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CHAPTER 3: COMMENT SUMMARIES AND RESPONSES
This chapter summarizes the comments the Department of Energy received on the Draft
Programmatic Environmental Impact Statement for Tritium Supply and Recycling during the
public comment period, and provides responses to those comments. Identical or similar
comments provided by more than one commentor were grouped together in one comment summary
and responded to. The responses indicate whether any changes were made to the PEIS and the
rationale behind those decisions.

01 Land Resources

01.01 Commentors suggest that the Department of Energy (DOE) carefully consider all of the
potential consequences of siting the proposed tritium facilities at the Pantex Plant
(Pantex). Commentors express the opinion that Pantex is surrounded by some of the nation's
richest agricultural resources and any accidental radioactive release or contamination
would seriously affect this vital national resource, as well as the surrounding
population. In the commentors' view, the Programmatic Environmental Impact Statement
(PEIS) for Tritium Supply and Recycling should address this issue.
Response: The PEIS addresses the potential impacts of the proposed tritium supply and
recycling facilities on the surrounding environment from facility accidents in section
4.5.3.9. Additionally, appendix F, section F.3.4 provides information on secondary impacts
of accidents at Pantex. DOE is aware of the valuable agricultural resources surrounding
the Pantex facility. If the proposed tritium supply and recycling facility was sited at
Pantex, appropriate safeguards would be taken to minimize the likelihood of an accident,
radioactive release, or contamination that could significantly degrade these resources,
such as described in section 3.4.2 and appendix section A.2.

01.02 The commentor notes that the area proposed for the proposed tritium supply and
recycling facility at Pantex infringes on land that was leased from Texas Technological
University. The commentor believes that DOE should address this issue and any
complications it may present in the PEIS.
Response: As discussed in section 4.5.2.1 of the PEIS, the proposed tritium supply and
recycling facility would be located in the interior industrial core at the Pantex site.
Three areas have been designated for future industrial sites within that core, and one
area designated as Area C on figure 4.5.2.1-3 currently encompasses DOE-leased land from
Texas Technological University. As can be seen from figure 4.5.2.1-3, there are two areas
that would not affect leased land. Ultimate siting will be discussed in site-specific
tiered National Environmental Policy Act (NEPA) documents. For the area in question, the
boundaries can be rearranged to exclude any land DOE has leased from Texas Technological
University. Therefore, no complications concerning DOE-leased land and Texas Technological
University are anticipated with siting the facility at Pantex.

01.03 The commentor notes that Pantex has less total acreage than the other proposed
sites. As a result, the commentor believes that siting the Accelerator Production of
Tritium (APT) technology at that site could result in extensive and expensive relocation
of existing facilities and an inadequate security "buffer" zone unless additional land is
obtained. The commentor suggests that DOE should address these issues and their potential
impacts on properties adjacent to the site in the PEIS.
Response: Section 4.5.3.1 of the PEIS discusses environmental impacts associated with the
con- struction and operation of tritium supply and recycling facilities at Pantex. As
presented in table 4.5.3.1-1, siting the APT technology at Pantex would require 173 acres
of land. Three areas (A, B, and C) have been designated for future industrial sites at
Pantex. The APT land requirement translates into 30, 23, and 19 percent of the available
land for areas A, B and C, respectively. Although Pantex has the smallest total acreage of
all the candidate sites, it has sufficient land to accommodate any of the proposed tritium
supply technologies and recycling facilities.

01.04 The commentor expresses the opinion that the PEIS should include in its analysis the
current and future value of the land surrounding Nevada Test Site (NTS) (the new facility
could have an effect on its value).
Response: As discussed in section 4.3.3.1 of the PEIS, the construction and operation of
the proposed tritium supply site (TSS) facility would be consistent with the NTS Site
Development Plan and have no impacts on prime farmland, grazing allotments, other
agricultural activities, or other land uses on site. Offsite land will not be directly
affected since no tritium facilities will be constructed there. The socioeconomic
analysis presented in the PEIS assesses the potential impacts of the proposed tritium
supply alternatives on directly-affected sectors of the economy including labor supply and
demand, income, and public finance, as well as impacts on housing and transportation. The
analysis does not cover speculative issues such as the impacts to future property values
and business location or expansion decisions. Potential changes to socioeconomics in the
region, which may indirectly affect land values, are discussed in section 4.3.3.8. For
example, the increase in population created by some of the alternatives could increase
demand for housing.

01.05 The commentor asks whether land use assessments are being made on DOE-owned land,
such as those previously done for other interested landholders.
Response: As discussed in section 4.1.1 of the PEIS, changes in land use are expected to
occur at most, if not all, of the DOE candidate sites for tritium supply. The PEIS
contains an analysis of the impacts the proposed tritium supply and recycling facilities
would have on the future use or development of land at each DOE site. The PEIS considers
land use plans and policies, zoning regulations, specially protected lands, and existing
land use. Changes in land use within existing DOE site boundaries and on lands adjacent to
or in the vicinity of DOE sites (i.e., non-DOE land) that may result from the proposed
alternatives are considered in the PEIS.

01.06 The commentor notes that in section 4.5.2.1 of the PEIS, area farmland is considered
by the Soil Conservation Service as "prime farmland when irrigated." The commentor
suggests any "loss" of such potential prime farmland on Pantex to an industrial use would
be slight, relative to the expanse of cultivated and irrigated lands across the high
plains of Texas and the regional "Golden Spread." The commentor is of the opinion that
such a loss could be balanced by application of blowdown cooling tower waters as
irrigation to the immediate area.
Response: Sections 4.5.2.1 and 4.5.3.1 of the PEIS discussed environmental impacts to land
use as a result of the proposed construction and operation of the tritium facility at
Pantex. Three areas have been designated within the existing industrial core of Pantex to
accommodate the tritium supply and recycling facilities. Although classified as prime
farmland, these areas are essentially removed from agricultural use by ongoing plant
activities. There would be no loss of prime farmland within or outside of the Pantex site
boundary.
As described in section 4.5.3.4 of the PEIS, there would be no discharge of cooling system
blowdown waters at Pantex. Any pretreated utility, process, and sanitary wastewater not
recycled for tritium supply water needs would be discharged to the playas in accordance
with the Pantex National Pollutant Discharge Elimination System (NPDES) permit. These
wastewater discharges are not suitable for crop irrigation without advanced treatment
processing.

01.07 The commentor notes that section 4.5.3.1 of the PEIS identifies the Bureau of Land
Management Visual Resource Management (VRM) classification of Pantex as Class 4. The
commentor is of the opinion that the program would not downgrade that classification. In
fact the commentor points out that the "most sensitive viewpoint" from the Texas Plains
Trail, at the intersection of US 60 and Farm-to-Market Road 2373, designates the existing
industrial structures at Pantex as a "point of interest." Therefore, the commentor
believes that siting the tritium supply and recycling facility at Pantex would enhance the
visual resource.
Response: As discussed in sections 4.5.2.1 and 4.5.3.1 of the PEIS, the tritium supply and
recycling facilities would be visible from the key viewpoint from any of the proposed
industrial areas at Pantex. The VRM classification would not change with the construction
and operation of any of the technologies because existing views already include industrial
facilities.

01.08 The commentor states that the installation of transmission and distribution lines
does result in some land use and visual impacts. However, in the Pantex area, that is,
flat plains, and along existing corridors, the commentor believes that incremental
visual impacts would be slight. In addition, the commentor also believes that effects on
land resources during construction would be slight. The commentor also suggests that
effects on land resources during construction would be temporary, and effects on land use,
such as grazing or farmlands, likely would be slight as well, not only because
transmission structures occupy little land, but also because likely routes would be along
highway rights-of-way and/or existing power supply corridors.
Response: As discussed in sections 4.5.2.1 and 4.5.3.1, environmental impacts to land and
visual resources in the Pantex area are anticipated to be minimal. Any of the proposed
technologies for this site would be supported by a new electrical substation and
additional electrical transmission lines. In order to minimize the potential impacts to
natural resources, new transmission lines could be sited along existing rights-of-way. In
addition, the presence of sensitive habitats (for example, wetland, prime farmland) would
be considered if the construction of new rights-of-way are needed.

01.09 The commentor references pages 3-23, 3-35, 3-38, and 3-60, noting that in the
previous Environmental Impact Statement (EIS) for a New Production Reactor (April
1991), the land area required for each reactor concept (Heavy Water Reactor (HWR),
Advanced Light Water Reactor (ALWR), Modular High Temperature Gas-Cooled Reactor (MHTGR))
varied by site, but was never less than 360 acres (for an HWR at Savannah River Site
(SRS)). The MHTGR had the largest requirement at only one site, and only during
construction. The commentor points out that in this Draft PEIS, the land area requirements
are constant from site to site, and no extra land is needed during construction. The
commentor questions why the MHTGR now requires the most land, in spite of the fact that
only three modules are now needed compared with eight in 1991. Since none of the reactor
concepts is modular, the commentor believes it is not logical that their land requirements
would decrease more than the MHTGR requirements. The commentor is of the opinion that
either the MHTGR requirements are overestimated or the requirements of the other
concepts are underestimated. For these reasons, the commentor feels that the land use
impacts need to be reevaluated.
Response: Land use requirements for the MHTGR and other technologies are discussed in
sections 4.2 through 4.6 of the PEIS for each of the candidate sites. As discussed in
section 3.4.2.2, the MHTGR technology will require only three modules instead of six to
eight identified in the New Production Reactor EIS (April 1991) and disturb
approximately 360 acres of land. Land requirements given in the New Production Reactor
document included acreage for reactor facilities and support facilities for tritium
production, plutonium product, and spent fuel processing. In addition, the New Production
Reactors were site-specific designs incorporating infrastructure and environmental
features of the candidate sites.

02 Site Infrastructure

02.01 Commentors express the opinion that the analysis of the site infrastructure impacts
in the PEIS is unclear and vague, particularly with regard to electrical needs, and that
DOE needs to be more explicit and thorough in its analysis of the environmental impacts
and costs associated with either additional electrical consumption or a new power plant.
The commentors believe that the PEIS should consider various energy sources (e.g.,
nuclear, coal, hydro) for additional power and that the choice could be based on the
composition of the regional power pool. Commentors also state that DOE should clearly
indicate the quantity of additional water that will be needed for the additional
electricity, the size (physical and electrical) of the additional power plant, and an
analysis of the impacts associated with buying electricity from power pools inside and
outside the area of each of the five proposed sites. In addition, one commentor states
that 6 years might be required to construct a 500 to 600 megawatts electric (MWe)
coal-fueled steam electric plant rather than the 3 years estimated in section 4.8.
Another commentor notes that in volume I, page 4-3, column 2, paragraph 4, the PEIS
states, "A detailed quantitative analysis based on the proportional contributions from
each fuel source, would be conducted..." The commentor expresses the opinion that
apportionment of power requirements on the basis of the current mix of fuel sources would
probably be inappropriate, especially for the APT which has large power requirements, and
especially for the northwestern United States (e.g., at Idaho National Engineering
Laboratory (INEL)), where current electric power use relies heavily on hydroelectric
plants, and where significant expansion of hydroelectric generating capacity may be
unlikely. The commentor also believes that the impact of a 500 to 600 MWe power
requirement would be similar to that described in section 4.8.2 (pages 4-443 to 4-446),
whether it is filled by a dedicated collocated plant or by increased generating capacity
elsewhere.
Response: The site infrastructure methodology found in section 4.1.2 of the Draft PEIS
explains in detail to what extent the electrical impacts are assessed. The discussion
presented in the PEIS presents data and impacts in a programmatic context. For all of the
technologies, the electrical requirements to support each technology is added to the
projected site No Action requirement to determine the total site electrical requirement
for each of these technologies. These requirements are listed in tables 4.2.3.2-1,
4.3.3.2-1, 4.4.3.2-1, 4.5.3.2-1, and 4.6.3.2-1 for INEL, NTS, Oak Ridge Reservation (ORR),
Pantex, and SRS, respectively. The peak power and the total annual energy required for
each of these technologies were then compared against the capacity margin and the total
electricity production of the appropriate subregional power pool. These comparisons are
presented in tables 4.2.3.2-2, 4.3.3.2-2, 4.4.3.2-2, 4.5.3.2-2, and 4.6.3.2-2 for INEL,
NTS, ORR, Pantex, and SRS, respectively. In all cases, it appears that the subregion can
adequately support all of the technologies. However, as a bounding case for the APT
option, the construction and operation of a dedicated natural gas fuel power plant at each
site has been analyzed. Cost is not addressed in this PEIS but the cost studies being
prepared for the decision maker include the cost of buying electricity and the income from
selling it, as appropriate. The cost studies are included in the Technical Reference
Report available in DOE reading rooms.
The detailed quantitative analysis referred to in the comment would not necessarily show
that the current mix of fuel sources is expected to equate to the future mix. The
usefulness of site-specific tiered NEPA documents is that they are more able to focus on
the unique power characteristics of a chosen site (and its respective utility and power
pool) and determine whether or not a proposed impact analysis methodology is appropriate
for further consideration. The electrical contributions from the ALWR and the MHTGR are
taken into account in the environmental analysis since the designs of these reactors and
the operating requirements used in the PEIS are based on the fact that they generate
electricity. The economic benefit of this electricity production is included in the cost
analysis presented in the Technical Reference Report available in DOE reading rooms.

02.02 Commentors express the opinion that DOE should consider the possibility of using
alternative energy sources such as wind or solar energy to meet additional electricity
requirements for the various technologies. In addition, one commentor believes that this
possibility should be addressed in the PEIS. The commentors state that solar-generated
electricity from a proposed central receiving and photovoltaic facility could be used for
NTS. This could be handled by a private company, according to the commentors.
Response: The possibility of utilizing solar energy to supply additional electrical power
for the various technologies will be evaluated at NTS where a solar power demonstration
project is scheduled for implementation. The potential contribution of electric supply
from the central receiving and photovoltaic facility at NTS proposed by the Corporation
for Solar Technology and Alternative Resources has been included in the Final PEIS
analysis for NTS. Descriptions of the facility, the proposed construction and operation
schedule, power output, and the contribution to the NTS energy system are discussed in
section 4.3.2.2.

02.03 Commentors state that the technology options which are capable of producing
electricity result in avoided environmental impacts because they would displace existing
generating capacity and/or new capacity, and that this should be discussed in the PEIS.
One commentor also notes that the PEIS discusses at length the adverse impacts of
transmission lines but provides no discussion of the avoided impacts that are realized by
not having to build other generating capacity to supply the needs of the surrounding
service area.
Response: The PEIS does recognize the fact that the ALWR and MHTGR technologies can
produce electricity. The benefit of selling this electricity is accounted for in the cost
analysis included in the Technical Reference Report available in DOE reading rooms.
Section 4.8.1 of the PEIS discusses the potential of the ALWR and MHTGR reactor
technologies to produce power by a power conversion facility. This section also
describes the potential for impacts associated with offsite distribution of that power.
Incident to producing the tritium requirements, the ALWR and MHTGR technologies would also
generate significant quantities of electricity (approximately 600 MWe, 1,300 MWe, and 400
MWe for the Small ALWR, Large ALWR, and three-module MHTGR respectively). Electricity
produced from any of these reactors would likely be sold in accordance with Section 44 of
the Atomic Energy Act, and DOE has incorporated the revenues from such electricity sale
into the cost estimates for these reactors. The PEIS also addresses the potential
environmental impacts of generating this electricity. In addition to this cost benefit,
the benefit of not building future electrical production facilities could be realized.
These so-called "avoided environmental impacts" are acknowledged for both the ALWR and
MHTGR, and are discussed below.
Primarily as a result of the Energy Policy Act of 1992, the electric power industry is
undergoing significant changes, most notably related to the transmission of electric
power. It is expected that electric power will be more freely "wheeled" from one power
pool to other power pools, essentially nationalizing the transmission of electric power.
Transmission of electric power will be more efficient because there will be fewer barriers
to the use of available and future electrical generating capacity. Thus, the demand for
electricity in one part of the country could be met by an electrical generating facility
operating in a different part of the country.
A tritium production facility that also produces electric power would provide an
additional 400MWe to 1,300 MWe of electric power to supply future electrical demands, and
could, thus, obviate the need to build some electrical generating facility in the future.
This means that the potential environmental impacts of this additional facility could
indeed be avoided. However, given the situation described above regarding the national
wheeling of electric power, it would be speculative to say where the environmental
impacts of a 400 MWe to 1,300 MWe would be avoided, or what type of electrical generating
facility (e.g., coal, gas, nuclear, etc.) would not have to be built. About all that can
be said with any certainty is that the environmental impacts of such a facility could be
avoided. Nonetheless, this PEIS provides an environmental impact assessment of building
400MWe to 1,300 MWe reactors at various sites around the country, and also assesses the
environmental impact of constructing and operating a dedicated 550 MWe gas-powered
facility at these same sites. These general types of impacts for 400 MWe to 1,300 MWe
could be avoided because of the ALWR or MHTGR.

02.04 The commentor states that the analysis of regional power pool capacities and needs
in the PEIS for Tritium Supply and Recycling is incorrect. The excess capacity for
regional power pools is not extra electricity, but electricity needed by these power
pools. The commentor is of the opinion that the PEIS projections for future growth in
power pool regions may be inaccurate and this may force utilities to build new facilities
if the APT technology is selected. In addition, the commentor also notes that the PEIS
also incorrectly identifies the regional electrical power pool from which Pantex, through
Southwestern Public Service Company, draws service. Southwestern Public Service is
connected to the Southwest Power Pool, and has additional access to the Western Systems
Coordinating Council and the Electric Reliability Council of Texas (refer to sections
4.5.2.2, 4.5.3.2, and 4.8.1, and table 4.5.2.2-2). The commentor suggests that DOE will
want to review tables 4.5.2.2-2 and 4.5.3.2-2. As a result of this mistake, the commentor
believes that the percentages shown in the public meetings as "percent power pool capacity
margin" may be incorrect. Another commentor states that the future need for power in the
southeastern United States should be assessed as part of the EIS. Commentors further
suggest that the document should address how the APT may affect reserve electrical
capacity within the proposed power pools in general and should fully evaluate the
environmental effects and electricity-rate-based real costs of the additional electricity.
One commentor believes that the risk analysis needs to take into account the additional
risk if a power plant is needed to produce the additional power required for the APT.
Response: The PEIS does not equate generating capacity reserve margin with excess
electricity availability. Capacity margin is defined by the North American Electric
Reliability Council as the amount of generating capacity available to provide for
scheduled maintenance, emergency outages, system operating requirements, and unforeseen
electrical demand. The PEIS recognizes that the reserve margin is an amount of electricity
that is ineligible for use by all but the aforementioned activities. This is evidenced by
the statement in section 4.5.3.2, site infrastructure, that additional energy and power
required by the tritium supply and recycling alternatives would be accommodated with
approximately 9 miles of transmission lines and a new electrical substation. This shows
that the utility, and ultimately the subregional and regional power pools, could be
expected to provide all of the equipment necessary to transmit the additional power, but
does not imply that the additional power is to be supplied out of the reserve margin.
Rather, the statement that the tritium supply and recycling alternatives would require
between 0.47 and 4.28 percent of the reserve margin is an indication of what the
subregional power pool would suffer in terms of loss of reserve margin if implementation
of the tritium supply and recycling alternatives were not accompanied by new power
generation, power imports, or demand side management. The PEIS defers to the decision of
the respective utility and power pool as to exactly how this extra power would be
supplied.
The PEIS projections are only as accurate as the North American Electric Reliability
Council projections. In an effort to limit errors in projections, North American
Electric Reliability Council-projected data for 2002 was used as the estimate for 2005.
This was done because the PEIS does not purport to assess electrical impacts for 2005 by
further manipulating data that have already been estimated for 2002. The power pool
analysis for the Pantex site has been corrected in the Final PEIS to reflect the West
Central Subregion of the Southwest Power Pool as the primary provider of electricity to
the site. This PEIS provides an indication of what the particular power pool would suffer
in terms of loss of reserve margin if tritium supply and recycling alternatives
requirements were not accompanied by new electrical generation.

02.05 The commentor is of the opinion that the PEIS should include a more detailed
analysis of the proposed transmission lines for the tritium facility. The commentor
further suggests that the analysis should include the proposed route of the lines, whether
they will be underground, what the costs will be, and any potential impacts to human or
natural resources in the area.
Response: The location of tritium facilities on any of the five potential sites is merely
representative and does not lend itself to the detailed analysis suggested in the
comment. Based on the representative site, the electrical utility requirements,
including amounts of new transmission lines, were assessed. Following the Record of
Decision (ROD) on this PEIS, a site-specific tiered NEPA analysis could be performed in
which a specific location of the facility on the chosen site would be evaluated. This
would enable a more detailed analysis of the proposed transmission lines.

02.06 The commentor states that the electrical power loads would range from 62 MWe to 566
MWe. The commentor states that the power requirements, depending on the technology, would
require additional transmission lines and additional supply. The commentor points out
that the Nevada Power Company is assumed as the supplier. The commentor suggests that the
proposal should consider Valley Electric Power Company as a primary source for NTS as
well. The commentor feels the proposed Solar Enterprise Zone may offset environmental
impacts associated with power generation by providing a "cleaner" source of electricity
for some of the additional load requirements.
Response: The California and Southern Nevada Power Area Subregion is the assumed source of
any additional power that the Nevada Power Company would obtain. Any more detailed
analysis of procurement from other local power companies would be analyzed in the
site-specific tiered NEPA documents. The possible impact of the proposed Solar
Enterprize Zone on power requirements at NTS has been added in the Final PEIS.

02.07 The commentor notes that the PEIS does not propose to use the existing natural draft
cooling tower constructed for the K-Reactor at SRS. The commentor believes that the PEIS
should consider the use of this facility, if technically feasible, because of pollution
prevention considerations. Under the mitigation section (page 4-432), the commentor points
out that the PEIS states that the existing treatment facilities could be used. The
commentor expresses the opinion that these facilities (for example, liquid low-level waste
(LLW) waste processing facilities, the saltstone process, and the proposed Consolidated
Incineration Facility) should be maintained and upgraded as a preferable alternative to
constructing new facilities.
Response: DOE acknowledges that the K-Reactor cooling tower exists and that there is a
potential for its use and it may represent a cost savings at that site. This information
will be factored into the decision to select the tritium supply and recycling facility
location. In addition, the use of other existing facilities such as waste management
facilities mentioned in the comment would also be considered for use or possible upgrade
in site-specific tiered NEPA analysis as an alternative to constructing new facilities
to do the same job. The use of the natural draft cooling tower built for the K-Reactor
will be considered in a site-specific tiered NEPA document if SRS is selected as the site
for a new tritium supply reactor.

02.08 One commentor suggests obtaining cost estimates from commercial electrical companies
and finding out if the power pools can support the APT electrical requirement. Another
commentor also urges DOE to consider what would happen if the electricity for the APT were
cut off (that is, how reliable are the commercial electrical companies).
Response: Cost is not addressed in this PEIS but the cost estimates being prepared for the
decision maker include the cost of buying electricity and the income from selling it, as
appropriate. Reliability concerns for all of the technologies are being addressed in
separate studies (feasibility reports) for the decision maker to consider. The cost and
technical feasibility studies are included in the Technical Reference Report available in
DOE reading rooms.

