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

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

Section I Environmental Assessments

EXECUTIVE SUMMARY

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

1.0 INTRODUCTION AND BACKGROUND

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

2.0 PURPOSE AND NEED FOR THE PROPOSED ACTION

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

3.0 PROPOSED ACTION

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

4.0 ALTERNATIVES TO THE PROPOSED ACTION

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

4.1 No-Action

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

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

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

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

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

4.4 Interim Storage at a Department of Defense Facility

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

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

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

5.0 EXISTING ENVIRONMENT

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

5.1 Environment

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

5.2 Radiological Environment

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

6.0 ENVIRONMENTAL IMPACTS

6.1 Routine Operating Conditions

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

6.1.1 Radiological Impacts

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

6.1.1.1 Radiological Exposure to Workers Associated with the Proposed Action

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

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

6.1.1.2 Radiological Impacts Associated with the No-Action Alternative

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

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

6.1.2 Radiological Exposure to Public

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

6.1.3 Cumulative Impacts for the Proposed Action

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

6.2 Abnormal Events/Accidents Associated with the Proposed Action

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

6.2.1 Screening of Potential Accident Initiating Events

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

6.2.2 Potential Blast Hazards

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

6.2.3 Structural Analysis

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

6.2.4 Forklift Operational Accident

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

6.2.5 Aircraft Hazard Analysis

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

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

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

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

7.0 POTENTIAL IMPACTS ON THE OGALLALA AQUIFER

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

8.0 EXTERNAL AGENCY AND STAKEHOLDER INVOLVEMENT

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

9.0 REFERENCES

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

APPENDIX A
SCREENING OF POTENTIAL ACCIDENT-INITIATING EVENTS

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

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

APPENDIX B
BLAST CALCULATIONS

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

B.1 ADJACENT EXPLOSION PRESSURE EFFECTS

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

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

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

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

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

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

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

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

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

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

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

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

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

B.2 QUANTITY-DISTANCE CALCULATIONS

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

B.3 DEFINITION OF MAXIMUM CREDIBLE EXPLOSION MISSILE

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

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

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

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

B.4 REFERENCES

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

APPENDIX C
STRUCTURAL ANALYSIS SUMMARY

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

C.1 DESCRIPTION OF ZONE 4 MAGAZINES

C.1.1 Modified-Richmond Magazines

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

C.1.2 Steel Arch Construction Magazines

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

C.1.3 Earth Overburden

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

C.2 DEFINITION OF DESIGN BASIS AND MAXIMUM CREDIBLE EVENTS

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

C.3 EARTHQUAKE ANALYSIS


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

C.3.1 Static Analysis

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

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

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

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

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

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

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

C.3.2 Dynamic Analysis

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

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

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

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

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

C.4 EXTERNAL EXPLOSION ANALYSIS

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

C.4.1 Modified-Richmond Magazine

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

C.4.2 Steel Arch Construction Magazine

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

C.5 EXPLOSION-GENERATED MISSILE ANALYSIS

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

C.6 TORNADO ANALYSIS

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

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

C.7 TORNADO-GENERATED MISSILES

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

C.8 AIRCRAFT IMPACT ACCIDENTS

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

C.8.1 Modified-Richmond Single Degree of Freedom

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

C.8.2 Impact on Steel Arch Construction Magazine

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

C.8.3 Impact on Concrete Barriers

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

C.8.4 Conclusions

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

C.9 REFERENCES

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

APPENDIX D
FORKLIFT OPERATIONAL ACCIDENTS

D.1 FORKLIFT ACCIDENT

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

D.2 SUMMARY OF POTENTIAL EFFECTS

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

D.3 REFERENCES

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

APPENDIX E
AIRCRAFT HAZARD ANALYSIS

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

E.1 BACKGROUND

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

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

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

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

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

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

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

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

E.2 ESTIMATION OF AIRCRAFT CRASH PROBABILITY

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

E.2.1 Estimation of the Impact Area

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

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

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

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

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

E.2.3 Estimation of Aircraft Crash Probability

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

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

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

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

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

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

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

E.3 REFERENCES

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

APPENDIX F
WORKER RADIATION EXPOSURE

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

F.1 DESCRIPTION OF OPERATIONS

F.1.1 Inventory

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

F.1.2 Pit Evaluation

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

F.1.3 Corrosion Inspection

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

F.1.4 Miscellaneous Operations

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

F.2 MAGAZINE CAPACITIES

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

F.3 RADIATION EXPOSURE

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

F.3.1 Modeling

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

F.3.2 Results of MCNP4 Calculations

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

F.3.3 Other Radiation Dose Rates

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

F.4 CALCULATIONS

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

F.4.1 Proposed Action Calculations

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

F.4.2 No Action Calculations

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

F.5 CONCLUSIONS

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

F.6 REFERENCES

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

Section II Response to Comments Pre-Approval Environmental Assessment

EXECUTIVE SUMMARY

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

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

Part A

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

Part B

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

Part C

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

Part D

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.1) FOLLOWS.
Document #: 1011 Comment #: 9 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
Even if no environmental contamination occurs, will increased operations at Pantex require excessive water use,
thus contributing to depletion (mining) of the Ogallala Aquifer?
Document #: 1015 Comment #: 18 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Despite claims by director Steve Walton of the AEDC that vast amounats (sic) of water exist for use by industry,
such is not the case. Even now, the Canadian River Municipal Water Authority is purchasing Southwestern Public
Service Co.'s water rights in Roberts Countay (sic) to provide adequate water for its southernmost customers.
Document #: 1016 Comment #: 13 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Are they planning a reprocessing facility at the Pantex site? The amount of water available will not be sufficient for
this.
Document #: 1017 Comment #: 21 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
I don't think there is enough water available for reprocessing in this area. Amarillo has drilled at least 7 dry holes in
their water field in northern Potter County. The Carson County field where the city is now pumping its water is
rapidly declining. Our static level in our walls had dropped four feet this past year and at least one of the Amarillo
wells dropped 12 feet.
Response #: D.1
The proposed interim storage activity is not expected to require any
additional water use at Pantex Plant. The water used at Pantex Plant
is a mixture of water from the Ogallala Aquifer and Lake Meredith.
These are the same sources which are used by the City of Amarillo.
Water usage at the Pantex Plant during calendar year 1992 was as
follows:
Total pumped 750,121 gpd
Pantex Plant Operations 550,091 gpd
Texas Tech Research Farms 200,030 gpd
Depletion of the Ogallala Aquifer would not be accelerated due to the
proposed action covered by the Environmental Assessment.
gpd = gallons per day
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.2) FOLLOWS.
Document #: 1011 Comment #: 10 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
Has the Texas Water Commission been duly advised of the potential risks to surface water and groundwater
resources?
Response #: D.2
Pantex Plant has cooperated fully with the several state regulatory agencies having
cognizance over risks to surface water and groundwater resources. These include not only
the Texas Water Commission, but also the Bureau of Radiation Control of the Texas
Department of Health. Both of these organizations as well as the Texas Air Control Board and
the Division of Emergency Management of the Texas Department of Public Safety have been
provided the opportunity to review and comment upon the subject Environmental Assessment.
In addition, as part of the Agreement in Principle between the State of Texas and the
Department of Energy, the Texas Air Control Board is conducting site-wide air dispersion
modeling and collecting and analyzing ambient air samples collected from inside Pantex Plant.
The Bureau of Radiation Control of the Texas Department of Health has conducted
radiological monitoring at both on-site and off-site locations since the early 1980's. None of
the measurements performed by the various state regulatory agencies has indicated that
emissions in excess of regulatory limits have occurred. These regulatory limits are set at
levels several orders of magnitude below those known to present significant health hazards or
risks to the environment. Thus the risks have been reviewed and determined to be negligible.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.3) FOLLOWS.
Document #: 1012 Comment #: 1 Date: 1/16/93
Margie K. Hazlett (1)
Citizen Comments
Comment:
On Thursday, July 25, 1991, The Environmental Protection Agency added the Pantex Weapons Plant to a list
of hazardous waste sites posing the greatest threat to human health and our environment. Pantex was one of 22
sites nationwide that the Environmental Protection Agency proposed adding to its Superfund National Priorities
List. ... The total number of sites nationwide that were targeted for cleanup were one thousand, two hundred and
eleven. Pantex was quickly removed from the list, unjustly so, and remained a hazardous waste site posing a
threat to our health and welfare in this area.
Document #: 1015 Comment #: 2 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Page 1-1: The statement that PX has conducted its activities in a safe and responsible manner belies the facts of
... eligibility for being considered as a Superfund site, and pollutants existing in the soil to a depth of 329 feet-a
scant 40 feet above the Ogallala aquifer.
Document #: 1048 Comment #: 4 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
"The Pantex Plant has conducted these activities in a safe and reasonable fashion for more than 40 years" (1-1)
the SAR's, the GAO Report, the Tiger Team, the Adhearn (sic) Committee Report - are all these reports in error?
Pantex has been nominated for a Superfund site, is this because the activities have been conducted safely and
reasonable? Why is ER/WM now being addressed at Pantex if the above statement is true.
Document #: 1048 Comment #: 5 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
In a statement made by Lowell F. Cranfill, President/Chief Steward, Metal Trades Council, Mason & Hanger, May
17, 1989, before the Subcommittee on Health and Safety, Committee on Education & Labor, U.S. House of
Representatives, he states "I am very seriously concerned with the health and welfare of my friends and members
of my union working at the Plant. I am also concerned with the Panhandle of Texas and the potential problems
they may have in that area due to the toxic waste (sic) that are accumulating because of the spills and dumps from
Pantex. I know that the Energy Department estimate last June was in excess of 700 million dollars to clear up the
Pantex Plant. I do not know what the spills and dumps consist of. I solicit your aid in trying to find that out and
help us clear up the plant. It is a serious and dangerous hazardous waste dump if that amount of money is to be
spent in trying to clear it up. I would like to be involved in stopping the things that Pantex is doing that is causing
the need for such expenditure."
Response #: D.3
The statement made by the Department regarding the activities conducted at Pantex Plant in
safe and reasonable manner for over 40 years refers to the overall health and safety record of
the plant. Since nuclear weapons operations have begun at Pantex Plant, there have been no
accidents involving nuclear weapons which have caused impacts off-site. Some accidents
involving the processing of high explosives and radiological contamination of some work areas
have occurred, however.
Environmental restoration activities are currently underway at the Pantex Plant. The
Department is working with the Texas Water Commission under the Resource Conservation
and Recovery Act to develop plans for investigation and remediation of contaminated sites.
These sites include construction landfills, locations which contained leaking underground
storage tanks, and an old sewage treatment plant and contain common industrial
contaminants such as lead, chromium, dioxin, and gasoline by-products that are now more
stringently regulated by state and federal government than in the past. In addition, the
Environmental Restoration program at Pantex Plant has funding set aside for interim corrective
action measures. If it is found through the investigation portion of the program that there is an
imminent danger to the environment, this funding would be used to start remediation actions
immediately to prevent further contamination of the environment.
The consideration of Pantex Plant as a Superfund site is in accordance with the requirement of
the Comprehensive Environmental Response, Compensation and Liability Act, Section 120(a).
Under this Act, all Federal facilities are subject to consideration as Superfund sites. The
Environmental Protection Agency proposed Pantex Plant for placement on the National Priority
List on July 24, 1991 based upon the hazard ranking scores. In September 1991, the
Department submitted comments to the Environmental Protection Agency regarding the
methods and calculations used to derive the hazards ranking score. The Department's
comments are still under review by the Environmental Protection Agency and no final
determination has been made regarding the final listing of Pantex Plant on the National Priority
List.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.4) FOLLOWS.
Document #: 1015 Comment #: 6 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg 4-5: Storage capacity at PX would be reached by the 4th quarter of `93 to the 2nd quarter of `94. The AEDC
has offered $5.5 million for additional land purchases to be deeded to the DOE-how (sic) many families might this
affect? This has come about after it was stated that no additional land would be needed for PX expansion.
Response #: D.4
The purchase of additional land for $5.5 million does not pertain to the pit storage in Zone 4.
The Department of Energy and the Amarillo Economic Development Committee submitted the
joint proposal referenced in the comment. This land, currently leased from Texas Tech
University by the Department of Energy, is used as an additional security buffer zone along
the southwest boundary of the site. It will not involve the purchase of land from the public.
This land may be used to provide additional space between public lands and Pantex Plant,
support present or future needs for expansion, relocate support facilities, and allow security to
better isolate personnel traffic from the highly secured areas of Pantex Plant.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.5) FOLLOWS.
Document #: 1016 Comment #: 19 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Also, section 5.1 states that surface runoff flows into several playa lakes on the site. Runoff also comes out of the
plant on the north into the barrow ditches that drain into the Pratt lake one-half mile to the north of the plant. Pratt
lake also catches lots of water running down the draw by the old sewage plant. Debris is often caught on the
barbed wire fence in the draw.
Response #: D.5
The Environmental Assessment describes the usual surface hydrology at Pantex Plant. The
individual is correct in noting that unusual conditions (i.e., mechanical failure coupled with
intense precipitation events) have resulted in storm water runoff from the extreme northeast
section of Pantex Plant toward the playa lake located north of the site. In any event, storm
water flows from Zone 4 are not involved and are contained onsite in Playa One.
Pantex Plant has developed drainage systems to divert the rainwater runoff onto playas
located on-site. This collection system includes a collection pit and return pumping system
located in the northeast corner of Pantex Plant.
This location is regularly sampled by Pantex Plant Environmental Monitoring personnel to
monitor water quality and to identify any problems should they exist. Additional water samples
are collected and analyzed to ensure water quality and protection of the public. Automatic
sampling devices are assigned to collect samples at this location in the event of a storm.
Environmental sampling data from this location, as well as others, are reported to the Texas
Water Commission and become public records.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 5.1 on page 5-1 has been changed to reflect the comments.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.6) FOLLOWS.
Document #: 1042 Comment #: 47 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
14. Page 6-1. The statement that "routine operations of the No-Action Alternative are similar to those for the
proposed action" would appear to be false and is at odds with other statements in the draft EA about worker
exposure impacts. Even for non-radiological impacts, common warehouse/industrial accidents and injuries will be
higher with the proposed action than with no action.
Response #: D.6
The complete statement in the Environmental Assessment is "Routine operations of the No-
Action Alternative are similar to those for the proposed action, differing only in the quantity of
materials held and number of magazines authorized for pit storage". This statement
addresses the type of operations, which are essentially the same in either case (the storing
and inspecting of pits). The referenced statement does not address, nor is it intended to
address, the resulting impacts from the number of pits stored and the storage configurations.
Radiological exposure to workers associated with the proposed action is discussed in Section
6.1.1.1 of the Environmental Assessment, while exposure to workers associated with the No-
Action alternative is discussed in Section 6.1.1.2.
Increased radiation exposure was found to be the only potential impact to workers as a result
of the proposed action. It is expected that common industrial accidents will be reduced due
to the use of Automated Guided Vehicles and the decrease in the frequency of inspections.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.7) FOLLOWS.
Document #: 1011 Comment #: 8 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
The groundwater risk assessment does not address any organic solvents, heavy metals, or other potential
groundwater hazards. If I recall correctly, the United States Environmental Protection Agency reported several
years ago that they had found evidence of heavy metal and organic chemical contamination of the soil and water
environment associated with previous Pantex operations.
Section D D-8
Response #: D.7
The interim storage activity does not require the use of organic solvents in the storage site.
The pits that are the subject of the proposed action contain plutonium, a heavy metal. The
risks associated with the release of plutonium were evaluated in the Environmental
Assessment and were found to be negligible.
Investigations of heavy metal and organic chemical contamination at other parts of Pantex
Plant are currently under way. The investigations are conducted in accordance with a Permit
for Industrial Solid Waste Management Site (No. HW-50284) issued by the Texas Water
Commission. The proposed interim storage activity is not expected to contribute any
contamination to the other sites currently under investigation.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.8) FOLLOWS.
Document #: 1035 Comment #: 11 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
#3 Pantex - Amarillo...
b. burns 300,000 pounds of nuclear explosives every year which we breathe.
Response #: D.8
The burning of high explosives is not within the scope of the proposed pit storage activity.
Neither the plutonium components (pits) that are the subject of this Environmental Assessment
nor nuclear explosive devices are burned at Pantex Plant. Pantex Plant does conduct open
burning of high explosives under a written grant of authority from the Texas Air Control Board.
The quantities of explosives burned at the Pantex Plant High Explosives Burning Grounds
during the last five years is as follows:
1988 226,000 lb (estimated)
1989 226,000 lb
1990 100,000 lb
1991 112,000 lb
1992 74,000 lb
The downward trend in the amount of high explosives burned each year can be attributed to
two reasons. First, the stoppage in production of nuclear weapons has eliminated the scrap
high explosives that were produced as a result of machining operations. In addition, the high
explosives removed during dismantlement operations are being recycled.
lb = pounds
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.9) FOLLOWS.
Document #: 1044 Comment #: 6 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
From 1981 to 1986, Pantex had a burning pit in which solvents and uranium were found and were present at 329
below the surface in soils underlying the pit, while the Ogallala Aquifer occurs at a depth of 390 to 420 beneath the
site. These years when the Department of Energy did not tell us about these dangerous pollutants coming from
the burn pits has had a great impact on the Panhandle of Texas. I will enclose a summary of "Texas Background
Radiation Levels determined by Thermoluminescent Dosimeter (TLD) Monitoring" in the "1990 Environmental
Monitoring Results". The 1988-89 surveillance program already showed considerable contamination of the soil,
surface water, vegetation, sediment, and crops such as sorghum and winter wheat. Also a passive integration of
gamma radiation was obvious in this report. In the 1988-1989 Environmental Surveillance Program. Gamma scan,
(suspected radionuclides: U3238 (sic)); gross alpha; gross beta; H-3 were present in the soil, surface water,
vegetation, sorghum and winter wheat. Surface water showed all of the above analysis types with Pu-239
included. I am enclosing the 1990 "Summary of Texas Background Radiation Levels" as determined by
Thermluminescent (sic) dosimeter (TLD) Monitoring.
Response #: D.9
The burn pit is out of the scope of the proposed action. The environmental impacts of
increased plutonium storage have been analyzed in the Environmental Assessment. The only
possible accident scenario that would release plutonium to the environment involved the
forklifts used for movement of the pit containers in Zone 4, as discussed in Appendix D of the
Environmental Assessment. The potential impacts on the environment due to a plutonium
release were found to be negligible.
The State of Texas and the Pantex Plant Environmental Monitoring Section both use
thermoluminescent dosimeters as well as other monitoring media to monitor the Pantex Plant
site and ensure that no release of radiation to the public takes place. Soil, air, groundwater,
and vegetation are regularly monitored by the State of Texas and Pantex Plant Environmental
Monitoring Section. These results, which are published in annual reports that are available to
the public, show that the levels of radiation are consistent with background levels. The results
also indicate that releases in excess of state and federal standards for protection of the public
from radiation and/or other contaminants have not occurred at Pantex Plant.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.10) FOLLOWS ON PAGE D-13
Document #: 1016 Comment #: 8 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
The EA only addresses storage in Zone 4 magazines. Are there other places on the site to store Pu? If so. why
aren't they being addressed?
Document #: 1017 Comment #: 17 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Storing Pits in Assembly Bay #8 - Electrical power for lights, air conditioning and heating is present in the work
bays.
Document #: 1042 Comment #: 30 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
3. Page 1-1. The draft EA states that Pantex workload requirements "is (sic) expected to be similar to that
experienced in the past for all assembly/disassembly operations." Questions that should be answered include:
What were the historic peak years for disassembly, and for assembly/disassembly? What types of disassembly
accidents have occurred with what exposures to workers and releases into the environment?
Footnote 1 states that 50,000 nuclear weapons have been dismantled in the last 40 years. How many were
done at Pantex? How many were done at other facilities? What other facilities were used? Can those facilities be
used for at least some of the proposed dismantlement?
Footnote 2 describes staging. What is the maximum time that pits have been stored at Pantex? Where were
they stored? With what results? What types of accidents have occurred during transportation, with what
exposures to individuals, with what releases into the environment?
4. Page 1-2. The implication is that pits have been stored at Pantex since December 1989. How many pits?
What kind of inspections have been done? What measured exposures have workers received? What accidents
have occurred?
Document #: 1042 Comment #: 35 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
6. Page 2-2. Figure 2.1 indicates that in the three years since RFP stopped processing pits (December 1989 to
4th Quarter 1992), Pantex has accumulated between 3,300 and 3,800 pits. How many are actually stored at
Pantex? Have any pits been shipped off-site since December 1989? If so, how many and to what location(s)?
(See also: issues raised in comments about page 1-2.)
Section D D-11
Document #: 1045 Comment #: 7 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
6) The draft EA does not discuss all the plutonium storage locations at the Pantex Plant itself.
The title of the draft EA seems to encompass the entire Plant (Interim Storage of Plutonium Components at
Pantex) yet only Zone 4 is ever discussed. In reality there are at least two other locations at Pantex which store
plutonium for various lengths of time: Cell 8 and 12-26 Vault, both in Zone 12.
In addition, there is another facility currently under construction in Zone 12, referred to as Special Nuclear
Material Staging Facility, which might be capable of holding as many as 4,880 pits. (see attached document 2,
"DOE Plutonium Strategy Task Force, Steering Committee Meeting, January 30, 1992 (Predecisional), p. 26)
None of this storage is taken into account in the Draft EA discussion. Nor has there ever, to STAND's
knowledge, been any mention of an intended EA process evaluating the new Zone 12 SNM facility, yet that facility
could store more pits than Zone 4 is currently allowed to do.
Though Cell 8 and 12-26 might be used only to briefly stage pits until they are transferred to a storage area,
this should be discussed in the text of the draft EA.
The SNM Staging Facility, however, must undoubtedly be considered as relevant to the draft EA proposed
action. It will provide such a significant amount of storage that it changes the entire picture of pit storage time
frames, options and capacity as portrayed in the draft EA.
Such a significant facility also deserves at least the same amount of careful evaluation process as is being
applied to Zone 4 igloos.
Document #: 1045 Comment #: 8 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
7) The draft EA must accurately portray the history of dismantlement and pit storage at Pantex. There are many
instances where this is not the case, but the following two examples are particularly pertinent:
a) In the Executive Summary DOE consistently uses the term storage. The purpose of the EA is even stated
as, "to evaluate the environmental impacts of additional interim storage of pits at Pantex..." (p. vii)
As previously discussed in comment 1d, pit storage is new to Pantex. If "additional interim storage" is true in
any sense, it is only because it has become unavoidable given the current condition of the complex and the
change in the world situation. To portray it as merely more of the same, a usual part of Pantex's work, is
inaccurate. Pit storage has transpired because it has been unavoidable. Being unavoidable does not mean that it
is not a significant change from either past practice or past mission which must be evaluated as such.
In addition, because it is a NEPA process, the final version of this draft EA will become a public document. As
such, it is logical that most people will have access to and read the Executive Summary. The summary must be
scrupulously written and accurately reflect the significant points of the whole. Section 1.1, Introduction and
Background, makes the distinction between staging and storage."
b) The text of the draft EA gives a false impression of the number of dismantlements conducted in the past at
Pantex when it uses a footnote within the statement "The primary mission of the DOE Pantex Plant is the
assembly and disassembly of nuclear weapons. "(p. 1-1) The footnote to the word "disassembly" reads: "Over
50,000 nuclear weapons have been dismantled in the last forty years."
Clearly the impression is that all 50,000 dismantlements took place at Pantex. However, during the August
20, 1992 public meeting of the Defense Nuclear Facility Safety Board, when a Board member pursued this same
statement, the Pantex official admitted that of the 50,000 dismantlements only an estimated 10,000 to 15,000 had
been done at Pantex.
Document #: 1048 Comment #: 19 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Is Zone 4 the only place the DOE intends to 'hold pits'? This is the only area discussed in the EA. What about the
other structures, bays, etc.?
Section D D-12
Document #: 1048 Comment#: 21 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
DOE assumes there will be no problems, either human or mechanical at any time during storage. All potential
problems associated with storage need to be addressed.
Document #: 1048 Comment#: 22 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
For the EA to state that the proposed action would not result in additional generation or management of wastes
(vii) - evades the original issue being - dismantlement - which is increasing so the pits can be stored at Pantex and
there is additional waste being generated. The issue of waste management was not addressed in the EA. This is
a major issue and needs to be fully explored.
Response #: D.10
The Environmental Assessment addresses the hazards associated with the interim storage of
no more than 20,000 pit containers. The analysis for 20,000 pits will bound the actual number
of pits stored at Pantex Plant. Approximately 5,200 pits (as of 11/1/93) are currently stored at
Pantex Plant. The purpose of the Environmental Assessment is to evaluate the environmental
impacts for Zone 4, the only area of Pantex Plant that is being considered for additional
interim storage of pits. Some pits have been stored at Pantex Plant since the closure of
Rocky Flats Plant in 1989. For further information refer to the National Environmental Policy
Act issue discussion (Response B.1).
Other locations in the production areas of Pantex Plant provide staging of pits to support
assembly as well as dismantlement activities. Pits that have been staged at Pantex Plant since
December 1989 have been handled in accordance with the Pantex Site-Wide Environmental
Impact Statement and the Final Safety Analysis Report Magazines for the particular staging
location. Two of these locations, Building 12-44 Cell 8 and the Building 12-26 Pit Vault, are
staging facilities and are not used for storage. Pits are moved in and out of these facilities
periodically. The capacity of Cell 8 is 288 pits, and the capacity of the Pit Vault is 152 pits.
There are no plans to increase the staging capacities of either of these facilities. Since only
Zone 4 will be used for interim storage, only Zone 4 is addressed in this Environmental
Assessment.
A new building for the staging of weapon components under construction is the Special
Nuclear Materials Staging Facility (Building 12-116). National Environmental Policy Act
documentation for this facility was completed in the form of a Memo To File, which was
appropriate under the Department of Energy National Environmental Policy Act implementation
requirements at the time. This facility will be used as a staging facility for weapon components
resulting from the disassembly of nuclear weapons. Components in transport containers will
be moved to Building 12-116 where they are readied for staging. The facility will have two
vaults (Rooms 120 and 121) with the capability of staging 834 pits (Building 12-116 Preliminary
Safety Analysis Report, Section 1.0). Other types of special nuclear material will also be
staged there. Since the purpose of the Special Nuclear Material Staging Facility will be
staging of pits and other special nuclear material, and the purpose of the Environmental
Assessment is the interim storage of pits, it would not be appropriate to include both facilities
in the same document.
The introduction and background sections of the Environmental Assessment are intended to
provide the reader with some current and historical facts of Pantex Plant. The historic peak
years for disassembly/assembly, types of disassembly accidents, exposure to workers, and
releases into the environment are not within the scope of the Environmental Assessment. The
footnote on Page 1-1 of the Environmental Assessment, that states "Over 50,000 weapons
have been dismantled in the last forty years," covers all Department of Energy Nuclear
Weapons Complex sites, including Pantex Plant. From January 1, 1967 through
May 31, 1993, the total number of weapons that have been dismantled at Pantex Plant is
23,463. Prior to 1967, the records for dismantlements are not computerized and are not
readily available.
Final Safety Analysis Reports are written for the pit staging locations in Zone 12 of Pantex
Plant. Aspects of a safety analysis report are to provide a formal evaluation to systematically
identify the hazards of an operation and to analyze and evaluate potential accidents and their
associated risks. The Pantex Plant Final Safety Analysis Report for Zone 4 Magazines has
recently been updated to include the new proposed interim storage configurations. The
Pantex Plant Final Safety Analysis Report for Zone 4 Magazines performed a systematic
identification of the hazards for the storage of the pits in Zone 4. The presence of electrical
power for security purposes does not pose any credible accident that could release
plutonium; therefore, no unacceptable risk is associated with the presence of electrical power
in Zone 4.
Waste generated in the dismantlement process is generated prior to the storage of pits in
Zone 4 and is not therefore within the scope of the Environmental Assessment. Pits are
considered a resource, not a waste; therefore Zone 4 is not a waste storage facility.
Appendix A of the Environmental Assessment is a summary of the 38 potential accident
initiating events. These analyses and a more complete description of the potential accident
initiating events are contained in the Pantex Plant Final Safety Analysis Report for Zone 4
Magazines. A quantitative analysis was performed for the accidents with the highest potential
to cause a release of plutonium. These accidents included aircraft impacts, earthquakes,
external explosions, forklift accidents, tornados, and tornado-generated missiles. The
consequences from these potential accidents are contained in Appendices B, C, D, and E of
the Environmental Assessment. To date no accidents have occurred because of pit storage
operations.
In addition to the accident analysis, a formal process is now being implemented to perform an
18 month surveillance of containers for corrosion and other attributes. Corrosion inspections
have been conducted on a periodic basis, with approximately 1.7 rem cumulative yearly
radiation exposure to workers associated with the inspection. Pits and containers will be
surveyed through a statistical sampling program whereby a percentage will be removed from
Zone 4 to a production area. The purpose of the program is to verify the integrity of the pits
and containers and to return them to Zone 4. Currently the same process is used to
occasionally ship pits from Pantex Plant to one of the national laboratories for additional
testing and surveillance. For additional information on the inspection of pits, refer to the
configuration, inspection, stability and dose rates discussion (Response D.23).
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 1 has been revised to reflect the comments.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.11) FOLLOWS.
Document #: 1017 Comment #: 18 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Work Bay #1 -- Still not cleaned up since the tritium leak in 1989. I understand that they have tried to clean it up,
but it still will not meet specs and they are talking about tearing it down.
Response #: D.11
Actions related to the decontamination or decommissioning of Cell 1 are not the subject of the
proposed action. An assessment to determine the extent of the contamination was performed
and an evaluation of clean-up options is currently under review.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.12) FOLLOWS.
Document #: 1042 Comment #: 21 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Unanswered in the draft EA are basic questions, including: ...
- What is the actual accident history and exposure rates for inspections under storage configurations;
Response #: D.12
No accidents with radiological consequences have occurred as a result of Zone 4 operations.
Historical exposure rates for inspections are discussed in Section 6.1.1 of the Environmental
Assessment. Current dosimetry records for both 1991 and 1992 indicate that the collective
dose rate for personnel associated with all Zone 4 operations is less than 10 person-rem/yr.
Estimates for the proposed configuration are detailed in Appendix F of the Environmental
Assessment.
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.13) FOLLOWS.
Document #: 1011 Comment #: 2 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
Do the designers of the storage configurations know that it is safe to store these quantities of plutonium in such a
small area? Is there danger of nuclear reaction due to "critical mass"?
Document #: 1015 Comment #: 4 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg 3-2: Some proposed multiple stacking configurations have in mathematical formulas approached 80%-90% of
criticality.
Response #: D.13
The statement made by the individual regarding the neutron multiplication factors for the
proposed storage configurations is true. The proposed storage configurations for the pits in
the Zone 4 magazines were prepared to prevent criticality. Criticality is determined by
calculating the number of neutrons that will be present for subsequent chain reactions to
occur. The number of neutrons is referred to as the neutron multiplication factor. The neutron
multiplication factor is strongly dependent upon two items: geometry (surface to volume ratio)
and material characteristics.
Geometry is a strong factor because of the increased chance for neutrons given off by the
radioactive material to interact with more radioactive material. More interactions are possible if
the same amount of radioactive material is shaped in the form of a sphere (large surface to
volume ratio) versus a thin rectangular slab (small surface to volume ratio). The quantity of
material present (mass) does not significantly influence the calculation of criticality for finite
arrays and is not an influence in calculating neutron multiplication factors for infinite arrays.
The AL-R8 containers that store the pits have been designed to prevent criticality by providing
fixed separation of the pits. Administrative controls are in place to ensure that only one pit is
placed into each container and that the correct packaging procedures are performed. Since
the geometric configuration of the pit inside of the container is constant, the arrangement of
the containers within the magazines could alter the neutron multiplication factor. The
proposed storage configurations of the pits within the magazines were examined to determine
if criticality could occur. In each of the proposed storage configurations, criticality was not
obtained. Various accident scenarios that could alter the geometric arrangement of the pits in
the magazines were also examined and the possibility of obtaining criticality was found to be
not credible.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.14) FOLLOWS ON PAGE D-19.
Document #: 1011 Comment #: 18 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
The health effects of long-term, low-level radiation exposure are not known.
Document #: 1015 Comment #: 9 Date: 2120/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg 52: Scientists are continualy lowering the levels that are deemed to be safe, and arguments abound that in
the long run, no levels of radiation are truly safe. Witness the current concerns being voiced about naturally
occurring radon accumulations in our area's basements.
Document #: 1015 Comment #: 10 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg 64: If annual collective worker radiation doses increase but Federal individual worker exposure limits are not
exceeded, It logically follows that even more workers will be at risk for radiation-induced cancer.
Document #: 1042 Comment #: 25 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Further, basic information about the DOE approach to worker safety is not included in the draft EA. Will a few
workers be charged with doing all inspections, thereby increasing doses to a few workers, or will many workers
conduct inspections, thereby increasing the number of workers receiving some exposures but limiting exposures to
individuals? Related questions are whether having a few highly trained workers make inspections quicker and
more efficient, thereby reducing exposures, or whether having teams of more than two workers would reduce the
time and resulting exposures from inspections. Other questions are: Are the same workers responsible for
moving pits from the disassembly bays to the storage facilities and then doing inspections? If so, what are the
cumulative exposures?
Document #: 1048 Comment #: 2 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
"Environmental impacts would be limited to radiation exposure of workers which would be controlled to insure
that ALARA objectives are achieved" (vii), (3-2), (4-1); to assume no adverse health effects among workers is
ludicrous. Workers will receive increased radiation doses in taking pits from Assembly Bay to Zone 4 - will these
be the same workers? If there are fewer workers there will be higher doses, but if there are more workers there is
less exposure, but more people are involved
In inventorying the pits, the estimates for worker radiation exposure are based on current inventory operations
- these in no way are a guide for determining full worker exposure for the future operations. "Impacts of the
proposed action were assessed and found to be limited to worker exposures to radiation" (vii, 4-4,8-1) - we
demand for the workers that this proposed action be further examined - no one person's life is expendable.
Section D D-18
Document #: 1048 Comment #: 3 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
For the workers who handle the pits the radiation risks are not fully analyzed. The EA has failed to adequately
address radiation exposure to workers. "The workload requirements for increased weapons disassembly is
expected to be similar... in the past" (1-1) how can this be when the workload is increased?
Response #: D.14
Although the long term effects of low-level radiation exposure are not known, it is standard
practice within the Department on Energy to limit both individual and collective exposures to
minimal levels. This is outlined in the Department's As Low As Reasonable Achievable
Program. In this program, Pantex Plant has established an administrative limit on individual
dose to 1 rem/yr. This limit is below the current federal radiation limit of 5 rem/yr.
Additionally, pursuant to the Department of Energy Radiological Control Manual (July 1992),
the As Low As Reasonably Achievable goal to further reduce exposure to 500 mrem/yr is
planned to be implemented by the end of 1993.
Frequently, the practice of trying to reduce both types of radiation exposure (individual and
collective) requires a balanced approach that may include compromise. Situations do arise
where the use of a limited number of highly efficient workers will result in higher individual
doses but lower collective doses. Other considerations, such as safety, security, job
efficiency, and contingency planning will also determine the number of trained personnel
required. To determine the ideal number of personnel to perform a given activity requires
assessments by radiation safety and operations professionals. These assessments are
performed at Pantex Plant on an activity-by-activity basis.
Workers responsible for transporting pits from the disassembly bays and cells are not the
same workers performing inspection operations. Exposures associated with the preparation
of the pits for shipment will be essentially the same regardless of the location where stored
(provided a similar number of units are disassembled). Further, doses associated with the
receipt and emplacement of pits at Zone 4 are included in the dose calculations (see
Appendix F of the Environmental Assessment). Worker radiation exposures received in the
disassembly areas and during transport of the containers will continue to be limited to the
Pantex Plant Administrative Dose Limit of 1 rem/yr.
As stated by an individual, increasing the number of workers exposed to the same level of
radiation will increase the number of workers at risk of radiation-induced cancer. Based on
the latest studies on the effect of continuous exposure to low-level radiation, a dose of 1 rem
is estimated to result in an increase of cancer risk of 0.08 percent ("National Research Council,
Health Effects of Exposure to Low Levels of Ionizing Radiation; BEIR V," Committee of the
Biological Effects of Ionizing Radiation, National Academy Press, Washington, DC, December,
1989). (This risk is based on projections from observations at high doses.) Based on this
finding, the health effects of long term, low-level radiation exposures are very small and
comparable to the health effects from natural background radiation.
The mortality rates for radiation workers have been studied by scientific groups. At least one
study has concluded that radiation workers tend to live longer than members of the general
public. This conclusion is attributed to the fact that radiation workers receive more frequent
examinations than the general public and illnesses can be diagnosed and treated in the early
phases. (For more information, refer to "Mortality Among Workers at Pantex Weapons
Facility," Journal of Health Physics 48 (1985): 735-746.)
Department of Energy Orders (5480 series) contain directives regarding worker safety. In
addition, Secretary of Energy, Hazel O'Leary has outlined a new program to enhance and
improve worker radiological health and safety. This safety and health initiative will establish
clear roles for independent oversight, empower employees to assure safety and health,
develop a shared strategy for continuous improvement, and clearly articulate expectations for
safety and health. This policy was published in 48 Federal Register 33804 on June 21, 1993.
mrem = millirem
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.15) FOLLOWS.
Document #: 1017 Comment #: 11 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Missiles -- How about missiles from a test firing or from an HE press accident? We know these kinds of accidents
have happened in the past. We know of at least three.
Document #: 1017 Comment #: 19 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
I know one breech block from a 16 inch naval gun has been blown up. I have heard that at least three high
explosive presses were also blown up over the years. These accidents could provide missiles for penetration of
the igloos and possible fires.
Response #: D.15
Appendices C and D of the Environmental Assessment discuss potential accident initiating
scenarios as a result of blast pressure, fragments, and missiles generated from accidental
explosions in adjacent structures. The maximum credible explosion found was the result of an
explosion of a Richmond magazine in Zone 4 east which contained high explosives. Since
this is the maximum credible accident scenario involving explosion-generated missiles,
explosions from more distant areas of the plant are considered to be not credible.
In addition, administrative controls have been implemented at the Plant firing sites to control
fragments from explosives tests that have the potential for producing fragments off-site.
Quantity-distance separation requirements, as specified in applicable Department of Energy
Standards, are provided from operations such as test firing to the Plant boundary as well as
to other Plant operations. These separation distances are monitored and routinely evaluated
by internal and external groups from the Department of Energy and the Department of
Defense.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.16) FOLLOWS.
Document #: 1036 Comment #: 1 Date: 3/1/93
Arjun Makhijani, Ph.D.
Institute for Energy & Environmental Research
Comment:
V. Accident Scenarios - Calculations of the effects of an accidental explosion of high explosives on the
Modified Richmond and SAC magazines are based on the assumption that the blast can be represented as a
triangular wave distributed load on the roof of the structure in questions (sic). These calculations indicate that the
combination of blast and dead load on the roof of the Modified Richmond magazine would be about 65% of the
estimated held strength of the beam.
Since the resorts of the stress calculations are dependent on pressure waveform and on the distribution of the
load, the DOE should do a sensitivity analysis that includes waveforms with sharper rise profiles (such as
exponential or parabolic) and non-uniform load distributions across the roof. Similar sensitivity analyses should
also be done for other aspects of calculating the consequences of an accidental explosion. This is critically needed
for the doors of the SAC magazine, since the calculated ductility ratio with the assumed waveform and load
distribution indicates significant deformations may occur with the assumed waveforms.
Response #: D.16
The structural response of the roof, in the event of an adjacent detonation, has been
addressed using standard Department of Energy and Department of Defense design
methods. The pressure event used in the accident scenario is a result of a detonation a great
distance away (480 ft, 435 ft).
The positive phase impulse is the area under the pressure-time event back to the first point of
ambient pressure, to ("Structures to Resist the Effects of Accidental Explosions", TM 5-1300,
NAVFAC P-397, AFR 88-22, Figure 2-90, Page 2-232). The equivalent pressure history is
represented by the idealized positive phase curve. The modified pressure time history
appears as an immediate over-pressure coincident to the actual over-pressure, Pso, then
decays linearly to the original environmental pressure after the equivalent load duration is met,
t(of). As a result, the equivalent triangular event conserves the original magnitude of the over-
pressure and the actual incident impulse on the structure. The simplified load duration, t(of), is
the only assumption used in the pressure history. Both histories still represent the original real
impulse. The figure cited above is not to scale, and the negative phase pressure is
overstated. The time history of the pressure pulse, as stated in the Environmental
Assessment, has a relatively low original pressure component along with a relatively longer
applied duration.
Because of the combination of the strength of the structure and the resulting pressure time
history from the detonation, the design falls into the design category of a pressure sensitive
structure. Since this structure is pressure sensitive, the design approach undertaken is the
acceptable method to use. The applied pressure used in the analysis is the pressure at the
wall closest to the point of detonation. In addition, this pressure time history is applied to the
entire length of the roof to ensure the bounding case loading history has been examined.
Therefore, a sensitivity analysis is not needed because a bounding case event has been used
in the original analysis.
ft = feet
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.17) FOLLOWS ON PAGE D-25.
Document #: 1007 Comment #: 3 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 3-2 Line 23-29: The discussion of the shielded forklift with passive guidance system is written in the present
tense, as though it exists and is in use today.
Document #: 1015 Comment #: 13 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg A-2: Table A-1 states the possibility of internal fire as being "not possible or plausible at this site or facility".
However an earlier statement in this EA document considered a forklift accident scenario in which Pu escaped its
confinement. Since Pu is pyrophoric (burns on contact with air), a very real internal fire possibility exists.
Document #: 1016 Comment #: 22 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
A-5 does not mention any possibly (sic) of an explosion caused by a forklift penetrating a container causing great
heat by friction or the possibly (sic) of an exploding battery or other electrically (sic) short.
Document #: 1017 Comment #: 6 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Internal Explosions - Plutonium pits implode: not explode. Forklift batteries may explode.
Document #: 1017 Comment #: 7 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Internal Fires - Plutonium is combustible in the presence of oxygen. How about electrical fires from an electric
forklift? How about heating and or air conditioning in Work area Bay #8 where storage is now being done? How
about wooden pallets? They burn.
Document #: 1017 Comment #: 8 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Lightning Strikes - How about static electricity from nearby lighening (sic) strikes and static electricity from wind?
Document #: 1017 Comment #: 9 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Loss of Power - Would gasoline or deisel (sic) powered generators be used to light the storage area if power is
lost from commercial suplies?
Section D D-23
Document #: 1017 Comment #: 12 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Sand storms and Dust storms - How about static electricity? How about missiles from high winds? The day
before Labor Day (Sept. 3, 1968 or 1969) we had a wind storm that took a four mile wide swath of high voltage
electrical lines and poles and roofs from homes and machine sheds and barns. One Pantex employee at that time
told me that the wind speed indicator at the plant registered 113 mph before it broke. Also there were reports of
as many as 7 funnel clouds reported in that storm. He said after he saw a 55 gallon drum go over the
administration building that it was time to go to the basement.
Document #: 1017 Comment #: 13 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Transportation Accident: - Electric fork lifts may catch fire - Batteries may explode from either fire or overload.
Trucks could be involved incollisions (sic), catch fire or be turned over by high winds.
Document #: 1017 Comment #: 16 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Fork Lift Accident - If, as the EA suggests, the container is punctured and the pit crushed, plutonium would be
exposed to air. Friction from the fork lift line penetration of the pit could cause spontaneous combustion. The
workers would be exposed to fire and smoke as well as plutonium dusts. Presuming that the door of the magazine
(sic) was open. The surrounding area and people could also be exposed.
Document #: 1042 Comment #: 24 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Unanswered in the draft EA are basic questions, including: ...
- If storage containers are punctured, what amount of plutonium dust could be released, with what effect on
workers, what emergency response measures will be put into place to treat workers so exposed?
Document #: 1042 Comment #: 39 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
The draft EA discusses the shielded electric forklift, but does not provide important information, including:
- how many of those forklifts are currently in use,
- what are measured reduced exposures to workers,
- what is the accident history of those forklifts compared to unshielded forklifts?
The draft EA mentions the AGVs, but does not describe:
- when such vehicles could be available,
- the calculated reductions in time for inspections or reduced worker exposures,
- what kind of testing has been done with prototype vehicles and with what results,
- how the barcodes would be placed on pits already stored.
Document #: 1042 Comment #: 50 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
17. Page 6-5. The discussion of a forklift accident does not use the most conservative assumptions, including for
the amount of plutonium dust available and the actual inhalation by a worker. Thus, the statements that there
would be no health effect to the worker and no consequences to the public are not adequately supported.
Section D D-24
Document #: 1048 Comment #: 13 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
5.0... any serious dispersal of plutonium was not carefully examined, 5.2 does not talk about risks to the general
off-site population. Off-site ionizing radiation was not even considered. No Emergency Preparedness plans were
presented for off-site communities in the event of a hazardous or toxic release.
Response #: D.17
Forklifts Puncturing Containers
The Zone 4 operations were carefully examined for the possibility of operational accidents.
The most limiting accident involves a forklift puncturing an AL-R8 container. A forklift
penetration might cause a breach of the container, but since there is no explosive material in
the container (only the pit and packing material), an explosion is not possible. The analysis
provided in Section 6.2.4 of the Environmental Assessment is consistent with the analysis
documented in the Pantex Plant Final Safety Analysis Report for Zone 4 Magazines. The
forklift analysis described in the Pantex Plant Final Safety Analysis Report for Zone 4
Magazines is very conservative.
A forklift accident has been evaluated and the potential for a spontaneous combustion was
found to be not possible. A more likely event is that the crushing of the pit would cause the
expulsion of respirable plutonium dust. Using conservative assumptions, it is estimated that
0.57 mg (92 -Ci of 45 year old weapons grade plutonium) of this dust could be expelled from
the container. A worker who is exposed to this quantity of plutonium dust could receive a
committed effective dose equivalent of 6.6 rem to the whole body over the next 50 years. The
committed effective dose equivalent to an individual at 2.1 km is 0.00013 rem to the whole
body over the next 50 years. In both instances, less than one-half of the 50-year committed
effective dose equivalent would be received during the first year, and smaller amounts would
be received during all ensuing years. Therefore, the maximum dose to the worker would be
3.3 rem and to the general public would be 0.000065 rem during the first year after a release
of this magnitude. Thus, neither the 5.0 rem Federal radiation limit for the dose to the whole
body that each radiation worker at nuclear facilities is allowed to receive each year, nor the
0.010 rem/yr standard developed by the Environmental Protection Agency in 40 Code of
Federal Regulations 61, Subpart H, to limit risk to the general public and the environment
would be exceeded in any one year. These regulatory limits are established at levels
significantly lower than those that have been known to cause any public health hazard. The
shielded forklift will reduce the possibility of puncturing a container due to electrical and
mechanical interlocks not accounted for in this conservative analysis.
Battery Explosion, Transportation, Fire, and Other Vehicle Accidents
A pit in its storage configuration does not contain explosive material and cannot explode. An
exploding battery, an electrical short, or a forklift penetration cannot cause a pit to explode.
Battery explosions usually occur during the charging cycle, which is done at a different
location than Zone 4.
Several vehicles may be near the magazines, including Safe, Secure Trailers, diesel-powered
forklifts, electric forklifts, and various transport and security vehicles. Only electric forklifts are
allowed inside the magazines. Due to the structure of the magazines, transportation activities
outside the magazines do not pose an internal threat. The pits are transferred to and from
Zone 4 in either the AL-R8, an approved storage container, or a certified Type B transportation
container. The AL-R8 container has been reviewed for the bounding transportation accident in
the "Rocky Flats Container, Model AL-R8 Safety Analysis Report for Packaging". The Type B
transportation container has been rigorously tested to prove compliance with requirements.
Only a minimal amount of exposed combustible material is allowed in the magazines
(principally in the form of shipping/identification tags). In an effort to reduce the threat of
internal fires, the pallets used for stacking are made of metal and are not combustible. The
minimum level of exposed combustibles associated with these items was evaluated in the
Pantex Plant Final Safety Analysis Report for Zone 4 Magazines. The likelihood of an internal
fire scenario was examined in Appendix D of the Pantex Plant Final Safety Analysis Report for
Zone 4 Magazines. The initiating event for a fire (a hydraulic fluid leak from an electric forklift)
is an implausible event. Based on the frequency of this initiating event and the probability of
other events that are necessary for an uncontrolled fire to occur, the likelihood of a fire
initiated inside a magazine leading to the release of radioactive material is 2.7 x 10-7 per year.
No damage to the structures or their contents are expected because there is insufficient
material to sustain an internal fire. Consequently, no effects on the general public, the Pantex
Plant workers, or the environment are expected, although damage to the forklift may occur.
Plutonium Dispersion Accidents
Pits cannot spontaneously implode. For weapons to function, a high explosive shell around
the pit is detonated that implodes the pit. The configuration evaluated in the Environmental
Assessment is for single pits with no explosive material present. Neither explosion nor
implosion of a pit is possible in this configuration.
Plutonium metal in large pieces (such as present inside plutonium-containing pits) does not
burn on exposure to air. Plutonium metal can be handled in air and is often processed and
stored in normal air in environmental glove boxes. Spontaneous ignition only occurs when
plutonium is present as particles less than 0.2 mm thick and then only on exposure to
temperatures in excess of 150o C. Larger samples must be exposed to temperatures in
excess of 500o C before ignition. Formation of such small particles is difficult. Plutonium
subjected to considerable mechanical stress does not form such small particles. Analysis of
plutonium pits subjected to mechanical deformation or stress shows plutonium does not burn
or spread as a result of chemical reaction with air. Plutonium oxide forms when plutonium
metal or a compound of plutonium reacts with oxygen. The oxide forms an adherent layer on
the metal surface and acts as a barrier that slows the rate at which additional oxygen can
react. The oxide is the most stable compound of plutonium in an oxygen-containing
environment, and, once formed, it does not react further upon continued exposure to the air.
Controlled chemical processing is necessary to convert the oxide back to the metal or to
another plutonium compound.
Shielded Forklifts and Automated Guided Vehicles
Shielded forklifts are not yet in use at Pantex Plant, and no historical information is available
on shielded forklift accidents. However, the shielded forklift has been delivered to Pantex
Plant, and operators are being thoroughly trained prior to operating it. Sensors have been
installed to assist in the operation by providing position of the forklift and height indication of
the boom used for pallet retrieval. In addition, electrical and mechanical interlocks will further
reduce the probability of a forklift puncture accident. The expected reduction in radiation
exposure to personnel using the shielded forklift is anticipated to be a factor of 20.
The implementation date of the Automated Guided Vehicles delivery is unknown at this time
because the contract is currently in the procurement phase, and it has not been awarded.
Since the Automated Guided Vehicles are currently in the procurement phase, no testing has
been performed to date. Once the Automated Guided Vehicles are delivered (expected in the
fall of 1994), both Pantex Plant and Sandia National Laboratory will perform prototype testing.
The goal for the Automated Guided Vehicle project is to eliminate the need for personnel to
enter the magazines for inventory and inspection. The inventory and inspection requirements
will be satisfied by using a bar code reader and cameras. By eliminating the need to enter
the magazines, radiation exposure will be drastically reduced.
Confusion was generated because on Page 3-2 (of the December 1992 Draft Environmental
Assessment) the third paragraph starts with "An electric shielded forklift with shielding for
radiation purposes would be used for storage, retrieval, and inventory operations for palletized
stacking configurations or individual container handling". The paragraph then continues in the
present tense as if the forklift was already in use. The shielded forklift was not constructed
when the draft Environmental Assessment was written but has now been delivered. The unit
has been tested and workers are being trained in its use. The forklift is shielded to maintain
worker radiation exposure "As Low As Reasonably Achievable", which is less than 1 rem/yr.
This is another system that Pantex Plant has planned for protection of its workers.
Lighting in the Magazines
Neither the Modified-Richmond nor Steel Arch Construction magazines has lighting inside.
The electrical system is used for security purposes, is supported by two redundant sources,
and has a backup generator that is not in Zone 4. A complete loss of electrical power to the
magazines would not lead to safety-related consequences.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Sections 3.0 and 6.0 have been changed to reflect comments.
mg = milligram
km = kilometers
yr = year
-Ci = microCuries
mm = millimeters
C = Celsius
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.18) FOLLOWS.
Document #: 1015 Comment #: 11 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners
Comment:
Pg 6-5: If a forklift accident occurs, conservative calculations show .57 mg of Pu escaping to the atmosphere. A
lethal inhaled dose of Pu is a scant one-billionth of a gram.
Response #: D.18
If 0.57 mg of 45 year old weapon grade plutonium was released into the air, a fraction of this
dispersed material could be inhaled by personnel in the immediate area of the accident. An
analysis of such an event is discussed in the Pantex Plant Final Safety Analysis Report for
Zone 4 Magazines in Appendix D. These results are:
1) The worker would be expected to receive 0.02 -Ci through breathing;
2) The resultant 50 year committed effective dose equivalent for lungs would be 24
rem; and
3) The resultant 50 year committed effective dose equivalent for whole body dose
would be 6.6 rem.
One billionth of a gram of weapon grade plutonium is equivalent to 0.06 nCi (6 x 10-11 Ci) of
activity. This amounts to 0.3 percent of the activity calculated by the event discussed above,
and would result in a 50-year committed effective dose equivalent for lungs and whole body in
direct ratio to the doses reported in Appendix D of the Pantex Plant Final Safety Analysis
Report for Zone 4 Magazines, or about 72 mrem to the lungs and 20 mrem to the whole body
over 50 years. Consider these exposure levels when compared to the annual effective dose
equivalent for inhalation of naturally occurring radon gas (200 mrem/yr) as stated on page 15
of the National Council of Radiation Protection 1993 Report.
mg = milligram
-Ci = microCuries
nCi = nanoCuries
Ci = Curies
mrem = millirem
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.19) FOLLOWS.
Document #: 1015 Comment #: 16 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pu is in this EA addressed as 45 years or more old, as if by this advanced age it is relatively innocuous (sic).
However, 45-year-old Pu has spent but 1/5,333rd of its total life before it is an inert substance.
Breakdown/decay/sister products of Pu have half-lives of up to 28 billion years.
Since we do not know the long term chemical form of Pu in this ecosystem, we've absolutely no idea of its
effects on the ecosystem. To assume the initial form of Pu to be an oxide might be correct, or it may be a gross
fallacy with a horrible unthought of effect.
Response #: D.19
The age of the plutonium (Pu) refers to the time that has lapsed since it was manufactured
into weapons grade material. Rather than describing the plutonium as relatively innocuous at
45 years, the Environmental Assessment describes it in a state where it emits more
penetrating radiation than when it is newly manufactured. Older manufactured plutonium
emits more penetrating radiation because of a natural isotopic contaminant, Pu-241. This type
of plutonium has a much shorter half-life than Pu-239 and it decays to americium (Am-241).
The Am-241 emits penetrating radiation similar to an X-ray, which is the primary contributor to
dose rates present outside of the pit storage containers. Therefore, assuming that the
plutonium is 45 years old describes a conservative case when predicting dose rates near pit
storage areas.
If the sealed pit is compromised by external forces, the plutonium will oxidize as do other
metals. Plutonium oxides are insoluble and move very slowly through the ecosystem. The
effects of plutonium as well as other radioisotopes in the ecosystem have been extensively
studied and are discussed in such documents as Radiological Assessment: Predicting the
Transport, Bioaccumulation and Uptake by Man of Radionuclides released to the Environment
(NCRP Report No. 76), National Council on Radiation Protection and Measurements,
Bethesda, Maryland, 1984; and Radiological Assessment, A Textbook on Environmental Dose
Analysis (NUREG/CR-3332, ORNL-5968), Till, John E. and Meyer, H. Robert, editors, U.S.
Nuclear Regulatory Commission, Washington, D.C., 1983; as well as in other scientific
literature.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.20) FOLLOWS ON PAGE D-31.
Document #: 1010 Comment #: 1 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
1. The maximum tornado winds shown in the assessment are 220 mph. This wind speed falls in the range of a
category F4 tornado (wind range 207-260 mph). This past year an F4 level tornado struck Fritch, Texas, a
community approximately 20 miles NE of the plant. During recent years we have spotted and tracked several
tornados near the plant. More emphasis needs to be placed on the effects of the maximum winds of an F4 level
tornado (260 mph) and consideration needs to be given to an F5 level (winds 261-318 mph) tornado. A new
engineering study needs to be completed on the older storage areas in sector 4. The threat is listed in the
assessment as extremely unlikely yet the plant has very extensive tornado plans and elaborate spotting techniques
and equipment.
Document #: 1016 Comment #: 18 Date: 2/15/93
Jeri Osborne
Citizen Comments
Comment:
As Dana O. Porter soil and water conservation engineering specialist at Mississippi State University says, the EA is
lacking in basic information that the DOE needs to accurately determine the safety of the proposed storage of Pu
at Pantex. The scope is too narrow. Extremes of the weather are very conservative. Section 31 states the
prevailing wind direction is from the south-southwest with an average wind speed of 14 mph with occasional gusts
of up to 70 mph. The weather bureau at National Weather Service says th (sic) annual average is 13.1 mph at a
230 degree true direction. Wind gusts have been recorded in excess of 100 mph. On September 3,1968, a wind
guage (sic) on the Pantex site registered 113 mph before it broke. We have observed numerous tornadoes,
funnel clouds, and massive wall clouds both near and over the plant. In June, 1992, a tornado crossed from our
tail water pit into the plant before lifting near Firing Site 4. Two very large wall clouds were seen over the plant and
our home the same week. In May, 1991, a tornado moved from just west of Panhandle directly toward the east
gate of Pantex before lifting just before it got there.
Document #: 1024 Comment #: 4 Date: 3/10/93
Jay A. Roselius, County Judge
Carson County
Comment:
... request that authorities from these different agencies be assembled together in their area of expertise and
address and formulate the best possible response to the following areas which seem to me to be the areas of most
concern when considering all of the various comments...
4. What impact would tornadic winds have on a bunker/magazine or other strategic location.
Document #: 1030 Comment #: 1 Date: 3/2/93
Judy Osborne
Citizen Comments
Comment:
One can be sure that if the city of Panhandle has the potential of being hit by a tornado, the Pantex plant is also
vulnerable to a hit.
Numerous very devastating tornadoes have struck near the plant. In late June, 1992, the city of Fritch, about
15 miles to the north of the plant was very hard hit. The city of Amarillo has been hit. White Deer has had three
hits. A farm was destroyed 4 miles to the north of the plant. Tornadoes have been spotted on all sides of the
plant. In September, 1968, a rather large storm with numerous tornadoes and funnel clouds moved from the north
onto the plant site. A wind guage (sic) on the site broke at 114 mph. in (sic) 1991, a large tornado headed
directly toward the east gate from Panhande, lifting just before it reached the plant. In June, 1993(sic), at least
three tornadoes were spotted on the north side of the plant. One moved onto the site, lifted at Firing site 5.
We believe the possibility of a devastating tornado striking the Pantex plant is too great (sic) threat for Pantex
to be considered as an intrium (sic) storage site for plutonium. Missiles hurled by the very high winds of a tornado
are capable of penetrating the storage areas. There would not have to be a direct strike for massive destruction.
Section D D-30
Response #: D.20
Response #: D.20
From the Pantex Plant Final Safety Analysis Report for Zone 4 Magazines, the analysis of the
magazines indicates the structure will not fail as a result of a 132 mph Design Basis Tornado
or a 200 mph Maximum Credible Tornado. Since the maximum credible tornados was
calculated to be 200 mph, tornados with winds speeds in excess of that amount were
considered to be not credible and thus not examined. There are considerable safety margins
associated with the magazine roof/steel arch and earth overburden, walls, doors, and security
barriers to resist the forces produced by both levels of tornados. It is important to note that
the magazine structures have been analyzed under the condition that the doors are closed.
Operating procedures require that the magazines be secured during the onset of severe
weather. In this secured configuration, the Pantex Plant Final Safety Analysis Report for
Zone 4 Magazines identifies the large concrete blocks protecting the steel doors as the only
vulnerable component to the effects of a tornado.
Another design configuration for tornado analysis includes atmosphere pressure change. The
maximum pressure difference applied to the concrete blocks during the Maximum Credible
Tornado is approximately 100 psf. Since the pressure required to topple the concrete blocks
is 140 psf, the magazines are considered invulnerable to the wind effects of both the Design
Basis Tornado and the Maximum Credible Tornado. In addition, the statement that winds
average 14 mph from the south-southwest is consistent to the given statement that the annual
average is 13.1 mph at 230 degrees true direction.
The analysis in the Pantex Plant Final Safety Analysis Report for Zone 4 Magazines also
concluded that the most credible generated missile is a tornado-driven, 75 lb., 3 in. diameter
pipe traveling at 50 mph will penetrate the concrete structure approximately 8 in. Since the
magazine structure is earthen-covered and at its thinnest point is 24 in. thick, the magazine
structures are considered invulnerable to the effects of the tornado-generated missiles.
mph = miles per hour
psf = pounds per square foot
lb = pound
in = inch
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.21) FOLLOWS.
Document #: 1012 Comment #: 5 Date: 1/16/93
Margie K. Hazlett (1)
Citizen Comments
Comment:
Our climate is not suitable for plutonium storage such as that at Pantex. During a 24 hour period, usually in the
Spring or Fall, we can have an extreme temperature of hot weather and then extremely cold, and vice versa. This
process could cause any container to rust after condensation, or cause a lot of moisture in your plutonium storage
places. Our climate can be fine some days, but then we have violent tornadoes with hail, straight winds and strong
thunder storms. During high winds, we prefer not to have grass fires.
Response #: D.21
The climate has been recognized as a source of accident conditions, specifically high winds
and tornados. The facilities have been evaluated in the Pantex Plant Final Safety Analysis
Report for Zone 4 Magazines for earthquakes, tornados, fires, flooding, explosions, and
missiles (generated by explosions or tornados). These analyses have concluded that natural
phenomena do not pose a threat to the plutonium storage facilities. The containers have
been designed and approved for the storage of plutonium to avoid corrosion and other
accident conditions.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.22) FOLLOWS
Document #: 1011 Comment #: 4 Date 2/18/93
Dana O. Porter
Citizen Comments
Comment:
I question the accuracy of the average annual rose, located on page 5-10, Figure 5.8, in the report. I found
no reference cited for the data in the figure. An error or misrepresentation of such data can result in
inappropriately placed air quality samplers, and consequently, errors in air quality measurements.
Response #: D.22
Figure 5.8, which appears on Page 3-3 of the 1983 Final Environmental Impact Statement,
Pantex Plant Site (DOE/EIS-0098), represents the average annual wind rose for 1955 through
1964, based on data obtained from the National Weather Service Station located at the
Amarillo International Airport in Amarillo, Texas. This 10 year wind rose is similar to wind roses
from recent years and is considered to be accurate.
Placement of air quality sampling equipment is based on numerous factors including the
prominent wind direction(s), but also on input from various regulatory agencies (Environmental
Protection Agency, Texas Air Control Board) and on permit requirements.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 6.0 has been changed to reflect the comments.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.23) FOLLOWS ON PAGE D-45.
Document #: 1007 Comment #: 2 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
"Page 3-1, Lines 35-36: The statement "DOE Orders and procedures for insuring sale and secure storage of pits
would continue to be followed rigorously." is misleading and is contradicted by Paragraph 6.1.1.1, which states that
"inspections and inventories would (bolded) occur a minimum of once every 18 months..." (emphasis added).
During a DOE briefing conducted on January 14,1993, this was verified as a departure from the current
bi-monthly minimum physical inventory requirement."
Document #: 1007 Comment #: 9 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 6-1, Paragraph 6.1.1.1: This passage reflects a diversion from previous DOE Security and Safeguards
requirements to mitigate substantial increase in worker radiological exposures. The statement on Page 3-1, Lines
36-37, "The DOE Orders and procedures for ensuring sale and secure storage of the pits would continue to be
followed rigorously." needs to be reconciled here. It should also be noted that the "approval" contained in
DOE/SA-124 Memorandum, Dated January 12,1993, Subject, "Request for Exception of the Bimonthly Minimum
Physical Inventory Frequency Requirement at the Pantex Facility" relates only to 18 Igloos. It is interesting to note
that the "effective date" is not a date certain, but rather a "floating" date starting (or restarting) within 30 days
after a physical inventory of the contents of each igloo has been accomplished.
Document #: 1007 Comment #: 10 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 6-2, Chart: This gives the appearance that corrosion inspections are not required for containers in the
horizontal palletized stacking configuration.
Document #: 1008 Comment #: 1 Date: 2/1/93
Boyd Deaver
Texas Water Commission
Comment:
Comment: Executive Summary: page vii fourth paragraph. -- Reference is made to capacities of the magazine,
the statement of "up to 20,000 pits" appears to be an inference rather than a declaration... Capacities of
magazines mentioned well exceeds 20,000 pits.
Question: What is the maximum capacity of Storage?
Document #: 1008 Comment #: 4 Date: 2/1/93
Boyd Deaver
Texas Water Commission
Comment:
Comment: 3.0 PROPOSED ACTION: p. 3-1, Third Paragraph. - "... hold up to 384 or 392 pits, in the single-layer
vertical or horizontal palletized multiple stacking configurations respectively.
Question: Figure 3.4 exhibits 460 pit capacity for horizontal palletized multiple stacking. Which number is the
capacity to be used?
Section D D-34
Document #: 1008 Comment #: 5 Date: 2/1/93
Boyd Deaver
Texas Water Commission
Comment:
Comment: 3.0 PROPOSED ACTION: p. 3-2, Second paragraph. - "Variations and/or a combination of these
arrangements may be used.
Question: Is this a "disclaimer" or "loophole" that can be used to deviate from arrangements previously
proposed in this document?
Document #: 1011 Comment #: 6 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
The report indicates that the containerized plutonium pits will be inspected on an 18-month schedule. There is
a comment on page 6-1 of the report that some minor releases of air pollutants (sic) during these inspections.
Inventory and inspection operations described by the report have allowed one minute per container. Does this
include locating and moving the containers to an area where they can be visually inspected? From the stacking
configurations described in the report, I was not able to visualize how the inspectors could locate and and inspect the
individual pits at a rate of one per minute, especially if the pits must be moved with a forklift. If inspection time and
handling requirements are underestimated, are the associated risks also underestimated?
Document #: 1015 Comment #: 8 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg 5-1: PX storage magazines employ natural ventilation. Any accidental leakages would be vented to the
atmosphere for dispersal by the winds to who-knows-where: the Canadian river, Lake Meredith, the assorted
playa lakes of the area, and by subsequent percolation/infiltration, most likely into the Ogallala aquifer.
Document #: 1016 Comment #: 8 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Radiation is not adequately addressed. The exposure of workers will be much greater with realistic time frames
for inspection. There is no way workers can make a full visual inspection of storage containers in one minute,
especially taking into account the removing and replacement of the container (F-1.3.). The long term exposure of
low levels of radiation to workers and/are (sic) peoples living nearby are are (sic) not addressed. A one time
exposure is a lot different than an exposure of low levels 24 hours a day for months and years. What are the
cumulative effects? DOE must answer.
Document #: 1016 Comment #: 15 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
At what point will natural deterioration of the containers, Pu, and storage area occure (sic)? How will radiation
effect the containers and the storage area? Will radiation cause more rapid deterioration of the concrete, the
steel, or even the gravel and dirt of the magazines?
Section D D-35
Document #: 1016 Comment #: 20 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Section 6.1.2. states that "the expected level of penetrating radiation would result in no measurable effect or
exposure to an individual occupying a position for an entire year at the nearest Pantex site boundary. Such a level
would be indistinguishable from natural background radiation." Since this "individual" is either me or a member of
my family I question if the Pantex operations and storage of Pu and other radioactive activities may be adding to
the background radiation. How does long term exposure to low levels affect us?
Document #: 1017 Comment #: 1 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
After reading the EA, I visited with a former Pantex employee who also read the EA. He told me that at the time
he worked there, they were only allowed to store 32 or 40 pits per igloo instead of the 270 to 400 04 (sic) 440 pits
they are proposing to store or stage now.
Document #: 1017 Comment #: 2 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
After reading the EA, I visited with a former Pantex employee who also read the EA. ... He said he felt that
monitoring on an 18 month basis is not nearly often enough and that the number of containers proposed to be
monitored is not nearly enough.
Document #: 1017 Comment #: 3 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
After reading the EA, I visited with a former Pantex employee who also read the EA. ... He also wants to know if
the pits are to be segregated according to type for storage or will they be stored randomly?
Document #: 1017 Comment #: 4 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
After reading the EA, I visited with a former Pantex employee who also read the EA. ... He said there is not (sic)
way that workmen can remove, inspect and restore a container per minute. He said it would take hours and hours
to remove all the containers to get to one near the rear of an igloo and that worker exposure would be too great.
Document #: 1019 Comment #: 3 Date: 1/20/93
W.H. O'Brien
Operation Commonsense
Comment:
There also remains a critical need for detailed analysis of the comparitive (sic) stability of the 18
Modified-Richmond magazines vs. the 42 Steel Arch Construction (SAC) magazines and the overall adequacy of
magazines built 50 years ago to hold conventional bombs.
Document #: 1019 Comment #: 4 Date: 1/20/93
W.H. O'Brien
Operation Commonsense
Comment:
Moreover, differences in the density of storage [number of pits] in each magazine could impact the degree of risk
as well as the ease and safety for inspection tasks.
Section D D-36
Document #: 1021 Comment #: 8 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
The DOE points out that using the safer method of storage will fill up the present storage areas this year while the
less safe method will fill it up by the summer of 1994. That horizontal, palletized multiple stacking has not been
used before in either the Modified Richmond or the steel arch constructed magazines rather implies that the DOE
has not previously thought about storage of Pu pits, does it not?
Document #: 1022 Comment #: 2 Date: 2/11/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
p. 2-1 - Both here and elsewhere in the EA (e.g. compare number on p. vii with those on p.3-1), there are
numerous inconsistencies in the number of pits to be stored at Pantex. In addition, this same problem of
inconsistency involves the storage capacity of Pantex and DOE's proposed storage levels at Pantex.
Document #: 1026 Comment #: 5 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
There is no discussion on the stability of plutonium pits during interim or long-term storage.
Document #: 1026 Comment #: 6 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
The effect on the workers is not adequately addressed in this draft document. It does not explicitly analyze doses
to workers who handle the pits in the disassembly areas and those transporting them from disassembly areas to
Zone 4.
Document #: 1026 Comment #: 7 Date: 2/19/93
Tamara Snodgrass
Citizen Comments
Comment:
It does not calculate the doses for the maximally exposed worker, or the doses to workers if inspections are
required more frequently pthan (sic) every 18 months. Not discussed is the increased worker exposures
compared with the current operations, yet it appears those exposures will be several times current levels.
Document #: 1031 Comment #: 3 Date: 3/1/93
Louise Daniel
Citizen Comments
Comment:
Deterioration of the pits and storage containers over the long term should receive intensive study.
Document #: 1032 Comment #: 5 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
There is no discussion on the stability of plutonium pits during interim or long-term storage.
Section D D-37
Document #: 1032 Comment # : 6 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
The effect on the workers is not adequately addressed in this draft document. It does not explicitly analyze doses
to workers who handle the pits in the disassembly areas and those transporting them from disassembly areas to
Zone 4.
Document #: 1032 Comment #: 7 Date: 2/19/93
Betty E. Barnard
Citizen comments
Comment:
It does not calculate the doses for the maximally exposed worker, or the doses to workers if inspections are
required more frequently pthan (sic) every 18 months. Not discussed is the increased worker exposures
compared with the current operations, yet it appears those exposures will be several times current levels.
Document #: 1033 Comment #: 5 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
There is no discussion on the stability of plutonium pits during interim or long-term storage.
Document #: 1033 Comment #: 6 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
The effect on the workers is not adequately addressed in this draft document. It does not explicitly analyze doses
to workers who handle the pits in the disassembly areas and those transporting them from disassembly areas to
Zone 4.
Document #: 1033 Comment #: 7 Date: 2/19/93
Norbert Schlegal
Citizen Comments
Comment:
It does not calculate the doses for the maximally exposed worker, or the doses to workers if inspections are
required more frequently pthan (sic) every 18 months. Not discussed is the increased worker exposures
compared with the current operations, yet it appears those exposures will be several times current levels.
Document #: 1034 Comment #: 5 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
There is no discussion on the stability of plutonium pits during interim or long-term storage.
Document #: 1034 Comment #: 6 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
The effect on the workers is not adequately addressed in this draft document. It does not explicitly analyze doses
to workers who handle the pits in the disassembly areas and those transporting them from disassembly areas to
Zone 4.
Section D D-38
Document #: 1034 Comment #: 7 Date: 2/19/93
48 signatures/form letter
Citizen Comments
Comment:
It does not calculate the doses for the maximally exposed worker or the doses to workers if inspections are
required more frequently than every 18 months. Not discussed is the increased worker exposures compared with
the current operations, yet it appears those exposures will be several times current levels.
Document #: 1035 Comment #: 5 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
There is no discussion on the stability of plutonium pits during interim or long-term storage.
Document #: 1035 Comment #: 6 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
The effect on the workers is not adequately addressed in this draft document. It does not explicitly analyze doses
to workers who handle the pits in the disassembly areas and those transporting them from disassembly areas to
Zone 4.
Document #: 1035 Comment #: 7 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
It does not calculate the doses for the maximally exposed worker or the doses to workers if inspections are
required more frequently pthan (sic) every 18 months. Not discussed is the increased worker exposures
compared with the current operations, yet it appears those exposures will be several times current levels.
Document #: 1036 Comment #: 5 Date: 2/19/93
Arjun Makhijani, Ph.D.
Institute for Energy & Environmental Research
Comment:
III. Container Types - The EA mentions two different types of containers: carbon steel and stainless steel. It
provides no discussion of the relative merits of these containers, how many of each will be used, and what the
effects of various assumptions about the use of these containers (sic) be on the dismantlement rates and on
worker health and safety. In addition, the EA does not discuss the relative merits of each type of container with
respect to a number of crucial issues, such as corrosion rates, inspection frequency, verification issues, and
severity of some accidents, notably those involving possible rupture of containers. The EA also does not provide
the information necessary for an independent evaluation of the containers using such criteria. The EA should also
discuss the experience of corrosion and worker doses with these two types of containers, as well as the maximum
length of time that a pit has been stored in each type.
Section D D-39
Document #: 1036 Comment #: 6 Date: 3/1/93
Arjun Makhijani, Ph.D.
Institute for Energy & Environmental Research
Comment:
IV. Inspections and Inventory-Taking Procedures - The EA claims that a 100 percent inspection of the
single-layer vertical configuration will take one minute per container, including removal, inspection and returning
containers to the magazines. It does not provide any basis for this estimate, nor the variation in the amounts of
time for containers in different parts of the magazine. This information is essential since both the soundness of the
inspection and the doses to workers depend directly on this time estimate.
Further, aisle space would have to be cleared in order to inspect the containers in the rear of the magazine.
This would require taking the containers to other magazines and stacking them appropriately, finishing the
inspections and then retrieving and restacking the containers. Indeed, it would appear that all rows from front to
back but one would have to be cleared and the containers stored elsewhere in order to inspect the containers in
the last rows (parallel to the sides and stretching back from the door.)
It strains the imagination that all these operations, including thorough inspections, could be carried out at the
rate of one minute per container. Further, such procedures raise verification questions, since the moving and
stacking of containers rapidly from one magazine to another increases the opportunities for possible diversion.
The EA should provide detailed descriptions of all inspection procedures and the evidence from actual
operating records that such inspection times are realistic for magazines that are full. It is also necessary for the
EA to specify how much experience there is with inspections with full igloos in vertical configurations. Careful
verification of DOE's inspection procedures is necessary to calculate compliance with dose limits, since workers
will be in a highly radioactive environment, with neutron dose rates in the tens of millirems per hour and gamma
dose rates in the hundreds of millirems per hour.
Finally, taking inventories of pits also raises similar questions. Since the magazines do not have fighting,
physical verification of all of the inventory in a full, vertically stacked magazine would be quite time consuming. Yet
the estimated time for such an inventory is not much greater than the estimated time to inventory a
horizontally-stacked modified Richmond magazine, where all the containers would be in relatively easy view (90
minutes for the horizontally-stacked versus 140 minutes for the vertically stacked.)
The rates of inspection and inventory-taking are critical to estimating worker doses. They are also central to
estimating whether Pantex can meet the worker dose limits without compromising other goals, such as
thoroughness of inspections. In this context, it is also important for the EA to include further information on other
radiation to which the inspection and inventory workers would be subjected under normal or non-routine
circumstances.
Document #: 1037 Comment #: 5 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
There is no discussion on the stability of plutonium pits during interim or long-term storage.
Document #: 1037 Comment #: 6 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
The effect on the workers is not adequately (sic) addressed in this draft document. It does not explicitly analyze
doses to workers who handle the pits in the disassembly areas and those transporting them from disassembly
areas to Zone 4.
Document #: 1037 Comment #: 7 Date: 3/1/93
Bishop Leroy T. Matthiesen
Diocese of Amarillo
Comment:
It does not calculate the doses for the maximaly exposed worker, or the doses to workers if inspections are
required more frequently than every 18 months. Not discussed is the increased worker exposure compared with
the current operations, yet it appears those exposures will be several times current levels.
Section D D-40
Document #: 1038 Comment #: 5 Date: 2/26/93
Boyd M. Foster, President
Arrowhead Mills
Comment:
There is no discussion on the stability of plutonium pits during interim or long-term storage.
Document #: 1038 Comment #: 6 Date: 2/26/93
Boyd M. Foster, President
Arrowhead Mills
Comment:
The effect on the workers is not adequately addressed in this draft document. It does not explicitly analyze doses
to workers who handle the pits in the disassembly areas and those transporting them from disassembly areas to
Zone 4.
Document #: 1038 Comment #: 7 Date: 2/26/93
Boyd M. Foster, President
Arrowhead Mills
Comment:
It does not calculate the doses for the maximally exposed worker, or the doses to workers if inspections are
required more frequently than every 18 months. Not discussed is the increased worker exposures compared with
the current operations, yet it appears those exposures will be several times current levels.
Document #: 1039 Comment#: 5 Date: 3/10/93
Tonya Kleuskens, Chairman
Texas Nuclear Waste Task Force
Comment:
DOE's draft EA does not adequately address the effect on Pantex workers. It does not explicitly consider doses
of radiation to workers who handle the pits in the disassembly area and those transporting pits from disassembly
to Zone 4.
Document #: 1039 Comment #: 6 Date: 3/10/93
Tonya Kleuskens, Chairman
Texas Nuclear Waste Task Force
Comment:
Specifically, the EA does not calculate the doses for the maximally exposed worker, or the doses to workers if
inspections are required more frequently than every 18 months. Also not discussed is the increased worker
exposures compared with the current operations, yet it appears those exposures will be several times current
levels.
Document #: 1040 Comment #: 3 Date: 3/9/93
Cart L. King, President
Texas Corn Growers Assn.
Comment:
They do not even bother to discuss the stability of plutonium pits during interim or long-term storage.
Document #: 1042 Comment #: 12 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Issues that must be specifically discussed include: ...
e. Expected lifetime of Modified-Richmond and SAC facilities, including effects of increased radiation, and their
expected performance from the two new proposed storage configurations and "maximum packing;"
Section D D-41
Document #: 1042 Comment #: 16 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Worker exposure information in Appendix F is based on one inspection in each magazine every 18 months. No
basis is given for why that is the appropriate frequency of inspection. The EA must present a detailed discussion
of why more frequent inspections are not necessary. It must also discuss why more frequent inspections would
not be required in later years, when radiation exposure could result in container or building deterioration.
Document #: 1042 Comment #: 17 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Further, the EA should present comparative data as to the level of exposures if inspections are required every
month or every six months.
The basic information about the length of worker exposure is highly suspect. The draft EA states that for the
Modified-Richmond magazines (single-layer vertical configuration) each inspection would require 70 minutes and
for the horizontal palletized stacking 45 minutes for each side, and for the SAC each inspection would require 140
minutes for single-layer configuration and 90 minutes for the horizontal palletized configuration.
Document #: 1042 Comment #: 18 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Unanswered in the draft EA are basic questions, including:
- What kind of lighting will be provided for the inspections since the magazines apparently have no lighting;
Document #: 1042 Comment #: 19 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Unanswered in the draft EA are basic questions, including: ...
- If each container will be removed from the magazines in case of single-layer vertical stacking (as stated on p.
F-2), what kind of accidents could occur, what exposures will occur, and how long would such moving actually
take (certainly longer than the few seconds estimated);
Document #: 1042 Comment #: 20 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Unanswered in the draft EA are basic questions, including: ...
- During removal how many pits would be outside at any one time, what types of accidents could occur (including
from weather related events), how many times would a pit actually be handled - i.e., moving pits to allow aisle
space to reach the rear of the magazine; how could just two workers properly keep track of and log the pits to
ensure that they are each returned to their assigned storage location - if additional workers are required,
additional exposures will result;
Document #: 1042 Comment #: 22 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Unanswered in the draft EA are basic questions, including: ...
- If the pits will not be handled or moved during inspections as is implied for horizontal palletized stacking, how will
corrosion or leaks in "hidden" areas be identified;
Section D D-42
Document #: 1042 Comment #: 29 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
The 18 Modified-Richmond magazines capacity would increase from 370 to a maximum of 440 pits and the SAC
magazines could hold up to 384 pits. However, page 3-1 states that the Modified-Richmond would increase from
378 to 440 pits and the SAC could hold 384 or 392 or 406 pits (according to footnote 2). Which numbers are
correct? Using the maximum figures shows that more than 24,000 pits (not 20,000 pits) could be stored. The EA
should discuss if storage for more than 20,000 pits is eventually necessary, how could Pantex accommodate such
an increase?
Document #: 1042 Comment #: 36 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
7. Page 3-1. Footnote 1 states that using the 18 Modified-Richmond magazines for up to 6,800 pits (or 378
each) "is not currently the operationally preferred configuration" but does not explain why that is so.
Footnote 2 states that the 406 pits/magazine single-layer vertical configuration "will not be considered for use"
but does not provide any basis for that statement.
Document #: 1042 Comment #: 38 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Variations or combinations of potential storage configurations are mentioned. What are the costs and risks of
such variations? Why are aisles not required? How can inventories be done without aisles unless virtually the
entire magazine is taken outside?
Document #: 1042 Comment #: 40 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
"Individual pit containers could rest on casters rather than on the concrete floor of magazines," but Figure 3.2
(page 34) says that having six rows of pits on casters is "operationally preferred." The EA must provide an
analysis of why such a configuration is operationally preferred. For each configuration, the EA must provide an
analysis of how inspections would be done, including how much movement of pit containers would be necessary,
how two workers could ensure that each container was returned to its assigned location, how much time the
configuration takes to load and unload and the calculated exposures. For containers on casters, the EA must
describe the operational experience with casters, how frequently casters break or containers fall off.
Section D D-43
Document #: 1042 Comment #: 49 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
15. Page 6-2. Some of the specific assumptions for the proposed action alternative do not appear to be
conservative:
- inventory inspections should be calculated on a more frequent basis than once every 18 months; to be
consistent with assumptions used for the no-action alternative end to make reasonable comparisons, inventory
inspections should be each month (see page 6-3).
- since the maximum Modified-Richmond capacity is 440 pits (page 3-1), 220 pits per side could not be
inspected in 70 minutes. Unless better information about actual inspection rates is available, a conservative
assumption should be that the time required is at least twice that specified;
- inspecting 392 pits in a SAC (maximum capacity specified on page 3-1) is assumed to take 140 minutes, the
same amount of time given for inspecting 440 pits in a two-sided Modified-Richmond magazine. Inspecting more
than ten percent more pits should take at least more than ten percent more time.
- horizontal palletized stacking is assumed to lake about one-third less time than for single-layer stacking.
Justification and actual calculations are needed to justify that difference;
- corrosion inspections are specified only for single-layer vertical configuration. However, container and pellet
integrity inspections are necessary for palletized storage and must be assumed in calculations.
- two hours for storage facilities to be open is not conservative based on 140 minutes each (which itself is not
conservative). In terms of number of workers to be affected, more than two workers per inspection should be
used and two workers should be assumed to inspect only one magazine per day.
- capacities assumed are not consistent with those stated in other places in the draft EA. Consistent number
should be used throughout.
- radiation dose rates are not adequately supported; actual historically measured rates and calculations, and
conservative extrapolations from those data, should be used.
The statement that shielded forklifts and AGVs "would further reduce worker exposure" should be supported
by actual calculations and analysis. If such vehicles do have that effect, the EA should specifically describe the
health effects and justification for storing pits without using such vehicles.
16. Page 6-3. Some assumptions used for the no-action alternative do not appear to be conservative:
- 70 minutes inventory inspection time is not well supported (see comments about page 6-2);
- corrosion inspections only once in 18 months;
- see also comments about page 6-2 for other assumptions.
Document #: 1045 Comment #: 10 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
9) Finally, but of extreme importance, the draft EA fails to make clear the implications for worker exposure if the
change from current pit storage to intensified pit storage begins to occur before automated systems are
developed. Nor does the draft EA clearly commit to Best Management Practices if the decision is delayed. In fact,
it does not clearly commit to best management practices even if the intensified storage is approved.
In Section 3.0 describing the proposed action, it sides that proposed action storage in either type of magazine
would be, "in one of two configurations: multiple stacking... and/or a single layer..." It then continues, "These two
configurations represent the bounding cases for the number of pits that would be held in a single
Modified-Richmond or SAC magazine." (p. 3-2)
No where in the draft EA does DOE commit to not using the single-layer configurations depicted in Figures 3.5
and 3.6, both described as "(Bounding)," yet both depicting and adding up to the maximum packing arrangement.
However, on page 4-1 the discussion warns of maximum packing, and states: "Actual best management practice
to facilitate required safeguards and security activities and reduce worker exposure to radiation could dictate use
of other storage configurations that would provide less pit storage capacity."
In addition, the proposed action which would seem to allow DOE ample room for storage, still hedges.
"Individual pit containers could rest on casters rather than on the concrete floor of the magazines, and aisles may
also be used. This would facilitate inventory operations, ensure worker safety, and accommodate operational
needs." (p. 3-2)
Wording such as "could" and "may" for procedures which ensure worker safety and benefit other needs is
unacceptable in this document -- particularly when outlining the proposed storage option.
Section D D-44
Document #: 1048 Comment #: 12 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pits change over time, what happens to containers that change overtime? With pits and containers changing
over time, what are we looking at for the future? Do you have any idea how it these will react, either individually or
collectively, over time?
Document #: 1048 Comment #: 17 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
The Executive Summary, vii, and 3-1 states "SAC magazines have not been used previously for holding pits, and
the multiple stacking configuration has not been used previously in SAC or Modified-Richmond magazines." Our
question is then why are you going to store plutonium, with a half life of 24,000 years in a structure which is not
proven to be 100% safe for `holding pits'?
Response #: D.23
The proposed action is consistent with storage activities currently conducted at Pantex Plant.
Magazines will continue to be used to stage weapons, and pits and weapons will not be
placed in the same magazine. Operational changes, such as automated inventory, shielded
forklift, or potentially modified inventory schedules, have been investigated to support the
magazines for interim storage of pits.
Individual Magazine Capacities
Pits in each magazine type can be stacked in the single-layer vertical or the horizontal
palletized multiple stacking configuration. For the Modified-Richmond magazine, the horizontal
palletized multiple stacking configuration is 440 (Figure 3.3) and the single-layer vertical
configuration is 378 (Figure 3.5). For the Steel Arch Construction magazine, the horizontal
palletized multiple stacking configuration is 392 (Figure 3.4) and the single-layer vertical
configuration is 384 (Figure 3.6). Figure 3.4 in the Environmental Assessment exhibits a
center section that consists of two rows of nine sets stacked three high with four pits in each
set for a total of 216 pits. There is also a left and a right row of 11 sets stacked two high with
four pits in each set for a total of 176 pits. The combined total for Figure 3.4 is 392 pits. The
Steel Arch Construction magazine shown in Figure 3.6 is capable of having 406 containers but
the operational limits is set to 384 containers, which will allow for some space in the room for
movement of the containers.
The close pack vertical configuration shown in Figure 3.5 of the Environmental Assessment is
for 378 containers in a solid arrangement. If all 18 Modified-Richmond magazines were
configured like this, the total capacity would be 6,804 (the 6,800 maximum packing
configuration). The operationally preferred configuration shown in Figure 3.2 of the
Environmental Assessment is for 336 containers in a solid arrangement with an aisle on each
side of the magazine. If all 18 Modified-Richmond magazines were configured like this, the
total capacity would be 6048 (the nominal 6000 pits). The operational preferred configuration
in Figure 3.2 facilitates required safeguards and security activities and reduces worker
exposure to radiation by providing an aisle down each side of the magazine.
Total Magazines Capacity
The maximum interim storage capacity is based on the number of magazines intended to be
used and the type of configuration used.
The maximum interim storage possible with the single-layer vertical configuration in both the
Modified-Richmond and Steel Arch Construction magazines would be approximately 22,932 pit
containers.
Using the preferred horizontal palletized multiple configuration, the 18 Modified-Richmond
magazines would contain 7,920 pits and the 42 Steel Arch Construction magazines would
contain 16,464 pits for a total of 24,384 pits.
These capacities are based on the Modified-Richmond and Steel Arch Construction
magazines being completely dedicated to interim storage. This situation is not practical
because some magazines would have to be used for weapons staging to support the
weapons dismantlement process. Staged weapons and stored pits will not be together in the
same magazine.
The paragraph in Section 3.0 states "It should be noted that some Steel Arch Construction
magazines would be reserved for assembled weapons and component staging activities that
have historically taken place, and will continue to take place, in these facilities." If 20,000 pits
were stored with the maximum capacity in the 18 Modified-Richmond and the remainder in the
Steel Arch Construction magazines, about 11 magazines, would be left for other activities.
Therefore, the 20,000 pit containers to be stored in Zone 4 is a realistic approximation for
future needs, not storage capacity.
Storage Configuration Bounding Analysis
The storage configuration described is the bounding case for the number of pits that would
be held in a single magazine. Variations and/or combinations of these arrangements would
not exceed the boundary assumed in the analysis for the Environmental Assessment. The
words "could" and "may" are used in the Environmental Assessment to indicate possible
options for pit storage. All possible storage configurations considered are within the bounding
analysis presented in Section 6.0 and the appendices.
The magazines have been analyzed in the Pantex Plant Final Safety Analysis Report for Zone
4 Magazines for the maximum density of material that can be stored in each magazine type.
The risk associated for each magazine assumes that the magazine has the maximum number
of pits. Designation of which stacking options will be used in each magazine is done in the
Environmental Assessment to "allow operational flexibility and facilitate security and
safeguards." The inspection process was developed with the maximum number of pits
possible for the magazine. The risks are bounded by the consequence analyses performed
as a result of the Pantex Plant, Final Safety Analysis Report for Zone 4 Magazines. The dose
rate calculations are also based on the maximum number of pits in a magazine.
The variations or combinations of potential storage configurations are for the horizontal
palletized multiple stacking configuration or the single-layer vertical configuration. Aisles are
not required in the single-layer vertical configuration because absence of the aisles does not
reduce the safety of the magazine. The inventory of the single-layer vertical configuration can
be performed without an aisle by rotating the containers in and out as needed, and therefore,
not having to unload the entire magazine. The single-layer vertical configuration (full with no
aisles) is not the preferred option because the horizontal palletized multiple stacking
configuration provides greater capacity, better access, and an opportunity to reduce long term
exposure. However, the single-layer vertical configuration may be necessary during the
transition to the horizontal palletized multiple stacking configuration.
Comparison Between the Vertical and Horizontal Configurations
For the single-layer vertical configuration, the individual pit containers may rest on casters
rather than on the concrete floor for ease in rolling the container. This scheme is a transition
before implementation of the horizontal palletized multiple stacking configuration. The pit
containers can withstand a drop considerably more severe than would occur if a container
drops due to a broken caster.
The horizontal palletized multiple stacking configuration is preferable because it will minimize
personnel time inside the magazines (therefore minimize radiation exposures) and maximize
the interim storage space for pit containers. With this configuration, the pit containers will be
transported from the truck into the magazines on precision pallets (four or six horizontally
oriented pit containers semi-permanently affixed to the pallet) secured to a specially equipped
shielded forklift. The shielded forklift is designed to minimize the possibility of operational
accidents leading to a release of radioactive material. A number of electronic and mechanical
interlocks have been designed into the forklift to reduce the possibility of puncturing a
container. Efforts are under way to develop Automated Guided Vehicles that could be used to
assist in taking inventories using bar code readers. This would further reduce worker
exposure for inventory activities.
Similar types of pits will be placed on a pallet of either four or six units for the horizontal
palletized multiple stacking configuration. Therefore the pits will be segregated by type in that
each pallet will typically have only one kind of pits on it. There will not be segregation of the
pits for each magazine. Since the pits are in geometrically safe containers, there is no
criticality benefit from the segregating of pits. An automated storage and retrieval system is
being developed so that it will be possible to retrieve any particular pallet.
Doses and Dose Rates for Inspections
The estimates presented in Appendix F of the Environmental Assessment assume a very
conservative pit source term with the maximum americium (Am-241) buildup and a smaller
floor space (one half of the magazine). This maximizes the dose rates and minimizes the
distance between the source and the exposed worker. Section F.3.3 points out that the actual
dose rates measured during worker exposure for these types of operations with vertical
configured containers were about 30-60 mrem/hr, whereas the calculated dose rates were 250
mrem/hr for palletized and 522 mrem/hr for the single-layer vertical configuration (see Section
F.3.2). Even with the bounding calculation assumptions, the collective doses given in Section
F.5 indicate that implementing the proposed action would give 100-200 person-rem/yr for
single-layer vertical configuration and 50-100 person-rem/yr for the horizontal palletized
multiple stacking configuration. The no-action proposal (continuing storage as vertical
stacking configuration and stopping dismantlement when magazines are full) gave a
calculated collective dose at 50-100 person-rem/yr. However, the field survey dose rates are
much less (60 mrem/hr versus 522 mrem/hr), which indicates that actual exposures could be
much less (about a factor of nine) than the calculated exposures for each configuration.
Appendix F of the Environmental Assessment summarizes the conservative dose calculations
used to make the estimates of the exposures for the radiation workers for the vertical and
horizontal palletized multiple stacking and inventory operations. Implementing the proposed
action (storing the pit containers in vertical or horizontal configurations) would only give a
calculated maximum of about a factor of three increased collective dose (see F.5,
Conclusions). Since the calculated doses are about nine times greater than the actual
averaged survey doses, it is not likely that the collective doses will increase for the Zone 4
activities implemented.
The preferred alternative, the horizontal palletized multiple stacking configuration, gives a
factor of two to four decrease in collective doses and allows expanded interim storage for the
containerized pits without an increase in collective dose above the current operations. The
horizontal palletized multiple stacking option actually decreases the calculated collective doses
over the single-layer vertical configuration. The horizontal palletized multiple stacking
configuration gives a dose reduction factor of about two to four due to the remote handling
and increased distance factors when compared to the single-layer vertical configuration. The
expected reduction in radiation exposure to personnel with the shielded forklift is anticipated
to be a factor of twenty.
Individual radiation worker exposures are controlled by the Pantex Plant Administrative Control
Limit of 1 rem/yr which is significantly lower than the Federal radiation limit of 5 rem/yr. The
proposed automation and the horizontal stacking will allow increased storage capacity without
increasing the collective dose and with no change in the individual exposures above the
current operations. Even with the proposed greater number of pit containers the collective
dose and individual worker doses are not expected to increase over previous annual doses.
Using the shielded forklift (and later the Automated Guided Vehicles) with the horizontal
palletized multiple stacking configuration, and by only doing inventories on an 18 month basis,
individual and collective doses are expected to decrease. Appendix F, Worker Radiation
Exposure, presents the detailed work activities that are compared between the vertical and
horizontal stacking configurations.
Eighteen-Month Inventory Schedule
Inventories have been performed on the magazines bimonthly. During the transition to the
horizontal palletized multiple stacking configuration, the inventory cycle has been increased
because adequate security and safeguard controls are in place and the magazines will be
secured for long periods of time. Once a magazine is secured, it is anticipated that it will not
be opened until the next scheduled inventory. The longer inventory cycle will be used for the
single-layer vertical configuration and will result in a lower worker dose since the occupancy
time will be considerably less. When the Automated Guided Vehicles are operational and
available to take inventories for the horizontal palletized multiple stacking configuration, the
inventory cycle will be re-evaluated. The Automated Guided Vehicles will allow a more
frequent inventory cycle but still maintain a reduced worker dose.
An exception was requested and granted by the Department of Energy (Office of Security
Affairs) for the vertical single-layer vertical configuration. The exception allows the physical
inventory of 18 magazines to be extended from bimonthly to 18 months. The exception to the
bimonthly physical inventory, as required by the Department of Energy Order 5633.3, only
applies to the 18 magazines because only 18 magazines are currently approved for interim
storage of pits.
The exception was based on inventory credits determined using the July 1992 Office of
Security Affairs guidance on extending physical inventory periods and additional detection
capabilities within Zone 4. With the approved exception, the extended cycle for physical
inventory is still in rigorous compliance with the Department of Energy Orders and procedures
for ensuring safe and secure storage of pits. Providing all conditions of the original approval
are adhered to, the intent of the original exception was that it would permanently extend the
physical inventory periods to 18 months. In accordance with Department guidance on
physical inventory requirements and the provisions of Department of Energy Order 5630.11A,
the current Pantex exception on inventory frequency for the Zone 4 igloos would be converted
to a variance. The variance would be approved for an indefinite period of time consistent with
the previously approved exception by the Office of Security Affairs (SA-10). A recertification
will continue to be necessary every 18 months based on the original terms and conditions of
the exception. The Department of Energy Office of Field Security Oversight and the
Albuquerque Operations Office will be jointly responsible for assuring that the recertification
will be conducted. This is considered consistent with the original approval of the exception,
and the applicable provisions of Department of Energy Order 5630.11A, for both deviations
and approvals. In addition, this process will continue to assure that adequate safeguards are
employed for the security of Special Nuclear Material and will provide for a greater measure of
safety for Plant personnel responsible for conducting inventories at the igloos.
Magazine Stability with Age
The Modified-Richmond and Steel Arch Construction magazines have some similarities. Both
types of magazines have at least 3 feet of earth overburden and natural circulation ventilation.
Each magazine type is evaluated to determine its increased usage by a systematic process to
identify hazards within a given operation; to describe and analyze the adequacy of measures
taken to eliminate, control, or mitigate identified hazards (e.g., stability of construction); and to
analyze and evaluate potential accidents and their associated risks. An analysis predicting the
consequences of an aircraft impact, tornado, external fire, explosion, and other accidents has
been documented in the Pantex Plant Final Safety Analysis Report for Zone 4 Magazines. The
expected lifetime of the magazines is dependent upon the ability of Pantex Plant to maintain
the magazines within the conditions specified by the Pantex Plant Final Safety Analysis Report
for Zone 4 Magazines. These conditions are periodically assessed to verify operational
reliability of the magazines.
Pit and Container Stability with Age
Pits have been under careful scrutiny for many years through various the Department of
Energy programs, particularly the weapons Quality Assurance Testing Program, that includes
the Pit Surveillance Program and an accelerated aging program, to ensure that aging-related
defects do not develop in pits. The same pits have already spent several decades under the
surveillance of the Department of Energy, the national laboratories, and the military in the field.
A routine stockpile surveillance has been performed on the pits for 20 to 30 years in more
hostile environments of Zone 4. All data indicates that pits and containers will not degrade
over the interim storage period. A pit surveillance program will continue in effect throughout
the entire storage time frame.
Although the half life of plutonium is 24,000 years, the proposed action is to provide additional
storage for an interim time period. The overall conclusion drawn from the accident analysis is
that the potential for adverse impacts to the plant workers, the public, or the environment is
low.
Inspection of Pits and Containers
The Sandia National Laboratory Stockpile Evaluation Department has defined a sampling and
inspection plan to verify the integrity of the pits and containers during interim storage. In this
plan, coincident with the 18 month physical inventory, 10-20 containers of the total site
population per year would be statistically selected for 100 percent visual inspection of the pits
and the container and individual container parts. In addition to visual inspection for rust and
corrosion, inspection of the insulation, weld integrities, and plastic parts will be conducted.
The statistical sampling inspection program will be conducted for both the single-layer vertical
and horizontal palletized multiple stacking configurations. The single-layer vertical
configuration will be performed on an 18 month period. The inspection period for the
horizontal palletized multiple stacking configuration has not yet been determined.
The 100 percent corrosion inspection cited in Section F.1.3, is for the bounding radiation
exposure analysis and does not mandate that 100 percent corrosion inspection inside the
magazine will be performed. It is planned that a visual inspection of magazine conditions and
of exposed pit container surface followed by removal of surveillance samples would take
place. A corrosion inspection of the pits, pit containers, and the individual parts will be
performed on the 10-20 containers selected from the total site population as surveillance
program samples. After the results are reviewed and it is determined if additional corrosion
inspection is needed, the dose rates in Appendix F will bound the expected worker dose even
if a 100 percent corrosion inspection is performed.
For the single-layer vertical configuration in the Modified-Richmond magazines, containers may
be on casters for ease in rolling the container. Containers will be moved to the entrance of
the magazine (to reduce dose to personnel from other containers), a visual inspection
performed for corrosion (rust and paint bulging). The container will then be moved back into
the magazine. The number of pit containers allowed out of the magazines (on the apron) is
not specified. Only the minimum number necessary for operational continuity will be moved;
even then, the maximum number allowed will be based on environment, safety and health and
security considerations. This operation will be performed by two people and is anticipated to
take one minute for each container. This estimate is based on current inventory operations
and knowledge of what is proposed for this future inventory activity for interim storage
configuration. The one minute for each container is based on dividing the time expected to
perform the inspection for an entire magazine by the number of containers in the magazine.
In all cases, estimates are considered conservative in comparison to current inventory time
requirements.
Under normal circumstances, it would be expected that no corrosive media other than
moisture resulting from changes in relative humidity would come in contact with the interior
surfaces of the magazine. In the absence of a highly corrosive media, there is no mechanism
to cause corrosion that would lead to the degradation of the pit containers. It should be
noted that minor rusting of the carbon steel container is expected but in no way impacts
containment of Special Nuclear Material or the ability of the AL-R8 to serve as a suitable
storage container.
Plutonium Release Conditions
Several conditions preclude an accidental release of plutonium. The first is the absence of a
credible initiating event. The second is that the metal is encapsulated in a metal shell of
material to prevent direct exposure to the atmosphere. The third is that the encapsulated pit
is packaged in a container to ensure that the contents will remain stationary. Additionally, an
environmental monitoring program encompassing sampling of the atmosphere, soil,
vegetation, and surface water for radionuclides used at Pantex Plant exists, and would detect
releases of the radionuclides should such releases occur in the storage area.
The accident analysis in Appendix A of the Environmental Assessment is applicable if the
containers are either inside or outside of the magazine. Accidents due to weather-related
events are not applicable to containers outside the magazine because work is suspended; the
containers are placed in the magazine; and the doors are secured if there is a tornado watch,
static electricity alert, or any other inclement weather.
The statement in Section 6.1 of the Environmental Assessment that "routine operations of the
No-Action Alternative are similar to those for the proposed action" is in regard to the subject of
the paragraph - minor releases of air pollutants and a minor increase in particulate (dust).
Dose During the Inventory Process
As indicated in Section 6.1.1.2 and Appendix F the current collective dose for Zone 4
operations is less than 10 person-rem/yr. Measured dose rates in Modified-Richmond
magazines currently used for pit storage are on the order of 30 mrem/hr.
As discussed in Sections 6.1, 6.1.1.1, and the summary, no radiation exposures (acute or
chronic) to the public are anticipated for the proposed action. The estimated worker
exposures provided in Sections 6.1.1.1 and 6.1.1.2 and Appendix F are based on a year of
routine operation. The dose is not assumed to be provided by a one time exposure but by a
series of exposures occurring over the work year. The health effects discussed (i.e., the
increased cancer risk) are based on the long-term accumulation of chronic low-level
exposures. Detailed and current information of the effects of low-level chronic radiation
exposure can be found in the National Research Council, Health Effects of Exposure to Low
Levels of Ionizing Radiation; (BEIR V), and Committee of the Biological Effects of Ionizing
Radiation, National Academy Press, Washington, DC, December 1989 (UNSCEAR 1988)
reports.
Pantex Plant performs measurements of penetrating radiation at several off-site locations near
the facility and at a background location near the Bushland Agricultural Research Center,
approximately 30 miles southwest of the facility. The results of the measurements, which have
been confirmed by independent measurements made by the Bureau of Radiation Control of
the Texas Department of Health, do not indicate levels in excess of expected background
levels. Therefore, personnel who reside near Pantex Plant receive no additional low-level
radiation exposure as a result of Pantex Plant operations.
The average annual background exposure from natural radiation received by people living in
the United States is approximately 300 mrem ("Exposure of the Population in the United States
and Canada from Natural Background Radiation", Report #94 of the National Council on
Radiation Protection and Measurements, Table 9.6). There are parts of the earth where
average annual background exposure is in the range of 1,000 to 3,000 mrem ("Environmental
Aspects of Nuclear Power", Jeffrey G. Eichholz, Page 110). No adverse effects on human
populations living in these regions of elevated background radiation exposure have been
observed.
The impact to worker exposure if inspections are performed at higher frequencies of once
every month or six months, as opposed to the proposed schedule of once every 18 months,
is an increased dose to workers. As can be seen in Section 6.1.1.1 and more fully explained
in Appendix F, the radiation doses to workers resulting from inspections are directly
proportional to the frequency at which these inspections are performed. Thus, if inspections
are performed every 6 months rather than every 18 months, resulting doses from these
operations would increase threefold.
The reason for the decreased inspection time required for the horizontal palletized multiple
stacking configuration versus the single-layer vertical configuration is not fully discussed in the
Environmental Assessment. The horizontal palletized multiple stacking configuration allows
inspections to be performed in less than 60 percent of the time required for the single-layer
vertical configuration. The horizontal palletized multiple stacking configuration allows the use
of a forklift to lift and manipulate a group of containers in a way that facilitates and speeds
inspections. In the single-layer vertical configuration the containers must be individually
handled for the inspection process and therefore have a longer inspection time and a larger
worker dose.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 6.0 has been changed to reflect the comments.
mrem = millirem
hr = hour
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.24) FOLLOWS.
Document #: 1015 Comment #: 14 Date 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Additionally, chemical/toxic gas releases have occurred, the incidents not being made public until well after
the fact, if at all.
Response #: D.24
Any unusual releases are reported to the 24 hour Emergency Operations Center at Pantex
Plant. The operations center reports any incident to the regulatory authorities as required in
Section V.D of the Resource Conservation Recovery Act permit for Pantex Plant. The permit
requires any release which endangers the public to be reported orally within 24 hours
pursuant to Title 31 Texas Administrative Code, Section 305.123(9). It is still the responsibility
of the civil authorities to control public announcements. In any emergency situation where the
general public is endangered, civil authorities would make a public announcement and
information centers would be quickly established by the Department of Energy to inform the
public concerning the nature of the hazard and how to respond.
The only unusual release of chemical/toxic gases at Pantex Plant was the tritium release
incident that occurred in 1989. The incident was immediately reported to State and local
authorities in accordance with the requirement of the Department of Energy Order 5300.3B
and with the Pantex Plant Emergency Plans. State and local authorities had responsibility for
making public announcements. The release was controlled on-site and did not represent any
hazard to the general public. No additional chemical/toxic gases have been released in the
past that were considered abnormal at the time, such as disposing of solvent chemicals by
burning. All Department of Energy occurrences become public documents and can be found
in reading rooms located in Amarillo and Panhandle, Texas.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.25) FOLLOWS.
Document #: 1042 Comment #: 15 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
The draft EA contains no discussion of worker exposures during dismantlement and at any other time prior to
the inspections in the interim storage facilities. In fact, significant exposures could occur during dismantlement,
during storage prior to arrival at Zone 4, during transport of the pits from the disassembly facilities to Zone 4, and in
loading the pits into the Modified-Richmond and SAC buildings.
Questions that must be addressed in the EA include:
- How many workers are involved in those operations;
- What is the duration of exposures;
- What are the potential maximum exposures;
- What kind of accidents can occur during disassembly, storage, and shipment to Zone 4,
- What kind of accidents could occur during loading pits into the Modified-Richmond and SAC magazines;
- Will the differing storage configurations in the two types of storage buildings require different training for
workers to avoid accidents;
- What kind of cumulative exposures can workers receive for participating in various activities, or will each
operation have its own specialized work force?
Response #: D.25
Dismantlement activities other than interim pit storage are not within the scope of this
Environmental Assessment. The dismantlement of nuclear weapons has always been part of
the mission of the Pantex Plant, and all potential accident scenarios have been addressed in
the 1983 Final Environmental Impact Statement, Pantex Plant Site (DOE/EIS-0098).
The radiation worker operations concerned with interim storage are addressed in Appendix F
of the Environmental Assessment and include inventory, container corrosion inspection, and
miscellaneous operations. Assumptions about the number of workers and projected exposure
rates can be found in this discussion. The radiation worker exposures in Zone 4 as well as
the rest of the site will be routinely monitored to ensure that they will not exceed the Pantex
Plant Administrative Limit of 1 rem/yr. The As Low As Reasonably Achievable Program
Coordinator reviews the radiation doses monthly. If any adverse trends are found, these are
investigated to determine what corrective actions are appropriate. Workers in Zone 4 do not
participate in the disassembly and transport operations outside of Zone 4. Zone 4 workers
are not expected to receive greater than 200 mrem/yr from any of these operations.
Potential accidents that could occur as a result of operations in Zone 4 were analyzed in
Section 6.2 and Appendices A, B, C, D, and E of the Environmental Assessment. Additional
information on potential accidents during Zone 4 operations can be found in the Pantex Plant
Final Safety Analysis Report for Zone 4 Magazines. Also, improvements to operations to
reduce accident potential such as systems to prevent a forklift from crushing a containerized
pit, technology upgrades such as the shielded forklift and the Automated Guided Vehicle are
identified in the Pantex Plant Final Safety Analysis Report for Zone 4 Magazines.
Training of radiation workers at Pantex Plant, including Zone 4 workers, involves classroom as
well as on-the-job training (Specialized Training, the Department of Energy Radiological
Control Manual Article 634). The differing storage configurations do not require different
training using the written standard operating procedures for vertical and horizontal stacking
configurations to ensure the operations are done to limit radiation exposure.
yr = year
mrem = millirem
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.26) FOLLOWS.
Document #: 1012 Comment #: 2 Date: 1/16/93
Margie K. Hazlett (1)
Citizen Comments
Comment:
The General Accounting Office, the investigating arm of Congress, early in 1991 said Pantex had one of the worst
occupational safety records in the Department of Defense (sic) Weapons complex.
Document #: 1021 Comment #: 14 Date 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
There is no reference to Coy Overstreat, who has been collecting cases of atomic radiation victims for years. The
search for potential problems seems thoughtful but there is no mention of previous complications. I would
recommend the Governor insist upon a careful evaluation of all previous accidents, injuries and environmental
abuses which have occurred at Pantex and other DOE plants before permitting even one Pu pit to be stored in
Texas.
Response #: D.26
Pantex Plant operations experienced an average of 120 recordable injuries per year from
1990-1992. Approximately 41 percent of those injuries resulted in lost time, with an average of
592 lost days and 915 restricted workdays reported by Pantex Plant each year. Compared to
other Department of Energy production contractors, Mason & Hanger ranks 11 out of 14
relative to the number of recordable injuries. No fatalities were reported at Pantex Plant from
1990-1992 (no fatalities have been experienced since 1977). The resultant 1990-1992 average
total recordable case and lost workday case rates for Pantex Plant were significantly lower,
5.03 and 2.05 respectively, than the Bureau of Labor Statistics average rates of 8.5 and 3.9.
Table 1 provides Pantex Plant statistics for 1990-1992 and a three-year average for Pantex
Plant. The table illustrates the decline in total recordable cases, lost workday cases, and lost
workdays Pantex Plant has experienced since 1990. This is significant considering that each
year the number of employees and hours worked have increased. Table 2 provides a direct
comparison of the Pantex Plant three-year average rates with the Bureau of Labor Statistics
rates for all industrial workers.
The data provided do not go back past 1990 because on January 1, 1990, the Department of
Energy changed the reporting requirements and adopted 29 Code of Federal Registrations
1904, for recording and reporting occupational injuries and illnesses. Field Offices were
advised to use Department of Labor publication, "Record Keeping Guidelines for Occupational
Injuries and Illnesses," for determining the recordability of injuries and illnesses. Prior to that
time, Pantex Plant reported injuries and illnesses in accordance with the DOE-76-45/7A,
SSDC-7B, "Department of Energy Guide to the Classification of Recordable Accidents." The
intent in adopting Department of Labor regulations was to ensure that the Department
captures all data for the types of cases being reported by the rest of the nation, and to
establish a record keeping and reporting system at the Department of Energy comparable to
the very stringent Department of Labor system.
Pantex Plant is continuing efforts to reduce the number of work-related injuries by increasing
employee awareness. Monthly injury reports, electronic message boards, incentive programs,
and training courses are a few ways that Pantex Plant is getting the message out to inform
and educate employees on how to prevent work-related injuries.

Table D.26-1 - Pantex Plant Composite Statistical Summary
1990 1991 1992 Avg.
Equivalent Full-time Employees 2274 2468 2728 2490
Work Hours (per 1000) 4321 4691 5289 4767
Total Recordable Cases (TRC) 138 103 118 120
TRC Rate 6.39 4.39 4.46 5.03
Number Illness Cases 10 11 7 9
Illness Rate 0.46 0.47 0.26 .38
Number Lost Work Cases (LWC) 82 28 38 49
LWC Rate 8 1.19 1.44 2.05
Lost Workdays:Away 1017 384 374 592
Restricted 2237 123 385 915
Total 3254 507 759 1507
Lost Work Day Rate 150.63 21.62 28.70 63.23
Number Fatalities 0 0 0

Table D.26-2 - Average Injury Rates Comparison for 1990-1992
Total Lost Lost
Recordable Workday Work
Cases Cases Days
Pantex Plant Composite 5.03 2.05 63.23
Bureau of Labor Statistics 8.5 3.9 75.2
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.27) FOLLOWS ON PAGE D-59.
Document #: 1007 Comment #: 4 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 4-2, Lines 6-10: The "Note" in italics is misleading. It suggests that any alternative involving shipment will
require repackaging into a shipping container at Pantex and repackaging into a suitable storage container at the
alternate site. Page 3-2, lines 3-7 indicate that pits may be stored in Type B shipping containers. It would appear
that in any case, the radiological exposure to workers would be approximately the same as when pits were
routinely returned to Rocky Flats Plant.
Document #: 1007 Comment #: 7 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 4-4, Lines 29-38: Concerns expressed in this passage would not necessarily be valid if the pits were
packaged and shipped to an alternate location in suitable transportation/storage containers, as is suggested on
Page 3-2.
Document #: 1016 Comment #: 11 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Is there independent quality control on the containers? What are "other approved containers"? The EA must
address these questions.
Document #: 1016 Comment #: 16 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
If the Pu would have to be repackaged into Type B shipping containers for shipping (4.1), why can they not be
stored in the Type B containers as stated by 3-2.
Document #: 1017 Comment #: 5 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
After reading the EA, I visited with a former Pantex employee who also read the EA. ... He also said that the new
stainless steel containers shown to the media are apparently brand new and most pits are stored in the od (sic)
style carbon steel containers that will rust and deteriate (sic) faster. He said the packing material shown to the
media is all new to him and apparently both the stainless steel containers and the packing material are new since
the EA was written.
Document #: 1019 Comment #: 2 Date: 1/20/93
W.H. O'Brien
Operation Commonsense
Comment:
There appear to be differences in the relative degrees of protection provided by the two types of storage
containers for the plutonium pits.
Section D D-57
Document #: 1042 Comment #: 23 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Unanswered in the draft EA are basic questions, including: ...
- What types and levels of gas buildup can occur inside the pit storage containers;
Document #: 1042 Comment #: 28 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
The stated purpose of the EA is to evaluate environmental impacts of additional pit storage. However, there is no
discussion of some storage related activities, including transporting pits from disassembly bays to Zone IV and the
actual loading of pits into the magazines.
Document #: 1042 Comment #: 37 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
8. Page 3-2. "The majority of the stored components in Zone 4 would be packaged in AL-R8 containers... but
other approved containers" may be used. The EA should provide much more information about the AL-R8
containers, including:
- description, including size, weight, composition (compare with page 6-1 description of "carbon or stainless
steel drum")
- how many currently exist,
- how old they are,
- how many new containers will be built,
- what kind of independent certification will be required,
- what the demonstrated optimum lifetime has been,
- what kind of deterioration/corrosion has occurred with the existing inventory?
Similarly, much more information about "other approved containers" is necessary, including:
- detailed information on the specific containers to be used,
- what kind of independent certification will be required,
- whether combined storage/transportation containers can be used,
- the time frame within which such containers will be available?
Document #: 1042 Comment #: 41 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
For palletized multiple stacking, the EA must describe how frequently the pellets would be changed, the history of
damage and breaking of the pallets, accident scenarios including possible releases when pallets break and
containers are dropped. It must describe the structural integrity of each pit container, its design specifications
including weight-bearing ability, actual history of containers supporting triple stacking (as shown in Figure 3.4).
Document #: 1042 Comment #: 44 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
11. Page 4-2. The Note stating that additional repackaging would be required for off-site shipment must be
explained. What differences are required for repacking now as compared to when pits were being shipped to
Rocky Flats? Are the "Type B shipping containers" going to be certified by the Nuclear Regulatory Commission?
Why could pits not be shipped in the AL-R8 containers?
Section D D-58
Document #: 1042 Comment #: 48 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
The few sentences in Section 6.1.1 are the most detailed description of the pit and storage container, but do not
provide adequate or complete information (see also: comments about page 3-2).
Document #: 1044 Comment #: 4 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
Why were the majority of the pits stored in ALR8 containers? You commented that Type B containers were less
dangerous and are certified for off-site transportation of pits under the Department of Energy's performance
criteria adopted from Section 10 of the Federal Regulations Part 71(10 CFR 71).
Document #: 1048 Comment #: 11 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
(3-2,4-2, A-3) The majority... packaged In AL-R8 containers, but other approved containers may be used." What
is the history of these containers? What are the "other approved containers"? A thorough discussion of
containers is imperative. Can these containers be used for shipping and/or storage? What are the test results on
any of these containers?
Response #: D.27
The AL-R8 is currently not approved for off-site transport of pits. The procedures and the
radiological exposure would be approximately the same (for shipment of pits to an off-site
interim storage site) as when pits are routinely returned to Rocky Flats Plant. However, pit
shipping containers returned to Rocky Flats Plant from Pantex Plant were removed from the
certified shipping container and staged for the next process step. The shipping container was
then returned to Pantex Plant, either empty or with a pit slated for new production. The
certified shipping container was then used to return pits awaiting shipment back to Rocky
Flats Plant. This allowed the Department of Energy to continue pit shipment operations with a
minimal number of certified containers. The Department of Energy, not the Nuclear Regulatory
Commission, certifies shipping containers. The Department of Energy uses criteria consistent
with Department of Transportation guidelines for the transport of radioactive materials.
The age of the containers varies from approximately 30 years to newly built. The majority of
the first containers built approximately 30 years ago are still in service. When the AL-R8
containers were being fabricated, all components for the containers were purchased from
approved fabricators and vendors, inspected, and then assembled for service or stocked as
spare parts. Using a combination of physical measurements, visual determinations, and
nondestructive tests, requirements given on the engineering drawing are confirmed.
Acceptable product is certified for use, defective material is identified, segregated, and
returned to the supplier for repair or replacement. These acceptance tests fulfill the quality
assurance provisions of 10 Code of Federal Regulations 71. There are no limited life
components that must be periodically replaced or periodic tests that must be performed on
the container, fiberboard, or clamping fixture other than corrosion inspections.
AL-R8 and Type B Container Description
AL-R8 outer containers are "Specification 17H Steel Drums," that have a 1-inch vent plug in the
top lid. The model AL-R8 container is typical of the drum type containers used for
transporting fissile material within the Department of Energy weapons complex. The design
specifications for the pit container are contained in a classified document; therefore, it is not
available for publication, but the AL-R8 containers were designed and tested to the
requirements of the Department of Energy Order 5610.1; 10 Code of Federal Regulations 71;
and 49 Code of Federal Regulations Parts, 100-178. The AL-R8 container utilizes the pit
structure for containment, whereas a shipping container, such as the Type B, has two
independent seals for containment. This results in a substantial cost increase. There are four
sizes of AL-R8 containers: Models 2030, 2040, 2050, and 2060. The model number refers to
the 20-inch diameter of the drum and its 30-, 40-, 50-, or 60-inch. height. All AL-R8 containers
are constructed of 18-gauge carbon steel. The container is internally lined with Celotex-
fiberboard to provide impact and thermal protection. The pit is suspended within the
fiberboard using a steel clamping device.
Pits may also be stored in Type B containers, which are double-containment stainless steel
drums categorized as Type B shipping packages. The outer containment of a Type B
shipping package has a 22.5-inch diameter and a 50-inch height. The drum is 16-gauge
stainless steel. The inner containment drum (within which the pit is located) is constructed of
12-gauge stainless steel and has a 13.8-inch diameter and a 38-inch height. Celotex-
packaging material is used between the inner and outer containment drums and also around
the pit inside the inner containment drum.
Comparison of the Two Containers
Statements are made in Section 3.0 that "the majority of the stored components in Zone 4
would be packaged in AL-R8 containers but other approved containers, such as Type B
containers, may be used. Type B containers are certified for off-site transportation of pits
under the Department of Energy performance criteria". This does not imply that Type B
containers are "less dangerous", but that Type B containers are certified for transportation to
Pantex Plant. Both the AL-R8 and the Type B are approved for the use of interim storage of
pits.
The Type B containers are primarily used for shipping. The plutonium pits could be stored in
Type B containers, but due to the limited number of Type B containers available, and time and
cost to build more, the plutonium pits are being stored in AL-R8 containers. The AL-R8
containers have been in service for approximately 30 years, and with this 30-year history the
AL-R8 container has proven itself to be a durable container for pits. Both container types
adequately meet the design safety requirements necessary for interim storage of pits; thus, it
makes sense to avoid storing pits in the much more costly shipping containers.
Analysis of Possible Hazards
An analysis of credible hazards associated with the horizontal palletized multiple stacking
configuration is contained in the Zone 4 Pantex Plant Final Safety Analysis Report for Zone 4
Magazines. In an effort to reduce the threat of internal fires, the pallets used for stacking are
made of metal and are not combustible. Since this is a relatively new storage configuration
there is currently no historical data associated with damaging and breaking of pallets. The
consequences from the event of a pallet breaking and the containers dropping to the floor are
bounded by the safety analysis. In addition, the container and packaging provide additional
protection to the pit that would preclude a potential release using this scenario. Therefore, no
additional analysis is required. No historical data are associated with triple stacking, but the
pallet has been formally analyzed and will be subjected to rigorous testing prior to
implementation.
As to the potential gas buildup within the containers, the pit does not release a gas; therefore,
no gas buildup from the pit will occur. The AL-R8 containers have been fitted with a 1-inch
vent plug in the top lid. This vent plug is to relieve over-pressurization in the containers due to
heated air generated from an external fire.
Transportation to and from Zone 4
Most of the activity associated with the magazines is a result of movements to and from the
production areas in Zone 12 (Building 12-26, Pit Vault and Building 12-44, Cell 8 staging
areas). Weapons assemblies and weapons components transferred between Zone 4 and
Zone 12 are moved by Safe-Secure Trailers or hardened trailers. The pits are transferred in
either the AL-R8, an approved storage container, or a container certified for transportation.
The AL-R8 has been reviewed for the bounding transportation accident in the AL-R8 Safety
Analysis Report for Packaging. This analysis and the supporting documentation are used as
the basis for transporting material to and from Zone 4.
The stated purpose of the Environmental Assessment is to evaluate environmental impacts of
additional pit storage. The transportation of the pits to Zone 4 and loading the pits into the
magazines will continue to be the same for Zone 4 as they have been in previous years. The
only exception is that when the horizontal palletized multiple stacking configuration is
approved, Automated Guided Vehicles will be developed and used to place the pits in the
magazines and to assist in taking inventories using bar code readers. This would reduce
worker exposures for inventory activities. The Automated Guided Vehicles are discussed in
Section 3.0 of the Environmental Assessment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (D.28) FOLLOWS.
Document #: 1011 Comment #: 3 Date: 2/18/93
Dana O. Porter
Citizen Comment
Comment:
The report does not address the hazards of air-borne dusts and gases. Dusts are only mentioned in reference to
their potential to contribute to groundwater contamination. What about the public health risks associated with
ingestion or inhalation of radioactive or chemical dusts and/or gases? Has the Texas Air Control Board been
appropriately consulted with respect to these dangers?
Response #: D.28
The interim storage of pits is not expected to generate emissions other than extremely minor
amounts associated with internal combustion engines used to transport materials and
personnel to and through the area. The Texas Air Control Board has conducted ambient air
measurements of chemical dust and/or gases at several discrete locations on site. These
measurements do not indicate concentrations of the pollutants greater than regulatory limits.
Since the regulatory limits restrict off-site releases and are set at fractions of those levels
known to cause health effects, there are no anticipated public health effects from releases of
chemical dust and/or gases.
Since the storage of plutonium components does not represent an air emission source, the
public health hazard related to releases of radioactive dust and or gases from the facility
would be bounded by the analysis in the Pantex Plant Final Safety Analysis Report for Zone 4
Magazines.
Pantex Plant has appropriately consulted and cooperated fully with the several state regulatory
agencies having cognizance over releases of radioactive/chemical dust and/or gases. These
include not only the Texas Air Control Board, but also the Bureau of Radiation Control of the
Texas Department of Health and the Texas Water Commission. All of these organizations as
well as the Division of Emergency Management of the Texas Department of Public Safety have
been provided the opportunity to review and comment upon the subject Environmental
Assessment. In addition, as part of the Agreement in Principle between the State of Texas
and the Department of Energy, the Texas Air Control Board is conducting site-wide air
dispersion modeling and collecting and analyzing ambient air samples collected from inside
Pantex Plant. The Bureau of Radiation Control of the Texas Department of Health has
conducted radiological monitoring at both on-site and off-site locations since the early 1980's.
None of the measurements performed by the various state regulatory agencies has indicated
that emissions in excess of regulatory limits have occurred.

Part E

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.1) FOLLOWS.
Document #: 1001 Comment #: 1 Date 2/25/93
Ann W. Richards, Governor
State of Texas
Comment:
In addition, state officials believe that the methodologies used in the report addressing the potential impact of a
plutonium release to the Ogallala Aquifer, ... are so fundamentally flawed that they must be revisited. In their
current form, it is impossible to determine whether the resulting conclusions are, in fact, valid.
Response #: E.1
In an analysis prepared at the Department of Energy's request, the Los
Alamos National Laboratory Earth and Environmental Sciences Division
analyzed potential consequences to the Ogallala Aquifer of a
hypothetical plutonium release (Appendix L of "Response to Comments").
Standard scientific and engineering methodologies were used to complete
the analysis. Many of the comments from individuals questioned the
assumptions, data, and subsequent result of calculations. The specific
comments are addressed in the following responses.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.2) FOLLOWS.
Document #: 1006 Comment #: 1 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
I. Cleanup to the Level of 0.2 uCi/m2 Following the Hypothetical Accident
The first assumption (listed on page 7-1 of the EA report and on page 1 of Turin and others, 1992) is that
"Surface soils would be decontaminated to levels no greater than 0.2 uCi/m2 following the hypothetical accident.
(Previous experience indicates that this level is achievable)." Neither the EA nor Turin and others (1992) provide
support for this critical assumption, and numerous questions about it can be raised. First, the potential for soil and
ground-water contamination at initial post-accident levels during the cleanup period cannot be summarily excluded.
Accordingly, documentation should be provided on the anticipated range of initial contamination levels at the
surface prior to decontamination. Further, the basis for concluding that a maximum post-cleanup radiation level of
0.2 uCi/m2 is achievable should be provided. If this assumption is based on previous remediation efforts, the
report should discuss such prior cleanups and show that they are applicable to the Pantex Plant area.
Second, the length of time taken for cleanup is important to assessing plutonium concentrations in soils, and in
particular playas, during this period (reference Footnote on Page 2 of letter from The University of Texas at Austin,
dated February 25,1993). The inference that cleanup will be performed in a timely fashion using methods based
on past experience for released plutonium needs explanation. Will soil removal be required? If so, this task could
be substantial. For example, if the accident occurred as described but with contamination spread over only
(underlined) 1/5 of 1 percent of the 50-mi- (80-km-) radius, then the following volumes of contaminated soil would
result. If only the top 4 inches (10 cm) of soil had to be removed during decontamination of this 15.7 mi2 (40 km2)
area, the volume of soil would equal approximately 5,000,000 yd3 (4,500,000 m3). If 250 trucks with a carrying
capacity of 10 yd3 (7.6 m3) were used and each truck could make 12 round trips per day to a temporary disposal
facility then the total cleanup time required would be 160 days.
Because of the time likely required to achieve decontamination to the desired level throughout the affected
area, it appears unrealistic to assume that no plutonium concentration above 0.2 uCi/m2 will occur in soils prior to
decontamination or during cleanup. For example, if the cleanup period extends as long as one year, a rainfall
event with a 5-year return interval would have a 20% chance of being equaled or exceeded in that one-year
period. According to Becker and Purtymun (1982) in a previous study of the Pantex Plant region, there is a
recurrence interval of 5 years for a 2.9-in (7.36 cm) rainfall event in a 6-hour period and a 3.7-in (9.40 cm) rainfall
event in a 24-hour period. Any precipitation event that produced significant surface runoff such as a 5-year
return-interval storm, would result in concentration of plutonium contamination because of the closed drainage
typical of the region. In sum, the cleanup effort could require some time, during which contaminated soil would be
exposed to rainfall/recharge events. Runoff could possibly concentrate contaminants in playas, and contamination
could extend to the subsurface. Thus, the conceptual model described for this hypothetical accident is presently
unsubstantiated with regard to the implication that cleanup could be completed prior to movement of plutonium into
the subsurface and with regard to the initial concentration of 0.2 uCi/m2 of plutonium.
Response #: E.2
The 0.2 -Ci/m2 post-cleanup contamination level was proposed in 1977 in a draft
Environmental Protection Agency Guideline (42 Federal Register 60956) as an acceptable level
of residual plutonium surface contamination (see Final Environmental Impact Statement,
Pantex Plant Site (DOE/EIS-0098, October 1983), Section 4.2.7 and the Environmental
Assessment, Section 7.0). This level would result in dose rates less than the guidance
recommendations for acceptably low risks from alpha radiation exposure (about 1 mrad/yr to
lung tissue). This guideline was never adopted by the Environmental Protection Agency;
however, it is a level believed to be achievable using current technology. This technology has
been demonstrated at such cleanups as those performed at Johnston Atoll, Eniwetok, and
current research and development activities at the Nevada Test Site.
If required, surface soil cleanup may be both expensive and time-consuming. However, a
delay on the order of a few years would not significantly change the analysis stated in the
Environmental Assessment concerning the potential effects of a plutonium-dispersal accident
on the Ogallala Aquifer. Although there is uncertainty concerning the long-term rate of
plutonium transport, soil scientists generally agree that it is relatively immobile and that it will
not migrate beyond remediable depths within the few years that could be needed to complete
a cleanup.
An exception might be the short-circuit paths described in the Los Alamos National Laboratory
report entitled "Potential Ogallala Aquifer Impacts of a Hypothetical Plutonium Dispersal
Accident in Zone 4 of the Pantex Plant" (Turin et al. (1992)). In the extremely unlikely event of
a plutonium-dispersal accident, these areas would receive priority for decontamination and
steps taken to eliminate the short-circuit path to groundwater. The Department has initiated
steps to identify and document preferential pathways that may exist within the postulated area
of contamination.
-Ci = microCurie
m = meter
mrad = millirad
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.3) FOLLOWS.
Document #: 1006 Comment #: 2 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
II. Plutonium Concentrations in Soils
The second assumption (listed on page 7-1 of the EA report and on page 1 of Turin and others, 1992) is
"Surface transport processes may increase soil concentrations ten-fold to 2.0 uCi/M2 before infiltration takes
place." The assumption that only a tenfold increase in contaminant levels for playa basins in the area of the
Pantex Plant is questionable. Data from an investigation by Becker and Purtymun (1982) of the 10 playa basins
on or immediately adjacent to the Pantex Plant indicate a significantly higher concentration factor. Becker and
Purtymun method for determining concentration potential is based on the ratio of surface area of the playa
(drainage) basin to the surface area of the playa floor (collection point for the basin). They reported measured
areas for 10 basins (Turin's Basin No. 7 had zero acres recorded for the playa floor and is thus ignored in the
following statistics). The minimum basin-to-playa ratio reported, and therefore the minimum concentration factor,
was 12 (for their Basin No. 10). Thus, the concentration ratio of 10 is neither conservative nor equivalent to the
actual minimum measured ratio. The maximum ratio was 29 (for their Basin No. 3). The mean ratio for the nine
basins is 21, with a standard deviation of 8. Therefore, if a "conservative" value is used for the potential
concentration of contaminants, a minimum factor of 25 to 30 should be selected, assuming an antecedent moisture
concentration of saturation and no infiltration of precipitation.
To accurately determine a more statistically defensible "conservative" concentration factor, an effort could be
made to compute the ratio of playa-basin surface area to playa-floor surface area ford of the basins in the 80-km
radius of the hypothetical accident area. This could be done by comparing the area of Randall Clay soils (playa
floors) to the area of upland soil. Soil data are available in county soil surveys published by the USDA Soil
Conservation Service.
Response #: E.3
This comment concerns the assumption in Turin et al. (1992) that surface transport processes
may increase plutonium concentrations ten-fold. The comment cites a 1982 investigation by
Becker and Purtymun which compared playa lake drainage basin areas to playa floor areas
and found that basin-to-playa ratios range from 12 to 29. The comment suggests that the Los
Alamos National Laboratory should have used this ratio as the plutonium concentration factor.
The Los Alamos National Laboratory chose not to use the assumption suggested by the
individual, and the following discussion presents their rationale.
Stating that the basin-to-playa ratio is equivalent to the plutonium concentration factor implies
acceptance of an assumption that surface transport processes are 100 percent effective at
moving all forms of plutonium (including dissolved, sorbed, and colloidal) from the upland soil
surface into the playa lakes. This assumption is clearly not reasonable. Previous research
and the laboratory studies for Turin et al. (1992) indicate that most plutonium will be sorbed to
soil particles of various sizes. Direct observation illustrates that 100 percent of upland surface
soil is not transported into playa lakes during any given rainfall event.
The Los Alamos National Laboratory intentionally chose not to use extreme assumptions in
predicting the groundwater effects of an extremely unlikely event that would disperse
plutonium over the area around the Pantex Plant. Rather, conservative yet reasonable
assumptions were made. To identify reasonable assumptions about an appropriate
concentration factor, actual field data on surface transport concentration from the Trinity Site
was used. These data showed concentration factors of 1.5 to 2. Because of potential
differences between the Trinity Site and the Pantex Plant, the Los Alamos National Laboratory
conservatively increased the concentration factor to ten.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.4) FOLLOWS.
Document #: 1006 Comment #: 3 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
III. Flow and Contaminant Transport Through Playas
The third assumption (listed on page 7-1 of the EA report and on page 1 of Turin and others, 1992) states that
"Recharge to the Ogallala Aquifer is focused at playa lake beds. Playa lake recharge rates are approximately 3
cm/yr, ten times the High Plains average." The assumption that recharge to the Ogallala aquifer is focused in
playa lake beds is probably valid (reference Footnote 2, Page 4 of letter from The University of Texas at Austin,
dated February 25. 1993). However, in our view, the 3 cm/yr playa lake recharge rate, which is reported to be 10
times the High Plains' average recharge rate, is probably invaluable for this contaminant transport analysis.
A. In Contaminant Transport Analysis, a "Site Specific" Recharge Rate Should be Used Rather Than
Regionally Averaged Recharge Values.
Turin and others (1992) point out that local variability in recharge rates may be quite high, but these values
may be averaged over larger areas to provide a representative recharge rate for the entire landscape. This
approach is suitable for estimating regional ground-water resources, but it is not valid for evaluation of site-specific
ground-water contamination. In contaminant transport analyses it is important to know not only the rate at which
water is recharged to an aquifer but also the rate and concentration at which contaminants move down to the
aquifer. Gee and Hillel (1988) discuss the fallacy of averaging, and Gee and others (1991) discuss the importance
of preferred pathways that may bypass much of the vadose zone and transport contaminants directly to an
underlying aquifer. If most of a region's recharge occurs beneath only 3 to 4 percent of the land surface, then the
much higher focused recharge rate actually would transport a greater mass of contaminants at greater velocities
than would be predicted from regionally averaged recharge values.
The methodologies and recharge values listed in the Turin report are not appropriate for several reasons.
For example, most of the recharge rates reported in Turin and others (1992) are based on very little quantitative
data (Wood and Petraitis, 1984), or on a ground-water flow model calibration (Knowles, 1984: Luckey, 1984),
(reference Footnote 3 on Page 5 from The University of Texas at Austin letter dated February 25, 1993).
Recharge rates based on the chloride mass balance approach (Stone and McGurk, 1985) are subject to the
assumptions of one-dimensional piston-type flow and of precipitation as the only source of chloride (Scanlon,
1991). Because surface runoff into the playas provides another source of chloride such as irrigation return waters,
recharge estimates based on the chloride mass balance approach in playa settings are minimum estimates.
Therefore, the recharge values provided by Stone and McGurk (1985) should be used only as minimum estimates
and not as absolute values, as in the EA. In addition, the potential existence of preferential flow pathways beneath
playas may invalidate the application of the chloride mass balance approach beyond estimating minimum recharge
rates.
The method used by Nativ (1908) and Nativ and Riggio (1990) in calculating recharge rates, which ranged
front 1.3 to 8 cm/yr, is probably the most applicable for this study. This range in recharge rate is based on "bomb"
tritium (reference Footnote 4, Page 5 of letter from The University of Texas at Austin, dated February 25, 1993)
found in shallow Ogallala aquifer wells in Lubbock County. Turin and others (1992) accept the methods used and
recharge rates reported in Nativ (1988) and Nativ and Riggio (1990) but point out that the higher rates were
recognized in areas far south of the Pantex Plant. However, as discussed next, Nativ (1988) also reports elevated
tritium in a well near the Pantex Plant.
Response #: E.4
This comment consists of three main points shown in three paragraphs beneath the sentence
labelled "A." The following is offered in response:
Paragraph 1: The Los Alamos National Laboratory made a concerted effort to estimate local
playa lake recharge rates because local, rather than regional, recharge rates are the key to
predicting how much plutonium might appear in the groundwater.
Paragraph 2: In Turin et al. (1992), the Los Alamos National Laboratory compiled and
presented available estimates of recharge rates from open literature sources. While each
individual method is vulnerable to technical criticism, the overall agreement of the results
suggests that the true recharge rate is close to those presented. This was further supported
by information reported in Nativ (1988), an unpublished report which was not available to the
Los Alamos National Laboratory at the time Turin et al. (1992) was prepared. Nativ (1988)
compiled a list of literature recharge estimates for the Southern High Plains, which includes
four references not listed by the Los Alamos National Laboratory in Table 3-1 of Turin et al.
(1992) (these include United States Bureau of Reclamation (1982), Klemt (1981), Knowles et al.
(1984), and Barnes et al. (1949)). These references provide recharge estimates ranging from
0.15-2.54 cm/yr, all within the range of values presented in Turin et al. (1992).
Paragraph 3: The comment states that "Turin et al. (1992) accept the methods used and
recharge rates reported in Nativ (1988) and Nativ and Riggio (1990)...." Los Alamos National
Laboratory did not have access to Nativ (1988) while preparing Turin et al. (1992), and,
therefore, did not cite it. Furthermore, by listing Nativ and Riggio's (1990) recharge estimate in
Table 3-1, the Los Alamos National Laboratory did not intend to endorse or accept either the
estimate, or the method by which it was derived. Since publishing Turin et al. (1992), the Los
Alamos National Laboratory has carefully reviewed the recharge estimates in Nativ (1988), and
has concerns about both the method and results. These concerns are described in detail in
Response E.5.
cm = centimeter
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.5) FOLLOWS.
Document #: 1006 Comment #: 4 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
B. A Proposed "Site Specific" Recharge Rate Based On Known Tritium Levels In Wells On or Near Pantex Plant
Nativ (1988) reports elevated tritium in a well in Carson County, immediately north of the Pantex Plant in the
Amarillo Well Field (Well No. 627, TWC No. 06-44-207) and in a well in northern Armstrong County. Therefore, on
the basis of these data alone, there is clearly some recharge in progress at rates capable of transporting tritium to
the water table at depths of at least 200 to 500 ft (161 to 152 m), and this recharge has been occurring within the
last 40 years. In the Pantex Plant area, Bureau scientists found elevated tritium in all wells producing from a
perched aquifer. Tritium levels in these wells range from 0.4 tritium (TU) (in well OW-WR-44) to 44 TU (in a private
well 1.9 mi south of the Pantex Plant).
Nativ (1988) estimated that water sampled in 1985 with a tritium content of 73 TU was probably from a
precipitation event that occurred between 1966 and 1967. Nativ (1988) calculated recharge rates based on the
equation (see Figure on Page 6 of the letter from The University of Texas at Austin, dated February 25, 1993).
Because Turin and others (1992) accepted the validity of methods used by Nativ (1988) and Nativ and
Riggio (1990), it is appropriate to apply this same method to calculate a "conservative" site-specific recharge rate
of the Pantex Plant area based on the tritium levels reported for wells in the perched aquifer in the area. Two
technical considerations complicate the selection of time intervals for recharge events based on current tritium
levels. The first problem is that the input function for tritium today has dropped to a level that is nearly at prebomb
background levels. Second, there is no simple method for taking into account mixing of younger waters recharging
vertically with old water moving along the natural system. For example, a water sample with 5 TU might derive
from a single source of water with 5 TU or from several sources by mixing 5 parts water with 100 TU end 95 parts
water with no tritium; or infinite other combinations could apply.
Most of the tritium values reported for perched ground water in the Pantex area are too low (for example.
less than 8 TU) to relate to the tritium-decay curve. In the well with 44 TU, however, a conversion can be made so
that this water can be applied to Nativ's (1988) tritium-decay curve. The most reasonable time period for a
recharge event with this tritium input function (44 TU in 1892 is approximately equal to 65 TU in 1985, the date at
which Nativ's [1988] samples were collected) is 1966 to 1967. Thus, an elapsed time from recharge event to
arrival in the perched aquifer at this well could be approximately 25 years. The average volumetric moisture
content, as measured by Bureau scientists in several boreholes in the area, ranges from about 0.1 to 0.2 m3,
higher moisture contents being observed near the surface. The unsaturated zone at this well is reported to be
approximately 200 ft (61 m) thick. Unsaturated thickness above some perched aquifers are as great as 260 ft (79
m). Using a range In moisture content of 0.1 to 0.2, thickness of an unsaturated zone ranging from 200 to 260 ft
(61 to 79m), and a time since recharge ranging from 25 to 40 years results in a range in recharge rates from 0.5
to 2.1 ft/yr (15.2 to 63.3 cm/yr).
Response #: E.5
This comment presents a report of field evidence of higher transport velocities than the Los
Alamos National Laboratory assumed. Detailed responses to each paragraph of this
comment are presented below which analyze the comment at some length. The Los Alamos
National Laboratory believes that the extremely high recharge rates suggested by the Texas
Bureau of Economic Geology, when combined with the other conservative assumptions made
by Turin et al. (1992), form a scenario which is so conservative it appears to be unreasonable.
Nevertheless, additional plutonium transport simulations were performed using this extremely
conservative scenario. Below, the results are compared with the original predictions. Even
with a very low assumed dispersivity of 1 cm, the maximum peak plutonium concentration in
the Ogallala Aquifer recharge, while higher than the most conservative public water supply
standard, still does not exceed the exposure-based standard described in Turin et al. (1992),
Appendix B.
Paragraph 1: The comment states that Nativ (1988) reports elevated tritium in a well in
Carson County... (Well No. 627, Texas Water Commission No., 06-44-207); this is incorrect.
Nativ (1988) reports a tritium concentration for this well of 0.7 TU. This value is close to typical
tritium detection limits, does not conclusively indicate a significant nuclear-age component,
and should not be considered elevated. The comment also discusses elevated tritium in a
well in northern Armstrong County. According to Nativ (1988), this well had 6.9 TU, which
suggests some influence from recent recharge. Nativ (1988) does not list a depth-to-water for
this Armstrong County well, but by comparing Nativ's figures 18 and 21, it appears that depth-
to-water at this well is between 150 and 200 ft. There is, therefore, no basis to conclude, as
the comment does, that "...there is clearly some recharge in progress at rates capable of
transporting tritium to the water table at depths of at least 200 to 500 feet (161 to 152 m [sic]),
and this recharge has been occurring within the last 40 years." The comment then states that
the Texas Bureau of Economic Geology has "found elevated tritium in all wells producing from
a perched aquifer. Tritium levels in these wells range from 0.4 TU to 44 TU." (A tritium level of
0.4 TU cannot be considered elevated, but this is a small point.) These tritium data have not
been reported in any published document; however, the Texas Bureau of Economic Geology
has provided them to the Los Alamos National Laboratory, and they are addressed below
under Paragraph 4.
Paragraph 2: The comment states that "Nativ (1988) estimated that water sampled in 1985
with a tritium content of 73 TU was probably from a precipitation event that occurred between
1966 and 1967." However, the comment does not mention the associated assumptions and
caveats. As Nativ (1988) states, this estimate is based on "a simplified model that assumes
piston-type flow and a complete displacement of water present in both the vadose and the
saturated zone by the recharging water." As Turin et al. (1992) discussed, a piston-flow model
is intuitively simple, but is not physically realistic. Specifically, it neglects dispersion, which
would result in some high-tritium water reaching the water table at a faster rate than purely
advective transport would predict. Using a piston-flow model would assign this faster rate
entirely to advection, resulting in an erroneously high transport estimate. Nativ (1988)
acknowledges this: "The model provides a minimum estimate for the water age and a
maximum value for the local recharge rate."
In addition to this questionable model, Nativ's (1988) age estimate is further confused by
mathematical errors, an inaccurate value for the half-life of tritium and a limited and flawed
precipitation data set. The precipitation data set problems are more severe. Nativ cites no
references for the precipitation data reported; however, comparison with data published by
the International Atomic Energy Agency (IAEA, 1969; 1971; 1973; 1975; 1979; 1983; and 1986)
and compiled by Shevenell (1990) reveals numerous differences, some minor, some major.
The net effect of these errors is revealed in Figure E.5-1, which shows Nativ's (1988) data
together with corrected data. Nativ (1988) concluded that 1985 water containing 73 TU was
probably precipitation from 1966-1967. Figure E.5-1 shows that the corrected data predict
that 1961 precipitation would also have approximately 74 TU. Therefore, even assuming that
the piston-flow model is valid, a single tritium value cannot be assigned to a unique
precipitation year. This conclusion is further illustrated by considering a more complete
precipitation data set. Figure E.5-2 is based on published International Atomic Energy Agency
data supplemented by estimates by Shevenell (1990). These data show that precipitation
water from three different years (1958, 1961, and 1966) all would contain approximately 75 TU
in 1985.
Nativ's (1988) simplified model also did not consider dispersive mixing. In order to give some
idea of the nature of dispersive mixing, Figure E.5-2 presents a 5-point moving average of
Nativ's (1988) data. This is not intended to represent an accurate estimate of the effects of
dispersion, but shows how dispersion would cause "smoothing."
Paragraph 3: The comment states that, in Turin et al. (1992), the Los Alamos National
Laboratory accepted the validity of the methods used by Nativ (1988) and Nativ and Riggio
(1990). The statement is incorrect since the Los Alamos National Laboratory had no access
to Nativ (1988) while Turin et al. (1992) was prepared. Additionally, inclusion of data from
Nativ and Riggio (1990) was not intended as an endorsement. As discussed above, the Los
Alamos National Laboratory does not accept Nativ's (1988) method for tritium-dating water,
and seriously doubts the validity of the results.
Paragraph 4: Despite several uncertainties and complications with the tritium-dating method,
Paragraph 4 applies that method to new tritium data from the perched aquifer beneath the
Pantex Plant. These data consist of tritium concentrations from wells known or suspected to
tap the perched aquifer beneath the Pantex Plant. These data, provided by the Texas Bureau
of Economic Geology, are shown in the Table E.5-1. The distribution of these data is rather
peculiar - six of the wells show less than 5 TU, three fall between 5 and 9 TU, and a single
well shows 44 TU. The Texas Bureau of Economic Geology confirmed the 44 TU data point
by reanalyzing the sample. Therefore, three hypotheses are possible: a) the true concentra-
tion of tritium in the perched aquifer is somewhere between 0 and 9 TU, and the single high-
tritium well is anomalous; b) the true concentration is around 44 TU, and the nine low-tritium
wells are anomalous; or c) the perched aquifer is so heterogeneous in age that tritium
concentrations ranging from 0 to 44 TU coexist within a short-distance.
Hypothesis b) is difficult to defend because the possibility of nine wells all producing similarly
anomalous low-tritium water seems remote. Hypothesis c) is difficult to disprove; however,
evidence against it includes the fact that the high-tritium well is within a mile of a well
producing water with 5.64 TU. The water level in these two wells differs by only 24 feet,
suggesting close hydrologic contact. Furthermore, lower-tritium wells include those
immediately around the Pantex Plant Playa #1, which is strongly suspected to be a site of
anomalously high recharge due to Pantex Plant waste water operations. High tritium in these
wells could more easily be correlated to rapid recharge.
Hypothesis a) is the most likely explanation due to the risks posed by improperly constructed
wells that can provide a short-circuit route to the water table. The well which produced the
44 TU sample is a private well in an agricultural setting that taps a shallow aquifer. This is
exactly the type of well most at risk for short-circuiting.
Assuming that the true tritium concentration of the perched aquifer is 0 to 9 TU, what can we
say about the transport rate? Figure E.5-3 shows that either with or without dispersion-driven
smoothing, 1992 tritium concentrations of 9 TU may be associated with precipitation from
about 1955. Lower tritium concentration water could be considerably older, with the 0.4 TU
water having a minimum (piston-flow) age of 47 years, based on a pre-bomb background
level of 6 TU. Thus, the perched-zone samples exhibit an age range of 37 - >47 years. For
an unsaturated zone between 61 and 79 m thick (based on the comment), this corresponds
to a velocity range of <1.3 - 2.1 m/yr, or, assuming a volumetric moisture content of 0.15, a
recharge rate of <19 cm/yr - 32 cm/yr. (The additional uncertainty introduced into the Texas
Bureau of Economic Geology's recharge estimates by uncertainty in moisture content is
irrelevant to this problem because velocity, rather than recharge, is the key parameter affecting
solute transport.)
These velocity and recharge rates are significantly higher than the assumed rates used in
Turin et al. (1992), which were based on literature recharge estimates. It is difficult to explain
the discrepancy -- possible contributing factors include errors in the tritium age introduced by
the piston-flow model; extreme transport acceleration due to preferential flow; and
anomalously high recharge rates in the immediate vicinity of the Pantex Plant due to waste
water discharge to Pantex Plant Playa #1. Regardless of the cause, the Texas Bureau of
Economic Geology tritium data suggest that downward velocities as high as 2.1 m/yr may be
possible. Therefore, the Los Alamos National Laboratory has conducted additional
advection/dispersion simulations using the CXTFIT computer code, with downward velocities
of 2.0 and 4.0 m/yr (corresponding to recharge rates of 30 cm/yr and 60 cm/yr, with a
volumetric moisture content of 0.15), and dispersivities of 1 cm and 1 m. The results of these
simulations are shown in the Figures E.5-4, E.5-5, and E.5-6.
The most obvious impact of increased transport velocity is a shorter travel time to the water
table. Peak plutonium concentrations reach a 50-foot deep water table in 6,200 - 7,600 years
at 2 m/yr (Figure 4) and in 3,100-3,800 years at 4 m/yr (Figure E.5-5), compared to the base
case shown in our report, with a travel time of 52,000-75,800 years at 20 cm/yr velocity
(3 cm/yr recharge). With these shorter vadose-zone residence times, radioactive decay has
less opportunity to reduce plutonium concentrations. However, this effect is mostly offset by
the increased initial dilution of the 2.0 -Ci/m2 surface loading caused by the increased annual
recharge. As can be seen in Figure E.5-4, with a velocity of 2.0 m/yr, the 1 cm dispersivity
simulation predicts a peak recharge concentration of 7.7 pCi/L, which exceeds the conserva-
tively-calculated public water supply drinking water based standard of 1.3 pCi/L, but is
significantly below the conservatively-calculated total exposure based standard of 30 pCi/L
(see Appendix B of Turin et al. (1992) for details on dose calculations, including an
explanation of conservatively-calculated). This calculated recharge concentration represents
the concentration in a drop of water in the vadose zone just above the Ogallala Aquifer water
table. Before this water reaches any potential receptor, additional horizontal and vertical
mixing within the aquifer and in a water-supply well would further dilute the plutonium, likely
leading to well-head concentrations below any applicable standard. With a more realistic
dispersivity of 1 m, the predicted peak recharge concentration is 0.94 pCi/L, well below both
previously-mentioned dose standards. Again, dilution within the aquifer and well casing would
further decrease plutonium concentrations before any potential receptors are reached.
Doubling the recharge rate and velocity does not greatly affect predicted peak recharge
concentrations: 8.65 pCi/L and 1.02 pCi/L for 1 cm and 1 m dispersivities, respectively (see
Figure E.5-5). The relationship of these predictions to dose standards is much the same as
for the 2.0 m/yr velocity results.
With a more typical depth to water of 200 feet, recharge plutonium concentrations will peak at
3.1 pCi/L assuming a 1 cm dispersivity, and at 0.33 pCi/L with a more realistic assumed
dispersivity of 1 m (see Figure E.5-6). These values should be compared to the most
conservative public water supply standard of 1.3 pCi/L and the total exposure standard of
30 pCi/L.
To summarize: because of the concerns of the Texas Bureau of Economic Geology about the
assumptions used in Turin et al. (1992) for estimating recharge, additional plutonium transport
simulations were performed using conservative velocity and recharge estimates, based on the
Texas Bureau of Economic Geology unpublished tritium data. These additional simulations
assumed transport to a 50-foot deep aquifer (which only occurs south of the Pantex Plant) in
a direction opposite the prevailing wind.
A ten-fold increase in surface loading over the stated cleanup levels was also assumed, and
the entire unsaturated zone was postulated to exhibit the relatively low plutonium sorption
measured for Ogallala Sand, an assumption that Texas Bureau of Economic Geology admits
is extremely conservative (Comment 1006/6). It was conservatively assumed that the entire
surface plutonium loading dissolves in a single year's recharge. Given all these assumptions,
even with a very low assumed dispersivity of 1 cm, the maximum plutonium concentration in
recharge is predicted at 8.65 pCi/L. This figure is higher than the most conservative public
water supply drinking water standard but significantly lower than the total exposure based
standard of 30 pCi/L. When aquifer and well-casing dilution is taken into account, anticipated
plutonium concentrations reaching a potential receptor are lower than either standard. With a
more realistic dispersivity of 1 m, our analysis predicts that even the recharge concentration
would be lower than any applicable standard.
Considering the extreme conservatism of the assumptions of this analysis, the Department
continues to support the original conclusion of the Environmental Assessment that the
hypothetical plutonium dispersal accident does not pose a significant threat to the Ogallala
Aquifer.
cm = centimeter
m = meter
-Ci = microCurie
pCi = picoCurie
L = liter
TU = tritium units
yr = year
Table E.5-1 - Texas Bureau of Economic Geology
Perched Aquifer Tritium Concentrations.
Perched Aquifer Well Tritium Concentration.
(TU)
PM-19 7.28/8.39
PM-20 1.39
PM-38 4.71/4.92
PM-44 0.44/0.40
PM-45 6.10/8.75
C. Wink 1.77
P. Smith 42.7/44
F. Wink 5.64
E. Pratt 1.40
PM-106 0.72
Source: Alan Fryer, Texas Bureau of Economic
Geology, personal comment, 3/30/93.
Figure (Page E-13 Figure E.5-1 - Observation Year - 1985 ...)
Figure (Page E-14 Figure E.5-2 - Observation Year - 1985...)
Figure (Page E-15 Figure E.5-3 - Observation Year - 1992...)
Figure (Page E-16 Figure E.5-4 - Fast Recharge (30cm/yr) 50-Foot Deep Water Table)
Figure (Page E-17 Figure E.5-5 - Fast Recharge (60cm/yr) 50-Foot Deep Water Table)
Figure (Page E-18 Figure E.5-6 - Fast Recharge (60cm/yr) 200-Foot Deep Water Table)
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.6) FOLLOWS.
Document #: 1006 Comment #: 5 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
C. Calculation of a "Conservative" Velocity for Determining Contaminant Transport in the Vicinity of Pantex
The above site-specific recharge range describes the volume rate of transfer of water to the aquifer, not the
velocity at which a water molecule moves through the unsaturated zone. Velocity, which is critical in determining
contaminant transport, is calculated by dividing the thickness of the unsaturated zone, 200 to 260 a (61 to 79 m),
by the time since recharge, 25-40 years. Given these values, the velocity beneath the Pantex Plant is
approximately 5 to 10 ft/yr (150 to 300 cm/yr).
In addition to "bomb" tritium levels observed at depth, recharge experiments conducted at the Bushland
Agricultural Research Station demonstrate the potential for subsurface velocities substantially exceeding those
assumed in the Turin report. Recharge experiments were performed in basins that had been excavated to a depth
of 3.9 ft (1.2 m) to remove the Pullman soil and expose the unconsolidated caliche layer (Aronovici and others,
1970). Infiltration rates beneath the basins were on the order ~3.3 ft/d ~1,200 ft/yr (100 cm/d ~ 36,500 cm/yr).
In sum, our view is that for purposes of this site-specific groundwater analysis, contaminant transport
concepts, which consider the velocity of water movement through the unsaturated zone, should be used rather
than volumetric-oriented ground-water resources concepts, which focus on the rate at which water is recharged to
an aquifer. For the Pantex Plant area, tritium-dating methodology indicates water may move at significantly higher
rates in the subsurface then assumed in the Turin report.
Response #: E.6
When Turin et al. (1992) was prepared, the Los Alamos National Laboratory did not have the
unpublished tritium data from the Texas Bureau of Economic Geology. Therefore, recharge
rate estimates, adjusted for effective water saturation, were used to perform the transport
calculations. Upon learning that the unpublished tritium data from the Texas Bureau of
Economic Geology suggested faster velocities, the potential impacts of these velocities on
plutonium transport were analyzed. (See Response E.5.)
The infiltration rates referenced in the comment were the result of experimental conditions
designed to maximize recharge rates and do not appear relevant to natural recharge
situations.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.7) FOLLOWS.
Document #: 1006 Comment #: 6 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
V. Plutonium Sorption/Preferential Flow Paths
The fifth assumption (listed on page 7-2 of the EA report and on page 1 of Turin and others, 1992) states that
"The entire unsaturated zone exhibits a plutonium sorption coefficient of 100 mL/g, approximating the sorption of
clean Ogallala sand." There are several issues here. First, it is our view that actual retardation of plutonium
filtrating through the Pullman and Randall soils is, in the absence of preferential flow, going to be substantially
greater than that reported. Actual mobility, however, would have to be evaluated in terms of preferential flow
through fractures or root tubules, which these batch-equilibrium sorption coefficients do not consider. Thus, this
assumption, while conservative to the extent of its reach, does not fully address the issue of plutonium either at the
surface or in the subsurface.
A. Plutonium Sorption Coefficient for Porous Media
The experiments reported to validate this assumption are based on plutonium sorption studies performed
on Pullman soil and Ogallala sediment and did not consider the Randall clay soil. Unfortunately, the actual Kd
reported from these experiments cannot be directly evaluated. The authors report using the 75 to 500 um size
fraction for their experiments. This size fraction, although somewhat representative of Ogallala sediments, is
inappropriate for evaluating sorption of inorganic solutes. This size fraction is dominated by framework silicates,
and, if the sample is not disaggregated first, by soil aggregates of some unknown structure.
Most importantly, however, sorption is dominated by the clay fraction, in which particle size is generally less
than a few microns. Based on our evaluation of the Pullman and Randall soils, the specific surface areas of the
bulk soil are approximately 20 to 40 m2/g, whereas specific surface areas of the size fraction used in the Turin
report experiments are approximately 0.01 to 0.05 m2/g, or three orders of magnitude smaller. Thus. in the
absence of preferential flow, actual retardation of plutonium infiltrating through Pullman and Randall soils is going to
be substantially greater than that reported, based on the experiment's size fraction. This part of the Turin analysis
is, therefore, extremely conservative. However we again emphasize that these results are valid only in the
absence of preferential flow.
Response #: E.7
The experimental procedure used for the batch sorption measurements was developed at the
Los Alamos National Laboratory specifically to determine the sorption of actinides onto
unconsolidated material. The specific sample preparation method and grain-size selection
was shown by Thomas (1987) to maximize reproducibility of results. Thomas (1987) showed
that irreproducible results are obtained if particles of all sizes are utilized to determine sorption
coefficients, due to the practical problems involved in separating the solution from the solid
phase which is an integral part of the batch sorption procedure. Because of this problem, the
Los Alamos National Laboratory developed careful procedures to sieve unconsolidated
materials without causing fractionation (Rogers and Meijer (1993)). Rogers and Meijer (1993)
report that the sorption coefficients obtained using particles in the size range from 4 mm to
75 -m do not vary with particle size.
However, because of the concern raised by the comment author, the batch sorption
experiments have been repeated using bulk soil samples instead of the specific size fraction
used previously. For these new experiments, the field soil samples were carefully and gently
ground to break up soil aggregates, and then passed through a 2 mm sieve to remove
gravel-sized particles. Results from these new experiments are compared to the results
reported by Turin et al. (1992) in Tables E.7-1 and E.7-2. The new results show increased
sorption for the Pullman Soil samples (5,000 -7,000 mL/g versus 3,000 - 4,000 mL/g) and no
significant change for the Ogallala Sand (100 -200 mL/g versus 60 - 500 mL/g). Using
100 mL/g for all KD values still appears to be a highly conservative assumption.
Response E.8 discusses the issue of preferential flow.
mm = millimeter
um = micrometer
mL = milliliter
g = gram
Table E.7-1 - Plutonium Sorption onto Pullman Soil from Deionized Water
KD (mL/g)
Initial Plutonium
Oxidation StateSample 1A Sample 1B
75 - 500 um <2 mm 75 - 500 um <2 mm
(Turin et al., 1992) (new data) (Turin et al., 1992) (new data)
IV 4000 6000 3000 7000
V 3000 5000 4000 5000
Table E.7-2 - Plutonium Sorption onto Ogallala Sand from Deionized Water
KD (mL/g)
Initial PlutoniSample 3A Sample 3B
Oxidation State
75 - 500 um <2 mm 75 - 500 um <2 mm
(Turin et al., 1992) (new data) (Turin et al., 1992) (new data)
IV 300 200 500 100
V 60 100 100 100
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.8) FOLLOWS.
Document #: 1006 Comment #: 7 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
B. Preferential Flow Paths
The report by Turin and others (1992) does not fully describe the potential for preferential flow of recharging
waters and retardation of plutonium moving through the Ogallala and Blackwater Draw Formations. Cores from
these formations and from playa-filling sediments contain abundant open root tubules that are typically 0.04 in (1
mm) in diameter but range up to 0.3 in (8 mm) in diameter. Root tubules are commonly lined with a thin layer of
illuvial clay. Cores through the Randall Clay commonly contain fractures, some filled with silt end very fine sand
and some with oxidized zones. Both root tubules and fractures are sites through which preferential flow and
infiltration can occur. Root tubules are preserved throughout the fine-grained eolian facies of both the Blackwater
Draw and Ogallala Formations. The presence of open tubules and fractures indicates that pathways exist through
which downward flow is accelerated and contact with sediments is reduced, thus lessening the potential for
sorption of radionuclides. Such pathways may explain the high flow rates discussed in Aronovici and others
(1970). As noted in the attached specific comments, the subject of preferential flow should be examined in much
greater detail.
Document #: 1006 Comment #: 15 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 18: Preferential Flow section: A much more detailed evaluation of preferential flow should be presented
because this is a critical issue with respect to recharge beneath playas. Numerical simulation of preferential flow
should include mobile and immobile water. Using twice the calculated water velocity is not a sufficiently
conservative assumption. A review article by Beven ad Germann (1982) cites velocity ratios between matrix and
macropore flow between 100:1 and 400:1. The subsurface beneath playas is particularly conducive to preferential
flow because the soils are close to saturation and are subject to a ponded upper boundary when playas contain
water. Because this is the most likely area of recharge and is critical for contaminant transport, the subject of
preferential flow should be examined in much greater detail.
Document #: 1011 Comment #: 13 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
2. The authors of the report indicated that preferential flow is expected to have negligible contribution to the
aquifer contamination risk. The Pullman clay loam and Randall clay soils, containing appreciable amounts of
montmorillonitic clay, are subject to cracking which increases opportunity for preferential flow.
Document #: 1015 Comment #: 15 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Potential Ogallala Aquifer Impacts...: The "preferential flow" arena is by the EA's own admission an unknown
regarding flow rates to and effects on the Ogallala aquifer.
Response #: E.8
Turin et al. (1992) estimated the effect of preferential flow on contaminant transport by
doubling the assumed transport velocity. Since determining preferential flow effects is an
active soil science research area, this estimate can be disputed and cannot be confirmed
without local field experiments and/or measurements. Nevertheless, it is a conservative
estimate based on good professional judgment.
The root tubules and fractures mentioned in the comment may or may not act as conduits,
depending on local soil moisture tension and the nature of fracture or tubule fills. As was
mentioned in Turin et al. (1992), Goss et al. (1973) did not detect deep contaminant migration
(below 9 ft) in their experiments, despite obvious and visible open soil pores. While this is not
conclusive evidence, it suggests that the visible pores may not accelerate transport as much
as might otherwise be thought.
Mobile/immobile water models are a useful conceptual tool for research into preferential flow
(but of minimal practical application in this case) because of the paucity of site-specific
experimental data needed to estimate the numerous parameters required by such models.
Doubling the downward velocity is analogous to a mobile/immobile water situation with a
domain ratio of 1:1, and no solute exchange between the two domains. This no-exchange
assumption is actually more conservative than standard mobile/immobile water models. The
velocity ratios cited in the comments are of academic interest, but irrelevant to the discussion
at hand. Both Turin et al. (1992) and a mobile/immobile water model assume an infinite
velocity ratio.
ft = feet
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.9) FOLLOWS.
Document #: 1006 Comment #: 8 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 3, Line 13-14: the statement that the Ogallala Formation has been eroded and is no longer present along
the Canadian and Pecos Rivers is incorrect. The Ogallala Formation is present in the Canadian River Valley for at
least 70 mi northeast of the Pantex Plant.
Response #: E.9
The Ogallala Formation does indeed extend northeast of the Pantex Plant; however, in the
study area north of the plant, the Canadian River (and Lake Meredith) flow through outcrops
of pre-Tertiary rocks, indicating that the Ogallala has been completely eroded away in this
area.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.10) FOLLOWS.
Document #: 1006 Comment #: 9 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 6, Line 8-9: The statement is made that "Local recharge rates in the playa basins must therefore significantly
exceed the regional averages cited above." This relationship between playas and recharge supports use of
specific recharge rates instead of regional averages.
Response #: E.10
As mentioned in Section 7.0 of the Environmental Assessment and discussed in Turin et al.
(1992), an estimated local playa recharge rate of 3 cm/yr was used instead of the regional
average value of approximately 0.3 cm/yr.
cm = centimeter
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.11) FOLLOWS.
Document #: 1006 Comment #: 10 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 6, line 19-20: the statement is made that "no recent contour maps showing depth-to-water for the study
area were available." It should be noted that Bureau researchers simultaneously submitted to DOE (1) a report on
perched aquifers at the Pantex Plant (referenced in Turin and others, 1992) and (2) a report containing
potentiometric-surface maps of the Ogallala aquifer through 1991 (not referenced in Turin and other [1992]).
Response #: E.11
The Turin et al. (1992) statement concerning the availability of recent maps showing depth-to-
water was not intended to imply that the potentiometric-surface maps provided by the Texas
Bureau of Economic Geology were not available when the Environmental Assessment was
prepared. The potentiometric-surface map does not show depth-to-water and deriving depth-
to-water from potentiometric-surface maps is difficult.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.12) FOLLOWS.
Document #: 1006 Comment #: 11 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 7, Line 4: At steady state, the Ogallala outcrop areas along the margins of the Canadian River and Palo
Duro Canyon were clearly discharge zones. With the continued lowering of Ogallala water levels in some areas, a
reversal in gradients may occur and what were previously discharge zones may in fact convert to recharge zones.
Response #: E.12
This comment speculates that if water levels in some areas of the Ogallala Aquifer continue to
be lowered, discharge zones along the margins of the Canadian River and Palo Duro Canyon
may become recharge zones. The Environmental Assessment does not address this because
predicting future groundwater levels beneath the Southern High Plains is beyond its scope.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.13) FOLLOWS.
Document #: 1006 Comment #: 12 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 7, Line 20: Considering the differences in geology, hydrology, climate, and vegetation, the comparison
between the Trinity site and the Pantex Plant seems inappropriate.
Response #: E.13
While the Trinity Site and the Pantex Plant are not identical with respect to geology, hydrology,
climate, and vegetation, they are similar. Also, the Trinity Site data are the only available
estimates of surface transport concentration effects on fallout. To account for the differences
between the two sites, the observed Trinity Site concentration factors of 1.5 to 2 were
conservatively increased to a factor of 10 for the Environmental Assessment analysis.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.14) FOLLOWS.
Document #: 1006 Comment #: 13 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 9, Line 11: It is regrettable that Pullman soils and Ogallala sediments were collected but Randall soils with
their higher clay content were not.
Response #: E.14
Samples of the Randall Clay soil, not available during the preparation of Turin et al. (1992),
were recently obtained by the Los Alamos National Laboratory. The sample was measured
for its plutonium absorption properties using experimental procedures described in Appendix
A of Turin et al. (1992) with the exception that sorption was measured on a bulk soil sample
instead of a sieved size fraction. The soil was prepared by air-drying, followed by crushing
the hard clay clods in a shatterbox. The sorption results, presented in Table E.14-1, show that
the Randall Clay soil has plutonium sorption properties similar to the Pullman soil. (See
Appendix A of Turin et al. (1992).) Both the Pullman and Randall soils sorb plutonium more
strongly that the Ogallala sand, so applying the Ogallala sand properties in the original
analysis was a conservative assumption.

Table E.14-1 - Plutonium Sorption Characteristics of Randall Clay Soil
Initial Pu Distilled Water Ogallala Aquifer Water
Oxidation StateKD (mL/g) KD (mL/g)
Sample A Sample B Sample A Sample B
V 1 x 103 1 x 103 3 x 103 3 x 103
NOTE: Initial Ogallala Aquifer water was pH 8.2, Eh 240 mV
After preconditioning, Ogallala water was pH 7.7, Eh 240 mV
mL = milliliter
g = gram
mV = milliVolt
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.15) FOLLOWS.
Document #: 1006 Comment #: 14 Date: 2/25/93
Auburn L. Mitchell
Univ. of Texas, Austin, Bureau Economic Geology
Comment:
Page 9, Line 13-14: More detail is needed concerning advection-dispersion simulations to allow full evaluation of
the results. For example, the specific boundary and initial conditions and flow and transport parameters used in
the simulations are not described.
Response #: E.15
The technical details of the CXTFIT runs were not included in Turin et al. (1992) because that
report was intended for a general, non-technical audience. These details are provided below.
CXTFIT (Parker and van Genuchten (1984)) when used in the predictive mode (as opposed to
its inverse, curve-fitting mode) is a relatively straightforward FORTRAN program that uses well-
established numerical approximations of transcendental functions to provide analytical
solutions to the one-dimensional advection-dispersion equation. The solution requires auxiliary
conditions and transport parameters.
Necessary auxiliary conditions include initial conditions and boundary conditions. For this
project, initial conditions were set to zero plutonium concentration throughout the system. The
soil surface is assigned a third-type (flux-type) boundary condition, while the lower boundary
condition is set as a finite concentration gradient at infinite depth (semi-infinite domain). Full
details on the boundary condition assumptions and solution method are presented by Parker
and van Genuchten (1984).
Relevant transport parameters are listed and defined in Table E.15-1, and the various CXTFIT
runs performed are described in Table E.15-2.
yr = year
uCi = microCurie
pCi = picoCurie
m = meter
cm = centimeter
L = liter

Table E.15-1 - CXTFIT Parameters
Definition Value
C0 Input Concentration at Varies: See Table E.15-2
Upper Boundary
t0 Input Pulse Width 1 year
I* Recharge Rate Varies: See Table E.15-2
THEATA* Volumetric Water Content Varies: See Table E.15-2
v Downward Water Velocity Varies: See Table E.15-2
R Plutonium Retardation 1000
Factor
ALPHA* Dispersivity Varies: See Table E.15-2
D Dispersion Coefficient Varies: See Table E.15-2
k Plutonium Radioactive 2.84 x 10-5 year-1 (based on 239Pu)
Decay Constant
*These parameters are not directly input into CXTFIT; they are used to
determine other parameter values.

Table E.15-2 - CXTFIT Parameter Values
Run ID Figure C0 I - v - D
(Obs. depth) (pCi/L) (cm/yr) (cm/yr) (cm) (cm2/yr)
PLUTO3 (50') Turin 6.67 x 104 3 0.15 20 1 20
PLUTO5 (200') Report,
Figure 4-1
PLUTO4 (50') Turin 6.67 x 104 3 0.15 20 100 2000
PLUTO6 (200') Report,
Figure 4-1
PLUTO7 (50') Turin 6.67 x 104 3 0.075 40 1 40
Report,
Figure 5-1
PLUTO8 (200') Turin 6.67 x 104 3 0.075 40 100 4000
Report,
Figure 5-1
PLUTO9 (50') Response 3.33 x 103 60 0.15 400 1 400
PLUTO13 (200') E.5,
Figures
E.5-5,
E.5-6
PLUTO10 (50') Response 3.33 x 103 60 0.15 400 100 40000
PLUTO14 (200') E.5, Figure
E.5-6
PLUTO11 (50') Response 6.67 x 103 30 0.15 200 1 200
E.5,
Figure
E.5-4
PLUTO12 (50') Response 6.67 x 103 30 0.15 200 100 20000
E.5,
Figure
E.5-4
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.16) FOLLOWS.
Document #: 1010 Comment #: 5 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
(At a minimum, the following areas should be covered in the study or unclassified supporting documents:)
A matrix of possible contamination levels that can be expected, off-site, based on the number of ruptured pits.
This data should be presented in progressive levels of 25 to the maximum number that will be stored in any one
area.
Response #: E.16
Although not referenced in the Environmental Assessment, Sandia National Laboratories
performed an analysis of the possible off-site contamination resulting from ruptured pits. The
document stating the results of the analysis (Memorandum from R.E. Smith Org. 0333, Sandia
National Laboratories to David E. Rosson, Jr., Department of Energy, Albuquerque Operations
Office/WMOSD dated December 11, 1992, Subject: "Plutonium Dispersal Consequence
Analysis of Hypothetical Aircraft Crash into Pantex Zone 4.") has been placed in the
Department of Energy public reading rooms in Amarillo and Panhandle, Texas and Section I of
this document.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.17) FOLLOWS.
Document #: 1011 Comment #: 7 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
The potential risks of groundwater contamination were evaluated by the Los Alamos National Laboratory - a
D.O.E. facility. Are their findings assumed to be objective? Can we accept the results without question?
Document #: 1021 Comment #: 13 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
Their reference to threats to the Ogallala aquifer is internal DOE research by Turin et al from the Los Alamos
National Laboratories so it is no wonder they concluded no risk would occur to the aquifer. The DOE cites no local
criticism.
Document #: 1021 Comment #: 17 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
... research cited has come from DOE sponsored laboratories and is therefore suspect. I recommend some
outside reading: (see listing in letter)
Response #: E.17
The Los Alamos National Laboratory was assigned to estimate objectively and independently
the potential effect on Ogallala Aquifer in the event of a hypothetical accident. It was
understood from the outset that the Department would accept the results, regardless of the
outcome. Further, no pressure, real or implied, was applied by the Department relative to the
reported results or findings. With regard to the credibility of the conclusions reached by the
Los Alamos National Laboratory, it should be noted that the comment and comment resolution
process effectively provide an independent review of the Los Alamos National Laboratory's
work.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.18) FOLLOWS.
Document #: 1011 Comment #: 12 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
In the report, Potential Ogallala Aquifer Impacts of a Hypothetical Plutonium Dispersal Accident in Zone 4 of the
Pantex Plant, compiled by the Los Alamos National Laboratory, there were several points I find questionable.
1. According to the report, research has shown that recharge rates below playa lakes in the area have been
estimated between 1.3 and 8 cm/year (page 8). The report indicates that a "conservative" recharge estimate of 3
cm/year was used in the modeling project. Why was the 8 cm/year estimate not used?
Document #: 1016 Comment #: 23 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
The report mentions the "conservative" figures numerous times as in the recharge rates of the Ogallala Aquifer.
Why weren't the higher rates used? If the rates of 1.3 to 8 cm/year, why use 3 cm/year? If the higher rate is
possible, it should be used.
Response #: E.18
The question of estimating recharge rates is central to the analysis of the hypothetical accident
on the Ogallala Aquifer and is addressed in great detail in Response E.5. The 8 cm/yr
estimate mentioned in Turin et al. (1992) was a maximum estimate based on tritium analyses
for a higher recharge area south of the study area and was not considered reasonable for the
actual study area. However, the unpublished tritium data from the Texas Bureau of Economic
Geology (Nativ (1988)) suggests higher recharge rates may be possible near the Pantex Plant.
Therefore, these higher recharge rates have now been evaluated. The analysis supports the
original conclusion of the Environmental Assessment that the hypothetical plutonium dispersal
accident does not pose a significant threat to the Ogallala Aquifer.
cm = centimeter
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.19) FOLLOWS.
Document #: 1011 Comment #: 14 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
Mobility of potential groundwater pollutants downward through the soil is often dependent upon the chemical
properties of contaminants, the soil properties, and the interactions between the contaminants, soil and water in
the system. Organic matter content, cation exchange capacity, moisture content, and pH of the soil, as well as
pre-existent soil structure and condition, can affect the transport of potential pollutants toward the aquifer. These
issues are not adequately addressed by the Los Alamos report.
Response #: E.19
Laboratory sorption studies using plutonium, actual soil samples from the Pantex Plant area,
and Ogallala Aquifer water were conducted to evaluate how the soil properties cited in this
comment affect contaminant mobility in the area of the Pantex Plant site. These experiments
are described in Appendix A of Turin et al. (1992); the results were used in the transport
models.
The comment raises the question of soil structure. There are no routine methods available for
collecting soil samples with representative soil structure intact. Therefore, in the Los Alamos
National Laboratory's experiments, the soil was sieved, effectively destroying the soil structure.
It is difficult to precisely estimate the impact of sieving on the soil's sorptive properties.
Because of this uncertainty, a conservatively low KD value was used, making the technical
analysis fully adequate.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.20) FOLLOWS.
Document #: 1011 Comment #: 15 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
3. The group at Los Alamos used a computer model to estimate plutonium transport rate by advection-dispersion
analysis. In order to account for preferential flow, the investigators increased the assumed flow velocity by a factor
of 2. In the report, they cited research which had found accelerated solute transport rates at 5 times the predicted
rates. Why did the investigators choose a factor of 2 instead of the more conservative factor of 5 in the model
runs? Why were the accelerated rates not applied with the piston flow model?
Response #: E.20
The overall approach taken by the Los Alamos National Laboratory in evaluating the potential
effects of the hypothetical plutonium dispersion accident on the Ogallala Aquifer was to use
conservative but reasonable assumptions rather than extreme values. Of the seven studies of
preferential flow cited in Turin et al. (1992), three resulted in an acceleration factor of one (no
acceleration), three in a factor of two, and one in a factor of five. Without local site-specific
field experiments, using a factor of two was a conservative, but reasonable assumption.
The piston-flow model was presented primarily as a teaching tool and an introduction to the
more rigorous advection/dispersion analysis, rather than as a realistic analysis of contaminant
transport. Therefore, all of the complicating factors, such as preferen-
tial flow, were not
incorporated into the piston-flow model runs. The Environmental Assessment conclusions are
based on the more accurate advection/dispersion model which was run under various
scenarios, including preferential flow.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.21) FOLLOWS.
Document #: 1011 Comment #: 16 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
4. Experiments conducted at Los Alamos to estimate the plutonium sorption characteristics of the Pullman soil
used only the A (upper) Horizon of the Pullman soil. These samples were air-dried and sieved to obtain particles in
a given range (Appendix A). Sieving eliminates the soil's characteristic structure (aggregates, etc.) from the tests.
Since the A horizon was all that was tested, sorption properties of lower horizons were not known. Can we
reasonably assume that undisturbed field soils will behave like the samples tested in the experiments?
Response #: E.21
As discussed in Response E.19, the effects of soil structure are difficult to predict, as are the
sorptive properties of untested subsurface horizons of the Pullman soil. To account for this,
Turin et al. (1992) made the extremely conservative assumption that all soils encountered by
the plutonium contaminant would have the sorptive properties of the Ogallala sand. This
assumption is known to be conservative because the Pullman A horizon was measured at
roughly ten times greater sorption than the Ogallala sand. Also, while subsurface Pullman
soils are likely to have lower sorption than the A horizon, based on reported mineralogy,
subsurface Pullman soil will most likely show higher sorption than the Ogallala sand.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.22) FOLLOWS.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.21) FOLLOWS.
Document #: 1011 Comment #: 17 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
As a research engineer involved in modeling of soil-water flow, I must point out that models are only as good as
the data and assumptions that are put into them. They can only provide estimates of soil water behavior according
to the understanding of the model developer. The performance of a model in a particular application is limited by
the quality of data used to describe the specific site conditions to the model.
I recognize that my questions are directed to increase conservatism in estimates of groundwater pollution risk. I
feel that in a project of such great importance, and with such great potential for damage to the environment and to
the people in the Texas panhandle, that this conservatism is appropriate. It is reasonable to expect the D.O.E. to
provide best-case and worst-case scenarios. It is reasonable to investigate the history of Pantex's environmental
stewardship.
Response #: E.22
Turin et al. (1992) used conservative, yet reasonable assumptions, and clearly stated those
assumptions. Making extreme assumptions (piling one extreme on top of another) was
purposely avoided because it can result in predictions that, while theoretically possible, are so
extremely unlikely as to be misleading. Instead, values that are at the conservative end of a
reasonable range were selected.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.23) FOLLOWS.
Document #: 1012 Comment #: 3 Date: 1/16/93
Margie K. Hazlett (1)
Citizen Comments
Comment:
According to the Los Alamos report, "Plutonium transport through the unsaturated zone is a major risk, under
evaluated, and is primarily controlled by the degree of plutonium sorption onto local soils and aquifer materials (sic)
Members of the Los Alamos Laboratory Earth and Environmental Science Division described in their report, the
potential for Ogallala Aquifer contamination should plutonium be released into the environment within an 80 km.
(Kilometer) radius of Pantex Plant. As in an accident that disperses plutonium into the environment, active
groundwater recharge projects should be shut down, if possible, and I doubt seriously if there would be any
manpower left to shut down these projects which would have vanished.
Response #: E.23
This comment misquotes Turin et al. (1992) as follows: "Plutonium transport through the
unsaturated zone is a major risk, under evaluated, and is primarily....". The sentence in Turin
et al. (1992) on page 8 actually begins: "Plutonium transport through the unsaturated zone is
the major risk under evaluation in this report, and is primarily....". The meaning of the phrase
as misquoted is significantly different than the meaning of the actual phrase.
The comment also suggests that manpower may not be available to shut down groundwater
recharge projects in the event of a plutonium dispersion accident. The Department has no
reason to suspect, and the comment provides no support for its hypothesis, that groundwater
projects cannot be terminated in the extremely unlikely event of plutonium dispersion.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.24) FOLLOWS.
Document #: 1018 Comment #: 1 Date: 1/20/93
Bob Bullock, Lt. Governor
State of Texas
Comment:
The briefing included a technical presentation regarding the risks of plutonium contamination to the Ogallala
Aquifer, but did not cover contamination of surface water. I would appreciate information regarding the risks and
the potential consequences of contamination to surface water and soil.
Response #: E.24
A comprehensive analysis of all the potential consequences of accident events found to occur
with a frequency less than one in a million per year was not conducted by the Department.
The only accident which would have the potential for contaminating surface water would be an
aircraft crash into an interim storage magazine with subsequent dispersal of plutonium
material. This accident, together with subsequent dispersal, was found to have the probability
of less than one in a million per year.
Although the potential consequences to surface water were not specifically analyzed, impacts
to the Ogallala Aquifer were analyzed, as stated in the comment, and an analysis was
conducted to project the contaminated area of such an accident. This area was found to be
75 km2 which is an order of magnitude less than that of accidents analyzed within the Final
Environmental Impact Statement, Pantex Plant Site (DOE/EIS-0098, October 1983) for
operations which continue to be conducted at the Pantex Plant. In addition, the dispersal of
plutonium material and the immediate health effects of such a dispersal were also found to be
significantly less than that of accidents analyzed within the above mentioned document.
km = kilometer
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.25) FOLLOWS.
Document #: 1024 Comment #: 1 Date: 3/10/93
Jay R. Roselius, County Judge
Carson County
Comment:
... request that authorities from these different agencies be assembled together in their area of expertise and
address and formulate the best possible response to the following areas which seem to me to be the areas of most
concern when considering all of the various comments...
1. The chance of contaminating the Ogallala Aquifer.
Response #: E.25
Los Alamos National Laboratory was tasked by the Department of Energy to analyze potential
consequences to the Ogallala Aquifer as a result of a hypothetical plutonium release. Many of
the comments raised during the State and public review of the Environmental Assessment and
the analysis by Turin, et al questioned the assumptions, data, and the subsequent result of
calculations. The Department, having addressed the issues raised, continues to conclude that
the hypothetical plutonium dispersal accident does not pose a significant threat to the Ogallala
Aquifer.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.26) FOLLOWS.
Document #: 1048 Comment #: 15 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
7.0 Potential impacts on the Ogallala Aquifer... does not address the possibility of cracks in the soil, from Texas
Panhandle droughts, thereby creating faster pathways to the Ogallala. Why were DOE LANL studies used and
not studies done by local geologists (sic)
Response #: E.26
The Los Alamos National Laboratory was selected by Department of Energy Albuquerque
Operations Office to analyze the potential effects on the Ogallala Aquifer of a hypothetical
plutonium dispersal accident, utilizing the expertise of health physicists, plutonium chemists,
and geologists. It is felt that the Los Alamos National Laboratory study is technically credible
and accurate.
This comment also inquires about preferential pathways which might be created by cracks in
the soil from panhandle droughts. Turin et al. (1992) estimated the effect of preferential flow
on contaminant transport by doubling the assumed transport velocity. This approach is
conservative based on good professional judgment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.27) FOLLOWS.
Document #: 1048 Comment #: 24 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
7-2 ... "Field experiment... suggests colloidal transport will not enhance radionuclide transport enough to
significantly effect groundwater quality". Hogwash, "suggest", "not enough" and "significantly affect" have no place
in a study of drinking water for the people of the area. We are being fed a document prepared by an agency that
has no credibility in preserving present water supplies at any of their other facilities.
To come to the final conclusion of "no significant threat to the Ogallala Aquifer from plutonium dispersal" is
simply conjectural.
Response #: E.27
The analysis of the potential for contamination of the Ogallala Aquifer determined that, if an
event such as that hypothesized in the aircraft crash analysis expected to occur with an
annual frequency of 7 x 10-7, plutonium could migrate through the soil and reach the aquifer in
76,000 years [Turin et al. (1992)], if the aquifer is 50 feet below the surface. The analysis used
geological parameters that are reasonable and conservative, rather than extreme. The
estimated concentration of plutonium predicted to appear in the aquifer following this
extremely unlikely event, while not zero, should not be significant.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.28) FOLLOWS.
Document #: 1048 Comment #: 23 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
who (sic) have done in-depth studies on the Ogallala? LANL studies have not correctly addressed the full scope of
the aquifer and the potential impacts. DOE's previous record of contamination to underground water supplies only
reinforces the lack of accountability in DOE studies.
Response #: E.28
The reference list provided in Turin et al. (1992) lists a number of in-depth studies of the
Ogallala Aquifer. As required by the National Environmental Policy Act, the scope of the
Environmental Assessment was defined based on the proposed action of adding increased
interim plutonium storage capacity at the Pantex Plant. To that end, the potential impacts to
the Aquifer as a result of the proposed action were fully addressed.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (E.29) FOLLOWS.
Document #: 1011 Comment #: 5 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
The groundwater contamination models were run with the assumption that, in the event of a plutonium release,
any contaminated soil would be de-contaminated to a 2.0 uKCi/L. (sic) In the event of a release of radioactive
dust, how large of (sic) area would be affected? What costs in human safety, agricultural productivity, and
environmental quality would be associated with such a clean-up operation? Is it possible that contaminated
surface soils would have to be removed from a large area? How would these contaminated soils be treated or
disposed?
Response #: E.29
The size of the area that would be contaminated above the proposed Environmental
Protection Agency guideline of 0.2 -Ci/m2 depends on the energy source (thermal or
explosive) available to disperse the plutonium, the amount of plutonium involved in the
accident, the size of the particles resulting from the accident, and the meteorological
conditions at the time of the accident. The energy source postulated by the Environmental
Assessment for dispersing plutonium is a large, long-lasting fire resulting from the ignition of
aircraft fuel. The amount of plutonium available to be dispersed in an accident was reasoned
to be 25 percent of the maximum inventory in a Modified-Richmond or Steel Arch Construction
Magazine. (See Section I of this document.) Experiments have shown that in a thermal
environment, 1 percent of the exposed material is aerosolized and 5 percent of the
aerosolized particles are 10 micron aerodynamic diameter or less. Based on these
parameters, the maximum calculated area that is expected to be contaminated to a level
above the proposed Environmental Protection Agency guideline due to an accident in Zone 4
is 75 km2.
The Final Environmental Final Impact Statement, Pantex Plant Site (DOE/EIS-0098,
October 1983) estimated the expected contaminated area and the cleanup costs resulting
from 120 kg and 30 kg of plutonium dispersed by detonation of high explosives under
meteorological conditions D and E (see Section 4.2.5 and Tables 4.2.7-1 and 4.2.7-2). The
contaminated area predicted from the 120 kg case for conditions of D and E stability were
824 km2 and 1,036 km2, respectively. The areas predicted from the 30 kg case were 650 km2
and 751 km2. These predictions should be compared to the estimated areas of contamination
presented above (75 km2 maximum) which may result from an aircraft crash into a magazine
used for interim storage of pits in Zone 4.
Cleanup, as described on Page 4-44 of the Final Environmental Impact Statement, Pantex
Plant Site (DOE/EIS-0098, October 1983) could be accomplished by vegetation and soil
removal using farm or road machinery. The extent of the vegetation and soil removal would
be determined by the level of contamination. Decontamination technologies which involve soil
cleanup as opposed to permanent removal may also be used and have been demonstrated at
Johnston Atoll. Material generated as a result of a cleanup activity would be treated and
disposed of in compliance with Environmental Protection Agency and State of Texas
requirements. All Federal response and recovery activities would be coordinated by the
Federal Emergency Management Administration. A lead Federal Agency, such as the
Environmental Protection Agency or the Department of Energy, would be appointed. The lead
Federal Agency would work out specific response efforts with the State. Additional information
regarding coordination and management for emergency and recovery activities can be found
in Response G.1.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 7.0 was changed to reflect the comment.
-Ci = microCurie
m = meter
km = kilometer
kg = kilogram
SECTION E REFERENCES
Barnes, J.R., W.C. Ellis, E.R. Leggat, R.A. Scalapino, W.O. George, and B. Irelan (1949).
Geology and Ground Water in the Irrigated Region of the Southern High Plains in Texas,
Progress Report No. 7. Texas Board of Water Engineers, 51 pp.
Goss, D.W., S.J. Smith, B.A. Stewart, and O.R. Jones (1973). Fate of Suspended during Basin
Recharge. Water Res. Res., 9(3):668-675.
International Atomic Energy Agency, 1969, 1971, 1973, 1975, 1979, 1983, 1986. Environmental
Isotope Data No. 1-8; World Survey of Isotope Concentration in Precipitation. IAEA, Vienna.
Klemt, W.B. (1981). Neutron Probe Measurements of Deep Soil Moisture as an Indicator of
Aquifer Recharge Rates. Texas Department of Water Research. LP 142, 31 pp.
Knowles, T., P. Nordstrom, and W.B. Klemt (1984). Evaluation of the Ground Water
Resources of the High Plains of Texas. Texas Department of Water Research, Report 288,
Volume 1, 113 pp.
Nativ, R. (1988). Hydrogeology and Hydrochemistry of the Ogallala Aquifer, Southern High
Plains, Texas Panhandle and Eastern New Mexico. Bureau of Economic Geology Report of
Investigations, No. 177. University of Texas, Austin.
Nativ, R. and R. Riggio (1990). Meteorologic and Isotopic Characteristics of Precipitation
Events with Implications for Ground-Water Recharge, Southern High Plains; in Geologic
Framework and Regional Hydrology: Upper Cenozoic Blackwater Draw and Ogallala
Formations, Great Plains, T.C. Gustavson, ed., Texas Bureau Of Economic Geology, Austin,
TX, pp. 152-179.
Parker, J.C. and M. Th. van Genuchten (1984). Determining Transport Parameters from
Laboratory and Field Tracer Experiments. Virginia Agricultural Exp. Stn. Bull. 84-3,
Blacksburg, VA.
Rogers, P.S.Z. and A. Meijer (1993). Dependence of Radionuclide Sorption on Sample
Grinding, Surface Area, and Water Composition. Paper presented at the 1993 International
High-level Waste Management Conference, April 26-30, 1993, Las Vegas, sponsored by the
American Nuclear Society.
Shevenell, L. (1990). Chemical and Isotopic Investigation of the New Hydrothermal System at
Mount St. Helens, Washington. Ph.D. dissertation submitted to the University of Nevada,
Reno.
Thomas, K.W. (1987). Summary of Sorption Measurements Performed with Yucca Mountain,
Nevada, Tuff Samples and Water from Well J-13. Los Alamos National Laboratory Report
#LA-10960-MS.
Turin, H.J., I.R. Triay, W.R. Hansen, and W.J. Wenzel (1992). Potential Ogallala Aquifer
Impacts of a Hypothetical Plutonium Dispersal Accident at the Pantex Plant. Report prepared
for the U.S. Department of Energy by Los Alamos National Laboratory.
U.S. Bureau of Reclamation (1982). Llano Estacado Playa Water Resources Study, A Special
Investigation. Southwest Regional Office, Amarillo, Texas.

Part F

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.1) FOLLOWS.
Document #: 1001 Comment #: 2 Date: 2/25/93
Ann W. Richards, Governor
State of Texas
Comment:
In addition, state officials believe that the methodologies used in the report..., and the section addressing the
Aircraft Hazard Analysis, are so fundamentally flawed that they must be revisited. In their current form, it is
impossible to determine whether the resulting conclusions are, in fact, valid.
Document #: 1003 Comment #: 2 Date: 1/12/93
Thomas A. Griffy
Univ. of Texas, Austin, Dept. of Physics
Comment:
On a more detailed note, I believe the analysis presented of aircraft accidents is fundamentally flawed. While
aircraft accidents might occur at a rate estimated to be more than 1.OE-6 per year, analysis of the impact of air
carrier or military accidents was not included on the basis that this subgroup had a probability estimated to be less
than 1.OE-6 per year. This procedure of dividing an accident class into subgroups in order to reduce the probability
of each subgroup below that necessary for inclusion is surely unjustified. (When carried to its logical conclusion
one could divide the class of aircraft accidents to a subgroup which consisted of MD-88 aircraft, carrying exactly
121 passengers flown by a captain named Kruger on Thursday!) Risk analysis should be performed on the basis
of probability times consequences.
Document #: 1005 Comment #: 9 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
Overall, considerable work is required to produce an acceptable analysis of hazards posed by aircraft. This Aircraft
Hazards Analysis does not provide a comprehensive or accurate picture of the danger posed by aircraft to material
stored at the Pantex plant.
Response #: F.1
The Environmental Assessment uses a generally accepted methodology for
examining aircraft crash. The aircraft crash rates for commercial,
military, and general aviation are different. This is not unexpected
because the nature of the operations are significantly different and,
we believe, independent. To lump all the accident rate data together
and use a single number to estimate the probability of impact would be
unrealistic. On the other hand, the total probability of an aircraft
crash has been generated by developing the probability for the
subclasses and then summing these estimates. (See, for example, An
Assessment of the Probability of Aircraft Impact with Pantex
Structures, SAND76-0120, Sandia National Laboratories, June 1976;
Estimate of the Probability that an Aircraft Will Impact the PVNGS,
Solomon, K.A., NUS-1416, Revision 1, Arizona Nuclear Power Project,
July 25, 1975; and NUREG-0800.) Argonne National Laboratory reviewed
various methods of aircraft hazard analysis, including Solomon and
NUREG-0800. Argonne reviewed the body of published literature, found
that it corresponds to the method of Solomon and the data bases,
methodologies, and modeling approaches are adequate to estimate the
threat and plant response. (For additional information, refer to
Evaluation of Aircraft Hazards Analyses for Nuclear Power Plants,
NUREG/CR-2859, ANL-CT-81-32, Argonne National Laboratory, June 1982).
If this document were intended to be a probabilistic risk assessment, then the analysis would
be based on the product of the frequency (probability of occurrence) and consequence.
However, the underlying analysis (the Final Safety Analysis Report, Pantex Plant Zone 4
Magazines, Issue D, April 1993) on which the Environmental Assessment is based is not and
was not intended to be a probabilistic risk assessment. Quantitative methods were used
wherever appropriate.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.2) FOLLOWS.
Document #: 1002 Comment #: 1 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
Subdivision into Aircraft Subclasses is Used to Eliminate the Need to Consider the Impact of Certain Types of
Aircraft with Zone 4 Structures
Initially, the EA finds the probability that an aircraft will impact a Zone 4 structure to be greater than
one-in-a-million. In other words, the chance of airplane impact with a structure scheduled for the interim storage of
plutonium is calculated to be a credible event. However, the potential consequences of airplane impact with Zone
4 structures are not reported.
The probability of impact is developed by dividing aircraft into four classes: air carriers, military aircraft, aerial
application, and general aviation. The probability of impact for any specific class of aircraft, except general
aviation, is calculated to be less than one-in-a-million. Thus the EA concludes, it is unnecessary to consider any
class of aircraft except for general aviation. This is a clear deviation from the 1976 Sandia report, which concludes
only that the probability of aircraft impact is 4.7 in 100,000(4.7E-05). The most critical objection to the
methodology of the EA is that conclusions are drawn about the probability of subclasses of aircraft while the
methodology followed is clearly developed for a population estimate. This technique of subdivision into aircraft
classes is used in order to reduce credible events into incredible specific events. I am especially concerned about
the validity of subpopulation estimates of probability since the environmental consequences of an incredible event
do not have to be analyzed.
The probability of impact for a general aviation aircraft with a Zone 4 structure was calculated to be greater than
one-in-a-million annually. Again, the method of subdivision into aircraft classes was applied. General aviation
aircraft were subdivided into two classes: single engine aircraft and multi-engine aircraft. Multiple engine aircraft
are then shown to have an impact probability which is incredible. It is possible to further subdivide the class of
single-engine general aviation aircraft so that the impact of those subclasses of planes with the Pantex Zone 4
structures is an incredible event. However, the report instead references analyses by Jacob (sic) Engineering
(Appendix C) which "suggest it is reasonable to exclude single-engine aircraft from further consideration in the
accident analysis." Clearly, by employing a subdivision method, it is possible to reduce the probability of almost
any event to an incredible level.
Response #: F.2
The statement that the sum of the probabilities of any aircraft crash into Zone 4 is greater than
1 x 10-6/yr is correct. However, the Environmental Assessment also states the sum of the
probabilities of aircraft crash with a potential for significant impact and consequences is less
than 1 x 10-6/yr. Therefore, neither the Environmental Assessment nor the safety analysis
report present the potential consequences for this event. Nevertheless, selected aspects of
the potential consequences of an aircraft crash may be found in Section I of this document.
The reviewer objects to using categories stating that the methodology reported is a "clear
deviation from the Sandia study (An Assessment of the Probability of Aircraft Impact with
Pantex Structures, SAND76-0120, Sandia National Laboratories, June 1976)." The method
used is not a deviation from the Sandia National Laboratories study. This current effort was
conducted using the Sandia National Laboratories methodology. As a point of information,
the following is reproduced from the Sandia National Laboratories study.
Conclusion
The total probability (emphasis added) of an aircraft impact per year with structures at the
Pantex Plant is 4.7 x 10-5. Table VII describes the contributions to the total. A sensitivity
analysis of the input parameters has been completed. The values chosen for the analysis
represent the range over which parameters might reasonably be expected to vary. The
most sensitive single parameter is the skid factor and its effects are relatively insignificant
(Figure 11).

TABLE VII - Probability of Crash at the Pantex Plant per Year
Buildings Ramps Total
Air Carrier 1.9 x 10E-6 1.7 x 10E-7 2.1 x 10E-6
Military 9.8 x 10E-6 1.1 x 10E-6 1.1 x 10E-5
General Aviation 3.0 x 10E-5 3.5 x 10E-6 3.4 x 10E-5
Aerial Application 2.4 x 10E-7 2.8 x 10E-8 2.7 x 10E-7
Total 4.2 x 10E-5 4.8 x 10E-6 4.7 x 10E-5

An Assessment of the Probability of Aircraft Impact with Pantex Structures, SAND76-0120, Sandia
National Laboratories, June 1976.
Thus, it can readily be seen that the total probability is the sum of the individual probabilities
by aircraft type and target. Also, it should be remembered that in the Sandia National
Laboratories study buildings and ramps in Zone 4 and Zone 12 were the targets of concern.
Further, the reviewer seems to discount the fact that the consequences of an aircraft impact
will be very much a function of the type of aircraft impacting the structure. To suggest that the
consequences are somehow just a function of an impact is simply incorrect. A portion of the
general aviation class was excluded on the grounds that an impact of a single-engine, 3,500-
lb. class aircraft would generally not have sufficient energy to cause consequences of
concern. To retain the probability that this class of aircraft would crash in the total probability
and then to estimate the consequences based on the energetics of larger commercial, general
aviation, or military aircraft would be incorrect and lead to erroneous conclusions.
The reader is referred to Response F.1 for information regarding the methodology. The Final
Safety Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993) was placed in
Department of Energy reading rooms located in Amarillo and Panhandle, Texas, and was
provided to State of Texas officials in April 1993.
yr = year
lb = pound
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.3) FOLLOWS.
Document #: 1002 Comment #: 2 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
Zone 4 Effective Areas Reduced from 1976 Sandia Report
In order to calculate the probability of a plane impacting into the Zone 4 structures, a formula was used which
considers only the portion of Zone 4 where an aircraft could strike a magazine. The formula given is equal to the
sum of the actual area the building occupies, a shadow area dependent on the sub class of aircraft considered and
a skid area dependent on the subclass of aircraft. The areas used are smaller than the areas used in the 1976
Sandia report. This is due to a substantial reduction in the skid areas and the wingspans capable of doing damage
to Zone 4 structures from the values used in the 1976 Sandia report. This reduces the "effective" area for over 60
percent (%) of the aircraft to less than one-tenth of a square kilometer. From the maps provided in the
environmental assessment and references, it appears that Zone 4 covers at least one square kilometer. Thus, the
Zone 4 areas where an airplane crash might cause damage has been reduced by 90% for most types of aircraft
considered. This cannot be verified as the actual dimensions of Zone 4 and its structures were not provided in the
environmental assessment.
Response #: F.3
The geographical area of Zone 4 is not a significant factor to the analysis because the size of
the targets at risk (i.e., the storage magazines) is what must be considered in the analysis.
The effective size of the target at risk is related to its physical size, the size of the aircraft, and
the potential skid distance of an aircraft that impacts away from the magazine and skids into
the structure. The information presented in the Sandia National Laboratories study (An
Assessment of the Probability of Aircraft Impact with Pantex Structures, SAND76-0120, Sandia
National Laboratories, June 1976) for the physical size of the magazines is essentially the
same as that used in the Environmental Assessment for the actual physical dimensions of the
targets. Earlier work did look at buildings in Zone 4 (magazines) and Zone 12, plus the ramps
that connect the buildings. The estimates would be lower than the Sandia estimates if only
Zone 4 were examined.
On the other hand, it is the modification of the skid distance that has the most significant
effect on the results. Appendix E to the Environmental Assessment describes the rationale
used to reduce the skid contribution for this analysis. It was the consensus of the technical
reviewers and others involved in such analyses that the skid distances assumed in the earlier
referenced works were much too conservative. These skid estimates were revised and
updated in a reasonable and consistent manner.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.4) FOLLOWS.
Document 1002 Comment #: 3 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
Probability per Kilometer of an Aircraft Crash is Reduced from the 1976 Sandia Report:
A crucial element for calculating the probability of aircraft impact with a Zone 4 structure is the probability of an
aircraft crash per kilometers flown. The type of aircraft crash considered is one in which the aircraft is significantly
damaged since the assessment claims these are the only type of crashes which could impact a magazine. In
addition, only crashes which occurred while the plane was inflight are considered. For every subclass of aircraft,
the 1992 EA reports a substantially lower probability per kilometer of a significant inflight aircraft crash than the
1976 Sandia report (see Table 1). [Table 1 - not reproduced here]
The EA relies on fatal accident figures (provided by the National Transportation Safety Board [NTSB] in a
memo from Lin and Tenney of Sandia National Laboratories, dated July 2, 1992, to R.E. Smith) upon which to
base a new rate for the probability per kilometer of an inflight United States air carrier crash. This relationship is
assumed despite a comment by Lin and Tenney that "the number of aircraft destroyed is not highly correlated to
the number of fatal accidents." The EA reduces the mean fatal accident rate by the ratio 18/31 to provide an
estimate of the inflight accident rate in which the accident is severe enough to seriously damage or destroy a Zone
4 magazine (page E-2). This method of estimation assumes a linear relationship between the known quantity (fatal
accident rate) and the unknown quantity (inflight severe accident rate). This is not a valid assumption unless the
two variables are correlated.
Response #: F.4
The reviewer notes that the aircraft crash rates are greatly reduced from the values used in the
Sandia National Laboratories study (An Assessment of the Probability of Aircraft Impact with
Pantex Structures, SAND76-0120, Sandia National Laboratories, June 1976). To ignore the
demonstrable fact that aircraft crash rates have declined in the last two decades for all types
of aircraft would be improper analysis. Section E.1, Appendix E of the Environmental
Assessment provides an extensive discussion of our rationale.
The reviewer correctly quotes Lin and Tenney to the effect that the "number of aircraft
destroyed is not highly correlated to the number of fatal accidents" for U.S. air carrier
operations. The reason for this lies in the method the Federal Aviation Administration uses to
declare that a flight had a fatal accident associated with it. In the accident data bases, a flight
is listed as a flight with fatalities if there are any deaths associated with it. For example, if an
aircraft is arriving or departing from a passenger gate and strikes and kills a ramp worker, that
flight is listed as one with fatalities. (See for example the Federal Aviation Administration
Statistical Handbook of Aviation, Calendar Year, 1989, U.S. Department of Transportation).
Similarly, if a passenger should suffer a fatal heart attack enroute, the flight would be listed as
one with fatalities. These sorts of events have no bearing on accidents that can cause
damage to the Zone 4 magazines. However, based on analysis of the accidents in the data
base, there is a strong correlation between fatalities and aircraft destroyed inflight. Therefore,
in examining the data, those accidents that involved both fatalities and destruction were
selected. The ratioing of accidents with fatalities and destruction (18) to the total reported
flights with fatalities (31) was used to account for the peculiarities of the Federal Aviation
Administration reporting system as follows. The Federal Aviation Administration defines the
fatal accident rate as the number of flights with fatal accidents divided by the total number of
miles flown. The inflight fatal accidents with destruction rate is approximated in the analysis by
multiplying the average annual fatal accident rate by the number of accidents with fatalities
and aircraft destroyed inflight (18) and dividing by the total number of fatal accidents (31).
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.5) FOLLOWS.
Document #: 1002 Comment #: 4 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
In order to estimate the probability per kilometer of a severe inflight general aviation crash, the NTSB data base
was again referenced (memo from Lin of Sandia National Laboratories, dated August 13, 1992, to R.E. Smith).
The EA generates a severe in flight accident rate for general aviation using the data provided by Lin (page E-2).
The most critical assumption in calculating the accident rate is the average speed. The memo from Lin provides
"average speeds" for the various classes of aircraft included in the general aviation group. However, the average
speeds used in the EA are greater than the average speeds reported by Lin. These appear to be the only
numbers from the memo that were changed for the EA. By adjusting the speeds upward, the estimated probability
of a severe inflight crash is decreased. The EA does not provide justification for using the higher average speeds.
Furthermore, the total accident rate per mile for general aviation and the total accident rate per mile for general
aviation except single engine aircraft (Table E-6, last two columns) cannot be calculated from the information in the
EA or the reference documents. Since this is a critical subclass of aircraft, additional documentation is necessary
to justify the average speeds used in the calculations. At a minimum, the average speeds used in the calculations
for the last two columns of Table E-6 should be provided.
Response #: F.5
The reviewer is correct that the analysis reported in the Environmental Assessment uses
average aircraft speeds that are higher (10 percent to 29 percent) than those assumed by Lin.
This modification upward was based on information obtained from individuals who regularly fly
such aircraft and from a review of information available in Jane's All the World's Aircraft. The
analysts believe these to be more appropriate representations of average speeds for the
various aircraft types.
The information in Appendix E of the Environmental Assessment can be used to generate the
accident rates summarized in Table E-6. However, the authors do acknowledge that the
methodology is not as well documented in the appendix as it might have been. The following
information is provided by way of further clarification.
The values reported in Table E-5 of the Environmental Assessment are obtained by taking the
number of aircraft destroyed Inflight from Table E-4 and dividing that by the number of hours
flown taken from Table E-3. The total reported in Table E-5 must be obtained by using the
total number destroyed in flight from Table E-4 and the total number of hours from Table E-3.
The total rate per 100,000 hours is not the sum of the individual class rates, but the weighted
sum (i.e., weighted by the hours flown). Therefore, the totals from Tables E-3 and E-4 must
be used to get the totals in E-5. The values reported in Table E-6 are obtained by dividing the
number destroyed by class (Table E-4) by the product of the estimated speed (Table E-6) and
hours flown (Table E-3). For example:
(502 Single Engine Aircraft Destroyed)/(26.3 x 106 hr)(160 mph) = 0.119 Destroyed/1 x 106 mi
As noted above, the total rate destroyed per million miles (Column 6, Table E-6) cannot be
obtained by simply summing the individual rates. The total number destroyed (Table E-4)
must be divided by the total miles flown, that is, the sum of the products of estimated speed
and hours flown for each class. For example:
576/[(26.3 x 160)+(4.8 x 225)+(1.6 x 275)+(1.3 x 450)] x 106 = 576/(6.31x109) = 0.091
where: 0.091 = Total Rate of Aircraft Destroyed
576 = Total Number Aircraft Destroyed (Table E-4)
160, 225, 275, 450 = Estimated Speeds in mph (Table E-6)
26.3, 4.8, 1.6, and 1.3 = million hr flown (Table E-3)
A similar approach is taken to generate the estimate of Modified Total without Single-Engine
Aircraft (Column 7, Table E-6). That is:
74/[(4.8 x 225)+(1.6 x 275)+(1.3 x 450)] = 74/(2.1 x 106) = 0.035
0.035 = Total Rate of Aircraft Destroyed (excluding single engine)
74 = Total Number of Nonsingle-engine Aircraft Destroyed (Table E-4)
160, 225, 275, 450 = Estimated Speeds in mph (Table E-6)
26.3,4.8, 1.6, and 1.3 = million hr flown (Table E-3)
The values reported in Columns 8 and 9 of Table E-6 (i.e., the rates per mile) are simply the
values in Columns 6 and 7 divided by one million. This explanation should resolve the issues
raised in the comment.
As indicated, the total accident rate per mile for general aviation and the total accident rate per
mile for general aviation except single-engine aircraft are calculated from the number of aircraft
destroyed divided by total miles flown for the types of aircraft involved. Thus, it is not
necessary to have an average speed for the last two columns of Table E-6.
It should be noted that there are numerical errors in the 1988 entries in Columns 5, 6, and 7 of
Table E-6. The values clearly should be 0.004, 0.059, and 0.0365, respectively. The analysts
have carried three significant figures through the analysis as a computational convenience to
avoid round off issues. It would not be unreasonable to reduce the three significant figures to
no more than two for the summary values.
Information regarding stall speed is provided in Response F.17.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Table E-6 was changed to reflect the comments.
mi = miles
mph = miles per hour
hr = hour
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.6) FOLLOWS.
Document #: 1002 Comment #:5 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
Note on Aerial Application Probability
For aerial application, the EA claims the "accident rate for aerial application of (2.945E-02/100,000 km,
4.7E-07/mi) was retained (from the 1976 Sandia report) for analysis" (page E-7). However, on page E-22 a
different accident rate is recorded. It appears the accident rate per kilometer was recorded as the accident rate
per mile.
Response #: F.6
Table E-10 did contain a typographical error. The crash rate per kilometer was incorrectly
listed for the crash rate per mile. The correct values for aerial application are: 2.95 x 10-7/km
(4.71 x 10-7/mi). Based on the comment, the calculations were reexamined and it was
established that the proper values were used in estimating the probability of aircraft impact
into Zone 4 magazines. Accordingly, the only change to the Environmental Assessment is to
correct the typographical error.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Table E-10 was changed to reflect the comment.
km= kilometer
mi = mile
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.7) FOLLOWS.
Document #: 1002 Comment #: 6 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
General Notes
After reviewing the reference material provided by the author of "Appendix E, Aircraft Hazard Analysis," I can
find no justification for using three significant figures.
Document #: 1007 Comment #: 16 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page E-25, Table E-13: Use of three significant figures here appears to be unjustified. Therefore, 6.63E-07 may
be rounded up and expressed as 1.0E-06.
Response #: F.7
The analysts dealt with the significant figure issue throughout the preparation of the study. In
general, significant figures are carried to three digits through the calculations to minimize
round-off error problems, but then reduced to two and sometimes one when the data is
sketchy. The appendix is not consistent in this regard; however, it is not necessary that the
approach be consistent since it does not change the conclusion drawn from the analysis.
However, the solution recommended in the comment is not correct either. The value reported
was 6.63E-07, which may be reasonably rounded up to 7E-07. In order to compare to other
numbers, the proper way to round to one significant figure is shown in the following from
Table E-13:
Air Carrier 2.78E-08 = 3.E-08
Military 2.50E-07 = 3.E-07
General Av 3.31E-07 = 3.E-07
Aerial App 5.42E-08 = 5.E-08
Total 6.63E-07 = 7.E-07
There is no consistent rounding technique that will result in a Total of 1E-06.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.8) FOLLOWS.
Document #: 1002 Comment #: 7 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
General Notes
A reference on page E-20 is off by one section. Specifically, the probability equation is defined in Section E.2
not E.2.1.
Response #: F.8
The comment is correct.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section E-2 of Appendix E was changed to reflect the comment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.9) FOLLOWS ON PAGE F-13.
Document #: 1002 Comment #: 8 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
General Notes
According to the reference material (reference 8 of Appendix E) used to generate Table E-2, Summary of
Aircraft Accidents - U.S. General Aviation, the number of fatalities and serious injuries in 1978 was 1,146, not
1,145, and in 1986, the number of fatalities and serious injuries was 790 and not 748.
Document #: 1002 Comment #: 9 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
General Notes
In Table E-3. General Aviation Hours Flown (Millions) by Aircraft Class, the number of hours flown for single
engine aircraft in 1988 should have been 21.2, not 21.1, according to the reference material (see reference 8 of
Appendix E). In 1988, the total number of hours flown for all general aviation aircraft should be 27.1, rather than
21.1, according to the reference material.
Document #: 1002 Comment #: 10 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
General Notes
The Table E-5. General Aviation Aircraft Destroyed inflight Per 100,000 Hours by Class has a column for the
Total. It appears from the text that this column should contain the sum of the preceding four columns. The
numbers that appear in the Total column are not equal to the sum of the preceding columns. Likewise, the
Modified Total w/o Single Engine Aircraft does not appear to contain the sums of the previous columns.
Document #: 1002 Comment #: 11 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
General Notes
Table E-7. Summary of Military Aircraft Crash Rates. The reference (a memo authored by Lin from Sandia
National Laboratories, dated August 25, 1992) used to create Table E-7 reports the number of miles flown for the
C-5 type of military aircraft to be 517 million miles. In the table, the number of miles flown for the C-5 type of
military aircraft is reported to be 414.4 million miles.
Document #: 1005 Comment #: 8 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
Throughout the document, mathematical errors are found. Speeds are quoted in mph when they are actually in
knots, roughly a 15% error in non-conservative direction. The impact energies considered are low in magnitude by
as much as 32% due to the use of incorrect units of velocity (based upon the velocity squared term in the equation
for kinetic energy).
Document #: 1007 Comment #: 15 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page E-24, Table E-12: The TOTAL column contains erroneous data.
Section F F-12
Document #: 1016 Comment #: 24 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
In Appendix E, numerous mathmatical (sic) errors are on the "conservative" side. These tend to bring the
credibility and validity of the EA into question.
Response #: F.9
[Document 1002, Comment 8] The number of fatalities and serious injuries in 1978 should
have been reported as 1,146, not 1,145. For 1986, the number of fatalities and serious injuries
is correctly stated as 748 in Table E-2 of the Environmental Assessment. The sum of the
entries (431 and 317, respectively) in Columns 2 and 3 of Table 1 in "U.S. General Aviation
Aircraft Accidents" (Y.T. Lin, Sandia National Laboratories Memorandum, August 13, 1992) is
748 and not the 790 shown in Column 5. The correct values were used in the analysis.
[Document 1002, Comment 9] In Table E-3 of the Environmental Assessment, the number of
hours flown for single-engine aircraft should have been reported as 21.2 x 106 hr, similarly the
total number of hours should have been reported as 27.1 x 106 hr. The only effect of these
typos is that the total rate of aircraft destroyed inflight per 100,000 hours (Column 6, Table E-5
of the Environmental Assessment) should be 1.13 rather than the 1.45 reported. This error
does not flow through because the values in Table E-6 in the Environmental Assessment were
computed separately.
[Document 1002, Comment 10] The values reported in Table E-5 of the Environmental
Assessment are obtained by taking the number of aircraft destroyed inflight from Table E-4
and dividing that by the number of hours flown taken from Table E-3. The total reported in
Table E-5 must be obtained by using the total number destroyed inflight from Table E-4 and
the total number of hours from Table E-3. The total rate of aircraft destroyed inflight per
100,000 hours is not the sum of the individual class rates, but the weighted sum (i.e., weighted
by the hours flown). Therefore, the totals from Tables E-3 and E-4 must be used to get the
totals reported in Table E-5. This is also the case for the totals without single-engine aircraft.
[Document 1002, Comment 11] The values reported in Table E-7 of the Environmental
Assessment are correct. The miles flown (in millions) estimate is the product of the hours
flown (in millions) in Column 2 and the assumed speed in Column 3. The product of
1.036 x 106 hr and 400 mph is 414.4 x 106 mi, the value used in the analysis. The 517 mph
value is a typographical error in "Military Aircraft Crash Rate (Y.T. Lin, Sandia National
Laboratories Memorandum, May 18, 1992)."
[Document 1005, Comment 8] The National Transportation Safety Board reports use miles per
hour. Military normally use Knots Indicated Air Speed in knots. Our analysis used miles per
hour, this produces conservative results in that it under predicts the mileage flown and thus
over predicts the accident rate. Even if the assumed impact velocity is increased by
15 percent (kinetic energy by 32 percent), this does not alter the conclusion of the structural
analysis (Appendix C of the Environmental Assessment) that the single engine aircraft will not
penetrate the magazines.
[Document 1007, Comment 15] Apparently when the information in Table E-9 in the
Environmental Assessment was revised to reflect the removal of a portion of the General
Aviation, the total column was not properly checked. This typographical error has no impact
on the analysis because the traffic counts for the individual flight paths and categories are
used in the calculations. The total on a given flight path is not used in the calculation. The
total column should simply reflect the sum of Columns 3 through 6.
[Document 1016, Comment 24] While some typographical errors and numerical
inconsistencies have been discussed, none have a significant impact upon the conclusions of
the effort.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Appendix E was changed to reflect the comment.
hr = hour
mi = miles
mph = miles per hour
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.10) FOLLOWS.
Document #: 1002 Comment #: 12 Date: 2/19/93
Alison A. Miller
Texas Air Control Board
Comment:
General Notes
The definition of an incredible event is based upon an annual probability of occurrence. lam concerned that
this may offer a false sense of security. The probability of an event occurring during the anticipated 10 years of
storage is much greater than the probability an event will occur during the one year period used for calculation.
For example, the annual probability of a military aircraft impacting a Zone 4 structure is estimated in the EA to be
2.5E-07. Thus, over a 10 year storage period, the probability of a Zone 4 structure being seriously impacted by
military aircraft climbs to 2.5E-06. That is, over a 10 year period, the chance of military aircraft impacting a Zone 4
structure is much greater than one-in-a-million.
Response #: F.10
The definitions of various events including an incredible event, are based upon a deliberate
process of comparison between events having various societal risks. Ultimately, the definition
of an incredible event is based upon the expectation that the event has a sufficiently small
likelihood of occurrence such that it need not be further assessed. In particular, it need not
be further assessed relative to other societal risks.
All events that are quantified are typically stated in terms of annual probability of occurrence.
It is the standard practice for consistency and convenience and because it provides a
standard block of time to make a judgement on the acceptability of risks from different events.
As an example of industry practice, the Nuclear Regulatory Commission, in its Nuclear
Regulation 0800 Section 2.2.3, evaluates the acceptability of an accident on the basis of the
event occurring annually.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.11) FOLLOWS.
Document #: 1003 Comment #: 3 Date: 1/12/93
Thomas A. Griffy
Univ. of Texas, Austin, Dept. of Physics
Comment:
Excluding low probability events (below some threshold) which could have catastrophic consequences is clearly
wrong.
Response #: F.11
If this document were intended to be a probabilistic risk assessment, the analysis would be
based on the product of frequency (probability of occurrence) and consequence. However,
the underlying analysis (Final Safety Analysis Report, Pantex Plant Zone 4 Magazines (Issue D,
April 1993)) on which the Environmental Assessment is based is not, and was not intended to
be, a probabilistic risk assessment. Quantitative methods were used wherever appropriate.
Aspects of the potential radiological consequences were examined separately. These are
reported in the memorandum located in Section I of this document.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.12) FOLLOWS.
Document #: 1004 Comment #: 1 Date: 1/28/93
C. Ross Schulke
U.S. Dept. of Trans., Federal Aviation Administration
Comment:
During... January, February, and March, 1991,... I provided information to a contractor for the Department of
Energy. This information was limited to Amarillo Air Traffic Control Towers' monthly traffic count logs and the Daily
Flight Progress Strips on aircraft operating in our airspace.
The Aircraft Hazard Analysis Data on pages 6-5 through 6-8 and Appendix E of the Environmental Assessment ...
has no resemblance to the data provided by this office. Therefore, I am unable to comment on any information
contained in the Assessment. For your information, the total aircraft operations for the Amarillo area in the
CY1992 was 91,800. Any further restrictions to flight or changes of airspace to the Pantex Prohibitive area would
have an immediate and adverse impact on the utilization of Amarillo International Airport.
Document #: 1009 Comment #: 2 Date: 2/22/93
Tom Millwee, Chief
Texas Dept. of Public Safety, Div. of Emergency Management,
Comment:
The data provided by the Amarillo Air Traffic Manager differs from the aircraft hazard analysis pages 6-5 through
6-8. The variance on the number of aircraft flying into Amarillo must be reconciled. The projected increase in
plutonium pits must be compared with the projected aircraft traffic during the interim storage period. Using invalid
data will render an invalid conclusion.
Document #: 1024 Comment #: 2 Date: 3/10/93
Jay R. Roselius, County Judge
Carson County
Comment:
... request that authorities from these different agencies be assembled together in their area of expertise and
address and formulate the best possible response to the following areas which seem to me to be the areas of most
concern when considering all of the various comments...
2. The data used to reach a decision on a plane crash into a bunker/magazine or other strategic location.
Response #: F.12
Information was requested from the Amarillo Air Traffic Manager in 1991 to assist in verifying
that current aircraft crash analysis conducted for the Final Safety Analysis Report, Pantex Plant
Zone 4 Magazines (Issue D, April 1993) could be accomplished using the methodology from
the Sandia National Laboratories study (An Assessment of the Probability of Aircraft Impact
with Pantex Structures (SAND76-0120, Sandia National Laboratories, June 1976)). The Sandia
National Laboratories study was a thorough assessment of air operations in the Pantex Plant
area and the probability of aircraft impact into Pantex Plant structures. It included a
characterization of the air traffic in the area, the classes of aircraft, the nature of the
operations, the number of operations per year, and other information that could affect the
probability of an aircraft crash onto the Pantex Plant.
The information obtained from the Amarillo Air Traffic Manager as well as other recent flight
data from the Federal Aviation Administration assisted in verifying the adequacy of the
methodology used in the Sandia National Laboratories study. Because the flight information
from these sources was encompassed by the flight information within the Sandia National
Laboratories study, the yearly flight operations in the Sandia National Laboratories study were
used to maintain conservatism in the analysis. For this reason, we believe that the Amarillo Air
Traffic Manager did not recognize the data in the Environmental Assessment and stated he
was unable to comment on the information contained in the document.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.13) FOLLOWS.
Document #: 1005 Comment #: 1 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
He [James Michael Osborne] noted that the EA did not address Helicopters (sic) that fly over the site. All types of
military helecopters (sic) can be seen on a regular bases (sic). This type of aircraft does not crash by skidding.
They crash by falling straight down.
Response #: F.13
As noted in the cited response, the helicopter traffic in the vicinity of the Pantex Plant has not
been quantified as there was no data on helicopters recorded in the Federal Aviation
Administration flight data that was examined.
However, based on data that is available, helicopters have an annual fatal accident rate (per
100,000 hours) comparable to that of general aviation (see Analysis of Helicopter Accident
Risk Exposure Near Heliports, Airports, and Unimproved Sites, R.J. Adams, E.D. Maconkey,
L.D. Dzamba, DOT/FAA/RD-9019, February 1992) and have approximately an order of
magnitude fewer flying hours. Also, accident data indicate that helicopters do not skid,
therefore the area at risk (i.e., probability of impact) is significantly reduced. Furthermore, the
subset of large helicopters that could cause significant damage is small compared to the total.
For these reasons, helicopter crashes potentially leading to offsite consequences are
qualitatively assessed as beyond extremely unlikely. (See Response F.24 for additional
information on military aircraft.)
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.14) FOLLOWS.
Document #: 1005 Comment #: 2 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
Mike [James Michael Osborne] also noted that no mention of the about 1955 emergency landing of a B 25 on the
site near the present burning ground after the plane ran out fuel. (sic)
Response #: F.14
No data about the emergency landing of a B-25 aircraft in 1955 has been compiled in the
accident data base. An emergency landing that resulted in no damage or injury would not be
included in the accident data bases. It should also be noted that the class of aircraft
represented by the B-25 aircraft (medium, multi-engine bombers of World War II vintage) are
no longer flown. To include accident data for this type of aircraft would be inappropriate.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.15) FOLLOWS.
Document #: 1005 Comment #: 3 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
Secondly, the term "General Aviation" is grossly misused in the Aircraft Hazard Analysis. Traditionally, "General
Aviation" has been used to describe all aeronautical activity that is neither military nor civil, that pertaining to
airlines. Typically, agricultural aviation is also excluded from that heading. General aviation is made up of aircraft
ranging in size from the 1600 lb Cessna 150/152 and smaller up through the 73,600 lb Gulfstream IV. The 3500 lb
aircraft used in the Aircraft Hazard Analysis is hardly representative of General Aviation as it currently exists.
Thirdly, the definition of the takeoff and landing phases of flight as being within 5 kilometers of the airport in (sic)
highly misleading. By using this definition of the takeoff and landing phases as being those within 5 kilometers of
the run way, the analysis is able to take advantage of the lower occurrence of accidents for the "inflight" phase.
This ignores the fact that a high percentage of the flights over the Pantex plant are by aircraft making straight-in
approaches to the NE-SW runway at Amarillo International Airport. These flights consist of military training flights,
as well as military cargo flights by C-5A, C-5B, C-141B and C-130 aircraft. Few light aircraft actually pass over the
plant while on approach to the NE-SW runway at Amarillo International Airport due to the zone of prohibited
airspace and due to normal operational requirements. Typically, these aircraft do not make straight-in approaches,
but rather, fly a much smaller traffic pattern.
The combined effect of the mis-definition of General Aviation and the operation of larger military aircraft over the
Pantex plant implies an exposure to accidents involving much heavier aircraft. A 3500 lb aircraft with a 500 lb
engine is representative of single-engine aircraft only. The Beechcraft 300LW is also representative of General
Aviation. This aircraft is a twin-engine turbo-prop up to 14000 lbs and being driven by two engines weighing 465
lbs each without accessories. The Learjet Model 35 is a twin-engine turbofan weighing up to 18500 lbs and
powered by two engines weighing 734 lbs each without accessories. The Gulfstream IV mentioned above weighs
up to 73600 lbs and is powered by two turbofan engines each weighing 3100 lbs without accessories.
At this point it should also be noted that the military cargo aircraft that routinely operate over Pantex operate at
much higher weights. The C-130 turboprop weighs up to 155000 lbs and is driven by four engines each weighing
approximately 1800 lbs. The C-141B weighs up to 343000 lbs and is powered by four turbofans weighing in
excess of 4300 lbs each. Finally, the C-5B weighs up to 837000 lbs and uses four turbofans weighing more than
7900 lbs each.
In summary,... This does not address the unrealistically small aircraft and light weights... used in the analysis.
Document #: 1044 Comment #: 7 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
Potter County includes Amarillo, Texas, which is only 7.68 miles from Pantex. The Amarillo Air Terminal is only
8.16 miles from the Pantex Plant. The run ways (sic) are even closer than this mileage. No city or town should be
this close to Pantex; nor should the busy air terminal be in the vicinity of Pantex, as most of the air traffic includes
passenger planes and a great number of military aircraft shooting running take-offs and landing. (sic)
Response #: F.15
General Aviation includes U.S. registered aircraft not conducting air carrier revenue operations
under 14 Code of Federal Regulations 121, 125, or 127 or 135. In Section E.2.4 of the
Environmental Assessment, only those single-engine aircraft as represented by a 3,500-lb
aircraft flying below 18,000 ft were not counted. The single-engine aircraft were excluded on
the basis of insignificant consequences. The reviewer is correct, a 3,500-lb aircraft does not
represent the entire general aviation category. However, Appendix E of the Environmental
Assessment shows that the aircraft crash analysis defines General Aviation in precisely the
same manner that the reviewer proposes, i.e., all aviation that is not commercial air, military
air, or crop dusting. The Environmental Assessment does not propose that the category
general aviation be represented by a 3,500-lb aircraft. The Environmental Assessment does
propose that the single-engine class of general aviation be represented by a 3,500-lb
single-engine aircraft. (See Responses F.21 and F.22 for more information.)
Takeoff and landing are defined as the mode of the aircraft within 8 km (5 mi) of the airport
(see A Methodology for Calculation of the Probability of Crash of An Aircraft into Structures in
Weapon Storage Areas, SAND82-2409, Sandia National Laboratories, February 1983). The
inflight mode includes the climb, inflight, and descent of the aircraft. The aircraft crash rate is
strongly dependent on the mode of operation. Because the Pantex Plant is 13.6 km from the
runway at Amarillo International Airport, only the inflight mode of aircraft operation is used for
estimating the aircraft crash rate. All types of aircraft including air carrier, military, and general
aviation are included in the yearly operations for estimating the overall crash probability. The
single-engine aircraft are then excluded to estimate the probability of crash with significant
consequences. If the aircraft cited by the reviewer (e.g., C-5, C-141, C-130) are on straight-in
approaches, they are well beyond 8 km, and if they pass over the plant site, they must be at
least 1200 ft above the terrain. Therefore, the use of inflight crash rates is reasonable and
correct.
The reviewer is correct, the Environmental Assessment does consider that Zone 4 is exposed
to aircraft crashes of heavier and higher performance aircraft than the single-engine class.
The single-engine aircraft (as represented by the 3,500-lb aircraft) was excluded on the basis
of the structural analysis indicating that the impact of such an aircraft would not cause
unacceptable damage. Therefore, when this group of aircraft are excluded, the revised
estimate of impact probability includes only heavier higher speed aircraft. The revised
estimate put the combined events at a probability no greater than 1 x 10-6/yr and no further
analysis was conducted. Table E-13 of the Environmental Assessment is reproduced below.

Table E-13 - Annual Probabilities of Aircraft Crashes
Capable of Producing Significant Consequences
Aircraft Class Crash Probability/Year
Air Carrier 2.78E-08
Military Aviation 2.50E-07
General Aviation 3.31E-07
Aerial Application 5.42E-08
Total 6.63E-07
As noted by another reviewer (Document 1002, Comment 6), the use of three significant
figures in a summary may imply more accuracy than the data available to support the analysis
justifies. Therefore, it would not be unreasonable to round the Total reported above to 7E-07.
But, even if the Total were rounded to 7E-07, the conclusion would remain unchanged.
ft = foot
lb = pound
km= kilometer
mi = mile
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.16) FOLLOWS.
Document #: 1005 Comment #: 4 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
Further, the Aircraft Hazard Analysis seems to consider only accidents in which the aircraft slides to a stop, a
condition consistent with takeoff or landing incidents. No effort is made to analyze higher angle impacts resulting in
energy dissipation through cartwheeling (Sioux City, Iowa DC-10 accident) or the cratering resulting from high
impact angles. Due to the distance from the runway (quoted as being 13.6 km), aircraft passing over the Pantex
plant and following a standard 3 degree glide slope will be at an altitude of approximately 2300 feet above ground
level. This is not conducive to a sliding impact, but rather a high angle impact with resulting vertical penetration of
components into the crash site. In this type of accident, the low-pressure rotor shafts of turbine engines have
been known to penetrate several feet of granite.
... In summary,... No effort was made to address the penetration by high-density engine rotating components...
Document #: 1015 Comment #: 12 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg 6-6: The light aircraft penetration probabilities were all modeled on low-speed/low-angle-of attack (sic)
scenarios. Not considered was a high-speed/perpendicular angle-of-attack scenario induced by vertigo such as
occurred near my residence a few years ago. The aircraft engine in the above incident penetrated a hardland
slope to a depth of 3-5 feet.
Also not considered was a similar situation involving commercial multi-engined craft or heavy military craft which
seem to be in abundance in our air space.
Document #: 1016 Comment #: 5 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Any aircraft that is likely to crash on Pantex is most likely to be a high angle impact instead of the 3 degree skidding
crash.
Response #: F.16
The Environmental Assessment analysis considers direct impacts as well as skidding impacts.
The reviewer implies that the analysis considered only impacts from a 3- angle. Appendix E,
Section E.2.2 of the Environmental Assessment shows that an impact angle of 15- was used
to estimate the shadow area. Higher angles of incidence were not used because the earlier
Sandia National Laboratories study (An Assessment of the Probability of Aircraft Impact with
Pantex Plant Structures, SAND76-0120, Sandia National Laboratories, June 1976) concluded
from a sensitivity study that impact angle did not have a strong effect on the estimates of
effective area. This was confirmed by the current analysts, although it was not reported in the
Environmental Assessment.
The reviewer implies that the DC-10 incident at Sioux City, Iowa, involved cart-wheeling
because the aircraft approached the ground at a high angle. Review of the extensive photo
coverage of that event indicates that the DC-10 was approaching the ground at glide angles
consistent with landing, not at a high angle. The National Transportation Safety Board report
(AAR-90/06) described the Sioux City, Iowa, DC-10 accident as follows:
The airplane touched down on the threshold slightly to the left of the centerline on
Runway 22 at 1600 hours. First ground contact was made by the right wing tip
followed by the right main landing gear. The airplane's right wing began to break up
immediately following touchdown. The remainder of the airplane broke up as it
tumbled down the runway. The fuselage center section, with most of the left wing still
attached, came to rest in a cornfield after crossing Runway 17. The cockpit separated
early in the sequence and came to rest at the edge of Runway 17/35. The largely
intact tail section continued down Runway 22 and came to rest on Taxiway "L". The
engines separated during the breakup. The No. 1 and No. 3 engines came to rest
near Taxiway "L" and the intersection of Runway 17/35, between 3,000 and 3,500 feet
from the point of first impact. No. 2 engine fan rotor components forward of the fan
forward shaft, as well as part of the shaft, had separated from the engine inflight.
High-speed, high angle of impact scenarios are implicit in the analysis by the way the effective
target areas are estimated. It should also be noted that the higher impact angle will have
lower probability of impact with a magazine of concern. The lower angle of potential impact
(15 percent) used in the analysis is conservative in that it increases the estimated shadow
area and, thus, the effective area, or probability of impact. In the limit, as the angle of impact
increases, the shadow area goes to zero. This is easily recognized by examining the equation
for determining shadow area (Ash):
Ash = Z(2d + D)/tan PHI D = (a2 + be2)e0.5
where Z is the magazine height, d is the one-half the aircraft wingspan, a is the magazine
length, b is the magazine width, and PHI is the angle the aircraft path makes with the horizon at
impact. The penetration analysis in Appendix C of the Environmental Assessment assumes
perpendicular impacts into the structure, both roof and doors. A sensitivity study used several
combinations of weight and speed (see Appendix C of the Environmental Assessment).
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.17) FOLLOWS.
Document #: 1005 Comment #: 5 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
The aircraft speed of 80 mph at the time of the accident, as quoted in the Aircraft Hazard Analysis is also highly
unrealistic. This is stated to be derived by multiplying the landing speed of a single-engine aircraft by 1.3. It should
be noted that FAR Part 23-49 requires single-engine aircraft to have a stall speed of not greater than 61 knots
Indicated Airspeed (KIAS), or 70 mph. Multiplying this value by 1.3 results in a speed of 79.3 KIAS or 91 mph.
This is approximately the lowest speed that would be anticipated. Multi-engined aircraft typically stall at higher
speeds, and most turbofan aircraft stall at speeds in excess of 100 KIAS or 115 mph when (sic) operating at light
weights. At heavy weights, the stall speed may rise to more than 150 KIAS or 173 mph. These speeds are only
consistent with low angle impacts. High angle impacts may occur at speeds exceeding the maximum operational
speed of the aircraft.
... In summary,... This does not address... the low impact velocities used in the analysis.
Response #: F.17
The individual states that the 80 mph speed is unrealistic and then provides an argument that
it should be 91 mph, or approximately 14 percent greater. This appears to be a relatively
small change. Stall and/or impact speeds of other aircraft could be higher. However, that fact
is not germane to the analysis conducted. The 80 mph figure was selected as representative
of a single-engine aircraft experiencing difficulties, but with the pilot still exercising some
degree of control. A review of stall speed data for single-engine aircraft of the types flying in
the Amarillo area indicates that this is a reasonable value (approximately 30 percent above
flaps down stall speed). The objective was to establish whether or not the single-engine class
of aircraft could be eliminated from consideration on the basis that an impact by such an
aircraft would not cause unacceptable damage. A limited sensitivity investigation in the
structural analysis (Appendix C of the Environmental Assessment) indicates that even heavier
aircraft at higher speeds will not penetrate or collapse the magazine. As noted in the other
responses, the impact of other classes of aircraft were eliminated on the basis of the
probability of the event, not the energetics of any potential event. (See Responses F.5 and
F.25 for additional information.)
mph = miles per hour
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.18) FOLLOWS.
Document #: 1005 Comment #: 6 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
Additionally, no mention is made of the effects of a post-crash fire or explosion in the Aircraft Safety Analysis. In
the event of an accident involving a large turbine-engined aircraft, several thousand gallons of jet fuel would be
available for combustion. This is not addressed.
... In summary,... No effort was made to address... post-crash fire.
Document #: 1016 Comment #: 6 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Fuel spills and subsequent fire or explosion resulting from such a crash are not adequatly (sic) addressed.
Document #: 1031 Comment #:: 5 Date: 3/1/93
Louise Daniel
Citizen Comments
Comment:
5. The very real danger of an airplane crash causing a major fire is not honestly examined.
Response #: F.18
The effects of a post-crash fire and aspects of the potential consequences of aircraft crash
may be found in Section I of this document.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.19) FOLLOWS.
Document #: 1005 Comment #: 7 Date: 2/8/92
Jeri Osborne & Family
Citizen Comments
Comment:
Finally, the military aircraft accident rates fail to include a number of major accidents. The C-5 is listed as
having had no crashes when, in fact, two are easily recalled. The first of these in the 1970's involved a C-5,
departing from the Republic of Vietnam, and carrying a large number of orphaned children. During the climb to
altitude, several minutes after takeoff, a door seal failed and eventually resulted in the uncontrolled descent and
crash landing of the aircraft. The second, more recent accident took place near Ramstein AFB in Germany and
was associated with Operation Desert Shield.
The B-1B is also listed as having had no accidents. Disregarding the loss of one proto-type at Edwards AFB
due to the failure to maintain proper center-of-gravity during a stall test, three operational aircraft have been lost to
date. The first, in Colorado, was due to a bird strike while operating at low level and was a high-energy impact.
The second, at Dyess AFB in Abilene, TX was due to the catastrophic failure of the low-pressure rotor of one of
the four engines. The third was in late 1992 in the Davis Mountains of Texas.
At approximately the same time as the third B-1B accident, two C-141 aircraft were involved in a mid-air
collision at high altitude over Montana. Both aircraft were destroyed. These accidents involve military aircraft of
types that routinely fly over the Pantex plant and are not addressed in the Aircraft Hazard Analysis.
Response #: F.19
The C-5 aircraft accident in the 1970's, the third B-1B, and the two C-141 accidents in late
1992 were not in the military aircraft crash data provided through the Defense Nuclear Agency
Headquarters because the database included the accidents from 1976 to early 1992.
Therefore, the C-5 aircraft accident was prior to the period covered and the latter three had
not yet been included. Also, of the three B-1B incidents, one was not an inflight accident and
another involved a low-level, high-performance training mission which is not appropriate to the
Pantex Plant analysis. Therefore, those accidents were not included in estimating the crash
rate.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.20) FOLLOWS.
Document #: 1007 Comment #: 13 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page C-10, Line 14: It is unclear why 3500 lbs is paired with 117 fps. Just above, on lines 8 and 9, 117 fps (80
mph) is paired with 6200 lbs. (Possible error)
Response #: F.20
There are two types of analysis being discussed here. First, the single degree of freedom
model was used to investigate the deflection of the Modified-Richmond magazine roof panel
under a loading from aircraft impact. The 3,500-lb aircraft at 117 fps (80 mph) was the base
case and the one for which the response was only 1.3 times the elastic limit. In addition, three
combinations of weight and speed that result in the maximum allowable deflection were
identified and reported in Section C.8.1, Appendix C of the Environmental Assessment. A
6,200-lb aircraft at 117 fps is one of those combinations.
Second, the energy required for penetration of the combined earth overburden and concrete
roof was investigated. As noted in the Environmental Assessment, bomb penetration data
indicates that an energy of 38.0 x 106 lb, fps (as determined by the empirical relation WV1.8
where W is the weight and V is the velocity) would be required for penetration. The base case
aircraft (3,500 lb, 117 fps) has an energy of 18.4 x 106 lb, fps and therefore would not
penetrate the magazine.
lb = pound
fps = feet per second
mph = miles per hour
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.21) FOLLOWS.
Document #: 1007 Comment #: 14 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page E-9, Lines 7-10: Aircraft take-off and landings have been excluded by this assumption. This does not
appear to be conservative in approach, as most commercial and military aircraft operating to the north of the
Amarillo Airport can be observed to fly very close to, if not directly over, the Pantex Plant.
Response #: F.21
Aircraft takeoffs and landings have not been excluded in this analysis. Aircraft using the
Amarillo Airport (13.6 km (8.5 mi) from the Pantex Plant) are included in the overall traffic
counts. Also, the literature contains ample data to indicate that beyond 8 km (5 mi) from an
airport the crash rates are those characterized as inflight. (See for example A Methodology
for Calculation of the Probability of Crash of An Aircraft into Structures in Weapon Storage
Areas, SAND82-2409, Sandia National Laboratories, February 1983.) If the aircraft observed
by the reviewer are over the Pantex Plant, they must be at least 1,200 ft above the terrain and
they are more than 13 km (8.1 mi) from the runway. Therefore, the use of inflight crash rates
is reasonable and correct. (See Response F.15 for more information.)
km = kilometer
mi = miles
ft = feet
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.22) FOLLOWS.
Document #: 1010 Comment #: 2 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
2. Even though a large plane accident is not considered creditable (sic) and not discussed in table 6-1, more
information is needed to insure adequate planning and to give the assessment creditability (sic) with the public.
The information used to determine the probability of this type accident seems to be questionable and needs to be
reevaluated. Since a large aircraft accident is the only type of incident that can have extensive off site
consequences more data must be provided in the assessment. At a minimum the following areas should be
covered in the study or unclassified supporting documents:
The number of military flights that pass directly over area with specific data on the type of aircraft.
Document #: 1010 Comment #: 4 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
(At a minimum the following areas should be considered in the study or unclassified supporting documents:)
The accident history of the type of military aircraft being flown in this area.
Document #: 1010 Comment #: 6 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
(At a minimum the following areas should be covered in the study or unclassified supporting documents:)
Maximum health effects of an off-site release.
Document #: 1010 Comment #: 7 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
(At a minimum the following areas should be covered in the study or unclassified supporting documents:)
Environmental effects and risk levels of maximum possible release.
Response #: F.22
Table 6.1 of the Environmental Assessment includes only events that are considered credible.
A crash of a single-engine aircraft is considered credible based on the analysis in Appendix E
of the Environmental Assessment; all others are not credible. Table 6.1 then proceeds to
examine the effects of a crash of a single-engine aircraft. Based on the analyses in
Appendices C and E of the Environmental Assessment, the effects of the crash of a single-
engine aircraft are considered negligible. It should be noted that the Emergency Planning
Zone developed during the Radiation Hazard Assessment is not affected by these analyses,
and it is not anticipated that the Emergency Planning Zone will change. (See Response F.15
for more information.)
Aspects of the potential off-site consequence analyses of hypothetical aircraft crash into
Zone 4 of the Pantex Plant are documented in the memorandum found in Section I of this
document.
The reviewer also asks for the number of military flights that pass directly over the area with
specific data on the type of aircraft and the accident history of the type of military aircraft
being flown in this area. This information is presented in Appendix E of the Environmental
Assessment. The following is quoted from the appendix:
"The 1976 Sandia study assumed, based on the work of Solomon (Reference 3), that
military crash rates are approximately a factor of five greater than that for commercial
aviation. Recently, Sandia National Laboratories were able to access the United States
Air Force Aircraft Accident Data Base through arrangements with the Defense Nuclear
Agency. The data base includes information by aircraft class, hours flown, and
accidents by flight regime (e.g., landing, cruise). Following the approach developed
for commercial air carriers and general aviation, Sandia established the number of
aircraft destroyed as a result of in-flight accidents (Reference 9). Using the Federal
Aviation Administration flight data for the Amarillo area, ten specific models of military
aircraft flying in the vicinity of the Pantex Plant were identified. This was supplemented
with information based on actual aircraft observed from the plant site, so that 13
aircraft models are considered. The flight information for these aircraft was converted
to an accident rate per mile by multiplying the number of hours flown by the average
cruising speed of the aircraft. The results are summarized in Table E-7. An
examination of a randomly selected 14 days of 1989 Federal Aviation Administration
flight records for the Amarillo area indicates that approximately 90.5 percent of the
military traffic came from high performance aircraft (e.g., fighters and trainers) and 9.5
percent from cargo and bomber type aircraft.
Furthermore, it is noted that nearly 53 percent of the traffic comes from T-38 aircraft
and approximately 79 percent from a combination of T-37 and T-38 aircraft. Therefore,
a weighted military aircraft crash rate for the Amarillo area was generated by
multiplying the "raw" rate for each aircraft class by the ratio of the number of that class
to the total number of military flights (e.g., from Table E-7, for T-38 aircraft, [161/304] -
4.535E-09 = 2.402E-09/mile). These weighted rates may then be summed to generate
a new overall rate. This "reduces" the accident rate for high performance military
aircraft operating in the Pantex Plant area to 4.7E-09 per mile, and the total to 5.04E-09
per mile. The latter value will be used in the analysis."
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.23) FOLLOWS.
Document #: 1010 Comment #: 3 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
(At a minimum the following areas should be covered in the study or unclassified supporting documents:)
The qualifications of the pilots in command of these aircraft. This area is used for a lot of training flights.
Response #: F.23
The reviewer has asked for "The qualifications of the pilots in command of these aircraft. This
area is used for a lot of training flights." Certainly, it is understood by the analysts that there
are numerous training flights in the general area of the Pantex Plant. However, even if a flight
is designated as training, it does not imply an unqualified crew. In peacetime in the
continental United States, the majority of the military flights are training or proficiency missions.
Pilots in command of these aircraft will have satisfied military qualification requirements. We
are not aware of any record keeping that would provide an indication of the pilot credentials of
individuals flying those aircraft on a routine basis, other than the training records of the
particular unit to which the aircraft are assigned. If an aircraft has been involved in an
accident, it would be possible, perhaps, to ascertain the qualifications of the individual at the
controls when the accident occurred, but this would require an extensive review of the
individual accident reports. Furthermore, it is not at all clear what one would do with this
information. But, even it were possible to show that some percentage of all accidents
occurred with a trainee in control, that would not provide any particular insights unless one
knew what fraction of all flights involved trainees.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.24) FOLLOWS.
Document #: 1016 Comment #: 4 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
The plan also assumes the worst possible hazard would be the skidding crash of a light aircraft weighing 3500
pounds. The accompaning (sic) information in section E to support that assumption contains many inaccuracies.
Most aircraft flying directly over the site are of the large military aircraft such as the B-1, C-130, C-141B, F-111,
T-38, which are practicing "touch and goes" at the former SAC base Amarillo International Airport. By the time the
larger aircraft are over Pantex, they are committed to land. Large military helicopters fly over the area
regularly too.
Response #: F.24
The Environmental Assessment does not assume that the worst possible hazard would be the
skidding crash of a light aircraft weighing 3,500 pounds. The estimation of the effective area
takes into account the actual footprint of the structures (true area), the expanded footprint
because the structure has height (shadow area), and the expanded footprint (skid area)
because an aircraft could impact and skid. (See Response F.9)
The potential for impact by aircraft from all four categories (commercial air, military air, general
aviation, aerial application) is considered. Military aircraft flying over the Pantex Plant are
included in the yearly operation as shown in Table E-7, Appendix E of the Environmental
Assessment. The data was based on 14 days of flight records obtained from the Federal
Aviation Administration in 1989. The aircraft types and the numbers of aircraft flying over are
representative near the Pantex Plant in 1989.
No data on military helicopters was recorded in the Federal Aviation Administration flight data
we examined. However, based on available data, helicopters have an annual fatal accident
rate (number/100,000 hours) comparable to that of general aviation (see Analysis of Helicopter
Accident Risk Exposure Near Heliports, Airports, and Unimproved Sites, R.J. Adams, E.D.
Maconkey, L.D. Dzamba, DOT/FAA/RD-9019, February 1992) and helicopters have
approximately an order of magnitude fewer flying hours. Also, accident data indicate that
helicopters do not skid, therefore the area at risk (i.e., probability of impact) is significantly
reduced. Furthermore, the subset of large helicopters that could cause significant damage is
small compared to the total. For these reasons, helicopter crashes potentially leading to
offsite consequences are qualitatively assessed as beyond extremely unlikely.
The reviewer asserts that the information in Section E to support the assumption that a
skidding 3500-pound aircraft contains many inaccuracies. We are unable to respond because
from this limited statement we are unable to ascertain what information the reviewer considers
inaccurate or why it is considered inaccurate.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.25) FOLLOWS.
Document #: 1017 Comment #: 15 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
C.2 Aircraft -- The EA uses as an example a 3500 pound aircraft at 80 miles per hour. What about a 200,000
pound aircraft at 500 or 600 mph?
I heard an F111 crashing into a mountain. The plane weighs approximately 75,000 pounds and flies at speeds in
excess of 600 mph. The body of the plane basically stayed on the side of the mountain but the engine shaft
augered itself 150 feet through solid granite.
Response #: F.25
As noted in other responses (see Response F.15), the Environmental Assessment uses the
3,500-pound aircraft to exclude that type of aircraft from further consideration. The
Environmental Assessment considers that other aircraft could impact the Zone 4 magazines,
but does not present an analysis of the potential consequences because the total probability
of such impacts is no greater than 1.0 x 10-6/yr.
The "anecdotal" report of a F-111 crash into a mountain may be correct. But again, the
analysis did not exclude this class of event on any grounds other than the probability of
occurrence was no greater than 1.0 x 10-6/yr.
A Monte Carlo simulation for predicting earth penetration by projectiles was performed using
the PENDEPTH Code (see PENDEPTH Code Documentation Update, S.C. Wright, DNA-TR-91-
232, Defense Nuclear Agency, June 1992). PENDEPTH contains empirically based equations
derived from penetration tests (see Equations for Predicting Earth Penetration by Projectiles:
An Update, C.Y. Young, SAND88-0013, Sandia National Laboratories, July 1988). The
calculation modeled the engine as a 4,000 lbs, 18 inches by 24 inches, ogive nose shape,
normally impacting a hard rock with S parameter of 0.7 and standard deviation of 0.4. A S
number of 0.3 to 1.2 represents massive rock formation with very few cracks or fissures and
no weathering. The results of this calculation are presented below.
Impact Velocity (fps) 800 900
Mean depth of penetration (ft) 39 44
Standard deviation (ft) 16 18
95th percentile (ft) 68 78
Based on this analysis, the penetration of an F-111 engine shaft through 150 feet of solid
granite would appear to be a very unlikely, if not impossible, occurrence.
yr = year
lbs = pounds
fps = feet per second
mph = miles per hour
ft = feet
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (F.26) FOLLOWS.
Document #: 1048 Comment #: 14 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
6.2.5, Appendix E Aircraft Hazard Analysis does not present an accurate account of aircraft over Zone 4.
Wednesday, February 24, 1993, we sat right here in our home on the west side of Pantex with the Special Project
Directors of the OTA Study on Dismantlement and watched 3 C-5A's practice "touch and go" for three hours.
These aircraft fly directly over Zone 4. We have observed military aircraft of all descriptions flying over Pantex for
years. This is regular military practice. Army helicopters regularly fly over Pantex. We watch them, we know this
is happening! What hazard analysis do you propose for these aircraft?
Response #: F.26
Any aircraft over the Pantex Plant are in the inflight mode, therefore, these operations are
included in the analysis. (See Response F.21.)
No data on military helicopters were recorded in the Federal Aviation Administration flight data
examined. However, based on data that is available, helicopters, in general, have an annual
fatal accident rate (number/100,000 hours) comparable to that of general aviation (see
Analysis of Helicopter Accident Risk Exposure Near Heliports, Airports, and Unimproved Sites,
R.J. Adams, E.D. Maconkey, L.D. Dzamba, DOT/FAA/RD-9019, February 1992), and
helicopters have approximately an order of magnitude fewer flying hours. Also, accident data
indicate that helicopters do not skid, therefore the area at risk (i.e., probability of impact) is
significantly reduced. Furthermore, the subset of large helicopters that could cause significant
damage is small compared to the total. For these reasons, helicopter crashes potentially
leading to off-site consequences are qualitatively assessed as beyond extremely unlikely.

Part G

STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.1) FOLLOWS.
Document #: 1011 Comment #: 11 Date: 2/1/93
Dana O. Porter
Citizen Comments
Comment:
The environmental assessment report states that the D.O.E. "as with all Federal agencies", will be responsible for
cleanup of any contamination. Who would enforce this policy and ensure that the cleanup would be accomplished
in a timely manner? What are their cleanup contingency plans?
Response #: G.1
The policy and plans for any emergency regarding a radiological release
off-site of the Pantex Plant is founded in the Federal Response Plan
and the Federal Radiological Emergency Response Plan. Under the
Federal Radiological Emergency Response Plan, a Federal Radiological
Monitoring and Assessment Center would be established to provide an
organizational and structural focal point to coordinate all of the
Federal agencies' radiological monitoring and assessment efforts and
activities.
The Department of Energy would initially manage and operate the Federal
Radiological Monitoring and Assessment Center and provide assets such
as management and technical personnel; command and control;
communications equipment; administrative and logistical personnel and
equipment; and other equipment and personnel from elements such as
Aerial Monitoring Survey, Accident Response Group, Atmospheric Release
Advisory Capability, and others. The Federal Emergency Management
Administration would coordinate the activity of all Federal Agencies.
After the emergency response activities are completed, a lead Federal
Agency would take over the Federal Radiological Monitoring and
Assessment Center. This could be the Environmental Protection Agency
or the Department of Energy. In either case, the Department of Energy
would continue to provide technical assistance. The Federal Emergency
Management Administration would assist the lead Federal Agency in
coordinating the activities from all Federal Agencies, such as
Department of Agriculture, Department of Health and Human Services,
Department of Justice, Department of the Interior, and others.
The lead Federal Agency would work out specific response efforts with
the State. Recovery planning would be initiated at the request of the
State, but would generally not take place until after the initiating
conditions of the emergency have stabilized and immediate actions to
protect public health and safety and property have been accomplished.
The Federal government would, on request, assist the State in
developing off-site recovery plans.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.2) FOLLOWS.
Document #: 1027 Comment #: 4 Date: 3/5/93
Portia Dees
Citizen Comments
Comment:
How can both the United States and Texas governments guarantee the safety of citizens living near and in
Amarillo?
I respectfully urge you to make sure that Texas citizens are protected from proven hazards.
Response #: G.2
Although there is no way to provide for a risk free environment, the Department has dedicated
significant resources and management attention to ensure compliance with all applicable
Federal, State, and local safety standards to provide the safest environment possible. The
Department continues to place safety as a predominant priority in the operation and
management of its sites. Throughout the Environmental Assessment, the Department
examined risk resulting from interim storage of additional plutonium components at the Pantex
Plant. This issue was evaluated in terms of risk to workers, the public in the surrounding
communities, and potential for contamination of the Ogallala Aquifer. The conclusion of the
Environmental Assessment is that the only additional risk associated with implementing the
proposed action is increased radiological worker exposure. As stated in Section 6.0 of the
Environmental Assessment, the Department will carefully monitor this risk through the Pantex
Plant personnel dosimetry program and take appropriate management actions to ensure limits
are not exceeded.
The database compiled for this analysis includes a safety analysis; natural phenomena design
reviews of the facilities; natural-phenomena hazard modeling; probability analysis of aircraft
impacts, earthquakes, and tornados; external explosions; worker accidents such as a forklift
accident; and damage from missiles. For a complete list of considerations involved in the
development of the Environmental Assessment, the reader is referred to Appendix A of the
Environmental Assessment.
This analysis has been documented in the Final Safety Analysis Report, Pantex Plant Zone 4
Magazines (Issue D, April 1993) and the Los Alamos National Laboratory study "Potential
Ogallala Aquifer Impacts of Hypothetical Plutonium Dispersal Accident in Zone 4 of the Pantex
Plant" (November 1992).
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.3) FOLLOWS.
Document #: 1046 Comment #: 5 Date: 3/22/93
Dan Morales, Attorney General
State of Texas, Office of the Attorney General
Comment:
III. DOE has failed to adequately assess the risk of dismantling thousands of nuclear warheads and storing the
plutonium pits at Pantex.
DOE has failed to adequately address safety and risk issues in the draft EA. This is a fundamental deficiency
of the draft EA. ...
B. Lack of Resources to Ensure Safety.
It is not only the lack of a meaningful DOE safety policy against which to measure a safety analysis which
makes the draft EA deficient, it is also the lack of an adequate analysis of whether Pantex has the necessary
resources to undertake its new mission. [footnote 6 (Until the last two years, the mission of Pantex was to
construct and dismantle nuclear warheads. The components of dismantled weapons, including the plutonium pits,
were shipped back to the facility from which they came originally. The mission of Pantex today--to dismantle
thousands of warheads, store and manage the plutonium pits extracted therefrom, and to help maintain a nuclear
weapon stockpile a fraction of the size which existed during the Cold War--is clearly different. Such a change in
mission may in and of itself necessitate an EIS.)] As stated by the GAO:
Over the next several years, DOE must take custody of and dismantle thousands of nuclear weapons that the
Department of Defense will retire. The capability of DOE to safely dismantle so many weapons could present a
problem and tax the capabilities of DOE resources at the Pantex Plant in Texas. Storage of weapon components
at the plant, the projected workload to accomplish this work, and the transportation of weapons to the plant are
important issues that need to be examined carefully. (Emphasis added.) [footnote 7 (Statement by Victor
Rezendes, Director, Energy Issues, GAO, given at Hearing, p. 5.]
I believe the adequacy of resources issue needs to be more fully addressed.
Response #: G.3
Dismantlement of nuclear weapons has always been a part of the Pantex Plant mission. In the
past, the number of disassemblies was balanced with production requirements such that total
production and disassembly requirements were carried out in accordance with National
Security Directives, and the appropriate resources were allocated by the Department of
Energy.
Currently, disassembly activities are conducted in accordance with National Security Directives
and receive the required resources to accomplish that mission. The only difference is that, in
the past where resources would have been allocated towards production, they can now be
used towards disassembly. Thus, an increase in the total number of disassemblies per year
would not impact the Department's capability to safely accomplish the work required to meet
national arms reductions objectives. Discussion of the Department's Nuclear Safety Policy is
presented in Response G.5.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.4) FOLLOWS.
Document #: 1048 Comment #: 18 Date: 2/28/93
Doris & Phillip Smith
Citizen Comments
Comment:
What consideration is being given to the possibility of contamination to the land, the air or the Ogallala?
Response #: G.4
The Environmental Assessment addresses all potential accidents both from normal operational
and abnormal means that could have a possibility of contaminating the environment, workers,
or the public.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.5) FOLLOWS ON PAGE G-6.
Document #: 1046 Comment #: 4 Date: 3/22/93
Dan Morales, Attorney General
State of Texas, Office of the Attorney General
Comment:
III. DOE has failed to adequately assess the risk of dismantling thousands of nuclear warheads and storing the
plutonium pits at Pantex.
DOE has failed to adequately address safety and risk issues in the draft EA. This is a fundamental deficiency
of the draft EA.
A. Lack of Meaningful Safety Policy. DOE has long been criticized for its failure in developing a set of
comprehensive and satisfactory safety procedures, i.e., a "safety policy," for its nuclear weapons facilities. Without
such an overarching, meaningful safety policy against which to measure fundamental safety policy decisions at its
sites, it is difficult to understand how the DOE under your predecessor was able to adequately develop the "Safety
Analysis Report" (or "SAR") which preceded the draft EA and upon which much of the analysis of the draft EA was
based. Moreover, it is difficult to understand how, if the draft EA would have properly analyzed the complete range
of dismantlement activities at Pantex, DOE could adequately develop SARS for each of the activities associated
with the dismantlement and storage of the nuclear weapons.
As stated by the Office of Technology Assessment; [footnote 3 (OTA Assessment Proposal: Managing Nuclear
Materials from Warheads. Feb. 1, 1992: submitted to Senate Committee on Governmental Affairs.)]
In its Final Report on DOE Nuclear Facilities, the DOE Advisory Committee on Nuclear Facility Safety
["ACNFS"] noted that the job of solving the operational and safety problems at the DOE weapons complex is "far
from complete" and that some of the problems "will take into the next century" to correct. [footnote 4 ([Footnote in
original.] Advisory Committee on Nuclear Facility Safety. "Final Report on DOE Nuclear Facilities," report
prepared for the Secretary of Energy, U.S. Department of Energy, Washington, D.C., Nov. 1991. p. 11. The
ACNFS vigorously advocated the development of a department-wide safety policy which would allow different
parts of the DOE to make internally consistent decisions between possibly conflicting values such as safety and
production.)]
Although DOE did issue a new Nuclear Safety Policy in September 1991, DOE was subsequently criticized by
the ACNFS in its final report for substituting nebulous language such as "continuous improvement" for measurable
standards; for paying little attention to the largely chemical nature of the risk at some DOE facilities; and for
inadequately treating the inevitable conflict between safety and production responsibilities by simply asserting that
they are "compatible." The ACNFS's report stated that DOE needs to spell out how safety goals will be achieved,
how priorities will be set, how self-assessments will be judged, and how progress and success will be measured.
[footnote 5 (See Statement by J. Dexter Peach, Assistant Comptroller General, General Accounting Office, given
at Hearing before the Senate Committee on Governmental Affairs of Nuclear Disarmament on Department of
Energy. Feb. 25, 1992 ("Hearing"). p. 5.]
At this time, we are not confident that DOE under your predecessor provided sufficient guidance to its regional
and field offices for them to make meaningful decisions about acceptable risks, risk assessment methodology, and
procedures and policies to identify and minimize safety risks. Such decisions would, of course, be reflected in the
SAR or SARS providing the basis or bases of the EA or EAs. I believe that production of an EIS would ensure the
public that important risk and safety issues were clearly and fully analyzed.
More specifically, the draft EA does little to allay our concerns about the potential safety problems that could
arise from DOE's proposed activities. Of particular concern to us is the analyses in the draft EA of the probability
of an airplane crash with Zone 4 Pantex plant structures and the potential impacts on the Ogallala Aquifer from a
plutonium dispersal accident in Zone 4. We refer you to the comments submitted by the Texas Air Control Board
and the Texas Department of Public Safety (Division of Emergency Management). Furthermore, we refer you to
several issues raised by the City of Amarillo and the Counties of Potter and Randall regarding potential effects of
the maximum winds of a category F4 tornado, as well as the possibility of terrorist actions involving an aircraft.
In analyzing both the potential airplane crash and impacts on the Ogallala aquifer of a dispersal accident, it is
apparent that DOE relied on inaccurate assumptions and employed inappropriate methodologies. Given the
seriousness of the deficiencies in these analyses, this office cannot have any confidence in DOE's ultimate
conclusions concerning the possible environmental impacts of interim storage at the Pantex plant.
Section G G-5
Response #: G.5
Response #: G.5
The Zone 4 safety and operational envelope associated with the proposed action is well
defined and based on studies performed by professionals in accordance with sound analytical
principles. The Final Safety Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April
1993) was started in August 1991, went through several iterations, and was accepted by the
Department in December 1992 after considerable review and an independent analysis by a
Technical Safety Review Panel. Issue D, the unclassified version, was provided to the public
in April 1993.
The Environmental Assessment is based on the risk analyses provided by the Final Safety
Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993). This document
identifies accident events that might produce a risk to the public. The assessment of these
risks has been developed using techniques and procedures consistent with those used in the
commercial nuclear industry. As such, the Environmental Assessment is sufficient to bound
the environmental impacts for the National Environmental Policy Act decisions.
Department of Energy Order 5480.23, Nuclear Safety Analysis Reports was issued in 1992
specifying requirements for safety analyses involving Department of Energy nuclear facilities,
and for submittal, review, and approval of contractor plans and programs to meet these
requirements. Standards aiding implementation of this order are being issued, such as
Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order
5480.23, Nuclear Safety Analysis Report (DOE-STD-1027-92, December 1992). Additionally,
the Department has developed an action plan to strengthen Department of Energy Nuclear
Safety Standards. This action plan will:
a. Issue the Department of Energy's Nuclear Safety Policy to:
. Establish/maintain management involvement and accountability to ensure
nuclear safety requirements are met, priorities are set, and progress/success is
measured.
. Develop enhanced technical personnel competence and technical standards.
. Use established nuclear safety goals as performance benchmarks.
. Maintain nuclear safety oversight and a culture to enhance nuclear safety.
b. Enhance standards, managers/technical staff qualifications, training, and staffing.
c. Elevate organizational Department of Energy and contractors standards development
and implementation to enhance assurance of public and worker health and safety.
Development of a strong standards program has been focused on achieving measurable
performance improvement, and also on "continuous improvement" in the total quality sense.
Regarding chemical and occupational risks, the Pantex Plant management has initiated an
Occupational Safety and Health Hazard Abatement Program that establishes a safety and
health baseline audit program for each building and facility. Performance indicators are
developed and published frequently.
For additional information, refer to the general response discussions for the Ogallala Aquifer
Analysis and the Aircraft Crash Scenario Analysis, Sections E and F of this document.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.6) FOLLOWS.
Document #: 1008 Comment #: 2 Date: 2/1/93
Boyd Deaver
Texas Water Commission
Comment:
Comment: Executive Summary: Page vii fifth paragraph. - "... would not result in additional generation or
management of wastes."
Question: Is this referring to a pit as a waste?
Response #: G.6
The quoted statement does not refer to the pit. Instead, the statement refers to the fact that
the proposed action, increased interim storage of the pits, would generate no additional or
extremely insignificant amounts of waste. This waste, if generated, would be limited to
compactible, low-level wastes such as paper wipes.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
The Executive Summary was changed to reflect the comment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.7) FOLLOWS.
Document #: 1044 Comment #: 3 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
The increase in storage capacity for each Modified-Richmond magazine involves the use of a multiple stacking
configuration of the pits within the magazine. S.A.C. Magazines have not been used previously for holding pits,
and the multiple stacking arrangement has not been used previously in S.A.C. or Modified-Richmond Magazines.
These methods of storage will be extremely dangerous for both workers and the public, as the pit containers in the
vertical arrangement will be wall to wall and there is no way an inspector could inspect containers in the back, for
the plans show no walking room. Some arrangements have a very narrow middle aisle. The interior of the pit
storage igloos have an awesome, unhealthy atmosphere and the inspectors are allowed a very short time while
inspecting the pit containers.
Response #: G.7
The Final Safety Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993), from
which the Environmental Assessment draws most of its technical hazard assessments, has
shown that the Steel Arch Construction magazines are suitable for pit storage, and no
incremental risk is created when compared to their current authorized use. In addition,
extensive analysis of the concept and mechanical design of the canister pallets that hold the
pit storage containers in place in the multiple stacking configuration show that the proposal is
functional and, more importantly, safe. As discussed in the Environmental Assessment, there
are no credible scenarios whereby plutonium would be released off-site to the public
regardless of the magazine type or storage configuration used.
A concern was raised that inspections could not be safely done of containers located in the
back of the magazines that are stored in the wall to wall vertical arrangement (identified in the
Environmental Assessment as the maximum packing configuration). As stated in the
Environmental Assessment, this storage configuration was used to provide bounding
parameters for the safety and environmental analyses. The Department acknowledges that
this is not an operationally feasible configuration and would not store the pits in this
configuration. For those vertical configurations that have aisle spaces identified, the width is
adequate for inventory and inspection activities. However, the configuration that the
Department has proposed for use during interim storage is the horizontal stacked
configuration that will have much wider aisle spaces and will allow for use of the shielded
forklift to further mitigate worker exposure.
Due to concerns for maintaining minimal personnel exposure, the time spent inside the
magazines will be short. The process will utilize methods to conduct the inventory in minimum
time.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.8) FOLLOWS.
Document #: 1012 Comment #: 4 Date: 1/16/93
Margie K. Hazlett (1)
Citizen Comments
Comment:
There are approximately 423,630 people living in the twenty-seven counties surrounding Pantex Plant. These
people are proud of their heritage and bountiful crops of wheat, corn, other grains and vegetables. The many
ranchers, over 80 feed-lot operators and many packing companies for processing and shipping. (sic) These
farmers and ranchers furnish our nation with 76% of all beef consumed. These are the people who have traded in
Amarillo for many years and have kept Amarillo's economy stable for generations.
Reasons for opposing the plutonium storage that is at Pantex, and opposing any more plutonium for storage:
In the event of an accident caused by forklift or plane crash, landing or taking off from the Amarillo Air Terminal
which is much too close to a Nuclear Plant with plutonium storage.
Contamination of the Ogallala Aquifer, leaving plutonium on the water table which will be deadly for 76,000
years. If we are so unfortunate to be down-wind from an accident, we would be in the plume of plutonium
dispersal, and it would be too late for any emergency care for our people. This is a reality and is causing much
stress, plus physical and mental problems among healthy people.
Response #: G.8
The Environmental Assessment provides the analysis that concludes: 1) there would be no
impact to the Ogallala Aquifer from a hypothetical accident; 2) there is no impact other than to
workers in the immediate vicinity for a forklift accident; and 3) it is beyond extremely unlikely
(less than one in one million probability) for the occurrence of an aircraft accident that would
cause a dispersion of material.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.9) FOLLOWS.
Document #: 1022 Comment #: 8 Date: 2/11/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
Additionally, the recent recommendation (93-1, dated January 21, 1993) of the Defense Nuclear Facilities Safety
Board (DNFSB) raises the possibility that nuclear safety might be deficient in those operations involving the
disassembly of nuclear weapons. The Board specifically cited its concern of nuclear safety at Pantex.
Response #: G.9
The comment cites the Defense Nuclear Facilities Safety Board Recommendation 93-1 (dated
January 21, 1993) as a reason to be concerned about the safety of Zone 4 operations.
Defense Nuclear Facilities Safety Board Recommendations do not necessarily, as in this case,
imply a lack of safe operations. Rather, in their independent oversight capacity, Defense
Nuclear Facilities Safety Board Recommendations request the Department to focus emphasis
in a particular area of interest to ensure public health and safety. Recommendation 93-1
requested that the Department perform an order compliance and standards management
assessment to specifically address weapons related activities and to clarify how basic safety
principles are applied within Departmental Orders and Directives. This is to ensure these
principles are applied not only at facilities that produce and process fissile materials, but also
at those facilities that assemble, disassemble, and test nuclear weapons.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.10) FOLLOWS.
Document #: 1044 Comment #: 2 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
I oppose the storage plan the Department of Energy has outlined for plutonium containers in the old, obsolete and
unsafe Modified-Richmond and SAC (steel arch construction) huts or igloo type buildings.
Response #: G.10
The Final Safety Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993)
evaluates the integrity, both under normal and abnormal conditions, of the Modified-Richmond
and Steel Arch Construction magazines. The magazines are structurally sound and meet or
exceed the requirement to safely and securely stage or store nuclear weapon assemblies and
other components, including the plutonium pits. The designs of the magazines are consistent
and appropriate for the proposed activities.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.11) FOLLOWS.
Document #: 1021 Comment #: 5 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
One reason why citizen and local government interest is so crucial is that the DOE has been working for five
decades in a shroud of secrecy and a war threat mentality spending their time preparing weapons and much less
time, quite insufficient time, on the protection of the environment. When DOE reports that Pantex has been run in
a "safe and responsible fashion for 40 years", they conveniently leave out the management of the plants at Rocky
Flats in Colorado and Hanford in Washington. The DOE has a bad reputation for environmental and health
hazards. Remember, considerations other than safety will be considered, e.g. timeliness, cost and efficiency (sic) in
using space already available.
Response #: G.11
The Environmental Assessment addresses potential impacts of interim storage on the
environment and on operations at the Pantex Plant. Operations at other facilities within the
nuclear weapons complex are not the subject of this Environmental Assessment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.12) FOLLOWS.
Document #: 1040 Comment #: 4 Date: 3/9/93
Carl L. King, President
Texas Corn Growers Assn.
Comment:
When the Department of Energy moved everything from Rocky Flats, Colorado into Pantex, they stated that
Pantex would not be a permanent storage site. This concerns us greatly because the D.O.E.'s credibility has been
very bad for the people in the Panhandle area. We live less than 100 miles from this site in a very large agricultural
area. We produce all types of crops and this is also the largest cattle feeding area in the world. The environment
has a tremendous effect on not only the livestock and crops but especially the human beings that live here.
Document #: 1044 Comment #: 8 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
The storage of pit plutonium will be extremely hazardous and life threatening to the citizens of our entire Panhandle
Area, and will have a destructive impact on the Ogallala Aquifer, our environment, our agriculture and livestock
industries.
Response #: G.12
The Department recognizes the importance of agriculture to the Texas Panhandle. Agriculture
is an integral part of the environment described in the draft Environmental Assessment and,
accordingly, the Department must devote particular attention to any potential impacts to the
Ogallala Aquifer. The analysis has revealed no credible accident, either operational or external
to the facilities for interim storage, that would result in a measurable impact to the environment
and subsequently to agriculture. The only accident identified as even potentially capable of
affecting the environment was an aircraft crash into a storage magazine, an event with less
than a one in a million probability of occurrence, per year.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.13) FOLLOWS.
Document #: 1021 Comment #: 10 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
The DOE has not used EPA or OSHA standards for their work.
Response #: G.13
Department of Energy Order 5400.1 requires compliance with applicable Federal, State and
local environmental protection laws and regulations for all the Department of Energy
operations. Department of Energy Orders 5480.4 and 5483.1A require compliance with a
number of Occupational Safety and Health Administration standards. In addition, new
departmental incentives were established in December 1992 for Department of Energy
contractors to enhance Occupational Safety and Health performance and to acknowledge
excellence in a contractor's Occupational Safety and Health performance. Department of
Energy Order 5480.4 also requires that where both Department of Energy and non-
Department of Energy Environment, Safety, and Health standards are applicable and
mandatory, and there are conflicts in such standards, the Environment, Safety, and Health
standards providing greater protection shall govern.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.14) FOLLOWS.
Document #: 1022 Comment #: 3 Date: 2/11/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
The Department of Energy, in coordination with the President and the Department of Defense, should declassify
the Nuclear Stockpile Memorandum. It can no longer be argued that keeping the information from the American
public is in the national interest. The Russian government knows because of the provisions in the recent START
agreements.
Response #: G.14
This comment is outside the scope of the Environmental Assessment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.15) FOLLOWS.
Document #: 1021 Comment #: 3 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
We should know that breeder technology and Pu fuel cycle nuclear programs are not working well because of
safety and economic problems so we can anticipate a big increase in the inventory of Pu in other forms than
warheads. We should not set Texas up for this kind of storage.
Response #: G.15
The proposed action calls for increased interim storage of plutonium pits. The storage of any
other form of plutonium is outside the scope of the proposed action and would not be
undertaken without appropriate National Environmental Policy Act considerations.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.16) FOLLOWS.
Document #: 1049 Comment #: 1 Date: 3/12/93
Jerome W. Johnson
Panhandle 2000
Comment:
Texas governor Ann Richards recently forwarded to Secretary of Energy Hazel O'Leary the comments received by
the State of Texas regarding the Environmental Assessment of the proposed interim storage of plutonium at the
Pantex Plant in Amarillo, Texas. In her letter to Secretary O'Leary, Governor Richards requests an extension of
the deadline for comments to be submitted to DOE on the Environmental Assessment to March 16, 1993.
Panhandle 2000 supports the Governor's request for an extension, and would respectfully request that DOE
favorably consider granting the extension. The extension will provide State agencies and other interested parties
sufficient time to comment fully on the Environmental Assessment, and will allow all parties to feel as though they
have had their "day in court" with DOE on this issue. Granting the extension will, in our opinion, foster support for
DOE's final decision on interim storage, and will demonstrate that the cooperative relationship with the State of
Texas DOE has established will continue in the new Administration.
Response #: G.16
The extension requested in the Governor's letter was granted.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.17) FOLLOWS.
Document #: 1049 Comment #: 1 Date: 3/12/93
Jerome W. Johnson
Panhandle 2000
Comment:
We at Panhandle 2000 clearly support DOE's preliminary decision to house the interim storage function at
Pantex, and understand fully its importance in the context of the full-blown reconfiguration plans. After carefully
reviewing the comments submitted to date, it is our opinion that the debate centers not on DOE's conclusion that
no significant increase in risk will occur from the additional storage, but merely on the data and methodologies used
by DOE in its analysis. Such a debate, while important, should not serve to impede DOE's plans regarding interim
storage or final reconfiguration. pantex (sic) continues to enjoy strong support from State officials and residents,
especially those from the Texas Panhandle. We look forward to a swift resolution of the issues discussed in the
comments, and implementation of the plans for interim storage at Pantex.
I also wish to express our support for the proposed plan to site a research facility at the "plutonium site"
selected by DOE in the reconfiguration process. We are hopeful Secretary O'Leary will concur in this aspect of the
reconfiguration plan and stand ready to assist you in accomplishing this end. The heads of the University of
Texas, Texas A&M University, and Texas Tech University are formulating plans for a research consortium to assist
DOE in its research efforts, especially if Pantex is chosen as the site for this research facility.
Finally, we have noted with interest the Secretary's recent decision to review the Nonnuclear Reconfiguration
Cost Effectiveness Study. We are willing to assist DOE in the selection of the consultants charged with evaluating
this decision if appropriate, and look forward to working with your office on this issue.
Response #: G.17
The data and methodologies presented in the Environmental Assessment have been shared
with the State and public. If the National Environmental Policy Act commenting process
reveals any discrepancies in the data or methodologies used in the preparation of this
document, appropriate consideration will be given to any necessary alterations of the
Environmental Assessment or associated additional analyses.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.18) FOLLOWS.
Document #: 1016 Comment #: 1 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
I have been an observer of the "Pantex mentality" and the "Pantex work ethic" for many years. I have often seen
"damned if I care" attitude portrayed by the workers at the plant.
Document #: 1021 Comment #: 18 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
I conclude that the 40 years of "responsible and safe" work done at Pantex cannot be extrapolated to a future of
ten years of storage of Pu. I also conclude that the DOE has a long history of secrecy and willingness to take risks
which have harmed the environment and the health of workers and neighbors. So, go SLOW!
Response #: G.18
The concerns raised in these comments are understandable. During the past year, the
Department of Energy, through the Office of the Assistant Secretary for Defense Programs
and the Albuquerque Operations Office, has put more focus on the day-to-day activities at the
Pantex Plant. In addition and on its own initiative, Mason & Hanger-Silas Mason Co., Inc. (the
Pantex Plant Management and Operating contractor) has developed and has been carrying
out since November 1992 a Performance Improvement Plan aimed at achieving a level of
discipline and formality in operations that addresses the types of concerns raised in the
comments. The Department has been and will continue to monitor Mason & Hanger's
progress on their implementation of the Performance Improvement Plan.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.19) FOLLOWS.
Document #: 1042 Comment #: 11 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Issues that must be specifically discussed include: ...
c. Activities from all dismantlement activities, including optimum and maximum rates for dismantling warheads;
transporting materials off site; and storing and disposing of materials on site, including multiple handling of pits
(including moving or shifting them during storage);
d. Disclosure of effects on workers of realistic accidents from disassembly, on-site transportation, failures in
storage facilities, and exposures from "normal" operations, including increased exposures from disassembly,
materials handling, doses from more frequent and more lengthy inspections, maximally exposed worker, and
discussion of having few workers having relatively higher doses versus more workers having more minimal
exposures;
Document #: 1043 Comment #: 5 Date: 3/12/93
Mavis Belisle, Director
the Peace Farm
Comment:
The EA should include the full scope of dismantling activities at Pantex, including increased worker exposure to
radiation and other hazardous materials throughout the dismantling process, transportation on and off site, any
increase in chemicals used to clean work areas, tools and clothing, and any increased disposal of high explosive
material associated with increased dismantling. It should also include analysis of the increased handling and
short-term storage of other nuclear materials involved in the dismantling process.
Hazards are dealt with speciously in the current document, and should be dealt with fully when there is risk of
catastrophic harm, even if the likelihood itself is very low. The document should include effects of interim storage
on structures and surrounding soil overburden. It should include an assessment of any risks involved in transit
from dismantling to storage and transit accidents, and of the consequences of accidents in monitoring procedures
or in the event of corrosion, either of containers or structures themselves.
Response #: G.19
The proposed action calls for increased interim storage of plutonium pits. The comments with
respect to other activities throughout the dismantlement process (transportation, high
explosive disposition, etc.) are outside the scope of this Environmental Assessment but are
discussed in the Final Environmental Impact Statement, Pantex Plant Site (DOE/EIS-0098,
October 1983). (Further discussion is provided in Response B.1). Discussions regarding
operations associated with the proposed action with respect to the storage magazines, on-site
transit, operations during the interim storage period, worker exposure, and potential for
accidental releases during operations or interim storage are provided in the Environmental
Assessment. (Additional information is provided in Section D of this document.)
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.20) FOLLOWS.
Document #: 1044 Comment #: 1 Date: 3/15/93
Margie K. Hazlett (3)
Citizen Comments
Comment:
In this nation which supports freedom of speech, I feel that it is my democratic obligation to express my sincere
views and comments on the proposed plutonium pit storage at the Pantex Plant, which was designed solely for
assembling and disassembly of nuclear warheads, missiles and conventional bombs during World War II. prior to
now, only a few assembled bombs and disassembled parts were stored at Pantex until they could be transferred to
a proper, safe facility which stores plutonium pits underground, so the temperature of the containers will have an
environment of more constant temperature.
Response #: G.20
The magazines in Zone 4 used to house weapons components are designed for storage of
weapons as well as weapon components. Furthermore, the weapon components at issue are
themselves contained in the AL-R8 storage container. There is no evidence to indicate that
storage underground would have any environmental benefit, or that storing components
above the ground in magazines and the packaging drums currently used creates any
additional safety risk.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.21) FOLLOWS.
Document #: 1027 Comment #: 1 Date: 3/5/93
Portia Dees
Citizen Comments
Comment:
Have the following questions been adequately answered? Has worker safety in all divisions of the plant been
adequately studied? If so have the recommended safety precautions been taken? Have dangers to surrounding
farmland and agricultural workers been studied? Are there safeguards for the land, it's (sic) productive qualities
and it's (sic) agricultural value?
Response #: G.21
The Environmental Assessment addresses worker safety and the potential impacts to the
environment with regard to the proposed action. Safeguards will be maintained through
programs that keep radiation exposure to the workers at levels well below required standards.
There are no potential operational accidents in the Zone 4 operations that would produce a
danger to surrounding farmland and agricultural workers. In addition, the facilities within
Zone 4 provide for safety from external abnormal events. Worker safety throughout the plant
is under constant review, enhancement, and external oversight to ensure that the safety and
health of all the Pantex Plant workers is maintained.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.22) FOLLOWS.
Document #: 1007 Comment #: 12 Date: 2/25/93
Joseph Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 6-7, Table 6-1: Note 3 refers to Tables 7-2A and 7-2B; should be 6-2A and 6-2B.
Response #: G.22
The Department acknowledges the error in Note 3 of Table 6-1 and has corrected the
Environmental Assessment.
ENVIRONMENTAL ASSESSMENT TEXT CHANGE
Section 6, Table 6-1 was changed to reflect the comment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.23) FOLLOWS.
Document #: 1016 Comment #: 14 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
If the transportation of the Pu is too dangerous to move, how safe can the transportation of bringing the warheads
to Pantex be? Maybe it's best to just dismantle them and store the components right where they are.
Document #: 1031 Comment #: 4 Date: 3/1/93
Louise Daniel
Citizen Comments
Comment:
Transportation to and from the Pantex site, and between all facilities, is not adequately addressed.
Response #: G.23
Transportation of warheads and components within the nuclear weapons complex is outside
the scope of the Environmental Assessment. In addition, the Environmental Assessment does
not mean to imply that transportation of plutonium is dangerous. The analysis indicated that
no environmental benefit would be derived by transporting the pits off-site. In addition, the
Pantex Plant is the only facility currently capable of handling the volume of weapons requiring
dismantlement to meet National Security Initiatives.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.24) FOLLOWS.
Document #: 1019 Comment #: 8 Date: 1/20/93
W.H. O'Brien
Operation Commonsense
Comment:
While I believe most of us in the community can be convinced of the safety of the plan, there will be many outside
the community who will be hesitant to locate in this area because they are wary of the unknown or unproven.
There will be little doubt that the future growth of business in Amarillo and the surrounding area will suffer with the
public knowledge of the storage of these pits. This probably creates the need for DOE to assert an active and
effective role in planning an (sic) assisting Amarillo in maintaining the growth we have every right to expect,
notwithstanding the plutonium storage plans. Active help from DOE in directing certain highly desirable
non-nuclear government operations here or funding to assist in recruiting new businesses is appropriate (sic) and
necessary.
Response #: G.24
The Final Environment Impact Statement, Pantex Plant Site (DOE/EIS-0098, October 1983)
does discuss the economic impact of the plant and plant activities in the community.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.25) FOLLOWS.
Document #: 1018 Comment #: 2 Date: 1/20/93
Bob Bullock, Lt. Governor
State of Texas
Comment:
Since increasing the number of pits will necessitate additional handling and transportation. I would like information
about any increased risk of human error or accident resulting in localized spillage or contamination.
Response #: G.25
Based on the analyses presented in the Environmental Assessment and the Final Safety
Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993), there is no increased
risk associated with the Pantex Plant operations now planned for the 1990's compared to
those conducted in the 1980's or to the previously scheduled 1990's workload. The risks
(probability and consequences) of localized on-site spillage or contamination are proportional
not only to the number of items handled but also to the relative hazards associated with the
items handled. The risk associated with the activities involving weapons assemblies is higher
than activities involving pits because of the presence of explosives in nuclear weapons
assemblies. As pointed out in the Environmental Assessment and the Final Safety Analysis
Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993), the total plant workload is not
expected to increase in the 1990's. The increase in the number of weapons dismantled will be
offset by the reductions in new weapons assembly requirements and the other major
component of plant workload, stockpile surveillance. The stockpile surveillance program
should decrease with the reduced numbers of nuclear weapons in the total national inventory.
Accordingly, any increased pit handling and transportation at the Pantex Plant associated with
the dismantlement program would be offset by decreased handling and transportation of pits
and assembled nuclear weapons associated with new weapon production.
The Final Safety Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993)
identifies a hypothetical operational accident due to human error that could result in
measurable on-site and off-site contamination and worker exposure. This accident scenario
reflects the puncture of a container and the associated pit inside the magazine structure by a
forklift tine. The consequences of this postulated accident were calculated to be as follows:
1. 0.6 mg plutonium, as plutonium oxide, is released inside the magazine.
2. Worker dose calculated to be 0.02yCi; 50-year committed effective dose equivalent
whole body dose is 7 rem; 50-year dose to the lung is 24 rem.
3. The off-site exposure (calculated at 2.1 km from Zone 4) was estimated to be
0.47 mrem lung and 0.13 mrem whole body 50-year committed effective dose
equivalent. This is far below the current Department requirement that limits off-site
exposure to no greater than 100 mrem/yr and below the measured background levels
of 300 mrem/yr.
It should be noted that the above impacts are based on extremely conservative assumptions.
The detailed analysis and discussion supporting this are found in Chapter 7 of the Final Safety
Analysis Report, Pantex Plant Zone 4 Magazines (Issue D, April 1993). The forklift scenario is
applicable to the horizontal palletized storage configuration projected for future Zone 4
operations. However, forklift and system operation design goals planned for future operations
are expected to reduce the probability to less than 1 x 10-6 per year. The horizontal palletized
pit storage configuration will not be implemented until the National Environmental Policy Act
process is complete.
mg = milligrams
-Ci = microCurie
km = kilometer
mrem = millirem
yr = year
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.26) FOLLOWS.
Document #: 1042 Comment #: 33 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
5. Page 2-1. The draft EA states that without additional storage, disassembly would cease by as early as the
fourth quarter of 1993. Would such cessation in any way violate the terms of negotiated arms agreements? What
contingency plans exist or are being developed to avert such a cessation?
Response #: G.26
Given the current dismantlement rates, magazine capacity would likely be reached in the first
quarter of 1994.
Under present arms control agreements, thousands of nuclear warheads will be removed from
weapons systems as the United States and the successors to the Soviet Union reduce their
weapons arsenals. The key issue is the disposition of these fully-assembled warheads.
Placing many thousands of excess nuclear warheads in long-term storage is a major
international concern and is viewed by many nations as being contrary to arms control and
nonproliferation objectives. Because of the seriousness of this issue, the United States and
the Former Soviet Union have made unilateral declarations to eliminate and dismantle nuclear
warheads (e.g., Presidential Initiative to reduce United States nuclear forces,
September 27, 1991), even though dismantlement per se is not required by the negotiated
arms agreements. If the United States fails to dismantle its own weapons, it is logical to
expect that Russia would cease its dismantlement efforts, thereby seriously undermining a
major United States nonproliferation goal. Significantly, the sense of Congress has been to
insist on dismantling the nuclear warheads resulting from "ongoing and future arms reduction
negotiations and agreements" (see, for example, the National Defense Authorization Act for
Fiscal Year 1993).
At present, the only alternative to dismantling nuclear weapons and storing the plutonium
components is to store fully assembled warheads. Putting aside Presidential direction to
eliminate and dismantle the United States inventory of Theater Nuclear Weapons,
dismantlement is a sounder alternative when compared to storing fully assembled weapons.
First and foremost, dismantlement eliminates the potential for an accidental or unauthorized
detonation. Secondly, dismantlement reduces the number of highly attractive targets for
terrorists--weapons are more attractive than pits. Finally, dismantlement opens the way for
more cost effective operation for the Department of Defense.
There are many factors influencing the future use of munitions storage facilities in the
Department of Defense. An overriding consideration in the military services is realignment of
bases, and consolidation of forces into remaining installations. The Army is returning 600,000
short tons of conventional ammunition from Europe (North Atlantic Treaty Organization) and
Pacific storage sites between 1991 and 1998 and has allocated all available space in the
Continental United States (to include previous nuclear storage sites) for this project. The Air
Force and Navy are consolidating units and moving nuclear and conventional weapons to
maximize storage space, and match missions of on-base and regional forces. Many sites are
not available because the host military service has moved or plans to move a mission (or
facility) from a closed based to a retained base.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.27) FOLLOWS.
Document #: 1011 Comment #: 19 Date: 2/18/93
Dana O. Porter
Citizen Comments
Comment:
If an accident occurs at the Pantex facility, the economy of the entire area is at risk.
Document #: 1016 Comment #: 26 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
To ensure the safety of the peoples and of the environment, we request that the DOE post a bond in the amount
of at least $200,000,000. This bond would be used to help pay damages in case of contamination or destruction of
any private property, crops, livestock, as well as bodily injury or death of a person or persons outside the parimeter
(sic) of the plant. Property owners and/or their heirs must be compensated for their loses (sic).
Document #: 1017 Comment #: 22 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
I would also like for DOE to post a $200,000,000 bond to be forfeited in case of contamination or destruction of
any private property, crops, or livestock or bodily injury or death of a person or persons outside the parimeter (sic)
of the plant. This bond should pay property owners or their heirs for losses incurred.
Document #: 1043 Comment #: 4 Date: 3/12/93
Mavis Belisle, Director
the Peace Farm
Comment:
There should be a provision for compensation for any real or perceived loss in property value caused by interim
storage of a large quantity of plutonium pits and a provision for compensation for loss of value, real or perceived, to
agricultural products of the area caused by any activity associated with dismantling.
Response #: G.27
All potential accidents were evaluated within the draft Environmental Assessment. The
impacts of almost all credible potential accidents, both operational and externally initiated
events, were limited to on-site effects. Only an aircraft accident, which was found to be
beyond extremely unlikely at less than one in a million probability, would have the capability to
disperse a significant amount of nuclear material off the Pantex Plant. Even this accident was
found to be bounded by analysis previously conducted for the Final Environmental Impact
Statement, Pantex Plant Site (DOE/EIS-0098, October 1983) of an aircraft crash into a nuclear
weapon staging facility.
In the unlikely event that contamination does occur from a nuclear incident at the Pantex Plant,
the Price Anderson Act (42 United States Code 2014-2210, - 170 of the Atomic Energy Act)
creates a comprehensive system to allow compensation for third party claims.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.28) FOLLOWS.
Document #: 1003 Comment #: 1 Date: 1/12/93
Thomas A. Griffy
Univ. of Texas, Austin, Dept. of Physics
Comment:
The decision to significantly increase the amount of plutonium stored at this facility is an important one and the
environmental impacts of this decision need to be carefully assessed. Unfortunately one cannot judge from the
document provided whether or not this has been done.
The report provided creates the impression of providing a detailed analysis (often quoting results to three
significant figures!) while at the same time withholding some of the essential data on which those calculations are
based. The public is therefore presented with what appear to be detailed calculations, on the basis of which
well-informed judgements might be reached, when in fact this is not the case.
There may be valid security concerns which preclude including such information as the dimensions of the
structures in which the plutonium is stored or the amount of plutonium contained in each pit. If so, two reasonable
options are available:
1) present only the results of the analysis (i.e. trust me!) or
2) present the details of the calculation in a classified document which could be reviewed by individuals
having the appropriate clearances.
The report as it stands appears to be a full and open discussion of the problem when in fact it is not.
Document #: 1022 Comment #: 7 Date: 2/11/93
James Thomas
Hanford Education Action League (HEAL)
Comment:
p. 6-4 -- DOE has failed to provide the public with sufficient information to assess the Department's safety analysis.
DOE has refused to make available to the public the most recent version of the Pantex Safety Analysis Report.
Document #: 1042 Comment #: 14 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
Final Safety Analysis Report, Pantex Plant Zone 4 Magazines, the basic document describing the anticipated
exposures has not been made available to the public. Prior to the issuance of the final EA, or a draft EIS, the SAR
must be publicly available. Any national security aspects can be segregated in a classified appendix.
Response #: G.28
The details of the calculations summarized in the Environmental Assessment and the data on
which they are based are formed in the Final Safety Analysis Report, Pantex Plant Zone 4
Magazines (Issue D, April 1993). This document was made available to the public (in Amarillo
area Department of Energy reading rooms) and to State officials in April 1993.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.29) FOLLOWS
Document #: 1013 Comment #: 1 Date: 2/15/93
Margie K. Hazlett (2)
Citizen Comments
Comment:
I previously forwarded to you my comments concerning plutonium storage at Pantex Plant. I understood that
these comments were due in the near future. One thing that has not been available is the Texas Department of
Health's publication, Environmental Monitoring Annual Report for 1990-1991. Any review or assessment should be
postponed until such time when this report is completed, printed, distributed and ample time for reading it, so that a
knowledgeable assessment can be made. A complete assessment is of utmost importance, as it will affect the
Texas Panhandle citizens for generations.
Response #: G.29
While the issuance of the Texas Department of Health Report is not under control of the
Department of Energy, monitoring data for the Pantex Plant are available in the Annual
Environmental Report for the Pantex Plant. The latest report, for the Calendar Year 1991, was
issued in January 1993.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.30) FOLLOWS.
Document #: 1050 Comment #: 1 Date: 3/22/93
Senator Teel Bivins (Dist 31)
The Senate of the State of Texas
Comment:
This letter is to commend you and your staff on the process you have implemented regarding the Department
of Energy's Predecisional Environmental Assessment for Interim Storage of Plutonium Components at the Pantex
Nuclear Weapons Facility in Amarillo, Texas. As the Texas Panhandle's state senator, I'm sensitive to the issues
you face as you deliberate the future of our nuclear weapons complex, including Pantex. My constituents have the
most to gain economically and lose environmentally from Pantex. To proceed with any DOE plans for Pantex it's
important for citizens of that area, and the officials who represent them, to have a high degree of confidence that
DOE activities will be conducted in a safe, environmentally sound fashion.
In the past, the public has been unable to have this kind of trust in DOE activities. I'm delighted to see the new
administration is operating in an open, cooperative manner. This new openness is reflected in the approach your
department took regarding the interim plutonium storage issue at Pantex. You invited comments not only from
state agencies but also from other interested parties. To give everyone an opportunity to comment fully on the
issue, you extended the deadline for comments not once, but twice, when requested by the state. The January
1993 briefing by top DOE staff for state officials and other parties on the interim storage issue was very informative
and exhibited the new constructive dialogue encouraged by the department which is welcomed by the state.
Finally, DOE's offer to respond to all comments before proceeding with the plans, although the department is not
required to do so, build on the improved relationship between DOE and the state.
I respectfully encourage you to continue this healthy dialogue after DOE responds to the state's comments on
the interim storage issue. Agreeing to sit down and discuss differences, with the goal of resolving them, will ensure
that the interests of both DOE and the state are protected. Further, this dialogue would serve to resolve
outstanding issues in an expeditious manner and avoid a long, drawn-out "paper exchange." Although this
dialogue may conclude with differences of opinion on some small issues, I'm confident that an accord can be
achieved on the "big picture" items which will allow DOE to proceed after taking the comments into account. I
would appreciate being involved in these meetings and will pledge my assistance and support to the process.
Response #: G.30
The Department of Energy is aware of the role that both citizens and officials of the State of
Texas have in safe and environmentally responsible conduct of operations at the Pantex Plant.
The Department of Energy is committed to continuing the dialogue established with the State
and is establishing a citizen advisory board for the Pantex Plant.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.31) FOLLOWS.
Document #: 1048 Comment #: 25 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
8.0 All issues should have been discussed openly with federal, state, and local agencies with local citizen input. To
only have kept the state agencies informed of the development of the document undermines the integrity of the
work of the state agencies.
Response #: G.31
The National Environmental Policy Act process followed in developing the draft Environmental
Assessment for Interim Storage of Plutonium Components at the Pantex Plant has taken into
account input from Federal, State and local agencies. In addition, comments from local
citizens and other interested parties and groups have been reviewed and responded to in this
document. Forty-six letters with a total of 423 comments were addressed.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.32) FOLLOWS.
Document #: 1007 Comment #: 1 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 3-1, Lines 29-32: It is noted that assembled weapons and components will continue to be staged in a
number of the SAC magazines. The proposed action does little to diminish the potential threat to public health and
safety and the environment from these items.
Document #: 1007 Comment #: 11 Date: 2/25/93
Joseph A. Martillotti
Texas Dept. of Health, Bureau of Radiation Control
Comment:
Page 6-5, Paragraph 6.2.5: The Aircraft Hazard Analysis is purported to be conservative in nature, but much
effort has been expended to reduce the calculated probability of an occurrence from unlikely to extremely unlikely,
The stated purpose of this document was to determine environmental impacts, if any, from storing more pits in an
igloo than before. At issue is the fact that the maximum amount of plutonium permitted per Modified-Richmond
magazine has not increased, while the maximum number of igloos containing only plutonium pits will increase. The
amount of plutonium proposed for storage in the SAC magazines is consistent with the previous limit on the
Modified-Richmond magazines. There is also a corresponding decrease in the number of igloos available to stage
weapon assemblies and other nuclear explosive components, which remain the most serious threat from Zone 4
activities. These igloos, in addition to some specific Zone 12 facilities, continue to present the most serious
potential off-site consequences if involved in an initiating event.
Response #: G.32
The Department of Energy continues to believe that the low risks associated with weapon
staging are acceptable and bounded by current analyses, specifically the Final Environmental
Impact Statement, Pantex Plant Site (DOE/EIS-0098, October 1983). The aircraft hazard
analysis is considered conservative in that it uses the air traffic data from the earlier analyses,
even though the available information indicates that the total air traffic in the vicinity has
declined. Some changes were made in assumptions (e.g., reduction of crash rates and skid
areas, dropping of single-engine aircraft) to reflect the current thinking in regard to such
modeling.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.33) FOLLOWS.
Document #: 1012 Comment #: 6 Date: 1/16/93
Margie K. Hazlett (1)
Citizen Comments
Comment:
The reason which stands out above the others listed is that we would prefer to live the only life God gave us in a
peaceful, healthful atmosphere. The plutonium storage in the Panhandle of Texas will envolve (sic) too much - we
saw some of the people who have terrible diseases because of plutonium and different types of cancers. We
want to protect this generation and healthy generations to come.
Document #: 1015 Comment #: 1 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Pg. 1-1: The statement that PX has conducted its activities in a safe and responsible manner belies the facts of
elevated cancer rates of downwinders and retired PX personnel, ...
Document #: 1035 Comment #: 9 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
There are several severe environmental polluters that I believe are causing extremely high percentages of
cancer and immune system diseases.
#1. Hoechst Celanese - Pampa Texas
a. has polluted the air & water for 40 years
b. even our creek in our parks in Pampa
c. 4 million pounds of benzene dumped on us every year; plus many other chemicals (toxic)
#2. Phillips Petroleum Plant - Borger, Texas (I have no statistics on this plant, but I assume it is as bad or worse
than H. Celanese in Pampa (sic) -> Could very well be contaminating Lake Meredith (the Panhandle's water
supply).
Document #: 1035 Comment #: 10 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
#3 Pantex - Amarillo
a. Pantex has kept important environmental facts from the public.
Response #: G.33
Regarding health effects attributable to the Pantex Plant operations, a Texas Department of
Health letter dated April 7, 1992, to Mrs. Jeri Osborne of Panhandle, Texas, states: "Based on
cancer incidence data (for the years 1980-1990), no significant excess of cancer exists in the
southwest quadrant of Carson County. This finding parallels a previous analysis, which
showed the total cancer mortality of Carson County to be lower than what would be expected
based on the cancer mortality experience of the entire state of Texas. ... Finally, the chances
of a person developing cancer as a result of exposure to an environmental contaminant are
slight. ..." This letter substantiates earlier data presented in the Final Environmental Impact
Statement, Pantex Plant Site (DOE/EIS-0098, October 1983) that indicate no measurable
increase in cancer mortality rates due to Pantex Plant operations. Therefore, it appears that
Pantex Plant operations impose no measurable addition to cancer mortality in the Panhandle
area.
The Department of Energy cannot comment regarding the health affects from the activities and
operations of Hoechst Celanese and the Phillips Petroleum Plant cited in Ms. Son's letter.
No environmental facts have been kept from the public. Documents such as the Site Annual
Environmental Report are made available to the public and open meetings such as the
Environmental Monitoring Council are held regularly.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.34) FOLLOWS.
Document #: 1036 Comment #: 1 Date: 3/1/93
Arjun Makhijani, Ph.D.
Institute for Energy & Environmental Research
Comment:
I. General Comments (bolded) - The stated purpose of the proposed action in the EA "is to provide interim
storage of pits removed from nuclear weapons in response to the President's nuclear weapons reduction initiative."
(p. 2-1) The proposed action would expand the capacity for storage of pits from the current 6,800 (p. 3-1) to
20,000 or more pits. The EA claims that there is considerable urgency in implementing this expansion because the
DOE may have to cease disassembly activities "as early as the fourth quarter of 1993" if the proposed action is not
implemented (p. 2-1).
The EA does not provide the information required to independently verify the claim of urgency or the overall
goal for expansion of capacity that DOE seeks under the proposed action. Two items are at issue:
First, the EA does not provide any figure for the actual number of pits in storage as of December 1992. There
is only a chart for "projected" storage capacity requirements (p. 2-2) that starts in the fourth quarter of 1992 in the
range of about 3,500 to about 3,800 pits. The EA does not state whether this is an actual figure or was a
projection for 1992 based on an assumed disassembly rate of 2,000 weapons per year. The projected date when
current storage capacity may run out must be based on actual figures for pits currently in storage. Second,
information must also be provided on how the disassembly figure of 2,000 weapons per year was arrived at, and
how it might vary, in light of past rates of dismantlement and assembly combined.
Document #: 1045 Comment #: 3 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
2) The draft EA does not present realistic time frames for when current storage capacity will be reached, yet
timing is portrayed as urgent.
a) The draft EA could, but does not, present sufficient information about the number of pits already cumulated
at Pantex so that an accurate starting inventory can be established. Information from other DOE sources (see
attached document 1: U.S. DOE Pantex Plant Nuclear Weapons Disassembly History FT 1980 thru FY 1992)
indicate the actual dismantlement resulting in pits potentially remaining at Pantex are: FY 1990 - 1151; FY 1991 -
1595; FY 1992 - 1303.
b) There is insufficient information provided in the draft EA to substantiate any of the statements about when
capacity would be reached, such as, "Capacity, at currently projected dismantlement schedules could be reached
as early as 4th calendar quarter of 1993." (p. 3-1)
Since 1990, the highest annual rate of disassembly, for either retirement or evaluation, appears never to have
exceeded 1757. (see attached document 1) Historical records seem to indicate the DOE's goal of maintaining a
disassembly rate of 2000 weapons per year may be overly ambitious.
Clearly the actual rate of dismantlement is variable, and should be, since different weapons systems have
different requirements, etc. More importantly, the primary consideration of the Plant must be worker and
operational safety.
In order to establish a better basis for planning, free of exaggerated time constraints, the establishment of both
a clear starting point and an achievable rate of dismantlement is necessary, and otters no threat to national
security. Indeed, it enhances safety by supporting informed decision-making which is not driven unnecessarily by
a false sense of urgency.
Response #: G.34
The Environmental Assessment states that the proposed action will result in "...An increase in
the number of pits stored, up to (emphasis added) 20,000;" The projected capacity
requirement is based on the assumed disassembly rate of 2,000 weapons per year. This rate
of disassembly is required to achieve nuclear weapon reduction goals established in
international treaties and agreements. More information on the purpose and need for the
Environmental Assessment can be found in Response B.1 (National Environmental Policy Act
Issues) and Response C.1 (Alternatives).
Figure 2.1 of the Environmental Assessment presents the actual data for the starting pit
inventory at the Pantex Plant. As of November 1, 1993, the total number of pits stored at the
Pantex Plant is approximately 5,200. Based on this figure, it is expected that storage capacity
will likely be reached in the first quarter of 1994.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.35) FOLLOWS.
Document #: 1045 Comment #: 9 Date: 3/22/93
Beverly Gattis
Serious Texans Against Nuclear Dumping (STAND)
Comment:
8) As a public process (made possible at this point only by the efforts of the state of Texas) which will produce a
public document, it is important that there is some definition of terms.
a) Both NEPA and DOE use certain words and phrases with a particular intent. For example, an
"environmental" impact as defined by NEPA is very broad, encompassing far more than the usual implication of the
word. For the DOE, there are numerous terms such as "DOE orders" or "safeguards and security" which have a
consistent definition for DOE which should be clarified for the general reader.
The draft EA offers listings of Acronyms (p. iv) and Abbreviations - Units and Measures (p. vi). To enhance
the public understanding of what is actually being said, a listing and clarification of terminology should be added as
well.
b) In addition, the EA must be careful not to confuse issues by using a similar set of words which could give one
impression but which could just as easily refer to something else.
For instance, "the DOE Orders and procedures for ensuring safe and secure storage of the pits would
continue to be followed rigorously." (p. 3-1) One standard term for DOE is "safeguards and security," referring to
the control of the material rather than safety in a health sense. "Safe and secure" leaves a reader in some doubt
as to exactly what the DOE is "rigorously" committed to by that statement.
Response #: G.35
The words "safe and secure" were used in the broader sense than the words "safeguards and
security," which has a more limited application. The Safeguards and Security program for the
Pantex Plant is specifically designed to prevent loss, theft, or diversion of materials; to protect
classified information; and to protect against damage theft, loss, or other harm to government
property. The safeguards and security function includes: physical security, material control
and accountability, and emergency preparedness. While Department of Energy Orders which
require implementation of the Safeguards and Security program will be rigorously followed,
there are other equally stringent orders within the Department which call out Occupational
Safety and Health and Environmental protection requirements. These requirements are also
rigorously followed.
The Department's definition of terms throughout the Environmental Assessment is consistent
with that of Federal, State and local laws. The Final Environmental Impact Statement, Pantex
Plant Site (DOE/EIS-0098, October 1983) contains a full glossary of terms as does the
Environmental Assessment.
The Department of Energy Orders are self-implemented mandatory guidelines.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.36) FOLLOWS.
Document #: 1032 Comment #: 9 Date: 2/19/93
Betty E. Barnard
Citizen Comments
Comment:
Though this is a letter drafted by STAND of which I am a member, it expresses my concerns as you may know,
worker contract negotiations are in progress (health issues & insurance as main concern). There is much at stake,
and much could go wrong.
Response #: G.36
While this issue is outside the scope of the National Environmental Policy Act Environmental
Assessment process, it should be noted that the work force labor negotiations referred to in
the comment between Mason & Hanger (the Management and Operating contractor of the
Pantex Plant) and the Metal Trades Council, Amarillo Chapter are complete.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.37) FOLLOWS ON PAGE G-42
Document #: 1009 Comment #: 1 Date: 2/22/93
Tom Millwee, Chief
Texas Dept. of Public Safety, Div. of Emergency Management,
Comment:
While the statistical probabilities may conclude that there is no increased risk to the local population as a direct
result of the increased storage of plutonium pits, the public perception of increased risk must be considered in
addressing this issue.
Pantex has not had a public information program in effect to educate and prepare the population on the
hazards posed by a radiological release. DOE is now preparing to tell the local population that an increase in the
number of plutonium pits stored in zone 4 igloos will pose no additional risk to the local populace. Unless a public
information program is in place, the result may be public hysteria. The increased level of plutonium storage must
be accompanied by a comprehensive public information program that will withstand public and political scrutiny.
We remain unconvinced that the public will believe that an increased storage level of plutonium pits will not cause
additional risk.
Document #: 1019 Comment #: 7 Date: 1/20/93
W.H. O'Brien
Operation Commonsense
Comment:
We want first and foremost to assure that the risks to the community are acceptable. The dangers that have been
brought to many communities by the weapons plants have been clearly established, and it is only reasonable that
we consider that history in our own assessment of this operation. The community's confidence in assurances of
safety can only be confirmed with independent monitoring and the willing acceptance by DOE of applicable laws of
our land. We must all be comfortable that a supervisory structure is in place that will provide technical oversight as
well as community liason (sic). A clear delineation of this need will require a cooperative effort involving DOE, the
State, and our community.
Document #: 1021 Comment #: 2 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
We are planning to store 84,000 pounds of a deadly poison which will remain deadly for thousands of years. While
Pu is stored at Pantex, it should be very visible and under close scrutiny by Federal Government officials, Texas
officials, and local Amarillo and neighboring county officials as well as concerned citizens. Personally, I would hope
the Governor would really stress citizen involvement.
Document #: 1021 Comment #: 12 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
This same DOE has supported legislation to relax environmental protection laws governing the removal of toxic
wastes. Change the words and the problem goes away. The same DOE has stifled research and whistle-blowing
among employees. Secretary Watkins has said he "never got his arms around" the problems at DOE. DOE now
plans for some oversight by outside organizations, the Department of Health and Human Services and the
Department of Health for the State of Texas, for example, which sounds great but the DOE is not accustomed to
outside scrutiny so this should be spelled out very carefully. In their text it is not spelled out at all.
Section G G-41
Document #: 1025 Comment #: 1 Date: 2/16/93
William and Mary Klingensmith
Citizen Comments
Comment:
As residents of Amarillo, Texas, we are deeply concerned about the activities at the DOE Pantex Plant near our
city. To have bombs assembled there was at best very worrisome but to have a massive disassembly of these
bombs and the storage of the highly toxic plutonium plus other fissionable material seems intolerable. We are most
anxious that the activities at Pantex be examined and monitored and that the storage of plutonium be especially
studied. Proper environment studies are crucial and the plant should be open to outside expert inspection.
Does the Panhandle want the title of Plutonium Storage for the western world? Just how much is known about
the storage, how long can it be stored here and why can't this whole subject be opened to public scrutiny?
Response #: G.37
There are numerous agencies which provide technical oversight of Department operations.
Internally, several offices such as the Office of Environment, Safety and Health, Office of
Security Affairs, Inspector General, and others provide assessment of the safety operations to
the Secretary independent of Defense Programs.
External to the Department, several agencies routinely evaluate safety of the Pantex Plant such
as the Defense Nuclear Facilities Safety Board and the General Accounting Office, which both
report to Congress. The Defense Nuclear Facilities Safety Board maintains a staff member at
the Pantex Plant during normal working hours.
The State of Texas has several agencies (including the Texas Water Commission, the Texas
Department of Health, Bureau of Radiation Control, and the Texas Air Control Board) that
routinely access and observe operations at the Pantex Plant and have access to Department
management and documents.
To include the local governments and citizens, an extensive outreach program has been
instituted at the Pantex Plant. Examples of programs that provide public access to information
and the ability to express concerns are:
. General plant briefings are regularly provided to elected officials, civic, fraternal, and
educational groups throughout the region. Specially organized briefings and tours for
elected and/or appointed officials are conducted as frequently as needs arise. General
public tours and plant briefings are conducted twice daily each Wednesday. The
Department of Energy, Amarillo Area Office and plant management hold open dialogue
public meetings four times per year.
. Two Department of Energy Public Reading Rooms are in full operation with a goal of
making all unclassified documents pertaining to the Pantex Plant available to the
public.
. Environmental Restoration/Waste Management Five-Year Plan public meetings are
conducted twice yearly, and the Pantex Plant Environmental Restoration activity update
public meetings are held at least four times a year. An Environmental Restoration
Public Information Coordinating Group, composed of eleven area citizens with a broad
spectrum of backgrounds, was organized to serve as an information link between the
Pantex Plant and the public.
. A Citizens' Advisory Group is in the process of being developed for the Pantex Plant.
This group will be funded by the Department of Energy and will focus on
environmental restoration and waste management, environmental monitoring, and
public/worker safety and health issues.
The motto, "Safety First," is integral to operations at the Pantex Plant. Secretarial safety policy
emphasizes this as a guiding principle. Numerous oversight elements, including those
responsible for programmatic operations at the Pantex Plant, are committed to ensure that
safety to the environment, worker, and public is maintained.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.38) FOLLOWS.
Document #: 1010 Comment #: 9 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
These comments are submitted with the intent to obtain additional information to enhance our planning efforts. I
see no reason why DOE should not be allowed to increase the amount of plutonium at the plant as long as:
The data used to prepare the assessment is validated by the State agencies that are part of AIP.
DOE continues to include local government in all phases of emergency planning.
State and Local agency inspections continue.
Response #: G.38
The Department of Energy expects to continue its participation in the Agreement-in-Principle.
Furthermore, the Department will continue to involve and cooperate with State and local
agencies in emergency planning and inspection activities.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.39) FOLLOWS.
Document #: 1035 Comment #: 12 Date: 2/19/93
Karen Son
Citizen Comments
Comment:
#3 Pantex - Amarillo...
c. stores plutonium which may be emitting harmful or deadly radiation into our air and water - which may also
be contaminating the $5 billion of agricultural produce which affects the whole nation.
Document #: 1048 Comment #: 26 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
DOE says they are committed to the environment, safety and health of workers and surrounding communities!
Why push to dismantle warheads and expose the population to health and death risks?
Response #: G.39
The Environmental Assessment evaluates the proposed action of interim storage of plutonium
pits and addresses protection of the environment. The Department does not expect any
releases that would contaminate the agricultural products or water resources of the area.
However, if such an incident were to occur, emergency management plans are in place to
minimize the effects on the public and environment.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.40) FOLLOWS.
Document #: 1036 Comment #: 4 Date: 3/1/93
Arjun Makhijani, Ph.D.
Institute for Energy & Environmental Research
Comment:
The EA also makes the inappropriate comment that plutonium pits from warheads that are no longer needed in the
U.S. arsenal are "valuable national assets." (p. 2-1) Such a conclusion prejudges a possible decision in the
Reconfiguration of PEIS that the surplus plutonium is a waste, due to the security and environmental threats it
poses. Due consideration must be given to the proliferation implications of any decision to treat it as an asset in
the United States, since that would result in reinforcing corresponding decisions in the former Soviet Union, other
nuclear weapons powers, and aspiring nuclear weapons powers.
Document #: 1041 Comment #: 6 Date: 3/12/93
Beverly Gattis
Military Production Network
Comment:
4) The predecisional EA inappropriately refers to plutonium components from retired warheads as "valuable
national assets." (p. 2-1)
The decision whether to treat plutonium from retired warheads as an asset or a waste is critical to plans for its
long-term storage and disposition. This decision should be arrived at through an open process with ample
opportunity for meaningful public participation. DOE should not -- in this EA or any other document -- presuppose
this important national policy decision.
Document #: 1048 Comment #: 7 Date: 2/28/93
Doris & Phillip Smith
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
Justification needs to be made as to why they are referred to as national assets and not liabilities? To presume
"assets" and not to address liabilities is in appropriate (sic).
Response #: G.40
Pits are described in the Environmental Assessment as "valuable national assets" based on
their expense of production. The Department is continuing to study the question of the future
of plutonium and other special nuclear material. Other groups outside of the Department of
Energy, such as the Office of Technology Assessment and the National Academy of Sciences,
are also studying the issues surrounding the future of plutonium reserves. Until the results of
these studies are thoroughly reviewed and understood, the description of pits as "valuable
national assets" is a fair characterization. This current description in no way prejudices any
future characterization based on updated analyses.
In regard to the disposition of plutonium, on September 27, 1993, the President established an
interagency task force to determine the disposition of plutonium surplus to national defense
requirements. This task is being led by the National Security Council and the Office of
Science and Technology Policy.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.41) FOLLOWS.
Document #: 1014 Comment #: 1 Date: 1/15/93
Sam Day, Director
Nukewatch
Comment:
Paradoxically, Nukewatch's goal of educating the public about nuclear dangers would best be served by the
Department of Energys proposal to store 20,000 or more nuclear weapon plutonium pits at Pantex. The
concentration of so much destructive and deadly material in one place would facilitate our job, especially in the
Amarillo area, of educating the public about the local impact of nuclear weapons production. Such an outcome
would help us in our work of making Amarillans (sic) and other Texans more aware of the use to which their soil is
being put in the manufacture and storage of weapons of mass destruction.
We believe, however, that6 (sic) the public interest would be better served by taking an alternative step more
likely to lead from storage to destruction of plutonium residues of the nuclear weapons now earmarked for
disassembly. Rather than store the plutonium pits at Pantex, where they could readily be used later for new
nuclear weapons (sic) or for plutonium-based breeder reactors, it would be better to store them at the Savannah
River Plant, where facilities now exist for vitrification of the plutonium in a way which makes recovery of the
plutonium virtually impossible.
We strongly suggest as part of this proposal that plutonium storage capacity not be increased anywhere and
that plutonium reprocessing/vitrification capacity be expeditiously enhanced at the Savannah River Plant or some
other appropriate site so that non-retrievable disposal of the plutonium can keep pace with retirement of the
weapons. Thus, we can "lock in" the results of current and future SALT agreements and nuclear disarmament
accords.
When ratified by the U.S. Senate, SALT and other nuclear weapons reduction treaties will constitute a clear
mandate to destroy nuclear weapons, not to hold their key elements--the plutonium pits--in indefinite "interim
storage" for possible later reassembly into nuclear weapons. Any storage proposal which fails to provide for
simultaneous non-retrievable disposal appears to border on negation of the START agreements.
Document #: 1021 Comment #: 16 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
Let me repeat that research on the disposal and security of Pu and Pu pits should have been under way for
decades. This problem is chronic and is not going to go away. Therefore, we should slow the DOE down and
demand more thorough preparations and research before doing anything. I know that this will leave us with bombs
sitting in their silos but, if the State of Texas can make these silos public and keep the Pu pits in the minds of alert
citizens, we will have performed a real service for all the world. Keep in mind that storing these pits at Pantex
permits the Government to restart making bombs again before anyone had time to wonder why trucks were
carrying Pu pits back to Texas again.
Response #: G.41
This comment is outside the scope of this Environmental Assessment. The Department is
continuing to study the question of the future of plutonium and other special nuclear material,
as discussed in Response #: G.40.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.42) FOLLOWS ON PAGE G-49.
Document #: 1010 Comment #: 8 Date: 2/8/93
Walt Kelley
City of Amarillo, Emergency Management
Comment:
(At a minimum, the following areas should be covered in the study or unclassified supporting documents:)
Possibility of terrorist of (sic) actions involving an aircraft.
Document #: 1015 Comment #: 19 Date: 2/20/93
Addis Charless, Jr.
Panhandle Area Neighbors and Landowners (PANAL)
Comment:
If so large a number of pits is to be stored at PX, does that fact not make PX a prime target for terrorists bent on
having Pu at any cost?
Document #: 1016 Comment #: 21 Date: 2/16/93
Jeri Osborne
Citizen Comments
Comment:
Appendix A-1 does not mention a possible terrorist or high priority military attact (sic). With the storage of Pu,
manufacturing of HE, and capability of assembling weapons, would not Pantex be a prime site for these events?
Document #: 1017 Comment #: 10 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
Missiles - How about guided missiles from enemy forces or from terrorists? It appears to me that 20,000 pits
would make the storage area a very high priority target.
Document #: 1017 Comment #: 14 Date: 2/15/93
Jim Osborne
Citizen Comments
Comment:
C 1.2 - SAC Magazines - What if a terrorist dropped an explosive such as a grenade down the ventilation pipe?
Document #: 1019 Comment #: 5 Date: 1/20/93
W.H. O'Brien
Operation Commonsense
Comment:
The risk assessment analysis also appears to have overlooked the most likely danger, that of an attack on the
arsenal by an enemy or terrorist.
Document #: 1021 Comment #: 7 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
DOE writes that radiation exposure of workers will be controlled as currently done with procedures and monitoring
to insure DOE present standards are maintained so therefore no adverse health effects among workers should be
expected. In their search for the possibility of accidents, they mention aircraft crashes, forklift accidents,
earthquakes, tornadoes and missiles, all of which are listed as requiring quantitative analysis. There is no mention
of a psychotic terrorist or a thief wishing to sell Pu to the Japanese.
Section G G-48
Document #: 1021 Comment #: 15 Date: 1/25/93
Lawrence D. Egbert, MD
Physicians For Social Responsibility
Comment:
There is no mention of security, yet Pantex has had security problems in the past. What are their plans to prevent
a terrorist attack? Or a thief who wishes to steal a Pu pit? I am sure the black market would have good prices for
Pu pits.
Document #: 1024 Comment #: 3 Date: 3/10/93
Jay R. Roselius, County Judge
Carson County
Comment:
... request that authorities from these different agencies be assembled together in their area of expertise and
address and formulate the best possible response to the following areas which seem to me to be the areas of most
concern when considering all of the various comments...
3. The question of sabotage/terrorist attack on a bunker/magazine or other strategic location. This could cause
a release that would make an environmental impact.
Response #: G.42
The Department of Energy recognizes the terrorist threat and has planned accordingly. It is
Departmental policy not to address this issue in Environmental Assessments so that security
of the plant is not compromised.
STAKEHOLDER COMMENTS TO ENVIRONMENTAL ASSESSMENT. DEPARTMENT OF
ENERGY RESPONSE (G.43) FOLLOWS.
Document #: 1042 Comment #: 42 Date: 3/12/93
Beverly Gattis
Save Texas Agriculture and Resources (STAR)
Comment:
9. Pages 3-3 to 3-8. All the figures are deficient for several reasons:
- no scale is given
- the containers are not specified (AL-R8 or others)
- the figures are inconsistent with the narrative. For example, Figure 3-6 shows the bounding single-layer
configuration in the SAC magazines is 420 containers, whereas page 3-1, footnote 2 says maximum packed
capacity is 406 pits. Figure 3.2 shows 336 pits as the "operationally preferred" configuration for
Modified-Richmond magazines, whereas page 3-1 says that storage would increase from existing 378 pits to
440 pits. In contrast Figure 3.5 shows 378 pits as the "bounding" configuration.
Clearly, either the figures are wrong, the text is wrong, or both are wrong. In any case, the discrepancies
must be resolved and explained.
Response #: G.43
Information on figure scales can be found in the Final Safety Analysis Report, Pantex Plant
Zone 4 Magazines (Issue D, April 1993). The figures in the referenced section of the
Environmental Assessment are included as a visual aid and are not engineering specifications.
Section 3.0 of the Environmental Assessment states that "The majority of the pits in Zone 4 will
continue to be packaged in AL-R8 containers ... but other approved containers such as
Type B containers may be used." This statement specifies the types of container to be used
in the proposed action and therefore it did not appear necessary to specify it in the referenced
figures.
On the third point, Figure 3.6 of the Environmental Assessment shows the bounding single
layer configuration of 406 containers, which is consistent with the maximum packed capacity
mentioned in the second footnote of Section 3.0. Figure 3.2 shows 336 pits as the
operationally preferred configuration for vertical single-layer storage; whereas Section 3.0
explains that the maximum or bounding limits would increase from 378 pits (bounding vertical
single-layer storage configuration) to 440 in the horizontal palletized multiple stacking
configuration. Table G-1 clarifies these issues.
While fewer pits are typically stored in the magazines than the stated bounding vertical single-
layer configuration, these values bound the Final Safety Analysis Report, Pantex Plant Zone 4
Magazines (Issue D, April 1993) and the Environmental Assessment and therefore are a valid
depiction of the maximum changes expected as a result of the proposed action. The
Operationally Preferred vertical single-layer configuration is provided to illustrate typical
configurations used in Zone 4. (For additional information on storage configurations, refer to
Response D.23.)
Table (Page G-51 Table G.1 - Pit Storage Capacity...)

Part H

SECTION H - SUMMARY
Comments from the Defense Nuclear Facilities Safety Board
On October 1, 1993, the Board stated concerns regarding the lack of
uniform approach within the Department of Energy in analyzing aircraft
crash probabilities. In a letter to the Department, specific issues
were cited with the Zone 4 aircraft crash analysis, including accident
probabilities, aircraft impact analytical methodology, consequence
analysis, and documentation adequacy. Department of Energy
representatives met with the Board staff to discuss these concerns on
two occasions. On October 26, 1993, the Department prepared a formal
response to the Board letter of October 1, 1993. This response
contains a summary of the meetings information presented to support the
Zone 4 aircraft crash analysis. In addition, a position paper was
prepared to address the consequence of plutonium dispersal from a fire
resulting from an aircraft crash into a Zone 4 magazine. On October
29, 1993, the Board concluded that the results shown in the
Environmental Assessment Report and the Final Safety Analysis Report
for the Pantex Plant Zone 4 do meet the Nuclear Regulatory Commission
assessment criteria for evaluating aircraft hazards. The Department
must yet resolve issues related to basic data, aircraft impact
analytical methodology, analysis of consequences, and analysis
documentation in connection with documentation of the safety analysis
for Zone 4.
This section contains the studies and correspondence relating to the
Board reviews, in chronological order to date.
John T. Conway, Chairman DEFENSE NUCLEAR FACILITIES
A.J. Eggenberger, Vice Chairman SAFETY BOARD
John W. Crawford,Jr.
Joseph J. DiNunno 625 Indiana Avenue, NW, Suite 700, Washington, D.C. 20004
Herbert John Cecil Kouta (202) 208-6400
October 1, 1993
The Honorable Victor H. Reis
Assistant Secretary for
Defense Programs
U.S. Department of Energy
Washington, DC 20585
Dear Dr. Reis:
The Defense Nuclear Facilities Safety Board, its staff and outside exerts have been
reviewing the analyses done to assess aircraft crash accidents for certain DOE Defense
Nuclear Facilities. This review has included aircraft crash analyses for the DP-West Facility
at the Los Alamos National Laboratory, the Rocky Flats Plant, and Zone 4 at the Pantex
Plant. Our review and evaluation indicate that the methodologies employed in these studies
are not consistent and vary significantly. Further, the methodologies are not consistent with
accepted commercial nuclear industry practices regarding aircraft crash risks. Areas of
inconsistencies noted by the Board staff include assessment of the probability of an aircraft
crash, aircraft impact analytical methodology, and analysis of consequences of the crash.
The Board believes that such differences in approach to aircraft crash analyses at DOE
defense nuclear facilities result from lack of uniform guidance by DOE. Since such guidance
is being developed for evaluations of other external hazards, such as seismic and tornado
events, the Board believes that the concerns noted above would be addressed if technically
appropriate guidance for conducting analyses of aircraft crash accidents were developed by
the Department.
The Board is particularly concerned with the accident analyses covering possible aircraft
crashes at the Pantex Zone 4 which we have recently reviewed. Our review included the
Environmental Assessment Report, the Final Safety Analysis Report (FSAR) and its
supporting classified document, and the August 3, 1993 Sandia National Laboratory Report.
Additionally, the Board's staff has met with DOE and its contractors on several occasions to
discuss details of the accident analyses for Pantex Zone 4. As a result of this review, the
Board considers that specific issues exist related to the probability of a crash, the impact
analytical methodology, the consequence analysis, and the adequacy of analyses
documentation. These issues are discussed in the enclosure to this letter. The Board is
aware of DOE's plan for interim storage of increasing amounts of plutonium from
disassembled weapons in Modified-Richmond and Steel Arch Construction magazines in
Zone 4 at Pantex. Such actions warrant that proper analyses of the aircraft crash hazard be
performed and the issues be resolved expeditiously.
Section H H-2
The Honorable Vicior Reis Page 2
Pursuant to 42 U.S. C. $ 2286B(d), the Board requests that DOE provide the following
reports:
. A report comparing the various approaches used to assess aircraft crash
accidents in the DOE complex and evaluating the approaches against industry
standards, methodologies, and practices. The report should address the need
for development of a guidance document and any other action planned in this
area.
. A report evaluating the existing Pantex Zone 4 analyses against the issues of
probability of a crash, impact analytical methodology, and consequence
analysis discussed in the enclosure. The report should include any planned
corrective actions with regard to interim storage of plutonium in the Modified-
Richmond ad Steel Arch Construction magazines.
The Board requests the above reports be submitted within 60 days of receiving this letter. If
you need any further information, please let me know.
Sincerely,
John T. Conway
Chairman
c: M. Whitaker, Acting DOE/EH-6
Enclosure
Section H H-3
DNFSB Issues Regarding the Pantex Zone 4 Aircraft Crash Analysis
1. Probability of the Accident:
a. DOE's analysis has used a criterion according to which a probability of an
aircraft crash exceeding 1 per year would lead to defining this as a credible
event. The U.S. Nuclear Regulatory Commission (NRC) requires a more
stringent criterion for determining if an aircraft crash is to be considered
credible. Specifically, NRC considers the aircraft crash accident to be credible
if the probability is greater than 10-' per year. Additionally, if the facility is
located less than 10 miles from an airport and the projected annual number of
operations at the airport is greater than 500 D2, the aircraft crash accident is
considered by the NRC to be credible. (D is the distance in miles from the
airport runway to the facility, see NUREG 0800 Section 3.5.1.6).
b. A number of other factors affecting the probability of a crash are not routinely
considered for the Pantex Zone 4 aircraft crash analyses:
(l) Back course instrument approaches to runway 22 at the Amarillo
International Airport (AMA). These published approaches, that are
used for both take-off and landing, result in aircraft flying directly over
the Pantex facility. Due to the meteorological conditions at Pantex,
this flight path is used for landing about 70 percent of the time, and
takeoff about 30 percent of the time.
(2) Visual Flight Rule (VFR) flights near Pantex.
(3) Air traffic from nearby private airports.
(4) Military operations at AMA.
c. The methodology employed for determining the design basis missile for
aircraft crash into a Zone 4 magazine utilizes the concept of subdivision and
compartmentalization of aircraft by specific type. For example, if the
probability of a crash by a specific aircraft type (large military aircraft,
commercial airliner, etc.) was less than l0E-6 per year, then that component of
the aggregate aircraft crash probability was declared incredible, and dismissed
from consideration as a source of a possible design basis missile.
2. Aircraft Impact Analytical Methodology:
a. The methodology used for the Zone 4 impact analysis insofar as missile mass,
impact velocity and angle;. is not consistent with current commercial practice
and methodology, such as that found in " Report of the ASCE Committee on
Section H H-4
Impact and Impulsive Loads", Vol. V, Civil Engineering and Nuclear Power
Specialty Conference, September 1980. Nor is it apparent that the initial
conditions ad assumptions in the Pantex FSAR impact analysis are
Conservative. A slight change in the assumptions regarding the impact velocity
or the weight of the missile would result in significantly different Conclusions
regarding penetration of a magazine by the missile generated from the aircraft.
b. DOE recently submitted a revised evaluation of the effects of an aircraft crash
on Pantex Zone 4, entitled, "Vulnerability of the Zone 4 Magazines to Impact
by General Aviation Single Engine Aircraft." The methodology used in this
report for evaluation of the consequences of a missile generated from the event
is similar to that discussed in Item 1 .c above. The report, utilizing the concept
of deaggregation of probability by aircraft type, concludes that generated
missiles with sufficient weight, velocity, and angle of attack to collapse a
magazine, are incredible. In commercial industry practices, if an accident is
credible and considered to be a Design Basis Event (or in DOE Order 5480.23
terminology, "Evaluation Basis Event"), then the controlling parameters such
as weight, velocity, and angle of attack are defined using a conservative set of
assumptions.
3. Analysis of Consequences:
a. The consequences of plutonium dispersal from a fire following an aircraft
crash into a storage facility do not appear to envelope the following bounding
conditions:
(l) The respirable release fraction used in the analysis for Zone 4 at Pantex
does not appear to realistically represent the accident conditions and is
not technically justified or supported by test results.
(2) Sandia National Laboratory performed a Comparison of the results of
their atmospheric dispersion computer program, ERAD, with results
from the NRC code, MACCS. Based on this comparison, it appears
that the ERAD computer program does not correctly model the fire
scenario ad significantly underestimates the consequences compared to
the results from MACCS analysis.
b. The effect of dispersal of plutonium in particle sizes larger than 10 microns on
the population or the environment has not been addressed in the Pantex Zone 4
analysis.
2
Section H H-5
c. The on-site consequences of such an accident have not been evaluated with
respect to safety of the workers and other operations at other facilities at
Pantex.
d. The consequences of aircraft impact into a Steel Arch Construction magazine
at Pantex have not been addressed.
4. Adequacy of Analysis Documentation: The detailed analyses performed by Sandia and
Ogden Energy & Environmental Company to support their Zone 4 results and conclusions
have not been made available in a form that would support a corroborative review. This is
apparently due to the analyses and documentation not being developed in accordance with
quality assurance requirements, such as DOE Order 5700. 6C, Quality Assurance, including
proper development of documents and records, with independent review.
3
Section H H-6
Department of Energy
Washington, DC 20585
October 26, 1993
Honorable John T. Conway
Chairman
Defense Nuclear facilities Safety Board
625 Indiana Avenue, N.W.
Suite 700
Washington, D.C. 20004
Your October I, 1993, letter regarding Defense Nuclear facilities Safety
Board staff review of analyses to assess aircraft crash accidents for
certain DOE facilities raises specific issues about Zone 4 at the Pantex
Plant. We have wet with Board staff on two occasions regarding the
Pantex issues.
On October 8, 1993, the discussion focused on aircraft accident
probabilities and the issues raised regarding the application of
Nuclear Regulatory Commission (NRC) criteria and their
implications for design basis accident considerations.
Representatives from the NRC attended the meeting and explained
how the Standard Review Plans (SRP) for Evaluation of Potential
Accidents (2.2.3) and Aircraft Hazards (3.5,1.6) are applied. The
NRC staff has provided a summary regarding the application of the
SRPs. This summary is provided as an attachment to this letter
(Attachment 1). from a reading of the NRC staff summary you will
find that our treatment of the aircraft crash analysis is
consistent with SAPs, including issues raised regarding the
concept of subdivision and compartmentalization. Also at the
October 8, 1993 meeting information was provided regarding the
frequency and conditions for use of runway 22 at the Amarillo
International Airport. This information was based on a letter
provided by the Amarillo Air Traffic Control, federal Aviation
Administration (Attachment 2),
The second meeting took place on October 15, 1993, This meeting was
dedicated to the technical bases for the respirable release fraction
used in the consequence analyses of postulated aircraft crashes into a
Zone 4 storage magazine. It should be noted that this analysis was
undertaken to follow through on a commitment made to the State of Texas
and not for the purpose of design basis considerations. Design basis
concerns were considered in terms of aircraft crash probabilities
consistent with the NRC criteria previously discussed.
I would appreciate confirmation if the foregoing satisfactorily resolves
the issues raised in your October 1, 1993 letter regarding Pantex
Zone 4.
Section H H-7
2
Your letter also contains a request for a report comparing the various
approaches used to assess aircraft crash accidents in the DOE complex
and evaluating the approaches against industry standards, methodologies,
and practices. This report will be provided under separate cover.
You also requested that I identify plans for development of a guidance
document for airplane accident analysis. In that regard, I have tasked
my Deputy Assistant Secretary for Weapons Complex Reconfiguration to
incorporate the guidance developed from the preparation of the report
into the design criteria manual for reconfigurati on of the Weapons
Complex. This information will be provided for your review prior to
finalization.
Sincerely,
Victor H. Reis
Assistant Secretary
for Defense Programs
Attachments
cc:
M. Whitaker, EH-6
Section H H-8
ATTACHMENT 1
UNITED STATES
NUCLEAR REGULATORY COMMISSION
Washington, D. C, 20656
October 18, 1993
Victor Stello, Jr.
Principal Deputy Assistant Secretary for facilities
Department of Energy
l000 Independence Avenue, S. is,
Washington, D.C. 20585
Dear Mr, Stello:
This is in response to your request to provide a brief description and
interpretation of the current NRC criteria regarding aircraft hazards. In
assessing the risk associated with potential aircraft accidents on nuclear
facilities licensed by the NRC, we use the criteria and methodology described
in the NRC Standard Review Plan (SRP). Enclosed is a brief characterization
of how NRC applies the above review guidance and criteria in assessing
aircraft risks with respect to nuclear power plants. We trust that this
information will be useful in your consideration of aircraft hazards with
respect to DOE nuclear facilities. If we can be of any further assistance,
please let us know.
Sincerely,
Ashok C. Thadani, Director
Divi ion of Systems Safety and Analysis
Offi e of Nuclear Reactor Regulation
Enclosure: As stated
cc: JTaylor
TMurley
WRussell
Section H H-9
NRC ASSESSMENT OF AIRCRAFT HAZARDS
Chapter 2.2.3 of the NRC Standard Review Plan (SRP) provides acceptance
ri teria with respect to potential accidents involving hazardous materials or
ctivities in the vicinity of a nuclear power plant. The criteria are in
erms of the likelihood of an accident leading to a 10 CFR Part 100 release.
hey apply to a number of site hazards, including those posed by aircraft.
Specifically,SRP 2.2.3 indicates that the risk pposed by an activity in the
vicinity of - plant is acceptable if the probability of exposures exceeding
O CFR Part 100 is approximately 10E-7 per year.
typically, sufficient data are not available to make a precise estimate of the
risk. Lack of data precision is addressed by using conservative estimates.
Hence, the criterion of 10 per year is acceptable if reasonable qualitative
arguments can be used to show that the realistic probability is lower.
Chapter 2.2.3 also indicates that the above criteria are to be applied to the
aggregate probability of an outcome from a particular hazard. This calls for
The consideration of the sum total of all hazards posing $ particular type of
threat to a facility. In the case of aircraft, this pertains to all aircraft
activity in the vicinity of a site.
In practice, some initial screening is performed so that aircraft that do not
pose a threat to the facility are excluded from the analysis. For example
since all nuclear plants are required to be protected against tornado missile
damage, the safety-related plant systems typically are protected, as a
minimum, by eighteen inches of reinforced concrete. Hence, most light general
aviation aircraft can be screened out from the analysis on desi g n basis
considerations. Section II.2 of SRP Chapter 3.5.1.6 refers to General Design
Criteria 3 and 4 of 10 CFR Part 50 as an acceptable basis for dismissing
specific aircraft from further consideration if it can be shown that the
safety related plant. systems, structures. and components are capable of
withstanding the effects of aircraft fires or impacts, respectively,
The remaining ensemble of aircraft identified with the site (i.e., those that
have the potential for causing loss of safe shutdown capability of causing &
release of radioactivity in excess of 10 CFR Part 100) are considered in the
analysis by estimating the aggregate probability of an on-site crash. In
order to simplify the analysis, the staff conservatively assumes that an air-
craft impact on safety-related plant structures results ina 10 CFR Part 100
release. If the probability of this is less than about 10 per year, the
aircraft hazard is considered to be acceptable.
If not, there remains the option of extending the analysis to include aircraft
impacts and their effects on plant structures and equipment. To do this it is
.necessary to consider each type of aircraft separately in terms of flight
frequency, crash rate statistics, and aircraft size, weight and flight
characteristics (e.g. speed, direction, distance, altitude). Ultimately,
however, the contribution from each type of aircraft is summed and the
estimated total probability of a 10 CFR Part 100 release is compared with the
acceptance criteria in SRP 2.2.3.
Section H H-10
SRP 3.5. 1.6 provides additional review and evaluation gui dance that is
specific to aircraft hazards. For example, ito describes screening criteria
for nearby airports. Alspoa it gives guidance on evaluating crash prob-
abilities due too air traffic on federal airways. aviation corridors, civilian
and military airports, designated airspaces, and holding patterns.
It should be noted that the above staff guidance and criteria have been
developed for use in regulatory actions involving nuclear plant license .
applicants. I; the NRC staff ware to consider applying different criteria
than those discussed above, there is a requirement for a backfit analysis
(10 CFR part 50.59). Specifically, the backfit rule requires that a proposed
change a) provide substantial additional protection, and b) be cost-effective.
In addition, the Commission's Safety Goals (particularly the large release
guideline of 10E-6 per reactor year, and the subsidiary objective of limiting
core damage frequency to less than 10 per reactor year) are used to assess
if the proposed requirement would provide substantial additional protection to
the public health and safety. Since the intent of the Safety Goals is to
address societal risks, these guidelines typically are not applied to
individual plant actions and are considered to be more sui to bl e for addressing
issues involving groups of plants (e.g., a class of plants of a particular
design).
Section H H-11
ATTACHMENT 2
U.S. Department Amaril1o Air Traffic Control
of Transportation Rt 3. Box 579
Federal Aviation Amarillo, Texas 79107
Administration
October 7, 1993
Bret Simpkins
Battelle Pantex
Section Manager
Safety Programs
At the request of Mr. Simpkins, the following are my comments
regarding Section 1.b of the Pantex Zone 4 Aircraft Crash
Analysis.
1 .b (1) Amarillo International Airport does have * Localizer
backcourse Instrument Approach to Runway 22, This approach is
used only for landing aircraft and is not intended, or ever
used, for departing aircraft. If aircraft are flying the
Backcourse Approach to Runway 22f they will fly directly over
Pant ax restricted to an altitude of 5000MSL until reaching the
Amarillo VOR before beginning decent. The Amarillo VOR is
outside the Pantex prohibited area.
Using the DOE's assumption that meteorological conditions in
the Amari area require the use of Runway 22 seventy per
cent (70%) of the time in no way reflects that 70% of
Amarillo `a landing traffic flys over the Pantex Plant. The
only time the Backcourse Approach would be used is during
actual (IFR) Instrument Flight Rules weather conditions and
the wind dictated Runway 22 or practice approaches.
Using the figures of the Amarillo Chamber of Commerce that 73
percent of the .year is under sunny skies and the conservative
figure of Amarillo Tower that 85 percent of year is under
(VFR) visual Flight Rules. you must remember that aircraft
landing Runway 22 are not overflying the Pantex prohibited
area at all. Most aircraft are flying visually and will turn
their base legs within the 7 mile distance between Pantex and
the Amarillo Airport.
All aircraft departing Amarillo Airport during the control
toward hours of operation (0600 AM - 1200 AM local time),
regardless of the runway they depart, are assigned headings to
expedite their climb on course. It would be a rare occasion
for * . departing aircraft to overfly. the Pantex prohibited
area.
Edward Warren First American Aloft
Section H H-12
-2-
Also. please keep in mind that runways 04, 13, and 31 are
of ten used and have no bearing on Pantex what so ever.
1.b (2) All VFR aircraft landing or departing Amarillo are
required to be in two-way radio communication with Air Traffic
Control. This also includes all overflying VFR aircraft
within 10 nautical miles of Amarillo international Airport.
If these aircraft are not aware of the Pantex prohibited area
Air Traffic control will provide factors around the area. or
ensure their altitude is above 4800 MSL.
1.b(3) Nearby private airports include Panhandle Airport,
Stamps Field (crop dusters) and Eagle Airport (gliders).
1 See attached,
C. Ross Schulke
Air Traf fic Manager
DOT/FAA
Amarillo Air traffic Control Tower
Amar i l Texas
Section H H-13
Table (Page H-14 Table 4 - FISCAL YEAR 1992)
AIRCRAFT OPERATIONS SUMMARY
AMARILLO INTERNATIONAL AIRPORT January, 1993
% Change
1988 1989 1990 1991 1992 1991-92
CIVILIAN
Itinerant 21,646 21,410 20,173 19,052 20,477 7.5%
Local 9,122 5,211 7,349 9,387 8,857 -7.8%
Subtotal 30,788 26,621 27,622 28,439 29,134 2.4%
Scheduled Air Carrier 15,247 13,339 13,174 12,128 12,334 1.7%
Air Taxi 2,652 3,799 5,177 5,662 9,005 35.2%
TOTAL CIVILIAN 48,667 43,759 45,873 47,227 50,473 6.9%
MILITARY
Itinerant 9,023 8,390 7,913 7,305 6,999 -4.2%
Local 28,761 31,958 31,529 29,432 31,517 7.1%
TOTAL MILITARY 37,784 40,348 39,442 36,737 38,516 4.8%
TOTAL OPERATIONS 86,461 84,107 85,315 83,964 88,989 6.0%
INSTRUMENT APPROACHES - IFR CONDITIONS
CIVILIAN
Civil 377 526 683 672 603 -10.3%
Scheduled Air Carrier 551 651 629 674 559 -17.1%
Air Taxi 179 263 419 417 464 11.3%
TOTAL CIVILIAN 1,107 1,440 1,731 1,763 1,626 -7.8%
MILITARY 208 310 270 358 430 20.1%
TOTAL INSTRUMENT APPROACHES 1,315 1,750 2,001 2,121 2,056 -3.1%
INSTRUMENT OPERATIONS
Primary (to/from AMA) 47,831 49,051 49,593 50,619 51,861 2.5%
Secondary (other airport) 3,543 2,995 3,310 3,410 2,992 -12.3%
TOTAL INSTRUMENT APPROACHES 51,374 52,046 52,093 54,029 54,853 1.5%
OTHER RADAR OPERATIONS
IFR Overflights Controlled by
Amarillo Approach Control 2,746 3,169 3,776 4,049 3,803 -6.1%
Stage III VFR Operations by
aircraft arriving/departing AMA 15,596 12,364 14,079 14,937 17,070 14.3%
Stage III VFR Operations of air-
craft operating to/from secondary
airports or overflying AMA 17,752 18,055 15,019 14,298 14,018 -2.8%
TOTAL OTHER RADAR OPERATIONS 37,194 33,688 34,604 33,384 34,891 4.5%
TOTAL RADAR OPERATIONS HANDLED
BY AMA APPROACH CONTROL 88,568 85,643 91,283 87,413 91,800 5.0%
SOURCE: FAA Tower, Traffic Activity Report, FAA Form 7230#-1
Section H H-15
John T. Conway, Chairman DEFENSE NUCLEAR FACILITIES
A. J. Eggenberger, Vice Chairman SAFETY BOARD
John W. Crawford, Jr,
Joseph J. Dinunno 625 Indiana Avenue NW, Suite 700, Washington, D.C. 20004
Herbert John Cecil Kouts (202) 208-6400
October 29, 1993
The Honorable Victor H. Reis
Assistant Secretary for Defense Programs
Department of Energy
Washington, DC 20585
Dear Dr. Reis:
The board has received your letter of October 26, 1993, which discusses assessment of
aircraft accidents at the Pantex Plant. The information provided in your transmittal also
includes attachments from the Nuclear Regulatory Commission (NRC) and the Federal
Aviation Administration (FAA).
Based on the above, the Board has concluded that the results shown in the Environmental
Assessment Report and the Final Safety Analyses Report (FSAR) for the Pantex Plant
Zone 4 do meet the NRC assessment criteria for evaluating aircraft hazards. The issue of
compatibility with NRC probability criteria was detailed in the enclosure to our October 1,
1993, letter to you. The Board's staff will continue to discuss the remaining sections of the
enclosure with your staff. These sections are related to basic data, aircraft impact analytical
methodology, analysis of consequences, and analysis documentation in connection with
documentation of the safety analysis for Zone 4. Additionally, the Board awaits the report
concerning the generic evaluation and assessment of aircraft crash accidents.
If you have any questions on these matters, please call me.
Sincerely,
John T. Conway
Chairman
c: Mark Whitaker, Acting EH-6
Section H H-17
November 3, 1993
"Airborne Release Fraction (ARF) and Respirable Fraction (RF)
as a Result of a Fire Following Impact of Aircraft into
Storage Igloo at Pantex Facility
by
Jofu Mishima, SAIC-Richland
Bob Luna, Sandia National Laboratory
Doug Stephens, Lawrence Livermore National Laboratory
The amount of material suspended as a result of an accident is dependent upon the
physicochemical properties and the physical configuration of the material impacted, the type
and level of stress imposed, the responses of materials involved, and the aerodynamic flow
that carries the suspended materials aloft. For safety analyses, this information is provided
by the postulated accident scenarios, the engineering analysis/assumptions that describes the
abnormal environments and material responses and, dictates the choice of the applicable ARF
(total airborne release) and RF (fraction of airborne material in the respirable size range*)
for the stresses imposed. Under accident conditions where the metal is not closely
surrounded by detonating High Explosive, very little metal is suspended from surfaces of
relatively large pieces (subsect. 4.2.1.1.1, Mishima July 1993). Conversion to an oxide will
generate and release particulate materials from metals.
For the specific scenario under consideration, it is postulated that an aircraft impacts a
storage igloo in the Pantex Zone 4 area. Engineering analysis indicates that the roof of the
Modified-Richmond type igloo containing the largest number of Pu components could fail by
collapse of some of the 1-ft thick, reinforced concrete panels overlaid with 3-ft of soil that
has weathered in place for years. The estimated damage to the contained materials from this
scenario exceeds that estimated for the penetration of the Steel Arch Construction igloos. It
is assumed that the crush-impact of the debris from the roof failure and penetration of some
parts of the aircraft (e. g. engine spools) damages some fraction of containers releasing the
"pits" and damaging the pit cladding sufficiently to expose the metal underneath to the post-
accident environment. The debris from the limited roof collapse would bury much of the
materials that is at floor level. (The presence of large amounts of dust generated by the
collapse would tend to increase the agglomeration of airborne particles present and increase
the removal by gravitational settling as occurred in operation Roller Coaster.)
___________________________________________________________________________________________
* Respirable fraction - commonly defined as all particles 10 micrometer or less Aerodynamic
Equivalent Diameter [A sphere with a density of 1 g/cm3 that has the same aerodynamic
characteristics (same terminal velocity) as the particle].
1
Section H H-18
Since the "pits" are balls of heavy metal, they would have a tendency to fall to the lowest
level that would support/hold the mass. whether any of the "pits" can be split by the
impact of the edge of a container or other debris is dubious but, the interaction with an
engine spool might shred the package and pit cladding to expose/damage the Pu shape. If
such is assumed, some pieces of metal may be suspended on debris above the floor level. In
either case, stripping of the cladding or tearing of Pu metal, only the surfaces of large pieces
of Pu metal would be exposed to the post-impact accident generated conditions.
The remnants of the igloo would provide at least partial confinement that would contain the
debris; although, the doors of the igloo would not be water-tight and liquid could leak via
openings around the doors and the air vents at floor level on either side of the doors. The
aircraft fuel released by the impact would most likely spread over a large are, but for this
scenario is assumed to collect at the floor level of the igloo and be ignited. A substantial
amount of scattered fuel could form a "fire ball" (an explosive, rapid burning of
vaporized/aerosolized fuel) but the fire would be above the igloo. Fireball overpressures are
unlikely to enhance damage to the packages or "pits" caused by the impact. Such a "
ball" would have little impact upon the suspension of plutonium since little if any finely
divided Pu or PuO2 is present at this time. Any loss of containment prior to the fire would
result in the formation of oxide on the exposed surfaces of the metal.
The fuel would burn above the debris surface and radiate heat to the fuel to evaporate the
fuel required to sustain combustion. The temperature of the debris including the Pu would
vary from the boiling point of the fuel at the lower end of the range to temperatures
appropriate to the radiation from the fuel-rich hydrocarbon fuel combustion at the upper end
of the range. The atmosphere within the damaged igloo structure would be fuel-rich, oxygen
depleted (concentration of >13% oxygen are required for flaming combustion) and oxidation
would be limited by the oxygen availability. Pu is such an efficient oxygen-getter that
reducing conditions would only produce substoichiometric Pu oxides. Materials covered by
the debris. Therefore, much of the Pu would be exposed to temperatures less than those
experienced in fires free-burning hydrocarbon fuel.
The metal suspended in the flames and exposed to the radiant heat would oxidize at an
accelerated rate with the increase in temperature and if the large pieces with surface to mass
ratios greater than 10 cm2/g attain a temperature of > 500oC for the entire metal mass, the
metal could achieve self-sustaining oxidation (Stakebake June 1992). Experiments involving
ignition and self-sustained oxidation for large pieces of plutonium showed that pieces heated
in flowing air or in contact with substantial metal surfaces (glovebox floor) could not be
heated to achieve self-sustained oxidation even with a welding torch (felt 1967). Metal
heated to self-sustained oxidation formed oxide coat on their exterior surfaces (except the
surface in contact with the insulating material) that periodically split to allow flow of molten
metal (Felt 1967). For one experiment reported by Stewart (1960) in the Vixen A Trials
2
Section H H-19
where plutonium metal rods were suspended in & chimney above a petroleum fire, only 44%
of the metal was oxidized during a 30-minute fire indicating that even under these conditions
the plutonium metal did not achieve self-sustained oxidation. However, in a second Vixen A
experiment, Stewart (1960) reported 100% oxidation for 200-grams of Pu suspended in a 50-
minute fire under controlled temperature increase conditions. The material suspended above
the surface in flowing air would only oxidize at accelerated rates while being heated and,
since oxidation of substantial pieces could take hours, the suspended metal may not be
completely oxidized in the 40-min [ire duration postulated for the scenario. (The mass of Pu
in "pits" is in kilograms.) Thus, assuming self-sustained oxidation that assures complete
oxidation of the metal is a conservative assumption.
Mechanisms for conversion of plutonium into powder form prior to the loss of containment
(such as minor breaches in the cladding) do not appear to be capable of generating any
significant quantity of powder. Any small quantities of such powder present initially would
most likely be buried under debris or fuel and not be available for suspension at the surface
until very late in the fire. The gas flow in the igloo remnants would be primarily due to the
mass flux of fuel vapors (the igloo remnants form a vessel to contain the fuel and debris)
and, are less i the latter stages of the fire when greater quantities of oxide are present
Furthermore, oxides formed by the high temperature oxidation of plutonium metal are
relatively coarse - see Figure 3 "Size Distributions Produced by Oxidation of Metallic
Plutonium" (Mishima December 1965, attached). The ordinate is Particle Size in Equivalent
Spheres (Geometric Diameter) for the residues collected from high temperature oxidation
measured by sieve. The oxide was friable and, therefore, sieving may have causeed addition
size reduction by abrasion. The only measured valuc at 3 micrometers in the figure
(approximately equivalent to 10 micrometers AED) is approximately <0.001 Wt/o of the
initial mass. Although the respirable fraction implied by Stewart's proposal is twice the
value suggested here (~0.1%), the distribution is for residues, not acrosolized material.
There are many additional factors that reduce the fraction of <3 micrometer particles being
suspended.
In the opi in ion of the authors and others knowledgeable on the airborne release of plutonium
under various accident conditions, the airborne release of 5E-4 fraction (0.05%) of the mass
of plutonium metal exposed as particles in the respirable size fraction (10 micrometers
Aerodynamic Equivalent Diameter or less)(designated the Respirable Release Fraction, RRF)
is a technically supportable, conservative RRF for the case of Pu release during a fire
resulting from the impact of: aircraft into storage igloos at Pantex for the following
reasons:
A based on a review of ARF and RE values proposed by the authors who developed the
values performed for a tri-lab "delphi" estimate of the airborne release of plutonium
from weapons components involved in various types of severe accidents including
3
Section H H-20
Figure (Page H-21 FIGURE 3 Size Distributions Produced by Oxidation of Metallic Plutonium)
aircraft impacts, & RRF of 5E-4 is appropriate. (Stephens 1993) and is the same as
currently recommended by the French Ballereau 1987).
B. a RRF of 5E 4 envelopes the respirable size fraction release derived by a reevaluation
the 2 Vixen "A" Trials performed by R.E Luna (1993) based upon the published data
for airborne material samples taken downwind of the source and considering the
normal atmospheric transport conditions. The metal was not completely oxidized in
one of the two events 30-minute fire at - 1000o C). Bases on the total mass of
materials exposed, the ARF/RF for the two tests were lE-2/0.02 (RRE 2E-4) and 32
2/0.008 (RRF 2.4E-4) during 30- and 50-minute fires. The enhanced flow and test
configuration favorable to suspension relative to most laboratory test arrangements
(oxidizing metal suspended iut a chimney over a petroleum fire) appears to have
suspended & substantial fraction of larger particles that deposited a short distance from
the source. Based on the RRFs from these experiments, the RRF applied in these
analyses is conservative.
C. the RRF used in these analysis is equal to the bounding Airborne Release Fraction,
5E-4, shnown by Mishima (DRAFT July 1993) to bound all published experimental
measurements of the airborne release during self-sustained oxidation, natural
convection. The RF associated with the ARF is 0.5 and yields a RRF of 2.5E-4 that
is the essentially the same as the two values in B above for the respi rable airborne
release fraction from the large scale outdoor tests by Stewart (1959). The data cited
includes experimental measurements of ARF and RF during the self-sustained
oxidation of plutonium metal pieces ranging in mass from 500 to 1700 grams (exceeds
the mass used in other experimental study by up to a factor of - 100). Therefore, the
RRF used for the scenario is conservative.
D. the value exceeds the Respirable Fraction for high temperature oxidation estimated by
Haschke (Table III, July 1992). The data actually presented in the table is in
Geometric Diameter (the linear dimensions of the particle) and must be multiplied by
the square root of the density of the oxide (11.5 g/cm3) to approximate the
Aerodynamic Equivalent Diameter. Thus, the values listed in the table for 3.0
micrometer particles (4.6 X 10E-5 cumulative mass fraction) are equivalent to the
Respirable Fraction. Using an untested, unvalidated fragmentation model, Haschke
estimated that a cumulative mass fraction of 0.25% could be generated by the
oxidation. Suspension of 10% of the particle generated by aerodynamic stress is
difficult under most circumstances and Haschke's data in Table III indicates the
suspension of -2% of the respirable particles that could be formed.
In a telecom with Jolnn Haschke, 10/18/93, he supported use of the RRF of 5E-4 for
the situation described. His concerns about the data uncertainties expressed in the
document prompted the development of the fragmentation model and his concerns
lessened by the results of the calculations.
5
Section H H-22
Based upon the above scenario, no other release mechanism appear tenable. Concerns of the
possible flow of molten metal and the formation of droplets that fall over great distances do
not appear realistic based upon the observations indicating the lack of molten metal during
the Vixen "A" Trials - an experimental configuration that appears to exceed the fire
environment that is postulated for the igloo fire event.
In conclusion, the most significant point is that the RRF applied by DOE in the Zone 4
analyses exceeds both the bounding RRF for all the experimental measurements during self
sustained oxidation, natural convection and the RRFs measured from the Vixen A TrialsE
The value applied is very conservative for a number of reasons:
ø the difficulty of damaging the pits clad in stainless steel and held in various packages
to expose the metal.
the difficulty in obtaining the conditions to achieve self-sustained oxidation in large
pieces (both intense heat must be applied to heat the entire metal to >400oC and the
unheated surface must be insulated to prevent significant heat loss). Metal standing in
pools of fuel would be cooled by the evaporation of fuel.
due to its mass, the metal would require substantial support to be held in a flame and
would probably not achieve self-sustained oxidation as shown in one of the Vixen A
Trials.
If any of these conditions are not fulfilled, the airborne release would be substantially less
and be limited to the fraction of metal oxidized.
Notwithstanding the special problems with sample collection and interpretation, the data from
the Vixen A Trials are the only measurements from a large scale outdoors release of Pu
under conditions that equal or exceeds those expected for aircraft impacts. The results
reflect the "real world" without the special scaling concerns that may be present in some
experimental configurations. That the RRF applied agrees within a factor of two with the
value derived from both types of experimental results gives added confidence in its use.
REFERENCES
Ballereau, P. 1987. Formation of Aerosols by Oxidation of Plutonium and Its Compounds
(translated from CEA-BIB-242, Commissariat A L'Energie Atomique), UCRL-TT-108790,
Lawrence Livermore National Laboratory, Livermore, CA.
6
Section H H-23
Felt, R.E. August 1967. Burning and Extinguishment Characteristics of Plutonium Metal
Fires, ISO-756, Isochem, Inc. (currently Westinghouse Hanford Company), Richland, WA
99352.
Haschke, J.M. July 1992. Evaluation of Source-Term Data for Plutonium Aerosolization,
LA-12315-MS, Los Alamos National Laboratory, Los Alamos, NM 87545.
Haschke, J.M. 10/1 Personal communication, Los Alamos National Laboratory, Los
Alamos, NM 87545.
Luna, R.E. October l993. A New Analysis of the Vixen A Trials, SAND93-2528, Sandia
National Laboratory, Albuquerque, NM.
Mishima, J. July 1993. Recommended Values and Technical Bases for Airborne Release
Fractions (ARFs). Airbomo Release Rates (ARRs). and Respirable Fractions (RFs) at DOE
Non-Reactor Nuclear Facilities, DOE-STD-0013-93 DRAFT, Science Application
International Corporation, Richland, WA 99352.
Stakebake, J.L. June 1992. Plutonium Pyrophoricity, RFP-4517, EG&G Rocky Flats, Inc.,
Golden, CO 80402-0464.
Stephens, D.R. October 1993. Personal communication, Lawrence Livermore National
Laboratory, Livermore, CA 94551.
Stewart, K. 1960. Vixen A Trials 1959. Experiments to Study the Release of Particulate
Material During Combustion of Plutonium, Uranium and Beryllium, AWRE Report No.
T15/60, Atomic Weapons Research Establishment, Aldermaston, U.K.
7
Section H H-24

Part I

                                            SANDIA NATIONAL LABORATORIES
                                                              Albuquerque, New Mexico 87185
date: December 11,1992
   to: David E. Rosson, Jr
      DOE/AL/WMOSD
 from R E. Smith 0333
subject: Plutonium Dispersal Consequence Analysis of Hypothetical Aircraft Crash into Pantex
      Zone 4
   This memo provides an unclassified version of the final results of the consequence analysis of
   the Pantex Plant Zone 4 magazines. The results are expressed in terms of peak dose at the site
   boundary and offsite and latent cancer fatalities (LCF) from the site boundary to both 16 and 80
   km. The results should be considered as upper-bound estimates. A discussion of pit storage
   scenarios, consequence methodology, Pu release scenarios, and final results is given here. Also
   presented in this memo is a discussion of the preliminary analysis, as submitted to DWMOE in
   October 1992 This memo supersedes Reference 1.
   1. Storage Scenarios
   A conservative approach was taken to model the consequences arising from a potential aircraft
   crash into a Zone 4 magazine. Two magazine designs are present in Zone 4: the Modified
   Richmond (MR) and the Steel Arch Construction (SAC). A generic type of large (commercial
   or military) or high performance (military) aircraft was assumed to impact a magazine, collapse
   or penetrate the structure, and cause significant damage to the contents. No attempt was made to
   further discriminate between the types of aircraft that could impact a magazine. This is
   conservative and consistent with the aircraft crash probability estimate generated in Appendix F
   of the Safety Analysis Report (SAR) [2]. Although any magazine may potentially be penetrated
   or collapsed by an aircraft impact, the amount of plutonium (Pu) release depends on the contents
   in the magazine.
   1.1    Inventory
   To bound the various types of scenarios that could result from an aircraft crash event, bounding
                                      -1-
  section I                               I-1
case scenarios were considered. These considered a pit storage magazine that is penetrated, a
fraction of the containers is breached, and a fuel fire involving the exposed Pu ensues.
The cases that involve pit storage are estimated conservatively as a function of impact dynamics.
The conservative approach inherent in these scenarios is discussed in Section 1.2.
1.2 Worst-Case Plutonium Dispersal Source Term for Pit Storage
Several analyses have been performed to assess the credibility of various aircraft types
penetrating the MR and SAC magazines [4 - 8]. These analyses and engineering judgments of
the analysts associated with the Pantex Zone 4 SAR were significant in developing the rationale
given in this section.
The basic scenario for this discussion is a hypothetical aircraft crash into one of the magazines.
Severe magazine damage and resulting fire are hypothesized. The fire is caused by the fuel on
board the aircraft. The progression of this scenario ultimately results in the exposure of Pin to
the fuel fire and the production of aerosols that then could be carried offsite by the wind.
Parameters that effect the consequence source terms are:
      Pit: ruggedness of design, heat resistance, amount of Pu
      Container: resistance to breaching by impact, crush, puncture, or fire
      Storage Configuration: location and number of items, stacking arrangement, intervening
      materials, existence of sandbagged components
      Magazine: design, size, structural strength, earth overburden
      Site Layout: magazine spacing, orientation
      Scenario Parameters: specifics associated with the scenario.
Scenario specific parameters are:
      Aircraft: type, size, weight, fuel load, accident rate, frontal surface area, location, and
      size of engines
      Flights: frequency, location
      Crash: impact point, angle, speed, orientation
      Pilot: target avoidance.
                                      -2-
section I                               I-2
The scenario specific parameters and the site layout parameters are the dominant parameters
used in evaluating crashes into a magazine. The SAR contains a detailed analysis of the
frequency of crashes into magazines. The starting point was the penetration of a magazine. The
.pit, container, storage configuration, magazine, and aircraft parameters all influenced release
quantities.
Crash scenarios have been grouped into six bounding cases as a function of magazine type and
penetration location and are identified below:
      Magazine Type: SAC or MR
      Magazine Penetration Location: front doors, roof, sides or back.
Penetration of the front doors and the roof of both the MR and SAC magazines is assessed to be
credible for some of the larger and faster commercial carriers and some types of military aircraft.
The worst-case release scenario for the SAC magazine was assessed to be penetration of the
front doors; for the MR magazine, it was assessed to be penetration of the roof. Penetration of
the sides or back of either magazine type is not considered credible because they are protected
by massive amounts of earth overburden and concrete walls.
1.2.1 Aircraft Crash into Front of Magazines. An aircraft crash into the front of a SAC or MR
magazine could result in the large concrete block security barriers being showed into the doors.
This could either shear the entire front wall around the magazine perimeter or cause the
magazine doors to collapse. The resultant debris from the walls, doors, concrete blocks, the
aircraft, and possible collapsed roof could then impact the contents in the magazine. Since
spilled aircraft fuel is likely to cause a fire in a crash of this severity, it is conservatively
assumed that a fire will occur. Whether or not the fire involves the interior of the magazine is a
significant consideration; in this analysis, it is assumed that it does.
If a pit container is damaged and the fire is of sufficient duration, the Pu metal can ultimately be
aerosolized and released to the environment in a fire plume. Therefore, it is conservatively
assumed that Pu release will occur when a pit storage container is damaged and exposed to fire.
If a container is undamaged, thermal tests indicate it will maintain its fire resistance for a
minimum of 30 minutes. Based on the thermal tests, it was estimated that at least 40 minutes is
required for eventual combustion and atmospheric release of the Pu.
The likelihood of a fire lasting 40 minutes or longer is assessed to be less likely than the
likelihood of a short duration fire by an order of magnitude [9]. Note that the SAR assessed the
likelihood of any aircraft crash penetrating the magazine as less than one-in-a-million per year.
Since this fire-only container damage scenario is an order of magnitude less likely, it is clearly
not credible and is not further assessed. For this study, damage of the pit storage containers and
fire was the only scenario considered to result in a Pu release. Given pit storage container
                                      -3-
section I                               I-3
damage and fire involving combustion of Pu, the amount of Pu rel eased in aerosol form would
be small and the respirable amount would be even smaller. These values are given in Section 4.
      1.2.1.1 Structural Analysis of the MR Magazine. Structural consideration of the MR
magazine indicates that in an aircraft impact on the front of the MR, the mid-wall would be
displaced and the roof sections adjacent to the front of the magazine would collapse when the
front wall fails [4]. This would result in significant additional debris from the one-foot thick
concrete roof and a minimum of three feet of dirt overburden falling onto the stacked containers.
The likelihood that any damaged container would be exposed to the resultant aircraft fire is
reduced by this type of roof collapse. For this analysis, this scenario is not further assessed since
direct impact into the roof is assessed as a more serious scenario.
      1.2.1.2 Structural Analysis of the SAC Magazine. It is assumed that the SAC magazine
roof will not collapse from a front wall crash. In this assumption, a larger number of damaged
containers are exposed to fire. An estimate is made of the number of containers that could be
damaged when debris is pushed into the stacked containers. The containers have significant
resistance to impact. They have been tested to survive ground transportation criteria associated
with the shipment of radioactive materials and have a demonstrated design capability to survive
impact into a flat hard surface at 30 feet per second.
While the containers are resistant to impact, it does not follow that they have significant
resistance to penetration, especially resistance to sharp massive puncture probes. The test
sequence, however, does indicate some resistance. It is important to consider that the stacking
and storage array of the containers also provides a yielding and energy-absorbing configuration.
These factors, along with the energy-absorbing characteristics of the debris and the reduced
velocity of the aircraft crash due to moving the concrete blocks and collapsing the front wall,
indicate that it is unlikely that many of the containers would be damaged enough to lose
container integrity. It is estimated that 5% to 50% of the containers would be damaged. For this
analysis, 50% damage will be used, Next, we assume that a fire occurs (80% to 90% estimate):
Additional likelihoods for whether the container is exposed to the fire, how close it is to the fire,
and how long the fire lasts must be considered for eventual combustion of Pu. A detailed
analysis of these parameters is not available. An estimate of 50% is used for their likelihood of
occurrence. Thus, an overall bounding estimate of 25% (50% damaged containers x 50%
sufficiently exposed to fire) is obtained for the percentage of stored pits that contribute to a
release of Pu aerosols resulting from an aircraft crash into a SAC magazine.
1.2.2 Aircraft Crash into Roofs of Magazines. The other credible magazine penetration point is
through the roof. Although the roof has at least three feet of earth overburden, it still has the
least amount of overburden when compared to the sides and back of the magazine. Several
analyses have been conducted to predict impact velocity thresholds for collapse and puncture of
both the SAC and MR magazines for different aircraft types [4 - 8]. These analyses form the
basis for determining the worst-case consequence scenario.
                                      -4-
Section I                               I-4
      1.2.2.1 Roofs of the MR Magazines. The MR magazines arc vulnerable to collapse of
large roof sections due to mass loading from the aircraft. The roof is also vulnerable to puncture
from larger aircraft engines. Puncture scenarios are not expected to expose many containers in
the magazine to a fire severe enough to cause a release of Pu aerosols into the environment,
since the damage would likely be more localized than a more massive collapse of large roof
sections.
For the MR magazine, it was determined that the worst-case consequence scenario results from
the collapse of several roof sections. A large aircraft could potentially cause collapse of half of
the roof on one side of the magazine [4]. Collapse would result in debris from the one-foot thick
concrete roof, from the three-foot-thick (or more) dirt overburden, and from the aircraft and
cargo falling onto the stacked containers. This debris could damage the containers. As many as
50% of the containers in that half of the magazine are directly below the collapsed structure and
are at risk. The containers, however, have significant resistance to impact and the stacking and
storage array further provides a yielding ad energy-absorbing environment. From these
considerations, an estimate for container loss of integrity is taken to be from 20% to 70%. For
this analysis, the 70% estimate was used.
Assume a fire occurs (100% versus 80% to 90% estimate). If a fire does occur, fire duration,
view factors of the damaged containers to the fire, container damage, and pit resistance to the
fire all reduce the likelihood of a Pu aerosol release. An estimate for the percentage of exposed
pits that contribute to an aerosol release, assuming damaged containers and a fire, is 10% to
70%. The value of 70% was used for this analysis.
From this presentation, an overall bounding estimate of 25% of the containers in one side of the
MR magazine is used for the percentage of pits that contribute to a Pu aerosol release. The 25%
is determined by the following formula: 50% of the containers are at risk x 70% of the
containers are damaged x 70% of the damaged containers are exposed to the fire. The fire
occurs 100% of the time.
      1.2.2.2 Roofs of the SAC Magazines. For the SAC magazines, the worst case roof
penetration scenario is similar to the MR roof collapse scenario except that the corrugated metal
roof would likely result in less irregularly shaped roof debris and less opportunity for puncture
of the pit containers. If the conservative assumption is made that the SAC results are the same
as the MR results, 25% of the stored pits can be estimated to contribute to thc Pu aerosol release.
This value is the same as that obtained for a crash into the front of the SAC magazine.
2. Consequence Methodology
This section describes the methodology used to estimate the maximum Pu-caused health affects
on the population surrounding the Pantex Plant resulting from a postulated aircraft crash into
Zone 4. Assessments are given for a release of Pu aerosol into the environment from the
                                     -5- 
section I                               I-5
burning of nuclear weapon pits. Sections 3 and 4 give a more detailed description of scenario
input parameters and assumptions.
2.1 Cloud Generation and Transport Model
ERAD is a three-dimensional numerical simulation of atmospheric dispersion from high
explosive detonations [10]. An integral method for estimating plume rise is used to provide a
description of the physical and thermodynamic properties of the cloud of warm gases formed
when the explosive detonates. Particle dispersion is treated as a stochastic process that is
simulated using a discrete time Lagrangian Monte Carlo method.
Version 3.0 of ERAD [10] was used to simulate the cloud formation and aerosol transport phases
for this analysis. One of the ERAD outputs is the time-integrated, airborne concentrations of the
respirable size particulate reported in the physical units of microgram-seconds per cubic meter.
Estimates of an averaged value of this parameter are provided in a user-defined rectangular
coordinate grid system. The positive x axis is the downwind direction during cloud passage.
The number of grid points used for this analysis was 40 in the crosswind direction and 40 in the
downwind direction.
The boundaries for the grid were determined by executing the ERAD code using estimated
extreme values for the boundaries to ensure capture of the 0.1 rem values. A simple screening
code was written to examine the ERAD output and the minimum and maximum grid values were
reassigned as necessary. The screening code also provided diagnostics if the original grid did
not capture the 0.1' rem values. The ERAD code was then executed again using the new
minimum and maximum grid boundaries. In all cases, the maximum downwind distance was set
at 80 km. This downwind distance relates to the methods described in Reference 11.
2.2 Pantex Meteorological Data
Fourteen sets of meteorological data were generated for the Pantex site to represent conditions
that range from very unstable to very stable. Each meteorological condition has an associated
frequency of occurrence and a set of 36 downwind directional frequencies based on observed
data. Each directional frequency covers a ten-degree segment of the total 360 degrees possible.
2.3 Population Data
The 1990 Census Bureau population data was used in this analysis. Urban population cells (with
at least 25,000 persons) as well as rural cells were used. The rural cells were assigned radii of
1.0 km to model small communities.
                                      -6-
section                                 I-6
 2.4 Health Effects
A FORTRAN computer code, PROCON, was written to convert the grid of ERAD calculated
values of time-integrated Pu concentrations from mass units to 50-year, whole-body inhaled
doses. The doses were assumed to be constant for each cell in the rectangular grid and were
integrated with population data to obtain estimates in terms of person-rem. The integration
routine was written to be independent of cell width, cell length, and population cell radius.
To estimate the health effects for the pit storage scenarios described in Section 3, fourteen
meteorological conditions representing stable to unstable conditions were used with ERAD to
produce 14 grid maps containing time-integrated airborne concentrations or doses.
For each grid map, downwind centerline peak dose curves were generated and weighted by the
frequency of occurrence of each meteorological condition. At each range of interest, the doses
were ranked with their meteorological frequencies, and estimates were made of the expected,
50%, and 95% downwind centerline dose.
Each of the 14 grid maps was integrated with the population density at one-degree intervals, for
a total of 360 integrations. The average values were calculated every ten degrees to coincide
with the 36 wind-directional frequencies. The frequency of the wind blowing in a certain
direction under a particular meteorological condition was calculated by multiplying the
downwind direction frequencies with the meteorological frequencies. The person-rem values
were then ranked to generate cumulative distribution curves. This data was then used to obtain
the expected, 50th, and 95th percentile LCF values for ranges from 0 to 16 km and 0 to 80 km.
 3. Scenarios
Two different pit storage scenarios that could potentially l eadto Pu release and transport offsite
by the wind have been identified. These scenarios should be considered as bounding cases that
could expose the public to maximum amounts of Pu particulate.
The scenarios postulate an aircraft crash and fire that results in the release of Pu from pit
containers in a Zone 4 magazine. It is postulated that an aircraft impacts and collapses the
magazine, and subsequently, damages a portion of the stored pit containers. The impact by the
aircraft is accompanied by a fuel spill and fire.
In order to determine the consequences of this type of Pu fire, it is necessary to make a
conservative estimate of the number of pit containers that will be damaged and the amount of Pu
that will be at risk. It is assumed that 25% of the Pu pits are involved in' the release. This was
discussed in more detail in Section 1. Based on current understanding [12], it is assumed that in
a fire 0.05% of the Pu at risk is released in respirable form.
                                      -7-
section I                               I-7
   The release from a fire is modeled using the ERAD code: An energy source of 10 lbs of TNT is
   used to generate the cloud into which the Pu is injected. This is considered to be conservative in
   that the Pu is released instantaneously, while in a fire, even of short duration, the release is
   spread over time.
   Case 1 is based on a quantity of pits. This case is representative of what would be obtained if
   the average amount of Pu per pit were stored in each magazine. The information in this case
   could provide insight for determining administrative controls for limiting the amount of Pu in
   each magazine if limits arc necessary.
   Case 2 is based on the maximum number of pit containers a SAC magazine can accommodate
   and the type of pit with maximum amount of Pu stored.
   4. Assumptions and Parameter Values
   The assumptions for these calculations are intended to provide maximum bounding case
   expected values; therefore, parameter values were chosen as upper bound point estimates. For
   the Pu fire cases, the respirable amount of Pu was taken as 0.05% [12].
   New understandings of health effects have developed and new interpretations of the data have
   occurred [13]. As noted in Reference 13, the dose conversion factor from person-rem to
â  expected LCF has recently undergone changes. Current values range from a committed effective
   dose equivalent (CEDE) of 1 LCF/4000 person-rem to 1 LCF/1250 person-rem. For this set of
   calculations, a CEDE value of 1 LCF/2000 person-rem is used.
   An airborne particulate integration boundary dose of 0.1 rem is used. The output option of the
   ERAD code used in this study produces results in units of ug-sec/m3 that must be converted to
   rem CEDE. An integration threshold boundary value of 10.2 ug-sec/m3 approximates to 0.1 rem
   on the basis of the following factors:
         3.3 x 10E-4m3/s standard man-breathing rate (light activity) [14]'
         0.085 Ci/g-Pu calculated for 10-yr-old Pu-239 [15]
         an inhalation dose at 50 years of 350 rem/uCi [16] was used and corresponds with the
         current value of 330rem/uCi [17]. These values are based on a 1 u activity mean
         aerodynamic diameter (AMAD).
     Other assumptions made in performing the calculations are:
         sheltering is not considered
         resuspension of radioactive materials is not considered
                                      -8-
Section I                               I-8
      the only pathway considered for estimating health effects is through inhalation
      only 10 year old Pu-239 is analyzed
      all the respirable material is released instantaneously
      no changes in wind direction or meteorological conditions occur during the time of cloud
      movement out to 80 km.
The net effect of these assumptions is to obtain results that tend to overpredict both the
individual dose values and the integrated population dose.
5. Results
At the beginning of this study, preliminary results were obtained by calculating doses in larger
grid cells than those calculated in this report. The preliminary results were submitted to DOE
[1] and are discussed in Section 6. This report deals only with subsequent results obtained using
smaller grid cells. All values are rounded to 1 or 2 significant figures as is appropriate for the
precision of input information available here.
Table 1 contains peak dose values at the nearest site boundary (2.2 km) and beyond (>2.2 km).
The expected, 50th percentile, and 95th percentile values are reported.
                      Table 1. Downwind Centerline Doses
Case                  Doses at Site Boundary             Peak Offsite Doses
                     Exp.   50th    95th                Exp    50th  95th
 1                     2       3       4                  2       3     4
 2                     4       5       7                  4       5     7
Table 2 contains LCFs for the two cases studied. Again, the expected, 50th percentile, and 95th
percentile values are provided for the 0 to 16 km radius around the plant and also for the 0 to 80
km radius.
                                      -9-
section I                               I-9
                       Table 2. Latent Cancer Fatalities
Case               0- l6 Km Radius                 0-80 Km Radius
                   Exp 50th 95th                 Exp    50th' 95th
 1                 0.01   0     0.1              0.4    0.01   1.4
 2                 0.02   0     0.2              0.8    0.05   4
Using the bounding case estimate of Pu in the accident, the expected or mean 50-year LCF value
for the affected area within i6 km radius is 0.02. The 50th percentile or median value is 0 and
the 95th percentile value is 0.2.
For this bounding case, the expected or mean 50-year LCF value for the affected area within 80
km radius is 0.8. The 50th percentile or median value is 0.05 and the 95th percentile value is 4.
The expected 50-year peak offsite dose (>2.2 km) is 4 rem. The 50th percentile value is 5 rem;
the 95th percentile value is 7 rem.
6. Discussion of Preliminary Results
For each of the scenarios described in Section 3, the ERAD code was used to estimate the
amount of radioactive materials that would be dispersed after a postulated aircraft crash into a
storage magazine at the Pantex Plant in Amarillo, Texas. As a first step in using `the code, the
area surrounding the plant was divided into areas of interest, called cells Cell size as well as a
number of other factors including the amount of material dispersed, particle size distributions,
weather and meteorological conditions, and atmospheric dispersion phenomena were used by
ERAD to obtain a value for the average amount of radioactive materials present in each cell.
One of the outputs from the ERAD code is the time integrated airborne concentrations of the
respirable size particulate. Average values are reported in physical units of microgram-seconds
per cubic meter and are tracked in a user defined rectangular coordinate system. Distance from
the accident location zero is measured in meters, using an X-Y coordinate system. The Y-axis is
the crosswind direction and the X-axis is the downwind direction. The accident location is -
defined as (0,0). The preliminary determinations of radioactive materials present in the area
surrounding the Pantex Plant were calculated using a large cell size and a 100 x 100 cell grid.
The ERAD code, written for a 40 x 40 grid. was modified to accommodate a larger affected
area. The boundaries for the grid were determined by executing the ERAD code two times. The
first execution used estimated extreme values for the boundaries to insure capture of the 0.1 rem
(CEDE) values. The ERAD output was examined and reassigned the minimum and maximum
values of the grid as necessary. The ERAD code was then executed a second time using the new
minimum and maximum grid boundaries. In all cases, the maximum downwind distance was se
at 80 km.
                                     -10-
section I                               I-10
To simulate a fire scenario, using the ERAD code, an estimate of the amount Pu released in the
fire and an energy source to represent the fire are necessary. At the time of preliminary
evaluation, the maximum number of pits involved in' a Pu release was assessed incorrectly. The
preliminary results as reported to DOE [1] used inappropriate source terms and cell size, to
calculate the consequences of Pu released in a fire. The preliminary results wcre in error. The
results as presented in this memo supersede the preliminary results.
7. Summary and Conclusions
The Department of Energy Albuquerque Field Office (DOE/AL) requested that Sandia National
Laboratories/New Mexico determine the radiological consequences from an aircraft crash into an
MR or SAC magazine containing stored Pu pits in Zone 4 of the Pantex Plant: This memo
summarize in an unclassified form the requested information. It further desc rib es' the methods'
used in quantifying the highest anticipated source term and documents the cloud transport model
and the important parameter values used to obtain the results. Data to support the analysis are
abstracted from formal and informal reports. Results from the analysis consist of distributions of
dose and health effects from site boundary to 16 km and 80 km from the boundary.
Major conclusions are:
        For the upper limit of source term release from fire scenarios, the peak offsite doses
        have an estimated expected value of 4 rem and 95% of the peak doses calculated are 7
        rem. Estimated increase in LCFs within a radius of 16 km from the site has a mean of
        0.02 and 95% of the LCFs are calculated to be less than 0.2 persons. The increase in
        LCFs to a radius of 80 km from the site has an expected value of 0.8 and 95% of the
        LCFs are calculated to be 4 persons.
        The total population in the ten-mile radius is about 3800. Based on SEN-35-91 [18],
        the risk can be compared to the criteria by calculating the sum of the product of credible
        scenario probabilities multiplied by the expected LCFs for each scenario divided by the
        total population and then comparing this value with two-in-a-million that is the implied
        SEN-35-91 criterion for individual LCF maximum allowable risk. Given a scenario
        probability bounded by one-in-a-million, an LCF value of .02, and a population of 3800
        yield a value of 6x l 0E-12. This value is more than five orders of magnitude less than the
        allowable maximum risk. Thus, the contribution to the overall risk, according to the
        criteria given in SEN-35-91, from these operations is negligible.
        No early fatalities due to radiation exposure are expected from the Pu fire cases studied.
        No attempt was made to address what positive measures could reduce the risk, how
        much thc risk could be reduced, and what costs would be involved.
                                     -11-
section I                               I-11
References
1  R. E. Smith (SNL/333) Memorandum to D. E. Rossen (DOE/AL). Subject: Consequence
   Analysis for Pantex Environmental Assessment. October 15, 1992.
2  Final Safety Analysis Report, Pantex Pl ant, Zone 4 Magazines (Storage and Interim Storage
   for Nuclear Weapon and Components), Amarillo, Texas, Mason & Hangar-Mason Co.,
   December, 1992.
3  Final Environmental Impact Statement, Pantex Plant Site, Amarillo, Texas, US Department
   of Energy, Amarillo, Texas, October, 1983.
4  R K. Thomas (SNL/1544), Memorandum to R E. Smith (SNL/7233), Subject:
   Consequence of Aircraft Impact with Earth Covered Building, June 18,1991.
5  R K. Thomas (SNL/1562) Memorandum to R. E. Smith (SNL/333). Subject: Additional
   Data on Consequences of Aircraft Impact with Earth-Covered Buildings, May 21,1992.
6  E. P. Chen (SNL/1562) Memorandum to R. K.Thomas (SNL/2562). Subject: Steel Cylinder
   Impacting Soil-Covered Concrete Target, May 13,1992.
7  R K. Thomas (SNL/1 562) Memorandum to R E. Smith (SNL/333). Subject: Aircraft
   Impact with Pantex Steel Arch Construction (SAC) Building, December 10, 1992.
8  E. P. Chen (SNL/1562) Memorandum to R. E. Smith (SNL/333). Subject: Steel Cylinder
   Impacting Soil-Covered Corrugated Target, November 25,1992.
9  T. I. McSweeney and J. T.Johnson, An Assessment of the Risk of Transporting Plutonium
   Dioxide by Cargo Aircraft, BNWL-2030, Battelle Pacific Northwest Laboratories, Richland,
   Washington, June 1977.
10 B. A. Boughton and J. M. DcLaurentis, Description and Validation of ERAD: An
   Atmospheric Dispersion Model for High Explosive Detonations, SAND 92-2069 (SNL: -
   Albuquerque, NM), October, 1992.
11 J. C. Elder, et al., "A Guide to Radiological Accident Considerations for Siting and Design of
   DOE Nonreactor Facilities," LA-10294-MS, Los Alamos National Laboratory, January 1986
12 J. M. Haschke, Evaluation of Source-Term Data for Plutonium Aerosolization. LA- 12315-
   MS, Los Alamos National Laboratory, Los Alamos, NM, July 1
13 Committee on the Biological Effects of Ionizing Radiations, Board on Radiation Effects
   Research, Report, Health Effects of Exposure to Low Levels of Jonizing Radiation - BEIR V
                                     -12-
section I                               I-12
   Commission on Life Sciences, National Research Council, Washington, DC, National
   Academy Press, 1990.
14 ICRP 1974: "Report of the Task Group on Reference Man, "International Commission on
   Radiological Protection Report ICRP 23 (1974).
15 Chart of the nuclides, Thirteenth Edition, General Electric Company, 1983.
16 D. E. Dunning, Estimates of internal Dose Equivalents from Inhalation and Ingestion of
   Selected Radionuclides, WIPP-DOE-176, Rev. 1, Evaluation Research Corporation.
17 Internal Dose Conversion Factor for Calculation of Dose to Public (US DOE Assistant 
   to Secretary for Environment, Safety, and Health), Washington, DC, July 1988.
18 Nuclear Safety Policy Notice, SEN-35-91, US Department of Energy, Washington, DC,
   Secretary of Energy, September9, 1991.
Copy to:
  300 R. L. Schwoebel
  331 S. D. Spray
  333 R. E. Smith
  5407 P. A. Longmire
                                      -13-
Section I                              I-13
                      MEMORANDUM DATED APRIL 30, 1993
                         ATTACHMENT TO APPENDIX I
                                                                Sandia National Laboratories
                                                                Albuquerque, New Mexico 87185
date:     April 30, 1993
to:       Dave Rosson, Jr., DOE/AL
from:     Y. T. Lin, N. R. Grandjean, and R. E. Smith, 0333
Subject:  Plutonium Dispersal Deposition Area Estimates of a Hypothetical Aircraft Crash Into
          Pantex Zone 4
Department 0333 was requested by DOE/AL to continue the consequences analysis resulting from
a hypothetical aircraft crash into a Zone 4 magazine. Previously, the health effects were reported
in terms of whole body rem and latent cancer fatalities. This memo documents the estimates of 
the deposition area for bounding case scenario as previously reported[1, 2].
Previous studies have used 14 sets of meteorological data (A to N) for the Pantex site to
represent various meteorological conditions. Each meteorological condition has an associated
frequency of occurrence and a set of 36 downwind directional frequencies based on observed
data. Each directional frequency covers a ten-degree segment of the total of 360 degree possible
[2, 3]. The meteorological conditions, the frequencies of occurrence and the wind directional
frequencies used in this analysis are the same as those previously used to estimate the health
effect calculations in reference 1 and 2. Attachment A lists these 14 sets of data.
The source term for this study is the same as in the Case 2 pit storage fire scenario listed in
Attachment B-2 of Reference 2. The aerosolization release fraction used for this analysis is one
percent of the total exposed Pu material; and the respirable amount of the Pu aerosol is taken as
0.05%[4]. This number represents what was believed by experts as an upper bound estimate at the
time of the study[1]. The release from a fire modeled using ERAD code. An energy source of
10 lbs of TNT is used to generate the cloud into which the Pu is injected. This is conservative in
that the Pu is released instantaneously, while in a fire, even of short duration, the release is spread
over time. The reader should be cautioned that the results are sensitive to the particle size
distribution which is a function of various parameters and could change (likely be reduced with
new data). The results from the ERAD simulations are documented in Reference 2. Plots of the 
deposition contour for each of the 14 meteorological conditions were developed and are illustrated
in Attachment B.
Section I                                   I-17
The Environmental Protection Agency (EPA) proposed guidance on dose limits for person exposed
to transuranium elements[5] suggested that a soil contamination level of 0.2 micro curie per square
meter would establish a reasonable "screening level" for cleanup purpose. Table 1 summarizes
the area that needs to be evaluated using the EPA screening level and the frequency of occurrence for
the 14 meteorological conditions. The average area that needs to be evaluated around Pantex is 54
square kilometers. The median or 50 percentile area that needs to be evaluated is 58 square
kilometers; and the 90 percentile are that needs to be evaluated is 64 square kilometers.
                Table 1. Summary of the Area That Needs to be Evaluated Around Pantex Area.
                                                        Frequency of                   Area
      Meteorological Conditions                     Occurrence (in percent)         (in sq. km)
      -------------------------                     -----------------------         -----------
                 A                                          0.6531                      41
                 B                                          2.8204                      75
                 C                                          3.2162                      45
                 D                                          6.4720                      36
                 E                                          6.5809                      48
                 F                                          5.1361                      55
                 G                                         18.1296                      47
                 H                                          7.3231                      64
                 I                                          8.4117                      59
                 J                                         12.4790                      64
                 K                                          8.1148                      59
                 L                                          8.6987                      58
                 M                                          9.5596                      63
                 N                                          2.4048                      49
                                                           -------
                                                          100.00
Three geographical areas near the Pantex plant are of primary concern. The city of Amarillo located 
west-southwest from Pantex; Lake Meredith located north-northwest from Pantex; and the fifty foot
unsaturated zone area [6] located south-southwest from Pantex. A map of the Pantex area [7] is
shown in the Attachment C. Due to time and resource constraints the actual intersection of the 
deposition area with these areas of interest was not calculated. The results reported in this memo are
total area that needs to be evaluated in the sector or segment that contains the area of interest. The
values given are, therefore, calculated upper bounds of the area that needs to be evaluated based on
the 14 meteorological conditions and the frequencies of the wind direction downwind towards the 
areas of interest. 
Table 2 summarizes the area that needs to be evaluated and the frequencies of the wind direction
downwind toward the sector containing Amarillo. The city occupies only a portion of the sector in the
downwind direction between 215 and 265 degree clockwise. The assumption of using the total
deposition areas for each meteorological condition instead of the deposition area intercepted by the
city boundary is very conservative. However, the estimates provide an upper bound calculation.
The chance of depositions occurring in the sector containing Amarillo is about 15%.
Section I                                         I-18
         Table 2. Summary of the Area That Needs to Be Evaluated in the Sector Containing Amarillo
         Meteorological     Area                              Frequency of Occurrence (in percent)
         Conditions      (in sq. hn)                          Downwind Direction (degree from North)
						                                                                         Sub-Total
                                           2lS      225     235      245     255	 265        (in percent)
           A                41	         0.0026	 0.0046	  O.0066   0.0085  0.0098  0.0243	      0.0564
           B                75	         0.0881	 O.0400	  0.0243   0.0380  0.0405  0.0344	      0.2652
           C                45	         0.1617	 0.0973	  0.0644   0.0672  0.0260  0.0219	      0.4386
           D                36	         0.400S	 0.2424	  0.1313   0.1144  0.0707  0.0438	      1.0003
           E                48	         0.3717	 0.1454	  0.1131   0.1454  0.2020  0.0727	      1.0504
           F                55	         0.2003	 0.2699	  0.2264   0.4267  0.1480  0.0784	      1.3497
           G                47	         1.1239	 0.9132	  0.8991   0.4496  0.2248  O.2248	      3.8354
           H                64	         0.3691	 0.2768	  0.2399   0.0554  0.0369  O.O554	      1.0334
           I                59	         0.6547	 0.3791	  0.1838   Q.0574  0.0689  0.0345	      1.3784
           J                64	         O.S745	 0.3018	  0.4759   0.278S  0.0929  0.1160	      1.8396
           K                58	         0.1502	 0.1871	  0.2041   0.1069  0.0992  0.0454	      0.8928
           L                58	         0.1198	 0.1651	  0.1837   0.1678  0.0772  0.0799	      0.7935
           M                63	         0.0961	 0.1441	  0.2191   0.2477  0.1966  0.1636	      1.0672
           N                49	         0.0437	 0.0400	  0.0486   0.0486  0.0480  0.0486	      0.2774
                                                                                   ---------------------
         						                                                   Total         15.28
         
         Similarly, the area that needs to be evaluated and the frequencies of the wind direction downwind
         toward Lake Meredith is summarized in the Table 3. The lake area is a small portion of the sector
         between the downwind direction from 215 to 265 degrees clockwise. The chance of depositions
         occurring in the sector containing Lake Meredith is about 28%.
         Table 3. Summary of the Area That Needs to Be Evaluated in the Sector Containing Lake Meredith
   Meteorological   Area                        Frequency of Occurrence (in percent)		         	         	
   Conditions     (in sq. hn)	                Downwind Direction (degree from North)       Sub-Total
                                   295    305    315    325    335   345     355		5    (in percent)
         A           41	         0.0301 0.0360 0.0321 0.0249 0.0190 0.0203 0.0295 0.0177        0.2097
         B           75	         0.0400 0.0531 0.0719 0.0784 0.1063 0.1159 0.1468 0.2065        0.8189
         C           45	         0.0219 0.0302 0.0260 0.0348 0.0973 0.0864 0.1288 0.2577        0.6867
         D           36	         0.0404 0.0438 0.0707 0.0909 0.1447 0.1818 0.2996 0.3602        1.2319
         E           48	         0.0404 0.0404 0.0808 0.1374 0.1616 0.1212 0.2343 0.3232        1.1393
         F           SS	         0.0784 0.0610 0.0261 0.0784 0.0871 0.1045 0.2351 0.2525        0.9231
         G           47	         0.1124 0.1545 0.3231 0.2529 0.3934 0.5479 0.6884 0.8149        3.2875
         H           64	         0.0001 0.1107 0.3875 0.2030 0.2399 0.1845 0.2030 0.6090        1.9377
         I           Sg	         0.0804 0.1723 0.3561 0.2872 0.4365 0.4135 0.6432 0.4595        2.8486
         J           64	         0.1973 0.2785 0.3l34 0.3772 1.0736 1.0271 0.8240 0.7196        4.8107
         K           58	         0.1077 0.2069 0.2806 0.4223 0.70S8 0.7625 0.6009 0.5924        3.6791
         L           58	         0.1012 0.1651 0.2104 0.4234 0.5059 0.6231 0.0687 0.6204        3.7182
         M           63	         0.1606 0.2206 0.3167 0.3692 0.3362 0.3722 0.5794 0.7114        3.0664
         N           49	         0.0326 0.0308 0.0474 0.0517 0.0560 0.0781 0.1009 O.1150        0.5123
                                                                                               -------
	                                                                                     Total 27.87
        Section I                                    I-19
         Finally, the area that needs to be evaluated and the frequencies of the wind direction downwind toward
         the 50-ft unsaturated zone area is summarized in the Table 4. The area is in the sector of the downwind
         direction from 175 to 225 degree clockwise. The chance of depositions occurring in thc sector
         containing thc 50-ft unsaturated zone area is about 29%.
         Table 4. Summary of the Area That Needs to Be Evaluated in the Sector Contain1ng 5-ft Unsaturated Zone
         	                           Frequency of Occurrence (in percent)			         		         	         
      Meteorological    Area	         Downwind Direction (degree from North)	    Sub-Total
      Condition      (in aq. km)	   175    18S    195    205    215    225     (in percent)
          A             41	         0.0210 0.0170 0.0111 0.0098 0.0026 0.0046	   0.0662
          B             75	         0.0688 0.1184 0.1367 0.1260 0.0881 0.0400	   0.5780
          C             45	         0.0548 0.2042 0.2001 0.1631 0.1617 0.0973	   0.8814
          D             36	         0.1447 0.4073 O.S789 0.4039 0.4005 0.2424	   2.1778
          E             48	         0.1454 0.3959 0.9131 0.6222 0.3717 0.14S4     2.S937
          F             55	         0.0435 0.2003 0.4964 0.5486 0.2003 0.2699     1.7590
          G             47	         0.4496 1.3909 2.7958 2.3181 l.l238 0.9132	   8.9914
          H             64	         0.0923 0.7935 0.8858 0.9042 0.3691 0.2768	   3.3217
          I             59	         0.0919 0.4709 0.8960 0.6662 0.6547 0.3791	   3.1588
          J             64	         0.1625 0.4817 0.4759 0.7254 0.5745 0.3018	   2.7216
          K             58	         0.0624 0.2778 0.1842 0.1814 0.1502 0.1871	   1.0431
          L             58	         0.0746 0.2050 0.2024 0.1465 0.1198 0.1651	   0.9134
          M             63	         0.0765 0.1621 0.1891 0.1936 0.0961 0.1441	   0.8615
          N             49	         0.0424 0.0387 0.0492 0.0461 0.0437 0.0400	   0.2602
                                                                                  -------
																	Total         29.33
         Table 5 Summary of the Cumulative Frequency of the Area That Needs to Be Evaluated
                                           Cumulative Frequency
                                                     Lake	         50-Ft
         Area          Around	      Amarillo     Meredith        Unsaturated
      (in sq. km)      Pantex	      Sector	   Sector          Zone Sector
         35.8            6.5           6.6	        4.4	             7.4
         40.7            7.1           6.9	        5.2	             7.7
         44.i           10.3           9.8	        7.6	            10.7
         46.5           28.5          34.9	       19.4	            41.3
         48.3           3S.1          41.8	        3.5	            50.2
         48.5           37.5          43.6	       25.4	            51.0
         54.6           42.6          52.4	       28.7	            57.0
         57.5           50.7          58.3	       41.9	            60.6
         58.3           59.4          63.5	       51.6	            63.7
         58.5           67.8          72.5	       61.9	            74.5
         62.6           77.4          79.5	       72.9	            77.4
         63.7           89.9          91.S	       90.1	            86.7
         63.9           97.2          98.3	       97.0	            98.0
         75.1          100.0         100.0	      100.0	           100.0
         Section I                     I-20
         Table S summarizes the normalized cumulative frequency of the area that needs to be evaluated for the
         area of primary concern The median or 50 percentile area that needs to be evaluated is about 48 to 58
         square kilometer; and the 90 percentile area that needs to be evaluated is 64 square kilometers for
         all the area of primary concern. In other words, 50% of the time the area that needs to be evaluated is
         about 48 to 58 sq. km or less; and 90% of the time the area the needs to be evaluated is 64 sq. km or
         less. The deposition are which need to be evaluated are reported here as the bounding case
         calculatio.
         References
         1. R E. Smith (SNL/0333) Memorandum to David E Rosson Jr (DOE/AL/WMOSD), Subject:
            Plutonium Dispersal Consequence Analysis of Hypothetical Aircraft Crash into Pantex Zone 4,
            December 11, 1992.
         2. Y. T. Lin, N.R. Grandjean. and S. A. Kalemba (SNL/0333) Memorandum to R E. Smith (SNL/0333),
            Subject: Pantex Zone 4 Consequence Analysis Source Data, UCNI, Memo, December 21, 1992.
         3. This reference is removed for classification purposes.
         4. J. M. Haschke, Evaluation of Source-term Data for Plutonium Aerosolization, La-12315-MS, July 1992,
            Los Alamos National Laboratory. Los Alamos, N.M.
         5. Proposed Guidance on Dose Limits for Persons Exposed to Transuranium Element in the General
            Environment, EPA 520/4-77-016, U. S. Environmental Protection Agency, September, 1977.
         6. H. J. Turin, I. R. Triay, W. R Hansen, and W. J. Wenzel, "Potential Ogallala Aquifer Impacts of a
            Hypothetical Plutonium Dispersal Accident in Zone 4 of the Pantex Plant", November, 1992, Los
            Alamos National Laboratory, Los Alamos, N. M.87545
         7. Final Environmental Impact Statement, Pantex Plant Site, Amarillo, Texas, U. S. Department of
            Energy, October, 1983.
         0333 File - Zone 4 EA, P-2B
         Secbon I              I-21
Table (Page I-22 Attachment A: The Frequencies of the Downwind Direction for Various Meteorological Conditions)
Figure (Page I-23 Attachment B: The disposition Contours of the Meteorological Condition A)
Figure (Page I-24 Attachment B: The disposition Contours of the Meteorological Condition B)
Figure (Page I-25 Attachment B: The disposition Contours of the Meteorological Condition C)
Figure (Page I-26 Attachment B: The disposition Contours of the Meteorological Condition D)
Figure (Page I-27 Attachment B: The disposition Contours of the Meteorological Condition E)
Figure (Page I-28 Attachment B: The disposition Contours of the Meteorological Condition F)
Figure (Page I-29 Attachment B: The disposition Contours of the Meteorological Condition G)
Figure (Page I-30 Attachment B: The disposition Contours of the Meteorological Condition H)
Figure (Page I-31 Attachment B: The disposition Contours of the Meteorological Condition I)
Figure (Page I-32 Attachment B: The disposition Contours of the Meteorological Condition J)
Figure (Page I-33 Attachment B: The disposition Contours of the Meteorological Condition K)
Figure (Page I-34 Attachment B: The disposition Contours of the Meteorological Condition L)
Figure (Page I-35 Attachment B: The disposition Contours of the Meteorological Condition M)
Figure (Page I-36 Attachment B: The disposition Contours of the Meteorological Condition N)
Figure (Page I-37 Attachment C: A Map of the Pantex Plant Region)

Part J

                                                  Sandia National Laboratories
                                                  Albuquerque, New Mexico 87185
  date: August 3,1993
   to: D.E. Rosson, Jr., DOE/AL
  from: Y. T. Lin, J. L. Tenncy, and R. E. Smith, SNL/0333
subject: Vulnerability of Zone 4 Magazines to Impact by General Aviation Single Engine Aircraft
         This study supports the DOE/AL. and DOE/DP6.2 by providing an independent
      assessment of Section E.2.4 in the Environmental Assessment (EA) for Interim Storage of
      Plutonium Components at Pantex [1]. One potentially credible scenario identified in the EA
      is an aircraft crash into any magazine in Zone 4. The general aviation aircraft crash rate has
      been identified as the most dominant factor because of the large number of such flights near
      Pantex. We were asked to perform an independent validation concerning the approach taken
      in the EA to identify the number of general aviation single-engine aircraft having potential to
      damage the magazines such that subsequent plutonium release may be possible. In our study,
      we have estimated the crash frequencies for general aviation single-engine aircraft away from
      an airport as a function of aircraft weight, airspeed at impact, and impact angle. We then
      assessed the frequency of single-engine aircraft accidents that exceeded the threshold of
      magazine collapse. These calculations provide: an alternative method to the assessment in the
      EA by considering aircraft weight, e crash velocity, `angle variability versus average
      stall/impact velocities, and aircraft weights.
         Crash frequencies were estimated from the National Transportation Safety Board (NTSB)
      Aviation Accident/Incident Factual Report database. The NTSB database was queried to
      determine the fraction of the accidents that exceed the threshold for magazine collapse. The
      threshold in terms of weight and impact velocity was derived from Appendix C.8 of the
      FSAR [2] and a recent study[3]. With this information, the conditional impact probability for
      general aviation can be calculated and compared to the somewhat simpler approach of the
      EA.
         Currently, in our NTSB database there are 19,723 total aircraft accident records listed
      from 1983 through 1990. There is no convenient method to filter out the general aviation
      aircraft from air taxis, commuters, and air carriers because the same plane can fly under
      different registrations and regulations. We can, however, filter the single-engine aircraft data
      by using the number of engines listed in the NTSB data fields. We decided to use all single-
      engine aircraft less than l2,500 lbs weight category (small size) to represent single-engine
      general aviation aircraft. Next, single-engine aircraft destroyed or substantially damaged in
      an accident were retrieved for our study. This left 2,581 aircraft accidents for evaluation (787
      aircraft had substantial damage; 1794 aircraft we ere destroyed). A list of these accidents is
      presented in Attachment 1.
  Section J                               J-1
    Another filter applied in our study was the accident distance from the airport. Accident
distance is defined as the distance from the aircraft crash site to the center of the closest
airport. The closest airport is not necessarily the origin or destination airport. Of the 2,581
cases, F 52 were located greater than 5 mi. from the closest airport. These 152 accidents
representing the general aviation single-engine inflight accident scenario are tabulated in
Table 1. A summary of single-engine aircraft crashes inflight is tabulated in Table 2 as a
function of aircraft weight and airspeed at impact.
    An aircraft impacting a magazine may result in the collapse of the structure due to total
loading created by the aircraft or penetration of the magazine due to massive aircraft parts
such as engines. Previous analyses indicated that collapse is the most credible scenario for
small aircraft. The analyses presented in reference [2] indicate that single-engine aircraft
may have the ability to collapse an MR or a SAC magazine provided that the combination of
mass and speed is sufficiently great. Table 3 shows composite aircraft combinations of
weight and speed that have the potential to collapse either the MR or the SAC magazine at
90 degree impact angle (a vertical impact into the top of the magazine). Using these values,
the number of inflight single-engine aircraft accidents in which the combination of weight
and impact speed exceeded this threshold (shown as ### in the Table 2) were counted. Of
152 accidents, 46 are above the threshold. .
    Preliminary study of the 46 accidents above the threshold revealed that 19 had records on
the actual impact angle. Of these 19 accidents, only two had a flight path angle greater than
45 degrees. A threshold of 45 degrees impact angle was selected to filter out crashes
sufficiently different from a direct vertical impact into a magazine so as not to result in a
magazine collapse. Since a data set of 19 incidents is relatively small, we checked the larger
set of the 152 single-engine aircraft accidents greater than five miles from an airport. From
these 152 accidents, 46 had kinematics impact angle data and seven of these 46 exceeded 45
degrees. This gives a ratio 7/46=. l 5 instead of 2/1 9=. 11 for aircraft impact angles greater
than 45 degrees. Further investigation of the larger set of 2581 single-engine aircraft
accidents with aircraft destroyed or substantially damaged indicates that 1135 accidents had
impact angles listed, and 277 of these 1 l35 exceeded 45 degrees. These simple statistics
indicate that only a fraction of the accidents would be expected to have the conditions
sufficient to collapse a magazine. These flight path angle distributions are summarized in
Table 4.
Section J                                J-2
        Table 1 - Brief Listing of Inflight Single-Engine Aircraft Accidents
   NTSB NBR     AIRCRAFT_WGT AIRSPEED_IMPAC FLT_PATH_ANGL   DISTANCE_AIRPO  AIRCRAFT_DAMA
  ANC83FA122            43             3          10              10              4
  ANC83FA126          3000             3           O               6              3
  ANC83FA152          3320             6           O              15              4
  ANC83FAA07           900             6           9              15              4
  ANC83FA176          2050             4           3              75              3
  ATL83FA117          2550             7           5               6              4 
  ATL83FA129          2950             0           3               6              4
  ATL83FA161          2800             8           2              15              4
  ATL83FA176          3325             8           3              20              4
  ATL83FA198          3600             0           0              25              4
  ATL83FA340          3800             6           0              12              3
  ATL83FKG11          4000             5           0              12              3
  ATL83FU006           517             2           0              6               3
  ATL84AA053          3600             0           3              7               4
  ATL84FA028          3600             8           0              8               4
  ATL84FA068          2300             7           3              9               4
  ATL84FA075          2740             4           0             17               4
  ATL84FA088          4000             6           0              7               4
  ATL84FA106          3600             7           4              6               4
  ATL84FA060          2200             6           0             10               4
  ATL84FA071          2300             4           0             25               3
  ATL84FA080          1950             5           0              9               4
  CHI83FA334          2550             8           5             12               4
  CHI83FA366          3272             0           0              8               4
  CHI83FA407          1670             3           0              7               4
  CHI84AA016           925             7           0              8               4
  CHI84FA073          2500             8           0              8               4
  CHI84FA282          3350             5           0             20               4
  DEN83FA122          3200             1           0             45               3
  DEN83FA203          1500             5           0             25               4
  DEN83FA222          1750             5           2             13               4
  DEN83FTE12          2900             5           0              8               3 
  DEN83FTM05           550             3          11             25               3 
  DEN84FA011          2550             0           2             28               4
  DEN84FA106          4850             2           0             20               3
  DEN84FA142          2100             0           0             10               3
  DEN84FA144          2450             3           0             15               4
  DEN85FA035          2800             6           0             15               4
  FTW83FA134          2550             4           3             10               4
  FTW83FA144          2150             7           3              8               4
  FTW83FA222          2200             6           8             11               4
  FTW83FA226          2800             4           0             10               4
  FTW83FA311          2450             2           0             10               4
  FTW83FA343          1670             3           0              7               4
  FTW83FA361          2900             9           3             19               4
  FTW83FA373          2500             8           0             10               4
  FTW84FA060          1670             6           0              9               4
  FTW84FA102          2850             0           0             10               4
  FTW84FA121          3600             6           0              9               3
  FTW84MA069          4000             8           0              8               4
  FTW85FA084          3600             6           0             35               4
  LAX83FA455          2150             5           0             12               4
  LAX83FUJ12          2650             5           0             10               3
  LAX83FVG10          1650             0           0              8               4
  LAX83LUQ01          1670             6           0             45               4
  LAX84FA032          1450             1           0             12               3
  LAX84FA047          2300             7           8             23               4
  LAX84FA055          1700             6           0             11               4
  LAX84FA444          3800             4           0             63               3
  LAX85FA048          2300             6           7             7                4
  LAX85FA086          2300             7           0             9                4
  LAX85FA093          2950             9           0             8                4
  Section J                               J-3
Table 1 - Brief Listing of Inflight Single-Engine Aircraft Accidents (continued)
     NTSB NBR      AIRCRAFT_WGT  AIRSPEED_IMPAC  FLT_PATH_ANGL  DISTANCE_AIRPO  AIRCRAFT_DAMA
   LAX85FVW01            1600             2             0           12            3
   MLA85FA038            3900             4             0           16            4
   MKC84FA262             790             0             0           10            3
   NYC83FA085            2750             7             0           10            4
   NYC83FA086            3800             3             0            6            3
   NYC83FA087            3600             8             0            8            4
   NYC83FA091            2300             7             0           16            4
   NYC83FA107            2800             7             2            7            4
   NYC83FA125            1950             7             0            7            4
   NYC83FA187            2400             7             0           10            4
   NYC83FA242            3600             0             0            6            4
   NYC83FHA03            2000             0             0           13            3
   NYC84FA269            4118             0             0           10            4
   NYC84FGM01            2325             0             7           10            4
   SEA83FA037            4000             8             3            7            4
   SEA83FYA02            1650             6             0           10            3
   SEA84FA015            1600             4             0           14            4
   SEA84FA020            1300             2             0           20            4
   SEA84FA058            3000             7             0           11            4
   SEA84FA078            3125             4             0            7            4
   ANC86FA130            2800             7             0           35            3
   ATL85FA081            2800             4             0           13            4
   ATL85FA143            2650             5             0           12            4
   ATL85FA170            4000             1             4           8             4
   ATL85FLT12            1600             3             3           12            3
   ATL86FA003            2300             6             0           10            4
   ATL86FA028            3400             7             0           13            4
   ATL86FA084           12499             1             0           10            3
   ATL86FA126            2450             7             0           13            4
   ATL86FA259            1600             6            11            8            4
   ATL86FKG03            2950             0             0            7            4
   ATL87FA004            2550             4             0           10            3
   ATL87FA021            3800             0             0           17            3
   BFO85FA025            2150             5             0           15            3
   BFO85FA070            1450             6             0            7            4
   BFO86FA002            3600             0             4            6            4
   BFO86FLA01            1560             4             0            7            4
   BFO87FA004            2750             7             0            8            4
   CHI85FE102            2300             0             0            7            3
   CHI86FA100A           2300             7             0           14            4
   CHI86FEX06            3400             5             3            8            4
   CHI87FA048            2650             5             6           33            3
   DEN85FA067            4150             7             0           15            4
   DEN85FA097            2740             8             9           26            4
   DEN85FA202            2200             6             5           10            4
   DEN85FA203            2550             7             3           27            4
   DEN86FA028            2900             7             8           45            4
   DEN86FA071            2800             5             0           15            4
   DEN86FA115            4000             4             0           15            3
   FTW85FA180            1670             5             0            8            4
   FTW85FA220            3100             6            11            8            4
   FTW85FA331            1804             5             0            6            4
   FTW86FA046            1450             4             8           12            4
   FTW86FA092            3800             9            11           31            4
   FTW86FQG04            1560             0             0            9            4
   FTW86FRD10            2150             4             3            8            3
   FTW86FRD24            2350             0             0           15            3
   FTW86FRG02            2900             5             0           25            3
   FTW86MA010            3400             5             9           20            4
   FTW87FA017            1670             4             6           61            4
   FTW87FA029            2650             8             0           15            4
   LAX85FA102            3400             4             0           25            4
       Section J                                 J-4
      Table 1 - Brief Listing Of Inflight Single-Engine Aircraft Accidents (continued)
    NTSB_NBR     AIRCRAFT_WGT  AIRSPEED_IMPAC  FLT_PATH_ANGL  DISTANCE_AIRPO  AIRCRAFT_DAMA
  LAX85FA115             9500             5             4           25            4
  LAX85FA178             1600             6             8           10            4
  LAX86FA038             2000             0             0           20            4
  LAX87FA066             2740             0             0           26            3
  LAX87MA018             2250             0             0            9            4
  LAX87MA068A            2325             0             0           16            3
  LAX87MA068B            2900             0             3           16            3
  MKC85FA089             3200             7             0           15            4
  MKC85FA189             2850             1             0           10            3
  NYC85FA227             1600             0             0           15            4
  NYC86FA057             2800             0             9            6            4
  NYC87FA023             2550             7             3            7            4
  ANC88FA021             3200             8             0            7            4
  ATL88FA068             2750             7             0            7            4
  ATL88FA073             4000             5             0           10            4
  ATL88FA109             1600             0             0            6            4
  ATL88FA233             3400             0             0           12            4
  CHI88DEE07             2050             1             0            8            3
  DEN87FA064             4000             8             3           11            4
  DEN88FA016             3600             9             3           12            4
  FTW87FA123             3600             4            11            8            4
  FTW88DPJ08             1670             2             7           13            3
  FTW88DRD20             1450             8            11           10            4
  FTW88FA011             2300             4             0           16            4
  LAX87FA087             7000            10             3           46            4
  LAX88FA278             3800             5             0            6            4
  MKC87DCQ02             3800             0             0            9            4
    87FA185              3300             0             0            7            4
      Section J                                J-5
                          Table 2 - Single Engine Aircraft Crash Frequencies for Various Weights and Speed
                                             Airspeed At Impact (mph)
    AIRCRAFT_WGT    Other     0-17  17-35  35-52  52-69  69-86  86-104  104-138  138-173  173-207  207-242
                      0        1      2      3      4      5      6        7        8        9       10
      500 to 999      1               1       1                   1         1                   ##
    1000 to 1499               1      1             1             1                ##1
    1500 to 1999      4               2       3     3      5      6         1   ## 
    2000 to 2499      8       1       1       1     4      2      5       ##8
    2500 to 2999      7       1                     5      6      1     ##  9       6        2
    3000 to 3499      3       1               1     2      3      2 ##      3       2
    3500 to 3999      6                       1     3      1    ##3         1       2        2
    4000 to 4499      1       1               1     1      2   ## 1         1       3
    4500 to 4999                     1                        ##
    7000 to 7499                                         ##                                       1
    9500 to 9999                                 ##       1
   12000 to 12499             1             ## 
        Total:        30      6       6       8   19     20      20       24      14        4     1
    Section J                                         J-6
        Table 3 - Thresholds for Potential Collapse of Magazine at 90 Degree Impact
     Aircraft Weight (lbs.)     Airspeed At Impact (fps)      Airspeed At Impact (mph)
        500                         407                                278
       1000                         320                                218
       1500                         235                                160
       2000                         206                                140
       2500                         182                                124
       3000                         166                                113
       3500                         154                                105
       4000                         143                                 98
       4500                         136                                 93
       5000                         130                                 88
       5500                         125                                 85
       6000                         120                                 82
       6500                         112                                 76
       7000                         104                                 71
       7500                          97                                 66
       8000                          92                                 63
       8500                          85                                 58
       9000                          80                                 55
       9500                          75                                 51
      10000                          70                                 48
      10500                          67                                 46
      11000                          64                                 44
      11500                          61                                 42
      12000                          58                                 40
      12500                          56                                 38
         Table 4 - Single-Engine Crash Flight Path Angle Distribution
Flight Path Angle   Destroyed/Damaged    Inflight Accidents    Accidents Exceeded
                   Accidents(2581 Cases)   (152 Cases)         Threshold (46 Cases)
(0)      Other               1431                  103                  25
(l)      Up                     3                    0                   0
(2)      Down                  12                    3                   2
(3)      0-5 deg.             310                   18                  10
(4)      5-10 deg.            147                    4                   2
(5)      10-15 deg.           111                    3                   2
(6)      15-20 deg.            69                    2                   0
(7)      20-25 deg.            40                    3                   0
(8)      25-30 deg.            65                    5                   2
(9)      30-45 deg.           116                    4                   1
(10)     45-60 deg.            84                    1                   0
(11)     60-90 deg.           193                    6                   2
No. of accidents (45-90 deg)  277                    7                   2
No. of accidents (0-90 deg)  1135                   46                  19
Section J                               J-7
    To actually assess the effects of impact angle on the impact threshold, we used the most
recent calculations presented in reference [3]. The reference addressed the revisions to the
aircraft impact analysis in accordance with the ASCE method [4] and the USAF method [5].
The most significant change resulting from this revision was that the ASCE method predicts
shorter natural periods (as a result of larger effective moments of inertia), a lower allowable
ductility ratio, and shorter load duration [3]. The loading was modified from that used in the
original FSAR [2] in that - the duration of the load was shortened The response of the
structure was estimated for load duration based on the estimated stopping distance of the
aircraft and its length. The results of this assumption make a significant difference e
anticipated response. The effective loaded area was estimated using two methods r
distributing the load. These two methods result in significant differences at only fairly low
angles of impact. Both methods result in a distributed load over a span. A unit width of the
roof was then analyzed for the response. In the original FSAR calculations a four foot wide
strip was assumed to carry the entire impact load. The vulnerability curves from reference
[3] are plotted in Figures 1 and 2.
Based on the 152 accidents listed in Table 1,39 accidents had actual kinematics impact speed
and impact angledata listed. Each of 39 accidents was then tested against the vulnerability
curve to identify the accidents that had the potential to collapse an MR magazine. Of those
39 accidents, only one accident was above the threshold using the ASCE method and none of
the accidents was above the threshold using the USAF method. This gives the fraction of the
accidents with conditions sufficient to cause collapse as 1/39 = 0.025. Further filtering of the
large data set of 2581 single-engine aircraft accidents listed in Attachment 1/ indicates that
1060 accidents had both impact angle and impact speed listed. Again, each of the 1060
accidents were tested against the aircraft weight, impact speed, and impact angle given in the
vulnerability curve to identify the accidents with conditions sufficient to collapse a magazine.
Thirty-three accidents were above the impact threshold by the ASCE method and 20
accidents were above the impact threshold by the USAF method. Thus, the fraction of
accidents with conditions sufficient to cause collapse is 33/1060 = 0.03. This ratio was
selected because it has a larger data base and provides a larger value which should be more
defensible.
    Data reported in the EA, Section E.4.2, indicates that approximately 77% (0.77) of
general aviation flights are single-engine and 23% (0.23) are not single-engine. Therefore,
the impact probability for general aviation (1.52E-06) reported in Table E-l l of the EA can
be written:
(1.52E-06*0.23)*(3.3E-08/7.lE-08) + (1.52E-06 * 0.77 )* 0.03*(9.lE-08/7.lE-08)
or      l .62E-07 + 0.45E-07 = 2.07E-07
    The first term above (1.62E-07) accounts for the 23% of the impact probability
attributable to all general aviation except single-engine aircraft, which is also modified by
updating the crash rate to account for deletion of the single-engine aircraft. The number,
3.3 E-08, is the general aviation crash rate per mile without single-engine aircraft and the
number, 7. lE-08, is the average general' aviation aircraft crash rate per mile in Table E-6 of
the EA. The second term accounts for that fraction of the single-engine aircraft that have
sufficient weight and speed to have the potential to collapse a magazine. The number,
Section J                               J-8
Figure (Page J-9 Figure 1 - Vulnerability Curves Generated By ASCE Method.)
Figure (Page J-10 Figure 2 - Vulnerability Curves Generated By USAF Method.)
9.1 E-08, is the single-engine crash rate per mile. Here the crash rate has been modified to
reflect only the higher rate for the single-engine aircraft This results in the refined estimate
of the probability of impact with potential for adverse consequences shown in Table 5.
       Table 5 - Annual Probabilities of Aircraft Crashes With Potential
                         For Significant Consequences
Aircraft Class               Crash Probability/Year   Crash Probability/Year
                           Verification Analysis        EA Analysis
Air Carrier                    2.78E-08                   2.78E-08
Military Aviation              2.50E-07                   2.50E-07
General Aviation               2.07E-07                   3.3 lE-07
Aerial Application             5.42E-08                   5.42E-08
Total                          5.39E-07                   6.63E-07
   These numbers reflect the probability of the particular categories of aircraft impacting a
magazine with the potential to cause damage to the magazine. It should bc noted that this is
still a conservative estimate because we have not reduced or modified the skid area.
   Our estimates consider only the probability of impact, they do not reflect the probability
that a release of plutonium will occur. This latter probability is a function of the conditional
probability that the containers and contents of the magazine are damaged if the magazine is
damaged. These conditional probabilities are not readily quantified because `the combined
damage of magazine and contents represents a complex scenario that is further complicated
by a lack of sound data and thorough analysis Nevertheless, the product of this sequence of
conditional probabilities leading to release will be less than one, and it is likely to be
significantly less than one. From this analysis, we conclude that the probability estimate for
general aviation aircraft having conditions sufficient to collapse the magazines in Zone 4 as
given in the EA is within a reasonable fraction of the more refined analysis given here.
   In our opinion, the annual probability of general aviation crashes with the potential for
significant consequences presented in EA is a valid and reasonable assessment of the
probability.
References
l.   Environmental Assessment for Interim Storage of Plutonium Components at Pantex,
     Pre-decisional, DOE/EA-08 12, U.S. Department of Energy, December, 1992.
2.   Final Safety Analysis, Appendix C.8,Pantex Plant Site, Amarillo, Texas, US. Dept.
     of Energy, December, 1992.
Section J                               J-11
3.    Ray Bennett, Revised Aircraft Crash Calculations For Zone 4 Modified Richmond
      Magazines, Jacobs Engineering Group Inc., July 30, 1/ 993.
4.    Structural Analysis and Design of Nuclear Plant Facilities, Chapter 6, Design Against
      Impulse and Impact Loads, ASCE - Manuals/Reports on Engineering Practice, No. 58,
      American Society of Civil Engineers, 1980.
5.    The AirForce Manual for Design and Analysis of Hardened Structures.Volume l,
      Sections 1 through 8, Air Force Weapons Laboratory Technical Report 87-57 (Wl-TR-
      87-57), June 1987.
Copy to:
David Chaney, DOE/DP6.2
Ted Dobry, DOE/DP6.2
Dan Rhoades, DOE/DP6.2
0333      NSIC File P-2A
Section J                               J-12
Attachment 1 - A Brief Listing Of Single-Engine Aircraft Accidents
This attachment lists 2,581 single-engine aircraft accidents retrieved from our current NTSB
database. The meaning of the columns are listed in the following table:
 Column                    Date                                         Code
   1            NTSB accident/incident number
   2            Aircraft weight in lb.
   3            Distance of crash site from center
                of nearest airport in miles
   4            Aircraft damage                        1 = none
                                                       2 = minor
                                                       3 = substantial
                                                       4 = destroyed
   5            Airspeed at impact in knots            1 = 0-15            7 = 90-120
                                                       2 = 15-30           8 = 120-150
                                                       3 = 30-45           9 = 150-180
                                                       4 = 45-60          10 = 180-210
                                                       5 = 60-75          11 = 210 plus
                                                       6 = 75-90           0 = other
   6            Flight path angle at impact in         0 = other           6 = 15-20
                degrees                                1 = up              7 = 20-25
                                                       2 = down            8 = 25-30
                                                       3 = 0-5             9 = 30-45
                                                       4 = 5-10           10 = 45-60
                                                       5 = 10-15          11 = 60-90
NTSB_NBR         AIRCRAFT_WGT      DIST_AIRPORT       ACFT_DAMAGE      AIRSPEED_IMPACT       FLT_PATH_ANGLE
ANC83FA030           3800              5                 3                   5                 0
ANC83FA032           3200              0                 4                   4                 0
ANC83FA033           1650              0                 3                   3                 0
ANC83FA037           3400              0                 3                   5                 0
ANC83FA042           1800              0                 4                   0                 0
ANC83FA064           1625              0                 3                   3                 0
ANC83FA070           1500              3                 3                   4                 0
ANC83FA071           3400              0                 3                   6                 0
ANC83FA092           2450              0                 3                   1                 0
ANC83FA095           3300              0                 3                   6                 0
ANC83FA113           3800              0                 3                   4                 0
ANC83FA120           2800              0                 3                   4                 0
ANC83FA122           4300             10                 4                   3                10
ANC83FA126           3000              6                 3                   3                 0
ANC83FA127           1200              0                 3                   3                 0
ANC83FA134           1600              0                 3                   1                 0
ANC83FA139           1650              0                 3                   4                 0
ANC83FA144           4250              0                 3                   1                 0
ANC83FA146           3600              4                 4                   4                 3
ANC83FA152           3320             15                 4                   6                 0
ANC83FA154           2800              0                 4                   8                 0
ANC83FA161           1650              0                 3                   3                 0
ANC83FA167           1750              0                 4                   4                 0
ANC83FAA06           2400              1                 4                   8                 0
ANC83FAA07            900             15                 4                   6                 9
ANC83FAG02           2300              0                 3                   4                 0
ANC83FAG03           3350              1                 4                   8                 8
ANC84FA0l6           2300              5                 3                   0                 0
ANC84FA036           2300              0                 3                   3                 o
ANC84FA043           3800              0                 3                   4                 0
ANC84FA051           3400              0                 4                   0                11
ANC84FA052           1650              0                 3                   0                 0
ANC84FA056           1800              o                 3                   1                 0
ANC84FA063           2300              0                 3                   4                 0
ANC84FA067           3200              0                 3                   1                 0
ANC84FA068           2950              0                 3                   0                 0
ANC84FA091           4250              0                 3                   2                 0
ANC84FA116           3400              0                 3                   4                 5
_____________________________________________________________________________________________________
                                                                                                 1
 NTSB_ NBR          AIRCRAFT_WGT     DIST_AIRPORT   ACFT_DAMAGE    AIRSPEED_IMPACT   FLT_PATH_ANGLE
ANC84FA140           2950            0                  3                    3                4
ANC84FA141           2400            0                  4                    &                0
ANC84FA166           1750            0                  3                    3                0
ANC84FA169           2100            0                  4                    7                0
ANC84FA175           2800            1                  4                    0                0
ANC84FA176           2050           75                  3                    4                3
ANC84FA189           4000            2                  3                    4                0
ANC84FA190           1800            0                  3                    6                0
ANC84FA194           1725            3                  3                    4                0
ANC85FA012           2500            0                  3                    4                0
ANC85FA023           2900            0                  3                    7                0
ANC85FA026           1750            0                  4                    1                0
ANC85FA027           1450            0                  3                    3                0
ANC85FA03F           1750            0                  3                    3                8
ANC85FA036           3200            0                  4                    7                0
ANC85FA040           1750            0                  4                    7               10
ANC85FA042           1750            0                  3                    2                0
ANC85FA048           1670            0                  3                    3                0
ANC85FA052           3200            0                  4                    3                0
ANC85FA056           1750            0                  3                    3               10
ANC85FA063           1750            0                  3                    3                0
ANC85FA065           3200            0                  3                    2                0
ANC85FA078           2800            0                  4                    0                0
ANC85FA085           3800            0                  3                    7                0
ANC85FA090           1313            0                  3                    3                3
ANC85FA092           1650            0                  3                    4                0
ANC85FA093           3800            0                  3                    4                3
ANC85FA095           3800            0                  3                    7                9
ANC85FA100           2950            0                  3                    2                3
ANC85FA107           1760            0                  3                    5                0
ANC85FA111           1750            0                  4                    4                0
ANC85FA124           3320            0                  3                    4               10
ANC85FA135           3550            0                  4                    8                5
ANC85FA136           2800            1                  3                    3                8
ANC85FA184           5090            0                  4                    2                0
ANC86FA007           7300            1                  4                    6                6
ANC86FA009           3400            0                  4                    5                3
ANC86FA014           3600            0                  3                    0                0
ANC86FA035           3350            1                  3                    4                8
ANC86FA055           2350            0                  4                    5                3
ANC86FA057          12125            0                  3                    6                8
_________________________________________________________________________________________________
                                                                                               2
  NTSB_NBR          AIRCRAFT__WGT        DIST_AIRPORT       ACFT_DAMAGE    AIRSPEED_IMPACT     FLT_PATH _ANGLE
ANC86FA071                 1625                    0                 3                   4                 3
ANC86FA074                 2300                    0                 3                   3                 4
ANC86FA080                 1650                    0                 3                   0                 4
ANC86FA081                 1625                    0                 4                   4                 3
ANC86FA085                 1220                    0                 3                   4                 0
ANC86FA114                 1650                    0                 3                   3                 0
ANC86FA116                 2078                    0                 4                   0                 0
ANC86FA118B                1670                    0                 3                   9                 0
ANC86FA126B                2550                    0                 3                   1                 0
ANC86FA130                 2800                   35                 3                   7                 0
ANC86FA151                 1760                    0                 4                   3                 9
ANC86FA152                 1850                    0                 3                   4                 9
ANC86LAG06                 1080                    0                 4                   8                 8
ANC86MA027                 3800                    0                 4                   7                 3
ANC87DAG03                  850                    0                 3                   2                 0
ANC87FA023                 3800                    0                 4                   7                 3
ANC87FA025                 1670                    0                 3                   1                 3
ANC87FA028                 3800                    1                 4                   6                 5
ANC87FA031                 1350                    0                 3                   2                 0
ANC87FA036                 1650                    0                 3                   4                 4
ANC87FA043                 2450                    0                 3                   1                 3
ANC87FA051                 3200                    0                 3                   4                 0
ANC87FA084                 3320                    0                 3                   3                 0
ANC87FA097                 1750                    0                 3                   3                11
ANC87FA101                 3350                    0                 4                   6                11
ANC87FA112                 1750                    1                 3                   3                 8
ANC87FA117                 3600                    0                 4                   0                 0
ANC87FA118                 5090                    0                 3                   1                 3
ANC87FA137                 2600                    1                 3                   3                 4
ANC87FA138                 2450                    0                 3                   3                 0
ANC87FA153                 1625                    0                 4                   4                 9
ANC88DAG06                  651                    0                 3                   2                 0
ANC88FA011                 1750                    0                 3                   0                 9
ANC88FA012                 3200                    0                 3                   5                 3
ANC88FA020                 3800                    0                 3                   7                 0
ANC88FA021                 3200                    7                 4                   8                 0
ANC88FA022                 7300                    0                 3                   6                 3
ANC88FA037                 2650                    0                 4                   0                 0
ANC88FA045                 1625                    0                 3                   3                 0
ANC88FA056                 3600                    0                 3                   2                 0
ANC88FA057                 1500                    0                 3                   3                 9
______________________________________________________________________________________________________________
                                                                                                            3
  NTSB NBR              AIRCRAFT_WGT         DIST_AIRPORT          ACFT_DAMAGE        AIRSPEED_IMPACT        FLT PATH ANGLE
ANC88FA059                    3400                     0                    4                     7                   3
ANC88FA062                    5100                     0                    4                     5                   7
ANC88FA63A                    3600                     5                    4                     7                   4
ANC88FA063B                   4300                     5                    4                     7                   3
ANC88FA065                    2200                     0                    4                     2                   4
ANC88FA067                    5100                     0                    3                     5                   4
ANC88FA083                    3320                     0                    3                     7                   0
ANC88FA053                    1600                     0                    4                     7                   4
ANC89FA009                    1750                     0                    3                     0                   0
ANC89FA028                    2300                     0                    3                     3                   0
ATL83AA305                    2750                     0                    4                     8                   0
ATL83FA083                    2450                     0                    4                     0                   0
ATL83FA091                    2450                     1                    4                     0                   0
ATL83FA095                    2800                     1                    4                     3                   0
ATL83FA099                    2400                     0                    4                     7                   0
ATL83FA116                    2400                     0                    3                     4                   0
ATL83FAl17                    2550                     6                    4                     7                   5
ATL83FAl21                    2740                     0                    4                     0                   0
ATL83FA129                    2950                     6                    4                     0                   3
ATL83FA135                    2325                     0                    3                     5                   0
ATL83FA140                    2150                     0                    4                     6                   0
ATL83FA144                    1200                     1                    4                     3                   0
ATL83FA150                    2200                     0                    3                     0                   O
ATL83FA155                    2550                     0                    4                     1                   0
ATL83FA161                    2800                    15                    4                     8                   2
ATL83FA163                    3400                     0                    4                     3                   0
ATL83FAl74                    3600                     0                    4                     7                   0
ATL83FA176                    3325                    20                    4                     8                   3
ATL83FA178                    1600                     1                    3                     4                   0
ATL83FA179                    1600                     0                    4                     7                   0
ATL83FA182                    2400                     0                    3                     0                   0
ATL83FA185                    1600                     0                    4                     1                   0
ATL83FA198                    3600                    25                    4                     0                   0
ATL83FA213                    1800                     0                    4                     4                   0
ATL83FA230                    1500                     0                    3                     4                   0
ATL83FA232                    2230                     0                    3                     5                   0
ATL83FA238                    2300                     0                    3                     6                   0
ATL83FA249                    7600                     1                    4                     7                   0
ATL83FA262                    3125                     0                    4                     7                   2
ATL83FA2G3                    1670                     0                    4                     0                   0
ATL83FA267                    2300                     0                    3                     4                  10
_________________________________________________________________________________________________________________________
                                                                                                                      4
 NTSB_NBR                AIRCRAFT_WGT          DIST_AIRPORT         ACFT_DAMAGE      AIRSPEED_IMPACT         FLT_PATH_ANGLE
ATL83FA270                    3400                     0                     3                    5                  0
ATL83FA271                    1220                     0                     4                    4                  1
ATL83FA272                    1220                     0                     3                    4                  4
ATL83FA313                    2800                     0                     3                    4                  8
ATL83FA339                    1670                     0                     4                    7                  0
ATL83FA340                    3800                    12                     3                    6                  0
ATL83FA365                    5300                     2                     4                    7                  0
ATL83FA386                    1600                     0                     3                    4                  0
ATL83FIA04                    1670                     0                     4                    5                  0
ATL83FID04                    3400                     0                     3                    3                  0
ATL83FIG03                    2200                     5                     3                    5                  0
ATL83F1G04                    3400                     1                     3                    5                  2
ATL83FIG06                    1600                     0                     3                    4                  0
ATL83FIJ02                    2950                     1                     4                    0                  0
ATL83FKG08                    4000                     0                     4                    4                  2
ATL83FKG09                    2200                     0                     3                    1                  0
ATL83FKG11                    4000                    12                     3                    5                  0
ATL83FKJ02                    1400                     1                     3                    4                  0
ATL83FKJ03                    1500                     0                     4                    0                  9
ATL83FKJ05                    1220                     0                     4                    6                  0
ATL83FKQ03                    7000                     0                     3                    0                  0
ATL83FLJ01                    2900                     5                     4                    7                  9
ATL83FU006                     517                     6                     3                    2                  0
ATL83LA203                    1006                     0                     3                    4                  0
ATL83LA204                    2900                     0                     3                    6                  0
ATL04AA053                    3600                     7                     4                    0                  3
ATL84FA001                    3200                     0                     4                    2                  0
ATL84FA005                    3300                     0                     4                    4                  0
ATL84FA0l7                    1800                     1                     3                    6                  0
ATL84FA026                    2800                     5                     3                    5                  0
ATL84FA028                    3600                     8                     4                    8                  0
ATL84FA033                    2300                     1                     4                    6                  0
ATL84FA054                    2400                     0                     4                    0                  0
ATL84FA057                    2600                     0                     3                    2                  0
ATL84FA059                    3600                     1                     4                    6                  0
ATL84FA061                    2900                     1                     4                    6                  0
ATL04FA068                    2300                     9                     4                    7                  3
ATL84FA075                    2740                    17                     4                    4                  0
ATL84FA080                    3600                     1                     4                    5                  0
ATL84FA082                    2500                     0                     4                    4                  0
ATL84FA088                    4000                     7                     4                    6                  0
________________________________________________________________________________________________________________________
                                                                                                                       5
 NTSB_NBR                AIRCRAFT_WGT          DIST_AIRPORT         ACFT_DAMAGE      AIRSPEED_IMPACT         FLT_PATH_ANGLE
ATL84FA090                    2450                     0                    4                    10                   0
ATL84FA092                    3600                     0                    4                     7                   0
ATL84FA093                    3600                     5                    4                     0                   0
ATL84FA095                    1653                     l                    4                     6                   0
ATL84FA100                    2450                     0                    4                     l                   0
ATL84FA106                    3600                     6                    4                     7                   4
ATL84FA111                    3600                     0                    4                     9                   0
ATL84FA116                    3100                     3                    4                     8                   0
ATL84FA129                    3400                     0                    3                     5                   0
ATL84FA133                    3650                     0                    3                     6                   0
ATL84FAl41                    2950                     0                    4                     7                   0
ATL84FAl47                    2400                     0                    4                     5                   0
ATL84FA150                    3400                     1                    4                     6                   0
ATL84FA151                    3400                     0                    4                     6                   0
ATL84FA158                    3200                     0                    4                     4                  10
ATL84FA164                    3325                     0                    4                     5                   0
ATL84FA168                    2658                     0                    4                    11                  11
ATL84FAl72                    2950                     1                    4                     6                   4
ATL84FA184                    3600                     0                    4                     0                  11
ATL84FA190                    2750                     0                    3                     3                   0
ATL84FA193                    1600                     1                    4                     8                   0
ATL84FA216                    1600                     0                    3                     6                   0
ATL84FA218                    3000                     0                    4                     2                   0
ATL84FA222                    3600                     0                    4                     0                   0
ATL84FA225                    1930                     0                    4                     5                   9
ATL84FA250                    1600                     0                    4                     4                   8
ATL84FA252                    2717                     0                    3                     4                   0
ATL84FA268                    4200                     0                    4                     5                   0
ATL84FA275                    3100                     2                    4                     4                   4
ATL84FA292                    2740                     5                    4                     8                   0
ATL84FA297                    3200                     0                    4                     1                   0
ATL84FA298                    3400                     0                    4                     0                   0
ATL84FIA0l                    1600                     1                    3                     0                   0
ATL84FIG01                    2600                     0                    4                     4                   0
ATL84FIJ02                    1500                     0                    3                     3                   0
ATL84FKJ02                    3300                     3                    4                     7                   5
ATL84FLT07                    3500                     0                    3                     2                   0
ATL84FLT10                   10500                     0                    4                     6                   0
ATL84FMG05                    3600                     0                    4                     0                   0
ATL84FU002                     510                     O                    4                     3                   0
ATL84FU003                     465                     0                    4                     5                   0
________________________________________________________________________________________________________________________
                                                                                                                      6
      NTSB_NBR           AIRCRAFT_WGT          DIST_AIRPORT         ACFT_DAMAGE      AIRSPEED_IMPACT         FLT_PATH_ANGLE
ATL84FU005                     370                     0                    4                     2                   0 
ATL84LA027                    1450                     0                    3                     0                   0
ATL84MA101                    3400                     0                    4                     8                   0
ATL84MA208                    3400                     0                    4                     0                   0
ATL85FA007B                   1670                     1                    4                     6                   0
ATL85FA008                    1600                     1                    4                     5                   4
ATL85FA011                    5200                     0                    4                     0                   0
ATL85FA0l3                    1600                     0                    3                     6                   0
ATL85FA020                    1650                     1                    4                     4                   8
ATL85FA041                    2300                     0                    3                     6                   5
ATL85FA043                    2950                     0                    4                     5                   0
ATL85FA050                    3135                     0                    4                     7                   0
ATL85FA056                    2450                     0                    4                     5                   0
ATL85FA060                    2200                    10                    4                     6                   0
ATL8SFA061                    2325                     1                    4                     6                   0
ATL85FA070                    1300                     0                    4                     1                  11
ATL8SFA071                    2300                    25                    3                     4                   0
ATL85FA072                    2650                     2                    4                     7                   3
ATL85FA077                    3100                     0                    4                     8                   0
ATL85FA081                    2800                    13                    4                     4                   0
ATL85FA090                    1670                     0                    3                     5                   0
ATL85FA101                    3100                     0                    4                     7                   0
ATL85FA106                    1670                     4                    4                     8                   5
ATL85FA113                    2800                     0                    4                     8                   6
ATL85FA118                    2800                     1                    4                     5                   0
ATL85FA140                    1450                     0                    4                     7                   0
ATL85FA143                    2650                    12                    4                     5                   0
ATL85FA146                    3400                     0                    4                    11                  11
ATL85FA147                    1670                     0                    4                     0                  11
ATL85FA157                    2740                     0                    4                     0                   0
ATL85FA165                    2325                     2                    3                     0                   0
ATL85FA170                    4000                     8                    4                     1                   4
ATL85FAl71                    2550                     1                    4                     7                   0
ATL85FA173                    3100                     0                    4                     6                   4
ATLS5FA179                    2150                     2                    3                     5                   0
ATLS5FA181                    3600                     5                    3                     6                   0
ATL85FAl82                    1650                     0                    4                     4                   0
ATL85FA189                    2300                     0                    4                     5                  11
ATL85FA191                    1450                     1                    3                     4                   0
ATL85FA198                    1220                     0                    3                     6                   0
ATL85FA2l6                    1570                     0                    3                     2                   0
________________________________________________________________________________________________________________________
                                                                                                                      7
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT         ACFT_DAMAGE        AIRSPEED_IMPACT        FLT_PATH_ANGLE
ATL85FA330                     3800                    2                     3                     4                    0
ATL85FA237                     2200                    0                     3                     5                    0
ATL85FA242                     2400                    1                     4                     6                    0
ATL85FA243                     1600                    1                     4                     4                    0
ATL85FA252                     2575                    0                     4                     6                    0
ATL85FA266                     2900                    0                     4                     0                    0
ATL85FA276                     1150                    0                     4                     0                   11
ATL85FA278                     1800                    0                     3                     0                    0
ATL85FA280                     2300                    1                     3                     5                    3
ATL85FA285                     3600                    1                     4                     4                    9
ATL85FLT02                     2800                    0                     3                     5                    3
ATL85FLT05                     2500                    0                     3                     3                    0
ATL85FLT06                     1600                    0                     3                     4                    9
ATL85FLT09                     1600                    0                     4                     1                    0
ATL85FLT12                     1600                   12                     3                     3                    3
ATL85FMG03                     1092                    0                     4                     5                    5 
ATL85FMG05                      750                    5                     4                     3                    0
ATL85FMG08                     2650                    5                     4                     4                    3
ATL85LA122                     2800                    0                     4                     5                    0
ATL85LLT11                     3800                    1                     4                     4                    0
ATL85MA282B                     790                    0                     4                     2                    0
ATL85MA286                     7300                    1                     4                     4                   11
ATL86FA001                     2300                    0                     4                     3                    0
ATL86FA002                     1600                    0                     4                     6                    7
ATL86FA003                     2300                   10                     4                     6                    0
ATL86FA009                     2300                    0                     4                     7                    0
ATL86FA025                     2950                    3                     3                     5                    0
ATL86FA028                     3400                   13                     4                     7                    0
ATL86FA029                     3100                    1                     4                     7                   11
ATL86FA034                     2400                    3                     4                     3                    9
ATL86FA040                     1800                    0                     4                     7                    0
ATL86FA04l                     2740                    0                     3                     6                    3
ATL86FA049                     2800                    1                     4                     5                    3
ATL86FA064                     3400                    0                     4                     7                    0
ATL86FA066                     1670                    1                     3                     4                    0
ATL86FA077                     2950                    0                     4                     8                    0
ATL86FA079                     1675                    2                     4                     8                    0
ATL86FA081                     1300                    0                     4                     3                    0
ATL86FA082                     2355                    0                     3                     0                    0
ATL86FA084                    12499                   10                     3                     1                    0
ATL86FA097                     1370                    0                     4                     5                    0
__________________________________________________________________________________________________________________________
                                                                                                                        8
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT         ACFT_DAMAGE        AIRSPEED_IMPACT        FLT_PATH_ANGLE
ATL86FA102                     8094                     2                    4                     0                  0
ATL86FA116A                    1600                     0                    3                     3                  0
ATL86FA120                     2200                     0                    4                     8                  0
ATL86FA126                     2450                    13                    4                     7                  0
ATL86FA129                     2950                     0                    3                     6                  0
ATL86FA132                     2300                     2                    4                     3                  0
ATL86FA133                     2075                     0                    4                     5                  5
ATL86FA148                     1650                     0                    3                     3                  0
ATL86FA160                     2985                     0                    4                     4                  8
ATL86FA176                     2450                     0                    3                     4                  3
ATL86FA178                     1450                     0                    4                     6                  7
ATL86FA212                     2300                     3                    4                     6                  4
ATL86FA217                     2150                     0                    4                     4                  3
ATL86FA220                     3000                     0                    4                     6                  9
ATL86FA222                     2575                     1                    4                     5                  0
ATL86FA223                     3000                     0                    4                     9                  0
ATL86FA235                     1150                     0                    4                     2                  9
ATL86FA239                     3600                     5                    4                     6                  4
ATL86FA240                     2150                     0                    4                     7                  4
ATL86FA242                     1260                     0                    4                     2                  0
ATL86FA259                     1600                     8                    4                     6                 11
ATL86FA266                     1100                     0                    4                     4                 11
ATL86FE103                     2200                     0                    3                     4                  4
ATL86FE104                     1670                     0                    3                     2                  3
ATL86FE105                     1100                     0                    3                     0                  0
ATL86FE106                     1350                     1                    4                     4                  9
ATL86FE108                     2562                     0                    3                     3                  4
ATL86FE109                     3223                     0                    4                     4                  0
ATL86FEK02                     1089                     0                    3                     0                  0
ATL86FEK03                     3200                     0                    3                     3                  0
ATL86FKG0l                     3400                     0                    4                     4                  0
ATL86FKG03                     2950                     7                    4                     0                  0
ATL86FKG04                     2740                     5                    4                     7                  3
ATL86FKG07                     2400                     0                    4                     7                  3
ATL86FKG10                     450O                     0                    3                     5                  0
ATL86FLQ02                     250O                     0                    3                     4                  0
ATL86FLQ03                     2900                     0                    3                     6                  5
ATL86FLQ06                      925                     0                    4                     5                  0
ATL86FMG05                     1600                     0                    3                     6                  0
ATL86LA189                     2200                     5                    3                     4                  3
ATL86LMG06                     1600                     0                    4                     5                  7
________________________________________________________________________________________________________________________
                                                                                                                      9
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT              ACFT_DAMAGE        AIRSPEED_IMPAC      FLT_PATH_ANGLE
ATL86MA087                     3400                    0                     4                     5                 11
ATL86MA114A                    4150                    0                     4                     7                  0
ATL86MA114B                    2400                    0                     3                     7                  0
ATL87DEG03                     1880                    1                     4                     3                 11
ATL87DEG04                      500                    0                     3                     2                  3
ATL87DEG05                     2150                    0                     3                     1                 11
ATL87DE101                     2800                    0                     3                     5                  8
ATL87DE104                     1265                    5                     3                     4                  3
ATL87DE105                     2450                    0                     3                     1                  0
ATL87DE106                     1700                    0                     4                     8                 11
ATL87DE108                     4500                    0                     3                     5                  0
ATL87DE109                     2200                    0                     3                     0                  0
ATL87DE111                     2400                    0                     3                     4                  4
ATL87DE112                     1450                    0                     3                     2                  0
ATL87DE113                     1500                    0                     3                     4                  3
ATL87DEK03                      900                    0                     3                     4                  0
ATL87DKG05                     4500                    0                     3                     4                  4
ATL87DKG07                     4500                    0                     4                     6                  9
ATL87DLQ01                     1050                    0                     4                     5                  0
ATL87DLQ04                     2150                    0                     4                     5                  0
ATL87DLT02                     2000                    0                     3                     4                  0
ATL87DMG02                     2900                    0                     4                     6                  3
ATL87FA001A                    1170                    0                     4                     4                 11
ATL87FA001B                    3100                    0                     4                     5                 11
ATL87FA003                     3000                    1                     4                     4                  7
ATL87FA004                     2550                   10                     3                     4                  0
ATL87FA006A                    1500                    1                     3                     3                  3
ATL87FA006B                    1170                    1                     3                     6                  4
ATL87FA007                     3600                    4                     4                     0                  0
ATL87FA009                     3200                    5                     3                     1                 10
ATL87FA010                     1670                    0                     4                     4                  0
ATL87FA012                     3400                    2                     4                     5                  6
ATL87FA016                      925                    2                     4                     3                 10
ATL87FA0l7                     3800                    1                     4                     0                  0
ATL87FA021                     3800                   17                     3                     0                  0
ATL87FA029                     3300                    3                     4                     6                  4
ATL87FA038A                    3200                    0                     4                     5                  5
ATL87FA038B                    2575                    0                     4                     5                  0
ATL87FA042                     2150                    0                     4                     5                  5
ATL87FA045                     2200                    1                     4                     5                 11
ATL87FA051                     2900                    1                     3                     8                  4
_________________________________________________________________________________________________________________________
                                                                                                                       10
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT              ACFT_DAMAGE        AIRSPEED_IMPAC      FLT_PATH_ANGLE
ATL87FA052                     1600                    0                    4                     2                   0
ATL87FA071                     1670                    0                    4                     0                  11
ATL87FA074                     2950                    0                    4                     8                   0
ATL87FA082                     2950                    1                    4                     7                   0
ATL87FA087                     1600                    0                    4                     8                   8
ATL87FA088                     2450                    0                    4                     4                   0
ATL87FA104                     2300                    0                    4                     0                   0
ATL87FA111                     1220                    1                    4                     5                   0
ATL87FA130A                    3100                    0                    4                     0                   0
ATL87FA130B                    2300                    0                    4                     0                   0
ATL87FA132                     1220                    2                    4                     6                  11
ATL87FA136                     1200                    5                    4                     0                   9
ATL87FA147                     2750                    0                    4                     3                   9
ATL87FA160                     1570                    0                    4                     5                   4
ATL87FAl68                     3300                    0                    4                     5                   0
ATL87FA174                     2600                    0                    4                     7                  11
ATL87FA187                     3400                    0                    4                     4                   3
ATL87FA189                     2450                    0                    4                     6                   0
ATL87FA194                     2070                    1                    4                     3                  11
ATL87FA209                     1670                    0                    4                     5                   4
ATL87FA230                     2650                    0                    4                     8                  11
ATL87FA234                     2150                    0                    4                     0                   0
ATL87FA235                     2200                    0                    4                     6                   3
ATL87FA243                     2650                    0                    4                     7                  11
ATL87FA244                     1600                    0                    3                     6                   4
ATL87FA248                     2550                    0                    4                     6                   0
ATL87FA257                     3400                    0                    4                     9                   0
ATL87FKG0l                      900                    1                    4                     5                  11
ATL87LA044                     2200                    0                    4                     1                   0
ATL87LA149                     1600                    0                    3                     3                   8
ATL87LA267                     1950                    0                    3                     1                   3
ATL87MA035                     4050                    5                    4                     7                   3
ATL87MA057                     4150                    0                    4                     0                   0
ATL88DKG03                     1099                    0                    4                     7                   0
ATL88DKG08                     7200                    0                    3                     1                   0
ATL88DKG09                     4200                    0                    4                     8                   0
ATL88DKG10                     4200                    0                    3                     4                   3
ATL88DKG11                     2900                    0                    3                     5                   5
ATL88DKG12                     2238                    0                    4                     6                   9
ATL88DKG15                     6000                    0                    4                     5                   3
ATL88DKG17                     3186                    0                    3                     1                   0
________________________________________________________________________________________________________________________
                                                                                                                      11
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT              ACFT_DAMAGE         AIRSPEED_IMPAC      FLT_PATH_ANGLE
ATL88DL101                     1500                     0                    4                     0                   0
ATL88DMG01                     1555                     0                    4                     5                  11
ATL88FA010                     2325                     3                    4                     0                   0
ATL88FA020                     2750                     5                    3                     6                  10
ATL88FA025                      850                     0                    4                     4                   0
ATL88FA040                     2800                     0                    3                     4                   7
ATL88FA043                     2300                     0                    4                     5                   0
ATL88FA044                     3600                     0                    4                     7                   0
ATL88FA046                     1670                     1                    4                     5                   0
ATL88FA055                     3400                     0                    4                     5                   5
ATL88FA056                     2150                     0                    3                     5                   0
ATL88FA060                     3400                     4                    4                     0                   0
ATL88FA066                     2800                     5                    4                     0                  11
ATL88FA067                     2450                     0                    4                     0                   4
ATL88FA068                     2750                     7                    4                     7                   0
ATL88FA070                     1670                     0                    3                     7                   0
ATL88FA072                    11000                     0                    4                     8                   9
ATL88FA073                     4000                    10                    4                     5                   0
ATL88FA078                     1600                     0                    3                     5                  10
ATL88FA081                     2650                     0                    4                     0                   9
ATL88FA085                     9500                     0                    4                     0                   0
ATL88FA088                     1600                     0                    3                     0                  10
ATL88FA104                     3600                     0                    4                     6                   0
ATL88FA106B                    1675                     0                    3                     5                   5
ATL88FA109                     1600                     6                    4                     0                   0
ATL88FA110                     3600                     5                    4                     7                   0
ATL88FA118                     1220                     0                    4                     5                  10
ATL88FAl23                     2450                     0                    3                     0                   0
ATL88FA125                     2900                     0                    4                     5                   0
ATL88FA136                     3600                     0                    4                     0                   9
ATL88FA155                     1600                     l                    4                     5                   9
ATL88FA168                     1600                     0                    0                     0                   0
ATL88FA174                     2740                     0                    3                     5                  10
ATL88FA185A                    2750                     0                    4                     6                   5
ATL88FA185B                    2300                     0                    3                     0                   0
ATL88FA198                     1600                     0                    4                     5                   0
ATL88FA199                     1200                     0                    4                     4                  11
ATL88FA200                     1970                     0                    4                     3                  10
ATL88FA210                     3800                     5                    3                     5                   0
ATL88FA211                     2350                     0                    4                     4                   0
ATL88FA219                     2400                     0                    4                     5                  10
__________________________________________________________________________________________________________________________
                                                                                                                       12
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT           ACFT_DAMAGE        AIRSPEED_IMPAC      FLT_PATH_ANGLE
ATL88FA220                   2325                     0                    3                     4                3
ATL88FA231                   2400                     0                    4                     7                0
ATL88FA233                   3400                    12                    4                     0                0
ATL88FA254                   3800                     0                    4                     0                7
ATL88FA256                   2700                     0                    4                     9               10
ATL89DKG01                   4500                     0                    3                     4                0
ATL89DKG02                   4200                     0                    3                     4                3
ATL89FA005                   1450                     0                    4                     6                0
ATL89FA006                   3800                     0                    3                     5                0
ATLB9FA0l3                   2800                     0                    4                     9                3
ATL89FA015                   2500                     0                    4                     7                0
ATL89FA019                   1220                     0                    3                     5                8
ATL89FA024                   2900                     o                    3                     5                3
ATL89FA025                   1670                     0                    3                     5                6
ATL89FA035                   2050                     0                    4                     4                9
ATL89FA036                   1670                     0                    4                     5                3
ATL89FA045                   2150                     0                    4                     8                0
ATL89FA047                   3125                     0                    4                     7                0
ATL89FA051                   3200                     0                    3                     2               11
ATL89FA059                   2300                     2                    4                     6                4
ATL89LA030                   2150                     0                    4                     7                4
ATL89MA023                   3100                     2                    4                     7                0
ATL89MA070                   2400                     0                    4                     0               11
BFO84FA001                   2900                     0                    4                     9                0
BFO84FA003                   1500                     1                    4                     0                0
BFO84FA008                   2150                     3                    4                     4                0
BFO85FA002                   3600                     0                    4                     7                5
BFO85FA004                   1770                     0                    4                     4                9
BFO85FA006                   1220                     0                    4                     7               11
BFO85FA007                   1100                     0                    3                     4                3
BFO85FA008                   2450                     0                    3                     4                0
BFO85FA009                   2200                     0                    4                     3                0
BFO85FA013                   6615                     0                    3                     3                0
BFO85FA023                   2550                     4                    4                     6                3
BFO85FA025                   2150                    15                    3                     5                0
BFO85FA026                   2950                     0                    3                     5                0
BFO85FA032                   3325                     3                    3                     3                0
BFO85FA048                   2800                     1                    4                     0                0
BFO85FA051                   3325                     1                    4                     5                s
BFO85FA052                   2150                     0                    3                     5                9
BFO85FA061                   1670                     0                    3                     7               11
______________________________________________________________________________________________________________________
                                                                                                                  13
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT             ACFT_DAMAGE         AIRSPEED_IMPAC      FLT_PATH_ANGLE
BFO85FA062                    1700                    0                    4                     4                11
BFO85FA068                    1800                    1                    4                     4                11
BF085FA070                    1450                    7                    4                     &                 0
BFO85FA071                    3100                    0                    4                     8                 4
BFO85FA077                    1600                    1                    4                     4                 5
BFO85FBD02                    2500                    1                    3                     4                 0
BFO85FID03                    3650                    0                    3                     4                 0
BFO86FA002                    3600                    6                    4                     0                 4
BFO86FA006                     720                    0                    4                     4                 0
BFO86FA011                    2150                    4                    4                     5                 4
BFO86FA012                    3100                    0                    3                     5                 4
BFO86FA015                    3400                    1                    4                     7                 3
BFO86FA016                    3100                    1                    4                     5                 4
BFO86FA018                    2100                    5                    3                     1                 9
BFO86FA020                    2300                    0                    3                     4                 4
BFO86FA021                    2150                    0                    4                     5                 6
BFO86FA027                    3325                    1                    4                     4                10
BFO86FA029                    1000                    0                    3                     4                 0
BFO86FA032                    2900                    0                    4                     6                 4
BFO86FA036                    2200                    5                    3                     6                 3
BFO86FA037                    2150                    0                    4                    11                 5
BFO86FA044                    2500                    0                    3                     5                 3
BFO86FA047                    2l50                    0                    4                     6                11
BFO86FA050                    2740                    1                    4                     5                 9
BFO86FIA01                    1560                    7                    4                     4                 0
BFO86FIA02                    2325                    0                    4                     5                 0
BFO86FID01                    2300                    1                    4                     2                 0
BFO86FID03                    1013                    0                    4                     0                11
BFO86FID05                    2100                    1                    3                     5                 3
BFO86FID08                     550                    0                    4                     0                 0
BFO86FID10                    1250                    0                    4                     0                 0
BFO86FIG03                    1500                    0                    3                     4                 3
BFO86LA041                    3000                    1                    3                     4                 4
BFO87DIG08                    2350                    0                    3                     4                 0
BFO87FA003                    2400                    0                    3                     4                 0
BFO87FA004                    2750                    8                    4                     7                 0
BFO87FA006                    2050                    0                    3                     5                 4
BFO87FA009                    2440                    0                    4                     7                 3
BFO87FA020                    1670                    0                    4                     6                 9
BFO87FA022                    1300                    0                    4                     0                 3
BFO87FA027                    2950                    0                    4                     0                 0
_____________________________________________________________________________________________________________________
                                                                                                                   14
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT            ACFT_DAMAGE        AIRSPEED_IMPAC      FLT_PATH_ANGLE
BFO87FA031                   2800                     0                      4                 0                  0
BFO87FA037                   1600                     0                      4                 0                  0
BFO87FA046                   2400                     0                      4                 0                  0
BFO87FA050                   2400                     0                      3                 4                 10
BFO87FA057                   3200                     0                      4                 1                 11
BFO87FA062                   2400                     0                      4                 0                  0
BFO87FIG04                   8100                     0                      3                 0                  0
BFO88DIA01                   1632                     0                      4                 6                  7
BFO88DID04                   2300                     0                      4                 6                 10
BFO88DIG01                   2500                     0                      3                 0                  0
BFO88DIGO3                   4500                     0                      4                 4                  4
BFO88FA007                   1670                     0                      4                 7                 11
BFO88FA008                   3400                     0                      4                 0                  0
BFO88FA009                   2650                     0                      4                 0                  9
BFO88FA011                   1650                     0                      4                 6                  4
BFO88FA014                   4000                     0                      3                 6                  3
BFO88FA022                   1600                     0                      4                 5                  0
BFO88FA024                   2800                     0                      4                 0                  3
BFO88FA025                   1600                     1                      3                 4                  3
BFO88FA026                   3800                     0                      4                 0                  0
BFO88FA034                   2150                     0                      4                 5                  9
BFO88FA046                   2450                     0                      3                 5                  0
BFO88FA050                   1950                     0                      3                 0                  0
BFO88FA051                   1600                     1                      4                 4                 11
BFO88FA054                   2800                     0                      3                 4                  5
BFO88FA060                   3600                     0                      3                 4                  0
BFO88FA068                   3100                     0                      4                 0                  0 
BFO88FID02                   1200                     0                      4                 1                  3
BFO88FID03                   1670                     1                      4                 0                  0
BFO88FIG0l                   1670                     0                      3                 3                  0
BFO89DID01                   1063                     0                      4                 4                  0
CHI83FA069                   5300                     0                      4                 0                  0
CHI83FA076                   2300                     2                      4                 6                  0
CHI83FA080                   1950                     9                      4                 5                  0
CHI83FA086                   3400                     0                      4                 6                  6
CHI83FA089                   2300                     2                      4                 5                  4
CHI83FA090                   2000                     3                      4                 4                  0
CHI83FA092                   1500                     0                      3                 3                  0
CHI83FA125                   1050                     0                      4                 1                  0
CHI83FA135                   2325                     0                      4                 7                  0
CHI83FA161                   2550                     0                      4                 7                  0
____________________________________________________________________________________________________________________
                                                                                                                  15
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT            ACFT_DAMAGE        AIRSPEED_IMPAC      FLT_PATH_ANGLE
CHI83FA168                   3100                     3                      4                  7                   0
CHI83FA213                   2740                     0                      4                  0                   0
CHI83FA384                   2550                    12                      4                  8                   5 
CHI83FA336                    630                     0                      4                  3                   0
CHI83FA340                   1220                     0                      3                  4                   0
CHI83FA350                    560                     0                      3                  3                   0
CHI83FA353                   2400                     0                      3                  0                   0
CHI83FA366                   3272                     8                      4                  0                   0
CHI83FA407                   1670                     7                      4                  3                   0
CHI83FA440                    900                     0                      4                  6                   9
CHI83FU008                    525                     0                      4                  3                   0
CHI83FU010                    550                     0                      4                  0                   0
CHI84AA016                    925                     8                      4                  7                   0
CHI84FA037                   1675                     0                      4                  7                   0
CHI84FA054                   1675                     1                      4                  5                   5
CHI84FA058                   3800                     0                      3                  8                   0
CHI84FA063                   1600                     0                      4                  7                  11
CHI84FA073                   2500                     8                      4                  8                   0
CHI84FA110                   2800                     0                      4                  6                   0
CHI84FA121                   3600                     1                      4                  6                   0
CHI84FA194                   3600                     0                      3                  0                   3
CHI84FA250A                  6075                     0                      4                  6                   4
CHI84FA250B                  2500                     0                      4                  6                   5 
CHI84FA282                   3350                    20                      4                  5                   0
CHI84FA289                   3000                     0                      4                  4                   7
CHI84FA292                   2650                     0                      3                  6                   4
CHI84FA313                   3000                     0                      4                  5                   0
CHI84FA115                   3600                     0                      4                  4                  11
CHI84FA343                   1750                     0                      4                  4                   0
CHI84FA348                   2000                     0                      3                  4                   0
CHI84FA352                   2900                     1                      4                  5                   0
CHI84FA364                   3320                     0                      4                  0                   0
CHI84FA376                   1750                     0                      4                  3                   0
CHI84FA402                   1600                     0                      4                  4                  10
CHI84FE101                   2450                     0                      4                  1                   0
CHI85FA020                   3400                     0                      4                  7                   0
CHI85FA034                   3550                     1                      3                  1                   4
CHI85FA036                   3400                     0                      4                  7                   6
CHI85FA050                   8157                     0                      4                 11                   0
CHI85FA054                   2150                     0                      3                  4                   4
CHI85FA059                   1400                     0                      4                  2                   6
_____________________________________________________________________________________________________________________________
                                                                                                                         16
 NTSB_NBR                AIRCRAFT_WGT         DIST_AIRPORT            ACFT_DAMAGE        AIRSPEED_IMPAC      FLT_PATH_ANGLE
CHI85FA067                   1200                    2                    4                    4                  0
CHI85FA096                   1600                    0                    3                    4                  4
CHI85FA104                   2575                    0                    4                    5                  0
CHI85FA139                   3400                    0                    4                    7                  0
CHI85FA156                   2300                    0                    4                    6                  0
CHI85FA158                   3800                    0                    4                    8                  0
CHI85FA211                   2079                    0                    4                    6                  5
CHI85FA213                   3550                    1                    4                    1                 11
CHI85FA229                   1200                    2                    4                    2                  0
CHI85FA253                   2150                    0                    4                    6                  0
CHI85FA292                   2200                    0                    3                    4                  0
CHI85FA301                   2850                    0                    4                    0                  0
CHI85FA316                   2300                    1                    4                    5                  0
CHI85FA325                   2450                    0                    3                    5                  0
CHI85FA356                   2200                    0                    4                    5                 11
CHI85FA370                   1710                    1                    4                    5                  5
CHI85FEC01                   2800                    0                    3                    3                  8
CHI85FEE01                   2325                    1                    4                    4                  9
CHI85FEE03                   1600                    0                    3                    3                  9
CHI85FEI02                   2300                    7                    3                    0                  0
CHI85FEM02                   2050                    1                    4                    5                  5
CHI85FEP01                   2700                    0                    3                    5                  0
CHI85FEP02                   1100                    0                    4                    3                 11
CHI85FEP04                   1650                    1                    3                    5                  0
CHI85FER01                   2706                    0                    4                    4                  4
CHI85FER02                   4500                    3                    3                    4                  4
CHI85FER03                   2330                    1                    3                    5                  9
CHI85FET01                   2300                    0                    3                    3                  0
CHI85FET02                   2050                    1                    3                    4                  0
CHI85FEV03                   2200                    0                    4                    0                 11
CHI85FEX03                   2450                    0                    3                    2                  0
CHI85FEX04                   2750                    0                    4                    1                 11
CHI86FA029                   2300                    0                    4                    5                  0
CHI86FA031                   2325                    3                    4                    5                  0
CHI86FA038                   3400                    0                    3                    5                  0
CHI86FA068                   2800                    3                    4                    5                  9
CHI86FA077                   2575                    0                    4                    5                  4
CHI86FA094A                  1680                    1                    4                    6                  5
CHI86FA094B                  2300                    1                    4                    6                  5
CHI86FA100A                  2300                   14                    4                    7                  0
CHI86FA102                   3325                    1                    4                    6                  9
_____________________________________________________________________________________________________________________
                                                                                                                  17
 NTSB_NBR          AIRCRAFT_WGT         DIST_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPAC   FLT_PATH_ANGLE
CHI86FA108                4100               3                4                8                 0
CHI86FA120                1200               1                4                6                 7
CHI86FA146                1650               1                4                6                 0
CHI86FA170                2000               0                4                5                10
CHI86FA171                2250               1                4                7                 0
CHI86FA174                2300               1                4                5                 0
CHI86FA179                2200               1                4                5                 6
CHI86FA183                1500               0                4                6                 3
CHI86FA194                2800               1                3                6                 3
CHI86FA198                1650               0                3                6                11
CHI86FEC01                1200               0                3                3                 0
CHI86FEC02                3800               0                3                0                 0
CHI86FEC03                3600               0                3                4                 5
CHI86FEC07                4400               0                3                4                 3
CHI86FEE02                2950               0                3                1                 0
CHI86FEE03                 520               0                3                5                 0
CHI86FEE05                 750               0                3                2                 6 
CHI86FEE06                1425               0                3                5                 3
CHI86FEE07                1350               0                3                6                 3
CHI86FE102                1600               0                3                3                 0
CHI86FEM05                5400               0                3                4                 4
CHI86FEM06                2200               0                3                1                 5
CHI86FEM07                3700               0                4                8                11
CHI86FEM08                2650               0                4                4                 8
CHI86FEM10                2900               1                3                3                 9
CHI86FEM12                1300               0                3                4                 4
CHI86FEM13                2150               0                3                1                 3
CHI86FEM14                2900               0                3                4                 3
CHI86FEP02                1670               0                3                4                 6
CHI86FEP06                1150               0                3                2                 0
CHI86FEP08                7400               0                3                6                 3
CHI86FER01                2300               0                3                6                 4
CHI86FER03                1900               0                4                4                 3
CHI86FER04                2558               0                3                4                 3
CHI86FER06                2820               0                4                7                 0
CHI86FER07                2150               0                3                4                 5
CHI86FER11                2850               0                4                4                 3
CHI86FER12                2900               0                3                3                 4
CHI86FER16                3000               0                3                6                 5
CHI86FET01                1800               1                3                4                 5 
CHI86FEV03                1210               0                4                7                 6
______________________________________________________________________________________________________
                                                                                                  18
 NTSB_NBR          AIRCRAFT_WGT         DIST_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPAC   FLT_PATH_ANGLE
CHI86FEX02                1018               0                4                0                 0
CHI86FEX03                1300               0                3                1                 0
CHI86FEX06                3400               8                4                5                 3
CHI86FEX07                5000               0                4                7                 0
CHI86FEX09                1600               0                4                4                 7
CHI86FEX10                4050               0                4                1                11
CHI86MA071                3200               0                4                6                 3
CHI86MA212B               1670               2                4                6                 4
CHI87DEC01                1500               0                4                5                 0
CHI87DEC03                3150               0                4                6                10
CHI87DEC04                3300               0                4                5                10
CHI87DEE01                2950               5                3                2                 4
CHI87DEE03                 600               0                3                I                 3
CHI87DEE05                 732               0                3                1                10
CHI87DEE07                2300               1                3                6                 3
CHI87DEE08                 890               0                4                0                 3
CHI87DEE09                 510               0                3                1                 3
CHI87DEE10                1550               0                3                3                 5
CHI87DEM02                1200               0                3                4                 4
CHI87DEM04                 925               1                4                3                 4
CHI87DEM05                3800               0                3                6                 5
CHI87DEM07                2690               0                3                4                11
CHI87DEM08                1670               0                3                4                 3
CHI87DEM09               10500               0                4               11                 9
CHI87DEM10                2900               0                3                4                 5
CHI87DEM11                2400               0                4                4                 6
CHI87DEM12                1050               0                3                2                 0
CHI87DEP01                1650               0                3                0                 0
CHI87DEP06                 790               0                4                4                 9
CHI87DEP07                4800               0                4                6                 6
CHI87DEP08                 850               0                3                3                 3
CHI87DEP09                6000               0                3                4                 3
CHI87DEP10                 850               0                4                5                 8
CHI87DER03                3100               0                3                3                 3
CHI87DER05                2300               0                3                3                 4
CHI87DER08                4400               0                3                4                 0
CHI87DER09                2000               0                3                4                 6
CHI87DER10                5000               0                3                5                 8
CHI87DER12                1500               0                3                3                 3
CHI87DET03                 850               0                3                3                 0
CHI87DET05                 785               0                3                2                 0
______________________________________________________________________________________________________
                                                                                                   19
 NTSB_NBR          AIRCRAFT_WGT         DIST_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPAC   FLT_PATH_ANGLE
CHI87DET07                1500                0                4               7                  3
CHI87DET08                2500                0                4               8                  6
CHI87DEX06                2300                0                3               4                 11
CHI87DEX07                3200                0                4               4                  0
CHI87DEX08                1650                1                3               3                  4
CHI87FA004A               2325                2                3               6                  3
CHI87FA004B               2550                2                4               7                  6
CHI87FA012                1625                0                4               5                  8
CHI87FA040                2575                2                4               5                  0
CHI87FA048                2650               33                3               5                  6
CHI87FA054                3000                1                4               5                  3
CHI87FA057                3600                0                3               2                  3
CHI87FA069                3800                1                4               7                  0
CHI87FA083                2300                0                4               7                  3
CHI87FA104                3400                0                4               8                  7
CHI87FA129                1600                0                4               4                  9
CHI87FA140                2200                1                4               6                  8
CHI87FA149                2200                0                4               5                  0
CHI87FA151                2650                0                4               7                  4
CHI87FA198                2950                0                3               0                  0
CHI88DCA01                3200                0                3               1                  0
CHI88DEE01                 900                0                3               4                  3
CHI88DEE04                3300                0                4               7                  0
CHI88DEE06                2900                0                3               5                  4
CHI88DEE07                2050                8                3               1                  0
CHI88DEG01                2000                0                3               0                  0
CHI88DE101                2003                0                3               5                  6
CHI88DE103                2150                0                3               4                  3
CHI88DEM01                7400                0                3               6                  5
CHI88DEM03                3750                0                3               4                  3
CHI88DEM07                1500                0                3               3                  5
CHI88DEP02                3400                0                4               5                  5
CHI88DEP04                2150                0                3               3                  3
CHI88DEP05                1000                0                3               4                  3
CHI88DEP06                 900                0                3               2                  3
CHI88DEP08                 935                0                3               2                  3
CHI88DEP09                1300                0                3               3                  3
CHI88DEP10                2900                0                3               3                  3
CHI88DEP11                4500                0                3               5                  8
CHI88DER02                1650                0                4               0                  0
CHI88DER03                2300                0                3               4                  0
_______________________________________________________________________________________________________
                                                                                                   20
 NTSB_NBR          AIRCRAFT_WGT         DIST_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPAC   FLT_PATH_ANGLE
CHI88DER04                2900               0                3                4                 0
CHI88DER07                1300               0                4                0                10
CHI88DER09                1130               0                3                4                 3
CHI88DET01                2550               0                3                0                 4
CHI88DET03                 741               0                3                4                 3
CHI88DET04                4000               0                3                4                 3
CHI88DEX01                2800               0                4                4                 0
CHI88DEX02                1215               0                3                2                 6
CHI88DEX03                2150               5                3                3                 0
CHI88DEX06                1220               0                3                2                 0
CHI88DEX07                2350               0                3                4                 0
CHI88DEX08                2450               0                3                1                 4
CHI88FA001                1907               0                3                6                 3
CHI88FA079                4150               0                4                1                11
CHI88FA090                3400               0                4                7                 5
CHI88FA102                1650               0                4                4                10
CHI88FA177                1200               0                3                3                 0
CHI88FA178                 925               0                3                4                 0
CHI89DEP02                2300               0                3                4                 5
CHI89DEV01                1670               0                3                4                 3
CHI89DEV03                2350               0                3                4                 5
CHI89DEV05                2650               0                3                4                 5
DCA85AA020                6615               0                3                1                 3
DCA88AA028B               3200               0                4                9                 0
DEN83FA045                2822               0                3                4                 0
DEN83FA049                1300               1                4                0                 3
DEN83FA053                3800               0                4                7                 0
DEN83FA056                3150               0                4                7                 0
DEN83FA070                2200               0                4                6                 5
DEN83FA071                2800               1                4                6                 0
DEN83FA072                2450               0                3                7                 0
DEN83FA077                1450               0                4                0                 0
DEN83FA084                2800               0                3                5                 0
DEN83FA087                3800               0                4                0                 0
DEN83FA089                3400               0                3                7                 0
DEN83FA090                1600               0                4                0                 0
DEN83FA092                4150               0                4                0                 0
DEN83FA108                2400               0                4                7                 0
DEN83FA116                2400               0                4                7                 0
DEN83FA120                1670               1                4                4                 0
DEN83FA122                3200              45                3                1                 0
_____________________________________________________________________________________________________
                                                                                                   21
 NTSB_NBR          AIRCRAFT_WGT         DIST_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPAC   FLT_PATH_ANGLE
DEN83FA123                2550               0                4                7                  0
DEN83FA129                2950               0                3                0                  0
DEN83FA150                2690               0                4                4                  0
DEN83FA152                3850               0                4                5                  0
DEN83FA156                1750               0                4                4                 11
DEN83FA180                2900               0                4                s                  0
DEN83FA183                3600               0                3                6                  1
DEN83FA203                1500              25                4                5                  0
DEN83FA214                2550               0                4                7                  0
DEN83FA221                2740               1                4                4                  9
DEN83FA222                1750              13                4                5                  2
DEN83FTC02                 900               0                4                7                  0
DEN83FTE06                 520               1                3                5                  4
DEN83FTE12                2900               8                3                5                  0
DEN83FTG01                1100               0                4                6                  0
DEN83FT103                1750               0                3                4                  0
DEN83FT104                1675               0                4                4                  0
DEN83FTK03                3400               3                4                8                  0
DEN83FTK04                2550               5                4                2                  0
DEN83FTK05                2400               0                4                4                  0
DEN83FTM04                2900               0                3                4                  0
DEN83FTM05                 550              25                3                3                 11
DEN83FTM07                 750               0                3                2                  0
DEN84FA010                2800               0                4                7                  0
DEN84FA011                2550              28                4                0                  2
DEN84FA012                3400               0                3                3                  0
DEN84FA019                3000               0                4                0                  0
DEN84FA039                3325               0                4                5                  0
DEN84FA049                3125               0                4                0                  0
DEN84FA064                1220               0                3                1                  0
DEN84FA076                3650               0                4                6                  0
DEN84FA081                2350               0                4                0                  0
DEN84FA085                3100               0                4                7                  0
DEN84FA086                3800               0                4                8                  0
DEN84FA102                3200               0                4                1                  0
DEN84FA106                485O              20                3                2                  0
DEN84FA107                2740               4                4                7                  0
DEN84FA115                2650               5                4                4                  0
DEN84FA137                2150               0                4                4                  0
DEN84FA142                2100              10                3                0                  0
DEN84FA143                3800               0                3                4                  3
______________________________________________________________________________________________________
                                                                                                    22
 NTSB_NBR          AIRCRAFT_WGT         DIST_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPAC   FLT_PATH_ANGLE
DEN84FA144                2450              15                4               3                  0
DEN84FA155                2800               0                3               2                  0
DEN84FA172                2800               0                4               0                  0
DEN84FA184                2800               0                3               2                  0
DEN84FA188                5550               0                4               0                  0
DEN84FA194                2150               0                4               3                  3
DEN84FA196                2658               0                4               4                  0
DEN84FA199                2740               0                4               4                  0
DEN84FA202                2550               0                4               4                  0
DEN84FA211                2650               0                4               4                  0
DEN84FA219                2900               0                4               0                  0
DEN84FA222               10500               0                4               8                  0
DEN84FA242                2550               0                4               7                  4
DEN84FA259                2300               0                4               8                  0
DEN84FA274                2717               0                3               5                  0
DEN84FA275                2800               0                4               3                  0
DEN84FA278                1500               0                4               3                  0
DEN84FA290                4150               0                4               0                  0
DEN84FA293                2300               0                3               0                  0
DEN84FA295                3300               0                4               8                  0
DEN84FA298                2950               0                4               8                  0
DEN84FTK01                1450               0                3               4                  0
DEN84FTM02                1500               0                3               4                  0
DEN84FTM03                1285               0                3               0                  0
DEN84FU001                 450               5                4               2                  0
DEN84LA101                2300               0                3               1                  0
DEN85FA007                3200               0                3               2                  3
DEN85FA008                3350               0                4               7                  0
DEN85FA009                3000               0                4               8                 11
DEN8SFA010                3400               0                4               7                  0
DEN85FA014                2575               0                4               6                  4
DEN85FA019                3100               0                4               7                  5
DEN85FA027                3200               0                4               5                  0
DEN85FA028                1650               0                4               4                  9
DEN85FA034                3300               0                4               0                  0
DEN85FA035                2800              15                4               6                  0
DEN85FA037                3400               0                4               0                  0
DEN85FA048                3400               2                4               0                  0
DEN85FA067                4150              15                4               7                  0
DEN85FA069                1600               0                3               4                  0
DEN85FA074                2550               0                4               0                  0
______________________________________________________________________________________________________
                                                                                                  23
 NTSB_NBR          AIRCRAFT_WGT         DIST_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPAC   FLT_PATH_ANGLE
DEN85EA084                1150               0                4               4                 11
DEN85FA088                1650               0                4               7                  0
DEN85FA096                2900               0                4               6                  0
DEN85FA097                2740              26                4               8                  9
DEN85FA099                2800               0                4               5                  3
DEN85FA102                2550               0                4               7                  3
DEN85FA118                2400               0                4               0                  0
DEN85FA153                3400               0                3               3                  8
DEN85FA179                1220               1                3               2                  0
DEN85FA180                2550               1                4               3                  0
DEN85FA186                2325               0                4               4                  0
DEN85FA202                2200              10                4               6                  5
DEN85FA203                2550              27                4               7                  3
DEN85FA222                2400               0                4               6                 11
DEN85FA225                2800               0                3               5                  3
DEN85FA229                1750               0                4               4                  0
DEN85FA236                2900               0                4               7                  4
DEN85FA241                5040               0                4               6                  6
DEN85FA246                2550               1                4               4                  0
DEN85FTE08                2950               0                3               4                  0
DEN85FT102                1150               s                3               4                  0
DEN85FTK01                2950               0                3               5                  9
DEN85FTK03                1670               1                3               4                  3
DEN85FTM06                2500               1                3               6                  0
DEN85LTG02                3600               0                4               7                  0
DEN85LTG06                2950               5                3               1                 11
DEN86FA002                1625               0                4               6                 11
DEN86FA008                2350               0                4               6                  5
DEN86FA009                2550               0                4               5                  9
DEN86FA022                2900               0                4               7                 11
DEN86FA023                2950               1                3               4                  8
DEN86FA028                2900              45                4               7                  8
DEN86FA039                3150               0                4               7                  9
DEN86FA054                4150               0                4               2                  3
DEN86FA056                3800               4                4               9                  0
DEN86FA060                1670               2                3               3                  4
DEN86FA070                1670               0                3               6                  3
DEN86FA071                2800              15                4               5                  0
DEN86FA076                3800               0                4               5                  0
DEN86FA077                4016               0                3               6                  7
DEN86FA092                2500               0                4               4                  3
________________________________________________________________________________________________________
                                                                                                   24
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
DEN86FA101               3400               0               4               3               0
DEN86FA115               4000              15               3               4               0
DEN86FA131               2150               0               4               6               3
DEN86FA141               1600               0               3               4               0
DEN86FA142               4000               0               4              11               0
DEN86FA146                615               3               4               4              10
DEN86FA147               1800               0               3               4              11
DEN86FA149               1500               1               3               5               4
DEN86FA150               3650               0               4               9              10
DEN86FA160               2450               0               4               4               9
DEN86FA165               3600               0               4               7              10
DEN86FA170               1600               0               4               5              11
DEN86FA181               3000               0               4               9               6
DEN86FA207               1450               1               3               3               3
DEN86FA208A              4100               0               4               8               8
DEN86FA211               1250               0               4               4               3
DEN86FA213               1563               2               4               7               0
DEN86FA216               3400               0               4               5               3
DEN86FA223               2200               0               4               4               0
DEN86FA231               5300               0               4               7               0
DEN86FA232               3800               0               4               8              10
DEN86FA249               2800               0               4               9               0
DEN86FA252               2300               0               4               8               0
DEN86FA254               2950               0               4               8               3
DEN86FTE01               1000               0               3               4               9
DEN86FTE02               1825               0               4               0              11
DEN86FTG02               1507               1               3               4               8
DEN86FTK01               1650               0               3               3               9
DEN86FTK02               3000               0               3               4               0
DEN86FTK03               2300               0               3               7               4
DEN86FTK04               2900               0               4               5               3
DEN86FTM02                820               0               3               3               0
DEN87DTI01               4000               0               3               5               3
DEN87DTK01               1500               0               4               8               3
DEN87DTM01                600               0               4               5               7
DEN87FA002               1220               0               4               3               0
DEN87FA007               2900               0               4               6               3
DEN87FA008               2450               0               4               4               3
DEN87FA011               2400               0               4               4               0
DEN87FA014               2075               0               4               4              11
DEN87FA017               3600               5               3               6               3
_______________________________________________________________________________________________
                                                                                             25
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
DEN87FA018               4150               0               4               1               3
DEN87FA023               3650               0               4               6               3
DEN87FA024               2550               0               4               0               3
DEN87FA035               1750               0               4               4              11
DEN87FA036               2150               0               4               5               3
DEN87FA037               1625               0               3               3               0
DEN87FA038               2300               0               3               4               3
DEN87FA041               3800               0               4               7               0
DEN87FA046               2900               0               3               9               0
DEN87FA050               3100               0               4              10               0
DEN87FA057               3800               0               3               5               3
DEN87FA061               3800               0               4               8               3
DEN87FA064               4000              11               4               8               3
DEN87FA081               2000               0               4               4               9
DEN87FA090               1650               0               4               5               9
DEN87FA091A              4500               0               4               7               9
DEN87FA091B              2900               0               4               7               0
DEN87FA103               2300               0               4               6               3
DEN87FA111               1500               0               3               4               0
DEN87FA134               2900               4               4               6               4
DEN87FA147               4150               0               4               1               0
DEN87FA148               2900               0               4               6              11
DEN87FA159               2450               0               4               6              10
DEN87FA167               2740               0               4               4              11
DEN87FA177               1670               0               3               4               4
DEN87FA178               2800               0               4               8               3
DEN87FA186               2575               0               4               7              11
DEN87FA188               2900               0               3               8               0
DEN87FA203               4000               0               4               5               0
DEN87FA216               1618               0               4               7               6
DEN87FA218               2250               0               4               7               0
DEN87FA219               2950               0               4               6               3
DEN87FA220               2670               0               4               6               4
DEN87FA224               1650               0               4               0              10
DEN87FA226               2650               0               4               8               3
DEN87FA230               2200               0               4               5               5
DEN87FA234               1750               0               4               6               3
DEN87FA237               2750               0               4               6               3
DEN87LA170               1237               0               4               7               0
DEN88DQA01               1600               0               4               0              11
DEN88DTE02               4000               4               4               6               0
_______________________________________________________________________________________________
                                                                                             26
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
DEN88DTE06               1100               0               3               5               3
DEN88DTK01               4000               0               4               7               7
DEN88DTM01               3300               0               4               7              10
DEN88DTM03               1950               0               4              11              11 
DEN88FA001               1500               0               3               4               0
DEN88FA016               3600              12               4               9               3
DEN88FA021               2558               0               4               4               7
DEN88FA023               2650               0               4               8               3
DEN88FA030               2900               0               4               9               4
DEN88FA033               2900               0               4               9               4
DEN88FA036               1670               0               4               6               3
DEN88FA037               2325               0               4               1              11
DEN88FA054               2200               0               4               7               0
DEN88FA062               1500               0               4               7              11 
DEN88FA071               2300               0               4               7               0
DEN88FA084               2000               0               4               4               3
DEN88FA090               3600               2               4               5               3
DEN88FA096               2325               0               4               6               0
DEN88FA097               1500               0               4               5               0
DEN88FA098               2650               0               3               8               3
DEN88FA099               2200               0               4               5               3
DEN88FA100               2800               3               4               5              11
DEN88FA106               2860               0               4               1               4
DEN88FA107               2230               0               4               5               5
DEN88FA109               3800               0               4               5              11
DEN88FA110               1670               0               4               4              11
DEN88FA111               4000               0               4               5               5
DEN88FA112               1200               0               4               5              10
DEN88FA114               4250               1               4               6               4
DEN88FA119               2200               0               4               5              11
DEN88FA120               1400               0               4               4               6
DEN88FA121               2400               0               4               4               3
DEN88FA128               2800               0               4               6               3
DEN88FA141               2900               0               4               8               0
DEN88FA186               1200               0               4               4               9
DEN88FA193               2740               0               4               0              11
DEN88FA212               2000               0               4               5               7
DEN88GA185               2800               0               3               7               0
DEN89FA001               1670               0               4               4               0
DEN89FA007               2575               0               4               7               4
DEN89FA009               3800               0               4               0               0
_______________________________________________________________________________________________
                                                                                             27
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
DEN89FA010               2550               0               4               4               3
DEN89FA017               2150               0               4               5               4
DEN89FA019               4250               0               4               7               0
DEN89FA036               3300               0               4               7               4
DEN89FA038               1600               0               4               4              11
DEN89FA041               2900               0               4               8              10
DEN89FA045               2900               0               4               7               3
DEN89FA056               8750               3               4               7               3
DEN89FA101               3200               0               3               1               3
FTW83FA078               1600               1               4               4              11
FTW83FA079               2575               0               4               0               0
FTW83FA092               1600               0               3               3               3
FTW83FA097               4150               0               4               7               0
FTW83FA101               2575               3               3               4               0
FTW83FA126               2300               2               4               5               2
FTW83FA134               2550              10               4               4               3
FTW83FA142               3300               0               4               8               0
FTW83FA143               2350               0               3               1               0
FTW83FA144               2150               8               4               7               3
FTW83FA150               2550               1               4               6               0
FTW83FA170               3600               4               4               9               0
FTW83FA176               2300               0               4               5               0
FTW83FA222               2200              11               4               6               8
FTW83FA226               2800              10               4               4               0
FTW83FA251               2150               0               3               0               0
FTW83FA254               2175               0               4               8               0
FTW83FA259               3190               0               4               4               0
FTW83FA261               2900               0               4               7               0
FTW83FA270               1500               1               4               5              11
FTW83FA276               1500               0               4               5               0
FTW83FA280               3200               0               4               0               0
FTW83FA302               1600               0               3               6               0
FTW83FA310               3600               0               4               5               6
FTW83FA311               2450              10               4               2               0
FTW83FA323               1500               0               4               3               0
FTW83FA343               1670               7               4               3               0
FTW83FA361               2900              19               4               9               3
FTW83FA362               2300               2               4               5               0
FTW83FA373               2500              10               4               8               0
FTW83FA387               3400               1               4               5               0
FTW83FA441               2300               0               4               5               0
______________________________________________________________________________________________
                                                                                            28
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
FTW83LA296               2650               0               3               0               0
FTW84FA014               3350               0               4               8               0
FTW84FA020               7800               1               4               6               0
FTW84FA023               2300               0               4               0               0
FTW84FA032               2950               0               4               8               0
FTW84FA034               1260               0               4               4               0
FTW84FA050               2325               0               4               8               0
FTW84FA057               3800               1               3               6               0
FTW84FA060               1670               9               4               6               0
FTW84FA068               2740               0               4               0               0
FTW84FA083               3325               5               4               8               0
FTW84FA102               2850              10               4               0               0
FTW84FA115               1800               0               4               0               0
FTW84FA121               3600               9               3               6               0
FTW84FA125               1670               3               4               7               0
FTW84FA170               2400               5               4               3               0
FTW84FA171               1800               0               4               5               0
FTW84FA180               3350               0               4               7               0
FTW84FA206               5300               0               4               7              10
FTW84FA209               2000               1               4               5               6
FTW84FA218               1770               0               4               4               0
FTW84FA220               1000               0               4               7               0
FTW84FA224               1250               0               4               4               0
FTW84FA237               2775               0               4               0               9
FTW84FA242               2775               0               4              11               0
FTW84FA243               2500               0               3               0               0
FTW84FA244               3350               0               4               2               0
FTW84FA264               3350               0               4               7               3
FTW84FA272               1650               0               4               6               0
FTW84FA288               1950               0               4               4               0
FTW84FA291               1670               0               4               7               0
FTW84FA297               1615               0               4               8               0
FTW84FA300               1670               0               3               4               0
FTW84FA321               3200               0               4               0               0
FTW84FA331               3350               0               4               8               0
FTW84FA342               3400               1               3               6               0
FTW84FA343               1600               0               4               4               5
FTW84FA347               1066               0               4               0               0
FTW84FA354               2950               0               4               4              11
FTW84FA382               2150               0               4               6               0
FTW84FA393               3200               1               3               0               0
_______________________________________________________________________________________________
                                                                                             29
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
FTW84FA404               3400               0               4               7               0
FTW84FA408               2220               0               4               6               9
FTW84FPJ01               1800               0               4               7               0
FTW84LA416               3800               0               4               8               3
FTW84MA069               4000               8               4               8               0
FTW85FA006               1670               0               4               7               0
FTW85FA032               3200               0               4               1               0
FTW85FA034               1800               0               4               7               0
FTW85FA041               5300               0               4               7               0
FTW85FA045               2100               0               4               5               8 
FTW85FA050               1670               0               4               1               0
FTW85FA054               3325               0               3               9               0
FTW85FA055               3650               0               4              10               0
FTW85FA060               2075               2               4               4               0
FTW85FA065               2650               0               4               7               0
FTW85FA079               1670               0               4               5               0
FTW85FA084               3600              35               4               6               0
FTW85FA087               3800               0               4               7               3
FTW85FA088               2740               0               4               9               0
FTW85FA090               2300               0               4               5              10
FTW85FA100               4150               3               3               1               9
FTW85FA130               2050               0               3               2               9
FTW85FA140               2400               0               4               4               3
FTW85FA152               2000               0               4               4               3
FTW85FA158               2750               1               3               5               0
FTW85FA159               1670               0               4               4               0
FTW85FA171               3800               0               4               4               0
FTW85FA176               1670               0               4               3               0
FTW85FA180               1670               8               4               5               0
FTW85FA188               8500               0               4               1              10
FTW85FA204               1095               1               4               6               9
FTW85FA220               3100               8               4               6              11
FTW85FA245               1500               3               4               4               5
FTW85FA247               2900               1               4               4               6
FTW85FA254               2350               0               4               2               3
FTW85FA257               3800               1               4               4               0
FTW85FA261A              1600               0               3               5              10
FTW85FA261B              1670               0               4               5              11
FTW85FA265               4190               0               4               0               0
FTW85FA287               2000               0               4               0               0
FTW85FA300               4190               0               4               1               5
______________________________________________________________________________________________
                                                                                            30
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
FTW85FA306               1600               0               3               7               0
FTW85FA310               8500               0               4               1               0
FTW85FA331               1804               6               4               5               0
FTW85FA335               5300               0               4               8               0
FTW85FA346                900               0               4               8              11
FTW85FA358               2800               0               3               4               0
FTW85FPA01               5000               0               3               0               0
FTW85FPA02               2900               4               3               7               0
FTW85FQG03               2900               0               4               0              10
FTW85FRD01               1450               0               4               4               3
FTW85FRD02                735               0               4               3              11
FTW85FRD03               7100               0               4               4               0
FTW85FRG01               1450               0               3               4              11
FTW85MA296               2900               0               4               0               0
FTW86FA008               2400               2               4               8               0
FTW86FA019               2400               4               4               8               0
FTW86FA023               1670               0               4               6               0
FTW86FA024               3300               1               4               6               3
FTW86FA026               1600               0               4               4              11
FTW86FA027A              2200               1               4               4              11
FTW86FA027B              1150               1               3               0               0
FTW86FA028               3000               2               4              10               6
FTW86FA033               3200               0               4               1               0
FTW86FA035               2950               0               4               9               0
FTW86FA046               1450              12               4               4               8
FTW86FA049A              1150               0               3               5              10
FTW86FA050               3532               0               4               5              11
FTW86FA054               1600               0               4               5               3
FTW86FA063               2800               2               4               0               0
FTW86FA076               5300               0               4               6               8
FTW86FA086B              1220               5               3               6               3
FTW86FA092               3800              31               4               9              11
FTW86FA098               3800               5               4               0              11
FTW86FA142               3200               0               3               3               0
FTW86FA154               1750               0               4               3               0
FTW86FA171               1670               0               3               4               0
FTW86FPA05               2740               0               3               5               0
FTW86FPA07               1500               1               4               7               0
FTW86FPA18               5400               0               3               4               9
FTW86FPA21               1600               0               3               3               3
FTW86FPA22               1425               0               3               5               0
_______________________________________________________________________________________________
                                                                                             31
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT    ACFT_DAMAGE    AIRSPEED_IMPACT  FLT_PATH_ANGLE
FTW86FPA23               4000               0               4               5               0
FTW86FPA26               1150               0               3               4               0
FTW86FPA27               2910               1               4               4               5
FTW86FQG02               2050               0               3               1              11
FTW86FQG04               1560               9               4               0               0
FTW86FQG09               5000               0               3               6               0
FTW86FRA09               2450               5               4               4               8 
FTW86FRD10               2150               8               3               4               3
FTW86FRD11               4500               0               3               0               9
FTW86FRD24               2350              15               3               0               0
FTW86FRD25               9260               2               4               6              11
FTW86FRG02               2900              25               3               5               0
FTW86FRG10               2575               0               4               4               0
FTW86FRG19               1600               1               4               6               0
FTW86LPJ10               3725               0               3               3               0
FTW86LQG17               1500               0               4               3               3 
FTW86LRD18               4500               0               4               4               3
FTW86MA001B              1670               0               4               4               0
FTW86MA010               3400              20               4               5               9
FTW87DPA04               1129               0               3               3               6
FTW87DPJ03               4200               0               3               6               9
FTW87DPJ04               5000               0               3               4               3
FTW87DPJ05               1930               2               4               7               8
FTW87DPJ07               2740               0               3               0               0
FTW87DPJ09               2500               0               3               2               0
FTW87DRA02               1285               0               4               1               3
FTW87DRA04               4450               0               4               6               0
FTW87DRA05               3300               0               3               3               4
FTW87DRA07               5000               0               3               6               0
FTW87DRA08                840               0               3               3               5
FTW87DRD03               7200               0               3               2               3
FTW87DRD04               3700               1               3               4               5
FTW87DRD12               2000               2               4               3               3
FTW87DRG01               1112               0               4               6               8
FTW87DRG04               1500               0               4               6               3
FTW87DRG05               6000               0               3               4               3
FTW87FA007               3200               1               3               1               4
FTW87FA017               1670              61               4               4               6
FTW87FA022A              2150               0               4               4              10
FTW87FA022B              1650               0               3               4              10
_______________________________________________________________________________________________
                                                                                            32
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
FTW87FA029               2650               15                4                 8                 0
FTW87FA031               1700                3                4                 6                 5
FTW87FA043               2740                2                4                 9                 0
FTW87FA047               1600                4                4                 3                 0
FTW87FA054               1950                4                4                 4                 3
FTW87FA064               3800                0                4                10                 0
FTW87FA087               2050                0                3                 4                 9
FTW87FA088               2550                0                4                 6                10
FTW87FA090               3600                0                3                 4                 9
FTW87FA093               1600                0                3                 6                 5
FTW87FA111               3200                0                3                 3                 0
FTW87FA116               3400                0                4                 0                 0
FTW87FA123               3600                8                4                 4                11
FTW87FA134               2550                0                3                 6                 6
FTW87FA137               1560                0                3                 3                 0
FTW87FA139               3400                2                4                 4                 5
FTW87FA15l               4200                0                3                 4                 3
FTW87FA161               2800                0                4                 4                 5
FTW87FA168               2450                4                3                 0                 5
FTW87FA170               3325                2                3                 4                 5
FTW87FA183               2900                0                4                 6                11
FTW87FA190               3600                0                3                 5                 0
FTW87FA196               3400                1                4                 5                 3
FTW87FA197               6500                0                3                 6                 6
FTW87FA198               3200                0                3                 1                11
FTW87FA206A              3600                0                4                 4                11
FTW87FA208               8000                0                3                 0                 9
FTW87FA209               2575                0                4                 6                 8
FTW87FA210               1220                0                3                 5                 9
FTW87FA223               1220                0                3                 4                 3
FTW87MA133               4100                0                4                 5                11
FTW88DPA03               6500                0                3                 5                 9
FTW88DPA04               1350                0                3                 6                 8
FTW88DPA05               1200                0                3                 3                 6
FTW88DPA06               1600                0                3                 2                 0
FTW88DPA09               1250                0                3                 4                 4
FTW88DPJ01                935                0                4                 7                 7
FTW88DPJ02               2900                0                4                 3                 0
FTW88DPJ03               2350                1                4                 5                 6
FTW88DPJ05               2400                0                4                 4                 5
FTW88DPJ08               1670               13                3                 2                 7
______________________________________________________________________________________________________
                                                                                                   33
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
FTW88DPJ09               1670                0                3                 1                 3
FTW88DPJ10               4200                0                4                 5                 0
FTW88DPJ11               1600                1                3                 3                 5
FTW88DPJ13               6000                0                3                 4                 4
FTW88DQG02               5000                0                3                 0                10
FTW88DQG03               2775                0                3                 5                 3
FTW88DQG04               3000                0                3                 6                 3
FTW88DRA04                785                0                3                 2                 0
FTW88DRA06               1700                5                4                 4                 0
FTW88DRA07               4500                0                4                 4                 3
FTW88DRA10               1425                0                3                 6                 6
FTW88DRA11               2430                0                4                 0                11
FTW88DRA12               4500                0                3                 6                 3
FTW88DRA14               3750                0                3                 4                 4
FTW88DRA15                850                0                4                 4                11
FTW88DRD02               3800                0                3                 3                 3
FTW88DRD04               4500                1                3                 5                 0
FTW88DRD06               4500                0                3                 3                 0
FTW88DRD07              10370                0                3                 3                 3
FTW88DRD08               4000                0                4                 4                 0
FTW88DRD11               6500                0                4                 3                 0
FTW88DRD12               2750                0                4                 2                 6
FTW88DRD14               4500                0                4                 4                 9
FTW88DRD15               4200                0                3                 6                 0
FTW88DRD16               9260                0                3                 2                 0
FTW88DRD17               4500                0                3                 4                 5
FTW88DRD18               4500                0                3                 5                 4
FTW88DRD19               520O                0                4                 6                 0
FTW88DRD20               1450               10                4                 8                11
FTW88DRG02               4500                1                3                 4                 0
FTW88DRG04               1350                2                4                 6                 3
FTW88DRG06                200                0                3                 1                 8
FTW88DRG07               4500                0                4                 4                 3
FTW88DRG10               2750                2                4                 6                 0
FTW88FA005               2350                2                4                 4                10
FTW88FA007               3400                0                4                 4                10
FTW88FA011               2300               16                4                 4                 0
FTW88FA023               3400                0                4                 7                 3
FTW88FA024               1450                0                4                 4                 9
FTW88FA032               2900                0                4                11                 0
FTW88FA046               3850                1                3                 6                 6
______________________________________________________________________________________________________
                                                                                                   34
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT     ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
FTW88FA057                1450               0                 4                 4                 6
FTW88FA060                3600               0                 3                 6                 3
FTW88FA063                3300               0                 4                 8                11
FTW88FA069                1200               0                 4                 6                10
FTW88FA074A               1600               0                 3                 5                 4
FTW88FA074B               1200               0                 4                 4                11
FTW88FA084                2300               0                 4                 5                 0
FTW88FA085                3200               0                 4                 0                 8
FTW88FA100                2150               0                 4                 4                 9
FTW88FA103                1710               1                 4                 5                 6
FTW88FA104                2400               0                 4                 5                 0
FTW88FA114A               2400               0                 4                 5                 3
FTW88FA114B               2900               0                 3                 5                 3
FTW88FA119                3300               0                 4                 7                 3
FTW88FA162                2400               0                 4                 6                 4
FTW89DPA01                 600               0                 3                 3                 9
FTW89DPJ01                1235               0                 4                 1                 3
FTW89DPJ02                1260               0                 4                 6                 9
FTW89DQA01                3000               0                 3                 4                 0
FTW89DRA02                1100               0                 3                 6                10
FTW89DRD01                1200               0                 4                 4                 4
FTW89DRD02                2900               4                 3                 3                 8
FTW89FA006                2575               0                 4                 8                 0
FTW89FA015                1600               0                 4                 4                11
FTW89FA023                3600               0                 4                 7                 3
FTW89FA025                1400               0                 4                 6                10
FTW89FA028                1670               0                 4                 5                11
LAX83FA067                2400               0                 4                 0                 0
LAX83FA091                2800               0                 4                 7                 3
LAX83FA095                4000               0                 4                 8                 0
LAX83FA120                6000               0                 4                 6                 0
LAX83FA121                2050               0                 4                 1                 0
LAX83FA124                1500               0                 4                 9                 0
LAX83FA141                3233               0                 4                 0                 0
LAX83FA144                3600               0                 4                 0                 0
LAX83FA153                2200               0                 4                 7                 0
LAX83FA160                2575               0                 4                 8                 0
LAX83FA185                3400               0                 4                 0                 0
LAX83FA192                2800               0                 4                 7                 0
LAX83FA205                2650               1                 3                 6                 3
LAX83FA211                2550               5                 4                 5                 0
_______________________________________________________________________________________________________
                                                                                                    35
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT     ACFT_DAMAGE       AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX83FA240               1860               5                   4                   0                 0
LAX83FA246               1050               0                   4                   0                 0
LAX83FA260               3400               1                   4                   6                 0
LAX83FA266               2350               0                   4                   2                 0
LAX83FA276               2550               s                   4                   0                 0
LAX83FA295               2650               1                   4                   4                 0
LAX83FA314               2200               0                   4                   5                 0
LAX83FA341               2350               1                   4                   0                 0
LAX83FA346               1110               0                   4                   0                 0
LAX83FA348               3800               0                   4                   7                 0
LAX83FA377               2400               0                   4                   6                 0
LAX83FA388               3600               0                   4                   6                 0
LAX83FA397               1400               0                   4                   4                 0
LAX83FA424               6500               0                   4                   6                 4
LAX83FA434               2150               5                   3                   5                 0
LAX83FA435                750               0                   4                   7                 0
LAX83FA439               1670               2                   4                   3                 0
LAX83FA442               1680               0                   3                   4                 8
LAX83FA455               2150              12                   4                   5                 0
LAX83FA456               2900               0                   4                   8                 0
LAX83FJA05               6250               0                   4                   7                 0
LAX83FUA02               2325               1                   4                   4                 0
LAX83FUG13               3400               0                   4                   0                 0
LAX83FUG20               2200               1                   3                   6                 0
LAX83FUJ12               2650              10                   3                   5                 0
LAX83FUJ13               2500               2                   3                   0                 0
LAX83FUM06               2650               0                   4                   7                 0
LAX83FUM08               1350               0                   4                   7                 0
LAX83FVA02               1600               0                   3                   5                 0
LAX83FVG09               3400               0                   4                   7                 0
LAX83FVG10               1650               8                   4                   0                 0
LAX83FVG13               1650               0                   4                   5                 0
LAX83FVG17               3100               1                   4                   3                 0
LAX83LUQ01               1670              45                   4                   6                 0
LAX84FA002               2800               0                   4                   9                 0
LAX84FA012               3300               0                   4                   8                 0
LAX84FA025               1200               0                   3                   4                 0
LAX84FA028               1260               0                   4                   5                 0
LAX84FA032               1450              12                   3                   1                 0
LAX84FA034               2300               0                   3                   4                 0
LAX84FA046               1128               0                   3                   4                 0
_________________________________________________________________________________________________________
                                                                                                       36 
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX84FA047              2300               35                   4                   7                 8
LAX84FA055              1700               11                   4                   &                 0
LAX84FA057              1670                0                   4                   4                 0
LAX84FA065              2450                0                   4                   7                 0
LAX84FA068              3000                0                   4                   0                 0
LAX84FA071              2800                0                   4                   7                 0
LAX84FA073              2900                3                   4                   6                 0
LAX84FA087              3400                0                   4                   0                 6
LAX84FA107              2900                1                   4                   5                 2
LAX84FA113              2900                0                   4                   8                 0
LAX84FA114              2800                0                   4                   7                 0
LAX84FA116              3125                0                   4                   0                 0
LAX84FA129              1150                1                   4                   0                 0
LAX84FA138              2650                1                   4                   5                 3
LAX84FA142              2950                0                   4                  10                 0
LAX84FA144              3400                0                   4                   4                 0
LAX84FA152              2220                0                   4                   0                 0
LAX84FA193              1300                0                   4                   0                 0
LAX84FA221              1280                0                   4                   5                 0
LAX84FA227              3600                0                   4                   4                 0
LAX84FA251              2200                0                   4                   8                 0
LAX84FA253               890                0                   4                   7                 0
LAX84FA256              2430                0                   4                   4                 0
LAX84FA258              1220                0                   4                   6                 0
LAX84FA259              2550                0                   4                   4                 0
LAX84FA280              2400                0                   4                   7                 0
LAX84FA299              3100                0                   4                   6                 0
LAX84FA300              2150                0                   3                   5                 0
LAX84FA304              1000                0                   4                   7                 0
LAX84FA319A             1670                0                   4                   4                 0
LAX84FA319B             2500                0                   4                   6                 0
LAX84FA330              1150                0                   4                   3                 0
LAX84FA367              2550                3                   4                   2                11
LAX84FA371              1670                4                   4                   8                11
LAX84FA378A             2950                0                   3                   7                 0
LAX84FA378B             2300                0                   4                   7                 0
LAX84FA390              2500                1                   4                   7                 0
LAX84FA395              3100                0                   3                   1                 0
LAX84FA396              2450                0                   4                   4                 0
LAX84FA405              3000                0                   4                   0                 0
LAX84FA407              3400                0                   4                   0                 0
________________________________________________________________________________________________________
                                                                                                       37
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX84FA421              2750                0                   4                   2                 0
LAX84FA429              1650                0                   4                   3                11
LAX84FA439              3100                0                   4                   8                 0
LAX84FA444              3800               63                   3                   4                 0
LAX84FA452              2150                0                   4                   6                 0
LAX84FA459              2050                0                   4                   0                 0
LAX84FA460              2150                0                   4                   7                 0
LAX84FA463              2400                1                   3                   4                 0
LAX84FA466              2450                0                   3                   0                 0
LAX84FA469              3400                0                   4                   8                 0
LAX84FA473              2650                0                   4                   4                 0
LAX84FA481              3000                3                   4                   5                 7
LAX84FA484              2050                1                   4                   5                 0
LAX84FA498              2200                0                   4                   7                 0
LAX84FJA02              2150                0                   4                   4                 0
LAX84FUJ04              4000                0                   4                   0                 0
LAX84FVM01              1100                0                   3                   1                 3
LAX84FVM02              2400                0                   3                   6                 0
LAX84LA305              1650                0                   3                   0                 0
LAX85FA015              1650                0                   4                   3                 0
LAX85FA019              2900                3                   3                   4                 0
LAX85FA024              3800                1                   4                   4                 0
LAX85FA030              1600                0                   4                   5                 3
LAX8SFA036              3200                0                   4                   1                 0
LAX85FA038              2150                0                   4                   6                 0
LAX85FA048              2300                7                   4                   6                 7
LAX85FA066               500                0                   4                   2                11
LAX85FA067              2775                0                   3                   0                 0
LAX85FA068              1519                3                   4                   6                11
LAX85FA069              1670                0                   4                   7                 0
LAX85FA071              2200                0                   4                   6                 0
LAX85FA074              1675                5                   4                   7                 5 
LAX85FA078              2400                2                   4                   5                 7
LAX85FA086              2300                9                   4                   7                 0
LAX85FA088              2950                0                   4                   7                 3
LAX85FA093              2950                8                   4                   9                 0
LAX85FA097              2950                0                   3                   4                 3
LAX85FA100              2650                0                   4                   7                 7
LAX85FA102              3400               25                   4                   4                 0
LAX85FA106              2500                2                   4                   0                 6
LAX85FA115              9500               25                   4                   5                 4
________________________________________________________________________________________________________
                                                                                                       38
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX85FA122              3600                0               3                  5                 3
LAX85FA123A             1450                5               4                  8                 0
LAX85FA123B             1670                5               3                  5                 7
LAX85FA128              2650                0               3                  4                 5
LAX85FA136              3000                0               3                  0                 0
LAX85FA137              2800                0               4                  5                 0
LAX85FA142              3400                0               3                  2                 0
LAX85FA159              2725                1               4                  5                11
LAX85FA163              1670                0               4                  6                 9
LAX85FA178              1600               10               4                  6                 8
LAX85FA192              1600                0               4                  3                 0
LAX85FA193              1600                0               3                  4                 3
LAX85FA199              3100                0               4                  0                 0
LAX85FA202A             2300                0               4                  4                11
LAX85FA202B             2150                0               3                  4                 4
LAX85FA213              3300                0               4                  7                 0
LAX85FA216              2900                1               4                  7                 0
LAX85FA217              4150                0               4                  2                 0
LAX85FA218              1670                0               4                  6                 5
LAX85FA228              5300                0               4                  5                 0
LAX85FA232              3000                1               4                  5                 5
LAX85FA241              5250                0               4                  1                 0
LAX85FA251              3600                0               4                  5                 9
LAX85FA253              2500                0               4                  4                 0
LAX85FA259              1710                0               4                  6                 0
LAX85FA262              3600                0               4                  4                 0
LAX85FA280              1300                0               3                  1                11
LAX85FA283              2550                0               4                  4                 0
LAX85FA286             11200                0               4                  5                 7
LAX85FA311              1670                0               4                  4                 9
LAX85FA355A             1600                0               4                  1                 0
LAX85FA355B             1600                0               4                  6                 0
LAX85FA384              3650                0               3                  5                 3
LAX85FA385              1100                0               3                  6                 4
LAX85FA402              4300                0               3                  1                 0
LAX85FJA06              6250                0               4                  0                 0
LAX85FUG01              3350                0               3                  2                 0
LAX85FUM01              1500                0               4                  7                 0
LAX85FVA02              2200                0               4                  0                 0
LAX85FVW01              1600               12               3                  2                 0
LAX85LA273              1600                0               3                  4                 0
____________________________________________________________________________________________________
                                                                                                  29
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX85LVA04               8500                0                   3                   0                0
LAX86DVA04               2400                0                   4                   0                0
LAX86DVA06               8500                0                   4                   2                0
LAX86DVA07                941                5                   4                   0                9
LAX86DVA09               3100                2                   3                   0                0
LAX86DVA17               2850                4                   4                   5                7
LAX86FA003               2400                0                   4                   4                0
LAX86FA007               2150                0                   4                   8                0
LAX86FA014               3200                0                   4                   5               10
LAX86FA024               1650                0                   3                   4                0
LAX86FA038               2000               28                   4                   0                0
LAX86FA039               2950                0                   4                   4                9
LAX86FA048               2800                0                   4                   8                0
LAX86FA063               3100                0                   4                   9                3
LAX86FA069               3100                4                   4                   6                7
LAX86FA077               3800                0                   4                   5                0
LAX86FA089               2300                1                   4                   8                0
LAX86FA092               3800                0                   4                   9                6
LAX86FA106               3200                0                   4                   1                0
LAX86FA107               2550                0                   4                   7                3
LAX86FA114               3200                0                   4                   5                0
LAX86FA130               2350                1                   4                   7                5
LAX86FA178               2550                0                   4                   5                9
LAX86FA183               1500                0                   4                   0                0
LAX86FA220               2200                0                   4                   5                9
LAX86FA240               2500                1                   4                   4                0
LAX86FA243               3200                1                   4                   0                0
LAX86FA247               3150                0                   4                   6                3
LAX86FA249               1570                0                   4                   4                8
LAX86FA282               1600                0                   4                   4                3
LAX86FA297               1750                0                   4                   3                8
LAX86FA326               2800                0                   4                   5                4
LAX86FA328               2300                1                   4                   6                5
LAX86FJA03               2950                0                   3                   2                9
LAX86FJA06               3200                0                   4                   7               10
LAX86FUM02                496                0                   4                   7                0
LAX86FUM04               1650                0                   4                   1                5
LAX86FVA08               1050                0                   4                   6                3
LAX86FVA10               8500                0                   3                   1                3
LAX86FVA11               2850                0                   3                   1                0
LAX86FVA12               6000                1                   4                   6                8
_________________________________________________________________________________________________________
                                                                                                       40
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX86FVA14              3100                5                   3                   4                 7
LAX86FVD01              1500                0                   4                   0                11
LAX86FVD02               550                0                   3                   6                11
LAX86FVD04              1150                0                   4                   6                11
LAX86FVD07              2850                0                   4                   1                 0
LAX86MA050A             4150                0                   4                   2                 9
LAX86MA050B             4150                0                   4                   2                11
LAX86MA311              3200                0                   4                   4                11
LAX87DJA02              2300                2                   4                   5                 3
LAX87DJA03              6250                0                   4                   0                 0
LAX87DJA07              6250                0                   3                   4                 0
LAX87DUG04              1250                0                   3                   4                 0
LAX87DUG06              1650                0                   3                   2                 3
LAX87DUG07              1100                1                   4                   7                 0
LAX87DUG08              1800                0                   3                   3                 5
LAX87DUJ06              1250                0                   4                   7                 3
LAX87DUJ09              2900                0                   3                   5                 3
LAX87DUJ11              2750                0                   4                   0                 9
LAX87DUM01              8238                0                   3                   1                 3
LAX87DUM05              1050                0                   4                   5                 6
LAX87DVA02              4500                0                   3                   7                 3
LAX87DVA03              4000                0                   3                   5                 5
LAX87DVA04              2750                0                   3                   1                 0
LAX87DVA05              3100                0                   3                   1                 3
LAX87DVA11              8500                0                   3                   6                 3
LAX87DVD02              1305                5                   4                   0                 0
LAX87DVD03              4400                1                   4                   6                 0
LAX87DVG06              6000                0                   3                   4                 4
LAX87DVG07              6000                0                   3                   6                 0
LAX87FA017              3200                0                   4                   1                 3
LAX87FA065              2300                1                   3                   5                 0
LAX87FA066              2740               26                   3                   0                 0
LAX87FA084              3400                0                   4                   6                 9
LAX87FA087              7000               46                   4                  10                 3
LAX87FA102              2400                0                   4                   7                 0
LAX87FA112              3550                0                   4                   1                 0
LAX87FA117              2800                0                   4                   8                10
LAX87FA136              1650                0                   4                   6                 3
LAX87FA149              2800                0                   4                   7                 0
LAX87FA151              3800                0                   4                   6                 5
LAX87FA196              2550                0                   3                   7                 0
________________________________________________________________________________________________________
                                                                                                       41
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX87FA198              2740                1                   3                   5                 3
LAX87FA207              2800                1                   4                   5                 5
LAX87FA212              3140                0                   4                   8                 4
LAX87FA264              1885                3                   4                   4                 4
LAX87FA267              3800                0                   4                   7                 9
LAX87FA291              2550                1                   3                   3                 0
LAX87FA296B             2740                0                   3                   8                 0
LAX87FA298              1600                0                   3                   5                 3
LAX87MA018              2250                9                   4                   0                 0
LAX87MA052              3600                0                   4                   4                10
LAX87MA068A             2325               16                   3                   0                 0
LAX87MA068B             2900               16                   3                   0                 3
LAX88DUG01              1000                0                   3                   4                 3
LAX88DUM01               560                0                   4                   3                10
LAX88DUM03              3650                0                   4                   2                11
LAX88DUM04              2750                0                   4                   4                 4
LAX88DUM06              2750                0                   3                   4                 3
LAX88DVA01              3860                0                   4                   6                 5
LAX88DVA03              3300                0                   3                   3                 5
LAX88DVA04              1100                0                   4                   4                 8
LAX88DVA06               590                0                   4                   3                 5
LAX88DVA09               500                0                   4                   2                 3
LAX88DVA15              6075                0                   3                   6                 4
LAX88DVA16              2750                0                   3                   1                 0
LAX88DVD03              1300                0                   4                   7                 8
LAX88DVD05               850                0                   3                   2                 3
LAX88DVG02              4500                0                   3                   6                 3
LAX88DVG03              5200                0                   3                   5                 5
LAX88DVG05              4500                2                   4                   4                 0
LAX88DVG07              5000                0                   3                   3                 3
LAX88DVG10              4000                0                   4                   7                 8
LAX88DVM01              2600                0                   3                   4                 0
LAX88DVM02              2850                0                   3                   2                 3
LAX88DVM04              4800                0                   4                   3                 0
LAX88DXQ02               800                0                   4                   4                11
LAX88FA001              2650                0                   4                   4                 8
LAX88FA016              2750                0                   4                   6                 6
LAX88FA033              4150                0                   3                   1                 0
LAX88FA052              3800                0                   4                   9                 0
LAX88FA061              1550                0                   4                   6                 0
LAX88FA114              2350                5                   4                   7                 0
_________________________________________________________________________________________________________
                                                                                                       42
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
LAX88FA144              2175                0                   4                   3                 0
LAX88FA149              1670                0                   3                   2                 6
LAX88FA196              2900                3                   4                   7                 0
LAX88FA258              2150                0                   4                   5                11
LAX88FA278              3800                6                   4                   5                 0
LAX89DUJ02              2900                0                   3                   7                 3
LAX89DUM02              4400                0                   4                   3                 4
LAX89DVA01              8653                0                   3                   3                 0
LAX89DVA05              6075                0                   3                   6                 4
LAX89DVD02              2000                0                   4                   0                 0
LAX89DVD03              1237                0                   4                   9                 3
LAX89DVG01              1500                0                   4                   0                 0
LAX89DVM01              2450                0                   3                   1                 3
LAX89DVM02              3100                0                   3                   1                 0
LAX89FA032              2900                0                   3                   5                 4
LAX89FA076              2175                0                   3                   2                 5
MIA83FA057              1670                0                   4                   8                 5
MIA83FA058              1675                0                   4                   0                 0
MIA83FA065              1235                4                   3                   2                 0
MIA83FA073              1450                0                   4                   6                 0
MIA83FA081              2800                1                   4                   5                 0
MIA83FA082              3600                0                   4                   0                 0
MIA83FA096              1220                0                   4                   6                 0
MIA83FA113              2650                0                   4                   4                 0
MIA83FA123              3400                0                   4                   5                 6
MIA83FA140              1800                0                   4                   6                 0
MIA83FA143              2150                0                   4                   7                 0
MIA83FA145              1850                1                   4                   6                 0
MIA83FA146              4016                0                   4                   0                 4
MIA83FA148              3400                0                   4                   6                 0
MIA83FA152              3400                0                   4                   0                 0
MIA83FA168              3400                1                   4                   5                 0
MIA83FA173              1500                0                   4                   4                10
MIA83FA174              1600                0                   4                   4                 0
MIA83FA175              1650                0                   4                   9                 0
MIA83FA177              3200                0                   3                   1                 0
MIA83FA178               560                1                   4                   4                 0
MIA83FA197              2150                0                   4                   5                 0
MIA83FA202              3250                0                   4                   0                 0
MIA83FA203              1400                0                   4                   0                 0
MIA83FA208               685                0                   3                   0                 0
________________________________________________________________________________________________________
                                                                                                       43
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MIA83FA216              2325                0                   4                   5                 1
MIA83FA223              3300                0                   3                   5                 0
MIA83FA225              1670                0                   4                   6                 0
MIA83FA231              1500                0                   3                   0                 0
MIA83FA233              3600                0                   4                   5                 0
MIA83FKA01               500                0                   4                   4                 0
MIA84FA005              1710                0                   4                   6                 0
MIA84FA036              3100                0                   4                   0                 0
MIA84FA038              2650                0                   4                   0                 0
MIA84FA042              1850                0                   4                   4                 0
MIA84FA048              3400                1                   4                   5                 0
MIA84FA049              1750                0                   4                   5                 0
MIA84FA051              4500                0                   4                   0                 0
MIA84FA072              2000                0                   4                   3                 0
MIA84FA075              2150                0                   4                   5                 4
MIA84FA078              2750                0                   4                   5                 0
MIA84FA081              2450                0                   3                   1                11
MIA84FA082              1670                0                   4                   7                 6
MIA84FA091              3350                0                   4                   5                 0
MIA84FA099              2800                0                   4                   4                 0
MIA84FA101              1670                0                   4                   5                 5
MIA84FA116              1929                0                   4                   8                 9
MIA84FA139              3260                0                   4                   0                 0
MIA84FA149              2150                0                   4                   0                 0
MIA84FA161              2550                1                   4                   4                 0
MIA84FA164               850                0                   4                   0                 0
MIA84FA170              1670                0                   4                   7                 0
MIA84FA188              3300                0                   4                   4                 4
MIA84FA190              2950                0                   4                   5                 0
MIA84FA196              3400                3                   4                   5                 0
MIA84FA200              1650                0                   3                   5                 0
MIA84FA203              2600                0                   4                   5                 0
MIA84FA204              2900                1                   3                   6                 9
MIA84FA206              3600                0                   4                   0                 0
MIA84FA225              1800                0                   4                   4                11
MIA84FA234              4100                0                   4                   5                 0
MIA84FA240              1670                0                   4                   5                 0
MIA84FA241A             1670                1                   4                   6                 0
MIA84FA241B             1600                1                   4                   5                 0
MIA85FA002              1670                5                   3                   3                 3
MIA85FA009              1425                1                   4                   5                 0
_________________________________________________________________________________________________________
                                                                                                       44
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MIA85FA012              3000                0                   4                   4                11
MIA85FA016              2850                0                   3                   1                 0
MIA85FA023              2450                2                   4                   4                 5
MIA85FA028              1600                0                   4                   4                 0
MIA85FA037              1750                1                   4                   4                 0
MIA85FA038              3900               16                   4                   4                 0
MIA85FA041              2550                0                   4                   4                 7
MIA85FA065              2530                0                   4                   4                11
MIA85FA067              1500                0                   4                   4                 0
MIA85FA071              3250                0                   3                   4                 5
MIA85FA098              2650                1                   4                   3                 0
MIA85FA101              2500                1                   4                   5                 0
MIA85FA105              3800                0                   4                   7                 6
MIA85FA106              2200                0                   4                   7                 0
MIA85FA123              1880                0                   4                   8                 0
MIA85FA146              2450                0                   3                   3                11
MIA85FA150              1800                5                   4                   7                 5
MIA85FA159              2700                0                   4                   6                 7
MIA85FA170              1200                0                   4                   4                10
MIA85FA187              1260                0                   4                   6                 3
MIA85FA202              3400                0                   4                   6                 3
MIA85FA215              3400                0                   3                   1                 0
MIA85FA227              2650                1                   4                   5                 0
MIA85FA233B             1670                1                   3                   5                 3
MIA85FA234              2300                0                   4                   4                 0
MIA85FA235              2300                0                   4                   5                11
MIA85FA239              1400                0                   4                   4                11
MIA85FA241              1560                0                   3                   6                 0
MIA85FA248              2250                0                   4                   4                 8
MIA85FA251               813                0                   4                   4                 0
MIA85FA254              2740                0                   4                   7                 0
MIA85FA261              2400                0                   3                   4                 0
MIA85FLD01              2075                5                   3                   4                 3
MIA86FA015              2650                0                   3                   4                 3
MIA86FA028              3400                0                   4                   0                 0
MIA86FA033              6871                0                   4                   5                 0
MIA86FA034              2740                0                   4                   4                 0
MIA86FA044              2450                0                   4                   G                 0
MIA86FA053              2300                0                   4                   7                 0
MIA86FA055              3800                0                   4                   0                 0
MIA86FA059              1600                0                   4                   4                 0
_________________________________________________________________________________________________________
                                                                                                       45
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MIA86FA081              2690                0                   4                   0                 0
MIA86FA085              3400                0                   4                   0                 0
MIA86FA091               550                0                   4                   5                 0
MIA86FA093              2150                0                   3                   3                 0
MIA86FA097              1100                0                   4                   8                 0
MIA86FA101              1700                0                   3                   5                 0
MIA86FA110              2750                0                   4                   4                 0
MIA86FA115               900                0                   4                   7                 0
MIA86FA135              2300                0                   3                   3                 7
MIA86FA142              2300                0                   4                   4                 9
MIA86FA146              1600                0                   4                   0                 0
MIA86FA148              1600                0                   4                   4                 6
MIA86FA181              1300                0                   4                   5                 0
MIA86FA184              1300                0                   4                   5                11
MIA86FA18S             10000                0                   4                   6                 9
MIA86FA202              7020                1                   4                   6                 0
MIA86FA218              2450                0                   4                   8                11
MIA86MA182              2550                0                   4                   1                11
MIA87FA009              1670                0                   3                   4                 0
MIA87FA015              8000                0                   4                   5                 8
MIA87FA020              1500                0                   4                   8                 8
MIA87FA022              3160                0                   4                   3                 4
MIA87FA025              1670                0                   4                   7                10
MIA87FA031              3600                0                   4                   8                 4
MIA87FA035              3300                1                   4                   7                 4
MIA87FA046              2400                0                   4                   6                 0
MIA87FA048              2950                0                   3                   4                 4
MIA87FA056              2150                0                   4                   7                11
MIA87FA067              3400                0                   4                   7                 4
MIA87FA084              1670                0                   4                   8                 0
MIA87FA091              3650                1                   3                   5                10
MIA87FA114              2150                0                   4                   6                 4
MIA87FA118              1140                0                   4                   7                 6
MIA87FA135              2450                0                   4                   9                11
MIA87FA150              1220                0                   4                   4                 9
MIA87FA153B             1670                0                   3                   4                 4
MIA87FA157              1600                0                   4                   4                 5
MIA87FA160              6075                0                   4                   7                 3
MIA87FA186              1800                0                   4                   5                 0
MIA87FA187              2740                0                   4                   5                 0
MIA87FA188              2150                0                   3                   4                 0
________________________________________________________________________________________________________
                                                                                                       46
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MIA87FA189              2300               0                   4                   5                 6
MIA87FA203              2650               0                   4                   4                 3
MIA87FA205              3000               0                   4                   7                 0
MIA87FA217              3350               0                   3                   4                 9
MIA87FA220               600               0                   4                   4                 0
MIA87FA231              2650               0                   4                   4                 8
MIA87FA234              3600               2                   4                   4                 7
MIA87FA257              3400               0                   4                   6                 3
MIA87FA260              2650               0                   4                   6                10
MIA88DL001              1200               0                   3                   7                 4
MIA88FA006              1300               0                   4                   1                11
MIA88FA012              3800               0                   4                   5                 3
MIA88FA025              1250               0                   3                   3                 0
MIA88FA044              2150               0                   4                   7                 3
MIA88FA049              2950               0                   4                   5                 0
MIA88FA063              1850               0                   4                   4                 0
MIA88FA071              1600               0                   4                   6                 0
MIA88FA081              1670               0                   4                   6                11
MIA88FA083              3400               0                   4                   5                 0
MIA88FA088              1800               0                   4                   3                 9
MIA88FA114              2150               0                   4                   4                 5
MIA88FA127              2740               5                   4                   6                 4
MIA88FA134              3000               0                   4                   5                 3
MIA88FA142              2300               0                   4                   4                 3
MIA88FA144              2350               0                   3                   5                 0
MIA88FA178              3600               0                   3                   0                 0
MIA88FA179              2550               0                   4                   7                 0
MIA88FA184              1220               0                   4                   4                11
MIA88FA187              2300               0                   3                   4                 4
MIA88FA191              1670               0                   3                   4                 0
MIA88FA206              2450               0                   4                   0                 3
MIA88FA213              1000               0                   4                   4                 0
MIA88FA214              3325               0                   4                   5                 5
MIA88FA232              7000               0                   4                   4                 0
MIA88FA234              3000               0                   4                   0                 9
MIA88FA244              1600               0                   4                   3                 0
MIA88FA254              2300               0                   4                   1                10
MIA88FA257              2700               0                   3                   5                 5
MIA88FA262              1038               0                   4                   0                10
MIA88FA269              2300               0                   3                   5                 6
MIA88LA215              1670               0                   4                   4                 0
_______________________________________________________________________________________________________
                                                                                                      47 
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MIA89FA004              1670                0                   4                   1                 3
MIA89FA027              2000                0                   4                   7                 5
MIA89FA033              2550                1                   4                   0                 0
MIA89FA044              2325                0                   4                   7                11
MIA89FA048              1600                0                   4                   1                 0
MIA89FA078              2550                0                   4                   4                 0
MIA89GA082              3800                0                   3                   5                 5
MKC83FA060              2900                0                   4                   7                 0
MKC83FA065              3100                0                   4                   9                 0
MKC83FA066              2600                0                   4                   7                 0
MKC83FA069              1600                0                   4                   4                 0
MKC83FA081              3800                0                   4                   6                 0
MKC83FA090              1360                0                   4                   3                 4
MKC83FA114              2750                0                   4                   4                 0
MKC83FA136              1670                0                   4                   9                 0
MKC83FA165              1450                0                   4                   3                 0
MKC83FA171              1350                0                   3                   4                 0
MKC83FA177              2900                0                   4                   5                 0
MKC83FA189              2900                0                   4                   4                 0
MKC83FA190              2900                2                   3                   0                 0
MKC83FA209              4800                0                   4                   4                11
MKC83FA214              2700                0                   3                   4                 0
MKC83FA216              1700                0                   3                   4                 0
MKC83FA225              6725                0                   4                   0                 0
MKC83FU001               510                0                   3                   2                 0
MKC84FA002              3100                0                   4                   4                 0
MKC84FA005              1800                0                   4                   4                 3
MKC84FA014              3400                1                   4                   7                 3
MKC84FA029              4190                0                   3                   2                 0
MKC84FA034              3800                4                   3                   4                 0
MKC84FA106              3850                0                   4                   4                 0
MKC84FA115              2650                0                   4                   8                 0
MKC84FA119              2150                0                   4                   4                 0
MKC84FA147              2100                0                   3                   4                 0
MKC84FA157              1220                0                   3                   3                 0
MKC84FA164              2900                0                   4                   0                 0
MKC84FA174              2700                0                   4                   S                 8
MKC84FA195              2550                0                   4                   6                 0
MKC84FA197              162S                0                   4                   5                 0
MKC84FA218              1500                0                   4                   G                 0
MKC84FA221              1600                0                   4                   7                 0
_________________________________________________________________________________________________________
                                                                                                       48
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MKC84FA225                736               1                   4                   3                 0
MKC84FA240A              3300               0                   3                   6                 0
MKC84FA245               3300               0                   4                   0                 0
MKC84FA254               3300               0                   4                   7                 0
MKC84FA256               2200               0                   4                   6                10
MKC84FA262                790              10                   3                   0                 0
MKC84FA271               3100               1                   3                   6                 4
MKC84FA272A              3150               0                   4                   0                 0
MKC84FA272B              2550               0                   4                   0                 0
MKC84FA285               1650               0                   4                   3                 0
MKC84FCA02               2575               0                   4                   7                 3
MKC84FU002                500               0                   3                   2                 0 
MKC85FA007               2450               0                   4                   8                 3
MKC85FA017               1750               0                   3                   5                 0
MKC85FA030               1600               0                   4                   5                 6
MKC85FA039               2950               0                   4                   7                 3
MKC85FA042               1600               0                   3                   4                 9
MKC85FA069               1600               0                   4                   6                 5
MKC85FA070               4100               0                   4                   0                 0
MKC85FA078               2650               0                   4                   8                 0
MKC85FA080               4500               0                   4                   6                11
MKC85FA084               3600               0                   4                   0                 0
MKC85FA087               6000               0                   4                   6                 7
MKC85FA089               3200              15                   4                   7                 0
MKC85FA111               1500               0                   3                   7                 0
MKC85FA114               2350               0                   3                   2                 3
MKC85FA120               1500               0                   4                   4                 9
MKC85FA124               1578               0                   4                   6                 0
MKC85FA134               3233               0                   4                   7                10
MKC85FA137               1670               0                   3                   4                 0
MKC85FA169               1500               0                   4                   3                11
MKC85FA177               4000               0                   4                   6                 0
MKC85FA179               3200               0                   4                   6                 0
MKC85FA180               1600               0                   4                   8                 0
MKC85FA181               1750               0                   4                   0                 0
MKC85FA182                630               1                   4                   2                 0
MKC8SFA189               2850              10                   3                   1                 0
MKC85FA191               1500               0                   4                   0                 0
MKC85FA199               1220               0                   4                   4                 0
MKC85FA217               2450               0                   3                   7                 0
________________________________________________________________________________________________________
                                                                                                       49
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MKC85FCA01              2150                  0                 4                   4                 0
MKC85FCA02              2600                  0                 4                   7                 0
MKC85FCD02              2300                  1                 3                   5                 0
MKC85FCJ01              1300                  0                 4                   1                 0
MKC85FCQ02              3000                  0                 3                   6                 3
MKC85FCQ04              2750                  0                 3                   0                 0
MKC85FPG01              2150                  0                 3                   4                 0
MKC85FPG02              3800                  0                 4                   6                 0
MKC85FPG03              3400                  0                 3                   6                 4
MKC86FA002              2650                  1                 3                   6                 0
MKC86FA008              2450                  0                 4                   8                11
MKC86FA011              3400                  0                 4                   7                 0
MKC86FA017               750                  0                 3                   5                 0
MKC86FA020              4050                  0                 4                   5                 0
MKC86FA023              3600                  0                 4                   4                 0
MKC86FA027              3400                  0                 4                   8                10
MKC86FA030              4000                  0                 4                  10                 0
MKC86FA033              3400                  0                 3                   3                 0
MKC86FA048              2650                  1                 4                   9                 5
MKC86FA053              3400                  2                 4                   0                 0
MKC86FA077               895                  1                 4                   5                 0
MKC86FA080              1600                  0                 3                   0                 0
MKC86FA082              2500                  0                 4                   3                 0
MKC86FA098              1650                  0                 3                   5                10
MKC86FA103              1150                  2                 4                   1                 8
MKC86FA123A             1450                  0                 4                   5                 0
MKC86FA139              2800                  0                 4                   9                 8
MKC86FA151              2200                  0                 4                   7                 0
MKC86FA166              1050                  0                 4                   3                 0
MKC86FA181              2150                  1                 4                   4                11
MKC86FA189              2300                  0                 4                   7                11
MKC86FA195              2450                  0                 4                   8                 7
MKC86FCA01               934                  5                 4                   7                11
MKC86FCA02              1670                  0                 4                   4                10
MKC86FCA03              1800                  0                 4                   0                 0
MKC86FCD01              2900                  0                 4                   3                 0
MKC86FCD02              1474                  0                 3                   3                 0
MKC86FCJ01              1065                  0                 4                   0                 0
MKC86FCJ02              4200                  0                 4                   0                 4
MKC86FCJ03              3000                  0                 4                   6                11
MKC86FCJ04              1100                  0                 4                   5                 0
________________________________________________________________________________________________________
                                                                                                       50
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MKC86FCQ01               950                0                   3                   4                 0
MKC86FPG03              5200                0                   4                   5                 9
MKC87DCA01              1675                0                   4                   2                10
MKC87DCA02              1285                0                   3                   1                11
MKC87DCA03              1100                1                   3                   6                 4
MKC87DCQ01               485                1                   4                   4                11
MKC87DCQ02              3800                9                   4                   0                 0
MKC87DCQ03              4800                0                   4                   0                 0
MKC87DPG01              4200                0                   4                   5                 9
MKC87DPG02              2900                0                   4                   3                 0
MKC87DPG03              5000                1                   3                   6                 0
MKC87FA002              1600                0                   4                   4                11
MKC87FA012              2550                1                   4                   8                 6
MKC87FA020              2650                0                   4                   0                 4
MKC87FA022              2550                0                   4                   7                 5
MKC87FA027              2800                0                   4                   7                 0
MKC87FA030              2325                0                   4                   5                 5
MKC87FA033              1650                0                   3                   4                 9
MKC87FA036              1670                0                   4                   7                 0
MKC87FA037              4000                0                   3                   6                 4
MKC87FA044              1600                0                   4                   4                 4
MKC87FA048              1600                3                   4                   6                 0
MKC87FA051              1500                0                   4                   6                11
MKC87FA077              1600                0                   4                   4                11
MKC87FA078              2690                0                   4                   6                 3
MKC87FA083              1250                0                   3                   4                 0
MKC87FA087              3400                0                   4                   8                 6
MKC87FA092              2550                0                   4                   6                 7
MKC87FA094              2050                0                   4                   2                 0
MKC87FA103              1450                0                   4                   1                 0
MKC87FA106              2500                3                   4                   8                11
MKC87FA121              1150                0                   3                   4                 0
MKC87FA131              1800                0                   4                   8                11
MKC87FA148               728                0                   3                   0                11
MKC87FA159              2150                0                   4                   7                 6
MKC87FA161              1840                0                   4                   5                 7
MKC87FA163              2550                0                   4                   4                 4
MKC87FA165              1840                0                   4                   5                10
MKC87FA169              3200                0                   4                   8                 0
MKC87FA172              4500                0                   3                   5                 3
MKC88DCA02              3400                0                   3                   0                 3
_________________________________________________________________________________________________________
                                                                                                       51
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT        ACFT_DAMAGE     AIRSPEED_IMPACT   FLT_PATH_ANGLE
MKC88DCA03              1200                0                   4                   4                 7
MKC88DCD01               900                0                   3                   3                 3
MKC88DCD02               900                0                   4                   2                11
MKC88DCG01              3520                0                   3                   7                 4
MKC88DCJ01              4200                0                   4                   7                 5
MKC88DCQ02              2300                0                   3                   5                 9
MKC88DCQ03              1250                0                   3                   2                 0
MKC88DCQ04               900                0                   3                   2                 4
MKC88DPG01              1400                0                   4                   0                10
MKC88DPG02A             4400                0                   4                   7                 3
MKC88DPG02B             4550                0                   4                   7                 3
MKC88FA003              2078                0                   3                   3                 3
MKC88FA005              3400                0                   4                   6                 6
MKC88FA007              1650                1                   4                   5                10
MKC88FA012              1100                4                   3                   6                 4
MKC88FA019              3600                1                   4                   7                 3
MKC88FA021              2175                0                   4                   7                 0
MKC88FA023              2550                0                   4                   4                 9
MKC88FA026              1817                1                   4                   6                 5
MKC88FA039              2800                1                   4                   5                 6
MKC88FA040              2050                0                   4                   S                10
MKC88FA043              4300                0                   4                   1                 9
MKC88FA058              2150                0                   4                   1                 0
MKC88FA070              4150                0                   3                   3                 6
MKC88FA086              1600                0                   3                   4                 8 
MKC88FA147              2575                0                   3                   0                 0
MKC88FA166              1600                0                   3                   7                 4
MKC89DCJ01              1150                0                   3                   6                11
MKC89FA004              2550                0                   3                   2                 7
MKC89FA011              1220                0                   3                   4                 8
MKC89FA014              1500                0                   3                   3                11
MKC89FA017              3800                0                   3                   5                 6
NYC83AA208              2550                0                   4                   0                 0
NYC83AA209              4300                0                   4                   5                 0
NYC83FA052              1300                0                   3                   1                 0
NYC83FA061              1200                1                   4                   3                 0
NYC83FA062              2325                0                   3                   S                 0
NYC83FA071              2300                0                   3                   5                 0
NYC83FA072              1600                2                   3                   4                 0
NYC83FA085              2750               10                   4                   7                 0
NYC83FA086              3800                6                   3                   3                 0
_________________________________________________________________________________________________________
                                                                                                       52
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE       AIRSPEED_IMPACT    FLT_PATH_ANGLE
NYC83FA087               3600               8                     4                     8                  0
NYC83FA088               2550               4                     3                     5                  0
NYC83FA091               2300              16                     4                     7                  0
NYC83FA098               2550               1                     4                     6                  0
NYC83FA102               2750               0                     4                     4                  0
NYC83FA105               1670               0                     4                     3                  0
NYC83FA106               2450               0                     4                     0                  0
NYC83FA107               2800               7                     4                     7                  2
NYC83FA110               2400               3                     3                     5                  0
NYC83FA121               2900               0                     4                     0                  0
NYC83FA122               2200               0                     4                     5                  0
NYC83FA125               1950               7                     4                     7                  0
NYC83FA126               3866               1                     4                     0                  0
NYC83FA130               5300               0                     4                     0                  0
NYC83FA141               2950               0                     4                     5                  0
NYC83FA142               1750               0                     4                     0                  0
NYC83FA168               2400               0                     3                     5                  0
NYC83FA172               1220               0                     4                     3                  0
NYC83FA187               2400              10                     4                     7                  0
NYC83FA188A              3500               1                     4                     7                  3
NYC83FA188B              3000               0                     4                     1                  0
NYC83FA192               3300               0                     4                     0                  3
NYC83FA198               3400               1                     4                     6                  0
NYC83FA204               3300               1                     4                     9                  0
NYC83FA242               3600               6                     4                     0                  0
NYC83FA244               4850               0                     4                     2                  0
NYC83FA256               2740               0                     4                     5                  0
NYCG3FA260               2200               0                     4                     0                  0
NYC83FFA02               1600               0                     3                     6                  3
NYC83FFA03               3400               1                     3                     6                  0
NYC83FFJ02               4500               0                     3                     5                  3
NYC83FGM02               2350               0                     3                     0                  5 
NYC83FGM03               1100               0                     4                     2                  3
NYC83FGM04                720               1                     4                     0                  0
NYC83FGM05               1675               1                     4                     0                  0
NYC83FHA03               2000              13                     3                     0                  0
NYC83FHD02               3400               4                     4                     5                  2
NYC83FHM02               1500               0                     4                     9                  0
NYC83FNC08               2350               0                     4                     3                  0
NYC83FNC09               2300               0                     4                     4                  3
NYC83FNC11               1800               0                     3                     3                  0
_____________________________________________________________________________________________________________
                                                                                                            53
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE       AIRSPEED_IMPACT    FLT_PATH_ANGLE
NYC83FNE02               2200               1                     3                     5                  0
NYC83FNE03               1800               1                     4                     6                  0
NYC83FNE04                959               0                     3                     6                  2
NYC83FU002                550               0                     4                     4                  0
NYC83FU004                445               0                     4                     5                  0
NYC83FU005A               440               0                     4                     3                  0
NYC83FU005B               440               0                     3                     3                  0
NYC83LA066               3600               0                     3                     0                  0
NYC84FA009               3200               0                     4                     3                  0
NYC84FA016               3325               0                     4                     7                  0
NYC84FA022               3400               1                     4                     0                  0
NYC84FA032A              2950               0                     4                     0                  0
NYC84FA039               1500               2                     4                     5                  0
NYC84FA046               1670               0                     3                     6                  5
NYC84FA053               3200               2                     4                     0                  0
NYC84FA057               1220               0                     4                     0                  0
NYC84FA058               2950               0                     4                     9                  0
NYC84FA059               3600               1                     4                     5                  0
NYC84FA072               1675               0                     4                     0                  0
NYC84FA074               4000               2                     4                     9                  9
NYC84FA085               2650               1                     4                     0                  0
NYC84FA096               3350               1                     4                     5                  0
NYC84FA104               2550               0                     4                     0                  0
NYC84FA107               1500               0                     4                     1                  0
NYC84FA108               2500               0                     4                     5                  0
NYC84FA117               2450               0                     4                     0                  0
NYC84FA118               1650               0                     4                     0                  0
NYC84FA129               2750               0                     4                     3                  8
NYC84FA137               1600               1                     4                     5                  0
NYC84FA138               3050               5                     4                     7                  3
NYC84FA143               2650               3                     4                     8                  0
NYC84FA148               3600               0                     4                     7                  0
NYC84FA149               2200               0                     4                     4                  0
NYC84FA157               1670               0                     4                     0                  0
NYC84FA158               1750               0                     4                     3                  0
NYC84FA159               2150               1                     4                     5                  3
NYC84FA165               2150               0                     4                     5                  0
NYC84FA178               3100               3                     4                     0                  0
NYC84FA180               2985               1                     4                     0                  0
NYC84FA189               1100               0                     4                     0                  0
NYC84FA201               2400               0                     4                     3                  0
______________________________________________________________________________________________________________
                                                                                                            54
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE       AIRSPEED_IMPACT    FLT_PATH_ANGLE
NYC84FA214               4300               0                     4                     0                  0
NYC84FA218               1600               1                     4                     0                  0
NYC84FA224               2400               1                     4                     0                  0
NYC84FA233               2200               0                     4                     6                  0
NYC84FA269               4118              10                     4                     0                  0
NYC04FA274               3100               1                     4                     0                  0
NYC84FA275               2300               1                     4                     6                  3
NYC84FA293B              2650               0                     3                     5                  3
NYC84FA306               2150               0                     4                     0                 11
NYC84FA307               3200               0                     4                     0                  0
NYC84FA310               1250               0                     4                     3                  0
NYC84FA314               3600               0                     4                     6                  0
NYC84FFA01               1600               0                     3                     4                  0
NYC84FFA02               2400               0                     3                     2                  8
NYC84FFA03               1250               0                     4                     4                  0
NYC84FFA05               1500               0                     3                     4                  0
NYC84FFJ01               2750               0                     4                     6                  0
NYC84FGM01               2325              10                     4                     0                  7
NYC84FGM03                950               0                     3                     4                  0
NYC84FGM04               3100               0                     3                     2                  0
NYC84FGT01               2575               0                     4                     6                 11
NYC84FGT02               2850               0                     3                     0                  0
NYC84FHJ02               1830               0                     3                     0                  0
NYC84FHM01               2550               0                     4                     0                 11
NYC84FHM02               2740               0                     3                     1                  0
NYC84FHM03               1000               1                     3                     6                  0
NYC84FHM05               2950               4                     4                     0                  0
NYC84FIA03               2550               0                     3                     4                  0
NYC84FIG01               2325               2                     3                     4                  0
NYC84FIG02               2075               0                     3                     5                  0
NYC84FIG03               1670               0                     3                     5                  0
NYC84FNA01               2500               0                     3                     2                  0
NYC84FNC03               2150               0                     3                     4                  0
NYC84FNC07               3400               0                     3                     0                  0
NYC84FNC08               1250               1                     4                     4                  0
NYC84FNC09               2200               0                     4                     0                  0
NYC84FNC10               2950               0                     3                     1                 10
NYC84FNE01               2325               0                     3                     2                  0
NYC84FNE04               1600               0                     3                     6                 10
NYC84FNE05               2575               1                     4                     4                  0
NYC84FNE06               4150               0                     3                     1                  3
_____________________________________________________________________________________________________________
                                                                                                            55
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE       AIRSPEED_IMPACT    FLT_PATH_ANGLE
NYC84FU005                530               1                     4                     3                  0
NYC85FA001               4000               0                     3                     0                  0
NYC8SFA003               2550               0                     4                     5                 11
NYC8SFA014               1600               0                     4                     7                  4
NYC85FA015               2200               0                     4                     5                  0
NYC85FA019               2150               1                     4                     7                  0
NYC85FA029               2900               0                     4                     7                 11
NYC85FA092               7200               0                     3                     6                  0
NYC85FA103               2740               2                     4                     0                  0
NYC8SFA104               2450               0                     4                     6                  3
NYC85FA109               2150               0                     4                     5                  6
NYC85FA110               3100               0                     4                     7                  0
NYC85FA131               3100               0                     4                     0                  0
NYC85FA166               2900               1                     4                     4                  3
NYC85FA201               2500               0                     4                     0                  0
NYC85FA213               2300               0                     4                     4                  0
NYC85FA219               1600               0                     4                     4                  0
NYC85FA222               1400               0                     4                     3                  0
NYC85FA227               1600              15                     4                     0                  0
NYC85FA241               2150               0                     4                     8                  0
NYC85FA244               3400               2                     4                     4                  6
NYC85FA245               3350               0                     4                     1                  0
NYC85FFA01               2300               0                     3                     4                  0
NYC85FFA03               2300               0                     3                     0                  0
NYC85FFJ01                274               0                     3                     0                  0
NYC85FGM04               3200               0                     3                     4                  0
NYC85FGM05               1500               0                     4                     0                  0
NYC85FGT02               1800               0                     4                     4                  0
NYC85FHA02               2950               0                     3                     0                  0
NYC85FHA03               2300               0                     3                     3                  8
NYC85FHD01               2150               0                     3                     4                  0
NYC85FHD02               3300               0                     4                     7                  0
NYC85FHD03               2300               0                     3                     3                  0
NYC85FHJ01               2150               0                     4                     0                  0
NYC85FHJ02               1670               0                     3                     4                  0
NYC85FHJ04               2300               0                     3                     4                  5
NYC85FNA02                793               0                     3                     3                 11
NYC85FNC06               1350               0                     4                     4                 10
NYC85FNE01               1050               0                     3                     5                  6
NYC88FA001               2740               1                     4                     7                  9
NYC86FA023               2300               1                     4                     4                  0
_____________________________________________________________________________________________________________
                                                                                                           56
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE       AIRSPEED_IMPACT    FLT_PATH_ANGLE
NYC86FA030                 2950               0                  4                     7                  3
NYC86FA037                 2900               0                  4                     5                  0
NYC86FA040                 2150               0                  4                     0                  0
NYC86FA057                 2800               6                  4                     0                  9
NYC86FA077                 2150               1                  4                     5                 11
NYC86FA084                 2550               1                  4                     7                  0
NYC86FA096                 2500               2                  4                     7                  0
NYC86FA111                 2150               1                  4                     6                  0
NYC86FA114A                1014               0                  4                     6                  0
NYC86FA127                 1370               0                  4                     3                  0
NYC86FA135                 2600               1                  4                     6                  8
NYC86FA138                 2300               0                  4                     4                  0
NYC86FA158                 3400               2                  4                     7                  6
NYC86FA176                 2400               0                  4                     5                  3
NYC86FA213                 4100               0                  4                     5                  5
NYC86FA214                 2900               0                  4                     0                  0
NYC86FA216                 3000               0                  4                     7                 10
NYC86FA210                 2150               2                  4                     5                  0
NYC86FA219                 1600               0                  4                     7                  0
NYC86FA234                 3600               2                  3                     4                  3
NYC86FGM05                 1500               0                  4                     5                  8
NYC86FGM06                 1339               1                  4                     6                  9
NYC86FGM07                  550               0                  4                     3                  0
NYC86FHA01                 2150               0                  3                     4                  0
NYC86FHA02                 1500               1                  3                     6                  0
NYC86FHD03                 2000               0                  4                     0                 10
NYC86FHM01                 2300               0                  3                     0                  0
NYC86FNC02                 1220               1                  3                     3                  9
NYC86FNC03                 1100               0                  4                     4                  7
NYC86FNC07                 1600               0                  4                     2                 11
NYC86FNC08                 1650               0                  4                     5                 11
NYC87DGM01                 2740               0                  3                     5                  0
NYC87DGM02                 1100               0                  3                     5                  0
NYC87DHD04                  803               0                  4                     7                  5
NYC87DHJ01                 1600               5                  4                     0                  0
NYC87DHM02                 1254               0                  3                     4                  8
NYC87DNC04                 1200               0                  3                     3                 11
NYC87DNC05                 1500               0                  4                     5                  0
NYC87DNC07                  450               0                  4                     4                 10
NYC87DNC12                 1600               0                  4                     5                  0
NYC87FA002                 1670               0                  4                     3                 11
______________________________________________________________________________________________________________
                                                                                                            57
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE       AIRSPEED_IMPACT    FLT_PATH_ANGLE
NYC87FA006               2050               2                     4                     7                  0
NYC07FA015               3350               0                     3                     5                  6
NYC87FA020A              2800               0                     4                     3                  0
NYC87FA021               3000               2                     4                     6                  5
NYC87FA023               2550               7                     4                     7                  3
NYC87FA025               3200               0                     4                     7                  5
NYC87FA038               2325               0                     4                     7                  3
NYC87FA045               1670               0                     4                     9                  0
NYC87FA063               2450               5                     4                     7                  4
NYC87FA095               1670               0                     4                     5                 11
NYC87FA119               2300               0                     4                     4                  0
NYC87FA127               2400               0                     4                    10                  9
NYC87FA160               2500               0                     4                     4                  0
NYC87FA262               3400               0                     4                     6                  0
NYC87MA024               2600               0                     4                     2                  0
NYC88DFJ04               3000               0                     3                     6                  0
NYC88DGM03               2325               0                     4                     7                  0
NYC88DGT01               7000               0                     4                     0                  0
NYC88FA062               3600               0                     4                     6                  5
NYC88FA133               3200               0                     4                     4                  9
NYC88FA143               3200               0                     3                     4                  5
NYC88FA202               2400               0                     4                     5                  3
NYC88FA216               3600               0                     3                     4                 10
NYC89FA003               1250               0                     4                     4                  6
NYC89FA007               1500               0                     4                     1                 11
NYC89FA013               4050               0                     4                     1                 10
SEA83AA176               2750               0                     4                     0                  0
SEA83FA037               4000               7                     4                     8                  3
SEA83FA042               1800               0                     4                     6                  0
SEA83FA044               4000               3                     4                     0                  0
SEA83FA045               1150               1                     4                     1                  0
SEA83FA052               2300               0                     4                     3                  0
SEA83FA058               1450               0                     4                     4                  0
SEA83FA060               1700               1                     4                     0                  0
SEA83FA062               1600               0                     4                     0                  0
SEA83FA065               2750               0                     4                     0                  0
SEA83FA072               1500               0                     4                     2                  0
SEA83FA087               2400               0                     4                     8                  0
SEA83FA089               2150               0                     4                     7                  9
SEA83FA093               1675               0                     4                     3                  0
SEA83FA094               2200               1                     4                     4                  0
______________________________________________________________________________________________________________
                                                                                                            58
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE       AIRSPEED_IMPACT    FLT_PATH_ANGLE
SEA83FA095               2450               0                     4                     8                  4
SEA83FA103               3600               1                     4                     5                  0
SEA83FA113               2800               0                     4                     8                  0
SEA83FA115               2800               0                     4                     0                  0
SEA83FA118               2900               0                     4                     7                  0
SEA83FA127               2900               0                     4                     4                  0
SEA83FA131               3400               0                     4                     8                  0
SEA83FA135               2350               0                     3                     2                  0
SEA83FA139               2800               0                     4                     4                  0
SEA83FA141                560               3                     4                     4                  0
SEA83FA142               1500               0                     4                     5                  0
SEA83FA162               4800               0                     4                     5                  0
SEA83FA168               1150               2                     4                     3                  0
SEA83FA178               1500               1                     4                     3                  0
SEA83FA186               1834               0                     4                     2                  0
SEA83FA187               2650               0                     4                     5                  1
SEA83FA197               3600               0                     4                     7                  0
SEA83FA198               9500               0                     4                     2                  2
SEA83FA204               2600               4                     4                     0                  0
SEA83FYA02               1650              10                     3                     6                  0
SEA83FYK04               1600               0                     4                     0                  0
SEA83FYM05               1600               0                     3                     1                  0
SEA83FYM06               3800               5                     3                     0                  0
SEA84FA005               1500               0                     4                     4                 11
SEA84FA007               3100               0                     4                     3                  0
SEA84FA011               2950               0                     4                     4                  3
SEA84FA015               1600              14                     4                     4                  0
SEA84FA017               3350               0                     4                     4                  0
SEA84FA020               1300              20                     4                     2                  0
SEA84FA055               1300               0                     4                     0                  0
SEA84FA058               3000              11                     4                     7                  0
SEA84FA063               2350               0                     4                     0                  0
SEA84FA068               2750               0                     4                     7                  0
SEA84FA071               2900               0                     4                     7                  0
SEA84FA078               3125               7                     4                     4                  0
SEA84FA088               1600               0                     4                     0                  0
SEA84FA090               1650               0                     4                     6                  0
SEA84FA101               3800               0                     4                     9                  0
SEA84FA102               1450               0                     4                     3                  0
SEA84FA110               6000               0                     3                     4                  0
SEA84FA111               2400               0                     4                     5                  0
______________________________________________________________________________________________________________
                                                                                                            59
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT       ACFT_DAMAGE      AIRSPEED_IMPACT    FLT_PATH_ANGLE
SEA84FA113               1600               0                    4                  0            0
SEA84FA135               2200               0                    4                  0            0
SEA84FA158               1600               1                    4                  5            0
SEA84FA164               1650               0                    4                  4            0
SEA84FA171               3350               4                    4                  5            3
SEA84FA173               2800               0                    4                  0            0
SEA84FA17S               2800               2                    4                  7            0
SEA84FA178               1800               0                    4                  0            0
SEA84FA185               5100               0                    4                  5            0
SEA84FA196               2000               1                    4                  4            0
SEA84FA198               1400               1                    4                  4            0
SEA84FA201               2800               0                    4                  4            0
SEA84FA204               1616               0                    4                  0            0
SEA84FA209                600               0                    4                  3            0
SEA84FA215A              2175               0                    4                  0            0
SEA84FA215B              2100               0                    4                  0            0
SEA84FA217               3800               0                    4                  3           11
SEA84FA223               3800               0                    4                  0            0
SEA84FA228               3600               2                    4                  5            0
SEA84FYK01               2300               0                    4                  6            6
SEA84MA016               5100               0                    4                  4            0
SEA85FA001               3100               0                    4                  4            8
SEA85FA012               2800               0                    4                  8            0
SEA85FA016               2300               0                    4                  0            0
SEA85FA030               1670               1                    4                  5            0
SEA85FA034               8000               5                    3                  6            0
SEA85FA036               1750               0                    4                  0            0
SEA85FA040               3200               0                    3                  2            0
SEA85FA043               2050               0                    4                  4            0
SEA85FA048               2447               0                    4                  7            3
SEA85FA050               2350               0                    4                  4            0
SEA85FA051               3125               0                    4                  7            3
SEA85FA065               2500               0                    4                  8            0
SEA85FA067               2350               0                    4                  5            4
SEA85FA082               2200               0                    4                  0            0
SEA85FA084               3325               2                    4                  5           11
SEA85FA086               1750               0                    4                  2            0
SEA85FA100               1850               0                    4                  0            0
SEA85FA103               3600               0                    4                  5           11
SEA85FA104               3000               0                    4                  1            3
SEA85FA113               2800               0                    4                  0            0
_____________________________________________________________________________________________________
                                                                                                  60
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE        AIRSPEED_IMPACT    FLT_PATH_ANGLE
SEA85FA120               3300               0                     4                      0                  0
SEA85FA122               3400               0                     4                      7                  9
SEA85FA124               2350               0                     4                      5                 11
SEA85FA134               8500               0                     4                      0                  0
SEA85FA137               2400               0                     3                      2                  4
SEA85FA147               2800               0                     4                      4                  0
SEA85FA156                850               0                     4                      4                  0
SEA85FA162               3600               0                     4                      0                  0
SEA85FA171               1220               0                     4                      1                 11
SEA85FA181               2000               0                     4                      4                  4
SEA85FA190               1350               0                     4                      3                  5
SEA85FA203               3400               0                     4                      0                  0
SEA85FA208               2900               0                     4                      3                  0
SEA85FA211               3200               0                     4                      4                  0
SEA85FA212               1200               0                     4                      0                  0
SEA85FA217               1260               0                     4                      0                  0
SEA85FA225               2500               0                     4                      4                  0
SEA85FYM01               6600               0                     4                      0                  0
SEA85FYM03               2200               0                     3                      5                  0
SEA85LA054               2800               0                     4                      0                  0
SEA85LA095               3600               1                     4                      0                  0
SEA86FA004               1650               0                     4                      1                  0
SEA86FA007               2300               0                     4                      5                  5
SEA86FA020               1650               0                     4                      7                  0
SEA86FA034               2100               0                     4                      4                  3
SEA86FA035               2325               0                     4                      4                 10
SEA86FA039               3100               0                     4                      0                 11
SEA86FA041               2950               1                     4                      6                  8
SEA86FA047               3300               2                     4                      0                  0
SEA86FA052               3500               0                     4                      5                  0
SEA86FA053               2550               2                     4                      7                  4
SEA86FA054               2300               0                     4                      8                  3
SEA86FA056               3000               0                     4                      7                  3
SEA86FA071               2950               0                     4                      0                  0
SEA86FA073               3650               0                     4                      3                 11
SEA86FA075               2400               0                     4                      5                  4
SEA86FA092A              2400               0                     4                      0                  0
SEA86FA092B              2400               0                     4                      0                  0
SEA86FA096               2450               4                     4                      6                  0
SEA86FA098               3600               0                     4                      2                 11
SEA86FA100               2500               0                     4                      0                  0 
_______________________________________________________________________________________________________________
                                                                                                             61
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE        AIRSPEED_IMPACT    FLT_PATH_ANGLE
SEA86FA121A               1670               0                  4                     0                   0
SEA86FA121B               3600               0                  4                     8                   0
SEA86FA126                3050               0                  4                     5                  11
SEA86FA137                9500               0                  4                     0                   0
SEA86FA139                2750               0                  4                     3                   0
SEA86FA144                1704               0                  4                     4                   0
SEA86FA145                2200               0                  4                     0                  11
SEA86FA155                1300               1                  4                     3                  11
SEA86FA165                1500               1                  4                     5                   0
SEA86FA174                1125               0                  4                     0                  10
SEA86FA188                2200               0                  4                     5                   3
SEA86FA207                2350               1                  4                     4                   0
SEA86FA213                1400               0                  4                     3                  11
SEA86FA215                3800               0                  4                     0                   0
SEA86FA216                1500               0                  4                     5                   0
SEA86FA217                1650               0                  4                     3                   9
SEA86FA231                1400               0                  4                     4                  10
SEA86FA232                2175               0                  4                     0                   0
SEA86FA233                2550               0                  4                     7                   0
SEA86FA245                1600               0                  4                     0                   0
SEA86FA248                2300               0                  4                     6                   4
SEA86LA043                1260               0                  4                     7                   0
SEA86LA122                2950               0                  4                     7                   4
SEA87FA014                1670               0                  4                     7                   0
SEA87FA019                2950               0                  4                     7                   4
SEA87FA027                3600               0                  4                     5                   0
SEA87FA031                2800               1                  4                     6                   4
SEA87FA051                1600               0                  4                     0                  11
SEA87FA060                2800               4                  4                     7                   0
SEA87FA062                1600               0                  4                     0                   0
SEA87FA100A               2200               0                  4                     7                  11
SEA87FA102                2535               0                  4                     0                   0
SEA87FA112                1600               0                  3                     4                   5
SEA87FA129                1600               0                  4                     0                   0
SEA87FA145                4000               0                  4                     0                   0
SEA87FA152                2150               0                  4                     5                   0
SEA87FA158                1600               2                  4                     5                  11
SEA87FA162B               3100               1                  3                     6                   0
SEA87FA165                2050               0                  4                     0                   0
SEA87FA166                2650               0                  4                     5                   3
SEA87FA178                1800               0                  4                     4                   0
_____________________________________________________________________________________________________________
                                                                                                            62
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE        AIRSPEED_IMPACT    FLT_PATH_ANGLE
SEA87FA185               3300                7                   4                      0                  0
SEA87FA190               3800                0                   4                      0                  0
SEA87FA194               3000                0                   3                      1                  0
SEA87LA048               1100                0                   4                      0                 11
SEA87LA142               2150                0                   4                      8                  0
SEA87LA174                825                1                   4                      0                  0
SEA87MA034               4150                5                   4                      4                  4
SEA87MA035               3500                0                   4                      6                  3
SEA88FA011               2650                0                   4                      5                  3
SEA88FA012               2450                0                   4                      0                  0
SEA88FA021               3100                0                   4                      9                  0
SEA88FA023               2300                0                   4                      6                  3
SEA88FA024               2800                0                   4                      7                  3
SEA88FA031               3600                0                   4                      0                  0
SEA88FA032               1950                0                   4                      0                  0
SEA88FA034               2800                0                   4                      5                  4
SEA88FA039               2450                0                   4                      0                  0
SEA88FA054               4000                0                   4                      6                  4
SEA88FA060A              1450                0                   4                      5                  3
SEA88FA060B              1397                0                   4                      5                  3
SEA88FA078               3600                0                   4                      7                  0
SEA88FA095               2300                1                   4                      0                  0
SEA88FA120               1600                0                   4                      0                  0
SEA88FA122               3600                0                   4                      5                  0
SEA88FA140               3320                0                   4                      5                  9
SEA88FA154               3100                0                   4                      7                  3
SEA88FA156               5090                0                   4                      0                  0
SEA88FA160               2450                0                   4                      4                  9
SEA88FA166               1600                0                   3                      4                  0
SEA88FA176               9500                0                   4                      1                 11
SEA88LA072               1950                1                   4                      6                  4
SEA88LA094               1750                0                   4                      4                  6
SEA88EA177               2300                0                   4                      3                 10
SEA88LA182               2900                0                   4                      0                  0
SEA88EA188               1000                o                   4                      0                 11
SEA89FA002               3800                0                   4                      6                  3
SEA89FA010               2400                0                   4                      7                  9
SEA89FA027               5000                0                   4                      4                  9
SEA89FA036               7967                o                   4                      0                  0
SEA89FA041               1260                0                   4                      3                  0
SEA89GA064               2400                0                   4                      4                  0
______________________________________________________________________________________________________________
                                                                                                            63
 NTSB_NBR          AIRCRAFT_WGT        DIS_AIRPORT          ACFT_DAMAGE        AIRSPEED_IMPACT    FLT_PATH_ANGLE
SEA89LA011               1325               0                     4                     0
SEA89LA013               3100               0                     4                     6
_____________________________________________________________________________________________________________
                                                                                                           64

Part K

                                                Index to Comment Responses
---------------------------------------------------------------------------------------------------------------------
  Document #: 1001 Comment #: 1........Response #: E.1         Document #: 1007 Comment #: 5........Response #: C.3
  Document #: 1001 Comment #: 2........Response #: F.1         Document #: 1007 Comment #: 6........Response #: C.1
  Document #: 1001 Comment #: 3........Response #: A.1         Document #: 1007 Comment #: 7........Response #: D.27
  Document #: 1002 Comment #: 1........Response #: F.2         Document #: 1007 Comment #: 8........Response #: C.1
  Document #: 1002 Comment #: 2........Response #: F.3         Document #: 1007 Comment #: 9........Response #: D.23
  Document #: 1002 Comment #: 3........Response #: F.4         Document #: 1007 Comment #:10........Response #: D.23
  Document #: 1002 Comment #: 4........Response #: F.5         Document #: 1007 Comment #:11........Response #: G.32
  Document #: 1002 Comment #: 5........Response #: F.6         Document #: 1007 Comment #:12........Response #: G.22
  Document #: 1002 Comment #: 6........Response #: F.7         Document #: 1007 Comment #:13....... Response #: F.20
  Document #: 1002 Comment #: 7........Response #: F.8         Document #: 1007 Comment #:14....... Response #: F.21
  Document #: 1002 Comment #: 8........Response #: F.9         Document #: 1007 Comment #:15........Response #: F.9
  Document #: 1002 Comment #: 9........Response #: F.9         Document #: 1007 Comment #:16........Response #: F.7
  Document #: 1002 Comment #: 10.......Response #: F.9         Document #: 1008 Comment #: 1........Response #: D.23
  Document #: 1002 Comment #: 11.......Response #: F.9         Document #: 1008 Comment #: 2........Response #: G.6
  Document #: 1002 Comment #: 12.......Response #: F.10        Document #: 1008 Comment #: 3........Response #: A.1
  Document #: 1003 Comment #: 1........Response #: G.28        Document #: 1008 Comment #: 4........Response #: D.23
  Document #: 1003 Comment #: 2........Response #: F.1         Document #: 1008 Comment #: 5........Response #: D.23
  Document #: 1003 Comment #: 3........Response #: F.11        Document #: 1009 Comment #: 1........Response #: G.37
  Document #: 1004 Comment #: 1........Response #: F.12        Document #: 1009 Comment #: 2........Response #: F.12
  Document #: 1005 Comment #: 1........Response #: F.13        Document #: 1009 Comment #: 3........Response #: B.7
  Document #: 1005 Comment #: 2........Response #: F.14        Document #: 1010 Comment #: 1........Response #: D.20
  Document #: 1005 Comment #: 3........Response #: F.15        Document #: 1010 Comment #: 2........Response #: F.22
  Document #: 1005 Comment #: 4........Response #: F.16        Document #: 1010 Comment #: 3........Response #: F.23
  Document #: 1005 Comment #: 5........Response #: F.17        Document #: 1010 Comment #: 4........Response #: F.22
  Document #: 1005 Comment #: 6........Response #: F.18        Document #: 1010 Comment #: 5........Response #: E.16
  Document #: 1005 Comment #: 7........Response #: F.19        Document #: 1010 Comment #: 6........Response #: F.22
  Document #: 1005 Comment #: 8........Response #: F.9         Document #: 1010 Comment #: 7........Response #: F.22
  Document #: 1005 Comment #: 9........Response #: F.1         Document #: 1010 Comment #: 8........Response #: G.42
  Document #: 1006 Comment #: 1........Response #: E.2         Document #: 1010 Comment #: 9........Response #: G.38
  Document #: 1006 Comment #: 2........Response #: E.3         Document #: 1011 Comment #: 1........Response #: A.1
  Document #: 1006 Comment #: 3........Response #: E.4         Document #: 1011 Comment #: 2........Response #: D.13
  Document #: 1006 Comment #: 4........Response #: E.5         Document #: 1011 Comment #: 3........Response #: D.28
  Document #: 1006 Comment #: 5........Response #: E.6         Document #: 1011 Comment #: 4........Response #: D.22
  Document #: 1006 Comment #: 6........Response #: E.7         Document #: 1011 Comment #: 5........Response #: E.29
  Document #: 1006 Comment #: 7........Response #: E.8         Document #: 1011 Comment #: 6........Response #: D.23
  Document #: 1006 Comment #: 8........Response #: E.9         Document #: 1011 Comment #: 7........Response #: E.17
  Document #: 1006 Comment #: 9........Response #: E.10        Document #: 1011 Comment #: 8........Response #: D.7
  Document #: 1006 Comment #: 10.......Response #: E.11        Document #: 1011 Comment #: 9........Response #: D.1
  Document #: 1006 Comment #: 11.......Response #: E.12        Document #: 1011 Comment #:10........Response #: D.2
  Document #: 1006 Comment #: 12.......Response #: E.13        Document #: 1011 Comment #:11........Response #: G.1
  Document #: 1006 Comment #: 13.......Response #: E.14        Document #: 1011 Comment #:12........Response #: E.18
  Document #: 1006 Comment #: 14.......Response #: E.15        Document #: 1011 Comment #:13........Response #: E.8
  Document #: 1006 Comment #: 15.......Response #: E.8         Document #: 1011 Comment #:14........Response #: E.19
  Document #: 1007 Comment #: 1........Response #: G.32        Document #: 1011 Comment #:15........Response #: E.20
  Document #: 1007 Comment #: 2........Response #: D.23        Document #: 1011 Comment #:16........Response #: E.21
  Document #: 1007 Comment #: 3........Response #: D.17        Document #: 1011 Comment #:17........Response #: E.22
  Document #: 1007 Comment #: 4........Response #: D.27        Document #: 1011 Comment #:18........Response #: D.14
      Section K                                           K-1
                                                Index to Comment Responses
---------------------------------------------------------------------------------------------------------------------
  Document #: 1016 Comment #: 19.......Response #: G.27        Document #: 1011 Comment #:20........Response #: D.23
  Document #: 1012 Comment #: 1........Response #: D.3         Document #: 1016 Comment #:21........Response #: G.42
  Document #: 1012 Comment #: 2........Response #: D.26        Document #: 1016 Comment #:22........Response #: D.17
  Document #: 1012 Comment #: 3........Response #: E.23        Document #: 1016 Comment #:23........Response #: E.18 
  Document #: 1012 Comment #: 4........Response #: G.8         Document #: 1016 Comment #:24........Response #: F.9
  Document #: 1012 Comment #: 5........Response #: D.21        Document #: 1016 Comment #:25........Response #: B.1
  Document #: 1012 Comment #: 6........Response #: G.33        Document #: 1016 Comment #:26........Response #: G.27
  Document #: 1003 Comment #: 1........Response #: G.29        Document #: 1017 Comment #:1.........Response #: D.23
  Document #: 1004 Comment #: 1........Response #: G.41        Document #: 1017 Comment #:2.........Response #: D.23
  Document #: 1015 Comment #: 1........Response #: G.33        Document #: 1017 Comment #:3.........Response #: D.23
  Document #: 1015 Comment #: 2........Response #: D.3         Document #: 1017 Comment #:4.........Response #: D.23
  Document #: 1015 Comment #: 3........Response #: A.1         Document #: 1017 Comment #:5.........Response #: D.27
  Document #: 1015 Comment #: 4........Response #: D.13        Document #: 1017 Comment #:6.........Response #: D.17
  Document #: 1015 Comment #: 5........Response #: C.1         Document #: 1017 Comment #:7.........Response #: D.17
  Document #: 1015 Comment #: 6........Response #: D.4         Document #: 1017 Comment #:8.........Response #: D.17
  Document #: 1015 Comment #: 7........Response #: C.1         Document #: 1017 Comment #:9.........Response #: D.17
  Document #: 1015 Comment #: 8........Response #: D.23        Document #: 1017 Comment #:10........Response #: G.42 
  Document #: 1015 Comment #: 9........Response #: D.14        Document #: 1017 Comment #:11........Response #: D.15
  Document #: 1015 Comment #: 10.......Response #: D.14        Document #: 1017 Comment #:12........Response #: D.17
  Document #: 1015 Comment #: 11.......Response #: D.18        Document #: 1017 Comment #:13........Response #: D.17
  Document #: 1015 Comment #: 12.......Response #: F.16        Document #: 1017 Comment #:14........Response #: G.42
  Document #: 1015 Comment #: 13.......Response #: D.17        Document #: 1017 Comment #:15........Response #: F.25
  Document #: 1015 Comment #: 14.......Response #: D.24        Document #: 1017 Comment #:16........Response #: D.17
  Document #: 1015 Comment #: 15.......Response #: E.8         Document #: 1017 Comment #:17........Response #: D.10
  Document #: 1015 Comment #: 16.......Response #: D.19        Document #: 1017 Comment #:18........Response #: D.11 
  Document #: 1015 Comment #: 17.......Response #: A.1         Document #: 1017 Comment #:19........Response #: D.15
  Document #: 1015 Comment #: 18.......Response #: D.1         Document #: 1017 Comment #:20........Response #: B.1
  Document #: 1015 Comment #: 19.......Response #: G.42        Document #: 1017 Comment #:21........Response #: D.1
  Document #: 1016 Comment #: 1........Response #: G.18        Document #: 1017 Comment #:22........Response #: G.27
  Document #: 1016 Comment #: 2........Response #: B.1         Document #: 1018 Comment #:1.........Response #: E.24
  Document #: 1016 Comment #: 3........Response #: C.5         Document #: 1018 Comment #:2.........Response #: G.25
  Document #: 1016 Comment #: 4........Response #: F.24        Document #: 1018 Comment #:3.........Response #: A.1
  Document #: 1016 Comment #: 5........Response #: F.16        Document #: 1019 Comment #:1.........Response #: B.1
  Document #: 1016 Comment #: 6........Response #: F.18        Document #: 1019 Comment #:2.........Response #: D.27
  Document #: 1016 Comment #: 7........Response #: A.1         Document #: 1019 Comment #:3.........Response #: D.23
  Document #: 1016 Comment #: 8........Response #: D.10        Document #: 1019 Comment #:4.........Response #: D.23
  Document #: 1016 Comment #: 9........Response #: D.23        Document #: 1019 Comment #:5.........Response #: G.42
  Document #: 1016 Comment #: 10.......Response #: B.1         Document #: 1019 Comment #:6.........Response #: A.1
  Document #: 1016 Comment #: 11.......Response #: D.27        Document #: 1019 Comment #:7.........Response #: G.37
  Document #: 1016 Comment #: 12.......Response #: A.1         Document #: 1019 Comment #:8.........Response #: G.24
  Document #: 1016 Comment #: 13.......Response #: D.1         Document #: 1020 Comment #:1.........Response #: A.1
  Document #: 1016 Comment #: 14.......Response #: G.23        Document #: 1021 Comment #:1.........Response #: A.1
  Document #: 1016 Comment #: 15.......Response #: D.23        Document #: 1021 Comment #:2.........Response #: G.37
  Document #: 1016 Comment #: 16.......Response #: D.27        Document #: 1021 Comment #:3.........Response #: G.15
  Document #: 1016 Comment #: 17.......Response #: C.1         Document #: 1021 Comment #:4.........Response #: A.1
  Document #: 1016 Comment #: 18.......Response #: D.20        Document #: 1021 Comment #:5.........Response #: G.11
  Document #: 1016 Comment #: 19.......Response #: D.5         Document #: 1021 Comment #:6.........Response #: C.9
    Section K                                           K-2
                                                Index to Comment Responses
---------------------------------------------------------------------------------------------------------------------
 Document #:  1021  Comment #:   7........Response #:  G.42    Document #:  1032  Comment #:  3........Response #:  C.1
 Document #:  1021  Comment #:   8........Response #:  D.23    Document #:  1032  Comment #:  4........Response #:  A.1
 Document #:  1021  Comment #:   9........Response #:  A.1     Document #:  1032  Comment #:  5........Response #:  D.23
 Document #:  1021  Comment #:  10........Response #:  G.13    Document #:  1032  Comment #:  6........Response #:  D.23
 Document #:  1021  Comment #:  11........Response #:  C.4     Document #:  1032  Comment #:  7........Response #:  D.23
 Document #:  1021  Comment #:  12........Response #:  G.37    Document #:  1032  Comment #:  8........Response #:  B.1
 Document #:  1021  Comment #:  13........Response #:  E.17    Document #:  1032  Comment #:  9........Response #:  G.36
 Document #:  1021  Comment #:  14........Response #:  D.26    Document #:  1033  Comment #:  1........Response #:  B.1
 Document #:  1021  Comment #:  15........Response #:  G.42    Document #:  1033  Comment #:  2........Response #:  A.1
 Document #:  1021  Comment #:  16........Response #:  G.41    Document #:  1033  Comment #:  3........Response #:  C.1
 Document #:  1021  Comment #:  17........Response #:  G.17    Document #:  1033  Comment #:  4........Response #:  A.1
 Document #:  1021  Comment #:  18........Response #:  G.18    Document #:  1033  Comment #:  5........Response #:  D.23
 Document #:  1022  Comment #:   1........Response #:  B.1     Document #:  1033  Comment #:  6........Response #:  D.23
 Document #:  1022  Comment #:   2........Response #:  D.23    Document #:  1033  Comment #:  7........Response #:  D.23
 Document #:  1022  Comment #:   3........Response #:  G.14    Document #:  1033  Comment #:  8........Response #:  B.1
 Document #:  1022  Comment #:   4........Response #:  A.1     Document #:  1034  Comment #:  1........Response #:  B.1
 Document #:  1022  Comment #:   5........Response #:  C.6     Document #:  1034  Comment #:  2........Response #:  A.1
 Document #:  1022  Comment #:   6........Response #:  C.1     Document #:  1034  Comment #:  3........Response #:  C.1
 Document #:  1022  Comment #:   7........Response #:  G.28    Document #:  1034  Comment #:  4........Response #:  A.1
 Document #:  1022  Comment #:   8........Response #:  G.9     Document #:  1034  Comment #:  5........Response #:  D.23
 Document #:  1024  Comment #:   1........Response #:  E.2S    Document #:  1034  Comment #:  6........Response #:  D.23
 Document #:  1024  Comment #:   2........Response #:  F.12    Document #:  1034  Comment #:  7........Response #:  D.23
 Document #:  1024  Comment #:   3........Response #:  G.42    Document #:  1034  Comment #:  8........Response #:  B.1
 Document #:  1024  Comment #:   4........Response #:  D.20    Document #:  1035  Comment #:  1........Response #:  B.1
 Document #:  1025  Comment #:   1........Response #:  G.37    Document #:  1035  Comment #:  2........Response #:  A.1
 Document #:  1026  Comment #:   1........Response #:  B.1     Document #:  1035  Comment #:  3........Response #:  C.1
 Document #:  1026  Comment #:   2........Response #:  A.1     Document #:  1035  Comment #:  4........Response #:  A.1
 Document #:  1026  Comment #:   3........Response #:  C.1     Document #:  1035  Comment #:  5........Response #:  D.23
 Document #:  1026  Comment #:   4........Response #:  A.1     Document #:  1035  Comment #:  6........Response #:  D.23
 Document #:  1026  Comment #:   5........Response #:  D.23    Document #;  1035  Comment #:  7........Response #:  D.23
 Document #:  1026  Comment #:   6........Response #:  D.23    Document #:  1035  Comment #:  8........Response #:  B.1
 Document #:  1026  Comment #:   7........Response #:  D.23    Document #:  1035  Comment #:  9........Response #:  G.33
 Document #:  1026  Comment #:   8........Response #:  B.1     Document #:  1035  Comment #: 10........Response #:  G.33
 Document #:  1027  Comment #:   1........Response #:  G.21    Document #:  1035  Comment #: 11........Response #:  D.8
 Document #:  1027  Comment #:   2........Response #:  A.1     Document #:  1035  Comment #: 12........Response #:  G.39
 Document #:  1027  Comment #:   3........Response #:  C.1     Document #:  1035  Comment #:  1........Response #:  G.34
 Document #:  1027  Comment #:   4........Response #:  G.2     Document #:  1036  Comment #:  2........Response #:  A.1
 Document #:  1030  Comment #:   1........Response #:  D.20    Document #:  1036  Comment #:  3........Response #:  A.1
 Document #:  1030  Comment #:   2........Response #:  B.1     Document #:  1036  Comment #:  4........Response #:  G.40
 Document #:  1031  Comment #:   1........Response #:  A.1     Document #:  1036  Comment #:  5........Response #:  D.23
 Document #:  1031  Comment #:   2........Response #:  C.1     Document #:  1036  Comment #:  6........Response #:  D.23
 Document #:  1031  Comment #:   3........Response #:  D.23    Document #:  1036  Comment #:  7........Response #:  D.16
 Document #:  1031  Comment #:   4........Response #:  G.23    Document #:  1037  Comment #:  1........Response #:  B.1
 Document #:  1031  Comment #:   5........Response #:  F.18    Document #:  1037  Comment #:  2........Response #:  A.1
 Document #:  1031  Comment #:   6........Response #:  B.1     Document #:  1037  Comment #:  3........Response #:  C.1
 Document #:  1032  Comment #:   1........Response #:  B.1     Document #:  1037  Comment #:  4........Response #:  A.1
 Document #:  1032  Comment #:   2........Response #:  A.1     Document #:  1037  Comment #:  5........Response #:  D.23
    Section K                                             K-3
                                                Index to Comment Responses
---------------------------------------------------------------------------------------------------------------------
Document #:  1031  Comment #:  6........Response #:  D.23  Document #:  1042  Comment #:  18........Response #:  D.23
Document #:  1031  Comment #:  7........Response #:  D.23  Document #:  1042  Comment #:  19........Response #:  D.23
Document #:  1031  Comment #:  8........Response #:  B.1   Document #:  1042  Comment #:  20........Response #:  D.23
Document #:  1035  Comment #:  1........Response #:  B.1   Document #:  1042  Comment #:  21........Response #:  D.12
Document #:  1035  Comment #:  2........Response #:  A.1   Document #:  1042  Comment #:  22........Response #:  D.23
Document #:  1035  Comment #:  3........Response #:  C.1   Document #:  1042  Comment #:  23........Response #:  D.27
Document #:  1035  Comment #:  4........Response #:  A.1   Document #:  1042  Comment #:  24........Response #:  D.17
Document #:  1035  Comment #:  5........Response #:  D.23  Document #:  1042  Comment #:  25........Response #:  D.14
Document #:  1035  Comment #:  6........Response #:  D.23  Document #:  1042  Comment #:  26........Response #:  B.6
Document #:  1035  Comment #:  7........Response #:  D.23  Document #:  1042  Comment #:  27........Response #:  B.1
Document #:  1035  Comment #:  8........Response #:  B.1   Document #:  1042  Comment #:  28........Response #:  D.27
Document #:  1035  Comment #:  1........Response #:  A.1   Document #:  1042  Comment #:  29........Response #:  D.23
Document #:  1030  Comment #:  2........Response #:  A.1   Document #:  1042  Comment #:  30........Response #:  D.10
Document #:  1039  Comment #:  3........Response #:  C.1   Document #:  1042  Comment #:  31........Response #:  A.1
Document #:  1039  Comment #:  4........Response #:  A.1   Document #:  1042  Comment #:  32........Response #:  A.1
Document #:  1039  Comment #:  5........Response #:  D.23  Document #:  1042  Comment #:  33........Response #:  G.26
Document #:  1039  Comment #:  6........Response #:  D.23  Document #:  1042  Comment #:  34........Response #:  A.1
Document #:  1039  Comment #:  7........Response #:  B.1   Document #:  1042  Comment #:  35........Response #:  D.10
Document #:  1040  Comment #:  1........Response #:  B.1   Document #:  1042  Comment #:  36........Response #:  D.23
Document #:  1040  Comment #:  2........Response #:  A.1   Document #:  1042  Comment #:  37........Response #:  D.27
Document #:  1040  Comment #:  3........Response #:  D.23  Document #:  1042  Comment #:  38........Response #:  D.23
Document #:  1040  Comment #:  4........Response #:  G.12  Document #:  1042  Comment #:  39........Response #:  D.17
Document #:  1041  Comment #:  1........Response #:  B.4   Document #:  1042  Comment #:  40........Response #:  D.23
Document #:  1041  Comment #:  2........Response #:  A.1   Document #:  1042  Comment #:  41........Response #:  D.21
Document #:  1041  Comment #:  3........Response #:  A.1   Document #:  1042  Comment #:  42........Response #:  G.43
Document #:  1041  Comment #:  4........Response #:  C.7   Document #:  1042  Comment #:  43........Response #:  C.1
Document #:  1041  Comment #:  5........Response #:  C.1   Document #:  1042  Comment #:  44........Response #:  D.27
Document #:  1041  Comment #:  6........Response #:  G.40  Document #:  1042  Comment #:  45........Response #:  C.1
Document #:  1041  Comment #:  7........Response #:  B.3   Document #:  1042  Comment #:  46........Response #:  C.1
Document #:  1041  Comment #:  8........Response #:  B.1   Document #:  1042  Comment #:  47........Response #:  D.6
Document #:  1042  Comment #:  1........Response #:  B.1   Document #:  1042  Comment #:  48........Response #:  D.27
Document #:  1042  Comment #:  2........Response #:  B.1   Document #:  1042  Comment #:  49........Response #:  D.23
Document #:  1042  Comment #:  3........Response #:  B.1   Document #:  1042  Comment #:  50........Response #:  D.17
Document #:  1042  Comment #:  4........Response #:  A.l   Document #:  1043  Comment #:   1........Response #:  C.8
Document #:  1042  Comment #:  5........Response #:  C.1   Document #:  1043  Comment #:   2........Response #:  C.1
Document #:  1042  Comment #:  6........Response #:  C.1   Document #:  1043  Comment #:   3........Response #:  A.1
Document #:  1042  Comment #:  7........Response #:  C.1   Document #:  1043  Comment #:   4........Response #:  G.27
Document #:  1042  Comment #:  8........Response #:  A.1   Document #:  1043  Comment #:   5........Response #:  G.19
Document #:  1042  Comment #:  9........Response #:  A.1   Document #:  1043  Comment #:   6........Response #:  B.1
Document #:  1042  Comment #:  10.......Response #:  A.1   Document #:  1043  Comment #:   7........Response #:  A.1
Document #:  1042  Comment #:  11.......Response #:  G.19  Document #:  1044  Comment #:   1........Response #:  G.20
Document #:  1042  Comment #:  12.......Response #:  D.23  Document #:  1044  Comment #:   2........Response #:  G.10
Document #:  1042  Comment #:  13.......Response #:  B.5   Document #:  1044  Comment #:   3........Response #:  G.7
Document #:  1042  Comment #:  14.......Response #:  G.28  Document #:  1044  Comment #:   4........Response #:  D.27
Document #:  1042  Comment #:  15.......Response #:  D.25  Document #:  1044  Comment #:   5........Response #:  C.1
Document #:  1042  Comment #:  16.......Response #:  D.23  Document #:  1044  Comment #:   6........Response #:  D.9
Document #:  1042  Comment #:  17.......Response #:  D.23  Document #:  1044  Comment #:   7........Response #:  F.15
   Section K                                                      K-4
                                                Index to Comment Responses
---------------------------------------------------------------------------------------------------------------------
Document #:   1044  Comment #: 8........Response #:  G.12
Document #:   1045  Comment #: 1........Response #:  B.1
Document #:   1045  Comment #: 2........Response #:  B.1
Document #:   1045  Comment #: 3........Response #:  G.34
Document #:   1045  Comment #: 4........Response #:  C.1
Document #:   1045  Comment #: 5........Response #:  C.2
Document #:   1045  Comment #: 6........Response #:  C.1
Document #:   1045  Comment #: 7........Response #:  D.10
Document #:   1045  Comment #: 8........Response #:  D.10
Document #:   1045  Comment #: 9........Response #:  G.35
Document #:   1045  Comment #:10........Response #:  D.23
Document #:   1046  Comment #: 1........Response #:  B.1
Document #:   1046  Comment #: 2........Response #:  C.1
Document #:   1046  Comment #: 3........Response #:  B.2
Document #:   1046  Comment #: 4........Response #:  G.5
Document #:   1046  Comment #: 5........Response #:  G.3
Document #:   1046  Comment #: 6........Response #:  A.1
Document #:   1048  Comment #: 1........Response #:  B.1
Document #:   1048  Comment #: 2........Response #:  D.14
Document #:   1048  Comment #: 3........Response #:  D.14
Document #:   1048  Comment #: 4........Response #:  D.3
Document #:   1048  Comment #: 5........Response #:  D.3
Document #:   1048  Comment #: 6........Response #:  A.1
Document #:   1048  Comment #: 7........Response #:  G.40
Document #:   1048  Comment #: 8........Response #:  C.1
Document #:   1048  Comment #: 9........Response #:  C.1
Document #:   1048  Comment #:10........Response #:  C.4
Document #:   1048  Comment #:11........Response #:  D.27
Document #:   1048  Comment #:12........Response #:  D.23
Document #:   1048  Comment #:13........Response #:  D.17
Document #:   1048  Comment #:14........Response #:  F.26
Document #:   1048  Comment #:15........Response #:  E.26
Document #:   1048  Comment #:16........Response #:  B.1
Document #:   1048  Comment #:17........Response #:  D.23
Document #:   1048  Comment #:18........Response #:  G.4
Document #:   1048  Comment #:19........Response #:  D.10
Document #:   1048  Comment #:20........Response #:  A.1
Document #:   1048  Comment #:21........Response #:  D.10
Document #:   1048  Comment #:22........Response #:  D.10
Document #:   1048  Comment #:23........Response #:  E.28
Document #:   1048  Comment #:24........Response #:  E.27
Document #:   1048  Comment #:25........Response #:  G.31
Document #:   1048  Comment #:26........Response #:  G.39
Document #:   1048  Comment #:27........Response #:  B.1
Document #:   1049  Comment #: 1........Response #:  G.l6
Document #:   1049  Comment #: 2........Response #:  G.17
Document #:   1050  Comment #: 1........Response #:  G.30
   Section K                                                   K-5

Part L

POTENTIAL OGALLALA AQUIFER
IMPACTS OF HYPOTHETICAL
PLUTONIUM DISPERSAL ACCIDENT
IN ZONE 4 OF PANTEX PLANT
NOVEMBER 1992
H.J. TURIN
I.R. TRIAY
W.R. HANSEN
W.J. WENZEL
Los Alamos
Los Alamos National Laboratory
Los Alamos, New Mexico 87545
TABLE OF CONTENTS
1 - EXECUTIVE SUMMARY 1
2 - STATEMENT OF PROBLEM 2
3 - PLUTONIUM TRANSPORT TO THE OGALLALA AQUIFER 3
Regional Setting 3
Recharge to the Ogallala Aquifer 4
Thickness of the Unsaturated Zone 6
Definition of the Contaminant Source Term 6
Radionuclide Geochemistry and Sorption Properties 7
Conceptual Transport model 10
4 - ANALYSIS OF GROUNDWATER IMPACTS 11
Piston Flow Results 11
Advection-Dispersion Results 13
5 - POTENTIAL COMPLICATIONS 16
Colloidal Transport 16
Perched Aquifers 17
"Short-Circuit" Recharge Paths 17
Preferential Flow 18
Multidimensional Flow 19
Dropping Groundwater Levels 20
Decay Products 20
6 - DOSIMETRY AND RESRAD MODELING OF PLUTONIUM MIGRATION 21
7 - REFERENCES 24
Appendix A: Laboratory Plutonium Sorption Study 28
Appendix B: Recommended Drinking Water Dose Limits for Plutonium Ingestion 31
- i -
LIST OF TABLES
Table 3-1. Recharge rate estimated for the Southern High Plains 5
Table 3-2. Isotopic composition of weapons grade plutonium 8
Table 6-1. Distribution coefficients used for RESRAD simulations 22
Table 6-2. Initial contaminated mixture used for RESRAD simulations 22
Table 6-3. Contaminant breakthrough times predicted by RESRAD for various
aquifer depths 23
Table 6-4. Maximum water pathway doses predicted by RESRAD for various
aquifer depths 23
Table A-1. Plutonium sorption onto Pullman soil 30
Table A-2. Plutonium sorption onto Ogallala sand 30
LIST OF FIGURES
Figure 3-1. Central and Southern High Plains of Texas 4
Figure 3-2. Decay chains of weapons grade plutonium components 8
Figure 4-1. CXTFIT simulation results for plutonium transport to a 50-feet
and 200-foot deep aquifer 15
Figure 5-1. CXTFIT simulation results for plutonium transport to a 50-feet
deep aquifer, with accelerated transport due to preferential
flow 19
-ii-
1 - EXECUTIVE SUMMARY
Pantex Plant and DOE Albuquerque Field Office staffs are currently preparing a Safety Analysis
Report and Environmental assessment describing current weapon staging and proposed
component interim storage operations in Zone 4 of the Pantex Plant, near Amarillo, Texas. The
State of Texas has expressed concern over the potential consequences to the Ogallala Aquifer
of an accidental plutonium release. Members of the Los Alamos National Laboratory Earth and
Environmental Science Division has prepared this report describing the potential for aquifer
contamination should plutonium be released to the environment within an 80-km radius of the
Pantex Plant.
The following assumptions were used in preparing the groundwater impact analysis:
* Surface soils would be decontaminated to a maximum radiation level of 0.2 uCi/m2
following the hypothetical accident.
* Surface transport processes may increase soil concentrations ten-fold, to 2.0 uCi/m2,
before infiltration takes place.
* Recharge to the Ogallala Aquifer is focused at playa lake beds. Playa recharge rates
are approximately 3 cm/year, ten times the High Plains average.
* The Ogallala Aquifer water table may be encountered as shallow as 50 feet beneath the
land surface within the study area.
* The entire unsaturated zone exhibits a plutonium sorption coefficient of 100 mL/g,
approximating the sorption of clean Ogallala sand.
With these conservative assumptions in place, two analyses were performed. A non-dispersive
piston flow model indicated that significant plutonium levels be encountered in a 50-foot
deep aquifer after approximately 76,000 years. A second, more realistic analysis incorporating
dispersion showed that even with unrealistically low dispersivity values, peak plutonium
concentration in the 50-foot aquifer would never exceed the most restrictive drinking water dose
limits. With more realistic dispersivity values, or deeper water table more typical of the study
area, peak plutonium concentrations in the aquifer would be orders of magnitude below dose
limits. Neither analysis showed significant impacts to deeper aquifers.
Additional complicating factors have also been analyzed. These include colloidal plutonium
transport, preferential flow, the effects of perched aquifers, opportunities for "short-circuit flow
through abandoned wells or other conduits, and the fate of daughter products. Although it is
difficult to quantify these factors accurately, most are expected to have little if any negative
impact on the Ogallala Aquifer. Colloidal transport is perhaps the most uncertain process in this
category, but a field experiment at a nearby location suggests that colloidal transport will not
enhance radionuclide transport enough to significantly affect groundwater quality in the Ogallala
Aquifer.
The final conclusion of these analyses is that the hypothetical plutonium dispersal accident does
not pose a significant threat to the Ogallala Aquifer.
- 1 -
2 - STATEMENT OF PROBLEM
The hypothetical accident leading to dispersal of plutonium to the environment around Pantex
is a high temperature fire caused by a jet plane impact into a Zone 4 storage igloo containing
nuclear weapons components, and subsequent ignition of jet fuel. These conditions may cause
surface deposition of air-borne particulate plutonium across a large area downwind of the plant.
The exact dimensions and location of this plume will depend on local meteorological conditions
at the time of the fire, but much of the plutonium will likely fall on the Southern High Plains
and Central High Plains of Texas. These are the recharge areas for the Ogallala (or High
Plains) Aquifer, the primary water source for much of the Texas Panhandle. This aquifer is of
immense economic significance, and potential threats to the resource should be carefully
analyzed, and, if necessary, minimized.
This report describes the potential impacts of the hypothetical accident on water quality in the
Ogallala Aquifer. The results resented here are based on a thorough review of existing
information on local and regional hydrogeology, new laboratory sorption studies on local
geologic materials, and transport and dosimetry modeling. Although this is not a formal "worst-
case" analysis, we have consistently made conservative assumptions to maximize the probability
of identifying any real threats to the Ogallala Aquifer.
-2-
3 - PLUTONIUM TRANSPORT TO THE OGALLALA AQUIFER
Any potential impacts to the Ogallala aquifer would entail transport of contaminants from their
deposition site at the ground surface down to the water table. This section of the report briefly
outlines the processes that control this transport and describes the conceptual model that
underlies the quantitative calculations discussed in the following sections.
Regional Setting
In the Panhandle section of Texas, the Ogallala Aquifer underlies the Southern and Central High
Plains (Figure 3-1). These provinces are topographically-isolated plateaus bordered by the Pecos
and Canadian River valleys to the west and the Caprock Escarpment to the east. The Southern
High Plains are separated from the Central High Plains by the Canadian Breaks, an eroded
landscape along the Canadian River.
The Ogallala Formation, primary host of the Ogallala aquifer, is Tertiary in age and consists
of eolian and alluvial material derived from the Southern Rocky Mountains to the west. Aquifer
materials range from gravel to clay in grain size, and include some post-depositional caliche
layers. The Ogallala Formation has been eroded and is no longer present along the Canadian
and Pecos Rivers, or on the Rolling Plains, east of the Caprock Escarpment.
The Ogallala Formation is overlain by up to 27 m of Quaternary-age eolian silt and sand that
comprise the Blackwater Draw Formation (Holliday, 1990). The major soil on the uplands in
the study area is Pullman clay loam, derived from the underlying fine-textured eolian sediments
(Unger and Pringle, 1981). The lower horizons of the Pullman soils are characterized by
manganese-iron films on the surface (Allen et al., 1972). The High Plains surface is
characterized by numerous playa lakes, small surface depressions found throughout the study
area. The soil underlying the playa is primary Randall clay, sometimes associated with
soils of the Estacado, Mansker, Lofton, and Lipan series (Unger and Pringle, 1981). Based on
X-ray diffractometry, Allen et al. (1972) report that the clay mineralogy of the Randall soil
consists mainly of poorly organized montmorillonite (associated with fine clay). Silt
mineralogy is dominated by quartz and feldspars.
Groundwater in the Ogallala Aquifer occurs under unconfined or water-table conditions.
Regional groundwater flow is from west to east, reflecting the regional topography. Recharge
to the aquifer occurs through infiltration of rainfall and surface water through the Blackwater
Draw Formation (Nativ and, Smith, 1987). Recharge is probably focused at playa lakes, small
surface depressions ubiquitous throughout the study area. The question of focused recharge will
be discussed further below.
Natural discharge from the Ogallala Aquifer historically occurred through seeps and springs
along the boundaries of the High plains, particularly along the Eastern Caprock Escarpment and
-3-
Figure (Page 4 of Part L Central and Southern High Plains of Texas, showing the 80-km radius study area)
Figure 3-1. Central and Southern High Plains of Texas, showing the 80-km radius study
area (adapted from Gustavson et al., 1990).
the Canadian Breaks. Some leakage into underlying formations is also possible. Since massive
groundwater pumpage for agriculture began after World War II, many of these natural discharge
points have stopped flowing, and today, groundwater pumpage is by far the most significant
discharge route from the Ogallala Aquifer (Nativ and Smith, 1987). Current pumpage rates far
exceed recharge, and the resulting groundwater mining is leading to declining water tables in
most of the study area (Ashworth, 1991).
Water chemistry in the Ogallala aquifer and in the unsaturated zone beneath playas is generally
quite good, typically a mixed-cation/bicarbonate water with 200-500 mg/L total dissolved solids
and a pH of about 7.5 (Purtymun and Becker, 1982; Wood and Ostercamp, 1984).
-4-
Recharge to the Ogallala Aquifer
Because of the economic importance of the Ogallala Aquifer and concern over water level
declines, numerous researchers have studied the aquifer's recharge rate (Table 3-1). As Stone
and McGurk (1985) pointed out, recharge can be considered on various spatial scales, ranging
from local through areal to regional. At the local scale, recharge is likely to vary widely from
spot to spot over a distance of meters, due to variations in local rainfall, surface slope, and soil
properties. Over a larger area, these local variations will tend to average out, and a
representative recharge rate may be applied over the entire extent of a particular landscape
setting, such as playa lakes or uplands. Finally, a weighted average of different areal recharge
rates may represent an overall regional recharge rate for a region the size of the Southern High
Plains.
Table 3-1. Recharge rate estimates for the Southern High Plains.
Recharge Esti- (cm/year) Location Source
mate
--------------------------------------------------------------------------
< 0.5 in/yr <1.3 Regional, SHP C.V. Theis, cited by
Aronovici and Schneider, 1972
0.25 cm/yr 0.25 Regional, SHP Wood and Petraitis, 1984
4 - 5 cm/yr 4-5 Playa annuli Wood and Petraitis, 1984
SHP
0.11 in/yr 0.28 Regional Luckey, 1984
northern SHP
<3/16 in/yr <0.48 Regional, TX Knowles, 1984
High Plains
0.75 mm/yr 0.075 Blackwater Stone and McGurk, 1985
Draw Fm., NM
4.36mm/yr 0.436 Sand Dunes, Stone and McGurk, 1985
NM
12.22 mm/yr 1.222 Playas, NM Stone and McGurk, 1985
1.5 mm/yr 0.15 Regional, NM Stone and McGurk, 1985
0.3 cm/yr 0.3 Regional, SHP Ostercamp and Wood, 1987
1.3 - 8 cm/yr 1.3-8 Maximum, SHP Nativ and Riggio, 1990
--------------------------------------------------------------------------
SHP: Southern High Plains
--------------------------------------------------------------------------
-5-
Numerical model calibration have yielded regional recharge estimates for the High Plains
ranging from 0.25 - 0.3 cm/year (Luckey, 1984; Wood and Petraitis, 1984; Ostercamp and
Wood, 1987). This relatively narrow range suggests that this number is fairly accurate.
Local recharge is more variable. After years of controversy, there appears to be a consensus
building that the playa lakes of the High Plains focus recharge in a relatively small area, and that
recharge in the uplands between playas is relatively insignificant or even nonexistent (Wood and
Ostercamp, 1984; Wood and Petraitis, 1984; Stone and McGurk, 1985; Nativ and Smith, 1987).
Local recharge rates in the playa basins must therefore significantly exceed the regional averages
cited above. Local recharge estimates range from 1.2 cm/year for playas in eastern New
Mexico (Stone and McGurk, 1985) to 4-5 cm/year, for playa annuli (Wood and Petraitis, 1984).
By analyzing groundwater tritium concentrations, Nativ and Riggio (1990) calculated a maximum
estimated recharge rate at 1.3 - 8 cm/year, but pointed that the higher rates are found in the
southern part of the Southern High Plains, south of the present study area. For the purposes of
this project, we shall assume that recharge rates beneath playas in the study area consisting of
the northern part of the Southern High Plains and the southernmost part of the Central High
Plains is approximately 3 cm/year.
Thickness of the Unsaturated Zone
Water movement through the unsaturated zone between the ground surface and the water table
in arid regions is often quite slow. The thickness of the unsaturated zone is therefore an
important parameter controlling an aquifer's susceptibility to contamination. Although no recent
contour maps showing depth-to-water for the study area were available, a comparison of a recent
water-table elevation map (Ashworth, 1991) and USGS topographic maps suggest that typical
depths to the water table in the 80-km radius study area are on the order of 200 feet. In the
immediate vicinity of the Pantex Plant, the Ogallala water table is much deeper, 400 feet down,
primarily due to a zone of depression caused by the City of Amarillo well field. In parts of
Randall and Swisher counties, south of Pantex, water tables are shallower, in some cases as
shallow as 50 feet.
Hydrogeologic studies in the immediate vicinity of the Pantex Plant have revealed a local
perched aquifer above the main Ogallala Aquifer (Purtymun and Becker 1982; Texas Bureau
of Economic Geology, 1992). The lateral extent and continuity of this secondary aquifer is not
yet known. Possible effects of the perched aquifer on the potential for contamination of the
Ogallala Aquifer will be discussed in Section 5.
Definition of the Contaminant Source Term
An important step in this impact analysis is a determination of the quantity and location of
plutonium dispersed by the hypothetical accident that could impact the Ogallala Aquifer. Only
materials that fall on the recharge area of the aquifer have that potential. The recharge area for
-6-
the Ogallala Aquifer is the relatively flat High Plains surface shown in Figure 3-1. The Ogallala
Formation has been completely eroded away along the Canadian River Valley and on the Rolling
Plains east of the Caprock Escarpment, and the Ogallala outcrop areas along the margins of the
High Plains are groundwater discharge areas.
In the event of the hypothetical accident, the overail size and specific location of the affected
area will depend on local logical meteorological conditions. Predominant wind directions in the
Amarillo area to to the north-northeast (Dewart et al., 1982), but for this project, we have
conservatively assumed that the contamination plume may extend in all directions for a distance
of up to 80 km from the Pantex Plant. Contamination that may pose a risk to the Ogallala
Aquifer will therefore be assumed to be limited to material falling onto the High Plains surface
within a 80-km radius of Pantex.
If the hypothetical accident occurs, the affected area will be decontaminated to a maximum
radioactivity level of 0.2 uCi/m2. As mentioned earlier, recharge to the Ogallala Aquifer is
focused at playa lakes, and may be expected to carry particulate and sorbed plutonium as well. Wind
transport may also redistribute and locally concentrate plutonium at the playa lakes. To account
for these surface processes, we have assumed that a ten-fold concentration of plutonium may
occur between decontamination and infiltration in a soil contamination level of 2.0
uCi/m2 at the Ogallala areas in the playa lakes. This is a very conservative assumption
-- a study of 137Cs levels in soil affected by fallout from the Trinity Test showed that after 32
years, processes had locally concentrated contaminants by only a factor of 1.5 - 2
Hansen and Rodgers, 1985).
Radionuclide Geochemistry and Sorption Properties
The material dispersed to the environment by the hypothetical accident would be weapons-grade
plutonium, a mixture of plutonium isotopes with a trace of americium (Table 3-2). 239Pu
dominates the mixture on a mass basis, but because of its greater specific activity, 241Pu is the
primary activity source. The decay chains and daughter product half-lives for the various
nuclides are shown in Figure 3-2. The potential of concern are plutonium, americium,
neptunium, and uranium.
Plutonium Solution Chemistry and Sorption
The plutonium solubility reported by Nitsche (1990) in an oxidizing groundwater with a high
bicarbonate content at 25 degrees C and pH 7 - 8.5 is approximately 10E-7 M; the plutonium oxidation
states are: Pu(V) (~70%), Pu(VI) (~20%) and small amounts of Pu(IV) and Pu polymer. The
main species at pH 8.5 are Pu(V) and Pu(VI) carbonate complexes and Pu(IV) hydrolysis
products; at pH 7 the main species are PuO2CO3 and uncomplexed PuO2+. A review of the
sorption literature presented by Meijer (1992) indicates that plutonium has a high affinity for
quartz and feldspar. Triay et al. (1992) reported plutonium distribution sorption coefficients
-7-
Table 3-2. Isotopic composition of weapons grade plutonium (Wenzel and Gallegos, 1982).
Nuclide Weight % in Weapons Activity in Mixture
Grade Plutonium Mixture (Ci/g mixture)
------------------------------------------------------------------------
238Pu 0.05 0.0087
239Pu 93.6 0.0575
240Pu 6.0 0.0136
241Pu 0.4 0.448
242Pu 0.5 1.95 x 10E-6
241Am ~0.02 6.48 x 10E-4
(KD) for clays in an oxidizing groundwater at a pH of approximately 8.5: the KD values for
smectites, illite, and kaolinite are in the range of 6 x 10E2 - 1 x 10E4 mL/g. High affinities of
actinides for oxide minerals are reported by Meijer (1992) and Triay et al. (1991c). The
sorption mechanism for actinides onto oxide minerals seems to be correlated with hydrolysis
constants for these actinides in solution (Meijer, 1992).
Plutonium transport through the unsaturated zone is the major risk under evaluation in this
report, and is primarily controlled by the degree of plutonium sorption onto local soils and
aquifer materials. Because of the importance of this sorption process, a series of laboratory
238Pu -> 234U
(88 y) (2.5 x 10E5 y)
239Pu -> 235U
(2.4 x 10E4 y) (7.0 x 10E3 y)
240Pu -> 236U
(6.6 x 10E3 y) (2.3 x 10E7 y)
241Pu -> 241Am -> 237Np -> 233Pa -> 233U
(14.35 y) (432 y) (2.1 x 10E6 y) (27 d) (1.6 x 10E5 y)
242Pu -> 238U
(3.8 x 10E5 y) (4.5 x 10E9 y)
Figure 3-2. Decay chains of weapons grade plutonium components.
- 8 -
batch sorption studies were performed at Los Alamos National Laboratory, using actual
plutonium solutions and geologic samples from the vicinity of the Pantex Plant. Studies were
conducted using plutonium in various oxidation states, in both deionized and Ogallala Aquifer
water, and samples of the Pullman Clay Loam and Ogallala Sand. A full description of the
sorption experiments can be found in Appendix A. The plutonium sorption distribution
coefficient (KD) measured for the Pullman soil was on the order of 10E3 mL/g; the sorption
coefficient for the Ogallala sand was on the order of 10E2 mL/g. These experimental results are
in good agreement with published results which indicate that plutonium sorption distribution
coefficients for similar soils and water are on the order of 10E2 to 10E4 mL/g (Ames and Rai,
1978; Thomas, 1987; Meijer, 1992, Triay et. al, 1992). Unfortunately, no samples of the
Randall playa soils were available for experimentation, but based on their soil properties (Allen
et al., 1972), it is likely that the Randall soils would sorb plutonium more strongly than the
Pullman soils tested. Using the Pullman results is therefore a conservative assumption.
Americium Solution Chemistry and Sorption
The americium solubility reported by Nitsche (1990) in an oxidizing groundwater with a high
bicarbonate content at 25 degrees C and pH 7 - 8.5 is approximately 10E-9 M; americium exists in the
III oxidation state. The main species at pH 8.5 are Am(III) carbonate complexes; at pH 7 the
main species are AmCO3+, AmOH+2, and Am+3. The sorption distribution coefficients for
americium are extremely high ( >10E3 g) in groundwaters regardless of the sorbing mineral
phase (Thomas, 1987; Triay et al., 1991b; Meijer, 1992). In fact, americium has been shown
to sorb even to non-geologic materials, such as the walls of the containers used for sorption
experiments (Triay et al., 1991b).
241Am is a daughter of 241Pu, which is a minor constituent of the weapons mix (Table
3-2). Although 241Am has a relatively high specific activity, its high sorption suggests that it
poses only a minimal risk to the aquifer.
Uranium Solution Chemistry and Sorption
Uranium has a high solubility under oxidizing conditions, near neutral pH, in a bicarbonate
environment. Uranium exists in the VI oxidation state. The main species in the pH range from
7-8 are probably uranyl and U(VI) carbonate complexes. Meijer's review on sorption (1992)
indicates that uranium will have a sorption distribution coefficient larger than 10E2 mL/g on oxide
minerals, clays, and quartz. Uranium seems to sorb to clays by ion exchange. Uranium
sorption decreases at higher pH values (>8) due to the formation of U(V1) carbonate complexes
(Meijer, 1992).
The long half-lives of most uranium isotopes and uranium's low toxicity relative to plutonium
suggest that it is unlikely to pose a significant risk compared to plutonium.
- 9 -
Neptunium Solution Chemistry and Sorption
The neptunium solubility reported by Nitsche (1990) in an oxidizing groundwater with a high
bicarbonate content at 25 degrees C and pH 7 - 8.5 is approximately 10E-5 M; neptunium exists in the
V oxidation state. The main species in the pH range from 7 to 8.5 are NpO2+,NpO2CO3-, and
NpO2OH. The sorption distribution coefficients for neptunium are small (on the order of 0 - 50
mL/g) for quartz, feldspar, montmorillonite, and calcite (Thomas, 1987; Triay et al., 1991c;
Meijer, 1992). However, neptunium sorbs strongly to metal oxides in the pH range from 7 -
8.5 with a distribution coefficient larger than 10E3 mL/g (Triay et al., 1991c). Consequently the
oxide mineral coatings in the Pantex soils are expected to retard neptunium transport by
sorption.
237Np is the only neptunium isotope on the decay chains shown in Figure 3-2. It is in the decay
chain of 241Pu, which is a very minor mass constituent of the weapons material (Table 3-2).
This low concentration, coupled with its long half-life, limit the risk posed by 237Np.
It is apparent that of these four elements, plutonium poses by far the greatest risk. The
groundwater impact analysis will therefore be confined to plutonium. However, potential effects
of the daughter products will be discussed briefly in Section 5, and analyzed in Section 6.
Conceptual Transport Model
At this point, we have developed a conceptual model that describes our vision of the
environmental fate and transport of plutonium dispersed by the hypothetical accident. The jet-
fuel fire may disperse fine particulate plutonium downwind of the Pantex Plant. A prompt
decontamination on effort will reduce radiation levels to 0.2 uCi/m2, but surface runoff and wind
transport may concentrate contamination at playa lakes, where surface soil radiation levels may
be as high as 2.0 uCi/m2. Surface water infiltrating through this contaminated soil will tend to
carry contamination down towards the Ogallala Aquifer, with an average recharge rate of 3
cm/year. Recharge water will reach the Ogallala water table at a depth of 50 - 400 feet,
possibly after interacting with one or more perched aquifers on the way down. Sorption
interactions with both surficial materials and the unsaturated portion of the Ogallala Formation
will retard the movement of plutonium relative to the infiltrating water. During the transport
time, radioactive decay will constantly reduce plutonium concentrations. The purpose of the
quantitative analyses described in the next section is to estimate if and when plutonium will reach
the Ogallala water table, and if so, at what concentration.
- 10 -
4 - ANALYSIS OF GROUNDWATER IMPACTS
Starting with the conceptual transport model just described, we can estimate plutonium arrival
times and concentrations at the Ogallala water table. Two alternative calculation methods have
been used: a simple non-dispersive piston-flow model, and a more complex model based on the
one-dimensional advection-dispersion equation.
Piston Flow Results
Under the assumptions of piston flow, a "packet" of infiltrating water moves downward towards
the water table without interacting with water packets above or below. If we conservatively
assume that the entire plutonium surface loading infiltrates with a single year's recharge, we can
then envision a contaminated layer of 3 cm of water moving downward through the unsaturated
zone completely intact. This contamination layer will reach the water table as a single unit
during a single year at some time in the future, while the preceding and following year's
infiltration will be completely uncontaminated. Although this model is clearly unrealistic, it is
very simple conceptually and computationally, and provides a useful bounding case of transport
behavior.
With the piston-flow model, infiltrating water moves downward with a velocity vw:
I
vw = ---
O [theta]
where:
vw = Downward water velocity (cm/year)
I = Infiltration or recharge rate (cm/year)
O [theta] = Soil volumetric water content (cm3 water/cm3 soil)
Due to sorption effects, plutonium moves slower than water by a factor known as the retardation
factor, RPu:
vw
vPu = ----
RPu
where:
vPu = Downward plutonium velocity (cm/year)
RPu = Plutonium retardation factor
- 11 -
Assuming linear sorption and local equilibrium conditions, the retardation factor can be related
to the sorption distribution coefficient for plutonium on the materials in question:
pB KD
RPu = 1 + -----
O [theta]
where:
PB = Soil bulk density (g/mL)
RD = Sorption distribution coefficient (mL/g)
To calculate travel times and concentrations for plutonium, all of these quantities must be
measured or estimated. As described previously, KD has been measured directly using
laboratory batch studies on Pantex area geologic materials. Soil bulk density has not been
measured directly, but does not vary much under natural conditions, and has been estimated at
1.5 g/mL. Volumetric moisture content, on the other hand, can vary quite widely. Some
preliminary geophysical logs near Pantex suggest a mean subsurface moisture content of about
0.15, but also show high variability (Texas Bureau of Economic Geology, 1992).
Fortunately, it can be shown that for highly-sorbed species such as plutonium, the moisture
content does not significantly affect solute velocities. For a highly-sorbed species,
pB KD
RPu = ------- , when KD > 1
O [theta]
in which case
vw I/O [theta] I
VPu = ---- = ------- = -----
RPu pB KD/O pB KD
Using this last equation, we can calculate plutonium velocities directly, without estimating
moisture contents.
Using a recharge rate of 3 cm/year, a soil bulk density of 1.5 g/mL, and a conservative (low-
end) KD of 100 mL/g, we obtain a downward plutonium velocity of 0.02 cm/year. For water
table depths of 50, 200, and 400 feet (15.2, 61.0, 121.9 meters), plutonium travel times are
76,000 ,305,000, and 610,000 years, respectively. Based on the 24,400 year half-life of 239Pu,
the longest-lived component of the contaminant mix, during this period concentrations will
decrease to 11.5%, 0.02%, and 3.0 x 10E-8 of the initial concentration. Again, using our
conservative assumption that the entire 2.0 uCi/L plutonium loading is incorporated into one
- 12 -
year's 3-cm recharge, we can calculate that the initial plutonium concentration will be 6.7 x 10E4
pCi/L. By the time this material reaches the water table at depths of 50, 200, and 400 feet, the
concentration will have decreased to 7700 pCi/L, 13 pCi/L, and 2.0 x 10E-3 pCi/L, resectively.
Under the piston flow scenario, these concentrations are assumed to occur within a narrow layer
of the aquifer, sandwiched between uncontaminated water. The only significant route from the
aquifer to a receptor is via a water-supply well, which will likely be screened over a large
vertical interval. The contaminated groundwater will therefore be diluted within the well, before
it reaches any receptors. The degree of dilution can be estimated by comparing the thickness
of the contaminated layer to a typical screen length in a water supply well. Assuming a typical
aquifer porosity of 0.3, the 3 cm of contaminated water will form a layer 10 cm thick in the
aquifer. A high-capacity water-supply well will typically have at least 50 feet (15 m) of screen.
Mixing within the well will therefor dilute the recharge water by a factor of 150, decreasing
plutonium concentrations at the well head to 51 pCi/L, 0.09 pCi/L, and 1.0 x 10E-5 pCi/L for
the three different depth-to-water scenarios. Only the 50-foot scenario result exceeds any
recognized drinking water dose limits (Appendix B).
We have shown that even using the physically unrealistic and extremely conservative piston-flow
model for plutonium transport, plutonium concentrations in water delivered to potential receptors
will be well below dose limits over most of the study area. The only area at risk is shallow
groundwater regions south of Pantex, directly opposite predominant wind directions. In order
to further determine the extent of risk, we have we have conducted a more complex analysis, using the
advection-dispersion equation.
Advection-Dispersion Results
In the real world, packets of water do not travel intact through porous media for thousands of
years. Rather, mixing processes on various scales tend to mix and homogenize the water as it
travels. This effect is known as dispersion, and includes molecular diffusion, mixing within
single soil pores (hydrodynamic dispersion), and mixing processes induced by large-scale aquifer
property variations (macrodispersion). Transport with a dispersion component can be described
using a partial differential equation known as the advection-dispersion equation, and the
magnitude of dispersion is measured using an aquifer property known as dispersivity, with units
of length.
The advection-dispersion formulation is mathematically more complicated than the piston-flow
model, and computer codes are often used for solutions. One such code is CXTFIT (Parker and
van Genuchten, 1984). CXTFIT solves the one-dimensional advection-dispersion equation for
solutes that display linear sorption and first-order decay. CXTFIT simulations were performed
for the same plutonium transport scenarios described for the piston-flow model, using two
different dispersivities. A small dispersivity of 1 cm is typical of hydrodynamic dispersion
effects, such as might be observed in a column experiment using clean uniform sand. The larger
- 13 -
dispersivity of 1 m might result from macrodispersion effects observable during a field
experiment in actual aquifer materials.
The results of these simulations for a 50-foot and a 200-foot deep water table are shown in
Figure 4-1. These results show that even with the lower dispersivity and a shallow water table,
peek plutonium concentrations after 76,000 years are approximately 1.1 pCi/L, lower than the
strictest plutonium dose limits for drinking water. With the higher, more realistic dispersivity
value, peek concentrations arrive sooner, but are lower, roughly 0.2 pCi/L. Peak concentrations
at the deeper 200-foot water table are about three orders of a magnitude lower. 400-foot water
table simulations were not conducted, but peek plutonium concentrations would clearly be
several orders of magnitude lower still.
The advection-dispersion analysis shows that dispersion effects will reduce peek plutonium
concentrations below any drinking water dose limits, even for the low dispersivity / shallow
water table scenario. With a more realistic dispersivity value and a more typical deeper water
table, peek concentrations are decreased several orders of magnitude further.
- 14 -
Figure (Page 15 of Part L Figure 4-1. CXTFTT simulation results for plutonium transport to a 50-foot...)
5 - POTENTIAL COMPLICATIONS
The preceding sections focused on "well-behaved" solute transport processes. There are a
number of potential complicating factors that may affect plutonium transport to the Ogallala
Aquifer. These factors unfortunately tend to be difficult to quantify accurately, but in the
following paragraphs, some of these will be described, and their effects approximated.
Colloidal Transport
Colloids are extremely small (< 2um) solid particles that may be able to sorb contaminants and
carry them in moving water. Actinides can form several types of colloids in natural
groundwaters (Choppin, 1988; Kim, 1991). "Real colloids" can be formed as a result of the
aggregation of hydrolyzed actinide ions. "Pseudocolloids" can be formed by the sorption of
actinides onto natural colloids that exist in the groundwater. Triay et al. (1991a) have provided
evidence for the formation of real plutonium colloids at pH values of 1 and greater. Pseudo-
colloids can be formed by the attachment of plutonium or americium onto the colloids in the
Ogallala aquifer. Likely natural colloids have been identified by Wood and Petraitis (1984) and
Wood and Ostercamp (1987), who invoke clay colloids coated with organic material infiltrating
through the unsaturated zone in their hydrologic model of the playa lake basins.
The effects of colloids on the subsurface transport of contaminants has been reviewed by
McCarthy and Zachara (1989). Many researchers have invoked colloidal transport to explain
the observed movement of contaminants when it exceeds transport predictions. Penrose et al.
(1990) observed plutonium and americium mobility through a shallow aquifer in Los Alamos (a
semiarid region); they postulate that the observed transport (which exceeds predictions based on
laboratory data) is due to the irreversible sorption of plutonium and americium to colloidal
material.
The effect of colloidal filtration by a porous medium (McDowell-Boyer et al., 1986) is a likely
mechanism for retardation of colloids traveling through the Ogallala formation. However, this
filtration effect is difficult to quantify in the absence of a detailed characterization of the colloids
in the groundwater and a detailed hydrologic description of the transport pathway.
The most relevant paper relative to likely conditions in the study area after an accidental
dispersal of plutonium is the work of Goss et al. (1973). In this study Goss and co-workers
performed recharge experiments in Bushland, Texas, on the Southern High Plains just 50 km
west of the Pantex Plant. These investigators eluted radioactively-tagged clay colloids through
a recharge basin. The basin was constructed to maximize the potential for colloidal transport
by removing the slowly permeable surface of the Pullman clay loam and exposing the calcareous
underlying sediments, observed to have large pores (ranging from .1 to 1 mm). After
infiltration of the radioactively tagged clay colloids in 72.5 ft of water (equivalent to 730 years
of natural recharge, assuming 3 cm/year), 35% of the colloids were captured in the top six
inches, 50% in the top 18 inches, 75% in the top 4 feet, and there was no evidence of any
- 16 -
colloid transport below the top nine feet. In a second experiment, in which the large pores were
destroyed by cultivation, they found that after 52.2 ft of water infiltrated (530 years of natural
recharge), over 90% of the radioactively tagged colloids were retained in the upper 1 inch and
there was no evidence of colloid transport below the top 30 inches. Based on these results it is
not likely that colloid transport is a dominant transport mechanism for the migration of
contaminants to the Ogallala Aquifer.
Perched Aquifers
As mentioned previously, there is a known perched aquifer above the Ogallala Aquifer in the
immediate vicinity of the Pantex Plant (Purtymun and Becker, 1982; Texas Bureau of Economic
Geology, 1992). The lateral extent and continuity of this layer not known, and it was
completely neglected during the travel time and concentration analyses described previously.
This was a conservative decision, because it is clear that a perched water zone, if present, would
act as an impediment to downward transport for two reasons. First, the existence of perched
water indicates that there is a relatively impermeable perching layer present that is impeding
downward flow. Second, the perched water constitutes an additional reservoir of water within
the unsaturated zone, which implies increased travel times for a given recharge rate. Therefore,
a perched aquifer, if present beneath the hypothetical dispersal area, would actually decrease the
risk to Ogallala groundwater relative to that calculated here.
The shallow perched aquifer itself would be more vulnerable to contamination than the deeper
Ogallala aquifer, and in the event of a plutonium-dispersal accident, monitoring of perched-
aquifer water quality would be prudent.
"Short-Circuit" Recharge Paths
Under the conceptual model described earlier, primary protection of the aquifer is provided by
slow flow and transport through the unsaturated zone. It is possible that artificial recharge
conduits could bypass much of the unsaturated zone, thereby "short-circuiting" this protective
layer. Two major types of short-circuit paths are unintentional flow down along improperly-
constructed or abandoned water wells; and intentional flow to the Ogallala Aquifer as part of an
artificial recharge project.
Unintentional downward flow through water wells is unlikely to constitute a major problem,
because the high silt content of surface water in the area tends to quickly clog aquifer materials
encountered. In fact, this clogging effect stymied almost all early attempts at intentionally
recharging the Ogallala Aquifer with playa lake water (Urban et al., 1988). The risk of short-
circuiting along improperly-constructed or abandoned wells could be further minimized by
identification and grouting of these wells, possibly in conjunction with the post-dispersal
decontamination effort.
- 17 -
Recent advances in recharge techniques using geotextile filters have made artificial recharge of
the Ogallala Aquifer a real possibility, which will become ever more attractive as the water table
continues to fall (Urban et al., 1988). A successful artificial recharge project may conceivably
provide a means of moving plutonium down to the Ogallala Aquifer rapidly and in potentially
hazardous concentrations, although the same geotextile filter that traps silts may trap most
colloidal or polymeric plutonium. It is therefore imperative that in the event of an accident that
disperses plutonium into the environment, active groundwater recharge projects be monitored
and shut down if necessary.
The potential risks posed by these "short-circuit" recharge paths are purely local in scale, and
may be minimized by implementing the described measures in the event of the accident.
Preferential Flow
The term "preferential flow" encompasses different phenomena that all cause accelerated
transport -- solute velocities greater than that predicted using the simple infiltration rate /
moisture content relationship described earlier. Macropore flow is one obvious example, in
which water rapidly infiltrates via burrows, root casts, mud cracks, or other visible soil features.
Immobile water trapped in dead-end pores can also cause accelerated transport, as can
microporosity within individual soil grains. Gish and Shirmohammadi (1991) have edited a large
collection of papers describing recent research in this field.
The magnitude of accelerated transport observed in actual studies varies widely, from one
(Biggar and Nielsen, 1976; Van De Pol et al., 1977; Jury et al., 1982) to factors on the order
of 2 (Bowman and Rice, 1986a; 1986b; Turin, 1992). In one experiment, solutes moved
roughly 5 times the predicted rate (Rice et al., 1986). The degree of preferential flow seems
to depend primarily on soil type and infiltration patterns.
It is very difficult, if not impossible, to accurately determine the importance of preferential
effects on plutonium transport in the study area without conducting detailed field studies. To
get some idea of the sensitivity of the results of the advection-dispersion analysis to accelerated
transport, two additional CXTFIT simulations were formed for the 50-foot water table case,
using twice the calculated water velocity. Results are shown in Figure 5-1. As might be
expected, higher transport velocities result in faster plutonium arrival at the water table. Shorter
elapsed time before arrival means less radioactive decay, so peak concentrations are higher.
Even so, under these strongly conservative assumptions and a dispersivity of 1 cm, predicted
peek plutonium concentrations exceed only one of the three applicable drinking water dose limits
(Appendix B), and with a dispersivity of 1 m, no dose limits are exceeded. These results
indicate that even if preferential flow effects double predicted velocities, adverse impacts on the
Ogallala Aquifer are likely to be minimal.
- 18 -
Figure (Page 19 of Part L Figure 5-1. CXTFTT simulation results for plutonium transport to a 50-foot ...)
Figure 5-1. CXTFIT simulation results for plutonium transport to a 50-foot deep aquifer,
with accelerated transport due to preferential flow.
Multidimensional Flow
Both the piston-flow and advection-dispersion models assume one-dimensional downward flow
through the unsaturated zone. Approximately one-dimensional flow and transport would occur
if recharge was uniform across the surface of the High Planes, but as pointed out earlier,
recharge is focused at the playa lakes, and relatively unimportant elsewhere. Therefore, the
assumption of one-dimensional flow is not strictly valid. In this case, however, one-
dimensionality is a conservative assumption, and the true multidimensional nature of the flow
system will decrease the impact on the aquifer below that predicted here, for two major reasons.
Transverse (horizontal) dispersion in the unsaturated zone will cause increased dilution of the
contaminated recharge water, and horizontal spreading of the plume will increase travel time to
the water table, in turn allowing more radioactive decay en route.
- 19 -
Dropping Groundwater Levels
The groundwater impact analyses were performed assuming that 1990 water levels would persist
into the future. The present rate of water-table decline indicates that this is clearly not likely.
In fact, in much of the study area, the water table is dropping faster than the calculated
plutonium velocity, implying that the plutonium will never catch up and reach the water table.
Obviously, the present rate of water-table decline cannot persist for even a hundred years, and
certainly not for the tens of thousands of years discussed in this analysis, because the Ogallala
Aquifer would be pumped dry long before. Predicting actual future water levels in the Ogallala
is beyond the scope of this report, but it seems likely that as long as the Ogallala Aquifer
remains the primary water supply for future, residential, and industrial uses in the Texas
Panhandle, water levels are likely to continue to fall. In this case, using present-day water
levels is a conservative assumption, because at the hypothetical future date of the plutonium-
dispersal accident, and certainly by the time plutonium would have infiltrated down to the water
table, depths to water will have increased, affording additional protection to the aquifer.
Decay Products
As mentioned in Section 3, plutonium poses the primary risk in this hypothetical situation, and
was, therefore the only element considered in the preceding analyses. The conclusion that
minimal risk is posed by plutonium contamination suggests that none of the other potential
contaminants pose a significant risk. However, as a check of this assumption, the RESRAD
model, which incorporates decay-product transport, was used to calculate total doses caused by
the hypothetical accident. Results are presented and discussed in the following Section.
- 20 -
6 - DOSIMETRY AND RESRAD MODELING OF PLUTONIUM MIGRATION
A check of the results of the previous groundwater impact analyses was carried out using a
model developed for estimation of dose from residual radioactivity. The model, RESRAD, was
developed for determination of dose to man from all pathways of migration of radionuclides
(Gilbert et al., 1989). The model is recommended by DOE Order 5400.5 for determination of
doses and cleanup levels for residual radioactivity in the environment. RESRAD is a complex
model that allows the user to select site-specific parameters for estimation of dose. The result
is a more realistic estimation of the radiation dose, estimated as Committed Effective Dose
Equivalents (CEDE) that takes into consideration the specific climate and land use parameters
of the contaminated area.
For this project, several scenarios were developed to check on the potential for plutonium
migration to the water tables in the area of Pantex. These scenarios included three different
aquifer depths: 400 feet, 200 feet, and 50 feet.
The first RESRAD simulation determined the CEDE resulting from a soil contamination level
of 0.2 uCi/m2, using the default values of the model and standard conditions described for the
EPA's proposed standard for transuranic elements in soil. The output indicated a committed
dose equivalent of 10 mrem/year for the heavy dust loadings in air used by EPA, confirming
the behavior of the model. The doses in this scenario were dominated by resuspension of
plutonium attached to soil particles -- water pathways contributed an insignificant amount of
radiation dose from plutonium in the environment. Additional calculations using RESRAD for
conditions of a plume of plutonium contamination at the EPA screening limit dispersed over a
wide area results in the same conclusion, that the migration of plutonium to an aquifer is not a
significant source of radiation risk.
Tables 6-1 and 6-2 list the site-specific distribution coefficients (KD) and initial contaminant
isotopic composition used in the calculations. The isotopic mix used was weapons grade
plutonium (Table 3-2). 241Pu is the most abundant isotope, but emits beta particles. The
radioactive decay product 241Am is an alpha-emitter that appears wherever and whenever 241Pu
decays.
Table 6-3 lists the resulting breakthrough times for first arrival of contaminants at different depth
aquifers, and Table 6-4 lists estimated maximum dosages for the groundwater pathways. Each
scenario simulated has individual doses calculated for inhalation of air and dusts, consumption
of foods grown on the contaminated soils, meat and milk produced in the contaminated area, and
drinking water from an aquifer below the contaminated zone. Radioactive decay products are
included in the calculations. Estimation of the time and maximum dose rate is made by carrying
out dose calculations over 10,000 years. In all cases, the dose was dominated by inhalation of
resuspended plutonium followed by ingestion of plutonium attached to soil particles on
foodstuffs.
- 21 -
Table 6-1. Distribution coefficients used for RESRAD simulations.
Medium Element KD (mL/g)
------------------- ------- -----------
Contaminated Soil Pu 3000
Am 1000
Top meter of soil Pu 3000
Am 1000
Unsaturated zone Pu 100
Am 1000
Aquifer sands Pu 100
Am 1000
Table 6-2. Initial contaminant mixture used for RESRAD simulations.
Nuclide Activity (pCi/g)
------------------------------------------------------
238Pu 1.62
239Pu 10.7
240Pu 2.53
241Pu 83.6
242Pu 0.0004
241Am 0.121
The water dependent pathways did show one case of 0.001 mrem/year from migration of 237Np,
a decay product of 241Am, after 30 years for an aquifer 50 feet below the surface. 237Np is
conservatively assigned a KD of 0, indicating that the material moves with water with no
adsorption on the soils. The calculated dose for all other scenarios and times was zero. The
amount of transuranic elements was not sufficient to contaminate the water enough to produce
a radiation dose greater than 0.001 mrem/year for the large area of contamination at low levels.
RESRAD calculations resulted in zero dose for water pathways for all other depths to the water
table over a 10,000-year period.
The final case set up for calculations by RESRAD was that of a playa that received runoff
containing suspended sediments over time. In this case, the playa acts as an accumulation point
for radioactively contaminated sediments. This type of concentration was demonstrated within
- 22 -
Table 6-3. Contaminant breakthrough times predicted by RESRAD for various aquifer
depths.
Depth to Aquifer Breakthrough Time
----------------- -----------------
400 feet 190,000 years
200 feet 110,000 years
50 feet 56,000 years
Table 6-4. Maximum water pathway doses predicted by RESRAD for various aquifer
depths.
Depth to Aquifer Maximum Dose (mrem/yr)
----------------- ----------------------
400 feet 0.0
200 feet 0.0
50 feet 0.001
the Trinity Test fallout zone by Hansen and Rogers (1985), who measured accumulations of
radioactive fallout 137Cs in New Mexico playas that were 1.5 to 2 times the concentrations in
surrounding slopes after 32 years. For this calculation, the playa size and watershed area were
based on Playas 1 and 2 at the Pantex Plant. The aquifer was conservatively assumed to be
located at 50 feet below the surface. The inventory of plutonium and americium isotopes was
multiplied by 10 to reflect a conservative concentration of the residual radionuclides in playa
sediments. For this scenario, the maximum dose calculated was 0.01 mrem/year after 30 years,
from 241Am formation of 237Np. After 100 years the dose was zero. This conservative case
indicates that an insignificant radiation dose would be produced by the residuals resulting from
the hypothetical accident.
To summarize, in every RESRAD simulation, the doses estimated were zero or well below any
applicable standard for radioactive contamination of Aquifers or drinking water.
-23-
7 - References
Allen, B.L., B.L. Harris, K.R. Davis, and G.B. Miller, 1972. The Mineralogy and Chemistry
of High Plains Playa Lake Soils and Sediments. Texas Tech University Water Resources
Center, Lubbock, TX. Report WRC-72-4.
Ames, L.L. and D. Rai, 1978. Radionuclide Interactions with Soil and Rock Media. U.S.
Environmental Protection Agency Office of Radiation Programs Report EPA 520/6-78-
007, Vol. 1.
Aronovici, V.S. and A.D. Schneider, 1972. Deep Percolation through Pullman Soil in the
Southern High Plains, J. Soil Water Conserv., 27(2):70-73.
Ashworth, J.B., 1991. Water-Level Changes in the High Plains Aquifer of Texas, l980-1990.
Texas Water Development Board, Hydrologic Atlas No. 1.
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-25-
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1193-1208.
- 27 -
Appendix A
Laboratory Plutonium Sorption Study
239Pu-Solutions Preparation:
Three 239Pu oxidation states were studied: IV, V, and VI. Two waters were used for preparing
solutions: deionized water and water typical of the Ogallala aquifer (filtered through a 0.05 mm
polycarbonate filter). Solutions were prepared by adding an aliquot of a well-characterized
Pu(IV), Pu(V) or Pu(VI) acidic stock to deionized or Ogallala water. The concentration of all
plutonium solutions was 10E-7 M with the exception of the Pu(IV) solution in the Ogallala water
which was 10E-8. The reason for this difference is that Pu(IV) acidic stock was added to the
Ogallala water and most of the plutonium precipitated out (probably due to Pu(IV) polymer
formation). The resulting 10E-8 M plutonium solution was stable with no further loss of
plutonium after centrifugation for 4 hours at 12,000 rpm (28,000 g). Aliquots of all the
plutonium solutions were centrifuged for 4 hours at 12,000 rpm and the initial
plutonium concentrations never differed from the plutonium concentrations after centrifugation
by more than 6%.
Soil Samples:
Soils samples from the Ogallala Formation along Highway 136 (sample numbers 3A and 3B) and
the A Horizon of the Pullman soil (sample numbers 1A and 1B) were air-dried and sieved to
obtain particles in the size range from 75 - 500 um. For experiments involving the Ogallala
water, soil samples were preconditioned with the water by equilibrating the soil with the Ogallala
water (in the ratio of 1 g to 20 mL) for 24 hours. The phases were separated by centrifugation
for 1 hour at 12,000 rpm (28,000 g). The pre-conditioned soil was used for the sorption
experiments. The pH and Eh of the water after equilibration with the soil was measured.
Sorption Procedure:
The sorption procedure utilized in these studies consists of:
1) equilibrating a soil sample with an aliquot of a plutonium solution (in the ratio of 1 g to 20
mL) for 48 hours,
2) Separating the phases by serial centrifugations totaling 4 hours at 12,000 rpm (28,000 g).
3) measuring the pH and Eh of the water after sorption,
4) determining the amount of plutonium sorbed to the soil by liquid scintillation counting, and
- 28 -
5) calculating KD, defined as:
moles of plutonium sorbed to solid phase per g of soil
moles of plutonium in groundwater per mL of solution
Analytical Procedure for 239Pu Determination:
Liquid scintillation counting consists of counting the 239Pu solution three times for fifteen
minutes in a Packard Liquid Scintillation Counter with a window setting from 25 to 800 KeV.
The liquid scintillation samples consist of an aliquot of the plutonium solution and an aliquot of
make-up water totaling 6 mL, and 14 mL of Ultima Gold Liquid Scintillation Fluor. The
efficiency of the counter was determined by counting an aliquot of the 239Pu standard SRM-949F.
The counter was found to be 100% efficient.
Results
The results of the sorption experiments are given in Tables A-1 and A-2. The equilibration
among different oxidation states of plutonium in solution is slow; however only one optimal
plutonium speciation in each of the waters is expected once the plutonium solution attains
equilibrium. The water chemistry in these experiments is expected to be controlled by the type
of soil used. Consequently, sorption is fairly independent of initial plutonium oxidation state
and water used. The reason for the higher plutonium sorption distribution coefficients for the
Pullman soil is its high clay content. The Ogallala sand consist of quartz and feldspars which
have a lower affinity for plutonium than clay. The results for Pu(VI) in the Ogallala water are
different from all the other results due the change of pH during the experiment (from 8.2 to
7.4). Actinides are well known for having a sorption edge in the pH region from 7-8. The
reason for the change in pH in the case of Pu(VI) in the Ogallala water was probably an
experimental artifact; the pH of the Pu(Vi) solution in the Ogallala water was not adjusted
correctly after the aliquot of the Pu(VI) acidic stock was added to the water. The most
representative sorption results are those obtained with Pu(V) solutions since Pu(V) is the
expected plutonium oxidation state in this type of water. Consequently, even if the plutonium
solution did not attain equilibrium prior to use in the plutonium experiments, most of the
plutonium in the solutions should have been in the V oxidation state.
- 29 -
Table A-1. Plutonium sorption onto Pullman soil. Initial Ogallala water: pH 8.2, Eh 240
mV. After pre-conditioning: pH 7.7, Eh 220 mV.
KD (mL/g) 239Pu Solution after Sorption
--------- -------------------------------
Initial Plutonium Sample 1A Sample 1B pH Eh (mV)
Oxidation State
---------------------------------------------------------------------------
Deionized Water
-----------------
IV 4 x 10E3 3 x 10E3 8.1 190
V 3 x 10E3 4 x 10E3 8.3 200
VI 3 x 10E3 5 x 10E3 8.1 200
Ogallala Aquifer Water
------------------------
IV 2 x 10E3 2 x 10E3 7.9 240
V 3 x 10E3 4 x 10E3 8.0 230
VI 8 x 10E2 9 x 10E2 7.4 230
Table A-2. Plutonium sorption onto Ogallala sand. Initial Ogallala water: pH 8.2, Eh 240
mV. After pre-conditioning: pH 8.1, Eh 220 mV.
KD (mL/g) 239Pu Solution after Sorption
--------- -------------------------------
Initial Plutonium
Oxidation State Sample 3A Sample 3B pH Eh (mV)
--------------------------------------------------------------------------
Deionized Water
-----------------
IV 3 x 10E2 5 x 10E2 8.3 220
V 6 x 10E1 1 x 10E2 8.3 220
VI 7 x 10E2 8 x 10E2 8.3 220
Ogallala Aquifer Water
------------------------
IV 4 x 10E2 5 x 10E2 8.2 220
V 1 x 10E2 2 x 10E2 8.3 230
VI 3 x 10E2 4 x 10E2 7.6 240
- 30 -
APPENDIX B
Recommended Drinking Water Dose Limits for Plutonium Ingestion
A. DOE and EPA Drinking Water Dose Limits
The Committed Effective Dose Equivalent (CEDE) is the sum of the dose equivalents
from 239Pu alpha radiation deposited internally to various tissues in the body, each multiplied by
the appropriate ICRP 26 weighting factor. The CEDE is expressed in units of mrem.
In DOE Order 5400.5-II.1a the public dose limit is defined as "the exposure of
members of the public to radiation sources as a consequence of all routine DOE activities shall
not cause, in a year, a effective dose equivalent greater than 100 mrem." Derived Concentra-
tion Guides (DCGs) are given in 5400.5 for ingestion of two liters of water a day based on a
CEDE of 100 mrem for Plutonium taken into the body for one year. Plutonium is poorly
absorbed from the gut ad chemical forms influence the absorption. DOE gives a f1, the
fraction absorbed from the gut into the body, of .00001 for plutonium oxides and hydroxides,
.0001 for plutonium nitrates, and .001 for all other chemical forms of plutonium in the
environment. The DOE DCGs are 2000 pCi/L for oxides and hydroxides and 30 pCi/L for
"other" chemical forms of plutonium. To be conservative we will choose f1 of .001 since we
do not know the long term chemical form of plutonium in this ecosystem even though the initial
form is probably an oxide. Once we assume f1 then the 239Pu Dose Conversion Factor (DCF),
in mrem CEDE/pCi ingested, can be derived based on the ICRP 26 weighting factors,
metabolism, and disposition patterns in the body after absorption from the gut. DOE/CH-8901
gives a DCF of .0043 mrem/pCi for an f1 of .001. This gives the DOE DCG:
x pCi/L = (y/365d)(d/2L)(1/DCF)(100 mrem/yr Public Limit)
= (1/365)(1/2)(1/.0043)(100)
= 30 pCi/L in drinking water
DOE 5400.5-I3 also states " a higher dose limit, not to exceed the 500 mrem effective
dose equivalent recommended by ICRP as an occasional annual limit, may be authorized for a
limited period if it is justified by unusual operating conditions." Therefore, under "unusual"
conditions a 239Pu drinking water limit of 150 pCi/L could be acceptable and approved by DOE.
The Safe Drinking Water Act regulated by EPA under 40CFR141, National Interim
Primary Drinking Water Regulations, prescribes radionuclide concentration limits for public
drinking water systems. The limits in public water systems (PWS) for 226Ra and 228Ra are
explicitly given in 40CFR141.15 as "(a) Combined radium-226 and radium-228: 5pCi/L." Back
calculation of this limit to mrem CEDE/y gives:
mrem CEDE/y = (2L/d)(365d/y)[(2.5pCi (226Ra)/L)(.0011mrem/pCi) +
(2.5pCi (228Ra)/L)(.0012mrem/pCi)]
= 4.2 mrem CEDE/y
- 31 -
The EPA regulations further state in 40CFR141.26-ali that "a gross alpha particle
activity measurement may be substituted for the required radium-226 and radium-228 analysis
provided that the measured gross alpha particle activity does not exceed 5 pCi/L at a confidence
level of 95 percent." The regulations also develop other limits for beta and gamma emitting
nuclides based on the 4mrem CEDE/y.
DOE Order 5400.5-II.1d adopts the SDWA regulations by stating "It is the policy of
DOE to provide a level of protection for persons consuming water from a public drinking water
supply operated by the DOE, either directly or through a DOE contractor, that is equivalent to
that provided to the public by the public community drinking water standards of 40 CFR Part
141. These systems shall not cause persons consuming the water to receive an effective dose
equivalent greater than 4 mrem in a year. The dose limit is the effective dose equivalent to
individuals whose exclusive source of drinking water contains a radionuclide, or a mixture of
radionuclides, at a monthly average level of four percent of the appropriate DCG value." This
239Pu limit for PWS can be derived as follows:
x pCi (239Pu)/L = (y/365)(d/2L)(1/.0043)(4mrem/y)
= 1.3 pCi (239Pu)/L of drinking water
B. Recommendations for Limiting Doses
Three dose limits are recommended for plutonium ingested exclusively from the drinking
water pathway, one at 1.3 pC/L for PWS using 4 mrem CEDE/yr, the second at 3O pCi/L for
the "worst case plausible scenario for the family farm scenario addressed in DOE/CH-8901
based on 100 mrem CEDE/yr, and a third at 150 pCi/L based on 500 mrem CEDE/yr "unusual
circumstances" explained in 5400.5 IV .3b. We recommend usage of all three limits for this
exercise because the remediation and subsequent residual contamination of areas in the square
kilometer range will have public water systems, private farms with their own wells, and hot spot
unusual circumstances requiring application of the three limits based on risk, cost/benefit
optimization, and the site specific scenario.
C. References
DOE Order 5400.5. "Radiation Protection of the Public and the Environment", Effective
May 1990.
EPA Title 40 CFR 141. "National Interim Primary Drinking Water Regulations", (Safe
Drinking Water Act, Amended 1988).
Gilbert et al., June 1989. "A Manual for Implementing Residual Radioactive Material
Guidelines", DOE/CH-8901, Argonne National Laboratory.
ICRP, 1977. Recommendations of the International Commission on Radiological
Protection. ICRP Publication 26. Pergamon Press, Oxford.
- 32 -

Section III Response to Comments on the Revised Pre-Approval Environmental Assessment and Public Meeting

SECTION III
Response to Comments Received on the Revised Pre-Approval Environmental
Assessment at the December 6, 1993 Public Meeting in Amarillo, Texas and
during the Follow-on Two Week Comment Period from December 6 to 20, 1993
Introduction
On November 11, 1993, the Department issued a revised pre-approval Environmental
Assessment.  On December 6, 1993, the Department held a public meeting in
Amarillo, Texas so that members of the public and the State could discuss the revised
pre-approval Environmental Assessment and the Department's resolution of the
comments provided through the State of Texas.  Furthermore, the Department
accepted written comments for a two-week period (December 6 to 20, 1993) after the
public meeting.  During this period, the Department received 14 comment letters which
both supported and questioned the Department's proposed action.   The majority of
the comments submitted to the Department during this period were addressed in the
public meeting and, in some cases, resulted in revisions to the Environmental
Assessment. The transcripts have been placed in Department of Energy Public
Reading Rooms in Amarillo and Panhandle, Texas and have been sent to individuals
and organizations commenting on the Environmental Assessment.  Additional copies
of the transcripts are available from:
                Mr. Thomas Walton, Public Affairs Officer
                U.S. Department of Energy
                Amarillo Area Office
                P.O. Box 30030
                Amarillo, Texas  79120
                (806) 477-3120.
Response to Comments and Questions
Table 1 responds to written comments received during the two week comment period
that question the Department's proposed action.
TABLE 1 - RESPONSES TO COMMENTS QUESTIONING THE PROPOSED ACTION 
COMMENT                                                            DISPOSITION OF COMMENT 
Source of      Comment                                             DOE Response                                Reference 
Comment
O'Brien,       Your pre-decisional finding fails to properly       The Department accepts that fact            December 6, 1993 
12/6/93 Letter address...                                          that recharge is focused at the Playa       Public Meeting 
                                                                   Lakes on the High Plains.  In the           Transcript, Pages 
               1) "The wide gulf between the University of         original Los Alamos National                125 to 126 
                  Texas Department of Economic Geology's           Laboratory report, this fact is taken 
                  work on water mobility and recharge rates        into account by assuming that the 
                  from the playa lakes to the underground          recharge rate at the lakes are ten 
                  aquifers and Los Alamo's characterization of     times the average.  The Department 
                  these findings as "unreasonable and              does not dispute these findings - the 
                  unrealistic"."                                   recharge rates used in the Los 
                                                                   Alamos report were an estimate.  In 
                                                                   the response to comments provided 
                                                                   by the Texas Bureau of Economic 
                                                                   Geology, Los Alamos reanalyzed the 
                                                                   transport scenarios based on the 
                                                                   Texas Bureau of Economic Geology 
                                                                   recharge rates and came to the 
                                                                   same conclusion that the interim 
                                                                   storage does not pose a significant 
                                                                   threat to the Ogallala Aquifer. 
               2) "The failure to devote any detailed analysis to  Terrorist attacks have been                  
                  the possibility of terrorist attack."            addressed in the security plans and 
                                                                   procedures for the Pantex Plant 
                                                                   through such documents as the 
                                                                   Master Safeguards and Security 
                                                                   Agreement, which outlines the 
                                                                   threats to the site and the risks of 
                                                                   those threats.  Security plans and 
                                                                   procedures have been implemented 
                                                                   to address those threats and these 
                                                                   plans are evaluated and checked 
                                                                   yearly through reviews and 
                                                                   exercises. 
               3) "The adequacy of the World War II bunkers        The structural adequacy of bunkers           
                  for storage."                                    is addressed in the Safety Analysis 
                                                                   Report and appendices of the 
                                                                   Environmental Assessment.  
                                                                   Safeguards and security and material 
                                                                   accountability aspects of storing pits 
                                                                   is the same as that of storing 
                                                                   weapons already being performed in 
                                                                   Zone 4 and is addressed in security 
                                                                   plans and procedures of the Plant.  
                                                                   Storage will be carried out in a 
                                                                   manner that the Department believes 
                                                                   can be compatible with verification, 
                                                                   although international agreements 
                                                                   are not presently in place. 
O'Brien,       4) "The consideration of alternative sites for      Alternative sites were considered           Environmental 
12/6/93 Letter    storage, either interim or long-term."           and these analyses were                     Assessment, Pages 
(Cont'd)                                                           documented in the Environmental             4-1 to 4-11. 
                                                                   Assessment. 
Osborne        1) The Aircraft Hazards Analysis was                The Analysis does not focus on light        Environmental 
Comments       unrealistic.                                        aircraft, but uses physical arguments       Assessment, 
                                                                   relative to the ability of this class of    Appendix F, Page F-
Paragraph 3                                                        aircraft to penetrate the magazines         20 
                                                                   to drop this from further 
                                                                   consideration.  All other categories 
                                                                   (i.e., commercial, military, heavier 
                                                                   general aviation) are still considered 
                                                                   as potential threats to the 
                                                                   magazines.  Analysis of the potential 
                                                                   consequences of crashes of these 
                                                                   aircraft is dropped subsequently on 
                                                                   probabilistic grounds. 
Paragraph 4    2) Since aircraft are landing and taking off, the   Inflight is defined as greater than five    December 6, 1993 
                  in flight statistics used are inappropriate.     miles from an airport.  Inflight            Public Meeting 
                                                                   statistics are appropriate for aerial       Transcript, Pages 45 
                                                                   crash analysis regarding the Pantex         to 47, Environmental 
                                                                   Plant (8.5 miles from the Amarillo          Assessment, 
                                                                   International Airport).                     Appendix, Page F-20 
Paragraph 5    3) Military combat and training aircraft utilizing  The Amarillo Federal Aviation               December 6, 1993 
                  Amarillo International Airport are not normally  Administration does not consider            Public Meeting 
                  destined to terminate the flight in Amarillo.    multiple "touch and go" by a single         Transcript, Pages 61 
                                                                   aircraft as one activity, but logs each     to 65 
                                                                   as a landing or take off. 
                                                                   This paragraph also includes the             
                                                                   implicit assertion that all military 
                                                                   combat and training aircraft utilizing 
                                                                   Amarillo International Airport overfly 
                                                                   Pantex; Federal Aviation 
                                                                   Administration records and 
                                                                   statements indicate that they do not. 
               4) The Aircraft Hazards Analysis bases the          Aircraft crash data have been               Environmental 
                  accident rate for military aircraft on data for a verified for the timeframe from 1976        Assessment, Section 
                  period from 1976 through early 1992, missing     to early 1992 in Section III of the         III, pages 13-15. 
                  a number of major military accidents.            Environmental Assessment. 
Osborne                                                                                                         
Comments                                                                                                        
(Cont'd)                                                                                                        
               5) In assessing the hazard potential by aircraft    Use of the 15 degree impact angle is        Environmental 
Paragraph 6       coming down within the boundaries of the         conservative in terms of estimating         Assessment, 
                  Pantex Plant, the impact angle was assumed       the impact probabilities.  The Aircraft     Appendix F, Pages 
                  to be 15 degrees, marginally consistent with     Crash Analysis does not limit               F-22, F-32, and F-33 
                  a forced landing under controlled flight.        impacts to that angle. 
Paragraph 7    6) Aircraft descending from an altitude of 2,300    High impact angles are not excluded         December 6, 1993 
                  feet will likely impact at an angle much higher  from the Analysis.                          Public Meeting 
                  than the 15 degrees used in the                                                              Transcript, Pages 45 
                  Environmental Assessment.                                                                    to 46; Environmental 
                                                                                                               Assessment, 
                                                                                                               Appendix F, Pages 
                                                                                                               F-28 and F-34 
Paragraph 8    7) A comment was made regarding a                   Cited reference to Appendix F has           Environmental 
                  typographical error in Appendix F regarding      no relation to Aircraft Crash Analysis.     Assessment, 
                  impact energy.                                   Appendix C has the cited mistake in         Appendix C 
                                                                   the impact energy value.  This was 
                                                                   corrected in the Environmental 
                                                                   Assessment. 
Osborne                                                                                                         
Comments                                                                                                        
(Cont'd)                                                                                                        
               8) What is the possibility for penetration of       The consequences from objects                
Paragraph 9       storage facilities by objects separating from    separating from aircraft overflying the 
                  aircraft overflying the plant?  A 7,900 pound    Plant would be bounded by the 
                  engine falling from a C-5 at 2,300 feet would    analyses conducted for aircraft 
                  certainly be capable of significant damage to    accidents.  A summary of the release 
                  a storage facility.                              probability associated with the 
                                                                   bounding crash scenario follows:  1) 
                                                                   the conservative probability of any 
                                                                   aircraft or its components impacting 
                                                                   any magazine in Zone 4 West is 
                                                                   approximately one in a million per 
                                                                   year; 2) a conservative range of 
                                                                   probabilities of any aircraft or its 
                                                                   components penetrating or collapsing 
                                                                   a magazine after impact is 0.001 to 
                                                                   0.5; 3) a conservative range 
                                                                   probabilities for damaging magazine 
                                                                   contents after penetrating or 
                                                                   collapsing a magazine is 0.01 to 0.5; 
                                                                   and 4) the reasonable range of 
                                                                   probabilities for generating an energy 
                                                                   source capable of dispersing 
                                                                   radioactive material from damaged 
                                                                   containers is 0.01 to 0.5.  (NOTE:  
                                                                   With regard to either an engine or a 
                                                                   landing gear, no energy source 
Paragraph 10   9) The long runway at Amarillo International        While Amarillo International Airport         
                  Airport makes it a very attractive destination   may be an alternative choice for 
                  for an aircraft in distress.                     landings, not all such aircraft would 
                                                                   overfly Pantex. 
Osborne                                                                                                         
Comments                                                                                                        
(Cont'd)                                                                                                        
               10)                                                 The Department of Energy defines            Environmental 
Paragraph 11    A reconciliation of the terms "likely" "unlikely"  "likely" as greater than 1 x 10-2,          Assessment, Table 
                and "extremely unlikely" would be helpful.         "unlikely" as between 1 x 10-2 and 1        6-4B. 
                                                                   x 10-4, and "extremely unlikely" as 
                                                                   between 1 x 10-4 and 1 x 10-6. 
Gustavson,                                                                                                      
12/20/93                                                                                                        
Letter                                                                                                          
               1) Provide references as to who are the soil        Conclusions about plutonium                 December 6, 1993 
Paragraph 2       scientists who agree that plutonium is           immobility are based on Los Alamos          Public Meeting 
                  relatively immobile.                             National Laboratory experience in           Transcript, Pages 
                                                                   this area that ranges over 25 years.        117 to 119 
                                                                   Results of studies on Yucca 
                                                                   Mountain, the Trinity site, and the 
                                                                   Los Alamos site suggest that 
                                                                   plutonium is quite immobile in the 
                                                                   subsurface.  A list of references 
                                                                   regarding actinide sorption and 
                                                                   solubility is provided in Section 9.0 of 
                                                                   the Environmental Assessment. 
               2) "Where were their studies completed and          The studies conducted of the Trinity        December 6, 1993 
                  were these soils comparable to High Plains       site examined an area approximately         Public Meeting 
                  soils in mineralogy and texture?"                70 miles northeast of the site              Transcript, Page 121 
                                                                   including the High Plains of New 
                                                                   Mexico, which has soil types that are 
                                                                   similar to the Amarillo area. 
               3) "What are remediable depths?"                    Data from the Trinity site suggests         December 6, 1993 
                                                                   that plutonium remains within a few         Public Meeting 
                                                                   inches of the surface after dozens of       Transcript, Pages 
                                                                   years.                                      122 to 123 
               4) "What steps has DOE initiated to identify and    The Amarillo Area Office has been           December 6, 1993 
                  document preferential pathways that may          asked to look at the feasibility of         Public Meeting 
                  exist in postulated area of contamination?"      identifying all these pathways.  That       Transcript, Pages 
                                                                   effort is underway right now with           123 to 124 
                                                                   assistance from the Army Corps of 
                                                                   Engineers. The next step will be to 
                                                                   determine how best to eliminate the 
                                                                   pathways or deal with them in the 
                                                                   event of an actual release. 
Gustavson,                                                                                                      
12/20/93                                                                                                        
Letter (Cont'd)                                                                                                 
               5) "The values used by Los Alamos National          The Department accepts the fact that        December 6, 1993 
Paragraph 3       Laboratory for recharge rates are largely from   recharge is focused at the playa            Public Meeting 
                  earlier studies.  Many of these studies did not  lakes on the High Plains.                   Transcript, Pages 
                  recognize focused recharge through playas.                                                   125 to 126 
                  A rate of only 3 cm/yr is unreasonable." 
Paragraph 4    6) "Were the studies used by Los Alamos             References regarding preferential           December 6, 1993 
                  completed in areas closely comparable to the     flow are provided in Section 9.0 of         Public Meeting 
                  High Plains in terms of soil and sediment        the Environmental Assessment.               Transcript, Pages 
                  structure mineralogy and texture?"               There are a limited amount of               127 to 128 
                                                                   studies available on preferential flow.  
                                                                   The references used in the Los 
                                                                   Alamos study focused on preferential 
                                                                   flow in agricultural areas. 
Paragraph 5    7) "What are the anticipated contamination          30 microcuries in a contaminated            December 6, 1993 
                  levels prior to cleanup?"                        area under 2 square kilometers.             Public Meeting 
                                                                                                               Transcript, Page 130 
               8) "...if prior cleanups have been successful,      The cleanup technologies used in            December 6, 1993 
                  could this technology be applied to the          the past are nothing very                   Public Meeting 
                  Pantex area?"                                    sophisticated.  They basically have         Transcript, Page 132 
                                                                   involved the removal and disposal of 
                                                                   contaminated soil and this is the type 
                                                                   of response that would likely be 
                                                                   employed in the Pantex area. The 
                                                                   high plains has got an advantage in 
                                                                   terms of cleanup; it doesn't have 
                                                                   trees and shrubs, which can 
                                                                   complicate cleanup. 
               9) Where would soil for removal be stored.          In the most likely scenario which           December 6, 1993 
                  "How would it be removed.  What will happen      requires removal of contaminated            Public Meeting 
                  to livestock, farm buildings?"                   soil, the soil would be packed at           Transcript, Pages 
                                                                   Pantex in accordance with                   133 to 134 
                                                                   acceptance criteria and shipped to           
                                                                   the Nevada Test Site for burial.             
                                                                   The most probable method to clean           December 6, 1993 
                                                                   contaminated livestock and buildings        Public Meeting 
                                                                   would be to use high pressure water         Transcript, Pages 
                                                                   to remove the contamination.                155 to 156 
Gustavson,                                                                                                      
12/20/93                                                                                                        
Letter (Cont'd)                                                                                                 
               10)                                                 The Los Alamos National Laboratory          Comment Response 
Paragraph 7     The Nativ report was available when the            did not have access to Nativ (1988)         Document, Page E-6 
                Turin Report was being prepared.                   while preparing Turin et al. (1992), 
                                                                   and, therefore, did not cite it.  
                                                                   However, the critical information from 
                                                                   the report was evaluated with no 
                                                                   significant impact noted. 
Hutchison,     1) Not clear that shielded forklift will be         An electric forklift with shielding for     Environmental 
12/20/93       available.                                          radiation protection is available.          Assessment, Page 3-
Letter                                                                                                         2 
               2) Can forklifts be designed to be entirely         No, but the shielded forklift operator      Environmental 
               remote control?                                     will be inside the magazine during          Assessment, Page 3-
                                                                   operation.                                  2  
               3) Not clear how repairs would be made on the       The shielded forklift is not attached        
               forklift.                                           to the "tracking system." If the forklift 
                                                                   breaks down while in the magazine, 
                                                                   it will be withdrawn by pulling it from 
                                                                   the magazine; the forklift is equipped 
                                                                   with a hitch to accommodate this 
                                                                   operation if required.  In addition, the 
                                                                   forklift is also equipped with an 
                                                                   escape door that affords the operator 
                                                                   a means of egress should the 
                                                                   situation arise. 
               4) How would it be removed from the tracking        Same response as above.                      
                  systems or withdrawn from the building? 
               5) What would the estimated worker exposure         Shielding on the forklift should            Environmental 
                  be during such an operation?                     provide a dose reduction factor of at       Assessment, Page 3-
                                                                   least 20 over current inventory             2 
                                                                   methods.  No more than 3 minutes 
                                                                   would be required for either the exit 
                                                                   of the forklift operator through the 
                                                                   escape door or for another worker to 
                                                                   hitch a line to the forklift.  This being 
                                                                   the case, any increased exposure 
                                                                   would be minimal. 
Hutchison,     6) The statement that this proposed action          The Department is not planning on           Finding of No 
12/20/93          would not involve long-term or permanent         moving pits from other sites to             Significant Impact, 
Letter (Cont'd)   storage is incredible...  DOE is already         Pantex.  The Department has                 Pages 1-3. 
                  planning to move pits from other "interim"       increased interim storage of pits at 
                  storage at Rocky Flats to Pantex.                Pantex up to 12,000 until other 
                                                                   decisions, expected to be made in 
                                                                   the next three years from the date of 
                                                                   the Finding of No Significant Impact, 
                                                                   determine longer-term storage 
                                                                   alternatives. 
               7) Any serious suggestions that this decision       Interim storage is defined as storage       Finding of No 
                  does not support long-term storage at Pantex     until a long-term storage facility is       Significant Impact, 
                  must outline the length and the capacities       identified and operational.                 Pages1-3. 
                  that this Environmental Assessment will          Essentially, this suggestion has been 
                  cover.  This should be accompanied by a          adopted.  The Finding of No 
                  schedule of future decisions about storage       Significant Impact covers interim 
                  and a full description of the process by which   storage for 12,000 pits until decisions 
                  such decisions should be made.                   can be made on the longer-term 
                                                                   future storage / disposition of this 
                                                                   material.  These decisions will be 
                                                                   made following National 
                                                                   Environmental Policy Act reviews 
                                                                   and include decisions resulting from:  
                                                                   1) New site-wide Environmental 
                                                                   Impact Statement for Pantex Plant 
                                                                   expected to be completed in 
                                                                   November 1996.  This Environmental 
                                                                   Impact Statement, while not yet 
                                                                   scoped, is expected to address: 
                                                                   continued operation of the Plant, 
                                                                   mitigation of the impacts of 
                                                                   operations, and storage of material; 
                                                                   2) Reconfiguration Programmatic 
                                                                   Environmental Impact Statement 
                                                                   expected to be completed in 1995.  
                                                                   Among other complex features, this 
                                                                   Programmatic Environmental Impact 
                                                                   Statement addresses long-term 
                                                                   storage of these materials; and 3) 
Hutchison,     8) In Paragraph 4.0., DOE introduces a              Protection of the environment and            
12/20/93          discussion of the alternatives of the proposed   workers and public safety and health 
Letter (Cont'd)   action.  It is appalling that protection of the  are the basis for the Environmental 
                  environment and worker and public safety         Assessment process. 
                  and health are not included in this 
                  introduction and programmatic goal. 
               9) The Environmental Assessment must provide        Based on the Environmental                  Finding of No 
                  a more comprehensive and honest evaluation       Assessment and in accordance with           Significant Impact, 
                  of alternatives.  The question is not simply     the National Environmental Policy           Pages 1-3 
                  whether or not environmental benefit can be      Act, the Department believes that the 
                  derived but whether adverse environmental        proposed action (interim storage of 
                  impacts can be avoided.  The Environmental       up to 20,000 pits) does not 
                  Assessment does not address this.                significantly affect the quality of the 
                                                                   human environment. 
               10)                                                 If a Department of Defense facility         Environmental 
                Page 4-6, Footnote 11.  Footnote is                were selected, time delays would            Assessment, Section 
                insufficient to explain whether DOE/DOD            occur and disassembly would need            4.4 
                missions incompatibilities truly make storage      to be curtailed because appropriate 
                impossible at active conventional weapons          infrastructure in the way of security, 
                facilities.                                        material accountability, and 
                                                                   management would need to be put in 
                                                                   place. 
               11)                                                 It is likely that the Type B containers      
                Page 4-8, Footnote 13.  Not clear from the         will eventually be purchased for all 
                footnote if Type B shipping containers will be     pits placed in storage. 
                purchased anyway. 
               12)                                                 The "Introduction and Background"           Environmental 
                Page 4-9, Table 4-1.  Clarify whether the          section of the Environmental                Assessment, Page 1-
                "President's dismantlement objectives" and         Assessment makes this relationship          1 
                "President's weapons reduction initiatives"        clear.  They are the same. 
                are the same or different. 
               13)                                                 This was an assumption used to               
                Page 6-2, Table 6-1.  The phrase "100%             make a conservative calculation of 
                corrosion inspection is incorrect because          radiological exposure. 
                DOE does not intend to inspect 100 percent 
                of the containers for corrosion, but rather do 
                a random spot check. 
               14)                                                 After review of the comment, the             
                Environmental Assessment, Page 6-2, 6-3:           Department has decided that no 
                the word "natural" must be struck in both          change is needed. 
                instances where it refers to "incidents of fatal 
                cancer". 
Hutchison,     15)                                                 Worker radiation dose would be              Environmental 
12/20/93        Environmental Assessment, Page 6-2:  the           maintained below the established            Assessment, Page 6-
Letter (Cont'd) stock paragraph containing the statement           Pantex annual administration                2 
                "we're operating within guidelines" does not       operating unit (1 rem per year). 
                actually indicate clearly what the exposure 
                risk to a worker would be. 
               16)                                                 This is accepted practice.                   
                Page 6-4:  when DOE invokes the "one in 
                one million" acceptability ceiling DOE should 
                note that this ceiling has been arbitrarily 
                determined by agencies responsible for 
                public health and safety and has not been 
                subjected to public consent. 
               17)                                                 After consideration of the comment,         Environmental 
                DOE suggests that because the potential for        the Department believes that the            Assessment, 
                a large plane crash into a pit storage igloo is    Aircraft Crash Analysis should              Appendix E 
                calculated to be less than one in one million,     remain without change. 
                such a possible crash can be discounted. 
               18)                                                 In the scenario, the plutonium which        Environmental 
                Page 6-5:  the second paragraph under the          finally escapes is given a very             Assessment, 
                heading 6.2.4 Forklift Operational Accidents       conservative assumed dispersion.            Appendix D, Page D-
                makes an assumption that in the case of a                                                      1 
                puncture of a container plutonium would be 
                uniformly dispersed. 
               19)                                                 It does not need to be because no            
                Page 6-5:  in a container puncture accident,       more than 3 minutes would be 
                a worker would risk serious exposure.  The         required for either the exit of the 
                Environmental Assessment does not make             forklift operator through the escape 
                clear if the forklift operation shielded cab is    door or for another worker to hitch a 
                air tight.                                         line to the forklift.  This being the 
                                                                   case, any increased exposure would 
                                                                   be minimal. 
               20)                                                 In the scenario, a worker would             Environmental 
                The statement that a worker would receive          receive 0.02 microcuries; a worker in       Assessment, Page 6-
                "no immediate or long-term health effect as        the immediate vicinity of the site          5. 
                result of an accident of this type" is not         could receive a marginal radiation 
                supported by health studies to date.               dose.  No significant health effects 
                                                                   would be expected. (See National 
                                                                   Council on Radiation Protection 1993 
                                                                   Report.) 
               21)                                                 The approach taken in the Aircraft          Environmental 
                Page 6-6:  DOE's discounting of a potential        Crash Analysis is conservative.             Assessment, Page 
                aircraft crash is not acceptable.                                                              6.6
Although most questions that were asked in the public meeting were answered at that
time, a few were not.  The following is a summary of comments that were unanswered
during that public meeting and the Department's response:
Comment:  Although the Department of Energy found that an aircraft crash was
not credible, the Department should continue planning for emergency
management scenarios.
Response:  The Department of Energy Emergency Preparedness Plan (EPP-1000)
addresses possible emergency scenarios.  Furthermore, the Department has
committed to review that plan and to ensure it adequately addresses the
consequences of an aircraft crash.
Comment:  Review a memoranda written by Chris Kimura, Lawrence Livermore
National Laboratory, dated April 9, 1993, and determine if a discrepancy exists
regarding the number of aircraft destroyed in flight.
Response:  The Kimura memoranda observes that the number of aircraft shown in the
Environmental Assessment (Appendix E, Table E-7, Summary of Military Aircraft
Crash Rates) as "destroyed in flight" for the C-5 and B-1B is incorrect.  Specifically,
Kimura's information shows five C-5 and seven B-1B occurrences where aircraft were
destroyed.  It was inferred that this information was not properly considered in the
Department's analysis.
It appears that Kimura used Department of Defense Class A designated aircraft
damage statistics for the observations made in the memorandum.  Class A damage
consists of a fatality or a total cost criteria, including "uneconomical to repair". Class A
damage must be distinguished from aircraft "destroyed in flight".  The data used in the
Aircraft Crash Analysis (Appendix E, Reference 9) specifically identifies aircraft
"destroyed in flight", where "in flight" is defined as greater than five miles from an
airport.  Accidents that occur on the runway, during takeoff, landing or low level
training exercises are clearly not applicable.
Four of the C-5 occurrences cited in the Kimura memoranda do not fall within the
timeframe (1976 through early 1992) of the Aircraft Crash Analysis data.  The
remaining C-5 occurrence did not meet the "destroyed in flight" criteria.  Of the B-1B
occurrences, one was outside of the timeframe of the Aircraft Crash Analysis data and
the remaining six did not meet the "destroyed in flight" criteria.
Accident data pertinent to those identified in the Kimura memoranda are summarized
in Table 2, along with additional data for accidents not reported by Kimura that were
Class A accidents.  These data are obtainable from various sources, including
newspaper reports of the accidents.  The dates of each accident are included in
Table 2.
Based upon a comprehensive review, the Department concludes that the data
reported in the Environmental Assessment are correct and no changes need to be
made.  Differences in Kimura's data and the data used in the Environmental
Assessment are due to one or more of the following reasons:  1) not applicable to the
timeframe of the data base; 2) not an in flight accident; or 3) not an aircraft crash. 
The Department identified and included all of the aircraft crashes that Kimura had
identified over the timeframe used for the Aircraft Crash Analysis data.
Mr. Kimura also suggests that F-16 and F-18 aircraft operations should have been
considered in the Aircraft Crash Analysis.  These aircraft were not observed in the
Pantex area during the timeframe when actual aircraft counts were made.  The goal of
this aircraft accident analysis was to obtain a realistic overall average estimate of
accident rates for military aircraft which would then be used with the overall estimate
of actual flights.
In summary, the Department concludes that the accidents identified by Kimura and
consideration of Class A do not cause the military aircraft crash rate determined in the
Aircraft Crash Analysis to change.  Therefore, the analysis performed for the
Environmental Assessment (Appendix E, Reference 9) remains applicable.
TABLE 2 - AIRCRAFT ACCIDENT DATA 
AIRCRAFT  ACCIDENT ACCIDENT DESCRIPTION AND COMMENTS                                        PHASE OF               APPLICABLE 
TYPE      T DATE                                                                            OPERATION              TO PANTEX 
                                                                                                                   ENVIRONMENT 
                                                                                                                   AL 
                                                                                                                   ASSESSMENT 
C-5       5/25/70  Beyond applicable data timeframe.                                        N/A                    No 
C-5       10/17/70 Beyond applicable data timeframe.                                        N/A                    No 
C-5       9/27/74  Beyond applicable data timeframe.                                        N/A                    No 
C-5       4/4/75   Beyond applicable data timeframe.                                        N/A                    No 
C-5       9/19/76  Class A, destroyed.  Not a crash.  Number 2 Eng/pod fire, chafing        Landing                No 
                   hyd/elec lines. 
C-5       11/28/78 Class A, destroyed.  Not a crash.  Turbine failure, fire.                Takeoff                No 
C-5       1/16/80  Class A, not destroyed.  Not a crash.  Number 2 Eng. blade               Takeoff                No 
                   retainer failed.  Fire. 
C-5       6/8/82   Class A, not destroyed.  Not a crash.  Number 1 Eng. inner liner         Takeoff                No 
                   failed, cowl damage. 
C-5       7/31/83  Class A, not destroyed.  Crashed on landing 200 feet before              Landing                No 
                   threshold.  A/C from Travis AFB to Shemya AFB, Alaska. 
C-5       11/17/83 Class A, not destroyed.  Crashed on landing at Travis AFB on             Landing                No 
                   runway because landing gear up. 
C-5       3/16/86  Class A, not destroyed.  Not a crash.  Number 1 hyd pump failed          Landing                No 
C-5       7/19/89  Class A, not destroyed.  Crashed on landing 1,300 feet short of          Landing                No 
                   threshold.  Slid onto threshold. 
C-5       8/29/90  Class A, destroyed.  Ramstein AFB, crash during takeoff 4,000            Takeoff                No 
                   feet from end of runway. 
B-1       8/29/84  Class A, destroyed.  Twenty-two nautical miles from Edwards              Low Level              No 
                   AFB.  Low level training flight 
B-1       9/28/87  Class A, destroyed.  From Dyess AFB.  Crashed 102 nautical               Low Level              No 
                   miles from Peterson AFB.  Low level flight.  Kimura gives 9/27/87 
                   as date. 
B-1       11/8/88  Class A, destroyed.  Landing crash.  Four nautical miles from            Landing                No 
                   Dyess AFB.  Fire in wing fairing area. 
B-1       11/17/88 Class A, destroyed.  Crashed on landing at Ellsworth AFB.  One           Landing                No 
                   thousand feet off end of runway.  Kimura gives 11/18/88 as date. 
B-1       6/26/90  Class A, destroyed.  Not a crash.  Instructor pilot qualifying check.    Unknown                No 
                   Landed and refueled then damaged discovered. 
B-1       10/4/90  Class A, not destroyed.  Not a crash.  Lost engine in low-level          Low Level              No 
                   flight 
B-1       12/19/90 Class A, destroyed.  Not a crash.  Fan blade failure (inside right       In Flight              No 
                   Engine No. 3).  Landed without incident 
B-1       3/24/92  Class A, not destroyed. Mid-air collision with KC 135.  Both             In Flight              No 
                   landed safely. 
B-1       5/21/92  Class A, not destroyed,  Not a crash.  Landing gear failure.             Low Level              No 
B-1       6/19/92  Class A, not destroyed.  Not a crash.  Foreign object while in           In Flight              No 
                   climb.  Beyond applicable database timeframe. 
B-1       12/1/92  Class A, destroyed.  Crashed.  Low level terrain following               Low Level              No
                   operation.  Beyond applicable database timeframe. 
[Font:Courier 12pt]Comment:  Provide a definition of interim storage and indicate how
long and to what capacity the Environmental Assessment covers.
Response:  Interim storage is defined as storage until a long-term storage facility is
identified and operational.  The Department will complete an Environmental Impact
Statement covering dismantlement and storage of the resulting nuclear materials and
classified weapons components and will issue a record of decision within three years
of issuance of this Finding of No Significant Impact.  This is in addition to the Nuclear
Weapons Complex Reconfiguration Programmatic Environmental Impact Statement,
which will address long-term storage issues related to the future nuclear weapons
complex.
Subject to completion of the scoping process, the Department now envisions that the
new Pantex Site-Wide Environmental Impact Statement will address all current and
proposed facilities and activities at Pantex as well as storage requirements, including
alternate locations, for all plutonium, highly enriched uranium, tritium, and classified
weapons components, as appropriate, that result from the Pantex dismantlement
activities.  Scoping meetings for this Environmental Impact Statement will be held in
Amarillo, Texas and at other sites that may be affected by the activities at Pantex no
later than June 30, 1994.
Comment:  Provide a statement that clearly indicates that the Department of
Energy will cease max pack configuration after implementation of Stage Right.
Response:  Dismantlement at Pantex will continue and pit storage will be expanded in
the Zone 4 Steel Arch Construction magazines consistent with the Environmental
Assessment and the Final Safety Analysis Report for Zone 4 Magazines.  Individual
magazines will be loaded consistent with the preferred configurations in the
Environmental Assessment.
Comment:  Provide an inventory of pit age at Pantex.
Response:  The Pantex Zone 4 pit inventory as of September 27, 1993 is as follows:
           Maximum Age In Years             Quantity of Pits
                  33                               291
                  32                               688
                  31                               79
                  30                               222
                  29                               277
                  28                               850
                  27                               292
                  26                               82
                  25                               0
                  24                               175
                  23                               973
                  22                               463
                  21                               81
                  20                               151
                 19-14                             0
                  13                               45
                  12                               251
                  11                               55

Environmental Assessment for Interim Storage of Plutonium Components at Pantex and Department of Energy Response to Comments Received from the State of Texas

Volume II

January 1994
U.S. Department of Energy
Albuquerque Operations Office
Amarillo Area Office
Pantex Plant
P.O. Box 30030
Amarillo, Texas 79120
                          TABLE OF CONTENTS
                          VOLUME II, SECTION I
    LETTERS RECEIVED ON THE PRE-APPROVAL ENVIRONMENTAL ASSESSMENT
                          VOLUME II, SECTION II
   LETTERS RECEIVED DURING THE TWO-WEEK COMMENT PERIOD FOLLOWING
      THE DECEMBER 6, 1993 PUBLIC MEETING (DECEMBER 6 TO 20, 1993)

Section I Letters Received on the Pre-Approval Environmental Assessment

Volume II, Section I
Letters Received on the Pre-Approval Environmental Assessment
Documen Author Affiliation
t
1001 Ann W. Richards, Governor State of Texas
1002 Alison A. Miller Texas Air Control Board
1003 Thomas A. Griffy University of Texas at Austin, Department of Physics
1004 C. Ross Schulke U.S. Department of Transportation Federal Aviation
Administration
1005 Jeri Osborne & Family Citizen Comments
1006 Auburn L. Mitchell University of Texas at Austin, Texas Bureau of Economic
Geology
1007 Joseph A. Martillotti Texas Department of Health, Bureau of Radiation Control
1008 Boyd Deaver Texas Water Commission
1009 Tom Millwee, Chief Texas Department of Public Safety, Division of
Emergency Management
1010 Walt Kelley City of Amarillo/Counties of Potter and Randall
Emergency Management
1011 Dana O. Porter Citizen Comments
1012 Margie K. Hazlett (1) Citizen Comments
1013 Margie K. Hazlett (2) Citizen Comments
1014 Sam Day, Director Nukewatch
1015 Addis Charless, Jr. Panhandle Area Neighbors and Landowners (PANAL)
1016 Jeri Osborne Citizen Comments
1017 Jim Osborne Citizen Comments
1018 Bob Bullock, Lt. Governor State of Texas
1019 W.H. O'Brien Operation Commonsense
1020 Benito J. Garcia, Chief State of New Mexico, Environmental Department
1021 Lawrence D. Egbert, MD Physicians For Social Responsibility
1022 James Thomas Hanford Education Action League (HEAL)
1024 Jay R. Roselius, County Carson County
Judge
1025 William and Mary Citizen Comments
Klingensmith
1026 Tamara Snodgrass Citizen Comments
1027 Portia Dees Citizen Comments
1030 Judy Osborne Citizen Comments
1031 Louise Daniel Citizen Comments
1032 Betty E. Barnard Citizen Comments
1033 Norbert Schlegal Citizen Comments
1034 48 signatures/form letter Citizen Comments
1035 Karen Son Citizen Comments
1036 Arjun Makhijani, Ph.D. Institute for Energy & Environmental Research
1037 Bishop Leroy T. Diocese of Amarillo
Matthiesen
1038 Boyd M. Foster, President Arrowhead Mills
1039 Tonya Kleuskens, Chairman The Texas Nuclear Waste Task Force
1040 Carl L. King, President Texas Corn Growers Association
1041 Beverly Gattis Military Production Network
1042 Beverly Gattis Save Texas Agriculture and Resources (STAR)
1043 Mavis Belisle, Director The Peace Farm
1044 Margie K. Hazlett (3) Citizen Comments
1045 Beverly Gattis Serious Texans Against Nuclear Dumping (STAND) of
Amarillo, Inc.
1046 Dan Morales, Attorney State of Texas, Office of the Attorney General
General
1048 Doris & Phillip Smith Panhandle Area Neighbors and Landowners (PANAL)
1049 Jerome W. Johnson Panhandle 2000
1050 Senator Teel Bivins (Dist The Senate of The State of Texas
31)
46 letters forwarded from the State of Texas. Document numbers not
necessarily sequential.

Part 1001

STATE OF TEXAS
OFFICE OF THE GOVERNOR
AUSTIN, TEXAS 78711
February 25, 1993
ANN W. RICHARDS
GOVERNOR
The Honorable Hazel R. O'Leary
Secretary of Energy
Washington, D.C. 20585
Dear Secretary O'Leary:
Enclosed are the comments my office has received to date regarding the U.S.
Department of Energy's Predecisional Environmental Assessment for Interim
Storage of Plutonium Components at the Pantex Nuclear Weapons facility.
The Texas Attorney General's Office will forward their comments to you
under separate cover.
The state of Texas has made every effort to comply with the March 2, 1993
extended deadline provided by the U.S. Department of Energy. However, I
have been notified that a few individuals do need additional time to
complete their reviews. Therefore, I respectfully request that DOE establish a
final deadline of March 16, 1993, to ensure that all interested parties are given
every opportunity to have their concerns addressed.
There is no question that producing the environmental assessment was a
long and painstaking effort requiring the dedication and skills of many
talented individuals. Preparing an appropriate response to that document
elicited the same level of effort.
Rather than attempting to summarize the comments, and thereby run the
risk of either misinterpreting or failing to give them the full weight and
attention they deserve, I am forwarding the comments to DOE exactly as they
were received in this office. Thus, each submission stands alone and deserves
a detailed response to the various concerns expressed in that document. I
direct your particular attention to the comments prepared by Texas state
agencies and universities.
Post Office Box 12428 Austin, Texas 78711 (512)463-2000 (Voice)/(512)475-3165 (TDD)
Printed on Recycled Paper
The Honorable Hazel R. O'Leary
February 25, 1993
Page Two
Nevertheless, one inescapable fact is readily apparent: A number of the
assumptions and conclusions stated in the document simply cannot be
verified with out more information.
In addition, state officials believe that the methodologies used in the report 1001/1
addressing the potential impact of a plutonium release to the Ogallala
Aquifer, and the section addressing the Aircraft Hazard Analysis, are so 1001/2
fundamentally flawed that they must be revisited. In their current form, it is
impossible to determine whether the resulting conclusions are, in fact, valid.
Once you have had an opportunity to evaluate the enclosed comments, I am
confident you will agree that significant portions of the assessment require
further study. Therefore, any attempt to endorse or reject the assessment at
this time would be premature.
I am most concerned about the 6-10 year interim storage period. Specifically, I 1001/3
want to know when this 10-year period officially begins and ends. I also need
clear and definite information about what procedures will be followed if the
plutonium is still sitting at Pantex at the end of the 10-year period.
After my staff and other state officials have had an opportunity to review
your answers to our questions, they would like the opportunity to meet with
the appropriate DOE officials. The meeting held in January with individuals
from your headquarters in Washington, the area office in Albuquerque and
from the Pantex plant was very productive and beneficial.
If you have any questions or need additional information, please have your
staff contact Roger Mulder in my office at 512/463-2198.
Thank you for your cooperation. There is no question that protecting the
human health and safety and the environment of the Pantex community is a
challenge, a goal, and a responsibility that all of us share.
Sincerely,
ANN W. RICHARDS
Governor

Part 1002

TEXAS AIR CONTROL BOARD
February 19, 1993
Mr. Roger Mulder, Director
Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Austin, Texas 78711
RE: Methodology Used to Assess the Probability of Aircraft Impact with Zone 4 Pantex Nuclear
Weapons Facility (Pantex) Structures
Dear Mr. Mulder:
Executive Summary
The "Environmental Assessment (EA) for Interim Storage of Plutonium Components at Pantex,"
dated December 1992, finds an airplane crash to be an incredible event, that is the probability of
the event is less that one-in-a-million. The EA employs a method of reducing the probability of a
serious credible event into unlikely specialized events. This, it is claimed, eliminates the need to
report the potential consequences of the specialized events in the safety analysis. I believe the
probability calculations developed for the total aircraft population should not be assumed to have
the same validity at the subpopulation level.
I have reviewed the methodology used to assess the probability of aircraft impact with Zone 4
Pantex plat structures. This analysis is included as Appendix E in the EA. The modeling of an
airplane crash into Zone 4 structures of the Pantex plant closely follows the methods developed in
the 1976 Sandia report (reference 2 of Appendix E). However, the accident rates and effective
areas used to calculate the probability of impact are greatly reduced from the values used in the
1976 Sandia National Laboratories (Sandia) report. Most importantly, the analysis performed in
the Sandia report is used to assess the overall probability of aircraft impact with Zone 4 structures.
The EA applies the same methodology and claims the estimates of probability are valid at the
subpopulation level (specific types of aircraft). As the research and methodology were developed
to estimate the probability for the general population of aircraft, the "stretching" of this analysis to
estimate the probabilities for specific subclasses of aircraft substantially degrades the validity of
the estimates generated.
Texans working for clean air Printed on Recycled Paper
Mr. Roger Mulder, Director -2- February 19, 1993
Subdivision into Aircraft Subclasses is Used to Eliminate the Need to Consider the Impact 1002/1
of Certain Types of Aircraft with Zone 4 Structures
Initially, the EA finds the probability that an aircraft will impact a Zone 4 structure to be greater
than one-in-a-million. In other words, the chance of airplane impact with a structure scheduled
for the interim storage of plutonium is calculated to be a credible event. However, the potential
consequences of airplane impact with Zone 4 structures are not reported.
The probability of impact is developed by dividing aircraft into four classes: air carriers, military
aircraft, aerial application, and general aviation. The probability of impact for any specific class
of aircraft, except general aviation, is calculated to be less than one-in-a-million. Thus the EA
concludes, it is unnecessary to consider any class of aircraft except for general aviation. This is a
clear deviation from the 1976 Sandia report, which concludes only that the probability of aircraft
impact is 4.7 in 100,000 (4.7E-05). The most critical objection to the methodology of the EA is
that conclusions are drawn about the probability of subclasses of aircraft while the methodology
followed is clearly developed for a population estimate. This technique of subdivision into
aircraft classes is used in order to reduce credible events into incredible specific events. I am
especially concerned about the validity of subpopulation estimates of probability since the
environmental consequences of an incredible event do not have to be analyzed.
The probability of impact for a general aviation aircraft with a Zone 4 structure was calculated to
be greater than one-in-a-million annually. Again, the method of subdivision into aircraft classes
was applied. General aviation aircraft were subdivided into two classes: single engine aircraft
and multi-engine aircraft. Multiple engine aircraft are then shown to have an impact probability
which is incredible. It is possible to further subdivide the class of single-engine general aviation
aircraft so that the impact of those subclasses of planes with the Pantex Zone 4 structures is an
incredible event. However, the report instead references analyses by Jacob Engineering
(Appendix C) which "suggest it is reasonable to exclude single-engine aircraft from further
consideration in the accident analysis." Clearly, by employing a subdivision method, it is possible
to reduce the probability of almost any event to an incredible level.
Zone 4 Effective Areas Reduced from 1976 Sandia Report 1002/2
In order to calculate the probability of a plane impacting into the Zone 4 structures, a formula was
used which considers only the portion of Zone 4 where a aircraft could strike a magazine. The
formula given is equal to the sum of the actual area the building occupies, a shadow area
dependent on the subclass of aircraft considered and a skid area dependent on the subclass of
aircraft. The areas used are smaller than the areas used in the 1976 Sandia report. This is due to a
substantial reduction in the skid areas and the wingspans capable of doing damage to Zone 4
structures from the values used in the 1976 Sandia report. This reduces the "effective" area for
over 60 percent (%) of the aircraft to less than one-tenth of a square kilometer. From the maps
provided in the environmental assessment and references, it appears that Zone 4 covers at least
one square kilometer. Thus, the Zone 4 areas where an airplane crash might cause damage has
been reduced by 90% for most types of aircraft considered. This cannot be verified as the actual
dimensions of Zone 4 and its structures were not provided in the environmental assessment.
Mr. Roger Mulder, Director -3- February 19, 1993
Probability per Kilometer of an Aircraft Crash is Reduced from the 1976 Sandia Report 1002/3
A crucial element for calculating the probability of aircraft Impact with a Zone 4 structure is the
probability of an aircraft crash per kilometers flown. The type of aircraft crash considered is one
in which the aircraft is significantly damaged since the assessment claims these are the only type
of crashes which could impact a magazine. In addition, only crashes which occurred while the
plane was inflight are considered. For every subclass of aircraft, the 1992 EA reports a
substantially lower probability per kilometer of a significant inflight aircraft crash than the 1976
Sandia report (see Table 1).
Table 1 Estimates of the probability per kilometer of an aircraft crash from the Environmental
Assessment are significantly less than those used in the 1976 Sandia Report.
Class of Aircraft 1976 Sandia Report 1992 EA
--------------------------------------------------------------------------------------
Air Carrier 3.2E-09 4.0E-10
General Aviation 2.0E-07 4.4E-08
Military Aircraft 1.6E-08 3.1E-09
Aerial Application 3.0E-07 1.8E-07(possible error)
The EA relies on fatal accident figures (provided by the National Transportation Safety Board
[NTSB] in a memo from Lin and Tenney of Sandia National Laboratories, dated July 2, 1992, to
R. E. Smith) upon which to base a new rate for the probability per kilometer of an inflight United
States air carrier crash. This relationship is assumed despite a comment by Lin and Tenney that
"the number of aircraft destroyed is not highly correlated to the number of fatal accidents." The
EA reduces the mean fatal accident rate by the ratio 18/31 to provide an estimate of the inflight
accident rate in which the accident is severe enough to seriously damage or destroy a Zone 4
magazine (page E-2). This method of estimation assumes a linear relationship between the
known quantity (fatal accident rate) and the unknown quantity (inflight severe accident rate).
This is not a valid assumption unless the two variables are correlated.
In order to estimate the probability per kilometer of a severe inflight general aviation crash, the 1002/4
NTSB data base was again referenced (memo from Lin of Sandia National Laboratories, dated
August 13, 1992, to R. E. Smith). The EA generates a severe inflight accident rate for general
aviation using the data provided by Lin (page E-2). The most critical assumption in calculating
the accident rate is the average speed. The memo from Lin provides "average speeds" for the
various classes of aircraft included in the general aviation group. However, the average speeds
used in the EA are greater than the average speeds reported by Lin. These appear to be the only
numbers from the memo that were changed for the EA. By adjusting the speeds upward, the
estimated probability of a severe inflight crash is decreased. The EA does not provide
justification for using the higher average speeds. Furthermore, the total accident rate per mile for
general aviation and the total accident rate per mile for general aviation except single engine
aircraft (Table E-6, last two columns) cannot be calculated from the information in the EA or the
reference documents. Since this is a critical subclass of aircraft, additional documentation is
necessary to justify the average speeds used in the calculations. At a minimum, the average
speeds used in the calculations for the last two columns of Table E-6 should be provided.
Mr. Roger Mulder, Director -4- February 19, 1993
Note on Aerial Application Probability 1002/5
For aerial application, the EA claims the "accident rate for aerial application of (2.945E-
02/100,000 km, 4.7E-07/mi) was retained (from the 1976 Sandia report) for analysis" (page E-7).
However, on page E-22 a different accident rate is recorded. It appears the accident rate per
kilometer was recorded as the accident rate per mile.
General Notes 1002/6
After reviewing the reference material provided by the author of "Appendix E, Aircraft Hazard
Analysis," I can find no justification for using three significant figures.
A reference on page E-20 is off by one section. Specifically, the probability equation is defined in 1002/7
Section E.2 not E.2.1.
According to the reference material (reference 8 of Appendix E) used to generate Table E-2, 1002/8
Summary of Aircraft Accidents - U. S. General Aviation, the number of fatalities and serious
injuries in 1978 was 1,146, not 1,145, and in 1986, the number of fatalities and serious injuries
was 790 and not 748.
In Table E-3, General Aviation Hours Flown (Millions) by Aircraft Class, the number of hours 1002/9
flown for single engine aircraft in 1988 should have been 21.2, not 21.1, according to the
reference material (see reference 8 of Appendix E). In 1988, the total number of hours flown for
all general aviation aircraft should be 27.1, rather than 21.1, according to the reference material.
The Table E-5, General Aviation Aircraft Destroyed Inflight Per 100,000 Hours by Class has a 1002/10
column for the Total. It appears from the text that this column should contain the sum of the
preceding four columns. The numbers that appear in the Total column are not equal to the sum of
the preceding columns. Likewise, the Modified Total w/o Single Engine Aircraft does not appear
to contain the sums of the previous columns.
Table E-7, Summary of Military Aircraft Crash Rates. The reference (a memo authored by Lin 1002/11
from Sandia National Laboratories, dated August 25, 1992) used to create Table E-7 reports the
number of miles flown for the C-5 type of military aircraft to be 517 million miles. In the table,
the number of miles flown for the C-5 type of military aircraft is reported to be 414.4 million
miles.
The definition of an incredible event is based upon an annual probability of occurrence. I am 1002/12
concerned that this may offer a false sense of security. The probability of an event occurring
during the anticipated 10 years of storage is much greater than the probability an event will occur
during the one year period used for calculation. For example, the
Mr. Roger Mulder, Director -5- February 19, 1993
annual probability of a military aircraft impacting a Zone 4 structure is estimated in the EA to be
2.5E-07. Thus, over a 10 year storage period, the probability of a Zone 4 structure being seriously
impacted by military aircraft climbs to 2.5E-06. That is, over a 10 year period, the chance of
military aircraft impacting a Zone 4 structure is much greater than one-in-a-million.
Sincerely,
Alison A. Miller
Pantex Project
Air Quality Assessment Program
cc: Mr. Richard Ratlilf, Texas Department of Health, Bureau of Radiation Control, Austin
Ms. Nancy Olinger, Office of the Attorney General, Austin
Mr. Gerry Bolmer, Texas Water Commission, Austin
Mr. Ray Quijano, Texas Department of Public Safety, Division of Emergency Management,
Austin
Judge Jay Roselius, County Judge, Carson County, Panhandle
Dr. Tom Gustavson, Bureau of Economic Geology, Austin
Mr. Walt Kelley, City of Amarillo, Amarillo

Part 1003

DEPARTMENT OF PHYSICS
THE UNIVERSITY OF TEXAS AT AUSTIN
Austin, Texas 78712-1081 (512)471-1153
12 January 1993
Mr. Roger Mulder, Director
Special Projects
Environmental Policy Division
Office of the Governor
Austin, Texas 78711
Dear Mr. Mulder:
I appreciate the opportunity to comment on the Environmental Assessment related to the
Pantex Nuclear Weapons Plant. The decision to significantly increase the amount of 1003/1
plutonium stored at this facility is an important one and the environmental impacts of this
decision need to be carefully assessed. Unfortunately one cannot judge from the
document provided whether or not this has been done.
The report provided creates the impression of providing a detailed analysis (often quoting
results to three significant figures!) while at the same time withholding some of the
essential data on which those calculations are based. The public is therefore presented
with what appear to be detailed calculations, on the basis of which well-informed
judgments might be reached, when in fact this is not the case.
There may be valid security concerns which preclude including such information as the
dimensions of the structures in which the plutonium is stored or the amount of plutonium
contained in each pit. If so, two reasonable options are available:
1) present only the results of the analysis (i.e. trust me!) or
2) present the details of the calculation in a classified document which could be
reviewed by individuals having the appropriate clearances.
The report as it stands appears to be a full and open discussion of the problem when in
fact it is not.
On a more detailed note, I believe the analysis presented of aircraft accidents is 1003/2
fundamentally flawed. While aircraft accidents might occur at a rate estimated to be
more than 10E-6 per year, analysis of the impact of air carrier or military accidents was not
included on the basis that this subgroup had a probability estimated to be less than 10E-6
per year. This procedure of dividing an accident class into subgroups in order to reduce
the probability of each subgroup below that necessary for inclusion is surely unjustified.
(When carried to its logical conclusion one could divide the class of aircraft accidents to a
subgroup which consisted of MD-88 aircraft, carrying exactly 121 passengers flown by a
captain named Kruger on Thursday!) Risk analysis should be performed on the basis of
Mr. Roger Mulder, Director
Page Two
12 January 1993
probability times consequences. Excluding low probability events (below some 1003/3
threshold) which could have catastrophic consequences is clearly wrong.
I hope you find these comments useful. If you would like to discuss this issue further
please call me at (512)471-1053.
Sincerely,
Thomas A. Griffy
Professor of Physics
TAG:dlw

Part 1004

U.S. Department                                                     Amarillo ATCT
of Transportation                                                   Rt 3, Box 579
                                                                    Amarillo, Texas
Federal Aviation                                                    79107
Administration
January 28, 1993
Joseph A. Martillotti
Bureau of Radiation Control
Pantex Special Project Coordinator
Division of Compliance and Inspection
1100 West 49th Street
Austin, Texas 78756-3189
Mr. Martillotti:
During the months of January, February and March, 1991, under            1004/1
the "Freedom of Information Act", I provided information to a
contractor for the Department of Energy. This Information was
limited to Amarillo Air Traffic Control Towers' monthly traffic
count logs and the Daily Flight Progress Strips on aircraft
operating in our airspace.
The Aircraft Hazard Analysis Data on pages 6-3 through 6-8 and
Appendix E of the Environmental Assessment prepared by the
United States Department of Energy has no resemblance to the
data provided by this office. Therefore, I am unable to comment
on any information contained in the Assessment. For your in-
formation, the total aircraft operations for the Amarillo area
in the CY 1992 was 91,800. Any further restrictions to flight
or changes of airspace to the Pantex Prohibitive area would have
an Immediate and adverse impact on the utilization of Amarillo
International Airport.
If you have any questions, please do not hesitate to call.
C. Ross Schulke
Air Traffic Manager
cc:    ASW-530
       WTX-500
Edward Warren: First American Aloft

Part 1005

                                              Route 2, Box 11
                                              Panhandle, Texas 79068
                                              February 8, 1992
Roger Mulder
Director of Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Capitol Station
Austin, Texas 78711
Dear Roger
The enclosed comments were made by our son after he carefully reviewed
the Environmental Assessment prepared by the United States Depart-
ment of Energy regarding the proposal to increase the storage of
plutonium at the Pantex site in Carson County.
James Michael (Mike) Osborne received his BSAE from Texas A&M
University in 1987. His 9 1/2 years of experience in the aerospace
engineering field include propulsion specialist for General
Dynamics in Ft. Worth on F 16 and F 11 military aircraft; Gulf-
stream in Savannah, Georgia; and Senior Engineer in Propulsion for
Learjet in Wichita, Kansas. Mike has his private pilot's license.
Mike was raised on the farm immediately to the north of the plant
and directly under the flight approach and take-off path of the
Amarillo International Airport where all military aircraft practice
landing with touch and go practices as well having been a SAC base
for the Air Force during Mike's childhood. Mike has seen many
aircraft of all kinds flying directly overhead and over the Pantex
plant.
He noted that the EA did not address Helicopters that fly over the             1005/1
site. All types of military helicopters can be seen on a regular
basis. This type of aircraft does not crash by skidding. They
crash by falling straight down.
Mike also noted that no mention of the about 1955 emergency landing            1005/2
of a B 25 on the site near the present burning ground after the plane
ran out of fuel.
Please consider Mike's remarks carefully as you review the EA.
Thank you.
                                   Sincerely,
                                   Jeri Osborne 
                   COMMENTS ON AIRCRAFT HAZARD ANALYSIS
     Upon reviewing the Aircraft Hazard Analysis (Section E) a number of
fallacies become readily apparent.
     Firstly, there appear to be numerous mathematical errors within the
tables presented. While it may be that the values presented in those
tables have been adjusted through the use of factors, this is not readily
apparent from the column headings. Many of the mathematical errors are
in a conservative direction, but their existence seriously clouds the
credibility of the report itself. Further review of the references quoted
in support this analysis would be required in order to determine if the
statistics presented are valid.
     Secondly, the term "General Aviation" is grossly misused in the             1005/3
Aircraft Hazard Analysis. Traditionally, "General Aviation" has been used
to describe all aeronautical activity that is neither military nor civil,
that pertaining to airlines. Typically, agricultural aviation is also
excluded from that heading. General aviation is made up of aircraft ranging
in size from the 1600 lb Cessna 150/152 and smaller up through the 73600 lb
Gulfstream IV. The 3500 lb aircraft used in the Aircraft Hazard Analysis
is hardly representative of General Aviation as it currently exists.
     Thirdly, the definition of the takeoff and landing phases of flight
as being within 5 kilometers of the airport in highly misleading. By using
this definition of the takeoff and landing phases as being those within 5
kilometers of the runway, the analysis is able to take advantage of the
lower occurrence of accidents for the "inflight" phase. This ignores the
fact that a high percentage of the flights over the Pantex plant are by
aircraft making straight-in approaches to the B-SW runway at Amarillo
International Airport. These flights consist of military training flights,
as well as military cargo flights by C-5A, C-5B, C-141B and C-130 aircraft.
Few light aircraft actually pass over the plant while on approach to the
NE-SW runway at Amarillo International Airport due to the zone of prohibited
airspace and due to normal operational requirements. Typically, these
aircraft do not make straight-in approaches, but rather, fly a much smaller
traffic pattern.
     The combined effect of the mis-definition of General Aviation and the
operation of larger military aircraft over the Pantex plant implies an
exposure to accidents involving much heavier aircraft. A 3500 lb aircraft
with a 500 lb engine is representative of single-engine aircraft only. The
Beechcraft 300LV is also representative of General Aviation. This aircraft
is a twin-engine turbo-prop up to 14000 lbs and being driven by two engines
weighing 465 lbs each without accessories. The Learjet Model 35 is a twin-
engine turbofan weighing up to 18500 lbs and powered by two engines weighing
734 lbs each without accessories. The Gulfstream IV mentioned above weighs
up to 73600 lbs and is powered by two turbofan engines each weighing 3100 lbs
without accessories.
     At this point it should also be noted that the military cargo aircraft
that routinely operate over Pantex operate at much higher weights. The
C-130 turboprop weighs up to 155000 lbs and is driven by four engines each
weighing approximately 1800 lbs. The C-141B weighs up to 343000 lbs and is
powered by four turbofans weighing in excess of 4300 lbs each. Finally, the
C-5B weighs up to 837000 lbs and uses four turbofans weighing more than 7900
lbs each.
     Further, the Aircraft Hazard Analysis seems to consider only accidents      1005/4
in which the aircraft slides to a stop, a condition consistent with takeoff
or landing incidents. No effort is made to analyze higher angle impacts
resulting in energy dissipation through cartwheeling (Sioux City, Iowa DC-l0
accident) or the cratering resulting from high impact angles. Due to the
distance from the runway (quoted as being 13.6 km), aircraft passing over
the Pantex plant and following a standard 3 degree glide slope will be at
an altitude of approximately 2300 feet above ground level. This is not
conducive to a sliding impact, but rather a high angle impact with resulting
vertical penetration of components into the crash site. In this type of
accident, the low-pressure rotor shafts of turbine engines have been known
to penetrate several feet of granite.
     The aircraft speed of 80 mph at the time of the accident, as quoted         1005/5
in the aircraft Hazard Analysis is also highly unrealistic. This is stated
to be derived by multiplying the landing speed of a single-engine aircraft
by 1.3. It should be noted that FAR Part 23[-49] requires single-engine aircraft
to have a stall speed of not greater than 61 knots Indicated Airspeed (KIAS),
or 70 mph. Multiplying this value by 1.3 results in a speed of 79.3 KIAS or
91 mph. This is approximately the lowest speed that would be anticipated.
multi-engined aircraft typically stall at higher speeds, and most turbofan
aircraft stall at speeds in excess of 100 KIAS or 115 mph when operating at
light weights. At heavy weights. the stall speed may rise to more than 150
KIAS or 173 mph. These speeds are only consistent with low angle impacts.
High angle impacts may occur at speeds exceeding the maximum operational
speed of the aircraft.
     Additionally, no mention is made of the effects of a post-crash fire        1005/6
or explosion in the Aircraft Safety Analysis. In the event of an accident
involving a large turbine-engined aircraft, several thousand gallons of
jet fuel would be available for combustion. This is not addressed.
     Finally, the military aircraft accident rates fail to include a number      1005/7
of major accidents. The C-5 is listed as having had no crashes when, in
fact, two are easily recalled. The first of these in the 1970's involved
a C-5, departing from the Republic of Vietnam, and carrying a large number
of orphaned children. During the climb to altitude, several minutes after
takeoff, a door seal failed and eventually resulted in the uncontrolled
descent and crash landing of the aircraft. The second, more recent accident
took place near Ramstein AFB in Germany and was associated with Operation
Desert Shield.
     The B-1B is also listed as having had no accidents. Disregarding the
loss of one proto-type at Edwards AFB due to the failure to maintain proper
center-of-gravity during a stall test, three operational aircraft have been
lost to date. The first, in Colorado, was due to a bird strike while
operating at low level and was a high-energy impact. The second, at Dyess
AFB in Abilene, TX was due to the catastrophic failure of the low-pressure
rotor of one of the four engines. The third was in late 1992 in the Davis
Mountains of Texas.
     At approximately the same time as the third B-1B accident, two C-141
aircraft were involved in a mid-air collision at high altitude over Montana.
Both aircraft were destroyed. These accidents involve military aircraft of
types that routinely fly over the Pantex plant and are not addressed in the
Aircraft Hazard Analysis.
     In summary, the Aircraft Hazard Analysis contains numerous errors and
omissions. Throughout the document, mathematical errors are found. Speeds        1005/8
are quoted in mph when they are actually in knots, roughly, a 15% error in
in non-conservative direction. The impact energies considered are low in
magnitude by as much as 32% due to the use of incorrect units of velocity
(based upon the velocity-squared term in the equation for kinetic energy).
This does not address the unrealistically small aircraft and light weights
or the low impact velocities used in the analysis. No effort was made to
address the penetration by high-density engine rotating components or
post crash fire. Overall, considerable work is required to produce an            1005/9
acceptable analysis of hazards posed by aircraft. This Aircraft Hazards
Analysis does not provide a comprehensive or accurate picture of the
danger posed by aircraft to material stored at the Pantex plant.
Figure (Page 4 of Part 1005 Learjet)

Part 1006

BUREAU OF ECONOMIC GEOLOGY
THE UNIVERSITY OF TEXAS AT AUSTIN
University Station, Box X - Austin, Texas 78713-7508 - (512)471-1534 or 471-7721 - FAX 471-0140
10100 Burnet Road - Austin, Texas 78758-4497
February 25, 1993
Mr. Roger Mulder
Director, Special Projects
Environmental Policy Division
Office of the Governor
Austin, TX 78711
Dear Roger:
As requested in your letter, we have reviewed the "Environmental Assessment for Interim
Storage of Plutonium Components at Pantex." Our remarks address Section 7 therein and
an included report titled "Potential Ogallala Aquifer Impacts of a Hypothetical Plutonium
Dispersal Accident in Zone 4 of the Pantex Plant" by Turin and others (1992).
Scientists assigned to the Pantex Project have attempted to provide a constructive and, to
the extent feasible, thorough review of this important document. We have not sought to
address all elements of the Turin analysis, particularly those dealing with plutonium
chemistry, dosage, and toxicity; these are matters we do not ordinarily deal with and thus
are largely outside our area of expertise. Rather, our principal focus is on a central
element of the report, vadose zone flow and contaminant transport, which is the major
focus of our ongoing Pantex study. We have raised several questions and have included
suggestions for improving the report. Two sets of comments are included in the attached
review: (1) comments on technical issues, which critically review four of the five
assumptions upon which this ground-water impact analysis is based and (2) specific
comments, which are identified by page and line number.
In our view, the Turin report requires revision, for, in our judgment, four of the five
assumptions that were used in preparing the ground-water impact study need further
supporting analysis as outlined in the attached comments.
If you have any questions, please call me at (512)471-1534.
Sincerely yours,
Auburn L. Mitchell
Acting Associate Director
ALM:lch
Attachment
cc: W. L. Fisher
J. A. Raney
T. C. Gustavson
P. C. Bennett
K. A. Rainwater
SUMMARY
This review of "Potential Ogallala Aquifer Impacts of a Hypothetical Plutonium Dispersal
Accident in Zone 4 of the Pantex Plant" by H. J. Turin, I. R. Triay, W. R. Hansen, and W. J.
Wenzel, is divided into two sections. The first section addresses technical issues and concerns
about the conceptual model of the hypothetical accident. The second section lists specific technical
comments.
Turin and others (1992) (see also Section 7 in the EA Summary) describe a hypothetical
accident in which plutonium is released into the atmosphere, dispersed by wind, and deposited on
the land surface. Transport rates are then calculated for movement of the released plutonium to the
Ogallala aquifer. The authors state that "...we have consistently made conservative assumptions to
maximize the probability of identifying any real threats to the Ogallala Aquifer" (Turin and others,
1992, p. 2). In our opinion, some elements of this report are not conservative or are in need of
revision as outlined below. Conversely, as we also point out below, some elements of the analysis
may be more conservative than recognized.
Technical Issues
1. Cleanup to the Level of 0.2 uCi/m^2 Following the Hypothetical Accident 1006/1
The first assumption (listed on page 7-1 of the EA report and on page 1 of Turin and others, 1992)
is that "Surface soils would be decontaminated to levels no greater than 0.2 uCi/m^2 following the
hypothetical accident. (Previous experience indicates that this level is achievable)." Neither the EA
nor Turin and others (1992) provide support for this critical assumption, and numerous questions
about it can be raised. First, the potential for soil and ground-water contamination at initial post-
accident levels during the cleanup period cannot be summarily excluded. Accordingly,
documentation should be provided on the anticipated range of initial contamination levels at the
1
surface prior to decontamination. Further, the basis for concluding that a maximum post-cleanup
radiation level of 0.2 uCi/m^2 is achievable should be provided. If this assumption is based on
previous remediation efforts, the report should discuss such prior cleanups and show that they are
applicable to the Pantex Plant area.
Second, the length of time taken for cleanup is important to assessing plutonium
concentrations in soils, and in particular playas, during this period (1). The inference that cleanup will
be performed in a timely fashion using methods based on past experience for released plutonium
needs explanation. Will soil removal be required? If so, this task could be substantial. For
example, if the accident occurred as described but with contamination spread over only 1/5 of 1
percent of the 50-mi- (80-km-) radius, then the following volumes of contaminated soil would
result. If only the top 4 inches (10 cm) of soil had to be removed during decontamination of this
15.7 mi^2 (40 km^2) area, the volume of soil would equal approximately 5,000,000 yd^3
(4,500,000 m^3). If 250 trucks with a carrying capacity of 10 yd^3 (7.6 m^3) were used, and each
truck could make 12 round trips per day to a temporary disposal facility, then the total cleanup time
required would be 160 days.
Because of the time likely required to achieve decontamination to the desired level throughout
the affected area, it appears unrealistic to assume that no plutonium concentration above
0.2 uCi/m^2 will occur in soils prior to decontamination or during cleanup. For example, if the
cleanup period extends as long as one year, a rainfall event with a 5-year return interval would
have a 20% chance of being equaled or exceeded in that one-year period. According to Becker and
Purtymun (1982) in a previous study of the Pantex Plant region, there is a recurrence interval of 5
years for a 2.9-in (7.36 cm) rainfall event in a 6-hour period ad a 3.7-in (9.40 cm) rainfall event
in a 24-hour period. Any precipitation event that produced significant surface runoff, such as a 5-
year return-interval storm, would result in concentration of plutonium contamination because of the
_______________________________
(1) The comment regarding the potential for rainfall runoff to concentrate plutonium prior to and during cleanup do
not consider the effect of applying substances (fixants) to the land surface to hold the plutonium in place. If fixants
will be applied. The report should discuss their effectiveness in holding plutonium in place under rainfall conditions
based on prior use or tests.
2
closed drainage typical of the region. In sum, the cleanup effort could require some time, during
which contaminated soil would be exposed to rainfall/recharge events. Runoff could possibly
concentrate contaminants in playas, and contamination could extend to the subsurface. Thus, the
conceptual model described for this hypothetical accident is presently unsubstantiated with regard
to the implication that cleanup could be completed prior to movement of plutonium into the
subsurface and with regard to the initial concentration of 0.2 uCi/m^2 of plutonium.
II. Plutonium Concentrations in Soils 1006/2
The second assumption (listed on page 7-1 of the EA report and on page 1 of Turin and others,
1992) is "Surface transport processes may increase soil concentrations ten-fold to 2.0 uCi/m^2,
before infiltration takes place." The assumption that only a tenfold increase in contaminant levels
for playa basins in the area of the Pantex Plant is questionable. Data from an investigation by
Becker and Purtymun (1982) of the 10 playa basins on or immediately adjacent to the Pantex Plant
indicate a significantly higher concentration factor. Becker and Purtymun's method for determining
concentration potential is based on the ratio of surface area of the playa (drainage) basin to the
surface area of the playa floor (collection point for the basin). They reported measured areas for 10
basins (Turin's Basin No. 7 had zero acres recorded for the playa floor and is thus ignored in the
following statistics). The minimum basin-to-playa ratio reported, and therefore the minimum
concentration factor, was 12 (for their Basin No. 10). Thus, the concentration ratio of 10 is neither
conservative nor equivalent to the actual minimum measured ratio. The maximum ratio was 29 (for
their Basin No. 3). The mean ratio for the nine basins is 21, with a standard deviation of 8.
Therefore, if a "conservative" value is used for the potential concentration of contaminants, a
minimum factor of 25 to 30 should be selected, assuming an antecedent moisture concentration of
saturation and no infiltration of precipitation.
To accurately determine a more statistically defensible "conservative" concentration factor, an
effort could be made to compute the ratio of playa-basin surface area to playa-floor surface area for
3
all of the basins in the 80-km radius of the hypothetical accident area. This could be done by
comparing the area of Randall Clay soils (playa floors) to the area of upland soil. Soil data are
available in county soil surveys published by the USDA Soil Conservation Service.
III. Flow and Contaminant Transport Through Playas 1006/3
The third assumption (listed on page 7-1 of the EA report and on page 1 of Turin and others,
1992) states that "Recharge to the Ogallala Aquifer is focused at playa lake beds. Playa lake
recharge rates are approximately 3 cm/yr, ten times the High Plains average." The assumption that
recharge to the Ogallala aquifer is focused in playa lake beds is probably valid.(2) However, in our
view, the 3 cm/yr playa lake recharge rate, which is reported to be 10 times the High Plains'
average recharge rate, is probably invalid for this contaminant transport analysis.
A. In Contaminant Transport Analysis, a "Site Specific" Recharge Rate Should Be Used
Rather Than Regionally Averaged Recharge Values
Turin and others (1992) point out that local variability in recharge rates may be quite high, but
these values may be averaged over larger areas to provide a representative recharge rate for the
entire landscape. This approach is suitable for estimating regional ground-water resources, but it is
not valid for evaluation of site-specific ground-water contamination. In contaminant transport
analyses it is important to know not only the rate at which water is recharged to an aquifer but also
the rate and concentration at which contaminants move down to the aquifer. Gee and Hillel (1988)
discuss the fallacy of averaging, and Gee and others (1991) discuss the importance of preferred
pathways that may bypass much of the vadose zone and transport contaminants directly to an
underlying aquifer. If most of a region's recharge occurs beneath only 3 to 4 percent of the land
surface, then the much higher focused recharge rate actually would transport a greater mass of
contaminants at greater velocities than would be predicted from regionally averaged recharge
values.
____________________________
(2) Preliminary results of hydrological studies at the Pantex Plant suggest that ditches might also have been important
sources of recharge during the Plant's history.
4
The methodologies and recharge values listed in the Turin report are not appropriate for
several reasons. For example, most of the recharge rates reported in Turin and others (1992) are
based on very little quantitative data (Wood and Petraitis, 1984), or on a ground-water flow model
calibration (Knowles, 1984; Luckey, 1984) (3) . Recharge rates based on the chloride mass balance
approach (Stone and McGurk, 1985) are subject to the assumptions of one-dimensional piston-
type flow and of precipitation as the only source of chloride (Scanlon, 1991). Because surface
runoff into the playas provides another source of chloride such as irrigation return waters, recharge
estimates based on the chloride mass balance approach in playa settings are minimum estimates.
Therefore, the recharge values provided by Stone and McGurk (1985) should be used only as
minimum estimates and not as absolute values, as in the EA. In addition, the potential existence of
preferential flow pathways beneath playas may invalidate the application of the chloride mass
balance approach beyond estimating minimum recharge rates.
The method used by Nativ (1988) and Nativ and Riggio (1990) in calculating recharge rates,
which ranged from 1.3 to 8 cm/yr, is probably the most applicable for this study. This range in
recharge rate is based on "bomb" tritium (4) found in shallow Ogallala aquifer wells in Lubbock
County. Turin and others (1992) accept the methods used and recharge rates reported in Nativ
(1988) and Nativ and Riggio (1990) but point out that the higher rates were recognized in areas far
south of the Pantex Plant. However, as discussed next, Nativ (1988) also reports elevated tritium
in a well near the Pantex Plant.
B. A Proposed "Site Specific" Recharge Rate Based On known Tritium Levels In Wells 1006/4
On or Near Pantex Plant
Nativ (1988) reports elevated tritium in a well in Carson County, immediately north of the
Pantex Plant in the Amarillo Well Field (Well No. 627, TWC No. 06-44-207) and in a well in
_____________________________
(3) The comment at page 6 of the Turin report that the narrowness of the range in estimated recharge rates suggests
that the numbers are accurate, is clearly not applicable when evaluating contaminant transport. In reality, the
narrowness of range probably means that previous workers have not adequately considered natural variation.
(4) "Bomb" tritium is derived from atmospheric testing of nuclear weapons during the late 1950's and early 1960. The
presence of elevated tritium levels in ground water indicates, because of tritium's short half life, that those waters
were recharged during the last 40 years.
5
northern Armstrong County. Therefore, on the basis of these data alone, there is clearly some
recharge in progress at rates capable of transporting tritium to the water table at depths of at least
200 to 500 ft (161 to 152 m), and this recharge has been occurring within the last 40 years. In the
Pantex Plant area, Bureau scientists found elevated tritium in all wells producing from a perched
aquifer. Tritium levels in these wells range from 0.4 tritium (TU) (in well OW-WR-44) to 44 TU
(in a private well 1.9 mi south of the Pantex Plant).
Nativ (1988) estimated that water sampled in 1985 with a tritium content of 73 TU was
probably from a precipitation event that occurred between 1966 and 1967. Nativ (1988) calculated
recharge rates based on the equation
Thickness of unsaturated section X moisture content
recharge rate = -----------------------------------------------------
Time since recharge event
Because Turin and others (1992) accepted the validity of methods used by Nativ (1988) and Nativ
and Riggio (1990), it is appropriate to apply this same method to calculate a "conservative" site-
specific recharge rate for the Pantex Plant area based on the tritium levels reported for wells in the
perched aquifer in the area. Two technical considerations complicate the selection of time intervals
for recharge events based on current tritium levels. The rust problem is that the input function for
tritium today has dropped to a level that is nearly at prebomb background levels. Second, there is
no simple method for taking into account mixing of younger waters recharging vertically with older
water moving along the natural system. For example, a water sample with 5 TU might derive from
a single source of water with 5 TU or from several sources by mixing 5 Parts water with 100 TU
and 95 parts water with no tritium; or infinite other combinations could apply.
Most of the tritium values reported for perched ground water in the Pantex area are too low
(for example, less than 8 TU) to relate to the tritium-decay curve. In the well with 44 TU,
however, a conversion can be made so that this water can be applied to Nativ's (1988) tritium-
decay curve. The most reasonable time period for a recharge event with this tritium input function
(44 TU in 1992 is approximately equal to 65 TU in 1985, the date at which Nativ's [1988] samples
6
were collected) is 1966 to 1967. Thus, an elapsed time from recharge event to arrival in the
perched aquifer at this well could be approximately 25 years. The average volumetric moisture
content, as measured by Bureau scientists in several boreholes in the area, ranges from about 0.1
to 0.2 m^3, higher moisture contents being observed near the surface. The unsaturated zone at this
well is reported to be approximately 200 ft (61 m) thick. Unsaturated thickness above some
perched aquifers are as great as 260 ft (79 m). Using a range in moisture content of 0.1 to 0.2,
thickness of an unsaturated zone ranging from 200 to 260 ft (61 to 79 m), and a time since
recharge ranging from 25 to 40 years results in a range in recharge rates from 0.5 to 2.1 ft/yr (15.2
to 63.3 cm/yr).
C. Calculation of a "Conservative" Velocity for Determining Contaminant Transport in the 1006/5
Vicinity of Pantex
The above site-specific recharge range describes the volume rate of transfer of water to the
aquifer, not the velocity at which a water molecule moves through the unsaturated zone. Velocity,
which is critical in determining contaminant transport, is calculated by dividing the thickness of the
unsaturated zone, 200 to 260 ft (61 to 79 m), by the time since recharge, 25-40 years. Given these
values, the velocity beneath the Pantex Plant is approximately 5 to 10 ft/yr (150 to 300 cm/yr).
In addition to "bomb" tritium levels observed at depth, recharge experiments conducted at the
Bushland Agricultural Research Station demonstrate the potential for subsurface velocities
substantially exceeding those assumed in the Turin report. Recharge experiments were performed
in basins that had been excavated to a depth of 3.9 ft (1.2 m) to remove the Pullman soil and
expose the unconsolidated caliche layer (Aronovici and others, 1970). Infiltration rates beneath the
basins were on the order = 3.3 ft/d = 1,200 ft/yr (100 cm/d = 36,500 cm/yr).
In sum, our view is that for purposes of this site-specific ground-water analysis, contaminant
transport concepts, which consider the velocity of water movement through the unsaturated zone,
should be used rather than volumetric-oriented ground-water resources concepts, which focus on
the rate at which water is recharged to an aquifer. For the Pantex Plant area, tritium-dating
7
methodology indicates water may move at significantly higher rates in the subsurface than assumed
in the Turin report.
IV. Water Table at 50 ft
We concur with the conservative values stated in the fourth assumption of the EA report.
V. Plutonium Sorption/Preferential Flow Paths 1006/6
The fifth assumption (listed on page 7-2 of the EA report and on page 1 of Turin and others,
1992) states that "The entire unsaturated zone exhibits a plutonium sorption coefficient of 100
mL/g, approximating the sorption of clean Ogallala sand." There are several issues here. First, it is
our view that actual retardation of plutonium filtrating through the Pullman and Randall soils is, in
the absence of preferential flow, going to be substantially greater than that reported. Actual
mobility, however, would have to be evaluated in terms of preferential flow through fractures or
root tubules, which these batch-equilibrium sorption coefficients do not consider. Thus, this
assumption, while conservative to the extent of its reach, does not fully address the issue of
plutonium behavior either at the surface or in the subsurface.
A. Plutonium Sorption Coefficient for Porous Media
The experiments reported to validate this assumption are based on plutonium sorption studies
performed on Pullman soil and Ogallala sediment and did not consider the Randall clay soil.
Unfortunately, the actual Kd reported from these experiments cannot be directly evaluated. The
authors report using the 75 to 500 um size fraction for their experiments. This size fraction,
although somewhat representative of Ogallala sediments, is inappropriate for evaluating sorption of
inorganic solutes. This size fraction is dominated by framework silicates, and, if the sample is not
disaggregated first, by soil aggregates of some unknown structure.
8
Most importantly, however, sorption is dominated by the clay fraction, in which particle size
is generally less than a few microns. Based on our evaluation of the Pullman and Randall soils, the
specific surface areas of the bulk soil are approximately 20 to 40 m^2/g, whereas specific surface
areas of the size fraction used in the Turin report experiments are approximately 0.01 to 0.05 m^2/g,
or three orders of magnitude smaller. Thus, in the absence of preferential flow, actual retardation
of plutonium infiltrating through Pullman and Randall soils is going to be substantially greater than
that reported, based on the experiment's size fraction. This part of the Turin analysis is, therefore,
extremely conservative. However, we again emphasize that these results are valid only in the
absence of preferential flow.
B. Preferential Flow Paths 1006/7
The report by Turin and others (1992) does not fully describe the potential for preferential
flow of recharging waters and retardation of plutonium moving through the Ogallala and
Blackwater Draw Formations. Cores from these formations and from playa-filling sediments
contain abundant open root tubules that are typically 0.04 in (1 mm) in diameter but range up to
0.3 in (8 mm) in diameter. Root tubules are commonly lined with a thin layer of illuvial clay.
Cores through the Randall Clay commonly contain fractures, some filled with silt and very fine
sand and some with oxidized zones. Both root tubules and fractures are sites through which
preferential flow and infiltration can occur. Root tubules are preserved throughout the fine-grained
eolian facies of both the Blackwater Draw and Ogallala Formations. The presence of open tubules
and fractures indicates that pathways exist through which downward flow is accelerated and
contact with sediments is reduced, thus lessening the potential for sorption of radionuclides. Such
pathways may explain the high flow rates discussed in Aronovici and others (1970). As noted in
the attached specific comments, the subject of preferential flow should be examined in much
greater detail.
9
Specific Comments
Page Line
3 13-14 The statement that the Ogallala Formation has been eroded and is no longer 1006/8
present along the Canadian and Pecos Rivers is incorrect. The Ogallala
Formation is present in the Canadian River Valley for at least 70 mi northeast
of the Pantex Plant.
6 8-9 The statement is made that "Local recharge rates in the playa basins must 1006/9
therefore significantly exceed the regional averages cited above." This
relationship between playas and recharge supports use of specific recharge
rates instead of regional averages.
6 19-20 The statement is made that "no recent contour maps showing depth-to-water 1006/10
for the study area were available." It should be noted that Bureau researchers
simultaneously submitted to DOE (1) a report on perched aquifers at the
Pantex Plant (referenced in Turin and others, 1992) and (2) a report
containing potentiometric-surface maps of the Ogallala aquifer through 1991
(not referenced in Turin and others (1992)).
7 4 At steady state, the Ogallala outcrop areas along the margins of the Canadian 1006/11
River and Palo Duro Canyon were clearly discharge zones. With the
continued lowering of Ogallala water levels in some areas, a reversal in
gradients may occur and what were previously discharge zones may in fact
convert to recharge zones.
7 20 Considering the differences in geology, hydrology, climate, and vegetation, 1006/12
the comparison between the Trinity site and the Pantex Plant seems
inappropriate.
9 11 It is regrettable that Pullman soils and Ogallala sediments were collected but 1006/13
Randall soils with their higher clay content were not.
10
13-14 More detail is needed concerning advection-dispersion simulations to allow 1006/14
full evaluation of the results. For example, the specific boundary and initial
conditions and flow and transport parameters used in the simulations are not
described.
18 Preferential Flow section: A much more detailed evaluation of preferential 1006/15
flow should be presented because this is a critical issue with respect to
recharge beneath playas. Numerical simulation of preferential flow should
include mobile and immobile water. Using twice the calculated water velocity
is not a sufficiently conservative assumption. A review article by Beven and
Germann (1982) cites velocity ratios between matrix and macropore flow
between 100:1 and 400:1. The subsurface beneath playas is particularly
conducive to preferential flow because the soils are close to saturation and are
subject to a ponded upper boundary when playas contain water. Because this
is the most likely area of recharge and is critical for contaminant transport, the
subject of preferential flow should be examined in much greater detail.
11
REFERENCES
Aronovici, V. S., Schneider, A. D., and Jones, O. R., 1970, Basin recharging the Ogallala aquifer
through Pleistocene sediments: Texas Tech University, International Center for Arid and
Semiarid Land Studies, Proceedings of the Ogallala Aquifer Symposium, Special Report No.
39, p. 182-192.
Becker, N. M., and Purtymun, W. D., 1982, Supplementary documentation for an environmental
impact statement regarding the Pantex Plant hydrologic study for Pantex: Los Alamos
National Laboratory Contract Report LA-9445-PNTX-A, 65p.
Beven, K., and Germann, P., 1982, Macropores and water flow in soils: Water Resources
Research, v. 18, p. 1311-1325.
Gee, G. W., and Hillel, Daniel, 1988, Groundwater recharge in arid regions: review and critique
of estimation methods: Hydrological Processes, v. 2, p. 255-266.
Gee, G. W., Kincaid, C. T., Lenhard, R. J., and Simmons, C. S., 1991, Recent studies of flow
and transport in the vadose zone: Reviews in Geophysics, Supplement to Volume 29, U.S.
National Report 1987-1990, American Geophysical Union,
p. 227-239.
Knowles, T. R., 1984, Assessment of the ground-water resources of the Texas High Plains, in
Whetstone, G. A., ed., Proceedings of the Ogallala Aquifer Symposium II: Texas Tech
University Water Resources Center, p. 217-237.
Luckey, R. R., 1984, The High Plains Regional Aquifer--flow-system simulation of the Central
and Northern High Plains, in Whetstone, G. A., ed., Proceedings of the Ogallala Aquifer
Symposium II: Texas Tech University Water Resources Center,
p. 48-66.
12
Nativ, Ronit, 1988, Hydrogeology and hydrochemistry of the Ogallala aquifer, Southern High
Plains, Texas Panhandle and eastern New Mexico: The University of Texas at Austin,
Bureau of Economic Geology Report of Investigations No. 177, 64 p.
Nativ, Ronit, and Riggio, Robert, 1990, Meteorologic and isotopic characteristics of precipitation
events with implications for ground-water recharge, Southern High Plains, in Gustavson, T.
C., ed. Geologic framework and regional hydrology: Upper Cenozoic Blackwater Draw and
Ogallala Formations, Great Plains: The University of Texas at Austin, Bureau of Economic
Geology, p. 152-179.
Scanlon, B. R., 1991, Evaluation of moisture flux from chloride data in desert soils: Journal of
Hydrology, v. 128, p. 137-156.
Stone, W. J., and McGurk, B. E., 1985, Ground-water recharge on the Southern High Plains,
east-central New Mexico, in New Mexico Geological Society Guidebook, 36th Field
Conference, p. 331-335.
Turin, H. J., Triay, I. R., Hansen, W. R., and Wenzel, W. J., 1992, Potential Ogallala aquifer
impacts of a hypothetical plutonium dispersal accident in Zone 4 of the Pantex Plant: Los
Alamos National Laboratory, Contract Report, 32p.
Wood, W. W., and Petraitis, M. J., 1984, Origin and distribution of carbon dioxide in the
unsaturated zone of the Southern High Plains of Texas: Water Resources Research, v. 20, p.
1193-1208.
13

Part 1007

Texas Department of Health
David R. Smith M.D. 1100 West 49th Street Robert A. MacLean, M.D.
Commissioner Austin, Texas 78756-3189 Deputy Commissioner
(512)458-7111
Radiation Control
(512)834-6688
February 25, 1993
Mr. Roger Mulder
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Austin, Texas 78711
Dear Mr. Mulder:
Enclosed are the Bureau of Radiation Control comments on the draft Environmental
Assessment for Interim Storage of Plutonium Components at Pantex.
The assessment concludes that the proposed action impacts only potential increased
radiation exposures to workers, and that there should be no distinguishable additional
impacts on the general public as a result of normal operations. DOE's assertion
relating to the proposed action may be correct, but it should not be concluded that there
is no risk resulting from Zone 4 operations. There have been, and will continue to be,
conditions at the Pantex Plant which require planning and preparations to protect the
public health and safety, and surveillance to protect the environment.
Within the assessment, there are a number of areas which require clarification and or
correction. We believe it appropriate for the state to request the opportunity to review
and provide input to any changes the DOE makes to the document prior to publication
and the succeeding steps in the NEPA process.
If I can be of any further assistance, please do not hesitate to call.
Sincerely,
Joseph A. Martillotti
Pantex Project Coordinator
Division of Compliance and Inspection
Bureau of Radiation Control
Page 3-1, Lines 29-32: It is noted that assembled weapons and components will continue to 1007/1
be staged in a number of the SAC magazines. The proposed action does little to diminish the
potential threat to public health and safety and the environment from these items.
Page 3-1, Lines 35-36: The statement "DOE Orders and procedures for insuring safe and 1007/2
secure storage of the pits would continue to be followed rigorously." is misleading and is
contradicted by paragraph 6.1.1.1, which states that "...inspections and inventories would
occur a minimum of once every 18 months..." (emphasis added). During a DOE briefing
conducted on January 14, 1993, this was verified as a departure from the current bimonthly
minimum physical inventory requirement.
Page 3-2, Line 23-29: The discussion of the shielded forklift with passive guidance system is 1007/3
written in the present tense, as though it exists and is in use today.
Page 4-2, Lines 6-10: The "Note" in italics is misleading. It suggests that any alternative 1007/4
involving shipment will require repackaging into a shipping container at Pantex and
repackaging into a suitable storage container at the alternate site. Page 3-2, lines 3-7 indicate
that pits may be stored in Type B shipping containers. It would appear that in any case, the
radiological exposure to workers would be approximately the same as when pits were routinely
returned to Rocky Flats Plant.
Page 4-3, Lines 3-6: This passage seems to indicate that construction has been halted at the 1007/5
Nuclear Materials Storage Facility due to lack of funding from DOE, and that if construction
was resumed, it would take four to five years to complete.
Page 4-3, Lines 27-33: Beginning with "The nuclear weapons complex mission....", the 1007/6
discussion shows that serious consideration was not given to this option. It would seem that
storage of pits, as described in this document, should not aggravate or complicate the massive
environmental restoration and remediation efforts required at Hanford. The storage of parts
removed from weapons (presumably not ready for insertion into new weapons without some
preparation) does not clearly appear to be a defense only mission.
Page 4-4, Lines 29-38: Concerns expressed in this passage would not necessarily be valid if 1007/7
the pits were packaged and shipped to an alternate location in suitable transportation/storage
containers, as is suggested on Page 3-2.
Page 4-5, Paragraph 4.4: This report does not indicate that DOD facilities were seriously 1007/8
studied, only that they were "considered" and determined to be "not currently available". It is
difficult to visualize what may be different between Pantex SAC and Modified-Richmond
facilities and DOD facilities designed to protect and store weapon assemblies. The DOD
facilities certainly would provide the physical storage space and the security forces should be
comparable to Pantex capabilities. Transportation of components would seem to be less
hazardous than assembled weapon delivery, and represents no significant change from previous
Rocky Flats components shipments. Table 4-1, Section 4.4 affirms that apparently very little
consideration was given to this issue,bsy the total absence of information. If there is any
information available, it should be provided here for scrutiny.
Page 6-1, Paragraph 6.1.1.1: This passage reflects a diversion from previous DOE Security 1007/9
and Safeguards requirements to mitigate substantial increase in worker radiological exposures.
The statement on Page 3-1, lines 36-37, "The DOE Orders and procedures for ensuring safe
and secure storage of the pits would continue to be followed rigorously." needs to be
reconciled here. It should also be noted that the "approval" contained in DOE/SA-124
Memorandum, Dated January 12, 1993, Subject, Request for Exception of the Bimonthly
Minimum Physical Inventory Frequency Requirement at the Pantex Facility" relates only to 18
Igloos. It is interesting to note that the "effective date" is not a date certain, but rather a
"floating" date starting (or restarting) within 30 days after a physical inventory of the contents
of each igloo has been accomplished.
Page 6-2, Chart: This gives the appearance that corrosion inspections are not required for 1007/10
containers in the horizontal palletized stacking configuration.
Page 6-5, Paragraph 6.2.5: The Aircraft Hazard Analysis is purported to be conservative in 1007/11
nature, but much effort has been expended to reduce the calculated probability of an
occurrence from unlikely to extremely unlikely. The stated purpose of this document was to
determine environmental impacts, if any, from storing more pits in an igloo than before. At
issue is the fact that the maximum amount of plutonium permitted per Modified-Richmond
magazine has not increased, while the maximum number of igloos containing only plutonium
pits will increase. The amount of plutonium proposed for storage in the SAC magazines is
consistent with the previous limit on the Modified-Richmond magazines. There is also a
corresponding decrease in the number of igloos available to stage weapon assemblies and other
nuclear explosive components, which remain the most serious threat from Zone 4 activities.
These igloos, in addition to some specific Zone 12 facilities, continue to present the most
serious potential off-site consequences if involved in an initiating event.
Page 6-7, Table 6-1: Note 3 refers to Tables 7-2A and 7-2B; should be 6-2A and 6-2B. 1007/12
Page C-10, Line 14: It is unclear why 3500 lbs is paired with 117 fps. Just above, on lines 8 1007/13
and 9, 117 fps (80mph) is paired with 6200 lbs.(Possible error)
Page E-9, Lines 7-10: Aircraft take-off and landings have been excluded by this assumption. 1007/14
This does not appear to be conservative in approach, as most commercial and military aircraft
operating to the north of the Amarillo Airport can be observed to fly very close to, if not
directly over, the Pantex Plant.
Page E-24, Table E-12: The TOTAL column contains erroneous data. 1007/15
Page E-25, Table E-13: Use of three significant figures here appears to be unjustified. 1007/16
Therefore, 6.63E-07 may be rounded up and expressed as 1.OE-06.

Part 1008

John Hall, Chairman
Pam Reed, Commissioner
Peggy Garner, Commissioner
TEXAS WATER COMMISSION
PROTECTING TEXAN'S HEALTH AND SAFETY BY PREVENTING AND REDUCING POLLUTION
February 1, 1993
Mr. Roger Mulder, Director, Special Projects
Environmental Policy Division
Office of the Governor
P.0. Box 12428
Austin, Texas 78711
Re: Environmental Assessment (EA)
Dear Mr. Mulder:
This office received the draft EA from your office on December
31, 1992. The following comments are the result of the initial
review of this document.
Comment: Executive summary: page vii fourth paragraph. 1008/1
Reference is made to capacities of the magazine, the statement
of "up to 20,000 pits" appears to be an inference rather than a
declaration... Capacities of magazines mentioned well exceeds
20,000 pits.
Question: What is the maximum capacity of storage?
Comment: Executive Summary: page vii fifth paragraph. 1008/2
"...would not result in additional generation or management of
wastes."
Question: Is this referring to a pit as a waste?
Comment: 2.0 PURP0SE AND NEED FOR THE PROPOSED ACTION: p.2-1 1008/3
third paragraph.
"4... This is expected to be within a timeframe of 6-10 years.
Question: What if the 10 year goal is exceeded? What effect will
NEPA have on this goal commencement?
REPLY TO: DISTRICT 1 / 3918 CANYON DRIVE / AMARILLO, TEXAS 79109-4996 / AREA CODE 806/353-7830
P.O. BOX 13087 * 1700 North Congress Avenue * Austin, Texas 78711-3087 * 512/463-7830
Mr. Mulder
Page 2
February 1, 1993
Comment: 3.0 PROPOSED ACTION: p.3-1 Third Paragraph. 1008/4
"...hold up to 384 or 392 pits, in the single-layer vertical
or horizontal palletized multiple stacking configurations
respectively.
Question: Figure 3.4 exhibits 460 pit capacity for horizontal
palletized multiple stacking. Which number is the capacity to be
used?
Comment: 3.0 PROPOSED ACTION: p.3-2 Second paragraph. 1008/5
"Variations and/or a combination of these arrangements may be
used.
Question: Is this a "disclaimer" or "loophole" that can be used to
deviate from arrangements previously proposed in this document?
If you have any questions, please contact me in the District
1 office at 806/353-9251.
Sincerely,
Boyd Deaver
Pantex Grant Program Manager
BD:ls
cc: Ken Ramirez, Deputy Executive Director
office of Legal Services & Compliance

Part 1009

                       DIVISION OF EMERGENCY MANAGEMENT
                      TEXAS DEPARTMENT OF PUBLIC SAFETY
                             5805 N. Lamar Blvd.                 JAMES R. WILSON
ANN W. RICHARDS                  Box 4087                           Director
  Governor                Austin, Texas 78773-0001                TOM MILLWEE
                          Duty Hours 512 465-2138                 Coordinator
                        Nonduty Hours 512 465-2000
                             FAX 512 465-2444
                            February 22, 1993
Roger Mulder
Director, Special Projects
Environmental Policy Division
Office of the Governor
201 East 14th Street, Room 205
Austin, Texas 78701
Dear Mr. Mulder:
Thank You for the opportunity to review the Environmental Assessment regarding the
Interim Storage of Plutonium Components at Pantex. The increased amount of
storage of plutonium pits raises some issues that must be addressed. While the              1009/1
statistical probabilities may conclude that there is no increased risk to the local
population as a direct result of the increased storage of plutonium pits, the public
perception of increased risk must be considered in addressing this issue.
Pantex has not had a public information program in effect to educate and prepare the
population on the hazards posed by a radiological release. DOE is now preparing to
tell the local population that an increase in the number of plutonium pits stored in zone
4 igloos will pose no additional risk to the local populace. Unless a public information
program is in place, the result may be public hysteria. The increased level of
plutonium storage must be accompanied by a comprehensive public information
program that will withstand public and political scrutiny. We remain unconvinced that
the public will believe that an increased storage level of plutonium pits will not cause
additional risk.
The data provided by the Amarillo Air Traffic Manager differs from the aircraft hazard      1009/2
analysis pages 6-5 through 6-8. The variance on the number of aircraft flying into
Amarillo must be reconciled. The projected increase in plutonium pits must be
compared with the projected aircraft traffic during the interim storage period. Using
invalid data will render an invalid conclusion.
Roger Mulder
February 22, 1993
Page 2
The probability of an aircraft crashing into an igloo in zone 4 may be an incredible        1009/3
event. However, with respect to the increased dismantlement program, the
synergistic impact of every aspect of the dismantlement program must be considered.
The potential risk from the increased number of units, their movement, the
transportation of these units, the increased disassembly and storage, must be
assessed. The overall impact may result in a finding of a credible event.
We do not have the documentation or the resources to validate the finding of the
predecisional environmental assessment. We expect reasonable assurance that the
statistical probabilities are valid and therefore yield to the experts. We cannot endorse
the study without additional information. However, we strongly recommend a
comprehensive public information program if the interim storage of plutonium
components at Pantex is to occur.
Sincerely,
Tom Millwee
Chief
STM/RQ/mdd

Part 1010

        CITY OF AMARILLO                       COUNTIES OF
                                        POTTER AND RANDALL
                      EMERGENCY MANAGEMENT
                                  February 8, 1993
Mr. Roger Mulder
Director, Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Austin, Texas 78711
Dear Roger:
Review of the Environmental Assessment reveals two areas of
concern that warrants further explanation or discussion. The
additional information will be needed to aid in local emergency
planing and public awareness.
     1.   The maximum tornado winds shown in the assessment are         1010/1
          220 mph. This wind speed falls in the range of a
          category F4 tornado (wind range 207-260 mph). This
          past year an F4 level tornado struck Fritch, Texas, a
          community approximately 20 miles NE of the plant.
          During recent years we have spotted and tracked several
          tornados near the plant. More emphasis needs to be
          placed on the effects of the maximum winds of an F4
          level tornado (260 mph) and consideration needs to be
          given to an F5 level (winds 261-318 mph) tornado. A
          new engineering study needs to be completed on the
          older storage areas in sector 4. The threat is listed
          in the assessment as extremely unlikely yet the plant
          has very extensive tornado plans and elaborate spotting
          techniques and equipment.
     2.   Even though a large plane accident is not considered          1010/2
          creditable and not discussed in table 6-1, more
          information is needed to insure adequate planning and
          to give the assessment creditability with the public.
          The information used to determine the probability of
          this type accident seems to be questionable and needs
          to be reevaluated. Since a large aircraft accident is
          the only type of incident that can have extensive off
          site consequences more data must be provided in the
          assessment. At a minimum the following areas should be
          covered in the study or unclassified supporting
          documents:
P.O. Box 1971          Phone (806)378-3022          Amarillo. Texas 79186-0001
          The number of military flights that pass directly over
          area with specific data on the type of aircraft.
          The qualifications of the pilots in command of these          1010/3
          aircraft. This area is used for a lot of training
          flights.
          The accident history of the type of military aircraft         1010/4
          being flown in this area.
          A matrix of possible contamination levels that can be         1010/5
          expected, off-site, based on the number of ruptured
          pits. This data should be presented in progressive
          levels of 25 to the maximum number that will be stored
          in any one area.
          Maximum health effects of an off-site release.                1010/6
          Environmental effects and risk levels of maximum              1010/7
          possible release.
          Possibility of terrorist of actions involving an              1010/8
          aircraft.
These comments are submitted with the intent to obtain additional       1010/9
information to enhance our planning efforts. I see no reason why
DOE should not be allowed to increase the amount of plutonium at
the plant as long as:
     The data used to prepare the assessment is validated by the
     State agencies that are part of the AIP.
     DOE continues to include local government in all phases of
     emergency planning.
     State and Local agency inspections continue.
                              Sincerely,
                              Walt Kelley
                              EM Coord.
                             -2-

Part 1011

                                       P.O. Box 1118
                                       Mississippi State, MS 39762
                                       February 18, 1993
Roger Mulder
Director of Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Capitol Station
Austin, Texas 78711
Dear Mr. Mulder:
I am an agricultural engineer specializing in soil and water
conservation engineering. I earned my Bachelor of Science and
Master of Science degrees at Texas A&M University, and I expect
to receive my Doctorate in Agricultural and Biological
Engineering at Mississippi State University this summer. My work
experience includes research in modeling soil erosion, modeling
soil-water relations, and analyzing dust emission data collected
from feedlots and agricultural processing facilities. I am
currently employed by the United States Department of Agriculture
- Agricultural Research Service, where I am involved with field
research and computer modeling of soil-water movement and
distribution.
I have reviewed the Environmental Assessment prepared by the
United States Department of Energy regarding the proposal to
increase the storage of plutonium at the Pantex Nuclear Weapons
Plant near Amarillo, Texas. I understand the importance of
locating an appropriate storage facility for the plutonium.
However, I question whether the D.O.E. environmental assessment
adequately addresses the health and safety of the people or the
long-term economy of the Texas panhandle. I would like to bring
to your attention some specific concerns I had in response to the
D.O.E. environmental assessment.
The report states that the intention of the D.O.E. project is to        1011/1
provide temporary storage for the plutonium pits. The difficulty
in finding a permanent storage or disposal site for the plutonium
is obvious. In other words, if these "temporary" storage plans
are approved, the pits will likely move into the Texas panhandle
to stay.
Do the designers of the storage configurations know that it is          1011/2
safe to store these quantities of plutonium in such a small area?
is there danger of nuclear reaction due to "critical mass"?
The report does not address the hazards of air-borne dusts and          1011/3
gases. Dusts are only mentioned in reference to their potential
to contribute to groundwater contamination. What about the
public health risks associated with ingestion or inhalation of
radioactive or chemical dusts and/or gases? Has the Texas Air
Control Board been appropriately consulted with respect to these
dangers? I question the accuracy of the average annual wind             1011/4
rose, located on page 5-10, Figure 5.8, in the report. I found
no reference cited for the data in the figure. An error or
misrepresentation of such data can result in inappropriately
placed air quality samplers, and consequently, errors in air
quality measurements.
The groundwater contamination models were run with the assumption       1011/5
that, in the event of a plutonium release, any contaminated soil
would be de-contaminated to a 0.2 uKCi/L. In the event of a
release of radioactive dust, how large of area would be affected?
What costs in human safety, agricultural productivity, and
environmental quality would be associated with such a clean-up
operation? Is it possible that contaminated surface soils would
have to be removed from a large area? How would these
contaminated soils be treated or disposed?
The report indicates that the containerized plutonium pits will         1011/6
be inspected on an 18-month schedule. There is a comment on page
6-1 of the report that some minor releases of air pollutants
during these inspections.
Inventory and inspection operations described by the report have
allowed one minute per container. Does this include locating and
moving the containers to an area where they can be visually
inspected? From the stacking configurations described in the
report, I was not able to visualize how the inspectors could
locate and inspect the individual pits at a rate of one per
minute, especially if the pits must be moved with a forklift. If
inspection time and handling requirements are underestimated, are
the associated risks also underestimated?
The potential risks of groundwater contamination were evaluated         1011/7
by the Los Alamos National Laboratory - a D.O.E. facility. Are
their findings assumed to be objective? Can we accept the
results without question? The groundwater risk assessment does          1011/8
not address any organic solvents, heavy metals, or other
potential groundwater hazards. If I recall correctly, the United
States Environmental Protection Agency reported several years ago
that they had found evidence of heavy metal and organic chemical
contamination of the soil and water environment associated with
previous Pantex operations. Even if no environmental                    1011/9
contamination occurs, will increased operations at Pantex require
excessive water use, thus contributing to depletion (mining) of
the Ogallala Aquifer? Has the Texas Water Commission been duly
advised of the potential risks to surface water and groundwater         1011/10
resources?
The environmental assessment report states that the D.O.E., "as         1011/11
with all Federal agencies", will be responsible for cleanup of
any contamination. Who would enforce this policy and ensure that
the cleanup would be accomplished in a timely manner? What are
their cleanup contingency plans?
In the report, Potential Ogallala Aquifer Impacts of a                  1011/12
Hypothetical Plutonium Dispersal Accident in Zone 4 of the Pantex
Plant, compiled by the Los Alamos National Laboratory, there were
several points I find questionable.
     1. According to the report, research has shown that recharge
rates below playa lakes in the area have been estimated between
1.3 and 8 cm/year (page 8). The report indicates that a
"conservative" recharge estimate of 3 cm/year was used in the
modeling project. Why was the 8 cm/year estimate not used?
     2. The authors of the report indicated that preferential flow      1011/13
is expected to have negligible contribution to the aquifer
contamination risk. The Pullman clay loam and Randall clay
soils, containing appreciable amounts of montmorillonitic clay,
are subject to cracking which increases opportunity for
preferential flow. Mobility of potential groundwater pollutants         1011/14
downward through the soil is often dependent upon the chemical
properties of contaminants, the soil properties, and the
interactions between the contaminants, soil, and water in the
system. Organic matter content, cation exchange capacity,
moisture content, and pH of the soil, as well as pre-existent
soil structure and condition, can affect the transport of
potential pollutants toward the aquifer. These issues are not
adequately addressed by the Los Alamos report.
     3. The group at Los Alamos used a computer model to estimate       1011/15
plutonium transport rate by advection-dispersion analysis. In
order to account for preferential flow, the investigators
increased the assumed flow velocity by a factor of 2. In the
report, they cited research which had found accelerated solute
transport rates at 5 times the predicted rates. Why did the
investigators -choose a factor of 2 instead of the more
conservative factor of 5 in the model runs? Why were the
accelerated rates not applied with the piston flow model?
     4. Experiments conducted at Los Alamos to estimate the             1011/16
plutonium sorption characteristics of the Pullman soil used only
the A (upper) Horizon of the Pullman soil. These samples were
air-dried and sieved to obtain particles in a given range
(Appendix A). Sieving eliminates the soil's characteristic
structure (aggregates, etc.) from the tests. Since the A horizon
was all that was tested, sorption properties of lower horizons
are not known. Can we reasonably assume that undisturbed field
soils will behave like the samples tested in the experiments?
As a research engineer involved in modeling of soil-water flow,         1011/17
I must point out that models are only as good as the data and
assumptions that are put into them. They can only provide
estimates of soil water behavior according to the understanding
of the model developer. The performance of a model in a
particular application is limited by the quality of data used to
describe the specific site conditions to the model.
I recognize that my questions are directed to increase
conservatism in estimates of groundwater pollution risk. I feel
that in a project of such great importance, and with such great
potential for damage to the environment and to the people in the
Texas panhandle, that this conservatism is appropriate. It is
reasonable to expect the D.O.E. to provide best-case and worst-
case scenarios. It is reasonable to investigate the history of
Pantex's environmental stewardship.
The health effects of long-term, low-level radiation exposure are       1011/18
not known. If an accident occurs at the Pantex facility, the
economy of the entire area is at risk.                                  1011/19
I thank you for your consideration of these issues. If you wish
to contact me for further information, please contact me at (601)
324-4341 or at (601) 323-0871.
                                  Respectfully,
                                  Dana O. Porter
                                     Sam Day
                                     2206 Fox Ave.
                                     Madison, WI 53711
                                     January 15, 1993

Part 1012

Figure (Page 1 of Part 1012 Hand writing text)
Figure (Page 2 of Part 1012 Hand writing text)
Figure (Page 3 of Part 1012 Hand writing text)
Figure (Page 4 of Part 1012 Hand writing text)
Figure (Page 5 of Part 1012 Hand writing text)
Figure (Page 6 of Part 1012 Borger News-Herald)
Figure (Page 7 of Part 1012 Feedlot %Figure (Page 7 of Part 1012 Feedlot & Packing Plant Locations)
Figure (Page 8 of Part 1012 Feedlot 1990)
Figure (Page 9 of Part 1012 Lake Meredith)
Figure (Page 10 of Part 1012 Ogallala Aquifer)

Part 1013

Figure (Page 1 of Part 1013 Hand writing text)

Part 1014

Roger Mulder
Director, Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Capitol Station
Austin, TX 78711
  Re: Environmental Assessment, Plutonium Storage, Pantex
Dear Roger Mulder:
  I write as a director of Nukewatch, a nonprofit public interest
group which conducts educational programs about the danger of
nuclear weapons and nuclear war. One of these programs tracks and
publicizes the movement of unmarked U.S. Department of Energy
nuclear weapons convoys over the streets and highways of Texas and
other states. Most of these convoys originate and terminate at the
Pantex plant near Amarillo, which is the final assembly point for
all these weapons of mass destruction.
  Paradoxically, Nukewatch's goal of educating the public about           1014/1
nuclear dangers would best be served by the Department of Energy's
proposal to store 20,000 or more nuclear weapon plutonium pits at
Pantex. The concentration of so much destructive and deadly
material in one place would facilitate our job, especially in the
Amarillo area, of educating the public about the local impact of
nuclear weapons production. Such an outcome would help us in our
work of making Amarillans and other Texans more aware of the use to
which their soil is being put in the manufacture and storage of
weapons of mass destruction.
  We believe, however, that the public interest would be better
served by taking an alternative step more likely to lead from.
storage to destruction of plutonium residues of the nuclear weapons
now earmarked for disassembly. Rather than store the plutonium pits
at Pantex, where they could readily be used later for new nuclear
weapons or for plutonium-based breeder reactors, it would be
better to store them at the Savannah River Plant, where facilities
now exist for vitrification of the plutonium in a way which makes
recovery of the plutonium virtually impossible.
  We strongly suggest as part of this proposal that plutonium
storage capacity not be increased anywhere and that plutonium
reprocessing/vitrification capacity be expeditiously enhanced at
the Savannah River Plant or some other appropriate site so that
non-retrievable disposal of the plutonium can keep pace with
retirement of the weapons. Thus, we can "lock in" the results of
current and future SALT agreements and nuclear disarmament accords.
Roger Mulder                      -2-                 January 15, 1993
  When ratified by the U.S. Senate, SALT and other nuclear weapons
reduction treaties will constitute a clear mandate to destroy
nuclear weapons, not to hold their key elements--the plutonium
pits--in indefinite "interim storage" for possible later re-
assembly into nuclear weapons. Any storage proposal which fails to
provide for simultaneous non-retrievable disposal appears to border
on negation of the START agreements.
                                Sincerely,
                                SAMUEL H. DAY, JR.

Part 1015

February 20, 1993
Mr. Roger Mulder
Director, Special Projects
Environmental Policy Division
P.O. Box 12428
Austin, TX 78711
Dear Mr. Mulder:
Having been provided a copy of the Environmental Assessment for Interim Storage of
Plutonium Components at Pantex, I read it thoroughly and made notes about the things I
had questions about. My comments are enclosed with this letter.
Sincerely,
Addis Charless, Jr.
Member of PANAL
Pg. 1-1: The statement that PX has conducted its activities in a safe and responsible 1015/1
manner belies the facts of elevated cancer rates of downwinders and retired PX personnel, 1015/2
eligibility for being considered as a Superfund Site, and pollutants existing in the soil to a
depth of about 329 feet-a scant 40 feet above the Ogallala aquifer.
Pg. 2-1: The estimated interim storage period of 6-10 years is questionable if only for 1015/3
the DOE's assurances in times past of a "temporary" anything.
Pg. 3-2: Some proposed multiple stacking configurations have in mathematical formulas 1015/4
approached 80%-90% of criticality.
Pg. 4-3: Hanford, with modifications, could store approximately 10,000 pits. Some 1015/5
knowledgeable persons have suggested that Hanford may become a "national sacrifice
zone". Would not Hanford then be a more appropriate storage site? If suitable for no
other purpose, why not put the pits there?
Pg. 4-5: Storage capacity at PX would be reached by the 4th quarter of '93 to the 2nd 1015/6
quarter of '94. The AEDC has offered $5.5 million for additional land purchases to be
deeded to the DOE-how many families might this affect? This has come about after it was
stated that no additional land would be needed for PX expansion.
Pg. 4-6: Table 4-1 does not mention Kirtland AFB/Monzano Mtn. as a possible storage 1015/7
site despite their storage capabilities. Why was the above complex not considered?
Pg. 5-1: PX storage storage magazines employ natural ventilation. Any accidental leakages 1015/8
would be vented to the atmosphere for dispersal by the winds to who-knows-where: the
Canadian river, Lake Meredith, the assorted playa lakes of the area, and by subsequent
percolation/infiltration, most likely into the Ogallala aquifer.
Pg. 5-2: Scientists are continually lowering the levels that are deemed to be safe, and 1015/9
arguments abound that in the long run, no levels of radiation are truly safe. Witness the
current concerns being voiced about naturally occurring radon accumulations in our area's
basements.
Pg. 6-4: If annual collective worker radiation doses increase but Federal individual 1015/10
worker exposure limits are not exceeded, it logically follows that even more workers will be
at risk for radiation-induced cancer.
Pg. 6-5: If a forklift accident occurs, conservative calculations show .57 mg of Pu 1015/11
escaping into the atmosphere. A lethal inhaled dose of Pu is a scant one-billionth of a gram.
Pg. 6-6: The light aircraft penetration probabilities were all modeled on low-speed/low- 1015/12
angle-of attack scenarios. Not considered was a high-speed/perpendicular angle-of-attack
scenario induced by vertigo such as occurred near my residence a few years ago. The
aircraft engine in the above incident penetrated a hardland slope to a depth of 3-5 feet.
Also not considered was a similar situation involving commercial multi-engined craft or
heavy military craft which seem to be in abundance in our air space.
Pg. A-2: Table A-1 states the possibility of internal fire as being "not possible or 1015/13
plausible at this site or facility". However, an earlier statement in this EA document
considered a forklift accident scenario in which Pu escaped its confinement. Since Pu is
pyrophoric (burns on contact with air), a very real internal fire possibility exists.
Additionally, chemical/toxic gas releases have occurred, the incidents having not 1015/14
been made public until well after the fact, if at all.
Potential Ogallala Aquifer Impacts...: The "preferential flow" arena is by the EA's own 1015/15
admission an unknown regarding flow rates to and effects on the Ogallala aquifer.
Miscellaneous:
Pu is in this EA addressed as 45 years or more old, as if by this advanced age it 1015/16
is relatively innocuous. However, 45-year-old Pu has spent but 1/5,333rd of its total life
before it is an inert substance.
Breakdown/decay/sister products of pu have half-lives of up to 28 billion years.
Since we do not know the long term chemical form of Pu in this ecosystem,
we've absolutely no idea of its effects on the ecosystem. To assume the initial form of Pu
to be an oxide might be correct, or it may be a gross fallacy with a horrible unthought of
effect.
If, because the pits are at PX and where better to have a reprocessing facility 1015/17
than where the pits already are, PX becomes a reprocessing facility for Pu, what will
become of the waste thus generated? For every cubic unit of Pu reprocessed, 17 million
cubic units of toxic waste are generated.
Despite claims by director Steve Walton of the AEDC that vast amounts of 1015/18
water exist for use by industry, such is not the case. Even now, the Canadian River
Municipal Water Authority is purchasing Southwestern Public Service Co.'s water rights in
Roberts County to provide adequate water for its southernmost customers.
If so large a number of pits is to be stored at PX, does that fact not make PX a 1015/19
prime target for terrorists bent at having Pu at any cost?

Part 1016

                                              Route 2, Box 11
                                              Panhandle, TX 79068
                                              February 16, 1993
Roger Mulder
Director of Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Capitol Station
Austin, Texas 78711
Dear Mr. Mulder:
My husband and I live on and farm 960 acres directly across FM 293
from the north side of Pantex. We are downwind of the activities
that occur at the Department of Energy site in Carson County. My
husband was raised on the farm and remembers when the Pantex site
was first taken from his neighbors. I have lived here 31 years
while we raised our family of three children. I hold a Master of
Science degree and have served on numerous councils, task forces,
and committees on both regional and state levels. I have been             1016/1
an observer of the "Pantex mentality" and the "Pantex work ethic"
for many years. I have often seen "damned if I care" attitude por-
trayed by the workers at the plant.
I have reviewed the Environmental Assessment For Interim Storage          1016/2
of Plutonium Components At Pantex and found that its inadequacy
to be typical of the "Pantex attitude". The plan does not adequately
address the health and safety of either the workers or the peoples
living near the Plant. The plan contains much false information
and lack of accurate information to conclude the storage of pluto-
nium in any amount to be safe. Examples of this are "none of the           1016/3
other DOE sites is considered reasonable"Executive Summary p. vii.
Yet section 4 contains several possibilities. The plan also as-           1016/4
sumes the worst possible had would be the skidding crash of a
light aircraft weighing 3500 pounds. The accompanying information
in section E to support that assumption contains many inaccuracies.
Most aircraft flying directly over the site are of the large mili-
tary aircraft such a the B-1, C-130, C-141B, F-111, T-38, which
are practicing "touch and goes" at the former SAD base Amarillo
International Airport. By the time the larger aircraft are over
Pantex, they are committed to land. Large military helicopters
fly directly over the area regularly too. Any aircraft that is            1016/5
likely to crash on Pantex is most likely to be a high angle impact
instead of the 3 degree skidding crash. Fuel spills ad subse-             1016/6
quent fire or explosion resulting from such a crash are not adequately
addressed.
There is nothing about the storage that really needs to be classified.    1016/7
The storage and management of all plutonium must be review throughout
Page 2 EA Pantex
the DOE complex should be addressed through an environmental impact
statement for all facilities.
The EA only addresses storage in Zone 4 magazines. Are there other        1016/8
places on the site to store Pu? If so, why aren't they being addressed?
Radiation is not adequately addressed. The exposure of workers will       1016/9
be much greater with realistic time frames for inspection. There
is no way workers can make a full visual inspection of storage
containers in one minute, especially taking into account the re-
moving and replacement of the container (F-1.3.). The long term
exposure of low levels of radiation to workers and/are peoples
living nearby are are not addressed. A one time exposure is
a lot different than an exposure of low levels 24 hours a day for
months and years. What are the cumulative effects? DOE must             1016/10
answer. Doe must do a full EIS.
Is there independent quality control on the containers? What are        1016/11
"other approved containers"? The EA must address these questions.
What does DOE plan to do with the Pu after six to ten years? Are        1016/12
they planning a reprocessing facility at the Pantex site? The
amount of water available will not be sufficient for this. If the       1016/13
transportation of the Pu is too dangerous to move, how safe can the     1016/14
transportation of bringing the warheads to Pantex be? Maybe it's
best to just dismantle them and store the components right where
they are.
At what point will natural deterioration of the containers, Pu,         1016/15
and storage area occur? How will radiation effect the containers
and the storage area? Will radiation cause more rapid deteriora-
tion of the concrete, the steel, or even the gravel and dirt of
the magazines?
If the Pu would have to be repackaged into Type B shipping contain-     1016/16
ers for shipping (4.1), why can they not be stored in the Type B
containers as stated by 3-2.
Section 4.4 c states "decentralization of storage could effect a net    1016/17
increase in the expected radiological worker exposure over the proposed
action... Ah ha, there is danger to the workers and to the public
after all. The entire EA tells us there is no danger of excess
exposure at Pantex, but here we learn the same Pu in smaller amounts
at other sites creates a danger. Which is it? DOE must do a full
EIS to know.
As Dana 0. Porter soil and water conservation engineering specialist    1016/18
at Mississippi State University says, the EA is lacking in basic
information that the DOE needs to accurately determine the safety
of the proposed storage of Pu at Pantex. The scope is too narrow.
Extremes of the weather are very conservative. Section 5-1 states
Page 3 EA Pantex
the prevailing wind direction is from the south-southwest with an
averse wind speed of 14 mph with occasional gusts of up to 70 mph.
The weather bureau at National Weather Service says the annual average
is 13.1 mph at a 230 degree true direction. Wind gusts have been
recorded in excess of 100 mph. On September 3, 1968, a wind gauge
on the Pantex site registered 113 mph before it broke. We have observed
numerous tornados, funnel clouds, and massive wall clouds both near
and over the plant. In June, 1992, a tornado crossed from our tail
water pit into the plant before lifting near Firing Site 4. Two very
large wall clouds were seen over the plant and our home the same week.
In May, 1991, a tornado moved from just west of Panhandle directly
toward the eat gate of Pantex before lifting just before it got
there.
Also, section 5.1 states that surface runoff flows into several         1016/19
playa lakes on the site. Runoff also comes out of the plant on
the north into the barrow ditches that drain into the Pratt lake
one-half mile to the north of the plant. Pratt lake also catches
lots of water running down the draw by the old sewage plant. Debris
is often caught on the barbed wire fence in the draw.
Section 6.1.2. states that "the expected level of penetrating radia-    1016/20
tion would result in no measurable effect or exposure to an individual
occupying a position for an entire year at the nearest Pantex site
boundary. Such a level would be indistinguishable from natural back-
ground radiation." Since this "individual" is either me or a member
of my family, I question if the Pantex operations and storage of Pu
and other radioactive activities may be adding to the background
radiation. How does long term exposure to low levels affect us?
Appendix A-1 does not mention a possible terrorist or high priority     1016/21
military attack. With the storage of Pu, manufacturing of HE, ad
capability of assembling weapons, would not Pantex be a prime site
for these events? A-5 does not mention any possibly of an explosion     1016/22
caused by a forklift penetrating a container causing great heat by
friction or the possibly of an exploding battery or other electrically
short.
The report mentions the "conservative" figures numerous times a         1016/23
in the recharge rates of the Ogallala Aquifer. Why weren't the
higher rates used? If the rates of 1.3 to 8cm/year, why use 3
cm/year? If the higher rate is possible, it should be used.
In Appendix E, numerous mathematical errors are on the "conserva-        1016/24
tive" side. These tend to bring the credibility and validity of
the EA into question.
We believe the United States Department of Energy must proceed to       1016/25
initiate an environmental impact statement (EIS) on the issue of
plutonium storage and management at Pantex and throughout the
DOE and DOD complexes. The questions raised because of the in-
adequacy and inaccuracies of the draft must be answered prior to
the storage for even the six to ten years proposed. We must
Page 4 EA Pantex
be certain, without a doubt, that the interim storage of plutonium
at Pantex is completely safe for the workers at the plant, the
peoples living nearby and in the area of the plant, and for the
Ogallala Aquifer and perched water zones. The highly productive
agricultural lands and livestock must be safe also.
To ensure the safety of the peoples and of the environment, we          1016/26
request that the DOE post a bond in the amount of at least
$200,000,000. This bond would be used to help pay damages in
case of contamination or destruction of any private property,
crops, livestock, as well a bodily injury or death of a per-
son or persons outside the perimeter of the plant. Property
owners and/or their heirs must be compensated for their loses.
Thank you.
                                 Jeri Osborne

Part 1017

                                                  Route 2, Fox 11
                                                  Panhandle, Texas 79068
                                                  Feb. 15, 1993
I am Jim Osborne, I live Just across the Farm Road 293 north of
Pantex. I farm 960 acres just north of the Pantex Plant. I own
part of the land and rent part of it. I would like to respond to
the Environmental Assessment for Plutonium Storage.
After reading the EA, I visited with a former Pantex employee who          1017/1
also read the EA. He told me that at the time he worked there,
they were only allowed to store 32 or 40 pits per igloo instead
of the 270 to 400 04 440 pits they are proposing to store or stage
now. He said he felt that monitoring on an 18 month basis is not           1017/2
nearly often enough and that the number of containers proposed to
be monitored is not nearly enough. He also wants to know if the            1017/3
pits are to be segregated according to type for storage or will
they be stored randomly? He said there is not way that workmen can         1017/4
remove, inspect and restore a container per minute. He said it
would take hours and hours to remove all the containers to get to
one near the rear of an igloo and that worker exposure would be
too great. He also said that the new stainless steel containers            1017/5
shown to the media are apparently brand new and most pits are stored
in the old style carbon steel containers that will rust and deteri-
orate faster. He said the packing material shown to the media is
all new to him and apparently both the stainless steel containers
and the packing material are new since the EA was written.
In regard to Appendix A- Screening of potential accident initiating
events:
Internal explosions --Plutonium pits implode; not explode. Forklift       1017/6
                      batteries may explode.
Internal Fires      --Plutonium is combustible in the presence of         1017/7
                      oxygen. How about electrical fires from an
                      electric forklift?
                      How about heating and or air conditioning in
                      Work area Bay #8 where storage is now being
                      done?
                      How about wooden pallets? They burn.
Lightening Strikes  --How about static electricity from nearby             1017/8
                      lightening strikes and static electricity
                      from wind?
Loss of Power       --Would gasoline or diesel powered generators         1017/9
                      be used to light the storage area if power
                      is lost from commercial supplies?
Page 2  EA
Missiles            --How about guided missiles from enemy forces         1017/10
                      or from terrorists? It appears to me that
                      20,000 pits would make the storage area a
                      very high priority target.
                      How about missiles from a test firing or from       1017/11
                      an HE press accident? We know these kinds of
                      accidents have happened in the past. We know
                      of at least three.
Sand storms and     --How about static electricity? How about             1017/12
  Dust storms         missiles from high winds? The day before
                      Labor Day (Sept. 3, 1968 or 1969) we had a
                      wind storm that took a four mile wide swath
                      of high voltage electrical lines and poles
                      and roofs from homes and machine sheds and
                      barns. One Pantex employee at that time told
                      me that the wind speed indicator at the plant
                      registered 113 mph before it broke. Also
                      there were reports of as many as 7 funnel
                      clouds reported in that storm. He said after
                      he saw a 55 gallon drum go over the administra-
                      tion building that it was time to go to the
                      basement.
Transportation      --Electric fork lifts may catch fire --Batteries      1017/13
    Accident:         may explode from either fire or overload.
                      Trucks could be involved in collisions, catch
                      fire or be turned over by high winds.
C 1.2 SAC Magazines  -What if a terrorist dropped an explosive such       1017/14
                      as a grenade down the ventilation pipe?
C.2 Aircraft        --The EA uses as an example a 3500 pound aircraft     1017/15
                      at 80 miles per hour. What about a 200,000
                      pound aircraft at 500 or 600 mph?
                      I heard an F111 crashing into a mountain. The
                      plane weighs approximately 75,000 pounds and
                      flies at speeds in excess of 600 mph. The body
                      of the plane basically stayed on the side of
                      mountain but the engine shaft augered itself
                      150 feet through solid granite.
Fork Lift Accident  --If, as the EA suggests, the container is punc-      1017/16
                      tured and the pit crushed, plutonium would be
                      exposed to air. Friction from the fork lift
                      tine penetration of the pit could cause spontan-
                      eous combustion. The workers would be exposed
                      to fire and smoke as well as plutonium dusts.
                      Presuming that the door of the magazine was open,
                      the surrounding area and people could also be
                      exposed.
Page 3  EA
Storing Pits in     --Electrical power for lights, air conditioning       1017/17
  Assembly Bay #8     and heating is present in the work bays.
Work Bay #1         --Still not cleaned up since the tritium leak         1017/18
                      in 1989. I understand that they have tried
                      to clean it up, but it still will not meet
                      specs and they are talking about tearing it
                      down.
I know one breech block from a 16 inch naval gun has been blown up. I     1017/19
have heard that at least three high explosive presses were also blown
up over the years. These accidents could provide missiles for pene-
tration of the igloos and possible fires.
I would like to call for an Environmental Impact Statement.               1017/20
I don't think there is enough water available for reprocessing in         1017/21
this area. Amarillo has drilled at least 7 dry holes in their water
field in northern Potter County. The Carson County field where the
city is now pumping its water is rapidly declining. Our static level
in our wells had dropped four feet this past year and at least one
of the Amarillo wells dropped 12 feet.
I would also like for DOE to post a $200,000,000 bond to be forfeited     1017/22
in case of contamination or destruction of any private property, crops,
or livestock or bodily injury or death of a person or persons outside
the perimeter of the plant. This bond should pay property owners or
their heirs for losses incurred.
Thank you.
                                  Jim Osborne

Part 1018

Bob Bullock
Lieutenant Governor of Texas
The Capitol
Austin, Texas 78711-2068
(512)465-0001
January 20, 1993
Mr. Richard A. Claytor
Assistant Secretary for Defense Programs
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C. 20585
Dear Richard:
Two members of my staff attended the Department of Energy briefing for the State of
Texas on January 14, 1993, and told me that your agency did an excellent job
presenting complex information. They also said that you invited further questions.
And I have some.
The briefing included a technical presentation regarding the risks of plutonium 1018/1
contamination to the Ogallala Aquifer, but did not cover contamination of surface
water. I would appreciate formation regarding the risks and the potential
consequences of contamination to surface water and soil.
Since increasing the number of pits will necessitate additional handling and 1018/2
transportation, I would like information about any increased risk of human error or
accident resulting in localized spillage or contamimination.
I would also like information regarding the proposed consolidated nuclear unit, its 1018/3
functions, and the criteria that will be used in deciding its location. Thank you for
your time and courtesy.
Sincerely,
BOB BULLOCK
Lieutenant Governor
BB:sww

Part 1019

                             OPERATION COMMONSENSE
                                January 20,1993
Mr. Roger Mulder
Director, Special Projects
Environmental Policy Division
Office of the Governor
Austin, Texas 78711
Dear Roger,
      I recently received a copy of the Environmental Assessment regarding
the proposal to increase the storage of plutonium at the Pantex Nuclear
Weapons Plant near Amarillo, Texas. You asked for comments on the
assessment documents, and while this letter will address the subject, it is
not meant to be comprehensive due to time constraints. This                       1019/1
environmental assessment sets forth operations more properly designated
as a new mission, from holding plutonium in inventory for current use, to
holding it in storage with no planned use. l believe this is a very important
distinction, and might well require additional disclosure and public comment.
      Our concerns are solely with the impact of your plans on Amarillo and
the surrounding area. It is obvious from the assessment that this new
mission has not been previously tested and that the storage plans set forth
involve varying degrees of risk and uncertainty. There appear to be               1019/2
differences in the relative degrees of protection provided by the two types
of storage containers for the plutonium pits. There also remains a critical       1019/3
need for detailed analysis of the comparative stability of the 18 Modified-
Richmond magazines vs. the 42 Steel Arch Construction (SAC) magazines
and the overall adequacy of magazines built 50 years ago to hold
conventional bombs. Moreover, differences in the density of storage               1019/4
(number of pits) in each magazine could impact the degree of risk as well as
the ease and safety for inspection tasks. The risk assessment analysis also       1019/5
appears to have overlooked the most likely danger, that of an attack on the
arsenal by an enemy or terrorist. Additionally, incremental risks created by      1019/6
   P.O. Box 9618 * Amarillo Texas  79105 * 806-372-3877 * Fax 806-372-7207
extending the storage period longer than 10 years is not assessed, nor is
the method of indemnification provided this community that the period will
not be longer than 10 years. Temporary storage fails to be credible
without the designation of a permanent storage site, if past histories are
to be believed.
      Our interest is simple and straightforward. We want first and               1019/7
foremost to assure that the risks to the community are acceptable. The
dangers that have been brought to many communities by the weapons
plants have been clearly established, and it is only reasonable that we
consider that history in our own assessment of this operation. The
community's confidence in assurances of safety can only be confirmed with
independent monitoring and the willing acceptance by DOE of applicable laws
of our land. We must all be comfortable that a supervisory structure is in
place that will provide technical oversight as well as community liaison. A
clear delineation of this need will require a cooperative effort involving DOE,
the State, and our community.
      While I believe most of us in the community can be convinced of the         1019/8
safety of the plan, there will be many outside the community who will be
hesitant to locate in this area because they are wary of the unknown or
unproven. There will be little doubt that the future growth of business in
Amarillo and the surrounding area will suffer with the public knowledge of
the storage of these pits. This probability creates the need for DOE to
assert an active and effective role in planning and assisting Amarillo in
maintaining the growth we have every right to expect, not withstanding the
plutonium storage plans. Active help from DOE in directing certain highly
desirable non-nuclear government operations here or funding to assist us
in recruiting new businesses is appropriate and necessary.
      Roger, your role and that of the Governor are critical to the success
and acceptance of this mission. Funding provided the State by DOE should
not be allowed to exceed actual expenditures by the State. This policy will
prevent any conflict of interest from developing between the financial
interest of the State and the safety needs of the Panhandle. Your role can
and should be that of facilitator and enforcer of guidelines necessary to a
safe mission.
   P.0. Box 9618 * Amarillo, Texas 79105 * 806-372-3877 * Fax 806-372-7207
      It is our hope that Pantex, including future missions, might remain
always a welcome member of our community. This possibility can become
a reality through the implementation of a two point strategy set forth in this
letter. We will be responsible for doing everything within our power to work
with the State and DOE to accommodate our mutual needs. We are looking
forward to opening a dialogue that will result in a positive future for all of us.
                                                Sincerely,
                                                W.H. O'Brien
cc:        Vicky Battley
           Steve Guidice
           interested parties
   P.O. Box 9618 * Amarillo, Texas 79105 * 806-372-3877 * Fax 806-372-7207

Part 1020

                              State of New Mexico
                             ENVIRONMENT DEPARTMENT
                            Harold Runnells Building
                     1190 St. Francis Drive, P.O. Box 26110
                           Santa Fe, New Mexico 87502         JUDITH M. ESPINOSA
                                 (505)827-2850                    SECRETARY
BRUCE KING                                                        RON CURRY
 GOVERNOR                                                      DEPUTY SECRETARY
  February 4, 1993
  Roger Mulder, Director
  Special Projects Group
  Environmental Policy Division
  State of Texas
  Office of the Governor
  Austin, Texas 78711
  RE:  EA for Interim storage of Plutonium Components at Pantex
  Dear Mr. Mulder:
  The Hazardous and Radioactive Materials Bureau of State of New
  Mexico's Environment Department has reviewed the Department of
  Energy's Environmental Assessment for the Interim Storage of
  Plutonium Components at Pantex. Given that the proposed activity        1020/1
  evaluated by this assessment is an enlargement of activities which
  have been on-going at the site for the past 40 years, the document
  seems to adequately addresses any associated environmental impacts.
  The proposed action seems to be the most favorable of the
  alternatives considered for interim storage. Of greater interest
  to the state of New Mexico is the long-term storage/disposal
  options being considered for these components, as presently under
  consideration in the Programmatic EIS for the Nuclear Weapons
  Complex Reconfiguration. The state of New Mexico would appreciate
  any future documentation on plans for long term storage including
  transportation impacts.
  Thank you for providing an opportunity to comment on this proposal.
  There is much to be gained through our states cooperation in
  resolving environmental problems.
  Sincerely,
  Benito J. Garcia, Chief
  Hazardous and Radioactive Materials Bureau
  BJG:JWP
       cc: Ray Powell, Special Asst. to Governor
            Kathleen Sisneros, Director, Water and Waste Mngmnt, NMED
            Neil Weber, DOE Oversight, NMED
            John Parker, Mixed Waste Section, HRMB-NMED

Part 1021

PHYSICIANS FOR SOCIAL RESPONSIBILITY
An affiliate of International Physicians for the Prevention of Nuclear War, winner of the 1985 Nobel Peace Prize
25 January 1993
Roger Mulder
Director, Special Projects
Environmental Policy Division
State of Texas
PO Box 12428
Austin, Texas 78711
Dear Mr. Mulder,
I respond to your draft of an Environmental Assessment prepared by the
U.S. Department of Energy (DOE), a proposal to increase the storage of plutonium
(Pu) at the Pantex Nuclear Weapons Plant sent to Governor Richards. Thank you
for inviting me to comment. I hope my comments are somehow useful but, quite
frankly, responding in 45 days really pushed my ability to read, digest and
criticize a very complicated proposal, much less prepare a response.
First of all, we should remember that a reduction from more than 20,000
nuclear warheads to somewhat less than 10,000 as ordered by the President
still leaves the world with enough explosives to make the planet uninhabitable
and unrecognizable. We should also remind ourselves that we Texans have had
Pantex in our State for many decades without showing much concern for the
hazards of preparing for war. Therefore, we should approach this problem with
humility and vigor. We should consider ourselves as part of a dreadful problem
which we are dumping on future generations of animals, plants and humans and
thus demand of ourselves very tight restrictions on what is done at Pantex.
We should insist that the storage of plutonium (Pu) in Texas should be 1021/1
TEMPORARY. The DOE mentions six to ten years but the text gives no details of
how this will be terminated, no description of research going on to prepare for
storage elsewhere. We are planning to store 84,000 pounds of a deadly poison 1021/2
which will remain deadly for thousands of years. While Pu is stored at Pantex,
it should be very visible and under close scrutiny by Federal Government officials,
Texas officials, and local Amarillo and neighboring county officials as well as
concerned citizens. Personally, I would hope the Governor would really stress
citizen involvement. We should know that breeder technology and Pu fuel cycle 1021/3
nuclear programs are not working well because of safety and economic problems
so we can anticipate a big increase in the inventory of Pu in other forms than
warheads. We should not set Texas up for this kind of storage. Are you aware 1021/4
that Hanford originally prepared "interim storage" which then became the de facto
standard for storage for the U.S. The limits of TEMPORARY should be very carefully
spelled out.
One reason why citizen and local government interest is so crucial is that 1021/5
the DOE has been working for five decades in a shroud of secrecy and a war
threat mentality spending their time preparing weapons and much less time, quite
insufficient time, on the protection of the environment. When the DOE reports
Dallas Office c.o. Department of Anesthesiology, Parkland Memorial Hospital, Dallas, Texas 75235 Telephone: (214)590-8536
National Office: 1000 16th Street, N.W., #810, Washington, D.C. 20036 Telephone: (202)785-3777
-2-
that Pantex has been run in a "safe and responsible fashion for 40 years", they
conveniently leave out the management of the plants at Rocky Flats in Colorado
and Hanford in Washington. The DOE has a bad reputation for environmental and
health hazards. Remember, considerations other than safety will be considered,
e.g. timeliness, cost and efficiency in using space already available.
We are aware of massive safety problems at various other DOE sites, 1021/6
problems which will take decades to clean up, billions of dollars, and probably
a number of injuries to personnel. Knowing that, do we want the DOE to store
Pu pits in magazines when Pantex does not have expertise in this? Governor
Richards should wonder, why experiment with Texas? Why not experiment at
Rocky Flats where the pollution levels are already severe? Or Hanford? Or
half a dozen places where the DOE has polluted? Or, why not some place where
the military has polluted?
DOE writes that radiation exposure of workers will be controlled as 1021/7
currently done with procedures and monitoring to insure DOE present standards
are maintained so therefore no adverse health effects among workers should be
expected. In their search for the possibility of accidents, they mention aircraft
crashes, forklift accidents, earthquakes, tornados and missiles, all of which
are listed as requiring quantitative analysis. There is no mention of a psychotic
terrorist or a thief wishing to sell Pu to the Japanese.
The DOE points out that using the safer method of storage will fill up the 1021/8
present storage areas this year while the less safe method will fill it up by
the summer of 1994. That horizontal, palletized multiple stacking has not been
used before in either the Modified Richmond or the steel arch constructed
magazines rather implies that the DOE has not previously thought about storage
of Pu pits, does it not? No mention is found in their text of any research 1021/9
about long term storage or destroying -modifying Pu, all projects which a
responsible DOE would have done decades ago if their sense of responsibility
had been toward the environment rather than toward military power. The DOE 1021/10
has not used EPA or OSHA standards for their work.
DOE could use other sites as well as Pantex but this would add the hazard 1021/11
of transportation. I find this interesting since they have said this hazard is
virtually zero for years. The advantage of storing at multiple sites and doing
it visibly, however, would be that numerous communities would then become
involved in this dreadful problem. Do you have nightmares thinking of having
to trust the Government with the storage of Pu for a half-life of 26,000 years?
This risk of trusting our Government is clarified by a marvelous euphemism on
page 4.3, "The primary mission of Hanford is environmental restoration." This 1021/12
same DOE has supported legislation to relax environmental protection laws
governing the removal of toxic wastes. Change the words and the problem goes
away. The same DOE has stifled research and whistle-blowing among employees.
Secretary Watkins has said he "never got his arms around" the problems at DOE.
DOE now plans for some oversight by outside organizations, the Department of
Health and Human Services and the Department of Health for the State of Texas,
for example, which sounds great but the DOE is not accustomed to outside scrutiny
so this should be spelled out very carefully. In their text it is not spelled
out at all.
Their reference to threats to the Ogallala aquifer is internal DOE research 1021/13
by Turin et al from the Los Alamos National Laboratories so it is no wonder they
concluded no risk would occur to the aquifer. The DOE cites no local criticism.
-3-
There is no reference to Coy Overstreat who has been collecting cases of atomic 1021/14
radiation victims for years. The search for potential problems seems thoughtful
but there is no mention of previous complications. I would recommend the
Governor insist upon a careful evaluation of all previous accidents, injuries
and environmental abuses which have occurred at Pantex and other DOE plants
before permitting even one Pu pit to be stored in Texas.
There is no mention of security, yet Pantex has had security problems in 1021/15
the past. What are their plans to prevent a terrorist attack? Or a thief who
wishes to steal a Pu pit? I am sure the black market would have good prices
for Pu pits. Let me repeat that research on the disposal and security of Pu 1021/16
and Pu pits should have been under way for decades. This problem is chronic
and is not going to go away. Therefore, we should slow the DOE down and
demand more thorough preparations and research before doing anything. I know
that this will leave us with bombs sitting in their silos but, if the State of
Texas can make these silos public and keep the Pu pits in the minds of alert
citizens, we will have performed a real service for all the world. Keep in
mind that storing these pits at Pantex permits the Government to restart making
bombs again before anyone had time to wonder why trucks were carrying Pu pits
back to Texas again.
I have mentioned that research cited has come from DOE sponsored labora- 1021/17
tories and is therefore suspect. I recommend some outside reading:
1. Peter Gray (editor): FACING REALITY: the future of the U.S. Nuclear Weapons
Complex, a project of the Tides Foundation, San Francisco (copies may be
obtained from the Nuclear Safety Campaign, 1914 North 34th street, suite 407,
Seattle, WA 98103).
2. Anthony Robbins, Arjun Makhijani, Katherine Yih: RADIOACTIVE HEAVEN AND
EARTH: the health and environmental effects of nuclear weapons testing in, on,
and above the earth. Apex Press, N.Y. 1991.
3. H. Jack Geiger & David Rush: DEAD RECKONING: a critical review of the Depart-
ment of Energy's epidemiological research. Physicians for Social Responsibility
1992.
4. Arjun Makhijani and Scott Saleska: HIGH LEVEL DOLLARS, LOW LEVEL SENSE: a
critique of present policy for the management of long-lived radioactive waste
and discussion on an alternative approach. Apex Press, 1992.
5. Nicholas Lenssen: NUCLEAR WASTE: the problem that won't go away. Worldwatch
Paper 106, December 1991.
6. Howard Hu, Arjun Makhijani, Katherine Yih: PLUTONIUM, deadly gold of the
nuclear age. International Physicians Press, 1992.
1021/18
I conclude that the 40 years of "responsible and safe" work done at Pantex
cannot be extrapolated to a future of ten years of storage of Pu. I also conclude
that the DOE has a long history of secrecy and willingness to take risks which have
harmed the environment and the health of workers and neighbors. So, go SLOW! We
should involve the Peace Farm, the Red River Peace Network (which has a team being
developed right now) and the Texas Nuclear Responsibility Network.
PEACE!
Lawrence D. Egbert, MD, MPH
PSR/Dallas Coordinator

Part 1022

HEAL
Hanford Education
Action League
February 11, 1993
Roger Mulder
Director, Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Austin, TX 78711
   Comments on the Environmental Assessment for Interim Storage of Plutonium
                      Components at Pantex (DOE/EA-0812)
Dear Mr. Mulder,
      Thank you for providing HEAL with a copy of the Pantex EA and inviting our
comments. First, some general comments concerning public participation and
involvement:
*   The deadline for comment was not specified in your letter of December 21, 1992.
When did the 45-day period begin and end? Why did you not inform all potential
commenters that the period had been extended to 60 days?
*   I feel it is improper for any state government to act as an intermediary for the federal
government. Yes, the Department of Energy has a very serious credibility problem; but
this situation is not solved by having a state act as a shield. Because of our objection
to this, HEAL is sending a copy of these comments directly to the Energy Department.
*   The Department of Energy should have prepared an Environmental Impact                        1022/1
Statement (EIS) instead of the EA. The proposed action constitutes a change in
mission for the Pantex facility (i.e. interim storage) and, as such, constitutes a major
federal action which requires an EIS under the National Environmental Policy Act
(NEPA).
Specific Comments
p. viii -- HEAL agrees with the Department in that "the reintroduction of a weapons
complex mission (at Hanford) would not be reasonable or appropriate."
p. 2-1 -- Both here and elsewhere in the EA (e.g. compare number on p. vii with those            1022/2
on p. 3-1), there are numerous inconsistencies in the number of pits to be stored at
Pantex. In addition, this same problem of inconsistency involves the storage capacity
of Pantex and DOE's proposed storage levels at Pantex. The Department of Energy,                 1022/3
in coordination with the President and the Department of Defense, should declassify
the Nuclear Stockpile Memorandum. It can no longer be argued that keeping this
information from the American public is in the national interest. The Russian
government knows because of the provisions in the recent START agreements.
         1720 N. Ash * Spokane, Washington 99205 * (509)326-3370 * FAX (509)326-2932
                     HEAL Comments on Pantex EA -- page 2
      p. 3-1 -- DOE has failed to sufficiently define what it means by interim.                  1022/4
      p. 4-1 to 4-7 -- DOE has not presented an adequate examination of the alternatives,        1022/5
      especially regarding the possible security risks of having only one interim storage
      facility. Moreover, DOE has failed to consider the alternative of the construction of a    1022/6
      new DOE facility, or several of them.
      p. 6-4 -- DOE has failed to provide the public with sufficient information to assess the   1022/7
      Department's safety analysis. DOE has refused to make available to the public the
      most recent version of the Pantex Safety Analysis Report. Additionally, the recent
      recommendation (93-1, dated January 21, 1993) of the Defense Nuclear Facilities
      Safety Board (DNFSB) raises the possibility that nuclear safety might be deficient in
      those operations involving the disassembly of nuclear weapons. The Board
      specifically cited its concern of nuclear safety at Pantex.
            In conclusion, DOE should prepare an EIS to provide for a more thorough
      examination of all alternatives, more extensive public participation, and sufficient time
      for citizens to prepare comments and the Department to review nuclear safety at
      Pantex (DNFSB recommendation 93-1). Such a delay for EIS preparation need not
      prevent the United States from continuing to withdraw nuclear weapons from active
      deployment as set forth in recent agreements and initiatives. The delay would also
      provide time for public review of the dismantlement study now underway by the Office
      of Technology Assessment.
      Sincerely,
      James Thomas
      Research Director

Part 1024

Jay Robert Roselius
County Judge
Carson County
Box 369 Panhandle, Texas 806-537-3622
March 10, 1993
Mr. Roger Mulder
Environmental Policy Division
Office of the Governor
Sam Houston State Office Building
P. O. Box 12428
Austin, Texas 78701
Dear Mr. Mulder,
I have seen pages and pages of comments concerning the interim storage of plutonium
pits at the Pantex Plant. Most of these comments and concerns are the same as mine,
and I would only be repetitious if I commented on them. These concerns have been
addressed by authorities in the different areas. People who we must place our trust.
People from state agencies, federal agencies and private industries.
However, I would request that authorities from these different agencies be assembled 1024/1
together in their area of expertise and address and formulate the best possible response
to the following areas which seem to me to be the areas of most concern when considering
all of the various comments. The areas are as follows:
1. The chance of contaminating the Ogallala Aquifer.
2. The data used to reach a decision on a plane crash into a bunker/magazine 1024/2
or other strategic location.
3. The question of sabotage/terrorist attack on a bunker/magazine or other 1024/3
strategic location. This could cause a release that would make an
environmental impact.
4. What impact would tornadic winds have on a bunker/magazine or other 1024/4
strategic location.
Respectfully submitted for consideration.
Sincerely,
JAY R. R0SELIUS, County Judge
Carson County, Texas 79068
JRR/wh

Part 1025

                                                 2612 Mockingbird Lane
                                                 Amarillo, Texas 79109
                                                 February 16, 1993
Mr. Roger Mulder
Governor's Office
Policy Council 12428
Austin, Texas 78711
Dear Mr. Mulder:
      As residents of Amarillo, Texas, we are deeply concerned about         1025/1
the activities at the DOE Pantex Plant near our city. To have bombs
assembled there was at best very worrisome but to have a massive dis-
assembly of these bombs and the storage of the highly toxic plutonium
plus other fissionable material seems intolerable. We are most anxious
that the activities at Pantex be examined and monitored and that the
storage of plutonium be especially studied. Proper environment studies
are crucial and the plant should be open to outside expert inspection.
      Does the Panhandle want the title of Plutonium Storage for the
western world? Just how much is known about the storage, how long can
it be stored here and why can't this whole subject be opened to public
scrutiny?
                                             Sincerely,
                                             William and Mary
                                             Klingensmith

Part 1026

February 19, 1993
To the United States Department of Energy
Through the Office of the Governor, State of Texas
P.O. Box 12428
Austin, TX 78711
As a responsible citizen committed to preserving the quality of life for all future generations I
am gravely concerned about the Environmental Assessment prepared by the United States 1026/1
Department of Energy regarding the proposal to increase the storage of plutonium at the Pantex
Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of informed
citizens, it is my opinion that this Environmental Assessment (EA) does not adequately address
the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits
for any period of time is a significant new action that should be analyzed in its own right, and
all reasonable alternatives and environmental impacts should be considered now.
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6 - 10 years.
There appears to be no basis for these figures. Where the pits will go after the ten year period 1026/2
was not discussed. Further, it does not provide assurance that pits will not be stored for more
than ten years.
All of the reasonable alternatives were not considered and inadequate attention was given to
existing available DOE or DOD facilities. As taxpayers we have spent millions of dollars 1026/3
providing warhead and pit storage facilities at Kirtland Air Force Base (Albuquerque, NM., and
the Sierra Army Depot in California.
The draft EA does not analyze the environmental effects of pit storage for more than ten years. 1026/4
There is no discussion on the stability of plutonium pits during interim or long-term storage. 1026/5
The effect on the workers is not adequately addressed in this draft document. It does not 1026/6
explicitly analyze doses to workers who handle the pits in the disassembly areas and those
transporting them from disassembly areas to Zone 4. It does not calculate the doses for the
maximally exposed worker, or the doses to workers if inspections are required more frequently
then every 18 months. Not discussed is the increased worker exposures compared with the 1026/7
current operations, yet it appears those exposures will be several times current levels.
Rather than issuing a final environmental assessment and a Finding of No Significant Impact
(FONSI), the Department of Energ should proceed to initiating an environmental impact 1026/8
statement (EIS) on the issue of plutonium management at Pantex.
Sincerely,
Tamara Swdgrais (sp.)
** Topic: OTA Briefing on Plutonium, Written 6:O4 pm Feb 16, 1993 by fbp
in cdp:nuc.facilities ** To: MPN, From: Steve Schwartz, Re: Summary
of OTA Plutonium Workshop, Date: February 10, 1993
Office of Technology Assessment (OTA) Plutonium Storage Workshop
Peter Johnson (leader of the OTA team studying "Nuclear Weapons
Dismantlement--and its Aftermath): Opened the session by stating that some
form of interim storage of plutonium from retired warheads (i.e. 6-20
years) is needed pending a final decision on what to do with it. He then
asked team member German (pronounced Herman) Reyes to brief the group on
OTA'a research-to-date.
German Reyes; Pit storage at Pantex under existing configurations will
run out in late 1993 or early 1994. DOE has proposed to alleviate this
situation with an EA on a new configuration option.
If Pantex proves inadequate, there is a capacity at other sites--
* Rocky Flats can only handle its own waste and residues;
* Savannah River has two suitable buildings;
* Hanford can store up to 3,000 pits, but this would contradict DOE's
stated intention to end the defense mission there;
* Communications from DOE suggest that underground storage at Kirtland AFB
(NM) or Sierra Army Depot (CA) could be utilized.
DOE insists that the new and increased pit retirement/storage mission is
merely "business as usual" but OTA has found that while the dismantlement
process won't be fundamentally altered, the rate of dismantlement and the
2-3-93 Nucfacil - Page 3
storage of thousands of pits will change the role of Pantex:
* the total number of pits stored at Pantex will significantly increase,
from 6-8,000 up to 20,000);
* DOE's new storage configuration has never been tested and raises serious
worker health and safety as well as public acceptance issues;
* the greater number of pits will result in worker radiation exposures
2-8 times higher than at present, especially from the gamma exposure via
Am-241 decay and neutron generation. DOE's proposed use of shielded
forklifts and robotics must be evaluated;
* moreover, should DOE experiment now with a new configuration before a
final decision has been made on whether or not to use it;
* does DOE need to do a safety analysis report specifically on increased
worker exposures under the proposed changes?
DOE's ability to accurately track plutonium to ensure there are no
criticality problems is unclear.
DOE's lack of a clear timetable for long-term storage has increased
public skepticism about "short term" storage at Pantex.
Criticality issues are not confined to Pantex. At Rocky Flats there are
numerous potential problems, made worse by the fact that there are only 2
criticality safety engineers for the entire plant.
Some 20 percent of the entire U.S. plutonium inventory is in
scrap/residue form, largely at SRS, Hanford, Los Alamos and Rocky Flats
(which has the most). At Rocky Flats there is more than 00,000 pounds of
solid residues containing some 6,000 pounds of plutonium, plus an
additional 14,000 liters of liquid waste containing additional plutonium.
The limited number and size of approved shipping containers for this
type of waste (there is only 1 approved container, capable of holding 2
liters of material) may seriously hamper removing this material from its
current storage sites (this applies only to the type of waste with a low
specific level of radioactivity). Los Alamos, for example, would have to
purchase 10,000 such drums to meet current shipping criteria (which limit
how much combustible material may co-mingle with plutonium).
General Discussion
Jesse Cleveland (USGS, Denver and former member of the Advisory
Committee on Nuclear Facility Safety): I'm concerned that OTA is
discounting storage options at other DOE sites (e.g, Hanford or INEL)
because DOE has indicated that is not the preferred option. By using
existing sites, we could maybe get there faster than starting from scratch.
Also, if the storage medium is in pit form, that's retrievable, and not
just by us.
Peter Johnson: Our consideration of alternative storage sites utilized
DOE's own analysis, but of course those are not set in concrete. We're
assuming interim storage as pits because other options are possible but
will take time to fully implement.
Dewey Large (Scientific Ecology Group, Inc): It may be worthwhile to
study the development of the MRS. That may hold some solutions for this
problem.
Joel Gingold (S.M. Stoller Corp.): MRS may be feasible, but the problem
is that nobody wants it. I'm not sure that the public reaction to pure
plutonium storage would be better or worse than that for spent fuel. And if
we can't do it for spent fuel, it won't work for plutonium pits. Keep the
focus on the current DOE plutonium sites and put it where people have been
living with the weapons for a long time and may perceive a tangible benefit
to being a storage site.
Dave Hafemeister (Sen. Governmental Affairs Committee): If you're
concerned about security risks from storing whole pits, why not spray a
borated plastic/resin into the pit? That would alleviate some criticality
problems and would present any would-be thief with a significant obstacle
to immediate use as a bomb.
2-3-93 Nucfacil - Page 4
Victor Trebulis (Director of DOE's Office of Civilian Radioactive Waste
Management Storage Division): I manage the MRS for DOE. MRS is only
intended for spent fuel. Using it for pits would only increase the public's
perception problems. Many county and tribal studies have concluded that MRS
would be safe and of benefit to them, but the problems seem to be of the
perception kind, and come from those who have less direct involvement with
the potential site. We're still hoping to find a voluntary site.
Peter Johnson: We're only looking at the MRS to see if there's anything
we can learn/use from it.
Charles Haughney (Chief, Source and Containment Devices Branch, Nuclear
Regulatory Commission): Victor is right, our regulations are only for spent
fuel. In any case, using a spent fuel cask for pit storage, even with some
modifications, would be overkill since there is far more intense radiation
from spent fuel than from
pits.
John Trout (U.S. Army Corps of Engineers, Omaha District): As a result
of the Nunn-Lugar language [in the FY92 defense bill], we are assisting the
Russians with the design of their storage facility for plutonium and HEU.
The Russians have indicated that their plutonium will be stored as either
pits or ingots. They are very much interested in this being a long-term,
permanent facility. While the U.S. has only committed funds for design
work, the Russians seem to assume that we'll help build it too.
Lisa Chan (DOE Weapons Complex Reconfiguration Office): The PEIS will
consider long-term storage issues. We expect a draft PEIS by late '93/early
'94, with a record of decision by the fall of `94. Our assumption is that
storage will be in the form of pits.
Dave Hafemeister: Well, that's sort of dumb, isn't it, because if you
decide to mix the plutonium with waste you don't need to build long-term
storage facilities?
Lisa Chan: The PEIS on not site-specific. We're looking at requirements
first end then we'll look and see if we have the facilities we need or if
we need to build them.
Louis Willett (DOE Defense Programs, Office of Weapons and Materials
Planning): The work of the plutonium task force is largely completed, but
the report is behind schedule and is still undergoing internal review. The
scope is near-term storage up to when Complex-21 kicks in. Among the things
it considered were: interim storage, stockpile support end residue
disposition.
John Herczeg (DOE Nuclear Energy): A separate report of the task force
looks at storage options and will be issued by Sal Rosen (NE's Director of
International Programs). The most important considerations we identified in
that report were safeguards, environmental impacts and economics.
Everything else was deemed secondary. I can't characterize this as a DOE
report, since is has not be formally approved/released, but it concludes
that the best way to safeguard the plutonium is to invoke broad policies of
nonproliferation and consider it as spent fuel. The focus is on the options
that produce the most environmentally benign consequences.
Tara O'Toole IOTA): We've found that in making plutonium less of a
security risk, you increase worker radiation risks/exposures.
John Herczeg: What is "most acceptable from a political standpoint" is
to either radiate or "spike" the plutonium and store it as spent fuel. The
goal is to "render it non-usable within certain environmental
considerations. Isotopic poisoning, for example, was found to he
unacceptable.
Paul Cunningham (Los Alamos National Laboratory): OTA needs to get some
criticality expertise. This is not an issue at Pantex. Criticality is
overstressed. Plutonium in ingots is not pyrophoric so long as its
temperature does not reach 400 degrees Fahrenheit. Gamma rays emitted by
Am-241 decay are "relatively soft" and easy to shield against. The neutron
2-3-93 Nucfacil - Page 5
fields generated by a large number of pits is a bigger problem.
My position on this (and I can't speak for the lab) is that this will be
a long process to decide what we should ultimately do with this plutonium.
We should think about who we're making it difficult to retrieve from. Don't
make our waste problems even bigger by adding plutonium to the mix.
"I advocate that we do as little with this material as possible."
Storage in pit form creates the least waste and worker exposure. Pits are
well known, quality controlled items; we know a great deal about them. Yes,
there's a lot of plutonium coming out of the stockpile, but by the time
Complex-21 comes on-line this will be dwarfed by the inventories of
commercial plutonium. Just look at where Japan is heading. As for diluting
plutonium, we won't gain much [in nonproliferation]. We know how to recover
plutonium from any form we can put it in.
And mixing plutonium in with waste will "create a legacy we can't
manage." Pits are compact and they store and last very well in hermetically
sealed containers. With the pits in their storage and shipping containers,
you can't create a critical array of pits in any configuration in the
Pantex igloos.
Duane Schmoker (Pacific Nuclear Fuel Services, Inc.): As with the MRS,
public perception is the key, right up there with technology
considerations. I am assuming this won't be done in secret--although maybe
it will for security considerations--but the times are changing. DOE also
has an effort underway [since 1993] to identity a voluntary site to accept
TRU wastes [as a result of many Governors refusing DOE's request to move
Rocky Flats waste to DOE facilities in their states].
Emilia Govan (OTA): Can you foresee doing a full EIS on pit storage at
Pantex?
Ted Dobry (DOE Defense Programs, Director Pantex Facility Management
Division): [After a long pause] "I think that's a possible outcome." I
helped do the EA and I don't believe there are any technical issues that
would force us to do an EIS.
German Reyes: We asked because the EA has very little information on the
capabilities of the other sites to handle the plutonium.
Bill Shuler (Assistant to the Acting Assistant Secretary of Defense for
Atomic Energy): Is OTA trying to provide just an analysis or will you issue
recommendations?
Peter Johnson: This is just an interim report on where we are today. The
final report has not been written. We will have some recommendations and
options in the final report, which will examine everything related to
warhead dismantlement.
Bill Shuler: Taking an existing facility and making it transparent [open
to inspection for arms control purposes] is harder than building a new
facility with transparency in mind.
Mark Percival (DOE Office of Arms Control): We have a draft report on
transparency at Pantex that consists of guidance for DOE but not
recommendations. I can't tell you more about it until Vic Alessi (Director)
releases it.
John Herczeg: DOE has asked the labs and now five vendors to study
burning plutonium in a reactor. But there needs to be several years of R&D
just to demonstrate the technology, so burning could only really begin in
about 20-25 years (factoring in time to comply with environmental
regulations). The first report from Livermore also took as an assumption
that whatever was recommended would have to be acceptable in Russia. The
fission task force (headed by Sol Rosen) will issue a separate report on
this at some future date.
Paul Cunningham: Accelerator technology is the only way to totally
eliminate the plutonium, The physics are sound, we know
this will work, it's just an engineering problem.
[For the afternoon session, which I did not attend (but which Tom
2-3-93 Nucfacil - Page 6
Clements of Greenpeace, Tom Zamora-Collins of Friends of the Earth and
Steve Dolley of the Nuclear Control Institute did), the group discussed
future plutonium storage approaches. Items for discussion included:
o Types and conditions of materials to be stored and policies to be
followed
o Requirements and design criteria that need to be developed
o Research and testing needed
o Environmental impacts to be investigated
o Site selection process to be developed
o Health and safety studios required
o Security, monitoring and materials accounting studies needed
o Facility construction and operation requirements
***************************************************
From Don Gardner

Part 1027

                                                 822 Oak
                                                 Dalhart, TX 79022
                                                 March 5, 1993
  To the United States Department or Energy
  Through the Office of the Governor, State of Texas
  P.O. Box 12428
  Austin, TX 78711
         As a Texas citizen I am concerned about the storage of
  nuclear material at the Pantex Nuclear Weapons Plant near
  Amarillo, Texas.
                                                                           1027/1
         Have the following questions been adequately answered?
  Has worker safety in all divisions of the plant been adequately
  studied? If so have the recommended safety precautions been
  taken? Have dangers to surrounding farmland and agricultural
  workers been studied? Are there safeguards for the land, it's
  productive qualities and it's agricultural value?
         I understand that this is interim storage for a period            1027/2
  of 6 to 10 years. What happens to the plutonium and other
  nuclear materials after ten years? Are there available                   1027/3
  sights for storage of nuclear materials farther from populated
  areas? How can both the United States and Texas governments              1027/4
  guarantee the safety of citizens living near and in Amarillo?
         I respectfully urge you to make sure that Texas citizens
  are protected from proven and potential hazards.
                                               Respectfully,
                                               Portia Dees

Part 1030

March 2, 1993
To the United States Department of Energy
Through the the Office of the Governor, State of Texas
P.O. Box 12428
Austin, Texas 78711
I am enclosing information that was sent to the residents of the
city of Panhandle with their water bills. Panhandle is located in
Carson County ten miles to the east of Pantex. Farm to Market
highway 293 borders both the Pantex plant and the city of Panhandle
on the north.
One can be sure that if the city of Panhandle has the potential of 1030/1
being hit by a tornado, the Pantex plant is also vulnerable to a
hit.
Numerous very devastating tornados have struck near the plant.
In late June, 1992, the city of Fritch, about 15 miles to the north
of the plant was very hard hit. The city of Amarillo has been
hit. White Deer has had three hits. A farm was destroyed 4 miles
to the north of the plant. Tornados have been spotted on all
sides of the plant. In September, 1968, a rather large storm with
numerous tornados and funnel clouds moved from the north onto the
plant site. A wind guage on the site broke at 114 mph. in 1991,
a large tornado headed directly toward the east gate from Panhandle,
lifting just before it reached the plant. In June, 1993, at least
three tornados were spotted on the north side of the plant. One
moved onto the site, lifted at Firing site 5.
We believe the possibility of a devastating tornado striking the
Pantex plant is too great threat for Pantex to be considered as an
interim storage site for plutonium. Missiles hurled by the very
high winds of a tornado are capable of penetrating the storage areas.
There would not have to be a direct strike for massive destruction.
We request a full environmental impact statement (EIS) with the pos- 1030/2
sibility of a large tornado be done on the issue of plutonium
storage at the Pantex plant,
Sincerely,
Judy Osborne
THE CITY OF PANHANDLE, TEXAS MARCH 1993
IT'S TORNADO SEASON (AGAIN)!
More than 750 tornados strike the The following shelters are available to
United States each year with most of them Panhandle residents who seek shelter from
occurring in the months of April, May and severe weather: Carson County Courthouse
June. If you know a tornado is approaching, (enter the north door and go to the base-
the best thing you can do to protect your- ment floor) and the Panhandle High School
self is act quickly. weight room (this is only available when
If you're outside, don't try to outrun school is not in session) located under the
the storm. The National Oceanic and Atmo- vocational building east of the field house
spheric Administration (NOAA) and the Fed- (enter through the west side door of the
eral Emergency Management Agency recommend building.
that you leave your car for indoor shelter
if there is time. If you're caught in the The City of Panhandle's Emergency Warn-
open, lie in a depression or ditch, curl up ing System consists of emergency warning
to protect your vital organs, and cover sirens and a cable television interrupt
your head with your arms. capability. The Cable Television Emergency
Seek inside shelter, preferable a cel- Notification System includes access to all
lar, underground excavation or steel-framed television sets connected to cable TV that
or reinforced concrete buildings of sub- are powered on. When activated, your screen
stantial construction. will go blank (no matter what channel is
If you're inside, stay away from win- selected) and an alert tone will sound fol-
dows and exterior doors. You want to avoid lowed by emergency information (or a test
flying debris and collapsing walls. Inside message).
a house, seek shelter in a well-constructed The City uses three emergency warning
basement or small, enclosed spaces such as sirens to notify citizens of threatening
stairwells, closets or bathrooms near the weather or disaster situations. The sirens
center of the building. In an office build- are activated for three minutes (except for
ing stay inside a hallway or on the lowest tests) in one continuous sound. This is the
floor. alert tone. The next sound identifies the
Although in the past it was recommend- type of emergency. A high/low tone means a
ed that you open windows to equalize inside tornado or a hazardous material incident is
and outside atmospheric pressure this is no threatening the City. When the sirens stop,
longer suggested by NOAA. An open window the immediate danger has passed. There will
can let strong, destructive winds inside, NEVER be a signal for "all clear."
and wind-driven rain can destroy paint, The cable television and siren system
carpets, floors and furnishings. If a tor- is tested on the last Friday of each month
nado gets close enough to a structure to between 4:30 p.m. and 5:00 p.m. Various
cause extreme atmospheric pressure changes, siren tones are sounded. If weather condi-
chances are the strong tornado winds will tions are threatening, the test will not be
have already caused the most significant conducted. A schedule of dates and times
damage. of warning system testing is listed in the
Preparation is a very important key to Calendar of Events section of the City Hall
surviving a tornado. Every family member Update newsletter. Also, a news release is
should know where the safest areas of the given to the Panhandle Herald for publica-
home are and to move to these areas at the tion on the Thursday before each scheduled
first sign of danger. test.
HOW STRONG IS A TORNADO?
F0 (40-72 mph): Some damage to chimneys, tree branches broken, damage to sign boards,
television antennas damaged, damage to power lines and power poles.
F1 (73-112 mph): Peels surfaces from roofs, windows broken, mobile homes pushed off
foundations or overturned, moving vehicles pushed off roads.
(113-157 mph): Roofs torn from frame houses, mobile homes destroyed, large trees
uprooted.
F3 (158-206 mph): Roofs and some walls torn from well-constructed homes, trains over-
turned, heavy cars lifted and thrown.
F4 (207-260 mph): Well-constructed homes are leveled.
F5 (261-318 mph): Strong frame houses are lifted off their foundations and carried con-
siderable distance and disintegrate.
It's still cold outside, but now is the time for making preparations for
the spring severe weather season. Below are some helpful definitions.
THUNDERSTORM - A storm accompanied by thunder and may contain lightning,
gusty winds, heavy rain and hail.
SEVERE THUNDERSTORM - A thunderstorm that produces winds of 58 mph or
greater, or 3/4-inch hail or larger. This type of storm may also produce
torrential rain (more than an inch in one hour) and possibly tornados.
WALL CLOUD - An abrupt lowering cloud base which usually forms in the rain-
free base area of a thunderstorm. The wall cloud may develop in the south-
west portion (right rear) of the storm. Many wall clouds exhibit rapid
upward motion and rotation. A persistent, rotating wall cloud usually
develops before a tornado.
FUNNEL - A cloud pendant or inverted cloud cone which extends from the base
of the thunderstorm, but is not in contact with the ground.
TORNADO - A violently rotating narrow column of air in contact with the
ground and extending from a thunderstorm base.
GUST FRONT - The leading edge of rain-cooled sinking air in contact with
the ground and extending from a thunderstorm base.
DOWNBURST - A strong downdraft of air which produces an outburst of damaging
winds on or near the ground. These winds may cause tornado-like damage.
DRY LINE - A boundary separating hot dry air to the west from warm moist air
to the east. Thunderstorms often develop along or near a dryline.
CAP or "LID" - A hot dry layer of air between warm moist surface air and
cool dry air aloft. The cap may inhibit or delay the onset of thunder-
storms.
SEVERE WEATHER WATCHES - Watches identify an area where severe weather
might form. It only indicates where and when the severe weather prob-
abilities are highest. It should not be confused with a warning.
SEVERE WEATHER WARNINGS - Severe weather is imminent and you should take
immediate action to protect yourself and property.
HOW LARGE IS HAIL?
Hail of 3/4 inch in diameter or greater classifies a storm as severe
Pea Size - 1/4 inch Golfball size - 1 3/4 inch
Penny or Dime size - 3/4 inch Baseball size - 2 3/4 inch
Quarter size - 1 inch Softball size - 4 1/2 inch
HOW FAR ARE YOU FROM A THUNDERSTORM?
Flash to Bang method: When you see a lightning bolt, begin counting. Sound
travels one mile in about five seconds. Therefore, if you saw lightning and
hear thunder 25 seconds later, the storm was five miles away.
[Information from The Dryline, the newsletter of the National Weather
Service Office in Amarillo, Winter, 1992]

Part 1031

                                                    3805 Overlook
                                                    Amarillo, TX 79119
                                                    March 1, 1993
Roger Mulder
Director, Special Projects
Environmental Policy Division
Post Office Box 12428
Austin, TX 78711
Dear Mr. Mulder
The Environmental Assessment prepared by the U.S. Department of Energy
regarding the proposal to increase the storage of plutonium pits at the
Pantex Plant near Amarillo, Texas, is inadequate in many respects. Several
of the most significant are:
1.  Length of storage is estimated to be 6 to 10 years. In reality, there        1031/1
    are no plans being considered for long term storage. What is the basis
    for the 6 to 10 year estimate?
2.  Alternative storage facilities such as those at Kirkland Air Force Base      1031/2
    and Sierra Army Depot are not mentioned in the Environmental Assessment.
    These facilities are already constructed and should receive public
    consideration.
3.  Deterioration of the pits and storage containers over the long term          1031/3
    should receive intensive study.
4.  Transportation to and from the Pantex site, and between all facilities,      1031/4
    is not adequately addressed.
5.  The very real danger of an airline crash causing a major fire is not         1031/5
    honestly examined.
Therefore, I request that the Department of Energy prepare an environmental      1031/6
impact statement on the issue of plutonium management in the United States
and that full public hearings be held. This EIS should consider the problem
as a whole, not as an isolated operation at Pantex, and include the safety
of workers, long term storage methods and facilities, transportation, the
eventual uses and/or disposal of plutonium and other chemical and nuclear
materials.
There should be thorough long range planning and a carefully considered,
integrated, nationwide policy on this extremely critical issue.
                                                         Sincerely,
                                                         Louise Daniel

Part 1032

Part 1033

Part 1034

THE FOLLOWING INDIVIDUALS SUBMITTED THE INCLUDED FORM LETTER
Andrea Alpar Jack and Shell Geckerr F. R. O'Brien
Amarillo, Texas Amarillo, Texas Amarillo, Texas
Virginia Arttro Tim O. Gilbert F. Rose Oney
Hereford, Texas Amarillo, Texas Amarillo, Texas
Mr. & Mrs. J.B. Atkerson Steven L. Gilmore B. Frank Rapstine
Amarillo, Texas Amarillo, Texas Amarillo, Texas
K. Averett Jo Ann & Tony Hawtzi Bette Jo Roberts
Amarillo, Texas Amarillo, Texas Amarillo, Texas
Janie Banner H. J. Hughes Marla Rodgers
Hereford, Texas Panhandle, Texas Amarillo, Texas
Betty C. Barnard James Jones Norbert Schiegel
Amarillo, Texas Amarillo, Texas Shamrock, Texas
Rev. Darryl Birkenfeld Teresa Jones B. M. Shvain
Hereford, Texas Amarillo, Texas Amarillo, Texas
G. G. Campbell Fay Knapp J. P. Smith
Amarillo, Texas Panhandle, Texas Phalba, Smith
Beulah Lee R. Carter Albert Lopez Mildred Frost Smith
Amarillo, Texas Amarillo, Texas Amarillo, Texas
Douglas Coffee Wendy Marsh Karen Son
Pampa, Texas Amarillo, Texas Pampa, Texas
Peggy G. Croney Elaine McDougal Christine Stephens
Amarillo, Texas Hereford, Texas Jermyn, Texas 76459
Mr. & Mr. Danny Detten Teresa McFaul Jeannine & Duane Wendel
Panhandle, Texas Amarillo, Texas Amarillo, Texas
William C. Elsik Don McReynolds J. Williams
Houston, Texas Lubbock, Texas Panhandle, Texas
Blake L. English Tracy Meadows Diana Wood
Amarillo, Texas Amarillo, Texas Amarillo, Texas
Allen Finegold James P. Murphy Bob & Kay Younger
Amarillo, Texas Amarillo, Texas Amarillo, Texas
Russell B. Garmon Mary Gail Nichols Terri Younger
Amarillo, Texas Amarillo, Texas Amarillo, Texas
February 19, 1993

To the United States Department of Energy
Through the Office of the Governor, State of Texas
P.O. Box 12428
Austin, TX 78711
As a responsible citizen committed to preserving the quality of life for all future generations I 1034/1
am gravely concerned about the Environmental Assessment prepared by the United States
Department of Energy regarding the proposal to increase the storage of plutonium at the Pantex
Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of informed
citizens, it is my opinion that this Environmental Assessment (EA) does not adequately address
the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to store the pits
for any period of time is a significant new action that should be analyzed in its own right, and
all reasonable alternatives and environmental impacts should be considered now.
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6 - 10 years. 1034/2
There appears to be no basis for these figures. Where the pits will go after the ten year period
was not discussed. Further, it does not provide assurance that pits will not be stored for more
than ten years.
All of the reasonable alternatives were not considered and inadequate attention was given to 1034/3
existing available DOE or DOD facilities. As taxpayers we have spent millions of dollars
providing warhead and pit storage facilities at Kirtland Air Force Base (Albuquerque, NM., and
the Sierra Army Depot in California.
The draft EA does not analyze the environmental effects of pit storage for more than ten years. 1034/4
There is no discussion on the stability of plutonium pits during interim or long-term storage. 1034/5
The effect on the workers is not adequately addressed in this draft document. It does not 1034/6
explicitly analyze doses to workers who handle the pits in the disassembly areas and those
transporting them from disassembly areas to Zone 4. It does not calculate the doses for the 1034/7
maximally exposed worker, or the doses to workers if if inspections are required more frequently
than every 18 months. Not discussed is the increased worker exposures compared with the
current operations, yet it appears those exposures will be several times current levels.
Rather than issuing a final environmental assessment and a Finding of No Significant Impact 1034/8
(FONSI), the Department of Energy should proceed to initiating an environmental impact
statement (EIS) on the issue of plutonium management at Pantex.
Sincerely,

Part 1035

Part 1036

IEER INSTITUTE FOR ENERGY AND
ENVIRONMENTAL RESEARCH
Washington, D.C. office:
6935 Laurel Avenue
Takoma Park, MD 20912
Phone: (301)270-5500
FAX (301)270-3029
March 1, 1993
Roger Mulder
Director of Special Projects
Office of the Governor
P.O. Box 12428
Austin, TX 78711
Dear Mr. Mulder,
A few weeks ago you sent me the draft EA on pit storage at the Pantex plant for my
comments. They are being faxed to you with this note. A separate copy is being mailed to
you by two-day mall, in case you should need an original. I am also sending a copy of these
comments to Beverly Gattis and Don Gardner who both put you in contact with me.
I hope that you find these comments helpful. If you have any questions please let me know.
Yours Sincerely
Arjun Makhijani, Ph.D.
President
cc: Beverly Gattis
Don Gardner
European office: Wilhelm-Blum-Str. 12-14, 6900 Heidelberg, Germany. Tel (011-49)6221-47670. Fax (011-49)6221-476719
Printed on recycled paper
IEER INSTITUTE FOR ENERGY AND
ENVIRONMENTAL RESEARCH
Washington, D.C. office:
6935 Laurel Avenue
Takoma Park, MD 20912
Phone: (301)270-5500
FAX (301)270-3029
Comments of Arjun Makhijani, Ph.D. on the Predecisional Environmental Assessment for
Interim Storage of Plutonium Components at Pantex, DOE/EA-0812, December 1992.
March 1,1993
1. General Comments 1036/1
The stated purpose of the proposed action in the EA "is to provide interim storage
of pits removed from nuclear weapons in response to the President's nuclear weapons
reduction initiative." (p. 2-1) The proposed action would expand the capacity for storage of
pits from the current 6,800 (p.3-1) to 20,000 or more pits. The EA claims that there is
considerable urgency in implementing this expansion because the DOE may have to cease
disassembly activities "as early as the fourth quarter of 1993" if the proposed action is not
implemented (p 2-1).
The EA does not provide the information required to independently verify the claim
of urgency or the overall goal for expansion of capacity that DOE seeks under the proposed
action. Two items are at issue:
First, the EA does not provide any figure for the actual number of pits in storage as
of December 1992. There is only a chart for "projected" storage capacity requirements (p.
2-2) that starts in the fourth quarter of 1992 in the range of about 3,500 to about 3,800 pits.
The EA does not state whether this is an actual figure or was a projection for 1992 based
on an assumed disassembly rate of 2,000 weapons per year. The projected date when
current storage capacity may run out must be based on actual figures for pits currently in
storage. Second, information must also be provided on how the disassembly figure of 2,000
weapons per year was arrived at, and how it might vary, in light of past rates of
dismantlement and assembly combined.
II. Interim Storage Period 1036/2
The EA claims that pit storage at Pantex will be for 6 to 10 years and that long-term
storage or disposition options will be implemented after this. It provides no justification
for the length of this interim storage period and no information on how it was calculated.
The EA states that long-term options will be decided as part of the Programmatic 1036/3
Environmental Impact Statement (PEIS) on the Reconfiguration of the Weapons Complex.
Since even a draft of this decision (which is supposed to take public comments on the draft
European office: Wilhelm-Blum-Str. 12-14, 6900 Heidelberg, Germany. Tel (011-49)6221-47670. Fax (011-49)6221-476719
Printed on recycled paper
2
into account), it is quite mysterious how the DOE arrived at the estimate that interim
storage would be for a 6 to 10 year period. The EA should provide a clear and complete
justification for this figure, including any assumptions about final disposition and the pace
of final disposition measures assumed in estimating the interim storage period.
The EA also makes the inappropriate comment that plutonium pits from warheads 1036/4
that are no longer needed in the U.S. arsenal are "valuable national assets." (p. 2-1) Such a
conclusion prejudges a possible decision in the Reconfiguration of PEIS that the surplus
plutonium is a waste, due to the security and environmental threats it poses. Due
consideration must be given to the proliferation implications of any decision to treat it as
an asset in the United States, since that would result in reinforcing corresponding decisions
in the former Soviet Union, other nuclear weapons powers, and aspiring nuclear weapons
powers.
III. Container Types 1036/5
The EA mentions two different types of containers: carbon steel and stainless steel.
It provides no discussion of the relative merits of these containers, how many of each will
be used, and what the effects of various assumptions about the use of these containers be
on the dismantlement rates and on worker health and safety. In addition, the EA does not
discuss the relative merits of each type of container with respect to a number of crucial
issues, such as corrosion rates, inspection frequency, verification issues, and severity of
some accidents, notably those involving possible rupture of containers. The EA also does
not provide the information necessary for an independent evaluation of the containers
using such criteria. The EA should also discuss the experience of corrosion and worker
doses with these two types of containers, as well as the maximum length of time that a pit
has been stored in each type.
IV. Inspections and Inventory-Taking Procedures 1036/6
The EA claims that a 100 percent inspection of the single-layer vertical
configuration will take one minute per container, including removal, inspection and
returning containers to the magazines. It does not provide any basis for this estimate, nor
the variation in the amounts of time for containers in different parts of the magazine. This
information is essential since both the soundness of the inspection and the doses to workers
depend directly on this time estimate.
Further, aisle space would have to be cleared in order to inspect the containers in
the rear of the magazine. This would require taking the containers to other magazines and
stacking them appropriately, finishing the inspections and then retrieving and restacking
the containers. Indeed, it would appear that all rows from front to back but one would
have to be cleared and the containers stored elsewhere in order to inspect the containers in
the last rows (parallel to the sides and stretching back from the door.)
3
It strains the imagination that all these operations, including thorough inspections,
could be carried out at the rate of one minute per container. Further, such procedures
raise verification questions, since the moving and stacking of containers rapidly from one
magazine to another increases the opportunities for possible diversion.
The EA should provide detailed descriptions of all inspection procedures and the
evidence from actual operating records that such inspection times are realistic for
magazines that are full. It is also necessary for the EA to specify how much experience
there is with inspections with full igloos in vertical configurations. Careful verification of
DOE's inspection procedures is necessary to calculate compliance with dose limits, since
workers will be in a highly radioactive environment, with neutron dose rates in the tens of
millirems per hour and gamma dose rates in the hundreds of millirems per hour.
Finally, taking inventories of pits also raises similar questions. Since the magazines
do not have lighting, physical verification of all of the inventory in a full, vertically stacked
magazine would be quite time consuming. Yet the estimated time for such an inventory is
not much greater than the estimated time to inventory a horizontally-stacked, modified
Richmond magazine, where all the containers would be in relatively easily view (90
minutes for the horizontally-stacked versus 140 minutes for the vertically stacked).
The rates of inspection and inventory-taking are critical to estimating worker doses.
They are also central to estimating whether Pantex can meet the worker dose limits without
compromising other goals, such as thoroughness of inspections. In this context, it is also
important for the EA to include further information on other radiation to which the
inspection and inventory workers would be subjected under normal or non-routine
circumstances.
V. Accident Scenarios 1036/7
Calculations of the effects of an accidental explosion of high explosives on the
Modified Richmond and SAC magazines are based on the assumption that the blast can be
represented as a triangular wave distributed load on the roof of the structure in questions.
These calculations indicate that the combination of blast and dead load on the roof of the
Modified Richmond magazine would be about 65% of the estimated yield strength of the
beam.
Since the results of the stress calculations are dependent on pressure waveform and
on the distribution of the load, the DOE should do a sensitivity analysis that includes
waveforms with sharper rise profiles (such as exponential or parabolic) and non-uniform
load distributions across the roof. Similar sensitivity analyses should also be done for other
aspects of calculating the consequences of an accidental explosion. This is critically needed
for the doors of the SAC magazine, since the calculated ductility ratio with the assumed
waveform and load distribution indicates significant deformations may occur with the
assumed waveforms.

Part 1037

                                                     Diocese of Amarillo
                                                       March 1, 1993
          To the United States Department of Energy
          Through the Office of the Governor, State of Texas
          P.O. Box 12428
          Austin TX 78711
               I am gravely concerned about the Environmental Assessment       1037/1
          prepared by the United States Department of Energy regarding the
          proposal to increase the storage of plutonium at the Pantex
          Nuclear Weapons Plant near Amarillo, Texas.
               It is my opinion that this Environmental Assessment (EA)
          does not adequately address the full range of the issue.
               The proposal to store the pits for any period of time is a
          significant new action that should be analyzed in its own right,
          and all reasonable alternatives and environmental impacts should
          be considered now.
               The draft EA declares that the plutonium pits will be           1037/2
          stored at Pantex for the next 6-10 years. There appears to be
          no basis for these figures. Where the pits will go after the
          ten year period was not discussed. Further, it does not provide
          assurance that pits will not be stored for more than ten years.
               All of the reasonable alternatives were not considered and      1037/3
          inadequate attention was given to existing available DOE or DOD
          facilities.
               The draft EA does not analyze the environmental effects of      1037/4
          pit storage for more than ten years. There is no discussion on
          the stability of Plutonium pits during interim or long-term          1037/5
          storage.
               The effect on the workers is not adequately addressed in        1037/6
          this draft document. It does not explicitly analyze doses to
          workers who handle the pits in the disassembly areas and those
          transporting them from disassembly areas to Zone 4. St does not      1037/7
          calculate the doses for the maximally exposed worker, or the
          doses to workers if inspections are required more frequently
          than every 18 months. Not discussed is the increased worker
          exposure compared with the current operations, yet it appears
          those exposures will be several times current levels.
                 DIOCESAN PASTORAL CENTER AMARILLO TX 79117-5644
                           PO. BOX 5644    806-3832243
                                       -2-            March 1, 1993
               Rather than issuing a final environmental assessment and a      1037/8
          Finding of No Significant Impact (FONSI), the Department of
          Energy should proceed to initiating an environmental impact
          statement (EIS) on the issue of plutonium management at Pantex.
                                        Sincerely,
                                        Bishop Leroy T. Matthiesen

Part 1038

Arrowhead February 26, 1993
Mills
To the United State apartment of Energy
Through the Office of the Governor, State of Texas
P. O. Box 12428
Austin, TX 78711
As a responsible citizen committed to preserving the quality of life for all future 1038/1
generations, I am gravely concerned about the Environmental Assessment prepared by the
United States Department of Energy regarding the proposal to increase the storage of
plutonium at the Pantex Nuclear Weapons Plant near Amarillo, Texas.
Because I believe that the quality of a Democracy depends on the participation of
informed citizens, it is my opinion that this Environmental Assessment (EA) does not
adequately address the full range of the issue.
Since historically plutonium pits have been refabricated and reused, the proposal to
store the pits for any period of time is a significant new action that should be
analyzed in its own right, and all reasonable alternatives and environmental impacts
should be considered now.
The draft EA declares that the plutonium pits will be stored at Pantex for the next 6 - 1038/2
10 Years. There appears to be no basis for these figures. Where the pits will go after
the ten-year period was not discussed. Further, it does not provide assurance that pits
will not be stored for more than ten years.
All of the reasonable alternatives were not considered and inadequate attention was 1038/3
given to existing available DOE or DOD facilities. As taxpayers we have spent millions
of dollars providing warhead and pit storage facilities at Kirtland Air Force Base
(Albuquerque, NM, and the Sierra Army Depot in California.)
1038/4
The draft EA does not analyze the environmental effects of pit storage for more than ten
years. There is no discussion on the stability of plutonium pits during interim or 1038/5
long-term storage.
The effect on the workers is not adequately addressed in this draft document. It does 1038/6
not explicitly analyze doses to workers who handle the pits in the disassembly areas and
those transporting them from disassembly areas to Zone 4. It does not calculate the 1038/7
doses for the maximally exposed worker, or the doses to workers if inspections are
required more frequently than every 18 months. Not discussed is the increased worker
exposures compared with the current operations, yet it appears those exposures will be
several times current levels.
Rather than issuing a final environmental assessment and a Finding of No Significant 1038/8
Impact (FONSI), the Department of Energy should proceed to initiating an environmental
impact statement (EIS) on the issue of plutonium management at Pantex.
Sincerely,
Arrowhead Mills, INC.
Boyd M. Foster
President
BMF:ef
Box 2059 * Hereford, Texas, USA 79045-2059 Tel 806-364-0730 * Fax 806-364-8242

Part 1039

THE TEXAS NUCLEAR WASTE TASK FORCE
The Texas Corn Producers, Women Involved in Farm Economics,
The Texas Chapter of The National Assn. of Social Workers,
The United Methodist Women of the Northwest Texas Conference,
The Texas Farmers Union, STAND of Tulia, STAND of Amarillo,
POWER of Hereford and Vega, The Texas Conference of Churches
March 10, 1993
To the United States Department of Energy
Through the Office of the Governor, State of Texas
P.O. Box 12428
Austin, Texas 78711
Dear Governor Richards,
The Texas Nuclear Waste Task Force is a coalition of ten organizations
sharing the common goal of preserving a high quality of life and seeking the
safest, most reasonable approach to the storage of hazardous and radioactive
materials. We are presently very concerned about the Department of Energy's 1039/1
Environmental Assessment regarding the proposal to increase plutonium
storage at the Pantex Plant near Amarillo, Texas.
The EA's basis is seriously flawed because it categorically presumes that
plutonium storage at Pantex will be temporary, limited to ten years. This
premise does not take into account the immense obstacles to siting an
alternative storage facility.
Any realistic proposal for the storage of plutonium pits should take into 1039/2
consideration the uncertainty of storage time at any DOE or Department of
Defense facility. Furthermore, if long-term storage should become a reality,
additional buildings would likely be necessary, a possibility not addressed in
the present EA. The cost, logistics and environmental impacts of these
structures should be studied, accordingly.
The existing EA does not examine reasonable storage alternatives and we 1039/3
do not believe this issue was given sufficient priority. The potential sites
mentioned in the EA are now serving other DOD or DOE missions. Also, they
have a limited storage capacity, which would probably not be adequate for the
the considerable quantities of plutonium to be stored at Pantex.
Further complicating this issue are the political realities that other states 1039/4
have established opposition to storage and/or transportation of radioactive
materials within their borders. This factor raises the importance of the EA's
need to consider the likelihood of pit storage becoming long-term or
permanent.
DOE's draft EA does not adequately address the effect on Pantex 1039/5
workers. It does not explicitly consider doses of radiation to workers who
handle the pits in the disassembly area and those transporting pits from
disassembly to Zone 4. Specifically, the EA does not calculate the doses for 1039/6
the maximally exposed worker, or the doses to workers if inspections are
required more frequently than every 18 months. Also not discussed is the
increased worker exposures compared with the current operations, yet it
appears those exposures will be several times current levels.
We are deeply concerned at DOE's Finding of No Significant Impact 1039/7
(FONSI), considering the critical nature of this proposal. Rather than
issuing a final environmental assessment, the Department of Energy should
proceed to initiating an Environmental Impact Statement (EIS) on the issue of
plutonium management at Pantex.
We recognize and appreciate that the State of Texas is our strongest ally
in assuring environmental integrity, public safety and the citizenry's right to
know. We ask for your continued support in this issue, which is of lasting
importance to present and future generations of Texans.
Sincerely,
Tonya Kleuskens
Chairman, TNWTF

Part 1040

                        Texas Corn Growers Association
                                 218 E. Bedford
                              Dimmit, Texas 79027
                             Phone (806) 647-4224
  March 9, 1993
  United States Department of Energy
  Office of the Governor, State of Texas
  P.O. Box 12428
  Austin, Texas 78711
  To whom it may concern:
  As President of the Texas Corn Growers Association and Executive       1040/1
  Director of the Texas Corn Producers Board, I am writing about
  our concerns about the Environmental Assessment prepared by the
  United States Department of Energy regarding the proposal to
  increase the storage of plutonium at the Pantex Nuclear Weapons
  Plant near Amarillo, Texas.
  We do not feel that the Environmental Assessment adequately
  addresses these issues that are created at this site. I have
  been associated with the Department of Energy for several years
  now and I certainly do not trust their analysis and statements
  on what is actually going on at this location. We feel that
  reasonable alternatives of environmental impact should be
  considered now.
  One big problem is that the draft of the Environmental Assessment      1040/2
  does not analyze the environmental effects of pit storage for
  more than ten years. They do not even bother to discuss the            1040/3
  stability of plutonium pits during interim or long-term storage.
  When the Department of Energy moved everything from Rocky Flats,       1040/4
  Colorado into Pantex, they stated that Pantex would not be a
  permanent storage site. This concerns us greatly because the
  D.O.E.'s credibility has been very bad for the people in the
  Panhandle area. We live less than 100 miles from this site in
  a very large agricultural area. We produce all types of crops
  and this is also the largest cattle feeding area in the world.
  The environment has a tremendous effect on not only the livestock
  and crops but especially the human beings that live here.
  Thank you for your time.
  Sincerely yours,
  Carl L. King
  President, Texas Corn Growers Association
  Executive Director, Texas Corn Producers Board
  CLK/rcd

Part 1041

Military Production Network
A national alliance of organizations working to address
issues of nuclear weapons production and waste clean-up
March 12, 1993
Mr. Roger Mulder
Director, Special Projects
Office of the Governor
Post Office Box 12428
Austin, TX 78711
Re: Predecisional Environmental Assessment (EA) for Interim Storage
of plutonium Components at Pantex, December 1992. DOE/EA-O812
Dear Mr. Mulder:
We have several concerns about issues raised in the above referenced EA, as well as additional 1041/1
concerns about other aspects of the Department of Energy's (DOE) dismantlement program. We
very much appreciate your sending us a copy of the EA and your willingness to forward our
comments to DOE. However, we hope that in the future DOE will make its preliminary EA's
available to the public at the same time they are made available to state governments.
The Military Production Network (MPN) is a national alliance of organizations working to address
issues of nuclear weapons production and waste cleanup. The MPN has been very active in DOE's
two, ongoing Programmatic Environmental Impact Statements (PEIS) and many other DOE decision
making processes. We are committed to full public participation in decisions regarding nuclear
warhead dismantlement and to independent regulation and verification of the dismantlement process.
The success of announced arms control agreements is critical to our nation's future, and DOE's 1041/2
dismantlement program is vital to the success of these agreements. We believe it is possible to
conduct the dismantlement program in a way that enhances public confidence in DOE and builds
the foundation for many of the difficult, long-term decisions which must be made about disposition
of retired warhead materials.
Unfortunately, the predecisional EA on plutonium storage at Pantex does not move us toward this
positive future. Moreover, DOE's lack of a coherent policy for complying with the National
Environmental Policy Act (NEPA) in regard to its dismantlement program causes us concern. Each
of these areas is discussed below.
The Predecisional EA.
1) The storage period assumed in the proposed action is not supported by credible analysis.
1
Washington D.C. Office: 218 D Street, SE * Washington, D.C. 20003 * phone: (202)544-8166 * fax: (202)543-5304
The predecisional EA states: "The proposed action is to provide additional storage for an interim
time period, expected to within (sic) 6-10 years, for up to 20,000 pits and does not constitute a
decision to store pits at the Pantex Plant for the long term." (p. vii) The only basis presented for
this "interim" storage period is the time required to complete DOE's Reconfiguration Programmatic
Environmental Impact Statement (R-PEIS) and additional site specific NEPA review and
documentation. (pp. 2-1 & 3.1)
However, the schedule for completing the R-PEIS has slipped over the last year, and there is
currently no publicly available schedule for even beginning site specific NEPA reviews to
implement decisions reached in the R-PEIS.
Also, it is not clear from the R-PEIS Implementation Plan (IP) (DOE/EIS-01611P, February 1992)
that dismantlement is to be addressed in the manner the predecisional EA implies. Dismantlement
activities were not widely considered during the R-PEIS scoping periods, end the R-PEIS IP
contains few references to the subject.
The IP indicates little more than that the future DOE complex will "[m]aintain the capability to
decommission the large number of weapons expected to be retired during stockpile downsizing or
replacement," and that the R-PEIS will evaluate "impacts of managing wastes generated
by...assembly/disassembly of nuclear weapons." (A-PEIS IP, pp. ES-8 & 2-3) In our review of the
IP, it is not at all clear that the A-PEIS will in fact consider proposals for long-term storage or
disposition of plutonium, as the predecisional EA states. (p. 2-1) If the final EA relies on the
R-PEIS, then DOE must first supplement the IP with a detailed description of how issues related
to dismantlement will be addressed.
Finally, history demonstrates that interim or temporary storage facilities for nuclear materials tend 1041/3
to become long-term storage sites. This is clearly illustrated by the experience at numerous DOE
and commercial waste storage locations. This issue is not addressed in the predecisional EA. The
final EA should clearly explain the steps DOE will take to ensure that Pantex does not become
another de facto long-term storage facility.
2) Inadequate information is provided on alternatives for storing plutonium components at other 1041/4
DOE sites.
The predecisional EA provides only scant details on why facilities at the Los Alamos National
Laboratory (LANL), Savannah River Site (SRS), and Hanford Site would be unable to store some
portion of the components. Part of the justification offered for not pursuing plutonium component
storage at these facilities is that:
"The nuclear weapons complex is undergoing numerous changes to include
environmental restoration and consolidation of its nuclear material to facilitate
restoration and to enhance safeguards and security. The complex has limited storage
capacity, and each site's capability to store material (pits and SNM in various other
forms) must be examined. There are many ongoing programs where the storage
capability at the above sites are currently being assessed. Consolidation of material and
2
subsequent inventory reduction at the RFP, reduction of the inventory at LLNL, and
clean out of processing canyons at SRS are a few that vie for the existing or potential
storage capacity at SRS, LANL, and Hanford." (p. 4-4)
The predecisional EA does not describe, and none of the referenced documents appear to discuss,
any of the "many ongoing programs" referred to above. At the very least, the final EA should list
these programs and provide ample information on the capacities of existing storage facilities as well
as storage needs to allow independent verification of the conclusions presented.
3) The predecisional EA does not adequately explain why Department of Defense (DOD) sites 1041/5
cannot store some or all the plutonium components from retired warheads.
The premise in the EA is simply that no DOD facility is "currently available" to DOE for use as
an interim storage facility. Consequently, the EA implies that there would be unspecified delays
and that needed modifications "would inevitably entail some degree of environmental impacts." (p.
4-5) However, there is no evidence presented for any of these conclusions.
The final EA should indicate which DOD facilities have been considered as possible storage sites
and provide a credible rationale for whether they could meet the identified need. Also, the final
EA should address the ability of DOD sites to store disabled warheads if delays arise in disassembly
operations at Pantex.
4) The predecisional EA inappropriately refers to plutonium components from retired warheads as 1041/6
"valuable national assets." (p. 2-1)
The decision whether to treat plutonium from retired warheads as an asset or a waste is critical to
plans for its long-term storage and disposition. This decision should be arrived at through an open
process with ample opportunity for meaningful public participation. DOE should not -- in this EA
or any other document -- presuppose this important national policy decision.
DOE should address each of the above stated concerns in the final EA and supporting documents. 1041/7
We also request that if DOE decides to issue a Finding of No Significant Impact (FONSI) for this
EA, a public comment period of no less than 45 days should be held, and comments received should
be meaningfully considered before a final decision is reached. Also, the EA and all documents
referenced by it should be made publicly available at the time the FONSI is published for public
comment.
Dismantlement and NEPA. 1041/8
In addition to our concerns about the predecisional EA itself, we are troubled by DOE's overall
approach to NEPA compliance in regard to its dismantlement program. As described above, there
are discrepancies between the way the treatment of dismantlement is described in the R-PEIS
Implementation Plan and the predecisional EA.
3
DOE needs to clarify how dismantlement and related efforts will be addressed in the R-PEIS, as
well as in the Environmental Restoration and Waste Management PEIS. If DOE's goal is -- as the
predecisional EA implies -- to use the PEIS process as the mechanism for evaluating long-term
storage and disposition of plutonium from retired warheads, then an additional scoping period for
the PEIS's may be necessary. Also, DOE should ensure that the PEIS process allows a fair
evaluation of whether to treat surplus plutonium as a waste or an asset, and full consideration of all
other long-term issues associated with dismantlement.
For the short-term, DOE appears to be pursuing NEPA compliance through separate reviews of
related activities. The predecisional EA on plutonium component storage at Pantex is an example
of this. Related activities include increased shipments of warheads to Pantex, disposition of high
explosives and other non-nuclear materials from retired warheads, shipment to and expanded storage
of highly-enriched uranium at Oak Ridge, shipment to and storage of radioisotope thermoelectric
generators at LANL, and expanded shipment to and processing of tritium reservoirs at SRS.
All activities which support DOE's dismantlement program should be evaluated in a single NEPA
document. This approach would facilitate a consistent and thorough review of the many activities,
public understanding of and involvement in the decision making process, and full compliance with
NEPA.
Dismantling as many as 2O,000 warheads -- and transporting, storing, and disposing of the resulting
materials -- is a major federal action significantly affecting the quality of the human environment
within the meaning of NEPA. Therefore, we believe an Environmental Impact Statement (EIS) is
the appropriate level of NEPA review. Such an EIS should be conducted with ample opportunity
for public participation in the scoping process and review of a draft EIS before a final decision is
made. If DOE does not agree that an EIS is called for at this time, then we ask that the Department
immediately begin preparation of an EA on its dismantlement program and that that EA be
circulated for public comment in order that the Department's position be subject to public review
and comment.
If you, your staff, or DOE officials have any questions regarding these issues please contact Beverly
Gattis, Serious Texans Against Nuclear Dumping, at 806/358-2622 or Brian Costner, Energy
Research Foundation, at 803/256-7298. Thank you.
Sincerely,
Beverly Gattis, on behalf of:
American Friends Service Committee
Denver, Colorado
Citizen Alert
Reno, Nevada
4
Coalition for Health Concern
Benton, Kentucky
Concerned Citizens for Nuclear Safety
Santa Fe, New Mexico
Energy Research Foundation
Columbia, South Carolina
Environmental Defense Institute
Troy, Idaho
Fernald Residents for Environmental Safety and Health (FRESH)
Ross, Ohio
Florida Coalition for Peace end Justice
Orlando, Florida
Greenpeace
Washington, D.C.
Hanford Education Action League
Spokane, Washington
Institute for Energy & Environmental Research
Takoma Park, Maryland
National Peace Action
Washington, D.C.
Knolls Action Project
Albany, New York
New Mexico Alliance
Albuquerque, New Mexico
Northwest Environmental Advocates
Portland, Oregon
Nuclear Safety Campaign
Seattle, Washington
Oak Ridge Environmental Peace Alliance
Knoxville, Tennessee
5

Part 1042

STAR - SAVE TEXAS AGRICULTURE AND RESOURCES
7105 W. 34th Street, Suite F
Amarillo, Texas 79109
March 12, 1993
Roger Mulder
Director, Special Projects
Office of the Governor
P.O. Box 12428
Austin, TX 78711
RE: Predecisional Environmental Assessment for Interim
Storage of Plutonium Components at Pantex
Dear Mr. Mulder:
The following comments are submitted by STAR (Save Texas Agriculture and Resources),
a coalition of four organizations concerned about the effects of Operations at the
Department of Energy (DOE) Pantex Plant on the people and resources of the Panhandle.
Representing thousands of members, STAR is composed of: Panhandle Area Neighbors
and Landowners (PANAL), the Peace Farm, Serious Texans Against Nuclear Dumping
(STAND) of Amarillo, and the Texas Nuclear Waste Task Force (TNWTF). The TNWTF is
itself an umbrella coalition of ten Organizations, the three largest being Texas Farmers
Union, Texas Corn Producers and Texas Conference of Churches. STAR calls for full 1042/1
public disclosure of all information necessary for sound decision making regarding the past,
present and future operations of the Pantex facility, and for substantive public participation
in those decisions.
In summary, we find major legal and substantive deficiencies in the Predecisional
Environmental Assessment (hereafter "draft EA"). The draft EA is insufficient and cannot
be used as the basis for a Finding of No Significant Impact (FONSI), which is clearly DOE's
plan.
We believe that DOE's proposal addresses only a small portion of the new but fundamental 1042/2
reality driving the changes at Pantex. The unparalleled situation of dismantlement of up to
20,000 warheads, and the immediate need to begin accommodating the work load and
variety of materials which that generates, is the essential change affecting Pantex and
other nuclear weapons complex sites. This constitutes a major federal action significantly
affecting the quality of the human environment and requires issuance of an environmental
impact statement (EIS).
Such an EIS should be issued in draft form for extended public comment. The draft should
include all reasonable alternatives to the proposed actions as well as realistic analysis of
environmental effects, as required by NEPA, before a final EIS is issued. DOE should
1
complete that process, including issuing a Record of Decision (ROD), before proceeding
even with the action presented in the draft EA.
Major comments
1. We strongly object to DOE's misuse of the National Environmental Policy Act
(NEPA). We believe that DOE's proposal to dismantle 20,000 warheads, store plutonium
pits at Pantex, and ship highly enriched uranium (HEU) and tritium to other DOE facilities is
a major federal action significantly affecting the quality of the human environment that
requires issuance of an environmental impact statement (EIS) which comprehensively
discusses the entire proposal and all reasonable alternatives.
A. DOE's proposed action is so narrowly defined that it constitutes illegal 1042/3
segmentation contrary to the requirements of NEPA [See, for example, Sierra Club v.
Callaway, 499 F.2d 982 (5th Cir. 1974). Taxpayers Watchdog, Inc. v. Stanley, 819 F.2d
294 (D.C. Cir. 1987)].
The draft EA says the proposed action is "to provide for the interim storage of up to
20,000 pits, pending the implementation of the ROD on the Nuclear Weapons Complex
Reconfiguration PEIS. This is expected to be completed within a time frame of 6-10
years" (p. 3-1).
There are several problems with that description:
1) The total scope of the proposed action is not included. The 20,000 pits come
from an unprecedented dismantlement of warheads which inevitably will yield significantly
increased quantities of many materials. This unprecedented dismantlement has not been
subjected to NEPA analysis. There has been no NEPA analysis of what to do with any of
the resulting materials -- not only plutonium pits, but also HEU, tritium, high explosives and
non-nuclear components.
2) Even within the limits of DOE's proposal as currently stated, the positive and
negative aspects of plutonium pit storage in one location or multiple locations should be
discussed. Total existing storage capabilities at all facilities should be described.
However, the fundamental assumption underlying the proposed action is to do all
dismantlement and interim storage at Pantex. Therefore. the dismantlement capabilities of
other DOE facilities should be discussed in the EIS.
3) The 6 to 10 year time frame is totally arbitrary and is an unreliable basis for any 1042/4
decision making. On July 6, 1992, then DOE Secretary Watkins wrote Attorney General
Dan Morales that the draft PEIS would be available for public comment by the end of
1992. That schedule was not kept, nor does any reliable schedule for the PEIS exist. If
issuance of the draft PEIS, which is totally in DOE's control, is so uncertain, then
implementation of a PEIS ROD, which may be more controlled by the courts or Congress
than DOE, cannot be relied upon at all.
In an EIS, DOE should fully discuss the useful lifetime of all existing and proposed
storage facilities so that decisions about the length of time for storage would have some
realistic basis, not DOE speculation.
2
B. The draft EA does not discuss all reasonable alternatives, as required by NEPA and 1042/5
the CEQ regulations (40 CFR 1502.14(a)).
The discussion of alternatives is the heart of any NEPA document,
yet the draft EA does not adequately analyze the alternatives that it mentions.
Alternative 4.2, combining storage at Pantex and other DOE facilities. is rejected 1)
without an adequate discussion of why other facilities at those sites could not be
converted to pit storage (just as facilities at Pantex have to be converted) and 2) without
adequately describing those "numerous changes" underway at other facilities. Moreover,
a more detailed discussion of why other DOE facilities can not store any pits is necessary.
Alternative 4.3, supplementing Pantex storage with other facilities, is not wholly
discussed. While supplemental storage at LANL and Hanford is mentioned, the discussion
of storage is limited to SRS. As with Alternative 4.2, a much more detailed discussion of
the storage capability of all DOE facilities is required.
Alternative 4.4. using Department of Defense (DOD) facilities, is wholly inaccurate. The 1002/6
federal government has spent millions of dollars developing pit storage capabilities at
Kirtland Air Force Base near Albuquerque, New Mexico. However, there is no specific
mention of that facility in the draft EA. Other DOE facilities have significant warhead
storage capability. A detailed discussion of why none of those facilities could be used for
interim storage is necessary. What will happen with those facilities when they are not
used to store warheads?
In addition, the draft EA must discuss other reasonable alternatives, including: 1042/7
a. Storing disarmed warheads;
b. Shipping all plutonium pits to other locations, just as tritium and highly enriched
uranium are now transported off site;
c. Providing one or more facilities that are open for international inspection;
d. Establishing one or more disposal facilities;
e. Storing pits at Pantex for a specific time period, with strict enforcement of the
time limit and penalties to ensure removal by the end of the time limit;
f. Storing pits in other areas of Pantex in addition to Zone 4; and
g. Others that DOE thinks are reasonable.
2. An adequate NEPA document would fully discuss the long-term hazards of 1042/8
plutonium storage at Pantex.
The 6 to 10 year "interim storage" period is without support in the draft EA. Thus, en
adequate EA would describe long-term hazards of plutonium storage in order to adequately
inform the decision maker and the public of the necessity to develop alternative storage
and disposal facilities.
The only basis that the draft EA States for that 6 to 10 year time frame is that within that
time decisions could be implemented from the Reconfiguration PEIS Record of Decision
(R-PEIS/ROD) (pp. 2-1 and 3-1). However, the R-PEIS Implementation Plan
(DOE/EIS-01611P, February 1992), does not clearly state that any decisions related to
3
long-term storage or disposition of plutonium will be made in the ROD. In fact,
dismantlement is only briefly mentioned in the R-PEIS Implementation Plan (see pages
ES-8, 2-3, and 3.9). Thus, if the final EA is going to rely on the R-PEIS, the latter
document must be supplemented with a detailed description of how storage and disposal,
as well as other dismantlement issues, will be addressed.
Moreover, the schedule for issuance of the R-PEIS itself is totally unknown. Secretary
Watkins's July 6, 1992 letter to Attorney General Morales stated that the draft R-PEIS
would be available for public review by the end of 1992. Secretary Watkins did not meet
that schedule, and to our knowledge Secretary O'Leary has not established any schedule
for the R-PEIS.
Clearly, the draft EA cannot use the R-PEIS as the basis for any decisions to be made now. 1042/9
Instead, the EA must provide the basis for any time frame used for interim storage. In
addition, the EA must fully discuss DOE's history of not meeting deadlines for "interim
storage." For example, Idaho has been promised for years that transuranic wastes that
were brought from Rocky Flats to the Idaho National Engineering Laboratory (INEL) were
for "interim storage," supposedly no more than 10 years. However, some of those
wastes have been at INEL for more than 20 years, and DOE still has no reliable schedule
as to when, if ever, those wastes will go to a disposal facility.
As another example, DOE has stated for years its intention to have a permanent repository
for spent fuel and high-level waste available by 1998. Even with congressional approval
for work at Yucca Mountain, Nevada, DOE is more than a decade behind meeting that
1998 date.
Similarly, even if the R-PEIS/ROD states a preference for having one long-term storage or
disposal facility, there is no precedent for having such a facility available within a decade.
At least one additional NEPA process would be required for such a facility and
congressional authorization and appropriation would be necessary.
Thus, an adequate NEPA document must realistically discuss the long-term hazards of pit
storage. Issues that must be specifically discussed include: 1042/10
a. Stability of plutonium pits during long-term storage, based on actual experience
(if any) and realistic projections;
b. Deterioration of storage containers over 10 years or longer and the need to
develop new storage containers that meet independent certification
requirements;
c. Activities from all dismantlement activities, including optimum and maximum 1042/11
rates for dismantling warheads; transporting materials off site; and storing and
disposing of materials on site, including multiple handling of pits (including
moving or shifting them during storage);
d. Disclosure of effects on workers of realistic accidents from disassembly, on-site
transportation, failures in storage facilities, and exposures from "normal"
operations, including increased exposures from disassembly, materials handling,
doses from more frequent and more lengthy inspections, maximally exposed
worker, and discussion of having few workers having relatively higher doses
4
versus more workers having more minimal exposures;
e. Expected lifetime of Modified-Richmond and SAC facilities, including effects of 1042/12
increased radiation, and their expected performance from the two new
Proposed storage configurations and "maximum packing;"
f. High consequence, low probability accidents -- airplane crash, criticality 1042/13
accident, and major release during disassembly; and
g. On-site storage versus transportation risks and costs for plutonium, highly
enriched uranium, and tritium.
3. Even over the short run, the draft EA inadequately describes the risks to workers
and the public from managing and storing plutonium pits.
While the draft EA has numerous pages supposedly devoted to worker exposure issues
(parts of Chapter 6 and Appendix F), the discussion is based on wholly inadequate
information. Much worker exposure is totally ignored, that which is discussed is
underestimated, and basic approaches to worker safety are totally missing. Moreover, the
Final Safety Analysis Report, Pantex Plant Zone 4 Magazines, the basic document 1042/14
describing the anticipated exposures has not been made available to the public. Prior to
the issuance of the final EA, or a draft EIS, the SAR must be publicly available. Any
national security aspects can be segregated in a classified appendix.
The draft EA contains no discussion of worker exposures during dismantlement end at any 1042/15
other time prior to the inspections in the interim storage facilities. In fact, significant
exposures could occur during dismantlement, during storage prior to arrival at Zone 4,
during transport of the pits from the disassembly facilities to Zone 4, and in loading the
pits into the Modified Richmond and SAC buildings.
Questions that must be addressed in the EA include:
- How many workers are involved in those operations;
- What is the duration of exposures;
- What are the potential maximum exposures;
- What kind of accidents can occur during disassembly, storage, and shipment to Zone 4,
- What kind of accidents could occur during loading pits into the Modified-Richmond and
SAC magazines;
- Will the differing storage configurations in the two types of storage buildings require
different training for workers to avoid accidents;
- What kind of cumulative exposures can workers receive for participating in various
activities, or will each operation have its own specialized work force?
Worker exposure information in Appendix F is based on one inspection in each magazine 1042/16
every 18 months. No basis is given for why that is the appropriate frequency of
inspection. The EA must present a detailed discussion of why more frequent inspections
are not necessary. It must also discuss why more frequent inspections would not be
required in later years, when radiation exposure could result in container or building
deterioration. Further, the EA should present comparative data as to the level of 1042/17
exposures if inspections are required every month or every six months.
5
The basic information about the length of worker exposure is highly suspect. The draft EA
States that for the Modified-Richmond magazines (single-layer vertical configuration) each
Inspection would require 70 minutes and for the horizontal palletized stacking 45 minutes
for each side, and for the SAC each inspection would require 140 minutes for single-layer
configuration and 90 minutes for the horizontal palletized configuration.
Unanswered in the draft EA are basic questions, including: 1042/18
- What kind of lighting will be provided for the inspections since the magazines apparently
have no lighting;
- If each container will be removed from the magazines in case of single-layer vertical 1042/19
stacking (as stated on p. F-2), what kind of accidents could occur, what exposures
will occur, and how long would such moving actually take (certainly longer than the
few seconds estimated);
- During removal how many pits would be outside at any one time, what types of 1042/20
accidents could occur (including from weather related events), how many times
would a pit actually be handled -- i.e., moving pits to allow aisle space to reach the
rear of the magazine; how could just two workers properly keep track of and log
the pits to ensure that they are each returned to their assigned storage location -- if
additional workers are required, additional exposures will result;
- What is the actual accident history and exposure rates for inspections under current 1042/21
storage configurations;
- If the pits will not be handled or moved during inspections as is implied for horizontal 1042/22
palletized stacking, how will corrosion or leaks in "hidden" areas be identified;
- What types and levels of gas buildup can occur inside the pit storage containers; 1042/23
- If storage containers are punctured, what amount of plutonium dust could be released, 1042/24
with what effect on workers, what emergency response measures will be put into
place to treat workers so exposed?
Further, basic information about the DOE approach to worker safety is not included in the 1042/25
draft EA. Will a few workers be charged with doing all inspections, thereby increasing
doses to a few workers, or will many workers conduct inspections, thereby increasing the
number of workers receiving some exposures but limiting exposures to individuals?
Related questions are whether having a few highly trained workers make inspections
quicker and more efficient, thereby reducing exposures, or whether having teams of more
than two workers would reduce the time and resulting exposures from inspections. Other
questions are: Are the same workers responsible for moving pits from the disassembly
bays to the storage facilities and then doing inspections? If so, what are the cumulative
exposures?
Specific comments
1. List of preparers. Council on Environmental Quality (CEQ) regulations (40 CFR 1042/26
1502.17) require listing of preparers of an EIS. The final EA should have such a listing
even though it is not required by regulation.
2. ES-vii. The first sentence states that the primary mission of Pantex is assembly 1042/27
end disassembly of weapons. Why is plutonium storage not considered to be a new
mission, requiring an EIS?
6
The stated purpose of the EA is to evaluate environmental impacts of additional pit 1042/28
Storage. However, there is no discussion of some storage related activities, including
transporting pits from disassembly bays to Zone IV and the actual loading of pits into the
magazines.
The 18 Modified-Richmond magazines capacity would increase from 370 to a 1042/29
maximum of 440 pits and the SAC magazines could hold up to 384 pits. However, page
3-1 States that the Modified-Richmond would increase from 378 to 440 pits and the SAC
could hold 384 or 392 or 406 pits (according to footnote 2). Which numbers are correct?
Using the maximum figures shows that more than 24,000 pits (not 20,000 pits) could be
stored. The EA should discuss if storage for more than 20,000 pits is eventually
necessary, how could Pantex accommodate such an increase?
3. Page 1-1. The draft EA states that Pantex workload requirements 1 "is (sic) expected 1042/30
to be similar to that experienced in the past for all assembly/disassembly operations."
Questions that should be answered include: What were the historic peak years for
disassembly, and for assembly/disassembly? What types of disassembly accidents have
occurred with what exposures to workers and releases into the environment?
Footnote 1 states that 50,000 nuclear weapons have been dismantled in the last
40 years. How many were done at Pantex? How many were done at other facilities?
What other facilities were used? Can those facilities be used for at least some of the
proposed dismantlement?
Footnote 2 describes staging. What is the maximum time that pits have been
stored at Pantex? Where were they stored? With what results? What types of accidents
have occurred during transportation, with what exposures to individuals, with what
releases into the environment?
4. Page 1-2. The implication is that pits have been stored at Pantex since December
1989. How many pits? What kind of inspections have been done? What measured
exposures have workers received? What accidents have occurred? Does the 6 to 10 year 1042/31
interim storage time frame start from 1989, from 1993, or what date? Will pits stored 1042/32
longest be moved first once some other storage or disposal facility is available?
5. Page 2-1. The draft EA states that without additional storage, disassembly would 1042/33
cease by as early as the fourth quarter of 1993. Would such cessation in any way violate
the terms of negotiated arms agreements? What contingency plans exist or are being
developed to avert such a cessation?
If 20,000 pits are stored at Pantex by 2003, how long would it take to ship that 1042/34
entire inventory to another location? What NEPA analysis or safety analysis has been
done of the relative risk of continuous shipment off-site for 10 years versus accelerated
shipment in higher volumes after the large inventory has been accumulated?
6. Page 2-2. Figure 2.1 indicates that in the three years since RFP stopped processing 1042/35
pits (December 1989 to 4th Quarter 1992), Pantex has accumulated between 3,300 and
3,800 pits. How many are actually stored at Pantex? Have any pits been shipped off-site
7
since December 1989? If so, how many and to what location(s)? (See also: issues raised
in comments about page 1-2.)
7. Page 3-1: Footnote 1 states that using the 18 Modified-Richmond magazines for 1042/36
up to 6,800 pits (or 378 each) "is not currently the operationally preferred configuration"
but does not explain why that is so.
Footnote 2 states that the 406 pits/magazine single-layer vertical configuration "will
not be considered for use" but does not provide any basis for that statement.
8. Page 3.2. "The majority of the stored components in Zone 4 would be packaged in 1042/37
AL-R8 containers... but other approved containers" may be used. The EA should provide
much more information about the AL-R8 containers, including:
- description, including size, weight, composition (compare with page 6-1 description of
"carbon or stainless steel drum")
- how many currently exist,
- how old they are,
- how many new containers will be built,
- what kind of independent certification will be required,
- what the demonstrated optimum lifetime has been,
- what kind of deterioration/corrosion has occurred with the existing inventory?
Similarly, much more information about "other approved containers" is necessary,
including:
- detailed information on the specific containers to be used,
- what kind of independent certification will be required,
- whether combined storage/transportation containers can be used,
- the time frame within which such containers will be available?
Variations or combinations of potential storage configurations are mentioned. What 1042/38
are the costs and risks of such variations? Why are aisles not required? How can
inventories be done without aisles unless virtually the entire magazine is taken outside?
The draft EA discusses the shielded electric forklift, but does not provide important 1042/39
information, including:
- how many of those forklifts are currently in use,
- what are measured reduced exposures to workers,
- what is the accident history of those forklifts compared to unshielded forklifts?
The draft EA mentions the AGVs, but does not describe:
- when such vehicles could be available,
- the calculated reductions in time for inspections or reduced worker exposures,
- what kind of testing has been done with prototype vehicles and with what results,
- how the barcodes would be placed on pits already stored.
"Individual pit containers could rest on casters rather than on the concrete floor of 1042/40
magazines," but Figure 3.2 (page 3.4) says that having six rows of pits on casters is
"operationally preferred." The EA must provide an analysis of why such a configuration is
8
operationally preferred. For each configuration. the EA must provide an analysis of how
inspections would be done, including how much movement of pit containers would be
necessary, how two workers could ensure that each container was returned to its
assigned location, how much time the configuration takes to load and unload and the
calculated exposures. For containers on casters, the EA must describe the operational
experience with casters, how frequently casters break or containers fall off.
For palletized multiple stacking, the EA must describe how frequently the pallets 1042/41
would be changed, the history of damage and breaking of the pallets, accident scenarios
including possible releases when pallets break and containers are dropped. It must describe
the structural integrity of each pit container, its design specifications including
weight-bearing ability, actual history of containers supporting triple stacking (as shown in
Figure 3.4).
9. Pages 3-3 to 3-8. All of the figures are deficient for several reasons: 1042/42
- no scale is given
- the containers are not specified (AL-R8 or others)
- the figures are inconsistent with the narrative. For example, Figure 3.6 shows the
bounding single-layer configuration in the SAC magazine is 420 containers, whereas
page 3-1, footnote 2 says maximum packed capacity is 406 pits. Figure 3.2 shows
336 pits as the "operationally preferred" configuration for Modified-Richmond
magazines, whereas page 3-1 says that storage would increase from existing 378
pits to 440 pits. In contrast Figure 3.5 shows 378 pits as the "bounding"
configuration.
Clearly, either the figures are wrong, the text is wrong, or both are wrong. In any case,
the discrepancies must be resolved and explained.
10. Page 4-1. The draft EA states: "For the other alternatives, in each case there were 1042/43
additional costs, transportation requirements, and facility modifications or infrastructure
requirements." No evidence is provided to support such a statement. At a minimum, the
EA must detail the costs of the preferred alternative and of each proposed alternative,
describe the transportation requirements and why procedures used in the past are not
adequate, and describe the types and costs of facility modifications.
11. Page 4-2. The Note stating that additional repackaging would be required for 1042/44
off-site shipment must be explained. What differences are required for repacking now as
compared to when pits were being shipped to Rocky Flats? Are the "Type B shipping
containers" going to be certified by the Nuclear Regulatory Commission? Why could pits
not be shipped in the AL-R8 containers?
12. Page 4-4. In c), the claim is made that decentralized storage "could effect a net 1042/45
increase in expected radiological worker exposure," but no basis is given for the
statement. Specific calculations should be presented and the discussion should
differentiate between cumulative exposures to a lesser number of workers versus lower
exposures to a larger number of workers.
9
13. Page 4-5. The statement that "no DOD facility is currently available" for pit storage 1042/46
appears to be false, Since news reports indicate that pit storage is immediately available at
Kirtland Air Force Base, near Albuquerque, New Mexico. In any case, the capabilities of
the Kirtland facility must be discussed in detail in the EA.
There is no basis provided for the statement that "the storage of pits at DOD
facilities would offer no environmental advantage over the proposed action." To support
that statement additional analysis and answers to questions include: do each of the
potential DOD facilities have a greater or lesser likelihood of a catastrophic airplane crash
than Pantex? Do any of the other facilities sit on an aquifer similarly important as the
Ogallala? Would the potential storage facilities at other locations allow for inspections that
would require less movement of pits and/or quicker inspections so as to reduce worker
exposure?
14. Page 6-1. The statement that "routine operations of the No-Action Alternative are 1042/47
similar to those for the proposed action" would appear to be false and is at odds with
other statements in the draft EA about worker exposure impacts. Even for non-radiological
impacts, common warehouse/industrial accidents and injuries will be higher with the
proposed action than with no action.
The few sentences in Section 6.1.1 are the most detailed description of the pit and 1042/48
storage container, but do not provide adequate or complete information (see also:
comments about page 3-2).
1 5. Page 6-2. Some of the specific assumptions for the proposed action alternative do 1042/49
not appear to be conservative:
- inventory inspections should be calculated on a more frequent basis than once every 18
months; to be consistent with assumptions used for the no-action alternative and to
make reasonable comparisons, inventory inspections should be each month (see
page 6-3).
- since the maximum Modified-Richmond capacity is 440 pits (page 3-1), 220 pits per side
could not be inspected in 70 minutes. Unless better information about actual
inspection rates is available, a conservative assumption should be that the time
required is at least twice that specified;
- inspecting 392 pits in a SAC (maximum capacity specified on page 3-1) is assumed to
take 140 minutes, the same amount of time given for inspecting 440 pits in a
two-sided Modified-Richmond magazine. Inspecting more than ten percent more
pits should take at least more than ten percent more time.
- horizontal palletized stacking is assumed to take about one-third less time than for
single-layer stacking. Justification and actual calculations are needed to justify that
difference;
- corrosion inspections are specified only for single-layer vertical configuration. However,
container and pallet integrity inspections are necessary for palletized storage and
must be assumed in calculations.
- two hours for storage facilities to be open is not conservative based on 140 minutes
each (which itself is not conservative). In terms of number of workers to be
affected, more than two workers per inspection should be used and two workers
should be assumed to inspect only one magazine per day.
10
- capacities assumed are not consistent with those stated in other places in the draft EA.
Consistent numbers should be used throughout.
- radiation dose rates are not adequately supported; actual historically measured rates and
calculations, and conservative extrapolations from those data, should be used.
The statement that shielded forklifts and AGVs "would further reduce worker
exposure" should be supported by actual calculations and analysis. If such vehicles do
have that effect, the EA should specifically describe the health effects and justification for
storing pits without using such vehicles.
16. Page 6-3. Some assumptions used for the no-action alternative do not appear to be
conservative:
- 70 minutes inventory inspection time is not well supported (see comments about page
6-2);
- corrosion inspections only once in 18 months;
- see also comments about page 6-2 for other assumptions.
17. Page 6-5. The discussion of a forklift accident does not use the most conservative 1042/50
assumptions, including for the amount of plutonium dust available and the actual inhalation
by a worker. Thus, the statements that there would be no health effect to the worker and
no consequences to the public are not adequately supported.
If you, your staff, or DOE have any questions regarding these issues please contact
Beverly Gattis, STAND of Amarillo, at 806/358-2622. or Don Hancock, Southwest
Research and Information Center, at 505/262-1862.
Thank you for your consideration of these issues.
Sincerely,
Beverly Gattis, on behalf of:
Panhandle Area Neighbors and Landowners (PANAL)
Panhandle, Texas
The Peace Farm
Panhandle, Texas
Serious Texans Against Nuclear Dumping (STAND) of Amarillo. Inc.
Amarillo, Texas
Texas Nuclear Waste Task Force
Hereford, Texas
11

Part 1043

                                 The Peace Farm
                                  HCR 2 Box 25
                             Panhandle, Texas 79068
                                  806-335-1715
                                               March 12, 1993
Roger Mulder
Director, Special Projects
Office of the Governor
P.O. Box 12428
Austin, TX 78711
                                   COMMENTS
               ON THE PREDECISIONAL ENVIRONMENTAL ASSESSMENT
              FOR INTERIM STORAGE OF PLUTONIUM PITS AT PANTEX
The Peace Farm is a membership-based organization whose mission
is to create an environment for peace through peaceful means, to
assert that peace can exist only where there is justice, and to
develop an ecological model for nonviolent social change. It has
about 750 members, some 550 of whom are Texas residents, with
slightly less than 200 in the Texas Panhandle. The following
comments were accepted in draft form at a Board of Directors'
meeting February 21, 1993.
                            ROLE OF INTERIM STORAGE
The Peace Farm believes that priority should be given to moving
as rapidly as possible from dismantlement of nuclear warheads to
international verification and permanent disposal of the pits in
such a way as to make reassembly of warheads or other use in
military of civilian economies as unfeasible as possible. In this
regard, we see the proposed interim storage of pits as signaling
ambiguity to the commitment of permanently ending the nuclear
arms race or to ending nuclear proliferation.
We recognize that final disposition of the plutonium should
involve a broad public debate and public decision. This decision
should be based on as full a public disclosure of all information
as possible regarding the stockpiles of pits, remaining warheads
and other special nuclear materials as is consistent with
legitimate national security concerns, but national security
should no longer be used as a shield to limit debate and public
decision making.
                           LIMITING INTERIM STORAGE
Interim storage, in so far as it is a necessary part of the
process, should be interim--as defined in the Environmental                1043/1
Assessment--and limited to the 6-10 year time period referenced
in the document.
To assure that this timeframe is met, there should be:
     * a strict and open accounting with the State of Texas for
the pits
     * a requirement for quarterly reports to the state for any
pits held in interim storage longer than 10 years, including
     * provision for financial penalties for pits held in interim
storage longer than 10 years. Otherwise, any pits exceeding the
time limit should be reclassified as waste and come under a full
review process and environmental impact statement for long term
storage. If the pits are to remain on site as a valuable national
resource, their international market value should be determined
and that value added to "in lieu of taxes" provisions, paid
annually to the State and to Carson County.
Additionally, the EA proposal for interim storage of all
plutonium pits at Pantex has rather summarily dismissed a number
of other possibilities, which should be carefully explored in the         1043/2
document. These include a dispersed storage, using several
Department of Energy sites, utilization of Department of Defense
sites, particularly Kirtland AFB.
                               LONG-TERM STORAGE
Because of the irreplaceable value of the Ogallala Aquifer and
the agricultural productivity of the area, Pantex should not be
considered as a site for longterm storage of the pits, final
disposition, or any plutonium processing activities. The burden           1043/3
of proof for any of these activities should be on DOE to assure
that this is the most suitable alternative in terms of
environmental safety and security, and that in event of a
catastrophe, this is the site for which consequences would be
least.
                                 COMPENSATION
There should be a provision for compensation for any real or
perceived loss in property value caused by interim storage of a           1043/4
large quantity of plutonium pits and a provision for compensation
for loss of value, real or perceived, to agricultural products of
the area caused by any activity associated with dismantling.
                               SCOPE OF DOCUMENT
The EA should include the full scope of dismantling activities at
Pantex, including increased worker exposure to radiation and
other hazardous materials throughout the dismantling process,
transportation on and off site, any increase in chemicals used to         1043/5
clean work areas, tools and clothing, and any increased disposal
of high explosive material associated with increased dismantling.
It should also include analysis of the increased handling and
short-term storage of other nuclear materials involved in the
dismantling process.
                                      2
                             HAZARDS AND ACCIDENTS
Hazards are dealt with speciously in the current document, and
should be dealt with fully when there is risk of catastrophic
harm, even if the likelihood itself is very low. The document
should include effects of interim storage on structures and
surrounding soil overburden. It should include an assessment of
any risks involved in transit from dismantling to storage and
transit accidents, and of the consequences of accidents in
monitoring procedures or in the event of corrosion, either of
containers or structures themselves.
                                RECOMMENDATION
The Peace Farm believes that the State of Texas should not accept
a Finding of No Significant Impact on the basis of the EA, and
should require a full Environmental Impact Statement that covers            1043/6
the entire range of dismantling and interim storage activities at
Pantex.
At the same time, the State should urge that the long-delayed
Programmatic Environmental Impact statement should be reopened to
include dismantling and storage on the scale at which it now                1043/7
occurring, or an additional system-wide EIS should be initiated to
cover effects of dismantling activities throughout the complex
and options for final disposition of plutonium, tritium and
highly enriched uranium.
We would also like to express our appreciation to the State for
its role in facilitating public comment on the EA.
Sincerely,
Mavis Belisle
Director, Peace Farm
                                       3

Part 1044

Figure (Page 1 of Part 1044 Hand writing text)
Figure (Page 2 of Part 1044 Hand writing text)
Figure (Page 3 of Part 1044 Hand writing text)
Figure (Page 4 of Part 1044 Hand writing text)
Figure (Page 5 of Part 1044 Hand writing text)
Figure (Page 6 of Part 1044 Appendices 1990 Report)
Figure (Page 7 of Part 1044 Amarillo Dally News Friday, February 19, 1993)
Figure (Page 8 of Part 1044 Amarillo Sunday News October 25, 1992)

Part 1045

STAND of Amarillo, Inc.
7105 W. 34th -- Suite F
Amarillo, TX 79109
(806)358-2622
March 22, 1993
Roger Mulder
Director, Special Projects
Environmental Policy Division
Office of the Governor
P.O. Box 12428
Austin, Texas 78711
re: Predecisional Environmental Assessment for Interim
Storage of Plutonium Components at Pantex (DOE/EA-0812)
Dear Mr. Mulder:
Thank you for the opportunity to offer the following comments about the Predecisional
Environmental Assessment for Interim Storage of Plutonium Components at Pantex
(hereafter "draft EA") on behalf of Serious Texans Against Nuclear Dumping (STAND) of
Amarillo, Inc. STAND is a non-profit membership organization concerned about the effects
of operations involving nuclear materials on the people and resources of the Panhandle.
STAND is committed to full pubic participation in the decision-making processes involving
the Department of Energy's (DOE) nuclear weapons complex (hereafter "complex"). It also 1045/1
believes that sound public policy can be achieved only when that public participation is
substantive end based on full access to all relevant information. The only exceptions to
full disclosure should be limited to information which poses legitimate national security
concerns, such as protection of weapons design data.
STAND finds there are major legal and substantive deficiencies in the draft EA. The draft
EA is insufficient to support a Finding of No Significant impact because the information
presented is inadequate. We believe the draft EA fails, as well, in its approach to the basic
issues and NEPA processes involved.
Most importantly, we find the scope of the draft EA to be so narrowly defined that it
cannot responsibly address the issues effecting Pantex. The proposed dismantlement of
up to 20,000 warheads, and the immediate need for the complex to accommodate both
trio work and variety of materials generated. is the fundamental situation driving the
changes involving Pantex and other sites.
Additionally, the proposed dismantlement is already underway. It is proceeding without
the benefit of any integrated evaluation of the demands of the work or facilities needed for
the Interim disposition of the variety and quantities of material, inevitably produced.
The unprecedented dismantlement of up to 20,000 nuclear warheads, and its inevitable
ramifications, constitutes a major federal action significantly affecting the quality of the
human environment and requires issuance of an environmental impact statement (EIS).
Major comments 1045/2
1) The scope of the draft EA must fully respond both to the nature of current
dismantlement work affecting Pantex, and to interim disposition not only of plutonium pits
but of all other materials which inevitably will result. Significant circumstances which
must be taken into account are:
a) Both the number of warheads to be dismantled and the pace scheduled for
dismantlement is unprecedented.
b) There is no current defense program need for the pits. Long-term future need is
anticipated to be small, conceivably even zero. What used to be a closed-loop cycle of
plutonium reprocessing and re-use no longer exists.
c) There is a breakdown of the historic pattern of materials flow within the
complex. The facility which used to receive and reprocess/recycle the plutonium pits from
Pantex, the Rocky Flats Plant, is closed; no other such facility currently exists in the
complex.
In the past (as recently as 1991) Pantex officials stated uncategorically that pits
were "staged," not stored, at Pantex. Though citizens always assume staging is an
extremely flexible proposition convenient to DOE, it is, even by the definition in the draft
EA, inherently different from storage.
"Staging is the temporary holding of materials (weapons or components) as
they await the next step in their process flow (i.e. disassembly or transport
off-site). There is no set time limit for staging since movement of materials
(for transport, disassembly, etc.) is dependent on scheduling, upstream
process flow stream conditions, resource availability, etc." (p. 1-1)
With no interim "upstream process flow" available, years of storage will be
required. This is a fundamental change in work and mission for Pantex.
e) Though the draft EA focuses on plutonium pits, the unprecedented
dismantlement yields a variety of other materials which must be temporarily staged or
stored in areas able to provide proper security.
Existing storage space qualified to provide proper safeguards and security is limited.
These materials require such space not only at Pantex, but compete for the limited space
available in other parts of the complex.
Pantex itself must accommodate at least: 1) special nuclear material (SNM) such
as highly enriched uranium (HEU), or other closely held material such as tritium, 2)
warheads awaiting dismantlement, 3) other weapons components, 4) mixed waste
containing SNM or closely held material, 5) warheads needing maintenance/evaluation. The
draft EA does not adequately discuss the space neeeded to accommodate these materials.
For the complex in general, the draft EA states, "The complex has limited storage
capacity, and each site's capability to store material (pits and SNM in various other forms)
must be maximized...." The draft EA continues by referring to "many ongoing programs
to assess current storage, and explains that other residues, wastes and material "vie for
the existing or potential storage capacity....(p. 4-4) The explanations are clearly
intended to create a sense of inevitability and necessity for acceptance of the draft EA's
proposed action of intensified pit storage at Pantex.
However, the explanation just as clearly establishes that there is an urgent need for
integrated evaluation of the demands on the complex. The effect of adding materials from
dismantlement to already existing materials is straining the storage facilities needed to
house them. The storage needs are interrelated, but evaluations are going forward in a
fragmented manner.
2) The draft EA does not present realistic time frames for when current storage capacity 1045/3
will be reached, yet timing is portrayed as urgent.
a) The draft EA could, but does not, present sufficient information about the
number of pits already accumulated at Pantex so that an accurate starting inventory can
be established. Information from other DOE sources (see attached document 1: U.S DOE
Pantex Plant Nuclear Weapons Disassembly History FY 1980 thru FY 1992) indicate that
actual dismantlements resulting in pits potentially remaining at Pantex are: FY 1990 -
1151; FY 1991 - 1595; FY 1992 - 1303.
b) There is insufficient information provided in the draft EA to substantiate any of
the statements about when capacity would be reached, such as, "Capacity, at currently
projected dismantlement schedules could be reached as early as 4th calendar quarter of
1993." (p. 3-1)
Since 1990, the highest annual rate of disassembly, for either retirement or
evaluation, appears never to have exceeded 1757. (see attached document 1) Historical
records seem to indicate that DOE's goal of maintaining a disassembly rate of 2,000
weapons per year may be overly ambitious.
Clearly the actual rate of dismantlement is variable, and should be, since different
weapons systems have different requirements, etc. More importantly, the primary
consideration of the Plant must be worker and operational safety.
In order to establish a better basis for planning, free of exaggerated time
constraints, the establishment of both a clear starting point and an achievable rate of
dismantlement is necessary, and offers no threat to national security. indeed, it enhances
safety by supporting informed decision-making which is not driven unnecessarily by a false
sense of urgency.
3) The draft EA does not establish a clear sense of DOE's prioritization of the different
environmental (as defined by NEPA) impacts.
Worker exposure is acknowledged to be the principal impact (viii). However, 1045/4
discussion of alternatives in the draft EA never clarifies whether or not any of the
alternatives might offer more worker protection than another. It is as if, no matter where
the storage location is, the rates of exposure will be the same -- though this is never
substantiated in the text.
Given that approach, one of the justifications for not accepting alternative 4.4,
"interim Storage at a DOD facility," is that, if any modifications were necessary, "these
modifications would inevitably entail some degree of environmental impacts of the type
generally associated with construction activities." (p. 4-5)
The draft EA should establish a general ranking of priorities so that decision-making
can distinguish among important differences. Lessening worker exposure could indeed
justify other concessions or expenses.
4) The draft EA does not completely discuss all the alternatives it presents.
As a most obvious example, in the discussion of Los Alamos National Laboratory 1045/5
(LANL) it lists existing pit storage at TA-41 and TA-55. TA-41 is eliminated because "it
does not meet current DOE requirements for ES&H, security, and conduct of operations,
and programmatic requirements do not justify the costs required to make needed
changes." (p. 4-3) Some of the problems with this discussion are:
a) TA-55 is never mentioned again, and remains unevaluated.
b) The extent of modifications needed for TA-41 is not explained.
c) The rationale based on "programmatic requirements do not justify the costs...
is insufficient. Programmatic requirements are only for dismantlement "in an
environmentally responsible way that is also timely, cost effective, and uses to the
maximum extent practicable, existing facilities and infrastructure." (p. 2-1) Depending on
what modifications TA-41 needs, it could be that ES&H benefits might justify the changes
when programmatic objectives might not.
5) The draft EA does not present all reasonable alternatives.
As one obvious example: there is no "Supplement No-Action Alternative Storage 1045/6
with Storage at other DOD Sites."
Given both the need for dismantlement to proceed in a timely but safe way, as well
as an equally valid and urgent need that any decision protect worker safety and public
health to the maximum extent, all reasonable alternatives must be available and evaluated
to provide flexibility in decision making.
6) The draft EA does not discuss all the plutonium storage locations at the Pantex Plant
itself.
The title of the draft EA seems to encompass the entire Plant (interim Storage of 1045/7
Plutonium Components at Pantex) yet only Zone 4 is ever discussed. In reality there are at
least two other locations at Pantex which store plutonium for various lengths of time: Cell
8 and 12-26 Vault, both in Zone 12.
In addition, there is another facility currently under construction in Zone 12,
referred to as Special Nuclear Material Staging Facility, which might be capable of holding
as many as 4,880 pits. (see attached document 2, "DOE Plutonium Strategy Task Force,
Steering Committee Meeting, January 30, 1992 (Predecisional), p.26)
None of this storage is taken into account in the Draft EA discussion. Nor has there
ever, to STAND's knowledge, been any mention of an intended EA process evaluating the
new Zone 12 SNM facility, yet that facility could store more pits than Zone 4 is currently
allowed to do.
Though Cell 8 and 12-26 might be used only to briefly stage pits until they are
transferred to a storage area, this should be discussed in the text of the draft EA.
The SNM Staging Facility, however, must undoubtedly be considered as relevant to
the draft EA's proposed action. it will provide such a significant amount of storage that it
changes the entire picture of pit storage time frames, options and capacity as portrayed in
the draft EA.
Such a significant facility also deserves at least the same amount of careful
evaluation process as is being applied to Zone 4 igloos.
7) The draft EA must accurately portray the history of dismantlement and pit storage at
Pantex. There are many instances where this is not the case, but the following two
examples are particularly pertinent:
a) In the Executive Summary DOE consistently uses the term storage. The purpose 1045/8
of the EA is even stated as, "to evaluate the environmental impacts of additional interim
storage of pits at Pantex..." (p. vii)
As previously discussed in comment 1d, pit storage is new to Pantex. If "additional
interim storage is true in any sense, it is only because it has become unavoidable given
the current condition of the complex and the change in the world situation. To portray it
as merely more of the same, a usual part of Pantex's work, is inaccurate. Pit storage has
transpired because it has been unavoidable. Being unavoidable does not mean that it is
not a significant change from either past practice or past mission which must be evaluated
as such.
In addition, because it is a NEPA process, the final version of this draft EA will
become a public document. As such, it is logical that most people will have access to and
read the Executive Summary. The summary must be scrupulously written and accurately
reflect the significant points of the whole. Section 1.1, Introduction and Background,
makes the distinction between staging and storage.
b) The text of the draft EA gives a false impression of the number of
dismantlements conducted in the past at Pantex when it uses a footnote within the
statement "The primary mission of the DOE Pantex Plant is the assembly and disassembly
of nuclear weapons." (p. 1 - 1) The footnote to the word "disassembly" reads: "Over
50,000 nuclear weapons have been dismantled in the last forty years."
Clearly the impression is that all 50,000 dismantlements took place at Pantex.
However, during the August 20, 1992 public meeting of the Defense Nuclear Facility
Safety Board, when a Board member pursued this same statement, the Pantex official
admitted that of the 50,000 dismantlements only an estimated 10,000 to 15,000 had
been done at Pantex.
8) As a public process (made possible at this point only by the efforts of the state of
Texas) which will produce a public document, it is important that there is some definition
of terms. 1045/9
a) Both NEPA and DOE use certain words and phrases with a particular intent. For
example, an "environmental" impact as defined by NEPA is very broad, encompassing far
more than the usual implication of the word. For the DOE, there are numerous terms such
as "DOE orders" or "safeguards and security" which have a consistent definition for DOE
which should be clarified for the general reader.
The draft EA offers listings of Acronyms (p. iv) and Abbreviations - Units and
Measures (p. vi). To enhance the public understanding of what is actually being said, a
listing and clarification of terminology should be added as well.
b) in addition, the EA must be careful not to confuse issues by using a similar set
of words which could give one impression but which could just as easily refer to
something else.
For instance, "The DOE Orders and procedures for ensuring safe and secure storage
of the pits would continue to be followed rigorously." (p. 3-1) One standard term for DOE
is "safeguards and security," referring to the control of the material rather than safety in a
health sense. "Safe and secure" leaves a reader in some doubt as to exactly what the
DOE is "rigorously" committed to by that statement.
9) Finally, but of extreme importance, the draft EA fails to make clear the implications for
worker exposure if the change from current pit storage to intensified pit storage begins to 1045/10
occur before automated systems are developed. Nor does the draft EA clearly commit to
Best Management Practices if the decision is delayed. In fact, it does not clearly commit
to best management practices even if the intensified storage is approved.
In Section 3.0 describing the proposed action, it states that proposed action
storage in either type of magazine would be, "in one of two configurations: multiple
stacking...and/or a single layer..." it then continues, "These two configurations represent
the bounding cases for the number of pits that would be held in a single Modified-
Richmond or SAC magazine." (p. 3-2)
No where in the draft EA does DOE commit to not using the single-layer
configurations depicted in Figures 3.5 and 3.6, both described as "(Bounding)," yet both
depicting and adding up to the maximum packing arrangement. However, on page 4-1 the
discussion warns of maximum packing, and states:
"Actual best management practice to facilitate required safeguards and
security activities and reduce worker exposure to radiation could dictate use
of other storage configurations that would provide less pit storage capacity."
In addition, the proposed action which would seem to allow DOE ample room for
storage, still hedges.
"individual pit containers could rest on casters rather than on the concrete
floor of the magazines, and aisles may also be used. This would facilitate
inventory operations, ensure worker safety, and accommodate operational
needs." (p. 3-2)
Wording such as "could" and "may" for procedures which ensure worker safety
and benefit other needs is unacceptable in this document -- particularly when outlining the
proposed storage option.
In closing, though there are many other significant points, they often fall into areas beyond
our resources or have been covered by other comments. These STAND comments are not
to be regarded as the limit of our interest or concerns.
If you, your staff, or DOE officials have any questions regarding these issues please
contact Beverly Gattis, STAND of Amarillo, at 806/358-2622. Thank you.
Sincerely,
Beverly Gattis
President
Table (Page 7 of Part 1045 DOCUMENT 1 Page 1 of 1)
PREDECISIONAL
DEPARTMENT OF ENERGY'S
PLUTONIUM STRATEGY TASK FORCE
STEERING COMMITTEE MEETING
JANUARY 30, 1992
Chartered by
RADM W. G. Ellis
Deputy Assistant Secretary for Military Application
Defense Programs
Chaired by
Charles G. Halsted
Director, Office of Weapons and Materials Planning
With Support From
Lamb Associates, Inc.
Don Ofte, Director, Plutonium Strategy Task Force
DOCUMENT 2
Page 1 of 2
PREDECISIONAL
PIT STAGING CAPACITY - PANTEX
LOCATION NET CUMULATIVE COMMENTS
POSITIONS POSITIONS
Cell 8 250 250 Available - In Use
To Be Replaced By SNM Staging Facility
12-26 Vault 150 400 Available - In Use
To Be Replaced By SNM Staging Facility
Zone 4 4080 4480 Available - in Use (Single Stack)
Igloos
SNM Staging 400 4880 Available 7/93
Facility
Zone 4 2720* 7600* Double Stack - Requires SAR Approval
Igloos and S&S Agreements
Weapons 3200* 12400* Single Stack - Requires SAR Approval
Staging 15600* Double Stack - Requires SAR oval
Igloos and S&S Agreements
*Rapid Implementation Possible
DOCUMENT 2 26 January 30,1992
Page 2 of 2

Part 1046

                        Office of the Attorney General
                                State of Texas
DAN MORALES
ATTORNEY GENERAL
     March 19, 1993
     The Honorable Hazel O'Leary
     Secretary of Energy
     Washington, D.C. 20585
     Re:  Environmental Assessments for the Interim Storage of
          Plutonium Components at the Pantex Plant
     Dear Secretary O'Leary:
     The Office of the Attorney General ("OAG") has received the draft
environmental assessment ("EA") for the "interim" storage of plutonium       1046/1
components at the Pantex plant. We appreciate the opportunity to review
the draft EA and look forward to working with the Department of Energy
("DOE") to ensure that the operation of the Pantex plant does not
threaten the health and safety of its workers and neighbors and the
natural resources of the Panhandle area.
I strongly believe, however, that the draft EA is deficient and that until
an environmental impact statement ("EIS") is completed, DOE will not be
in compliance with the National Environmental Policy Act of 1969
("NEPA"). The EIS process would ensure the full input of the public and
ensure that DOE would take a "hard look" at the environmental and
socio-economic consequences of its proposed activities, consider viable
alternatives to the method currently chosen by DOE, and ensure that the
adverse environmental and socio-economic consequences of its actions 
are minimized.
I have been deeply concerned about the activities at Pantex since I first
came into office in 1991. (1)  While I remain proud of the work done by the
workers at Pantex, I also remain profoundly concerned that generations
of Texans will be forced to live with a decision regarding the storage of
thousands of pounds of plutonium made behind closed doors.
As you know, DOE has operated in the past pursuant to a policy of
"decide, announce, defend." I believe that addressing this legacy is one of
________________________
(1) For your convenience, I have enclosed copies of all of the correspondence I sent to
your predecessor, Secretary Watkins. See Attachment A.
Secretary O'Leary
March 19, 1993
Page 2
your greatest challenges. Your office, reflecting the new direction of a
new administration, has an historic opportunity to break with the pat
12 years and to ensure that DOE does not continue with an exclusionary
vision of how it ought to accomplish its mission.
DOE's conclusions regarding environmental impacts in the draft EA
reflect the extremely--and impermissible--narrow crafting of the issue
assessed by the draft EA rather than the reality of dismantling
thousands of nuclear warheads over the coming years and storing, it
would appear, nearly 50 tons of plutonium at a single site for an
unknown period of time. Moreover, I believe that the conclusions
constitute a post hoc rationalization of a DOE decision to turn Pantex
into the de facto storage facility for plutonium, rather than the product of
a "hard look" at the consequences of DOE's dismantling and storage
activities it desires to undertake at Pantex.
More specifically, the draft EA is deficient for the following reasons:
     (1) DOE has failed to adequately consider viable alternatives
     to increasing the storage capacity at Pantex;
     (2) DOE has improperly segmented the dismantling and
     storage activities undertaken and to be undertaken at
     Pantex; and
     (3) DOE has failed to adequately assess the risk of
     dismantling thousands of nuclear warheads and storing the
     plutonium pits at Pantex.
   I. DOE has failed to adequately consider viable alternatives to                1046/2
   increasing the storage capacity at Pantex.
DOE's analysis of alternatives to the proposed action of expanded interim 
storage is extremely superficial at best. This failure to seriously analyze
the alternatives indicates that DOE has already determined to go forward
with increased interim storage at the Pantex plant and that the draft EA
was produced simply to pay lip service to the requirements of the 
National Environmental Policy Act.
   II.  DOE has improperly segmented the dismantling and                          1046/3
   storage activities undertaken and to be undertaken at Pantex.
DOE has improperly segmented the analysis of its proposed increased
activities at Pantex. While the possible environmental effects of
increased interim storage are discussed, the draft EA completely ignores
the environmental consequences resulting from the increase in
Secretary O'Leary
March 19, 1993
Page 3
dismantling activities necessitating the increased storage. The draft EA
should include, inter alia, a comprehensive analysis of the increase in
waste generated at the plant as a result of the increased dismantlement
activities.
For example, in the past DOE budget requests and in the Pantex Plant's
Environmental Restoration and Waste Management Five Year Plan for
Fiscal Year 1993, the Department refers to a high explosives incinerator
(see page 6-31 of FY 1993 Five Year Plan). Given that the need for this
incinerator necessarily relates to the increased dismantlement activities
at Pantex, it would appear that the potential environmental impacts from
the incinerator should have been discussed in the EA.
We also note that in the DOE budget request for FY 1993 that DOE
requested funds for a "Hazardous Waste Treatment and Processing
Facility."(2)  According to DOE's description provided to OMB:
       This facility will permit the treatment and declassification of 
       low-level radioactive waste (depleted uranium, tritium and
       thorium), hazardous waste, solvents, mixed waste, and
       classified metal components generated at Pantex Plant.
Again, it would appear that the potential environmental impacts from the
waste treatment facility, in the event DOE pursues construction of the
facility, should have been discussed in the EA.
Furthermore, the cumulative environmental effects associated with the
increase in movement of warheads into Pantex, the generation of waste
products, and the movement and storage of plutonium pits should have
been more adequately analyzed.
   III. DOE has failed to adequately assess the risk of                          1046/4
   dismantling thousands of nuclear warheads and storing the
   plutonium pits at Pantex.
DOE has failed to address safety and risk issues in the draft
EA. This is a fundamental deficiency of the draft EA.
                  A. Lack of Meaningful Safety Policy
DOE has long been criticized for its failure in developing a set of
comprehensive and satisfactory safety procedures, i.e., a "safety policy,"
for its nuclear weapons facilities. Without such an overarching,
meaningful safety policy against which to measure fundamental safety
policy decisions at its sites, it is difficult to understand how the DOE
__________________________
(2)  See Attachment B.
Secretary O'Leary
March 19, 1993
Page 4
under your predecessor was able to adequately develop the "Safety
Analysis Report" (or "SAR") which preceded the draft EA and upon which
much of the analysis of the draft EA was based. Moreover, it is difficult
to understand how, if the draft EA would have properly analyzed the
complete range of dismantlement activities at Pantex. DOE could
adequately develop SARS for each of the activities associated with the
dismantlement and storage of the nuclear weapons.
As stated by the Office of Technology Assessment: (3)
     In its Final Report on DOE Nuclear Facilities, the DOE
     Advisory Committee on Nuclear Facility Safety ["ACNFS"]
     noted that the Job of solving the operational and safety
     problems at the DOE weapons complex is "far from
     complete" and that some of the problems "will take into the
     next century" to correct. (4)
Although DOE did issue a new Nuclear Safety Policy in September 1991,
DOE was subsequently criticized by the ACNFS in its final report for
substituting nebulous language such as "continuous improvement" for
measurable standards; for paying little attention to the largely chemical
nature of the risk at some DOE facilities; and for inadequately treating
the inevitable conflict between safety and production responsibilities by
simply assessing that they are "compatible." The ACNFS's report stated
that DOE needs to spell out how safety goals will be achieved, how
priorities will be set, how self-assessments will be judged, and how
progress and success will be measured. (5)
At this time, we are not confident that DOE under your predecessor
provided sufficient guidance to its regional and field offices for them
to make meaningful decisions about acceptable risks, risk
assessment methodology, and procedures and policies to identify
and minimize safety risks. Such decisions would, of course, be
_____________________
(3) OTA Assessment Proposal: Managing Nuclear Materials from Warheads. Feb. 1,
1992: submitted to Senate Committee on Governmental Affairs.
(4) [Footnote in original.] Advisory Committee on Nuclear Facility Safety. "Final Report
on DOE Nuclear Facilities." report prepared for the Secretary of Energy, U.S.
Department of Energy, Washington, D.C., Nov. 1991. p.11. The ACNFS vigorously
advocated the development of a department-wide safety policy which would allow
different parts of the DOE to make internally consistent decisions between possibly
conflicting values such as safety and production.
(5) See Statement by J. Dexter Peach, Assistant Comptroller General, General
Accounting Office, given at Hearing before the Senate Committee on Governmental
Affairs of Nuclear Disarmament on Department of Energy, Feb. 25, 1992 ("Hearing").
p.5.
Secretary O'Leary
March 19, 1993
Page 5
reflected in the SAR or SARS providing the basis or bases of the EA
or EAs. I believe that production of an EIS would ensure the public
that important risk and safety issues were clearly and fully
analyzed.
More specifically, the draft EA does little to allay our concerns about the
potential safety problems that could arise from DOE's proposed activities.
Of particular concern to us in the analyses in the draft EA of the
probability of an airplane crash with Zone 4 Pantex plant structures and
the potential impacts on the Ogallala Aquifer from a plutonium dispersal
accident ;in Zone 4. We refer you to the comments submitted by the
Texas Air Control Board and the Texas Department of Public Safety
(Division of Emergency Management). Furthermore, we refer you to
several issues raised by the City of Amarillo and the Counties of Potter
and Randall regarding potential effects of the maximum winds of a 
category F4 tornado, as well as the possibility of terrorist actions
involving an aircraft.
                     B. Lack of Resources to Ensure Safety.                      1046/5
It is not only the lack of a meaningful DOE safety policy against which to
measure a safety analysis which makes the draft EA deficient, it is also
the lack of an adequate analysis of whether Pantex has the necessary
resources to undertake its new mission. (6)  As stated by the GAO:
     Over the next several years, DOE must take custody of and
     dismantle thousands of nuclear weapons that the
     Department of defense will retire. The capability of DOE to
     safely dismantle so many weapons could present a 
     problem and tax the capabilities of DOE resources at the
     Pantex plant in Texas. Storage of weapon components at
_____________________
(6) Until the last two years, the mission od Pantex was to construct and dismantle
nuclear warheads. The components of dismantled weapons, including the plutonium
pits, were shipped back to the facility from which they came originally. The mission of
Pantex today--to dismantle thousands of warheads, store and manage the plutonium
pits extracted therefrom, and to help maintain a nuclear weapon stockpile a fraction of
the size which existed during the Cold War--is clearly different. Such a change in 
mission may in and of itself necessitate an EIS.
Secretary O'Leary
March 19, 1993
Page 6
     the plant, the projected workload to accomplish this work,
     and the transportation of weapons to the plant are important 
     issues that need to be examined carefully. (Emphasis
     added.) (7)
I believe the adequacy of resources issue needs to be more fully
addressed.
   IV. Closing Comments                                                          1046/6
DOE provides no basis for the estimated interim storage time frame of 6-
10 years. Given that DOE does not yet have a proposal for long-term 
plutonium disposition, the statement in the EA that the time required
to implement decisions regarding long-term storage and/or disposition is
expected to be within a 6-10 years time frame is not credible. I am
concerned that the analysis of potential environmental impacts has been
premised on an interim storage period that is unrealistic. If anything can
be learned from DOE's civilian high-level  waste site experience and the
attempts by the states to locate low-level radioactive waste sites, it is that
nuclear waste storage issues are very difficult to resolve and take far
longer to resolve than first anticipated.
Many of the concerns raised in this letter are addressed in detail in the
comments submitted to you by the Texas Air Control Board, the Bureau
of Economic Geology and the Texas Department of Health's Bureau of
Radiation Control. Comments by other state agencies, individuals, and
citizen groups identify other areas of concern in the draft EA. I am
hopeful that the DOE will respond to each of these comments, especially
those of the above-mentioned state agencies.
When DOE first proposed increased interim storage of plutonium pits at 
Pantex, I requested that your predecessor direct DOE to prepare an EIS
that would address the impacts of the increased dismantlement and
storage activities at Pantex. I respectfully repeat this request now. It is
apparent from the draft EA that DOE will not run out of storage capacity
at the Pantex plant until the fourth quarter of 1993, at the earliest. DOE
has sufficient time to complete an EIS that will adequately address the
potentially devastating environmental impacts that could result from the
proposed increased interim storage.
The preparation of an EIS by DOE would demonstrate DOE's
commitment under your guidance to fully protecting the health, safety,
_____________________
(7) Statement by Victor S. Rezendes, Director, Energy Issues, GAO, given at Hearing. p.
5.
Secretary O'Leary
March 19, 1993
Page 7
and environment of this state and its citizens and would mark an historic
new direction for DOE towards full and legitimizing public participation
and open decision making. I welcome your suggestions as to how we
might encourage and support your efforts in the future.
Sincerely,
Dan Morales
Attorney General

Part 1048

Panhandle
Area
PANAL Neighbors
And
Landowners
HCR 2 BOX 20 PANHANDLE, TEXAS 79068 (806)335-1050
February 28, 1993
To the United States Department of Energy
Through the Office of the Governor, State of Texas
P.0. Box 12428
Austin, TX 78711
On behalf of the Panhandle Area Neighbors and Landowners (PANAL) we
wish to address the issues involved in the Predecisional
Environmental Assessment for Interim Storage of Plutonium
Components at Pantex.
PANAL is composed of a wide diversity of people, from farmers and
ranchers to teachers, geologists, lawyers, religious, clerical,
small and large business people, bankers, doctors, etc.. PANAL is
composed of a broad spectrum of concerned citizens, people who have
a strong tie to the land and people with a sincere commitment to
protecting the human environment for future generations.
Many of us are farmers, ranchers, landowners and families who
surround the Pantex Plant, live downwind from the plant, or people
who just believe in a democracy that includes involvement by all
people. We are Democrats, Republicans, Independents and represent
a variety of other agricultural, civic, church and community
organizations.
For those of us who till the soil it is our belief that the manner
in which we treat the land will in large measure determine the
productivity of our labors. The soil, water and air must be
conserved and protected from all possible contamination. We
believe this and we have lived by this rule so that our children,
grandchildren, great grandchildren, and all future generations to
come, will have the opportunity to also enjoy the fruits of the
land.
What we produce for this nation must always be the most wholesome,
clean and safe food supply possible. The nation depends on us to
provide such safe, healthy commodities, not only for our country,
but to use as power with the other nations of the world.
After consideration of the DOE's predecisional EA we believe that
our livelihood and our potential to produce quality food for the
world is in jeopardy. The modeling used in this document was 1048/1
intended to justify the storage of plutonium pits at Pantex and has
not taken into consideration the human environment or the $4
billion agricultural economy which is the lifeblood of this area.
"Environmental impacts would be limited to radiation exposure of
workers which would be controlled to insure that ALARA objectives
are achieved"(vii), (3-2), (4-1); to assume no adverse health
effects among workers is ludicrous. Workers will receive increased 1048/2
radiation doses in taking pits from Assembly Bay to Zone 4 - will
these be the same workers? If there are fewer workers there will be
higher doses, but if there are more workers there is, less exposure,
but more people are involved.
In inventorying the pits, the estimates for worker radiation
exposure are based on current inventory operations - these in no
way are a guide for determining full worker exposure for the future
operations. "Impacts of the proposed action were assessed and
found to be limited to worker exposures to radiation" (viii, 4-4,6-
1) - we demand for the workers that this proposed action be further
examined - no one person's life is expendable.
For the workers who handle the pits the radiation risks are not
fully analyzed. The EA has failed to adequately address radiation 1048/3
exposure to the workers. "The workload requirements for increased
weapons disassembly is expected to be similar...in the past" (1-1)
how can this be when the workload is increased?
"The Pantex Plant has conducted these activities in a safe and
reasonable fashion for more than 40 years" (1-1) the SAR's, the GAO
Report, the Tiger Team, the Adhearn Committee Report - are all 1048/4
these reports in error? Pantex has been nominated for a Superfund
site, is this because the activities have been conducted safely and
reasonable? Why is ER/WM now being addressed at Pantex if the
above statement is true.
In a statement made by Lowell F. Cranfill, President/Chief Steward,
Metal Trades Council, Mason & Hanger, May 17, 1989, before the 1048/5
Subcommittee on Health and Safety, Committee on Education & Labor,
U.S. House of Representatives, he states "I am very seriously
concerned with the health and welfare of my friends and members of
my union working at the Plant. I am also concerned with the
Panhandle of Texas and the potential problems they may have in that
area due to the toxic waste that are accumulating because of the
spills and dumps from Pantex. I know that the Energy Department
estimate last June was in excess of 700 million dollars to clear up
the Pantex Plant. I do not know what the spills and dumps consist
of. I solicit your aid in trying to find that out and help us
clear up the plant. It is a serious and dangerous hazardous waste
dump if that amount of money is to be spent in trying to clear it
up. I would like to be involved in stopping the things that Pantex
is doing that is causing the need for such expenditure.
(2-1,4-2,4-3)"...long term storage or disposition of these valuable 1048/6
national assets will be made in the...PEIS" - why is this EA being
done outside the PEIS/ROD? Justification needs to be made as to
why they are referred to as national assets and not liabilities? 1048/7
To presume "assets" and not to address liabilities is in
appropriate.
(2-1, 4-1, 4-3)"...DOE maybe required to cease the disassembly
activities..." what is the rush? Under the treaties signed we're
not obligated to dismantle immediately, there was no time limit
specified. Why not ship warheads or pits to other sites - