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 account but employment estimates are conservative to measure in-migration and its effect on the surrounding communities. The projected employment numbers at each candidate site in the year 2010 were estimated based on the best available information on the expected mission and workloads for that site. It is not clear at this time without knowing the selected technology for tritium supply where the planning and engineering will take place or by whom, but it is unlikely that many new long-term employment would be created by this phase of the project. At the candidate sites, projected employment is expected to remain essentially the same or decrease as shown in table D.2.1-1. Although the number of employees may be the same, the types of jobs and staffing categories may be substantially changed. The tritium supply and recycling project will create employment opportunities wherever it is located. Only tritium recycling related jobs at SRS would be lost if tritium recycling is collocated with tritium supply at a site other than SRS. The impacts due to tritium recycling phaseout at SRS are evaluated in the PEIS. 08.04 Commentors express their support for this action in the SRS region. Some of the reasons for this support are: that the multipurpose reactor would create over 4,000 high-tech jobs in the SRS and Charleston region, offsetting defense-related cutbacks; there is a need for additional jobs in this area as there has been a recent manpower downsizing; a qualified work force exists at SRS with 40 years of experience; and if the tritium recycling responsibilities were removed from SRS, more than 800 people would lose their jobs, engendering long term impacts at SRS. As an example of local and political support, one commentor refers to an article in the Augusta Chronicle and points out that supporters of the tritium supply and recycling facility at SRS outnumbered "antis" at the workshops. According to the commentor, the large number of participants, including United States Representative Graham, and the Metro Augusta Chamber Chair, lent support to SRS because of expertise and infrastructure already in place to build and sustain a multipurpose reactor. Response: The attributes of SRS 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 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. For SRS, the Replacement Tritium Facility, the amount of available land and water, compliance with environmental regulations and agreements, site waste management activities and facilities, and the surrounding local economies are all included in the environmental analysis of impacts. Although the local and political support for a multipurpose reactor have been voiced and are factors, they are not considered in the environmental analysis process presented in the PEIS. 08.05 Commentors state that there is support for this action in the Pantex region for the following reasons: employees at a tritium facility are an asset to the Panhandle's economy; the business community in Amarillo would benefit and the jobs would be filled by people from the community; and there is an over-80-percent public approval of Pantex and its missions. On the other hand, another commentor states that in the event of an incident at Pantex, crops and livestock in the nation's "breadbasket" would be perceived to be contaminated, destroying a multi-billion-dollar annual agriculture industry. Response: The attributes of Pantex 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. The impacts referred to by the commentor are considered "secondary impacts." The secondary impacts of accidents affect elements of the environment other than humans. For example, a radiological release may contaminate farmland, surface and ground water, recreational areas, industrial parks, historical sites, or the habitat of an endangered species. Section F.3 of volume II discusses the potential secondary impacts that potentially could occur from a design-basis accident for a typical reactor at each of the sites considered in the PEIS (section F.3.4 deals specifically with the effects at Pantex). 08.06 Commentors state that there is support for this action in the INEL region for the following reasons: the potential boost to Idaho's economy and technology base; the technology exists to handle nuclear waste; and that initiating tritium operations at INEL would help unemployment in the area. Response: The attributes of INEL 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 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. 08.07 Several commentors state that DOE should review the socioeconomic analysis, particularly for the NTS area, and incorporate the following: the economic multiplier for the NTS area should include not only indirect jobs, but also induced jobs (third level of job creation); Southern Nevada per capita income figures in the year 2010 seem low and may need to be adjusted; tourism may be affected negatively by the new facility; and the new facility may interfere with future housing and development needs or the new facility may have unforeseen effects on as-yet unbuilt housing. Response: The economic multiplier used in the PEIS analysis includes the household sector which also includes the induced employment in the multiplier. The term "indirect" includes both induced and indirect, and was used to be more understandable for the general public. The year 2010 per capita income figures presented in the PEIS were based on the Bureau of Economic Analysis most recent long-term published regional forecasts. Tourism in the Las Vegas area has continued to increase substantially over the years even in light of nuclear testing at NTS. It is highly unlikely that the addition of a tritium supply mission at NTS would affect tourism. The effects that any of the proposed tritium supply facilities would have on housing in the area of Las Vegas were examined in the PEIS and found to be negligible. 08.08 Commentors express concern about the construction start times for the tritium supply and recycling facility and the availability of jobs in the NTS area. One commentor states that DOE should begin work on the tritium supply and recycling immediately at NTS and not wait until the year 2000 to begin construction to offset the ongoing downsizing and provide jobs and money to the local economy. Additionally, the commentor states that there is a shortfall of work, and that there is a risk of losing more skilled workers if the project does not begin soon. Another commentor notes that the local, experienced NTS workforce (25,000 union workers) has an excellent safety record at NTS and is in place right now and can begin immediately. The commentor states that DOE should be concerned that local people benefit from the jobs, instead of people from outside of the region. The commentor notes that many components for the tritium production facility could be manufactured locally. The commentor states an aggressive contracting program with an emphasis on obtaining required components locally would enhance the region's manufacturing base. Furthermore, according to another commentor, the PEIS should consider current and future downsizing in its socioeconomic analysis of the NTS area. The commentor also adds that the downsizing at NTS should also be taken into account when making a decision as to the location of the Tritium Supply and Recycling facility. Response: Construction start times and hence start dates vary depending on the technology. Start dates in the PEIS were established around a peak construction date of 2005. This was done so that the potential environmental impacts of each technology could be compared. However, the construction of a tritium supply facility would not occur before the appropriate tiered NEPA documents were completed, and detailed engineering designs of the facility completed. Labor availability is included as a component in the socioeconomic modeling performed in preparing the socioeconomic analysis for the PEIS to determine the potential in-migration of population and community effects caused by the proposed project. 08.09 The commentor states that DOE should address the size and surrounding population density of ORR relative to other DOE candidate sites (to assess cumulative impacts). Also, relative population density maps would be helpful, according to the commentor. Response: As described in the methodology discussion detailed in appendix D, the Region of Influence (ROI) developed for each site was based upon where the current DOE employees and contractors reside, and assumes that any in-migration would locate proportionately in the same places. Any effects of in-migration in those communities where in-migration is most likely to occur would be indicated in the analysis regardless of current or expected population densities. 08.10 Commentors state that DOE should be more accurate in determining the actual number of jobs that will be provided with this project. DOE's estimates for the total number of construction and operation workers for each of its technology alternatives appears to be inflated according to one commentor. This overestimation is unwise because various locales lobby to be chosen for a particular alternative based on these values. Another commentor asserts that, in the past, DOE often overexaggerated the number of potential jobs associated with a proposed project to strengthen the selling point of the project. The commentor states that, when compared to the New Production Reactor project, the Tritium Supply and Recycling Program seems to have a longer employment period, making the Tritium Supply and Recycling Program appear attractive in job-starved regions. In addition, the commentor adds, the predicted projections may not be representative of the number of people in the region that benefit from the project. It seems grossly exaggerated that 12,000 jobs would be created in the ORR region, according to the commentor. Additionally, the estimate of an operational workforce of approximately 290 persons at a 500 to 600 MWe coal-fueled steam electric plant is double the staffing of similar plants, according to one commentor. Another commentor references page 5-21, finding the estimate for employment at a mixed-oxide facility seems to be high. However, if pit disassembly and conversion are included, then the number might be more reasonable. 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 account but employment estimates are conservative to measure in-migration and its effect on the surrounding communities. The projected employment numbers at each candidate site in the year 2010 were estimated based on the best available information on the expected mission and workloads for that site. At the candidate sites, projected employment is expected to remain essentially the same or decrease as shown in table D.2.1-1. The estimated operational workforce for the coal-fueled steam electric plant has been revised from 290 persons to 145 persons. Pit disassembly and conversion is included in the estimate for employment at a mixed-oxide facility. 08.11 Several commentors state that DOE should review the socioeconomic analysis pertaining to the Pantex area and incorporate the following socioeconomic issues: the economic multiplier that DOE used on their overheads appears wrong and, therefore, the PEIS should be checked for this mistake as well; and the River Road Independent School District north of Amarillo should be added to the Independent School District likely affected by the proposed action. Response: The economic multipliers used in the PEIS socioeconomic analysis were developed from the AFSEM model described in appendix D. This model is based upon United States Bureau of Economic Analysis Regional Inter-industry Multiplier System (RIMS) II multiplier coefficients, which are widely accepted and have been deemed to be accurate for the PEIS analysis. An underlying assumption used in this PEIS for addressing potential socioeconomic impacts was that the inmigrating population would locate in areas similar to the existing residents. Data on table D.3-52 shows that almost all the Pantex workers living in Potter and Randall Counties live in Amarillo and that only 58 workers live in unincorporated areas of Potter and Randall Counties. If all 58 workers lived in unincorporated Potter County this would be only 2 percent of the Pantex workforce. It was therefore determined that even if all 58 workers' children attended schools in River Road Independent School District that this would constitute only 2 percent of any effects that the proposed alternative would cause, and as such these effects would be negligible. 08.12 The commentor states that this PEIS should not focus on jobs. According to the commentor, this element changes the focus from nuclear weapons to maintaining jobs and economic stability, thus causing a potentially wrong basis for a decision. Response: The purpose of the PEIS is to assess potential environmental impacts. In socioeconomics, potential impacts could be caused by too many jobs leading to larger in-migration too quickly for the community infrastructure to absorb. The increase in jobs as analyzed in the PEIS does not pose significant environmental impacts and some people consider the jobs a positive benefit. 08.13 The commentor suggests that DOE clarify the basis for the calculation of the impacts to the NTS ROI. The population and housing projections assume that people would reside in cities and counties in the same relative proportion as the existing population. The commentor asks if the ROI includes only specific portions of the four-county area surrounding NTS and what the boundaries are. The commentor references volume II, table D.3-23, stating that the population estimates for Nye County appear to be underestimated. The commentor provides a contact for DOE to obtain current population figures. Response: The NTS ROI covers the entire four-county area surrounding the site, but the magnitude of the impacts was determined by the distribution of NTS employees within the ROI. Therefore, jurisdictions within the ROI with larger numbers of resident NTS employees would be more greatly affected by the proposed alternatives than those with fewer resident employees. The population estimates were based on the most recent Bureau of Economic Analysis regional projections, but because the NTS area is one of the fastest growing regions in the United States these projections are constantly changing. Nonetheless, given that Clark County is so much larger than Nye County, most of the impacts would still be found in Clark County, and any additional updating of the population estimates would not substantially change the results of the analysis. 08.14 The commentor references volume I, page 4-313, and notes that the number of jobs in the Amarillo area would increase more if the No Action alternative was chosen. Therefore, the commentor supports No Action for Pantex. Response: Under No Action, Pantex employment is expected to decrease from the 1994 level and total employment in the Amarillo area is expected to increase. However, as shown in figure 4.5.3.8- 1, total employment would increase over No Action if a tritium supply and recycling facility were located at Pantex. 08.15 The commentor states that, in figure 4.4.3.8-5, it is presented that for most of the proposed alternatives, increases in revenue to the city of Clinton and the Clinton schools would greatly exceed increases in required public expenditure, while for all other ORR governments increased revenues would be about the same as increased expenditures. The commentor asserts that this prediction may be erroneous and suggests a check for errors be made in the economic models. Response: The purpose of the public finance analysis is to determine if there would be any adverse environmental impacts on local government fiscal health and the ability to provide services. Generally, most local governments tend to have fairly balanced financial statements and if there are negligible to minimal effects caused by a proposed alternative this balance would remain unchanged, although revenues and expenditures would rise. This was the case for most of the ORR local governments. The city of Clinton was an exception to this because its recent trend data indicated a disproportionately large fund balance which was carried forward in making No Action and project alternative predictions. It is likely that this excess was created and planned for spending on a capital project or some other expenditure and would not have been carried forward as in our analysis, and the result would be a more balanced expenditure-to-revenue ratio. However, our methodology (described in section D.2.3) cannot account for undocumented planned expenditures, and the analysis is concerned with the environmental aspects of whether or not a local government would be fiscally damaged by the proposed alternatives. This analysis shows that the proposed alternatives would not negatively impact the city of Clinton and would instead provide some financial benefit. 08.16 The commentor references volume I, chapter 4, section 4.4.2.6, page 4-188, second column, second paragraph and suggests that an analysis be provided of the effects on the local economy (e.g., recreational sports, State of Tennessee wildlife resources license and permits sales) from displacing game animals from several hundred acres of regularly hunted land and possibly forcing those animals toward more contaminated areas of ORR. Response: Local government finances were evaluated in the PEIS. Licenses, permits, and fines were included in these analyses where local governments collected these types of revenues. These revenues are a small part of these local government budgets. Considering the small acreage involved with the proposed project and the extensive recreational opportunities in the ORR area, it is unlikely that there would be even a small effect on these governments' budgets. It should be noted that the primary purpose of conducting controlled hunts on ORR is to reduce collisions between deer and automobiles. Recreational and economic benefits of this activity are secondary to the primary goal of public safety. Deer displaced from the proposed TSS would migrate to other areas of the ORR. Since areas of the site that are a problem with respect to contamination are fenced and monitored, displaced deer would not have access to these areas. All deer harvested during controlled hunts are monitored for contamination prior to being released to the hunter. 08.17 The commentor references volume II, appendix D and suggests that a comparison be provided of the cost advantages of labor vs. the cost of supporting the laid off workers, as some workers may be in pre-retirement years. In such cases, the newer employees would have to be hired and trained, according to the commentor. Response: Cost analyses associated with phasing out tritium recycling at SRS are included in the Technical Reference Report available in DOE reading rooms and will be factored into the ROD. All other candidate tritium supply and recycling sites would have job increases. 08.18 The commentor references volume I, page 4-67, employment and local economy, under No Action: "...employment at INEL decreased to approximately 10,100 persons in 1994. This is a decrease of about 1,000 persons from the 1990 employment. INEL employment is projected to total almost 10,100 persons in 2010 and remain at this level through 2020." The commentor states that these figures need to be revisited. The commentor adds that in early 1995, approximately 1,200 INEL employees took early retirement or voluntary separation and another 1,000 may be laid-off later in 1995. The end of Naval reactor training at INEL and the departure of several hundred Navy personnel, many with dependents, also needs to be factored into the PEIS estimates, according to the commentor. Response: The size of the workforce at the affected DOE sites is constantly changing due to ongoing changes within the Complex. The employment figures used in the PEIS were the most recent figures obtained from INEL. The focus of the analysis was the assessment of the impacts associated specifically with the proposed alternatives using conservative assumptions, and it is not possible to analyze all possible future employment scenarios. However, under the scenario described by the commentor, potential negative socioeconomic impacts associated with the proposed alternatives (e.g., overcrowded schools, reduced housing availability, etc.) become less probable. 08.19 In reference to volume I, pages 4-479 and 4-480, figure 4.15-2, the commentor states that there is a problem with the scale and/or positioning of the INEL site as shown on this map. The commentor points out that the INEL site does not extend into Montana. According to the commentor, the 50- mile circle on this map also appears to be too large and/or incorrectly positioned; it should be approximately tangent to the southernmost point on the Idaho-Montana border. Response: The commentor is correct. The graphic has been changed to depict INEL's location and 50-mile radius more accurately, similar to the depiction of INEL in figure 4.2-1. 08.20 In reference to volume II, page D-8, table D.3-1, the commentor states that this table shows that approximately 74 percent of the INEL employees reside in Idaho Falls and 76 percent in Bonneville County. Yet, according to the commentor, the text that accompanies this section implies that the effects of building a tritium supply and recycling facility at INEL would be spread out over the region of influence. The commentor notes that such effects would be much more concentrated and localized than the PEIS indicates. Response: The PEIS examines the socioeconomic impacts within the entire ROI. As described in the methodology discussion in appendix D, the assumption was made that any in-migration would follow the same pattern as the existing workforce and, as such, effects would be proportionately greater in those places where the current workforce resides. The PEIS analysis measures the effects at the ROI, county, and city levels. 08.21 The commentor references volume I, pages 4-477 and 4-478 of the PEIS, which discusses environmental justice considerations associated with the project, including maps depicting minority and low income population distributions in Idaho, Tennessee, Texas, and South Carolina, within 50 miles of the DOE proposed site. The commentor recommends that a Nevada map be added because the 1990 United States Bureau of Land Management Nevada state map shows the Las Vegas Paiute Indian Reservation is located approximately 40 miles from the southeast corner of the NTS. Response: Additional maps have been included in the Final PEIS depicting minority and low- income populations in the vicinity of NTS. 08.22 The commentor notes that page 4-478 states that any disproportionately high, adverse health or environmental impacts on low-income or minority communities "would most likely result from toxic/hazardous air pollutants and radiological emissions." Although agreeing that such pollutants and emissions are highly significant, the commentor suggests that the PEIS analysis be expanded to assess groundwater withdrawals for NTS technologies. The commentor states, in light of the tremendous importance of groundwater in the western United States, that the PEIS assess any potential impacts to Native American communities and reservations associated with pumping groundwater, since the loss of groundwater to Native American populations can have a significant, adverse impact to agriculture- and livestock-based tribal economies. Response: As discussed in section 4.16, the analysis of impacts for each of the candidate sites indicates that even if there were any health impacts to minority and low income populations, these impacts will not have disproportionately high and adverse affects; therefore, adverse impacts to agriculture- and livestock-based tribal economies will be negligible. Based on revised recharge rates for the NTS aquifer system, no adverse impacts are expected. Implementation guidelines for the President's recent Executive Order 12898, Federal Action to Address Environmental Justice in Minority Populations and Low-Income Populations are still in draft form. This issue will be analyzed in more detail in site-specific tiered NEPA documents once a site has been selected. 09 Intersite Transportation 09.01 The commentor believes that DOE should provide a separate EIS to address the issues of transportation in more detail. Response: The intersite transportation section 4.7.2 has been expanded based on public comments received during the review of the Draft PEIS. DOE believes the analysis of intersite transportation impacts presented in the Final PEIS is appropriate for a programmatic NEPA document. A more detailed intersite transportation assessment would be prepared for site-specific tiered NEPA documents when a tritium supply technology and site are identified. 09.02 The commentor expresses the opinion that DOE should consider transportation as one of the selection criteria. Under that criterion, the commentor believes that NTS would be a suitable location because there is no need to transport wastes offsite. The commentor also notes that disposal options for all waste streams exist onsite. Response: Intersite transportation of Complex material is a consideration in the decision process and has been evaluated in this PEIS. Waste streams were also evaluated, including low-level radioactive waste. As stated in section 4.7.2.2, LLW can be disposed of at all candidate sites except Pantex. Impacts from the transport of LLW from Pantex to NTS are presented in table 4.7.2.2-2. The waste management program and facilities at NTS are discussed in section 4.3.2.10 and appendix H.2.2. 09.03 The commentor urges DOE to ensure that shipments of solid LLW from Pantex to NTS or SRS are handled with the utmost precaution and personnel screening. Response: All DOE shipments of LLW, including those from Pantex to NTS, are shipped in the Department of Transportation (DOT)-approved containers/packages in accordance with all applicable Federal and state regulations, and DOE orders. DOE does not ship LLW from Pantex to SRS. 09.04 Commentors express concern over the shipment of radioactive materials/waste to INEL. One commentor is opposed to such shipments while another commentor expresses concern about the safety of nuclear waste-carrying casks that are transported through the town of Shoshone, ID, "at 60 mph." In addition, the commentor believes that DOE should address in the PEIS the possibility of derailments, based on the four train derailments that have occurred in the last 6 months near the town of Shoshone. On a broader scale, another commentor feels that DOE must account for all INEL- and non-INEL-related radiological materials that are being transported across Idaho. The unprecedented level of radiological material movement associated with upcoming DOE decisions must be comprehensively evaluated. Response: As part of the Tritium Supply and Recycling Program, DOE is not proposing to ship any spent nuclear fuel or radioactive waste to INEL. Shipments containing radioactive materials would be made in compliance with Federal hazardous materials transportation regulations (DOT and/or NRC, as applicable). As stated in section 4.7.1.1, tritium shipments are made almost exclusively by air, and not by rail. Radioactive material shipments are required by Federal regulations to be made only in high integrity packaging. The DOE safety record is exemplary, as there has never been a transportation accident involving a release of radioactive material. 09.05 Commentors express concerns with railroad transportation at NTS. If the APT is selected for supply and recycling, one commentor believes that there is no need for a railroad line to NTS for tritium production. In addition, another commentor also states that an emergency management plan/structure for accidents on rail or road is needed for NTS. The commentor believes that responsibilities involved in such a plan should be clearly defined as to whether it is local, state, or Federal responsibility. DOE's planning in this area is not adequate and should incorporate the Department of Defense (DOD) experience and knowledge in shipping hazardous waste. Response: There is no requirement for a railroad for the APT option at NTS and it has been deleted from table 4.3.3.2-1. Tritium would be transported by air (not rail, and rarely by truck). DOE has an established emergency response program, which is promulgated in DOE directives (principally in series 5500). These directives are implemented and supplemented by NTS's emergency response procedures. In any case, DOT is responsible, under the Hazardous Materials Transportation Uniform Safety Act of 1990, for coordinating Federal training programs and for providing technical assistance to states, tribes, and local governments for emergency response training and planning. 09.06 The commentor notes that DOE uses inconsistent terminology in the intersite transport section of the executive summary. The commentor believes that the wording of the "relative transportation risk of tritium" paragraphs should be changed to make this section consistent. Response: The phrasing of the relative transportation risk is different between the executive summary and section 4.7, although both are correct. The discussion in section 4.7 has been revised to be more consistent with the summary. 09.07 The commentor references volume I, page 4-14, column 2, paragraph 3 and pages 4-437 to 4-441, section 4.7, and asks whether an assessment of the impacts of transportation of reactor fuel or spent fuel from the sites was analyzed. At a minimum, the commentor believes the rate of spent fuel generation in metric tons of heavy metal should be provided so that it can be compared to other sources. Response: The transport of reactor fuel and highly enriched uranium for HWR and MHTGR fuel fabrication has been added to the Final PEIS analysis. Reactor fuel would be provided from and transported by commercial vendors. Reactor fuel is routinely transported throughout the United States. The radiological health risks from transporting reactor fuel are expected to be very low and would not vary significantly regardless of the site selected. This transportation risk would be evaluated in more detail in site-specific tiered NEPA documentation once a site is selected. Spent fuel would be stored onsite during the life of the project. The Final PEIS now includes the spent fuel generation in metric tons of heavy metal. 09.08 The commentor suggests that the DOD share shipping knowledge with other agencies. Response: DOE and DOD must comply with and ship materials in accordance with the same DOT regulations (49 CFR). Shipments of tritium and other weapons complex materials between DOE and DOD sites are closely coordinated. 09.09 Commentors express concerns about the transportation of large amounts of tritium. One commentor suggests that the nuclear weapons stockpile stewardship and management program may be centered at a distant site (other than SRS) where the tritium recycling facility is presumed to be located in the year 2010. This raises questions concerning transportation of large amounts of tritium to and from another location (other than SRS) according to the commentor. The commentor is concerned that the cost impact of this transportation of tritium is not being evaluated; and inquires whether states, counties and municipalities can stop such shipments from passing through their jurisdictions to make this proposition invalid in 2010. Another commentor also asks what the risk is to transport tritium to and from assembly and disassembly sites. While the PEIS addresses the risk of moving low-level waste from Pantex to a DOE disposal site, the commentor believes the analysis fails to consider the risk of transporting tritium containers from the assembly/disassembly site to the tritium site. In addition, the commentor notes that the executive summary states that the relative transportation risk of tritium at NTS is 30 percent lower than the No Action alternative and asks how this was concluded since, under the No Action alternative, Pantex is the assembly/disassembly site. Another commentor references the PEIS alternative of producing tritium at one facility and then recycling the tritium at SRS. According to the commentor, other than the transportation of virgin tritium, which is addressed in section 4.7.2.2, the environmental impacts associated with extracting the tritium at the production facility, loading it into some sort of transport container, transporting the containers from the production site to SRS, and then unloading the containers at SRS are not addressed in the Safety Analysis Report. In any case, some commentors feel the increased costs of the additional handling, along with unnecessary health/environmental risks associated with transportation of tritium and related hazardous wastes, would seem to argue for a collocation alternative with the facility at one site. Response: The PEIS evaluates environmental impacts due to intersite transport of project radioactive materials; cost impacts are not addressed in the document. The cost analysis for each tritium supply technology can be found in the Technical Reference Report available in DOE reading rooms. The cost analysis along with the PEIS results will be evaluated and considered as part of the ROD. Transportation of tritium between all candidate sites (not just SRS) is addressed in the PEIS. Shipments would be made in compliance with Federal hazardous materials transportation regulations that supercede those of state and local jurisdictions. Inconsistent state and local regulations are preempted by the Federal Hazardous Materials Transportation Uniform Safety Act of 1990. Placing only tritium supply at INEL, NTS, ORR, or Pantex and transporting tritium by air to SRS would increase the relative risk by approximately 2 percent per year, as explained in section 4.7.2.2. Handling was considered in determining the consequences of an accidental tritium release during transport. The relative transportation risk of shipping tritium is related to the current location of the tritium recycling facility at SRS and the assembly/disassembly facility at Pantex. Moving the tritium supply to NTS and retaining assembly/disassembly at Pantex would decrease the risk by 30 percent due to the shorter distances involved. 09.10 The commentor references volume I, chapter 3, table 3.6.1, intersite transport, page 3-95, ORR column, first paragraph and asks for clarification on why no intersite transport of LLW would be required. Response: For the purposes of this PEIS analysis, the planned LLW disposal capability at ORR was assumed to be available in 2002; thus, no offsite transport of LLW would be required. 10 Waste Management 10.01 Commentors suggest that the Nevada Test Site has a superior waste management capability. The commentors further note that since it has existing low-level radioactive waste disposal facilities, it could avoid the need for transporting wastes from tritium production facilities if such production were located at NTS. According to the commentors, NTS is isolated, has plenty of room for expansion, and has been a repository for other sites' wastes. Response: The waste management capability at NTS has been discussed and analyzed as part of the tritium proposal in the PEIS. The PEIS analysis, including waste management issues, and other supporting program reports will be considered in the process leading up to the decision presented in the ROD. 10.02 Commentors note that DOE needs to seriously address the short-term and long-term nuclear waste disposal issue before undertaking a new project that will generate more spent fuel, more LLW, more hazardous waste, and more sanitary waste. The commentors state that no new wastes should be generated until all other wastes have been cleaned up, as cleanup should be a first priority. Commentors are of the opinion that there is no way to dispose of spent nuclear fuel in the United States, and the operation of the tritium supply and recycling facility will further add to the volume, no matter where it is located. One commentor states that disposal of high-level radioactive waste in the vadose zone will prove to be unacceptable, resulting in longer delays in putting a repository into operation. Moreover, commentors believe wastewater from tritium production could pollute groundwater resources in Amarillo. Adding additional waste at NTS, which has become a weapons waste dumping ground in the commentors' opinion, would only add to the problem there. Commentors feel that the costs of short-term and long-term cleanup should also be presented in the PEIS. Another commentor states that Oak Ridge needs money to clean up radioactive mess left by past practices. Response: As stated in chapter 2, DOE is responsible for developing and maintaining the capability to produce nuclear materials that are required for the defense of the United States. This responsibility includes the production of tritium. Because tritium decays over time, a new supply of tritium will be needed in the future. A major thrust of the Tritium Supply and Recycling Program has been, and will continue to be, the minimization of wastes through an overall philosophy of pollution prevention. Tritium supply and recycling facilities that will support the nuclear weapon stockpile requirements (both new and existing facilities) would treat and package all waste generated into forms which would enable long-term storage and/or disposal in accordance with all applicable Federal and state regulations and DOE orders. Materials will be stored until a final disposition is determined. The alternatives include a technology that does not generate spent nuclear fuel. Dry site designs for the various tritium supply technologies include provisions for maximum recycle of any wastewater in order to minimize liquid discharges from the facility. Any liquid discharges would be fully permitted by the applicable Federal and/or state regulatory authority. 10.03 One commentor suggests that DOE should analyze long-term waste management costs from the tritium production facility throughout its life and after closure. The commentor also asks that DOE use correct LLW figures in the "Waste Management" overhead used at the public hearings. Moreover, the commentor believes DOE should be alarmed by the massive increase in LLW generation (from 25yd3 per year to 15,980 for HWR). Commentors urge DOE to break down wastes by type, volume, disposal methods, and costs. Response: The PEIS does break down waste by type and volume. In the waste management envi- ronmental impacts section for each site the disposal method was discussed for each waste type. The cost analysis for each tritium supply technology can be found in the Technical Reference Report available in DOE reading rooms. To the extent practical, the long term management of those wastes is addressed in the Technical Reference Report. The cost analysis along with the PEIS will be evaluated and considered as part of the ROD. As shown in table A.2.1.1-4, section A.2.1.1 the annual LLW volume to be disposed of is 1,870 yd3 for the HWR. This would be added to the 117 yd3 (table 4.2.2.1-4, section A.2.2.1) from the recycling facility for a total of 1,987 yd3 per year. 10.04 The commentor indicates that spent fuel wastes from a multipurpose reactor program will be treated in the same manner as spent fuel from commercial reactors and this is an important characteristic of such an option. Response: The management of spent nuclear fuel from a multipurpose reactor would be done in the same manner as that described for the tritium supply reactors. A spent nuclear fuel storage facility capable of stabilizing and storing the spent nuclear fuel generated during the design life of the reactor will be constructed as part of the facility. If, at some point in the future, a Spent Fuel Repository is established, then the fuel would most likely be transferred there. 10.05 The commentor expresses the opinion that the planned liquid LLW facility at NTS should be considered by DOE. Response: A sentence has been added in section 4.3.3.10 under the No Action paragraph between the sentences in line 22 as follows: "A liquid LLW treatment facility is planned for the treatment of wastewater from soil decontamination." Liquid LLW is not transported by DOE, it must be solidified first. The treatment facility would have to be collocated with the other facilities. If sited at NTS, the potential utilization of the facility would be evaluated in a site-specific document. 10.06 One commentor addresses the disposal of spallation products in the APT, and suggests that the accelerator design should comply with NRC and EPA standards since minute but extremely hazardous radioactive elements may be produced. Another commentor believes that wastes from a coal plant to generate the power required to operate the APT should be factored in. Response: All tritium supply and recycling facilities would treat and package all waste generated into forms that would enable long-term storage and/or disposal in accordance with the RCRA, and other applicable statutes. The management of DOE radioactive waste will be conducted in accordance with DOE Order 5820.2A, Radioactive Waste Management. Hazardous waste will be managed in accordance with RCRA. NRC does not provide regulatory oversight for DOE wastes, but does review DOE orders which are developed through a formal regulatory development process. The PEIS has added an analysis to the environmental impact sections for each site throughout sections 4.2, 4.3, 4.4, 4.5, and 4.6 to account for the power required to operate the APT; however, the environmental parameters are based on a gas-fired power plant not a coal plant. 10.07 The commentor is of the opinion that the PEIS should include an analysis of long-term waste management costs, including facility life and afterward, past 2050. Response: Costs are not analyzed as part of the environmental impacts. However, costs are part of the input into the analysis for the ROD. 10.08 One commentor notes that the large volume of spent fuel waste associated with the MHTGR includes the moderator. According to the commentor this technology does not produce more fission products than other reactor types. Another commentor feels that the PEIS does not make it clear that additional storage space (above that required by the other reactor technologies) would be needed for MHTGR spent fuel generation. This need is due to the thermal (criticality) requirements of storing spent fuel, and the PEIS needs to mention this, according to the commentor. Response: In addition to the volume of the spent nuclear fuel, which for the MHTGR includes the moderator, the heavy metal content has been added to the waste tables in section 3.4 and appendix A.2 for all of the reactors for a more equitable comparison. 10.09 Commentors state DOE should not consider spent nuclear fuel as an asset. Response: Spent nuclear fuel was considered a resource by DOE when it was reprocessed to obtain special nuclear materials. With the reduction in the Nation's nuclear weapons stockpile, supplies of these special nuclear weapons became more than sufficient to satisfy needs for the foreseeable future. Accordingly, the decision to discontinue reprocessing was made and spent nuclear fuel is presently being stored only until a suitable repository becomes available. Processes similar to reprocessing may be utilized for treatment and stabilization. 10.10 One commentor questions why there is no consideration for onsite storage and disposal at Pantex (unlike the other sites under consideration) and why the city of Amarillo needs to change its landfill design. Another commentor suggests that additional solid waste from a tritium supply and recycling facility sited at Pantex would not have substantial impact on current landfill capacity even if the city's landfill were utilized. Response: The current site practice for sanitary waste disposal at Pantex is to utilize the landfill for the city of Amarillo. If Pantex were to construct an onsite sanitary landfill, it would certainly be used. Since the solid sanitary waste would increase by a factor of 13 to 20 depending on the technology chosen, there would be a substantial impact on current landfill capacity. There is no statement that a landfill design change is required; however, the increase in solid sanitary waste volume could affect the planned lifetime of the current landfill. 10.11 The commentor states that the Tritium Supply and Recycling Program would add only an incremental increase in wastes compared to previous DOE projects which have contaminated ORR. In the commentor's opinion, this seems to position ORR as a likely candidate by avoiding more prominent impacts at another site. Response: The Tritium Supply and Recycling Program would add an incremental amount of waste to any site selected. It is true that the increment is more of an impact at a site such as Pantex as opposed to ORR or SRS. However, the waste impacts are only one input into the overall decision process. 10.12 The commentor refers to page 3-87 and notes that in the previous EIS for a New Production Reactor (April 1991), the hazardous solid waste generated for each reactor concept (HWR, light water reactor, MHTGR) varied from site to site, but was generally more for the light water reactor than for the MHTGR and HWR by factors of 7 to 24. Here, the MHTGR allegedly produces 2.5 times as much as the light water reactor and HWR, and even produces more in three modules than it produced in 1991 in eight modules. The commentor indicates they have been unable to obtain the reference document to check the basis for these numbers, but there appears to be an error. According to the commentor, this should be re-evaluated. Response: The data for the PEIS were prepared by DOE's architectural and engineering contractor by extrapolating data from the New Production Reactor Program to include ensuring consistency across all tritium supply and recycling alternatives. The reactors assessed for the Tritium Supply and Recycling Program were down-sized to meet the decreased tritium requirements outlined in the Nuclear Weapons Stockpile Memorandum. The production of plutonium and the reprocessing of spent nuclear fuel were also eliminated from the proposed New Production Reactor Program. 10.13 The commentor is of the opinion that DOE should consider the possibility of reprocessing tritium from spent fuel. Response: There is little or no tritium that can be recovered by the reprocessing of spent nuclear fuel. It is for that reason that specially designed target rods must be used to manufacture tritium in a reactor. 10.14 The commentor notes that spent fuel storage is a function of heat. Therefore, the less heat generated, the less storage required. The commentor asserts that the document does not adjust the environmental impacts for storage of spent fuel as function of heat. Response: Spent fuel storage requirements and environmental parameters were developed by DOE's architectural and engineering contractor. The PEIS analysis assumed that the spent fuel storage requirements and environmental parameters did account for the difference in spent fuel characteristics of the various technologies. Assumptions about volume requirements for a repository based on heat load are speculative. 10.15 The commentor suggests that DOE present the percentage of spent fuel to be handled in the Tritium Supply and Recycling Program relative to total amount of spent fuel currently managed. The commentor believes that a more accurate perspective of the differences between reactor and APT technologies would result. Response: The residual heavy metal content of the spent nuclear fuel for the reactor technologies has been added to the Final PEIS. For comparison purposes, the DOE inventory in the year 2035 as reflected in the ROD from the Department of Energy Programmatic Spent Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (2,742 metric tons) and an estimated inventory in the year 2030 of commercial spent nuclear fuel (85,700 metric tons) has been added. The tritium supply reactor technologies would contribute the following amounts of heavy metal per year: Large ALWR (105 metric tons), Small ALWR (68 metric tons), MHTGR (0.3 metric tons), and HWR (0.2 metric tons). 10.16 The commentor believes the Final PEIS should express LLW in curies or mass units (in addition to yd3 and acres3). Response: LLW is defined as waste that contains radioactivity but is not classified as high-level waste, transuranic waste, spent nuclear fuel, or as "11e(2) by-product material" as defined by DOE Order 5820.2A, Radioactive Waste Management. Test specimens of fissionable material irradiated for research and development only, and not for the production of power or plutonium, may be classified as low-level waste, provided the concentration of transuranic waste is less than 100 nanocuries per gram. LLW is not typically measured in terms of curies, it is quantified in terms of cubic yards. Analyses of environmental impacts are not based on curie content per se but rather on the number of curies potentially released. 10.17 The commentor, who was present at a public hearing at NTS, refers to a slide which indicates the need for a new organic mixed-waste facility and asks what are the primary constituents of this waste stream. The commentor also wonders if it is the same as mixed LLW. The commentor believes DOE should clarify this. Response: This is a solid mixed waste stream consisting typically of contaminated oils absorbed on wipes, contaminated protective clothing, and plastics in relatively small volumes. NTS does not have a facility capable of treating this waste. Currently NTS sends such wastes offsite for treatment. If the tritium supply were located at NTS, an organic mixed-waste treatment capability would be needed either onsite or offsite. 10.18 In reference to volume I, chapter 4, table 4.4.3.10-1, page 4-254 (transuranic (solid) row, disposal method column, second and third statements), one commentor suggests that since the status of events cannot be accurately projected as to the opening of such a repository, DOE should remove the phrase "Federal repository in the future." Another commentor states that reactor technologies would generate from 7 (HWR) to 30 (MHTGR) yd3 of spent fuel a year. If Yucca Mountain is chosen, this commentor states that the projected disposal needs already exceed capacity. INEL and Spent Nuclear Fuel Final EIS appear to address only how to manage DOE spent nuclear fuel over next 40 years until final disposition options are available. Another commentor references volume I, chapter 4, section 4.4.2.10, page 4-201, and asks for clarification of where the LLW disposal area would be located and if acreage has been committed for the amounts of excess LLW waste identified in the table 3.6.1 under waste management. Assuming that LLW disposal facilities will be available on ORR, the commentor believes that waste disposal siting options by the NRC should be discussed. One commentor also asserts that there is much uncertainty about the location of an onsite LLW storage facility since there is no progress on the storage problems already existing at ORR. Response: It is agreed that the status of events cannot be accurately projected as to the opening of a Federal repository for transuranic waste; however, the discussion still accurately depicts DOE's future plans. It should be noted that it is widely accepted that such a facility will have to be built sometime in the future. As shown in the PEIS, current plans call for the Class II LLW disposal facility to be operational in 2002. This disposal facility is part of the overall LLW management program at ORR and is not being proposed to be constructed solely to meet the requirements of the Tritium Supply and Recycling Program. There are many factors that could affect the schedule, location, and capacity of this facility. These include: (1) Defense Nuclear Facilities Safety Board recommendation 94-2, concerning performance assessments for LLW disposal facilities, (2) the National Disposal Working Group, (3) the ROD from the Department of Energy Waste Management Programmatic Environmental Impact Statement, (4) future funding, and (5) the ORR environmental restoration program. The acreage quoted in the PEIS is the amount required to dispose of the LLW from the proposed action based on the current land usage factor for the proposed Class II facility. Currently DOE LLW disposal facilities are not licensed or regulated by the NRC. The management of LLW is outlined in DOE Order 5820.2A. The DOE Committee on External Regulation of DOE Facilities is now looking into the possibility of external oversight of DOE facilities by NRC. 10.19 One commentor refers to page 4-208 which states that radioactivity limits for Class L1 wastes are 560,000 curies per yd3. But the commentor believes that no amount of radioactive material produced in this program, however diluted, can be below regulatory concern. Another commentor believes that because of the waste hazard, no nuclear waste should be placed in Tennessee or anywhere near people. Response: The LLW generated as part of the Tritium Supply and Recycling Program is not considered to be below regulatory concern. The management of LLW is outlined in DOE Order 5820.2A, Radioactive Waste Management. As stated in the DOE order, it is DOE policy that "low-level waste operations shall be managed to protect the health and safety of the public, preserve the environment of the waste management facilities, and ensure that no legacy requiring remedial action remains after operations have been terminated." 10.20 The commentor notes that Pantex does not currently generate high-level radioactive waste; however, three of the production reactors would create high-level waste. This would force the Panhandle to deal with storage of both plutonium and high-level waste, according to the commentor. The commentor feels that this is unacceptable to residents since there is no storage facility for these wastes. Response: The three production reactors would generate spent nuclear fuel. Because this spent nuclear fuel is not being reprocessed, there is no generation of high-level waste. The design of the production reactors includes spent fuel storage. The preconceptual design has sufficient capacity to store the spent nuclear fuel for the life of the facility. 10.21 The commentor suggests that the volume I summary should provide information about LLW generated for each technology, maintenance frequency, and effort. Response: The PEIS does provide the amount of LLW generated from each of the reactor technologies (see appendix A, section A.2). The PEIS also provides the amount that requires disposal in a LLW disposal facility (see effluent column for technology in appendix A, section A.2). As described in section 3.1.2, the volumes of waste described in this PEIS are intended to be bounding for each technology as they are based at the maximum production level that the facility could achieve. 10.22 In reference to volume I, chapter 3, table 3.6.1, page 3-71, ORR column, second paragraph, the commentor asks for clarification on whether there would by any liquid releases associated with tritium supply and recycling operations at ORR. The commentor notes that tritium, as well as other radionuclides, is already found in groundwater at ORNL. Response: Section 4.4.2.4 discusses potential liquid releases for all the technologies at ORR. Potential impacts of these releases are given in section 4.4.3.4 for ORR. 10.23 The commentor refers to volume I, chapter 3, section 3.6 and asks that NRC data on the nature of fission by-products from reactors and spallation-induced products from APT be provided and that waste characteristics from each alternative be compared. Response: The comparison table in section 3.6 presents the waste data for each of the various technologies and compares it among sites. The data for the comparison requested by the commentor is available in the table. The data used that describe the fission by-products from reactors and the spallation-induced products from the APT are included in appendix E, as tables listing radioactive releases for normal operations for each of the technologies, and in appendix F, as source terms for various accident scenarios. 10.24 The commentor believes that siting tritium supply and recycling facility at Pantex will create toxic wastes affecting environmental health in the Panhandle. Response: The PEIS acknowledges that waste generation at Pantex would increase from the proposed action. The PEIS also states that tritium supply and recycling facilities would treat and package all waste generated into forms that would enable long-term storage and/or disposal in accordance with the Atomic Energy Act, Resource Conservation and Recovery Act (RCRA) and other relevant statutes. The management of DOE radioactive waste would be in accordance with DOE Order 5820.2A, Radioactive Waste Management. Hazardous waste would be managed in accordance with RCRA. There are no wastes estimated to be generated that are regulated under the Toxic Substances Control Act. DOE is committed to manage any waste generated from the Tritium Supply and Recycling Program in a manner that assures protection of the health and safety of the public, DOE and contractor employees, and the environment. 10.25 The commentor believes that DOE needs to consider if new processes, management/handling criteria, or containment will be required to dispose of the spent lead and tungsten targets from the APT. Response: The lead target assemblies from the LiAl option and the tungsten targets from the He-3 option have high activity levels immediately after irradiation. However, the total amount of activity decreases rapidly with time since the activation products have such short half-lives. As noted in the PEIS, the lead target assemblies are temporarily stored in pools until the activity levels have decreased to the point that the lead target assemblies can go through metal recycling to recover the lead or be macro-encapsulated to be disposed of as solid mixed LLW. The tungsten targets would be disposed of as solid LLW. If the APT is the selected technology, new processes would be investigated as part of refining the design. 10.26 Commentors state that the PEIS should include a discussion of the different types of wastes from the four technologies and how they will be disposed of. Another commentor believes that the PEIS should breakdown waste numbers for each technology. Response: The PEIS does provide a discussion of the types and quantities of wastes that will be generated from each of the tritium supply technologies (see sections 4.2.3.10, 4.3.3.10, 4.4.3.10, 4.5.3.10, 4.6.3.10, and appendix A, section A.2). As stated in the PEIS, the tritium supply and recycling facilities would treat and package all waste generated into forms that would enable long-term and/or disposal in accordance with applicable Federal and state regulations, and DOE orders. 10.27 In reference to volume I, chapter 4, section 4.4.3.10, page 4-252, the commentor requests clarification on whether the new storage facility for spent nuclear fuel and the new treatment facility would be placed on the tritium supply and recycling site or existing facilities at ORR. Response: Due to capacity limitations, there are no plans to use existing facilities. The third sentence has been revised to read "As part of their design, all reactor technologies would provide stabilization and storage of spent fuel for the life of the facility." 10.28 The commentor wonders how LLW figures were generated and for what timeframe. Response: For the HWR and MHTGR the LLW figures were generated using New Production Reactor data that were reviewed and revised to account for smaller reactors and waste minimization initiatives. For the ALWR and APT LLW estimates were taken from preconceptual design information on NRC documentation. The timeframe used was a 40-year lifetime of the facilities. 10.29 The commentor believes that DOE should include in the Final PEIS analyses of the costs to and impacts of a pipeline carrying wastewater from Amarillo to Pantex on the environment and surrounding communities, as well as the effects and costs of a pipeline carrying wastewater to the new tritium supply and recycling facility. Response: A pipeline carrying reclaimed water to Pantex from Amarillo will be constructed regardless of the Tritium Supply and Recycling Program and, therefore, is not analyzed. However the use of this water at the Pantex plant for cooling purposes has been added to the analysis in section 4.5.3.4. The wastewater generated by the tritium supply and recycling facility would not be recycled and would leave the plant site. 10.30 The commentor refers to volume II, page H-12, LLW and the statement: "...(incinerator, which was shut down for modifications, completed startup and resumed limited operations in 1994)." The commentor indicates that while sizing and compaction have resumed at Waste Experimental Reduction Facility (WERF), the incinerator has yet to restart actual waste incineration. According to the commentor, some incinerable LLW from the INEL is currently being sent to Tennessee for processing with stabilized ash and returned to the INEL for disposal. Once incineration at WERF resumes, it will be mainly low-level mixed waste that will be incinerated. Response: The referenced sentence in section H.2.1 has been changed to read: "...which was shut down for modifications, is in startup and is expected to resume operations in 1996.)" 10.31 The commentor suggests that the following statement be clarified in volume II, page H-12, transuranic waste: "Approximately half of the TRU wastes are expected to be reclassified as alpha contaminated LLW in the future. These wastes do not meet INEL waste acceptance criteria for LLW, and therefore will be managed as TRU waste." The commentor indicates that current plans are to ship the majority of INEL TRU waste to Waste Isolation Pilot Plant (WIPP) for disposal. Only low-level TRU waste can be disposed of in WIPP. The alpha-contaminated waste will likely be treated and disposed of elsewhere. Response: Transuranic wastes contain transuranic contamination over 100 nanocuries per gram. Alpha LLW contain transuranic contamination of more than 10 but less than 100 nanocuries per gram. While the wastes are in interim storage at INEL, they will be managed similarly. However, the transuranic waste will be certified for disposal at WIPP or another suitable repository should the WIPP prove unavailable. The Waste Characterization Facility will be utilized to determine which wastes are in the alpha contaminated category. The alpha contaminated low-level waste will be packaged to contain the alpha-type contamination and to permit disposal as LLW. The last sentence of the transuranic waste paragraphs (section H.2.1) has been modified as follows: "These wastes do not meet INEL waste acceptance criteria for LLW, and therefore will be managed as TRU waste until they can be characterized and repackaged to contain the alpha-type contamination to permit disposal as LLW." 10.32 The commentor suggests that in volume II, page H-11, transuranic waste, the statement "INEL contains 30 percent of DOE's TRU wastes," should be more like 60-65 percent. Response: The Final PEIS referenced text has been revised to state: "Since that time, TRU wastes have been segregated into contact-handled, remote-handled categories, and packaged and stored for ultimate retrieval and transport to an offsite repository at WIPP or another suitable repository should the WIPP prove unacceptable. INEL contains more than 50 percent of DOE's TRU wastes." 10.33 The commentor notes that in volume I, pages 4-94 to 4-99, the amounts of various waste types that would be generated by the different technologies are discussed. The commentor states that while there would be increases to all waste streams by all technologies, the increases in low-level radioactive waste, which is disposed of on INEL by shallow land burial, would be the most significant. The increases in possible site-wide disposal range from 109 percent with the HWR to 18 percent with the ALWR (small) and APT. With such large increases the commentor wonders whether the subsurface disposal area, where LLW is disposed of, would be able to meet the performance criteria for LLW disposal contained in DOE Order 5820.2A. The commentor further notes that while the current sub- surface disposal area performance assessment indicates that operations conducted on a scale similar to the present and recent past will likely meet the performance criteria, the performance assessment's sensitivity analysis indicated that subsurface disposal area performance might be close to the upper limit allowed. Response: Under DOE Order 5820.2a, INEL must establish performance objectives for the man- agement of LLW to protect human health and the environment. INEL is responsible for implementing and maintaining performance assessment documentation to certify that the dose limitations are not exceeded. The performance assessment is based on assumptions for engineered barriers and packaging. The text in section 4.2.3.10 of the EIS, in the last paragraph under Potential Mitigation Measures, states "Utilization of these facilities would require site-specific engineering and NEPA analysis." The isotopic analysis was not available for the projected waste streams when this document was completed. The reported waste volumes to be disposed of are also assumed to have not undergone any volume reduction other than compaction. INEL uses both onsite and offsite commercial incineration of LLW. 10.34 In reference to page 4-288, section 4.5.2.10, waste management, the commentor notes that the last sentence in the third paragraph which begins: "In September..." is incomplete. After the second sentence, the commentor suggests the text should be modified to add, "after the public comment period on the proposed listing for Pantex, the NPL ranking score increased from 34.42 to 51.22." Response: The sentence has been revised to read: "In September 1991, DOE submitted to EPA its technical comments regarding the proposed listing." The NPL ranking score was judged as not being necessary for a programmatic EIS. 10.35 The commentor refers to the following statement in volume I, page 4-49, nonhazardous waste: "INEL has eliminated the commercial/industrial waste streams that had previously been generated and disposed of in the commercial/industrial landfill." The commentor is of the opinion that this statement needs to be clarified or corrected. It is the commentor's understanding that the solid, nonhazardous waste generated on the INEL is, with one exception, classified as a commercial/industrial waste and the landfill is an industrial waste landfill. Response: Section 4.2.2.10 has been changed. The referenced sentence (last sentence under nonhazardous waste) has been deleted and replaced with: "Continuation of existing programs will require expansion of the industrial/commercial landfill, adding 225 acres to provide capacity for the next 30 years." 10.36 In reference to volume I, chapter 4, section 4.4.2.10 page 4-201, second column, third paragraph, "high-level waste," one commentor requests that the relationship that the proposed tritium supply and recycling facility would have with NRC regulations be described. In addition, the commentor suggests that spent nuclear fuel produced by the proposed facility should be defined and regulated as high-level waste by NRC. Another commentor states that consistent with the assumption by the DOE Office of Fissile Materials Disposition that options for the disposition of plutonium would have to be licensed by NRC to be deployed, the DOE should assume that the tritium supply technology will be licensed by NRC. The commentor notes that NRC can provide the necessary independent review and oversight, and it is likely that the NRC would be required to oversee the confirmatory inspections, tests, analysis of the ALWR if selected for tritium supply so that the conditions of certification are validated for licensed operation. The commentor states that the Defense Nuclear Facility Safety Board is judged not to be equipped for this task without using the NRC as permitted under law. The commentor states that it would be best not to burden the process with the Defense Nuclear Facility Safety Board when the NRC has a proven track record for nuclear safety assurance based on the licensing and ongoing regulation of over a hundred commercial reactors and numerous nuclear materials facilities. The commentor points out that the NRC has also provided DOE with the independent reviews for Naval Reactors, the Fast Flux Test Facility and the Light Water Breeder Reactor at Shippingport. Response: In response to concerns that DOE needs regulatory oversight at its nuclear facilities, the Secretary has created an independent Task Force on External Regulation. This task force is presently reviewing various alternatives for external oversight of activities at DOE's nuclear facilities and will submit a report, with recommendations, early in 1996. The NRC currently does not have regulatory authority over DOE facilities. DOE differentiates between spent nuclear fuel and the waste that results from the reprocessing of spent nuclear fuel. The DOE management of spent nuclear fuel is reflected in the ROD for the Department of Energy Programmatic Spent Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental Restoration and Waste Management Programs Final Enviornmental Impact Statement (DOE/EIS-0203-F). The definitions of spent nuclear fuel and high-level waste are in appendix H, table H.1.1-1. Since spent nuclear fuel is not reprocessed, the tritium supply and recycling proposed action would not generate any high-level waste. 10.37 One commentor refers to volume I, page 3-4, column 1, second bullet and notes that a comprehensive assessment of ultimate disposition of spent fuel is not yet possible. Yet, the commentor believes that a comparison of the amount of fuel (in units of metric tons of heavy metal) that would be disposed from the proposed facility to that from other government and commercial sources would be helpful in assessing the impact of the tritium facility and its contribution to the cumulative impact of management and disposition of spent fuel from various sources. Another commentor references volume I, section 3.4.2, pages 3-32 to 3-39 and pages 4-92 to 4-99, volume II, appendix A (tables), and suggests that spent nuclear fuel quantities in metric tons of heavy metal (instead of or in addition to yd3) should be provided in order to compare to quantities currently being stored at DOE facilities and expected to be produced in the future from other sources. In addition, several commentors state that they are extremely supportive of DOE's efforts to reduce its hazardous waste generation and encourage DOE to include appropriate waste minimization commitments as an integral component of the proposed course of action in the project's ROD. Response: The PEIS has been modified to include the residual heavy metal mass content of the spent nuclear fuel generated from the various reactor alternatives. These data are included in the waste tables in section 3.4 and appendix A.2. DOE recognizes that pollution prevention (as opposed to pollution control) is the preferred option to waste management. This approach has been emphasized by both former President Bush and President Clinton. As outlined in DOE Order 54001, it is also DOE policy that any new facility is required to incorporate waste minimization/pollution prevention principles and practices into its design. 10.38 The commentor observes that waste minimization/pollution prevention is mentioned frequently throughout this PEIS and the PEIS claims that it is a concept that will be incorporated into the design and operation of all the proposed technologies. The commentor points out that the PEIS also states that INEL has an active waste minimization/pollution prevention program. The commentor argues that, in reality, there seems to be a lack of long-term commitment to the program on the part of DOE- Idaho and its contractors. For example, the commentor notes that funds have been cut for waste minimization/pollution prevention activities and the program has been "zeroed out" for fiscal year 1996. The commentor notes that in fiscal year 1997, it falls below the available budget and will probably not be funded. The commentor also states that in day-to-day dealings with waste management operators at the site, they have experienced an opinion that waste minimization/pollution prevention is not a waste management function. Therefore, the commentor believes that there is some question as to whether it should be funded from EM-30. Without a strong commitment to waste minimization/pollution prevention, the commentor believes that the costs and environmental impacts associated with the proposed tritium technologies will increase. In other words, the commentor asserts that it makes good economical and environmental sense to avoid the creation of waste in the first place. The commentor acknowledges that waste minimization capability can be built into the design of a new facility, but without a commitment from the operators of the facility, many of the benefits mentioned in the PEIS are unlikely to be realized. Another commentor refers to volume I, page 3-4, first column, first bullet, which states that consideration has been given to waste minimization and pollution prevention in the design goals for new facilities with regard to their eventual D&D. The commentor suggests that consideration should also be given to the minimization of waste from facility operation. Response: DOE recognizes that pollution prevention (as opposed to pollution control) is the preferred option to waste management. This approach has been emphasized by both former President Bush and President Clinton. As outlined in DOE Order 54001, it is also DOE policy that any new facility is required to incorporate waste minimization/pollution prevention principles and practices into its design. The second sentence of the first bullet has been changed in section 3.1.1 of the Final PEIS to read: "The design goals of all new facilities include consideration of waste minimization and pollution prevention to minimize the generation of wastes from operation and facility and equipment contamination thereby making the future D&D of these facilities as simple and inex- pensive as feasible." 11 Human Health 11.00.01 The commentor believes that radiation monitoring at NTS has been inconsistent over the past 30 years. The commentor expresses the opinion that the radiation baseline used in the PEIS is not accurate; therefore, the radiation analysis is not accurate. In addition, the commentor suggests that DOE needs to ensure consistent monitoring in the future, and that the PEIS should take into account this inconsistent monitoring. Response: The PEIS baseline is taken from the annual site environmental report which is filed annually by the sites with appropriate regulators. This is believed to be the most consistent information available and receives independent review by the EPA. It is also generally available in site reading rooms. The data from these reports is used to determine the calculated annual dose for the No Action alternatives as presented in sections 4.2.3.9, 4.3.3.9, 4.4.3.9, 4.5.3.9, and 4.6.3.9. 11.00.02 One commentor states that the number of cancer fatalities per year for the APT versus the other technologies appears to be misleading. The APT considers only the risks associated with construction of the facilities, whereas the risks associated with the other technologies include both the construction and operational risks. The commentor suggests that DOE include in the PEIS the risks associated with constructing and operating the electrical source to power the APT, whether the source is coal-fired or nuclear powered. Response: A generic and site-specific analysis of impacts for a dedicated gas-fired power supply to support the APT has been incorporated in the Final PEIS, throughout sections 4.2.3, 4.3.3, 4.4.3, 4.5.3, and 4.6.3. For the APT, both construction and operation are included in the PEIS. 11.00.03 The commentor indicates that recent epidemiological research suggests that a large influx of people in a region may lead to higher rates of leukemia. This unknown phenomena may result from viral transmissions in an unstable population. The commentor believes that the document should attempt to include this in the human health section. Response: The sections on health effects studies that were summarized in the affected environment sections, and which were reviewed in more detail in appendix sections E.2 and E.3, did not include unknown phenomena. Only published study findings were reviewed and presented in the PEIS. Quantifying impacts from unknown phenomena was deemed speculative due to the current state of research and information available on this type of impact. 11.00.04 The commentor states that construction deaths (industrial accidents) will exceed cancer deaths from the tritium supply and recycling facility. The accident deaths in the PEIS result from radiological releases or accidents, not industrial accidents. The PEIS should account for industrial accidents. Response: Section 5.5 of the PEIS addresses project compliance with the Occupational Safety and Health Administration (OSHA), including the regulations regarding workplace safety and accidents. Included in that section is a discussion of potential impacts that might result from industrial accidents during construction. This issue will be further addressed in following site-specific tiered NEPA documents. 11.00.05 The commentor believes that the document should include information relating how DOE intends to monitor radiation health within a 50-mile radius, as well as the techniques it will use. Response: The monitoring of human health is discussed in section 4.1.9 under the subtopic "Epidemiological Studies." Information on specific epidemiological studies already performed or planned around each site are presented in appendix E, sections E.2 and E.3. A discussion of study methods is also presented in section E.4. 11.00.06 The commentor believes that there are some minor changes that would improve the document. On page E-3 of volume II, the commentor notes the internal committed doses are combined with external effective doses. For convenience, the sum is also called the committed effective dose equivalent in the Draft PEIS. Although this may be convenient, the commentor notes that it is not correct or conventional. A committed dose has a specific definition that involves only radioactive materials taken internally in the body. The definition implies that an intake today results in a dose received over subsequent days or years depending on the radiological and biological half-life of the specific radionuclide. For external effective doses, the dose ends when the person or the source is removed from the area of influence. Therefore, the commentor believes it is more correct to call this combined dose a total effective dose equivalent or just effective dose for that year of practice. Response: The commentor is technically correct and it was a matter of choice as to what nomenclature is used for such combination. The definition is included as used in section E.2.1.1 so as not to confuse readers. 11.00.07 One commentor contends that the comparison of health effects between the APT and the reactor technologies is not a fair comparison. According to the commentor, the human health effects that result from the high electromagnetic effects of an APT are unknown. The commentor states that the American Nuclear Society would not accept the comparison. In addition, the commentor notes that the history of the five reactors at SRS shows an excess of leukemia. In the commentor's opinion, the human health section would not be accepted by professionals in epidemiology. The commentor argues that DOE is presenting a narrow analysis to the public by displaying only radiation exposure. The Final PEIS should include the health risks from the electromagnetic radiation produced by the APT, according to another commentor. Response: The basis of the human health effects analysis is outlined in appendix E, section E.2. The Final PEIS presents information on health risks from electromagnetic radiation in appendix E.2.3.4. 11.00.08 The commentor believes that the draft seeks to preempt NRC licensing standards by placing significance upon accidents that might happen every 100,000,000 years. The commentor notes this particular accident frequency was chosen as significant but the basis for selection is not explained in the Draft PEIS. According to the commentor, in establishing the safety goal for ALWRs, the NRC stated that "the overall mean frequency of a large release of radioactive materials to the environment from a reactor accident should be less than 1 in 1,000,000 per year of reactor operation." The commentor notes that the Electric Power Research Institute proposed that ALWRs meet a conservative goal of accident frequencies less than once every 1,000,000 years for any accidents that produce releases exceeding 25 rem whole body dose over 24 hours at 0.5 miles from the reactor site boundary, for example. According to the commentor, the NRC's Final Safety Evaluation Report for the System 80+ design, Electric Power Research Institute concluded that the probability of exceeding the 25 rem criterion was once every 20,000,000 years. The commentor notes that this probability is about 20 times better than the Electric Power Research Institute goal. The commentor further points out that the NRC also noted that "the risk is very low compared to the current generation of operating plants." The commentor states that the total exposure over a 50-mile radius was estimated to be 17 person-rem over a 60-year plant-life based upon population and weather data developed by Electric Power Research Institute to bound 80 percent of the reactor sites in the United States. Using the conversion factors proposed in the Draft PEIS, such an exposure would result in no measurable latent fatalities, according to the commentor. The commentor states that based upon these and many other findings, the NRC issued a final design approval of the System 80+ design in July 1994. The commentor feels that the Draft PEIS should not preempt the NRC's safety findings by placing relevance upon extremely low probability accidents. Instead, the commentor believes that Draft PEIS should incorporate the NRC results, thereby presenting an accurate dose value for the Large ALWR. The commentor suggests that the Draft PEIS grossly overstates the potential for radiation releases from ALWRs during "low-to-moderate consequence accidents." According to the commentor, the results outlined in the table on page F-28 are completely wrong. The commentor states that what would be correct for System 80+, is that there would be no measurable offsite release and no fatalities. The probability of a large break loss of coolant accident is less than once every 1,000,000 years, because the reactor piping meets the NRC criteria of "leak before break." Even if such an accident did occur, the plant is designed to withstand it. No fuel rod failures would be expected and, therefore, no measurable radiation releases would result. Response: As described in appendix F, dose information has been revised using more representative accident scenarios. New values are located in appendix F and sections 4.2.3.9, 4.3.3.9, 4.4.3.9, 4.5.3.9, and 4.6.3.9. The results are more consistent with NRC licensing reviews. 11.00.09 The commentor expresses the opinion that the PEIS should display the current regulatory limits to be met and their history, and predict what these limits may be in the future. Response: DOE expects any tritium supply facility would comply with 10 CFR 100, DOE 6430. 1A dose limits, the Secretary of Energy SEN-35-91 safety goals, and the International Commission on Radiological Protection ICRP 26/10 CFR 834 recommendations regarding acceptable radiological risks. Appendix table E.3.3-1 gives regulatory limits for hazardous chemicals that could be documented for each alternative and at each of the sites analyzed. Table E.3.2-1 gives other pertinent information about each of the hazardous chemicals. Since it would be speculative, at best, to predict what limits might be applied to the very large number of chemicals cited and because limits are based on current toxicological, epidemiological and occupational information, it would be inappro- priate to predict the regulated limits for any chemicals. 11.00.10 Commentors state that the proposed tritium facility will not appreciably affect the public. One commentor states that construction and operation of facilities to rejuvenate and maintain tritium supply will not jeopardize the safety of his family. In addition, the commentor states that DOE's process of documenting every activity or hazard and designing mitigation features virtually eliminates consequences to the public. Another commentor states that more fatalities will occur as a result of electrical accidents than of nuclear radiation. Additionally, another commentor states that DOE should take into consideration the fact that, in general, construction and operation workers are healthier than the general population. This fact may influence the conclusions of the human health section. Another commentor references pages 4-421 and 4-385, and notes that the severe accident risk for ALWRs is stated as being low when compared to the risk of cancer fatalities from all other causes. The comment that "the results of the analysis indicate that the tritium supply technology with the highest severe accident sequence is the ALWR" seems misleading and should be deleted, according to the commentor. Response: DOE is very concerned about the safety of the public. All designs would meet or exceed applicable environmental, health and safety regulatory standards for workers. The risk associated with all technologies is low; however, the statement concerning the ALWR is correct. 11.00.11 The commentor states that the fatality figures presented in the document are misleading because there is a large disparity between the technologies. Response: As explained in section F.1.3, the accident consequences were estimated using accident source terms from the best available public documentation and the GENII and MACCS computer codes. The computer models used the same weather conditions and population patterns associated with a specific site for the comparison of candidate technologies at each candidate site. Disparities would be expected between different technologies because of differences in their designs and accident scenarios, not because of a difference in how the analyses presented in the PEIS were performed. 11.00.12 Commentors express general concerns about tritium, radiation and human health. Commentors state that tritium production will create additional environmental, safety, and health risks for the general population as well as the workers themselves. One commentor states that tritium is a radioactive gas with the potential for causing cancer and birth defects, in addition to genetic, chemical, and toxic health effects. The PEIS should analyze for all of these effects, according to the commentor. Another commentor states that increased radiation dose to workers and public is not acceptable. The people and their health are too valuable an asset to have them destroyed by a pipe dream of DOE, according to the commentor. Other commentors believe that SRS has released hundreds of thousands of curies of radiation into the air and water and that this is harmful to those who live along the Savannah River. Another commentor states that the safety of the tritium supply and recycling and its waste products is very difficult to maintain and there is always the danger of an accident or low-level radiation leak that is harmful. For this reason, the commentor does not want the tritium supply and recycling at ORR, fearing contamination of the Tennessee River. The commentor is also opposed to a tritium supply and recycling facility near any area universities, cities, land, or near the Smoky Mountains. Another commentor believes that to have nuclear waste stored directly above the largest aquifer in Idaho is unwise. The commentor is concerned that the safety of thousands is at stake should the inevitable accident occur. Another commentor states that the proximity of current and future schools and housing projects to the new facility should be fully analyzed in the PEIS. The commentor is specifically concerned about radiological risks to school and housing posed by tritium supply and recycling facility. The document should also include the projected construction worker fatality rates in the human health section, according to the commentor. Finally, another commentor feels the risk assessments for the project may be insufficient considering the health effects at ORR are significant. Response: The radiological and chemical doses, risks and health effects presented in the PEIS include the impacts associated with tritium production. The analyses demonstrate that the operation of all tritium supply and recycling facilities would result in impacts that are within regulatory limits, and the risks of adverse health effects to the public and to workers would be small. Impacts to aquifers from chemical or radiological contamination are not expected due to the Tritium Supply and Recycling Proposal. When the selected tritium supply technology is identified in the ROD, more detailed site-specific tiered NEPA analysis will be performed to further analyze the potential of aquifer contamination. Impacts from past operations at SRS are under study and are discussed in section 4.6.2.9 and appendix section E.4.6. 11.00.13 The commentor expresses the opinion that there is new scientific evidence that there exists a threshold of radiation and this may not be able to be accounted for in the document. Response: The basis of the human health effects sections are outlined in appendix E, section E.2.1.2. The PEIS analysis is based on the more conservative scientific opinion that any radiation causes an associated human health impact. This is consistent with the generally accepted report on health consequences of radiation exposures, the BEIR V report discussed extensively in that section. 11.00.14 The commentor states that risks depend on the choices people make. For instance, the commentor notes that radiation may cause cancer but people may choose radiation to cure cancer. Response: The PEIS presents a full disclosure of all the human health risks associated with each of the alternatives based on best available data. 11.00.15 One commentor, referring to page E-14, states that the 170 person-rem exposure for the reactor and tritium extraction is inconsistently high. System 80+ conservatively estimated 79 person-rem and defended this number successfully to NRC as shown on page 12-11 of the Final Safety Evaluation Report (NUREG 1462), according to the commentor. Response: The value of 170 person-rem is taken from DOE's Data Report on Advanced Light Water Reactor Tritium Supply Plant (February 1995). This value includes contributions from the tritium extraction which was not part of NUREG 1462. This source is consistent with the sources used for all technologies evaluated. 11.00.16 The commentor claims that in table 4.5.2.9-2, the doses of 2x10-5 mrem for the maximally exposed individual (MEI) and 5x10-5 person-rem for the population within 50 miles are incorrect numbers to calculate risk. Response: The dose values reported in the Draft PEIS were taken directly from the Pantex Plant Site Environmental Report for Calendar Year 1992. The environmental report is provided to regulatory agencies and the public as a tool for assessing the environmental performance of the Pantex Plant. 11.00.17 The commentor expresses the opinion that the PEIS is significantly flawed without assessing and accounting for the safety and health effect uncertainties and confidence values usually associated with the immaturity of APT, which has never been operated or the concept demonstrated for an APT "machine" the size the PEIS is proposing. The commentor believes that DOE risk analysts must figure in these "additional penalties" directly into the APT results. The commentor further suggests adding in the "common mode failure factors and Baysian update methods" to account for APT lack of experience. Response: Although the APT design has yet to be demonstrated, most of the technologies required for this facility are sufficiently mature to yield the required quantity of tritium. The technical risks, which take into account the maturity of the design, are evaluated in the Technical Reference Report available in DOE reading rooms. If the APT technology is selected, a more detailed analysis of safety and health impacts will be presented in site-specific tiered NEPA documents. 11.00.18 The commentor contends that if the APT technology is selected and found to require additional power from a facility which will be constructed in the future, then the document's evaluation is short on latent fatalities from the associated electricity production. Response: A generic and site-specific analysis of impacts for a dedicated gas-fired power supply to support the APT has been incorporated in the Final PEIS in sections 4.2.3, 4.3.3, 4.4.3, 4.5.3, and 4.6.3. 11.00.19 In reference to page F-25, commentors state that the treatment of the alternative concepts is obviously imbalanced, as revealed by the selection of an event for the MHTGR that includes multiple failures, whereas single failures were considered for the other concepts. According to one commentor, the event to analyze should include an isolated containment from the start of the event, as was assumed for all the other reactor concepts. The commentor notes that this discrepancy was present in the April 1991, Draft EIS for the New Production Reactor, was commented upon, and DOE agreed to resolve the issue. Unfortunately, the issue remains according to the commentor. The commentors further state that the assumption of 1.0x10-2 per year for the MHTGR event frequency is extremely and unfairly conservative for an event with multiple failures of safety systems, espe- cially when an event with a single failure is assumed for the ALWR to have a 1.0x10-3 per year frequency. For the releases given, numerous safeguards would have to fail which would lower the event frequency to the 1.0x10-6 range. The commentors assert that this event should be less likely than the initiating event frequency of 2.1x10-4 per year. This affects footnotes to tables F.2.2.2-2 and F.2.2.2-3, according to the commentors. Response: Appendix F has been revised to include a spectrum of low-to-moderate and high consequence accidents for the tritium supply technologies. The spectrum of accidents has been selected from the best available public documentation for each of the tritium supply technologies. The applicable page number or table number in the reference document for source terms, release fractions, core inventories, accident frequencies etc. have been cited. All of the tables that present accident consequences have been changed to reflect the results of new accident analyses. In addition the complementary cumulative distribution functions have been reformatted to provide risk-based summary comparisons. The ALWR accident source term used in the analysis was designated by the reactor vendor as a design-basis accident in a submittal to the NRC. The postulated design-basis accident was more severe than normal design-basis accidents because the analysis assumed the complete loss of safety systems that mitigate accident consequences. The documentation submitted to the NRC did not define the accident frequencies for design-basis accidents. The ALWR accident analyses have been revised to evaluate a spectrum of design-basis and beyond design accident source terms that had been submitted to the NRC as part of safety analysis reports. The design-basis accident analysis postulates the normal complement of safety systems for accident consequence mitigation. 11.00.20 Commentors indicate problems and some errors in the PEIS regarding safety and environmental results and comparisons of the alternate technologies. In reference to page F-10, a commentor states that the source term for the Advanced Boiling Water Reactor appears incomplete, since the list of nuclides is significantly shorter than for the other reactor concepts, including the Simplified Boiling Water Reactor. The commentor asks about the inclusion of strontium, ruthenium, antimony, tellurium, barium, lanthanum, and chlorine. Commentors refer to table F.2.2.3.5, volume II, page F-29, and state that the 1,500 cancer fatalities at ORR from a low-to-moderate consequence Advanced Boiling Water Reactor accident is unrealistic and argue that no one would permit such a reactor to be licensed. The commentors feel DOE should follow the NRC approach so that anyone who examines and compares results would recognize that risks are essentially identical for present power reactors and the proposed DOE production reactor. Another commentor references page F-29, and states that, according to page 3-80, the individual cancer fatality at NTS for the Large ALWR is 4.9x10-5, which is more reasonable than 4.9x10-4. The commentor suggests that table F.2.2.3-4 be fixed. Response: Appendix F has been revised to include a spectrum of accidents for the ALWR technologies based on source terms that are part of safety analyses submitted to the NRC as part of safety analysis reports. The applicable page number or table number in the reference document for source terms, release fractions, core inventories, etc. have been cited. The ALWR accident source term used in the analysis was designated by the reactor vendor as a design-basis accident in a submittal to the NRC. The postulated design-basis accident was more severe than normal design-basis accidents because the analysis assumed the complete loss of safety systems that mitigate accident consequences. Accident analyses submitted to the NRC normally define the doses at the site boundary to demonstrate that the doses are within acceptable NRC guidelines. The analyses do not assess the impact of propagating the accident consequences on the population within 50 miles of the plant. The ALWR accident analyses have been revised to evaluate a spectrum of design-basis and beyond design accident source terms that have been submitted to the NRC as part of safety analysis reports. The design-basis accidents postulates the normal complement of safety systems for accident consequence mitigation. DOE agrees with the commentors opinion on licensing such a reactor. A re-analysis of the reactor accident scenarios was conducted for the Final PEIS which indicates this number is substantially lower and more in line with expected licensing documents. 11.00.21 The commentor expresses concern with the creation of gamma radiation from spallation. Response: A detailed discussion of the APT is presented in appendix A. The amounts and types of radiation expected are given in table E.2.3.4-1 in appendix E. Argon-41, which emits gamma rays, is included in this table. Anticipated doses to the worker population from the APT and all its support facilities with spallation-induced lithium conversion target have been provided in section E.2.3.4. 11.00.22 The commentor suggests that in volume II, appendix E, information on why ORR is a viable option having the highest risk associated with working onsite and also to the public calculated on an annual dose basis (to the maximally exposed member) as compared with other sites be provided. Response: The dose for the No Action alternative at ORR is noted in section 4.4.3.9 as 17 mrem and is near the same for a site worker at INEL and SRS as noted in sections 4.2.3.9 and 4.6.3.9. The risk is also similar. The No Action alternative risk for the public is higher at Pantex and INEL than at ORR, as noted in sections 4.5.3.9 and 4.2.3.9. 11.00.23 Commentors suggest corrections and explanations for numbers and text in the human health section. The commentors request that DOE explain how ORR can have a higher chemical hazard index (by a factor of 100) than Pantex, and yet have no cancer risk while Pantex does. Also, the commentors believe that the cancer risk for Pantex is incorrect based on the chemicals listed. A Pantex employee does not have a 1 in 100 chance of cancer death as stated in the PEIS. An onsite contractor, using the same methodology as DOE, calculates the risk at 7.7x10-7. Furthermore, one commentor notes that SRS has a higher hazard index than Pantex, yet has a lower cancer risk. Finally, the commentor notes that the executive summary of the PEIS references potential cancer fatalities at only one site - Pantex, which is also the only site upon which a review of nonradiological factors is done. The commentors feel DOE should correct the data and explain the errors as soon as possible. Response: As stated in section E.3.1, the Hazard Index (HI) applies only to noncancer adverse effects, whereas the cancer risk considers only carcinogenic chemicals that have been classified as such and for which a slope factor or unit risk exists. There were no carcinogens identified from the site emissions reported for ORR. Since only chemicals that posed health hazards other than cancer were reported, it is not unexpected for the HIs to be higher than at Pantex. For the same reason it is also possible for any given site (e.g., SRS) to have a larger HI and the cancer risk to be lower compared to the other sites. However, the data from Pantex listed compounds that were carcinogenic or chemical categories containing carcinogens. Based on inadequate information concerning the carcinogens, a worst case representative was chosen for analysis which resulted in the high cancer risk values presented in the Draft PEIS. Subsequent information supplied by Pantex clarified the carcinogen issues and these results have been incorporated in the Final PEIS. 11.00.24 The commentor states that the risk assessments from exposure to hazardous chemicals at Pantex are incorrect. In reference to table E.3.4-28 in volume II, the commentor contends that the 0.01 number for total cancer risk is incorrect. The commentor suggests that DOE check all the numbers in this table and make sure they performed the correct analysis. Response: Based on the information available (data call response from Pantex, i.e., L.M. Paradee, L.M. 1992 a:10) at the time of preparation of the Draft PEIS, the analysis was appropriate for the best available information, given the uncertainties about contents within generic chemical classes and the information reported in the data call. However, corrections and explanations received from Pantex [received 4-11-95 and 4-21-95] have been factored into the recalculations from which the risk was significantly lowered to acceptable values, i.e., ~1.7x10-9 and 7.7x10-7, for the maximally exposed individual for the public and onsite worker, respectively. The regulatory threshold generally accepted by EPA for cancer risk is 1x10-6. 11.00.25 The commentor suggests revising the second and third sentences in the discussion concerning electromagnetic field and transmission lines to read: "Electric field levels associated with transmission lines and distribution lines are a function of the voltage of the line, while magnetic field levels are a function of the current carried by the conductors. Both field magnitudes are affected by the size of conductor, conductor separation distance, and the distance from the conductor." The commentor also suggests inserting after the present fifth sentence, "The magnitude of the fields and the time duration of exposure will both affect exposure levels. No correlation between various exposure levels and adverse health affects has been determined." Finally, the commentor suggests the present sixth sentence should begin a new paragraph. Response: DOE agrees and the appropriate changes have been made to section 4.8.1 of the Final PEIS. 11.00.26 One commentor, referring to page E-11, table E.2.2.2-1, states that one set of numbers (perhaps the second group) should be for general population consumption instead of both being for maximum individual consumption. Response: The commentor is correct and the appropriate changes have been made to table E.2.2.2- 1 in section E.2.2.2 of the Final PEIS. 11.00.27 The commentor references volume I, table 3.6-1; volume II, page I-66; and tables E.2.3-1 and E.2.4.1-2. According to the commentor, radiation doses and cancer risks for workers under the heading "tritium supply alone" in table 3.6-1 apparently include the doses and risks from other site activities as well as those from tritium supply (by comparison to table E.2.3.-1) but not those from tritium recycling. However, the commentor notes the dose and cancer risk in table 3.6-1 and on page I-66 under "tritium supply alone" to the maximally exposed individual (MEI) from the APT (helium-3) alternative at INEL are less than those derived from those in table E.2.4.1-2. If the "tritium supply alone" doses include those from other site activities, then the commentor states that the dose and risk to the MEI cannot be less than those from the other activities alone (No Action alternative). The commentor suggests that this apparent discrepancy be corrected or explained. Response: The doses in question are for average workers, not MEIs, and are consistent throughout the document. 11.00.28 In reference to pages F-30 and F-31, the commentor states that, for all of the preceding concepts, when no frequency of occurrence was estimated the PEIS assumes one. However, no such assumptions are presented for the APT alternatives, according to the commentor. The commentor suggests that treating the concepts differently should be avoided. Another commentor, referring to section F.2.2.4.1, page F-30, states that the selection of an administrative violation instead of an equipment failure as the design-basis accident for the APT severely negates the credibility of this PEIS, since it is not consistent with the fact that equipment failures are considered for all the other concepts. Response: The APT design-basis accident frequency of occurrence would be expected to be in the range of 1.0x10-4 to 1.0x10-6. The design-basis accident for the APT was initiated by equipment failure and is described in appendix section F.2.2.4.2 and F.2.2.4.3. The incorrect administrative procedure accident only applied to the APT beam transparent system. 11.00.29 One commentor believes that siting considerations of the tritium facility at Pantex should be conducted in such a manner as to ensure that the safety of area residences is held paramount. In addition, another commentor suggests that any current and future functions at Pantex must be conducted in a safe and environmentally sound manner. Response: The final siting of a tritium supply technology at Pantex, if selected, would include considerations of public health as well as the environment. DOE is committed to operating the Pantex Plant as well as all of its facilities in a safe and environmentally sound manner. 11.00.30 The commentor refers to volume II, appendix E, footnotes on tables E.2.4.1-2, E.2.5.1-2, E.2.6.1-2, E.2.7.1-2, and E.2.8.1-3, where annual background radiation doses are presented for INEL, NTS, ORR, Pantex, and SRS sites as 350, 323, 306, 323, and 315 mrem, respectively. The commentor questions why different values are presented in volume I, section 4, tables 4.2.2.9-1, 4.3.2.9-1, 4.4.2.9-1, 4.5.2.9-1, and 4.6.2.9-1. Section 4 of the Draft PEIS lists background radiation doses for INEL, NTS, ORR, Pantex, and SRS as 418, 382, 371, 411, and 380 mrem, respectively. The commentor notes that there should be only one referenced value for background used, despite the fact that the values come from different referenced sources. This commentor believes such discrepancies will confuse and mislead the reader. In addition, the commentor states that the reported values from NCRP 1987a are annual effective dose equivalents and not committed effective dose equiva- lents as the column heading in the volume I tables indicate. Response: The footnotes to the tables in appendix E present natural background radiation values while those in section 4 include manmade radiation, e.g., diagnostic x-rays. The footnotes have been clarified. The use of the term "committed effective dose equivalent" for both internal and external radiation is for convenience, as is noted in appendix E, section E.2.1.1. Also, refer to the response to comment 11.00.06. 11.00.31 The commentor refers to volume II, appendix E, footnotes on tables E.2.4.1-3, E.2.5.1-3, E.2.6.1-3, E.2.7.1-3, and E.2.8.1-4, where collective doses to the population within 50 miles from background radiation in the year 2030 are presented for INEL, NTS, ORR, Pantex, and SRS as 52,600, 5,770, 325,000, 88,500, and 240,000 person-rem, respectively. The commentor questions why different values are presented in volume I, section 4, tables 4.2.3.9-1, 4.3.3.9-1, 4.4.3.9-1, 4.5.3.9-1, and 4.6.3.9-1. Section 4 of the Draft PEIS lists the collective doses to the population within 50 miles from background radiation in the year 2030 for INEL, NTS, ORR, Pantex, and SRS as 53,270, 5,860, 329,800, 99,470, and 233,300 person-rem, respectively. In addition, the commentor notes that individual background radiation doses differ between these tables (for example, table E.2.5.1-2 and table 4.3.3.9-1 gives 323 and 317 mrem respectively; table E.2.7.1-2 and table 4.5.3.9-1 gives 323 and 346 mrem, respectively; and table E.2.4.1-2 and table 4.2.3.9-1 give 350 and 353 mrem, respectively). Response: The natural background radiation levels for each site are now consistent in the appendix E and section 4 tables in the Final PEIS. 11.00.32 The commentor notes that in volume I, table 4.4.2.9-2 and table 4.4.2.9-3, page 4-199, are incorrectly titled, `Doses to the General Public from Normal Operations at Nevada Test Site, 1992'. The corrected version should read `... at Oak Ridge Reservation'. Response: The commentor is correct and the appropriate changes have been made to tables 4.4.2.9- 2 and 4.4.2.9-3 in section 4.4.2.9 of the Final PEIS. 11.00.33 The commentor states that there is at least one error in the first paragraph of summary page S-21. The commentor believes that the cancer risk value in the second line (first column) should be 1.4x10-10 and not 7.1x10-6. The commentor also states that the other numbers are part of the MACCS or GENII output and cannot be easily checked. Response: The commentor is correct and the appropriate changes have been made to the discussion of radiological and hazardous chemical impacts during normal operations and accidents for SRS in the summary of the Final PEIS. 11.00.34 The commentor believes that the summary should more clearly state that: (a) "The calculated consequences are based upon the accident occurring and that the accident, particularly the high consequence accident, is a low probability event. The probability is included in each summary paragraph, but the commentor believes it is not emphasized. The commentor also notes that a "risk-based" summary comparison, such as tables 4.2.3.9-3 and 4.2.3.9-4 should be included in the summary. According to the commentor this may compensate for higher doses with lower frequencies; (b) also, while this will affect every system, the summary presents the consequence levels as absolute, i.e. "this exposure would result in 230 cancer fatalities" (see page S-2). The tables in appendix F state that the numbers are mean values (based on variations in meteorological conditions for an accident occurring throughout the year), which is typical of this type of analysis. The commentor suggests that all values, i.e., doses, cancer risks, and fatalities are mean values and the summary should acknowledge this. Therefore, overlap of the consequence level from different systems is possible and likely. Response: Appendix F has been revised to include a spectrum of accidents for the candidate tritium supply technologies. The complementary cumulative distribution function figures have been reformatted to provide risk-based summary comparisons. Appendix F now identifies all accident consequence numbers as mean values. All of the tables in volume I and in appendix F that present accident consequences have been changed to reflect the results of the new accident analyses. In addition, the associated complementary cumulative distribution functions have been reformatted to provide risk-based summary comparisons. 