02.09 Commentors are of the opinion that the PEIS should include the fact that some of the
reactor technologies could produce electricity (or steam for conversion to electricity)
and, as a result, would not require a new electricity source and might even be able to
contribute electricity to the regional power pool. The commentors further suggest that the
PEIS should consider this a potential benefit for selecting a reactor technology and DOE
should incorporate this into their final selection of a technology. One commentor states
that the evaluation in section 4.8.1 (page 4-442) of the sale of steam from tritium supply
technologies is grossly unbalanced. According to the commentor, the PEIS states that the
impacts of the sale are "too speculative" to be addressed at this time. Concerns regarding
the separation of military and commercial nuclear technology are also raised by the com-
mentor. In fact, the commentor states that the N-Reactor at Hanford sold electricity to
the local utility. Furthermore, the commentor notes that this issue was addressed during
the New Production Reactor Program. Initial discussions with the utility companies in the
service areas of the candidate New Production Reactor sites were quite positive, according
to the commentor. The commentor also believes that any precedents established at that time
should be cited as a basis under which the sale of electricity from the tritium supply
reactors could proceed. The commentor is of the opinion that there is sufficient basis
from the New Production Reactor Program for assuming that electricity sales would take
place. The commentor believes that the positive environmental impacts that result need to
be considered.
Response: It is reasonably foreseeable that electricity generated by the ALWR or MHTGR
incident to the production of tritium would be sold, as allowed by Section 44 of the
Atomic Energy Act. Thus, the PEIS includes an analysis of these potential impacts. Section
4.8.1 discusses the prospect of capturing the useful by-products (that is, steam and/or
electricity) of operating either the ALWR or MHTGR to produce tritium. In both reactors,
steam is produced. However, at the end of the first paragraph in section 4.8.1, the
question of what to do with this steam (whether it is sold or used to generate electricity
which is in turn sold) is clearly deferred to a separate site-specific tiered NEPA
document. The sale of electricity is similar to the sale of steam in that both
transactions require an in-depth analysis of site-specific utility and power pool
electricity supply and demand projections. Again, this is more appropriately left to the
separate site-specific tiered NEPA document mentioned above.

02.10 The commentor states that DOE should not locate a new tritium facility at NTS
because there is no experience in this area for the construction of a new nuclear reactor
facility.
Response: Technical feasibility and the schedule feasibility reports for completing the
various tritium supply technologies at each candidate site have been made available to
the decision maker and are reported in the Technical Reference Report available in DOE
reading rooms.

02.11 The commentor references the following statement in volume II, page I-10, APT:
siting the APT at INEL "would utilize 4.15 percent of the regional power pool capacity
margin." With the possibility of decreased generation by Bonneville Power Administration
to help salmon recovery along the Columbia River, the commentor believes this large draw
could become very problematic and needs significant discussion.
Response: In the event of decreased generation by the Bonneville Power Administration, the
Northwest Regional Power Pool Subregion in which INEL is located would adjust its
resources to compensate for this loss of generating capability independent of the
requirements generated by the APT at INEL. In any event, the APT electrical requirements
could be supplied by constructing a dedicated natural-gas fueled power plant at INEL if
the power was not available commercially. This option has been added to the Final PEIS and
is evaluated on a site-specific basis.

03 Air Quality and Acoustics

03.01 Commentors express the opinion that there are some inconsistencies, flaws, and
omissions in DOE's analysis of the potential impacts to air resources resulting from the
proposed action. In general, one commentor believes that DOE should be more concerned
about increased pollution levels and the effects these could have on visibility and air
quality. Another commentor suggests that the analysis should include the increased
pollutant levels resulting from additional power plants that may be needed or increased
levels from existing plants. In addition, another commentor suggests that the emissions
analysis in the PEIS for Tritium Supply and Recycling should clearly state where the data
for each technology originated. Finally, if a nuclear facility is selected, one commentor
believes that DOE should limit air exposures to more stringent standards than those
currently established. The commentor believes that the air exposures should not exceed
1/10 of the existing standards. In the commentor's opinion, this would provide some room
for error and avoid future shutdowns in the event these standards are not achieved.
Response: The Final PEIS has been revised to consider the impact of an additional power
plant which could be used to support the APT alternative. Air quality impacts for all the
alternatives at each candidate site are conservatively estimated and discussed in sections
4.2.3.3, 4.3.3.3, 4.4.3.3, 4.5.3.3, and 4.6.3.3 of the Final PEIS. DOE believes that the
current air quality standards which were used in assessing impacts and the modeling
approach used are sufficiently conservative to assure that the public and environment are
adequately protected. Sources of input data for the air quality analysis are referenced
for each of the alternatives throughout the document and technical support data are
presented in appendixB. Source documents are provided in DOE reading rooms. The air
emission standards for criteria pollutants, hazardous/toxic, and radiological emissions
are set by the Environmental Protection Agency (EPA) and/or the states to protect workers
and the public and already include an additional margin of safety. DOE intends to meet
these standards and, for most categories, operations would result in small increases to
the site emissions. The resulting total emissions would still fall below regulated
standards.

03.02 The commentor references section 4.1.3, air quality and acoustics, (volume I, page
4-5, column 1, paragraph 1) and appendix B, methodology and models, (volume II, page B-2,
column 1, paragraph 1). The commentor is of the opinion that the assumptions described for
modeling the effect of toxic/hazardous pollutant emissions are not necessarily
conservative, especially the artificial placement of sources at the center of a large
site, such as the INEL.
Response: The sources are centrally located within the complex of facilities at the
proposed TSS, not within the entire site. The phrase "within the complex of facilities"
has been inserted after "centrally located" in the two locations noted above for
clarification. The emissions have been "double counted" to ensure that the baseline is
conservative. The proposed TSS emissions are accurate as described above. There will
always be limitations associated with modeling.

03.03 The commentor questions why no mention was made of the proposed action's impacts on
global climate change. According to the commentor, the Draft PEIS indicated that if the
electrical power for the New Production Reactor was fossil fuel generated, then the
combustion could produce "...about 0.01 percent of the total United States emissions of
the gas (carbon dioxide) with potential significant cumulative effects on global warming."
The commentor recommends the addition of a clarifying statement concerning potential
project impacts on global climate change.
Response: The emissions of greenhouse gases for the reactor alternatives (HWR, ALWR,
MHTGR) range from approximately 64 tons per year for the light water reactor at Pantex to
approximately 230 tons per year for the MHTGR at NTS, ORR, or Pantex. Compared to the
estimated 5 billion tons per year of carbon dioxide released in the United States each
year, these emissions represent less than one-hundredth of a percent increase.
The APT emissions of greenhouse gases is approximately 13 tons per year without an
associated electric power facility. Emission of greenhouse gases from a 600 MWe natural
gas-fired turbine facility would generate approximately 1 million tons per year of
greenhouse gases. These combined emissions would be greater than those for the reactor
alternatives, but would still be less than two one-hundredths of a percent of the carbon
dioxide released in the United States each year.

03.04 Referring to sections 4.5.2.3 and 4.5.3.3, air quality and acoustics, several
commentors note potential advantages in the area of air emissions at Pantex. The
commentors see no emission rates in appendix table B.1.4-4 that would trigger Prevention
of Significant Deterioration review or permitting for any of the technologies at Pantex,
although section 4.5.3.3 states that Prevention of Significant Deterioration permits may
be required. The commentors find no evidence that Prevention of Significant Deterioration
permits could be triggered by the Pantex tritium program and strongly encourage DOE to
revisit this section of the EIS. The commentors also note that Pantex is in the air
quality attainment zone for automobile and industrial pollution, that this is not true
of other candidate sites, and that there are no Prevention of Significant Deterioration
Class I areas in the vicinity.
Additionally, one commentor points out that the estimated impacts of toxic hazardous air
pollutants from any of the tritium supply technologies and recycling facilities at Pantex
clearly would comply with applicable air quality regulations and standards, which protect
human health and welfare and the environment with an ample margin of safety. The commentor
also notes that the Pantex area, by wide margins, is in compliance with all air quality
standards - with the one exception of the 30 minute standard for hydrogen chloride
(exceeded occasionally at the Burning Ground, where a high explosives treatment/disposal
facility is expected to reduce the hydrogen chloride emissions so that even the short-term
standard is not exceeded). The commentor states that there appears to be nothing in the
Tritium Supply and Recycling Program that would degrade the air quality at Pantex.
Equally, nothing in the program is anticipated to degrade the area acoustically,
according to the commentor.
Response: The rationale for the text statement "that Prevention of Significant
Deterioration permits may be required" at Pantex is as follows: As shown in table
4.5.3.3-1, the 2010 No Action Pantex emissions for nitrogen dioxide plus incremental
nitrogen dioxide emissions from the MHTGR facility would exceed the Prevention of
Significant Deterioration applicable 100-ton-per-year emission criterion. Pantex would
therefore be designated as a major source. Also, the MHTGR facility would result in a
significant net increase in emissions of nitrogen dioxide (greater than 40 tons per year)
at Pantex. Therefore, the increase of nitrogen dioxide would subject it to a Prevention of
Significant Deterioration review.

03.05 The commentor notes that the proximity of the Great Smoky National Park, a
Prevention of Significant Deterioration Class I area, to ORR may require significantly
more stringent mitigation for air resource impacts. The commentor recommends that this be
noted in the impacts section of the PEIS.
Response: The following sentence has been inserted in sections 4.2.3.3 (INEL) and 4.4.3.3
(ORR) of the Final PEIS: "The proximity of Prevention of Significant Deterioration Class
I areas may require significantly more stringent mitigation for air resource impacts."

03.06 The commentor states that on page B-33, the value of 4.60 under APT should probably
be under ALWR as it was in the previous four tables.
Response: The commentor is correct and the appropriate changes have been made in the Final
PEIS.

03.07 Regarding section 4.4.3.3, the commentor suggests providing a cost structure for the
possibility of lowering the airborne emissions for each tritium supply technology.
Response: A cost structure to lower the airborne emissions for each tritium supply
technology is beyond the scope of the PEIS, although no exceedances of regulatory limits
were identified. Additional detail will be provided as appropriate in site-specific
tiered NEPA documents.

03.08 The commentor states that it is difficult to locate references in the PEIS. For
example, on page 4- 275, "EPA 1974a" is not even listed in the reference section (page
6-10). The commentor also notes that on page 4-273 table 4.5.2.3-1 has no reference.
Response: EPA 1974a is listed in the February 1995 draft as follows: "EPA 1974a
Environmental Protection Agency (EPA), Information on Levels of Environmental Noise
Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety,
(550/9-74-004), Office of Noise Abatement and Control, Arlington, VA, March 1974." The
references for table 4.5.2.3-1 are listed under "Source" at the bottom of the table. Both
source documents are listed in the references.

03.09 The commentor claims that NTS does not and did not perform any modeling for criteria
and noncriteria pollutants. The commentor wants DOE to explain the origins of the
results on page 4-108.
Response: The modeling for NTS was performed in accordance with the methodology presented
in section 4.1.3, air quality and acoustics, and further described in appendix B.

04 Water Resources

04.01 Surface Water

04.01.01 The commentor is of the opinion that DOE should be concerned about surface water
discharge from the APT once-through cooling system. An analysis of this discharge should
be included in the PEIS, according to the commentor.
Response: As discussed in section 4.3.3.4 of the PEIS, cooling system blowdown and
sanitary waste-water from the APT would be treated and recycled for reuse as cooling
system makeup. The treated effluent from the process treatment would be discharged to
evaporation ponds. Treated effluent would be monitored to comply with the NPDES permit and
other discharge requirements. There would be no discharges to surface water from operation
of the tritium supply technologies at NTS.

