
Corrosion
The interim storage to be provided for plutonium pits includes
containment of the plutonium in a corrosion-resistant metal shell
which in turn is surrounded by a positioning material (Celotex-),
sealed within either a carbon steel or stainless steel drum, which
is stored in a metal or concrete magazine.  Other than periodic
inventories, there are no other activities occurring in the interim
storage area magazines.
Under normal circumstances, it would be expected that no corrosive
media other than moisture resulting from changes in relative
humidity would come in contact with the interior surfaces of the
magazines, let alone the pit storage containers.  In the absence of
a highly corrosive media, there is no mechanism to cause corrosion
that would lead to the degradation of the pit containers.  It
should be noted that minor rusting of the carbon steel drum is
expected, but in no way impacts containment of Special Nuclear
Material or the ability of the AL-R8 to serve as a suitable storage
container.  In the event that an unexpected corrosive media was
determined to have entered a magazine, it would be removed
promptly.  The Sandia National Laboratories Stockpile Evaluation
Department has defined a pit storage container (AL-R8) sampling and
inspection plan to verify the integrity of the pit container during
interim storage.  In this plan, ten to twenty containers per year
would be selected for 100 percent visual inspection of all
individual piece parts.  In addition, visual inspection for
rust/corrosion, inspection of the insulation, weld integrities and
all plastic parts will be conducted.  Formal evaluation of all data
will be used to detect potential systematic problems.  This
sampling technique is similar to that used for stockpile evaluation
of weapons in the stockpile.
Criticality
No operational event was identified which could result in a
criticality event.
Drought
Droughts are possible at the site, but there is no potential for
adverse effects to the magazines or their contents.
Earthquakes
Seismic events could not be eliminated from consideration.  The
likelihood and effects of this event on the magazines and their
contents are considered in detail in Appendix C.
External Explosions
Blast pressures and fragments caused by accidental explosions in
adjacent structures could not be eliminated from consideration in
this screening assessment.  The effects of this event on the
magazines are considered in more detail in Appendices B and C.
External Fires
The only credible external fires would be those from grass fires
and from fires involving diesel-powered vehicles that may be close
to the entrance of the magazines.  Because of the absence of
uncontained combustibles in the magazines, no impacts to magazine
contents would result from external fires.
External Floods
Localized flooding (ponding) is possible near some magazines, but
the general inundation of the magazines is considered incredible
due to the elevation of Zone 4 (Reference 10).  Even if ponding
occurred due to rainfall, neither the magazines nor their contents
would be damaged.
Fog
Fog presents no hazard to the magazines.
Forest/Grass Fires
Because the Pantex Plant is located in an area of grassy plains,
forest fires are not a concern.  The area containing the magazines
is separated from other areas by gravel, which should preclude a
range (grass) fire from impacting the storage area. 
Forklift Accident
A forklift operational accident could not be eliminated from
consideration.  The likelihood and effects of this event on the
magazines, their contents, and the environment are considered in
Appendix D.
Frost
Frost presents no hazard to the magazines or their contents.
Hail
Hail is not a concern because of the structural characteristics of
the magazines.  Furthermore, any potential effects of hail on the
magazines (i.e., roof collapse) are subsumed in the consideration
of earthquakes and tornados.
Ice
Ice loading is not a concern because of the structural
characteristics of the magazines.   Furthermore, any potential
effects of ice loading on the magazines (i.e., roof collapse) are
subsumed in the consideration of earthquakes and tornados.
Internal Explosions
Because of the absence of high explosives inside the magazines,
internal explosions were eliminated from consideration in this
screening assessment.
Internal Fires
Because of the absence of uncontained combustibles in the
magazines, internal fires were eliminated from consideration in
this screening assessment.
Internal Floods
There are no water or fire protection sprinkler lines inside or
immediately outside the magazines.  Therefore, internal floods were
not considered credible events.
Industrial or Military Facility Accidents
Because of the large restricted area around Zone 4 and the remote
location of the Pantex Plant, no industrial or military facility
accidents are credible.
Lightning Strikes
Because of the lightning protection system installed throughout
each magazine, the protected nature of pits inside the earthen
magazines and the built-in design features of weapon assemblies to
withstand lightning strikes, this event is not considered a
credible threat to the magazines or their contents.
Loss of Off-Site Power
The only electrical loads associated with the magazines are for
security-related purposes exterior to the magazines.  Complete loss
of electrical power to the magazines would have no safety-related
consequences.
Low Lake or River Water Level
This hazard is considered only if off-site water sources are
required for safety-related cooling purposes.  No such cooling
requirements exist for the operations conducted in the magazines.
Meteor Strike
Previous analyses of the likelihood of a meteor strike on a
structure the size of a large process building indicated that this
event is incredible (Reference 11).  Furthermore, the United States
Nuclear Regulatory Commission has excluded meteor strikes as a
credible threat to nuclear power plants (Reference 12).
Missiles
Missiles generated as a result of tornados or external explosions
could not be eliminated from consideration.  The design basis
missiles that the magazines are required to withstand are listed in
Appendix B.  The effects of these events on the magazines are
considered in more detail in Appendix C.  No rotating machinery is
located within Zone 4 that has the potential to generate missiles
with the potential to adversely affect the magazines or their
contents.
Operational Accidents (Forklift)
Operational accidents generated by component failure or operator
error could not be eliminated from consideration.  The most
limiting operational accident, the puncture of a pit container by
a forklift, is analyzed in Appendix D.
Pipeline Accidents
The only pipelines containing high pressure or explosive materials
in or near the Zone 4 magazines are:  (1) a 2-1/2-inch steam line
that had previously supplied heaters within magazines 4-19 and 4-
21, (2) a 1-inch (30 psig) underground natural gas line that
previously supplied magazine 20E (this line passes approximately
100 feet west of magazine 4-19), and (3) a 2-inch (50 psig), north-
south underground natural gas line that passes approximately
700 feet east of magazines 4-39 through 4-44 and 4-119 through 4-
142 (Reference 15).  Rupture of the steam line is not considered to
be a significant threat because the branch lines previously
entering magazines 4-19 and 4-21 have been removed, and the
upstream lines could not cause damage to the magazines.  Natural
gas pipeline failures are not considered a credible threat because
of the lighter-than-air nature of the gas and the lack of a
collection point.
River Diversions
This potential hazard is only relevant for facilities that depend
on near-site rivers for safety-related cooling purposes. 
Therefore, it is not relevant to the magazines.
Sandstorms/Dust Storms
Because of the sealed nature of the magazines, sandstorms and
duststorms would not represent a hazard to the structures or their
contents.
Seiche
Seiches are not a concern for the magazines because no large
shallow bodies of water are located near the Pantex Plant.
Snow
Snow loading is not a concern because of the structural
characteristics of the magazines.  Furthermore, any potential
effects of snow loading on the magazines (i.e., roof collapse) are
subsumed in the consideration of earthquakes and tornados.
Straight Winds
Straight winds present less of a hazard to the magazines than
tornados (Reference 14).  Any effect of straight winds is subsumed
in the consideration of tornados.
Structural Interactions
No off-gas stacks, tall buildings, or other structures exist in the
immediate vicinity of the magazines.  Therefore, the potential for
interactions with these adjacent structures is not credible.
Temperature Extremes
All weapon assemblies and weapon components can withstand all
anticipated temperature extremes without adverse safety
implications.
Tornados
Tornados could not be eliminated from consideration.  The
likelihood and effects of this event on the magazines are
considered in more detail in Appendix C.
Transportation Accidents
Several vehicles may be near the magazines, including Safe, Secure
Trailer's, diesel powered forklifts, electric forklifts and various
transport and security vehicles.  Only electric forklifts are
allowed inside the magazines,  Therefore, transportation accidents
that could occur are subsumed in the consideration of
Chemical/Toxic Gas Releases, External Explosions, and Missiles. 
Transportation accidents inside the magazines involving the
inadvertent puncture of a weapon component container or the
collision into a weapon assembly are considered operational
accidents and are assessed qualitatively in Appendix D.
Tsunamis
Due to the inland location of the site, tsunamis are not relevant
to the Pantex Plant.
Volcanic Activity
No potential for volcanic activity exists at or near the Pantex
Plant.
REFERENCES
1.   Environmental Assessment - Pantex Plant, Amarillo, Texas,
     EIA/MA-76-3, United States Energy Research & Development
     Administration, June 1976.
2.   Final Safety Analysis Report for SNM Staging Facilities, Pantex
     Plant, Mason & Hanger-Silas Mason, Co., Inc., September 1986.
3.   Final Environmental Impact Statement - Pantex Plant Site -
     Amarillo, Texas, DOE/EIS-0098, United States Department of
     Energy, October 1983.
4.   Design and Evaluation Guidelines for Department of Energy
     Facilities Subject to Natural Phenomena Hazards, UCRL-15910-
     Interim, Lawrence Livermore National Laboratory, October 1989.
5.   Non-Reactor Nuclear Facilities:  Standards and Criteria Guide,
     DOE/TIC-11603, Rev. 1, United States Department of Energy,
     September 1986.
6.   A Guide to Radiological Accident Considerations for Siting and
     Design of Department of Energy Non-Reactor Nuclear Facilities,
     LA-10294-MS, Los Alamos National Laboratory, January 1986.
7.   Savannah River Site PRA of Reactor Operation Level 1 Internal
     Events, WSRC-RP-89-570, Vol. 1, Westinghouse Savannah River
     Company, June 1990.
8.   Replacement Tritium Facility, Safety Analysis - 200 Area,
     Savannah River Site (DRAFT), WSRC-SA-1-1, Westinghouse Savannah
     River Company, January 30, 1991.
9.   PRA Procedures Guide, NUREG/CR-2300, United States Nuclear
     Regulatory Commission, January 1983.
10.  Natural Phenomena Hazards Modeling Project:  Flood Hazards
     Models for Department of Energy Sites, UCRL-53851, Lawrence
     Livermore National Laboratory, May 1988.
11.  Bounding Safety Assessment for the Rocky Flats Building 371
     Liquid Residue Storage Tank Draining and Liquid Transport
     to Building 771 (Draft), Science Application International
     Corporation, January 1990.
12.  Evaluation of External Hazards to Nuclear Power Plants in
     the United States, NUREG/CR-5042, United States Nuclear
     Regulatory Commission, December 1987.
13.  Pantex Plant Site Development Plan, Mason & Hanger-Silas
     Mason Co., Inc., November 1988.
14.  Natural Phenomena Hazards Modeling Project:  Extreme
     Wind/Tornado Hazard Models for Department of Energy Sites,
     UCRL-53526, Lawrence Livermore National Laboratory,
     February 1984.
15.  Final Safety Analysis Report Pantex Plant Zone 4 Magazines,
     Issue D, United States Department of Energy, April 1993.
16.  Secretary of Energy Notice 35-91, "Nuclear Safety Policy,"
     dated September 9, 1991.
17.  DOE Order 6430.1A, "General Design Criteria," dated
     April 6, 1989.

APPENDIX B
BLAST CALCULATIONS

This appendix presents the basic data used to assess the potential
blast hazards associated with the Zone 4 magazines.  The blast
pressures produced by adjacent explosions and their resultant
effect on the Modified-Richmond and Steel Arch Construction
magazines are examined.  The effects of the blast pressure produced
by an adjacent explosion on specific human organs are considered as
part of these blast calculations.  Quantity-distance calculations
are presented to identify the safe and actual distances between
Zone 4 structures.  Finally, the maximum credible explosion-
generated missile that could affect a Zone 4 magazine is defined
and described.  All calculations have been conducted by one analyst
and were verified by a second analyst as a quality assurance
measure.

B.1 ADJACENT EXPLOSION PRESSURE EFFECTS

The methods outlined in References 1 and 2 were used to determine
the side-on overpressures, normally reflected pressures, and
specific impulses resulting from potential explosions in structures
adjacent to the Steel Arch Construction and Modified-Richmond
magazines.  The parameters that are required to estimate the blast
characteristics of adjacent explosions are:  (1) the distance from
the explosion (R); (2) the Trinitrotoluene-equivalent weight of
material involved in the explosion (W); and, (3) the correction
factor for the elevation of the Pantex Plant.  The distance (R)
from a potential explosion to a Steel Arch Construction or
Modified-Richmond magazine is taken directly from plant drawings. 
The Trinitrotoluene-equivalent weight of high explosive that could
be involved in the event is taken from Reference 3.  Finally, the
correction factor that accounts for the elevation of the Pantex
Plant is calculated using the following atmospheric pressures:
      Po  =  atmospheric pressure at sea level = 14.695 pounds per
             square inch (psi)
      P   =  atmospheric pressure at Pantex Plant elevation (3500
             feet) = 12.929 psi
Tables B-1 through B-6 illustrate the data and calculations
required for estimating the side-on overpressures (Ps), side-on
specific impulses (Is), normally reflected pressures (Pr), and
normally reflected specific impulses (Ir) on Modified-Richmond
magazines from hypothetical explosions in adjacent structures, and
the distances associated with the organ damage threshold pressures. 
The information for the Steel Arch Construction magazines is
included only in Tables B-3 and B-4.  The Modified-Richmond
calculations were done first for every conceivable donor building. 
This analysis showed that the cases in Tables B-3 and B-4 were the
limiting cases for any Zone 4 magazine.  Thus, only the cases in
Tables B-3 and B-4 were applied to the Steel Arch Construction
magazines.
Side-on overpressures were modeled as emanating from either:  (1)
a partially confined explosion occurring in a 3-walled structure,
or (2) an unconfined hemispherical explosive charge detonated at-
grade.  Side-on overpressures for a forward blast in a Steel Arch
Construction magazine were calculated from Figure 4-63 of Reference
2.  Pr, Is, and Ir were estimated from Figure 4.5 or Figure 4.6 of
Reference 1 using the appropriate values of Ps.  The ratio of side-
on overpressures to dynamic pressures used in the calculation of
human organ threshold distance are from Figure 4-66 of Reference 2.

Table B-1 - Blast Calculations for Adjacent Explosion in M-13 Road
            Magazines (Zone 4 East)
Corrected                                        Corrected     Corrected    Corrected 
Side-on     Corrected                            Side-on       Reflected    Reflected 
Overpress   Scaled       Scaled                  Specific      Overpressu   Impulse  
ure         Distance     Distance     Distance   Impulse       re           Ir(P/Po)2/3 
Ps(P/Po)                 (Z)          (ft)       Is(P/Po)2/3   Pr(P/Po)     (psi-
(psi)**     Z(P/Po)1/3   Z = R/W1/3   R          (psi-         (psi)***     sec)*** 
                                                 sec)*** 
100         2.6          2.7          125        0.76          570.7        2.6 
50          3.5          3.6          169        0.61          206.3        2.2 
10          7.1          7.4          348        0.31          32.5         0.9 
1.0         30.0         31.3         1472       0.08          2.11         0.17 
0.58        46.6         48.7         2290****   0.05          1.23         0.10

Table B-1A - Organ Threshold Limits
  Threshold Organ Type    Maximum Effect Overpressure
                             (psi) (PSO1 + PDYN2)          Distance (ft) R          
  Eardrum                               5                       540                      
  Lung                                 30                       277                      
  Lethal                              100                       167                      
   *       M-13 Road Magazines in Zone 4 East could contain material
           up to 104,000 lb of Trinitrotoluene-equivalent explosives.
  **       From Reference 2, Figure 4.63 (modeled as a partially
           confined 3-walled structure).
 ***       From Reference 1, Figures 4.5 or 4.6.
****       Actual distance to nearest Modified-Richmond magazine.
1   From Reference 1.
2   From Reference 2, Figure 4-66.

Table B-2 - Blast Calculations for Adjacent Explosion in M-12 Road
            Magazines (Zone 4 East)
Corrected                                        Corrected     Corrected    Corrected 
Side-on     Corrected                            Side-on       Reflected    Reflected 
Overpress   Scaled       Scaled                  Specific      Overpress    Impulse  
ure         Distance     Distance     Distance   Impulse       ure          Ir(P/Po)2/3 
Ps(P/Po)                 (Z)          (ft)       Is(P/Po)2/3   Pr(P/Po)     (psi-
(psi)**     Z(P/Po)1/3   Z = R/W1/3   R          (psi-         (psi)***     sec)*** 
                                                 sec)*** 
100         2.6          2.7          114        0.69          570.7        2.4 
50          3.5          3.6          154        0.56          206.3        1.8 
10          7.1          7.4          317        0.28          32.5         0.83 
1.0         30.0         31.3         1338       0.07          2.11         0.16 
0.67        40.9         42.7         1825****   0.05          1.36         0.11

Table B-2A - Organ Threshold Limits
           Threshold Organ Type   Maximum Effect       Distance (ft) R       
                                  Overpressure (psi) 
                                  (PSO1 + PDYN2) 
           Eardrum                  5                  490                   
           Lung                    30                  252                   
           Lethal                 100                  152                   
      *  M-12 Road Magazines in Zone 4 East could contain material up to 78,000 
         lb of Trinitrotoluene-equivalent explosives. 
     **  From Reference 2, Figure 4.63 (modeled as a partially confined 3-walled 
         structure). 
    ***  From Reference 1, Figures 4.5 or 4.6. 
   ****  Actual distance to nearest Modified-Richmond magazine. 
1  From Reference 1. 
2  From Reference 2, Figure 4-66.

Table B-3 - Blast Calculations for Adjacent Explosion in M-9 Road
            Magazines (Zone 4 East)
[Font:Courier 12pt]
Corrected                                                           Corrected         Corrected    Corrected 
Side-on    Corrected                                                Side-on           Reflected    Reflected 
Overpress  Scaled       Scaled                                      Specific          Overpress    Impulse  
ure        Distance     Distance               Distance             Impulse           ure          Ir(P/Po)2/3 
Ps(P/Po)                (Z)                    (ft)                 Is(P/Po)2/3       Pr(P/Po)     (psi-
(psi)**    Z(P/Po)1/3   Z = R/W1/3             R                    (psi-             (psi)***     sec)*** 
                                                                    sec)*** 
100        2.6          2.7                    107                  0.65              570.7        2.24 
50         3.5          3.6                    145                  0.52              206.3        1.72 
10         7.1          7.4                    298                  0.26              32.5         0.78 
1.0        30.0         31.3                   1259                 0.07              2.11         0.15 
4.1        11.4         11.9                   480****              0.18              9.8          0.49 
5.0        10.4         10.8                   435*****             0.19              12.7         0.50

Table B-3A - Organ Threshold Limits
           Threshold Organ Type   Maximum Effect       Distance (ft) R       
                                  Overpressure (psi) 
                                  (PSO1 + PDYN2) 
           Eardrum                  5                  462                   
           Lung                     30                 237                   
           Lethal                 100                  143                   
       *   M-9 Road Magazines in Zone 4 East could contain material up to 65,000 
                                    lb of Trinitrotoluene-equivalent explosives. 
      **   From Reference 2, Figure 4.63 (modeled as a partially confined 3-walled 
                                    structure). 
     ***   From Reference 1, Figures 4.5 or 4.6. 
    ****                            Actual distance to nearest Modified-Richmond magazine. 
   *****   Actual distance to nearest Steel Arch Construction magazine. 
1  From Reference 1. 
2  From Reference 2, Figure 4-66.

Table B-4 -  Blast Calculations for Adjacent Explosion in Steel
             Arch Construction Magazines (5-Plex/Sideward Blast)
Corrected                                                           Corrected         Corrected    Corrected 
Side-on    Corrected                                                Side-on           Reflected    Reflected 
Overpress  Scaled       Scaled                                      Specific          Overpress    Impulse  
ure        Distance     Distance               Distance             Impulse           ure          Ir(P/Po)2/3 
Ps(P/Po)                (Z)                    (ft)                 Is(P/Po)2/3       Pr(P/Po)     (psi-
(psi)**    Z(P/Po)1/3   Z = R/W1/3             R                    (psi-             (psi)***     sec)*** 
                                                                    sec)*** 
100        2.6          2.7                    37                   0.22              570.7        0.77 
50         3.5          3.6                    50                   0.19              206.3        0.59 
10         7.1          7.4                    102                  0.09              32.5         0.27 
16.7       5.6          5.8                    80****               0.11              63.2         0.37 
44.4       3.5          3.6                    50*****              0.19              201.9        0.55

Table B-4A - Organ Threshold Limits
[Font:Courier 12pt]
      Threshold Organ Type   Maximum Effect       Distance (ft) R       
                             Overpressure (psi) 
                             (PSO1 + PDYN2) 
      Eardrum                  5                  158                   
      Lung                    30                   81                   
      Lethal                 100                   49                   
       *   Steel Arch Construction magazines could contain material up to 2600 lb 
           of Trinitrotoluene-equivalent explosives. 
      **   From Reference 2, Figure 4.63 (modeled as a partially confined 3-walled 
           structure). 
     ***   From Reference 1, Figures 4.5 or 4.6. 
    ****   Actual distance to nearest Modified-Richmond magazine. 
   *****   Actual distance to nearest Steel Arch Construction magazine. 
1  From Reference 1. 
2  From Reference 2, Figure 4-66.

Table B-5 - Blast Calculations for Adjacent Explosion in Steel Arch
            Construction Magazines (3- or 5-Plex/Backward Blast)
Corrected                                                           Corrected         Corrected    Corrected 
Side-on    Corrected                                                Side-on           Reflected    Reflected 
Overpress  Scaled       Scaled                                      Specific          Overpress    Impulse  
ure        Distance     Distance               Distance             Impulse           ure          Ir(P/Po)2/3 
Ps(P/Po)                (Z)                    (ft)                 Is(P/Po)2/3       Pr(P/Po)     (psi-
(psi)**    Z(P/Po)1/3   Z = R/W1/3             R                    (psi-             (psi)***     sec)*** 
                                                                    sec)*** 
100        2.6          2.7                    37                   0.22              570.7        0.77 
50         3.5          3.6                    50                   0.18              206.3        0.59 
10         7.1          7.4                    102                  0.08              32.5         0.27 
1.0        30.0         31.3                   430****              0.02              2.15         0.05

Table B-5A - Organ Threshold Limits
                             Maximum Effect                             
      Threshold Organ Type   Overpressure (psi)   Distance (ft) R 
                             (PSO1 + PDYN2) 
      Eardrum                5                    158                   
      Lung                   30                   81                    
      Lethal                 100                  49                    
      *  Steel Arch Construction magazines could contain material up to 2600 lb 
         of Trinitrotoluene-equivalent explosives. 
     **  From Reference 2, Figure 4.63 (modeled as a partially confined 3-walled 
         structure). 
    ***  From Reference 1, Figures 4.5 or 4.6. 
   ****  Actual distance to nearest Modified-Richmond magazine. 
1  From Reference 1. 
2  From Reference 2, Figure 4-66.

Table B-6 - Blast Calculations for Adjacent Explosion in Steel Arch
            Construction Magazines (3- or 5-Plex/Forward Blast)
Corrected                                                           Corrected         Corrected    Corrected 
Side-on    Corrected                                                Side-on           Reflected    Reflected 
Overpress  Scaled       Scaled                                      Specific          Overpress    Impulse  
ure        Distance     Distance               Distance             Impulse           ure          Ir(P/Po)2/3 
Ps(P/Po)                (Z)                    (ft)                 Is(P/Po)2/3       Pr(P/Po)     (psi-
(psi)**    Z(P/Po)1/3   Z = R/W1/3             R                    (psi-             (psi)***     sec)*** 
                                                                    sec)*** 
100        4.1          4.3                    59                   0.15              144.9        0.48 
50         5.9          6.1                    84                   0.11              56.2         0.33 
10         11.8         12.3                   169                  0.06              9.7          0.14 
1.0        53.0         55.3                   760                  0.014             1.2          0.03 
2.1        18.1         28.7                   430****              0.04              4.6          0.09

Table B-6A - Organ Threshold Limits
      Threshold Organ Type   Maximum Effect       Distance (ft) R       
                             Overpressure (psi) 
                             (PSO1 + PDYN2) 
      Eardrum                  5                  323                   
      Lung                    30                  108                   
      Lethal                 100                   82                   
      *  Steel Arch Construction magazines could contain material up to 2600 lb 
         of Trinitrotoluene-equivalent explosives. 
     **  From Reference 2, Figure 4.63 (modeled as a partially confined 3-walled 
         structure). 
    ***  From Reference 1, Figures 4.5 or 4.6. 
   ****  Actual distance to nearest Modified-Richmond magazine. 
1  From Reference 1. 
2  From Reference 2, Figure 4-66.

B.2 QUANTITY-DISTANCE CALCULATIONS

The limiting quantity-distance for structures in the vicinity of
any Modified-Richmond or Steel Arch Construction magazine was
examined when the magazines were considered both receiver and donor
facilities.  When the magazines were considered as receiver
facilities, adjacent structures containing high explosives or
insensitive high explosives were compared to the siting criteria
set forth in Reference 4, Tables 9-5 and 9-10, respectively.  High
explosives intermagazine limiting quality-distances were determined
from the orientation of the adjacent structures to the magazines. 
Depending on the orientation of these structures, the
multiplicative constant (X) used in the standard limiting quality-
distance = X . W1/3 equation varied.  Conservative orientations were
used in all cases.  For example, the limiting quality-distance for
the M-9 Road magazines (Zone 4 East) (65,000 lb Trinitrotoluene-
equivalent explosives) from any Modified-Richmond magazine is
computed using the equation limiting quality-distance = 2 . W1/3
(from Reference 4, Table 9-5).  Therefore, the limiting quality-
distance for this structure is limiting quality-
distance = 2 . (65,000)1/3 = 80 feet.  Insensitive high
explosives intermagazine limiting quality-distances were taken
directly from Reference 4, Table 9-10.
When the Modified-Richmond or Steel Arch Construction magazines
were considered as potential donor facilities (2,600 lb
Trinitrotoluene-equivalent explosives), the appropriate high
explosives interbuilding limiting quality-distances to adjacent
structures were determined using Reference 4, Table 9-3a.  For
example, the high explosives interbuilding limiting quality-
distance to Building 4-26 from the nearest Modified-Richmond
magazine (conservatively assumed to be a side blast) is 97 feet. 
High explosives intermagazine limiting quality-distances were taken
directly from Table 9-5, assuming conservative geometries between
magazines.  (Insensitive high explosives limiting quality-distances
were omitted from this analysis because both the Modified-Richmond
and the Steel Arch Construction magazines have designs and
construction features in accordance with Reference 4 and may
contain up to their physical capacity of insensitive high
explosives.)  Tables B-7 through B-9 present the limiting quality-
distances for facilities adjacent to the Modified-Richmond and
Steel Arch Construction magazines.

B.3 DEFINITION OF MAXIMUM CREDIBLE EXPLOSION MISSILE

Based on an analysis of the potential for explosions that could
occur in Zone 4, the maximum credible explosion that could affect
a Modified-Richmond or Steel Arch Construction magazine is an
explosion that could occur in a high explosives staging magazine
(i.e., a Modified-Richmond magazine) located on M-9 Road on the
east side of Zone 4.  Because this is the maximum credible
explosion that could affect the magazines, it also has the
potential to generate the maximum credible explosion missiles.  The
following discussion defines the mass and velocity of the maximum
credible explosion-generated missile that could affect a Modified-
Richmond or Steel Arch Construction magazine.
The mass and velocity of the maximum credible missile from an
explosion in a Modified-Richmond magazine on Road M-9 were defined
using information contained in DOE/TIC-11268 (Reference 1). 
Reference 1 contains data on fragment characteristics (e.g., mass
and range) from several documented explosions.  The data are
presented in percentile form.  Therefore, it is possible to select
a 95th percentile projectile such that 95 percent of all fragments
would be lower in mass and lower in range than that projectile. 
Given that the data were available only to the 95th percentile,
this percentile was chosen as the statistical cutoff point.  From
this reference, the 95th percentile fragment mass is 40 lbs and the
95th percentile range is 1485 ft.  (That is, there is about a 10
percent chance that a more threatening missile [in terms of either
mass or range] could be generated from the explosion of a Modified-
Richmond magazine on M-9 Road).

Table B-7 - Explosive Separation (Intermagazine) Distances -
            Modified-Richmond Magazines as Receiver (Limiting Cases Only)
Adjacent                High Explosives Limit       Required Minimum    Insensitive High   Required Minimum   Distance
Structure/              (Trinitrotoluene-             Separation        Explosives Limit      Separation      From Nearest
Vehicle                  Equivalence, lb)*          Distance - High     (Trinitrotoluene-     Distance -      Modified- Richmond
                                                      Explosives       Equivalence, lb)***  Insensitive High  Magazine (ft)
                                                        (ft)**                              Explosives (ft)**  
Magazines on M-13 Road
(4-71 through 4-75)-        104,000                     94              200,000               250              2290
                                                                                                              (4-39 through 4-44)
Magazines on M-12 Road
(4-65 through 4-70)-        78,000                      85              200,000               250              1825
                                                                                                              (4-39 through 4-44)
Magazines on M-9 Road
(4-45 through 4-51)-        65,000                      80              200,000               250              435
                                                                                                              (4-39 through 4-44)
Modified-
Richmond Magazines-         2,600                       38              200,000               N/A@             450
                                                                                                              (Any except 4-19,
                                                                                                              4-21, or 4-25
Steel Arch                  2,600                       18              N/A@                  N/A@             80
Construction Magazines+
                                                                                                              (4-39 through 4-42)
      *      Trinitrotoluene- equivalence for high explosives is obtained by multiplying the high explosives limit by 1.3
             (Example:  for closest Steel Arch Construction magazines; 2,600 lb Trinitrotoluene- equivalence = 
             1.3 . 2,000 lb high explosives limit).
     **      From Reference 4, Tables 9-5 and 9-10.
    ***      Trinitrotoluene- equivalence for insensitive high explosives is obtained by multiplying the insensitive high
             explosives limit by 1.0 (Example:  for closest Modified-Richmond magazines; 200,000 lb Trinitrotoluene-
             equivalence = 1.0 * 200,0000 lb insensitive high explosives limit).
        -    Considered non-standard earth-covered magazines (see Reference 4).
        +    Considered standard earth-covered magazines (see Reference 4).
        @    These donor magazines may contain up to their physical capacity of insensitive high explosives, because their
             construction and siting requirements comply with Reference 4.

Table B-8 - Explosive Separation (Intermagazine) Distances - Steel
            Arch Construction Magazines as Receiver (Limiting Cases Only)
Adjacent       High           Required               Insensitive          Required          Distance 
Structure/Vehi Explosives     Minimum                High                 Minimum           From 
cle            Limit          Separation             Explosives           Separation        Nearest 
               (Trinitrotol   Distance -             Limit                Distance -        Steel Arch 
               uene-          High                   (Trinitrotol         Insensitive       Constructio 
               Equivalence,   Explosives             uene-                High              n Magazine 
               lb)*           (ft)**                 Equivalence,         Explosives        (ft) 
                                                     lb)***               (ft)** 
Magazines on   65,000         80                     200,000              250               480 
M-9 Road                                                                                    (4-119 
(4-45 through                                                                               through 4-
4-51)-                                                                                      142) 
Modified-      2,600          18                     200,000              N/A@              450 
Richmond                                                                                    (4-125 
Magazines+                                                                                  through 4-
                                                                                            140) 
Steel Arch     2,600          18                     N/A@                 N/A@              50 
Construction                                                                                (Any) 
Magazines+
 
      *    Trinitrotoluene-equivalence for high explosives is obtained by 
           multiplying the high explosives limit by 1.3 (Example:  for closest 
           Steel Arch Construction magazines, 2,600 lb Trinitrotoluene-equivalence 
           = 1.3 . 2,000 lb high explosives limit). 
     **    From Reference 4, Tables 9-5 and 9-10. 
    ***    Trinitrotoluene-equivalence for insensitive high explosives is obtained 
           by multiplying the insensitive high explosives limit by 1.0 (Example:  
           for Steel Arch Construction Magazines, 200,000 lb Trinitrotoluene-
           equivalence = 1.0 . 200,0000 lb insensitive high explosives limit). 
      -    Considered non-standard earth-covered magazines (see Reference 4). 
      +    Considered standard earth-covered magazines (see Reference 4). 
      @    These donor magazines may contain up to their physical capacity of 
           insensitive high explosive, because their construction and siting 
           requirements comply with Reference 4.

Table B-9 - Explosive Separation (Intraline and Intermagazine) Distances - 
            Steel Arch Construction Magazines as Donors (Limiting Cases Only)
Adjacent            Required Minimum      Required Minimum       Distance From 
Structure/Vehicle   Separation Distance   Separation Distance    Nearest Steel Arch 
                    From Nearest Steel    From Nearest Steel     Construction 
                    Arch Construction     Arch Construction      Magazine (ft) 
                    Magazine - High       Magazine - 
                    Explosives (ft)**     Insensitive High 
                                          Explosives (ft)*** 
Steel Arch          18                    N/A                    50 
Construction                                                     (Any) 
Magazines-
Modified-Richmond   18                    N/A                    80 
Magazines-                                                       (Any) 
Magazines in        55                    N/A                    480 
Zone 4 East+                                                     (4-44 through 4-
                                                                 51) 
Building 4-145      250                   N/A                    550 
                                                                 (4-119) 
Building 4-26       97                    N/A                    700 
                                                                 (4-103 or 4-104) 
 
       *   Steel Arch Construction magazines have a maximum of 2,600 lb 
           Trinitrotoluene-equivalent of explosives. 
      **   From Reference 4; Tables 9-3a and 9-5. 
     ***   Steel Arch Construction magazines may contain up to their physical 
           capacity of insensitive high explosives, because their construction and 
           siting requirements comply with Reference 4. 
       -   Considered standard earth-covered magazines (see Reference 4). 
       +   Considered non-standard-earth covered magazines (see Reference 4).
A reasonable determination of the missile velocity from the range
can be performed by recognizing that, given a fixed range, the
velocity varies with the takeoff angle of the fragment (i.e., a
fragment that travels 1485 feet from the point of the explosion
could get there either by going very fast at a takeoff angle near
0o or near 90o, or by traveling less rapidly at a takeoff angle near
45o).  If we assume that the takeoff angle of fragments are
randomly distributed, then it is possible to determine a
95th percentile velocity in the following manner.  If the 40 lb
fragment could travel 1485 feet by taking off at any angle between
0o and 90o, then we need only eliminate the 95 percent of the angles
in this range associated with the lowest velocities to find a 95th
percentile angle.  The angles which bound the slowest 95 percent of
all velocities are 2.25o and 87.75o, both of which yield the same
velocity.  Therefore, 95 percent of all of the possible takeoff
angles with the lowest velocities lie between 2.25o and 87.75o.  The
velocity which corresponds to these two angles (i.e., the 95th
percentile velocity) is obtained using the standard trajectory
equation:
  R     =  [VoE2 SIN(2$)]/g               (Reference 5)
where:
  R     =  the range of the projectile (ft)
  Vo    =  the takeoff velocity (ft/s)
  -     =  the takeoff angle (degrees or radians)
  g     =    the acceleration due to gravity (ft/s2)
Solving this equation for velocity and substituting for known
values yields:
  Vo    =  [Rg/SIN(2$)]0.5
     =  [1485 . 32/SIN(2 y 2.25o)]E0.5
     =  778 ft/s
Therefore, the result is that we have a 40 lb missile traveling at
778 ft/s with a takeoff angle of 2.25o.  Neglecting the effect of
air friction, the striking velocity will be the same.
Now it is necessary to see if this projectile can actually strike
a Modified-Richmond or Steel Arch Construction magazine, the
closest of which is a Steel Arch Construction magazine 425 feet
away.  The height of a projectile, neglecting air friction, is
given by the following formula:
  Y     = [TAN($)]x - [g/(2(VoE2)(COSE2)[$])]xE2  (Reference 5)
where:
  Y     = the height of projectile at distance x (ft)
  x     = the distance of projectile from takeoff point (ft)
  g     = the acceleration due to gravity (ft/s2)
  Vo    = the takeoff velocity of the projectile (ft/s)
Substituting in the known values gives:
  Y     =  [TAN(2.25o)] * 425 - [32/2 * (778)E2 * COSE2(2.25o)] * 425E2
        =  11.9 ft
Therefore, the projectile will be no more than 11.9 feet off the
ground when it has traveled 425 feet, the distance to the Steel
Arch Construction magazine, so it is physically possible for the
missile to strike the magazine.  The structural analysis of this
missile impact is presented in Appendix C, Section C.5.  The
probability of this missile event sequence is discussed in Section
7.2.8 of the Final Safety Analysis Report, Zone 4 Magazines
(Reference 6).

B.4 REFERENCES

     A Manual for the Prediction of Blast and Fragment Loadings on
     Structures, DOE/TIC-11268, Revision 2, United States Department
     of Energy, April 1, 1982.
     Structures to Resist the Effects of Accidental Explosions, TM-
     5-1300, NAVFAC P-397, AFM 88-22, Departments of the Army, Navy,
     and Air Force, United States Government Printing Office,
     Washington, DC, November 1990.
     Letter from J.E. Hemphill, Division Manager, Environment,
     Safety, and Health Division, Mason & Hanger-Silas Mason Co.,
     Inc., to B.L. Gage, Chief of the Environment, Safety, Health,
     and Emergency Preparedness Branch, United States Department of
     Energy, Amarillo Area Office, Subject:  "Maximum High
     Explosives Limits Information," March 26, 1990.
     Ammunition and Explosives Safety Standards, Department of
     Defense 6055.9-STD, Change 3, United States Department of
     Defense, January 25, 1991.
     Physics for Scientists & Engineers, Serway, R.A., Saunders
     College Publishing, New York, New York, 1983.
     Final Safety Analysis Report, Pantex Plant Zone 4 Magazines,
     Issue D, United States Department of Energy, April 1993.

APPENDIX C
STRUCTURAL ANALYSIS SUMMARY

This appendix presents a summary of the structural analysis for the
Zone 4 Modified-Richmond and Steel Arch Construction magazines. 
The response of the structures to Earthquake, Tornados, adjacent
explosion pressures, and missiles is evaluated using current
Department of Energy natural phenomena design guidelines and
appropriate analytical methods.  The purpose of this structural
analysis was to determine if the magazines could be damaged as a
result of the forces produced by these external events.  This
appendix is a summary of the analysis contained in the for Zone 4
Safety Analysis Report (Reference 1).  The magazines are classified
as Moderate Hazard facilities, based on a Pantex-specific facility
ranking methodology.

C.1 DESCRIPTION OF ZONE 4 MAGAZINES

C.1.1 Modified-Richmond Magazines

The original Richmond magazine sides and back wall are constructed
using unreinforced concrete, gravity-type retaining walls.  The
walls are thick at the base and taper to the top.  The magazines
were modified by the replacement of the original wood front wall
and roof with reinforced concrete components.  A reinforced
concrete center wall was also added.  The center wall is a steel-
reinforced concrete wall that divides the structure into two
distinct staging areas.  This dividing wall extends throughout the
entire length and height of a magazine.  The interior wall extends
below grade into concrete footings.  The walls are joined to the
footings by male/female notches.  The original magazine berms
reached the top of the side walls; these berms were enlarged and a
layer of soil is placed over the reinforced concrete roof.
The reinforced concrete front wall is attached to the rest of the
structure at the center wall.  The roof consists of reinforced
concrete slabs, which are supported by the side walls, rear wall,
and front wall.  The slabs are precast in some of the magazines and
cast in place for others.  Values of compressive concrete strength
of 3,000 psi and 40,000 psi for the reinforcing rebar were used.
The entrance to the magazines consists of one set of double doors
for each staging or interim storage area.  The doors are
constructed A-7 steel plate.  Each door is supported by two hinges
with a center locking mechanism.  There are large concrete block
barriers placed in front of the doors for security purposes.

C.1.2 Steel Arch Construction Magazines

The main feature of a Steel Arch Construction magazine is a metal
arch constructed of corrugated, galvanized steel panels fitted
together with bolts.  The steel arch is embedded into the front,
back, and side walls using anchor bolts and strap anchors that
extend into the concrete.  Earth overburden is placed over the
steel arch.  The only penetration in the arch is for a steel
ventilation pipe that provides a pathway for natural air
circulation through the magazine.
The side (north and south) walls of the magazine are curb-like and
are part of the stem wall of the structure.  The front (east) wall
is constructed of reinforced concrete.  This wall extends to the
top of the structure and spans the width of the magazine.  This
wall rests on top of a steel-reinforced concrete stem wall. 
Extending along the front wall of a magazine are "connecting" walls
that intertie the 3- and 5-magazine complexes.  These walls, along
with the front wall of each individual magazine, form a continuous
concrete face for each complex.  The connecting walls are tapered
in height away from the magazine front wall.  The primary function
of these walls is to retain the earth overburden placed against the
sides of the magazines.  The back (west) wall extends to the top of
the structure and spans the width of the magazine.  The magazine
floor is a steel-reinforced concrete slab that rests upon coarse
aggregate fill.  The slab is also sloped back to front for drainage
purposes.
The single entry to the magazine is an insulated, steel double
door.  The double doors are secured to each other with two locking
hasps, and the entire door assembly is secured to the magazine
structure with locking bars at the top and bottom of the door
opening.  Separate key locks are used in each locking hasp. 
Located in front of and covering the magazine door is a two-piece,
steel-reinforced concrete barrier.  There are also headwall
barriers placed on either side of the door barrier to protect the
front wall of some magazines.  These headwall barriers remain in
place under all normal operating conditions.

C.1.3 Earth Overburden

The earth overburden covering both the Modified-Richmond and Steel
Arch Construction magazines consists of a sandy clay.  The average
dry density of the soil is 110 pcf and the water content is
approximately 15 percent.  Based on these values, the total weight
of the soil is 130 pcf.

C.2 DEFINITION OF DESIGN BASIS AND MAXIMUM CREDIBLE EVENTS

For natural phenomena events (e.g., Earthquakes and Tornados), two
levels of magnitude are studied for their effects on the magazines: 
(1) Design Basis, and (2) Maximum Credible.  Design Basis
magnitudes are described in Department of Energy-sponsored
guidelines (References 2, 3, and 4).  Maximum Credible magnitudes
are based both on Department of Energy-sponsored guidelines and on
a detailed study of the regional and the Pantex Plant geology,
seismicity, and meteorology (References 4 and 5).  Maximum Credible
Events are considered beyond the design basis for this facility. 
The aircraft crash scenario is based on a light, general aviation
aircraft with a weight of 3,500 pounds and an impact velocity of 80
mph.  The basis for this selection is provided in Appendix E.  The
magnitude of other external events (e.g., pressures from adjacent
explosions, explosion- and tornado-generated missiles) is either
based on the blast analysis summarized in Appendix B or is
prescribed in Department of Energy-sponsored guidelines.  Only a
single magnitude level for these latter external events is studied
in this analysis.  Table C-1 presents the events that are
considered for the structural analysis, their magnitudes, and the
basis for their selection.

C.3 EARTHQUAKE ANALYSIS


Table C-1 - Definition of Design Basis and Maximum Credible Events
Event               Design Basis         Maximum Credible     Basis 
                    Magnitude            Magnitude 
Earthquake          0.10 g               0.33 g               . References 2 and 
                    (98 cm/sec2)         (323 cm/sec2)          3 Design Basis 
                                                                Earthquake 
                                                              . Reference 5 
                                                                Maximum Credible 
                                                                Earthquake 
External Blast      N/A                  5.7 psi              . Blast Analysis 
(M-9 Road                                overpressure           (see Appendix B) 
Magazine)                                (equivalent static 
                                         load) 
Blast-Generated     N/A                  40 lb piece of       . Blast Analysis 
Missile                                  concrete at 778        (see Appendix B) 
                                         ft/s 
Tornado             150 mph (132 mph     220 mph              . References 2 and 
                    fastest mile         (200 mph fastest       3 
                    [straight] wind)     mile [straight] 
                                         wind) 
Tornado-Generated   . 15 lb, 2N/Ach x 4            y Reference 2 
Missile               inch wooden 
                      timber, traveling 
                      at 100 mph 
                      (horizontal); 
                      maximum height 150 
                      ft; 70 mph 
                      (vertical) 
                    . 75 lb, 3 inch 
                      diameter pipe, 
                      traveling at 
                      50 mph 
                      (horizontal); 
                      maximum height 
                      75 ft; 35 mph 
                      (vertical) 
Aircraft Impact     N/A                  3,500 lb aircraft    . Appendix E
                                         impacting at 
                                         80 mph 
This section summarizes the response of the magazines to earthquake
forces.  The structures were assessed for both the design basis
earthquake and the maximum credible earthquake, which is beyond the
design basis.  The design basis earthquake for Moderate Hazard
facilities at the Pantex Plant has a maximum horizontal
acceleration of 0.10 g and a frequency of occurrence of 1.0 x 10-3
per year.  The maximum credible earthquake for the Pantex Plant is
defined as having a maximum horizontal acceleration of 0.33 g, with
a frequency of occurrence between 1.5 x 10-5 and 1.0 x 10-4 per year
(Reference 3).  The Design Response Spectrum used for the design
basis earthquake was used for the maximum credible earthquake with
appropriate scaling.

C.3.1 Static Analysis

The magazines are examined using a conservative static analysis
approach.  The static analysis was limited to determining the total
base shear on the magazines produced by the earthquake and then
determining if the shear resistance of the various magazine
structural elements can resist the load.  No analysis of the
magazine contents or subsystems to the earthquake load is
presented.

C.3.1.1 Design Basis Earthquake/Maximum Credible Earthquake - Modified-Richmond Magazine Earthquake Summary

The magazine structure resists earthquakes by transferring the
resulting lateral loads through the connection between the roof and
the wall and through the walls to the base slab.  The sidewalls
also serve to resist the active earth pressures developed in the
overburden as a result of the earthquake.  The lateral loads
resulting from the horizontal acceleration of the roof are resisted
by the shear strength of the grout between the roof and walls.
Based on a 16-inch wide grout pad, the grout strength from the
design basis earthquake is 1,100 pounds per square foot or 8 psi. 
Grouts and mortars are typically capable of developing shear
stresses of approximately 50 psi.  Thus, the resulting factor of
safety is about 6.  This analysis is extremely conservative in that
it neglects the additional support provided by steel dowels between
the roof and the walls and only accounts for the shear transfer
between two of the four walls.  Frictional forces are also
neglected.
In addition to the loads imposed by the roof, the sidewalls may
undergo an increase in lateral load as a result of the Earthquake. 
A check for addition horizontal loads (active pressure), placed on
the walls by the Earthquake, indicated that the cohesive strength
of the soils is sufficient to prevent it from imposing additional
loads on the wall due to a design basis earthquake.
The analysis of the response of the structure to the maximum
credible earthquake, which is beyond the facility's design basis,
was performed in the same manner as for the design basis
earthquake.  The lateral response of the roof was scaled directly
from the design basis earthquake results.  The resulting shear
stress in the grout will be approximately 25 psi (3.3 * 8 psi);
thus, the factor of safety during the Maximum Credible Earthquake
is expected to be close to 2.
Table C-2 indicates that the Modified-Richmond magazines are not
expected to suffer any distress from the horizontal or vertical
loads associated with both the design basis earthquake and maximum
credible earthquake.  The values shown in Table C-2 were taken
directly from the Zone 4 Safety Analysis Report.

Table C-2 - Design Basis Earthquake/Maximum Credible Earthquake
Modified-Richmond Magazine Static Analysis Summary
                      Design               Maximum              Design              Results 
    Type of Load      Basis                Credible             Allowable 
                      Earthquake           Earthquake 
                      Value                Value 
                      (0.10 g)              0.33 g) 
Horizontal - Shear    8 psi                25 psi               50 psi              No Damage 
Load at Roof/Wall                                                                   (remains 
                                                                                    elastic) 
Vertical - Roof       175 in-kips          208 in-kips          453 in-kips         No Damage 
Bending Moment                                                                      (remains 
                                                                                    elastic) 
Vertical - Shear at   45 psi               54 psi               110 psi             No Damage 
Roof Supports                                                                       (remains 
                                                                                    elastic) 
Vertical - Load on    3,940 psf            3,970 psf            4,900 psf           No Damage 
Footing                                                                             (remains 
                                                                                    elastic)

C.3.1.2 Design Basis Earthquake/Maximum Credible Earthquake - Steel Arch Construction Magazine Earthquake Summary

The method to calculate the total base shear on the magazine
structure is also based on the general static analysis equation
(Reference 6).  The required strength of the structure will be
based on the horizontal force (F) exerted on the structure from the
weight of the surrounding soil and the corresponding equivalent
hydrostatic force (P) exerted on one side of the arch only.  The
vertical analysis for the steel arch assumes that the structure is
in a compression mode.  The design pressure (Py) is created by the
weight of the soil above the arch.
The static analysis of the response of the structure to the maximum
credible earthquake may be performed in the same manner as for the
design basis earthquake.  The response of the structure was scaled
directly from the design basis earthquake results.  The resulting
vertical and horizontal stress may be obtained by multiplying the
values for the design basis earthquake conditions by appropriate
scaling factors.
Table C-3 shows no damage to the Steel Arch Construction magazines
for the design basis earthquake event.  The vertical analysis
indicates that there is a significant safety margin in the
structure to resist the maximum credible earthquake loads.  In
addition, the horizontal analysis indicates that under maximum
credible earthquake conditions, minor damage may be expected
because the maximum allowable bending stress applied to the steel
arch (35.6 ksi) is greater than the capacity of the structure (33
ksi).  However, because of the significant safety factors applied
to the construction of the steel arch and to the analytical
techniques used, only very minor damage is expected.

Table C-3 - Design Basis Earthquake/Maximum Credible Earthquake Steel Arch 
            Construction Magazine Static Analysis Summary
  Type of Load        Design               Maximum              Design              Results 
                      Basis                Credible             Allowab 
                      Earthquake           Earthquake           le 
                      Value                Value 
                      (0.10 g)             (0.33 g) 
Horizontal -          10.78 ksi            35.6 ksi             33.0                Minor yielding 
Bending                                                         ksi                 of Arch at 
Stress on                                                                           Maximum Credible 
Arch due to                                                                         Earth-quake, but 
Soil Loads                                                                          no failure, 
                                                                                    Design Basis 
                                                                                    Earthquake 
                                                                                    remains elastic 
Vertical -            0.386                1.275                3.658               No Damage 
Wall                  in2/ft               in2/ft               in2/ft              (remains 
Cross-Sectio                                                                        elastic)
nal Area (A)

C.3.2 Dynamic Analysis

C.3.2.1 Design Basis Earthquake/Maximum Credible Earthquake - Modified-Richmond Magazine Earthquake Summary

For the horizontal dynamic analysis, the roof and center wall were
modeled as an inverted pendulum, the motion of which is restricted
by the forces developed at the roof-sidewall connection.  This
connection is assumed to be rigid in the analysis.  The results are
then checked against the capacity of the connection.  If the
resulting reactions are less than the capacity, the assumption of
rigidity is valid.
Modeling the roof as a compression spring connecting the centerwall
and the sidewalls, an equivalent earthquake static load is
calculated to be 8.75 lb/ft.  Since the static analysis used an
earthquake load of 36 lb/ft for the design basis earthquake, the
static analysis is conservative.  In addition, the Maximum Credible
Earthquake static analysis is also conservative.  Thus, no
components of the magazine facility are vulnerable to either the
design basis earthquake or the maximum credible earthquake.

C.3.2.2 Design Basis Earthquake/Maximum Credible Earthquake - Steel Arch Construction Magazine Earthquake Analysis

The horizontal motions of the steel arch structure are obtained by
modeling the structure as a "pinned-pinned arch," with modes being
 symmetric and  antisymmetric about the midspan (Reference 7,
Table 9-2, Case 2).
Because the maximum horizontal bending stress of the steel arch
(5,776 psi) is significantly less than the allowable bending stress
of A-36 steel (33,000 psi), no failure of the structure is expected
for either the design basis earthquake or the maximum credible
earthquake.
Both the vertical and horizontal analyses indicate that there are
significant safety margins in the structure to resist the maximum
credible earthquake loads.

Table C-4 - Design Basis Earthquake/Maximum Credible Earthquake Steel Arch 
            Construction Magazine Dynamic Analysis Summary
   Type of Load       Design               Maximum              Steel Arch          Results 
                      Basis                Credible             Capacity 
                      Earthquake           Earthquake 
                      Value                Value 
                      (0.10 g)             (0.33 g) 
Horizontal -          5,776 psi            19,061 psi           33,000 psi          No Damage 
Maximum                                                                             (remains 
Bending                                                                             elastic) 
Stress (-H)
Vertical -            0.322                1.063 in2/ft         3.658 in2/ft        No Damage 
Wall Cross-           in2/ft                                                        (remains 
Sectional                                                                           elastic)
Area (A)

C.4 EXTERNAL EXPLOSION ANALYSIS

Based on consequence and probability estimates contained in
Appendix B, "Blast Calculations" and the Zone 4 Safety Analysis
Report, the maximum credible blast environment that a Modified-
Richmond or Steel Arch Construction magazine could experience would
result from a detonation of 50,000 lbs of high explosives in a
Richmond magazine on M-9 Road (Zone 4 East).  The effects of this
maximum credible explosion on both types of magazine structures are
discussed below.

C.4.1 Modified-Richmond Magazine

The maximum credible external explosion affecting Zone 4 could
result in a side-on overpressure of 4.1 psi and a corresponding
impulse of 0.18 psi-sec affecting a Modified-Richmond magazine. 
This blast acts as distributed load on the roof of the structure. 
For the purposes of the following calculation, the blast is modeled
as a triangular pulse with a peak value of 4.1 psi and a duration
(td) of 0.087 sec.
An equivalent static load may be computed based on the ratio of the
time of duration for the triangular pulse to the natural period of
the roof beam.  The natural period of a simply supported beam was
calculated in the seismic analysis section (T = 0.11 sec).
The Dynamic Load Factor obtained from Biggs (Reference 8) is 1.4. 
Thus, the equivalent static load is calculated to be 5.7 psi or 826
psf.  The combination of the blast load and the dead load (540 psf)
results in a maximum bending moment of 295 in-kips.  From the
seismic analysis, the ultimate capacity of the beam is 453 in-kips.
Because the maximum bending moment is less than ultimate capacity
of the roof beam, the roof will not collapse as a result of a
detonation in a Modified-Richmond magazine on Road M-9.
The steel doors of the facility are modeled as plates simply
supported along the top, bottom, and hinged side.  Since the
concrete barriers in front of the doors can be expected to shield
them from the effects of the reflected pressure, they are assessed
only against the side-on overpressure.
The side-on pressure necessary to yield the doors is 7.56 psi.  The
natural frequency of the door is (Reference 9) calculated to be 115
sec-1, and the period of the door is 0.054 sec.  The response of the
door may be obtained using td/T = 0.087/0.054 = 1.61 and
R/F = 7.56/4.1 = 1.84 and Figure 2.24 in Biggs.  The resulting
ductility ratio is 0.9, indicating the plate will not yield.  The
door can thus withstand the expected blast pressures, provided the
concrete front barriers are in place.

C.4.2 Steel Arch Construction Magazine

The maximum credible external explosion in Zone 4 could result in
a peak overpressure on the roof of 5.0 psi and a specific impulse
of 0.19 psi-sec affecting a Steel Arch Construction magazine.  This
pressure-time history may be represented by a triangular pulse with
a td of 0.076 sec.
The period of steel arch under a pure compressive load is computed
to be 0.03 sec.  From Reference 6, Figure 2-7, the dynamic load
factor is equal to DLFmax = 2, which leads to an equivalent static
load (Ls) on the roof of the structure of 10 psi (1440 psf). 
Equivalent static load (Ls) is used to compute ring compression (C)
of 18723 lb/ft.  Therefore, the required wall cross-sectional area
(A) can be computed to be 1.34 in2/ft.  Because the required wall
cross-sectional area (1.34 in2/ft) is much less than the actual
cross-sectional area of the steel arch (3.658 in2/ft), the
structure is expected to withstand the blast overpressure.
The doors on the Steel Arch Construction magazine are similar to
those on the Modified-Richmond magazines except in cross section. 
The Steel Arch Construction doors are steel plated backed angles. 
The plates have an equivalent thickness of approximately 1.38 in,
and a capacity at yield of 3.1 psi.  The natural period is 0.04
sec.  Using the same design charts as for the Modified-Richmond
magazine with td/T of 0.076/0.04 = 1.9 and R/F of 3.1/5.0 = 0.62
results in a ductility ratio of approximately 17.  The ductility
ratio of 17 implies significant deformations and is towards the
upper bound (20) of allowable deformations (Reference 10). 
However, the loading on the door is probably overstated, given the
shielding effects of the concrete barriers.  Furthermore, the yield
is based on the development of the plastic moment at one point, the
mid-span of the unsupported side of the door.  The pressures
required to develop the rest of the plastic hinges will be somewhat
higher.  The doors are thus expected to undergo significant plastic
deformations, but remain in place.

C.5 EXPLOSION-GENERATED MISSILE ANALYSIS

The maximum credible explosion-generated missiles that could
threaten a Modified-Richmond or Steel Arch Construction magazine
would be from a hypothetical explosion of 50,000 lbs of High
Explosives in a Richmond magazine on Road M-9 (Zone 4 East) (see
Appendix B).  The donor Richmond magazine is constructed of
unreinforced concrete and a wooden truss roof.  The maximum
credible missile produced by this explosion is estimated to be a 40
lb concrete fragment traveling 778 ft/sec (see Appendix B). 
Because all Modified-Richmond and Steel Arch Construction magazines
face east (toward the Road M-9 Richmond magazines), the security
barriers covering the front of each magazine would be the most
likely target for explosion-generated missiles.  Probability
discussions in the Zone 4 Safety Analysis Report also indicate that
the security barriers are the only credible missile target.
To determine if this missile penetrates the concrete barrier in
front of the magazines (which is identical for both Steel Arch
Construction and Modified-Richmond magazines), the methods
described in Reference 11 are followed.  This reference presents a
general penetration equation, which can be used regardless of the
source of the missiles.  This equation relates the scabbing
thickness (i.e., the thickness of the concrete barrier needed to
resist scabbing on the inward face) to the weight, velocity and
size of the missile and to the strength of the concrete barrier. 
The scabbing thickness  serves as a very conservative estimate of
the penetration thickness (i.e., the thickness of the concrete
barrier needed to resist penetration) (Reference 12).
The scabbing thickness is calculated to be 24.1 in.  Thus, the
barrier must be 24.1 inches thick or scabbing off the back face of
the barrier will occur.  The barrier is 24 inches thick at its
thinnest point, so scabbing by the missile is expected to occur. 
Because the required thickness to resist scabbing is the same as
the actual barrier thickness, it would be overly conservative to
conclude that the missile will actually penetrate the barrier and
strike the magazine.  (It is important to note that the analysis is
already extremely conservative because a non-deformable missile is
assumed.  The real missile is concrete, which is likely to break up
on impact).  Since the penetration of the magazine wall will not
occur, the only damage of interest would be to the concrete
barrier, not to the magazine itself.  Thus, the effects on the
Modified-Richmond and Steel Arch Construction magazines due to the
maximum credible explosion-generated missiles are negligible.

C.6 TORNADO ANALYSIS

Of the three types of winds (straight, hurricane, and tornado)
investigated, tornados are considered the most pertinent and severe
for the Pantex Plant.  The only components of the Modified-Richmond
and Steel Arch Construction magazine that may be vulnerable to
these winds are the doors.  The doors are blocked with large
concrete blocks, which must be moved before the steel magazine
doors can be opened.  Because the magazines are closed and the
concrete blocks replaced at the first sign of severe weather, the
magazines are modeled in this secured configuration.
The design basis tornado and maximum credible tornado wind speeds
used in assessing the structure are 132 mph and 200 mph,
respectively.  The resulting pressures are 36 psf for design basis
tornado and 82 psf for maximum credible tornado.  The effective
pressure on the concrete blocks, depending on its orientation to
the wind, is shown in Table C-5.

Table C-5 - Effective Pressure for Design Basis Tornado and Maximum
            Credible Tornado
Orientation of Wind      Design Basis         Maximum Credible     Concrete            Results 
                         Tornado Value        Tornado Value (82    Block 
                         (36 Psf at 132       Psf at 200 mph)      Toppling 
                         mph)                                      Capacity 
Windward: 80 percent     29.6 psf             66.0 psf             140.0 psf           No 
of Pressure for Design                                                                 Damage 
Basis Tornado and                                                                      (block 
Maximum Credible                                                                       remains 
Tornado                                                                                upright) 
Leeward: -50 percent     -18.0 psf            -41.0 psf            140.0 psf           No 
of Pressure for Design                                                                 Damage 
Basis Tornado and                                                                      (block 
Maximum Credible                                                                       remains 
Tornado                                                                                upright) 
Side: -70 percent of     -25.0 psf            -57.0 psf            140.0 psf           No 
Pressure for Design                                                                    Damage 
Basis Tornado and                                                                      (block 
Maximum Credible                                                                       remains 
Tornado                                                                                upright)
Because it requires approximately 140 psf to topple the blocks, the
magazines are considered invulnerable to the design basis tornado
and the maximum credible tornado.

C.7 TORNADO-GENERATED MISSILES

Two types of missiles are considered in this analysis:  (1) a
tornado-driven, 75-lb, 3-inch diameter pipe traveling at 50 mph,
and (2) a tornado-driven, 15-lb, 2-inch by 4-inch wooden timber
traveling at 100 mph.  Tornado-driven missiles are specified as a
Design Basis Accident in the Department of Energy design and
evaluation guidelines.
Similar to Section C.5, Explosion-Generated Missile Analysis, the
scabbing thickness is used to determine if the missile penetrates
the magazine's concrete barrier.  The scabbing thickness is
calculated to be 8.0 inches for the pipe missile and 6.6 inches for
the timber missile.  The barrier is 24 inches thick at its thinnest
point, so scabbing (and, thus, penetration) by both the pipe
missile and the timber missile is not a problem.

C.8 AIRCRAFT IMPACT ACCIDENTS

General aviation aircraft represent the only credible threat to the
Modified-Richmond and Steel Arch Construction magazines in Zone 4
(see Appendix E).  For purposes of assessing the damage potential
of these aircraft, the following parameters are used:
      Aircraft Weight          =        3,500 lbs
      Aircraft Impact Velocity =        80 mph
The weight is typical of light general aviation aircraft which make
up the bulk of the class.  The impact velocity is approximately 1.3
multiplied by the stall speed (y60 mph for aircraft of this class). 
The aircraft impact area is 20 ft2.
The analysis consists of converting the momentum of the airplane
into an impulsive load for the component (roof or front door) of
interest.  The roof and concrete front barriers are also checked
against penetration.

C.8.1 Modified-Richmond Single Degree of Freedom

The resulting load time history is applied to a single degree of
freedom system representing the magazine response.  The system has
the same elastic-plastic deformation properties as the magazine. 
The loading is not assumed to be attenuated by the soil cover,
however the soil does distribute the load and serve as additional
mass in the calculations.  This analysis is conservative since the
impulse is assumed to act normal to the structural surfaces
involved.
The maximum response is calculated to be approximately 1.3 times
the elastic response and well within the allowable limits.
Assessing other general aviation weight and velocity combinations
in the same manner results in the following combinations, which
yield the maximum allowable deflection:
      Weight    3,500 lbs               5,000 lbs             6,200 lbs
      Velocity    105 mph               88 mph                   80 mph
Using bomb penetration data, the energy required to penetrate
concrete covered with soil is estimated to be 38.0E+06 (lbs, fps)
(Reference 10).  Energy is typically expressed in terms of WV1.8 for
penetration problems of this type.  This is a result of empirical
fits rather than derivation.
The energy contained in the aircraft at impact (3,500 lbs at
117 fps) is 18.4 x 106 (lbs, fps).  Thus, the plane is not expected
to penetrate the roof.

C.8.2 Impact on Steel Arch Construction Magazine

For the analysis of the aircraft impact on the Steel Arch
Construction magazine, it is conservatively assumed to be a static
load because the dynamic load factor (Reference 8) is calculated to
be less than 1.0.  The resulting peak stress is calculated to be
6.1 psi.
Because the resulting stress (17,400 psi calculated from F=Mc/I) is
less than the allowable (33,000 psi material strength), the arch
will survive.  Since the arch shape is susceptible to buckling
effects, the critical stress for buckling is compared to the actual
stress.  The actual stress (6.1 psi) is less than the critical
buckling stress (41.6 psi).  Thus, the arch will not buckle.
Penetration analysis is performed assuming the aircraft generates
a peak load of 77,600 lbs over a 20 ft2 area.  Allowing for a
maximum dynamic load factor of 2.0, the actual shear stress is
calculated to be 3,000 psi with an allowable shear stress of
approximately 14,000 psi.  Thus, the shear limits of the steel arch
are not exceeded.

C.8.3 Impact on Concrete Barriers

The light aircraft cannot penetrate the barriers.  This is based on
data for general purpose bombs, which indicates that for general
purpose bombs of 500 lbs or less, perforation is limited to
approximately 1.7 ft (Reference 10).  This occurs only at much
higher velocities than being considered here.  The 500 lb was used
as a limit since this is the approximate weight of the engine.  The
rest of the aircraft is light weight and easily crushable and,
therefore, not considered a penetration threat.

C.8.4 Conclusions

The Modified-Richmond magazines are more vulnerable than the Steel
Arch Construction magazines to aircraft impact.  Both should be
able to withstand the impact of the light aircraft postulated in
Appendix E.

C.9 REFERENCES

1.  Final Safety Analysis Report, Pantex Plant Zone 4 Magazines,
    Issue D, United States Department of Energy, April 1993.
2.  Design and Evaluation Guidelines for Department of Energy
    Facilities Subject to Natural Phenomena Hazards,
    UCRL-15910-Interim, Lawrence Livermore National Laboratory,
    October 1989.
3.  Natural Phenomena Hazards Modeling Project:  Seismic Hazards
    Models for Department of Energy Sites, UCRL-53582, Rev. 1,
    Lawrence Livermore National Laboratory, November 1984.
4.  Natural Phenomena Hazards Modeling Project:  Extreme
    Wind/Tornado Hazards Models for Department of Energy Sites,
    UCRL-53526, Lawrence Livermore National Laboratory,
    February 1984.
5.  Seismic Hazard and Building Structure Behavior at the Pantex
    Facility, URS/John A. Blume & Associates, Engineers, prepared
    for the United States Energy Research and Development
    Administration, Amarillo Area Office, April 1976.
6.  Uniform Building Code, 1988 Edition, International Conference of
    Building Officials, Whittier, California, 1988.
7.  Formulas for Natural Frequency and Mode Shape, Blevins, Robert
    D., Kreger Publishing Co., 1979.
8.  Introduction to Structural Dynamics, Biggs, John M., McGraw-Hill
    Co., New York, New York, 1964.
9.  Theory and Analysis of Plates, Szilard, Rudolph, Prentice
    Hall, 1974.
10. Protection From Non-Nuclear Weapons, Air Force
    Weapons Laboratory Technical Report 70-127
    (AFWL-TR-70-127), February 1971.
11. Handbook of Steel Drainage and Highway Construction,
    AISC, Third Edition, 1983.
12. "Impact of Solid Missiles on Concrete Barriers,"
    Journal of the Structural Division, American Society
    of Civil Engineers, Vol. 107, pp. 252-271, No. ST2,
    February 1987.

APPENDIX D
FORKLIFT OPERATIONAL ACCIDENTS

D.1 FORKLIFT ACCIDENT

The Zone 4 operations were carefully examined for the possibility
of operational accidents.  The most limiting accident involves a
forklift puncturing an AL-R8 pit container, which was qualitatively
estimated to have potentially significant consequences in the
failure modes and effects analysis performed in the Zone 4 Safety
Analysis Report.  This accident involves the special forklift that
would operate in magazines with the planned palletized,
horizontally stacked pit containers.
The forklift will have a single boom projection for picking up
specially designed pit pallets, instead of the double tine fork
mechanism usually found on forklifts.  The forklift will also have
many safety features that should prevent the puncture accident. 
Among these are metal guide rails that should physically prevent
the forklift from veering into a stack of pallets and sensors that
will prevent the movement of the forklift boom, unless it is
positioned properly in both the vertical and horizontal planes for
picking up a pallet.  In addition, the operators will be trained to
exercise extreme care in performing operations in the magazines. 
Many factors are involved that reduce the probability of damage to
a pit, even if a forklift accident were to occur.  These include
the angle of incidence of the boom on the container, the range of
forklift forces and velocities involved, and other factors. 
However, since the design of the forklift/pallet system was not
complete at the time of publication, it was not possible to do a
complete quantitative analysis of the system to determine the
probability of occurrence of a forklift accident.  Therefore, the
forklift accident that involves damage to a pit in a container is
assigned a probability of "Likely" according to Department of
Energy guidance, and the consequences are estimated.
After consideration of the range of operational accidents that
could occur, a bounding accident scenario was developed.  This
accident could occur when a 20,000 lb forklift traveling at 5 mph
strikes a horizontally positioned AL-R8 container that is fixed. 
The impact occurs between the boom of the forklift and the AL-R8
container.  The boom is square in cross-section and blunt on the
end.  The boom is presumed to impact the side of a can, puncturing
the container so as to crush the pit.  The pit, which contains
inert gas at atmospheric pressure, expels the gas and plutonium
dust as it is crushed from its original volume to an assumed final
volume of zero.  A conservative estimate of 20 mg of plutonium dust
was selected for analysis.  The exit orifice is assumed to be a 1/4
inch diameter hole where the pit tube is attached to the pit, a
joint that is postulated to fail under such stress.  The crushing
of the pit is expected to cause no other failure of the pit due to
the ductility of the shell and cladding.  Thus, the pit crushing
event is modeled as a cylinder/piston system in which the piston
stroke forces the cylinder contents out through an exit orifice. 
The crushing of the pit is assumed to take place in a time based on
the forklift speed.  The contents of the pit exit through a known
orifice, imparting a known volume flow rate and thus a known
velocity to the pit contents.  This velocity represents a kinetic
energy imparted to the contents, a large fraction of which is
imparted to gas and small fraction of which is imparted to the
plutonium dust.  This energy is used to estimate the amount of
plutonium that becomes airborne in the air inside the AL-R8
container using an accepted experimentally derived equation.  Then,
the amount of plutonium exiting the AL-R8 can be estimated by
calculating the volume change of the container during its crushing,
thus producing a pressure change.  The plutonium which finally
escapes into the air breathed by workers is given a very
conservative assumed dispersion, from which lung and whole body
committed effective dose equivalent's may be calculated.
An analysis was performed in the Zone 4 Safety Analysis Report to
determine the amount of plutonium released to the worker
environment, worker exposure, and worker dose.  These results are
summarized below:
      (1)    The worker would be expected to receive 0.02 yCi through
breathing;
      (2)    The resultant 50-year committed effective dose
             equivalent for lungs would be 24 rem; and
      (3)    The resultant 50-year committed effective dose
             equivalent for whole-body dose would be 6.6 rem.
This scenario, and the resulting radiation dose to workers, is
extremely conservative for a number of reasons.  First, as the pit
is crushed, it is very unlikely that 100 percent of the plutonium
dust inside will be expelled into the air of the AL-R8 container. 
Test data indicate that less than 10 percent of the plutonium
contents would be expected to release in far more energetic
accidents.  No credit is taken for the fact that some of the
plutonium dust will cling to the inside surface of the pit. 
Likewise, no credit was taken for the significant amount of
plutonium dust that may be expected to cling to the celotex
insulation and the inside surface of the AL-R8 container.  As a
result, arguments may be made that this analysis of the release
fractions and corresponding doses could be an order of magnitude
conservative.