11.00.35 The commentor states that tritium occurs naturally and is far less toxic/deadly than plutonium. The commentor suggests that DOE take steps to ensure that the public understands this to avoid irrational fears about the gas. Response: Additional discussions regarding the relative toxicity of tritium versus other materials have been added to appendix E. 11.00.36 The commentor quotes from the document "Deadly Defense: Military Radioactive Landfills" (1988) that events occurred at SRS, where DOE was producing and disposing of tritium. On May 2, 1974, 180,000 curies of tritium oxide were released to the air in 1.5 minutes. In December 1975, 480,000 curies of tritium gas were released to the air in 4 minutes. As of 1988, about 1/4 of the 420,000 curies of tritium that had been discharged to seepage basins had migrated to Four Mile Creek. The tritium plume in the groundwater under the burial grounds exceeded EPA's drinking water standard by 3,500 times. The commentor notes that the PEIS executive summary (page 24) states that no individual exposure data for chemical worker exposures are available. If DOE and its predecessors have not kept good health records on their employees proving their operations are safe, the commentor contends that the public is justified in withdrawing its support of DOE's nuclear weapons activities. Regarding the estimated cancer risk among workers and the public at the various alternative sites and with the alternative technologies, the commentor believes it is unacceptable for the Federal Government to knowingly proceed with a project that they know will cause these levels of cancer. Response: The PEIS evaluates the potential environmental impacts for the PEIS alternatives. To the extent possible, past activities are accounted for in describing the affected environment. The potential impacts to human health will be factored into the ROD. 11.00.37 One commentor states that the tables and figures that contain information relative to latent cancer deaths (for example, figure 4.6.3.9-1) must also identify the risk alongside or as an integral part of the figure or table. Otherwise, the commentor believes that this latent cancer information out of context may be misunderstood or misused. Another commentor states that in the appendices, the explanation of the complementary cumulative distribution functions is incorrect, although the error again affects each system. The commentor suggests rewrites for the following statements on the AP- 600 system (page F-13, second column): "The curves show the possibility that the number of cancer fatalities that may result when an AP600 ALWR severe accident exceeds the value N on the horizontal axis. The curves assume that the accident has occurred." The commentor believes that the text should be replaced with the following: "The curves are based on the assumption that the accident has occurred and show the variation in cancer fatality magnitude based on the site meteorological conditions, that is, to account for an accident occurring throughout the year. Therefore, the actual probability of a specific consequence level (that is, fatality magnitude) is equal to the probability of the accident times the conditional probability of the consequence level." Another commentor refers to volume II, pages F-4 to F-16, and states that the patterns of probability curves in most of the figures showing conditional probability vs. latent cancer fatalities for high consequence reactor accidents are similar; they are essentially shifted to the right or left. However, states the commentor, the pattern in figure F.2.1.3.4-1 for the Simplified Boiling Water Reactor is quite different; there is a much greater difference between the NTS curve and those for the other sites. This difference should be explained or corrected according to the commentor. The commentor states that the tables of population dose in person-rem and cancer fatalities do not appear to show this difference; the ratio of INEL population dose to NTS population dose, or of INEL cancer fatalities to NTS cancer fatalities is consistently about 10 in all of the tables. Response: The complementary cumulative distribution functions (e.g., figure 4.6.3.9-1) have been reformatted based on this and other comments. 11.01 Human Health - Normal Operations 11.01.01 The commentor notes a three orders of magnitude difference for the release of tritium between the MHTGR and ALWR. The commentor believes this to be an error. Response: Table E.2.3.2-1 (MHTGR), table E.2.3.3.1-1 (Large ALWR), and table E.2.3.3.2-1 (Small ALWR) show tritium releases between 2.1x103 (MHTGR) and 1.62x104 (Small ALWR). This range is less than a factor of 10 and is not in error. 11.01.02 The commentor states that it would be deplorable for DOE to site the Tritium Supply and Recycling Program at Pantex, since it is in this agricultural area that the food chain begins and any contamination risk to the agricultural industry would devastate Texas. Texas High Plains is one of the most diversified agricultural areas in the world, with 14 million acres of agricultural land, commercially producing 25 crops and generating more than 100,000 jobs. Response: The PEIS presents the potential impacts of the Tritium Supply and Recycling Program, including an analysis of human health (e.g., radiation exposures, potential accidental releases, etc.) and socioeconomic resources. Potential secondary impacts on agricultural areas due to an accident are discussed in appendix F.3. 11.01.03 The commentor states that DOE fails to consider diseases other than cancer fatalities resulting from the operation of a tritium production facility. According to the commentor, tritium causes birth defects. The commentor believes that DOE should examine what other health effects a new tritium production facility would have upon populations. Response: Health impacts from radiation exposure, whether from sources external or internal to the body, generally are identified as "somatic" (affecting the individual exposed) or "genetic" (affecting descendants of the exposed individual). Radiation is more likely to produce somatic effects rather than genetic effects. Therefore, for this PEIS, only the somatic risks are presented. The somatic risks of most importance are the induction of cancers. Except for leukemia, which can have an induction period (time between exposure to carcinogen and cancer diagnosis) of as little as 2 to 7 years, most cancers have an induction period of more than 20 years. 11.01.04 In reference to volume II, page E-10, paragraph 2, the commentor questions whether the writers intended to use two different time periods: 1989 to 1992 versus 1982 to 1992. Response: Only the 1989 to 1992 time period was used. The appropriate changes have been made to the discussion of food production and consumption data in section E.2.2.2 of the Final PEIS. 11.01.05 The commentor references volume II, page E-71, section E.3.1, and states that this section is very sketchy, especially the third paragraph, outlining how HQs were calculated. The commentor notes that it appears that all HQs were summed to yield HIs for all options relevant to the site. The commentor requests a definition for "options relevant to the site." The commentor also notes that HIs should only be summed for HQs when the individual chemicals contribute to the same toxicological endpoint and the toxicity is additive, otherwise, effect-specific HIs need to be calculated. The commentor questions whether the HQ and HI modeling methods consider Short Term Exposure Limits and ceilings. According to the commentor, ceiling values are used by all included agencies' exposure limits, so why were they not considered in the background statement (e.g., n-butyl alcohol). The commentor further notes that the only stated exposure time frames were 15 minutes and 8 hours and asks in addition to ceilings, what about 16 hour (double shift) or 4-10 hour workdays or overtime in general. Paragraph one in this section, further states that risk assessors calculated the risk of long-term low-level (chronic) and short-term high level (acute) exposures. However, paragraph two states that workers are assumed to have a low exposure 8 hour day, 40 hour work week. The commentor asks about acute exposures and chemicals which have Short Term Exposure Limits or ceilings. In such cases, the commentor notes that the 8 hour day, 40 hour work week assumption would not apply. If all exposures are going to be maintained at less than the exposure limits, the commentor wonders whether a health risk assessment for workers should be performed. The commentor states that the slope factors for all carcinogens are multiplied by the inhaled dose to determine the cancer risk and suggests that the fourth sentence in paragraph 3 should read: "The inhalation slope factors for all carcinogens are multiplied by the inhaled dose to determine the cancer risk from inhalation." The overall cancer risk for each chemical is determined by summing the lifetime cancer risks for each relevant route (ingestion, inhalation, and dermal) of exposure. Different slope factors often exist for each route of exposure. Finally, the commentor notes that Permissible Exposure Limits were used in the calculations and asks whether Threshold Limit Values, Recommended Exposure Limits, and Short Term Exposure Limits, which were mentioned earlier in this section and those listed in the exposure limit table E.3-2, were used. Response: "Options relevant to the site" means "alternative actions" relevant to the site. The text has been changed using "alternative actions" in place of options for clarity and consistency with other PEIS sections. EPA's Superfund guidance allows for preliminary screening methods to be used, such as summing all of the HQs regardless of toxicity endpoint in order to eliminate unnecessary calculations and evaluations. Hence, summing the HQs for an overall HI tells the evaluator whether a potential problem exists. If the HI exceeds a value of 1.0, then one would proceed with the analysis based on common toxicity endpoints, but if the total HI value is less than 1.0, the sum of effect-specific HQs will be less than 1.0. Based on the screening analysis, effect-specific HIs are not needed for the PEIS. It should also be pointed out that by using single point emission concentrations at site positions close to the source terms, the values will be conservative compared to other approaches, e.g., Monte Carlo simulation results (Risk Analysis, Aug. 1994, page 437) which utilize multiple points to generate a range of HIs or cancer risks. It is also useful to point out that one should calculate from single point exposures as a first step in risk assessment before proceeding with more complex procedures as a way to save resources without compromising the integrity or usefulness of the analysis to the risk manager (Risk Analysis, Aug. 1994, page 478). The modeling methods could have, but did not consider Short Term Exposure Limits and ceilings because the analyses were performed on data for normal operations where the Permissible Exposure Limits set by OSHA are the relevant regulations. Further analyses would not serve any purpose and would only add to the cost and burden on resources available. Before undertaking the analyses, many potential deviations from a "standard/normal" operation were considered. Considering all of the conservative assumptions made in the approach and knowing that Reference final Concentrations, Permissible Exposure Limits, etc. values for regulation are already made conservative by incorporating large uncertainty factors, it was decided that the approach taken easily bounds the "worst case" of normal operating conditions without the necessity of excessive analyses on data in a PEIS; it is even doubtful whether site-specific EIS analyses would require a more in-depth approach. Section E.3.1 of the Final PEIS deals with normal operations of the various alternative technologies within the boundary of specified sites where emissions associated with each site can be based upon reported levels of releases that have occurred for documented periods. Based on anticipated activities at future dates, emission levels are projected (e.g., to the year 2005). It is then assumed that technologies proposed will add to the total site emissions if added to the existing site activities. By modeling the concentrations projected for the alternative technology and the concentrations due to all other site activities, using appropriate dispersion factors for each site, it can be validated whether the exposures are actually likely to be maintained within the limits that are regulated. Since emissions averaged over one year periods of time are used to derive concentrations at specified distances from source terms through modeling, one cannot apply Short Term Exposure Limits and ceiling values (concentrations that cannot be exceeded during any part of the work day) to the data. In fact, unless concentration values were so extraordinarily high that the Permissible Exposure Limits would be exceeded, the Short Term Exposure Limits and ceiling values should never be reached, but if they were reached the Permissible Exposure Limits by virtue of its being the regula- tory value relevant to normal operations is the "ruling" regulatory value to protect the worker. The text where the Short Term Exposure Limit, Recommended Exposure Limits, and Threshold Limit Values are mentioned has been expanded in the Final PEIS to explain why they were included in the tables while the Permissible Exposure Limits, being the legal value, was the only one used in calculations. In the Final PEIS text has been modified to explain why these values have been given in table E.3.3- 1. It should also be noted that table E.3.2-1 has information on physical, chemical, and toxicity properties that were not necessarily utilized in a direct sense. However, information such as this as well as other limit values should help inform the reader as to concentration and dose levels that would cause an immediate problem, or a long-term one, and how the estimated concentrations compare to these values. 11.01.06 In reference to volume II, page E-71, section E.3.2, chemical toxicity profiles, the commentor asks in the last sentence, what does, "for those chemicals for which adverse health effects were developed in this PEIS," mean. Response: This sentence has been modified in the Final PEIS for clarity as follows: "Table E.3.2- 1 presents the information described above for the hazardous chemicals analyzed in this PEIS." 11.01.07 The commentor refers to the following statement in volume II, page E-72, paragraph 1: OSHA Permissible Exposure Limits are also for preventing cancer effects, not just noncancer adverse effects. According to the commentor, this paragraph indicates that all three (OSHA, National Institutes of Occupational Safety and Health (NIOSH), and American Council of Governmental Industrial Hygienists (ACGIH)) were used to develop HQs and HIs. Therefore, the commentor questions why NIOSH was not included in the risk assessment section tables. Also, the commentor asks why does the equation for the HQs use Permissible Exposure Limits and not the others. Response: While the OSHA Permissible Exposure Limits might also be effective in preventing cancer effects, they are designed for 8 hour occupational exposures and do not factor into any calculations that can be used for predicting the risk of cancer from exposures, in fact, identified human carcinogens are not assigned Permissible Exposure Limits. It would, therefore, be misleading to represent them as such. In fact, the OSHA-regulated carcinogens do not carry Permissible Exposure Limits values, but these compounds are to be controlled through the required use of engineering controls, work practices, and personal protective equipment, including respirators. The specific details of these requirements are in 29 CFR 1910.1003-1910.1016. The paragraph clearly states that OSHA's Permissible Exposure Limits regulate the hazardous chemicals, whereas the others only provide guidance. The document should not have cited a regulatory role for NIOSH, and this correction in the paragraph was made in section E.3.3 of the Final PEIS. It is, therefore, correct to use the legal value for Permissible Exposure Limits provided by OSHA. 11.01.08 Numerous specific comments were received on table E.3.1 in volume II, page E-73. Some of the concerns raised by the commentor included: how were the myriad of chemical entities in the table selected to be included in the risk assessment; compound names should be standardized (IUPAC or ACS) and the use of trade names (e.g., the DuPont trade names for Freon Brand Chlorofluorocarbons) should be avoided; the CAS Registry No. heading does not require a footnote; flash point would be a more useful heading than flammability, and the ranges currently used therein; criteria for "Carcinogenicity" ranking need additional defining in the text; and where in the document are the published reference sources mentioned in the table footnotes. Response: All the comments received on the table in section E.3-1 have been reviewed and appropriate changes made to table E.3.2-1 in the Final PEIS. The chemicals listed in table E.3.2-1 were identified as emissions at the specific DOE candidate sites or by other referral sources as toxic chemical releases or as chemicals associated with specific proposed technologies. They were selected based on quantities (generally 100 lb. or more) and their relative toxicity based on a variety of reference sources, e.g., EPA's Integrated Risk Information System and OSHA exposure limits. A standardized nomenclature is preferred, but the sources of information frequently used traded or common names. The chemical name, e.g., Chlorodifluoromethane (Freon 22) and the CAS Registry number were included to add certainty to the identification of the specific chemical. The CAS Registry No. heading has been removed. The heading "flammability" was considered appropriate for table E.3.2-1 because the issue is whether or not the chemical is flammable and to what degree it is considered flammable or combustible. For some readers the "Flash Point" may be more useful while for others the OSHA flammability classification is more useful. The flash point can be found in the reference document cited. Table E.3.2-1 has been revised to replace "none" with the International Agency for Research on Cancer classification as noted by footnote (r). "Not applicable" means that there is no cancer classification. Based on the resources available the chemical was not identified as carcinogenic. "Information not available" (e) is based on the availability of resource information on carcinogenicity, and it means that this information could not be found using standard references. The footnote references are located in volume I, chapter 6. 11.01.09 The commentor refers to volume II, pages E-73 to E-90, tables E.3-1 and E.3-2 and asks when the intent of the health risk section is to evaluate risk to the public and workers, why is the EPA's cancer classification the only one listed in the chemical toxicity profiles and table of exposure limits. The commentor notes that OSHA, NIOSH, and ACGIH classify carcinogens. In particular, the commentor states that ACGIH has a very detailed cancer classification system. Response: It is acknowledged that there are other classification systems that provide guidance on cancer classification and many were reviewed for this PEIS; however, it is EPA's system that is used in regulation of carcinogens. As noted in the PEIS, the International Agency for Research on Cancer also classifies carcinogens, but again it does not have regulatory status in the United States for carcinogens. Furthermore, the EPA unit risk and the slope factor for each carcinogen are the ones that are to be used in calculation of cancer risk. 11.01.10 Numerous specific comments were received on table E.3-2 in volume II, page E-82. Some of the concerns raised by the commentor included: why are the 1992 Threshold Limit Values used instead of 1994; what does an entry of "NA" in the cancer class mean; and what is the method of calculating the Reference final Dose and Reference final Concentration from the ACGIH Threshold Limit Values, the OSHA Permissible Exposure Limits, the NIOSH Recommended Exposure Limits, the Registry of Toxic Effects of Chemical Substances (RTECS), time-weighted average (TWA)/Permissible Exposure Limits, and the RTECS LD50. Response: All the comments received on the table in section E.3.3 have been reviewed and appropriate changes made to table E.3.3-1 in the Final PEIS. A cutoff point in time for regulated numbers was chosen to avoid unnecessary rewriting of tables and redoing calculations for the PEIS; however, the Threshold Limit Values are only guidance and not used for calculations due to this status. The Threshold Limit Values and Permissible Exposure Limits (actually used in calculations) available at the time of the Draft PEIS were those available. Only after completing the Draft PEIS did the new numbers become available. Action taken by the U.S. Supreme Court overruled the Permissible Exposure Limits so that they reverted to the 1970 standards until new ones are developed by OSHA; these are now in progress and may take up to 5 years, since they must be reconciled with the guidance from other agencies. Obviously, the 1994 published Permissible Exposure Limits are less conservative based on additional information gained during the 24 year time gap. The entry "NA" was intended to mean that the compound is either not been classified or that it is a noncarcinogen. This has been changed in table E.3.3-1 of the Final PEIS and replaced with the published classification, e.g., the official EPA or in the absence of EPA classification where decision is pending, used IARC classification. The method of calculating the Reference final Dose and Reference final Concentration from the ACGIH Threshold Limit Value, the OSHA Permissible Exposure Limit, and the NIOSH Recommended Exposure Limit is RfD (mg/kg/d) = 0.007 TWA (mg/m3) and was taken from the source citation in footnote reference b of table E.3.3-1 in the Final PEIS. The NIOSH Recommended Exposure Limits were not used in the calculation. The RTECS TWA/Permissible Exposure Limit values are actually LD50s which have been changed in the table where appropriate. Also, the LD50 is used only if there is no other way of approximating an Reference final Concentration or Reference final Dose for which there are no official values. In this case the following was used to estimate a Reference final Dose, according to the source in footnote reference b of table E.3.3-1 in the Final PEIS: RfD = LD50 x (4 x 10-5). The RTECS citation has been added as an EPA document citation where appropriate. 11.01.11 In reference to volume II, page E-85, table E.3-2, the commentor notes that the formaldehyde NIOSH Recommended Exposure Limit is not 0.16 ppm as listed, but rather 0.016 ppm. Furthermore, the commentor indicates that the OSHA Permissible Exposure Limit is 0.75 ppm and not 1 ppm. The commentor suggests that a thorough check should be made for other errors. The commentor notes that the result of such errors is to produce incorrect HQs and HIs for workers. Also, formaldehyde does not appear in the risk assessment tables, so the commentor wonders why is it included in the exposure limit table. The commentor further states that it seems logical to include only information on the chemicals of concern. Response: The error in the NIOSH Recommended Exposure Limit has been so noted and corrected from 0.16 ppm to 0.016 ppm and the OSHA Permissible Exposure Limit was also noted and changed to 0.75 ppm. In table E.3.4-22 (Pantex No Action) under aldehydes, formaldehyde appears as the representative used because it would be the worst case chemical which had been reported at this site. However, this chemical has been removed from the Pantex risk assessment based on new information that it is no longer present as a potential chemical emission. 11.01.12 In reference to volume II, beginning of page E-91, tables E.3.4-1 to E.3.4-7, the commentor states that either the risk assessment calculation used the least stringent exposure limits of the two listed or did not consider the Threshold Limit Values which are listed in the risk assessment tables as indicated by footnote c. The commentor notes that the Threshold Limit Values happen to be more stringent for the two chemicals, checked on page E-93, methanol and ethanol. This results in a smaller hazard quotient and a smaller hazard index, which implies less risk than if all the agency standards were considered. OSHA is the only law. However, it is recognized that the other agencies' standards (NIOSH and ACGIH) are more current with available toxicology and epidemiology. The commentor questions why only Permissible Exposure Limits would be considered and not the most conservative (e.g., ammonia) as listed in exposure limit tables PEL: 27 TLV: 17 REL: 18. Response: The risk assessment calculation did not use Threshold Limit Values because they are guidance only, whereas the Permissible Exposure Limits are the regulated numbers from OSHA and constitute the law. Consideration was given to using the most stringent number regardless of whether it was guidance, e.g., ACGIH, NIOSH, or OSHA, but since the OSHA is the enforceable regulation, it was decided to present the other guidance numbers and use only OSHA Permissible Exposure Limits, thus making the calculations uniform and from an official regulatory source. 11.01.13 In reference to volume II, pages E-91 to E-130 (tables E.3.4.1 to E.3.4.36), the commentor notes that the contaminants of potential concern vary from site to site. The commentor asks how they were chosen for each site. Response: The containments of potential concern vary from site to site only under No Action due to differing current activities at each site. Those identified for each technology are consistent from site to site. 11.01.14 The commentor refers to volume II, page E-92, table E.3.4-2 and states that the Threshold Limit Value listed for methanol of 200 mg/m3 is incorrect. The commentor believes that it should be 262 mg/m3. The commentor indicates that only a spot check was conducted so the rest of the numbers should be checked for errors. According to the commentor, it appears as though the larger the Permissible Exposure Limit, the larger the rounding. For example, the commentor notes that acetone was rounded up to 1800 from 1780 and nitric acid from 5.2 to 5. The commentor expresses the opinion that one would like to think that a fair amount of scientific rigor goes into establishing exposure limits. Therefore, the commentor wonders what is the purpose of rounding and especially rounding up. Response: The Threshold Limit Value corrections were noted and entered on the table. In 29 CFR 1910, the TWA is listed as 1800 mg/m3; this value was utilized as the Permissible Exposure Limit; likewise, in the same document nitric acid is listed at 5 mg/m3. If a rounded up number was used in our calculations, it would only be so because of the reference source that was used. However, the difference is only 1 percent which would hardly make a difference, if any, in the calculation and would still be protective since Permissible Exposure Limits and Threshold Limit Values are highly conservative, being reduced by large conservative factors. All numbers and references in table E.3.4-2 were rechecked against the original references on a page by page basis and corrected in the final table. The table references were corrected when it did not match the precise table reference. 11.01.15 The commentor refers to volume II, tables E.3.4-29 and E.3.4-35 and indicates that these tables mention tetrachloroethylene as a contaminant of potential concern. However, the commentor notes that it is not listed in either table E.3-1 or table E.3-2. The commentor requests an explanation as to why it is not reviewed in those tables if it is, in fact, a contaminant of potential concern. Response: The chemical mentioned above, tetrachloroethylene, was inadvertently deleted from both tables. It has been reinstated in both tables in section E.3 of the Final PEIS. 11.01.16 The commentor refers to volume II, page E-133, paragraph 2 and offers the correction: Odds Ratio not Odd Ratio. Response: Odds ratio is correct, and this change has been incorporated in section E.4.1.2 of the Final PEIS. 11.01.17 The commentor refers to volume II, page E-133, section E.4.2, INEL, and notes that two Idaho Department of Health and Welfare and one National Cancer Institute epidemiologic cancer studies are referred to in the text (that is, 1991a and 1991b). The commentor wonders where these references are located. Response: The National Cancer Institute and the Idaho Department of Health and Welfare references are located in chapter 6. 11.01.18 The commentor refers to the following statement in volume II, page E-133, section E.4.2, workers: "No occupational epidemiological studies have been conducted to date, although NIOSH is planning one in 1994." Considering the date of publication of the PEIS as February 1995, the commentor suggests that this statement needs to be corrected or updated. Response: The text has been changed in section E.4.2 of the Final PEIS to: "Although no occupational epidemiology studies have been conducted to date, according to NIOSH one is currently underway, but no results are expected before 1997." 11.01.19 For clarity to the public, the commentor suggests that the Final PEIS explain why the annual average doses to a site worker differ for each of the five proposed locations. Response: The Final PEIS has been revised to include this explanation. Basically, the differences result from the fact that the doses presented are the averages among all site workers, including those involved in activities other than tritium supply and recycling. This explanation has been added to the introduction in appendix E which covers the following concepts: the sites vary considerably in size, geography, meteorology, and topography, as well as the source terms present at each of the sites. They are presently performing different functions and the amount of activity is also different. Therefore, toxic releases will be different, the dispersion of these releases will be different, and consequently the level of exposure at any given distance from the source terms will vary. 11.01.20 The commentor, referencing volume II, appendix E, states that it is not clear that the Plutonium Pit Disassembly Conversion/Mixed-Oxide Fuel Fabrication Facility impacts are appropriately included in the proposed alternatives. The potential impacts from this facility should be evaluated as direct impacts associated with proposed alternatives, according to the commentor. The commentor believes that the occupational doses from normal plutonium handling and glovebox operations, as well as postulated accident scenarios to both onsite and offsite personnel, could be significant depending on the processes involved within this facility. The commentor further states that these actions will all contribute to cumulative impacts both onsite and offsite. Response: Cumulative impacts from the Plutonium Pit Disassembly Conversion/Mixed-Oxide Fuel Fabrication Facility impacts are included in site-specific radiological human health sections for the multipurpose reactor. 11.01.21 In reference to health risks data listed in volume II, page E-8, column 2, paragraph 5; page E-9, column 1, paragraph 1; page E-21, column 1, paragraph 3; etc., the commentor wonders whether the document identified is HNUS 1993b or HNUS 1995a. Response: The reference is HNUS 1995a. The citation in the text has been changed to reflect this. 11.01.22 In reference to pages I-53, I-55, I-59, I-63, and I-67, the commentor states that the cancer risk from hazardous chemicals to the maximally exposed member of the public at SRS differs from that shown in table E.3.4-36. The commentor asserts that this should be reconciled. Response: These values have been changed to be consistent with the text tables as well as the appendix. Other changes have been made for other sites in appendix I due to changes in site data made after the Draft PEIS. 11.01.23 In reference to page E-124, the commentor states that this table shows six chemical hazards for the MHTGR at SRS, whereas five hazards were listed for MHTGR at all the other sites. The commentor questions why ammonia and trichlorotrifluoroethane (Freon 113) would be hazards at SRS and not at other sites. The commentor also asks why should methane emissions not be listed at SRS. If changes are made, states the commentor, summary table E.3.4-36 on page E-130 should be corrected accordingly. Response: Ammonia and trichlorotrifluoroethane were inadvertently added to the MHTGR for SRS. The affected tables have been corrected and updated. 11.01.24 In reference to page 3-71, the dose and risk for the APT (helium-3) at ORR should be re-evaluated, according to several commentors. The commentors state that according to table E.2.6.1-2 APT (helium-3) contributes a factor of 20 less than APT spallation-induced lithium conversion target, not a factor of 2 less. The commentors also note that this comment applies to page 3-76. Commentors referring to page F-21 state that it is not reasonable that the population dose and cancer fatalities at ORR are only 20 percent higher than at INEL for the APT spallation-induced lithium conversion target, when they were nearly an order of magnitude higher for all the other concepts. The commentors suggest that this be reconciled with page 3-83, which indicates more than an order of magnitude difference between the two sites. Response: The values given in table 3.6-1 and appendix E are consistent in the Final PEIS. It should be noted that the values in table 3.6-1 include total site operations, not the technology alone. Appendix F has been revised to include a spectrum of accidents for each of the candidate tritium supply technologies. The applicable page number or table number in the reference document for source terms, release fractions, core inventories, accident frequencies, etc. has been cited. The data in section 3 have been revised and updated to reflect the changes. 11.01.25 In reference to page 3-71, the commentor states the doses at SRS given here are approximately 0.5 mrem higher for all concepts than values in section E.2.8.2. The corresponding risks are also higher, according to the commentor. The commentor suggests that this be reconciled. Response: The values given in table 3.6-1 and appendix E are consistent in the Final PEIS. However, the reader should refer to section E.2.8 for an explanation of how the total doses for each tritium technology are calculated. 11.01.26 In reference to page 3-72, the commentor states that the population doses at ORR given here are approximately 10 person-rem higher for all concepts than the values in section E.2.6.2. The commentor asserts that the risks are 0.4 fatalities higher, which is a factor of 2 more than would be expected from 10 person-rem. The commentor suggests that this be reconciled. Response: The values given in table 3.6-1 and appendix E are now consistent. It should be noted that the values in table 3.6-1 include total site operations from both air and liquid pathways. 11.01.27 In reference to page 3-73, the commentor states that the population doses at SRS given here are approximately 40 person-rem higher for all concepts than values in section E.2.8.2. The commentor adds that the risks are also correspondingly higher. This should be reconciled, according to the commentor. Response: The values given in table 3.6-1 and appendix E are now consistent. It is believed that the commentor meant to reference page 3-72 instead of 3-73. It should be noted that the values in table 3.6-1 include total site operations from both air and liquid pathways. 11.01.28 In reference to page 3-77, the commentor states that the value of person-rem for APT (helium-3) at INEL should be rounded to 0.6 instead of 1, to maintain consistency with the fatal cancer value. Response: All numbers have been rounded to be consistent with the fatal cancer values. 11.01.29 In reference to page 3-77, the commentor states that the population doses at ORR given here are approximately 10 person-rem higher for all concepts than values in section E.2.6.2. The risks are 0.4 fatalities higher, according to the commentor, which is a factor of 2 more than would be expected from 10 person-rem. The commentor suggests that this be reconciled. Response: The values given in table 3.6-1 and appendix E are now consistent. It should be noted that the values in table 3.6-1 include total site operations from both air and liquid pathways. 11.01.30 In reference to page 3-79, the commentor states that based on information in table E.3.4-7, the worker reduction for HWR at INEL should be 0.2 percent, not 0.02 percent, and the public reductions for the MHTGR, ALWR, and APT, should be 0.3, 0.09, and 0.3, respectively, not two orders of magnitude higher. The commentor suggests that this be reconciled. Also, referring to page 3-79, based on information in table E.3.4-28, the public reductions for the HWR, MHTGR, ALWR, and APT should be 0.1, 0.1, 0.09, and 0.1, respectively, not two orders of magnitude higher. This should be reconciled. Response: The error was due to not converting a decimal to a percentage. These corrections and others associated with the calculations have been made. 11.01.31 In reference to page E-13, the commentor states that the text for the HWR gives risk of fatal cancer from 1 year of operation, whereas for all the other concepts the text gives risk of fatal cancer from 40 years of operation (except for Large ALWR, for which no discussion paragraph is provided). The commentor suggests that the same figures of merit be quoted for all concepts, to avoid confusion or deception. Response: The text and the fatal cancer risk values have been modified to reflect 40 years of operation. 11.01.32 In reference to page E-20, the commentor notes that the annual tritium release given for tritium target extraction facilities in table E.2.3.5-1 is equal to the design criterion for the New Production Reactor Tritium Recovery Facility. This is not reasonable, according to the commentor. Since the current goal of producing 3/8 as much tritium would result in handling less than such a facility was designed for in the New Production Reactor Program, the commentor would expect a commensurate reduction in tritium release. Response: The technology designs for the Tritium Supply and Recycling Program differ from the technology designs in the New Production Reactor Program as the tritium supply and recycling facility is designed specifically to produce only tritium. In addition, the tritium releases estimated for the New Production Reactor Program were conservative and bounding. A site-specific analysis would incorporate the as low as reasonably achievable concept to minimize releases. 11.01.33 In reference to pages E-27 and E-28, the commentor states that the same values are entered in both tables (for maximally exposed individual and for population) for the Full APT with spallation-induced lithium conversion. The commentor asserts that this must be a mistake. Response: This typographical error has been corrected in tables E.2.4.1-2 and E.2.4.1-3 of the Final PEIS. 11.01.34 In reference to page E-30, the commentor states that the paragraph summarizing health effects should quote values for NTS, not INEL. Response: The appropriate changes have been made in section E.2.5.2 of the Final PEIS. 11.01.35 In reference to page E-37 and E-48, the commentor states that in table E.2.6.1-2, the committed effective dose equivalent (and next two entries to the right) for the Full APT cases are probably switched since they cannot be derived by adding the values to the left. The commentor suggests that alternatives be presented in the same order in both tables. (ALWR cases are switched with other reactor cases, Full APT cases are switched.) The commentor notes that on pages E-37 and E-38, the alternatives should be presented in the same order in both tables (Full APT cases are switched) and the title of table E.2.5.1-3 should be "...at Nevada Test Site". Response: The appropriate changes have been made to the document. 11.01.36 In reference to page E-123, the commentor states that the table shows five chemical hazards for HWR at SRS, whereas seven hazards were listed for HWR at all the other sites. The commentor asks why nitric acid (a dominant hazard at other sites) and trichlorotrifluoroethane (Freon 113) are not also hazards at SRS. If they are added, states the commentor, summary table E.3.4-36 on page E- 130 should be fixed accordingly. Response: Nitric acid and trichlorotrifluoroethane were inadvertently omitted from the HWR for SRS. The affected tables have been corrected and updated. 11.02 Human Health - Facility Accidents 11.02.01 One commentor wonders what are the risks and consequences for the accident scenarios presented for the proposed technologies. Another commentor expresses concern about the increased likelihood of cancer fatalities to the population within a 50 mile radius of a tritium recycling or extraction facility during an accidental release. Response: Appendix F of the PEIS presents the methodologies and assumptions used for the facility accident scenarios. Potential human health impacts are discussed in the PEIS and the ROD will consider these in any decisions for selecting a tritium supply technology or site. 11.02.02 The commentor refers to the following statement in volume I, page 4-454, column 2, paragraph 1: "...compared to doses resulting from direct exposure to such a criticality event, these doses are inconsequential and well below DOE standards for extreme accidents given in DOE Order 6430.1A." The commentor questions the estimated dose resulting from direct exposure to such a criticality event. Also, the commentor suggests that a more specific reference to DOE standards for extreme accidents be provided. Response: Recommendations for the Preparation of Environmental Assessments and Environmen- tal Impact Statements, prepared by the DOE Office of NEPA Oversight in 1993 provides guidance in the evaluation of extreme accidents. Facility design and operational information required for a PEIS is not detailed enough to identify the location of the criticality source in relationship to normal work stations and available shielding. The available information is not adequate to estimate involved worker doses due to a criticality event. 11.02.03 The commentor states that the release fraction values listed in appendix F, tables F.2.1.1-1, F.2.1.3.1- 1, F.2.1.3.2-1, F.2.1.3.3-1, and F.2.1.3.4-1 from postulated accidents could not be verified. The commentor asserts that reference documents provided in a DOE reading room did not provide adequate documentation to support release fraction value usage. Response: These sections in appendix F have been revised to include a spectrum of accidents. The applicable page numbers or table numbers in the reference document for source terms, release fractions, core inventories, etc. have been cited. 11.02.04 Commentors believe that appendix F, facility accidents, of the Draft PEIS needs to be revised substantially for the Final PEIS to assure parity between the reactor and APT assumed accident scenarios. The high consequence accident analyses reported in the Draft PEIS compare latent cancer deaths from very low probability, beyond design-basis severe accidents for the reactor alternatives, in which major safety related systems including the robust containment are assumed to fail, to design-basis accidents for the APT, in which key safety systems are assumed to operate to mitigate the accident. The commentors note that for even the bounding low-to-moderate consequence accident, it is unclear as to whether the reactor containment and isolation systems are also assumed to fail making the probabilities much lower than these assumed in the Draft PEIS. The commentors state that in the Draft PEIS presentation of the APT low-to-moderate consequence accidents, all protective systems are assumed to operate. The commentor suggests that the assumed equipment failures and the specific reference documentation for the reactor accident analyses (deterministic safety analysis reports, probabilistic risk analyses, and other topical reports submitted to NRC for bounding assessments) should be identified. The commentors further suggest that the source term total inventory of releasable nuclides and the release fraction should be quantified for each accident and alternative technology. The commentors assert that nonconservative assumptions that the APT requires no containment, the APT's non-seismic design, the lack of environmental qualification for equipment, and the lack of fire protection are just a few examples of design features that will be challenged by NRC and result in a more expensive design for the APT. Response: A reanalysis of the reactor accident scenarios was conducted, indicating accident consequences are substantially lower and more in line with expected licensing documents. For the ALWR, the postulated design-basis accident was more severe than normal design-basis accidents because the analysis assumed the complete loss of safety systems that mitigate accident consequences. A more reasonable value was used to obtain the results presented in appendix F and the associated human health sections. Additionally, the accident analysis for the APT has been revised to be more consistent with assumptions for the reactor alternatives. 11.02.05 The commentor offers several content and editorial changes to table 3.6-1. In reference to pages 3-80 to 3-83, the commentor asserts that the data entered on these pages is actually for tritium supply alone not for collocated tritium supply and recycling, as the headings allege. The commentor also suggests that the cancer risks from the accidents considered for the tritium target extraction facility in table F.2.2.5-1 and for the tritium recycle facility in table F.2.4-1 should be included on pages 3-80 and 3-81. The commentor believes this is especially significant for the APT concepts, since for the reactor concepts presented, the tritium supply dominates the cancer risk. According to the commentors, it would be more appropriate to present the sums of the cancer risks to the individual and the population along with the doses and fatalities associated with the risk dominant event/facility. In reference to page 3-82, the commentor states that, based on information in table F.2.1.4.2-3, the cancer risks at INEL for the APT concepts do not seem to have been adjusted for the accident frequency. The commentor additionally states that for all sites excepts SRS, the cancer risks and cancer fatalities for the APT concepts differ from those in tables F.2.1.4.2-3 and F.2.1.4.2-3 for no apparent reason. Also, for NTS, ORR, and Pantex, the individual doses for the APT concepts differ from those in tables F.2.1.4.2-3 and F.2.1.4.3-2 for no apparent reason, according to the commentor. The commentor suggests that this be reconciled. The commentor further states that, according to tables F.2.2.3-2 and F.2.2.3-4, the population doses at ORR for the large and Small ALWRs should be 4.9x105 and 2.2x104, respectively. This should be corrected on page 3-81, according to the commentor. Response: Chapter 3 has been reformatted to address the relationship between the APT and MHTGR technologies and the target extraction facility. Appendix F has been revised to include a spectrum of accidents for each of the candidate tritium supply technologies. The complementary cumulative distribution function figures have also been reformatted to provide risk-based summary comparisons. The ALWR accident analyses have been revised to evaluate a spectrum of design-basis and beyond design accident source terms that have been submitted to the NRC as part of safety analysis reports. The data in section 3 have been revised and updated to reflect these changes. The tables in appendix F have also been revised. In the accident consequence tables, the "Average Individual Risk of Cancer" heading has been changed to "Cancer Fatality." That column in the table does not reflect cancer risk because accident frequency was not considered. 11.02.06 The commentor states that the Final PEIS should include more information on emergency preparedness for each site, especially if a reactor technology is chosen as the preferred alternative. Response: The PEIS includes an expanded discussion on emergency preparedness at each of the candidate sites in sections 4.2.2.9, 4.3.2.9, 4.4.2.9, 4.5.2.9, and 4.6.2.9. Additional information has been provided that explains some of the changes to emergency preparedness planning and local agency agreements that would be required for candidate sites that would, if chosen, be receiving reactor technology for the first time. The PEIS also references the Emergency Preparedness Plan for each site. The referenced plans are available in DOE reading rooms. 11.02.07 In reference to page I-77, the commentor states that it seems inflammatory to include statements such as "If this accident occurred, this exposure would result in a total of ---- cancer fatalities. Response: The statement is used to indicate a constitutional probability of cancer induced fatalities, given that the accident occurs. It does not imply this event as a likely occurrence. 11.02.08 In reference to page F-31, the commentor states that the population dose at Pantex should be 25,000 and not 0.00025. Response: The typographical error has been noted. The exponent has been changed from -4 to 4. 11.02.09 In reference to page 3-83, the commentor states that, according to table F.2.1.4.2-3, the population dose for APT (helium-3) at NTS should be 1.8x10-3 and not 1.8x103. Response: The exponent has been changed from 3 to -3. 11.02.10 In reference to page 3-84, the data in table F.2.1.5-1 show that the tritium target extraction facility poses more cancer risk for high consequence accidents than either the MHTGR or the APT concepts, and the data in table F.2.2.5-1 show that the tritium target extraction facility poses more cancer risk for moderate consequence accidents than the APT concepts. Therefore, states the commentor, it is erroneous to state that "the radiological impacts from the recycling and extraction facilities are neg- ligible compared to those from the supply technologies." The commentor states that the tritium supply alone section needs to be revised by incorporating the data currently on pages 3-80 through 3-83. Response: The table 3.6-1 has been revised in the Final PEIS to reflect that accident consequences for tritium extraction and recycling associated with the APT and MHTGR tritium supply technology alternatives are more severe than the accident consequences associated with the APT and MHTGR tritium supply "alone" technology alternatives. 11.02.11 In reference to page F-6, the commentor states, the reference for MHTGR source terms should be a document applicable to the MHTGR, which DOE 1992r is not. The commentor states that table F.2.1.2-1 indicates that DOE 1995e is the source. Response: Table F.2.1.2-1 is correct, DOE 1995e is the source. 11.02.12 Commentors observe some discrepancies in chapter 6 references. In reference to page F-8, one commentor states that the references for ALWR source terms should probably be DOE documents, instead of DOESNL documents, which are not included in the chapter 6 references. A commentor referencing page F-12, notes that reference DOE 1993n:2 is cited as the source of table F.2.1.3.2-1 data, but is not included in the chapter 6 references. Response: The correct references for the ALWR source terms is the Data Report for Advanced Light Water Reactor Tritium Supply Plant, DOE 1995f. Chapter 6 has been revised to include all references cited in volumes I and II. 11.02.13 In reference to page F-31, the commentor states that section F.2.2.5, fourth sentence, ("Air leakage...") is garbled and appears incomplete as written. Response: The sentence has been changed in Section F.2.1.6 of the Final PEIS to read: "The explosion was initiated by air leakage from furnace leaks, tank leaks, connection leaks, pump leaks, valve leaks, or during process maintenance. The air leakage formed a flammable mixture that subsequently ignited." 11.02.14 In reference to page F-31, the commentor suggests that, in section F.2.2.4.3, the term "worst single failure" be explicitly defined. The commentor also suggests that the "minimal" release be quantified. Response: The reference document stated "The accident assumes that all plant-protection safety systems function as designed. The worst single failure in an active system responding to the initiating event is assumed to occur." No other information relevant to the single failure was presented. Normally in large break loss of coolant accident analyses, the worst single failure in an active system responding to the initiating event would be the loss of one leg of an active cooling system. The reference document stated "The source term for this event will consist of a small fraction of the circulating inventory of tritium released from the D20 coolant that is expelled into the confinement. The source term to the environment will be a small fraction of this and is expected to be determined by the confinement leakage rate." Quantification of these small release fractions would be developed and analyzed in subsequent NEPA reviews as appropriate. 11.02.15 In reference to page F-26, the commentor states that, in more than 10.87 years of actual PWR experience as of January, 1992, no large pipe breaks have been observed. The commentor states that the vessels and piping in both the MHTGR and the ALWRs will be similar. Thus, the frequencies of the events in sections F.2.2.2 and F.2.2.3 can be estimated based on the X(2) variate at the 50 percent cumulative probability level to be less than 2.1x104 per year, instead of 102 and 103, respectively. (See page 19.3-10 of the CESSAR for Design Certification of the System 80+.) This affects text on page F-26 and footnotes to tables F.2.2.2-2, F.2.2.2 -3, and F.2.2.3-2 through F.2.2.3.2-7, according to the commentor. Response: The size of the 1/8 size MHTGR module primary piping is anticipated to be significantly smaller than the primary piping associated with the 3/8 size ALWR. ALWR safety analysis reports submitted to the NRC typically show that the probability of a large break loss of coolant accident is an order of magnitude lower than a small break loss of coolant accident. The PEIS assumes that the same relationship was valid for the 1/8 size MHTGR module pipe breaks (i.e. small break loss of coolant accident) and the 3/8 size ALWR pipe breaks (that is, large break loss of coolant accident). The PEIS estimates that the frequency of ALWR large pipe breaks are in the range of 1x10-3 to 1x10-5 per year and the frequency of MHTGR pipe breaks is in the 1x10-2 to 1x10-4 per year range. The estimated ranges are not inconsistent. 11.02.16 In reference to page F-24, the commentor states that, according to page 3-80, the individual dose at NTS is 8.4x10-3, not 8.4. This should be reconciled according to the commentor. Response: The typographical error in table F.2.2.1-2 has been corrected and 8.4 has been changed to 8.4x10-3. 11.02.17 Commentors believe that values for radiation exposures and resulting fatalities for low/moderate accident consequences of HWR and ALWR are not accurate. The commentors note that the values of the accident consequences for the APT and MHTGR are unusually low. In addition, the commentors note that the 10-6 accident probability for the APT results in consequence orders less than the reactor technologies while the MHTGR consequences seem inconsistent with past analyses. The commentors also note that the document uses a value of 10-3 for accident probability for the HWR and ALWR when 10-6 would have been a more accurate value. In the commentors opinion, this makes reactor technologies look more dangerous than they are. According to the commentors, the document should integrate the risks of all potential accidents identified instead of the two individual events analyzed to present a range of consequences. The commentors believe that the risk values in the human health section are the more important figures and these values are extremely small irrespective of the technologies. Commentors further suggest the document put human health numbers in perspective by comparing the numbers to other activities which carry a cancer risk, such as smoking or living in a brick house. The commentors state that risks for the tritium supply dominate the moderate consequence cancer risk for all reactor concepts. According to the commentor, the sums of the cancer risks and fatalities associated with the risk dominant event/facility should be presented. The commentors assert that the ALWR low/moderate consequence accident assumptions are inconsistent with NRC standards. The commentors also caution that DOE must be careful to state what accident probabilities were used from NRC reports, such as accident probability value from a worst case scenario Safety Analysis Report, because these would lead to misleading values of consequences. Response: The accident consequences were estimated using source terms from the best available public documentation and the GENII computer code. The referenced documentation did not provide accident frequencies, so a frequency range was estimated. For conservatism, the lower end of the range was used for point estimates of risk. Volume I compared the cancer risk due to accidents to the risk of cancer due to other causes. The ALWR accident source term used in the analysis was designated by the reactor vendor as a design-basis accident in a submittal to the NRC. The postulated design-basis accident was more severe than normal design-basis accidents because the analysis assumed the complete loss of safety systems that mitigate accident consequences. The documentation submitted to the NRC did not define the accident frequencies for design-basis accidents. The ALWR accident analyses have been revised to evaluate a spectrum of design-basis and beyond design accident source terms that had been submitted to the NRC as part of safety analysis reports. The design-basis accident analysis postulates the normal complement of safety systems for accident consequence mitigation. 12 General/Miscellaneous Environmental 12.01 The commentor states that DOE should analyze the consequences of its actions beyond the year 2050. The PEIS should take into account the consequences of the proposed action after 2050, according to the commentor. Response: For the purposes of selecting a site and technology for the supply of tritium as well as designing and operating this facility, the analytical period ending with 2050 is appropriate. This amount of time allows for operation through a reasonable operating life based on a 40 year design, as well as providing sufficient time for the closing and D&D of such a facility. To expand the analytical timeframe beyond this date would introduce sufficient technical uncertainties to render projections based on this analysis too subjective for programmatic planning purposes. 12.02 One commentor asserts that the new tritium facility will cost taxpayers billions of dollars, produce more spent fuel for which there is no repository, and use too much of vital water supplies. Another commentor questions how waste generation and water consumption will be weighted in the final decision. These two issues, according to the commentor, should count heavily in the decision making process. The commentor also states that the PEIS should include a comparative analysis study on the benefits and risks involved with these two issues and that DOE should outline how they will be weighted. Other commentors express concern over the possible negative impacts the tritium supply and recycling facility might have on the environment. Response: Environmental impacts associated with spent nuclear fuel, waste management, and water consumption are being considered in the decision process as well as the cost and technical feasibility of the alternatives. 12.03 The commentor states that each of the proposed sites has a unique set of environmental challenges to mitigate if a tritium supply facility is constructed and operated on it. At all sites there are potential impacts on the habitat of flora and fauna. If SRS is chosen DOE will need to minimize impacts on the natural flow of surface and ground water. Both the NTS and Pantex plant have the potential for aquifer drawdown if the accelerator technology is selected and have the potential to impact the habitat of threatened and endangered species. If reactor technology is selected, ORR has the greatest potential to impact the offsite population should a severe accident occur. NTS is also located in a tectonically active region and would require the largest amount of infrastructure upgrades. INEL does not appear to have any significant discriminating environmental attributes associated with it. Response: The existing environmental conditions and past operations at each of the tritium supply candidate sites contribute to the environmental impacts and required mitigations for construction and operation of any of the proposed tritium supply technologies. The PEIS has identified the affected environment and potential impacts resulting from construction and operation of each of the technologies at each site. Potential mitigation has been identified based on the current conceptual design impact assessment. The impacts to SRS surface and groundwater resources are described in section 4.6.3.4 of the PEIS. Because the green-field design of the tritium supply technologies did not consider the candidate site site-specific characteristics, the design features normally used to mitigate many of the potential impacts were not identified. If selected, the technology design would proceed and site-specific NEPA documentation would analyze the potential impacts in much more detail. The potential impact to groundwater resources at NTS and Pantex from the APT technology has been reanalyzed in the Final PEIS based on information provided during the Draft PEIS public hearing and review process. The NTS aquifer recharge rate and potential impacts have been changed to reflect additional studies conducted on the aquifer. Water requirements for the APT technology have also been lowered based on more design implementation. Even including the potential water use of the proposed solar enterprise, informational activities at NTS, the projected water use would not exceed the estimated lower aquifer recharge rate. If selected as the tritium supply technology at NTS, further design development would be expected to reduce the conceptual design water use substantially. The aquifer issue and potential impacts at Pantex have been essentially eliminated. The availability of a substantial quantity of tertiary treated reclaimed wastewater for use as tritium supply technology cooling has replaced the use of Ogallala aquifer water for the tritium supply project at Pantex. The potential impacts to threatened and endangered species at Pantex and NTS was discussed in sections 4.5.3.6 and 4.3.3.6, respectively. As discussed in the PEIS, critical habitat for threatened and endangered species as defined in the Endangered Species Act (50 CFR 17.11; 50 CFR 17.12) exist on Pantex and NTS. The potential impacts to the bald eagle at Pantex and the desert tortoise at NTS are identified and potential mitigation measures proposed. If selected as a tritium supply site, more detailed site-specific analysis would be included in tiered NEPA documentation. The commentors observations on the ORR severe accident setting, the NTS tectonic setting and INEL attributes are correct. All of these issues and potential impacts, if any, are identified in the PEIS. Mitigation has been proposed for impacts based on the conceptual design impact assessment. If any of these sites is selected as the tritium supply site, more detailed analysis and technology design would be included to minimize potential impacts. 12.04 The commentor suggests that, when evaluating current designs, the PEIS should consider terrorist attacks, that is, aircraft attacks or trucks with weapons. Response: Security concerns are of paramount importance to DOE. Although there is not a great deal of description as to the importance security plays in the DOE's activities in the PEIS, security concerns are a major consideration for the design and operation of all of DOE's Defense Programs facilities. This PEIS is a programmatic level document and is focused on selecting the appropriate technology and site for the tritium supply and recycling facility. In the initial selection of candidate sites, security consideration played a strong role and, accordingly, only those DOE facilities which could offer a certain degree of security were considered. Once a site and technology selection is made, DOE will undergo a detailed site-specific design process which will include a lengthy analysis of all security requirements. 12.05 Several commentors note problems with the text, organization, and analysis in the PEIS. One commentor suggests that a clear statement about the tritium production goal be provided in either the executive summary or chapter 1. The commentor states that, currently, the explanation is not found until the reader reaches chapter 3, where the terms "steady state requirement" and "baseline requirement" are finally explained as fractions of the original New Production Reactor Program goal quantity. Another commentor states that the PEIS does a poor job of distinguishing among the alternatives. The commentor asserts that this is due to an analysis that relies on uncertain modeling and potentially unrealistic assumptions about the quality of operation. One commentor requested that a table listing the key discriminators for each technology independent of the sites be included. Another commentor suggests adding the acronyms HEU and MGY to page iv of volume II, while another states that in figure 1.4-1, the ORR geographical location should be referred to as `at Oak Ridge, TN', not `near Oak Ridge, TN'. Response: As with any large and complex document minor text problems and editing slip-throughs can be expected. Every effort has been made in preparing the Final PEIS to discover and correct these errors. The organization of the PEIS was felt to be the best approach and format for presenting the many tritium supply technologies, potential sites, and the variety of other options (e.g., collocation of recycling facilities, less than baseline operation). The organization also allows readers to concentrate on a particular site of concern and compare with other sites. The analysis presented in the Draft PEIS was based on best available existing data and project information developed specifically for the PEIS. In many instances however, because of the new designs and technologies being considered for analysis, the level of detail was not of sufficient quality to evaluate potential impacts without making conservative assumptions. Some of these assumptions, especially concerning conceptual design and accident analysis of tritium supply technologies, were questioned during the public review of the Draft PEIS. Based on the comments received, appropriate changes have been made in the Final PEIS. The acronym HEU is listed in the "acronyms and abbreviations" section of volume II (page xxv). The unit of measure MGY is listed on page xxvii under "chemicals and units of measure". Figure 1.4-1 has been changed to "at Oak Ridge, TN". The tritium production goal and the terms describing the different production scenarios have been added to the Final PEIS summary under the heading "Tritium Supply and Recycling Proposal." 12.06 The commentor states that the tritium production/recycling siting decision should focus on equity issues, human health and socioeconomic risks, and unavoidable environmental impacts. Response: The siting decisions will consider the issues which are analyzed in the PEIS and raised by the commentor. However, the decision on siting the preferred tritium supply technology will also consider many other factors and issues such as cost, technical uncertainty, and scheduling. 12.07 The commentor suggests that, in the Final PEIS, DOE should include a description of the old tritium facility, its current and planned disposition, the wastes generated, and a comparison between the old and new tritium facilities. The commentor asserts that this may help DOE learn from past mistakes and educate the public as to what can be expected from the new facility. Response: DOE has had more than a dozen facilities over the years that have provided tritium and other nuclear materials for the fabrication of nuclear weapons. All of these facilities are of the first generation reactor design and were designed and constructed in a timeframe prior to existing environmental and safety requirements. The operation of these facilities and the wastes they generated bear no resemblance to the facilities presently being considered. DOE has a separate action underway to study contamination resulting from past operations and will develop various technical alternatives for the remediation of these facilities. 12.08 Several commentors express the opinion that the PEIS does not account for impacts associated with the D&D of alternative technologies. Commentors note that the reason given in the PEIS is that the level of detail is not developed enough (page 3-4), therefore, this evaluation will be conducted as part of future site-specific tiered NEPA documents. While tiered environmental review may be appropriate for D&D activity, one commentor believes this PEIS should estimate the amount and type of waste that could be generated by such activity. Maximum quantities of each type of waste should be identified. In the commentor's opinion, such an accounting is necessary in order to present a realistic picture of the total contribution this proposed action will make to the waste DOE must manage. One commentor states that DOE waste management planning must ensure that appropriate facilities are available to handle projected waste streams from all of its activities. Otherwise, the proposed action presented in this PEIS could contribute cumulatively to an impact on DOE's waste treatment and disposal capability. Another commentor recommends that the Final PEIS include more D&D information concerning the proposed technologies and highlight any impact differences among the technologies. Response: The specific environmental impacts of D&D cannot be determined at this time because of the preconceptual designs of proposed facilities. However, a relative comparison of the D&D activities and potential impacts among the tritium supply technologies is presented in section 4.14 of the PEIS. The costs associated with D&D are included in the Technical Reference Report available in DOE reading rooms. 12.09 The commentor states that, on March 15, 1994, Dr. Harold Smith relayed to the House Appropriations Subcommittee on Energy and Water Development that tritium requirements are based on START I stockpiles, and not START II stockpiles as DOE claims today. Response: For purposes of the PEIS, tritium requirements are based on a range of stockpile requirements. For the base case, a stockpile consistent with START II requirements has been considered. DOE also performed analysis on tritium requirements based on a much lower stockpile requirement, as well as a higher stockpile requirement, consistent with Start I requirements. Analysis of three different stockpile requirements will enable the decision maker to utilize and benefit from additional factors which may develop prior to the actual decision. 12.10 The commentor suggests that the PEIS include an analysis on safety issues, focusing on past performance of the potential sites. Past safety records should count heavily in the decision making process, according to the commentor. Response: The focus of the PEIS is on how the tritium supply and recycling facilities would be operated in accordance with all applicable DOE orders, not on how past facilities were operated. A discussion of site accident history is provided for each site in the affected environment sections. 13 Tritium Supply and Recycling Proposal and Alternatives 13.00.01 Several commentors express the opinion that the No Action alternative is the option most consistent with international negotiations to achieve arms reductions and nonproliferation goals. One commentor also suggests that it is the preferred option relative to the health issues related to production, handling, and safe disposal of tritium. Another commentor notes that DOE could continue to reuse existing tritium from dismantled weapons until well beyond 2011 with no adverse effect on U.S. nuclear deterrent capability. In light of the START II Protocol, according to this commentor, tritium will not be needed as the number of nuclear warheads is reduced. In a similar vein, one commentor states that, since there are between 16 to 21 years before tritium becomes seriously low, it is more economical to further explore the options that have already been dismissed. Response: At the present time, DOE has no capability for the production of tritium. Furthermore, tritium is a short-lived radionuclide which is an integral component of every weapon in the Nations's nuclear weapons stockpile. Although the tritium in weapons which are being retired from the stockpile as a result of recent arms negotiations can be recovered and utilized in the existing weapons, this supply, alone, is not sufficient to replace the tritium which is decaying in the existing weapons. Based on a stockpile consistent with the requirements of START II levels, it is expected that an additional supply of tritium will be required by 2011. Accordingly, DOE is proposing to construct a new tritium supply facility. The PEIS analyzes the potential environmental impacts asso- ciated with various site and technology alternatives for the production of tritium. The No Action alternative is utilized in the PEIS as a baseline case, from which the environmental impacts of various alternatives can be developed and compared. Under the No Action scenario, DOE would not have sufficient quantities of tritium to fulfill its requirements under the Atomic Energy Act to support the enduring stockpile as directed by the President and approved and funded by Congress. As to the health and safety and disposal issues of the No Action alternative relative to the other alternatives, there are no significant health and safety issues associated with any of the alternatives being considered in the PEIS. All alternatives fall within reasonable and generally acceptable levels of risk. Furthermore, DOE does not dispose of any quantity of tritium and has no future need for the disposal of tritium, consequently, this document does not look at any tritium disposal alternatives. 13.00.02 Commentors express concern that uncertainties exist with the APT and MHTGR technology designs and with the associated cost estimates. One commentor asserts that there is not enough operating experience for the APT and MHTGR technologies; therefore, analyses of their environmental impacts or cost estimates cannot be fully accurate. Another commentor suggests that DOE build a small accelerator to test before building a full-sized one with questionable results and wasting money. Still, another commentor argues that the APT and MHTGR be eliminated from contention because they are not sufficiently proven and have an unreasonable risk of achieving success. The commentors contend that either the HWR or ALWR technology is a better choice. Another commentor references the following statement in the PEIS, on page ES-8: "only the HWR has tritium production operating experience." The commentor states that although DOE intends to avoid repeating past mistakes, three out of the four possibilities presented are unproven, which could cause problems. Another commentor feels that the Large ALWRs which have completed NRC review have a solid basis for evaluation in the PEIS. Although the threat of intervenor delays in the licensing of a new nuclear plant is often cited as a scheduler uncertainty, the commentor feels we should not lose sight of the fact that even the accelerator has been delayed by intervenors (at Los Alamos). In the Los Alamos case, the commentor notes that the research accelerator was much smaller than that proposed for APT. In addition, commentors express concern over the reliability and maturity of the technologies. According to one commentor, the more immature the technology, the greater the risk of substantial cost overruns, schedule delays, and overall unreliability which may threaten the technology's ability to supply tritium when needed. Some commentors suggest that reliability is the most important criterion when choosing a technology and the PEIS should include information on reliability and safety for the technologies. In fact, one commentor states that safety reports for each technology should be made available to the public. Another commentor expresses concern about how cost versus efficiency/reliability is going to be compared for all four technologies. Response: Although there is no real operational experience for the specific APT or MHTGR facilities being considered in the PEIS, most aspects of these technologies have been researched and fully demonstrated for more than 30 years. The specific designs being considered will draw on this experience and will operate as required, within acceptable levels of technical risk. For the MHTGR alternative, the Peach Bottom 1 Atomic Power Station demonstrated gas reactor technology as early as 1967. While the proposed configuration for the APT has never actually been constructed or operated, all of the various significant components have been used in various accelerators operated by DOE in the past. The Technical Reference Report available in the DOE reading rooms provides estimates of the technical feasibility of the various technologies, as well as cost and schedule estimates. These estimates include the effects of the various issues such as design maturity. 13.00.03 The commentor notes that the Final PEIS should include a full evaluation of the gas-turbine modular helium reactor as one of the technology alternatives in addition to the steam cycle MHTGR, rather than the current limited treatment. The commentor believes that the ROD evaluations of cost, schedule, and production assurance should include the gas turbine modular helium reactor as one of the candidate technologies. In reference to pages A-31 and A-97, another commentor states that it is not clear why the relationship between the 600 MW gas turbine-modular helium reactor and the 350 MW MHTGR is any different from the relationship between the Small ALWR and the Large ALWR. Both ALWRs are evaluated in this PEIS. The commentor believes that if information on the ALWR from the Surplus Fissile Materials Program is to be used, information from that program on the 600 MW gas-cooled reactor should also be used. Both gas-cooled reactors should also be evaluated in this PEIS. One commentor notes that it is stated that the gas turbine-modular helium reactor "represents a different technology." In fact, the commentor believes that the reactor technology of the two designs is the same while the differences lie in the power conversion system technology. The commentor suggests that the comparison of the gas turbine-modular helium reactor with a boiling water reactor is inappropriate. The gas turbine-modular helium reactor would not be plagued with the operating problems that have been experienced by the boiling water reactor and other light water reactors, according to the commentor. Response: As stated in section A.3.1, the direct cycle gas turbine design is basically a design modification of the basic gas reactor design. Inclusion of it as an alternative would offer nothing new in terms of environmental discrimination between technologies. The Technical Reference Report available in the DOE reading rooms provides estimates of the technical feasibility of the various technologies, as well as cost and schedule estimates. The cost estimates have accounted for the cost differences between the 600MW and 350MW reactors referenced by the commentor, and there is comparatively little technical difference between the technologies. If the MHTGR technology is chosen then further studies may show that consideration of this new design is warranted. 13.00.04 The commentor remarks that it is stated that, "The MHTGR and light water reactor....lack tritium production experience and the development of tritium target technology. The APT technology....also has no tritium production experience and only recent development of tritium targets." This statement is incorrect, according to the commentor. DOE should refer to Tritium Target Development Project Executive Summary Topical Report, PNL-8142, September 1992 for light water reactor target development information. For gas-cooled target development status DOE should refer to two reports, Fuel and Target Technical Development Status Report, CEGA-002818, December 1993 and Tritium Recovery Facility Technical Development Status Report, CEGA-002693, February 1993. Response: The statement is correct as stated since it refers to operational production experience and the completion of target development. It does not refer to research and development experience as is cited in the referenced reports. 13.00.05 Several commentors express support of the "triple play" reactor, citing the following advantages: it is the most practical, proven, and economical option; it is able to generate revenue by selling electricity (and providing that electricity to communities that need it); and it may be able to dispose of plutonium, providing mission flexibility. In addition, some commentors indicate support for the ALWR triple play reactor. Some commentors also indicate that there is much support for locating the reactor at SRS because it would address the plutonium problem, produce tritium, provide inex- pensive power for the area, and encourage economic development. In fact, one commentor points out that some private initiatives in South Carolina are interested in this option and may provide financing. In addition, some commentors believe that the benefits of electricity production were not adequately presented in the PEIS and suggest that DOE should address environmental impacts and cost/benefits for a tritium production reactor and for a reactor that both produces tritium and burns plutonium. One commentor believes that a single ROD process should be adopted for both the Tritium Supply and the Fissile Materials Disposition programs to ensure that the multipurpose options are properly taken into account. In the commentor's opinion, this single ROD process would permit valid comparisons of cost, schedule, production assurance and environmental impact of multipurpose plants versus the combinations of other technologies required to satisfy both the Tritium Supply and Fissile Materials Disposition missions. Some commentors also feel the treatment of the multipurpose options in the PEIS is not a full and fair evaluation, so it is not consistent with the requirements of NEPA. The commentors also note that the environmental impacts of the multipurpose options are compared only with those of the tritium production options and a full and fair assessment would compare the impacts of the multipurpose options with those of the plutonium disposition and tritium production options combined. One commentor refers to page A-102 and notes that evaluations of multipurpose core designs by General Atomics indicate that the plutonium disposition rate per reactor module is increased by 50 percent when the reactor is operated in a multipurpose mode versus plutonium disposition only. For the ALWR, the commentor believes the plutonium disposition rate per reactor is decreased due to derating and the effects of periodic retargeting. According to the commentor, six 350 MWt MHTGR modules or four 600 MWt gas turbine-modular helium reactor modules could disposition about 60 MT of plutonium over their 40-year reactor life. The commentor suggests that speculation on this matter on page A-100 should be replaced with this information. Another commentor referring to pages 4-447 and 4-467, believes that for the ALWRs for plutonium disposition, at least two small ALWRs would have to be used, to carry out the same amount of plutonium disposition as the large ALWR. For a large ALWR, the commentor feels that it is not necessary to require a full core refueling, with a major reduction in fuel disposal. Response: DOE does not expect that the ROD on tritium production would restrict or prejudice decisions of any plutonium options. In fact, DOE's preferred alternative would allow for subsequent integration with future plutonium disposition decisions, if desired. As stated in the description of the NEPA process in section 1.2, any decision made in the ROD would be followed by a site-specific EIS which would address the technologies and locations on the chosen site. The PEIS for Tritium Supply and Recycling evaluates alternative technologies and sites for long-term, assured tritium supply and recycling. Another DOE program office, the Office of Fissile Materials Disposition, is preparing a PEIS addressing the issue of how to dispose of plutonium that is excess to the nuclear weapons complex. Of the tritium supply technologies evaluated in the PEIS for Tritium Supply and Recycling, only the ALWR, MHTGR, and commercial reactor alternative are being considered for plutonium disposition. Therefore, the environmental impacts of plutonium-burning are analyzed and presented in the PEIS for Tritium Supply and Recycling in section 4.8 and in the environmental impact sections for each site. Estimates of the amount of plutonium that could be consumed by these technologies are included in section A.3.2. It is reasonably foreseeable that electricity generated by an ALWR, MHTGR or commercial reactor 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 environmental impacts. Because an ALWR, MHTGR or commercial reactor could also be used to "burn" plutonium, these environmental impacts are also addressed in the PEIS. 13.00.06 The commentor notes that the Draft PEIS states that "the analysis in this PEIS is based on the requirements of the Nuclear Weapons Stockpile Plan which covers an 11-year period, specifies the types and quantities of weapons required, and sets limits on the size and nature of the stockpile changes that can be made without additional approval of the President." The commentor feels that this document standing alone should not be the basis for the proposed action, for the following reasons: the period covered by the Nuclear Weapons Stockpile Plan does not extend through the construction phase and does not even begin to address the operational phase (2010 to 2050) of DOE's proposed tritium supply and recycling capability, and, therefore, it cannot form the basis for assessing stockpile tritium requirements and supply/recycling alternatives in the PEIS; an EIS for a tritium supply and recycle capability for the years 2010 to 2050 must take into account reasonable, indeed likely, alternatives not presently accounted for in the Nuclear Weapons Stockpile Plan for 1994 (or 1995, assuming the classified appendix in the Final PEIS will contain updated stockpile plan information). By definition, the range of "reasonable alternatives" for tritium supply in the first half of the 21st century cannot be narrowed to sole consideration of the tritium "requirement" in an already approved government plan for the period 1995 to 2005. According to the commentor, not only does such a premature narrowing of options make a mockery of NEPA's requirement for analysis of reasonable alternatives, but the commentor contends that the Nuclear Weapons Stockpile Plans themselves historically have been unreliable predictors of actual nuclear weapon requirements and force levels. They have, in fact, regularly overestimated future nuclear materials requirements. Response: As discussed in chapter 2, the need for new tritium supply is based on the 1994 Nuclear Weapons Stockpile Plan, which projects a need for tritium to approximately 2011 based on a START II level stockpile size of approximately 3,500 accountable weapons. The 1994 Nuclear Weapons Stockpile Plan represents the latest official guidance for tritium requirements. A Nuclear Weapons Stockpile Plan for 1995 was not issued. The PEIS also includes analyses of providing tritium at an earlier date should that become necessary. For a stockpile size smaller than STARTII, the need for new tritium could be extended beyond approximately 2011. If the need date for new tritium were significantly later than 2011, DOE would not have a proposal for new tritium supply, and would not be preparing a PEIS for Tritium Supply and Recycling. The potential impacts of future arms control agreements are accounted for in the development of the Nuclear Weapons Stockpile Plan, which is not the purpose of this PEIS. This PEIS has the sole purpose of evaluating the reasonable alterna- tives for providing the tritium necessary to support the enduring stockpile as defined by the President in the Nuclear Weapons Stockpile Plan. A new section has been added to the PEIS (section 4.11) that discusses the differences in environmental impacts should tritium be required sooner than currently envisioned. 13.00.07 Commentors express support for having and maintaining capability for nuclear materials production, including tritium. The commentors suggest that DOE select a technology that would produce the highest quality tritium as well as minimize waste generation. To further enhance national security, one commentor suggests that the U.S. should have two sources of tritium production for a strategic advantage (for example, an APT at NTS and a facility at SRS). Another commentor feels that to rely on recycled tritium mixed with deuterium in unsuitable concentrations could jeopardize our deter- rence capability. One commentor states that if it is decided that tritium production and recycling is necessary to achieve a goal that the public is in agreement with, then the least harmful design and method should be selected. Finally, another commentor expresses support for reactor production of tritium citing the facts that other nations will pursue nuclear power despite our reluctance, the dependence of the United States on oil imports for electric production, and nuclear power's favorable comparison to other energy sources. Response: The technologies can all produce the high quality tritium needed while minimizing waste. The APT has the least waste of the potential technologies. The purpose of this PEIS is to analyze the reasonable alternatives for tritium supply and sites to support the enduring stockpile as defined by the President in the Nuclear Weapons Stockpile Plan. The preferred alternative identified in section 3.7 of the PEIS is a dual-track strategy to pursue both the use of an existing commercial light water reactor and the construction of an accelerator to produce tritium. 13.00.08 In reference to the Stockpile Stewardship and Management Program booklet on page 4: the commentor quotes, "All of the candidate weapons for the START II stockpile require tritium replenishment." The commentor believes that DOE should not make the assumption that we will maintain a stockpile of weapons requiring tritium when no tritium facility exists. Response: All of the candidate weapons for the START II stockpile already exist today and they all require tritium replenishment. The fact that there is currently no tritium supply is the reason that this PEIS is being prepared. 13.00.09 Commentors question why DOE needs 15 years to bring a new tritium production facility online if construction estimates ranging from 5 years for the APT to 9 years for the MHTGR are accurate. For example, one commentor notes, the APT could begin construction in 2006 and be complete in 4 to 5 years. If DOE waits 4 to 5 years beyond 2006 to begin construction, the commentor believes that tritium production may not even be required until well beyond 2010 because of further arms reductions. Response: Depending on the technology selected, it could take as long as 15 years to bring a tritium supply facility online to account for facility design and further technical research and development of targets. Considerable design work is required to bring these technologies and facilities to the construction phase. The 5 to 9 year construction duration to which the commentor refers does not fully represent all of the activities that are necessary to bring a new tritium supply facility online. Regarding the alternative selected, varying degrees of additional research, development, and design will be required, and a site-specific tiered NEPA document will be prepared. These activities will occur prior to construction. After construction, start-up and test activities will be required prior to actual tritium production. In total, the analysis indicates that it could take as many as 15 years to bring a new tritium supply facility into operation. Because new tritium is needed by approximately 2011, DOE is proceeding with a tritium supply decision now. More detailed analysis of the construction schedules can be found in the Technical Reference Report available in DOE reading rooms. 13.00.10 In reference to section 3.4.1.4, cooling systems, the commentor states that the PEIS indicates mechanical draft dry cooling towers would be used for the reactors at all dry sites, and wet cooling would be used for APT technology at any site. The commentor would like to see two additional cooling system technologies considered for use for any of the technologies at the Pantex "dry" site. Another commentor suggests that DOE consider a combination of wet/dry cooling technology at any type of facility selected for NTS. Response: As discussed in section 3.4.1.4, dry cooling towers would be used for reactors at all dry sites, namely Pantex, NTS and INEL. Dry sites and wet cooling would not be appropriate based on the lack of abundant water. The specific cooling design would be site-specific and considered at that time. 13.00.11 One commentor suggests an alternate site for the Tritium Supply and Recycling facility, located approximately 12 miles from Rogersville, Tennessee, in Hawkins County. The site, according to the commentor, was the former headquarters for the International Printing Pressmen's Union and is remote, accessible, and low in population. Another commentor suggests that DOE consider siting the Tritium Supply and Recycling facility outside of the existing Complex sites. Response: Adding a non-DOE site would be contrary to the goal of downsizing and consolidation. DOE established a Site Evaluation Panel and this panel developed specific selection criteria for determining the suitability of facilities to be considered. Such factors as safety, security, availability of required resources, availability of waste management facilities, the availability of an existing technically qualified workforce, and other factors were determined to be necessary. The addition of a new site would not be consistent with the overall goal of DOE to consolidate and downsize the Complex. 13.00.12 The commentor states that despite spending $1 billion on technical studies, DOE's Office of the Assistant Secretary for Defense Programs does not believe reactor technology is the best option for tritium production. The commentor expresses the belief that jobs are the real basis for considering HWR, MHTGR, and ALWR. Response: The PEIS addresses the environmental impacts of all reasonable alternatives identified for the tritium production mission, and includes analysis of socioeconomic issues such as job creation and loss. These environmental factors along with costs, technical feasibility, and scheduling will be presented to the decision maker. The decision maker will consider all of these factors and issue a technology and site selection in the ROD. No alternatives were deemed to be reasonable or unreasonable based on job creation. 13.00.13 In reference to volume I, page 4-444, fuel receiving, storage, and handling, the commentor states that the indirect impacts of coal mining and shipping should be considered along with the impact of operations at the plant site. Response: A description of the mining and transport of coal and the general impacts associated with this part of the energy cycle has been added to the discussion on fuel receiving, storage, and handling in section 4.8.2.1. 13.00.14 Commentors state that the PEIS should include a discussion of other uses for tritium and for the chosen technologies. One commentor suggests that information be provided on what the tritium facility would be able to produce/dispose of when or if tritium is no longer needed. The selected technology must be flexible enough to be used for other needs without compromising the ability to produce tritium, according to the commentors. One example given is the ability to produce a wide range of isotopes. Another commentor notes that there is a commercial market in the United States for tritium and DOE should consider using the tritium facility for commercial (non-defense) purposes in addition to its primary mission of producing tritium for weapons enhancement. One commentor suggests that with no tritium supply requirements, the chosen technology could be used to make electricity, medical isotopes, etc., cost effectively. The commentor believes that under no circumstances should the taxpayers be asked to fund another study and another technology if the tritium supply requirements change. Response: As explained in chapter 2 of the PEIS, DOE is required by law to maintain the nuclear weapons stockpile as directed by the President in the Nuclear Weapons Stockpile Plan. The tritium supply facilities presented in this document are sized to support this stockpile. Additional uses, such as those suggested above, should not be included in initial planning but could be accomplished on a space available, non-interference basis after DOE's statutory requirements were met. 13.00.15 Commentors state that the PEIS needs to make it clear that the tritium facility analysis is based on new START II levels, reflecting the most recent agreement for weapons reductions. One commentor also notes that it should be made clear that the associated reserve that is needed to maintain the stockpile is also based on START II levels. A commentor suggests that the PEIS should also clarify that the tritium reserve stockpile includes tritium for active weapons (in the stockpile) only, not any that are currently inactive or dismantled. Finally, one commentor notes that total reductions in the nuclear stockpile are to be completed by 2003 and this fact should be taken into account when planning for the tritium facility. Response: As stated in chapter 2 of the PEIS, the tritium requirements in this document are based on the 1994 Nuclear Weapons Stockpile Plan approved by the President on March 7, 1994. These levels are based on START II levels. This plan does take into account the changing world situation to include ongoing arms control negotiations. More specific details than that found in the PEIS are included in the classified appendix. 13.00.16 The commentors state that DOE should consider purchasing tritium from foreign countries at different times; this would both benefit the United States and bring in revenue to some of the poor countries. For example, suggests one commentor, DOE should tell Russia to sell all the tritium they can or else we will build a reactor to produce it. By the time the United States has depleted that source, a new and better technology might be available or the existing stockpile might be further reduced. Response: The option of purchasing tritium from foreign sources was evaluated but dismissed from further consideration for the reasons stated in section 3.1.3. 13.00.17 Commentors suggest additional technologies and approaches for DOE to consider in its facility analysis. According to the commentors, other reactor types for consideration as alternative technologies should include the molten salt reactor, the commercial boiler reactor with lithium, the low temperature light water reactor, and the gas turbine-modular helium reactor. Advantages of the low temperature light water reactor, one commentor cites, include expensive heavy water would not be required for coolant and moderator, and the waste tritium buildup in the coolant would be drastically reduced over that in the HWR. In addition, the commentor states that no heavy water processing facility would be required to detritiate the expensive heavy water as would be required for the HWR. Commentors also believe that DOE should consider putting the K-Reactor at SRS back online because it could keep up with the tritium needs if started immediately, which would add time for new technology development or for decisions about further stockpile reductions, as well as save money. According to one commentor, if one or more smaller reactors were also upgraded then DOE would have a backup in the event the larger reactor had to be shut down. The commentor also states that DOE should have continued to use the reactor that last produced the gas, rather than build a new facility. Another commentor suggests that DOE consider technology alternatives that reuse spent fuel, making spent fuel a resource as other countries are doing. A commentor asserts that DOE should use a phased approach to all alternative technologies. Another commentor believes that DOE should also consider a fusion facility in the PEIS. Response: The option of using DOE existing reactors or accelerators was evaluated but dismissed from further consideration for the reasons stated in section 3.1.3. DOE has experience with the operation of many reactor types, and considers that those included in this PEIS represent a reasonable range of technologies. DOE has not only considered putting the K-Reactor back online but had an extensive and costly effort underway in the early 90s to restart the K-Reactor. Unfortunately, the age of this facility and the magnitude of the environmental and safety upgrades required for this task proved too great and in 1994, the K-Reactor was placed in a "cold stand-by" status with no provision for restart. 13.00.18 One commentor indicates that on page 4-462, the PEIS states that spent light water reactor mixed-oxide fuel assemblies would have greater decay heat than spent uranium fuel assemblies. It is then assumed that the same is true for the gas-cooled reactor, according to the commentor. The commentor charges that this assumption is not correct. The commentor states that the decay heat of plutonium spent fuel in the gas-cooled reactor is less than that of the uranium spent fuel from the tritium production-only design. Accordingly, notes the commentor, storage density in the spent fuel storage area is not adversely affected. The commentor also notes that references to wet storage of the gas-cooled reactor spent fuel should be deleted since MHTGR spent fuel is stored in dry facilities at all times. It should also be recognized, states the commentor, that, in general, the gas-cooled reactor spent fuel volumetric decay heat generation rate is several orders of magnitude less than that for light water reactor spent fuel which has a much higher power density. Therefore, the commentor states that even though the volume of spent fuel generated by two gas turbine-modular helium reactors is as much as a factor of 20 larger than that of a Small ALWR, this does not adversely affect onsite spent fuel. These parameters are governed by thermal heat load rather than by volume of the spent fuel, according to the commentor. The commentor asserts that the heat loads allow only about four canisters per acre for light water reactor spent fuel whereas about 77 canisters per acre are allowed for gas turbine-modular helium reactor spent fuel. Thus, the commentor concludes that the geologic repository area required for disposal of spent fuel from three MHTGR modules or two gas turbine-modular helium reactor modules is about half that required for disposal of spent fuel from one Small ALWR. Another commentor notes that on page A-100 the cyclic tritium production campaigns would affect the light water reactor fuel cycle such that the level of destruction of plutonium in the multipurpose application would be reduced. Thus, the discharged fuel would not meet the spent fuel standard. The commentor also notes in the discussion of the MHTGR and gas turbine-modular helium reactor on page A-101 that the level of plutonium destruction achieved for the multipurpose plant is in excess of the spent fuel standard. Another commentor states that discussion of the System 80+ design describes the need to derate the plant in various modes of operation as if it were a virtue by referring to how it maintains "flexibility" in its power output. The commentor feels that this is, in fact, a limitation of the ALWR as a multipurpose plant - one from which the MHTGR does not suffer. In addition, the commentor feels that the amount of tritium produced in an ALWR when concurrently using MOX fuel should be addressed, as well as the potential safety issues that are associated with that fuel configuration that require derating the plant. Response: No technical criteria for disposal of spent fuel have been firmly established for the Yucca Mountain repository. A key technical criteria that is expected to bear significantly on the ultimate amount of volume that a given technology's spent fuel will take up is the repository loading strategy based on areal thermal loading limits. Thus, whether the spent fuel from an MHTGR would take up a greater volume of repository space than the spent fuel from an ALWR or HWR would depend on whether a "hot", "intermediate", or "cold" areal thermal limit were established for the repository areal thermal loading limit. 13.00.19 In reference to volume I, page 3-6, use of existing department of energy reactors or accelerators, one commentor states that it is not reasonable to reject the use of DOE's existing reactors because none of the operating facilities is large enough to produce the amount of tritium required to support the projected stockpile requirements, they are currently committed to existing programs, and are reaching the end of their design life. First, states the commentor, while none of the reactors alone may be able to meet the projected tritium demand, together it may be feasible. In fact, the commentor believes it would seem particularly strategic from a defense standpoint to have several small producers, at widely scattered locations, rather than a single, large producer. Second, states the commentor, since these reactors are reaching the end of their design life, one can assume that their commitment to existing programs is also coming to an end. The commentor states that for that reason, modifying and upgrading these reactors for a new mission as tritium producers sounds like a reasonable alternative. Not only would DOE be reusing existing facilities rather than adding them to a growing D&D stockpile, but it would be possible to delay the development and expense of an entirely new facility, according to the commentor. Such an option may be desirable given the uncertainties regarding how much tritium will be needed. Also, given the changing international scene with respect to nonproliferation, this alternative may be attractive because it does not send the message that the United States is building new nuclear defense capabilities, according to the commentor. Another commentor asks what fraction of the goal quantity discussed on page S-9, paragraph 4, could all four of the existing DOE reactors together produce. The commentor additionally asks: how long their commitments to existing programs are; and, if the fast flux test facility were modified, what its life expectancy would be. Another commentor also references the fast flux test facility and suggests that the Draft PEIS is in error when it states that no source of a new tritium supply is available. Response: The option of using DOE existing reactors or accelerators was evaluated but dismissed from further consideration for the reasons stated in section 3.1.3. DOE has experience with the operation of many reactor types, and considers that those included in this PEIS represent a reasonable range of technologies. 13.00.20 Commentors suggest that DOE consider in the PEIS a no-weapons or fewer-weapons alternative and the consequences this would have on tritium needs. In addition, some commentors believe that tritium is not necessary for the functioning of nuclear weapons and suggest that DOE analyze weapons that do not use tritium. The commentors believe that tritium could be phased out and weapons made from other materials such as the plutonium stockpile. Response: The alternative of redesigning weapons to require less or no tritium was considered but eliminated from detailed study. This is explained in section 3.1.3 of the PEIS. Also, as discussed in chapter 2, the need for new tritium supply is based on the 1994 Nuclear Weapons Stockpile Plan, which projects a need for tritium by approximately 2011 based on a START II level stockpile size of approximately 3,500 accountable weapons. A smaller than START II stockpile size would extend the need date for new tritium beyond approximately 2011. If the need date for new tritium were significantly later than 2011, DOE would not have a proposal for a new tritium supply, and would not be preparing a PEIS for Tritium Supply and Recycling. 13.00.21 The commentor notes that several of the reactor alternatives for which accident analyses are presented in appendix F of the PEIS are under review by NRC for design certification under 10 CFR Part 52. The commentor adds that this fact gives NRC both "special expertise" in the safety aspects of the technology presented in the PEIS and jurisdiction over outside analyses that could impact the course of current deliberations on certification. The commentor suggests that NRC be asked to review the adequacy of the material presented characterizing the environmental impacts (PEIS volume II, appendices A, E, and F) of reactors currently being reviewed for licensing actions to assure consistency. The commentor notes that NRC also has "special expertise" in the safety review of gas-cooled reactors. NRC review of the accident analysis methodology used by DOE is also appropriate because of the NRC's "special expertise" in reviewing vendor methodologies and because NRC's independence can assist DOE in satisfying the above-cited regulatory requirement for ensuring "professional integrity." The commentor adds that NRC's expertise and recent experience in looking at different types of advanced reactors can also aid DOE in identifying and assessing the legitimacy of "safety issues" for the APT. Another commentor feels that the licensing of the APT by NRC should be assumed as the basis for the PEIS and discussions held with NRC to establish a licensing design-basis for the APT. Response: NRC has been provided with copies of this document for review as suggested. Meetings were held with NRC to discuss the potential uses of commercial reactors, licensing implications, potential external oversight and nuclear safety related issues. 13.00.22 According to one commentor, the discussion of decreasing tritium production efficiency of the MHTGR in the multipurpose mode neglects the fact that the tritium production efficiency of the gas-cooled reactor is far better than that of other candidate reactor technologies. The commentor notes that in the PEIS, the MHTGR has the lowest overall environmental impacts of any of the production reactor options under consideration. The commentor is of the opinion that the MHTGR is the most efficient tritium production reactor under consideration. The commentor notes that in the multipur- pose application, the total installed thermal capacity required to produce tritium at 3/8 goal while dispositioning plutonium is 3,000 to 4,800 MWt, which is comparable to the installed capacity required for the ALWR options. If one compares the multipurpose reactor options with the combined impacts of the tritium production and plutonium disposition plants, it is clear that the total installed capacity required for the multipurpose plant is lower for the MHTGR and is about equal for the ALWR, states the commentor. The commentor notes that the environmental impacts presented on page 4-460 for the multipurpose gas-cooled reactor should be compared with those for other multipurpose reactor technologies and with those for the combined individual tritium production and plutonium disposition missions. Instead, the commentor feels that the presentation provided in the PEIS limits its focus to the relative number of modules required for tritium production only versus multipurpose while providing no perspective as to whether these environmental impacts are large or small compared to other options. One commentor states that DOE must plan in the design of its tritium production reactor the capability to burn cores fueled by both uranium and plutonium. Another commentor states that plutonium should not be considered a resource, as it is in the PEIS, since its disposal is in question. Another commentor inquires whether plutonium burning cycles have been explored as alternatives (as in France and Japan). Response: The decision on the tritium supply technology will not be identified until the ROD has been published after this PEIS, although section 3.7 identifies the preferred alternative. Three of the technologies analyzed for tritium production in the PEIS have the capability to burn plutonium (ALWR, MHTGR and commercial reactors). The potential use of these technologies for plutonium disposition has been analyzed in the PEIS. The PEIS does not judge large or small impacts. None-the-less, the number of modules does have impacts and the analysis focused on those impacts. 