04.01.02 The commentor expresses several concerns about surface water at ORR. Regarding
chapter 4, table 4.4.2.4-1, page 4-185, the commentor requests that DOE explain how the
"Average Water Body Concentration" values were derived. In the paragraph "surface water
rights and permits" on page 4- 186, the commentor believes that DOE should include the
following: "Dependent on intake location, construction may require a 26A permit from
Tennessee Valley Authority, review by the Watts Bar Inter-Agency Working Group, State
Aquatic Resources Alteration Permit, or a Corps of Engineers 404 permit with State 401
certification."
Response: Regarding table 4.4.2.4.-1, the average water body concentration values were
derived from monitoring data provided by ORR. The site average water body concentration
is derived by taking an average of the samples collected throughout the year (monthly or
quarterly), and taking an average of the results of the analysis. The text in section
4.4.2.4 of the Final PEIS under surface water rights and permits has been changed to
incorporate the commentors suggested revision: "Dependent on intake location, construction
may require a 26A permit from the Tennessee Valley Authority, review by the Watts Bar
Inter-Agency Working Group, State Aquatic Resources Alteration Permit, or a Corps of
Engineers 404 Permit with State 401 certification."

04.01.03 The commentor states that in the PEIS Los Alamos National Laboratory is described
as infeasible and impractical as an alternative site for APT-generated tritium because of
cooling water requirements. However, the commentor notes that there are similar water
limitations in southeastern Idaho. At a minimum, the commentor believes that the PEIS
should acknowledge that surface water in southeastern Idaho is the subject of ongoing
court adjudication. The commentor notes that the outcome of this process cannot be
predicted at this point, but ultimately it could affect INEL's water rights.
Response: The text has been modified in section 4.2.2.4 of the Final PEIS under surface
water rights and permits indicating that surface water in southeastern Idaho is the
subject of ongoing court adjudication.

04.01.04 Commentors note that DOE is currently involved with remediation of East Fork
Poplar Creek (near ORR) under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) because the creek was contaminated by past releases from the Y-12
plant. Significant cleanup activities are required onsite and offsite. The commentors
suggest that any activities (e.g., cooling tower blowdown) involved with tritium
production that include discharges to the creek causing scouring, erosion, and flooding
may be unacceptable and contrary to the goals of the remedial activities.
Response: The following text has been added in section 4.4.3.4 of the Final PEIS under
surface water and groundwater "As discussed in section 4.4.2.4, DOE is currently involved
with remediation of East Fork Poplar Creek under CERCLA. Any discharges, including
cooling tower blowdown, involved with tritium production that may potentially impact East
Fork Poplar Creek would require engineering design mitigation measures to avoid
interference with the goals of the remediation effort."

04.02 Groundwater

04.02.01 Commentors express the opinion that the water resources analysis in the PEIS
lacks consideration of some reasonable and superior alternatives, and unfairly favors
other sites over Pantex. For example, treated wastewater from the sites or the surrounding
communities could be used to provide the water and cooling requirements of the various
technologies and decrease or eliminate the need to withdraw groundwater from the Ogallala
aquifer and eliminate any aquifer drawdown at Pantex. In addition, the commentors believe
DOE should evaluate water conservation practices (such as those employed by the city of
Phoenix) and advanced technologies that could also be employed to reduce water use
impacts, particularly at Pantex and other "dry" sites. Other commentors note that the
region around Pantex is dependent on the Ogallala aquifer and DOE should examine all
program and other activities, such as the red bed drilling and pumping that are in
process in and around Pantex, that could cause aquifer drawdowns. In addition, any
activities that could introduce contamination into groundwater (either directly or
indirectly through playa discharges) should be analyzed in detail.
Response: No wastewater will be directly discharged to groundwater. All wastewater will be
recycled or treated prior to any discharge to the playas. Furthermore, such discharges
will be monitored and controlled by permits. Groundwater contamination is a result of
past operations and with proper wastewater treatment methods will not present a problem in
the future. Based on public comment and new information, only reclaimed wastewater has
been evaluated for cooling system water usage for the proposed tritium supply technologies
at Pantex. Groundwater is not proposed to be used for cooling and other production
operations. The reclaimed wastewater would be obtained from the city of Amarillo
Wastewater Treatment Plant. The red bed drilling and pumping that are in process in and
around Pantex would be examined in site-specific tiered NEPA documents if Pantex is
selected as the TSS. The following text has been added in section 4.5.2.4 in the Final
PEIS under surface water: "Since the 1960s, reclaimed waste effluent has been used for
cooling water processes on the Texas High Plains. There are two potential sources of
reusable wastewater available in the vicinity of Pantex Plant: the Hollywood Road
Wastewater Treatment Plant and the Pantex Plant Wastewater Treatment Facility."
The Hollywood Road Wastewater Treatment Plant is located on the southside of Amarillo,
approximately 20 miles from Pantex. Currently the Hollywood Road Wastewater Treatment
Plant is discharging approximately 7 MGD (2,555 MGY) of advanced secondary treated water
that has gone through a filter treatment and is then discharged to the Prairie Dog Town
Fork of the Red River. This amount is anticipated to increase to 12 MGD (4,380 MGY) by the
year 2010. A commitment has been made by the city of Amarillo to develop this wastewater
to reduce the amount of ground-water withdrawals and slow the annual decline rate of the
Ogallala aquifer. In addition, a commitment has been made between the city of Amarillo
and DOE to use reclaimed wastewater from the Hollywood Road Wastewater Treatment Plant.
The analysis of water resources for tritium supply at Pantex now includes use of reclaimed
wastewater in lieu of groundwater.

04.02.02 Commentors believe that the water requirements for the APT are significant at
NTS. Commentors also suggest that DOE study NTS basin recharge rates to clearly
understand the amount of ground-water available to the project. In addition, commentors
believe that DOE should also confirm that future NTS water needs were considered in
addition to current and tritium supply and recycling requirements. Considerations should
include impacts on local water needs, financial and environmental costs associated with
aquifer drawdown, and increased water consumption as a result of future and concurrent
projects at the site, according to the commentor. Commentors also believe that the PEIS
should include an analysis of the impacts from potential existing or future contamination
of aquifers associated with DOE activities.
Response: When a site has been selected, a site-specific evaluation of water resources
will be performed on local water needs (farmers, businesses, etc.). The site water
requirements were based on future projects and site workload reasonably foreseeable at
this time. Previous recharge rates furnished by NTS have been modified by the site and the
new recharge rate numbers have been used to re-evaluate the tritium supply and recycling
facilities. The new recharge rates indicate that none of the technologies would exceed the
new recharge rates. The units for flow rate of a particular area are gallons per day or
year. All data were based on studies that used recharge rates or flow over a given amount
of time and over a given area. The text has been modified so the recharge rates are not
averages, but various estimates of flow exemplified among authors. All authors rely on
similar methodologies and assumptions, so the uncertainty in recharge and discharge
estimates is based on a lack of complete data and different initial assumptions. However,
the following specific revisions have been made.
The discussion of groundwater in section 4.3.2.4 of the Final PEIS has been expanded to
include the following: "A study by the United States Geological Survey (Harrill et al.,
1988) balanced the amount of recharge and discharge throughout the Great Basin and
estimated a total of 32 BGY recharge for the entire Death Valley System. Of this total,
about 11 BGY flowed through or near Frenchman Flat into the Ash Meadows discharge area to
the south. A study by the Desert Research Institute (A Deuterium-Calibrated and
Discrete-State Compartment Model of Regional Groundwater Flow, Nevada Test Site and
Vicinity (DOE/NV/108, March 1992)) modeled groundwater flow through discrete areas of the
Death Valley system and concluded that of 16 BGY total system recharge, about 7 BGY flowed
through Frenchman Flat. These differences in estimates of flow exemplify common variations
among authors of a factor of 2 or 3 but rarely of as much as a factor of 10. All authors
rely on similar methodologies and assumptions, so the uncertainty in recharge and
discharge estimates is based upon a lack of complete data and different initial
assumptions."
The discussion of groundwater availability, use and rights in section 4.3.3.4 has been
expanded to include the following: "Some proportion of the estimated flow through
Frenchman Flat (11 BGY) is available for use by the tritium technologies. The exact amount
available would have to be determined through site-specific studies to determine
potential impacts on Ash Meadows and Devil's Hole and surrounding users. Harrill et al.,
1988 estimated that there is four times as much water in storage as there is in annual
recharge. Thus, there is the capacity to buffer the effects of annual or multi-year
droughts through the use and replenishment of stored water. In addition, substantially
more water could be made available by using resources in the Alkali Flat-Furnace Creek
Ranch Subbasin to the west (service area D of figure 4.3.2.4-1)."

04.02.03 One commentor notes that NTS and the city of Las Vegas use completely independent
and separate groundwater basins to meet their water needs. Therefore, the commentor
believes that water resources should not be an issue at NTS. Another commentor expresses
the opinion that the need for jobs and an economic boost outweigh the needs to conserve a
water source which only serves the needs of NTS.
Response: The city of Las Vegas, like the NTS, is located in the Great Basin. Even though
most of the city of Las Vegas's potable water is obtained from surface water resources,
approximately 15 percent of the water is obtained from groundwater wells, making
groundwater a vitally important natural resource. Because a portion of the community
relies on groundwater to supply a portion of its freshwater needs, it will be directly
affected by groundwater usage and quality. The proper water resources for the tritium
facility to operate effectively would also relate to additional jobs and economic benefit
to the surrounding communities. Both the impacts to water resources and socioeconomics
will be weighed by the decision maker.

04.02.04 Several commentors note that the PEIS for Tritium Supply and Recycling should
have a more thorough analysis of the potential for aquifer contamination at INEL.
Commentors state that past practices at the site have resulted in tritium contamination to
the Snake River Plain aquifer. The aquifer is vital to southern Idaho and the commentors
suggest that the PEIS identify all possible pathways (including those initiated by
earthquakes) through which discharges (radioactive or not) could reach the aquifer or the
land. The commentors also want DOE to provide additional information about groundwater
supply impacts on the Snake River aquifer if the APT is selected for INEL.
Another commentor refers to the section on groundwater quality in volume I, page 4-26 of
the PEIS, and offers several changes. According to the commentor, the following sentence
is inaccurate: "Two groundwater monitoring networks are operated at the INEL, one by the
United States Geological Survey, the other by Radiological Environmental Science
Laboratory." The commentor points out that there are several "networks" of monitoring
wells drilled and maintained by the USGS. These include the INEL-wide facility groundwater
monitoring group and well networks for Resource Conservation and Recovery Act (RCRA) and
CERCLA-required monitoring. In addition, the commentor notes that groundwater beneath the
INEL is monitored by groups including the USGS, DOE's site contractor, Lockheed Idaho
Technology Company, other DOE contractors, and the State of Idaho. The commentor quotes
further from page 4-26: "No tritium is currently disposed of at the INEL..." The commentor
suggests that this statement should read: No tritium is currently disposed to the
groundwater at the INEL.
Continuing on page 4-26, the commentor also refers to this statement: "Other radionuclides
of significance include strontium-90, cesium-137 and iodine-129. The first two,
especially cesium-137, are strongly held on mineral grains in the soil. Therefore, it is
unlikely that either will reach the aquifer in significant quantities." The commentor
contends that this statement suggests that all strontium-90, cesium-137, and iodine-129 in
the aquifer had to migrate through the vadose to reach the aquifer. From ORR and Cecil,
1991 (DOE/ID-22096), the commentor notes that in 1988 there was an area of about 1 mi2
where the strontium-90 concentrations exceeded the Maximum Containment Level. There are
significant enough quantities of strontium-90 present to exceed the Maximum Containment
Level over this region. In addition, the commentor states that recent CERCLA inves-
tigations at the Idaho Chemical Processing Plant under the Federal Facility
Agreement/Consent Order indicate that there is a significant source term of strontium-90
in the vadose and the current strontium-90 levels in the aquifer are as great as when
direct injection of strontium-90 bearing wastes was occurring. The commentor believes that
this discovery, with supporting information from vadose monitoring wells, suggests that
strontium-90 levels in the aquifer may increase in the future.
Response: Water sampling at INEL includes both onsite and offsite groundwater monitoring
with samples taken from the Snake River and other surface streams and tributaries in the
INEL vicinity, some of which flow onto the site and sink into its porous soils. Because
the Snake River Plain aquifer, which lies beneath INEL, serves as one of the primary
sources for drinking water and crop irrigation in the Snake River Basin, the USGS has an
extensive monitoring program to maintain surveillance of the aquifer, and perched water
bodies above it, on INEL and at a few locations beyond the southern and western
boundaries. Results of monitoring of surveillance activities that are published in USGS
reports are summarized in the INEL Site Environmental Report annually. At INEL, not all
environmental monitoring responsibilities reside within the same organization. Operating
contractors at each INEL facility are responsible for monitoring of effluents (releases)
and for any ambient environmental monitoring or surveillance performed within the facility
fences. The most extensive of these is conducted by EG&G Idaho. The Environmental
Monitoring Unit conducts a radiological environmental surveillance program which includes
water.
Low, but detectable, concentrations of tritium, the most mobile low-level radioactive
contaminate in the water of the aquifer, were reported in samples from wells just inside
the INEL boundary in 1983. However, tritium from INEL has never been detected in any of
the wells south of the boundary. Thus atmospheric transport is the principal potential
exposure pathway from the site. Therefore, liquid-borne radioactive materials disposed to
surface disposal ponds could percolate down through the porous soils into the Snake River
Plain aquifer and into pumped water supplies. In addition, air to surface transfer of
airborne radioactive materials could go to the Big Lost River (intermittent stream) and
affect upstream fish migration, or air to surface transfer of airborne radioactive
materials could fall on soils and percolate downward to the Snake River Plain aquifer.
Assessments, including monitoring programs and self-assessments, are being conducted
onsite and offsite, as discussed in the INEL baselines, section 4.2.2.4. With regard to
earthquakes, all proposed project structures would be built to meet DOE design standards
applicable to the seismic area. In addition, facilities such as the tritium supply would
meet the standards of 10 CFR 100, appendix A. Additional information about groundwater
supply impacts on the Snake River aquifer if the APT is selected for INEL will be
addressed in site-specific tiered NEPA documents.
In the Final PEIS the first few sentences under groundwater quality, section 4.2.2.4, have
been rewritten as follows: "There are several `networks' of monitoring wells drilled and
maintained by USGS. These include the INEL sitewide facility groundwater monitoring group
and well networks for RCRA and CERCLA required monitoring. Groundwater beneath INEL is
monitored by groups including USGS, DOE's site contractor, Lockheed Idaho Technology
Company, other DOE contractors, and the State of Idaho." Text in the second paragraph of
section 4.2.2.4 has also been rewritten to read: "No tritium is currently disposed to the
groundwater at INEL; however, tritium plumes are present in the Snake River Plain aquifer
and in perched groundwater under these sites (figure 4.2.2.4-2 (in USGS 1988a)."