D.2 SUMMARY OF POTENTIAL EFFECTS

The potential consequences of an accident involving the puncture of
a pit container by a forklift boom could range from negligible to
marginal.  No permanent damage to the structures or their contents
is expected, though decontamination could require the expenditure
of a marginal amount of funds.  No consequences to the public or
the environment are anticipated.  The workers in the immediate
vicinity of the accident site could receive a marginal radiation
dose.  The effect on program continuity would be negligible.

D.3 REFERENCES

Appendix D "Forklift Operational Accidents" is provided from the
Final Safety Analysis Report, Pantex Plant Zone 4 Magazines, Issue
D, United States Department of Energy, April 1993.

APPENDIX E
AIRCRAFT HAZARD ANALYSIS

This appendix presents an analysis of the likelihood of an aircraft
crash into a Modified-Richmond or Steel Arch Construction magazine
in Zone 4.  Methodologies developed previously to estimate the
probability of an aircraft crash into specific structures and
current data describing the air traffic around the Pantex Plant are
used in this analysis.  Based on the guidance provided in
Department of Energy Albuquerque Order 5481.1B, if the likelihood
of any potential accident is less than 1 x 10-6 per year, the event
is considered incredible and its potential consequences need not be
reported in the safety analysis.  However, if the annual
probability of an aircraft crash into a magazine is greater than or
equal to 1.0 x 10-6, a quantitative analysis of the resulting
consequences is required (Reference 1).  As a quality assurance
measure, all calculations were performed by one analyst and
verified by a second analyst.

E.1 BACKGROUND

The Pantex Plant is located about 12.8 kilometers northeast of
Amarillo, Texas, approximately 13.6 kilometers from the northeast-
southwest runway at the Amarillo International Airport.  There is
an approximately square prohibited airspace extending to 4,800 feet
mean sea level directly above the site that measures about
7.1 kilometers on a side.  Sandia National Laboratories performed
an assessment of the probability of aircraft impact into Pantex
Plant structures in the mid-1970s (Reference 2).  That study used
the Best-Estimate Model of K. Solomon (Reference 3) and included a
thorough characterization of the air traffic in the area, i.e., the
classes of aircraft (e.g., commercial, military), the nature of the
operations, the number of operations per year, and other
information that could affect the probability of an aircraft crash
onto the Pantex Plant.
As noted in the Sandia study, the number of air operations annually
in the immediate site vicinity is influenced by several factors. 
There is a regional air navigational aid, known as a VORTAC, that
is located within 8 kilometers of the plant.  Thus, the air traffic
in each of the 13 low altitude and eight high altitude air
corridors serviced by the VORTAC contributes to air traffic in the
vicinity of the Pantex Plant.  Also, because the Pantex Plant is
located in farm country, aerial application activities (i.e., crop
dusting) for several farm plots near the plant add to the air
traffic volume.  The 1976 Sandia study estimated that the overall
probability of an aircraft crash into any of the structures
(including the interstructure ramps) within either Zone 4 or the
production area of Zone 12 of the Pantex Plant is 4.7 x 10-6,  per
year.  The effective area (see Section E.2 for definition) of
structures for potential impact in Zones 4 and 12 is approximately
5.6 square kilometers and includes over 50 major structures and
other facilities.
The basic approach of the 1976 Sandia study is used in the current
analysis, and the probability of an aircraft crash into a Zone 4
magazine is addressed in the following manner.  First, the data
used in the Sandia study were evaluated for applicability at this
time.  The 1976 assessment was based upon 141,500 yearly air
operations near the plant.  Discussions with Federal Aviation
Administration staff (Reference 4) indicate that air operations at
the Amarillo airport currently range between 80,000 and 85,000
annually.  This is modestly lower (approximately 10 to 15 percent)
than the activity reported for Fiscal Year 1987, which was 93,316
(Reference 5).  In addition, a review of 14 days of randomly
selected air traffic data from 1989 Federal Aviation Administration
records suggests that there are approximately 120,000 flights per
year in the air traffic corridors near the Pantex Plant, or about
15 percent less than the 1976 Sandia study.  Because the more
recent data is limited to 14 days, the flight count used in the
1976 Sandia study will be used to maintain conservatism in this
analysis.
The 1976 Sandia study was completed 15 years ago, therefore, more
recent aircraft accident statistics were reviewed to ensure that
the analysis could be accomplished using the Sandia methodology. 
The accident rates for commercial aircraft and general aviation
show a decline over the past 10 years.  The 1976 Sandia study
reported the fatal crash rate for commercial aircraft as 5.12 x 10-9 
mile (3.2 x 10-4/100,000 km).  A review of the Federal Aviation
Administration statistics (Reference 6) for the years 1978-1988
(see Table E-1) indicates that the fatal accident rate varies from
approximately 0.3 x 10-9 to 1.9 x 10-9 per mile for air carriers,
with a mean of 1.1 x 10-9 per mile.  However, this data must be used
with discretion because it includes all phases of all flights in
which a fatality occurred, even if that fatality occurred on the
ground.  Because the Pantex Plant is located approximately 14 km
(8.7 miles) from the Amarillo Airport, the accident rate of
interest is that for in flight accidents in which fatalities
occurred.  A recent Sandia examination (Reference 7) of the Federal
Aviation Administration and National Transportation Safety Board
data bases indicates that in the 1980 to 1988 time frame there were
31 fatal accidents of which only 18 in flight involved fatalities
and aircraft destruction.  Thus, the mean fatal accident rate is
reduced by the ratio 18/31 = 0.581 to provide an estimate of an in
flight accident rate in which the accident is severe enough to
seriously damage or destroy a Zone 4 magazine.  This accident rate
is 6.39 x 10-10 per mile, which is the value that will be used in
the analysis.

Table E-1 - Fatal Accident Rate by Year 1978-1988
Year   Rate per 10E9 Miles 
1978   1.9 
1979   1.7 
1980   0.3 
1981   1.4 
1982   1.4 
1983   1.3 
1984   0.3 
1985   1.9 
1986   0.5 
1987   0.9 
1988   0.4 
Mean   1.1
For General Aviation, the 1976 Sandia study reported a fatal
accident rate of 3.2 x 10-7/mile, (1.976 x 10-2/100,000 km) while
current Federal Aviation Administration data of 1.4 fatal
accidents/100,000 hours flown, suggest that a rate of 8.0 x 10-
8/mile (5.0 x 10-8/km) is reasonable, assuming an average speed for
general aviation of 170 mph.  However, like the commercial data,
this rate includes all accidents in which fatalities occurred.  The
National Transportation Safety Board accident reports for general
aviation was recently reviewed by Sandia (Reference 8) to ascertain
the proper rates for application to the Pantex Plant Zone 4
aircraft crash probability estimates.  The data for the years 1977
through 1988 indicate that there is a strong correlation between
the number of accidents in which there were fatalities and serious
injuries and the number in which the aircraft were destroyed. 
(Correlation coefficient 0.936.)  It is also noted that both
quantities show a decline (approximately 33 to 40 percent) over the
1977 to 1988 time period (see Table E-2).  This follows to some
extent the decline (approximately 21 percent) in hours flown, thus
there may not be such a decline in accident rates.

Table E-2 - Summary of Aircraft Accidents - United States General
Aviation
Year      Aircraft Accidents Involving 
          Fatalities                     Serious    Fatalities   Aircraft 
                                         Injuries   + Serious    Destroyed 
                                                    Injuries 
1977      661                            427        1088         1129 
1978      718                            427        1146         1118 
1979      631                            374        1005         998 
1980      618                            398        1016         1014 
1981      654                            349        1003         1121 
1982      591                            338        929          978 
1983      555                            319        874          860 
1984      543                            348        891          894 
1985      497                            306        803          795 
1986      431                            317        748          744 
1987      431                            290        721          673 
1988      447                            288        735          668 
Average   565                            348        913          916
Using aircraft destroyed as the starting point, Sandia also
examined the data base to determine how many aircraft were
destroyed during in flight accidents as opposed to other causes. 
The number of aircraft destroyed in flight is approximately one-
third to one-half the total destroyed.  The hours flown, the number
of aircraft destroyed in flight, and the number of aircraft
destroyed in flight per 100,000 hours flown by class and total are
presented on Tables E-3 through E-5.  These data can be used to
generate an accident rate, aircraft destroyed per million miles by
assuming a reasonable average speed for the various classes of
general aviation.  The results are presented in Table E-6.  The
eight-year average accident rate is 7.1 x 10-8 per mile for all
general aviation, and 3.3 x 10-8 per mile for general aviation
exclusive of single engine aircraft.

Table E-3 - General Aviation Hours Flown (Millions) by Aircraft Class
Year      Single     Multi-     Turbo        Turbo       Total   Modified 
          Engine     Engine     Prop         Jet                 Total 
                                                                 Without 
                                                                 Single 
                                                                 Engine 
                                                                 Aircraft 
1981      26.3       4.8        1.6          1.3         34.0    7.7 
1982      23.2       4.0        1.5          1.3         30.1    6.8 
1983      22.2       3.8        1.5          1.5         29.0    6.8 
1984      22.7       3.9        1.7          1.3         29.6    6.9 
1985      21.9       3.6        1.4          1.5         28.5    6.5 
1986      20.9       3.5        1.3          1.5         27.2    6.3 
1987      21.3       3.4        1.4          1.4         27.4    6.2 
1988      21.2       3.0        1.4          1.5         27.1    5.9

Table E-4 General Number of Aircraft Destroyed In Fight By Class
Year      Single     Multi-     Turbo        Turbo       Total   Modified 
          Engine     Engine     Prop         Jet                 Total 
                                                                 Without 
                                                                 Single 
                                                                 Engine 
                                                                 Aircraft 
1981      502        59         14           1           576     74 
1982      442        64         4            1           511     69 
1983      291        57         6            2           356     65 
1984      310        57         7            1           375     65 
1985      336        56         5            2           399     63 
1986      285        43         10           3           341     56 
1987      235        34         6            4           279     44 
1988      243        52         7            3           305     62

Table E-5 - General Aviation Aircraft Destroyed in Flight Per 100,000 Hours by Class
Year       Single     Multi-     Turbo        Turbo       Total   Modified Total 
           Engine     Engine     Prop         Jet                 Without Single 
                                                                  Engine 
                                                                  Aircraft 
1981       1.91       1.23       0.88         0.08        1.69    0.96 
1982       1.91       1.60       0.27         0.08        1.70    1.01 
1983       1.31       1.50       0.40         0.13        1.23    0.96 
1984       1.37       1.46       0.41         0.08        1.27    0.94 
1985       1.53       1.56       0.36         0.13        1.40    0.97 
1986       1.36       1.23       0.77         0.20        1.25    0.89 
1987       1.10       1.00       0.43         0.29        1.02    0.71 
1988       1.15       1.73       0.50         0.20        1.13    1.05 
NOTE: 
The values reported in Table E-5 of the Environment Assessment are obtained by 
taking the number of aircraft destroyed inflight from Table E-4 and dividing 
that by the number of hours flown taken from Table E-3.  The total reported in 
Table E-5 must be obtained by using the total number destroyed inflight from 
Table E-4 and the total number of hours from Table E-3.  The total rate of 
aircraft destroyed inflight per 100,000 hours is not the sum of the individual 
class rates, but the weighted sum (i.e., weighted by the hours flown).  
Therefore, the totals from Tables E-3 and E-4 must be used to get the totals 
reported in Table E-5.  This is also the case for the totals without single-
engine aircraft.

Table E-6 - General Aviation Aircraft Destroyed in Flight Per Million Miles
Year     Single Multi      Turbo        Turbo       Total   Modified         Accidents   Accidents 
         Engine -          Prop         Jet                 Total            per Mile    per Mile 
                Engin                                       Without          Total       Without 
                e                                           Single                       Single 
                                                            Engine                       Engine 
                                                            Aircraft                     Aircraft 
Estima   160    225        275          450                                               
ted 
Speed
1981     0.119  0.055      0.032        0.002       0.091   0.035            9.12E-08    3.52E-08 
1982     0.119  0.071      0.010        0.002       0.091   0.036            9.11E-08    3.64E-08 
1983     0.082  0.067      0.015        0.003       0.065   0.033            6.48E-08    3.35E-08 
1984     0.085  0.065      0.015        0.002       0.067   0.034            6.74E-08    3.37E-08 
1985     0.096  0.069      0.013        0.003       0.074   0.034            7.42E-08    3.37E-08 
1986     0.085  0.055      0.028        0.004       0.066   0.031            6.60E-08    3.08E-08 
1987     0.069  0.044      0.016        0.006       0.054   0.025            5.38E-08    2.47E-08 
1988     0.072  0.077      0.018        0.004       0.059   0.0365           5.97E-08    3.57E-08 
         Average                                                             7.10E-08    3.29E-08 
         e 
NOTE: 
The values reported in Table E-6 are obtained by dividing the number destroyed 
by class (Table E-4) by the product of the estimated speed (Table E-6) and 
hours flown (Table E-3). 
The total rate destroyed per million miles (Table E-6, Column 6) is not 
obtained by summing the individual rates.  The total number destroyed (Table E-
4) must be divided by the total miles flown, that is, the sum of the products 
of estimated speed and hours flown for each class. 
A similar approach is taken to generate the estimate of Modified Total without 
Single-Engine Aircraft (Table E-6, Column 7). 
The values reported in Table E-6, Columns 8 and 9, i.e., the rates per mile are 
the values in Columns 6 and 7 divided by one million.
The 1976 Sandia study assumed, based on the work of Solomon
(Reference 3), that military crash rates are approximately a factor
of five greater than that for commercial aviation.  Recently,
Sandia National Laboratories were able to access the United States
Air Force Aircraft Accident Data Base through arrangements with the
Defense Nuclear Agency.  The data base includes information by
aircraft class, hours flown, and accidents by flight regime (e.g.,
landing, cruise).  Following the approach developed for commercial
air carriers and general aviation, Sandia established the number of
aircraft destroyed as a result of in Flight accidents (Reference
9).  Using the Federal Aviation Administration flight data for the
Amarillo area, ten specific models of military aircraft flying in
the vicinity of the Pantex Plant were identified.  This was
supplemented with information based on actual aircraft observed
from the plant site, so that 13 aircraft models are considered. 
The flight information for these aircraft was converted to an accident
rate per mile by multiplying the number of hours flown by the
average cruising speed of the aircraft.  The results are summarized
in Table E-7.  An examination of a randomly selected 14 days of
1989, Federal Aviation Administration flight records for the
Amarillo area indicates that approximately 90.5 percent of the
military traffic came from high performance aircraft (e.g.,
fighters and trainers) and 9.5 percent from cargo and bomber type
aircraft.

Table E-7 - Summary of Military Aircraft Crash Rates
Aircraft     Hours     Speed      Miles        Aircraft    Crash      Number           Weighted 
Model        Flown     Miles      Flown        Destroye    Rate per   "Local"          Crash Rate 
             (millions Per        (million     d In        Billion    Flights          Pantex 
             )         Hour       s)           flight      Miles                       Plant 
C-5          1.036     400        414.40       0           0.000      7                0.000 
C-130        5.817     318        1849.81      9           4.865      14               0.224 
C-135        4.286     589        2524.45      6           2.377      4                0.031 
C-141        4.794     380        1821.72      1           0.549      2                0.004 
B-1B         0.122     500        61.00        0           0.000      1                0.000 
B-52         1.838     448        823.42       5           6.072      1                0.020 
F-111        1.274     500        637.00       11          17.268     1                0.057 
A-7          1.374     439        603.19       15          24.868     7                0.573 
A-10         2.730     277        756.21       5           6.612      1                0.022 
F-4          5.013     389        1950.06      32          16.410     9                0.486 
F-15         2.531     490        1240.19      14          11.289     17               0.631 
T-37         4.844     183        886.45       2           2.256      79               0.586 
T-38         5.600     315        1764.00      8           4.535      161              2.402 
Cargo &                           8131.80      32          3.935                       0.336 
Bomber
High                              7200.10      76          10.555                      4.700 
Performance
All                               15331.9      108         7.044                       5.035
Military 
Aircraft
Furthermore, it is noted that nearly 53 percent of the traffic
comes from T-38 aircraft and approximately 79 percent from a
combination of T-37 and T-38 aircraft.  Therefore, a weighted
military aircraft crash rate for the Amarillo area was generated by
multiplying the "raw" rate for each aircraft class by the ratio of
the number of that class to the total number of military flights
(e.g., from Table E-7, for T-38 aircraft, [161/304] . 4.535 x 10-9
= 2.402 x 10-9/mile).  These weighted rates may then be summed to
generate a new overall rate.  This "reduces" the accident rate for
high performance military aircraft operating in the Pantex Plant
area to 4.7 x 10-9 per mile and the total to 5.04 x 10-9 per mile. 
The latter value will be used in the analysis.
The accident rate for aerial application (2.945 x 10-2/100,000 km,
4.7 x 10-7/mile) was retained for this analysis.  The number of such
flights is small compared to all other traffic, therefore, changes
in the rate will not have a significant impact on the overall
estimate of the probability of impact.
Certainly, the "target area" presented by the magazines to an
impacting aircraft is much less than that presented by the
combination of all structures in Zone 4 and the production area of
Zone 12.  The affected magazine areas for Zone 4 were recomputed
(Section E.2) and the probability of impact re-estimated using the
Sandia methodology.

E.2 ESTIMATION OF AIRCRAFT CRASH PROBABILITY

In the 1976 Sandia study, the Best-Estimate Model (Reference 3) was
used to estimate the probability of aircraft crash.  The Best-
Estimate Model uses an exponential probability distribution to
estimate the postulated aircraft impact location orthonormal to the
intended flight path.  In this model, the calculated probability
includes all types of postulated impacts whether slight or severe
in consequence (i.e., a touch is a hit approach).
A set of indices are used in the model to differentiate airways,
flight categories, and flight modes.  These indices are designated
(i), (j), and (k), respectively.  Index (i) describes the air
activity and refers either to an airway or a farm plot, the latter
being used to identify the crop spraying applications.  Index (i)
can take on the following values:
   i = 1, . . ., 13    13  Low altitude airways
   i = 14, . . ., 21     8  High altitude airways
   i = 22, . . ., 26     5  Farmland plots
Index (j) divides the flight operations into categories and can
take on the following values:
   j = 1          Air Carrier
   j = 2          Military Air
   j = 3          General Aviation
   j = 4          Aerial Applications
Index (k) differentiates the mode of operations (e.g., landing,
takeoff, inflight) and can take on the following values:
   k = 1          Takeoff (within 8 km [5 miles] of airport)
   k = 2          Inflight
   k = 3          Landing (within 8 km [5 miles] of airport).
An approximation of the total probability per year (Ptot) that any
aircraft in any flight path, category, or mode of operation will
impact structures is given by:
   Ptot <= SIGMA SIGMA SIGMA Nijk * Ajk * fjk(x) * Pjk
             i     j     k
where:
   Nijk is the number of annual operations inflight path i, category
        j, and mode of flight k.
   Ajk  is the effective plant area for an aircraft of flight
        category j and mode k.
   fjk(x)   is the distribution of impacts, orthonormal to the
            intended flight path.
   Pjk  is the probability per km that an aircraft inflight category
        j and mode of flight k will crash.
Because the Pantex Plant is located more than 8 km (5 miles) from
the Amarillo Airport, the air operations of interest for this
analysis are the inflight modes (i.e., k = 2) only.  Therefore, the
index, k, may be dropped and the equation reduces to:
   Ptot <= SIGMA SIGMA Nij * Aj * fj(x) * Pj
             i     j
In this model, the probability that an impact is in a strip of
width -w which is located at a distance x and parallel to the
intended flight path can be represented by -w . f(x), where f(x) is
the impact distribution.  If there is such an impact, the fact that
the impact point lies in any perpendicular (to the flight path)
strip -L is assumed to be probabilistically independent that it
occurred in the -w  strip (see Figure E-1).  The probability of
both events occurring is the product of their probabilities, -w y
f(x) . -L y P, where P is the crash probability per kilometer. 
Thus, the distribution function f(x) is a factor by which the crash
probability per kilometer is weighted relative to the distance of
the plant area from the intended flight path.  An exponential
distribution, f(x), is symmetric and decays away from the origin.
   fj = 1/2 GAMMAj exp(-GAMMAj|x|)    -infinite <= x <= +infinite
The constants, GAMMA, reflect the impact distributions for flight
categories consistent with accident statistics.  In this analysis
the following values of GAMMAj were used.
   GAMMAj=1  =  0.99/km (1.58/miles) - Air Carrier
   GAMMAj=2  =  0.62/km (0.99/miles) - Military Air
   GAMMAj=3  =  1.24/km (1.99/miles) - General Aviation
   GAMMAj=4  =  0.62/km (0.99/miles) - Aerial Application

E.2.1 Estimation of the Impact Area

The total effective area (Aeff) required for the probability model
is the sum of the base area, a shadow area, and a skid area.  It is
postulated that if an aircraft impact occurs within this total
effective area, the structure will be hit either before ground
impact or as a result of an aircraft skid after impact.  In
estimating each area, allowance is made for aircraft dimension. 
Initially, there is no consideration of mutual shadowing or
shielding of the structures.
In this current study, the total effective area is the sum of the
true areas (the magazine base area adjusted for aircraft
dimension), the shadow areas (defined by the magazine height and
the angle of postulated impact), and the skid areas (the area
covered by a skidding aircraft after impact with the ground) posed
by all 60 magazines in Zone 4.  In this analysis, the Modified-
Richmond magazines are considered as single structures (18 total),
while the Steel Arch Construction magazines are analyzed as 9
groups of 3 (27 total) and as 3 groups of 5 (15 total).  To
estimate the overall probability of aircraft impact into any
magazine in Zone 4, the probability of striking an individual
magazine or group of magazines is summed appropriately over the
individual magazines or groups analyzed, i.e., 18 Modified-Richmond
magazines, 9 groups of 3 Steel Arch Construction magazines, and 3
groups of 5 Steel Arch Construction magazines.
The true area (At) is the base area of the building adjusted for
aircraft dimension and is defined as:
   AT  =  a(b+2d)
where a is the magazine length, b is the magazine width, and d is
1/2 the aircraft wingspan.  In the 1976 Sandia study, the "typical"
wingspans used for the various classes of aircraft were:  42.6
meters for air carriers, 12.0 meters for general aviation and
aerial application, and 12.2 meters for military aircraft.  Thus,
if even the tip of a wing struck the structure, it was included as
a hit.  In this analysis, the wingspans were modified to include
essentially only the inboard one-third of the span.  This was based
primarily on two considerations:  (1) the magazines are very
compact structures, well shielded with earth; therefore, it will
require more than a grazing hit by a wing tip to cause damage, and
(2) the arrangement of the magazines in Zone 4 West (see Figure
E-2) is such that if just the tip of a large wing were to impact
one magazine, major portions of the aircraft could be impacting
another.  Therefore, in this analysis the wingspans used are:  14.2
meters for air carriers, 4 meters for general aviation and aerial
applications, and 61 meters for military aviation.
The shadow area, Ash, is determined by the structure height, Z, and
the angle, -, of the postulated aircraft impact (see Figure E-3)
and is defined as:
   Ash  =  Z(2d + D)/tanTHEATA    D  =  (a2 + b2)0.5
where a is the magazine length, b is the magazine width, Z is the
magazine height, d is 1/2 the aircraft wingspan, and THEATA is the angle
the aircraft path makes with the horizon at impact.  In this
analysis, the impact angle is assumed to be 15 degrees, consistent
with the recommendations of Solomon (Reference 3).  This is a
conservative approach; however, the 1976 Sandia study parameter
sensitivity investigation indicated that the results are relatively
insensitive to impact angle.
There is a possibility that an aircraft could impact the ground at
some distance from a magazine and still strike the structure as a
result of skidding into it.  The skid area is defined as:
   Askid  =  (2d + D)Xm
where d and D are as defined above and Xm is the skid length.  The
1976 Sandia study used the skid distances recommended by Solomon
(Reference 3), that is, Xm for air carriers of 500 meters, for
military aircraft 1000 meters, and for general aviation and aerial
application 100 meters.  However, over the past several years there
has been considerable discussion as to the "correct" value to use
in estimating aircraft skid distances.  The values used in the
Sandia study represent a conservative position.  In his report
(Reference 3), Solomon states:
   "If an aircraft were postulated to impact the land immediately
   in front of a structure, it is conceivable that the aircraft
   might skid into that structure.  Depending upon aircraft
   weight, size and its horizontal component of velocity, the
   aircraft can skid up to approximately 1 mile (for a high
   velocity military aircraft on a very smooth terrain). 
   [Emphasis added]  For a high velocity military aircraft, the
   skid length is typically 0.6 miles.  For a United States Air
   Carrier, the typical skid length may be 0.3 miles and for a
   United States General Aviation, the skid length is typically
   0.06 miles.
   Insight into the phenomenon of skidding may be gained by
   considering the motion of an aircraft on the ground as the
   linear motion of a body with an initial horizontal velocity
   Vo(mph) and a uniform deceleration equal to a multiple K of
   gravity.  The simplest model leads to a skid distance of:
      Xm  =  (6.3 x 10E-6)(VE2o/K) miles
   The value of K is directly proportional to the amount of
   friction between the skidding aircraft and the terrain. 
   Typical values of K may be estimated to vary between 2.5 and
   5.
Thus, the values used earlier are apparently based upon the
"typical values" information provided by Solomon.  However, it must
be noted that these maximum distances represent skids on smooth
surfaces, probably airfields.  It is also worth noting that using
the simple model cited, the initial impact velocity would have to
be approximately 500 mph (730 fps) in order for the predicted skid
distance to be 1000 meters (3280 ft).  This is a factor of two to
three above typical landing speeds, thus it is difficult to imagine
aircraft striking the ground with horizontal velocities this high. 
If an aircraft is falling out of control from high altitudes, its
forward velocity may be 300 to 500 mph (440 to 733 fps), but the
angle of impact will be high and, therefore, the horizontal
component of velocity significantly lower.
Although the terrain surrounding the Pantex Plant is relatively
level, it would be difficult to describe it as "smooth" in the
sense that airfields and runways are smooth.  Therefore, it is
concluded that using the information from the Solomon report is, in
fact, conservative.  The simple model predicts skid distances on
the order of 50 to 365 meters (164 to 1200 ft) for impact
velocities between 150 and 300 mph (220 and 440 f/s).  Based upon
discussions with a number of experienced aviators, these seem to be
much more realistic values.
A 1983 Sandia report (Reference 10) provided an indication of
aircraft skid distance for several aircraft classes that is linear
in nature.  For an impact velocity of 220 mph (323 f/s), it was
estimated that military (high performance aircraft) skid
approximately 675 meters (2210 ft) and air carrier approximately
480 meters (1575 ft).  A subsequent Sandia analysis (Reference 11)
of a sliding body acted upon by friction (Coulomb friction assumed,
i.e., sliding on dry surface) yielded the following relationships:
   x (ft)    = Vot -(ug/2)t2
   dx/dt(f/s)  = Vo - ugt
where:
   x     =  skid distance
   dx/dt    = remaining velocity
   Vo       = impact velocity
   u     =  coefficient of sliding friction
   t     =  time after impact
It should be noted that the analysis yields a relationship that is
independent of aircraft weight and only a function of the impact
velocity and the coefficient of friction.  A set of estimates using
this relationship are shown on Figure E-4.  A sliding coefficient
of friction of 1.0 was assumed along with four impact velocities: 
400, 220, 170, and 68 mph (or 587, 323, 250, and 100 f/s,
respectively).  (The individual curves end at the point where
velocity (dx/dt) is zero.)  It may be noted that at initial impact
velocities of 170 to 220 mph (250 to 323 f/s), skid distances on
the order of 300 to 500 meters (980 to 1640 ft) are predicted. 
These are less than those of the 1983 Sandia report, but within a
factor of 1 to 1.5 of those values.  This model predicts a skid
distance of approximately 1600 meters (5250 ft), given an initial
impact velocity of 400 mph (587 f/s).  It should be noted that the
value used above for the coefficient of sliding friction, - = 1.0,
is greater than that for smooth materials (metals) sliding over one
another (typically on the order of 0.2 to 0.6), but not
significantly so (Reference 12).
Another source (Reference 13) quotes a value of 0.67 for "rough
steel" sliding over sand, but again this is a smooth metal in
contact with a well defined material.  In an impact of an aircraft,
even at low angles of incidence, the terrain surrounding Zone 4 is
not a smooth surface.  Although it is "level" in a very macroscopic
sense, it is not smooth in the sense of a well-maintained airfield. 
In this regard, it also should be noted that if K = 1.0, the
correlation quoted by Solomon yields the same result as the Coulomb
analysis when C = 1.0.  Thus, the correlation assumes that the
coefficient of friction for sliding aircraft is significantly
higher than that for smooth materials in contact with each other.
Based upon these considerations, the skid distances for the
aircraft impact in this analysis were set at 300 meters (984 ft)
for air carriers, 600 meters (1970 ft) for military aircraft (also
based, in part, on the fact that the smaller high performance
military aircraft dominate the military traffic in the Pantex Plant
area), and 50 meters (164 ft) for general aviation.  In addition to
these general arguments for reducing the skid distances for this
analysis, it must be noted that the geometry of Zone 4 (see Figure
E-2) affects the areas exposed to potential aircraft impacts. 
Aircraft approaching from either the north or south have a very
small "view" angle for the majority of the magazines, so the
problem may be treated essentially as one in which aircraft
approach either from the east or west.  Any such aircraft does not
"see" all the magazines with equal likelihood.  An aircraft that
impacts the ground prior to reaching a line of magazines, (i.e., it
is now in a skid mode) can impact one line of magazines, but is
essentially precluded from reaching the second.  Therefore, the
effective areas for one line of magazines (and the five isolated
Modified-Richmond magazines) are estimated using the revised skid
distances described above.  However, the skid distances for
magazines in the second line are reduced to no more than the
distance between the two rows of magazines (125 m).  These
calculations are illustrated below.

E.2.2 Example Area Calculation Steel Arch Construction Magazine Group of Three

The following section illustrates the calculation of the individual
areas and the effective area for the Steel Arch Construction
Magazine group of three.  In this calculation, the magazines are
assumed to be in a position (e.g., east row on Figure E-2) that
allows the longest skid distance prior to impact with a magazine.
   True Area (At):    At = a(b + 2d)
   Air Carrier      13 . (24 + [2 * 7.1])     = 4.97E-04 km2
   Military Aviation  13 . (24 + [2 * 2.03])    = 3.65E-04 km2
   General Aviation   13 . (24 + [2 * 2.00])    = 3.64E-04 km2
   Aerial Application 13 . (24 + [2 * 2.00])    = 3.64E-04 km2
   Shadow Area (Ash): Ash = Z(2d + D)/tanFI
   D = (242 + 132)0.5 = 27.3m, Z = 5.3m, - = 15o
   tan(-) = 0.26795, Z/tan(-) = 19.78m
   Air Carrier      19.78 . ([2 * 7.1] + 27.3)      = 8.21E-04 km2
   Military Aviation  19.78 . ([2 * 2.03] + 27.3)     = 6.21E-04 km2
   General Aviation   19.78 . ([2 * 2.0] + 27.3)     = 6.19E-04 km2
   Aerial Application 19.78 . ([2 * 2.0] + 27.3)     = 6.19E-04 km2
   Skid Area (Askid):  Askid = (2d + D)Xm
   Air Carrier      ([2 . 7.1] + 27.3) * 300     = 1.24E-02 km2
   Military Aviation  ([2 . 2.03] + 27.3) * 600     = 1.88E-02 km2
   General Aviation   ([2 . 2.0] + 27.3) * 50     = 1.56E- 03 km2
   Aerial Application ([2 . 2.0] + 27.3) * 50     = 1.56E- 03 km2
Therefore, the Steel Arch Construction Magazine (group of three)
Effective Areas (Aeff) with the longer skid distances are:
   Air Carrier      (4.97E-04) + (8.21E-04) + (1.24E-02) = 1.37E-02 km2
   Military Aviation   (3.65E-04) + (6.21E-04) + (1.88E-02) = 1.98E-02 km2
   General Aviation   (3.64E-04) + (6.19E-04) + (1.57E-03) = 2.54E-03 km2
   Aerial Application (3.64E-04) + (6.19E-04) + (1.57E-03) = 2.54E-03 km2
Similar calculations were performed for the Steel Arch Construction
Magazine group of five and the Modified-Richmond magazines in the
same row and for those Modified-Richmond magazines on the west side
of Zone 4 that are not effectively shielded by the east row.  The
calculations were repeated for the Steel Arch Construction Magazine
group of three and the Modified-Richmond magazines in the west row,
but in this latter instance, the skid distances for air carrier and
military air were reduced to 125 meters, the inter-row distance. 
The computed effective area for each of the magazine types and skid
distance combinations is summarized in Table E-8.

Table E-8 - Summary of Effective Areas for Zone 4
                        Steel Arch                     Steel Arch     Modified Richmond 
                        Construction                   Construction 
                        3                              5 
         Effective Areas (km2) - 300/600 Meter Skid Distances 
Air Carrier             1.37E-02                       1.87E-02       1.03E-02 
Military Aviation       1.98E-02                       2.92E-02       1.33E-02 
General Aviation        2.55E-03                       3.79E-03       1.63E-03 
Aerial Application      2.55E-03                       3.79E-03       1.62E-03 
Effective Areas (km2) - 125 Meter Skid Distance 
Air Carrier             6.50E-03                       8.85E-03       4.77E-03 
Military Aviation       4.91E-03                       7.25E-03       3.22E-03 
General Aviation        2.55E-03                       3.79E-03       1.63E-03 
Aerial Application      2.55E-03                       3.79E-03       1.62E-03 
Total Effective Areas (km2) - Zone 4 
Air Carrier                                            2.81E-01        
Military Aviation                                      3.45E-01        
General Aviation                                       6.35E-02        
Aerial Application                                     6.35E-02 
A total effective area for the Zone 4 magazines was then computed
by combining the effective areas in the following manner.  The
effective area for magazines in the east row is the sum of the
effective areas for three of the Steel Arch Construction group of
three magazines, three of the Steel Arch Construction group of five
magazines, and six Modified-Richmond magazines.  All of these
effective areas were computed using the larger skid distances for
air carriers and military air (e.g., 300 and 600 meters,
respectively).  The effective area for magazines in the west row is
the sum of the effective areas for six of the Steel Arch
Construction group of three magazines and seven of the Modified-
Richmond magazines.  All of these effective areas were computed
using the 125 meter inter-row separation as the skid distance for
air carriers and military air.  The total effective area for Zone 4
is the sum of the effective areas for the east and west row plus
the effective areas of the five Modified-Richmond magazines on the
western side of Zone 4.  These areas are also summarized on Table
E-8.

Table E-9 - Yearly Operations
                          Traffic Volume                                               
               Distance                                                                
Flight Path    (km)                                                                   Total 
                          Air Carrier      Military            General     Aerial      
V81S           9.7        5900             1400                9000        0          16300 
V81E           9.7        0                0                   2700        0          2700 
V114S          9.7        500              500                 4500        0          5500 
V114           9.7        0                300                 2400        0          2700 
V140           4.0        900              2000                8100        0          11000 
V140N          0.8        300              0                   900         0          1200 
V12-230        2.4        0                0                   4200        0          4200 
V304-12N       6.4        0                1100                0           0          1100 
V81NW          9.7        0                0                   300         0          300 
V81W           9.7        100              600                 5100        0          5800 
V12N           9.7        0                300                 6600        0          6900 
V12W           9.7        700              300                 10500       0          11500 
V280SW         9.7        0                0                   900         0          900 
J-26-NE        2.4        3200             1200                4800        0          9200 
J-6-14-78      4.0        2600             2800                3300        0          8700 
J-58W          9.7        2500             1300                3000        0          6800 
J-17S          9.7        300              2000                1200        0          3500 
J-26SW         9.7        400              2500                900         0          3800 
J-6-78         9.7        3200             3200                7800        0          14200 
J-58SE         8.0        5800             2100                6600        0          14500 
J-17NW         9.7        3200             2700                4800        0          10700 
Farm Plot #1   2.1        0                0                   0           2          2 
Farm Plot #2   0.8        0                0                   0           10         10 
Farm Plot #3   0.3        0                0                   0           3          3 
Farm Plot #4   6.4        0                0                   0           10         10 
Farm Plot #5   8.8        0                0                   0           4          4 
                          29600            24300               87600       29         141529

E.2.3 Estimation of Aircraft Crash Probability

An estimate of an aircraft crash into any of the Zone 4 magazines
was generated using the probability equation defined in Section
E.2.1, the effective areas calculated in Section E.2.2, flight
information data extracted from the 1976 Sandia report (see
Table E-9), and the aircraft crash rates developed in Section E-1. 
Pertinent information is summarized in Table E-10.
The estimates of the aircraft crash probabilities by aircraft class
are summarized in Table E-11.
The analysis indicates that the likelihood of any class of aircraft
impacting into any of the 60 Zone 4 Material Access Area magazines
(regardless of the magnitude of that impact) is
approximately 1.9 x 10-6 per year.  The overall estimated
probability of impact is greater than 1 x 10-6 per year.  However,
it must be observed that this estimate is dominated by the results
for general aviation in that approximately 82 percent of the total
probability comes from that source. This arises from the fact that
general aviation clearly dominates the air traffic in the Amarillo
area.  From Table E-9 it may be noted that 62 percent of the total
traffic count is general aviation.  Given this situation, and the
fact that these single-engine aircraft are light-weight and fly at
low speeds compared to the air carriers and military aircraft, the
vulnerability of the magazines in Zone 4 to impacts from general
aviation aircraft was examined.

Table E-10 - Aircraft Operational Data
                     Air Carrier   Military         General             Aerial 
                                   Aviation         Aviation            Application 
Operations/Yr        29,800        24,300           87,600              29 
1/2 Wingspan* (m)    7.1           2.03             2                   2 
Skid Length (m)      125 or 300    125 or 600       50                  50 
Impact Angle -       15            15               15                  15 
(deg)
(- /km)              0.99          0.62             1.24                0.62 
In flight Crash      6.39 x 10E-10  5.04 x 10E-9      7.10 x 10E-8         2.95 x 10E-7 
Rate (#/mi)
In flight Crash      3.97 x 10E-10  3.13 x 10E-9      4.41 x 10E-8         1.83 x 10E-7 
Rate (#/km)
Effective Areas      2.81 x 10E-1   3.45 x 10E-1      6.35 x 10E-2         6.35 x 10E-2 
(km2)
* In this instance, 1/2 wingspan is 1/6 of the wingspan reported in the 1976 
  Sandia report. 
 See Section E.2.1 for a discussion of this change.

Table E-11 - Annual Probabilities of Aircraft Crashes
Aircraft Class          Crash 
                        Probability/Year 
Air Carrier             2.78 x 10E-8 
Military Aviation       2.50 x 10E-7 
General Aviation        1.52 x 10E-6 
Aerial                  5.42 x 10E-8 
Application
Total                   1.86 x 10E-6

E.2.4 Vulnerability of Zone 4 Magazines to Impact by General Aviation

Analyses by Jacobs Engineering (see Appendix C) indicate that light
aircraft (i.e., single-engine aircraft) moving at typical speeds
will not penetrate or collapse a Zone 4 magazine structure.  These
light aircraft were modeled as a 3,500-pound aircraft moving at 80
mph.  This weight is representative of single-engine aircraft
(e.g., Cessna 172/182, Piper 28, Beech 33/35) in the 2,500 to
5,000-pound range.  The speed is nominally 30 percent above stall
speed.  The results suggest that it is reasonable to exclude
single-engine aircraft from further consideration in the accident

Table E-12 - Yearly Operations (77 Percent General Aviation Below
18,000 Ft Deleted)
                         Traffic Volume                                                 
               Distance                                                                 
Flight Path    (km)                                                                    Total 
                         Air Carrier      Military            General       Aerial      
V81S           9.7       5900             1400                2070          0          9370 
V81E           9.7       0                0                   621           0          621 
V114S          9.7       500              500                 1035          0          2035 
V114           9.7       0                300                 552           0          852 
V140           4.0       900              2000                1863          0          4763 
V140N          0.8       300              0                   207           0          507 
V12-230        2.4       0                0                   966           0          966 
V304-12N       6.4       0                1100                0             0          1100 
V81NW          9.7       0                0                   69            0          69 
V81W           9.7       100              600                 1173          0          1873 
V12N           9.7       0                300                 1518          0          1818 
V12W           9.7       700              300                 2415          0          3415 
V280SW         9.7       0                0                   207           0          207 
J-26-NE        2.4       3200             1200                4800          0          9200 
J-6-14-78      4.0       2600             2800                3300          0          8700 
J-58W          9.7       2500             1300                3000          0          6800 
J-17S          9.7       300              2000                1200          0          3500 
J-26SW         9.7       400              2500                900           0          3800 
J-6-78         9.7       3200             3200                7800          0          14200 
J-58SE         8.0       5800             2100                6600          0          14500 
J-17NW         9.7       3200             2700                4800          0          10700 
Farm Plot #1   2.1       0                0                   0             2          2 
Farm Plot #2   0.8       0                0                   0             10         10 
Farm Plot #3   0.3       0                0                   0             3          3 
Farm Plot #4   6.4       0                0                   0             10         10 
Farm Plot #5   8.8       0                0                   0             4          4 
                         29600            24300               45096         29         99025
 analysis and to focus attention on those aircraft that have some
potential for penetration or destructive impact.  A limited set of
sensitivity calculations indicates that a 5,000-pound aircraft
impacting at a speed below 80 mph will not collapse or penetrate a
magazine, nor will a 3,500-pound aircraft impacting at a speed
below 105 mph.  However, a simple reduction in the accident rate
per mile, as presented in Table E-10, is insufficient.  These
single-engine aircraft must also be excluded from the flight
activity data base.  The difficulty lies in estimating the number
of aircraft that fall into this category.  Using the data in
Table E-3, and postulating that the average individual flight time
is essentially the same for all categories of general aviation
(discussions with a number of general aviation pilots leads to the
conclusion that this is a reasonable assumption), it can be shown
that the single-engine aircraft represent approximately 77 percent
of the general aviation activity.  However, the vast majority of
the single-engine aircraft will operate at flight levels below
18,000 ft; therefore only those airways (Victor Airways) below
18,000 ft are affected.  Therefore, the first approach taken was to
reduce the number of general aviation aircraft below 18,000 ft by
77 percent (see Table E-12).  When the probability calculation was
redone with the change, the overall estimate of the probability of
aircraft crash dropped below 1 x 10-6 per year.  The results by
aircraft class are shown in Table E-13.

Table E-13 - Annual Probabilities of Aircraft Crashes Capable of
Producing Significant Consequences
Aircraft Class             Crash 
                           Probability/Year 
Air Carrier                2.78 x 10E-8 
Military Aviation          2.50 x 10E-7 
General Aviation           3.31 x 10E-7 
Aerial Application         5.42 x 10E-8 
Total                      6.63 x 10E-7
Using similar rationale, it also may be argued that the number of
aircraft in the lower flight levels should be reduced even more
than 77 percent, because although the single-engine aircraft
represent 77 percent of all flights, they will represent a
significantly higher fraction of those in the lower flight levels. 
Unfortunately, there is insufficient information in the available
data base to make this additional correction with certainty. 
Nevertheless, the above approach is considered conservative, and on
the basis of this analysis, an aircraft crash into a Zone 4
magazine sufficient to cause damage and potential release of
radioactive material is considered incredible and no consequence
estimates are presented.

E.3 REFERENCES

   DOE/AL Order 5481.1B, "Safety Analysis and Review System," United
   States Department of Energy, Albuquerque Operations Office,
   January 27, 1988.
   An Assessment of the Probability of Aircraft Impact with Pantex
   Structures, SAND76-0120, Sandia National Laboratories, June 1976.
   Estimate of the Probability that an Aircraft will Impact the
   PVNGS, Solomon, K.A., NUS-1416, Revision 1, Arizona Nuclear Power
   Project, July 25, 1975.
   Private Communication [telephone conversation] with Ross Schulke,
   Federal Aviation Administration Amarillo Operations, October 24,
   1990.
   Federal Aviation Administration Traffic Activity, Fiscal Year
   1987, United States Department of Transportation.
   Federal Aviation Administration Statistical Handbook of Aviation,
   Calendar Year 1989, United States Department of Transportation.
   Y.T. Lin and J.L. Tenney, "National Transportation Safety Board
   Aircraft Accident Data Base," Sandia National Laboratories Memo,
   July 2, 1992.
   Y.T. Lin, "United States General Aviation Aircraft Accidents,"
   Sandia National Laboratories Memo, August 13, 1992.
   Y.T. Lin, "Military Aircraft Crash Rate," Sandia National
   Laboratories Memo, August 25, 1992.
   A Methodology for Calculation of the Probability of Crash of an
   Aircraft into Structures in Weapon Storage Areas, SAND82-2409,
   Sandia National Laboratories, February 1983.
   P.P. Stirbis, "Skid Distance-Velocity Profile for Aircraft
   Crash," Sandia National Laboratories Memo, May 18, 1992.
   R.E. Bolz and G.L. Tuve, Ed., CRC Handbook of Tables for Applied
   Engineering Science, 2nd Edition, CRC Press, Inc., Boca Raton,
   Florida, 1973.
   J.G. Potyondy, "Skin Factor Between Various Soils and
   Construction Materials," Geotechnique, Volume 2, No. 4,
   December 1961.
Figure (Page E-18 Figure E.1 - Relationship of Flight Path and Impact Areas)
Figure E.1 - Relationship of Flight Path and Impact Areas
Figure (Page E-19 Figure E.2 - Zone 4 Layout)
Figure E.2 - Zone 4 Layout
Figure (Page E-20 Figure E.3 - Illustration of True Area and Shadow Area for Structure)
Figure E.3 - Illustration of True Area and Shadow Area for Structure
Figure (Page E-21 Figure E.4 -Skid Distance as Function of Time After Impact)
Figure E.4 -Skid Distance as Function of Time After Impact

APPENDIX F
WORKER RADIATION EXPOSURE

Additional worker radiation exposure has been identified as the
only impact from routine operations associated with increased
interim storage of pits in Zone 4.  To address this concern,
bounding worker exposure doses have been calculated for these
activities.  Information provided in this appendix has been
coordinated with the Safety Analysis Report for Zone 4 magazines as
well as the Radiation Safety Department and the Operations Manager
of Zone 4.

F.1 DESCRIPTION OF OPERATIONS

F.1.1 Inventory

Inventory is a safeguards and security requirement for Zone 4 pit
interim storage activities.  Inventory includes verification of
contents using bar codes and readers.  Inventory for the vertical
single-layer configuration would be performed manually by workers
entering the magazines and reading the assigned code for each pit
container.  Inventory for the horizontal palletized stacking
configuration would be performed with the use of a forklift
equipped with a bar code reader.  Proposed inventory frequencies
for interim storage activities will include each magazine every
18 months.  The time required to perform inventories is estimated
as follows:
      .     Modified-Richmond magazines (vertical single-layer
            configuration):  Two workers will be involved with
            inventories.  For this interim storage configuration, 70
            minutes is estimated for each side of the magazine for
            conducting each inventory.
      .     Steel Arch Construction magazines (vertical single-layer
            configuration):  Two workers will be involved with
            inventories.  For this interim storage configuration, 140
            minutes is estimated per Steel Arch Construction magazine
            for conducting each inventory.
      .     Modified-Richmond magazines (horizontal palletized
            stacking configuration):  Two workers will be involved
            with inventories.  For this interim storage
            configuration, 45 minutes is estimated for each side of
            the magazine for conducting each inventory.
      .     Steel Arch Construction magazines (horizontal palletized
            stacking configuration):  Two workers will be involved
            with inventories.  For this interim storage
            configuration, 90 minutes is estimated per Steel Arch
            Construction magazine for conducting each inventory.
Estimates are based on current inventory operations and knowledge
of what is proposed for future activities for each interim storage
configuration.  In all cases, estimates are considered conservative
in comparison to current inventory time requirements.

F.1.2 Pit Evaluation

Random pit evaluations are required to meet weapons component
reliability requirements.  Approximately 10 to 20 pits will be
randomly selected each year for these evaluation activities.  In
order to minimize impacts to Zone 4 operations, random sampling for
evaluations will be performed coincidental with magazine
inventories.  Additional Zone 4 worker exposure time associated
with these evaluations is considered negligible and is subsumed in
the exposure time estimated for inventory operations.

F.1.3 Corrosion Inspection

Under normal circumstances, water would not be expected to come in
contact with pit containers.  In the absence of water, there is no
mechanism to cause corrosion and possible failure of pit
containers.  Since the vertical single-layer configuration requires
containers to be placed directly on the floor, it is possible for
water to come in contact with pit containers in the event it
accidentally enters a magazine.  This is not considered likely for
the horizontal palletized stacking configuration, because all
containers will be placed on pallets holding them several inches
above the floor.
A 100 percent container inspection for corrosion is included in the
analysis for the vertical single-layer configuration in each Steel
Arch Construction and Modified-Richmond magazine.  Inspection
frequencies are estimated to be 18 months for each magazine.  Two
workers will remove each container from magazines and visually
examine the exterior for corrosion.  It is anticipated to take one
minute per container for these inspections (includes removal,
inspection and returning containers to the magazines).

F.1.4 Miscellaneous Operations

Miscellaneous operations include loading and unloading of
magazines.  These operations are performed using forklifts and hand
carts.  Estimates for these activities include 2 workers for one
Steel Arch Construction and one Modified-Richmond magazine, 2 hours
each workday.

F.2 MAGAZINE CAPACITIES

Proposed storage configurations for Steel Arch Construction and
Modified-Richmond magazines include a vertical single-layer
configuration on the floor, a horizontal palletized stacking
configuration and a combination of the two.  Maximum magazine
capacities are as follows:
Magazine Type   Vertical Single-    Horizontal 
                Layer               Palletized 
                Configuration       Stacking 
                                    Configuration 
Modified-       378 pits/magazine   440 pits/magazine 
Richmond
Steel Arch      406 pits/magazine   392 pits/magazine
Construction
For the vertical single-layer configuration, operational
limitations prevent utilizing the physical capacities shown
above.  Operational limits are 384 pits/magazine for Steel Arch
Constructions and 336 pits/magazine for Modified-Richmonds.  A
conservative capacity of 384 was used in this analysis for
simplification and because 70 percent of the magazines available
for interim storage activities are Steel Arch Construction
magazines.

F.3 RADIATION EXPOSURE

The radiation types of concern for interim storage of pits are
gamma, x-ray and neutron.  These radiation types are sufficiently
penetrating to pass through pit containers and deliver a whole body
dose to workers present in the magazines.  Information provided in
this section was taken from the Safety Analysis Report for Zone 4
Magazines.

F.3.1 Modeling

The Safety Analysis Report for Zone 4 Magazines presented a
conservative model for the magazine interim storage configurations
(Reference 1).  The models were incorporated into the General Monte
Carlo Code for Neutron and Photon Transport (MCNP4) (References 2
and 3).  The conservative generic facility models were constructed
with the following features:
      Vertical Single-Layer Configuration:
      .     The magazines were modeled with half the nominal floor
            area, and floor, roof and walls on three sides
            constructed of 12-inch thick concrete equivalent.
      .     No center divider wall was considered, but a "reflection"
            plane was included in MCNP4 to include the effect of the
            other half of Modified-Richmond magazines.
      .     A single layer of upright AL-R8 containers 29 deep by 9
            across was included.  The actual container radius was
            reduced by approximately 7 percent to allow a square
            pitch to model hexagonal close-pack arrangements.  The
            522 containers in this model are greater than the maximum
            capacity of 378 containers for Modified-Richmond
            magazines and 406 containers for Steel Arch Construction
            magazines, as well as the operational limit of 384
            containers used in the cumulative worker exposure
            analysis.
      .     Two dosimetry volumes were selected.  One volume was a
            slab 6 inches thick on top of the container array.  The
            second dosimetry volume was an aisle created adjacent to
            the reflecting plane that is one container wide and
            extends the length of the magazine.  The second dosimetry
            volume resulted in a higher dose rate and was included in
            the cumulative worker dose calculations.
      Horizontal Palletized Stacking Configuration:
      .     A building was modeled with half of the nominal floor
            area, and floor, roof and walls on three sides
            constructed of 12-inch thick concrete equivalent.
      .     A center divider void was modeled (as opposed to the
            concrete dividing wall in Modified-Richmond magazines)
            and used as a "reflection" plane in MCNP4 to include the
            effect of the other half of the structure.
      .     Two rows of "palletized" AL-R8 containers in groups of 4
            containers per pallet, stacked 3 pallets (6 containers)
            vertically and 11 pallets (22 containers) horizontally in
            each half of the building were included in the model. 
            This configuration has 528 containers compared to the
            maximum capacity of 440 containers for Modified-Richmond
            magazines or the maximum capacity of 392 containers for
            Steel Arch Construction magazines.
      .     An aisle 70 inches wide was used between the two rows of
            containers.  The aisle between the stacks of palletized
            containers was used as the volume for dosimetry purposes.
      .     The roof was modeled at 13 feet, 4 inches to accommodate
            pallet heights.

F.3.2 Results of MCNP4 Calculations

For the vertical single-layer configuration, the radiation dose
rate calculations resulted in:
      (expected dose rate in an aisle one container wide extending
      the depth of the magazine)
      Neutron Dose Rate              35 mrem/hr
      Photon Dose Rate              487 mrem/hr
      TOTAL                   522 mrem/hr
Dose rates for the vertical single-layer configuration should be
considered very conservative, because all pits were modeled as
having a generic high mass, 532 pits were included in the model, no
gaps were modeled for the close pack hexagonal pattern other than
the aisle, and all plutonium was considered aged to more than 45
years.  525 mrem/hr is used in the worker exposure analysis.
For the horizontal palletized stacking configuration, the radiation
dose rate calculations resulted in:
      Neutron Dose Rate              37 mrem/hr
      Photon Dose Rate              211 mrem/hr
      TOTAL                   248 mrem/hr
Dose rates for the horizontal palletized stacking configuration
should also be considered very conservative, because all pits were
modeled as having a generic high mass, 528 pits were included in
the model, and all plutonium was considered aged to more than 45
years.  250 mrem/hr is used in the worker exposure analysis.

F.3.3 Other Radiation Dose Rates

All activities associated with the Zone 4 interim storage of pits
will not occur in magazines filled to capacity (e.g., loading,
unloading and corrosion inspection).  Health physicists of the
Pantex Radiation Safety Department have performed surveys to
measure actual dose rates for typical worker exposure from
miscellaneous activities (averaged 30 mrem/hr) as well as dose
rates at 30 centimeters from pit containers (60 mrem/hr).  For
corrosion inspection activities, closer handling of pit containers
warrants the use of 60 mrem/hr, and miscellaneous loading and
unloading activities would be more typical of the 30 mrem/hr dose
rate.  These dose rates were used in calculating the bounding
worker doses.

F.4 CALCULATIONS

This section provides the calculations performed to arrive at
bounding cumulative worker doses for the Proposed Action (vertical
single-layer, and horizontal palletized stacking configurations in
both Modified-Richmond and Steel Arch Construction magazines), and
the No-Action Alternative (vertical single-layer configuration in
Modified-Richmond magazines).

F.4.1 Proposed Action Calculations

The Proposed Action addresses both the vertical single-layer
configuration and the horizontal palletized stacking configuration
for 18 Modified-Richmond and 42 Steel Arch Construction magazines.
ASSUMPTIONS:
Inventory           2 people, 70 minutes for each side of a 
Process:            Modified-Richmond magazine.  Also assumes 140 
(Vertical Single-   minutes per Steel Arch Construction magazine.  
Layer               Inventory of each magazine once every 18 
Configuration)      months (40 magazines/yr). 
Inventory           2 people, 45 minutes for each side of a 
Process:            Modified-Richmond magazine, and 1 person, 90 
(Horizontal         minutes for each Steel Arch Construction 
Palletized          magazine.  Inventory of each magazine once 
Stacking            every 18 months (40 magazines/yr). 
Configuration)
Corrosion           100 percent container corrosion inspection for 
Inspections:        each magazine every 18 months (vertical 
                    single-layer configuration only).  Assume 1 
                    minute per container for surveillance 
                    operations, 2 workers (100 percent 
                    inspection). 
Miscellaneous       One Steel Arch Construction magazine and one 
Operations:         Modified-Richmond magazine opened every 
                    workday for 2 hours with 2 workers. 
Magazine            For the vertical single-layer configuration 
Capacities:         384 containers is the operational maximum for 
                    Steel Arch Construction magazines and is used 
                    for both magazine types in the calculations.  
                    For horizontal palletized stacking 
                    configuration, the maximum capacity is 440 
                    containers in Modified-Richmond and 392 
                    containers for Steel Arch Construction 
                    magazines. 
Radiation Dose      525 mrem/hr for the vertical single-layer 
Rates:              configuration inventory process.  250 mrem/hr 
                    for the horizontal palletized stacking 
                    configuration inventory process.  60 mrem/hr 
                    for corrosion inspection activities.  30 
                    mrem/hr for miscellaneous operations.
PROPOSED ACTION-18 MODIFIED-RICHMOND AND 42 STEEL ARCH CONSTRUCTION
MAGAZINES (vertical single-layer configuration)
Inventory Operations:
      2 persons x 140 min/magazine x 40 magazines/yr = 11,200 min/yr
      11,200 min/yr x (525 mrem/hr)/60 min/hr = 98,000 person-
      mrem/yr = 98 person-rem/yr
Corrosion Inspections:
      2 persons x 384 min/magazine x 40 magazines/yr = 30,720 min/yr
      60 mrem/hr x (30,720 min/yr)/60 min/hr = 30,720 person-mrem/yr
      = 30.7 person-rem/yr
Miscellaneous Operations:
      2 persons x 2 magazines/day x 2 hrs/day x 260 workdays/yr =
2,080 hr/yr
      2,080 hrs/yr x 30 mrem/hr = 62,400 person-mrem/yr = 62.4
person-rem/yr
Totals for the Vertical Single-Layer Configuration:
Operation                               Cumulative Personnel Exposure 
                                         (person-rem/year) 
Inventory                               98.0 
Corrosion Inspection                    30.7 
Miscellaneous                           62.4 
TOTAL                                   191.1
Conservatism in Calculations:
      .     525 mrem/hr dose rate based on most conservative analysis
            from Safety Analysis Report
      .     No credit was taken for personnel shielding (lead aprons)
      .     Assumes worker exposure over the duration of activities
      .     Assumes 384 pits for Steel Arch Construction and
            Modified-Richmond magazines
      .     100 percent corrosion inspection will probably be no more
            than 20 percent
      .     Duration for miscellaneous operations may be reduced with
            plans for the future (approximately 1/2 hr/day is
            anticipated)
PROPOSED ACTION - 18 MODIFIED-RICHMOND AND 42 STEEL ARCH
CONSTRUCTION MAGAZINES (horizontal palletized stacking
configuration)
Inventory Operations:
      2 persons x 90 min/magazine x 40 magazines/yr = 7,200 min/yr
      7,200 min/yr x (250 mrem/hr)/60 min/hr = 30,000 person-mrem/yr
      = 30.0 person-rem/yr
Corrosion Inspections:
      Not applicable for the horizontal palletized stacking
configuration.
Miscellaneous Operations:
      2 persons x 2 magazines/day x 2 hrs/day x 260 workdays/yr =
2,080 hr/yr
      2,080 hrs/yr x 30 mrem/hr = 62,400 person-mrem/yr = 62.4
person-rem/yr
Totals for the Horizontal Palletized Stacking Configuration:
Operation                               Cumulative Personnel Exposure 
                                         (person-rem/year) 
Inventory                               30.0 
Corrosion Inspection                    0.0 
Miscellaneous                           62.4 
TOTAL                                   92.4
Conservatism in Calculations:
      .     Calculation for inventory of magazines assumed 2 workers
            for duration of time
      .     250 mrem/hr dose rate based on worst case analysis from
            Safety Analysis Report for horizontal palletized stacking
            configuration
      .     No credit was taken for personnel shielding (shielded
            forklift, lead aprons)
      .     Assumes worker exposure over the duration of activities
      .     Duration for miscellaneous operations may be reduced with
            plans for the future (approximately 1/2 hr/day is
            anticipated)

F.4.2 No Action Calculations

The No-Action alternative addresses the vertical single-layer
configuration for the 18 Modified-Richmond magazines only.
ASSUMPTIONS:
Inventory Process:                      2 people, 70 minutes for each side of an 
(Vertical Single-                       Modified-Richmond magazine.  Inventory 2 
Layer                                   sides each month.  Frequency is in 
Configuration)                          accordance with current operations. 
Corrosion                               100 percent container corrosion inspection 
Inspections:                            for each Modified-Richmond magazine every 18 
                                        months.  Assume 1 minute per container for 
                                        surveillance operations, 2 workers 
                                        (100 percent inspection of 12 magazines/yr). 
Miscellaneous                           One Modified-Richmond magazine opened every 
Operations:                             day for 2 hours with 2 workers.  Loading, 
                                        unloading, use of forklifts, continuous 
                                        close exposure is limited. 
Radiation Dose                          525 mrem/hr for the vertical single-layer 
Rates:                                  configuration inventory process.  60 mrem/hr 
                                        for corrosion inspection activities. 
                                        30 mrem/hr for miscellaneous operations.
NO-ACTION - 18 MODIFIED-RICHMOND MAGAZINES ONLY
(vertical single-layer configuration)
Inventory Operations:
      2 persons x 70 min/side x 2 sides/mo x 12 mo/yr = 3,360 min/yr
      (3,360 min/yr)/60 min/hr x 525 mrem/hr = 29,400 person-mrem/yr
      = 29.4 person-rem/yr
Corrosion Inspections:
      2 persons x 384 min/magazine x 12 magazines/yr = 9,216 min/yr
      (9,216 min/yr)/60 min/hr x 60 mrem/hr = 9,216 person-mrem/yr
= 9.2 person-rem/yr
Miscellaneous Operations:
      2 persons x 2 hr/day x 260 workdays/yr = 1,040 hrs/yr
      1,040 hrs/yr x 30 mrem/hr = 31,200 person-mrem/yr = 31.2
person-rem/yr
Totals for the Vertical Single-Layer Configuration:
Operation                                  Cumulative Personnel Exposure 
                                            (person-rem/year) 
Inventory                                  29.4 
Corrosion Inspection                       9.2 
Miscellaneous                              31.2 
TOTAL                                      69.8
Conservatism in Calculations:
      .     525 mrem/hr dose rate based on most conservative analysis
            from Safety Analysis Report
      .     No credit was taken for personnel shielding (lead aprons)
      .     Assumes worker exposure over the duration of activities
      .     Assumes 384 pits for Modified-Richmond magazines
      .     100 percent corrosion inspection will probably be no more
            than 20 percent
      .     Duration for miscellaneous operations may be reduced with
            future plans (approximately 1/2 hr/day is anticipated)

F.5 CONCLUSIONS

The analysis provided in this appendix results in the following
cumulative worker exposure estimates:
Proposed Action
(vertical single-layer configuration)
   191.1 person-rem/yr (bounding range of 100 to 200 person-rem/yr)
Proposed Action
(horizontal palletized stacking configuration)
   92.4 person-rem/yr (bounding range of 50 to 100 person-rem/yr)
No Action
(vertical single-layer configuration)
   69.8 person-rem/yr (bounding range of 50 to 100 person-rem/yr)
Each configuration calculation includes a high degree of
conservatism in the results.  Although extremely conservative, the
intent of this analysis was to provide bounding numbers for the
cumulative personnel dose to Zone 4 workers and is considered to
meet National Environmental Policy Act requirements established for
identifying consequences in Environmental Assessment documents.

F.6 REFERENCES

1.    Final Safety Analysis Report, Zone 4 Magazines, Issue D,
      United States Department of Energy, April 1993.
2.    MCNP - A General Monte Carlo Code for Neutron and Photon
      Transport, Version 3, Briesmeister, J. (ed), LA-7396-M,
      Revision 2, Los Alamos National Laboratory, September 1986.
3.    "MCNP Newsletter," Briesmeister, J., Los Alamos National
      Laboratory, April 1991.

Section II Response to Comments Pre-Approval Environmental Assessment

EXECUTIVE SUMMARY

Introduction
An earlier draft Environmental Assessment for Interim Storage of
Plutonium Components at Pantex was provided to the State of Texas in
December 1992 in accordance with the Department of Energy National
Environmental Policy Act Implementing Procedures [10 Code of Federal
Regulations 1021.301] that require the Department to provide
Environmental Assessments to the host State and Indian Tribes for
review prior to approval. Comments from State and local government
officials, national and local interest groups and private citizens were
forwarded to the Department through the Office of the Governor for
response. In total, forty-six letters were received (see Table ES-1)
and from those letters, 423 comments were extracted and categorized
into the general topical areas described below. The Department also
recently received comments regarding the aircraft crash analysis from
the Defense Nuclear Facilities Safety Board. The comments were
carefully reviewed and considered; and where appropriate, this draft
Environmental Assessment has been modified to address those comments.
A. Nuclear Weapons Complex Programmatic Environmental Impact Statement
and Long-Term Plutonium Storage Issues - concerns regarding the
interim storage period and the decisions to be made in the Record
of Decision in the Nuclear Weapons Complex Reconfiguration
Programmatic Environmental Impact Statement. (50 comments)
B. National Environmental Policy Act Issues - concerns regarding the
adequacy of an Environmental Assessment for the proposed action,
changes in mission for the Pantex Plant, and concern that the
programmatic requirements for U.S. nuclear weapons dismantlement
should be addressed. (42 comments)
C. Alternatives to the Proposed Action - concerns regarding the
Department's obligation to evaluate and consider all reasonable
alternatives to the proposed action. (39 comments)
D. Operational Issues - general concerns and requests for
clarification of various operational issues and hazards analyses
performed for Zone 4 operations. These include the 1) worker
exposure calculations; 2) storage configuration; 3) the forklift
operational accident scenario; and 4) other general hazards
analyses such as tornadic winds. (140 comments)
E. Ogallala Aquifer - technical differences regarding data used and
methodology of the analysis. (35 comments)
F. Aircraft Crash Hazard Analysis - technical differences regarding
data used and methodology of the analysis. (45 comments)
G. General Topics - those issues and concerns that do not fit into the
previous categories. (72 comments)
H. Comments from the Defense Nuclear Facilities Safety Board -
technical concerns regarding the methodology and adequacy of the
aircraft crash analysis. (4 comments)
Response Summaries
With the exception of the "General Topics" category, a summary of the Department's
overall response is provided below.
A. Nuclear Weapons Complex Programmatic Environmental Impact Statement and
Long-Term Plutonium Storage Issues
The proposed action analyzed in this document has evolved as a result of recent
developments in the areas of national security and foreign policy. As originally
envisioned, the proposed action was to provide additional storage for up to 20,000
pits at Pantex for a period of approximately six to ten years. The anticipated duration
of the interim storage was based on the December 1994 expected completion of the
Department's Reconfiguration Programmatic EIS, allowing sufficient time to implement
the decision regarding the future nuclear weapons complex that would be made on
the basis of that Programmatic Environmental Impact Statement. It was expected
that one of the elements of the future weapons complex would be a new long-term
storage facility, to be constructed within the six to ten year time frame.
The President, on September 27, 1993 established an interagency task force to
determine the disposition of plutonium surplus to national defense requirements. This
task force is being led by the National Security Council and the Office of Science and
Technology Policy with the participation of the Arms Control and Disarmament
Agency, the Central Intelligence Agency, the Office of Management and Budget,
and the Departments of State, Defense and Energy. The public and certain foreign
nations will also be invited to participate in the task force. The results and
implementation of its recommendations are likely to have significant impact on both
the number of pits requiring long-term storage, and the duration of the storage period.
It is likely that a substantial majority of the pits proposed to be stored at Pantex, which
are surplus to the nation's defense needs, will be affected by decisions resulting from
the work of the task force. Because the task force was so recently chartered,
however, it is impossible to now predict the timing of its recommendations or their
implementation.
In addition to its participation in this task force, the Department is conducting or will
shortly commence the following National Environmental Policy Act reviews which also
will address the storage of plutonium:
First, as noted above, the Reconfiguration Programmatic Environmental Impact
Statement is examining the alternatives for the long-term storage of all Department of
Energy owned plutonium. The alternatives being considered for long-term storage
include "no-action," which, if selected in the Record of Decision on that Environmental
Impact Statement, would continue the storage of the pits at Pantex in the existing
facilities. Another alternative being considered is to upgrade the existing facilities. If
this alternative is selected in the Record of Decision, upgrades to existing storage
facilities, including Pantex, could occur following a likely additional project specific
review under the National Environmental Policy Act. The final alternative under
consideration is the siting and construction of a new long-term storage facility which, if
selected in the Record of Decision, would result in the pits stored at Pantex being
moved to that facility, at 1 of 5 considered sites. The Record of Decision is expected
to be issued in January, 1995. It should be noted that the Pantex site is among five
sites under consideration for the location of a new long-term storage facility.
Second, the Department is commencing the preparation of a new site-wide
Environmental Impact Statement for the Pantex site. This Environmental Impact
Statement will examine all aspects of current and foreseeable activities and
operations of the Pantex Plant, including all dismantlement and storage-related issues.
This Environmental Impact Statement will include analysis of measures to further
mitigate the impacts of Pantex operations. While the scope of the Environmental
Impact Statement cannot be defined precisely until the public scoping process has
been completed, the Department of Energy expects that alternatives to the
continued storage of pits at Pantex will be considered. This review will take 2-3 years
to complete. The Public will be invited to help determine the scope of issues to be
addressed and provide comments on the Draft Environmental Impact Statement
when completed.
Third, the Department is committed to include in an Environmental Impact Statement
any implementation actions it proposes to take in conjunction with the task force on
the disposition of surplus plutonium. This will help ensure meaningful public
involvement in the examination of alternative means of disposition.
The resolution of all these uncertainties and the preparation of these documents will
require time, making it less likely to site and construct a new long-term storage facility
on the schedule previously indicated and which would have led to storage relief at
Pantex in six to ten years. Because of the national security and foreign policy
considerations previously described, which highlights the importance of the continued
disassembly of nuclear weapons and the consequent interim storage of the fissile
material they contain, the Department cannot wait for these longer-term
programmatic decisions. If the proposed action is not adopted, shipment of nuclear
weapons to Pantex for dismantlement will cease in the first quarter of 1994 and actual
dismantlement will cease within weeks of the cessation of shipments.
Accordingly, the Department is proposing to provide interim storage for up to 20,000
pits in the Pantex facility on an interim basis until the longer-term decisions on
storage/disposition are made and implemented. The Department is now
contemplating that the new site-wide Environmental Impact Statement for the Pantex
site will consider the environmental impacts for a period of 5-10 years associated with
continued operation of the Pantex Facility, including storage. The long-term decisions
regarding the storage/disposition of plutonium will be made following the completion
of the Reconfiguration Programmatic Environmental Impact Statement now
scheduled for late 1994, and the work of the task force on plutonium disposition.
These decisions will be made on the basis of the various activities and analyses
described above. The Environmental Assessment has been revised to include a
discussion of these developments.
Several comments observed that the initial Nuclear Weapons Complex
Reconfiguration Programmatic Environmental Impact Statement scope did not
include consideration of the long-term storage of plutonium weapon components.
This observation is correct; long-term plutonium pit storage was not a requirement at
the time the Department published its Nuclear Weapons Complex Reconfiguration
Study (DOE/DP-0083, January 1991). At that time, the Department's nuclear weapons
complex was required to support a much larger nuclear weapons stockpile that is
now the case. Accordingly, it was expected that nuclear materials would be
recycled without the need for long-term storage capacity. Consequently, initial
planning for the Reconfiguration Programmatic Environmental Impact Statement did
not consider analysis of the environmental impacts associated with a long-term
plutonium storage facility. Neither the "Notice of Intent" (56 Federal Register 5590,
February 11, 1991) announcing the preparation of the Programmatic Environmental
Impact Statement nor the Implementation Plan, Nuclear Weapons Reconfiguration
Programmatic Environmental Impact Statement (DOE/EIS-0161IP, February 1992) dealt
specifically with the need for such future long-term storage.
Subsequent events dictated that the complex of the future (Complex 21) must
provide for long-term storage of plutonium. The first of three arms reductions initiatives
by former President George Bush was announced in September 27, 1991 and,
together with the initiative announced on the January 28, 1992 State of the Union
address and the June 16, 1992 Bush/Yeltsin agreement (later codified in the Strategic
Arms Reduction Treaty II), resulted in large reductions in the nation's nuclear weapons
stockpile requirements. These reductions resulted in the retirement of weapons in the
stockpile in much larger numbers and in a much more compressed timeframe than
had been previously contemplated. In addition, the Department was faced with a
situation in which the present authorized storage capacity at the Pantex Plant would
be exhausted long before the announced weapons retirements were completed and
before the Reconfiguration Programmatic Environmental Impact Statement could be
completed and reconfiguration decisions made concerning long-term storage. Thus,
in order to continue the dismantlement of weapons, the additional interim storage
capacity would be required regardless of any decisions that are subsequently made
concerning reconfiguration.
Since it has now been determined that Complex 21 must provide for long-term
plutonium storage capacity, the environmental impacts of locating such a facility at
any one of several alternative sites must be included in the Reconfiguration
Programmatic Environmental Impact Statement. Conceptual design efforts have
already begun for long-term storage capacity. A Revised Notice of Intent that
includes these changes to the original reconfiguration proposal as well as other
potential modifications to that proposal was published in the Federal Register on July
23, 1993 (58 Federal Register 39528). The Department has held additional scoping
hearings to assure opportunity for input and comments, and the Department will revise
the Programmatic Environmental Impact Statement Implementation Plan to include
any changes.
Following completion of a Draft Programmatic Environmental Impact Statement,
public review and comment, and preparation of a Final Programmatic Environmental
Impact Statement, it is expected that a Record of Decision can be issued in early
1995. The Pantex Plant is one of the sites being considered for location of nuclear
facilities in the reconfigured complex, including long-term plutonium storage.
Environmental analyses will include, among other things, evaluations of the impacts of
transportation of plutonium from sites where it is now stored to potential long-term
storage locations, as well as the risks of long-term storage of pits and other forms of
plutonium. The Record of Decision will be followed by a Site-Specific Environmental
Impact Statement which will examine the environmental impacts of any construction
and operation of the facility at the location selected. In accordance with the
Department's implementing regulation for the National Environmental Policy Act
[10 Code of Federal Regulations Part 1021] affected States, Indian Tribes, and the
general public will continue to have opportunities for review and comment regarding
the planning for and analyses contained in both the Programmatic Environmental
Impact Statement and the Site-Specific Environmental Impact Statement. The
Secretary of Energy's decisions regarding reconfiguration will be based on a
combination of environmental impact, cost, and technical consideration.
Several comments questioned when the Department would complete moving
plutonium pits stored in Zone 4 at the Pantex Plant. The timing for completion of any
transfer will depend on where the long-term storage function is performed, the rate at
which materials can be moved safely, and the priorities established for moving various
types of nuclear material.
Several comments questioned what would occur if a long-term storage facility is not
available at the end of the interim storage period. The Department will do all within
its control to expedite timely completion of the Programmatic Environmental Impact
Statement, Record of Decision and site-specific National Environmental Policy Act
reviews. The nature of the National Environmental Policy Act process, as well as
possible changes in national policy or funding availability, prevents the Department
from guaranteeing against unexpected delays. The Department is committed to
working closely with the State of Texas and the public to resolve issues that arise
during the interim storage period and during any transfer of the plutonium
components to long-term storage.
A few comments expressed concern that if the interim storage period were incorrectly
estimated, the conclusions of the Environmental Assessment might also be incorrect.
The conclusions of the Environmental Assessment are not dependent on the length of
the interim storage period, but rather the environmental impacts from routine storage,
as well as potential accidents. Section 6.0 of the Environmental Assessment evaluates
the potential impacts of using certain Steel Arch Construction and Modified-Richmond
magazines to provide interim storage capability for plutonium weapons components.
Increases in worker radiation exposures due to on-site interim storage operational
activities were evaluated on an annual basis, and personnel would be monitored to
ensure administratively controlled annual limits on exposure are met. Container
integrity during the interim storage period will be ensured by a surveillance program
that would detect any change in the integrity of the container or packaging
materials. Deterioration is expected to occur very infrequently since, especially after
the horizontal storage configuration is implemented, container exposure to moisture
that might cause corrosion would be minimal. Pit stability during the interim storage
period will be monitored by conducting pit surveillance testing in conjunction with the
pit container surveillance program. The Environmental Assessment's analysis of
potential accidents found frequencies and effects to be insignificant.
The Department is aware of no issue which would limit interim storage duration to a
specified time period.
B. National Environmental Policy Act Issues
The Pre-Approval Environmental Assessment was provided to the State of Texas for
review and comment in accordance with the Department's National Environmental
Policy Act Implementing Procedures [10 Code of Federal Regulations 1021.301(d)].
The Department has carefully considered all of the comments on the Environmental
Assessment provided by the State of Texas, including comments by State and local
agencies and officials, interest groups, and the public. The Department met with the
State and stakeholders to discuss the comments and the revisions made in the
Environmental Assessment to incorporate State and public input. When the
Environmental Assessment is finalized, the Department will determine whether to issue
a Finding of No Significant Impact for the proposed action or prepare an
Environmental Impact Statement. The Department will issue a Finding of No Significant
Impact only if the Environmental Assessment supports the finding that the proposed
action will not have a significant effect on the human environment, in accordance
with the Council on Environmental Quality Regulations for Implementing the National
Environmental Policy Act [40 Code of Federal Regulations Parts 1500-1508] and the
Department's National Environmental Policy Act regulations [10 Code of Federal
Regulations Part 1021].
Comments on the scope of the Environmental Assessment stated that the proposed
action should include long-term storage of plutonium components and/or
dismantlement operations at the Pantex Plant. The decisions on long-term storage of
plutonium components are being addressed in the Programmatic Environmental
Impact Statement for reconfiguration of the weapons complex, as discussed in
Section A of this document. However, in order to proceed with the reduction of the
nuclear weapons stockpile, the Department determined that a decision on additional
interim storage would be needed prior to completion of the Programmatic
Environmental Impact Statement. To support this decision, the Department prepared
the Environmental Assessment in accordance with the Department's National
Environmental Policy Act Implementing Procedures [10 Code of Federal Regulations
Part 1021]. Additional National Environmental Policy Act analysis of dismantlement
activities is not needed to decide whether to increase interim pit storage at the
Pantex Plant. Dismantlement has historically been part of the Pantex Plant mission
and is addressed by the Final Environmental Impact Statement, Pantex Plant Site
(DOE/EIS-0098, October 1983). Weapons dismantlement is being conducted in much
the same way it has always been conducted, with ongoing improvements to safety
and environmental protection in accordance with regulatory requirements.
Dismantlement operations will remain within the normal historic range of
assembly/disassembly activity at the Pantex Plant.
To address any potential concerns regarding cumulative impacts from increased
dismantlement activities, the Department will prepare a new Pantex Site-Wide
Environmental Impact Statement. A Notice of Intent to prepare this document will be
issued in the Federal Register soon. The Department has initiated assembly of
environmental baseline information in support of this effort. This Environmental Impact
Statement will examine all aspects of current and foreseeable activities and operation
of the Pantex Plant, including dismantlement and storage-related issues. This
Environmental Impact Statement will include analyses of measures to further mitigate
the effect of Pantex activities. Although the scope of the Environmental Impact
Statement cannot be defined until the public scoping process has been completed,
the Department now envisions considering alternatives to the continued storage of
pits at Pantex. The Department cannot predict how long this review will take but best
efforts will be made to complete the Environmental Impact Statement on an
expedited basis. The public will be invited to help determine the scope of issues to be
addressed and comment on the draft Environmental Impact Statement when it is
available. When the Nuclear Weapons Complex Programmatic Environmental Impact
Statement Record of Decision is issued, aspects specific to the Pantex Plant will be
incorporated into the new Site-Wide Environmental Impact Statement.
Comments stated that the interim storage of plutonium components constitutes a
change in mission for the Pantex Plant, and therefore an Environmental Impact
Statement should be prepared. The Department believes that the proposed action is
consistent with the historical mission of the plant, as it relates to the temporary staging
of plutonium components after disassembly of retired weapons and prior to shipping
to Rocky Flats for processing. The proposed action analyzed in the Environmental
Assessment is the augmentation of the capability to store plutonium components
temporarily, in response to the cessation of plutonium operations at the Rocky Flats
Plant.
C. Alternatives to the Proposed Action
Several comments suggested inadequate treatment of the Department's discussion of
alternatives to interim storage at the Pantex Plant. In response, the Department has
substantially enhanced this discussion. The major issues follow:
1. All possible alternatives were not discussed or were not discussed in sufficient
detail.
The National Environmental Policy Act requires that reasonable alternatives to a
proposed action be discussed in an Environmental Assessment. Several alternatives
were developed and are described in Section 4.0 of the Environmental Assessment.
Both Department of Defense sites and other Department of Energy sites were
considered as alternative storage areas.
While every conceivable alternative was not mentioned, those alternatives discussed
were potentially available and were considered to be potentially reasonable
alternatives. Sites which commenters mention that are not specifically discussed in
the Environmental Assessment are either in use now or slated for future uses other than
pit storage.
The discussion of alternatives in the Environmental Assessment explains that a
combination of factors led to the conclusion that none of the other sites considered
(those of the Department of Energy and the Department of Defense) is reasonable in
that none meet the criteria for the proposed action. The sites considered do not
meet programmatic goals for interim storage because of the following factors:
1) increased cost (for facility modification, to augment or reactivate enhanced
security, for increased transportation requirements, etc.), 2) untimely implementation
of alternative interim storage (time to modify facilities, perform required safety
analyses, develop site-specific procedures, train personnel, etc.), and 3) no apparent
environmental benefit to interim storage at an alternate site. Under the proposed
action, there are no increased transportation requirements, only minor facility
enhancements are required, and activities required for implementation are essentially
in place.
2. No basis was presented in the Environmental Assessment to support the
Department's conclusion that no environmental advantage would be gained by
moving and storing the pits at an alternative site on an interim basis.
In the Department's discussion of alternatives, the Environmental Assessment analyzes
whether environmental benefit could be derived by storing pits off-site (either at up to
four separate Department facilities or at a Department of Defense facility). The
Environmental Assessment analysis indicates that radiation exposure to workers is the
principal impact of the proposed action, and there is no significant impact to the
environment. While impact to the environment would be no different, worker
exposure could be increased in the implementation of off-site or decentralized interim
storage. Decentralization of interim pit storage (at more than one site) would
generate duplication of security, handling, and inventory requirements. The processes
of moving (for shipping, receiving, movement into storage facility), transporting,
repackaging (as required), storing, and inventorying pits contribute to total person
exposure levels, thereby increasing the total cumulative person-rem exposure.
Efficiency in handling, monitoring, and inspecting the plutonium components is
achieved by conducting interim storage operation at one site rather than multiple
sites and could result in lower cumulative radiation exposure to workers.
The relative number of handling steps that would be required by the proposed action
and storage at another site is compared in the attached process flow diagram (Figure
ES-1). Eliminating transportation to alternate sites eliminates some of these processes
as well as the total work load and costs involved in pit storage management and is
consistent with "as low as reasonably achievable" principles. Although exposures from
implementing alternatives would not be unacceptable from the standpoint of worker
safety, worker exposures would be expected to be higher relative to the proposed
action. This conclusion does not imply that occupational exposure standards for
workers would be exceeded for any alternative.
3. The Department does not discuss specific Department of Defense facilities (as
cited in the comments) and, therefore, appears not to have considered them.
The Department has been working since May 1992 with the Department of Defense
concerning potential use of Department of Defense sites for interim pit storage. The
Environmental Assessment discussion has been expanded to reflect the most recent
results from this interaction. The Department has concluded that Department of
Defense sites are not feasible alternatives to the proposed action for the following
reasons:
y The Department of Defense is restructuring its forces to reflect both troop
reductions and base closures. As part of this effort, some Department of Defense
bases are being configured to accommodate only conventional forces and their
weapons. The remaining active weapon storage facilities are committed to
storing both nuclear and conventional weapons, which are being moved from
overseas bases and from facilities designated for closure. This restructuring
process could take several years. The requirement for additional continental U.S.
storage capacity is further strained by the backlog of retired weapons.
y All Department of Defense excess sites are placed on the Base Realignment and
Closure List. To store special nuclear material and establish special nuclear
material repository infrastructure (e.g., security, environmental study, training, and
negotiation of site-sharing agreements) at an inactive Department of Defense site
would require significant new funding and implementation time.
y No environmental benefit is apparent in the use of Department of Defense sites
for the interim storage of plutonium components.
The Environmental Assessment also discusses the implication that the No Action
alternative (and the resulting need to store an increasing number of weapons at
Defense sites) would have on Department of Defense plans for realignment and
closure of bases.
D. Operational Issues
Several commenters questioned the inspection types and schedules and voiced
concern over pit, pit container, and magazine stability. Some comments concerned
the possibilities of a plutonium release caused by either a forklift puncturing a
container, a battery exploding, an internal fire, or some other vehicle accident. There
were also concerns raised with respect to the analysis performed to project worker
exposures.
The configurations (single-layer vertical with and without aisles and horizontal
palletized multiple stacking) for the storage magazines allow for access to accomplish
appropriate inspection of containers. Inspection for both configurations would be
carried out concurrent with planned inventory activities (every 18 months), and would
consist of a visual inspection of magazine conditions and of exposed pit container
surfaces and removal of surveillance samples for the container and pit surveillance
programs. The surveillance programs consist of complete visual inspection of the pits
and individual container parts. Container integrity would be further evaluated via
inspection (both visual and using non-destructive evaluation techniques) of the
container surfaces (for corrosion), weld integrity, and integrity of insulation and plastic
parts. In addition, pits from these containers would be evaluated at the Los Alamos
National Laboratory to evaluate the pit integrity and monitor for aging-related
defects. These programs are consistent with and draw from the sampling and testing
criteria used in the Department's Weapons Quality Assurance Testing Program and will
also draw from historical pit surveillance data to ensure integrity of the pits and pit
container. With respect to magazine integrity, analysis has shown the magazines are
capable of withstanding the Maximum Credible Tornado (200 mph).
A spectrum of accident initiators was addressed in the analysis. Of the initiators
examined, the forklift accident was the only credible event that could conceivably
cause damage to the container or pit and therefore the effect of this initiator was
evaluated. Using conservative assumptions, the committed effective dose equivalent
to an individual at two kilometers would be 0.00013 rem over 50 years (compared to
the Environmental Protection Agency standard of 0.010 rem/year) and to the
unprotected forklift operator, the committed effective dose equivalent would be
6.6 rem over 50 years (compared to the Federal radiation limit of 5 rem/year). The
shielded forklift that was designed to reduce routine worker exposure, and is now at
the Pantex Plant, also includes features to specifically reduce the probability of this
initiator. Sensors have been installed in the forklift, along with electrical and
mechanical interlocks to reduce the possibility of puncturing a container.
With the increased number of pits for interim storage at the Pantex Plant, there exists a
potential for increased worker exposure. The Pantex Plant management has
proactively taken several steps to reduce worker exposure over current levels in
keeping with its "as low as reasonably achievable" goals. The horizontal palletized
multiple stacking configuration will reduce the dose rates, compared to the single-
layer vertical configuration, by a factor of two (Appendix F, Section F.3.2 of the
Environmental Assessment) due to self-shielding of the containers. In addition, the
proposed horizontal configuration allows the use of a shielded forklift to manipulate a
pallet of containers to reduce exposure time. In the present configuration, the
containers must be individually handled for the inspection process. Only the person
inside the shielded forklift will occupy the magazine during the operation (currently
two individuals normally conduct the inspection operation) and shielding on the forklift
should provide a dose reduction factor of at least 20 over current inventory methods.
An Automated Guided Vehicle, estimated to be available for Zone 4 operations by
fall of 1994, will eliminate the need for personnel to enter the magazine for inventory
and inspection by using a bar code reader and camera. By eliminating the need for
personnel to enter the magazines for routine inventory activities, radiation exposure will
be drastically reduced. All of these steps will ensure that the worker exposure dose for
the interim storage of pits will be less than the current dose.
E. Ogallala Aquifer
The Department tasked the Los Alamos National Laboratory to analyze the potential
effects on the Ogallala Aquifer from a hypothetical plutonium dispersal accident. This
analysis assessed the effect of a surface contamination of 0.2 microCuries per square
meter (yCi/m2) on the aquifer. This level of contamination is expected to be the
maximum amount remaining after decontamination efforts. The Department has
carefully considered and responded to each comment concerning the analysis. The
concerns raised by the comments can be grouped into four major areas of concern.
Below, the main ideas of the detailed responses to comments in these four areas are
summarized.
1. Comment authors were concerned about the Department's ability to perform a
cleanup to 0.2 yCi/m2 and about the validity of the assumption that surface
transport would concentrate plutonium in the playas by a factor of ten.
In 1977, the U.S. Environmental Protection Agency proposed 0.2 yCi/m2 as the cleanup
guideline for plutonium in soil. It should be noted that this Environmental Protection
Agency guideline is the more restrictive of two cleanup levels discussed and analyzed
in Section 4.2.7 of the Final Environmental Impact Statement, Pantex Plant Site
(DOE/EIS-0098, October 1983). This guideline was never adopted by the Environmental
Protection Agency as a standard; however, it is a level achievable using current
technology. This technology has been demonstrated at such cleanups as those
performed at Johnston Island, Eniwetok Atoll, and current research and development
activities at the Nevada Test Site. The analysis assumes a scenario that was analyzed
elsewhere in the environmental assessment and found to have a frequency of
occurrence of less than 7 x 10-7 per year. The scenario is that a large and/or fast flying
airplane crashes into and penetrates a Zone 4 nuclear weapons component storage
magazine at the Pantex Plant. In addition, for 25 percent of the magazine inventory
(approximately 100 containers), either the AL-R8 storage container is mechanically
damaged such that a fuel fire resulting from the ignition of aircraft fuel could breach
the pit cladding, melt and aerosolize the plutonium or for undamaged AL-R8
containers, the resulting fuel fire is sufficiently long lasting as to defeat the thermal
cladding and thus melt and aerosolize the plutonium. The thermal energy from the
fire also provides the necessary energy to disperse the aerosolized plutonium to areas
surrounding the plant site. The maximum size of the area that might be contaminated
above this cleanup guideline was estimated to be approximately 75 km2. See
memorandum from Sandia National Laboratory, dated April 30, 1993 from Y.T. Lin, N.R.
Grandjean, R.E. Smith to D.R. Rosson (Department of Energy/Albuquerque) titled
"Plutonium Dispersal Deposition Area Estimates of a Hypothetical Aircraft Crash Into
Pantex Zone 4, (which is provided in the Environmental Assessment Comment
Response, Appendix I). The 75 km2 area is much smaller than the 1036 km2 area that
the Final Environmental Impact Statement, Pantex Plant Site (DOE/EIS-0098, October
1983) projected to be contaminated by a hypothetical plant accident that involves
plutonium dispersal from assembled weapons by high explosives detonation.
Therefore, the analysis and conclusions reached in the Final Environmental Impact
Statement, Pantex Plant Site regarding the effects of a plutonium dispersal accident
caused by an incident already have taken into account effects that might be caused
by the hypothetical interim storage accident. Also, the discussions contained in the
Final Environmental Impact Statement, Pantex Plant Site concerning cleanup of any
contaminated area would apply equally well to the hypothetical accident. 1) See
Palomares Summary Report. Field Command, Defense Nuclear Agency, Technology
and Analysis Directorate, Kirtland Air Force Base. 2) Thule. United States Air Force
Nuclear Safety, AFRP 122, January/February/March 1970, No. 1, Volume 65 (Part 2),
Special Edition: "Project Crested Ice". 3) Johnston Island, Thermo Analytical
(Attention: Nels Johnson/5635 Jefferson Street, N.E., Albuquerque, New Mexico 87109),
Soil Clean of Technologies.
If soil removal were required, several years might be needed to clean all affected
areas. However, a delay on the order of a few years would not significantly change
the Environmental Assessment's conclusions concerning the potential effects of a
plutonium dispersal accident on the Ogallala Aquifer. Although there is uncertainty
concerning the long-term rate of plutonium transport, soil scientists generally agree
that it is relatively immobile and that it will not migrate beyond remediable depths
within the few years that could be needed to complete a cleanup. An exception to
this could occur, however, if short-circuits (i.e., artificial recharge projects or improperly
constructed or abandoned water wells) existed. In the extremely unlikely event of a
plutonium-dispersal accident, these areas would receive priority for decontamination
and steps taken to eliminate the short-circuit path to groundwater. The Department
has initiated steps to identify and document preferential pathways that may exist
within the postulated area of contamination.
Following the hypothetical accident, plutonium would be expected to concentrate
prior to infiltration in playa lakes as a result of surface transport processes. Therefore, a
conservative concentration factor of ten was applied to the cleanup level to estimate
the initial plutonium concentration in playa lakes. Actual field data from the Trinity Site
were used to confirm that the concentration factor of ten was reasonable, yet
conservative.
See Palomares Summary Report, Field Command, Defense Nuclear Agency,
Technology and Analysis Directorate, Kirtland, Air Force Base, Thule, United States Air
Force Nuclear Safety, AFRP 122, January/February/March 1970, No. 1, Volume 65 (Part
2), Special Edition: "Project Crested Ice", Johnson Island, Thermo Analytical (Attention:
Nels Johnson/5635 Jefferson Street, N.W., Albuquerque, New Mexico 87109), Soil Clean
of Technologies.
2. Comment authors expressed concern that the assumed operational recharge
rate of 3 centimeters/year (cm/yr) was not sufficiently conservative.
The Los Alamos National Laboratory reviewed existing literature to estimate local playa
lake recharge rates because local, rather than regional, rates are the key to
forecasting plutonium transport to groundwater. The Los Alamos National Laboratory
concluded that 3 cm/yr is a reasonable estimate. Subsequently, the Texas Bureau of
Economic Geology offered new evidence based on tritium-dating which suggests that
a local recharge rate as high as 63 cm/yr may be possible.
Based on an analysis of the literature values and technical concerns about the tritium
dating method, the Los Alamos National Laboratory believes that the extremely high
recharge rates suggested by the Texas Bureau of Economic Geology, when
combined with the other Los Alamos National Laboratory/Department of Energy
conservative assumptions assigned to the hypothetical accident scenario, is so
conservative as to be unreasonable. Given all these assumptions, even with a very
low assumed dispersivity of one centimeter, the maximum plutonium concentration in
recharge is higher than the most conservative public water system drinking water
standard, but significantly lower than the total exposure based standard of
30 picoCurie/Liter. However, when aquifer and well-casing dilution is considered,
anticipated plutonium concentrations reaching a potential receptor are lower than
either standard. With a more realistic dispersivity of 1 meter, the analysis predicts that
even the recharge concentration would be lower than any applicable standard.
Considering these results, the Department believes that the Environmental
Assessment's original conclusion that the hypothetical plutonium dispersal accident
would not significantly impact the Ogallala Aquifer, remains valid.
3. Comment authors expressed concern that preferential flow was not adequately
considered.
The overall approach taken in evaluating the potential effects of the hypothetical
plutonium dispersal accident on the Ogallala Aquifer was to use conservative but
reasonable assumptions. In the absence of local site-specific field experiments, the
Los Alamos National Laboratory judged it to be conservative, but reasonable, to
accelerate the flow velocity by a factor of 2 to account for preferential flow
conditions.
Since determining preferential flow effects is an active soil science research area, the
Los Alamos National Laboratory's professional judgment concerning the appropriate
acceleration factor can be disputed and cannot be confirmed without local field
experiments. The Los Alamos National Laboratory based its professional judgment on
seven published studies, of which six reported acceleration factors of two or less.
Mobile/
immobile water models were not used because of the paucity of site-specific
experimental data needed to estimate the numerous parameters required by such
models.
F. Aircraft Crash Hazard Analysis
The State of Texas comments raised a number of concerns about the methodology
used for the aircraft crash hazard analysis in the Environmental Assessment. To better
address these concerns, an analysis of the vulnerability of Zone 4 magazines to impact
by general aviation single-engine aircraft was performed. The result concluded that
the annual probability of general aviation crashes having the potential for significant
consequences presented in the Environmental Assessment is valid.
Issues related to aircraft crash methodology have been treated in the detailed
responses to the comments. The following paragraphs summarize those responses.
The concerns were focused on the following points:
1. Concern was expressed regarding the overall methodology used in the aircraft
hazard analysis.
The basic methodology used in the aircraft crash hazard analysis for the Environmental
Assessment (and the supporting safety analysis report) is that previously employed by
Sandia National Laboratories in the work that supports the Final Environmental Impact
Statement, Pantex Plant Site (DOE/EIS-0098, October 1983). The Sandia National
Laboratories methodology is based on earlier work by K. Solomon for commercial
nuclear power plants. This basic methodology is accepted in the risk assessment
community. The Argonne National Laboratory, on behalf of the U.S. Nuclear
Regulatory Commission, reviewed the body of public literature in this field in the early
1980's. Argonne found that the data bases, methodologies, and modeling
approaches are adequate to estimate the threat and plant response. Thus, the
Department of Energy feels that the method used in the Environmental Assessment is
sound and reasonable. In the course of the current work, a number of conservative
assumptions in the method were examined and modified to better model the
specifics of Zone 4 compared with the plant site as a whole.
Additionally, an independent assessment of the "Vulnerability of Zone 4 Magazines to
Impact by General Aviation Single Engine Aircraft" was performed and is contained in
Appendix J. It concluded that annual probability of general aviation crashes with the
potential for significant consequences presented in the Environmental Assessment on
Interim Storage of Plutonium Components at Pantex is a valid and reasonable
assessment of such probability.
2. Concern was expressed regarding the subdivision of aircraft crash data into
separate aircraft categories.
The analysis considers the four stated aircraft categories (commercial aviation, military
aviation, general aviation, and aerial applications) separately for several reasons.
First, the data (e.g., hours flown, accidents) gathered and collated by government
agencies are by aircraft category. Second, the nature of the operations are
decidedly different. Commercial aviation is conducted under regulations established
by the Federal Aviation Administration for licensed air carriers. While general aviation
is also controlled by the Federal Aviation Administration, there are significant
differences in the applicable rules. Military aviation operates under guidelines
established by the services (e.g., U.S. Air Force, U.S. Navy), except when flying
designated airways and using commercial facilities. The data, particularly that for
accidents, is quite different. Third, the characteristics of the aircraft are different,
particularly in terms of size and speed, which has a significant effect on the potential
consequences of an accident. Therefore, the crash probabilities are generated for
each category and then combined to provide an overall estimate of the likelihood of
any aircraft crash.
3. Concern was expressed regarding the development of aircraft crash rates.
Early studies had used the fatal accident rates published by the Federal Aviation
Administration. However, careful examination of the published information indicated
that the Federal Aviation Administration designates as a fatal flight those flights in
which a fatality of any type occurs. For example, if a commercial aircraft is arriving or
departing from a passenger gate and strikes and kills a ramp worker, that flight is listed
as one with fatalities. Similarly, if a passenger should suffer a fatal heart attack
enroute, the flight would be listed as one with fatalities. These sorts of events have no
relevance to accidents that could cause damage to structures on the Pantex Plant.
Therefore, in examining the data, only those accidents that involved both fatalities
and destruction of the aircraft were selected. This results in a crash rate lower than
the published fatal accident rate, but one that is more representative of the actual
situation that represents a risk to the Pantex Plant. However, even using the Federal
Aviation Administration published fatal accident rate for commercial aviation, the
probability is not significantly increased.
4. Concern was expressed that aircraft that are landing or taking-off from the
Amarillo Airport should be considered in the analysis.
Aircraft using the Amarillo Airport (approximately 13.6 kilometers from the plant) are
included in the overall traffic counts. However, the literature contains ample data to
indicate that beyond 8 kilometers from an airport, the aircraft crash rates are those
characterized as "inflight." Any aircraft observed to be "over the Pantex Plant" must
be at least 366 meters above the terrain (to comply with Federal Aviation
Administration rules) and more than 13 kilometers from the runway. Therefore, the use
of inflight crash rates is reasonable.
5. Concern was expressed regarding the calculation of the total effective area used
in the analysis.
The total effective area required for the probability model is the sum of the base area,
a shadow area, and a skid area. It is postulated that if an aircraft impact occurs
within this total effective area, either the structure will be hit directly, or before ground
impact by an aircraft grazing the structure because it has some height, or as a result
of an aircraft skidding into it after impact with the ground. In estimating each area,
allowance is made for aircraft dimension (i.e., wingspan). In the Environmental
Assessment, the total effective area is the sum of the true areas (the magazine base
areas adjusted for aircraft dimension by aircraft category), the shadow areas (defined
by the magazine height and the angle of postulated impact), and the skid areas (the
potential area covered by an aircraft skidding after impact with the ground at some
point away from the structure of interest). The 15 degree angle of impact selected is
representative of an aircraft on a controlled descent to the ground and provides a
conservative estimate of a shadow area (the projection of the structure height into a
horizontal plane). The shadow area is only a portion of the effective area, therefore,
the total effective area is not strongly dependent upon the angle selected.
G. General Topics
A variety of comment were received that did not fit neatly into the specific categories
described above. The responses to these comments are found in this section.
H. Comments from the Defense Nuclear Facilities Safety Board
During October 1993, the Defense Nuclear Facilities Safety Board (the Board) and the
Department met to discuss the Zone 4 aircraft crash analysis. In an October 1, 1993
letter, the Board identified issues regarding the methodology used and the adequacy
of the analysis used by the Department in assessing the Zone 4 aircraft crash analysis.
After meeting with the Department to discuss the concerns, on October 29, 1993, the
Board concluded that the results shown in the Environmental Assessment Report and
the Final Safety Analyses Report for the Pantex Plant Zone 4 do meet the Nuclear
Regulatory Commission assessment criteria for evaluating aircraft hazards. This
summary of the events as well as the correspondence between the Board and the
Department is included in this section. No revisions to the Environmental Assessment
resulted from these discussions with the Board.
I. Sandia National Laboratories Memorandums
R.E. Smith, Plutonium Dispersal Consequence Analysis of Hypothetical Aircraft Crash
into Pantex Zone 4, dated December 11, 1992.
Y.T. Lin, N.R. Grandjean, and R.E. Smith, Plutonium Dispersal Deposition Area Estimates
for Hypothetical Aircraft Crash into Pantex Zone 4, dated April 30, 1993.
References provided.
J. Sandia National Laboratories Memorandum
Y.T. Lin, J.L. Tenney, and R.E. Smith - Vulnerability of Zone 4 Magazines to Impact by
General Aviation Single Engine Aircraft.
References provided as independent assessment of vulnerability of Zone 4 Magazines
to Impact by General Aviation Single Engine Aircraft.
K. Index to Comment Responses
L. Los Alamos National Laboratory Report
H.J. Turin, et al., November 1992 - Potential Ogallala Aquifer Impacts of a Hypothetical
Plutonium Dispersal Accident in Zone 4 of the Pantex Plant.
Table ES-1 - List of Comment Documents
Documen Author Affiliation
t
1001 Ann W. Richards, Governor State of Texas
1002 Alison A. Miller Texas Air Control Board
1003 Thomas A. Griffy University of Texas at Austin, Department of Physics
1004 C. Ross Schulke U.S. Department of Transportation Federal Aviation Administration
1005 Jeri Osborne & Family Citizen Comments
1006 Auburn L. Mitchell University of Texas at Austin, Texas Bureau of Economic Geology
1007 Joseph A. Martillotti Texas Department of Health, Bureau of Radiation Control
1008 Boyd Deaver Texas Water Commission
1009 Tom Millwee, Chief Texas Department of Public Safety, Division of Emergency Management
1010 Walt Kelley City of Amarillo/Counties of Potter and Randall Emergency
Management
1011 Dana O. Porter Citizen Comments
1012 Margie K. Hazlett (1) Citizen Comments
1013 Margie K. Hazlett (2) Citizen Comments
1014 Sam Day, Director Nukewatch
1015 Addis Charless, Jr. Panhandle Area Neighbors and Landowners (PANAL)
1016 Jeri Osborne Citizen Comments
1017 Jim Osborne Citizen Comments
1018 Bob Bullock, Lt. Governor State of Texas
1019 W.H. O'Brien Operation Commonsense
1020 Benito J. Garcia, Chief State of New Mexico, Environmental Department
1021 Lawrence D. Egbert, MD Physicians For Social Responsibility
1022 James Thomas Hanford Education Action League (HEAL)
1024 Jay R. Roselius, County Judge Carson County
1025 William and Mary Klingensmith Citizen Comments
1026 Tamara Snodgrass Citizen Comments
1027 Portia Dees Citizen Comments
1030 Judy Osborne Citizen Comments
1031 Louise Daniel Citizen Comments
1032 Betty E. Barnard Citizen Comments
1033 Norbert Schlegal Citizen Comments
1034 48 signatures/form letter Citizen Comments
1035 Karen Son Citizen Comments
1036 Arjun Makhijani, Ph.D. Institute for Energy & Environmental Research
1037 Bishop Leroy T. Matthiesen Diocese of Amarillo
1038 Boyd M. Foster, President Arrowhead Mills
1039 Tonya Kleuskens, Chairman The Texas Nuclear Waste Task Force
1040 Carl L. King, President Texas Corn Growers Association
1041 Beverly Gattis Military Production Network
1042 Beverly Gattis Save Texas Agriculture and Resources (STAR)
1043 Mavis Belisle, Director The Peace Farm
1044 Margie K. Hazlett (3) Citizen Comments
1045 Beverly Gattis Serious Texans Against Nuclear Dumping (STAND) of Amarillo, Inc.
1046 Dan Morales, Attorney General State of Texas, Office of the Attorney General
1048 Doris & Phillip Smith Panhandle Area Neighbors and Landowners (PANAL)
1049 Jerome W. Johnson Panhandle 2000
1050 Senator Teel Bivins (Dist 31) The Senate of The State of Texas

46 letters forwarded from the State of Texas. Document numbers not necessarily sequential.
Figure (Page ES-16 Figure ES-1 - Comparison of Steps Required For Interim Storage at the Pantex Plant With Any Other Site)
Introduction to Comment Response Sections
The Environmental Assessment for Interim Storage of Plutonium Components at Pantex
was forwarded to the Governor of Texas on December 21, 1992, for review and
comment. Subsequently, forty-six letters were returned to the Department of Energy
containing 423 comments covering a wide range of issues. The letters and the issues
therein were addressed in this way:
. The letters were entered in an organizational data base as Documents
and assigned a control number for identification. Some of the letters
addressed a single issue, while others remarked on several issues and
listed a number of points for each issue.
. To keep track of these issues, Comment numbers were assigned within
each letter (Document). The numbers used for identification and
tracking imply no other purpose and are not to be interpreted as
indicators of priority.
The following is provided for each comment:
- Document #: The control number assigned to each letter.
- Comment #: The number assigned to one or more comments within the
same letter.
- Date: The date on the letter.
- Name/Org.: The signature on the letter and organization or other
identifier.
- Comment: The specific comment or issue raised regarding the
Environmental Assessment as written in the letter.
The comments were aggregated into like subjects in Sections A through F. Following a
grouping of similar comments is the Department of Energy's answer to the comments.
Comments falling outside these areas are captured in Section G under the category
of General Topics.
Note: Due to limitations within the database used to compile the
individual comments, text formatting (bolding, underlining and italics)
and tables were not reproduced.

Part A

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (A.1) FOLLOWS ON PAGE A-9.
Document #: 1001 Comment #: 3 Date: 2/25/93
Ann W. Richards, Governor
State of Texas
Comment:
I am most concerned about the 6-10 year interim storage period. Specifically, I want to know when this 10-year
period officially begins and ends. I also need clear and definite information about what procedures will be followed
if the plutonium is still sitting at Pantex at the end of the 10-year period.
Document #: 1008 Comment #: 3 Date: 2/1/93
Boyd Deaver
Texas Water Commission
Comment:
Comment: 2.0 PURPOSE AND NEED FOR THE PROPOSED ACTION: p. 2-1, third paragraph. - "4.... This is
expected to be within a timeframe of 6-10 years.
Question: What if the 10 year goal is exceeded? What effect will NEPA have on this goal commencement?
Document #: 1011 Comment #: 1 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
The report states that the intention of the D.O.E. project is to provide temporary storage for the plutonium pits.
The difficulty in finding a permanent storage or disposal site for the plutonium is obvious. In other words, if these
"temporary" storage plans are approved, the pits will likely move into the Texas panhandle to stay.
Document #: 1015 Comment #: 3 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Page 2-1: The estimated interim storage period of 6-10 years is questionable if only for the DOE's assurances in
times past of a "temporary" anything.
Document #: 1015 Comment #: 17 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
If, because the pits are at PX and where better to have a reprocessing facility than where the pits already are, PX
becomes a reprocessing facility for Pu, what will become of the waste thus generated? For every cubic unit of Pu
reprocessed, 17 million cubic units of toxic waste are generated.
Document #: 1016 Comment #: 7 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
There is nothing about the storage that really needs to be classified. The storage and management of all
plutonium must be review (sic) throughout the DOE complex (sic) should be addressed through an environmental
impact statement for all facilities.
Document #: 1016 Comment #: 12 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
What does DOE plan to do with the Pu after six to ten years?
Section A A-1
Document #: 1018 Comment #: 3 Date: 1/20/93
Bob Bullock, Lt. Governor
State of Texas
Comment:
I would also like information regarding the proposed consolidated nuclear unit, its functions, and the criteria that will
be used in deciding its location.
Document #: 1019 Comment #: 6 Date: 1/20/93
W. H. O'Brien
Operation Commonsense
Comment:
Additionally, incremental risks created by extending the storage period longer than 10 years is not assessed, nor is
the method of indemnification provided this community that the period will not be longer than 10 years. Temporary
storage fails to be credible without the designation of a permanent storage site, if past histories are to be believed.
Document #: 1020 Comment #: 1 Date: 2/4/93
Benito J. Garcia, Chief
State of New Mexico, Environmental Dept.
Comment:
Given that the proposed activity evaluated for this assessment is an enlargement of activities which have been
on-going at the site for the past 40 years, the document seems to adequately addresses (sic) any associated
environmental impacts. The proposed action seems to be the most favorable of the alternatives considered for
interim storage. Of greater interest to the state of New Mexico is the long-term storage/disposal options being
considered for these components, as presently under consideration in the Programmatic EIS for the Nuclear
Weapons Complex Reconfiguration. The state of New Mexico would appreciate any future documentation on
plans for long term storage including transportation impacts.
Document #: 1021 Comment #: 1 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
We should insist that the storage of plutonium (Pu) in Texas should be TEMPORARY. The DOE mentions six to
ten years but the text gives no details of how this will be terminated, no discription (sic) of research going on to
prepare for storage elsewhere.
Document #: 1021 Comment #: 4 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
Are you aware that Hanford originally prepared "interim storage" which then became the de facto standard for
storage for the U.S. The limits of TEMPORARY should be very carefully spelled out.
Document #: 1021 Comment #: 9 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
No mention is found in their text of any research about long term storage or destroying or modifying Pu, all
projects which a responsible DOE would have done decades ago if their sense of responsibility had been toward
the environment rather than toward military power.
Document #: 1022 Comment #: 4 Date: 2/11/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
p. 3-1 -- DOE has failed to sufficiently define what it means by interim.
Section A A-2
Document #: 1026 Comment #: 2 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6-10 years. There appears to
be no basis for these figures. Where the pits will go after the ten year period was not discussed. Further it does
not provide assurance that pits will not be stored for more than ten years.
Document #: 1026 Comment #: 4 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
The draft EA does not analyze the environmental effects of pit storage for more than ten years.
Document #: 1027 Comment #: 2 Date: 3/5/93
Portia Dees
Citizen Comments
Comment:
I understand that this is interim storage for a period of 6 to 10 years. What happens to the plutonium and other
nuclear materials after ten years?
Document #: 1031 Comment #: 1 Date: 3/1/93
Louise Daniel
Citizen Comments
Comment:
Length of storage is estimated to be 6 to 10 years. In reality there are no plans being considered for longterm
storage. What is the basis for the 6 to 10 year estimate?
Document #: 1032 Comment #: 2 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6-10 years. There appears to
be no basis for these figures. Where the pits will go after the ten year period was not discussed. Further, it does
not provide assurance that pits will not be stored for more than ten years.
Document #: 1032 Comment #: 4 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
The draft EA does not analyze the environmental effects of pit storage for more than ten years.
Document #: 1033 Comment #: 2 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6-10 years. There appears to
be no basis for these figures. Where the pits will go after the ten year period was not discussed. Further it does
not provide assurance that pits will not be stored for more than ten years.
Section A A-3
Document #: 1033 Comment #: 4 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
The draft EA does not analyze the environmental effects of pit storage for more than ten years.
Document #: 1034 Comment #: 2 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6-10 years. There appears to
be no basis for these figures. Where the pits will go after the ten year period was not discussed. Further it does
not provide assurance that pits will not be stored for more than ten years.
Document #: 1034 Comment #: 4 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
The draft EA does not ante the environmental effects of pit storage for more than ten years.
Document #: 1035 Comment #: 2 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6-10 years. There appears to
be no basis for these figures. Whore the pits will go after the ten year period was not discussed. Further it does
not provide assurance that pits will not be stored for more than ten years.
Document #: 1035 Comment #: 4 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
The draft EA does not analyze the environmental effects of pit storage for more than ten years.
Document #: 1036 Comment #: 2 Date: 3/1/93
Arjun Makhijani Ph.D.
Institute for Energy & Environmental Research
Comment:
II. Interim Storage Period - The EA claims that pit storage at Pantex will be for 6 to 10 years and that long-term
storage or disposition options will be implemented after this. It provides no justification for the length of this interim
storage period and no information on how it was calculated.
Document #: 1036 Comment #: 3 Date: 3/1/93
Arjun Makhijani Ph.D.
Institute for Energy & Environmental Research
Comment:
The EA states that long-term options will be decided as part of the Programmatic Environmental Impact Statement
(PEIS) on the Reconfiguration of the Weapons Complex. Since even a draft of this decision (which is supposed to
take public comments on the draft into account), it is quite mysterious how the DOE arrived at the estimate that
interim storage would be for a 6 to 10 year period. The EA should provide a clear and complete justification for
this figure, including any assumptions about final disposition and the pace of final disposition measures assumed in
estimating the interim storage period.
Section A A-4
Document #: 1037 Comment #: 2 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6-10 years. There appears to
be no basis for these figures. Where the pits will go after the ten year period was not discussed. Further it does
not provide assurance that pits will not be stored for more than ten years.
Document #: 1037 Comment #: 4 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
The draft EA does not analyze the environmental effects of pit storage for more than ten years.
Document #: 1038 Comment #: 2 Date: 2/26/93
Boyd M. Foster President
Arrowhead Mills
Comment:
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6 - 10 years. There appears to
be no basis for these figures. Where the pits will go after, the ten-year period was not discussed. Further it does
not provide assurance that pits will not be stored for more than ten years.
Document #: 1038 Comment #: 4 Date: 2/26/93
Boyd M. Foster, President
Arrowhead Mills
Comment:
The draft EA does not analyze the environmental effects of pit storage for more than ten years.
Document #: 1039 Comment #: 1 Date: 3/10/93
Tonya Kleuskens, Chairman
Texas Nuclear Waste Task Force
Comment:
We are presently very concerned about the Department of Energy's Environmental Assessment regarding the
proposal to increase plutonium storage at the Pantex Plant near Amarillo, Texas.
The EA's basis is seriously flawed because it categorically presumes that plutonium storage at Pantex will be
temporary, limited to ten years. This premise does not take into account the immense obstacles to siting an
alternative storage facility.
Document #: 1039 Comment #: 2 Date: 3/10/93
Tonya Kleuskens, Chairman
Texas Nuclear Waste Task Force
Comment:
Any realistic proposal for the storage of plutonium pits should take Into consideration the uncertainty of storage
time at any DOE or Department of Defense facility. Furthermore if long-term storage should become a reality,
additional buildings would likely be necessary, a possibility not addressed in the present EA. The cost, logistics
and environmental impacts of these structures should be studied, accordingly.
Document #: 1039 Comment #: 4 Date: 3/10/93
Tonya Kleuskens, Chairman
Texas Nuclear Waste Task Force
Comment:
Further complicating this issue are the political realities that other states have established opposition to storage
and for transportation of radioactive materials within their borders. This factor raises the importance of the EA's
need to consider the likelihood of pit storage becoming long-term or permanent.
Section A A-5
Document #: 1040 Comment #: 2 Date: 3/9/93
Carl L. King, President
Texas Corn Growers Assn.
Comment:
One big problem is that the draft of the Environmental Assessment does not analyze the environmental effects of
pit storage for more than ten years.
Document #: 1041 Comment #: 2 Date: 3/12/Q3
Beverly Gattis
Military Production Network
Comment:
The success of announced arms control agreements is critical to our nation's future, and DOE's dismantlement
program is vital to the success of these agreements. We believe it is possible to conduct the dismantlement
program in a way that enhances public confidence in DOE and builds the foundation for many of the difficult,
long-term decisions which must be made about disposition of retired warhead materials.
Unfortunately, the predecisional EA on plutonium storage at Pantex does not move us toward this positive
future. Moreover DOE's lack of a coherent policy for complying with the National Environmental Policy Act
(NEPA) in regard to its dismantlement program causes us concern. Each of these areas is discussed below.
The Predecisional EA.
1) The storage period assumed in the proposed action is not supported by credible analysis. The
predecisional EA states: "The proposed action is to provide additional storage for an interim time period, expected
to be within (sic) 6-10 years, for up to 20,000 pits and does not constitute a decision to store pits at the Pantex Plant
for the long term." (p. vii) The only basis presented for this "interim" storage period is the time required to
complete DOE's Reconfiguration Programmatic Environmental Impact Statement (R-PEIS) and additional site
specific NEPA review and documentation. (pp. 2-1 & 3-1)
However, the schedule for completing the R-PEIS has slipped over the last year and there is currently no
publicly available schedule for even beginning site specific NEPA reviews to implement decisions reached in the
R-PEIS.
Also, it is not clear from the R-PEIS Implementation Plan (IP) (DOE/EIS-0161IP, February 1992) that
dismantlement is to be addressed in the manner the predecisional EA implies. Dismantlement activities were not
widely considered during the R-PEIS scoping periods, and the R-PEIS IP contains few references to the subject.
The IP indicates little more than that the future DOE complex will "[m]aintain the capability to decommission the
large number of weapons expected to be retired during stockpile downsizing or replacement," and that the R-PEIS
will evaluate "impacts of managing wastes generated by...assembly/disassembly of nuclear weapons." (R-PEIS
IP, pp. ES-8 & 2-3) In our review of the IP, it is not at all clear that the R-PEIS will in fact consider proposals for
long-term storage or disposition of plutonium, as the predecisional EA states. (p. 2-1) If the final EA relies on the
R-PEIS, then DOE must must supplement the IP with a detailed description of how issues related to dismantlement
will be addressed.
Document #: 1041 Comment #: 3 Date: 3/12/93
Beverly Gattis
Military Production Network
Comment:
Finally, history demonstrates that interim or temporary storage facilities for nuclear materials tend to become
long-term storage sites. This is clearly illustrated by the experience at numerous DOE and commercial waste
storage locations. This issue a not addressed in the predecisional EA. The final EA should clearly explain the
steps DOE will take to ensure that Pantex does not become another de facto long-term storage facility.
Section A A-6
Document #: 1042 Comment #: 4 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
3) The 6 to 10 year time frame is totally arbitrary and is an unreliable basis for any decision making. On July 6,
1992, then DOE Secretary Watkins wrote Attorney General Dan Morales that the draft PEIS would be available
for public comment by the end of 1992. That schedule was not kept, nor does any reliable schedule for the PEIS
exist. If issuance of the draft PEIS, which is totally in DOE's control, is so uncertain, then implementation of a
PEIS ROD, which may be more controlled by the courts or Congress than DOE, cannot be relied upon at all.
In an EIS, DOE should fully discuss the useful lifetime of all existing and proposed storage facilities so that
decisions about the length of time for storage would have some realistic basis, not DOE speculation.
Document #: 1042 Comment #: 8 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
2. An adequate NEPA document would fully discuss the long-term hazards of plutonium storage at Pantex.
The 6 to 10 year "interim storage" period is without support in the draft EA. Thus, an adequate EA would
describe long-term hazards of plutonium storage in order to adequately inform the decision maker and the public
of the necessity to develop alternative storage and disposal facilities.
The only basis that the draft EA states for that 6 to 10 year time frame is that within that time decisions could
be implemented from the Reconfiguration PEIS Record of Decision (R-PEIS/ROD) (pp. 2-1 and 3-1). However,
the R-PEIS Implementation Plan (DOE/EIS-01611P, February 1992), does not clearly state that any decisions
related to long-term storage or disposition of plutonium will be made in the ROD. In fact, dismantlement is only
briefly mentioned in the R-PEIS Implementation Plan (see pages ES-8, 2-3, and 3-9). Thus, if the final EA is going
to rely on the R-PEIS, the latter document must be supplemented with a detailed description of how storage and
disposal as well as other dismantlement issues, will be addressed.
Moreover, the schedule for issuance of the R-PEIS itself is totally unknown. Secretary Watkins's (sic) July 6,
1992 letter to Attorney General Morales stated that the draft R-PEIS would be available for public review by the
end of 1992. Secretary Watkins did not meet that schedule, and to our knowledge Secretary O'Leary has not
established any schedule for the R- PEIS.
Document #: 1042 Comment #: 9 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Clearly, the draft EA cannot use the R-PEIS as the basis for any decisions to be made now. Instead, the EA
must provide the basis for any time frame used for interim storage. In addition, the EA must fully discuss DOE's
history of not meeting deadlines for "interim storage." For example, Idaho has been promised for years that
transuranic wastes that were brought from Rocky Flats to the Idaho National Engineering Laboratory (INEL) were
for "interim storage," supposedly no more than 10 years. However, some of those wastes have been at INEL for
more than 20 years, and DOE still has no reliable schedule as to when, if ever, those wastes will go to a disposal
facility.
As another example, DOE has stated for years its intention to have a permanent repository for spent fuel and
high-level waste available by 1998. Even with congressional approval for work at Yucca Mountain, Nevada, DOE
is more than a decade behind meeting that 1998 date.
Similarly, even if the R-Peis/ROD states a preference for having one long-term storage or disposal facility, there
is no precedent for having such a facility available within a decade. At least one additional NEPA process would
be required for such a facility and congressional authorization and appropriation would be necessary.
Document #: 1042 Comment #: 10 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Issues that must be specifically discussed include:
a. Stability of plutonium pits during long-term storage, based on actual experience (if any) and realistic projections;
b. Deterioration of storage containers over 10 years or longer and the need to develop new storage containers
that meet independent certification requirements;
Section A A-7
Document #: 1042 Comment #: 31 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Does the 6 to 10 year interim storage time frame start from 1989, from 1993, or what date?
Document #: 1042 Comment #: 32 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Will pits stored longest be moved first once some other storage or disposal facility is available?
Document #: 1042 Comment #: 34 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
If 20,000 pits are stored at Pantex by 2003, how long would it take to ship that entire inventory to another
location? What NEPA analysis or safety analysis has been done of the relative risk of continuous shipment off-site
for 10 years versus accelerated shipment in higher volumes after the large inventory has been accumulated?
Document #: 1043 Comment #: 3 Date: 3/12/93
Mavis Belisle, Director
the Peace Farm
Comment:
Because of the irreplaceable value of the Ogallala (sic) Aquifer and the agricultural productivity of the area,
Pantex should not be considered as a site for longterm storage of the pits, final disposition, or any plutonium
processing activities. The burden of proof for any of these activities should be on DOE to assure that this is the
most suitable alternative in terms of environmental safety and security, and that in event of a catastrophe, this is
the site for which consequences would be least.
Document #: 1043 Comment #: 7 Date: 3/12/93
Mavis Belisle, Director
the Peace Farm
Comment:
At the same time, the State should urge that the long-delayed Programmatic Environmental Impact Statement
should be reopened to include dismantling and storage on the scale at which it now occuring (sic), or an additional
system-wide EIS should be initiated to cover effects of dismantling activities throughout the complex and options
for final disposition of plutonium, tritium and highly enriched uranium.
Section A A-8
Document #: 1046 Comment #: 6 Date: 3/22/93
Dan Morales, Attorney General
State of Texas, Office of the Attorney General
Comment:
IV. Closing Comments
DOE Provides no basis for the estimated interim storage time frame of 6-10 years. Given that DOE does not
yet have a proposal for long-term plutonium disposition, the statement in the EA that the time required to
implement decisions regarding long-term storage and/or disposition is expected to be within a 6-10 years time
frame is not credible. I am concerned that the analysis of potential environmental impacts has been premised on
an interim storage period that is unrealistic. If anything can be learned from DOE's civilian high-level waste site
experience and the attempts by the states to locate low-level radioactive waste sites, it is that nuclear waste
storage issues are very difficult to resolve and take far longer to resolve than first anticipated.
Many of the concerns raised in this letter are addressed in detail in the comments submitted to you by the
Texas Air Control Board, the Bureau of Economic Geology and the Texas Department of Health's Bureau of
Radiation Control. Comments by other state agencies, individuals, and citizen groups identify other areas of
concern in the draft EA. I am hopeful that the DOE will respond to each of these comments, especially those of
the above-mentioned state agencies.
When DOE first proposed increased interim storage of plutonium pits at Pantex, I requested that your
predecessor direct DOE to prepare an EIS that would address the impacts of the increased dismantlement and
storage activities at Pantex. I respectfully repeat this request now. It is apparent from the draft EA that DOE will
not run out of storage capacity at the Pantex plant until the fourth quarter of 1993 at the earliest. DOE has
sufficient time to complete an EIS that will adequately address the potentially devastating environmental impacts
that could result from the proposed increased interim storage.
The preparation of an EIS by DOE would demonstrate DOE's commitment under your guidance to fully
protecting the health, safety, and environment of this state and its citizens and would mark an historic new
direction for DOE towards full and legitimizing public participation and open decision making. I welcome your
suggestions as to how we might encourage and support your efforts in the future.
Document #: 1048 Comment #: 6 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
(2-1, 4-2, 4-3) "... long term storage or disposition of these valuable national assets will be made in the... PEIS" -
why is this EA being done outside the PEIS/ROD?
Document #: 1048 Comment #: 20 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
"The proposed action is to provide additional storage for an interim time period, expected to within 6 - 10 years, for
up to 20,000 pits.... at the Pantex Plant" What will happen in 10 years - 15 years - 20 years, etc.? Where is the
plutonium going at the end of 10 years - we want to know! This is not identified in the EA. Where or what is being
planned for this plutonium after 20 years.
Response #: A.1
The proposed action analyzed in this document has evolved as a result
of recent developments in the areas of national security and foreign
policy. As originally
envisioned, the proposed action was to provide additional storage for up to 20,000
pits at Pantex for a period of approximately six to ten years. The anticipated duration
of the interim storage was based on the December 1994 expected completion of the
Department's Reconfiguration Programmatic EIS, allowing sufficient time to implement
the decision regarding the future nuclear weapons complex that would be made on
the basis of that Programmatic Environmental Impact Statement. lt was expected
that one of the elements of the future weapons complex would be a new long-term
storage facility, to be constructed within the six to ten year time frame.
The President, on September 27, 1993 established an interagency task force to
determine the disposition of plutonium surplus to national defense requirements. This
task force is being led by the National Security Council and the Office of Science and
Technology Policy with the participation of the Arms Control and Disarmament
Agency, the Central Intelligence Agency, the Office of Management and Budget,
and the Departments of State, Defense and Energy. The public and certain foreign
nations will also be invited to participate in the task force. The results and
implementation of its recommendations are likely to have significant impact on both
the number of pits requiring long-term storage, and the duration of any storage
period. It is likely that a substantial majority of the pits proposed to be stored at
Pantex, which are surplus to the nation's defense needs, will be affected by decisions
resulting from the work of the task force. Because the task force was so recently
chartered, however, it is impossible to now predict the timing of its recommendations
or their implementation.
In addition to its participation in this task force, the Department is conducting or will
shortly commence the following National Environmental Policy Act reviews which also
will address the storage of plutonium:
First, as noted above, the Reconfiguration Programmatic Environmental Impact
Statement is examining the alternatives for the long-term storage of all Department of
Energy owned plutonium. The alternatives being considered for long-term storage
include "no-action," which, if selected in the Record of Decision on that Environmental
Impact Statement, could continue the storage of the pits at Pantex in the existing
facilities. Another alternative being considered is to upgrade the existing facilities. If
this alternative is selected in the Record of Decision, upgrades to the existing storage
facilities, including Pantex, could occur following a likely additional project specific
review under the National Environmental Policy Act. The final alternative under
consideration is the siting and construction of a new long-term storage facility which, if
selected in the Record of Decision, would result in the pits stored at Pantex being
moved to that facility, at a location to be decided. The Record of Decision is
expected to be issued in January, 1995. It should be noted that the Pantex site is
among five sites under consideration for the location of a new long-term storage
facility.
Second, the Department is commencing the preparation of a new site-wide
Environmental Impact Statement for the Pantex site. This Environmental Impact
Statement will examine all aspects of current and foreseeable activities and
operations of the Pantex Plant, including all dismantlement and storage-related issues.
This Environmental Impact Statement will include analysis of measures to further
mitigate the impacts of Pantex operations. While the scope of the Environmental
Impact Statement cannot be defined precisely until the public scoping process has
been completed, the Department of Energy expects that alternatives to the
continued storage of pits at Pantex will be considered. This review will take several
years to complete. The public will be invited to help both scope the appropriate
review and review the draft Environmental Impact Statement when completed.
Third, the Department is committed to include in an Environmental Impact Statement
any implementation actions it proposes to take in conjunction with the task force on
the disposition of surplus plutonium. This will help ensure meaningful public
involvement in the examination of alternative means of disposition.
The resolution of all these uncertainties and the preparation of these documents will
require time, making it less likely to site and construct a new long-term storage facility
on the schedule previously indicated and which would have led to storage relief at
Pantex in six to ten years. Because of the national security and foreign policy
considerations previously described, which highlights the importance of the
continued disassembly of nuclear weapons and the consequent interim storage of the
fissile material they contain, the Department cannot wait for these longer-term
programmatic decisions. If the proposed action is not adopted, shipment of nuclear
weapons to Pantex for dismantlement will cease in the first quarter of 1994 and actual
dismantlement will cease within weeks of the cessation of shipments.
Accordingly, the Department is proposing to provide interim storage for up to 20,000
pits in the Pantex facility on an interim basis until the longer-term decisions on
storage/disposition are made and implemented. The Department is now
contemplating that the new site-wide Environmental Impact Statement for the Pantex
site will consider the environmental impacts associated with continued operation of
the Pantex Facility, including storage, for a period of 5-10 years from the completion
of the Environmental Impact Statement. The long-term decisions regarding the
storage/disposition of plutonium will be made following the completion of the
Reconfiguration Programmatic Environmental Impact Statement now scheduled for
late 1994, and the work of the task force on plutonium disposition. These decisions will
be made on the basis of the various activities and analyses described above. The
Environmental Assessment has been revised to include the above discussion.
Also, several comments noted that the initial scope of the Programmatic
Environmental Impact Statement did not include consideration of the long-term
storage of plutonium weapon components. These comments are addressed below.
Long-term plutonium pit storage was not a contemplated requirement at the time the
Department published the Nuclear Weapons Complex Reconfiguration Study
(DOE/DP-0083, January 1991). At that time, the Department's nuclear weapons
complex was required to support a nuclear weapons stockpile that was projected to
be very large. This being the case, it was expected that nuclear materials would be
recycled without the need for long-term storage capacity. Consequently, initial
planning for the Reconfiguration Programmatic Environmental Impact Statement did
not consider analysis of the environmental impacts associated with a long-term
plutonium storage facility. Neither the "Notice of Intent" (56 Federal Register 5590,
February 11, 1991) announcing the preparation of the Programmatic Environmental
Impact Statement nor the Implementation Plan, Nuclear Weapons Complex
Reconfiguration Programmatic Environmental Impact Statement (DOE/EIS-0161IP,
February 1992) dealt specifically with the need for such future long-term storage.
However, subsequent events dictated that the complex of the future (Complex 21)
must contain a facility for long-term storage of plutonium. In September 1991, former
President George Bush announced the first of three arms reduction initiatives that had
a significant effect on both present Pantex Plant operations and the planning for
Complex 21. The September 27, 1991 announcement, together with the initiative
announced in the January 28, 1992, State of the Union address and the June 16, 1992,
Bush/Yeltsin agreement (later codified in the Strategic Arms Reduction Treaty II)
resulted in large reductions in the nation's nuclear weapons stockpile. These
reductions resulted in the retirement of weapons in the stockpile in much larger
numbers and in a much more compressed timeframe than had been previously
contemplated. In addition, the Department was faced with a situation where
presently authorized capacity of storage facilities at the Pantex Plant would be
exhausted long before the announced weapons retirements were completed and
before the Programmatic Environmental Impact Statement could be completed and
reconfiguration decisions made with regard to long-term storage. Thus, to continue
the dismantlement of weapons resulting from the three recent arms reduction
initiatives, the additional interim storage capacity would be required regardless of any
decisions that are subsequently made concerning reconfiguration.
Since it has already been determined that Complex 21 must include an alternative for
long-term plutonium storage capacity, the environmental impacts of locating such a
facility at one of several alternative sites must be included in the Programmatic
Environmental Impact Statement. Conceptual design efforts have already begun for
long-term storage capacity. A Revised Notice of Intent that includes these changes
to the original reconfiguration proposal as well as other potential modifications to that
proposal was published in the Federal Register on July 23, 1993 (58 Federal Register
39528). The Department has held additional scoping hearings to assure opportunity
for input and comments, and the Department will revise the Programmatic
Environmental Impact Statement Implementation Plan to include any changes.
Following completion of the Final Programmatic Environmental Impact Statement, it is
expected that a Record of Decision can be issued by early 1995. The Pantex Plant is
one of the sites being considered for location of nuclear facilities in the reconfigured
complex, including long-term plutonium storage. The Record of Decision will be
followed by a Site-Specific Environmental Impact Statement which will examine the
environmental impacts of construction and operation of the facility at the location
selected. This environmental analysis will include, among other things, evaluations of
the impacts of transportation of plutonium from sites where it is now stored to potential
long-term storage locations, as well as the risks of long-term storage of pits and other
forms of plutonium. Affected States, Indian Tribes, and the general public will
continue to have opportunities to review and comment the planning for and analyses
contained in both the Programmatic Environmental Impact Statement and later Site-
Specific Environmental Impact Statement. The Secretary of Energy's decisions
regarding reconfiguration will be based on a combination of environmental impact,
cost, and analysis of alternatives.
Several comments questioned when the Department would complete moving
plutonium pits stored at the Pantex Plant as a result of the proposed action. Timing for
completion of the movement will depend on where the long-term storage function is
performed, the rate at which materials can be moved safely, and the priorities
established for moving various types of nuclear material.
Some comments questioned what would occur if a long-term storage facility is not
available at the end of the interim storage period. The Department will do all within
its control to expedite timely completion of the Programmatic Environmental Impact
Statement, Record of Decision, and site-specific National Environmental Policy Act
reviews. The nature of the National Environmental Policy Act process, as well as
possible changes in national policy or funding availability, prevents the Department
from guaranteeing against unexpected delays. The Department is committed to
working closely with the State of Texas and the public to resolve issues that arise
during the interim storage period and during the transfer of the plutonium
components to permanent storage.
A few comments expressed concern that if the interim storage period was incorrectly
estimated, the conclusions of the Environmental Assessment might also be incorrect.
Section 6.0 of the Environmental Assessment evaluates the potential environmental
effects of using certain Steel Arch Construction and Modified-Richmond magazines to
provide interim storage capability for plutonium weapons components. The
conclusions of the Environmental Assessment are not dependent on the length of the
interim storage period, but rather the environmental effects from routine storage, as
well as potential accidents.
Increases in worker radiation exposures due to on-site interim storage operational
activities were evaluated on an annual basis, and worker exposure is controlled since
personnel would be monitored to ensure administratively controlled annual limits on
exposure are met . The assessment found that routine storage will require no new
construction and will cause no off-site radiological emissions, no surface or ground
water effluent, and only minor air emissions in the form of vehicle emissions and
fugitive dust from vehicle movements. Container integrity during the interim storage
period will be ensured by a surveillance program that would detect any change in
the integrity of the container or packaging materials. Deterioration is expected to
occur very infrequently since, especially after the horizontal storage configuration is
implemented, container exposure to moisture that might cause corrosion will be
minimal. Pit stability during the interim storage period will be monitored by conducting
pit surveillance testing in conjunction with the surveillance program. Similarly, the
length of the storage period does not influence the conclusion of the Environmental
Assessment that no significant impacts would occur as a result of credible accident
sequences including explosions, forklift operational accidents, earthquakes, tornadoes,
and aircraft crashes. The analysis of these accidents was based on the annual
probability of occurrence of each accident in combination with other time-
independent factors. Accidents with sufficiently low annual probability are
categorized as to their likelihood to occur during the lifetime of a facility. The duration
of 6 to 10 years did not enter into this determination.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 2.0 was changed to reflect the comments.