13.00.23 The commentor feels that DOE should reconsider having the current schematic drawings in the PEIS reflect New Production Reactor designs. Response: The most current available data are being used for the tritium supply and recycling facilities. The specific design-basis for each technology is listed in section A.2. 13.00.24 The commentor notes that page 4-447 of the PEIS states, "In fact, the gas-cooled reactor technology developer believes that it may not be feasible to use the 350 MWt MHTGR design as a multipurpose reactor." According to the commentor, this statement is absolutely false and must be deleted. The commentor states that the gas-cooled reactor developer has never said that the 350 MWt plant could not be used in a multipurpose application. The gas-cooled reactor developer has not evaluated the 350 MWt plant for multipurpose use, but believes that the machine could perform in this capacity. However, the commentor notes that the gas-cooled reactor developer believes that the 600 MWt gas turbine-modular helium reactor is the most cost-effective multipurpose gas-cooled reactor design and has the best environmental impact characteristics of potential multipurpose options. Response: The statement in question has been deleted in the Final PEIS. 13.00.25 One commentor opposes allowing the tritium production facility to be privately owned. However, if that is the decision, the commentor proposes that DOE consider building a second tritium facility to serve as a backup and ensure national defense in the event the privately operated facility could not be maintained. Either a light water reactor, which could generate power, or an accelerator, which could perform basic research, should be chosen as a secondary government-owned tritium production source, according to the commentor. Response: DOE considered private ownership and operation of a tritium supply facility as a potential alternative in the PEIS. This would be considered by the decision maker in the same manner as the other alternatives taking into account cost, technical, and environmental issues. The cost associated with private ownership is considered in the Technical Reference Report. As indicated in section 3.1.1 of the PEIS, the envisioned impacts would be the same regardless of ownership. The preferred alternative identified in section 3.7 of the PEIS is a dual-track strategy to pursue both the use of an existing commercial light water reactor and the construction of an accelerator to produce tritium. Within a three year period, DOE would select one of the alternatives to serve as the primary source of tritium. The other alternative, if feasible, would be developed as a back-up tritium source. 13.00.26 The commentor states that the baseline tritium requirements are presented in a misleading manner. The discussion in chapter 3 of tritium supply and recycling alternatives is inadequate and potentially misleading to those without a detailed prior knowledge of what is being discussed. The commentor believes that it is bizarre and misleading to define the "baseline requirement" as being composed of a "steady-state" requirement (for an unknown number of weapons) to make up for the tritium lost through natural decay and a "surge requirement" to replenish within 5 years the loss of a tritium reserve stockpile to some unspecified "emergency" or "contingency." According to the commentor, this definition stands logic on its head. The "baseline" requirement should be defined as that quantity of tritium needed to offset tritium decay in a given stockpile, and any "surge requirements" should be considered as excursions above this "baseline" requirement. In addition, the commentor notes that the current explanation of the "surge requirement" begs the question of how and why this reserve would be depleted, and why it was established in the first place. The commentor feels that without a comprehensive justification of why an actual "reserve" - rather than a reliable contingency production option - makes sense for an inherently decaying asset such as tritium, and of the specific contingencies under which such a reserve might be used in weapons - there can be no basis for the so-called "50 percent of baseline" requirement to replenish this reserve within 5 years. This whole analysis is "built on intellectual quicksand," and requires a major rework, according to the commentor. Response: The baseline requirement is clearly defined in section 3.1 as the sum of the steady-state requirement necessary to offset decay in the projected START II level of weapons stockpile and the surge requirement necessary to replenish the strategic reserve of tritium. These requirements come from the Nuclear Weapons Stockpile Memorandum as described in section 1.4.1. As described in chapter 2, the strategic reserve is based on the tritium needed to support the stockpile for 5 years in the event of lack of production. The fact that this amount is 50 percent of the baseline for this stockpile level is coincidental. The PEIS evaluates the environmental impacts of producing the steady-state requirement and the steady-state plus strategic reserve requirement. How and why the strategic reserve might be depleted is beyond the scope of the PEIS. 13.00.27 The commentor believes that the PEIS should address and evaluate the environmental impact associated with energy requirements of each technology and the respective energy output of each technology. The selected technology should be flexible in terms of its ability to produce a wide range of radioisotopes, according to the commentor. The commentor also supports the proven technology of nuclear fission as opposed to an accelerator that may or may not produce incidental tritium. Response: Energy output and the needs of each technology at the candidate sites are evaluated in the PEIS. Sections 4.2.2.2, 4.2.3.2; 4.3.2.2, 4.3.3.2; 4.4.2.2, 4.4.3.2; 4.5.2.2, 4.5.3.2; and 4.6.2.2, 4.6.3.2 address those issues for INEL, NTS, ORR, Pantex, and SRS respectively. 13.00.28 The commentor believes that the current draft mis-states, or over-states, the proliferation significance of the United States control rod production of tritium in civil reactors. The commentor feels that two points are relevant here. First, from a proliferation perspective, the commentor states that only those countries that already have nuclear weapons, and are seeking to advance to deuterium-tritium boosted and two-stage thermonuclear weapons, would be in a position to point to the DOE's action and possibly seek to take advantage of it to justify a similar program. For the last two decades, the commentor suggests that these countries have been India, Pakistan and Israel - i.e., countries outside of the Non-Proliferation Treaty with significant nuclear weapons capabilities. But Israel and Pakistan have no "civil" nuclear program to speak of, and India already uses its "civil" reactor to produce unsafeguarded plutonium for weapons. Second, the commentor notes that should they so desire, any non-weapons state party to the Non-Proliferation Treaty could legally produce tritium in safeguarded civil reactors, or in unsafeguarded accelerators, as long as no fissionable materials were present. The commentor notes that today for example, there is no legal or other barrier to Japanese or German production of tritium in safeguarded civil reactors for their fusion energy research programs, should they choose to do so. Since Japan is already producing and separating tons of weapon-usable plutonium in its safeguarded civil nuclear facilities - including weapon-grade plutonium from breeder reactor blankets - the production of tritium in safeguarded civil nuclear facilities alters the proliferation picture very little, if at all. At most, one could logically argue that any tritium production, extraction, purification, or utilization in non-weapon states should occur under safeguards. Unless one is willing to bar the production of plutonium in "civil" facilities, it makes no sense to arbitrarily apply a higher nonproliferation standard to production of tritium - a less strategically significant material - in "civil" reactors, particularly when the penalty for doing so could well amount to several billion dollars in additional spending on nuclear weapons - a fact that is, itself, not devoid of political significance for nonproliferation. Response: A more detailed and comprehensive analysis of the use of an existing light water reactor has been added to the PEIS. Among other issues, the report addresses potential nonproliferation issues, and is available in DOE reading rooms. The purchase of irradiation services from commercial reactors has been added as an alternative to the PEIS. Indeed, the preferred alternative in section 3.7 includes better investigation of the use of commercial reactors. 13.00.29 The commentor states that the triple play reactor, while sounding interesting, causes extra complications because of plutonium fuel fabrication and multiple objectives. If commercial power implementation of advanced light water reactors seemed imminent, this conclusion could be reversed. Response: The PEIS assesses the environmental impacts of the multipurpose reactor, but does not make technical judgements. 13.00.30 The commentor states that the draft DOE report to Congress on multipurpose light water reactors, dated January 31, 1995, makes it clear that the degree of plutonium destruction and rate of material processing achieved by the multipurpose light water reactor are lower than those of the mixed-oxide plutonium burning version of the light water reactor, unless the tritium targets are designed and tested to higher levels of exposure than have been achieved to date, or the lithium content of the target rods is reduced to limit the internal pressure in the target rods to that tested to date. In the latter case, the commentor notes that the rate of tritium production per target rod is reduced, and the installed thermal capacity required to reach 3/8 goal quantity increased. This information should be included in the PEIS, according to the commentor. Response: Consistent with the National Academy of Sciences' recommendation, the Office of Fissile Materials Disposition has determined that there is no advantage to burning plutonium beyond the spent fuel standard. The Office of Fissile Materials Disposition does not intend to evaluate options for the destruction of plutonium beyond the spent fuel standard. Thus, this PEIS only addresses alternatives which achieve the spent fuel standard. The Office of Fissile Materials Disposition is preparing a PEIS which will address the issue of how to dispose of plutonium that is excess to nuclear weapons. 13.00.31 One commentor states that, regardless of large DOE outlays over the past 10 years ($650 million for MHTGR and $425 million for ALWR), no company is willing to move ahead with either technology without sizable government subsidy. A privately financed multipurpose reactor should be considered, according to another commentor, since it would require minimum government funding, with charges against the United States only when tritium was produced. The commentor adds that APT construction, however, would require $2.5 to $3 billion from the United States treasury at a time of budget austerity. Response: The PEIS discusses the environmental impacts of constructing and operating alternatives for tritium supply, whether DOE-owned or privately financed. Costs analyses are included in the Technical Reference Reports available in DOE reading rooms. 13.00.32 The commentor states that the MHTGR should not be considered due to the amount of spent fuel it generates, the APT is too unreliable to be considered, and the HWR produces too much low-level waste. Response: The reliability of each of the technologies is evaluated in a separate Technical Reference Report which is available in DOE reading rooms. The impact of spent fuel and radioactive waste is given in the PEIS and is addressed in the Technical Reference Report with costs and technical reports. The impacts will be included in the decision making process. 13.00.33 The commentors state that some comments in the PEIS are biased towards certain technologies and sites. DOE must examine all options with equal scrutiny, asserts one commentor. Another commentor states that the treatment of the alternative concepts is obviously imbalanced, as revealed by the selection of a "low-to-moderate" consequence radiological accident for the MHTGR that includes multiple failures, whereas single failures were considered for the other reactor concepts, and an administrative violation is presented for the accelerators. A more balanced treatment of all concepts should be presented, states the commentor, where single equipment failures are considered for all concepts. Response: The assumptions and analysis used to predict the impacts due to design and beyond design (severe) accidents of the tritium supply technologies has been reconsidered and re-analyzed as appropriate based on public review comments on the Draft PEIS. The new results reported in appendix F and in sections 4.2.3.9, 4.3.3.9, 4.4.3.9, 4.5.3.9, and 4.6.3.9 are based on revised assumptions, new methodology for accident spectrum analyzed, and new data, and present a more balanced treatment of all potential technologies. 13.00.34 One commentor indicates concern about how the technical evaluations will be conducted in terms of selecting the particular technology for the tritium supply production facilities, and particular concern about how new technology will be evaluated versus proven technology, and if weighting factors will be applied. Another commentor refers to page 3-10, section 3.2.3, and notes that if the ROD will be based on the possibility of electricity production and/or plutonium burning, then this document should explain the relative importance of these items and the weighing factors that will be used to reach the final decision. Response: Many of the technical, cost, and schedule issues which will be evaluated by the decision maker are included in the Technical Reference Report available in DOE reading rooms. Such issues will be explained in the ROD. 13.00.35 In reference to volume II, page A-99, one commentor states that National Academy of Sciences' comments about combining the plutonium disposition and tritium production missions were taken out of context and not adequately explained. The commentor notes that the Draft PEIS refers to statements in the National Academy of Sciences' report which questions the desirability of combining the disposition of excess weapons plutonium with tritium production in the same reactor facility. However, according to the commentor, the National Academy of Sciences' report qualified its views by noting that "tritium production was not part of the committee's charge, and it has not examined alternatives for this purpose in detail." The commentor states that it also assumed that "tritium production capacity will be easier to provide than plutonium disposition capacity." Yet, the commentor asserts that DOE is known to be leaning toward a tritium production technology that will cost taxpayers $20 billion over its lifetime. The commentor states that this would appear to negate the National Academy of Sciences' committee assumption that tritium production will be easier than plutonium disposition. Another commentor states that the National Academy of Sciences' comment relative to cost savings stemmed from a concern about quickly initiating the plutonium mission. According to the commentor, the assumption of significant savings from combining the missions is proving to be incorrect. In fact, another commentor suggests that National Academy of Sciences' conclusions on the linkage between tritium production and plutonium disposition should be deleted. The commentor states that the National Academy of Sciences reached its conclusions without regard to the limitations that are faced today in setting the Federal budget. In addition, the commentor further notes that the National Academy of Sciences also made statements regarding the relative costs of multipurpose versus single purpose options without conducting detailed financial analyses to support those statements. The commentor claims that detailed evaluations have shown the National Academy of Sciences' conclusions regarding economics to be incorrect, both with regard to the merits of multipurpose options and with regard to the merits of exceeding the spent fuel standard for plutonium dispositions. Response: The National Academy of Sciences' report reference was provided for reader information and was not intended to subvert the National Academy of Sciences' conclusion and findings. The statement does not affect the impacts presented in the PEIS. 13.00.36 The commentor states that the PEIS should include analysis of reasonable alternatives which may conflict or differ from current Federal policies. Response: A range of reasonable alternatives has been evaluated in the PEIS. In addition, the purchase of irradiation services from a commercial reactor is now being considered as a reasonable alternative in the Final PEIS. A range of reasonable alternatives was considered. Those not considered are explained in section 3.1.3 of the PEIS. 13.00.37 One commentor favors any of the reactor options over the accelerator at SRS because of its unproven technology; belief that the risk that an accelerator may not work after it is built outweighs other considerations and could drastically affect the Nation's nuclear deterrence. The commentor also believes the environmental track record of the Nation's reactors has been stellar and understands that a primary reason for pursuing the APT over a reactor technology is its perceived environmental advantage. In addition, the commentor also states that the United States should refuse to continue taking seriously the minority of extremists who value environmental purity above this Nation's peace and security. Another commentor states that the reactor technology is proven while the APT is not. In addition, one commentor believes that there is no reason to continue research and development on the APT when reactors are proven to be reliable. Another commentor cites the advantage of the knowledgeable labor force associated with reactor technologies. One commentor suggests that the APT be studied on the side and a reactor should be used for tritium production. Response: All technologies have been evaluated equally in the PEIS. All relevant factors will be considered in the decision making process. The preferred alternative identified in section 3.7 of the PEIS is a dual-track strategy to pursue both the use of an existing commercial light water reactor and the construction of an accelerator to produce tritium. Within a three year period, DOE would select one of the alternatives to serve as the primary source of tritium. The other alternative, if feasible, would be developed as a back-up tritium source. SRS has been selected as the preferred site, if an accelerator is ultimately selected as the primary production option. 13.00.38 Commentors believe that each of the reactor technologies is sound, can be made environmentally safe, and would bring a strong power supply to the area. In addition, commentors believe that the APT will be environmentally safe. The commentors also feel that DOE should look at the environmental effects resulting from the reactors' radioactive cooling mechanism. Response: DOE agrees with the commentors statement that all proposed tritium supply technologies can be designed, constructed, and operated in an environmentally safe manner. DOE is committed to see that the selected technology would meet all applicable safety and environmental regulations and to obtain all necessary permits for construction and operation. Before a selected technology is constructed, further NEPA review is required which will identify the site-specific impacts of the project in much more detail. The effects of thermal release into the atmosphere from a large power plant have not been accurately defined or studied. The NRC, in the Three Mile Island Nuclear Power Plant EIS (NUREG-0112), concluded that major weather modifications were not expected from thermal releases from the plant's cooling tower. The NRC, also in the Sequoia Nuclear Power Plant EIS (Docket 50-327), predicted that a dry cooling tower (without evaporation) would have potential environmental advantages over the evaporative (wet) cooling tower because a dry cooling tower has no evaporation of water, no vapor plumes, no drift, and therefore no fogging and icing that normally may occur with a wet tower. However, more heat energy would be ejected to the atmosphere from a dry cooling tower. The impact of waste heat on the atmosphere would be a function of the heat flux density of the particular tower and the area over which the heat is discharged. An analysis of the effects of thermal releases into the atmosphere from the proposed tritium supply technologies was not performed because of the technologies' non site-specific designs and unknown cooling system design. In addition, no literature related to this topic was found in the National Technical Information Service and other open publications. The 1974 NRC document (NUREG-0112) did mention that Pacific Northwest Laboratory was conducting a general study at that time addressing possible weather modifications resulting from the operation of power plants. No information on the study or possible conclusions was found in the follow-up search. 13.00.39 In reference to tritium recycling, the commentors state that tritium recycling at any facility other than SRS will require construction of new facilities. At SRS the current facilities would require upgrading but would impact no additional acreage. The commentors therefore conclude that pollution prevention and cost considerations would, presumably, be substantially reduced by the use of this facility for recycling. Response: The reduced environmental impacts of utilizing the existing recycling facility at SRS versus building new recycling facilities at the other sites is taken into account in the PEIS and will be considered in the final decision. The preferred alternative identified in section 3.7 indicates that the "recycling" will remain at SRS. 13.00.40 The commentors cite page 2-2 and request an explanation for the decline in tritium requirements until approximately 2011, as shown in figure 2.1-1. In addition, one commentor notes that the amount in the reserve, as a percent of the total supply, seems to be increasing over time and suggests the reasons for this be explained. Response: The decline in the tritium requirements is a result of the declining nuclear weapons stockpile. The reserve amount is based on the refill requirements of the weapons in the stockpile and not on a percentage of the total supply. The commentor is correct, however, the graph shown is schematic and not drawn to scale. The reserve is in direct proportion to the number of weapons in the stockpile. 13.00.41 The commentor states that all reactor technologies, except the APT, will generate spent nuclear fuel, which is not accounted for in DOE's current inventory projections. In addition, DOE is in the process of deciding where and how its current and projected inventory will be stored. The commentor states that this tritium PEIS must: acknowledge that the proposed action will increase DOE's inventory of spent nuclear fuel above the amounts estimated in the Spent Nuclear Fuel and INEL Environmental Restoration and Waste Management Program PEIS; explain that the spent nuclear fuel from tritium production may not be stored at the reactor site; and take into account impacts associated with transporting the spent nuclear fuel to the designated storage site. Response: Spent nuclear fuel would be stored at the reactor site for the life of the project until a repository is available. The ROD for the Spent Nuclear Fuel and INEL Environmental Restoration and Waste Management Program PEIS only determined what the interim storage location for existing spent nuclear fuel would be until a repository was available for ultimate disposition. DOE does not believe it is equitable or reasonable to move tritium supply program spent nuclear fuel on an interim basis. 13.00.42 The commentor believes that DOE should consider using the coolant (water) from the tritium supply and recycling facility in the steam generation plant at Pantex. This could potentially save fuel, according to the commentor. Response: This analysis would be appropriately covered in a site-specific tiered NEPA EIS if Pantex were chosen as the tritium supply and recycling site. 13.00.43 In reference to page 1-3, section 1.4.2, the commentor requests that the PEIS discuss why the Mound Plant would not be suitable for the tritium recycling work. Mound was the best tritium site in all of the DOE, according to the commentor, and the capacity of the weapons production and recycling facilities is very close to that needed now. Response: Termination of the Defense Programs weapons production missions at the Mound Plant was the result of decisions following the Nonnuclear Consolidation Environmental Assessment (DOE/EA-0792, June 1993). It was not considered as a site for the tritium supply mission, and, as such, would not be a candidate for tritium recycling since recycling would either be collocated with the new tritium supply facility or would remain at the current facilities at SRS. 13.00.44 The commentor refers to the following statement in volume I of the PEIS, page 4-448, second column, first paragraph, next to last sentence: "For a multipurpose reactor, the fuel fabrication portion would also be required." According to the commentor, the statement is not correct. The commentor observes that it applies to any "reactor-based disposition technology, not just the multipurpose reactor." Response: This statement indicates that the multipurpose reactor has the same requirement as any reactor-based technology for a fuel fabrication facility. The difference between a multipurpose reactor and the other uranium-fueled reactors considered is that the fuel fabrication facility for a multipurpose reactor would be newly built and collocated with the reactor, whereas, the fuel fabrication facility for a light water reactor, which does not burn plutonium, could be an existing commercial facility. 13.00.45 The commentor states that in volume I, page 4-466, first column, first paragraph, pressurized water reactors are implied as more adaptable than boiling water reactors for tritium production. This appears to the commentor to be a bias. In addition, this statement needs to be fully supported with more and complete information. Otherwise, it should be deleted. The commentor feels that boiling water reactor/advanced boiling water reactors, compared to ALWR, can compete in many different areas such as performance. Response: While both pressurized water reactors and boiling water reactors could theoretically be modified to produce tritium, pressurized water reactors use burnable poison rods which can be replaced by target rods matching in form, fit, and function, which facilitates their adaptation to the tritium production mission. In addition, the prototype tritium target rods were designed and qualified for pressurized water reactor operating environments. The boiling water reactor design uses a distributed burnable poison, Gadolinium, to shape the axial and radial neutron flux distributions. Consequently, there are no burnable poison rod locations in the boiling water reactor design. For these reasons, it was concluded in feasibility studies that pressurized water reactors are more readily adaptable than boiling water reactors to the requirements of tritium production by DOE tritium target rod irradiation. 13.00.46 The commentor states that reactor selection should be based on a comparison of all relevant considerations not on just one criterion such as adaptability. According to the commentor such items as performance-meeting mission goals; impact on secondary goals; system/plant changes; operational changes; safety issues-accident behavior and ability to obtain a license; environmental impact; schedule; and cost should also be considered. Response: The tritium supply technology decision will be based on potential environmental impacts discussed in this PEIS and other information developed for the program on costs, technical risks, and schedule risks presented in separate reports, and policy considerations. Section 3.7 of the PEIS identifies DOE's preferred alternative, and was selected on numerous criteria, not adaptability alone. The analyses on cost, technical risk, and schedule risks are included in the Technical Reference Report available in DOE reading rooms. 13.00.47 In reference to volume I, summary, page S-5, the commentor requests DOE to provide information on the source and amounts of plutonium that would be processed as reactor fuel and how criticality and transportation issues would affect such an operation. Response: Appentix section A.3.2 discusses how much plutonium can be processed. Section 4.8.3.1 discusses the intersite transportation of plutonium for the multipurpose reactor. 13.00.48 In reference to volume II, summary, page S-8, the commentor requests that DOE provide in "alternatives considered but eliminated from detailed study" an analysis of using reactors of United States naval vessels to produce the required tritium. The commentor asks how much tritium could be produced without modifying refueling schedules and/or increasing spent fuel production. Response: Over the years, the Naval Reactor Program has developed a sophisticated nuclear propulsion system specifically designed for the demanding requirements of the submarine environment. This system involves a number of geographically dispersed support facilities specifically designed to support this unique system. The entire system, however, is very small in comparison to the type of facility necessary to supply the tritium required for the Nation's nuclear weapons. Specifics as to the size, capabilities, and other technical information associated with the Naval Reactor Program is extremely sensitive and cannot be released for public review. At the same time, it would be unwise to place additional missions on a system specifically designed for such an important national security mission as that of the Naval Propulsion Program. 13.00.49 The commentor feels that the effect of tritium's decay on United States nuclear deterrent capability is exaggerated. The commentor notes that page 2-2 of the Draft PEIS states that once the "strategic tritium reserve" is used up - in "approximately 2016" according to figure 2.2-1 - the "nuclear deterrent capability would degrade because the weapons in the stockpile would not be capable of functioning as designed. Eventually, the nuclear deterrent would be lost." The commentor feels that this statement is open to serious misinterpretation. It wrongly appears to equate the number of deuterium-tritium boosted weapons in the United States stockpile with the existence of a United States "nuclear deterrent capability," which would clearly persist even without boosted weapons in the stockpile. Without additional tritium production, the performance of some (not all) weapons would begin to degrade in subsequent years and they would have to be removed from the operational stockpile - which weapons are removed would be a matter of choice - and a sizable number (e.g., 500 to 1,000) of high priority deuterium-tritium boosted weapons could be retained in the stockpile for several more decades using tritium recycled from retired weapons. The commentor believes that during this period, which would last for several decades, the United States could, if required, produce conservatively designed, unboosted gun-type and implosion-type pure fission weapons that would assure the persistence of a "nuclear deterrent capability" with or without testing for an indefinite period. Even two-stage thermonuclear weapons could be manufactured using unboosted primary stages, and a smaller number of the resulting heavier warheads could still be carried by bombers and ballistic missiles, originally designed to carry 8 to 24 of the more efficient boosted weapons. The commentor is not aware of any technical experts who would dispute the technical feasibility of this course of action. Response: The statement in the PEIS that, "Once the strategic tritium reserve was depleted, the nuclear deterrent capability would degrade because the weapons in the stockpile would not be capable of functioning as designed," is true. First, all weapons in the stockpile require the proper amount of tritium in order to function as designed. Second, the nuclear deterrent is based upon maintaining the stockpile as directed by the President in the Nuclear Weapons Stockpile Memorandum and the Nuclear Weapons Stockpile Plan. Thus, without the proper amount of tritium, all weapons in the stockpile would not be capable of functioning as designed, the Nuclear Weapons Stockpile Memorandum and Nuclear Weapons Stockpile Plan requirements would not be met, and the nuclear deterrent would degrade. As further stated in the PEIS, eventually the nuclear deterrent would be lost. The commentor's suggestion that unilateral stockpile reductions could still maintain an adequate nuclear deterrent is beyond the scope of the PEIS analysis. However, DOE considers such a course unreasonable because it would not satisfy the DOE's requirements under the Atomic Energy Act, and would not satisfy the purpose of the proposed action. The alternative of redesigning weapons to require less or no tritium was evaluated but dismissed from further consideration for the reasons stated in section 3.1.3. 13.00.50 In reference to volume I, chapter 4, section 4.10.1, page 4-469, 2nd column, 1st paragraph, the commentor requests an explanation for the reason for the increase in spent nuclear fuel production. The commentor also asks can reactors that produce 245 percent spent nuclear fuel be reconfigured or engineered to produce tritium which maintains normal (100 percent) spent nuclear fuel production. Response: Section 4.10.3.2 explains the reason for the increase in spent nuclear fuel production: more frequent refueling operations and the segmenting of fuel assemblies could result in an increase in spent nuclear fuel volume. The goal is to produce tritium, not reduce spent nuclear fuel. Producing tritium results in increased generation of spent nuclear fuel due to more frequent refueling. In order to produce required amounts with current designs, the refueling indicated is required. Further analyses would be conducted in site-specific tiered NEPA documents to determine the measures which can be used to reduce spent nuclear fuel, maximizing tritium production, and minimizing costs. 13.00.51 The commentor asks why, based on the information in the environmental impacts section on page S-11, the calculated electric power consumption for the APT at the various sites is lowest at SRS. Response: The power requirement for the APT is the same at all sites. The discussion in question does not state what the power requirements of the various technologies are but how much the current power requirement of the site would be exceeded. 13.00.52 The commentor refers to volume I, page 3-2, column 2, paragraph 1, and remarks that the document "Tritium Supply and Recycling Plants Technical Reference Report" is not identified in the same manner as other references. The commentor asks if the document is reference FDI 1995a. Response: The commentor is correct, the document is reference FDI 1995a and it is now available in DOE reading rooms. 13.00.53 One commentor referring to volume I, page 3-12, column 1, paragraph 3, asks why the Hanford Site was dropped as a candidate site for future Complex missions. The commentor notes that page 1-10 explains that Hanford was eliminated because nuclear weapons functions at that site have been terminated, while page 3-12 states that Hanford is now dedicated to environmental and waste management activities. When and why was this decided, the commentor asks, and who made the decision. Another commentor asks if NEPA compliance was ever completed for this policy action and then cites that INEL currently has an environmental and waste management mission. The commentor adds that it is not part of the Complex (page 1-4). If this PEIS will provide NEPA compliance to locate defense-related activities at INEL, then the commentor believes it should also evaluate the suitability of Hanford. The commentor states that it is not appropriate to eliminate a reasonable alternative from an EIS simply because it does not fit with current agency policy. The commentor believes consideration of all reasonable alternatives is particularly important at the programmatic level. Response: Section 3.3.1 discusses why Hanford was eliminated. The Hanford site is dedicated to environmental restoration and all other missions have been removed. INEL has some restoration activities like all other sites; however, the INEL site has missions other than environmental management. This decision was announced by the Secretary of Energy in the Federal Register at 58 FR 39528 on July 23, 1993. 13.00.54 The commentor states that all isotopes of hydrogen, including tritium, are very diffusive. The diffusitivity of hydrogen increases dramatically as the temperature increases. At room temperature, tritium diffuses far into the stainless steel wall of a tank or pressure vessel. Therefore, it is very difficult to envision how a target could be clad with a material that would contain the tritium within the target. Any tritium that diffuses through the target cladding and into the coolant, goes from being product to being radioactive waste. The commentor concludes that the PEIS should address this subject before it concludes that power generation by a tritium production reactor is feasible. Response: The commentor is correct in that all isotopes of hydrogen are very diffusive and that this varies directly with temperature. However, there are methods to reduce the losses of tritium in the target rods such as coating the interior of the rod with a "getter" material which adsorbs and retains the tritium. DOE has extensive experience in this technology for the HWR temperatures and is currently involved in a research program to develop suitable target rods that would retain tritium at the higher temperatures that would be present in the ALWR technology. In any event, some tritium would still escape under normal operations and these releases are addressed in the PEIS. 13.00.55 Commentors express opposition to the construction of a multipurpose or "triple play" reactor, capable of producing tritium, burning plutonium, and generating revenues through the sale of electric power. According to the commentor, such a reactor would be counterproductive in at least two ways: it would violate United States policy that commercial reactors not be utilized for military purposes including tritium production, and using plutonium as fuel is more dangerous and expensive than using uranium for fuel. Another commentor feels that the HWR technology is better than the proposed "triple play" reactor. Other commentors believe that the "triple play" is risky because the focus would not be on tritium production and the additional complexity of combining tritium pro- duction with plutonium disposition activities would lead to operational tradeoffs. Such tradeoffs could decrease the efficiency of the reactor in performing its functions. One commentor also notes that electricity currently does not need to be generated in greater capacity because of increases in conservation and alternative energy sources. Finally, another commentor suggests the report Multi-Fallacy reactors be considered in the PEIS. Response: The Atomic Energy Act of 1954 (as amended) provides for the generation and sale of electrical power incident to the operation of a production facility. It is reasonably foreseeable that electricity generated by an ALWR, MHTGR or commercial reactor 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 environmental impacts. Because an ALWR or MHTGR could also be used to "burn" plutonium, these environmental impacts are also addressed in the PEIS. Regarding the policy of the United States to maintain separate military and commercial nuclear missions, such issues will be further evaluated if the preferred alternative identified in section 3.7 is selected in the ROD. 13.00.56 The commentor feels that the DOE should seriously consider the private consortium proposal as a viable alternative in the PEIS. Response: Section 3.1.1 of the PEIS acknowledges that a private consortium could provide a new tritium facility, but that the associated environmental impacts are independent of this. DOE has prepared a Technical Reference Report which contains cost and technical analyses that consider that proposal. The Technical Reference Report is available in DOE reading rooms. 13.00.57 The commentor feels that the phased approach for APT should be deleted and all of the technology options based on a single capacity requirement. Alternatively, the commentor remarks that the phased approach for tritium production should be explained in the executive summary, and it should be applied for all technologies that are capable of achieving it, including the MHTGR, the gas turbine-modular helium reactor and, presumably, the Small ALWR. Response: The phased approach for the APT is contained on page ES-16 of the executive summary. The phased approach for all of the other technologies was also evaluated, but dismissed for the ALWR and the HWR since these reactors couldn't be built smaller and then expanded. For the MHTGR, it was determined that although two modules would suffice for the steady state requirement, three would be needed for the full baseline requirement and it could not be built and brought online in the requisite 5 year timeframe. 13.00.58 In reference to page 3-1, the commentor states that it seems inconsistent for the PEIS to confuse its evaluation by considering 3/16 of 1988 goal (nominal) and then say that 3/8 of the 1988 goal is the basis for the PEIS. According to the commentor, this nominal goal seems to only benefit the APT. Response: As explicitly explained in section 3.1, the baseline requirement is composed of two parts, the steady state which is equivalent to 3/16 goal and the surge, which when added to the steady-state results in the 3/8 goal. The analysis of the APT in the PEIS covers the environmental impacts of the construction of the full APT since all of the "civil" construction would be done at one time. This is a potential advantage for the APT over the other new technologies. The operational impacts of running all of the tritium supply facilities at 3/8 goal are given in the PEIS since this bounds the problem environmentally. However, the APT is the only technology that allows for a phased approach to meet the 3/16 goal more rapidly than would be required to meet the 3/8 goal. Other benefits from operation at less than 3/8 goal will be covered in cost, technology, and schedule analyses being done by others. 13.00.59 Several commentors suggest that the PEIS does not provide a fair and consistent treatment of candidate technologies, specifically the 600 MWt gas turbine-modular helium reactor technology. In reference to the PEIS statement on page 4-448 that impacts of the 600 MWt gas turbine-modular helium reactor are not addressed because the available design information is not comparable to that of the 350 MWt MHTGR design, one commentor notes that there is even less design information available for the HWR evaluated in the PEIS. The HWR is stated to be a preconceptual design on which almost no work has been done, yet this information is presented in the PEIS. According to the commentors, the gas-cooled reactor developer provided ample information on the 600 MWt gas turbine-modular helium reactor for use in this PEIS, and DOE has chosen to use none of it. The 600 MWt gas turbine-modular helium reactor has environmental impact characteristics that are consid- erably more favorable than those of the 350 MWt design and the commentors feel these should be given full and fair presentation in the PEIS. Commentors suggest that the PEIS for plutonium disposition consider the impacts of the multipurpose and plutonium disposition plant configurations shown in table 1 (see document # - TSR-M-112), which include plutonium disposition plants that accommodate processing of the plutonium inventory over the design life of the reactors, as well as an accelerated disposition schedule. In reference to page A-101, another commentor notes that the PEIS indicates that the gas turbine-modular helium reactor presents a substantial increase in the technical, schedule, and cost risks of bringing the concept to maturity. In fact, the commentor notes that the gas turbine-modular helium reactor technology is the same as the MHTGR reactor technology, and has been substantially successfully demonstrated in German and United States reactors. Given adequate funding, a fully tested turbomachine could be delivered to the site in less than 7 years, according to the commentor. This would allow the design, testing and construction of the complete gas turbine-modular helium reactor to be accomplished in 10 years. The commentor further states that the PEISs for both programs, if kept separate, should include multipurpose plants (e.g., gas turbine-modular helium reactor and ALWR) as explicit technology alternatives including full environmental impact characterizations. This will ensure that if a ROD is made adopting a multipurpose alternative, the PEIS will support this decision. Response: The 350 MW (thermal) MHTGR is the gas reactor technology evaluated in the PEIS, and is based on the significant work done by the New Production Reactor Program. Significant monies were spent developing the data for this alternative, this technology was thoroughly reviewed as part of the New Production Reactor effort, and, in DOE's judgement, represents the best available information for a gas reactor. In August 1994, DOE received a July 1994 report from CEGA Corporation regarding the 600 MW (thermal) gas turbine-modular helium reactor. The CEGA Corporation Report describes the gas turbine-modular helium reactor concept and provides information that can be used to compare the gas turbine-modular helium reactor against the MHTGR. Appendix section A.3.1.1 of the PEIS discusses this. The most significant difference between the MHTGR and the gas turbine-modular helium reactor is in the area of costs/revenues. This is due to the fact that the gas turbine-modular helium reactor is a much more efficient electricity producer than the MHTGR (plant efficiency increases from 38 percent for the MHTGR to 47 percent for the gas turbine-modular helium reactor). The cost reports included in the Technical Reference Report available in DOE reading rooms present these differences. There are not significant environmental differences between the 2-module gas turbine-modular helium reactor and the 3-module MHTGR and even CEGA Corporation, in its report, acknowledges that the environmental impacts are only "slightly less" for the gas turbine-modular helium reactor compared to the MHTGR. In reality, the gas turbine-modular helium reactor would have slightly more environmental impact in some resource areas and slightly less environmental impact in other resource areas than the MHTGR. Thus, it really depends on one's perspective to conclude, overall, that the gas turbine-modular helium reactor has slightly less environmental impact than the MHTGR. To one whose overriding concerns are the amount of spent fuel generated, or the radiation doses from normal operations or accidents, the gas turbine-modular helium reactor has slightly more impact than the MHTGR. To one whose overriding concerns are the amount of water used or the number of workers required to operate the facility, the gas turbine-modular helium reactor has slightly less impact than the MHTGR. The most accurate thing that can be said about the gas turbine-modular helium reactor versus the MHTGR is this: from a PEIS environmental impact perspective, the issue of MHTGR versus gas turbine-modular helium reactor is not a significant issue. In summary, the PEIS presents a discussion of the environmental impact differences between the MHTGR (which is evaluated in detail in the PEIS) and the gas turbine-modular helium reactor (see appencix section A.3.1.1). The MHTGR was evaluated in detail in the PEIS because it represents the best available information for a gas-cooled reactor at the time when the PEIS was being prepared. The data received from CEGA for the gas turbine-modular helium reactor do not provide any significant new environmental data for the gas turbine-modular helium reactor. Moreover, as acknowledged by CEGA Corporation, the environmental impact differences between the gas turbine-modular helium reactor and MHTGR are only "slight" in any event. 13.00.60 The commentor suggests that the current approach taken in the PEIS for evaluating multipurpose options is distorted for the gas-cooled reactor in that it focuses solely on the relative number of reactor modules required for a multipurpose plant versus those required for a tritium production plant without providing any perspective on the meaning of these numbers. According to the commentor, the steam cycle MHTGR is capable of producing tritium at 3/8 goal quantity with a total installed thermal capacity of only 1050 MWt. Other reactor options, the commentor adds, require installed capacities of 1,800 MWt (if, in fact, only one Small ALWR can produce tritium at 3/8 goal quantity) to about 3,400 MWt to achieve the same level of tritium production. The commentor contends that the multipurpose gas-cooled reactor options discussed in the Draft PEIS are limited to those that are fueled with pure weapons-grade plutonium oxide and have no fertile fuel material. For these options, lithium targets are, due to reactor physics considerations, placed only in the core reflectors, resulting in decreased tritium production per reactor module relative to the highly enriched uranium-fueled tritium production MHR. The intent of these options has been to produce tritium while achieving a degree of plutonium destruction that exceeds the spent fuel standard, according to the commentor. The commentor believes that another option can be considered in which the degree of plutonium destruction achieved is only equal to that achieved by the ALWR. With this option, the commentor notes that natural uranium replaces the erbium poison, allowing lithium targets to be placed in the active plutonium-fueled core regions and significantly increasing tritium production per reactor module. This option is being quantified by the gas-cooled reactor developer at this time. The commentor states that in the multipurpose application, the flexibility of the MHTGR results in several options for producing tritium at 3/8 goal while dispositioning plutonium. Each individual module, with no changes in the plant design, can be dedicated separately to disposition plutonium, to produce tritium, or to achieve a combination of these two purposes. The commentor notes that the PEIS describes an option where the total installed thermal capacity is 2,100 MWt, which is small compared to the installed capacity required for the Large ALWR options. Therefore, it is only because the MHTGR and gas turbine-modular helium reactor are exceptionally efficient as tritium producers that the impact of changing to a multipurpose reactor appears to be so significant. However, if one compares the multipurpose MHTGR and gas turbine-modular helium reactor with the multipurpose ALWR, it is clear that the environmental impacts of the multipurpose MHTGR are generally lower, and the environmental impacts of the gas turbine-modular helium reactor are significantly lower, according to the commentor. If one compares the multipurpose reactor options with the combined impacts of separate tritium production and plutonium disposition plants, the commentor states that it is clear that the total installed capacity required for the multipurpose plant is lower for the MHTGR and is about equal for the ALWR. The commentor believes that all of these points need to be explicitly stated and clarified in the PEIS Response: Section 4.8.3 of the PEIS evaluates multipurpose reactors. The basis of this evaluation is the environmental impact of their construction and operation. The measure suggested in the comment is to evaluate the impact based on the installed thermal capacity. The environmental impact analysis presented in the PEIS is directly proportional to the installed and operated thermal capacity. The options evaluated for the multipurpose MHTGR reactor in the PEIS were those for which data were reasonably available at the time. The modification of the design to optimize both tritium production and plutonium production was not attempted in this document. Future design refinements, such as replacing the erbium poison with natural uranium in the core as suggested in the comment, would be done in the future refinement of this concept and would be considered in site-specific tiered NEPA documents, as appropriate. The use of individual modules in the tritium-only producing mode using uranium fuel was in fact considered in this document. The rationale in arriving at six 350 MWt reactor modules was based on the steady state (3/16 goal) tritium requirement. The assumption was made that if the full baseline (3/8 goal) quantity were required then one or more of the reactor modules could be run in the tritium-only production mode using uranium fuel. If this were not the case, then twice as many reactor modules (12) would have been required to produce the baseline quantity of tritium. The facility accident scenarios for the MHTGR include only one of the modules which, as the commentor noted, is considerably smaller than the other reactors. Thus, the impacts from MHTGR accident analysis are considerably less pervasive than those from the other technologies, which is evident in the facility accident analysis as presented in appendix F. 13.00.61 In reference to page 4-13, the commentor believes that the paragraph on uncertainties is misleading on maturity of design. The inference is that the sources being different presents an uncertainty and the issue of the maturity of the APT design is ignored. Response: The discussion in section 4.1.9 included the sources of the information used in the risk analysis. It indicates that information on the technologies for the HWR and MHTGR was largely based on documentation from the New Production Reactor Program, that the ALWR information was prepared by vendors, and that the APT information was prepared by DOE laboratories and private contractors. Issues regarding the respective maturity of the designs are included in the Technical Reference Report available in DOE reading rooms. 13.00.62 In reference to pages I-40 and I-41, the commentor states that these are typographical errors under No Action - INEL should be NTS and ORR and Pantex should be SRS. Response: The text has been revised to reflect the correct site in each column in appendix I of the Final PEIS. 13.00.63 In reference to page S-1, top of second column, the commentor asks if "surveillance" should be included as one of the functions of the Complex. Response: Surveillance is included within the maintenance activities of the site. 13.00.64 In reference to page S-1, top of second column, the commentor notes that there exist other sources of recyclable tritium, such as research, development, and testing scrap and tritium caught in effluent capture systems. Response: The statement in question was not meant to identify all possible sources of recyclable tritium but to define what tritium recycling meant in this document. 