04.02.05 Commentors assert that DOE needs to address and clarify some issues involving the
playas at Pantex. The commentors express the opinion that the PEIS should address whether
the discharge of water at high temperatures to the playas has any impacts, whether
pollutants discharged into the playas will seep into the aquifer (high explosives and
nitrates have been found in the aquifer), whether the characterization of the playas as
dry lakes is accurate, and the possibility that discharges to the playas actually sustain
species and play a beneficial role (currently in the PEIS, wastewater discharges are
portrayed as degradations).
Response: All discharges would be in compliance with existing NPDES permits and no impacts
were identified in the analysis or are anticipated. In addition, the following text has
been added to section 4.5.3.4 in the Final PEIS under surface water: "Closed-cycle
cooling systems include cooling ponds and towers. Because it is a closed system, water is
recirculated through the plant and tower or pond and replenished only to the extent that
it evaporates. These systems discharge heat to the atmosphere rather than to water. The
only water that is to be discharged to the playa is treated sanitary wastewater of the
same type currently discharged. All wastewater discharged from the wastewater treatment
plant is at ambient temperature."

04.02.06 The commentor believes that salt deposition from cooling towers may impact
groundwater quality. The commentor notes that salt was not addressed as a potential
source of groundwater contamination. The commentor is of the opinion that the PEIS
should address the potential effects of supply and recycling activities on downstream and
downgradient public water supply systems.
Response: Impacts associated with tritium supply and recycling activities on public water
supply systems would be addressed in site-specific tiered NEPA documents once a site is
selected. Additional information has been added to all sections regarding salt
deposition from the cooling towers. Any salt coming from the cooling tower originated from
the ground or surface water depending upon the site. At dry sites (that is, Pantex, NTS,
and INEL), dry cooling towers will be used, and salt would not be released at all from the
cooling tower. There could be some concentration of salt in the blowdown water, but that
can be treated. The dry cooling tower with blowdown recycle would couple reverse osmosis
with an evaporator and crystallizer system that would remove the dissolved solids from
blowdown so that water could be recycled to the cooling tower. This system would reduce
peak requirements for makeup water and discharge would not require disposal. The solids
from the crystallization processes would be disposed of as waste. This system would reduce
the salt from the cooling tower as well as from blowdown. At wet sites (that is, SRS and
ORR), because the salt is concentrated in a wet cooling tower, it can damage vegetation in
a small area near the facility. At all the wet sites there is adequate rainwater and
groundwater flow such that the salt from the cooling tower would be flushed into the
groundwater and diluted. The groundwater and surface water systems are connected such
that the salt originating from the major surface water body (that is, Clinch River and
Savannah River) and reaching the groundwater will return to the river and the total amount
of salt in the ecological system would remain the same.

04.02.07 Commentors believe that there are some additional water resources issues that DOE
should address in the PEIS for Tritium Supply and Recycling: DOE should provide
documentation of the reasoning behind the groundwater numbers in the PEIS; the water usage
numbers at the sites should be adjusted for the relative humidity at the sites; DOE should
acknowledge and address the fact that recent studies have suggested that Pleistocene
groundwater in the western United States may be a nonrenewable resource and that "dry"
years are causing more drawdown than DOE indicates; aquifer water levels in the PEIS
should be shown as depths, not only as elevations; DOE should ensure that an adequate
number of groundwater drawing sites are present at each site; and, DOE should indicate
exactly where drawdown is being measured and whether those measurements adequately
characterize the total area drawdown.
Response: The PEIS groundwater quality numbers were derived by taking groundwater samples
from existing monitoring or water production wells, running an analysis and comparing
water quality criteria and standards to the sample results. Groundwater usage numbers
were derived from current data on what is being used at the candidate sites. No Action
(2010) water usage was derived by each site based on projected mission and related
activities. No Action also included any new reasonably foreseeable projects or missions
that could be added to the site and their expected water usage. Total water requirements
for construction and operation are calculated by adding No Action water requirements with
the requirements for each tritium technology. The percentage increase in water use due to
the proposed tritium supply project was then calculated based on the No Action usage.
The relative humidity at each candidate site was not included in the engineering analysis
to determine water requirements. The preconceptual design of the proposed tritium supply
technologies is not of the quality to determine the increase or decrease of water usage
based on each sites environmental setting. In addition, the preconceptual designs were
"greenfield" (the same design was evaluated at each site without any modifications to take
advantage of existing infrastructure, resources, or environmental setting) except for the
designation of "wet" and "dry" sites and the change in cooling systems. At the
programmatic level of analysis, the water usage numbers for each technology are of
sufficient quality to identify differences for selection of a tritium supply. When a
tritium supply technology and site are selected, the site-specific tiered NEPA document
will consider all these factors, including the effects of relative humidity on water
requirements for the selected technology.
The commentor is correct in stating that recent studies have suggested that Pleistocene
groundwater in the Western United States may be a nonrenewable resource and that "dry"
years are causing more drawdown. These are just a few of the reasons why alternative water
sources, such as reclaimed wastewater from the city of Amarillo Hollywood Road Wastewater
Treatment Plant, have been proposed as potential water sources for new tritium supply
facilities.
The map indicating water elevations was provided by the Panhandle Groundwater Conservation
District No. 3. In that region water depths are measured by the district in elevations
because it gives a better indication of the areas that contain more or less water because
of the land surface. The average elevation of the land surface 3,550 feet must be
subtracted from the elevation to show the depth to the groundwater surface.
The groundwater drawdowns reported in the PEIS were measured from the city of Amarillo
water production supply well field area. Further groundwater withdrawal analysis at the
Pantex site and in the surrounding area would be addressed in site-specific tiered NEPA
documents if Pantex is selected as the TSS. Based on public hearing comments and
information received during the public review of the Draft PEIS, however, reclaimed
wastewater is analyzed as the source of cooling water for the tritium supply technologies
at Pantex in the Final PEIS.

04.02.08 In reference to volume I, page 4-28, groundwater availability, use and rights at
INEL, the commentor expresses concern about the following statement: "The combined
pumpage of the 27 onsite production wells averaged approximately 2,100 MGY from 1982
through 1985." The commentor suggests that more recent data are available and are used in
the Spent Nuclear Fuel INEL Environmental Restoration and Waste Management EIS. The more
recent data are slightly less, at about 2,000 MGY. The commentor also expresses concern
about another statement in the section: "This is 40 percent of the 5,280 MGY of
groundwater withdrawn from the aquifer in the Eastern Snake River Plain." The commentor
notes that Lindholm, 1993 (USGS Open-file Report 91-98), states that in 1980, 1.9 million
acre feet of water was pumped for irrigation on the Eastern Snake River Plain at 3.0689
acre feet per million gallons, that is 619,114 million gallons. Since irrigation accounts
for an estimated 96 percent of all groundwater use, the commentator notes total pumpage
from the Eastern Snake River Plain aquifer is about 645,000 MGY. Therefore, the commentor
contends that water pumped by the INEL is more like 0.3 percent of all water pumped from
the aquifer.
Response: The text has been rewritten in section 4.2.2.4 in the Final PEIS under
groundwater availability, use and rights, considering the new information in Lindholm,
1993 as follows: "The combined pumpage of the 27 onsite production wells averages
approximately 2,000 MGY. This is 0.3 percent of the 645,000 MGY of groundwater withdrawn
from the aquifer in the Eastern Snake River Plain. Most of the water withdrawn from the
aquifer in the Snake River Plain (619,114 MGY) is used for agriculture (Lindholm, 1993)."

04.02.09 At SRS the need for excavation and dewatering for the APT, as well as the
gas-cooled reactor, may lead to upsets in the natural flow of surface and ground water,
in one commentor's opinion. The commentor contends that mitigation and monitoring will be
extremely important to ensure that there is no potential for significant flow of
contaminants into the construction area because of the extensive groundwater contamination
already present at the site. Another commentor states that the tritium facility should not
be located at SRS in order to preserve the quality of the Savannah River for drinking
water.
Response: The text in section 4.6.3.4 has been modified and clarified, so the reader will
have a better understanding of the process of dewatering and mitigation measures that
will be implemented during the process to ensure that there is no potential for
significant flow of contaminants into the construction area.

04.02.10 Several commentors have serious concerns about the APT and its effect on water
resources, especially at the dry sites. One commentor requests clarification of the GPY
that the APT would require, as the number seems inflated. Additional commentors believe
that DOE has overstated the water requirement for the natural gas-fired plant. One
commentor notes that if treated wastewater is used for the APT, an assessment must be
performed on the area to which the wastewater is currently discharging. Another
commentor requests clarification on the term N/A for the APT closed loop system, i.e., if
this means that the APT would not be located at a dry site.
Response: The water requirements for the various technologies were provided by an
independent engineering contractor, based on preconceptual designs. Until the technology
and site location have been chosen, the numbers will remain generic to the technology and
type of site (wet vs. dry). Future site-specific tiered NEPA documents will further
analyze water requirements and their impacts. The APT is being considered for location at
all five candidate sites.

04.02.11 Regarding section 4.4.2.4, page 4-186, 2nd paragraph, the commentor asks that DOE
provide more detailed information on the flow of groundwater in the vicinity of the
proposed TSS, identify sources of information used in the groundwater section, and clarify
where the "class" of aquifers originated.
Response: The text has been modified to add more detail on the flow of groundwater in the
vicinity of the proposed TSS. The sources for the groundwater discussion in section
4.4.2.4 are DOE and the site documents cited in chapter 6. As of 1988, the sole source
aquifer (SSA) program allowed individuals and organizations to petition the EPA to
designate aquifers as the "sole or principal" source of drinking water for an area. The
program was established under section 1424(e) of the Safe Drinking Water Act (SDWA) of
1974. The primary purpose of the designation is to provide EPA review of Federal
financially assisted projects planned for the area to determine their potential for
contaminating the aquifer. The EPA has developed a three-part classification system for
the groundwaters of the United States:
Class 1: Special Groundwaters are those that are highly vulnerable to contamination
because of the hydrological characteristics of the areas under which they occur and that
are also either an irreplaceable source of drinking water or ecologically vital in that
they provide the base flow for a particularly sensitive ecological system.
Class II: Current and Potential Sources of Drinking Water and Waters Having Other
Beneficial Uses are all other groundwaters except Class III.
Class III: Groundwaters Not Considered Potential Sources of Drinking Water and of Limited
Beneficial Use because the salinity is greater than 10,000 mg/L or the groundwater is
otherwise contaminated beyond levels that can be removed using methods reasonably
employed in public water-supply treatment.
The EPA uses this classification scheme in promulgating rules and regulations at the
Federal level. The highest degree of protection is given to Class I groundwater.

04.02.12 The commentor is concerned about the groundwater contamination at SRS. The
commentor states that tritium from the SRS has contaminated wells in Georgia. In
addition, the commentor suggests that DOE must address this issue carefully and ensure
that no further contamination occurs.
Response: Groundwater contamination at SRS is a legacy of past waste disposal and
operational activities. Groundwater Quality Assessment reports have been submitted to the
State of Georgia for numerous years. There are no longer discharges of waste to
groundwater under present operational discharge controls. All waste water is treated and
discharges controlled by the permit process. The status of current operations is reported
annually to the public in the SRS Environmental Report.
Industrial solvents, metals, tritium, and other constituents used or generated on the site
have contaminated the shallow aquifer beneath 5 to 10 percent of the site. These
aquifers are not used for drinking water or for SRS operations; however, they do discharge
to site streams and eventually to the Savannah River. During operations of a tritium
supply and recycling facility, no direct discharges to groundwater will be made. All
wastewater will be treated and then discharged to SRS streams. Discharges made to SRS
streams that discharge to the Savannah River will be within NPDES permits and will comply
with South Carolina Water Quality Standards. Currently there are several onsite and
offsite remediation efforts being performed.

05 Geology and Soils

05.01 Commentors suggest that the PEIS for Tritium Supply and Recycling should address
general seismic and volcanic effects on new facilities, as well as site-specific
conditions, when selecting a site for the proposed activities. One commentor states that
future nuclear testing at NTS could increase the seismic risk to any tritium facilities
located there. Another commentor further states that INEL is located in an
earthquake-prone zone and is not a safe place to site the proposed tritium facilities.
Other commentors add that site-specific issues, such as proximity to capable faults,
should be addressed in the PEIS.
Response: Sections 4.2.2.5, 4.3.2.5, 4.4.2.5, 4.5.2.5, and 4.6.2.5 of the PEIS discuss
geology and soils for the INEL, NTS, ORR, Pantex, and SRS sites, respectively. Issues
such as volcanic hazard, seismicity, and proximity to capable faults were addressed in
those sections. The five candidate sites are considered to have little or no volcanic
hazard. As discussed in the summary of environmental impacts for each site (sections
4.2.3.5, 4.3.3.5, 4.4.3.5, 4.5.3.5, and 4.6.3.5), the seismic risks ranged from negligible
to moderately low. The existence of a low or moderate seismic risk would not preclude the
safe construction and operation of the proposed facilities at any of the sites. NTS and
INEL are the only two sites where capable faults exist; however, no faults are directly
located on the proposed location of the proposed TSS facility. No known capable faults
were detected at the other sites, and for those areas ground shaking rather than ground
rupture would be more likely. The proposed TSS facilities would be designed for earthquake
generated ground acceleration in accordance with DOE Order 5480.28 and accompanying
safety guides.

05.02 Commentors are of the opinion that seismicity and geology have been totally ignored
in the PEIS and that Pantex is by far the superior site for the tritium production
facility. The commentors categorize the following as advantages at Pantex: no evidence
of active faults has been found at Pantex; seismic hazards are minimal; engineering
load-bearing capacities of soils and ground sediments are superior to other candidate
sites; Pantex has less than 7 percent land area designated as wetlands; the site may be
excavated safely on steep, stable slopes; and it is suited for cut and cover construction.
Response: Sections 4.2.2.5, 4.3.2.5, 4.4.2.5, 4.5.2.5, and 4.6.2.5 of the PEIS discuss
seismicity, geology, and soils at all candidate sites. These factors identified by the
commentor, as well as many others, will be considered and evaluated in the decision
process leading to the selection of the tritium supply technology and the preferred site.

05.03 The commentor states that in terms of seismic-induced impacts, the PEIS failed to
address the relationship between nuclear testing and tritium production at NTS. The
commentor also states that although a moratorium on nuclear testing has been extended
indefinitely, the Administration's current defense policy requires DOE to retain the
capability to resume nuclear testing (The President's fiscal year 1996 includes $206
million to support the nuclear testing readiness program at NTS).
Response: The PEIS did not address a relationship between nuclear testing and tritium
production. Although underground testing was halted in 1992, NTS maintains the capability
to resume testing if required. In terms of seismic-induced impacts, although NTS is
located in an area of moderate historic seismicity as discussed in section 4.3.2.5,
facility designs ensure no adverse effects. As described in section 4.3.3.5, facilities
would be designed for earthquake-generated ground acceleration in accordance with DOE
Order 5480.28 and accompanying safety guides.

05.04 The commentor states that in sections 4.5.2.5 and 4.5.3.5, geology and soils, the
Draft PEIS correctly characterizes the soils that underlie Pantex as Pullman-Randall and
characterized by "very low permeability clays and clay loams." The commentor also states
that this fact greatly mitigates possible concerns (on page 4-305) about percolation to
groundwater of treated wastewaters discharged to playas. The commentor asserts that DOE
also correctly characterizes the seismicity of the Pantex area as low. However, the
commentor notes that on page 4-278, one of the subject basins is incorrectly identified
as the "Palo Verde Basin" rather than the "Palo Duro."
Response: As discussed in section 4.5.3.4, reclaimed wastewater will be used to fulfill
the water requirements for the construction and operation of any of the proposed tritium
supply and recycling facilities at Pantex. Treated wastewater will be either recycled for
cooling system makeup or discharged to the playas. Although there is no direct discharge
to groundwater from the proposed facilities, treated sanitary wastewater discharged to the
playas could percolate into the groundwater. Soils at Pantex, which are low permeability
clay and clay loams, should help minimize the impacts associated with this possibility. In
addition, a lined evaporation pond could be constructed to reduce wastewater seepage.
Although permeability of these clays is low, the PEIS must consider percolation
possibilities; therefore, any discharged wastewater would meet NPDES permit require-
ments. In section 4.5.2.5 of the PEIS, the sentence has been changed to read: "Seismicity
in the Palo Duro Basin and at Pantex is low".

05.05 Regarding page 4-385 of the Draft PEIS, the commentor states that the dewatering due
to construction activities for the APT could be a significant problem, as could the
potential spread of activation products in the soil. The commentor adds that should the
APT design proceed, it is possible that the required underground depth may increase,
resulting in further environmental impact.
Response: As discussed in section 4.6.3.4 of the PEIS, dewatering due to construction
activities of the APT could result in increases in stream flow and impacts to aquatic
resources without proper mitigation. Dewatering discharge could be directed to Par Pond to
prevent any impacts to Fourmile Branch. The potential for activation products to be spread
through the soil is considered low. Section 4.6.3.5 of the PEIS discussed potential
impacts to geology and soils from the proposed tritium supply and recycling facilities.
The impacts associated with deep excavations for the APT technology would be evaluated in
detail and potential mitigation measures identified in site-specific tiered NEPA studies.

05.06 Because of the seismic concerns, the commentor doubts that either a reactor
technology or the linear accelerator concept could be located at NTS.
Response: As discussed in section 4.3.3.5, the construction and operation of tritium
supply and recycling facilities at NTS would have no impact on geological resources. The
presence of a moderate seismic risk at NTS does not preclude the safe construction and
operation of the tritium supply and recycling facility onsite. The proposed facilities
would be designed for earthquake, and any potential weapons-testing-generated ground
acceleration in accordance with DOE Order 5480.28 and accompanying safety guides.

05.07 The commentor states that seismic stability should be one of the criteria for site
selection. The commentor considers the APT a more stable alternative. The commentor notes
that APT has no waste production, therefore, in the event of an earthquake, wastes would
not be released. The other alternatives are more vulnerable, according to the commentor.
The commentor concludes that, compared to the other sites, NTS would be the best suited
site because of lessened seismic activities.
Response: Section 4.3.2.5 of the PEIS discusses seismicity, geology, and soils at NTS.
These factors identified by the commentor, as well as many others, will be considered and
evaluated in the discussion process leading to the selection of the tritium supply
technology and the preferred site.

06 Biotic Resources

06.01 Commentors suggest that DOE carefully consider the potential impacts to area
wildlife when selecting a site for the proposed activities. Commentors assert that
special consideration should be given to sites such as Pantex that have several sensitive
species and habitats.
Response: An analysis of impacts on wildlife, including sensitive habitat and threatened
and endangered species, is presented for each site. This analysis is presented for INEL
in section 4.2.3.6, for NTS in section 4.3.3.6, for ORR in section 4.4.3.6, for Pantex in
section 4.5.3.6, and for SRS in section 4.6.3.6. The analysis is presented at a
programmatic level; however, since an analysis of project impacts on wildlife and
sensitive habitats is dependent on a specific site location and detailed project
engineering data, further analysis will be conducted at the site-specific level in tiered
NEPA documentation.

06.02 One commentor suggests that the PEIS for Tritium Supply and Recycling incorrectly
identifies the desert tortoise as an endangered species. The commentor states that the
PEIS should correctly classify the desert tortoise as a threatened species. Another
commentor notes that the executive summary indicates the bald eagle could lose nesting
habitat. This is not accurate and should be changed in the Final PEIS, according to the
commentor.
Response: References are made to the desert tortoise as a threatened species in sections
3.6, 4.3.2.6, table C-3, and table I.1-1. No references to the tortoise as an endangered
species are included in the PEIS. The executive summary states that the bald eagle may be
temporarily affected during construction but does not state that nesting habitat would
be lost.

06.03 The commentor states that the PEIS for Tritium Supply and Recycling asserts in a
number of places that construction of a tritium facility would affect Federal-listed,
Federal-candidate, or state-listed species, and could impact potential wetlands. More
specifically, the commentor adds that pages I- 31, I-32, I-35, and I-37 of volume II
reference possible impacts on the bald eagle, the swift fox, and other species. The
commentor asserts that this claim fails to recognize that construction activities would
occur well away from any of the Pantex playas (whose soils are inherently unsuited for
construction), which are the only potential nesting, foraging, and denning habitat for
these animals (e.g., no bald eagle nests or nesting pairs have ever been observed on
site). The commentor states that the Pantex playas constitute but 5 out of approximately
25,000 playas on the southern High Plains, and cannot be considered as critical habitat.
According to the commentor, personnel from the United States Fish and Wildlife Service
(USFWS) declined to support classification of any of the Pantex playas as "critical
habitat" during a site visit in 1994. Further, notes the commentor, only a small
proportion of the site (less than 7 percent) is designated as "playa wetlands". The
commentor cautions that any prudent site plan for tritium facility construction will
avoid these areas. The commentor also suggests that these claims in the PEIS should be
corrected.
Response: The commentor indicates that the PEIS assertions that the construction of a
tritium facility would affect Federal-listed, Federal-candidate, or state-listed species,
and could impact potential wetlands at Pantex are not warranted. These statements are
conditional descriptions of potential impacts. Section 4.5.2.6 states that field
surveillance would be required to determine the presence of listed species. The bald eagle
is described as a wintering species rather than a nesting species and it is well
documented that eagles are easily disturbed by human presence even in close proximity to
perched birds. It is further stated that there is no critical habitat on Pantex. The
playas are natural drainage areas for the Pantex site and the discharge resulting from
project activities could alter the nature of these wetlands. Because an analysis of
project impacts on biological resources is sensitive to specific site location and
detailed project engineering data, further analysis will be conducted at the site-specific
level in tiered NEPA documentation.