Part B

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (B.1) FOLLOWS ON PAGE B-11
Document #: 1016 Comment #: 2 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
I have reviewed the Environmental Assessment For Interum (sic) Storage of Plutonium Components at Pantex
and found that its inadequacy to be typical of the "Pantex attitude". The plan does not adequately address the
health and safety of either the workers or the peoples living near the plant. The plan contains much false
information and lack of accurate information to conclude the storage of plutonium in any amount to be safe.
Document #: 1016 Comment #: 10 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Doe (sic) must do a full EIS.
Document #: 1016 Comment #: 25 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
We believe the United States Department of Energy must proceed to initiate an environmental impact statement
(EIS) on the issue of plutonium storage and management at Pantex and throughout the DOE and DOD
complexes. The questions raised because of the inadequacy and inaccracies (sic) of the draft must be answered
prior to the storage for even the six to ten years proposed. We must be certain, without a doubt, that the interim
storage of plutonium at Pantex is completely safe for the workers at the plant, the peoples living nearby and in the
area of the plant, and for the Ogallala Aquifer and perched water zones. The highly productive agricultural lands
and livestock must be safe also.
Document #: 1017 Comment #: 20 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
I would like to call for an Environmental Impact Statement.
Document #: 1019 Comment #: 1 Date: 1/20/93
W. H. O'Brien
Operation Commonsense
Comment:
This environmental assessment sets forth operations more properly designated as a new mission, from holding
plutonium in inventory for current use, to holding it in storage with no planned use. I believe this is a very
important distinction, and might well require additional disclosure and public comment.
Our concerns are solely with the impact of your plans on Amarillo and the surrounding area. It is obvious from
the assessment that this new mission has not been previously tested and that the storage plans set forth involve
varying degrees of risk and uncertainty.
Section B B-1
Document #: 1022 Comment #: 1 Date: 2/1 1/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
The Department of Energy should have prepared an Environmental Impact Statement (EIS) instead of the EA.
The proposed action constitutes a change in mission for the Pantex facility (i.e. interim storage) and, as such,
constitutes a major federal action which requires an EIS under the National Environmental Policy Act (NEPA)...
In conclusion, DOE should prepare an EIS to provide for a more thorough examination of all alternatives, more
extensive public participation, and sufficient time for citizens to prepare comments and the Department to review
nuclear safety at Pantex (DNFSB recommendation 93-1). Such a delay for EIS preparation need not prevent the
United States from continuing to withdraw nuclear weapons from active deployment as set forth in recent
agreements and initiatives. The delay would also provide time for public review of the dismantlement study now
underway by the Office of Technology Assessment.
Document #: 1026 Comment #: 1 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
As a responsible citizen committed to preserving the quality of life for all future generations I am gravely
concerned about the Environmental Assessment prepared by the United States Department of Energy regarding
the proposal to increase the storage of plutonium at the Pantex Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of informed citizens, it is my
opinion that this Environmental Assessment (EA) does not adequately address the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits for any period
of time is a significant new action that should be analyzed in its own right, and all reasonable alternatives and
environmental impacts should be considered now.
Document #: 1026 Comment #: 8 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
Rather than issuing a final environmental assessment and a Finding of No Significant Impact (FONSI), the
Department of Energy should proceed to initiating an environmental impact statement (EIS) on the issue of
plutonium management at Pantex.
Document #: 1030 Comment #: 2 Date: 3/2/93
Judy Osborne
Citizen Comments
Comment:
We request a full environmental impact statement (EIS) with the possibility of a large tornado be done on the issue
of plutonium storage at the Pantex plant.
Document #: 1031 Comment #: 6 Date: 3/1/93
Louise Daniel
Citizen Comments
Comment:
Therefore, I request that the Department of Energy prepare an environmental impact statement on the issue of
plutonium management in the United States and that full public hearings be held. This EIS should consider the
problem as a whole, not as an isolated operation at Pantex, and include the safety of workers, long term storage
methods and facilities, transportation, the eventual uses and/or disposal of plutonium and other chemical and
nuclear materials. There should be thorough long range planning and a carefully considered, integrated,
nationwide policy on this extremely critical issue.
Section B B-2
Document #: 1032 Comment #: 1 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
As a responsible citizen committed to preserving the quality of life for all future generations I am gravely
concerned about the Environmental Assessment prepared by the United States Department of Energy regarding
the proposal to increase the storage of plutonium at the Pantex Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of informed citizens, it is my
opinion that this Environmental Assessment (EA) does not adequately address the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits for any period
of time is a significant new action that should be analyzed in its own right, and all reasonable alternatives and
environmental impacts should be considered now.
Document #: 1032 Comment #: 8 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
Rather than issuing a final environmental assessment and a Finding of No Significant Impact (FONSI), the
Department of Energy should proceed to initiating an environmental impact statement (EIS) on the issue of
plutonium management at Pantex.
Document #: 1033 Comment #: 1 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
As a responsible citizen committed to preserving the quality of life for all future generations I am gravely
concerned about the Environmental Assessment prepared by the United States Department of Energy regarding
the proposal to increase the storage of plutonium at the Pantex Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of informed citizens, it is my
opinion that this Environmental Assessment (EA) does not adequately address the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits for any period
of time is a significant new action that should be analyzed in its own right, and all reasonable alternatives and
environmental impacts should be considered now.
Document #: 1033 Comment #: 8 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
Rather than issuing a final environmental assessment and a Finding of No Significant Impact (FONSI), the
Department of Energy should proceed to initiating an environmental impact statement (EIS) on the issue of
plutonium management at Pantex.
Document #: 1034 Comment #: 1 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
As a responsible citizen committed to preserving the quality of life for all future generations I am gravely
concerned about the Environmental Assessment prepared by the United States Department of Energy regarding
the proposal to increase the storage of plutonium at the Pantex Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of informed citizens, it is my
opinion that this Environmental Assessment (EA) does not adequately address the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits for any period
of time is a significant new action that should be analyzed in its own right, and all reasonable alternatives and
environmental impacts should be considered now.
Section B B-3
Document #: 1034 Comment #: 8 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
Rather than issuing a final environmental assessment and a Finding of No Significant Impact (FONSI), the
Department of Energy should proceed to initiating an environmental impact statement (EIS) on the issue of
plutonium management at Pantex.
Document #: 1035 Comment #: 1 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
As a responsible citizen committed to preserving the quality of life for all future generations I am gravely
concerned about the Environmental Assessment prepared by the United States Department of Energy regarding
the proposal to increase the storage of plutonium at the Pantex Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of informed citizens, it is my
opinion that this Environmental Assessment (EA) does not adequately address the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits for any period
of time is a significant new action that should be analyzed in its own right, and all reasonable alternatives and
environmental impacts should be considered now.
Document #: 1035 Comment #: 8 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
Rather than issuing a final environmental assessment and a Finding of No Significant Impact (FONSI), the
Department of Energy should proceed to initiating an environmental impact statement (EIS) on the issue of
plutonium management at Pantex.
Document #: 1037 Comment #: 1 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
I am gravely concerned about the Environmental Assessment prepared by the United States Department of
Energy regarding the proposal to increase the storage of plutonium at the Pantex Nuclear Weapons Plant near
Amarillo, Texas.
It is my opinion that this Environmental Assessment (EA) does not adequately address the full range of the
issue.
The proposal to store the pits for any period of time is a significant new action that should be analyzed in its
own right, and all reasonable alternatives and environmental impacts should be considered now.
Document #: 1037 Comment #: 8 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
Rather than issuing a final environmental assessment and a Finding of No Significant Impact (FONSI), the
Department of Energy should proceed to initiating and (sic) environmental impact statement (EIS) on the issue of
plutonium management at Pantex.
Section B B-4
Document #: 1038 Comment #: 1 Date: 2/26/93
Boyd M. Foster, President
Arrowhead Mills
Comment:
As a responsible citizen committed to preserving the quality of life for all future generations, I am gravely
concerned abou(sic) the Environmental Assessment prepared by the United States Department of Energy
regarding the proposal to Increase the storage of plutonium at the Pantex Nuclear Weapons Plant near Amarillo,
Texas.
Because I believe that the quality of a Democracy depends on the participation of informed citizens, it is my
opinion that this Environmental Assessment (EA) does not adequately address the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits for any period
of time is a significant new action that should be analyzed in its own right, and all reasonable alternatives and
environmental impacts should be considered now.
Document #: 1038 Comment #: 8 Date: 2/26/93
Boyd M. Foster, President
Arrowhead Mills
Comment:
Rather than issuing a final environmental assessment and a Finding of No Significant Impact (FONSI), the
Department of Energy should proceed to initiating an environmental impact statement (EIS) on the issue of
plutonium management at Pantex.
Document #: 1039 Comment #: 7 Date: 3/10/93
Tonya Kleuskens, Chairman
Texas Nuclear Waste Task Force
Comment:
We are deeply concerned at DOE's Finding of No Significant Impact (FONSI), considering the critical nature of this
proposal. Rather than issuing a final environmental assessment, the Department of Energy should proceed to
initiating an Environmental Impact Statement (EIS) on the Issue of plutonium management at Pantex.
Document #: 1040 Comment #: 1 Date: 3/9/93
Cart L. King, President
Texas Corn Growers Assn.
Comment:
As President of the Texas Corn Growers Association and Executive Director of the Texas Corn Producers
Board, I am writing about our concerns about the Environmental Assessment prepared by the United States
Department of Energy regarding the proposal to increase the storage of plutonium at the Pantex Nuclear
Weapons Plant near Amarillo, Texas.
We do not feel that the Environmental Assessment adequately addresses these issues that are created at this
site. I have been associated with the Department of Energy for several years now and I certainly do not trust their
analysis and statement on what is actually going on at this location. We feel that reasonable alternatives of
environmental impact should be considered now.
Section B B-5
Document #: 1041 Comment #: 8 Date: 3/12/93
Beverly Gattis
Military Production Network
Comment:
Dismantlement and NEPA. - In addition to our concerns about the predecisional EA itself we are troubled by
DOE's overall approach to NEPA compliance in regard to its dismantlement program. As described above, there
are discrepancies between the way the treatment of dismantlement is described in the R-PEIS Implementation
Plan and the predecisional EA.
DOE needs to clarify how dismantlement and related efforts will be addressed in the R-PEIS, as well as in the
Environmental Restoration and Waste Management PEIS. If DOE's goal is -- as the predecisional EA implies -- to
use the PEIS process as the mechanism for evaluating long-term storage and disposition of plutonium from retired
warheads, then an additional scoping period for the PEIS's may be necessary. Also, DOE should ensure that the
PEIS process allows a fair evaluation of whether to treat surplus plutonium as a waste or an asset, and full
consideration of all other long-term issues associated with dismantlement.
For the short-term, DOE appears to be pursuing NEPA compliance through separate reviews of related
activities. The predecisional EA on plutonium component storage at Pantex is an example of this. Related
activities include increased shipments of warheads to Pantex disposition of high explosives and other non-nuclear
materials from retired warheads, shipment to and expanded storage of highly-enriched uranium at Oak Ridge,
shipment to and storage of radioisotope thermoelectric generators at LANL, and expanded shipment to and
processing of tritium reservoirs at SRS.
All activities which support DOE's dismantlement program should be evaluated in a single NEPA document.
This approach would facilitate a consistent and thorough review of the many activities, public understanding of and
involvement in the decision making process, and full compliance with NEPA.
Dismantling as many as 20,000 warheads -- and transporting, storing, and disposing of the resulting materials
-- is a major Federal action significantly affecting the quality of the human environment within the meaning of NEPA.
Therefore, we believe an Environmental Impact Statement (EIS) is the appropriate level of NEPA review. Such an
EIS should be conducted with ample opportunity for public participation in the scoping process and review of a
draft EIS before a final decision is made. If DOE does not agree that an EIS is called for at this time, then we ask
that the Department immediately begin preparation of an EA on its dismantlement program and that that EA be
circulated for public comment in order that the Department's position be subject to public review and comment.
Document #: 1042 Comment #: 1 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
STAR calls for full public disclosure of all information necessary for sound decision making regarding the past,
present and future operations of the Pantex facility, and for substantive public participation in those decisions.
In summary we find major legal and substantive deficiencies in the Predecisional Environmental Assessment
(hereafter "draft EA"). The draft EA is insufficient and cannot be used as the basis for a Finding of No Significant
Impact (FONSI), which is clearly DOE's plan.
Section B B-6
Document #: 1042 Comment #: 2 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
We believe that DOE's proposal addresses only a small portion of the new but fundamental reality driving the
changes at Pantex. The unparalleled situation of dismantlement of up to 20,000 warheads, and the immediate
need to begin accommodating the work load and variety of materials which that generates, is the essential change
affecting Pantex and other nuclear weapons complex sites. This constitutes a major federal action significantly
affecting the quality of the human environment and requires issuance of an environmental impact statement (EIS).
Such an EIS should be issued in draft form for extended public comment. The draft should include all
reasonable alternatives to the proposed actions as well as realistic analysis of environmental effects, as required
by NEPA, before a final EIS is issued. DOE should complete that process, including issuing a Record of Decision
(ROD), before proceeding even with the action presented in the draft EA.
Major Comments:
1. We strongly object to DOE's misuse of the National Environmental Policy Act (NEPA). We believe that
DOE's proposal to dismantle 20,000 warheads, store plutonium pits at Pantex, and ship highly enriched uranium
(HEU) and tritium to other DOE facilities is a major federal action significantly affecting the quality of the human
environment that requires issuance of an environmental impact statement (EIS) which comprehensively discusses
the entire proposal and all reasonable alternatives.
Document #: 1042 Comment #: 3 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
A. DOE's proposed action is so narrowly defined that it constitutes illegal segmentation, contrary to the
requirements of NEPA [See, for example, Sierra Club v. Callaway, 499 F.2d 982(5th Cir. 1974), Taxpayers
Watchdog, Inc. v. Stanley, 819 F.2d 294 (D.C.Cir 1987)].
The draft EA says the proposed action is "to provide for the interim storage of up to 20,000 pits, pending the
implementation of the ROD on the Nuclear Weapons Complex Reconfiguration PEIS. This is expected to be
completed within a time frame of 6-10 years" (p. 3-1).
There are several problems with that description:
1) The total scope of the proposed action is not included. The 20,000 pits come from an unprecedented
dismantlement of warheads which inevitably will yield significantly increased quantities of many materials. This
unprecedented dismantlement has not been subjected to NEPA analysis. There has been no NEPA analysis of
what to do with any of the resulting materials -- not only plutonium pits, but also HEU, tritium, high explosives and
non-nuclear components.
2) Even within the limits of DOE's proposal as currently stated, the positive and negative aspects of plutonium
pit storage in one location or multiple locations should be discussed. Total existing storage capabilities at all
facilities should be described.
However, the fundamental assumption underlying the proposed action is to do all dismantlement and interim
storage at Pantex. Therefore, the dismantlement capabilities of other DOE facilities should be discussed in the
EIS.
Document #: 1042 Comment #: 27 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
2. ES-vii. The first sentence states that the primary mission of Pantex is assembly and disassembly of weapons.
Why is plutonium storage not considered to be a new mission, requiring an EIS?
Document #: 1043 Comment #: 6 Date: 3/12/93
Mavis Belisle, Director
the Peace Farm
Comment:
The Peace Farm believes that the State of Texas should not accept a Finding of No Significant Impact on the
basis of the EA, and should require a full Environmental Impact Statement that covers the entire range of
dismantling and interim storage activities at Pantex.
Section B B-7
Document #: 1045 Comment #: 1 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
STAND is committed to full public participation in the decisionmaking processes involving the Department of
Energy's (DOE) nuclear weapons complex (hereafter complex). It also believes that sound public policy can be
achieved only when that public participation is substantive and based on full access to all relevant information.
The only exceptions to full disclosure should be limited to information which poses legitimate national security
concerns, such as protection of weapons design data.
STAND finds there are major legal and substantive deficiencies in the draft EA. The draft EA is insufficient to
support a Finding of No Significant Impact because the information presented is inadequate. We believe the draft
EA fails, as well, in its approach to the basic issues and NEPA processes involved.
Most importantly, we find the scope of the draft EA to be so narrowly defined that it cannot responsibly address
the issues affecting Pantex. The proposed dismantlement of up to 20,000 warheads, and the immediate need for
the complex to accommodate both the work and variety of materials generated, is the fundamental situation
driving the changes involving Pantex and other sites.
Additionally, the proposed dismantlement is already underway. It is proceeding without the benefit of any
integrated evaluation of the demands of the work or facilities needed for the interim disposition of the variety and
quantities of materials inevitably produced.
The unprecedented dismantlement of up to 20,000 nuclear warheads, and its inevitable ramifications,
constitutes a major federal action significantly affecting the quality of the human environment and requires
issuance of an environmental impact statement (EIS).
Section B B-8
Document #: 1045 Comment #: 2 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
Major Comments
1) The scope of the draft EA must fully respond both to the nature of current dismantlement work affecting
Pantex and to interim disposition not only of plutonium pits but of all other materials which inevitably will result.
Significant circumstances which must be taken into account are:
a) Both the number of warheads to be dismantled and the pace scheduled for dismantlement is
unprecedented.
b) There is no current defense program need for the pits. Long-term future need is anticipated to be small,
conceivably even zero. What used to be a closed-loop cycle of plutonium reprocessing and re-use no longer
exists.
c) There is a breakdown of the historic pattern of materials flow within the complex. The facility which used to
receive and reprocess/recycle the plutonium pits from Pantex, the Rocky Flats Plant, is closed; no other such
facility currently exists in the complex.
In the past (as recently as 1991) Pantex officials stated uncategorically that pits were "staged," not stored, at
Pantex. Though citizens always assume staging is an extremely flexible proposition convenient to DOE, it is, even
by the definition in the draft EA, inherently different from storage.
"Staging is the temporary holding of materials (weapons or components) as they await the next step in their
process flow (i.e. disassembly or transport off-site). There is no set time limit for staging since movement of
materials (for transport, disassembly, etc.) is dependent on scheduling, upstream process flow stream conditions,
resource availability, etc. a (p. 1-1)
With no interim "upstream process flow" available, years of storage will be required. This is a fundamental
change in work and mission for Pantex.
e). Though the draft EA focuses on plutonium pits, the unprecedented dismantlement yields a variety of other
materials which must be temporarily staged or stored in areas able to provide proper security.
Existing storage space qualified to provide proper safeguards and security is limited. These materials require such
space not only at Pantex, but compete for the limited space available in other parts of the complex.
Pantex itself must accommodate at least: 1) special nuclear material (SNM) such as highly enriched uranium
(HEU), or other closely held material such as tritium, 2) warheads awaiting dismantlement, 3) other weapons
components, 4) mixed waste containing SNM or closely held material, 5) warheads needing
maintenance/evaluation.
The draft EA does not adequately discuss the space neeeded(sic) to accommodate these materials.
For the complex in general the draft EA states, "The complex has limited storage capacity, and each site's
capability to store material (pits and SNM in various other forms) must be maximized...." The draft EA continues
by referring to "many ongoing programs" to assess current storage, and explains that other residues, wastes and
material "vie for the existing or potential storage capacity...." (p. 4-4) The explanations are clearly intended to
create a sense of inevitability and necessity for acceptance of the draft EA's proposed action of intensified pit
storage at Pantex.
However, the explanation just as clearly establishes that there is an urgent need for integrated evaluation of the
demands on the complex. The effect of adding materials from dismantlement to already existing materials is
straining the storage facilities needed to house them.
Section B B-9
Document #: 1046 Comment #: 1 Date: 3/22/93
Dan Morales, Attorney General
State of Texas, Office of the Attorney General
Comment:
The Office of the Attorney General ("OAG") has reviewed the draft environmental assessment ("EA") for the
"interim" storage of plutonium components at the Pantex plant. We appreciate the opportunity to review the draft
EA and look forward to working with the Department of Energy ("DOE") to ensure that the operation of the Pantex
plant does not threaten the health and safety of its workers and neighbors and the natural resources of the
Panhandle area.
I strongly believe, however, that the draft EA is deficient and that until an environmental impact statement
("EIS") is completed, DOE will not be in compliance with the National Environmental Policy Act of 1969 ("NEPA").
The EIS process would ensure the full input of the public and ensure that DOE would take a "hard look" at the
environmental and socio-economic consequences of its proposed activities, consider viable alternatives to the
method currently chosen by DOE, and ensure that the adverse environmental and socio-economic consequences
of its action are minimized.
I have been deeply concerned about the activities at Pantex since I first came into office in 1991. [footnote 1
(For your convenience, I have enclosed copies of all of the correspondence I sent to your predecessor, Secretary
Watkins. See Attachment A.)] While I remain proud of the work done by the workers at Pantex, I also remain
profoundly concerned that generations of Texans will be forced to live with a decision regarding the storage of
thousands of pounds of plutonium made behind closed doors.
As you know, DOE has operated in the past pursuant to a policy of decide, announce, defend." I believe that
addressing this legacy is one of your greatest challenges. Your office, reflecting the new direction of a new
administration, has an historic opportunity to break with the past 12 years and to ensure that DOE does not
continue with an exclusionary vision of how it ought to accomplish its mission.
DOE's conclusions regarding environmental impacts in the draft EA reflect the extremely -- and
impermissible -- narrow crafting of the issue assessed by the draft EA rather than the reality of dismantling
thousands of nuclear warheads over the coming years and storing, it would appear, nearly 50 tons of plutonium at
a single site for an unknown period of time. Moreover, I believe that the conclusions constitute a post hoc
rationalization of a DOE decision to turn Pantex into the de facto storage facility for plutonium, rather than the
product of a "hard look" at the consequences of DOE's dismantling and storage activities it desires to undertake at
Pantex.
More specifically, the draft EA is deficient for the following reasons:
(1) DOE has failed to adequately consider viable alternatives to increasing the storage capacity at Pantex;
(2) DOE has improperly segmented the dismantling and storage activities undertaken and to be undertaken
at Pantex; and
(3) DOE has failed to adequately assess the risk of dismantling thousands of nuclear warheads and storing
the plutonium pits at Pantex.
Document #: 1048 Comment #: 1 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
After consideration of the DOE's predecisional EA we believe that our livelihood and our potential to produce
quality food for the world is in jeopardy. The modeling used in this document was intended to justity the storage
of plutonium pits at Pantex and has not taken into consideration the human environment or the $4 billion
agricultural economy which is the lifeblood of this area.
Section B B-10
Document #: 1048 Comment #: 16 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
According to NEPA, our basic national charter for protection of the environment, Procedures must insure that
environmental information is available to the citizens before decisions are made and before actions are taken."
Furthermore, it is stated that ultimately, it is not better documents but better decisions that count. "Federal
agencies shall encourage and facilitate public involvement in decisions which affect the quality of the human
environment. We date this as a preface to our comments, because there is a lack of sufficient, accurate
information provided to warrant the continuation of the present mission of the storage of plutonium at Pantex.
Furthermore, the public is not involved in the decision making - we are only given a short time to "comment
Under NEPA all information must be presented and all reasonable alternatives must be defined. Alternatives are
the heart of an EA, every alternative should be discussed.
The focus presented in the Predecisional EA is too narrow as only one option was discussed. The
presentation does not legally address all alternatives. The only discussion is -STORAGE- as opposed to looking at
the full picture, the entire scope of the plutonium issue or plutonium management, which is bigger than just storing
pits at Pantex.
Document #: 1048 Comment #: 27 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
It is the opinion of the membership of PANAL that this mission requires a site specific environmental impact
statement (EIS). It is our belief that an environmental assessment and FONSI is totally inadequate. Dismantling
20,000 warheads and storing plutonium pits at Pantex is a new purpose for Pantex (and a major federal action)
which significantly affects the quality of the human environment
There is plenty of time to study every issue and alternative. A Pantex EIS needs to address all the issues related
to Pantex, the alternatives, the capabilities of other facilities, plus any and all environmental effects not only on-site
and to workers, but also off-site and to the agricultural economy. An EIS needs to address the entire plutonium
management issue. We request a draft document for public participation, comment time and public hearings.
What we're going to do with plutonium pits needs to be ultimately done only after a comprehensive, credible
accounting is done by all affected parties, state and federal agencies and technical experts. When will the policy
be made for the future use of the pits.
Section B B-11
Response #: B.1
Comments on the scope of the Environmental Assessment stated that
the proposed action should include long-term storage of plutonium
components and/or dismantlement operations at Pantex Plant. The
decisions on long-term storage of plutonium components for the
Department of Energy are being addressed in the Nuclear Weapons
Complex Reconfiguration Programmatic Environmental Impact
Statement. In order to achieve initiatives for reduction of the
weapons stockpile, the Department determined that a decision on
additional interim storage is needed prior to completion of the
Programmatic Environmental Impact Statement. In order to
evaluate the potential significance of environmental impacts
regarding additional interim storage, the Department prepared the
Environmental Assessment in accordance with Department's National
Environmental Policy Act Implementing Procedures [10 Code of
Federal Regulations Part 1021].
As a practical matter, it is necessary to study the environmental
considerations of interim storage of plutonium pits resulting
from dismantlement operations at the Pantex Plant in the near
term. This must be done separately from the current activities
of the Programmatic Environmental Impact Statement. Although the
Department's ultimate decisions regarding interim storage has
features in common with decisions regarding long-term storage to
be made under the Reconfiguration Programmatic Environmental
Impact Statement and decisions regarding the operation of the
Pantex Plant to be made under the site-wide Environmental Impact
Statement (see below), the decision on interim storage is neither
a "connected action" to, nor a "cumulative action" with these
other decisions, within the meaning of the Council on
Environmental Quality regulations. Interim storage and long-term
storage are not connected actions, because interim storage has
independent utility from long-term storage. Therefore, it is a
severable action for purposes of the National Environmental
Policy Act.
Interim storage is needed to meet immediate weapons dismantlement
requirements, and needs to occur regardless of what additional
actions are taken to address long-term storage or permanent
disposition of plutonium. Furthermore, all options for long-term
storage or disposition would remain viable during interim storage
and would be available when the later decisions are made.
The Department has also determined that additional National
Environmental Policy Act analysis of dismantlement activities at
the Pantex Plant is not necessary at this time in order to decide
whether to increase the interim storage capacity for pits. This
function has historically been part of the Pantex Plant mission
and is addressed in the Final Environmental Impact Statement,
Pantex Plant Site (DOE/EIS-0098, October 1983). Weapon
dismantlement is conducted in much the same way it has always
been conducted, with ongoing improvements to safety and
environmental protection in accordance with regulatory
requirements. Dismantlement operations are presently within the
normal historic range of assembly and disassembly activity at
Pantex Plant and does not constitute a new project. The impacts
of assembly and disassembly are comparable to each other, and the
analysis of combined operations contained in the 1983 impact
statement adequately bound the impacts of the proposal action.
Past disassembly activity alone at Pantex Plant has nearly
reached the planned maximum annual future disassembly rates of
2,000 weapons. (Approximately 1757 weapons were disassembled in
1981, See Figure B.1-1.)
Comments stated that the interim storage of plutonium components
constitutes a change in mission for the Pantex Plant and,
therefore, an Environmental Impact Statement should be prepared.
The mission of the Pantex Plant has historically included staging
of sealed plutonium pits prior to assembly (into new weapons) and
shipping operations. Prior to 1989, the pits were staged after
removal from weapons and transported to the Rocky Flats Plant for
recovery and reprocessing. In December 1989, plutonium
processing and pit fabrication operations at the Rocky Flats
Plant were curtailed by the Department of Energy pending
resolution of safety and environmental issues. The Pantex Plant
continued to disassemble weapons, but shipments of pits to the
Rocky Flats Plant were suspended. The pits from those weapons
were staged in Zone 4 for later shipment to the Rocky Flats
Plant. The Department anticipated that shipments of pits to the
Rocky Flats Plant would be reinitiated when processing activities
in support of new weapons programs resumed. Efforts to restart
plutonium processing operations at the Rocky Flats Plant
continued until January 1992 when they were terminated by the
Department of Energy because of reduced requirements for new
nuclear weapons production in support of the national defense.
Consequently, pits from weapons disassembled at Pantex Plant are
now placed in interim storage in Zone 4.
The Department believes that this action is consistent with the
historical mission of the Pantex Plant, as it relates to the
temporary staging of plutonium components after disassembly of
retired weapons and prior to shipping to the Rocky Flats Plant
for processing. The proposed action analyzed in the
Environmental Assessment is the augmentation of the capability to
temporarily store plutonium components in response to the
cessation of plutonium operations at the Rocky Flats Plant.
Comments were made on the sufficiency of the Environmental
Assessment analysis of the impacts of interim storage. The
Environmental Assessment finds that the impacts of the proposed
action would be limited to radiation exposure of workers which
would be controlled to avoid adverse health effects. The
Environmental Assessment was provided to the State of Texas for
review and comment prior to the Department's approval in
accordance with the Department's National Environmental Policy
Act Implementing Procedures [10 Code of Federal
Regulations 1021.301(a)]. The Department has carefully
considered all of the comments on the Environmental Assessment
provided by the State of Texas, including comments by State and
local agencies and officials, interest groups, and the public.
The Department will meet with the State and public to discuss the
comments and the revisions to the Environmental Assessment in
response to State and public input. When the Environmental
Assessment is finalized, the Department will determine whether to
prepare a Finding of No Significant Impact or an Environmental
Impact Statement for the proposed action. The Department will
prepare a Finding of No Significant Impact only if the
Environmental Assessment supports a finding that the proposed
action will not have a significant impact on the human
environment.
Nevertheless, the Department is aware of concerns that have been
raised regarding the cumulative impacts of increased
dismantlement activities, and is committed to addressing these
concerns by preparing a new Pantex Site-Wide Environmental Impact
Statement. The Department has initiated assembly of
environmental baseline information in support of this effort.
This Environmental Impact Statement will examine aspects of
current and foreseeable operations at the Pantex Plant, including
dismantlement and storage-related issues. This Environmental
Impact Statement will include analyses of measures to further
mitigate the effect of Pantex activities. Although the scope of
the Environmental Impact Statement cannot be defined until the
public scoping process has been completed, the Department now
envisions considering alternatives to the continued storage of
pits at Pantex. The Department cannot predict how long this
review will take but best efforts will be made to complete the
Environmental Impact Statement on an expedited basis. The public
will be invited to help both scope the appropriate review and
comment on the draft Environmental Impact Statement when it is
available. When the Nuclear Weapons Complex Programmatic
Environmental Impact Statement Record of Decision is issued,
aspects specific to the Pantex Plant will be incorporated into
the new Site-Wide Environmental Impact Statement.
Some comments raised the issue of public participation. The
Department will continue to provide opportunities to involve the
public in decisions related to Pantex Plant operations and the
nuclear weapons complex as a whole. A public meeting regarding
the plans for interim storage at Pantex is planned, which will
involve state officials, the local community and other interested
parties. The scoping process for the Programmatic Environmental
Impact Statement included public hearings in Texas as well as
other locations. There have been additional opportunities for
public participation as a result of the revised Notice of Intent
being issued for the Programmatic Environmental Impact Statement
and further opportunities will be provided when the Draft
Programmatic Environmental Impact Statement is released for
public comment. After the Programmatic Environmental Impact
Statement Record of Decision is released, Site-Specific
Environmental Impact Statements will be prepared for affected
Nuclear Weapon Complex Sites. Public meetings and comment
periods throughout the preparation of Site-Specific Environmental
Impact Statements will assure opportunity for input and comments
from affected stakeholders. (Refer to Response A.1 for further
information regarding the Programmatic Environmental Impact
Statement process.)
Additionally, the interagency task force determining the
disposition of plutonium surplus to national defense requirements
will include public participation. The Department is committed
to include in an Environmental Impact Statement, major federal
actions it proposes to take in conjunction with the task force on
the disposition of surplus plutonium. This will help ensure
meaningful public involvement in the examination of alternative
means of disposition.
Figure (Page B-15 Figure B.1-1 - Total Level of Weapons Operations at ....)
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (B.2) FOLLOWS.
Document #: 1046 Comment #: 3 Date: 3/22/93
Dan Morales, Attorney General
State of Texas, Office of the Attorney General
Comment:
II. DOE has improperly segmented the dismantling and storage activities undertaken and to be undertaken at
Pantex.
DOE has improperly segmented the analysis of its proposed increased activities at Pantex. While the possible
environmental effects of increased interim storage are discussed, the draft EA completely ignores the
environmental consequences resulting from the increase in dismantling activities necessitating the increased
storage. The draft EA should include, inter alia, a comprehensive analysis of the increase in waste generated at
the plant as a result of the increased dismantlement activities.
For example, in past DOE budget requests and in the Pantex Plant's Environmental Restoration and Waste
Management Five Year Plan for Fiscal Year 1993, the Department refers to a high explosives incinerator (see
page 6-31 of FY 1993 Five Year Plan). Given that the need for this incinerator necessarily relates to the increased
dismantlement activities at Pantex, it would appear that the potential environmental impacts from the incinerator
should have been discussed in the EA.
We also note that in the DOE budget request for FY 1993 that DOE requested funds for a "Hazardous Waste
Treatment and Processing Facility." [footnote (See Attachment B.)] According to DOE's description provided to
OMB:
This facility will permit the treatment and declassification of low-level radioactive waste (depleted uranium,
tritium and thorium), hazardous waste, solvents, mixed waste, and classified metal components generated at
Pantex Plant.
Again, it would appear that the potential environmental impacts from the waste treatment facility, in the event
DOE pursues construction of the facility, should have been discussed in the EA.
Furthermore, the cumulative environmental effects associated with the increase in movement of warheads into
Pantex, the generation of waste products, and the movement and storage of plutonium pits should have been
more adequately analyzed.
Response #: B.2
Additional National Environmental Policy Act analysis of dismantlement activities is not
required because dismantling weapons has historically been a part of the Pantex
Plant mission and has been addressed in the Final Environmental Impact Statement,
Pantex Plant Site (DOE/ EIS-0098, October 1983). (Further discussion on this point is
provided in Response B.1.) Dismantlement rates historically at Pantex have nearly
reached the 2000 per year anticipated dissemble projection. Since projected
dismantlement rates are within the level of past activity (i.e., combined assembly and
disassembly) at Pantex, the waste associated with these rates should be bounded.
Discussion of the Hazardous Waste Treatment and Processing Facility is outside the
scope of this Environmental Assessment, and considerations and decisions regarding
this facility are independent of the proposed action. The proposal for this facility was
based solely on the need to consolidate waste management functions at the site.
The need for the facility was not prompted in anticipation of increased dismantlement
activities, but rather in an effort to provide a more efficient and safer facility with
which to better comply with current and future federal and state waste management
regulatory requirements. Consideration of alternate waste treatment technologies
(both on-site and off-site) is a logical extension of the Department's commitment to
use the best available technology for treatment of plant wastes.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (B.3) FOLLOWS.
Document #: 1041 Comment #: 7 Date: 3/12/93
Beverly Gattis
Military Production Network
Comment:
DOE should address each of the above stated concerns in the final EA and supporting documents. We also
request that if DOE decides to issue a Finding of No Significant Impact (FONSI) for this EA. a public comment
period of no less than 45 days should be held, and comments received should be meaningfully considered before a
final decision is reached. Also, the EA and all documents referenced by it should be made publicly available at the
time the FONSI is published for public comment.
Response #: B.3
The Department has carefully considered all of the comments on the Environmental
Assessment provided by the State of Texas, including comments by State and local
agencies and officials, interest groups, and the public. The Environmental Assessment
was revised to incorporate this State and public input. All documentation cited in the
Environmental Assessment (except classified reports) have been made available to
the public (in Department of Energy reading rooms located in Amarillo and
Panhandle, Texas) and to State of Texas officials.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (B.4) FOLLOWS.
Document #: 1041 Comment #: 1 Date: 3/12/93
Beverly Gattis
Military Production Network
Comment:
We have several concerns about issues raised in the above referenced EA, as well as additional concerns
about other aspects of the Department of Energy's (DOE) dismantlement program. We very much appreciate
your sending us a copy of the EA and your willingness to forward our comments to DOE. However, we hope that
in the future DOE will make its preliminary EA's available to the public at the same time they are made available to
state governments.
The Military Production Network (MPN) is a national alliance of organizations working to address issues of
nuclear weapons production and waste cleanup. The MPN has been very active in DOE's two, ongoing
Programmatic Environmental Impact Statements (PEIS) and many other DOE decision making processes. We are
committed to full public participation in decisions regarding nuclear warhead dismantlement and to independent
regulation and verification of the dismantlement process.
Response #: B.4
The Environmental Assessment was provided to the State of Texas in accordance with
the Department of Energy National Environmental Policy Act Implementing
Procedures, which require the Department to provide an Environmental Assessment to
the host state and host tribe [10 Code of Federal Regulations 1021.301(a)].
Additionally, meetings will be held with the State and the public in order to broaden
public involvement on this Environmental Assessment. The Department is also
assessing other mechanisms to expand public participation opportunities on future
Department of Energy activities.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (B.5) FOLLOWS
Document #: 1042 Comment #: 13 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Issues that must be specifically discussed include: ...
f. High consequence, low probability accidents -- airplane crash, criticality accident, and major release during
disassembly; and
g. On-site storage versus transportation risks and costs for plutonium, highly enriched uranium, and tritium.
Response #: B.5
The Environmental Assessment does address high consequence, low probability
accidents for the interim storage proposal. The potential for accidents during
disassembly is not addressed because disassembly is not within the scope of the
proposed action stated in the Environmental Assessment. The potential for accidents
has been addressed in the Final Environmental Impact Statement, Pantex Plant Site
(DOE/EIS-0098, October 1983).
Activities dealing with highly enriched uranium and tritium are not in the scope of this
Environmental Assessment since they are processes normal to disassembly and within
historic production/disassembly activities (including transportation risks and costs).
Transportation issues and cost for plutonium interim storage (on-site versus off-site
interim storage) are discussed in relative terms in Section 4.0 of the Environmental
Assessment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (B.6) FOLLOWS.
Document #: 1042 Comment #: 26 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
1. List of preparers. Council on Environmental Quality (CEQ) regulations (40 CFR 1502.17) require listing of
preparers of an EIS. The final EA should have such a listing even though it is not required by regulation.
Response #: B.6
A list of individuals contributing to the formulation of the Environmental Assessment
follows:
DEPARTMENT OF ENERGY
Headquarters
Victor Stello
Daniel Rhoades
Michael Mitchell
David Chaney
Thaddeus Dobry
Tracey Leslie
Sandra Ch-vez (Sandia National Laboratories - Albuquerque)
Tom Goodwin
Sam Collins
Roy Hedtke
Steve Sohinki
Donna Kostka
Greg Rudy
Henry Garson
Tim Pflaum
Nancy Ranik (Argonne National Laboratory)
Diane Meir (Contractor)
Mike Volpe (Contractor)
Adam Lipinski (Contractor)
Angela Watmore (Contractor)
Albuquerque Operations Office
Steve Guidice
David Rosson
Connie Soden
Wendy Baca
Cliff Jarmin (Contractor)
Amarillo Area Office
Gerald Johnson
David Heim
Anthony Ladino
Vicki Battley
Dean Triebel
MASON & HANGER / BATTELLE - PANTEX
Steve Young
Barbara Nava
Brett Simpkins
Phillip Stewart
Jeff Petraglia
Jerry Martin
Iral Nelson (Pacific Northwest Laboratories)
LOS ALAMOS NATIONAL LABORATORY
Jake Turin
B. Thomas
S. Triay
W. Hansen
W. Wenzel
OGDEN ENVIRONMENTAL AND ENERGY SERVICES / JACOBS ENGINEERING
David Erickson
David Smith
Ray Bennett
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (B.7) FOLLOWS.
Document #: 1009 Comment #: 3 Date: 2/22/93
Tom Millwee, Chief
Texas Dept. of Public Safety, Div. of Emergency Management,
Comment:
The probability of an aircraft crashing into an igloo in zone 4 may be an incredible event. However, with respect to
the increased dismantlement program, the synergistic impact of every aspect of the dismantlement program must
be considered. The potential risk from the increased number of units, their movement, the transportation of these
units, the increased disassembly and storage, must be assessed. The overall impact may result in a finding of a
credible event.
Response #: B.7
This Environmental Assessment addresses the proposed additional interim storage of
plutonium pits at the Pantex Plant with the aircraft crash scenario representing the
range of reasonably foreseeable accidents. The effects of accidents outside of Zone
4 have been addressed in the Final Environmental Impact Statement, Pantex Plant
Site (DOE/EIS-0098, October 1983). (Refer to Response B.1 for more information on the
scope of the Environmental Assessment.)

Part C

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.1) FOLLOWS ON PAGE C-6.
Document #: 1007 Comment #: 6 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 4-3. Lines 27-33: Beginning with "The nuclear weapons complex mission...", the discussion shows that
serious consideration was not given to this option. It would seem that storage of pits, as described in this
document, should not aggravate or complicate the massive environmental restoration and remediation efforts
required at Hanford. The storage of parts removed from weapons (presumably not ready for insertion into new
weapons without some preparation) does not clearly appear to be a defense only mission.
Document #: 1007 Comment #: 8 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 4-5, Paragraph 4.4: This report does not indicate that DOD facilities were seriously studied, only that they
were "considered" and determined to be "not currently available". It is difficult to visualize what may be different
between Pantex SAC and Modified-Richmond facilities and DOD facilities designed to protect and store weapon
assemblies. The DOD facilities certainly would provide the physical storage space and the security forces should
be comparable to Pantex capabilities. Transportation of components would seem to be less hazardous than
assembled weapon delivery, and represents no significant change from previous Rocky Flats components
shipments. Table 4-1, Section 4.4 affirms that apparently very little consideration was given to this issue, bsy (sic)
the total absence of information. If there is any information available, it should be provided here for scrutiny.
Document #: 1015 Comment #: 5 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Page 4-3: Hanford, with modifications, could store approximately 10,000 pits. Some knowledgeable persons have
suggested that Hanford may become a "national sacrifice zone". Would not Hanford then be a more appropriate
storage site? If suitable for no other purpose, why not put the pits there?
Document #: 1015 Comment #: 7 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Page 4-6: Table 4-1 does not mention Kirtland AFB/Monzano (sic) Mtn. as a possible storage site despite their
storage capabilities. Why was the above complex not considered?
Document #: 1016 Comment #: 17 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Section 4.4 c states "decentralization of storage could effect a net increase in the expected radiological worker
exposure/over (sic) the proposed action... Ah ha, there is danger to the workers and to the public after all. The
entire EA tells us there is no danger of excess exposure at Pantex, but here we learn the same Pu in smaller
amounts at other sites creates a danger. Which is it? DOE must do a full EIS to know.
Document #: 1022 Comment #: 6 Date: 2/11/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
Moreover, DOE has failed to consider the alternative of the construction of a new DOE facility, or several of
them.
Section C C-1
Document #: 1026 Comment #: 3 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
All of the reasonable alternatives were not considered end inadequate attention was given to existing available
DOE or DOD facilities. As taxpayers we have spent millions of dollars providing warhead and pit storage facilities
at Kirtland Air Force Base (Albuquerque NM., and the Sierra Army Depot in California (sic).
Document #: 1027 Comment #: 3 Date: 3/5/93
Portia Dees
Citizen Comments
Comment:
Are there available sights (sic) for storage of nuclear materials farther from populated areas?
Document #: 1031 Comment #: 2 Date: 3/1/93
Louise Daniel
Citizen Comments
Comment:
Alternative storage facilities such as those at Kirkland (sic) Air Force Base and Sierra Army Depot are not
mentioned in the Environmental Assessment. These facilities are already constructed and should receive public
consideration.
Document #: 1032 Comment #: 3 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
All of the reasonable alternatives were not considered and inadequate attention was given to existing available
DOE or DOD facilities. As taxpayers we have spent millions of dollars providing warhead and pit storage facilities
at Kirtland Air Force Base (Albuquerque, NM., and the Sierra Army Depot in California (sic).
Document #: 1033 Comment #: 3 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
All of the reasonable alternatives were not considered and inadequate attention was given to existing available
DOE or DOD facilities. As taxpayers we have spent millions of dollars providing warhead and pit storage facilities
at Kirtland Air Force Base (Albuquerque, NM., and the Sierra Army Depot in California (sic).
Document #: 1034 Comment #: 3 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
All of the reasonable alternatives were not considered and inadequate attention was given to existing available
DOE or DOD facilities. As taxpayers we have spent millions of dollars providing warhead and pit storage facilities
at Kirtland Air Force Base (Albuquerque, NM., and the Sierra Army Depot in California (sic).
Document #: 1035 Comment #: 3 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
All of the reasonable alternatives were not considered and inadequate attention was given to existing available
DOE or DOD facilities. As taxpayers we have spent millions of dollars providing warhead and pit storage facilities
at Kirtland Air Force Base (Albuquerque. NM., and the Sierra Army Depot in California (sic).
Section C C-2
Document #: 1037 Comment #: 3 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
All of the reasonable alternatives were not considered and inadequate attention was given to existing available
DOE or DOD facilities.
Document #: 1038 Comment #: 3 Date: 2/26/93
Boyd M. Foster, President
Arrowhead Mills
Comment:
All of the reasonable alternatives were not considered and inadequate attention was given to existing available
DOE or DOD facilities. As taxpayers we have spent millions of dollars providing warhead and pit storage facilities
at Kirtland Air Force Base (Albuquerque, NM, and the Sierra Army Depot in California.)
Document #: 1039 Comment #: 3 Date: 3/10/93
Tonya Kleuskens, Chairman
Texas Nuclear Waste Task Force
Comment:
The existing EA does not examine reasonable storage alternatives and we do not believe this issue was given
sufficient priority. The potential sites mentioned in the EA are now serving other DOD or DOE missions. Also,
they have a limited storage capacity, which would probably not be adequate for the the(sic) considerable quantities
of plutonium to be stored at Pantex.
Document #: 1041 Comment #: 5 Date: 3/12/93
Beverly Gattis
Military Production Network
Comment:
3) The predecisional EA does not adequately explain why Department of Defense (DOD) sites cannot store
some or all the plutonium components from retireded warheads.
The premise in the EA is simply that no DOD facility is "currently available" to DOE for use as an interim
storage facility. Consequently, the EA implies that there would be unspecified delays and that needed
modifications "would inevitably entail some degree of environmental impacts." (p. 4-5) However, there is no
evidence presented for any of these conclusions.
The final EA should indicate which DOD facilities have been considered as possible storage sites and provide a
credible rationale for whether they could meet the identified need. Also, the final EA should address the ability of
DOD sites to store disabled warheads if delays arise in disassembly operations at Pantex.
Document #: 1042 Comment #: 5 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
B.) The draft EA does not discuss all reasonable alternatives, as required by NEPA and the CEQ regulations (40
CFR 1502.14(a)).
The discussion of alternatives is the heart of any NEPA document, yet the draft EA does not adequately
analyze the alternatives that it mentions.
Alternative 4.2, combining storage at Pantex and other DOE facilities, is rejected 1) without an adequate
discussion of any other facilities at those sites could not be converted to pit storage (just as facilities at Pantex
have to be converted) and 2) without adequately describing those "numerous changes" underway at other
facilities. Moreover, a more detailed discussion of why other DOE facilities can not store any pits is necessary.
Alternative 4.3 supplementing Pantex storage with other facilities, is not wholly discussed. While supplemental
storage at LANL and Hanford is mentioned, the discussion of storage is limited to SRS. As with Alternative 4.2, a
much more detailed discussion of the storage capability of all DOE facilities is required.
Section C C-3
Document #: 1042 Comment #: 6 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Alternative 4.4, using Department of Defense (DOD) facilities, is wholly inaccurate. The federal government has
spent millions of dollars developing pit storage capabilities at Kirtland Air Force Base near Albuquerque, New
Mexico. However there is no specific mention of that facility in the draft EA. Other DOD facilities have significant
warhead storage capability. A detailed discussion of why none of those facilities could be used for interim storage
is necessary. What will happen with those facilities when they are not used to store warheads?
Document #: 1042 Comment #: 43 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
10. Page 4-1. The draft EA states: "For the other alternatives, in each case there were additional costs,
transportation requirements, and facility modifications or infrastructure requirements. No evidence is provided to
support such a statement. At a minimum, the EA must detail the costs of the preferred alternative and of each
proposed alternative, describe the transportation requirements and why procedures used in the past are not
adequate, and describe the types and costs of facility modifications.
Document #: 1042 Comment #: 45 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
12. Page 4-4. In c), the claim is made that decentralized storage "could effect a net increase in expected
radiological worker exposure," but no basis is given for the statement. Specific calculations should be presented
and the discussion should differentiate between cumulative exposures to a lesser number of workers versus lower
exposures to a larger number of workers.
Document #: 1042 Comment #: 46 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
13. Page 4-5. The statement that "no DOD facility is currently available" for pit storage appears to be false,
since news reports indicate that pit storage is immediately available at Kirtland Air Force Base, near Albuquerque,
New Mexico. In any case, the capabilities of the Kirtland facility must be discussed in detail in the EA.
There is no basis provided for the statement that "the storage of pits at DOD facilities would offer no
environmental advantage over the proposed action." To support that statement additional analysis and answers to
questions include: do each of the potential DOD facilities have a greater or lesser likelihood of a catastrophic
airplane crash than Pantex? Do any of the other facilities sit on an aquifer similarly important as the Ogallala?
Would the potential storage facilities at other locations allow for inspections that would require less movement of
pits and/or quicker inspections so as to reduce worker exposure?
Document #: 1043 Comment #: 2 Date: 3/12/93
Mavis Belisle, Director
the Peace Farm
Comment:
Additionally, the EA proposal for interim storage of all plutonium pits at Pantex has rather summarily dismissed a
number of other possibilities, which should be fully explored in the document. These include a dispersed storage,
using several Department of Energy sites, utilization of Department of Defense sites, particularly Kirtland AFB.
Section C C-4
Document #: 1044 Comment #: 5 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
As taxpayers we commend the DOE's decision to plan carefully and use suitable places for pit storage which will
eliminate problems down through the years ahead. We have financed many facilities for the armes (sic) race.
Some of the facilities are: the warhead and pit storage at Kirtland Air Force Base (Albuquerque, New Mexico), the
Sierra Army Depot in California, the new unused plant for plutonium reprocessing called the New Special
Production Facility at the Savannah River Plant, and a new unused plant built in Rocky Flats in 1983. Arms
experts believe plutonium pits would be relatively safer at the Department of Defense's military bases where
security is better and the storages (sic) suitable and safe. When Pantex finishes its disassembly work, I
respectfully ask you to move the pit storage to a safer site where it will be guarded well and may be be used in the
pit reuse experiments, hopefully there will be a good purpose for nuclear components, such as the nuclear hospital
equipment we now have.
Document #: 1045 Comment #: 4 Date: 2/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
3) The draft EA does not establish a clear sense of DOE's prioritization of the different environmental (as defined
by NEPA) impacts.
Worker exposure is acknowledged to be the principal impact (vii). However, discussion of alternatives in the
draft EA never clarifies whether or not any of the alternatives might offer more workers protection than another. It
is as if no matter where the storage location is, the rates of exposure will be the same -- though this is never
substantiated in the text.
Given that approach, one of the justifications for not accepting alternative 4.4, "Interim Storage at a DOE
facility," is that, if any modifications were necessary, "these modifications would inevitably entail some degree of
environmental impacts of the type generally associated with construction activities." (p.4-5)
The draft EA should establish a general ranking of priorities so that decision-making can distinguish among
important differences. Lessening worker exposure could indeed justify other concessions or expenses.
Document #: 1045 Comment #: 6 Date: 2/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
5) The draft EA does not present all reasonable alternatives.
As one obvious example: there is no "Supplement No-Action Alternative Storage with Storage at other DOD
Sites."
Given both the need for dismantlement to proceed in a timely but safe way, as well as an equally valid and
urgent need that any decision protect worker safety and public health to the maximum extent, all reasonable
alternatives must be available and evaluated to provide flexibility in decision making.
Document #: 1046 Comment #: 2 Date: 2/22/93
Dan Morales, Attorney General
State of Texas, Office of the Attorney General
Comment:
I. DOE has failed to adequately consider viable alternatives to increasing the storage capacity at Pantex.
DOE's analysis of alternatives to the proposed action of expanded interim storage is extremely superficial at
best. This failure to seriously analyze the alternatives indicates that DOE has already determined to go forward
with increased interim storage at the Pantex plant and that the draft EA was produced simply to pay lip service to
the requirements of the National Environmental Policy Act.
Section C C-5
Document #: 1048 Comment #: 8 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
(2-1, 4-1, 4-3) "... DOE maybe required to cease the disassembly activities..." what is the rush? Under the treaties
signed we're not obligated to dismantle immediately, there was no time limit specified. Why not ship warheads or
pits to other sites - Pantex is not the only site available for dismantlement or storage, why were other DOE and
DOD sites not adequately addressed? To state that no DOD facility is "currently available" must be proved. Not
addressing the DOD facilities in full a false conjecture.
Document #: 1048 Comment #: 9 Date: 2/26/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
To come to the conclusion that "there is no environmental benefit to be gained in packaging and shipping some or
all of the pits to any other nation for interim storage purposes" (vii) has no credible basis from the information
presented in the EA.
Response #: C.1
Several comments alleged as inadequate the Department's discussion of
alternatives for interim storage at the Pantex Plant. Several points
were consistently made and are as follows:
1. All possible alternatives were not discussed or were not
discussed in sufficient detail.
The National Environmental Policy Act requires that alternatives
to a proposed action be developed for discussion in an
Environmental Assessment. The Environmental Assessment identifies
alternatives that are potentially available and considered to be
reasonable. Sites mentioned in the comments that are not
specifically discussed in the Environmental Assessment are either
in use now or slated for future uses other than pit storage. The
range of facilities capable of taking on pit interim storage
automatically includes sites that will have other missions,
storage capabilities, and their own competing requirements for
storage. There are no facilities, either within the Department of
Energy or the Department of Defense whose mission is limited to
storage of special nuclear material.
While the Department could have listed new construction of an
interim storage facility as an alternative, it was considered
unlikely to offer an environmental advantage since land
disturbance would be unavoidable. Additionally, new construction
could not support the preferred schedule for expanding pit storage
capacity and would require additional resources.
The discussion of alternatives in the Environmental Assessment
explains that a combination of factors led to the conclusion that
none of the other sites considered (those of the Department of
Energy and the Department of Defense) are reasonable in that none
meet the criteria for the proposed action. The sites considered
do not meet programmatic needs for interim storage because of the
following factors: 1) increased cost (for facility modification,
to augment or reactivate enhanced security, for increased
transportation requirements, etc.), 2) untimely implementation of
alternative interim storage (time to modify facilities, perform
required safety analyses, develop site-specific procedures, train
personnel, etc.), and 3) no apparent environmental benefit to interim
storage at an alternate site. Under the proposed action, there are no increased
transportation requirements, only minor facility enhancements are required, and
activities required for implementation are essentially in place.
2. No basis was presented in the Environmental Assessment to support the Department's
conclusion that no environmental advantage would be gained by moving and storing
the pits at an alternative site on an interim basis.
The Environmental Assessment analyzes whether environmental benefit could be
derived by storing pits off-site (either at up to four separate Department of Energy
facilities or at a Department of Defense facility). The Environmental Assessment
analysis indicates that radiation exposure of workers is the principal impact of the
proposed action and there is no significant impact to the environment. While impact to
the environment would be no different, worker exposure could be increased in the
implementation of off-site or decentralized interim storage. Decentralization of interim
pit storage (at more than one site) would generate duplication of security, handling,
and inventory requirements. Efficiency in handling, monitoring, and inspecting the
plutonium components is achieved by conducting interim storage operations at a
single site rather than at multiple sites and could result in lower cumulative radiation
exposure to workers. Also, additional personnel exposure would be expected due to
the additional moving, repackaging, and transporting operations required to ship the
pits to sites other than Pantex Plant. This is demonstrated in the process flow diagram
(Figure C.1-1) that compares the relative number of handling steps that would be
required by the proposed action and storage at another site. Eliminating
transportation to alternate sites eliminates some of these processes as well as the total
work load and costs involved in pit storage management and is consistent with the
Department's goal of reducing worker exposure to "as low as reasonably achievable"
levels. Exposures expected from implementing alternatives are not unacceptable from
the standpoint of worker safety, instead, worker exposures are expected to be higher
relative to the proposed action. This conclusion does not imply that occupational
exposure standards for workers would be exceeded for any alternative.
3. The Department does not discuss specific Department of Defense facilities (as cited in
the comments) and, therefore, appears not to have considered them.
The Department has been working since May 1992 with the Department of Defense
concerning potential use of Department of Defense sites for interim pit storage. The
Environmental Assessment has been expanded to reflect the most recent results from
this interaction. As a matter of Department of Defense policy, the presence of nuclear
weapons at specific sites cannot be confirmed or denied for security reasons.
Therefore, discussion of specific Department of Defense sites are not presented.
However, the Environmental Assessment does include information on the storage of
pits at different types of Department of Defense sites. Based on this information, the
Department has concluded that Department of Defense sites are not feasible
alternatives to the proposed action for the following reasons:
. The Department of Defense is restructuring its forces to reflect troop reductions
and base closures. As part of this effort, some Department of Defense bases
are being configured to accommodate only conventional forces and their
weapons. The remaining active weapon storage facilities are committed to
storing both nuclear and conventional weapons, which are being moved from
overseas bases and from facilities designated for closure. This restructuring
process could take several years. The requirement for additional continental
U.S. storage capacity is further strained by the backlog of retired weapons.
. All Department of Defense excess sites are placed on the Base Realignment
and Closure List. To store special nuclear material and establish the necessary
repository infrastructure (e.g., security, environmental study, training, and
negotiation of site-sharing agreements) at an inactive Department of Defense
site would require significant new funding and implementation time.
. No environmental benefit is apparent in the use of Department of Defense sites
for the interim storage of plutonium components.
Section 4.2 of the Environmental Assessment provides more explicit details regarding
impacts, timing and costs associated with implementation of a Department of Defense
site for interim storage of pits. Section 4.1 discusses the impact that a decision not to
expand the interim storage of pits at Pantex (i.e., the No-Action Alternative) would have
on Department of Defense plans for base realignment and closure.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 4.0 was changed to reflect the comments.
Figure (Page C-9 FigureC.1-1-Comparison of Steps Required For Interim...)
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.2) FOLLOWS.
Document #: 1045 Comment #: 5 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
4) The draft EA does not completely discuss all the alternatives it presents.
As a most obvious example, in the discussion of Los Alamos National Laboratory (LANL) it lists existing pit
storage at TA-41 and TA-55. TA-41 is eliminated because "it does not meet current DOE requirements for ES&H,
security, and conduct of operations, and programmatic requirements do not justify the costs required to make
needed changes." (p. 4-3) Some of the problems with this discussion are:
a) TA-55 is never mentioned again, and remains unevaluated.
b) The extent of modifications needed for TA-41 is not explained.
c) The rationale based on "programmatic requirements do not justify the costs..." is insufficient. Programmatic
requirements are only for dismantlement "in an environmentally responsible way that is also timely, cost effective,
and uses to the maximum extent practicable, existing facilities and infrastructure." (p. 2-1) Depending on what
modifications TA-41 needs, it could be that ES&H benefits might justify the changes when programmatic objectives
might not.
Response #: C.2
The comment addresses issues raised in the discussion of Los Alamos National Laboratory as
an alternate interim storage site.
a) The Department acknowledges that clarification is needed with respect to this
comment. A change was made to the Environmental Assessment to clarify this issue.
TA-55 is at approximately 90 percent capacity and overcommitted for the stated pit
storage needs at Los Alamos National Laboratory. The total storage capacity is
approximately 60 pits.
b) TA-41 and the major ancillary activities associated with this site are shut down and
security would have to be reactivated. The TA-41 storage facility is an enclosed,
unventilated vault, and major renovation would be required for installation of a
ventilation system.
c) Section 2 states that an interim solution (that is, increased interim storage capacity)
must meet the programmatic objectives of dismantlement that is also environmentally
responsible, timely, cost-effective, etc. The statement made in Section 4.2 "...and
programmatic requirements do not justify the costs required to make needed
changes." was clarified in the Environmental Assessment to read "... Los Alamos
National Laboratory's programmatic requirements did not justify the costs required to
make needed changes to maintain TA-41." The modifications (as described in b)),
would result in a total (in both TA-55 and TA-41) storage capacity of only 240 pits. The
Department cannot justify the expenditure of construction funds and resources in light
of the extremely limited increased capacity (180 pits).
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 4.0 was changed to reflect the comments.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.3) FOLLOWS.
Document #: 1007 Comment #: 5 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 4-3, Lines 3-6: This passage seems to indicate that construction has been halted at the Nuclear Materials
Storage Facility due to lack of funding from DOE, and that if construction was resumed, it would take four to five
years to complete.
Response #: C.3
The statement made by the comment author regarding the passage in page 4-3, lines 3-6, is
correct.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.4) FOLLOWS.
Document #: 1021 Comment #: 11 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
DOE could use other sites as well as Pantex but this would add the hazard of transportation. I find this interesting
since they have said this hazard is virtually zero for years. The advantage of storing at multiple sites and doing it
visibly, however, would be that numerous communities would then become involved in this dreadful problem. Do
you have nightmares thinking of having to trust the Government with the storage of Pu for a half-life of 26,000
years? This risk of trusting our Government is clarified by a marvelous euphemism on page 4.3, "The primary
mission of Hanford is environmental restoration."
Document #: 1048 Comment #: 10 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
(4-5,4,4) Why is transportation of pits so much more dangerous than entire warhead or component parts? Is
shipping and handling dangerous just for some materials? How dangerous is this stuff - DOE was shipping it
before to RF, what is the difference now? If there is danger in transportation, why were these problems not
addressed sufficiently? What about the transportation in to Pantex at the present time? Is this not dangerous
also?
Response #: C.4
The discussion in Section 4.0 of the draft Environmental Assessment does not imply that the
added risk of off-site transportation is a limiting factor in consideration of alternative interim
storage sites. From experience and separate analysis of transportation risks discussed in the
Final Environmental Impact Statement, Pantex Plant Site (DOE/EIS-0098, October 1983) and
further analyzed in a preliminary Defense Programs transportation study, the Department
concludes that the potential risk is acceptable. However, off-site transportation to an alternate
interim storage site would introduce a small but finite additional risk that was identified to
determine the relative effects of the various alternatives to storing pits only at the Pantex Plant.
The issue of transportation of weapons into the Pantex Plant is outside the scope of the
proposed action and has been previously addressed in the Final Environmental Impact
Statement, Pantex Plant Site (DOE/EIS-0098, October 1983).
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.5) FOLLOWS.
Document #: 1016 Comment #: 3 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Examples of this are "none of the other DOE sites is considered reasonable"Executive (sic) Summary p. vii. Yet
section 4 contains several possibilities.
Response #: C.5
The first line in the referenced paragraph in the Executive Summary states "A number of
alternatives to increased interim storage at the Pantex Plant were considered." From these
alternatives, it was decided which justified additional consideration. The major possibilities
considered were included in Section 4.0. The referenced paragraph in the Executive
Summary goes on to summarize the key points used to make the statement cited in the
comment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.6) FOLLOWS.
Document #: 1022 Comment #: 5 Date: 2/11/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
p. 4-1 to 4-7 -- DOE has not presented an adequate examination of the alternatives, especially regarding the
possible security risks of having only one interim storage facility.
Response #: C.6
Safeguards and security issues are considered by the Department of Energy during the
assessment of any proposed action. The Department would preclude consideration of any
option that analysis has shown would compromise or pose an unacceptable risk to national or
physical security.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.7) FOLLOWS.
Document #: 1041 Comment #: 4 Date: 3/12/93
Beverly Gattis
Military Production Network
Comment:
2) Inadequate information is provided on alternatives for storing plutonium components at other DOE sites.
The predecisional EA provides only scant details on why facilities at the Los Alamos National Laboratory
(LANL), Savannah River Site (SRS), and Hanford Site would be unable to store some portion of the components.
Part of the justification offered for not pursuing plutonium component storage at these facilities is that:
"The nuclear weapons complex is undergoing numerous changes to include environmental restoration and
consolidation of its nuclear material to facilitate restoration and to enhance safeguards and security. The complex
has limited storage capacity, and each site's capability to store material (pits and SNM in various other forms) must
be examined. There are many ongoing programs where the storage capability at the above sites are currently
being assessed. Consolidation of material and subsequent inventory reduction at the RFP, reduction of the
inventory at LLNL, and clean out of processing canyons at SRS are a few that vie for the existing or potential
storage capacity at SRS, LANL, and Hanford." (p. 4-4)
The predecisional EA does not describe, and none of the referenced documents appear to discuss, any of the
"many ongoing programs" referred to above. At the very least, the final EA should list these programs and provide
ample information on the capacities of existing storage facilities as well as storage needs to allow independent
verification of the conclusions presented.
Response #: C.7
Some of the ongoing programs were described in the sentence following the referenced
phrase and include: consolidation of material and subsequent inventory reduction at the
Rocky Flats Plant; reduction of the inventory at Lawrence Livermore National Laboratory; and
clean out of processing canyons at Savannah River Site; and are but a few of the day-to-day
issues that are addressed in the operation of these and other Department of Energy Nuclear
Weapons Complex facilities. Storage capacity and utilization (of that capacity) are elements of
mission and day-to-day operation of the particular facility. The Department has developed
and described in the Environmental Assessment several reasonable alternatives to the
proposed action. These alternatives were developed taking into account current Department
policies and strategies. It would be beyond the scope of this Environmental Assessment to
evaluate the need or likelihood of such changes. Reviews of the Department programs
mentioned in the Environmental Assessment, resulting from current Department or other
government policies and strategies, are being conducted independently pursuant to the
National Environmental Policy Act when required. (More detailed discussion of considerations
regarding alternatives is presented in Response C.1.)
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.8) FOLLOWS.
Document #: 1042 Comment #: 7 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
In addition, the draft EA must discuss other reasonable alternatives, including:
a. Storing disarmed warheads;
b. Shipping all plutonium pits to other locations, just as tritium and highly enriched uranium are now
transported off site;
c. Providing one or more facilities that are open for international inspection;
d. Establishing one or more disposal facilities;
e. Storing pits at Pantex for a specific time period, with strict enforcement of the time limit and penalties to
ensure removal by the end of the time limit;
f. Storing pits in other areas of Pantex in addition to Zone 4; and
g. Others that DOE thinks are reasonable.
Document #: 1043 Comment #: 1 Date: 3/12/93
Mavis Belisle, Director
the Peace Farm
Comment:
Interim storage, in so far as it is a necessary part of the process, should be interim -- as defined in the
Environmental Assessment -- and limited to the 6-10 year time period referenced in the document.
To assure that this timeframe is met, there should be
* a strict and open accounting with the State of Texas for the pits
* a requirement for quarterly reports to the state for any pits held in interim storage longer than 10 years
including their intended disposition and timeline for that disposition
* provision for financial penalties for pits held in interim storage longer than 10 years. Otherwise, any pits
exceeding the time limit should be reclassified as waste and come under a full review process and environmental
impact statement for longterm storage. If the pits are to remain on site as a valuable national resource, their
international market value should be determined and that value added to "in lieu of taxes" provisions, paid annually
to the State and to Carson County.
Response #: C.8
With respect to one comment author's call for "a strict and open accounting with the State of
Texas for the pits," the Department has a stringent material management policy in place. In
addition to the fact that the information contained therein is Restricted Data, it would be
inappropriate to create a jurisdictional issue regarding accountability of special nuclear
material where one does not now exist.
In addition, two comment authors called for provisions for enforcement of the interim storage
time period including penalties, "in lieu of taxes" provisions, or automatic reclassification of the
pits as a waste. It is inappropriate to attach the suggested enforcement or "in lieu of taxes"
provisions to the proposed action within the document. It is not within the scope of the
proposed action to require a determination of long-term disposition.
In addition, the comments assert that other reasonable alternatives should be discussed. A
more detailed discussion on alternatives can be found in Response C.1. However, particular
alternatives were proposed (Document 1042, Comment 7) that the comment author suggested
required further discussion. These are as follows:
a. Storing disarmed warheads - This alternative is discussed in the No-Action
Alternative.
b. Shipping all plutonium pits to other locations - This alternative was examined with
respect to storage at Department of Defense sites. Alternative Department of Energy
sites were not examined because it was recognized in Section 4.2 that sufficient pit
storage capacity (at Savannah River Site, Los Alamos National Laboratory, and
Hanford) would not provide all the needed capacity in a timely manner.
c. Providing one or more facilities that are open for international inspection - National
security policy and treaty obligations will dictate whether the Pantex Plant or any other
facility providing interim storage of pits would be open for international inspection, this
issue therefore, is outside the scope of the proposed action.
d. Establishing one or more disposal facilities - Issues associated with the ultimate
disposition of plutonium are beyond the scope of this document.
e. Storing pits at the Pantex Plant for a specific time period - See discussion above in
paragraph 2.
f. Storing pits in other areas of the Pantex Plant in addition to Zone 4 - The Department
did not consider other areas of the plant in addition to Zone 4 since the proposed
increase in capacity would be more than adequate for the stated need.
g. Others that the Department thinks are reasonable - All alternatives considered
reasonable by the Department were discussed.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (C.9) FOLLOWS.
Document #: 1021 Comment #: 6 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
We are aware of massive safety problems at various other DOE sites, problems which will take decades to clean
up, billions of dollars, and probably a number of injuries to personnel. Knowing that, do we want the DOE to store
Pu pits in magazines when Pantex does not have expertise in this? Governor Richards should wonder, why
experiment with Texas? Why not experiment at Rocky Flats where the pollution levels are already severe? Or
Hanford? Or half a dozen places where the DOE has polluted? Or, why not some place where the military has
polluted?
Response #: C.9
Over the years, Pantex Plant personnel have developed more than adequate expertise to
implement the proposed action. Staging of weapons and weapons components have
historically been part of the Pantex operations. Pit staging operations are well characterized at
the Pantex Plant. The personnel, training, procedures, handling fixtures, material
accountability, and facilities are all in place and are readily transferrable and directly applicable
to the proposed action of interim storage in Zone 4.
Alternative Department of Energy sites and the possibility of using Department of Defense
sites were considered, and were not found to be acceptable.

Part D

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.1) FOLLOWS.
Document #: 1011 Comment #: 9 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
Even if no environmental contamination occurs, will increased operations at Pantex require excessive water use,
thus contributing to depletion (mining) of the Ogallala Aquifer?
Document #: 1015 Comment #: 18 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Despite claims by director Steve Walton of the AEDC that vast amounats (sic) of water exist for use by industry,
such is not the case. Even now, the Canadian River Municipal Water Authority is purchasing Southwestern Public
Service Co.'s water rights in Roberts Countay (sic) to provide adequate water for its southernmost customers.
Document #: 1016 Comment #: 13 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Are they planning a reprocessing facility at the Pantex site? The amount of water available will not be sufficient for
this.
Document #: 1017 Comment #: 21 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
I don't think there is enough water available for reprocessing in this area. Amarillo has drilled at least 7 dry holes in
their water field in northern Potter County. The Carson County field where the city is now pumping its water is
rapidly declining. Our static level in our walls had dropped four feet this past year and at least one of the Amarillo
wells dropped 12 feet.
Response #: D.1
The proposed interim storage activity is not expected to require any
additional water use at Pantex Plant. The water used at Pantex Plant
is a mixture of water from the Ogallala Aquifer and Lake Meredit

Weapons of Mass Destruction (WMD)