13.00.65 Another commentor indicates that in the technologies section on page S-5, information should be included on the amount of electricity that could be produced and the amount of plutonium that could be burned for each supply technology. Response: Since both the MHTGR and the ALWR were developed originally to produce electricity and, as such, have steam turbines as an integral part of their designs, the PEIS evaluates the environmental effects of both of these technologies with electrical generating turbines included. However, the actual sale of steam or generation of electricity by DOE would be covered in the site-specific tiered NEPA documents if either of these technologies were chosen and if DOE developed a proposal to sell steam or electricity. The generic impacts of the sale of steam or electricity, including construction of electric transmission lines, are analyzed in section 4.8.1. Nominal gener- ating capacities are 1,100 to 1,300 MWe for the Large ALWR, 600 MWe for the Small ALWR, and 400 MWe for the three-module MHTGR. The actual estimates of electrical production are covered in the cost estimate included in the Technical Reference Report available in DOE reading rooms. The PEIS evaluates alternative technologies and sites for long-term, assured tritium supply and recycling. Another DOE program office, the Office of Fissile Materials Disposition, is preparing a PEIS addressing the issue of how to dispose of plutonium that is excess to the nuclear weapons complex. Information on the amount of plutonium that could be burned for each supply technology would be included in the PEIS being prepared by the Office of Fissile Materials Disposition. Of the four tritium supply technologies evaluated in the PEIS, only the ALWR, MHTGR and commercial reactors are being considered for plutonium disposition. Therefore, the environmental impacts of a plutonium-burning ALWR and MHTGR are analyzed and presented in the PEIS. Estimates of the amount of plutonium that could be consumed by the ALWR and MHTGR technologies are included in appendix section A.3.2. 13.00.66 The commentor states that the current PEIS analysis would have us believe that, on the one hand, DOE's purchase/completion of an existing light water reactor, such as WNP Unit 1 (65 percent complete), TVA's Bellefonte Unit 1 (88 percent) or Unit 2 (57 percent), or Watts Bar Unit 1 (99 percent) or Unit 2 (61 percent), is not worthy of detailed analysis due to lofty consideration of nonproliferation policy, but, on the other hand, that building the prototype of the next generation standardized civil reactor expressly for military production at a DOE weapons program site, and subsidizing such production with the commercial sale of electricity, is somehow entirely consistent with this alleged "policy." The commentor suggests that the current PEIS analysis thus appears grounded on an untenable double standard. In the commentor's opinion the apparent motive is to tilt the PEIS analysis in the direction of supporting the maximum expenditure of public funds at current DOE sites and gaining the maximum public subsidy for the next generation of commercial nuclear power development. The commentor charges that the evaluation of ALWR supply options is uneven, biased, and fraught with contradictions. Construction of an ALWR under DOE ownership is assessed in detail for its potential impact on five individual DOE sites, yet the commentor feels that an analysis of DOE's potential purchase of an existing operational or partially completed light water reactor is given a once-over-lightly "generic analysis" under the heading "Commercial Light Water Reactor Contingency." Why is an option that could save taxpayers billions of dollars relegated to second-class "generic" treatment, while a similar light water reactor option costing billions more receives detailed site-by-site analysis. Moreover, this generic approach effectively equates the impacts of control rod production of tritium in eight utility-owned, commercial light water reactors under contract to DOE with DOE's purchase or long-term lease of a single existing or partially completed light water reactor for production of tritium in fuel-target assemblies. The environmental, technical, institutional, and political impacts of these proposals are sufficiently different to warrant separate analyses as distinct tritium supply alternatives. Response: As discussed in section 4.10, DOE considers the purchase of an existing or incomplete reactor a reasonable alternative to meet the stockpile tritium requirement mission. In the Final PEIS, the analysis of this option has been expanded to resolve the apparent inconsistency noted by the commentor. A more detailed and comprehensive analysis of the purchase of an existing light water reactor has been added to the PEIS. Based upon public comments and a reevaluation of irradiation services, DOE decided to include the irradiation services as a reasonable alternative in the Final PEIS. DOE also invited public comments on this specific issue, including comments on the potential environmental impacts described in section 4.10 of the Draft PEIS, in a special 21 day comment period. Results of that additional comment period are included in this Comment Response Document. Furthermore, as identified in section 3.7, the preferred alternative involves the further investigation of commercial reactors to determine whether the policy and regulatory issues for this alternative can be resolved. 13.01 Heavy Water Reactor Technology 13.01.01 The commentors express support for selecting the HWR technology as the tritium source for several reasons. One commentor suggests that the other technologies, ALWR and MHTGR, can create unexpected problems that could cause long shutdowns and large operating expenses because they are newer, less-tested technologies. According to the commentor, the HWR requires less-complex safety systems and it also has a cooling system that is "similar to that used in commercial light water reactor nuclear power technology." The commentor believes that radioactive releases from HWRs would be fewer than those of other technologies. Because of its greater reliability than the other technologies, the commentor also notes that it will have fewer environmental impacts. Another commentor prefers that the HWR be located at SRS because its low operating temperature eases safety concerns and SRS's experience with reactors of similar type and scale should facilitate success. Response: The advantages of the HWR technology have been noted in the PEIS or the associated studies on cost, technical feasibility, and schedule. The Technical Reference Report compares those criteria for the technologies and is available in DOE reading rooms. 13.01.02 The commentor expresses concern that the HWR alternative is an extremely expensive endeavor. As a result, the commentor states that DOE must be reasonably certain that the technology will work. Response: The Technical Reference Report is available in DOE reading rooms and considers the technical and cost uncertainties of each technology. 13.01.03 The commentor questions whether the use of a HWR to generate electricity and dispose of plutonium can be explored as an alternative. Response: The design which was evaluated does not produce electricity and does not meet the screening criteria for the multipurpose reactor. 13.01.04 The commentor proposes a new alternative technology - a new HWR with a patent pending from DOE. The commentor contends that the unit is as safe or safer than the MHTGR since it eliminates design-basis accidents. In addition, the commentor states that it can be built for about one-third to one-half the cost of other production reactors under consideration in 1992 and considerably less than an accelerator. In the commentor's opinion, the HWR doesn't need as large an external power source as the APT, and the reactor is low cost, efficient, and proven. The commentor further notes that it is compatible with other proven and available SRS operations. Response: The HWR was developed as a result of the New Production Reactor Program, and it was later downsized and modified to meet the new tritium supply goal. Site-specific analysis would consider these types of improvements. 13.02 Modular High Temperature Gas-Cooled Reactor Technology 13.02.01 Several commentors feel that the MHTGR has a bad track record in both the United States and Europe; therefore, unless a thorough study and evaluation of the technical uncertainties associated with the MHTGR alternative is done prior to selecting this option, its use for the critical function of tritium production involves an unwarranted risk. The commentor cites the poor performance of General Atomics' demonstration plant in Ft. Vrain Colorado and Great Britain's change of mind in using the GASCO reactors as examples of such risk. The commentors also believe that there is limited technical expertise for the production of MHTGR fuel and this will most likely drive up the cost of producing this type of fuel. Response: DOE has prepared a Technical Reference Report comparing cost, technical feasibilities, and schedules for the technologies. This Technical Reference Report is available in DOE reading rooms. 13.02.02 The commentor references pages B-28 through B-32 and states that according to tables A.2.1.1-2 and A.2.1.2-2, the HWR consumes significantly more fossil fuel annually than the MHTGR. So, the commentor questions how can the MHTGR emit the most criteria pollutants. Response: The HWR and MHTGR reactors have different processes, facilities, and requirements which result in different air emissions. Criteria pollutants are not directly attributable to fossil fuel use, many other factors are involved. 13.02.03 The commentor states that a chemical that should be added to table A.2.1.2-3, page A-50 is graphite. According to information provided to DOE in the CEGA-94-0011 letter, enclosure 2, table 4-5, 122 tons of graphite are required per year. Response: Graphite has been added to table A.2.1.2-3 in section A.2.1.2 of the Final PEIS. 13.02.04 One commentor felt that the statement that it would require more than 5 years to add capacity for the MHTGR to produce additional tritium is not correct. The commentor believes that the MHTGR could bring additional modules online in this time period if proper provisions for plant expansion were made during construction of the initial modules. Response: The determination that it would take more than 5 years was a programmatic engineering judgement made by DOE after evaluating all relevant criteria. 13.02.05 In reference to page 3-33, one commentor notes that the safety-related electrical loads for the MHTGR are small enough that they are supplied by safety-related battery power. While a backup power facility is provided to mitigate unavailability, the commentor states that it is not a safety feature. The below-grade containment structure is made of steel-lined reinforced concrete. Gravity-drop of the control rods is in the front-line safety-related scram system. Independent shutdown capability is provided by gravity-drop of the reserve shutdown control material, which is in the form of boronated graphite pellets, not safety rods; both of these systems were successfully demonstrated at Fort St. Vrain. Response: The design of the MHTGR was based on modified New Production Reactor design and developed within that program by DOE. This represents the reasonable design for analysis in the PEIS. 13.02.06 One commentor, referring to page 3-34, feels that this layout is not consistent with the layout developed for the MHTGR during DOE's New Production Reactor Program. The commentor notes that the most recent and applicable layout is provided in the NP-MHTGR Project Closeout Report, CEGA-002764, 1993. Response: The layout is only intended to be an artist's rendering and is based on layouts from the New Production Reactor documentation. The notation (typical) is intended to show this fact and does not bear on environmental impacts. 13.02.07 One commentor feels that the basis for the following assertion should be given, or that the assertion should be deleted on page 4-447: "Substantial uncertainty exists for the use of a gas-cooled reactor for plutonium disposition." The commentor also states that use of plutonium coated particle fuel has been demonstrated in six separate tests, which were conducted more than 20 years ago in the Dragon and Peach Bottom HTGRs. Thus, the commentor believes that plutonium disposition is not a new mission for the gas cooled reactor. Response: The statement in question is consistent with the conclusion reached by DOE's Office of Fissile Materials plutonium disposition working group, which concluded that the MHTGR was not a reasonable alternative for plutonium disposition. Nonetheless, the technology was still evaluated in the PEIS. 13.02.08 The commentor states that the discussion of pit disassembly and conversion assumes that the facility for this activity would be collocated with the reactor. In fact, the commentor notes that safeguard considerations may dictate that this activity be conducted at the pit storage facility at the Pantex site, and that plutonium be shipped to the fuel fabrication facility in the form of plutonium oxide. The discussion also refers constantly to the fabrication of "mixed-oxide" fuel. In the case of the gas-cooled reactor, mixed-oxide fuel is not used, the fuel is weapons grade plutonium oxide only. No fertile material is used. The commentor believes that these matters should be acknowledged and discussed in the PEIS. Response: For the PEIS, the pit disassembly and conversion was assumed to be located with the tritium supply for the purposes of analyzing a multipurpose reactor. Consistent with this, the PEIS addresses the impacts of transportation of pits. More detailed analysis of pit disassembly and conversion facility, including site locations that may be different than those evaluated for tritium supply, can be found in the PEIS being developed for the Fissile Materials Disposition Program. 13.02.09 The commentor references the following statement on page 4-461: "The assumption can be made and supported that with more reactors the potential for accidents to occur may increase, as well as the radiological impacts to the public and site workforce." The commentor feels that it should be noted that even if doubled, the impacts of the gas-cooled reactor are small compared to those of other technologies. However, the commentor notes there is no basis for assuming that the radiological impacts of accidents would be larger as a result of having more reactor modules. MHTGR modules are designed to operate independently of each other with no common safety-related systems. Accident consequences are determined by events at a single module and are unaffected by the presence of other modules, according to the commentor. Response: The commentor is correct. The frequency of an accident is based on the number of modules even though the consequences of an accident do not increase due to the number of modules. 13.02.10 On page A-43, the commentor points out that the spent fuel storage facility is not "underwater," rather storage is provided in dry wells, the exterior of which is water cooled. Response: The description of the Interim Spent Fuel Storage Facility in appendix section A.2.1.2 of the Final PEIS has been changed to read as follows: "This facility consists of three water-cooled fuel storage basins paired with individual reactors. Fuel elements containing spent fuel would be stored in dry canisters for up to 3 years in the storage basins. After a 3-year cooling period, the spent fuel elements would be encapsulated and then transferred to dry storage vaults capable of storage for the life of the plant." 13.02.11 The commentor notes that the reactor is a "moderate" pressure device but on pages ES-9 and S-5 it is stated to be a "high" pressure device. The commentor feels that page A-42 should be changed to be consistent with the other two pages. Also, the commentor notes that the reserve shutdown material of the MHTGR is boronated graphite pellets, not boron carbide spheres. The commentor states that the electrically driven circulator is located above the steam generator, not above the core. A single cross vessel, not multiple ducts, directs the helium to the (single) steam generator. Response: The description of the MHTGR in the executive summary and summary has been revised to indicate that the technology is a high temperature, "moderate" pressure reactor. Appendix section A.2.1.2 has been revised to incorporate the commentor's proposed changes. 13.03 Advanced Light Water Reactor Technology 13.03.01 Commentors state that the ALWR technology is preferred because it offers multiple benefits: a proven, safe method for producing tritium; burns excess plutonium from defense and commercial activities, thereby reducing amount of waste plutonium to dispose of/store minimizing the likelihood that it could end up in the hands of terrorist groups; and generates electricity ("triple play"). One commentor states that the ALWR alternative offers the best engineering option to produce power for operating the tritium facilities, as well as other site facilities, because it can operate using plutonium fuel elements without having reductions in tritium or power production. Another commentor suggests that only the Large ALWR is capable of satisfying both the tritium production and plutonium disposition missions with relatively little added environmental impact. This could provide extra energy and jobs, according to the commentors. In addition, the commentors point out that it also meets DOE's goals of not only stockpile replenishment but of: encouraging technology transfer and economic development in vicinity of DOE sites; partnering with private sector to "test" streamlined commercial licensing process; and reducing likelihood of nuclear weapons proliferation. Response: The PEIS evaluates the ALWR technology for the production of tritium. However, the PEIS also assesses the impacts of the options available with the ALWR to produce electricity and burn plutonium in addition to producing tritium. DOE does not expect that the ROD on tritium production would restrict or prejudice decisions of any plutonium options. In fact, DOE's preferred alternative would allow for subsequent integration with future plutonium disposition decisions, if desired. As stated in the description of the NEPA process in section 1.2, any decision made in the ROD would be followed by a site-specific tiered NEPA document that would address the technologies and locations on the chosen site. 13.03.02 The commentor notes that the PEIS incorrectly assumes that a single, Small ALWR could simultaneously carry out both missions of tritium production and plutonium disposition. A single, Small ALWR would require well over 60 years to consume the 50 megatons of excess plutonium. Therefore, the commentor feels that the PEIS should be corrected to assume at least two Small ALWRs for the combined missions. The commentor also notes that for completeness, it should be noted that ABB - Combustion Engineering's proposal to DOE for a privatized multipurpose System 80+ reactor, assumed two units would be constructed - so that the plutonium disposition mission could be completed in 15 years of operation. For comparability, a 15-year plutonium mission would require that the number of gas cooled reactors and Small ALWRs also be doubled again, from the previous paragraphs. Response: The analysis presented for the tritium supply mission did not consider the need to burn plutonium to meet any specific time requirement. Rather, the PEIS evaluated multipurpose application of the reactors and attempted to distinguish the differences in technologies by providing information on how much plutonium could be dispositioned while still meeting the primary mission of tritium production. 13.03.03 The commentor believes that the limited database available for use in the evaluation of tritium production in ALWRs that was created as an adjunct to the plutonium disposition evaluations is not an in-depth evaluation of these reactor types for the mission. Instead, the commentor notes the evaluations were done as "Go-No-Go." The commentor also states that certainly the one, or at best two, conceptual designs for tritium production were not intended to optimize performance and cannot be used for quantitative comparisons. If the light water reactor option is endorsed in the PEIS, then further detailed evaluations should be made to establish a specific technology or design, according to the commentor. Response: The best available design information was used for the analysis in the PEIS. The analysis was appropriate for the programmatic decision necessary to select the tritium supply technology. A more detailed analysis of the selected technology will be done in future site-specific tiered NEPA documents. 13.03.04 The commentor suggests that in the PEIS, volume 2, page A-52, first column, fourth paragraph, the 1,100 MWe value for ALWRs should be 1,300 MWe. Response: The commentor is correct. The text has been changed in appendix section A.2.1.3 of the Final PEIS to indicate that both large reactors are 1,300 MWe. 13.03.05 Commentors believe that the PEIS should explicitly state how many Small ALWRs are needed to produce tritium at the 3/8 goal level, and should do so in a manner consistent with other DOE documents. In addition, the commentors believe a discussion should be provided of the effects of tritium production in light water reactors, both large and small, on fuel enrichment, operational constraints, and other safety and technical characteristics of the reactor. One commentor further notes that the discussion should include the effects of changes in the characteristics, caused by tritium production, on environmental impacts and the technology base/licensing (certification) basis of the light water reactors. In reference to page A-60, another commentor questions how a Small ALWR can produce the same quantity of tritium with half the lithium required by a Large ALWR assuming all ALWR concepts use the same targets. The commentor states that this PEIS never explicitly discusses how many Small ALWRs would be needed, but leaves the impression that one would suffice. This leads the commentor to ask whether one Small ALWR can really produce baseline quantities of tritium. If not, the commentor suggests that all tables throughout the document should be modified to be appropriate for the required number of Small ALWRs. Response: DOE agrees that the Small ALWR requires approximately the same quantity of lithium as the Large ALWR to produce tritium at the 3/8 goal level. The appendix table A.2.1.3-3 has been changed to reflect this fact in the Final PEIS. The number of Small ALWRs required to produce tritium at the 3/8 goal level is one. This number is stated throughout the Final PEIS, i.e., "a Small ALWR (600 MWe)" in the volume I summary and in section 3.4.2.3. 13.03.06 The commentor states that the information given in tables 4.8.3.1-4, page 4-451 appears to be based on assumptions appropriate for a light water reactor mixed-oxide assembly facility. For example, the building footprint is shown to be 115,000 ft2, but in reference GA 1994b cited in the PEIS, it is shown that the footprint of this facility is only about 75,000 ft2. The commentor suggests that appropriate information for the gas-cooled reactor fuel fabrication facility should be given. Response: The MHTGR technology conceptual design for tritium supply includes a fuel fabrication facility and therefore is analyzed in the PEIS. The ALWR technology for tritium supply would use reactor fuel from existing commercial sources, therefore there is no onsite fuel fabrication facility. For the multipurpose reactor option discussed in section 4.8.3 of the PEIS, a Pit Disassembly/Conversion/Mixed-Oxide Fuel Fabrication Facility was described which would be necessary to support the multipurpose ALWR. The multipurpose MHTGR analyzed in this section, since it was based on the tritium supply machine, would already have the fuel fabrication part of the same facility as part of the design. Some modification of this facility would be required to accommodate the fabrication of plutonium fuel but these modifications would be expected to be minor. A discussion of the "front end" pit disassembly and conversion facility has been added to section 4.8.3 for the MHTGR. However, as noted in the PEIS, the impacts of this added facility would be minor in comparison to the construction and operation of three more reactor modules. 13.03.07 One commentor refers to page A-52 and suggests that more detail should be provided regarding the need to increase enrichment of the light water reactor tritium production core and to derate the plant. The commentor states that the effects of these changes on safety parameters and licensing basis should be discussed. Another commentor references page 3-36 and states that the assumption of one 600 MWe ALWR, with no downrating in power output while producing 3/8 goal quantities of tritium, does not seem credible. Response: The discussion on appendix page A-52 indicates that modifications to the design for tritium production would be minimal. Thus, the effects of any such modifications on impacts and other analyses presented in the PEIS are expected to be minimal. The discussion in appendix section A.2.1.3 of the PEIS addresses the potential downrating in power output. A 600 MWe ALWR could produce the 3/8 goal quantity of tritium without fuel enrichment greater than 5 percent, and without impacting safety parameters. However, complete core changeout would be required annually rather than on the typical 18-month cycle for a commercial reactor. 13.03.08 The commentor notes that it is argued in the PEIS, page 3-36, that "a power conversions facility (steam turbine) is an integral part of the design for the ALWR because of the high temperature of the exit coolant and will be included in this analysis." The commentor also points out that appendix A states that the "ALWR and the MHTGR technologies offer the added benefit of being capable of producing [sic] steam for electricity production that could prove to be desirable in offsetting operational and capital costs" (PEIS page A-99), and that "the [ALWR] reactor would be an improved version of existing commercial electric power generating reactors and would be operated at or near rated power...Modifications to the design for tritium production would be minimal..." [PEIS page A-52 (emphasis added)]. Indeed, the commentor suggests that one of the candidate ALWR designs, ABB-Combustion Engineering's System 80+, is essentially the same design as the System 80 units already in operation at the "civil" Palo Verde Nuclear Generating Station in Arizona, and as the "civil" KHIC/C-E reactors built under license in South Korea and recently offered to North Korea as an allegedly "proliferation resistant" inducement to end its plutonium separation program. Response: Nonproliferation concerns such as these expressed by the commentor will be considered in the decision-making process. The preferred alternative identified in section 3.7 of the PEIS is a dual-track strategy to pursue both the use of an existing commercial light water reactor and the construction of an accelerator to produce tritium. Within a three year period, DOE would select one of the alternatives to serve as the primary source of tritium. The other alternative, if feasible, would be developed as a back-up tritium source. SRS has been selected as the preferred site, if an accelerator is ultimately selected as the primary production option. 13.03.09 In reference to page F-26, the commentor suggests that if data could not be found in System 80+ NRC docket, data should have been requested from ABB-Combustion Engineering. Response: Information on System 80+ has been requested and the best available information on this reactor has been incorporated into the PEIS. 13.03.10 The commentor states that the process described in section F.1 ignores the fact that two Large ALWRs have received final safety analysis reports and are proceeding through certification. Another commentor believes that System 80+ has a final safety analysis report and NRC-approved values should be used in F8. The commentor states that the System 80+ designer should have been consulted before the PEIS was published. Response: Technical Data Reports have been prepared which take into account the fact that two Large ALWRs have received final safety analysis reports and are proceeding through certification. DOE acknowledges that the Large ALWR reports are complete and this has been factored into the cost, technical feasibility, and schedule analyses. These analyses are included in the Technical Reference Report available in DOE reading rooms. 13.03.11 The commentor believes that the 1 to 2 years to check out the reactor, as mentioned on page 3-36 of the PEIS, isn't necessary for System 80+. Response: The 1 to 2 years for check out is an estimated time included for all the technologies. This check-out period includes the Operational Readiness Review required for all DOE facilities. 13.03.12 The commentor notes that the electrical load (house load) for a Large ALWR is produced by the reactor. A 1,300 MWe produced by the reactor is "net" after this house load is accommodated. Response: The house load for the reactors is required for the reactor to produce tritium, and this is listed for each technology. In all cases, this would need to be supplied to the facility. The nominal 1,300 MWe was not used in such a way that this would be affected. 13.04 Accelerator Production of Tritium Technology 13.04.01 Commentors express support for the APT for a variety of reasons: low generation of waste (compared to other technologies); lack of spent fuel production; no generation of high-level radioactive waste; safer for the environment; uses the least amount of water of the technologies considered; disturbs the least amount of land and, because it does not store energy, has fewer and less severe accidents. Some commentors also cite the fact that it would cost less to operate, can be turned off (unlike a reactor), and requires a relatively short time to construct. One commentor states that it is the best technology in the interest of national security because it is able to produce tritium quickly and continuously. Some commentors also note the low impact to human health from this technology. Another commentor believes that the APT generates the lowest risk of cancer and cancer fatalities. In addition to expressing support, one commentor suggests that the APT be located at INEL. Another commentor expresses support for the APT to be located at NTS because of seismic stability and remote location. Response: All of these advantages of the APT have been noted in the PEIS or the associated studies on cost, technical feasibility, and schedule in the Technical Reference Report available in DOE reading rooms, and will be taken into account by the decision maker in coming to the ROD. The preferred alternative identified in section 3.7 of the PEIS is a dual-track strategy to pursue both the use of an existing commercial light water reactor and the construction of an accelerator to produce tritium. The preferred alternative also identifies SRS as the preferred site if an accelerator is selected as the primary production option. 13.04.02 One commentor states that DOE does not consider the use of fissile material in the APT design as a source of neutrons for the eventual bombardment of target material. If DOE does consider a fissile neutron source, the commentor notes that the electricity requirements would be much less but this option would also produce radioactive wastes. The commentor suggests that by avoiding an investigation of the trade-off between the power needs and the resulting environmental impacts, DOE appears to have assumed a political position in avoiding a uranium, fissionable neutron source. Nevertheless, the commentor feels that DOE should have a more complete assessment including an APT design with a uranium neutron source weighed against potential environmental impacts. Another commentor suggests that the PEIS needs to address the comparative overall environmental impacts of alternative target/blanket materials for the APT. The PEIS should address the comparative levels of waste generation, radioactive and thermal effluent, and greenhouse gas emissions from electrical generating stations supplying power to an APT using targets fabricated respectively from on-fissioning heavy metals (tungsten and lead), fissionable material (depleted uranium), and fissile material (such as uranium-235). For the same level of tritium production, the required beam power drops significantly for fissionable and especially fissile targets. After accounting for other potential power loads that may be required for alternative targets, the total waste generation and environmental loads from the APT and its supporting power station may be significantly less for a fissile target than for a non-fissioning heavy-metal target. Response: The APT design is envisioned as an alternative for producing tritium without the use of fissile material. The PEIS analyzes the range of reasonable alternatives including alternatives that use fissile materials, i.e., reactors and alternatives that do not, i.e., accelerators. An accelerator that would use uranium as a target material would generate radioactive waste (comparable to spent fuel) and exacerbate the potential for severe accidents and subsequent decontamination and decommissioning considerations. DOE decided to evaluate an alternative that would not have these characteristics and, thus, the accelerator is based on the use of non-fissile materials. In any event, the impacts of producing electricity to support a non-fissile material targeted APT are included in the PEIS. 13.04.03 Several commentors feel that the APT should not be considered as an option until more research and development has been done to demonstrate its reliability and safety. One commentor is concerned that the APT will suffer like the supercollider, due to its uncertainties. Another commentor is concerned that national security may be jeopardized if construction of the APT is delayed due to its unreliability. Another commentor feels that the APT should not be considered since it has not been proven to work on a commercial level. One commentor notes that there has never been an accelerator that has run on a continuous basis, that has ever produced the amount of tritium required by the existing stockpile, or has ever used a high energy beam such as that being considered. Another commentor also expresses concern that the proposed APT will need to use high power, while the technology has only been researched at low power. The commentor believes that the target will not be feasible. In another commentor's opinion, the 15-year schedule seems optimistic based on the lack of technical maturity of the concept for this application. One commentor suggests that if the APT is considered, a weighting factor needs to be assigned to it due to the technology being unproven. One commentor referencing section 3-7 states that the decision not to consider non-evaporative cooling towers based on technical uncertainty seems to demonstrate significant technical uncertainties for the APT. Another commentor also points out a statement on page 3-40: "the number and arrangements of building and support areas are illustrative only and can change significantly as design progresses." Such statements, the commentor suggests, emphasize that the design may not be mature enough to be included in the PEIS. Response: Although it is true that the APT as configured to produce tritium has yet to be demonstrated, most of the component technologies required for this complex facility are sufficiently mature to yield sufficient levels of confidence in its ability to generate the required quantities of tritium. Analysis of technical uncertainties of this alternative are presented in the Technical Reference Report available in DOE reading rooms. 13.04.04 The commentor states that discussion of power supply options to support the operation of an APT in section 4.8.2 of the PEIS is unduly limited to an analysis of coal and natural gas plants. The discussion should be expanded to include the options of obtaining the necessary electric power for the initial phase (100 milliamperes) APT and full size (200 milliamperes) APT by investing equivalent sums in conservation and efficiency improvements and/or renewable energy sources for the regional grid that would supply the APT. Response: The PEIS evaluates the impacts of a dedicated power plant to support the APT at each site. Alternatively, the regional power pool could provide the necessary power to support the APT. Therefore the PEIS identifies the percentage of regional capacity margins for each of the alternatives. Section 4.8.2 of the PEIS provides a discussion of the general impacts of a 500 to 600 MWe power plant. 13.04.05 Several commentors give suggestions on the operation of the APT, if it is chosen. According to the commentors, DOE should consider using solar power as a potential power source; should consider using hydroelectric generators to support the capacity margins in the power pool; should locate the power source onsite with the APT to support its electricity requirements; and should operate at night and other off-peak hours to reduce the APT's operating costs. Response: Analysis of dedicated power plants at each of the sites to supply the electrical requirements of the APT have been added to the PEIS. The evaluation of utilizing power from a solar powered demonstration project at NTS has also been added. Any further evaluation of methods to reduce electricity costs will be done in the site-specific tiered NEPA documentation as appropriate. 13.04.06 The commentor asks as of what date the APT will utilize 4 to 13 percent of the regional power pool margin, as described on pages I-10 and I-11. In addition, the commentor asks is there any consideration given to other growth in the region that would reduce (or increase) that margin over the 40-year life of the tritium supply facility. Another commentor suggests that the cost of disposing of plutonium needs to be included in the cost of the APT. Response: All analysis is accomplished as of the No Action date, which in this case is 2010. The estimate of the margin is based on National Electric Reliability Council data which take into account projected regional growth or decline in its projections. Because the decision on plutonium disposition has not yet been made, it would be speculative to attribute any plutonium disposition costs to the APT. 13.04.07 Commentors suggest that the PEIS is biased toward the APT in several places throughout the document. One commentor remarked that the APT is touted to have a shorter construction schedule than a reactor, because it can be built in phases (i.e., the accelerator could operate at a reduced level at first). However, this is questionable given the preconceptual design status of the APT. Furthermore, the environmental impacts during construction are a function of the APT design and, until it is more well defined, impacts cannot be properly assessed. On the other hand, the Large ALWRs are based on a strong experience base and through industry/DOE programs have been designed to even further improve constructability. The ALWR has been treated very conservatively in the Draft PEIS, despite its maturity, while the APT has been treated optimistically, despite its immaturity. One commentor believes that DOE has already decided to support the APT for political reasons and because the Administration is opposed to reactors. Another commentor, referencing page A-102, states that this reference to the paper-study status of the accelerator-based disposition of plutonium seems to apply generally to the APT and reflects authors' bias with statements on the great potential of this option. Response: The technical feasibility of each of the technologies is evaluated and compared in the Technical Reference Report available in DOE reading rooms. The environmental impacts of constructing the Phased APT are the same as the Full APT, since the same construction would take place in the beginning. Only additional equipment would be added to reach the Full APT stage. 13.04.08 The commentor states that APT is more likely to receive public support because the public perceives reactors to have a "bad record" concerning safety/accidents. Response: The purpose of the PEIS is to analyze environmental impacts of the proposed tritium supply technologies. Public support for or against each technology does not bear on environmental impacts. Any of the tritium supply technologies could be constructed and operated safely. 13.04.09 Several commentors raised specific uncertainties about the APT technology that require further environmental impact evaluation, including the effects of evaporative cooling on the environment and whether activation products from spallation will contaminate part of the APT tunnel. One commentor states that if the tunnel is contaminated then the PEIS should include an analysis on the uncertainties with respect to the amount of contamination to the tunnel, whether or not the contamination will interfere with maintenance of the tunnel, or whether tunnel components will need to be decommissioned, and, finally, make it clear if the contaminated tunnel is included in the waste sections of the PEIS. Response: The APT design evaporates water to dissipate waste heat produced by operation of the APT. This process results in water vapor being released into the atmosphere in the immediate vicinity of the APT. The amount of water vapor released into the environment is not large enough to cause climatic change in the surrounding region. Other effects of evaporative cooling on the environment, including use of land and water resources, are addressed in more detail in chapter 4 of the PEIS. The activation products of spallation are retained within the envelope of the target/blanket assembly and will not be released to the accelerator tunnel during normal operation of the APT. The design provides that these materials are removed from the machine in a special hot cell adjacent to the tunnel where provision is made for their safe handling and disposition as radioactive waste. 13.04.10 The commentor notes that the numbers for APT facility construction and operation workers are the lowest for all the technologies. However, the commentor believes that the costs related to these workers may be on the low side. Response: The numbers for the APT facility construction have been adjusted upward and the analysis redone as appropriate. The Technical Reference Report includes cost evaluations and is available in DOE reading rooms. 13.04.11 The commentor states that it is important to understand the maturity of the accelerator technology, and asks how much tritium has been made with this technology. If the amount is little or none, the commentor asks does DOE have backup plans if the APT is chosen. The commentor wants to prevent a situation in 2011 when the United States could have no tritium production capacity if the accelerator cannot generate the material required. Response: The technological risks which take into account the maturity of design are evaluated in the Technical Reference Report available in DOE reading rooms. DOE will provide rationale for its decision in the ROD. The preferred alternative identified in section 3.7 of the PEIS is a dual-track strategy to pursue both the use of an existing commercial light water reactor and the construction of an accelerator to produce tritium. Within a three year period, DOE would select one of the alternatives to serve as the primary source of tritium. The other alternative, if feasible, would be developed as a back-up tritium source. 13.04.12 The commentor states that the Final PEIS accident analysis should include accidents for the APT that the NRC would be likely to impose as part of a licensing review of both the deterministic and probabilistic safety case. For example, the commentor notes it is likely that the NRC would require assuming that the beams would not be stopped when a loss of target cooling occurs given the absence of inherent feedbacks short of target relocation due to melting or vaporization. According to the commentor, this would be analogous to the Anticipated Transient without Scram event imposed by NRC for licensing of commercial reactors, which do have inherent feedback mechanisms to mitigate such transients. Similarly, considering that the proposed APT lacks a strong containment building, the commentor believes the NRC would also likely require assessing the probability and consequences of a steam explosion occurring, if cooling flow can be restored after major melting of the target and blanket occurs, or if the melted target can drop into water such as in the case of passive building flooding described in section F.2.1.4.3, page F-20 of the PEIS. Response: The design of the APT is at a preconceptual level of detail. Appropriately, the safety assessments have been concerned with identifying hazards and quantifying their approximate magnitude. Comprehensive accident analyses, as would be presented in a preliminary safety analysis report, have not been done for the APT. These would normally be done during the design process for the facility. The potential for serious offsite radiological consequences is much smaller for APT than for any of the reactors being considered because of the much smaller inventory of radioactive material in the APT facility compared with the quantity of fission products in the core of any of the reactors, and because an APT generates no significant decay heat like that of reactors. The Final PEIS has added an accident scenario that involves a complete loss of confinement which is expected to bound any accidents with the APT. 13.04.13 The commentor believes that the APT would be able to produce weapon-usable fissile material from source material if the latter were substituted for either helium-3 or lithium in the production targets. Since accelerators are not addressed in either the Atomic Energy Act of 1954, as amended, or the Nuclear Non-Proliferation Act of 1978, the commentor states that existing export controls given in NRC regulations at 10 CFR Part 110 and DOE regulations at 10 CFR Part 810 do not address controls on accelerator equipment that is used worldwide for research, development, and medical diagnosis and treatment. According to the commentor, DOE should describe how key technology developed to deploy the APT, which is much more powerful than existing accelerators, will be controlled to assure no threat of proliferation. Response: The APT design features required to produce these neutrons do not require new technologies. The technologies employed are well known in the international accelerator community. The APT is simply a larger and more powerful version than previous designs. Because of its size and its requirement for large amounts of electrical power for operation, its replication elsewhere could be easily detected. 13.04.14 The commentor states that the APT option would suffer in an assessment of how much technology change would be required to scale-up for tritium production. If the APT were chosen, the commentor states that quick demonstrations of portions of the design would be required and the commentor is not sure how that would be done. The commentor also notes that APT would score high on opening future options for use of spallation sources and on being safe against accidents that would affect offsite populations. In addition, the commentor suggests that lithium could be involved in an efficient design for APT-generated tritium. Response: The technical risks involved in all of the technologies are evaluated in the Technical Reference Report available in DOE reading rooms. In addition, there is an ongoing APT program to resolve remaining technical uncertainties regarding this technology. 13.04.15 The commentor suggests that in volume I, summary, pages S-7 and S-8 a comparison between currently operating accelerator technology and the projections for the APT in terms of amperage, downtime, waste, spent target production, and potential radiological impacts to the public be provided. In addition, the commentor refers to volume I, chapter 3, section 3.6, table 3.6-1 and suggests that other analyses on the efficiencies which compare acreage and power requirements for the APT be provided. Response: The kind of comparison suggested by the commentor is inappropriate for the summary section identified. In addition, the comparison between existing accelerators and the accelerator technology proposed for tritium supply would be very difficult to compare and noninformative. The principal reason is that existing accelerators are of the pulsed power type, of a lower power, and do not irradiate the type of targets evaluated in this PEIS. The design proposed for tritium production is a new continuous power machine that use targets designed specifically for the tritium mission. Typical accelerators are also usually operated for only short periods of time whereas the accelerator proposed in this PEIS would operate for extended periods of time. Any comparison of the type suggested by the commentor would therefore be like comparing one type of apple to a different type of apple (similar but not the same). 13.04.16 The commentor states that the PEIS should include any information gained from the New Production Reactor analysis that has been helpful with the APT alternative. The relationship between the APT technology and the New Production Reactor study should be addressed, if any exists. Response: The APT was previously considered by the New Production Reactor Program but dismissed due to the quantity of tritium required and time required to complete the APT. The APT analyzed in the PEIS has been developed based on preconceptual designs. 13.04.17 Commentors note that in addition to producing tritium, the APT design should be used for other purposes such as civilian/commercial research, transmutation, and short-lived medical isotope production. Possible design factors to enable secondary research uses are to make the APT modular, to leave enough space for expansion of the APT, and closed-loop cooling. Another commentor suggests that tritium be produced for commercial purposes in addition to the prime NTS mission of tritium production for the weapons program. One commentor believes that the PEIS needs to include any advantages of using the APT. Response: The PEIS identifies any environmental benefits and/or drawbacks associated with the technologies evaluated. The advantages (options) of some of the reactor technologies as they relate to other DOE programs as a side benefit to tritium production are discussed in the PEIS. Although there are potential research and development advantages to the accelerator technology, the use of such a machine during the production of tritium for such activities would probably not be feasible or appropriate. The mission of this program is to provide the tritium necessary for the enduring nuclear weapons stockpile. As has occurred in the past, once this requirement is met, there would be no reason that excess capacity could not be used to supply commercial users. 13.04.18 The commentor counsels against the dedicated power plant option for APT technology. At the Pantex site, the commentor is confident, there would be no cost savings from construction and utilization of a dedicated plant. Nor does the commentor think a dedicated plant would be as reliable as Southwestern Public Service grid supplies. Response: The costs associated with building a dedicated power plant to support an APT versus the cost of providing power through the utility servicing the site are some of the factors included in the cost analysis prepared in support of the Tritium Supply and Recycling Program. The environmental impacts from such a facility were therefore included in the PEIS analysis to give the reader and the decision maker an indication of the potential environmental issues resulting from the option. For the PEIS, these impacts were identified at each site. The decision to construct and operate a dedicated power plant would be determined in project-specific tiered NEPA documents. 13.04.19 The commentor refers to the second paragraph of section A.3.2.4 and notes that it states that excess commercial power could not be generated with the accelerator-based plutonium disposition systems based on the molten salt or particle bed target systems. This is correct, but the commentor feels it should also be noted that in August, 1994, General Atomics and Los Alamos presented a joint proposal to DOE requesting support to develop an accelerator-driven modular helium reactor that could achieve destruction of 99 percent of the initially charged plutonium-239 and generate enough electrical energy to drive the accelerator and sell excess capacity to the grid. Response: DOE acknowledges this proposal. 13.04.20 The commentor suggests that volume I, chapter 3 of the PEIS provide complete data on the viability of the project, its life, and the operational requirements associated with APT production of tritium. In addition, the commentor also requests that the following information be provided: an analysis of the amount of spallation-induced by-products be provided along with the used target materials special storage and disposal methods of this mixed waste; a comparison of spent targets to spent fuel in terms of hazards and radiological characteristics; a discussion on the significant annihilation radiation associated with spent targets; the quantity and mass of spent targets that will be produced; an analysis of the cost for repair or replacement of targets that may melt from a continuous and/or uncontrolled proton beam; and information on special maintenance and training dealing with worker health and safety in and around the plant area in the event of a subsystem failure of the APT, as large amounts of low-level waste may be produced. Response: Section 3.4.2.4 provides the data necessary for APT constraints and operation to analyze for environmental impacts. Sections 4.2.3.10, 4.3.3.10, 4.4.2.10, 4.5.3.10, and 4.6.3.10 discuss waste issues. Cost analyses are provided in the Technical Reference Report available in DOE reading rooms. Health and Safety is addressed in normal operations in sections 4.2.3.9, 4.3.3.9, 4.4.3.9, 4.5.3.9, and 4.6.3.9 for the five candidate sites. 13.04.21 In reference to pages A-54, A-63, and A-67, the commentor states that the storage concept for a 3- year transport of spent fuel is not consistent with DOE's Multi-Purpose Canister (5 years). The commentor notes that the spallation that occurs in the APT's beam stop, when it is accepting the full power beam for an unlimited time, could be significant. The spallation and activation products (including mercury 194) have significant half-lives, adds the commentor. The commentor suggests that the high power of the beam could result in orders of magnitude increase in waste products compared to existing accelerators. In the commentor's opinion, NRC should be requested to review the design and determine the classification of the waste. Additionally, the commentor states that the PEIS should quantify all wastes generated in the APT. Response: The comparison table in section 3.6 presents the waste data for each of the various technologies and compares it among sites. The data for the comparison requested by the commentor is available in the table. The data used that describe the fission by-products from reactors and the spallation-induced products from the APT are included in appendix E as tables listing radioactive releases for normal operations for each of the technologies and in appendix F as source terms for various accident scenarios. 