06.04 The commentor states that the PEIS for Tritium Supply and Recycling does not provide
a complete analysis of the impacts of the various alternatives on biotic resources. The
commentor also states that it is unacceptable not to evaluate the impacts of radionuclides
for onsite and offsite biota.
Response: An analysis of impacts to biological resources is presented for each site at a
programmatic level. This analysis is presented for INEL in section 4.2.3.6, for NTS in
section 4.3.3.6, for ORR in section 4.4.3.6, for Pantex in section 4.5.3.6, and for SRS in
section 4.6.3.6. Because an analysis of project impacts on biological resources is
sensitive to a specific site location and detailed project engineering data, further
analysis will be conducted at the site-specific level in tiered NEPA documentation.

06.05 One commentor states that siting the tritium program at Pantex would not further
threaten or endanger protected species. The commentor indicates that the PEIS notes on
page 4-279 that no critical habitat for threatened and endangered species exists on
Pantex, and on page 4-280 that there is little undisturbed habitat at Pantex that would
accommodate any of the threatened, endangered, and other special status species listed in
table 4.5.2.6-1. The PEIS also reports there are no Federal- or state-listed plant species
known to occur at Pantex. The commentor states that individual animals (for instance, slow
moving reptiles or small mammals) might be taken by construction activities but even this
possibility could be avoided (by surveys and by capture and transplantation) if deemed
appropriate. According to the commentor, the only consistently occurring Federal-listed
species at the Pantex site is the bald eagle. The commentor notes that the eagle is
highly mobile and the playa habitat it has used at Pantex is abundant nearby and common
throughout a great region. The commentor asserts that neither construction nor operation
of the tritium program would be expected to adversely affect the species. The commentor
notes that a representative of a second Federal-listed species, the whooping crane, was
reported at the site in 1990, as the draft relates. The rarity of occurrence of the
species on the site mitigates concern that it may be harmed by the program.
Relative to aquatic species, the commentor notes that it appears the only effect of siting
at Pantex would be positive (e.g., some small increase in the availability of habitat for
amphibians (page 4- 309)). Finally, another commentor points out that the terminology for
some of the endangered species is printed in bold print for the Pantex data only. The
commentor also states that there is also a grossly inaccurate statement in the PEIS on the
foraging and denning habitats concerning bald eagles and other animals that roam the
Pantex site. There will be no impacts to them, according to the commentor.
Response: The terminology in bold print was not located in the document. Because an
analysis of project impacts on biological resources is sensitive to specific site
location and detailed project engineering data, further analysis will be conducted at the
site-specific level in tiered NEPA documentation. Field surveillance would be conducted
at that time to determine the presence of species and their foraging, denning, and nesting
habitats.

06.06 The commentor states that DOE should give more thought to the effects of the
proposed facility on biotic resources. According to the commentor, the document states
that impacts to wetland and aquatic resources will not occur because these resources are
not located on project sites. The commentor adds that the conclusion that impacts will not
occur may be incorrect because impacted onsite groundwater may flow offsite and may affect
biotic resources. Furthermore, the commentor notes on page 4-139, the PEIS states that
because impacts from construction occur only at the beginning of the project life cycle,
it follows that impacts to biotic resources will be limited to only that time period. The
commentor asserts that this may not be true and suggests that DOE revisit the biotic
resources sections.
Response: An analysis of impacts to biological resources is presented for each site at a
programmatic level. This analysis is presented for INEL in section 4.2.3.6, for NTS in
section 4.3.3.6, for ORR in section 4.4.3.6, for Pantex in section 4.5.3.6, and for SRS in
section 4.6.3.6. Because an analysis of project impacts on biological resources is
sensitive to a specific site location and detailed project engineering data, further
analysis will be conducted at the site-specific level in tiered NEPA documentation. Onsite
impacts to wetlands and aquatic resources at INEL and NTS were not predicted based on the
fact that these resources do not occur on the proposed TSS. Impacts are also not expected
to wetlands and aquatic resources located offsite since groundwater withdrawals are not
expected to impact groundwater recharge rates at either INEL (section 4.2.3.4) or NTS
(section 4.3.3.4). With respect to construction impacts occurring only at the beginning
of the project life cycle, the statement made in section 4.3.3.6 referred specifically to
the fact that all construction associated with the HWR, MHTGR, and ALWR would only occur
at the beginning of the project but that additional construction (and hence construction
impacts) could occur at a later date, as in the case of the APT if expansion of the
facility were needed to meet future tritium requirements.

06.07 Regarding section 4.4.3.6, page 4-224, first column, third paragraph, the commentor
suggests that DOE provide information regarding the relationship between the number of
threatened and endangered species at a proposed site and the ranking of the site in the
selection process. For example, the commentor asks if a site has the potential to displace
more threatened or endangered species than another site, is it ranked lower in the site
selection process.
Response: The function of the PEIS is to assess the potential environmental impacts
resulting from the proposed tritium supply technologies and recycling facilities. The
potential impacts on threatened and endangered species are identified in the PEIS.
Environmental, cost, technical, and schedule factors are all considered in the siting
decision process. The tritium supply and recycling site selection process will involve
analysis of the environmental, cost, technological and schedule impacts which will be
considered by the decision maker.

06.08 In table 3.6-1, page 3-62, the ORR column, the phrase, "however this type of habitat
is abundant in the area," should be removed, according to the commentor. The commentor
asserts that this phrase appears to lessen the environmental impact of removing several
hundred acres of nesting and foraging habitat for four state-listed raptors.
Response: The appropriate changes have been incorporated into table 3.6-1 in the Final
PEIS.

06.09 The PEIS notes that no impact to biotic resources will result from supply and
recycling activities, according to the commentor. For example, the commentor states that
on page 4-64 the PEIS states, "...the Townsend's western big-eared bat could forage at
evaporation and stormwater retention ponds. No adverse impacts are expected...." The
commentor asserts that this statement is not supported by any factual data. Furthermore,
the commentor notes that although no state biotic resource consultation was identified for
INEL in table 5.3-4, DOE should confer with the appropriate state authorities to minimize
impacts.
Response: As a programmatic document, the PEIS discusses potential impacts and the
relative level of impacts. Because an analysis of project impacts on biological resources
is sensitive to specific site location and detailed project engineering data, further
analysis will be conducted at the site-specific level in tiered NEPA documentation.
Consultation with the Federal and state wildlife offices would be performed during the
preparation of this level of NEPA documentation.

06.10 One commentor states that in volume I, page 4-7, column 2, paragraph 3, the PEIS
explains that radiological impacts to onsite biota were not evaluated because studies
conducted at INEL have only detected sublethal effects in individual animals. The
commentor asserts that the fact that past activities have not caused radionuclide levels
of concern in animals is no indication that biota are not at risk. The commentor notes
that the impacts of the proposed tritium alternatives must be evaluated in conjunction
with potential releases from existing and proposed facilities, including the impacts from
tritium releases into waters that may already have measurable amounts of tritium. For
another, the commentor adds, the many studies conducted at INEL have shown elevated
levels of radionuclides in the tissues of plants and animals at the site. In order to
determine that the PEIS does not need to evaluate impacts on biota, there needs to be a
more thorough discussion of the findings of studies done at INEL, according to the
commentor. In addition, states the commentor, it must be shown that, cumulatively, tritium
releases will not have a significant impact. Another commentor suggests that the PEIS
provide details of biological and environmental impacts associated with introducing
tritium from proposed TSS operations into waters that already have measurable amounts of
tritium.
Response: As noted in section 4.1.6, two studies have shown that man is the most sensitive
organism to radiation (Radiation Biology (U.S. Atomic Energy Commission, 1968) and The
Effects on Populations of Exposure to Low Levels of Ionizing Radiation (National Academy
of Sciences, 1972)). In addition, the Environmental Standard Review Plans for the
Environmental Review of Construction Permit Applications for Nuclear Power Plant,
(NUREG-0555), notes that, "although guidelines have not been established for acceptance
limits for radiation exposure to species other that man, it is generally agreed that the
limits established for humans are also conservative for other species." Information
presented relative to INEL recognizes that measurable effects of radionuclides on indi-
vidual plants and animals have occurred, but that such effects at the population,
community, or ecosystem level have not been detected. A more complete discussion of these
findings can be found in the Programmatic Spent Nuclear Fuel Management and Idaho National
Engineering Laboratory Environmental Restoration and Waste Management Programs Final
Environmental Impact Statement (DOE/EIS-0203-F, April 1995). With respect to cumulative
effects of existing radionuclide levels and those emitted from the proposed facilities,
the second sentence of the third paragraph of section 4.1.6 has been changed to correctly
state, "these releases when added to those associated with other site activities would be
well below natural background levels and would also be within regulatory limits
established to protect workers and the public." It is not believed that further discussion
of radiological impacts to biota is necessary for this programmatic document.

06.11 The commentor notes that, as a newly constructed facility, a tritium recycling
operation would require radionuclide National Emission Standards for Hazardous Air
Pollutants (NESHAP) approval by EPA. If applicable to the site, the commentor notes that
EPA would evaluate the Endangered Species Act as a part of its radionuclide NESHAP
decision-making process; that is, EPA would assess whether radioactive emissions permitted
under a NESHAP authority would adversely affect any listed species under the Endangered
Species Act. As a part of the determination, the commentor states that EPA would consult
with the USFWS pursuant to section 7 of the Endangered Species Act. In addition, the
commentor also suggests that should DOE also need to consult with the USFWS, EPA is
willing to work with DOE on a joint consultation effort.
Response: DOE will consult with the USFWS concerning any impacts to threatened and
endangered species that may occur as a result of constructing and operating a tritium
supply and recycling facility, including potential impacts from radionuclides. This
consultation would take place at the site-specific level in tiered NEPA documentation.
This is necessary since preactivity surveys are necessary to determine if any special
status species are present and their location relative to the proposed facility. DOE will
make sure that all required permits are obtained and that all required consultations are
conducted.

06.12 Regarding section 4.4.3.6, page 4-226, first column, second paragraph, the commentor
suggests that DOE provide details of the effect of sediment mobilization and changes in
aquatic resources on CERCLA operable units in the area of the proposed TSS.
Response: A discussion of the relationship between impacts to aquatic resources from the
proposed tritium supply and recycling facility and CERCLA operable units is beyond the
scope of the PEIS. If ORR is selected as the site for a tritium production facility, more
detailed design, siting location information, and additional detailed project data would
be developed and available to discuss any relationship between the proposed action and ORR
CERCLA operable units. The analysis, if warranted, would be discussed in site-specific
tiered NEPA documentation.

06.13 The commentor believes that DOE overstates the environmental concern regarding the
Pantex playas (sections 4.5.2.6 and 4.5.3.6). The commentor points out that there are an
estimated 20,000 to 30,000 playas in the surrounding area whose sizes grow and diminish on
a seasonal basis. The commentor states that the playas all support the same, or highly
similar, plant and wildlife communities, and typically provide domestic livestock
watering places as well. Furthermore, the commentor notes that wastewater discharge to the
playas would not necessarily "cause a general degradation of the naturally occurring
ephemeral wetland system at Pantex." In fact, the commentor suggests that the permanence
of the playas in certain years may be "important to migratory birds and... valuable
habitat for nesting and wintering birds and waterfowl."
Regarding statements on page 4-307 about an increase in open water habitat and on page
4-309 about shifts in the composition of wetland plant communities, the commentor
suggests that DOE consider that it is the nature of playas to undergo temporary depth
changes and limited increases and decreases in open water areas. The plant species have
adapted to such changes, which have occurred down through the centuries (for example,
following major thunderstorms or long, rainy seasons or droughts). Such changes do not
"disturb" playa plant communities. Given the great commonality of habitats provided by the
great numbers of playas and the fact that wastewater discharges would create changes in
degree, not in kind, the commentor asserts that there is little practical reason for
environmental concern about the Pantex playas.
Response: While the commentor is correct in stating that a large number of playas occur in
the area of Pantex, many have been converted to agricultural use. An important aspect of
those occurring on the Pantex site is that, except for Playa 1, they are in a relatively
natural state and are within a protected area (that is, the Pantex site boundary). The
commentor is also correct in stating that playa vegetation has adapted to seasonal changes
in water levels; however, existing vegetation would not be able to adapt to permanent
inundation caused by wastewater discharges. The results would be a shift in plant
communities toward those that are adapted to permanent inundation. In fact, natural plant
communities in Playa 1 have been displaced by a nearly uniform stand of cattail, a plant
adapted to inundation. The analysis in the PEIS is presented at a programmatic level and
is intended to identify potential impacts which could occur as a result of constructing
new tritium supply and recycling facilities. A more detailed analysis of potential impacts
to site playas will be undertaken as part of a site-specific EIS if Pantex is selected as
the site for the proposed facilities.

06.14 In the PEIS, volume II, table C-3, under the plant section, the commentor states
that: Amargosa Penstemon should be Penstemon fruticiformis ssp. amargosae and that
Kingston bedstraw should be Galium hilendiae var. kinstonense.
Response: In 50 CFR Part 17, Plant Taxa for listing as Endangered or Threatened Species,
Notice of Review dated September 30, 1993, Amargosa Penstemon is listed as Penstemon
fruticiformis var. amargosae, and Kingston bedstraw is listed as Galium hilendiae ssp.
kinstonense. The appropriate changes have been made to the document.

06.15 The commentor states that DOE should indicate in the PEIS any records documenting
the existence of Parish's phacelia (Phacelia parishii) at NTS. The commentor adds that it
has been recently added to the Federal candidate plant species list.
Response: The appropriate changes have been made to the document.

06.16 The commentor states that SRS has a wildlife population that is within one of the
largest research sites in the United States. The commentor asserts that in order to
preserve and maintain this wildlife, SRS needs to assume another mission, preferably the
proposed Tritium Supply and Recycling Program. Continuation of DOE missions will ensure
that the surrounding wildlife remains intact, according to the commentor.
Response: Impacts of the proposed facilities on wildlife at SRS are discussed in section
4.6.3.6. The continuation of wildlife management and research programs, such as
controlled hunts and National Environmental Research Parks projects, are not directly
dependent upon the selection of the site for the proposed facilities.

06.17 One commentor urges a more even-handed and consistent analysis of biotic resources
in the executive summary and the PEIS. In addition, the commentor further notes that
there are subtle discrepancies in the analysis between the sites, and Pantex is unfairly
penalized due to the use of biased language. The commentor suggests that DOE check these
sections for unnecessary bias and use consistent terminology and language. Another
commentor suggests that table 3.6-1 list threatened and endangered species for each
candidate site with at least the specificity found in the Pantex column.
Response: The commentor suggests that the PEIS is written with a preconceived bias against
Pantex and recommends the use of more consistent terminology and language in the
executive summary, table 3.6-1, and site analysis of biotic resources in the PEIS. The
entire PEIS including the biotic resources sections of the PEIS was prepared and peer
reviewed without bias.

07 Cultural and Paleontological

07.01 The commentor expresses concern that the undertaking may affect historic properties
eligible for listing in the National Register of Historic Places (NRHP) at ORR. The
commentor expresses the desire to review a cultural resources survey report for the area,
in addition to DOE's assessment of the existence of historic properties within the area,
and DOE's assessment of potential for project impact upon cultural resources for this
project before any work commences.
Response: Historic properties that are potentially eligible for inclusion on the NRHP may
be affected, and are discussed in sections 4.4.2.7 and 4.4.3.7. If ORR is chosen as the
preferred site, a site-specific tiered NEPA document will include a discussion of impacts
to prehistoric and historic sites. In addition, if ORR is the preferred site, National
Historic Preservation Act (NHPA) section 106 would require a cultural resources survey of
any impacted acreage and a report of survey results. Cultural resources survey reports for
ORR are available through DOE.

07.02 The commentor states that a more even-handed and consistent analysis of cultural
resources in the executive summary and the PEIS is needed. According to the commentor,
there are subtle discrepancies in the analysis between the sites, and Pantex is unfairly
penalized due to the use of biased language. The commentor asserts that DOE should check
these sections for unnecessary bias and use consistent terminology and language.
Response: These sections were reexamined for any biases in the way the information was
presented. The language is similar among the different site descriptions in the PEIS and
in the Executive Summary.

07.03 The commentor references Native American resources text, under the Historic
Resources section, and states that the PEIS neglects to include Native American resources
when discussing compliance with Sections 106 and 110 of the NHPA, regarding the updating
of the buildings and the decontamination and decommission (D&D) actions on these
buildings and any historical properties. The commentor notes that the Native American
resources are absent from the same 106 requirements, as specified in the PEIS, and it is
only regarding the NEPA document. However, according to the commentor, other Federal
laws are requiring consultation between the Federal Government and the tribal governments
as mandated. In addition, the commentor references the last paragraph on page 4-9,
regarding the Native American resources, and asserts that the language regarding the
Native American resources does not apply the appropriate criteria. The commentor notes
that the PEIS acknowledges only the Native American physical environment and belief
systems; however, the issues go much deeper and are not being reflected within this
document being provided for comment.
Response: "Prehistoric resources" in the United States refers only to remains of Native
Americans and their antecedents. "Historic Resources" includes remains of all groups,
whether of European, African, Asian, Native American, or any other descent. Both historic
and prehistoric resources are protected under NHPA Sections 106 and 110. Other relevant
laws regarding tribal resources (American Indian Religious Freedom Act, Native American
Graves Protection and Repatriation Act) are described in table 5.3-1.
Impacts to land and water resources and other natural resources, which can also be
considered to be Native American concerns, are discussed in the other chapter 4 sections
(for example, in sections 4.2.2, 4.2.2.1, land resources; 4.2.2.2, site infrastructure;
4.2.2.3, air quality and acoustics; 4.2.2.4, water resources; 4.2.2.5, geology and soils;
4.2.2.6, biotic resources; 4.2.2.8, socioeconomics; and 4.2.2.9, radiation and hazardous
chemical environment). More details can also be found in the appendixes.
The following text change has been made to section 4.1.7: "In addition, cultural values
are placed on natural resources such as plants, which have multiple purposes within
various Native American groups." Section 4.3.2.7 now includes: "It is worth noting that
many natural resources at NTS are viewed as cultural resources by Native Americans. As one
example, sagebrush is used as a tool, and for clothing and medicinal purposes."

07.04 The commentor references page 4-311 of the Draft PEIS and questions if "would" in
the sentence "Some Native American (archaeological) resources would occur in Pantex site
areas" should read "could."
Response: The referenced sentence has been changed to "Some Native American resources
could occur within any areas disturbed..."

07.05 The commentor concurs that there exists a possibility of undiscovered cultural and
paleontological resources at Pantex that might be affected by construction of a tritium
supply and recycling facility. The commentor also concurs that such resources could be
protected by typical mitigation measures.
Response: Potential cultural and paleontological resources at Pantex are discussed in
section 4.5.2.7. If known cultural and paleontological resources at Pantex (or at any
other selected site) are within areas subject to potential impact, DOE would protect the
resources to the extent possible, first through avoidance of the resources, and second,
through mitigation of impacts. The possibility of undiscovered cultural and
paleontological resources is always a consideration. Site-specific cultural resources
analyses would be conducted as part of a subsequent, tiered EIS. In onsite areas having a
high probability for cultural resource discoveries, measures that can be taken to minimize
potential impacts include employment of an archaeological monitor during construction and
stopping work in the event of an unforeseen discovery.

08 Socioeconomics

08.01 The commentor suggests that DOE address in the PEIS the quality of jobs and benefits
that will be created as a result of a new tritium facility. The commentor also states
that DOE should include a comparison of the types of jobs that were associated with
various cleanup activities at INEL with more complex and higher technology projects that
would be associated with a new tritium facility.
Response: Labor categories (types of jobs) were considered in the socioeconomic analysis,
but were not specifically identified in the Draft PEIS. Instead, only total worker years
were analyzed and compared. More detailed information on the labor categories involved is
contained in the Technical Reference Report available in DOE reading rooms. Specific
socioeconomic impacts will also be further considered in site-specific tiered NEPA
documents.

08.02 Several commentors express their support for this action in the NTS region. The
commentors believe the project will increase the growth of the scientific community and
science/technology related business; reinvigorate the area economy and tax base; stimulate
light industry development in Las Vegas; and provide highly skilled technical and
management positions to experienced craftsman, technicians, and scientists who may have
lost jobs during the phaseout at NTS. One commentor also notes that there will be a lot of
public support if DOE can assure the public that tritium transportation and production
will be fairly safe. Another commentor states that NTS already has the available land,
skilled craftsmen, technicians, and scientists to support the tritium supply and recycling
facility.
One commentor suggests that siting the tritium supply and recycling facility at NTS can
improve DOE's image within the community by working together to contribute to the
positive growth of the community and its economy. Another commentor, expanding upon the
idea that locating the tritium supply and recycling facility at NTS helps the community,
states that NTS has been good to minority workers providing much needed training and
experience. According to the commentor, NTS contributes a solid education for the
workers and prepares them for other responsibilities and tasks. Another commentor believes
that DOE has spent too much time on waste disposal capabilities, and suggests that DOE
recognize the high-technology security work force as a valuable resource for stockpile
stewardship and management activities.
Response: The attributes of NTS as well as each of the other four sites considered for
siting the tritium supply and recycling facility would be included as part of the
decision making process. However, the PEIS considers these site factors only as they
relate to evaluating the environmental impacts of the tritium supply and recycling
facility at each site. In addition, transportation analyses were performed for all
materials considered in the PEIS, and risks were found to be low. Other DOE programs,
including those evaluating stockpile stewardship and management activities, will also
evaluate these candidate sites in accordance with NEPA and take socioeconomic factors into
consideration.

08.03 Several commentors state that DOE should review the socioeconomic analysis to
incorporate the following: that construction jobs will only be temporary; scientists
and skilled workers will be drawn to NTS because of the new facility; there are potential
job losses in regions that are not awarded the Tritium Supply and Recycling Program; a
review of the accuracy of the projected employment figures as new jobs may be staffed by
former employees of shutdown DOE facilities; an analysis of jobs that will be created at
facilities supporting the planning and engineering studies necessary for the tritium
supply and recycling facility such as at Los Alamos; the need for skilled workers created
by the new facility compared with the pool of skilled workers in each site's surrounding
area; transportation, electrical, water, and other environmental impacts from
out-of-region people who move to the area to work at Pantex; and the potential spawning of
new production or fabrication facilities to support the tritium supply and recycling
facility and its operation.
Response: The PEIS identifies that construction jobs are temporary. The increase in
construction jobs, the peak, and the decrease in construction jobs for each tritium
supply technology at each candidate site have been analyzed and are presented in the PEIS.
The PEIS also assesses the potential impacts caused by newly created jobs which lead to an
in-migration. Labor availability is taken into ac