CHAPTER 3: COMMENT SUMMARIES AND RESPONSES This chapter summarizes the comments the Department of Energy received on the Draft Programmatic Environmental Impact Statement for Tritium Supply and Recycling during the public comment period, and provides responses to those comments. Identical or similar comments provided by more than one commentor were grouped together in one comment summary and responded to. The responses indicate whether any changes were made to the PEIS and the rationale behind those decisions. 01 Land Resources 01.01 Commentors suggest that the Department of Energy (DOE) carefully consider all of the potential consequences of siting the proposed tritium facilities at the Pantex Plant (Pantex). Commentors express the opinion that Pantex is surrounded by some of the nation's richest agricultural resources and any accidental radioactive release or contamination would seriously affect this vital national resource, as well as the surrounding population. In the commentors' view, the Programmatic Environmental Impact Statement (PEIS) for Tritium Supply and Recycling should address this issue. Response: The PEIS addresses the potential impacts of the proposed tritium supply and recycling facilities on the surrounding environment from facility accidents in section 4.5.3.9. Additionally, appendix F, section F.3.4 provides information on secondary impacts of accidents at Pantex. DOE is aware of the valuable agricultural resources surrounding the Pantex facility. If the proposed tritium supply and recycling facility was sited at Pantex, appropriate safeguards would be taken to minimize the likelihood of an accident, radioactive release, or contamination that could significantly degrade these resources, such as described in section 3.4.2 and appendix section A.2. 01.02 The commentor notes that the area proposed for the proposed tritium supply and recycling facility at Pantex infringes on land that was leased from Texas Technological University. The commentor believes that DOE should address this issue and any complications it may present in the PEIS. Response: As discussed in section 4.5.2.1 of the PEIS, the proposed tritium supply and recycling facility would be located in the interior industrial core at the Pantex site. Three areas have been designated for future industrial sites within that core, and one area designated as Area C on figure 4.5.2.1-3 currently encompasses DOE-leased land from Texas Technological University. As can be seen from figure 4.5.2.1-3, there are two areas that would not affect leased land. Ultimate siting will be discussed in site-specific tiered National Environmental Policy Act (NEPA) documents. For the area in question, the boundaries can be rearranged to exclude any land DOE has leased from Texas Technological University. Therefore, no complications concerning DOE-leased land and Texas Technological University are anticipated with siting the facility at Pantex. 01.03 The commentor notes that Pantex has less total acreage than the other proposed sites. As a result, the commentor believes that siting the Accelerator Production of Tritium (APT) technology at that site could result in extensive and expensive relocation of existing facilities and an inadequate security "buffer" zone unless additional land is obtained. The commentor suggests that DOE should address these issues and their potential impacts on properties adjacent to the site in the PEIS. Response: Section 4.5.3.1 of the PEIS discusses environmental impacts associated with the con- struction and operation of tritium supply and recycling facilities at Pantex. As presented in table 4.5.3.1-1, siting the APT technology at Pantex would require 173 acres of land. Three areas (A, B, and C) have been designated for future industrial sites at Pantex. The APT land requirement translates into 30, 23, and 19 percent of the available land for areas A, B and C, respectively. Although Pantex has the smallest total acreage of all the candidate sites, it has sufficient land to accommodate any of the proposed tritium supply technologies and recycling facilities. 01.04 The commentor expresses the opinion that the PEIS should include in its analysis the current and future value of the land surrounding Nevada Test Site (NTS) (the new facility could have an effect on its value). Response: As discussed in section 4.3.3.1 of the PEIS, the construction and operation of the proposed tritium supply site (TSS) facility would be consistent with the NTS Site Development Plan and have no impacts on prime farmland, grazing allotments, other agricultural activities, or other land uses on site. Offsite land will not be directly affected since no tritium facilities will be constructed there. The socioeconomic analysis presented in the PEIS assesses the potential impacts of the proposed tritium supply alternatives on directly-affected sectors of the economy including labor supply and demand, income, and public finance, as well as impacts on housing and transportation. The analysis does not cover speculative issues such as the impacts to future property values and business location or expansion decisions. Potential changes to socioeconomics in the region, which may indirectly affect land values, are discussed in section 4.3.3.8. For example, the increase in population created by some of the alternatives could increase demand for housing. 01.05 The commentor asks whether land use assessments are being made on DOE-owned land, such as those previously done for other interested landholders. Response: As discussed in section 4.1.1 of the PEIS, changes in land use are expected to occur at most, if not all, of the DOE candidate sites for tritium supply. The PEIS contains an analysis of the impacts the proposed tritium supply and recycling facilities would have on the future use or development of land at each DOE site. The PEIS considers land use plans and policies, zoning regulations, specially protected lands, and existing land use. Changes in land use within existing DOE site boundaries and on lands adjacent to or in the vicinity of DOE sites (i.e., non-DOE land) that may result from the proposed alternatives are considered in the PEIS. 01.06 The commentor notes that in section 4.5.2.1 of the PEIS, area farmland is considered by the Soil Conservation Service as "prime farmland when irrigated." The commentor suggests any "loss" of such potential prime farmland on Pantex to an industrial use would be slight, relative to the expanse of cultivated and irrigated lands across the high plains of Texas and the regional "Golden Spread." The commentor is of the opinion that such a loss could be balanced by application of blowdown cooling tower waters as irrigation to the immediate area. Response: Sections 4.5.2.1 and 4.5.3.1 of the PEIS discussed environmental impacts to land use as a result of the proposed construction and operation of the tritium facility at Pantex. Three areas have been designated within the existing industrial core of Pantex to accommodate the tritium supply and recycling facilities. Although classified as prime farmland, these areas are essentially removed from agricultural use by ongoing plant activities. There would be no loss of prime farmland within or outside of the Pantex site boundary. As described in section 4.5.3.4 of the PEIS, there would be no discharge of cooling system blowdown waters at Pantex. Any pretreated utility, process, and sanitary wastewater not recycled for tritium supply water needs would be discharged to the playas in accordance with the Pantex National Pollutant Discharge Elimination System (NPDES) permit. These wastewater discharges are not suitable for crop irrigation without advanced treatment processing. 01.07 The commentor notes that section 4.5.3.1 of the PEIS identifies the Bureau of Land Management Visual Resource Management (VRM) classification of Pantex as Class 4. The commentor is of the opinion that the program would not downgrade that classification. In fact the commentor points out that the "most sensitive viewpoint" from the Texas Plains Trail, at the intersection of US 60 and Farm-to-Market Road 2373, designates the existing industrial structures at Pantex as a "point of interest." Therefore, the commentor believes that siting the tritium supply and recycling facility at Pantex would enhance the visual resource. Response: As discussed in sections 4.5.2.1 and 4.5.3.1 of the PEIS, the tritium supply and recycling facilities would be visible from the key viewpoint from any of the proposed industrial areas at Pantex. The VRM classification would not change with the construction and operation of any of the technologies because existing views already include industrial facilities. 01.08 The commentor states that the installation of transmission and distribution lines does result in some land use and visual impacts. However, in the Pantex area, that is, flat plains, and along existing corridors, the commentor believes that incremental visual impacts would be slight. In addition, the commentor also believes that effects on land resources during construction would be slight. The commentor also suggests that effects on land resources during construction would be temporary, and effects on land use, such as grazing or farmlands, likely would be slight as well, not only because transmission structures occupy little land, but also because likely routes would be along highway rights-of-way and/or existing power supply corridors. Response: As discussed in sections 4.5.2.1 and 4.5.3.1, environmental impacts to land and visual resources in the Pantex area are anticipated to be minimal. Any of the proposed technologies for this site would be supported by a new electrical substation and additional electrical transmission lines. In order to minimize the potential impacts to natural resources, new transmission lines could be sited along existing rights-of-way. In addition, the presence of sensitive habitats (for example, wetland, prime farmland) would be considered if the construction of new rights-of-way are needed. 01.09 The commentor references pages 3-23, 3-35, 3-38, and 3-60, noting that in the previous Environmental Impact Statement (EIS) for a New Production Reactor (April 1991), the land area required for each reactor concept (Heavy Water Reactor (HWR), Advanced Light Water Reactor (ALWR), Modular High Temperature Gas-Cooled Reactor (MHTGR)) varied by site, but was never less than 360 acres (for an HWR at Savannah River Site (SRS)). The MHTGR had the largest requirement at only one site, and only during construction. The commentor points out that in this Draft PEIS, the land area requirements are constant from site to site, and no extra land is needed during construction. The commentor questions why the MHTGR now requires the most land, in spite of the fact that only three modules are now needed compared with eight in 1991. Since none of the reactor concepts is modular, the commentor believes it is not logical that their land requirements would decrease more than the MHTGR requirements. The commentor is of the opinion that either the MHTGR requirements are overestimated or the requirements of the other concepts are underestimated. For these reasons, the commentor feels that the land use impacts need to be reevaluated. Response: Land use requirements for the MHTGR and other technologies are discussed in sections 4.2 through 4.6 of the PEIS for each of the candidate sites. As discussed in section 3.4.2.2, the MHTGR technology will require only three modules instead of six to eight identified in the New Production Reactor EIS (April 1991) and disturb approximately 360 acres of land. Land requirements given in the New Production Reactor document included acreage for reactor facilities and support facilities for tritium production, plutonium product, and spent fuel processing. In addition, the New Production Reactors were site-specific designs incorporating infrastructure and environmental features of the candidate sites. 02 Site Infrastructure 02.01 Commentors express the opinion that the analysis of the site infrastructure impacts in the PEIS is unclear and vague, particularly with regard to electrical needs, and that DOE needs to be more explicit and thorough in its analysis of the environmental impacts and costs associated with either additional electrical consumption or a new power plant. The commentors believe that the PEIS should consider various energy sources (e.g., nuclear, coal, hydro) for additional power and that the choice could be based on the composition of the regional power pool. Commentors also state that DOE should clearly indicate the quantity of additional water that will be needed for the additional electricity, the size (physical and electrical) of the additional power plant, and an analysis of the impacts associated with buying electricity from power pools inside and outside the area of each of the five proposed sites. In addition, one commentor states that 6 years might be required to construct a 500 to 600 megawatts electric (MWe) coal-fueled steam electric plant rather than the 3 years estimated in section 4.8. Another commentor notes that in volume I, page 4-3, column 2, paragraph 4, the PEIS states, "A detailed quantitative analysis based on the proportional contributions from each fuel source, would be conducted..." The commentor expresses the opinion that apportionment of power requirements on the basis of the current mix of fuel sources would probably be inappropriate, especially for the APT which has large power requirements, and especially for the northwestern United States (e.g., at Idaho National Engineering Laboratory (INEL)), where current electric power use relies heavily on hydroelectric plants, and where significant expansion of hydroelectric generating capacity may be unlikely. The commentor also believes that the impact of a 500 to 600 MWe power requirement would be similar to that described in section 4.8.2 (pages 4-443 to 4-446), whether it is filled by a dedicated collocated plant or by increased generating capacity elsewhere. Response: The site infrastructure methodology found in section 4.1.2 of the Draft PEIS explains in detail to what extent the electrical impacts are assessed. The discussion presented in the PEIS presents data and impacts in a programmatic context. For all of the technologies, the electrical requirements to support each technology is added to the projected site No Action requirement to determine the total site electrical requirement for each of these technologies. These requirements are listed in tables 4.2.3.2-1, 4.3.3.2-1, 4.4.3.2-1, 4.5.3.2-1, and 4.6.3.2-1 for INEL, NTS, Oak Ridge Reservation (ORR), Pantex, and SRS, respectively. The peak power and the total annual energy required for each of these technologies were then compared against the capacity margin and the total electricity production of the appropriate subregional power pool. These comparisons are presented in tables 4.2.3.2-2, 4.3.3.2-2, 4.4.3.2-2, 4.5.3.2-2, and 4.6.3.2-2 for INEL, NTS, ORR, Pantex, and SRS, respectively. In all cases, it appears that the subregion can adequately support all of the technologies. However, as a bounding case for the APT option, the construction and operation of a dedicated natural gas fuel power plant at each site has been analyzed. Cost is not addressed in this PEIS but the cost studies being prepared for the decision maker include the cost of buying electricity and the income from selling it, as appropriate. The cost studies are included in the Technical Reference Report available in DOE reading rooms. The detailed quantitative analysis referred to in the comment would not necessarily show that the current mix of fuel sources is expected to equate to the future mix. The usefulness of site-specific tiered NEPA documents is that they are more able to focus on the unique power characteristics of a chosen site (and its respective utility and power pool) and determine whether or not a proposed impact analysis methodology is appropriate for further consideration. The electrical contributions from the ALWR and the MHTGR are taken into account in the environmental analysis since the designs of these reactors and the operating requirements used in the PEIS are based on the fact that they generate electricity. The economic benefit of this electricity production is included in the cost analysis presented in the Technical Reference Report available in DOE reading rooms. 02.02 Commentors express the opinion that DOE should consider the possibility of using alternative energy sources such as wind or solar energy to meet additional electricity requirements for the various technologies. In addition, one commentor believes that this possibility should be addressed in the PEIS. The commentors state that solar-generated electricity from a proposed central receiving and photovoltaic facility could be used for NTS. This could be handled by a private company, according to the commentors. Response: The possibility of utilizing solar energy to supply additional electrical power for the various technologies will be evaluated at NTS where a solar power demonstration project is scheduled for implementation. The potential contribution of electric supply from the central receiving and photovoltaic facility at NTS proposed by the Corporation for Solar Technology and Alternative Resources has been included in the Final PEIS analysis for NTS. Descriptions of the facility, the proposed construction and operation schedule, power output, and the contribution to the NTS energy system are discussed in section 4.3.2.2. 02.03 Commentors state that the technology options which are capable of producing electricity result in avoided environmental impacts because they would displace existing generating capacity and/or new capacity, and that this should be discussed in the PEIS. One commentor also notes that the PEIS discusses at length the adverse impacts of transmission lines but provides no discussion of the avoided impacts that are realized by not having to build other generating capacity to supply the needs of the surrounding service area. Response: The PEIS does recognize the fact that the ALWR and MHTGR technologies can produce electricity. The benefit of selling this electricity is accounted for in the cost analysis included in the Technical Reference Report available in DOE reading rooms. Section 4.8.1 of the PEIS discusses the potential of the ALWR and MHTGR reactor technologies to produce power by a power conversion facility. This section also describes the potential for impacts associated with offsite distribution of that power. Incident to producing the tritium requirements, the ALWR and MHTGR technologies would also generate significant quantities of electricity (approximately 600 MWe, 1,300 MWe, and 400 MWe for the Small ALWR, Large ALWR, and three-module MHTGR respectively). Electricity produced from any of these reactors would likely be sold in accordance with Section 44 of the Atomic Energy Act, and DOE has incorporated the revenues from such electricity sale into the cost estimates for these reactors. The PEIS also addresses the potential environmental impacts of generating this electricity. In addition to this cost benefit, the benefit of not building future electrical production facilities could be realized. These so-called "avoided environmental impacts" are acknowledged for both the ALWR and MHTGR, and are discussed below. Primarily as a result of the Energy Policy Act of 1992, the electric power industry is undergoing significant changes, most notably related to the transmission of electric power. It is expected that electric power will be more freely "wheeled" from one power pool to other power pools, essentially nationalizing the transmission of electric power. Transmission of electric power will be more efficient because there will be fewer barriers to the use of available and future electrical generating capacity. Thus, the demand for electricity in one part of the country could be met by an electrical generating facility operating in a different part of the country. A tritium production facility that also produces electric power would provide an additional 400MWe to 1,300 MWe of electric power to supply future electrical demands, and could, thus, obviate the need to build some electrical generating facility in the future. This means that the potential environmental impacts of this additional facility could indeed be avoided. However, given the situation described above regarding the national wheeling of electric power, it would be speculative to say where the environmental impacts of a 400 MWe to 1,300 MWe would be avoided, or what type of electrical generating facility (e.g., coal, gas, nuclear, etc.) would not have to be built. About all that can be said with any certainty is that the environmental impacts of such a facility could be avoided. Nonetheless, this PEIS provides an environmental impact assessment of building 400MWe to 1,300 MWe reactors at various sites around the country, and also assesses the environmental impact of constructing and operating a dedicated 550 MWe gas-powered facility at these same sites. These general types of impacts for 400 MWe to 1,300 MWe could be avoided because of the ALWR or MHTGR. 02.04 The commentor states that the analysis of regional power pool capacities and needs in the PEIS for Tritium Supply and Recycling is incorrect. The excess capacity for regional power pools is not extra electricity, but electricity needed by these power pools. The commentor is of the opinion that the PEIS projections for future growth in power pool regions may be inaccurate and this may force utilities to build new facilities if the APT technology is selected. In addition, the commentor also notes that the PEIS also incorrectly identifies the regional electrical power pool from which Pantex, through Southwestern Public Service Company, draws service. Southwestern Public Service is connected to the Southwest Power Pool, and has additional access to the Western Systems Coordinating Council and the Electric Reliability Council of Texas (refer to sections 4.5.2.2, 4.5.3.2, and 4.8.1, and table 4.5.2.2-2). The commentor suggests that DOE will want to review tables 4.5.2.2-2 and 4.5.3.2-2. As a result of this mistake, the commentor believes that the percentages shown in the public meetings as "percent power pool capacity margin" may be incorrect. Another commentor states that the future need for power in the southeastern United States should be assessed as part of the EIS. Commentors further suggest that the document should address how the APT may affect reserve electrical capacity within the proposed power pools in general and should fully evaluate the environmental effects and electricity-rate-based real costs of the additional electricity. One commentor believes that the risk analysis needs to take into account the additional risk if a power plant is needed to produce the additional power required for the APT. Response: The PEIS does not equate generating capacity reserve margin with excess electricity availability. Capacity margin is defined by the North American Electric Reliability Council as the amount of generating capacity available to provide for scheduled maintenance, emergency outages, system operating requirements, and unforeseen electrical demand. The PEIS recognizes that the reserve margin is an amount of electricity that is ineligible for use by all but the aforementioned activities. This is evidenced by the statement in section 4.5.3.2, site infrastructure, that additional energy and power required by the tritium supply and recycling alternatives would be accommodated with approximately 9 miles of transmission lines and a new electrical substation. This shows that the utility, and ultimately the subregional and regional power pools, could be expected to provide all of the equipment necessary to transmit the additional power, but does not imply that the additional power is to be supplied out of the reserve margin. Rather, the statement that the tritium supply and recycling alternatives would require between 0.47 and 4.28 percent of the reserve margin is an indication of what the subregional power pool would suffer in terms of loss of reserve margin if implementation of the tritium supply and recycling alternatives were not accompanied by new power generation, power imports, or demand side management. The PEIS defers to the decision of the respective utility and power pool as to exactly how this extra power would be supplied. The PEIS projections are only as accurate as the North American Electric Reliability Council projections. In an effort to limit errors in projections, North American Electric Reliability Council-projected data for 2002 was used as the estimate for 2005. This was done because the PEIS does not purport to assess electrical impacts for 2005 by further manipulating data that have already been estimated for 2002. The power pool analysis for the Pantex site has been corrected in the Final PEIS to reflect the West Central Subregion of the Southwest Power Pool as the primary provider of electricity to the site. This PEIS provides an indication of what the particular power pool would suffer in terms of loss of reserve margin if tritium supply and recycling alternatives requirements were not accompanied by new electrical generation. 02.05 The commentor is of the opinion that the PEIS should include a more detailed analysis of the proposed transmission lines for the tritium facility. The commentor further suggests that the analysis should include the proposed route of the lines, whether they will be underground, what the costs will be, and any potential impacts to human or natural resources in the area. Response: The location of tritium facilities on any of the five potential sites is merely representative and does not lend itself to the detailed analysis suggested in the comment. Based on the representative site, the electrical utility requirements, including amounts of new transmission lines, were assessed. Following the Record of Decision (ROD) on this PEIS, a site-specific tiered NEPA analysis could be performed in which a specific location of the facility on the chosen site would be evaluated. This would enable a more detailed analysis of the proposed transmission lines. 02.06 The commentor states that the electrical power loads would range from 62 MWe to 566 MWe. The commentor states that the power requirements, depending on the technology, would require additional transmission lines and additional supply. The commentor points out that the Nevada Power Company is assumed as the supplier. The commentor suggests that the proposal should consider Valley Electric Power Company as a primary source for NTS as well. The commentor feels the proposed Solar Enterprise Zone may offset environmental impacts associated with power generation by providing a "cleaner" source of electricity for some of the additional load requirements. Response: The California and Southern Nevada Power Area Subregion is the assumed source of any additional power that the Nevada Power Company would obtain. Any more detailed analysis of procurement from other local power companies would be analyzed in the site-specific tiered NEPA documents. The possible impact of the proposed Solar Enterprize Zone on power requirements at NTS has been added in the Final PEIS. 02.07 The commentor notes that the PEIS does not propose to use the existing natural draft cooling tower constructed for the K-Reactor at SRS. The commentor believes that the PEIS should consider the use of this facility, if technically feasible, because of pollution prevention considerations. Under the mitigation section (page 4-432), the commentor points out that the PEIS states that the existing treatment facilities could be used. The commentor expresses the opinion that these facilities (for example, liquid low-level waste (LLW) waste processing facilities, the saltstone process, and the proposed Consolidated Incineration Facility) should be maintained and upgraded as a preferable alternative to constructing new facilities. Response: DOE acknowledges that the K-Reactor cooling tower exists and that there is a potential for its use and it may represent a cost savings at that site. This information will be factored into the decision to select the tritium supply and recycling facility location. In addition, the use of other existing facilities such as waste management facilities mentioned in the comment would also be considered for use or possible upgrade in site-specific tiered NEPA analysis as an alternative to constructing new facilities to do the same job. The use of the natural draft cooling tower built for the K-Reactor will be considered in a site-specific tiered NEPA document if SRS is selected as the site for a new tritium supply reactor. 02.08 One commentor suggests obtaining cost estimates from commercial electrical companies and finding out if the power pools can support the APT electrical requirement. Another commentor also urges DOE to consider what would happen if the electricity for the APT were cut off (that is, how reliable are the commercial electrical companies). Response: Cost is not addressed in this PEIS but the cost estimates being prepared for the decision maker include the cost of buying electricity and the income from selling it, as appropriate. Reliability concerns for all of the technologies are being addressed in separate studies (feasibility reports) for the decision maker to consider. The cost and technical feasibility studies are included in the Technical Reference Report available in DOE reading rooms. 