13.04.22 Commentators suggest that the PEIS consider the availability of helium-3. According to the commentators, DOE must assume that there will be a loss of helium-3 during the conversion to tritium since it is not 100 percent recoverable or recyclable. The commentors state that DOE must estimate the amount of helium-3 that will be available and the percentage that will be recycled; also, a safety factor for lost helium-3 in the case of a national emergency. One commentor believes that the PEIS does not present very much information as to the source of helium-3 for the target for the APT. The commentor notes that appendix figure A.2.1.4-5 shows helium-3 from weapon recycle and from commercial sources. If the only source of helium-3 is the decay of tritium, there would appear to be only three possible sources of substantial quantities of helium-3: the United States weapons program, the former Soviet Union weapons program, and Canada, according to the commentor. The Canadians are unlikely to provide helium-3 for the United States weapons program. The commentor believes that the only substantial supply is the decay of tritium in weapons. Since each recycle of helium-3 from decayed tritium will inevitably involve the losses of some helium-3, the commentor asks if we can be assured that there is ample supply of helium-3 to support a helium-3 target APT for the necessary lifetime of the production facility. Another concern of the commentor is that the PEIS does not address the neutronics of the reaction that produces tritium from helium-3. The commentor assumes it is of the form: 3He + 1n --> ?? --> 3H + 1H. However, the commentor states that it would seem that there is a nonzero cross section for the reaction: 3He + 1n --> ?? --> 4He. If there is a buildup of helium-4 in the target gas, the commentor notes that it would ultimately poison the reaction and reduce the efficiency of the tritium production. Also, the commentor asks how the helium-4 would be removed from the helium-3. Would this require the periodic disposal of all of the target gas, including the helium-3, which would seem to be in limited supply. Response: Since we have a much larger supply of tritium right now then the eventual steady-state requirement needed in 2011 as shown in figure 2.1-1, the helium-3 resulting from the decay of this excessive amount of tritium is being saved and will provide enough to supply the APT program. In 2011, a tritium supply technology, in addition to tritium recycling, will be online to ensure the required amount of tritium is produced. The neutronics of the reaction that produces H-3 (tritium) from He-3 (helium) is as follows: 3He + 1n -----> 4 He -----> 3H + 1H. The 4He, which is in a highly excited state, exists for only a fraction of a second before transforming into tritium and a proton. Therefore, 4He does not poison the reaction, does not reduce the efficiency of tritium production, and does not have to be removed from the closed-cycle gaseous target loop. 13.04.23 The commentor states that discussion of pulsed versus continuous wave accelerators on pages ES- 21 through ES-22 makes it unclear which is being proposed for APT, and hence leaves an unclear impression of the degree of technology development required to support APT. Response: The discussion referenced by the commentor is referring to the existing research accelerators being of the pulsed, low power design. To be comparable to the type being proposed for tritium production (the APT), these research accelerators would have to be modified to provide a continuous wave operation and be increased substantially in power. None of the research accelerators is of the proposed APT design or operates in the same manner as the proposed APT. 13.04.24 The commentor notes that the fuel requirements for the APT look low on page 3-42 and questions whether this amount is sufficient to test the emergency power supplies. Response: The fuel oil requirements listed are adequate for routine weekly 2-hour testing of the two 800 kW diesel generators. 13.04.25 In reference to page A-63, the commentor believes that more information should be provided regarding why there are different target designs under consideration for APT and why a backup is needed. The commentor notes that it appears as though the level of technical maturity of the APT target design is not adequate to define a reference conceptual system. If a phased approach were not adopted, the commentor asks what would the reference target be. Response: Because of the preconceptual design of the APT, DOE decided to evaluate two different target designs for the Full APT in the PEIS. This was done so that the environmental impacts of the two targets could be evaluated prior to any target down-select. Based on the best available information, the helium-3 target appears to be the better of the two targets, and thus was the target evaluated for the Phased APT. If the APT is selected, a formal target down-select would be made as part of the follow-on, project specific research, development, and testing. 13.04.26 In table A.2.1.4-3, page A-74, the commentor states that it makes no sense that the annual chemical requirements would change so drastically (lithium goes to zero?) just because the APT was constructed in phases instead of being fully constructed initially. The commentor believes that there must be an error. Response: The difference in the chemical requirements between the Full and Phased APT options is due to the fact that they use different target technologies in the analysis. The Full APT uses the spallation-induced lithium conversion target while the Phased APT uses the helium-3 target. 13.04.27 The commentor refers to page 4-443 and suggests that a better explanation be provided of why building a dedicated plant at a DOE site to support operation of an APT operation is considered to be a cost saving. Response: This information is provided in the Technical Reference Report available in DOE reading rooms. 13.04.28 The commentor states that while the PEIS does not consider costs, it implies that the APT design evaluation is based on assumptions that will lead DOE to an unrealistically low cost estimate for the APT - especially compared against more mature technology, for example, the Large ALWRs that have already been priced for overseas sales. Furthermore, the commentor notes that it should be obvious to all concerned that an electricity-producing ALWR will result in lower cost to the Federal Government than an electricity consuming accelerator. Another commentor believes that a cost-benefit ratio needs to be included with the APT. Response: This information is provided in the Technical Reference Report available in DOE reading rooms. The report details how the analysis was performed, assumptions, and other factors that were used to evaluate the different technologies. 13.05 Idaho National Engineering Laboratory 13.05.01 Several commentors feel that INEL is the best site for new weapons programs due to its proven ability to manage wastes safely and its existing workforce, which is capable of handling the tritium project. Tritium production would also boost the economy of southeastern Idaho. One commentor states that INEL should be preferred for siting any reactor types except for HWR; however it does seem unwise to increase the number of weapons-related sites; the small predicted offsite effects at the most populous sites are tiny compared to devastation from a nuclear conflict. Response: The attributes of INEL 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 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. For INEL, waste management activities and facilities and the surrounding local economies are included in the environmental analysis of impacts. Although the quality and experience of the existing site work force and the offsite available work force are factors, they are not considered in the environmental analysis process presented in the PEIS. In the final analysis, many factors will be considered in reaching the decision on tritium supply and recycling. The preferred alternative identified in section 3.7 of the PEIS identifies SRS as the preferred location if an accelerator is selected as the primary production option. 13.05.02 Commentors strongly oppose the existence of nuclear material in Idaho. One commentor states that we do not need any more "atomic nonsense" in the state of Idaho while another commentor expresses opposition to any waste being sent to idaho. Another commentor questions whether INEL can accommodate the waste management and disposal activities associated with the proposed action. Another commentor opposes the tritium supply facility because it endangers Idaho and is a pork barrel project supported by politicians. Response: The PEIS addresses the environmental impacts of the proposed action at INEL. 13.05.03 In reference to page S-19, the commentor suggests that the 64,217 MGY blowdown for a Large ALWR is inconsistent with table 4.6.3.4-1. Response: The commentor is correct, and the appropriate changes have been made to the summary of the Final PEIS. 13.05.04 The commentor believes that INEL should be responsible for researching and developing solutions to waste management problems, not storing nuclear waste. Response: The PEIS addresses the impacts of waste management and waste at INEL in sections 4.2.2.10 and 4.2.3.10. 13.06 Nevada Test Site 13.06.01 Commentors believe DOE should select NTS as the site for the tritium facility for a variety of reasons: skilled labor force, proximity to and relationship with two national laboratories, remote location, existing infrastructure, an air strip to bring in tritium, arid climate, low population density, great depth to groundwater, sufficient water and power resources, security buffer zone, strong safety record, in-place contractors, good proximity to a university for collaborative research opportunities, and reputation as a worldwide leader in testing and research. The commentors also believe that the tritium operations at NTS have wide state/Congressional support, would restore jobs lost since testing stopped, would contribute to the positive growth of the community and economy, and there would be no need to transport wastes to a storage location. Another commentor contends that locating the tritium supply and recycling facility at NTS will retain talented nuclear testing professionals, ensuring continued professional management of the readiness program. One commentor also notes that numerous underground testing and drilling projects at NTS have established its geological and hydrological suitability. In addition, another commentor believes that using NTS as a tritium production facility will preserve important weapons production and testing skills in a cost-effective manner at a location not being retired from the weapons complex. 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 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. For NTS, the remote location, the amount of available buffer land, depth to groundwater, compliance with environmental regulations and agreements, site waste management activities and facilities, and the characteristics of the surrounding local economies and communities are all included in the environmental analysis of impacts. Although the local and political support reasons mentioned are factors, they are not considered in the environmental analysis process presented in the PEIS. The potential impacts of additional jobs, the onsite waste infrastructure, and the transportation infrastructure are also considered in the environmental analysis. The preferred alternative identified in section 3.7 of the PEIS identifies SRS as the preferred location, if an accelerator is selected as the primary production option. 13.06.02 Siting the tritium supply and recycling facility at NTS would create a synergistic relationship between DOE and area educational institutions stimulating University of Nevada at Las Vegas research programs, according to the commentor. Response: DOE agrees that the indirect educational and research benefits to area educational institutions could occur. However, the potential level of involvement and the nature of the relationship cannot be determined at this time. 13.06.03 Commentors suggest that if the APT technology is chosen to be sited at NTS, the research and other alternative use potential of the technology would benefit the NTS community. According to one commentor, a benefit to the community would be the sale of electricity made possible by the reactor technologies; the commentor also suggests that this should be considered an advantage for NTS. Response: Potential uses of the APT for other than tritium production were not considered in the PEIS. However, the design, construction and operation of such a facility for tritium production would significantly advance the science of accelerator technology. The cost benefits of electricity production from the ALWR and the MHTGR reactors are examined in the Technical Reference Report available in DOE reading rooms. 13.06.04 One commentor asserts that none of the tritium supply and recycling alternatives should be sited at NTS based on two major environmental concerns: (1) limited groundwater to support either phased or full accelerator application and (2) seismic constraints for both reactor-based and accelerator technologies. Another commentor states that the PEIS lists no chemicals for NTS in the chemical inventory section of the PEIS, and recommends this be checked. Response: Section 4.3.3.4 of the PEIS discusses the potential groundwater impacts from the tritium supply technologies including that for the APT. Although the groundwater use requirement of the APT is large, it is still below the estimated recharge capacity of the affected aquifer. The potential seismic risks of locating a tritium supply at NTS are discussed in section 4.3.3.5 of the PEIS. Based on the seismic history of the area, a moderate seismic risk exists at NTS but should not preclude safe construction and operation of such a facility. All facilities would be designed to potential earth- quake-generated ground acceleration in accordance with DOE Order 5480.28 and appropriate safety guides. 13.07 Oak Ridge Reservation 13.07.01 Commentors are opposed to siting the tritium facilities at Oak Ridge and one commentor suggests Oak Ridge be removed from the list or placed very low in consideration as a site, due to the abundance at Oak Ridge of existing hazardous materials from dismantlement of nuclear weapons components and storage of highly enriched uranium. This commentor asserts that Oak Ridge has already become polluted with mercury and that safety controls were so poor during World War II that many ORR workers died early deaths. Response: The PEIS evaluates the environmental impacts associated with operating the tritium supply at ORR. The potential impacts from such a new facility would be considered additive to the environmental baseline which takes into account past activities at the site. The preferred alternative identified in section 3.7 of the PEIS identifies SRS as the preferred location, if an accelerator is selected as the primary production option. 13.07.02 The commentor asserts that the PEIS provides no information on the process that led to the selection of the undeveloped portion of West Bear Creek Valley and West Chestnut Ridge as the location of proposed tritium supply/recycling facilities. The commentor believes that cost and environmental impacts could be reduced if the facilities were located in one of the developed portions of ORR where the new facility could be served by existing infrastructure. Response: The site analyzed in the PEIS is appropriate for the programmatic analyses. Section 3.1.1 discusses the planning assumptions and basis of site selection for the tritium supply and recycling location. 13.07.03 In reference to volume I, summary, pages S-7 and S-8, the commentor suggests DOE provide details of the impact on safety and tritium production if the Watts Bar Nuclear Reactor does not come online as anticipated, or if Watts Bar shuts down during accelerator operations. Response: The PEIS evaluates the impact of a dedicated power plant as well as the impacts on the power pool. 13.08 Pantex Plant 13.08.01 Commentors urge DOE to select Pantex as the site for any new functions dealing with the nuclear weapons complex for many reasons: strong local and statewide support; skilled, lower-cost work-force; existing infrastructure/plant; lower utility costs; environmentally sound operation; no significant adverse impacts to natural resources, human health, welfare and the environment; strong safety record; ideal geographical location (equidistant from east and west coasts); easy access to LANL, Sandia National Laboratories, and Amarillo National Resource Center for Plutonium; favorable business community; available land for expansion; suitable year-round climate for construction and operation; ample water supply; no need to transport nuclear materials or wastes; excellent living conditions; and educational excellence. Several commentors qualified their support with an insistence that tritium supply and recycling operations must be handled in a safe and environmentally sound manner. For many of these same reasons, one commentor suggests that Pantex should also participate in DOE fissile materials storage and disposition activities. Another commentor believes that the two reactor technologies, the MHTGR and the ALWR, would provide additional electric power generation capacity for the Pantex area and the APT technology would provide the advantage of tritium production with minimum production of nuclear and hazardous waste. Response: The attributes of Pantex 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 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. For Pantex, the amount of available land and water, compliance with environmental regulations and agreements, site waste management activities and facilities, and the surrounding local economies are all included in the environmental analysis of impacts. Although the local and political support reasons mentioned are factors, they are not considered in the environmental analysis process presented in the PEIS. Cost factors are addressed in the Technical Reference Report available in DOE reading rooms and will be considered in the decision analysis process along with the environmental impact analysis presented in the PEIS. The preferred alternative identified in section 3.7 of the PEIS identifies SRS as the preferred location, if an accelerator is selected as the primary production option. 13.08.02 The commentor requests clarification of the energy consumption at Pantex: page ES-28, table ES- 1, page 1 of 31: does this statement mean after the year 2010. Response: The definition of No Action means from 2010 onward in the absence of any changes as a result of this PEIS. 13.08.03 Commentors state that Pantex should not be selected as the site for tritium supply and recycling because of insufficient water and adverse impacts on agricultural lands surrounding the site. One commentor suggests that the negative effects of the tritium supply and recycling facility on the (Ogallala) aquifer should be fully acknowledged in the PEIS. Also, given that the Pantex Plant is the smallest of all sites under consideration, the commentor believes it is much too close to farmland and adequate security could not be provided because of its size. Response: Comments received during the public hearings on the PEIS indicated that Ogallala water would not be required for the tritium supply technologies if sited at Pantex. More than enough reclaimed advanced treated sanitary wastewater is available from the city of Amarillo's Hollywood Road Wastewater Treatment Plant to meet the need of all tritium supply technologies considered, including the APT. Adverse impacts on agricultural lands are not expected from the proposed project using reclaimed water. The location of Pantex relative to agricultural lands and the city of Amarillo has been considered in the analysis of impacts presented in the PEIS. Security at Pantex is more than adequate to protect any new missions the site may receive. 13.08.04 In the hopes that Pantex is selected for tritium supply and recycling, the commentors suggest that DOE in the Final PEIS include a thorough evaluation of the use of treated wastewater to meet cooling requirements for a tritium production accelerator, and that the environmental impacts assessed include impacts where the water is currently being discharged. Response: The PEIS now includes an evaluation of the use of treated wastewater to meet cooling requirements for all of the tritium supply options. 13.09 Savannah River Site 13.09.01 Commentors urge DOE to site the tritium supply and recycling facility at SRS for many reasons: existing infrastructure; technology and work force base; existing tritium recycling facilities (including the new Replacement Tritium Facility); extensive local public, business community, and political support; 40 years of safe tritium operations experience; adequate secured land; strong safety record; many trained laborers; readily available water; weather conditions which permit year-round work; the fact that SRS has consistently met local, state, and Federal environmental regulations and related Federal requirements; would cause fewer environmental impacts; would benefit the economy; and would be the most cost-effective option. According to one commentor, SRS also processes and stores all waste produced on the site and is developing the most comprehensive capa- bility in the Complex to handle all types of radioactive waste, including burial vaults, consolidated incinerator, and the Defense Waste Processing Facility. The Aiken Commerce Board supports a decision to place the tritium supply and recycling facility at SRS. Another commentor supports the Tritium Supply and Recycling Program at SRS but recommends that DOE get some new management oversight to replace Westinghouse. The commentor's specific recommendation is to look at somebody with credentials of DuPont. Another commentor asserts that collocation of the Nation's new tritium supply source at the SRS could be the determining factor in locating the International Thermal Experimental Reactor in the United States. A sufficient power supply and new tritium handling capabilities would make the SRS site much more attractive than the French or German sites, according to the commentor. According to another commentor, it took 10 years for SRS to establish a training program that worked well. Therefore, it would be too costly to develop a training program when one is already in place at SRS. Response: The preferred alternative identified in section 3.7 of the PEIS identifies SRS as the preferred location, if an accelerator is selected as the primary production option. The attributes of SRS, 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 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. For SRS, the Replacement Tritium Facility, the amount of available land and water, compliance with environmental regulations and agreements, site waste management activities and facilities, and the surrounding local economies are all included in the environmental analysis of impacts. Although the local and political support reasons mentioned are factors, they are not considered in the environmental analysis process presented in the PEIS. Cost factors are included in the Technical Reference Report available in DOE reading rooms, and will be considered in the decision analysis process along with the environmental impact analysis presented in the PEIS. 13.09.02 The commentor suggests that data on aborted attempts to sell a New Production Reactor for tritium at SRS should be set forth and quantified in the PEIS. Response: As stated in section 1.4.2, the New Production Reactor Program was folded into the then Reconfiguration Program in November 1991 since the urgency to develop a new tritium supply source was eased due to stockpile reductions. This was reported and explained in a Federal Register Notice on November 29, 1991 (56 FR 60985). 13.09.03 The commentor suggests that the PEIS include an analysis of the relative environmental effects if the tritium mission at SRS is terminated. Response: The PEIS describes the environmental impacts of phasing out the tritium recycling mission at SRS in section 4.6.3. Under each resource and issue topic within the section a discussion of these impacts is found under the italic heading "Tritium Recycling Phaseout." 13.09.04 Commentors believe that South Carolina does not need another tritium facility. According to one commentor, South Carolina already has more than its share of toxic waste in the groundwater and should clean up sites instead. The commentor urges the United States to set an example for other countries. Another commentor states that nuclear weapons production at SRS has severely impacted the land and water around Aiken, South Carolina. Response: Remediation of contamination due to past operation of DOE facilities is an ongoing program under the direction of the DOE Office of Environmental Management. The characterization activities of potential contamination areas or any planned or ongoing remediation activities would be considered in the siting of any tritium supply technology at any site. Lessons learned from past DOE production reactors and the incorporation of the latest designs in proposed tritium supply technologies are being used to ensure the protection of the environment and minimize the generation of additional waste. 13.09.05 The commentor states that the Defense Waste Processor is not included under SRS in the table in the executive summary. Response: Although not explicitly stated in the executive summary, the Defense Waste Processing Facility is assumed to be operating under No Action at SRS. The possible use of that facility would be considered in a site-specific tiered NEPA document. The preconceptual designs of the tritium supply and recycling facilities include their own waste management infrastructure with the exception of the upgraded recycling facility at SRS. 13.09.06 Commentors express the opinion that the cooling tower at SRS be evaluated in the decision process. One commentor asserts that availability of the newly constructed cooling tower at SRS will yield significant cost savings. According to the commentor, the proposed location of the tritium supply facility (near the N Area) would take advantage of existing 10 miles of cooling water discharge pipe leading from K-Reactor to the Savannah River. Only 4 miles of new piping would be required, according the commentor. Response: If SRS is chosen as the site for tritium supply, a site-specific tiered NEPA document would be completed prior to construction. If the preferred alternative identified a reactor technology, an evaluation of the possible use of the K-Reactor cooling tower would be appropriate. If the APT is selected consistent with the preferred alternative, the K-Reactor cooling tower would probably not be used. 13.09.07 Commentors assert that the PEIS features an invalidated major assumption by assuming that the existing tritium facility will be able to handle a new tritium supply when it is at least 17 years old. One commentor suggests that it may need major upgrades by then, so the PEIS must calculate how much the facility costs, its worth today, and the cost to upgrade it by 2010. Response: Section 3.4.3.2 discusses the upgrades of the existing Replacement Tritium Facility. Cost and technical analysis reports are included in the Technical Reference Report available in DOE reading rooms. 14 Relationship to other DOE Programs/Activities 14.01 Commentors suggest that DOE should delay the decision on a tritium production facility for several reasons - to allow other EISs to reach the same stage so that decisions made reflect an integrated approach to all EISs pertaining to the Complex; to see how the PEIS for Tritium Supply and Recycling relates to other PEISs relative to costs and viability; and to consider the cumulative impacts on the entire Complex. According to one commentor, DOE should do a thorough evaluation of the impact of the multipurpose reactor versus the separate tritium supply facility and the plutonium facility (one facility versus two) and should also consider other options such as a fusion facility. Some commentors express opposition to the combining of tritium production with plutonium disposition activities. These commentors believe that DOE should address the disposition of plutonium before deciding to produce tritium; this decision may eliminate the need for tritium. Response: DOE does not expect that the ROD on tritium production would restrict or prejudice decisions of any plutonium options. In fact, DOE's preferred alternative would allow for subsequent integration with future plutonium disposition decisions if desired. Due to the rapid decay of tritium, and the long lead time required to bring a new source on line, even new supplies from retired weapons are not sufficient to postpone the need for a tritium supply facility to the point where decisions concerning technology and site selection can be deferred to coincide with other DOE decisions. Accordingly, the PEIS for Tritium Supply and Recycling is a separate action. This is not to say that it is being analyzed in the absence of input concerning other, related DOE activities. The analysis is closely coordinated with the analyses being performed for the Waste Management PEIS, the Stockpile Stewardship and Management PEIS, the Fissile Materials Disposition PEIS, as well as the Site-Wide EISs being conducted by those DOE facilities which have a Defense Program Mission. To the extent that programmatic changes are made in one of the programs which affect the others, the appropriate changes in the PEIS for Tritium Supply and Recycling analyses have been made. DOE has also analyzed a multipurpose reactor in the PEIS for Tritium Supply and Recycling. This reactor would utilize either a uranium fuel or a fuel blend of plutonium and uranium (mixed-oxide fuel) to generate tritium while at the same time irradiating surplus quantities of plutonium to the point where it could no longer be utilized in nuclear weapons. DOE is not considering a fusion reactor as an alternative, since this technology is not yet developed to the point of providing the necessary degree of confidence for producing a product so integral to the Nation's defense. 14.02 Several commentors express their dissatisfaction with siting the proposed tritium facility at some of the candidate sites because prior activities have left areas of contamination at these sites. Commentors state that DOE should not put a new facility at a site that needs environmental cleanup. One commentor states that NTS already has a mission as a waste site, and considering the site for another operation is deplorable. Another commentor opposes siting another hazardous project in Idaho because in his opinion Idaho has been a home for nuclear waste for too long (United States Naval nuclear waste in particular). In addition, the commentor fears aquifer contamination. Another commentor opposes locating the tritium facility at SRS because of the need to clean up existing radioactive wastes at the site. Another commentor believes that plutonium storage issues should be resolved and existing contamination cleaned up at Pantex before the tritium production decision is made at Pantex. Response: All of DOE's facilities require some level of environmental cleanup. Similar to other industries, DOE facilities were designed in the 1940s and 1950s, prior to environmental regulatory requirements when the understanding of waste management principles was not what it is today. Over the past several years, DOE has had a very aggressive cleanup program and has worked with the Environmental Protection Agency (EPA), states, stakeholders, and the general public to develop long-range programs and commitments to clean up its facilities to acceptable levels. All of these plans and commitments have been reviewed for the proposed sites to determine if there are any conflicts or restrictions which would inhibit these sites from serving as good locations for the facilities proposed in the PEIS for Tritium Supply and Recycling. Nothing was found which would inhibit the alternative sites from performing the required mission. Once a specific site is selected, additional site-specific tiered NEPA documents will be prepared. This analysis will address specific contamination problems of the specific proposed DOE facility and, to the extent mitigative measures are required to allow for ongoing environmental restoration or to prevent additional contamination, it will be an integral part of this site-specific analysis. The preferred alternative identified in section 3.7 of the PEIS identifies SRS as the preferred location, if an accelerator is selected as the primary production option. 14.03 Commentors state that, because of its efficiency, cost-effectiveness, and existing capital plant, Pantex should be an active participant in fissile material storage and disposition activities. Response: The storage and disposition of fissile materials are being addressed in a separate PEIS being prepared by the DOE Office of Fissile Materials Disposition. Pantex is one of the sites being considered for materials storage. 14.04 Commentors are concerned about the storage of nuclear weapons and fissionable material as described in the Stockpile Stewardship and Management PEIS. DOE should keep waste where it is until a national policy can be developed. Response: Storage of nuclear weapons and fissionable materials is beyond the scope of the PEIS for Tritium Supply and Recycling. Storage and disposition of nuclear weapons fissionable materials are being addressed in the Storage and Disposition of Weapons-Usable Fissile Materials PEIS being prepared by the DOE Office of Fissile Materials Disposition. The Waste Management Draft PEIS being prepared by the DOE Office of Environmental Management has recently been completed. These two PEISs address the issue of storing nuclear weapons fissionable material and wastes. 14.05 The commentor states that DOE should consider NTS for consolidation and future DOE/defense program activities. Response: NTS is included in the Stockpile Stewardship and Management PEIS now being prepared by the DOE Office of Reconfiguration. The Stockpile Stewardship and Management Program is evaluating the alternatives for consolidation and future operation of the Complex. 14.06 The commentor notes that it is stated in volume I, page 1-7 that the New Production Reactor Program was "canceled." The commentor states that the program was, according to the announcement signed by Secretary Watkins, "deferred." Response: The commentor is correct and the appropriate changes have been made to the document. 14.07 In reference to page S-2, the commentor questions whether the receiver sites for the Mound mission are still accurate. Response: The mission reassignments identified and analyzed in the Nonnuclear Consolidation Environmental Assessment (June 1993) have not changed and are in the process of being implemented. 14.08 The commentor suggests that DOE should consider consequences of selling electricity, i.e., competition with public market. Response: The sale of any energy produced incident to the operations of a DOE tritium production facility would be governed by Section 44 of the Atomic Energy Act. That section expressly provides that "if energy is produced at production facilities of the Commission, such energy may be... sold to publicly, cooperatively, or privately owned utilities at reasonable and nondiscriminatory prices. If the energy produced is electric energy, the price shall be subject to regulation by the appropriate agency having jurisdiction. In contracting for the disposal of such energy, the Commission shall give preference and priority to public bodies and cooperatives or to privately owned utilities providing electric utility services to high cost areas not being served by public bodies or cooperatives." Thus, by the very terms of the Atomic Energy Act, DOE would not be competing with existing electric energy producers, but rather would be augmenting their production by selling to them. This energy could reduce the burden of ratepayers. The electric utility industry is structured and regulated such that DOE would never be in such a position as to compete with electric utilities in the sale of electricity. The generation and sale of electricity is being analyzed for those alternatives in which electric generation could offset the other programmatic costs. In such a situation, DOE would tie into a regional power grid and be compensated for its input, which would be marketed by the electric utilities managing this grid at rates to be determined by state utility commissions and the Federal Energy Regulatory Commission. For such alternatives, DOE is looking at the environmental impacts associated with the generation of electrical power, pursuant to the requirements of NEPA. 14.09 Commentors express support for the recent establishment of the Amarillo National Resource Center at Pantex and the formation of the Higher Education Consortium by the Texas A&M University System, Texas Tech University, and the University of Texas System to manage the Amarillo National Resource Center. The commentors believe DOE should fund and utilize the Amarillo National Resource Center at Pantex to research critical issues of stewardship of nuclear weapons and their by-products. Response: There is no relationship between the tritium supply and the National Resource Center at Pantex. 15 Public Involvement/Community Relations 15.01 Several commentors commended DOE for holding useful and effective public hearings. One commentor states that the meetings make a complex subject easy to understand and ensure consideration of public concerns and views. Although most comments on the format were positive, some commentors offered the following suggestions: have "formal" (traditional format) comment sessions in addition to the new format; present conceptual estimates of costs of alternatives; hold evening sessions at a later time (7:00 p.m.); have a troubleshooting system for the phone system; and, hold meetings in all sites under Tritium Supply and Recycling Program consideration. Response: DOE elected to use the interactive meeting format in response to past public comments. The commentor's suggestions will be taken into consideration in the preparation and planning of future public meetings. Meetings were held at every site considered in the PEIS. 15.02 The commentor states that the PEIS does not adequately address key policy issues. Therefore, states the commentor, it is impossible to conduct meaningful public review and discussions of the alternatives presented. The commentor states that DOE should respond to the commentor's and others' concerns in a revised PEIS which is then circulated for public comment. Response: The PEIS was prepared to study the potential environmental impacts of a proposed major Federal action. National policy issues are factors that will be considered in the decision making process but will not be addressed in the PEIS. The mechanism for public input to the Nation's policies is through contact with Federal, state, and local elected representatives. 15.03 Commentors suggest DOE publicize public meetings early and in many different mediums (including Internet, CD-ROM, database) and consider having the PEIS in computer format. One commentor adds that DOE should expand its contact with all aspects of the community including Native American interests, schools, and churches and give the public more time to be involved. Another commentor states that impact and oversight money should be provided for public outreach. Scientists and technical experts should be placed in direct contact with the citizens, perhaps in a round-table approach, according to the commentor. Another commentor states that the public should be given full disclosure regarding the facility including uncertainties involved in the analyses (lack of experience for APT and MHTGR, future need for tritium, sale of electricity from reactor). Focus should be on the national and public interest in the proposed action rather than DOE's interest, according to the commentor. Response: DOE has utilized several different methods for publicizing public meetings and providing program information to the public. In addition to advertising in the traditional media, notices and meeting information have been made available electronically. Various documents can be requested or accessed using the toll-free information line, the electronic bulletin board, and the World Wide Web DOE Home Page. It is also possible to access and download the PEIS from a bulletin board service. There has been and will continue to be full disclosure of all relevant technical information concurrent with the publication of the final PEIS. Cost, technical and feasibility analyses for each technology are included in the Technical Reference Report, available in DOE reading rooms. Technical experts were present in each of the discussion groups during the public hearings to answer questions and provide additional information to the public. A speaker's bureau has been established with DOE officials available on a limited basis as requested to speak with interested groups concerning program activities and issues. This can be requested through the toll-free line or the electronic bulletin board services. In addition, once the announcement is made to hold public meetings, contact is made with local and Native American officials offering separate briefings prior to the public hearing in that area. Some meetings were requested and held prior to the PEIS public hearings. 15.04 Commentors state that political influence should not be a factor in the tritium supply and recycling decision. Response: DOE has analyzed environmental, cost, technical and schedule issues associated with the proposed action. The effects of political influence are beyond the scope of the PEIS. 15.05 One commentor suggests that DOE should declassify the number of kilograms in the overall tritium inventory, as well as current and projected active and reserve nuclear weapons stockpile requirements. The commentor believes that this would allow the public to draw their own conclusions regarding the reasonableness and urgency of future tritium supply and recycling alternatives. Another commentor suggests that chapter 2 of the PEIS be expanded because the public has the right to know how much tritium is needed at the taxpayer's expense. Response: There has been an effort in recent months and years by DOE to provide the public with as much information as is reasonably possible. However, there are still some details and issues which are matters of national security, and, as such, must remain classified. The exact amount of tritium in the inventory is one of these. 15.06 The commentor expressed the desire to know when people from other areas that are in close proximity to nuclear sites will be compensated like those covered under the 1990 Act. Response: This issue is beyond the scope of the PEIS. 15.07 Commentors ask how DOE will assure the public that their input has been included in the decision process. The commentors believe that DOE should allow the public to comment on the various decision making factors and the ROD. Response: Comments received during the public comment period are addressed and considered in preparation of the Final PEIS. Section 1.7.4 of the Final PEIS identifies specific changes made in response to public comments. The Comment Response Document available with the Final PEIS includes copies of all comment documents, summaries of all comments received, and the response by DOE to these comments. Cost and other analyses are included in the Technical Reference Report available in DOE reading rooms. The ROD will explain the factors used in DOE's decision making process and will be a publicly available document. 15.08 Commentors state that DOE should allow concerned citizens to speak at public hearings and not have biased entities controlling the sessions. A verbatim record of the hearing should be kept, according to the commentors. Response: The interactive hearing format was used to provide an opportunity for the public to have questions answered in order to allow more informed input. All participants were given an opportunity to ask questions or comment on the PEIS during sessions which were moderated by neutral facilitators. While verbatim transcripts were not made for the hearings, detailed comment summaries were prepared for consideration in this document. Several other methods (mail, fax, electronic bulletin board, toll-free information line) were available for the submission of written or verbal comments if commentors did not feel confident that their comments would be recorded correctly at the public meetings. DOE will consider these comments in planning future hearings. All comments, regardless of how received, are considered equally when preparing the Final PEIS. 15.09 Commentors state that DOE should select the preferred alternative before asking for public comment. Response: Council on Environmental Quality (CEQ) regulations require an agency to identify a preferred alternative in the draft only when one or more exists (40 CFR 1502.14(e)). At the time that the Draft PEIS was published, no preferred alternative existed. Studies have now been completed and the preferred alternative is now identified in section 3.7 of the Final PEIS. Members of the public may submit comments on the Final PEIS, including the preferred alternative. A decision on tritium supply and recycling will not be made until at least 30 days after issuance of the Final PEIS. 15.10 The commentor states that DOE should stick to its Tritium Supply and Recycling Program decision to be stated in the ROD and not deviate as it has done in the past. Changing the decision wastes money, according to the commentor. Response: Any actions taken will be in compliance with the requirements of NEPA. Should DOE determine or need to modify its decision as stated in the ROD, it will either issue a new ROD or modify the PEIS. 16 NEPA Process 16.01 The commentor states that under the requirements of NEPA, DOE, in the PEIS, should: discuss the accountability and responsibility for data gathering; include life cycle cost conducted on alternatives and cost analysis of waste disposal; evaluate the alternatives; explain operating scenarios for the sites; explain differences between tritium and other nuclear-type materials such as plutonium; indicate the number of weapons that will constitute START II Protocol levels and the number that constitutes a genuine deterrent; and include an unclassified version of the Nuclear Weapons Stockpile Memorandum and Plan. Response: The PEIS provides a full and fair evaluation of the environmental impacts of the reasonable alternatives. Data to support the analysis has been gathered from most recent environmental monitoring reports and from engineering analyses of the proposed alternatives. The estimated number of weapons (for START II stockpile levels) has been added to chapter 2. This chapter is the unclassified version of the Nuclear Weapons Stockpile Plan and Memorandum. The cost analysis is provided in the Technical Reference Report available in DOE reading rooms. 16.02 One commentor suggests that further stockpile reductions would allow DOE to use the tritium from the retired weapons, thereby eliminating the need for a brand new facility. The commentor believes that this alternative of further stockpile reduction should be considered by DOE and analyzed in the PEIS in accordance with the NEPA process. Response: Chapter 2 provides the rationale for stockpile size. DOE has to support the Nuclear Weapons Stockpile Plan under the Atomic Energy Act of 1954. These levels are established to provide an effective nuclear deterrent. DOE cannot unilaterally change the stockpile size. The PEIS also includes an analysis of providing tritium at an earlier date should that become necessary. For a stockpile size smaller than START II, the need for new tritium could be extended beyond approximately 2011. If the need date for new tritium were significantly later than 2011, DOE would not have a proposal for a new tritium supply, and would not be preparing a PEIS for Tritium Supply and Recycling. 16.03 One commentor is of the opinion that DOE should accelerate the process of technology and site selection to avoid loss of talent of the current workforce. Another commentor contends that more time is needed for the public to review the scientific analysis and decision making process for a project that will span 50 years. In fact, the commentor suggests that the government and DOE should use a scientific timeframe, instead of a political one, in the NEPA process. Another commentor advocates more continuous involvement between DOE and contractors in preparing EISs. Response: Technology and siting decisions will be identified in the ROD at least 30 days after the Final PEIS is published. In order to compare the potential environmental impacts of each technology, start dates in the PEIS were established around a peak construction date of 2005. The construction of a tritium supply facility would not occur before the appropriate site-specific tiered NEPA documents were completed, and detailed engineering designs of the facility completed. 16.04 The commentor notes that NEPA imposes a requirement for "sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public" through the analysis of alternatives in an EIS (40 CFR 1502.14). The commentor states that not only does the Draft PEIS fail to identify a preferred alternative, it fails even to present a consistent set of criteria by which the preferred alternative could be selected in the future. The summary comparison tables located in the executive summary (page ES-1), in section 3.6 of the Draft PEIS, and appendix I, do not clearly reveal which alternative at which site entails the least overall environmental impact and public health risk for a given level of investment. The commentor feels that evaluating the environmental risks of various proposed alternative technology/site combinations relative to their financial costs is impossible because no cost data is presented. According to the commentor, the Draft PEIS fails to present a comparative, qualitative discussion of the environmental impacts of the various alternatives in a manner that would allow the concerned citizen to gain an understanding of which option poses the least overall environmental burdens and risks. The commentor feels this is a clear defect in the current draft that must be remedied in the Final PEIS. According to the commentor, this strongly implies that the selection of a preferred alternative will be made on the basis of information not available to the public in the Draft PEIS, an action that would be in plain violation of NEPA. In this case, the PEIS must be reissued as a draft incorporating such information, including comprehensive cost, technical risk, and schedule risk data. The commentor claims politics, especially pressure from South Carolina and Georgia supporting SRS, should not have an influence on the preferred alternative and the ROD. Response: In addition to the summary comparison table, table 3.6-1, and appendix I, the summary and executive summary of the PEIS have been revised to include a concise, reader-friendly presentation of the alternatives. Section 3.7 of the PEIS defines the preferred alternative as the alternative that the DOE believes would fulfill its statutory mission, giving consideration to environmental, economic, technical, and other factors. CEQ regulations require an agency to identify a preferred alternative in the draft only when one or more exists (40 CFR 1502.14(e)). At the time that the Draft PEIS was published, no preferred alternative existed. Studies have now been completed and the preferred alternative is now identified in section 3.7 of the Final PEIS. The summary comparison of the environmental impacts of the tritium supply and recycling and the various options presented in table 3.6-1 and in appendix I do not present the relationship between costs and the protection of the environment as correctly noted by the commentor. The cost analyses for the various tritium supply technologies and recycling facilities are included in the Technical Reference Report prepared to support the program and decisions identified in the ROD prepared after this PEIS. The Technical Reference Report is available in DOE reading rooms. 16.05 One commentor suggests that the PEIS does not, but should, address the environmental impact resulting from resource requirements and waste for each alternative. Another commentor states that DOE should hold each site to equitable standards in the analysis of environmental compliance while cost factors should be weighted less as far as a decision making factor. Response: Sections 4.2.3, 4.3.3, 4.4.3, 4.5.3, and 4.6.3 of the PEIS discuss the resource requirements and impacts of construction and operation of each alternative at the five candidate sites. In the comparison of the alternative sites, DOE made every effort to hold each site to consistent and equitable environmental standards. The analysis for the PEIS was conducted in accordance with CEQ regulations (40 CFR 1500-1508), and DOE's NEPA Procedures. Furthermore, in the design of the various technology facilities, full compliance with all applicable Federal, state and local environmental requirements was considered. DOE has made every effort to utilize the NEPA process early on in the planning stages of the tritium supply program and, to the maximum extent practicable, has taken extra steps to include public participation in this decision making process. The weighting of cost factors is not a PEIS issue but will be explained in the ROD. 16.06 Commentors believe DOE should list the factors, including the weighting factors affecting technology and siting decisions. In fact, one commentor suggests DOE provide a clear description of the weighting factors which will be used in decision making before the public hearings. The commentor also states that it would be helpful to know how much weight the public hearings have in the decision making process. Response: The rationale for making tritium supply and recycling decisions will be identified in the ROD. DOE's decision making process will weigh factors such as cost, technological feasibility, environmental issues, and policy considerations. 16.07 A commentor notes that the Draft PEIS should have included an economic evaluation for the technologies. For example, costs associated with maintenance, operation, and implementation of the technologies should be evaluated and distributed to the public. Without cost estimates, the commentor believes it is not possible to weigh the relevance of any differences between the technologies. The commentor further states that the lack of budget information makes it difficult to provide informed comments and decisions on any of the tritium supply and recycling technologies and sites. In the commentor's opinion, the most cost efficient production source of acceptable reliability should be chosen with all cost factors considered. Another commentor states that the cost analysis and production assurance documents seem to be more important decision making factors than the PEIS. In addition, a commentor suggests that economic evaluations should also consider combining plutonium disposition and tritium production and the impact of privatizing the facilities on costs to the government. Response: Cost and technical feasibility studies are not part of an environmental impact statement but are included as a part of the Technical Reference Report available in DOE reading rooms. The analysis for the PEIS is being conducted in accordance with the CEQ Regulations (40 CFR 1500- 1508), and DOE's NEPA Procedures. 16.08 Several commentors believe that a cost-benefit analysis should be developed to support a programmatic decision concerning which technology to employ for tritium production. Response: DOE has developed cost, technical, feasibility, and schedule analyses which are included in the Technical Reference Report available in DOE reading rooms. These factors will be weighed in the decision making process along with environmental considerations. 16.09 The commentor believes that DOE should look at cost studies determining transportation of LLW by rail. There may be money to be saved by using the railroad, according to the commentor. Response: Impacts of transporting LLW to NTS from Pantex are analyzed in the PEIS. Highway transportation is the only available method to ship LLW from Pantex to NTS. 16.10 The commentor believes that DOE should consider the advantages of using existing DOE sites' infrastructure in the cost analysis for tritium production and recycling. Response: Section 3.3 of the PEIS lists the assumptions that were used in selecting reference sites. Site-specific analysis would consider the existing site infrastructure and any differences in cost. In determining the preferred alternative identified in section 3.7 of the PEIS, site infrastructure issues were among the many issues considered. SRS is the preferred location if an accelerator is selected as the primary production option. 16.11 The commentor states that representatives in Congress need to have more input into the Secretary's decision on the PEIS for tritium supply and recycling. Response: DOE participates regularly in Congressional hearings on defense issues in which the tritium issue is discussed. Congress determines how funds are allotted and DOE spends monies consistent with Congressional direction. Therefore, Congress ultimately determines whether the preferred alternative will be implemented. 16.12 Commentors state that the public should have access and input to the cost analyses and the weight given to the various costs in the final decision. The commentors feel the public should have an opportunity to comment on the cost analyses and the other associated studies. In fact, some commentors express concern that materials such as cost analyses and associated studies be released to the public early enough for review and comment before the ROD is issued. If materials cannot be released until after the Final PEIS is published, one commentor suggests that the comment period before the ROD be extended. In particular, the commentors believe that the public should be fully informed about the cradle to grave costs (including long-term waste costs, and D&D) of the facility. One commentor notes that a D&D comparison (including financial costs) between technologies should be included in the environmental effects section of the Final PEIS. Additionally, commentors suggest that the cost analysis should include decommissioning and revenues associated with any of the technologies, and any cost overruns with the APT. The commentors state the public needs to be convinced that developmental status of the accelerator option is properly reflected in cost and schedule sensitivity analyses. Response: CEQ regulations require an agency to identify a preferred alternative in the draft only when one or more exists (40 CFR 1502.14(e)). At the time that the Draft PEIS was published, no preferred alternative existed. Studies have now been completed and the preferred alternative is now identified in section 3.7 of the Final PEIS. Members of the public may submit comments on the Final PEIS, including the preferred alternative. A decision on tritium supply and recycling will not be made until at least 30 days after issuance of the Final PEIS. The specific environmental impacts of D&D cannot be determined at this time because of the preconceptual designs of proposed facilities. However, a relative comparison of the D&D activities and potential impacts between the tritium supply technologies is presented in section 4.15 of the PEIS. The costs associated with D&D are detailed in the supporting cost analyses included in the Technical Reference Report available in DOE reading rooms. The ROD will describe the basis for DOE's decision. 16.13 The commentor expresses interest in the cost benefits of the previously developed New Production Reactor Program in relation to this program. Response: The records for New Production Reactor Program have been archived and can be accessed through the National Archives. 16.14 Referring to volume I, chapter 3, section 3.6, commentors suggest providing an analysis of the cost associated with each of the alternatives to include direct cost of construction, project maintenance costs, research and development costs, and other indirect costs. The commentors state that the Tritium Supply and Recycling Program will compete with other Defense Program projects, such as the National Ignition Facility, with the programmatic responsibilities of Defense Programs, and with environmental cleanup. The commentors feel a fair analysis of the projects' impacts should include the billions of dollars of cleanup that will not occur, or will be deferred due to the Tritium Supply and Recycling Program. The commentor believes the absence of cost figures from the PEIS is a calculated attempt to avoid political attack. Since tritium decays, early production carries a financial penalty of roughly $200 to $400 million per year if interest costs on construction are added to operating costs. For example, the commentor states that Los Alamos National Laboratories (LANL) recently disposed of 106 curies of tritium because recovery was not deemed important. Finally, the commentors suggest that DOE should have a full budget analysis of how much this facility will cost in out years (into the next century). Response: Cost and technical feasibility studies are not part of an environmental impact statement but are included as a part of the Technical Reference Report available in the DOE reading rooms. The analysis for the PEIS is being conducted in accordance with the CEQ regulations (40 CFR 1500-1508), and DOE's NEPA procedures. 16.15 The commentor expresses the opinion that the NEPA process being used by DOE for the Tritium Supply and Recycling Program is flawed because it didn't address the combined impacts of different activities described in the PEIS. In the commentor's opinion, the approach to conduct individual assessments could run the serious risk of making the process appear to be "result-oriented." Response: The approach presented in the PEIS does describe the effects of individual facilities (tritium supply alone), but also provides the effects of the possible combinations of these facilities (e.g., tritium supply and recycling). The analysis also presents different operation scenarios to meeting tritium requirements (less than baseline operation). The methodology and presentation allow the public and the decision maker to review and consider all aspects of the project in the course of decision making. Section 4.9 has been expanded to include potential cumulative environ- mental impacts from other programs. 16.16 The commentor states that the current draft does not meet the requirements of NEPA and its implementing regulations. The CEQ regulations for implementing NEPA call the discussion of alternatives "the heart of the environmental impact statement" (40 CFR 1502.14). An EIS must discuss a reasonable range of alternatives, and an EIS that fails to do so violates NEPA (refer to Natural Resources Defense Council v. Morton, 458 F.2d 827 (D.C. Cir. 1972)). Because the PEIS analysis is not based on a reasonable range of estimates for the size of the post START II nuclear weapons stockpile for the period of 2003 to 2050 - when the period a tritium supply option would actually be constructed and operated - this PEIS fails to analyze a reasonable range of tritium supply alternatives and thereby violates NEPA. The uneven treatment and inadequate discussion of some of the alternatives considered in the analysis also violate NEPA. Response: As stated in chapter 2 of the PEIS, the tritium requirements in this document are based on the 1994 Nuclear Weapons Stockpile Plan approved by the President on March 7, 1994, which projects a need for new tritium by approximately 2011 based on a START II level stockpile size of approximately 3,500 accountable weapons. For a stockpile size smaller than START II, the need for new tritium could be extended beyond approximately 2011. If the need date for new tritium were significantly later than 2011, DOE would not have a proposal for a new tritium supply, and would not be preparing a PEIS for Tritium Supply and Recycling. Section 4.11 of the PEIS now includes an analysis of an increased stockpile level and a tritium need date of 2005. The PEIS analyzes the reasonable range of alternatives to meet the National security requirements for tritium. 16.17 The commentor feels the decision making process is not truly a public involvement process. In the commentor's opinion the public does not vote and therefore the public does not have an opportunity to decide how tax dollars are spent. Response: DOE is required by NEPA to allow several opportunities for the public to provide input on the proposed action and associated environmental impacts. In addition to public scoping meetings and public hearings held at specifically determined points in the review and development process, several other methods for public input are available. The public can request and review information by mail, electronically through the electronic bulletin board and Internet sites established by DOE, and by calling the toll-free information line. Members of the public are also encouraged to contact their elected officials concerning the decision making process as well as the spending and budget process. 16.18 The commentor notes that there is no mention of site-specific EISs on environmental restoration and waste management or other proposed projects (except those specifically related to weapons material), which would be relevant in assessing cumulative impacts and in choosing a site. The commentor asks if these will be considered in the future site-specific tiered NEPA process. Response: Compliance agreements at the candidate sites regarding environmental restoration and waste management were reviewed relative to environmental impacts as addressed in section 3.3. The analysis also includes the types of waste management facilities, their capacity, and projected life. The project impacts were evaluated based on these levels. More detailed analysis would be included in future site-specific tiered NEPA documents. Section 4.9 (cumulative impacts) describes the impacts of these actions. 16.19 The commentor greatly approves of the Draft PEIS format and indicates that the following sections were particularly helpful: section 3.1.1 - planning assumptions and analysis, section 3.1.2 - environmental impact analysis, and section 4.1.1 - environmental resource methodologies. The commentor also notes that these sections placed up front in the document rather than buried in an appendix provide a clearer introduction to the alternatives and impact assessments. In fact, the commentor believes that all of DOE's EISs should include similar sections. The commentor also likes the copresentation of the affected environment and environmental impacts for each candidate site. Response: DOE will consider these comments in future NEPA documents prepared by the Office of Reconfiguration and in other DOE programs. 16.20 The commentor suggests that DOE have the NRC review the PEIS. The NRC is not listed in table 6.2-1 of the Implementation Plan (IP) (1/95) for purposes of coordination and consultation. In 10 CFR 1021.100, 1021.101, and 1021.103, DOE acknowledges its obligation to comply with the regulations issued by the CEQ as given in 40 CFR 1500 - 1509. Specifically, under 40 CFR 1502.19, DOE is required to furnish the entire statement to "any Federal agency which has jurisdiction by law or special expertise with respect to any environmental impact involved," and, under 40 CFR 1502.24, DOE "shall ensure the professional integrity, including scientific integrity, of the discussions and analyses in environmental impact statements." Response: NRC has been provided with copies of this document for review as suggested. Meetings and discussions were held with NRC and they have been included in the PEIS process. 16.21 The commentor feels that tritium production environmental impacts, "from initial material collection to end by-products," need to be considered. In addition, the commentor feels other focus areas for consideration should include: how will tritium affect endangered and other species, and how will they be protected; what measures will be undertaken should a radiological accident occur; and how, when, and where will tritium "end" products be stored and disposed of. Also, another commentor states that the PEIS for Tritium Supply and Recycling should include information on the environmental conditions (for example, Superfund activities) of each site. Response: The PEIS does consider and evaluate the environmental impacts of the potential tritium supply and recycling facilities on biotic resources including endangered species at each site (see sections 4.2.3.6, 4.3.3.6, 4.4.3.6, 4.5.3.6, and 4.6.3.6). The emergency planning and emergency preparedness plans and procedures in place at each site are described in the affected environment sections for each site under the heading "radiation and hazardous chemical environment." More discussion of the emergency preparedness procedures as they relate to potential reactor accidents has been added to these sections in the Final PEIS. The "end" products of radioactive waste, hazardous waste, and spent nuclear fuel are addressed and included in the analysis presented in the PEIS (see the waste management sections 4.2.3.10, 4.3.3.10, 4.4.3.10, 4.5.3.10, and 4.6.3.10). 16.22 The commentor believes that DOE is being politically pressured into making a premature and unnecessary decision. The PEIS does not fully reflect this fact, but the commentor strongly encourages DOE to insist on completion of a thorough and open analysis and discussion of this matter before any decision on future tritium production is made. Response: As discussed in chapter 2, DOE has conducted a thorough and open analysis on the tritium issue. DOE does not think this is a premature and unnecessary decision. Rather, DOE is conducting this action in order to meet its responsibilities set forth in the Atomic Energy Act. 16.23 The commentor believes that each of the alternative technologies and sites has environmental impacts that will need to be further evaluated and mitigated in future NEPA documentation. The commentor further suggests that the ratings of the programmatic alternatives do not preclude the possibility of future, potentially significant, environmental impacts that may arise when site-specific tiered NEPA analyses are done. Response: DOE has already identified the need for further NEPA analysis in site-specific tiered NEPA documents and discusses the proposed compliance with NEPA for tritium supply and recycling in section 1.2 of the PEIS. The possibility of future significant impacts could arise but the PEIS attempted to bound the analysis so that impacts identified in site-specific tiered NEPA documents would be encompassed. 16.24 In reference to page S-3, paragraph 4, the commentor suggests that the ROD should also include a decision as to when to start to build the new supply and when it must be online. Response: The ROD will select potential tritium supply technologies and site locations; other issues such as construction and online data for operation are not expected to be provided in the ROD. However, the current guidance shows that the tritium supply must be online by 2011. The detailed start and ending dates for any tritium supply and recycling facilities will be included in subsequent, site-specific tiered NEPA document for such facilities. 16.25 The commentor notes that an operational date for the new supply given on page S-4, paragraph 5 does not appear to be consistent with the date given near the end of page S-1. Response: The statement that new tritium be available for use in the year 2011 is consistent in both sections referred to by the commentor. The confusion may be in the statement on page S-1 that a new "source" of tritium be available by 2009. This means that a tritium supply technology must be constructed and ready to irradiate targets in the year 2009 so that the tritium can be extracted and be available for replenishment of the tritium reserves in the year 2011. 16.26 The commentor asks how a person with a Q-clearance gains access to the classified appendix CA. Response: Personnel with an active Q-clearance may be able to gain access by contacting the Director of the Office of Reconfiguration at the following address: Office of Reconfiguration, US Department of Energy, P.O. Box 3417, Alexandria, Virginia 22302. In addition, interested parties can call the following toll-free number to obtain more information: 1-800-776-2765. 16.27 The commentor notes that page 1-1, paragraph 1 contains the statement that there is no capability to produce tritium within the Complex. While this may be technically correct, the commentor points out that DOE has significant capacity to produce tritium as described on page S-9. Response: The statement in section 1.1 has been changed to clarify that DOE does not have the capability to produce the required amounts of tritium. 16.28 The commentor requests that the particular NEPA documents referred to on page 1-2, top of second column concerning the commitment of resources be specified. Response: The other NEPA documents referred to in this section are the Waste Management PEIS being prepared by the DOE Office of Environmental Management; the Storage and Disposition of Weapons-Usable Fissile Materials PEIS being prepared by the DOE Office of Materials Disposition; the Foreign Research Reactor Spent Nuclear Fuel EIS and Programmatic Spent Nuclear Fuel Management EIS recently completed by the DOE Office of Environmental Management. A discussion of these documents is presented in section 1.5. To better clarify this, a reference to section 1.5 has been added to the paragraph noted by the commentor. 16.29 The commentor asks how can a requirement for tritium depend on funding levels as mentioned on page 1-2 of the PEIS. In addition, the commentor asks why the operational date for a new supply is not set only by military needs, treaty commitments, and the size of the existing tritium supply. Response: The tritium requirements are independent of funding levels. The need date is independent of funding, however, the operation date is dependent on funding. 16.30 The commentor notes that the fourth sentence on page 3-4 concerning the storage of spent fuel states "but no acceptance criteria has been established." Since criteria is plural, the word "has" should be replaced by the word "have". Response: The commentor is correct and the appropriate changes have been made to section 3.1.1 of the Final PEIS. 16.31 The commentor believes that DOE personnel and contractors are resources paid for by the taxpayers and should be accounted for in the PEIS. The commentor states that such an accounting may put to bed concerns that DOE creates programs to maximize DOE jobs via study and development programs with DOE employees/contractors. Response: The PEIS addresses the socioeconomic issues for each of the alternatives. The Tritium Supply and Recycling Program is a result of national defense needs and not a program for creating jobs. 17 Regulatory Compliance 17.01 The commentor is of the opinion that DOE needs to resolve the facility regulatory oversight issue and disclose its decision. In addition, the commentor also suggests that DOE should be wary of allowing the state to set regulatory standards as they are often too high. Response: States have the legal authority to establish environmental standards which may be more stringent than Federal standards. In response to concerns that DOE needs regulatory oversight at its nuclear facilities, the Secretary has created an independent Task Force on External Regulation. This task force is presently reviewing various alternatives for external oversight of activities at DOE's nuclear facilities and will submit a report, with recommendations, early in 1996. 17.02 Six departments within the state government of South Carolina, after reviewing the Tritium Supply and Recycling Program, state that it is consistent with their goals and objectives. In addition, the proposal is consistent with the South Carolina Coastal Zone Management Program. Response: As explained in the PEIS, DOE intends to meet all applicable state regulations of the affected state in the siting, construction, and operation of the tritium supply technology. 17.03 The commentor notes the classification of radioactive wastes generated by the target, multiplying blanket, and beam stop in the APT is under the jurisdiction of the NRC per sections 2(12)(B) and 2(16)(B) of the Nuclear Waste Policy Act of 1982, as amended, and per section 2(9)(B) of the Low-Level Radioactive Waste Policy Act. In addition, the commentor suggests that the NRC review the nuclear waste classifications for all options discussed in the PEIS. Response: Currently DOE-generated LLW is disposed of at DOE facilities and it is not regulated by the NRC. The PEIS was provided to the NRC for review. Mixed LLW is shipped offsite and does comply with NRC provisions. 17.04 The commentor provides a rewrite for volume I, chapter 5, table 5.3-4, page 4-14, water resources row, potential applicability/permits column. The suggested rephrasing is as follows: A permit may be required prior to any modification of waters of the state including stream alteration for the construction of intakes, discharges, bridges, submarine utility crossings, etc. Response: The phrase "A permit may be required prior to any modification of waters of the state including stream alteration for the construction of intakes, discharges, bridges, submarine utility crossings, etc." has been substituted in table 5.3-4 in section 5.3 of the Final PEIS. 17.05 The commentor suggests DOE ensure that all Nevada action alternatives are consistent with the State of Nevada's water protection laws. A copy of the those laws were mailed to DOE. In addition, the commentor believes that PEIS table 5.3-4, page 2 of 5 should be modified to indicate that a groundwater withdrawal permit is or will be required from the Nevada State Engineer. Response: DOE believes the proposed action at NTS would be consistent with applicable Federal law and State of Nevada water laws. The site-specific NEPA document will analyze these issues in more detail and DOE will comply with all applicable Federal, state, and local laws if NTS is selected. 18 National Nuclear Weapons Policies 18.01 Several commentors express opposition to additional tritium production and continuation of nuclear weapons production for the following reasons: such activity is a contradiction of the Non-Proliferation Treaty and the decision should be No Action; it does not show good faith to other countries; tritium from dismantled weapons can be used beyond the year 2011; it is unwise from a fiscal, health, and political standpoint; and it produces tremendous amounts of hazardous waste which we are already unable to handle. Also, commentors suggest reduced nuclear threat has reduced the need for nuclear bombs, and results of a re-evaluation/negotiation of the Non-Proliferation Treaty could eliminate the need for a production facility. Response: As a result of the STARTI Treaty, the STARTII Protocol, and the recently completed Nuclear Posture Review, the Nation's nuclear stockpile is being greatly reduced. The Nuclear Posture Review forecasts steady declines in both the size and diversity of the stockpile through the year 2003. Thus, DOE is currently engaged in a significant dismantlement effort. Such actions are consistent with the recently reaffirmed Nuclear Non-Proliferation Treaty. Additionally, DOE has made significant progress in consolidating the Complex, and is now considering further consolidation to make the Complex smaller and less costly to operate, while protecting the environment and public and worker safety. With the exception of a facility to make tritium, DOE is not considering the construction of any major new weapons production facilities. The need for a new tritium supply is discussed in chapter 2 of the PEIS. 18.02 The commentor is of the opinion that DOE should not create any more nuclear waste until a positive use can be found for it. Response: As discussed in the waste management sections, all tritium supply alternatives will create waste. DOE cannot meet its responsibilities without generating waste. DOE will attempt to minimize any waste that is produced and to manage waste in a safe and environmentally conscious manner in accordance with all applicable regulatory requirements. 18.03 The commentor states that we should abolish all weapons and not further destroy the land and the environment. According to the commentor, the SRS tritium production plant has already released significant amounts of radiation into air and water. The commentor adds that radioactive elements cannot be stored safely for long periods of time. In addition, the commentor notes that some of the land on military bases that have such storage will not be able to be used again. Response: DOE recognizes that its facilities require varying levels of environmental cleanup and has instituted a cleanup program over the past several years. DOE has worked with EPA, states, stakeholders, and the general public to develop long-range programs and commitments to clean up its facilities to acceptable levels. All of these plans and commitments have been reviewed for the proposed sites to determine if there are any conflicts or restrictions which would inhibit these sites from serving as good locations for the facilities proposed in the PEIS for tritium supply and recycling. Nothing was found which would inhibit the alternative sites from performing the required mission. Once a specific site is selected, additional site-specific tiered NEPA documents will be prepared. This analysis will address specific contamination problems of the specific proposed DOE facility and, to the extent mitigative measures are required to allow for ongoing environmental restoration or to prevent additional contamination, it will be an integral part of this site-specific analysis. 18.04 Commentors state that DOE should consider technology alternatives that use a commercial reactor for defense purposes and that create saleable electricity. One commentor suggests DOE consider producing excess tritium for sale to other countries to affect taxpayer burden. Another commentor states that developing APT technology could possibly pose a greater proliferation threat than using ALWRs, which have become a worldwide standard and are a controlled known technology. Response: The primary purpose of the proposed action is to obtain a new source of tritium to meet the National defense needs of the future. The PEIS evaluates the reasonable alternatives to meet defense requirements and potential environmental impacts associated with each tritium supply technology. Although there are other commercial uses for tritium both in the United States and abroad, this use of the new tritium supply to provide tritium for these uses is not proposed. The use of a commercial reactor to irradiate tritium target rods is now included as a reasonable alternative and has been added in the PEIS. The preferred alternative identified in section 3.7 of the PEIS is a dual track strategy to pursue both the use of an existing commercial light water reactor and the construction of an accelerator to produce tritium. The preferred alternative also identifies SRS as the preferred site if an accelerator is selected as the primary production option. 18.05 Commentors express support for the National Defense Policy and general mission of DOE. Another commentor notes that this is an important process and an important decision. Response: These comments will be considered in the decision making process. 18.06 The commentor is of the opinion that controversy over the nuclear program conceals hidden agendas designed to kill nuclear power. Response: The PEIS contains a fair and open assessment of the proposed alternatives. 18.07 One commentor states that the government continues to practice "pork barrel economics" by suggesting the possibility of a multipurpose reactor which can dispose of plutonium, produce tritium and generate electricity. Another commentor suggests using a plutonium trigger for weapons less than 20 tons of TNT equivalent. Response: The decision on the tritium supply technology will not be identified until the ROD has been published after this PEIS. Two of the technologies analyzed for tritium production in the PEIS have the capability to burn plutonium (ALWR and MHTGR), as does the commercial reactor alternative. The potential use of these technologies for plutonium disposition has been addressed in the PEIS. DOE does not expect that the ROD on tritium production would restrict or prejudice decisions of any plutonium options. In fact, DOE's preferred alternative would allow for subsequent integration with future plutonium disposition decisions if desired. 18.08 Commentors suggest that DOE should provide a declassified Nuclear Weapon Stockpile Plan showing what it considers a safe and reliable nuclear deterrent. Response: Chapter 2 of the PEIS is the unclassified version of the Nuclear Weapons Stockpile Plan. 18.09 One commentor refers to volume I, chapter 2, section 2.1 and requests that an explanation or history of the Nation's nuclear weapons stockpile adjustments be provided (i.e., the impact of recent treaties, the fall of the Soviet Union, the projected threat, and other associated factors that would affect future tritium needs). In addition, another commentor states that the public should be aware of the actual numbers and amounts of tritium that are needed. In the commentor's opinion, more analysis on tritium and weapons needs is necessary and might indicate that further reductions could be made thereby eliminating the need for a new facility. Another commentor suggests that the Final PEIS should address the total tritium supply needs for not only strategic defense but also for other defense missions, critical non-defense missions and energy security consistent with the legally binding goals imposed in Sections 1602, 2001, and 2114 of the Energy Policy Act of 1992. Response: The previous and current number of actual nuclear weapons in the stockpile, as well as the amount of tritium required for such stockpile numbers, remains classified. To the extent possible, the general levels, as well as a correlation to the various treaty activities, have been reflected in the PEIS. 18.10 In reference to the last paragraph on page S-1, the commentor questions the basis for the year 2009 as the time when the new supply of tritium must be available. The commentor also asks if this is based on START II levels or something else. Response: As stated in chapter 2 of the PEIS, the tritium requirements in this document are based on the 1994 Nuclear Weapons Stockpile Plan approved by the President on March 7, 1994. These levels are based on START II levels. 18.11 The commentor asks if DOE is turned over to DOD, what effect, if any, will that have on site selection and technology for tritium. Response: The requirements for tritium would not change as a result of a shift of responsibility from DOE to the DOD. The existing Complex has in the past and is currently charged with monitoring the Nation's nuclear weapons stockpile. There is no reason to believe that under DOD the potential sites or the technologies considered for tritium production would change. 18.12 The commentor asks what would be the impact of failing to supply tritium by 2011 and by 2016. Response: The consequences of failing to supply tritium by 2011 and 2016 is explained in section 2.1 of the PEIS. Essentially, after 2011 it would be necessary to use the strategic reserve of tritium to maintain the readiness of the nuclear stockpile. Without a new source of tritium, the strategic reserve would be depleted by 2016 and the nuclear deterrent capability would degrade because the weapons in the stockpile would not all be capable of functioning as designed. 18.13 The commentor states that it is unacceptable for the Federal Government to knowingly proceed with a project that they know will cause an increase in the levels of cancer estimated for the alternative PEIS sites. Response: Potential human health impacts are discussed in the PEIS and the ROD will consider these in any decisions for selecting a tritium supply technology or site. 18.14 The commentor states that the manufacturing of nuclear weapons has become a hornet's nest of environmental catastrophes. The cost of cleaning up these catastrophes, the commentor believes, is astronomical. Therefore, the commentor suggests that DOE should stop making weapons that it never intends on using. Response: The Nation has significantly reduced its nuclear arsenal. However, even with international treaties and major reductions, tritium will still be required. Chapter 2 of the PEIS addresses the purpose of and need to provide a tritium supply. The DOE Office of Environmental Management directs an ongoing program to remediate contamination of DOE facilities due to past operations. The characterization activities of potential contamination areas or any planned or ongoing remediation activities would be considered in the siting of any tritium supply technology at any site. Lessons learned from past DOE production reactors and the incorporation of the latest designs in proposed tritium supply technologies are being used to ensure the protection of the environment and minimize the generation of additional waste. 18.15 Commentors believe that global nuclear disarmament should also be considered an important variable in the decision to produce tritium. Several commentors believe that the continued existence of nuclear weapons and the materials to assemble them is a threat to our safety. According to the commentors, as a result of the reduced Russian threat there is no longer a need to produce nuclear weapons. Commentors feel reducing more weapons adds to the possibility of increased terrorist threats. The commentors state that the United States has almost 20 years to continue to seek quick ratification of START II and negotiate deeper cuts. In addition, the commentors suggest that DOE analyze various stockpile levels, not just conservative ones. If reductions are made, the commentors believe that recycling could continue to supply tritium into the twenty first century thereby greatly reducing the need for tritium. Finally, the commentors note that while DOE may not have final authority over whether a tritium facility should be built, DOE should make the case with the Nuclear Weapons Council that the United States does not need to make an immediate decision. Commentors recommend a delay since an immediate decision to build may be dangerous for the United States. In addition, commentors refer to section 2.1, paragraph 3, and section 3.1.1, paragraph 3 and request that the section on sizing be expanded to include the specific reductions in the stockpile, or limitations on the stockpile, as a result of specific treaties and international agreements. The commentors ask how much tritium is required to support the STARTI and START II levels, as a percentage of the pre-STARTI levels. With this information, the commentors believe that it will be easier to understand why the new supply needs to come online at a specified data. For example, the commentors note that if the STARTII level is 25 percent of the pre-START I level and the last production of tritium was in 1988, then a new supply must be available in 2013. The commentors note that under START II, implemented in 2003, our arsenal will contain approximately 8,000 weapons. By 2010, the commentors believe that number should be reduced as the result of negotiating further cuts. Therefore, the commentors feel that the need for additional tritium could be delayed well beyond 2010. Response: The Nation has significantly reduced its nuclear arsenal. Even with these treaties and major reductions, tritium will still be required. Chapter 2 provides the rationale for stockpile size. DOE has to support Nuclear Weapons Stockpile Plan under the Atomic Energy Act of 1954. These levels are established to provide an effective nuclear deterrent. DOE cannot unilaterally change the stockpile size. The previous and current number of actual nuclear weapons in the stockpile, as well as the amount of tritium required for such stockpile numbers, remains classified. To the extent possible, the general levels, as well as a correlation to the various treaty activities have been reflected in the PEIS. 19 Allocation of Federal Funds 19.01 Commentors believe DOE should not fund a tritium facility. One commentor claims that taxpayers are not ready to pay for a tritium facility for several reasons: the Federal Government is trying to reduce spending; it is a poor use of money that should be spent on environmental cleanup so as not to leave the cleanup legacy to our children; given the imminent financial insolvency of Medicare and the poor state of American schools, proceeding with tritium supply and recycling will only weaken the value of United States currency; and money should be used for people's needs. Also, after spending a lot of money, the commentor notes that the project could be canceled. Another commentor believes that DOE's decisions regarding the Tritium Supply and Recycling Program should keep pace with the proposed legislation to drastically reduce and balance government spending. Response: Congress determines how funds are allotted. DOE spends monies consistent with Congressional direction. All of DOE's facilities require some level of environmental cleanup. DOE facilities were designed in the 1940s and 1950s, prior to environmental regulatory requirements when the understanding of waste management principals was not what it is today. Over the past several years, DOE has had a very aggressive cleanup program and has worked with EPA, states, stakeholders and the general public to develop long-range programs and commitments to clean up its facilities to acceptable levels. 19.02 The commentor suggests that money should be spent on solar power and other alternative energy sources. Response: The evaluation of utilizing power from a Solar Powered Demonstration Project at NTS has been added to the PEIS. Any further evaluation of methods to reduce electricity costs will be done in the site-specific tiered NEPA documentation as appropriate. 19.03 The commentor is of the opinion that DOE should include funding support for the multipurpose facility as part of the FY'95 Energy and Water Appropriation Bill. Response: The development of the budget and congressional spending process are beyond the scope to the PEIS. 20 Support of or Opposition to DOE Policy 20.01 Several commentors oppose the funding and construction of the Tritium Supply and Recycling Program because they believe DOE should spend more time and funds on environmental cleanup and waste management at existing sites. One commentor expresses the opinion that DOE should counter any efforts to reduce funds allocated for environmental cleanup. For example, the commentor notes that a 9.2 percent decrease in such funding might require DOE to default on legally binding cleanup commitments. The commentor further suggests that if DOE would include in funding estimates for a tritium facility the costs required to dispose of waste produced by the facility, the project probably wouldn't be practical. In addition, the commentors also believe that opening a tritium supply facility will have a negative environmental impact. In fact, one commentor states that the tritium facility should not be built because weapons use is costly and as morally wrong as the Vietnam War. The commentor contends that the United States should be reducing weapons stockpiles instead of planning more weapons plant construction, which the commentor believes sends the wrong signal to the other nations and contradicts the assertion that DOE is downsizing. Another commentor favors tritium recycling instead of producing more tritium because it is safer and less expensive. Response: As a result of the START I Treaty, the START II Protocol, and the recently completed Nuclear Posture Review, the Nation's nuclear stockpile is being greatly reduced. With the exception of a facility to make tritium, DOE is not considering the construction of any major new weapons productions facilities. Remediation of contamination due to past operation of DOE facilities is an ongoing program of DOE under the direction of the Office of Environmental Management. The characterization activities of potential contamination areas or any planned or ongoing remediation activities would be considered in the siting of any tritium supply technology at any site. Lessons learned from past DOE production reactors and the incorporation of the latest designs in proposed tritium supply technologies are being used to ensure the protection of the environment and minimize the generation of additional waste. Congress determines how funds are allotted. DOE has no direct participation in funding, only allocation. 20.02 The commentor claims that originally, DOE was going to obey a CEQ requirement that DOE identify a preferred alternative for the tritium production facility. The commentor states that choice was to be the APT, located at NTS. However, the commentor contends that politicians from South Carolina and Georgia pressured the Secretary of Energy to postpone the decision. Pork barrel politics should not be involved in the choice, according to the commentor. Response: CEQ regulations require an agency identify a preferred alternative in the draft only when one or more exists (40 CFR 1502.14(e)). At the time the Draft PEIS was published a preferred alternative did not exist because cost and technical studies were not completed. These studies now exist and a preferred alternative is identified in section 3.7 of the Final PEIS. The rationale for selecting the tritium supply and recycling alternative will be identified in the ROD. DOE's decision making process will weigh factors such as cost, technological feasibility, environmental issues, and policy considerations. 20.03 The commentor states that DOE should not continue with its engineering studies that are scheduled for the next 5 years. In the commentor's opinion, this will just be an additional burden on the taxpayers. If DOE decides to proceed with the studies, the commentor believes that it will mean that the tritium facility will be built. Response: Engineering studies will continue to support decisions made by the ROD. 20.04 The commentor asserts that weapons should not be redesigned to avoid the need for tritium. Response: DOE considered but eliminated from detailed study the redesign of weapons to require less or no tritium. The reasons why redesign is not proposed are discussed in section 3.1.3 of the PEIS. 20.05 The commentor believes that the use of nuclear weapons is never appropriate and urges a No Action decision. Response: The PEIS analyzes the potential environmental impacts associated with various site and technology alternatives for the production of tritium. Under the No Action scenario, DOE would not have sufficient quantities of tritium to fulfill its requirements under the Atomic Energy Act of 1954 to support the enduring stockpile as directed by the President and approved and funded by Congress. The tritium in weapons which are being retired from the stockpile as a result of recent arms negotiations can be recovered and utilized in the existing weapons, but this supply is not sufficient to replace the tritium which decays in the existing weapons. Based on a stockpile consistent with the requirements of START II levels, it is expected that an additional supply of tritium will be required by 2011. Accordingly, DOE is proposing to develop a new source of tritium. The use of nuclear weapons is beyond the scope of the PEIS. 20.06 The commentor believes that Idaho has shouldered the Nation's most undesirable waste for far too long. In the commentor's opinion, the other states should accept an equal share of the waste. In addition, the commentor would like to see more environmental protection and less nuclear development. Response: Only waste generated at INEL would be handled there. No outside waste would be sent to INEL under any other alternatives. 20.07 The commentor believes that DOE should build a reactor fueled by plutonium or highly enriched uranium. Response: Section 4.8.3 of the PEIS discusses the option of building a reactor capable of burning this type of fuel. 20.08 The commentor believes that Westinghouse should be replaced as the prime contractor. Response: This issue is beyond the scope of the PEIS. However, DOE contracts are reviewed on a regular basis. 20.09 One commentor believes that new technology would be developed if sufficient time were allowed to pass before the project is approved, making the Tritium Supply and Recycling Program unnecessary. The commentor notes that by rushing headlong into the project now, we are precluding some feasible alternatives (using tritium from retired weapons). This kind of action the commentor states is what lead to the arms race/build-up in the first place. In addition, another commentor believes DOE should delay its decision to build a new tritium supply source for 20 years to save money and to phase-out "thermonuclear" weapons production here and in nuclear-capable nations. Response: Chapter 2 provides the rationale for stockpile size. DOE has to support the Nuclear Weapons Stockpile Plan under the Atomic Energy Act of 1954. These levels are established to provide an effective nuclear deterrent. DOE cannot unilaterally change the stockpile size. 21 Storage of Special Nuclear Materials 21.01 Commentors state concerns about waste management in Nevada. One commentor is opposed to storage or disposal of surplus special nuclear materials or high-level waste in Nevada. Another notes that State of Nevada officials contend that the PEIS fails to provide any real discussion or assessment of the real waste management risks and equity issues important to Nevadans. Currently, virtually all of the LLW being shipped to the NTS is shipped from offsite generators. Equity issues are concerns for Nevadans since DOE has stated that the NTS site could become the largest burial ground in the DOE Complex for defense-related radioactive waste. Finally, the commentor states, while the PEIS includes an assessment of the potential cumulative impacts associated with some of these storage activities, it fails to consider the civilian spent reactor fuel to be placed at Yucca Mountain. Response: Section 4.3.3.10 addresses the potential waste management impacts at NTS. None of the tritium supply technologies will generate high-level waste. Impacts of spent nuclear fuel at Yucca Mountain are not quantifiable at the present time. 22 Commercial Reactor Alternative 22.01 Several commentors believe that cost issues are a priority and offer suggestions on addressing this matter in the PEIS. One commentor asserts that there needs to be a cost estimate for a tritium production and plutonium disposition facility together and a cost estimate for each facility separately. DOE also needs to compare the three cost estimates. The cost analysis, according to another commentor, should also include the cost to the government of a privately financed reactor proposal - how would DOE inform the public on the costs/benefits of a privately- or publicly-owned multipurpose reactor. In addition, another commentor feels the high cycle costs of the proposed technology alternatives should be a major consideration in the ROD. The commentors also believe that DOE should compare the costs of accelerator-produced versus reactor-produced tritium and a per-gram tritium cost comparison. Finally, the commentors suggest evaluating the cost of buying tritium versus producing it. The obvious cost-effective option is to locate the tritium facility where a tritium recycling facility already exists, at SRS. Other cost-effectiveness-related comments from the commentors include: the idea to utilize and upgrade existing DOE tritium recycling facilities and reactors or accelerators; the idea to purchase foreign-source tritium such as from North American Free Trade Agreement partner, Canada; and purchasing irradiation services from existing commercial facilities. Response: DOE has conducted extensive cost and technical reliability analyses for each of the alternatives analyzed in the PEIS. All of this information will be considered along with the information developed through the PEIS to reach an ultimate decision. Information developed to analyze the costs associated with the various alternatives for the PEIS was further placed under the additional scrutiny of an independent review. Although these cost studies are not included in the PEIS, as the PEIS deals with the projected environmental impacts of the various programmatic alternatives, they are reflected in the Technical Reference Report which is available in DOE reading rooms. No cost analysis was performed on the purchase of tritium from a foreign source. This alternative was considered, but determined to be unreasonable, since it would place the Nation's defense at the mercy of the supply source nation. 22.02 Several commentors state that DOE should consider more closely the use of an existing commercial reactor. Using a commercial reactor might create fewer negative environmental impacts and save money compared to building a new facility, according to the commentors. Commentors suggest that an analysis be provided of the modifications necessary to convert a functioning reactor to tritium production and discuss the prospect of converting a commercial reactor to tritium reduction in more detail, with relation to costs, engineering feasibility, and public health and environmental issues. Other commentors believe that the PEIS does not adequately explain the exclusion of either the commercial reactor-purchase or control rod production alternatives from the full-scale analysis of tritium supply alternatives on page 3-7 and in section 4.10. The commentors further state that they believe nothing in existing nonproliferation law or practice suggests that the United States could not legally produce tritium for military or civil purposes in a "civil" reactor. One commentor notes that tritium is not a material subject to IAEA safeguards, is not regarded as central to the proliferation problem, and is also produced for civil purposes, such as runway lighting and fusion energy research. Finally, Commentors believe that the existing reactor option should be analyzed in more detail in the PEIS and also suggest that DOE develop a list of commercial reactors that are under consideration. One commentor feels that the nonproliferation policy of the reactor purchase options are not sufficiently different from DOE's own proposed ALWR alternative, which includes the use of a next generation civil reactor design and the generation of electricity for commercial sale, to justify its "elimination from detailed study." Another commentor contends that if DOE is now considering the existing reactor option that they should also consider the privatized multipurpose reactor. The commentor further states that if the existing reactor option were chosen then it should also include the large evolutionary light water reactor as well. In contrast, other commentors believe that the United States should not use commercial reactors for tritium production because we have asked other countries not to use their commercial reactors for national security efforts and it would be considered a violation of the Nonproliferation Treaty. In addition, commentors express skepticism about the conversion of commercial power reactor to tritium production, even if a new reactor were employed. Commentors also state that military and civilian nuclear technologies should be kept separate. Response: Section 3.1.3 of the Draft PEIS, alternatives considered but eliminated from detailed study addressed the issues of potentially using commercial reactors for the production of tritium. As a result of comments received on the Draft PEIS, DOE is now considering both the purchase of a commercial reactor and conversion to tritium production and the use of a commercial reactor for irradiation services as an alternative. A more detailed and comprehensive analysis of the purchase of an existing light water reactor has been added to the PEIS. DOE invited public comments on this specific issue, including comments on the potential environmental impacts described in section 4.10 of the Draft PEIS, in a special 21 day comment period. Results of that additional comment period are included in this Comment Response Document. 22.03 In reference to page 3-29, section 3.4.2.1, commentors request that a discussion be included on why a power-producing HWR, such as the Canadian CANDU reactor, has not been considered. One commentor asserts that given the objectives on page A-31, it would seem that basing the design on a modern design that is currently in commercial service, like the CANDU, would be preferable to using technology from the 1950s. Another commentor expresses opposition to considering the use of a CANDU reactor as an alternative, and states the United States must stop subsidizing the CANDU reactor in Canada. Response: Utilization of the CANDU reactors was not considered because the utilization of such facilities, or the sale of tritium generated from these facilities for use in nuclear weapons, is precluded by Canadian law. The heavy water reactor being considered as an alternative by DOE, however, is similar in design to the CANDU reactor. The CANDU reactor is a reliable but older reactor design. The heavy water reactor alternative being considered in the PEIS is the next generation reactor design, is much more advanced than the CANDU reactor, and has many more design safety features built in to it. 22.04 Several commentors express dissatisfaction with the length (21 days) of the extended comment period for the commercial reactor alternative. One commentor states that section 4.10 of the Draft PEIS does not provide a detailed study of the existing reactor option eliminated as a reasonable alternative. The commentor believes that DOE has not provided adequate justification for the "last minute" decision to allow existing reactors to be included in the Final PEIS. The commentor further suggests that DOE provide an opportunity for public comments on the Final PEIS, prior to issuing the ROD. Response: As discussed in the Federal Register Notice of August 25,1995 (60 FR 44327), the public comment period was reopened for a limited period to solicit comments on DOE's intention to consider utilizing a commercial reactor or reactors (securing irradiation services) as a reasonable alternative in the PEIS. The decision to treat the irradiation services scenario as a reasonable alternative was reached after further evaluation in response to public comments on the Draft PEIS, in which several commentors asserted that irradiation services (or purchase of a commercial reactor, which was considered a reasonable alternative in the Draft PEIS) have the potential to be a low cost option that would not violate any law nor weaken nonproliferation efforts. Section 4.10 of the Draft PEIS included an evaluation of the environmental impacts of both of these scenarios, and this discussion has been expanded in the Final PEIS. Although the irradiation services scenario was considered as a contingency in the case of a national emergency and not as a reasonable alternative in the Draft PEIS, the impacts were evaluated in detail and were not added to the Final PEIS without providing the opportunity for public review and comment. As the reopened public comment period was intended only to solicit additional comments on analysis available to the public throughout the original comment period, the 21 day period was deemed to be sufficient. Members of the public may submit comments on the Final PEIS, including the alternatives considered and the preferred alternative. A decision on tritium supply and recycling will not be made until at least 30 days after the issuance of the Final PEIS. 23 Commercial Irradiation Services 23.01 Some commentors express support for the purchase or lease of irradiation services for tritium production. One commentor states that such a purchase from a utility with an existing reactor is less costly than rebuilding a new facility since the infrastructure is already set. Other commentors favor the purchase of irradiation services only in the event of a national emergency or as a contingency source of tritium. In contrast, one commentor argues that building a new facility to produce tritium or leasing irradiation services is contradictory to the Nation's goals of reducing its nuclear weapons stockpile. Response: The decision to consider utilizing a commercial reactor or reactors (securing irradiation services) as a reasonable alternative in the PEIS was reached after further evaluation in response to public comments on the Draft PEIS, in which several commentors asserted that both have the potential to be a low cost option that would not violate any law nor weaken nonproliferation efforts. DOE has conducted extensive cost and technical reliability analyses for each of the alternatives analyzed in the PEIS. Although the irradiation services scenario described above was originally considered by DOE only in the case of a national emergency, as described in section 3.1.3 of the Draft PEIS, DOE has since concluded that it represents a reasonable alternative to be considered for all tritium supply requirements. These issues will also be considered in the decision on tritium supply and recycling.
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