02.09 Commentors are of the opinion that the PEIS should include the fact that some of the reactor technologies could produce electricity (or steam for conversion to electricity) and, as a result, would not require a new electricity source and might even be able to contribute electricity to the regional power pool. The commentors further suggest that the PEIS should consider this a potential benefit for selecting a reactor technology and DOE should incorporate this into their final selection of a technology. One commentor states that the evaluation in section 4.8.1 (page 4-442) of the sale of steam from tritium supply technologies is grossly unbalanced. According to the commentor, the PEIS states that the impacts of the sale are "too speculative" to be addressed at this time. Concerns regarding the separation of military and commercial nuclear technology are also raised by the com- mentor. In fact, the commentor states that the N-Reactor at Hanford sold electricity to the local utility. Furthermore, the commentor notes that this issue was addressed during the New Production Reactor Program. Initial discussions with the utility companies in the service areas of the candidate New Production Reactor sites were quite positive, according to the commentor. The commentor also believes that any precedents established at that time should be cited as a basis under which the sale of electricity from the tritium supply reactors could proceed. The commentor is of the opinion that there is sufficient basis from the New Production Reactor Program for assuming that electricity sales would take place. The commentor believes that the positive environmental impacts that result need to be considered. Response: It is reasonably foreseeable that electricity generated by the ALWR or MHTGR incident to the production of tritium would be sold, as allowed by Section 44 of the Atomic Energy Act. Thus, the PEIS includes an analysis of these potential impacts. Section 4.8.1 discusses the prospect of capturing the useful by-products (that is, steam and/or electricity) of operating either the ALWR or MHTGR to produce tritium. In both reactors, steam is produced. However, at the end of the first paragraph in section 4.8.1, the question of what to do with this steam (whether it is sold or used to generate electricity which is in turn sold) is clearly deferred to a separate site-specific tiered NEPA document. The sale of electricity is similar to the sale of steam in that both transactions require an in-depth analysis of site-specific utility and power pool electricity supply and demand projections. Again, this is more appropriately left to the separate site-specific tiered NEPA document mentioned above. 02.10 The commentor states that DOE should not locate a new tritium facility at NTS because there is no experience in this area for the construction of a new nuclear reactor facility. Response: Technical feasibility and the schedule feasibility reports for completing the various tritium supply technologies at each candidate site have been made available to the decision maker and are reported in the Technical Reference Report available in DOE reading rooms. 02.11 The commentor references the following statement in volume II, page I-10, APT: siting the APT at INEL "would utilize 4.15 percent of the regional power pool capacity margin." With the possibility of decreased generation by Bonneville Power Administration to help salmon recovery along the Columbia River, the commentor believes this large draw could become very problematic and needs significant discussion. Response: In the event of decreased generation by the Bonneville Power Administration, the Northwest Regional Power Pool Subregion in which INEL is located would adjust its resources to compensate for this loss of generating capability independent of the requirements generated by the APT at INEL. In any event, the APT electrical requirements could be supplied by constructing a dedicated natural-gas fueled power plant at INEL if the power was not available commercially. This option has been added to the Final PEIS and is evaluated on a site-specific basis. 03 Air Quality and Acoustics 03.01 Commentors express the opinion that there are some inconsistencies, flaws, and omissions in DOE's analysis of the potential impacts to air resources resulting from the proposed action. In general, one commentor believes that DOE should be more concerned about increased pollution levels and the effects these could have on visibility and air quality. Another commentor suggests that the analysis should include the increased pollutant levels resulting from additional power plants that may be needed or increased levels from existing plants. In addition, another commentor suggests that the emissions analysis in the PEIS for Tritium Supply and Recycling should clearly state where the data for each technology originated. Finally, if a nuclear facility is selected, one commentor believes that DOE should limit air exposures to more stringent standards than those currently established. The commentor believes that the air exposures should not exceed 1/10 of the existing standards. In the commentor's opinion, this would provide some room for error and avoid future shutdowns in the event these standards are not achieved. Response: The Final PEIS has been revised to consider the impact of an additional power plant which could be used to support the APT alternative. Air quality impacts for all the alternatives at each candidate site are conservatively estimated and discussed in sections 4.2.3.3, 4.3.3.3, 4.4.3.3, 4.5.3.3, and 4.6.3.3 of the Final PEIS. DOE believes that the current air quality standards which were used in assessing impacts and the modeling approach used are sufficiently conservative to assure that the public and environment are adequately protected. Sources of input data for the air quality analysis are referenced for each of the alternatives throughout the document and technical support data are presented in appendixB. Source documents are provided in DOE reading rooms. The air emission standards for criteria pollutants, hazardous/toxic, and radiological emissions are set by the Environmental Protection Agency (EPA) and/or the states to protect workers and the public and already include an additional margin of safety. DOE intends to meet these standards and, for most categories, operations would result in small increases to the site emissions. The resulting total emissions would still fall below regulated standards. 03.02 The commentor references section 4.1.3, air quality and acoustics, (volume I, page 4-5, column 1, paragraph 1) and appendix B, methodology and models, (volume II, page B-2, column 1, paragraph 1). The commentor is of the opinion that the assumptions described for modeling the effect of toxic/hazardous pollutant emissions are not necessarily conservative, especially the artificial placement of sources at the center of a large site, such as the INEL. Response: The sources are centrally located within the complex of facilities at the proposed TSS, not within the entire site. The phrase "within the complex of facilities" has been inserted after "centrally located" in the two locations noted above for clarification. The emissions have been "double counted" to ensure that the baseline is conservative. The proposed TSS emissions are accurate as described above. There will always be limitations associated with modeling. 03.03 The commentor questions why no mention was made of the proposed action's impacts on global climate change. According to the commentor, the Draft PEIS indicated that if the electrical power for the New Production Reactor was fossil fuel generated, then the combustion could produce "...about 0.01 percent of the total United States emissions of the gas (carbon dioxide) with potential significant cumulative effects on global warming." The commentor recommends the addition of a clarifying statement concerning potential project impacts on global climate change. Response: The emissions of greenhouse gases for the reactor alternatives (HWR, ALWR, MHTGR) range from approximately 64 tons per year for the light water reactor at Pantex to approximately 230 tons per year for the MHTGR at NTS, ORR, or Pantex. Compared to the estimated 5 billion tons per year of carbon dioxide released in the United States each year, these emissions represent less than one-hundredth of a percent increase. The APT emissions of greenhouse gases is approximately 13 tons per year without an associated electric power facility. Emission of greenhouse gases from a 600 MWe natural gas-fired turbine facility would generate approximately 1 million tons per year of greenhouse gases. These combined emissions would be greater than those for the reactor alternatives, but would still be less than two one-hundredths of a percent of the carbon dioxide released in the United States each year. 03.04 Referring to sections 4.5.2.3 and 4.5.3.3, air quality and acoustics, several commentors note potential advantages in the area of air emissions at Pantex. The commentors see no emission rates in appendix table B.1.4-4 that would trigger Prevention of Significant Deterioration review or permitting for any of the technologies at Pantex, although section 4.5.3.3 states that Prevention of Significant Deterioration permits may be required. The commentors find no evidence that Prevention of Significant Deterioration permits could be triggered by the Pantex tritium program and strongly encourage DOE to revisit this section of the EIS. The commentors also note that Pantex is in the air quality attainment zone for automobile and industrial pollution, that this is not true of other candidate sites, and that there are no Prevention of Significant Deterioration Class I areas in the vicinity. Additionally, one commentor points out that the estimated impacts of toxic hazardous air pollutants from any of the tritium supply technologies and recycling facilities at Pantex clearly would comply with applicable air quality regulations and standards, which protect human health and welfare and the environment with an ample margin of safety. The commentor also notes that the Pantex area, by wide margins, is in compliance with all air quality standards - with the one exception of the 30 minute standard for hydrogen chloride (exceeded occasionally at the Burning Ground, where a high explosives treatment/disposal facility is expected to reduce the hydrogen chloride emissions so that even the short-term standard is not exceeded). The commentor states that there appears to be nothing in the Tritium Supply and Recycling Program that would degrade the air quality at Pantex. Equally, nothing in the program is anticipated to degrade the area acoustically, according to the commentor. Response: The rationale for the text statement "that Prevention of Significant Deterioration permits may be required" at Pantex is as follows: As shown in table 4.5.3.3-1, the 2010 No Action Pantex emissions for nitrogen dioxide plus incremental nitrogen dioxide emissions from the MHTGR facility would exceed the Prevention of Significant Deterioration applicable 100-ton-per-year emission criterion. Pantex would therefore be designated as a major source. Also, the MHTGR facility would result in a significant net increase in emissions of nitrogen dioxide (greater than 40 tons per year) at Pantex. Therefore, the increase of nitrogen dioxide would subject it to a Prevention of Significant Deterioration review. 03.05 The commentor notes that the proximity of the Great Smoky National Park, a Prevention of Significant Deterioration Class I area, to ORR may require significantly more stringent mitigation for air resource impacts. The commentor recommends that this be noted in the impacts section of the PEIS. Response: The following sentence has been inserted in sections 4.2.3.3 (INEL) and 4.4.3.3 (ORR) of the Final PEIS: "The proximity of Prevention of Significant Deterioration Class I areas may require significantly more stringent mitigation for air resource impacts." 03.06 The commentor states that on page B-33, the value of 4.60 under APT should probably be under ALWR as it was in the previous four tables. Response: The commentor is correct and the appropriate changes have been made in the Final PEIS. 03.07 Regarding section 4.4.3.3, the commentor suggests providing a cost structure for the possibility of lowering the airborne emissions for each tritium supply technology. Response: A cost structure to lower the airborne emissions for each tritium supply technology is beyond the scope of the PEIS, although no exceedances of regulatory limits were identified. Additional detail will be provided as appropriate in site-specific tiered NEPA documents. 03.08 The commentor states that it is difficult to locate references in the PEIS. For example, on page 4- 275, "EPA 1974a" is not even listed in the reference section (page 6-10). The commentor also notes that on page 4-273 table 4.5.2.3-1 has no reference. Response: EPA 1974a is listed in the February 1995 draft as follows: "EPA 1974a Environmental Protection Agency (EPA), Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety, (550/9-74-004), Office of Noise Abatement and Control, Arlington, VA, March 1974." The references for table 4.5.2.3-1 are listed under "Source" at the bottom of the table. Both source documents are listed in the references. 03.09 The commentor claims that NTS does not and did not perform any modeling for criteria and noncriteria pollutants. The commentor wants DOE to explain the origins of the results on page 4-108. Response: The modeling for NTS was performed in accordance with the methodology presented in section 4.1.3, air quality and acoustics, and further described in appendix B. 04 Water Resources 04.01 Surface Water 04.01.01 The commentor is of the opinion that DOE should be concerned about surface water discharge from the APT once-through cooling system. An analysis of this discharge should be included in the PEIS, according to the commentor. Response: As discussed in section 4.3.3.4 of the PEIS, cooling system blowdown and sanitary waste-water from the APT would be treated and recycled for reuse as cooling system makeup. The treated effluent from the process treatment would be discharged to evaporation ponds. Treated effluent would be monitored to comply with the NPDES permit and other discharge requirements. There would be no discharges to surface water from operation of the tritium supply technologies at NTS. 04.01.02 The commentor expresses several concerns about surface water at ORR. Regarding chapter 4, table 4.4.2.4-1, page 4-185, the commentor requests that DOE explain how the "Average Water Body Concentration" values were derived. In the paragraph "surface water rights and permits" on page 4- 186, the commentor believes that DOE should include the following: "Dependent on intake location, construction may require a 26A permit from Tennessee Valley Authority, review by the Watts Bar Inter-Agency Working Group, State Aquatic Resources Alteration Permit, or a Corps of Engineers 404 permit with State 401 certification." Response: Regarding table 4.4.2.4.-1, the average water body concentration values were derived from monitoring data provided by ORR. The site average water body concentration is derived by taking an average of the samples collected throughout the year (monthly or quarterly), and taking an average of the results of the analysis. The text in section 4.4.2.4 of the Final PEIS under surface water rights and permits has been changed to incorporate the commentors suggested revision: "Dependent on intake location, construction may require a 26A permit from the Tennessee Valley Authority, review by the Watts Bar Inter-Agency Working Group, State Aquatic Resources Alteration Permit, or a Corps of Engineers 404 Permit with State 401 certification." 04.01.03 The commentor states that in the PEIS Los Alamos National Laboratory is described as infeasible and impractical as an alternative site for APT-generated tritium because of cooling water requirements. However, the commentor notes that there are similar water limitations in southeastern Idaho. At a minimum, the commentor believes that the PEIS should acknowledge that surface water in southeastern Idaho is the subject of ongoing court adjudication. The commentor notes that the outcome of this process cannot be predicted at this point, but ultimately it could affect INEL's water rights. Response: The text has been modified in section 4.2.2.4 of the Final PEIS under surface water rights and permits indicating that surface water in southeastern Idaho is the subject of ongoing court adjudication. 04.01.04 Commentors note that DOE is currently involved with remediation of East Fork Poplar Creek (near ORR) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) because the creek was contaminated by past releases from the Y-12 plant. Significant cleanup activities are required onsite and offsite. The commentors suggest that any activities (e.g., cooling tower blowdown) involved with tritium production that include discharges to the creek causing scouring, erosion, and flooding may be unacceptable and contrary to the goals of the remedial activities. Response: The following text has been added in section 4.4.3.4 of the Final PEIS under surface water and groundwater "As discussed in section 4.4.2.4, DOE is currently involved with remediation of East Fork Poplar Creek under CERCLA. Any discharges, including cooling tower blowdown, involved with tritium production that may potentially impact East Fork Poplar Creek would require engineering design mitigation measures to avoid interference with the goals of the remediation effort." 04.02 Groundwater 04.02.01 Commentors express the opinion that the water resources analysis in the PEIS lacks consideration of some reasonable and superior alternatives, and unfairly favors other sites over Pantex. For example, treated wastewater from the sites or the surrounding communities could be used to provide the water and cooling requirements of the various technologies and decrease or eliminate the need to withdraw groundwater from the Ogallala aquifer and eliminate any aquifer drawdown at Pantex. In addition, the commentors believe DOE should evaluate water conservation practices (such as those employed by the city of Phoenix) and advanced technologies that could also be employed to reduce water use impacts, particularly at Pantex and other "dry" sites. Other commentors note that the region around Pantex is dependent on the Ogallala aquifer and DOE should examine all program and other activities, such as the red bed drilling and pumping that are in process in and around Pantex, that could cause aquifer drawdowns. In addition, any activities that could introduce contamination into groundwater (either directly or indirectly through playa discharges) should be analyzed in detail. Response: No wastewater will be directly discharged to groundwater. All wastewater will be recycled or treated prior to any discharge to the playas. Furthermore, such discharges will be monitored and controlled by permits. Groundwater contamination is a result of past operations and with proper wastewater treatment methods will not present a problem in the future. Based on public comment and new information, only reclaimed wastewater has been evaluated for cooling system water usage for the proposed tritium supply technologies at Pantex. Groundwater is not proposed to be used for cooling and other production operations. The reclaimed wastewater would be obtained from the city of Amarillo Wastewater Treatment Plant. The red bed drilling and pumping that are in process in and around Pantex would be examined in site-specific tiered NEPA documents if Pantex is selected as the TSS. The following text has been added in section 4.5.2.4 in the Final PEIS under surface water: "Since the 1960s, reclaimed waste effluent has been used for cooling water processes on the Texas High Plains. There are two potential sources of reusable wastewater available in the vicinity of Pantex Plant: the Hollywood Road Wastewater Treatment Plant and the Pantex Plant Wastewater Treatment Facility." The Hollywood Road Wastewater Treatment Plant is located on the southside of Amarillo, approximately 20 miles from Pantex. Currently the Hollywood Road Wastewater Treatment Plant is discharging approximately 7 MGD (2,555 MGY) of advanced secondary treated water that has gone through a filter treatment and is then discharged to the Prairie Dog Town Fork of the Red River. This amount is anticipated to increase to 12 MGD (4,380 MGY) by the year 2010. A commitment has been made by the city of Amarillo to develop this wastewater to reduce the amount of ground-water withdrawals and slow the annual decline rate of the Ogallala aquifer. In addition, a commitment has been made between the city of Amarillo and DOE to use reclaimed wastewater from the Hollywood Road Wastewater Treatment Plant. The analysis of water resources for tritium supply at Pantex now includes use of reclaimed wastewater in lieu of groundwater. 04.02.02 Commentors believe that the water requirements for the APT are significant at NTS. Commentors also suggest that DOE study NTS basin recharge rates to clearly understand the amount of ground-water available to the project. In addition, commentors believe that DOE should also confirm that future NTS water needs were considered in addition to current and tritium supply and recycling requirements. Considerations should include impacts on local water needs, financial and environmental costs associated with aquifer drawdown, and increased water consumption as a result of future and concurrent projects at the site, according to the commentor. Commentors also believe that the PEIS should include an analysis of the impacts from potential existing or future contamination of aquifers associated with DOE activities. Response: When a site has been selected, a site-specific evaluation of water resources will be performed on local water needs (farmers, businesses, etc.). The site water requirements were based on future projects and site workload reasonably foreseeable at this time. Previous recharge rates furnished by NTS have been modified by the site and the new recharge rate numbers have been used to re-evaluate the tritium supply and recycling facilities. The new recharge rates indicate that none of the technologies would exceed the new recharge rates. The units for flow rate of a particular area are gallons per day or year. All data were based on studies that used recharge rates or flow over a given amount of time and over a given area. The text has been modified so the recharge rates are not averages, but various estimates of flow exemplified among authors. All authors rely on similar methodologies and assumptions, so the uncertainty in recharge and discharge estimates is based on a lack of complete data and different initial assumptions. However, the following specific revisions have been made. The discussion of groundwater in section 4.3.2.4 of the Final PEIS has been expanded to include the following: "A study by the United States Geological Survey (Harrill et al., 1988) balanced the amount of recharge and discharge throughout the Great Basin and estimated a total of 32 BGY recharge for the entire Death Valley System. Of this total, about 11 BGY flowed through or near Frenchman Flat into the Ash Meadows discharge area to the south. A study by the Desert Research Institute (A Deuterium-Calibrated and Discrete-State Compartment Model of Regional Groundwater Flow, Nevada Test Site and Vicinity (DOE/NV/108, March 1992)) modeled groundwater flow through discrete areas of the Death Valley system and concluded that of 16 BGY total system recharge, about 7 BGY flowed through Frenchman Flat. These differences in estimates of flow exemplify common variations among authors of a factor of 2 or 3 but rarely of as much as a factor of 10. All authors rely on similar methodologies and assumptions, so the uncertainty in recharge and discharge estimates is based upon a lack of complete data and different initial assumptions." The discussion of groundwater availability, use and rights in section 4.3.3.4 has been expanded to include the following: "Some proportion of the estimated flow through Frenchman Flat (11 BGY) is available for use by the tritium technologies. The exact amount available would have to be determined through site-specific studies to determine potential impacts on Ash Meadows and Devil's Hole and surrounding users. Harrill et al., 1988 estimated that there is four times as much water in storage as there is in annual recharge. Thus, there is the capacity to buffer the effects of annual or multi-year droughts through the use and replenishment of stored water. In addition, substantially more water could be made available by using resources in the Alkali Flat-Furnace Creek Ranch Subbasin to the west (service area D of figure 4.3.2.4-1)." 04.02.03 One commentor notes that NTS and the city of Las Vegas use completely independent and separate groundwater basins to meet their water needs. Therefore, the commentor believes that water resources should not be an issue at NTS. Another commentor expresses the opinion that the need for jobs and an economic boost outweigh the needs to conserve a water source which only serves the needs of NTS. Response: The city of Las Vegas, like the NTS, is located in the Great Basin. Even though most of the city of Las Vegas's potable water is obtained from surface water resources, approximately 15 percent of the water is obtained from groundwater wells, making groundwater a vitally important natural resource. Because a portion of the community relies on groundwater to supply a portion of its freshwater needs, it will be directly affected by groundwater usage and quality. The proper water resources for the tritium facility to operate effectively would also relate to additional jobs and economic benefit to the surrounding communities. Both the impacts to water resources and socioeconomics will be weighed by the decision maker. 04.02.04 Several commentors note that the PEIS for Tritium Supply and Recycling should have a more thorough analysis of the potential for aquifer contamination at INEL. Commentors state that past practices at the site have resulted in tritium contamination to the Snake River Plain aquifer. The aquifer is vital to southern Idaho and the commentors suggest that the PEIS identify all possible pathways (including those initiated by earthquakes) through which discharges (radioactive or not) could reach the aquifer or the land. The commentors also want DOE to provide additional information about groundwater supply impacts on the Snake River aquifer if the APT is selected for INEL. Another commentor refers to the section on groundwater quality in volume I, page 4-26 of the PEIS, and offers several changes. According to the commentor, the following sentence is inaccurate: "Two groundwater monitoring networks are operated at the INEL, one by the United States Geological Survey, the other by Radiological Environmental Science Laboratory." The commentor points out that there are several "networks" of monitoring wells drilled and maintained by the USGS. These include the INEL-wide facility groundwater monitoring group and well networks for Resource Conservation and Recovery Act (RCRA) and CERCLA-required monitoring. In addition, the commentor notes that groundwater beneath the INEL is monitored by groups including the USGS, DOE's site contractor, Lockheed Idaho Technology Company, other DOE contractors, and the State of Idaho. The commentor quotes further from page 4-26: "No tritium is currently disposed of at the INEL..." The commentor suggests that this statement should read: No tritium is currently disposed to the groundwater at the INEL. Continuing on page 4-26, the commentor also refers to this statement: "Other radionuclides of significance include strontium-90, cesium-137 and iodine-129. The first two, especially cesium-137, are strongly held on mineral grains in the soil. Therefore, it is unlikely that either will reach the aquifer in significant quantities." The commentor contends that this statement suggests that all strontium-90, cesium-137, and iodine-129 in the aquifer had to migrate through the vadose to reach the aquifer. From ORR and Cecil, 1991 (DOE/ID-22096), the commentor notes that in 1988 there was an area of about 1 mi2 where the strontium-90 concentrations exceeded the Maximum Containment Level. There are significant enough quantities of strontium-90 present to exceed the Maximum Containment Level over this region. In addition, the commentor states that recent CERCLA inves- tigations at the Idaho Chemical Processing Plant under the Federal Facility Agreement/Consent Order indicate that there is a significant source term of strontium-90 in the vadose and the current strontium-90 levels in the aquifer are as great as when direct injection of strontium-90 bearing wastes was occurring. The commentor believes that this discovery, with supporting information from vadose monitoring wells, suggests that strontium-90 levels in the aquifer may increase in the future. Response: Water sampling at INEL includes both onsite and offsite groundwater monitoring with samples taken from the Snake River and other surface streams and tributaries in the INEL vicinity, some of which flow onto the site and sink into its porous soils. Because the Snake River Plain aquifer, which lies beneath INEL, serves as one of the primary sources for drinking water and crop irrigation in the Snake River Basin, the USGS has an extensive monitoring program to maintain surveillance of the aquifer, and perched water bodies above it, on INEL and at a few locations beyond the southern and western boundaries. Results of monitoring of surveillance activities that are published in USGS reports are summarized in the INEL Site Environmental Report annually. At INEL, not all environmental monitoring responsibilities reside within the same organization. Operating contractors at each INEL facility are responsible for monitoring of effluents (releases) and for any ambient environmental monitoring or surveillance performed within the facility fences. The most extensive of these is conducted by EG&G Idaho. The Environmental Monitoring Unit conducts a radiological environmental surveillance program which includes water. Low, but detectable, concentrations of tritium, the most mobile low-level radioactive contaminate in the water of the aquifer, were reported in samples from wells just inside the INEL boundary in 1983. However, tritium from INEL has never been detected in any of the wells south of the boundary. Thus atmospheric transport is the principal potential exposure pathway from the site. Therefore, liquid-borne radioactive materials disposed to surface disposal ponds could percolate down through the porous soils into the Snake River Plain aquifer and into pumped water supplies. In addition, air to surface transfer of airborne radioactive materials could go to the Big Lost River (intermittent stream) and affect upstream fish migration, or air to surface transfer of airborne radioactive materials could fall on soils and percolate downward to the Snake River Plain aquifer. Assessments, including monitoring programs and self-assessments, are being conducted onsite and offsite, as discussed in the INEL baselines, section 4.2.2.4. With regard to earthquakes, all proposed project structures would be built to meet DOE design standards applicable to the seismic area. In addition, facilities such as the tritium supply would meet the standards of 10 CFR 100, appendix A. Additional information about groundwater supply impacts on the Snake River aquifer if the APT is selected for INEL will be addressed in site-specific tiered NEPA documents. In the Final PEIS the first few sentences under groundwater quality, section 4.2.2.4, have been rewritten as follows: "There are several `networks' of monitoring wells drilled and maintained by USGS. These include the INEL sitewide facility groundwater monitoring group and well networks for RCRA and CERCLA required monitoring. Groundwater beneath INEL is monitored by groups including USGS, DOE's site contractor, Lockheed Idaho Technology Company, other DOE contractors, and the State of Idaho." Text in the second paragraph of section 4.2.2.4 has also been rewritten to read: "No tritium is currently disposed to the groundwater at INEL; however, tritium plumes are present in the Snake River Plain aquifer and in perched groundwater under these sites (figure 4.2.2.4-2 (in USGS 1988a)." 04.02.05 Commentors assert that DOE needs to address and clarify some issues involving the playas at Pantex. The commentors express the opinion that the PEIS should address whether the discharge of water at high temperatures to the playas has any impacts, whether pollutants discharged into the playas will seep into the aquifer (high explosives and nitrates have been found in the aquifer), whether the characterization of the playas as dry lakes is accurate, and the possibility that discharges to the playas actually sustain species and play a beneficial role (currently in the PEIS, wastewater discharges are portrayed as degradations). Response: All discharges would be in compliance with existing NPDES permits and no impacts were identified in the analysis or are anticipated. In addition, the following text has been added to section 4.5.3.4 in the Final PEIS under surface water: "Closed-cycle cooling systems include cooling ponds and towers. Because it is a closed system, water is recirculated through the plant and tower or pond and replenished only to the extent that it evaporates. These systems discharge heat to the atmosphere rather than to water. The only water that is to be discharged to the playa is treated sanitary wastewater of the same type currently discharged. All wastewater discharged from the wastewater treatment plant is at ambient temperature." 04.02.06 The commentor believes that salt deposition from cooling towers may impact groundwater quality. The commentor notes that salt was not addressed as a potential source of groundwater contamination. The commentor is of the opinion that the PEIS should address the potential effects of supply and recycling activities on downstream and downgradient public water supply systems. Response: Impacts associated with tritium supply and recycling activities on public water supply systems would be addressed in site-specific tiered NEPA documents once a site is selected. Additional information has been added to all sections regarding salt deposition from the cooling towers. Any salt coming from the cooling tower originated from the ground or surface water depending upon the site. At dry sites (that is, Pantex, NTS, and INEL), dry cooling towers will be used, and salt would not be released at all from the cooling tower. There could be some concentration of salt in the blowdown water, but that can be treated. The dry cooling tower with blowdown recycle would couple reverse osmosis with an evaporator and crystallizer system that would remove the dissolved solids from blowdown so that water could be recycled to the cooling tower. This system would reduce peak requirements for makeup water and discharge would not require disposal. The solids from the crystallization processes would be disposed of as waste. This system would reduce the salt from the cooling tower as well as from blowdown. At wet sites (that is, SRS and ORR), because the salt is concentrated in a wet cooling tower, it can damage vegetation in a small area near the facility. At all the wet sites there is adequate rainwater and groundwater flow such that the salt from the cooling tower would be flushed into the groundwater and diluted. The groundwater and surface water systems are connected such that the salt originating from the major surface water body (that is, Clinch River and Savannah River) and reaching the groundwater will return to the river and the total amount of salt in the ecological system would remain the same. 04.02.07 Commentors believe that there are some additional water resources issues that DOE should address in the PEIS for Tritium Supply and Recycling: DOE should provide documentation of the reasoning behind the groundwater numbers in the PEIS; the water usage numbers at the sites should be adjusted for the relative humidity at the sites; DOE should acknowledge and address the fact that recent studies have suggested that Pleistocene groundwater in the western United States may be a nonrenewable resource and that "dry" years are causing more drawdown than DOE indicates; aquifer water levels in the PEIS should be shown as depths, not only as elevations; DOE should ensure that an adequate number of groundwater drawing sites are present at each site; and, DOE should indicate exactly where drawdown is being measured and whether those measurements adequately characterize the total area drawdown. Response: The PEIS groundwater quality numbers were derived by taking groundwater samples from existing monitoring or water production wells, running an analysis and comparing water quality criteria and standards to the sample results. Groundwater usage numbers were derived from current data on what is being used at the candidate sites. No Action (2010) water usage was derived by each site based on projected mission and related activities. No Action also included any new reasonably foreseeable projects or missions that could be added to the site and their expected water usage. Total water requirements for construction and operation are calculated by adding No Action water requirements with the requirements for each tritium technology. The percentage increase in water use due to the proposed tritium supply project was then calculated based on the No Action usage. The relative humidity at each candidate site was not included in the engineering analysis to determine water requirements. The preconceptual design of the proposed tritium supply technologies is not of the quality to determine the increase or decrease of water usage based on each sites environmental setting. In addition, the preconceptual designs were "greenfield" (the same design was evaluated at each site without any modifications to take advantage of existing infrastructure, resources, or environmental setting) except for the designation of "wet" and "dry" sites and the change in cooling systems. At the programmatic level of analysis, the water usage numbers for each technology are of sufficient quality to identify differences for selection of a tritium supply. When a tritium supply technology and site are selected, the site-specific tiered NEPA document will consider all these factors, including the effects of relative humidity on water requirements for the selected technology. The commentor is correct in stating that recent studies have suggested that Pleistocene groundwater in the Western United States may be a nonrenewable resource and that "dry" years are causing more drawdown. These are just a few of the reasons why alternative water sources, such as reclaimed wastewater from the city of Amarillo Hollywood Road Wastewater Treatment Plant, have been proposed as potential water sources for new tritium supply facilities. The map indicating water elevations was provided by the Panhandle Groundwater Conservation District No. 3. In that region water depths are measured by the district in elevations because it gives a better indication of the areas that contain more or less water because of the land surface. The average elevation of the land surface 3,550 feet must be subtracted from the elevation to show the depth to the groundwater surface. The groundwater drawdowns reported in the PEIS were measured from the city of Amarillo water production supply well field area. Further groundwater withdrawal analysis at the Pantex site and in the surrounding area would be addressed in site-specific tiered NEPA documents if Pantex is selected as the TSS. Based on public hearing comments and information received during the public review of the Draft PEIS, however, reclaimed wastewater is analyzed as the source of cooling water for the tritium supply technologies at Pantex in the Final PEIS. 04.02.08 In reference to volume I, page 4-28, groundwater availability, use and rights at INEL, the commentor expresses concern about the following statement: "The combined pumpage of the 27 onsite production wells averaged approximately 2,100 MGY from 1982 through 1985." The commentor suggests that more recent data are available and are used in the Spent Nuclear Fuel INEL Environmental Restoration and Waste Management EIS. The more recent data are slightly less, at about 2,000 MGY. The commentor also expresses concern about another statement in the section: "This is 40 percent of the 5,280 MGY of groundwater withdrawn from the aquifer in the Eastern Snake River Plain." The commentor notes that Lindholm, 1993 (USGS Open-file Report 91-98), states that in 1980, 1.9 million acre feet of water was pumped for irrigation on the Eastern Snake River Plain at 3.0689 acre feet per million gallons, that is 619,114 million gallons. Since irrigation accounts for an estimated 96 percent of all groundwater use, the commentator notes total pumpage from the Eastern Snake River Plain aquifer is about 645,000 MGY. Therefore, the commentor contends that water pumped by the INEL is more like 0.3 percent of all water pumped from the aquifer. Response: The text has been rewritten in section 4.2.2.4 in the Final PEIS under groundwater availability, use and rights, considering the new information in Lindholm, 1993 as follows: "The combined pumpage of the 27 onsite production wells averages approximately 2,000 MGY. This is 0.3 percent of the 645,000 MGY of groundwater withdrawn from the aquifer in the Eastern Snake River Plain. Most of the water withdrawn from the aquifer in the Snake River Plain (619,114 MGY) is used for agriculture (Lindholm, 1993)." 04.02.09 At SRS the need for excavation and dewatering for the APT, as well as the gas-cooled reactor, may lead to upsets in the natural flow of surface and ground water, in one commentor's opinion. The commentor contends that mitigation and monitoring will be extremely important to ensure that there is no potential for significant flow of contaminants into the construction area because of the extensive groundwater contamination already present at the site. Another commentor states that the tritium facility should not be located at SRS in order to preserve the quality of the Savannah River for drinking water. Response: The text in section 4.6.3.4 has been modified and clarified, so the reader will have a better understanding of the process of dewatering and mitigation measures that will be implemented during the process to ensure that there is no potential for significant flow of contaminants into the construction area. 04.02.10 Several commentors have serious concerns about the APT and its effect on water resources, especially at the dry sites. One commentor requests clarification of the GPY that the APT would require, as the number seems inflated. Additional commentors believe that DOE has overstated the water requirement for the natural gas-fired plant. One commentor notes that if treated wastewater is used for the APT, an assessment must be performed on the area to which the wastewater is currently discharging. Another commentor requests clarification on the term N/A for the APT closed loop system, i.e., if this means that the APT would not be located at a dry site. Response: The water requirements for the various technologies were provided by an independent engineering contractor, based on preconceptual designs. Until the technology and site location have been chosen, the numbers will remain generic to the technology and type of site (wet vs. dry). Future site-specific tiered NEPA documents will further analyze water requirements and their impacts. The APT is being considered for location at all five candidate sites. 04.02.11 Regarding section 4.4.2.4, page 4-186, 2nd paragraph, the commentor asks that DOE provide more detailed information on the flow of groundwater in the vicinity of the proposed TSS, identify sources of information used in the groundwater section, and clarify where the "class" of aquifers originated. Response: The text has been modified to add more detail on the flow of groundwater in the vicinity of the proposed TSS. The sources for the groundwater discussion in section 4.4.2.4 are DOE and the site documents cited in chapter 6. As of 1988, the sole source aquifer (SSA) program allowed individuals and organizations to petition the EPA to designate aquifers as the "sole or principal" source of drinking water for an area. The program was established under section 1424(e) of the Safe Drinking Water Act (SDWA) of 1974. The primary purpose of the designation is to provide EPA review of Federal financially assisted projects planned for the area to determine their potential for contaminating the aquifer. The EPA has developed a three-part classification system for the groundwaters of the United States: Class 1: Special Groundwaters are those that are highly vulnerable to contamination because of the hydrological characteristics of the areas under which they occur and that are also either an irreplaceable source of drinking water or ecologically vital in that they provide the base flow for a particularly sensitive ecological system. Class II: Current and Potential Sources of Drinking Water and Waters Having Other Beneficial Uses are all other groundwaters except Class III. Class III: Groundwaters Not Considered Potential Sources of Drinking Water and of Limited Beneficial Use because the salinity is greater than 10,000 mg/L or the groundwater is otherwise contaminated beyond levels that can be removed using methods reasonably employed in public water-supply treatment. The EPA uses this classification scheme in promulgating rules and regulations at the Federal level. The highest degree of protection is given to Class I groundwater. 04.02.12 The commentor is concerned about the groundwater contamination at SRS. The commentor states that tritium from the SRS has contaminated wells in Georgia. In addition, the commentor suggests that DOE must address this issue carefully and ensure that no further contamination occurs. Response: Groundwater contamination at SRS is a legacy of past waste disposal and operational activities. Groundwater Quality Assessment reports have been submitted to the State of Georgia for numerous years. There are no longer discharges of waste to groundwater under present operational discharge controls. All waste water is treated and discharges controlled by the permit process. The status of current operations is reported annually to the public in the SRS Environmental Report. Industrial solvents, metals, tritium, and other constituents used or generated on the site have contaminated the shallow aquifer beneath 5 to 10 percent of the site. These aquifers are not used for drinking water or for SRS operations; however, they do discharge to site streams and eventually to the Savannah River. During operations of a tritium supply and recycling facility, no direct discharges to groundwater will be made. All wastewater will be treated and then discharged to SRS streams. Discharges made to SRS streams that discharge to the Savannah River will be within NPDES permits and will comply with South Carolina Water Quality Standards. Currently there are several onsite and offsite remediation efforts being performed. 05 Geology and Soils 05.01 Commentors suggest that the PEIS for Tritium Supply and Recycling should address general seismic and volcanic effects on new facilities, as well as site-specific conditions, when selecting a site for the proposed activities. One commentor states that future nuclear testing at NTS could increase the seismic risk to any tritium facilities located there. Another commentor further states that INEL is located in an earthquake-prone zone and is not a safe place to site the proposed tritium facilities. Other commentors add that site-specific issues, such as proximity to capable faults, should be addressed in the PEIS. Response: Sections 4.2.2.5, 4.3.2.5, 4.4.2.5, 4.5.2.5, and 4.6.2.5 of the PEIS discuss geology and soils for the INEL, NTS, ORR, Pantex, and SRS sites, respectively. Issues such as volcanic hazard, seismicity, and proximity to capable faults were addressed in those sections. The five candidate sites are considered to have little or no volcanic hazard. As discussed in the summary of environmental impacts for each site (sections 4.2.3.5, 4.3.3.5, 4.4.3.5, 4.5.3.5, and 4.6.3.5), the seismic risks ranged from negligible to moderately low. The existence of a low or moderate seismic risk would not preclude the safe construction and operation of the proposed facilities at any of the sites. NTS and INEL are the only two sites where capable faults exist; however, no faults are directly located on the proposed location of the proposed TSS facility. No known capable faults were detected at the other sites, and for those areas ground shaking rather than ground rupture would be more likely. The proposed TSS facilities would be designed for earthquake generated ground acceleration in accordance with DOE Order 5480.28 and accompanying safety guides. 05.02 Commentors are of the opinion that seismicity and geology have been totally ignored in the PEIS and that Pantex is by far the superior site for the tritium production facility. The commentors categorize the following as advantages at Pantex: no evidence of active faults has been found at Pantex; seismic hazards are minimal; engineering load-bearing capacities of soils and ground sediments are superior to other candidate sites; Pantex has less than 7 percent land area designated as wetlands; the site may be excavated safely on steep, stable slopes; and it is suited for cut and cover construction. Response: Sections 4.2.2.5, 4.3.2.5, 4.4.2.5, 4.5.2.5, and 4.6.2.5 of the PEIS discuss seismicity, geology, and soils at all candidate sites. These factors identified by the commentor, as well as many others, will be considered and evaluated in the decision process leading to the selection of the tritium supply technology and the preferred site. 05.03 The commentor states that in terms of seismic-induced impacts, the PEIS failed to address the relationship between nuclear testing and tritium production at NTS. The commentor also states that although a moratorium on nuclear testing has been extended indefinitely, the Administration's current defense policy requires DOE to retain the capability to resume nuclear testing (The President's fiscal year 1996 includes $206 million to support the nuclear testing readiness program at NTS). Response: The PEIS did not address a relationship between nuclear testing and tritium production. Although underground testing was halted in 1992, NTS maintains the capability to resume testing if required. In terms of seismic-induced impacts, although NTS is located in an area of moderate historic seismicity as discussed in section 4.3.2.5, facility designs ensure no adverse effects. As described in section 4.3.3.5, facilities would be designed for earthquake-generated ground acceleration in accordance with DOE Order 5480.28 and accompanying safety guides. 05.04 The commentor states that in sections 4.5.2.5 and 4.5.3.5, geology and soils, the Draft PEIS correctly characterizes the soils that underlie Pantex as Pullman-Randall and characterized by "very low permeability clays and clay loams." The commentor also states that this fact greatly mitigates possible concerns (on page 4-305) about percolation to groundwater of treated wastewaters discharged to playas. The commentor asserts that DOE also correctly characterizes the seismicity of the Pantex area as low. However, the commentor notes that on page 4-278, one of the subject basins is incorrectly identified as the "Palo Verde Basin" rather than the "Palo Duro." Response: As discussed in section 4.5.3.4, reclaimed wastewater will be used to fulfill the water requirements for the construction and operation of any of the proposed tritium supply and recycling facilities at Pantex. Treated wastewater will be either recycled for cooling system makeup or discharged to the playas. Although there is no direct discharge to groundwater from the proposed facilities, treated sanitary wastewater discharged to the playas could percolate into the groundwater. Soils at Pantex, which are low permeability clay and clay loams, should help minimize the impacts associated with this possibility. In addition, a lined evaporation pond could be constructed to reduce wastewater seepage. Although permeability of these clays is low, the PEIS must consider percolation possibilities; therefore, any discharged wastewater would meet NPDES permit require- ments. In section 4.5.2.5 of the PEIS, the sentence has been changed to read: "Seismicity in the Palo Duro Basin and at Pantex is low". 05.05 Regarding page 4-385 of the Draft PEIS, the commentor states that the dewatering due to construction activities for the APT could be a significant problem, as could the potential spread of activation products in the soil. The commentor adds that should the APT design proceed, it is possible that the required underground depth may increase, resulting in further environmental impact. Response: As discussed in section 4.6.3.4 of the PEIS, dewatering due to construction activities of the APT could result in increases in stream flow and impacts to aquatic resources without proper mitigation. Dewatering discharge could be directed to Par Pond to prevent any impacts to Fourmile Branch. The potential for activation products to be spread through the soil is considered low. Section 4.6.3.5 of the PEIS discussed potential impacts to geology and soils from the proposed tritium supply and recycling facilities. The impacts associated with deep excavations for the APT technology would be evaluated in detail and potential mitigation measures identified in site-specific tiered NEPA studies. 05.06 Because of the seismic concerns, the commentor doubts that either a reactor technology or the linear accelerator concept could be located at NTS. Response: As discussed in section 4.3.3.5, the construction and operation of tritium supply and recycling facilities at NTS would have no impact on geological resources. The presence of a moderate seismic risk at NTS does not preclude the safe construction and operation of the tritium supply and recycling facility onsite. The proposed facilities would be designed for earthquake, and any potential weapons-testing-generated ground acceleration in accordance with DOE Order 5480.28 and accompanying safety guides. 05.07 The commentor states that seismic stability should be one of the criteria for site selection. The commentor considers the APT a more stable alternative. The commentor notes that APT has no waste production, therefore, in the event of an earthquake, wastes would not be released. The other alternatives are more vulnerable, according to the commentor. The commentor concludes that, compared to the other sites, NTS would be the best suited site because of lessened seismic activities. Response: Section 4.3.2.5 of the PEIS discusses seismicity, geology, and soils at NTS. These factors identified by the commentor, as well as many others, will be considered and evaluated in the discussion process leading to the selection of the tritium supply technology and the preferred site. 06 Biotic Resources 06.01 Commentors suggest that DOE carefully consider the potential impacts to area wildlife when selecting a site for the proposed activities. Commentors assert that special consideration should be given to sites such as Pantex that have several sensitive species and habitats. Response: An analysis of impacts on wildlife, including sensitive habitat and threatened and endangered species, is presented for each site. This analysis is presented for INEL in section 4.2.3.6, for NTS in section 4.3.3.6, for ORR in section 4.4.3.6, for Pantex in section 4.5.3.6, and for SRS in section 4.6.3.6. The analysis is presented at a programmatic level; however, since an analysis of project impacts on wildlife and sensitive habitats is dependent on a specific site location and detailed project engineering data, further analysis will be conducted at the site-specific level in tiered NEPA documentation. 06.02 One commentor suggests that the PEIS for Tritium Supply and Recycling incorrectly identifies the desert tortoise as an endangered species. The commentor states that the PEIS should correctly classify the desert tortoise as a threatened species. Another commentor notes that the executive summary indicates the bald eagle could lose nesting habitat. This is not accurate and should be changed in the Final PEIS, according to the commentor. Response: References are made to the desert tortoise as a threatened species in sections 3.6, 4.3.2.6, table C-3, and table I.1-1. No references to the tortoise as an endangered species are included in the PEIS. The executive summary states that the bald eagle may be temporarily affected during construction but does not state that nesting habitat would be lost. 06.03 The commentor states that the PEIS for Tritium Supply and Recycling asserts in a number of places that construction of a tritium facility would affect Federal-listed, Federal-candidate, or state-listed species, and could impact potential wetlands. More specifically, the commentor adds that pages I- 31, I-32, I-35, and I-37 of volume II reference possible impacts on the bald eagle, the swift fox, and other species. The commentor asserts that this claim fails to recognize that construction activities would occur well away from any of the Pantex playas (whose soils are inherently unsuited for construction), which are the only potential nesting, foraging, and denning habitat for these animals (e.g., no bald eagle nests or nesting pairs have ever been observed on site). The commentor states that the Pantex playas constitute but 5 out of approximately 25,000 playas on the southern High Plains, and cannot be considered as critical habitat. According to the commentor, personnel from the United States Fish and Wildlife Service (USFWS) declined to support classification of any of the Pantex playas as "critical habitat" during a site visit in 1994. Further, notes the commentor, only a small proportion of the site (less than 7 percent) is designated as "playa wetlands". The commentor cautions that any prudent site plan for tritium facility construction will avoid these areas. The commentor also suggests that these claims in the PEIS should be corrected. Response: The commentor indicates that the PEIS assertions that the construction of a tritium facility would affect Federal-listed, Federal-candidate, or state-listed species, and could impact potential wetlands at Pantex are not warranted. These statements are conditional descriptions of potential impacts. Section 4.5.2.6 states that field surveillance would be required to determine the presence of listed species. The bald eagle is described as a wintering species rather than a nesting species and it is well documented that eagles are easily disturbed by human presence even in close proximity to perched birds. It is further stated that there is no critical habitat on Pantex. The playas are natural drainage areas for the Pantex site and the discharge resulting from project activities could alter the nature of these wetlands. Because an analysis of project impacts on biological resources is sensitive to specific site location and detailed project engineering data, further analysis will be conducted at the site-specific level in tiered NEPA documentation. 06.04 The commentor states that the PEIS for Tritium Supply and Recycling does not provide a complete analysis of the impacts of the various alternatives on biotic resources. The commentor also states that it is unacceptable not to evaluate the impacts of radionuclides for onsite and offsite biota. Response: An analysis of impacts to biological resources is presented for each site at a programmatic level. This analysis is presented for INEL in section 4.2.3.6, for NTS in section 4.3.3.6, for ORR in section 4.4.3.6, for Pantex in section 4.5.3.6, and for SRS in section 4.6.3.6. Because an analysis of project impacts on biological resources is sensitive to a specific site location and detailed project engineering data, further analysis will be conducted at the site-specific level in tiered NEPA documentation. 06.05 One commentor states that siting the tritium program at Pantex would not further threaten or endanger protected species. The commentor indicates that the PEIS notes on page 4-279 that no critical habitat for threatened and endangered species exists on Pantex, and on page 4-280 that there is little undisturbed habitat at Pantex that would accommodate any of the threatened, endangered, and other special status species listed in table 4.5.2.6-1. The PEIS also reports there are no Federal- or state-listed plant species known to occur at Pantex. The commentor states that individual animals (for instance, slow moving reptiles or small mammals) might be taken by construction activities but even this possibility could be avoided (by surveys and by capture and transplantation) if deemed appropriate. According to the commentor, the only consistently occurring Federal-listed species at the Pantex site is the bald eagle. The commentor notes that the eagle is highly mobile and the playa habitat it has used at Pantex is abundant nearby and common throughout a great region. The commentor asserts that neither construction nor operation of the tritium program would be expected to adversely affect the species. The commentor notes that a representative of a second Federal-listed species, the whooping crane, was reported at the site in 1990, as the draft relates. The rarity of occurrence of the species on the site mitigates concern that it may be harmed by the program. Relative to aquatic species, the commentor notes that it appears the only effect of siting at Pantex would be positive (e.g., some small increase in the availability of habitat for amphibians (page 4- 309)). Finally, another commentor points out that the terminology for some of the endangered species is printed in bold print for the Pantex data only. The commentor also states that there is also a grossly inaccurate statement in the PEIS on the foraging and denning habitats concerning bald eagles and other animals that roam the Pantex site. There will be no impacts to them, according to the commentor. Response: The terminology in bold print was not located in the document. Because an analysis of project impacts on biological resources is sensitive to specific site location and detailed project engineering data, further analysis will be conducted at the site-specific level in tiered NEPA documentation. Field surveillance would be conducted at that time to determine the presence of species and their foraging, denning, and nesting habitats. 06.06 The commentor states that DOE should give more thought to the effects of the proposed facility on biotic resources. According to the commentor, the document states that impacts to wetland and aquatic resources will not occur because these resources are not located on project sites. The commentor adds that the conclusion that impacts will not occur may be incorrect because impacted onsite groundwater may flow offsite and may affect biotic resources. Furthermore, the commentor notes on page 4-139, the PEIS states that because impacts from construction occur only at the beginning of the project life cycle, it follows that impacts to biotic resources will be limited to only that time period. The commentor asserts that this may not be true and suggests that DOE revisit the biotic resources sections. Response: An analysis of impacts to biological resources is presented for each site at a programmatic level. This analysis is presented for INEL in section 4.2.3.6, for NTS in section 4.3.3.6, for ORR in section 4.4.3.6, for Pantex in section 4.5.3.6, and for SRS in section 4.6.3.6. Because an analysis of project impacts on biological resources is sensitive to a specific site location and detailed project engineering data, further analysis will be conducted at the site-specific level in tiered NEPA documentation. Onsite impacts to wetlands and aquatic resources at INEL and NTS were not predicted based on the fact that these resources do not occur on the proposed TSS. Impacts are also not expected to wetlands and aquatic resources located offsite since groundwater withdrawals are not expected to impact groundwater recharge rates at either INEL (section 4.2.3.4) or NTS (section 4.3.3.4). With respect to construction impacts occurring only at the beginning of the project life cycle, the statement made in section 4.3.3.6 referred specifically to the fact that all construction associated with the HWR, MHTGR, and ALWR would only occur at the beginning of the project but that additional construction (and hence construction impacts) could occur at a later date, as in the case of the APT if expansion of the facility were needed to meet future tritium requirements. 06.07 Regarding section 4.4.3.6, page 4-224, first column, third paragraph, the commentor suggests that DOE provide information regarding the relationship between the number of threatened and endangered species at a proposed site and the ranking of the site in the selection process. For example, the commentor asks if a site has the potential to displace more threatened or endangered species than another site, is it ranked lower in the site selection process. Response: The function of the PEIS is to assess the potential environmental impacts resulting from the proposed tritium supply technologies and recycling facilities. The potential impacts on threatened and endangered species are identified in the PEIS. Environmental, cost, technical, and schedule factors are all considered in the siting decision process. The tritium supply and recycling site selection process will involve analysis of the environmental, cost, technological and schedule impacts which will be considered by the decision maker. 06.08 In table 3.6-1, page 3-62, the ORR column, the phrase, "however this type of habitat is abundant in the area," should be removed, according to the commentor. The commentor asserts that this phrase appears to lessen the environmental impact of removing several hundred acres of nesting and foraging habitat for four state-listed raptors. Response: The appropriate changes have been incorporated into table 3.6-1 in the Final PEIS. 06.09 The PEIS notes that no impact to biotic resources will result from supply and recycling activities, according to the commentor. For example, the commentor states that on page 4-64 the PEIS states, "...the Townsend's western big-eared bat could forage at evaporation and stormwater retention ponds. No adverse impacts are expected...." The commentor asserts that this statement is not supported by any factual data. Furthermore, the commentor notes that although no state biotic resource consultation was identified for INEL in table 5.3-4, DOE should confer with the appropriate state authorities to minimize impacts. Response: As a programmatic document, the PEIS discusses potential impacts and the relative level of impacts. Because an analysis of project impacts on biological resources is sensitive to specific site location and detailed project engineering data, further analysis will be conducted at the site-specific level in tiered NEPA documentation. Consultation with the Federal and state wildlife offices would be performed during the preparation of this level of NEPA documentation. 06.10 One commentor states that in volume I, page 4-7, column 2, paragraph 3, the PEIS explains that radiological impacts to onsite biota were not evaluated because studies conducted at INEL have only detected sublethal effects in individual animals. The commentor asserts that the fact that past activities have not caused radionuclide levels of concern in animals is no indication that biota are not at risk. The commentor notes that the impacts of the proposed tritium alternatives must be evaluated in conjunction with potential releases from existing and proposed facilities, including the impacts from tritium releases into waters that may already have measurable amounts of tritium. For another, the commentor adds, the many studies conducted at INEL have shown elevated levels of radionuclides in the tissues of plants and animals at the site. In order to determine that the PEIS does not need to evaluate impacts on biota, there needs to be a more thorough discussion of the findings of studies done at INEL, according to the commentor. In addition, states the commentor, it must be shown that, cumulatively, tritium releases will not have a significant impact. Another commentor suggests that the PEIS provide details of biological and environmental impacts associated with introducing tritium from proposed TSS operations into waters that already have measurable amounts of tritium. Response: As noted in section 4.1.6, two studies have shown that man is the most sensitive organism to radiation (Radiation Biology (U.S. Atomic Energy Commission, 1968) and The Effects on Populations of Exposure to Low Levels of Ionizing Radiation (National Academy of Sciences, 1972)). In addition, the Environmental Standard Review Plans for the Environmental Review of Construction Permit Applications for Nuclear Power Plant, (NUREG-0555), notes that, "although guidelines have not been established for acceptance limits for radiation exposure to species other that man, it is generally agreed that the limits established for humans are also conservative for other species." Information presented relative to INEL recognizes that measurable effects of radionuclides on indi- vidual plants and animals have occurred, but that such effects at the population, community, or ecosystem level have not been detected. A more complete discussion of these findings can be found in the Programmatic Spent Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental Restoration and Waste Management Programs Final Environmental Impact Statement (DOE/EIS-0203-F, April 1995). With respect to cumulative effects of existing radionuclide levels and those emitted from the proposed facilities, the second sentence of the third paragraph of section 4.1.6 has been changed to correctly state, "these releases when added to those associated with other site activities would be well below natural background levels and would also be within regulatory limits established to protect workers and the public." It is not believed that further discussion of radiological impacts to biota is necessary for this programmatic document. 06.11 The commentor notes that, as a newly constructed facility, a tritium recycling operation would require radionuclide National Emission Standards for Hazardous Air Pollutants (NESHAP) approval by EPA. If applicable to the site, the commentor notes that EPA would evaluate the Endangered Species Act as a part of its radionuclide NESHAP decision-making process; that is, EPA would assess whether radioactive emissions permitted under a NESHAP authority would adversely affect any listed species under the Endangered Species Act. As a part of the determination, the commentor states that EPA would consult with the USFWS pursuant to section 7 of the Endangered Species Act. In addition, the commentor also suggests that should DOE also need to consult with the USFWS, EPA is willing to work with DOE on a joint consultation effort. Response: DOE will consult with the USFWS concerning any impacts to threatened and endangered species that may occur as a result of constructing and operating a tritium supply and recycling facility, including potential impacts from radionuclides. This consultation would take place at the site-specific level in tiered NEPA documentation. This is necessary since preactivity surveys are necessary to determine if any special status species are present and their location relative to the proposed facility. DOE will make sure that all required permits are obtained and that all required consultations are conducted. 06.12 Regarding section 4.4.3.6, page 4-226, first column, second paragraph, the commentor suggests that DOE provide details of the effect of sediment mobilization and changes in aquatic resources on CERCLA operable units in the area of the proposed TSS. Response: A discussion of the relationship between impacts to aquatic resources from the proposed tritium supply and recycling facility and CERCLA operable units is beyond the scope of the PEIS. If ORR is selected as the site for a tritium production facility, more detailed design, siting location information, and additional detailed project data would be developed and available to discuss any relationship between the proposed action and ORR CERCLA operable units. The analysis, if warranted, would be discussed in site-specific tiered NEPA documentation. 06.13 The commentor believes that DOE overstates the environmental concern regarding the Pantex playas (sections 4.5.2.6 and 4.5.3.6). The commentor points out that there are an estimated 20,000 to 30,000 playas in the surrounding area whose sizes grow and diminish on a seasonal basis. The commentor states that the playas all support the same, or highly similar, plant and wildlife communities, and typically provide domestic livestock watering places as well. Furthermore, the commentor notes that wastewater discharge to the playas would not necessarily "cause a general degradation of the naturally occurring ephemeral wetland system at Pantex." In fact, the commentor suggests that the permanence of the playas in certain years may be "important to migratory birds and... valuable habitat for nesting and wintering birds and waterfowl." Regarding statements on page 4-307 about an increase in open water habitat and on page 4-309 about shifts in the composition of wetland plant communities, the commentor suggests that DOE consider that it is the nature of playas to undergo temporary depth changes and limited increases and decreases in open water areas. The plant species have adapted to such changes, which have occurred down through the centuries (for example, following major thunderstorms or long, rainy seasons or droughts). Such changes do not "disturb" playa plant communities. Given the great commonality of habitats provided by the great numbers of playas and the fact that wastewater discharges would create changes in degree, not in kind, the commentor asserts that there is little practical reason for environmental concern about the Pantex playas. Response: While the commentor is correct in stating that a large number of playas occur in the area of Pantex, many have been converted to agricultural use. An important aspect of those occurring on the Pantex site is that, except for Playa 1, they are in a relatively natural state and are within a protected area (that is, the Pantex site boundary). The commentor is also correct in stating that playa vegetation has adapted to seasonal changes in water levels; however, existing vegetation would not be able to adapt to permanent inundation caused by wastewater discharges. The results would be a shift in plant communities toward those that are adapted to permanent inundation. In fact, natural plant communities in Playa 1 have been displaced by a nearly uniform stand of cattail, a plant adapted to inundation. The analysis in the PEIS is presented at a programmatic level and is intended to identify potential impacts which could occur as a result of constructing new tritium supply and recycling facilities. A more detailed analysis of potential impacts to site playas will be undertaken as part of a site-specific EIS if Pantex is selected as the site for the proposed facilities. 06.14 In the PEIS, volume II, table C-3, under the plant section, the commentor states that: Amargosa Penstemon should be Penstemon fruticiformis ssp. amargosae and that Kingston bedstraw should be Galium hilendiae var. kinstonense. Response: In 50 CFR Part 17, Plant Taxa for listing as Endangered or Threatened Species, Notice of Review dated September 30, 1993, Amargosa Penstemon is listed as Penstemon fruticiformis var. amargosae, and Kingston bedstraw is listed as Galium hilendiae ssp. kinstonense. The appropriate changes have been made to the document. 06.15 The commentor states that DOE should indicate in the PEIS any records documenting the existence of Parish's phacelia (Phacelia parishii) at NTS. The commentor adds that it has been recently added to the Federal candidate plant species list. Response: The appropriate changes have been made to the document. 06.16 The commentor states that SRS has a wildlife population that is within one of the largest research sites in the United States. The commentor asserts that in order to preserve and maintain this wildlife, SRS needs to assume another mission, preferably the proposed Tritium Supply and Recycling Program. Continuation of DOE missions will ensure that the surrounding wildlife remains intact, according to the commentor. Response: Impacts of the proposed facilities on wildlife at SRS are discussed in section 4.6.3.6. The continuation of wildlife management and research programs, such as controlled hunts and National Environmental Research Parks projects, are not directly dependent upon the selection of the site for the proposed facilities. 06.17 One commentor urges a more even-handed and consistent analysis of biotic resources in the executive summary and the PEIS. In addition, the commentor further notes that there are subtle discrepancies in the analysis between the sites, and Pantex is unfairly penalized due to the use of biased language. The commentor suggests that DOE check these sections for unnecessary bias and use consistent terminology and language. Another commentor suggests that table 3.6-1 list threatened and endangered species for each candidate site with at least the specificity found in the Pantex column. Response: The commentor suggests that the PEIS is written with a preconceived bias against Pantex and recommends the use of more consistent terminology and language in the executive summary, table 3.6-1, and site analysis of biotic resources in the PEIS. The entire PEIS including the biotic resources sections of the PEIS was prepared and peer reviewed without bias. 07 Cultural and Paleontological 07.01 The commentor expresses concern that the undertaking may affect historic properties eligible for listing in the National Register of Historic Places (NRHP) at ORR. The commentor expresses the desire to review a cultural resources survey report for the area, in addition to DOE's assessment of the existence of historic properties within the area, and DOE's assessment of potential for project impact upon cultural resources for this project before any work commences. Response: Historic properties that are potentially eligible for inclusion on the NRHP may be affected, and are discussed in sections 4.4.2.7 and 4.4.3.7. If ORR is chosen as the preferred site, a site-specific tiered NEPA document will include a discussion of impacts to prehistoric and historic sites. In addition, if ORR is the preferred site, National Historic Preservation Act (NHPA) section 106 would require a cultural resources survey of any impacted acreage and a report of survey results. Cultural resources survey reports for ORR are available through DOE. 07.02 The commentor states that a more even-handed and consistent analysis of cultural resources in the executive summary and the PEIS is needed. According to the commentor, there are subtle discrepancies in the analysis between the sites, and Pantex is unfairly penalized due to the use of biased language. The commentor asserts that DOE should check these sections for unnecessary bias and use consistent terminology and language. Response: These sections were reexamined for any biases in the way the information was presented. The language is similar among the different site descriptions in the PEIS and in the Executive Summary. 07.03 The commentor references Native American resources text, under the Historic Resources section, and states that the PEIS neglects to include Native American resources when discussing compliance with Sections 106 and 110 of the NHPA, regarding the updating of the buildings and the decontamination and decommission (D&D) actions on these buildings and any historical properties. The commentor notes that the Native American resources are absent from the same 106 requirements, as specified in the PEIS, and it is only regarding the NEPA document. However, according to the commentor, other Federal laws are requiring consultation between the Federal Government and the tribal governments as mandated. In addition, the commentor references the last paragraph on page 4-9, regarding the Native American resources, and asserts that the language regarding the Native American resources does not apply the appropriate criteria. The commentor notes that the PEIS acknowledges only the Native American physical environment and belief systems; however, the issues go much deeper and are not being reflected within this document being provided for comment. Response: "Prehistoric resources" in the United States refers only to remains of Native Americans and their antecedents. "Historic Resources" includes remains of all groups, whether of European, African, Asian, Native American, or any other descent. Both historic and prehistoric resources are protected under NHPA Sections 106 and 110. Other relevant laws regarding tribal resources (American Indian Religious Freedom Act, Native American Graves Protection and Repatriation Act) are described in table 5.3-1. Impacts to land and water resources and other natural resources, which can also be considered to be Native American concerns, are discussed in the other chapter 4 sections (for example, in sections 4.2.2, 4.2.2.1, land resources; 4.2.2.2, site infrastructure; 4.2.2.3, air quality and acoustics; 4.2.2.4, water resources; 4.2.2.5, geology and soils; 4.2.2.6, biotic resources; 4.2.2.8, socioeconomics; and 4.2.2.9, radiation and hazardous chemical environment). More details can also be found in the appendixes. The following text change has been made to section 4.1.7: "In addition, cultural values are placed on natural resources such as plants, which have multiple purposes within various Native American groups." Section 4.3.2.7 now includes: "It is worth noting that many natural resources at NTS are viewed as cultural resources by Native Americans. As one example, sagebrush is used as a tool, and for clothing and medicinal purposes." 07.04 The commentor references page 4-311 of the Draft PEIS and questions if "would" in the sentence "Some Native American (archaeological) resources would occur in Pantex site areas" should read "could." Response: The referenced sentence has been changed to "Some Native American resources could occur within any areas disturbed..." 07.05 The commentor concurs that there exists a possibility of undiscovered cultural and paleontological resources at Pantex that might be affected by construction of a tritium supply and recycling facility. The commentor also concurs that such resources could be protected by typical mitigation measures. Response: Potential cultural and paleontological resources at Pantex are discussed in section 4.5.2.7. If known cultural and paleontological resources at Pantex (or at any other selected site) are within areas subject to potential impact, DOE would protect the resources to the extent possible, first through avoidance of the resources, and second, through mitigation of impacts. The possibility of undiscovered cultural and paleontological resources is always a consideration. Site-specific cultural resources analyses would be conducted as part of a subsequent, tiered EIS. In onsite areas having a high probability for cultural resource discoveries, measures that can be taken to minimize potential impacts include employment of an archaeological monitor during construction and stopping work in the event of an unforeseen discovery. 08 Socioeconomics 08.01 The commentor suggests that DOE address in the PEIS the quality of jobs and benefits that will be created as a result of a new tritium facility. The commentor also states that DOE should include a comparison of the types of jobs that were associated with various cleanup activities at INEL with more complex and higher technology projects that would be associated with a new tritium facility. Response: Labor categories (types of jobs) were considered in the socioeconomic analysis, but were not specifically identified in the Draft PEIS. Instead, only total worker years were analyzed and compared. More detailed information on the labor categories involved is contained in the Technical Reference Report available in DOE reading rooms. Specific socioeconomic impacts will also be further considered in site-specific tiered NEPA documents. 08.02 Several commentors express their support for this action in the NTS region. The commentors believe the project will increase the growth of the scientific community and science/technology related business; reinvigorate the area economy and tax base; stimulate light industry development in Las Vegas; and provide highly skilled technical and management positions to experienced craftsman, technicians, and scientists who may have lost jobs during the phaseout at NTS. One commentor also notes that there will be a lot of public support if DOE can assure the public that tritium transportation and production will be fairly safe. Another commentor states that NTS already has the available land, skilled craftsmen, technicians, and scientists to support the tritium supply and recycling facility. One commentor suggests that siting the tritium supply and recycling facility at NTS can improve DOE's image within the community by working together to contribute to the positive growth of the community and its economy. Another commentor, expanding upon the idea that locating the tritium supply and recycling facility at NTS helps the community, states that NTS has been good to minority workers providing much needed training and experience. According to the commentor, NTS contributes a solid education for the workers and prepares them for other responsibilities and tasks. Another commentor believes that DOE has spent too much time on waste disposal capabilities, and suggests that DOE recognize the high-technology security work force as a valuable resource for stockpile stewardship and management activities. Response: The attributes of NTS as well as each of the other four sites considered for siting the tritium supply and recycling facility would be included as part of the decision making process. However, the PEIS considers these site factors only as they relate to evaluating the environmental impacts of the tritium supply and recycling facility at each site. In addition, transportation analyses were performed for all materials considered in the PEIS, and risks were found to be low. Other DOE programs, including those evaluating stockpile stewardship and management activities, will also evaluate these candidate sites in accordance with NEPA and take socioeconomic factors into consideration. 08.03 Several commentors state that DOE should review the socioeconomic analysis to incorporate the following: that construction jobs will only be temporary; scientists and skilled workers will be drawn to NTS because of the new facility; there are potential job losses in regions that are not awarded the Tritium Supply and Recycling Program; a review of the accuracy of the projected employment figures as new jobs may be staffed by former employees of shutdown DOE facilities; an analysis of jobs that will be created at facilities supporting the planning and engineering studies necessary for the tritium supply and recycling facility such as at Los Alamos; the need for skilled workers created by the new facility compared with the pool of skilled workers in each site's surrounding area; transportation, electrical, water, and other environmental impacts from out-of-region people who move to the area to work at Pantex; and the potential spawning of new production or fabrication facilities to support the tritium supply and recycling facility and its operation. Response: The PEIS identifies that construction jobs are temporary. The increase in construction jobs, the peak, and the decrease in construction jobs for each tritium supply technology at each candidate site have been analyzed and are presented in the PEIS. The PEIS also assesses the potential impacts caused by newly created jobs which lead to an in-migration. Labor availability is taken into ac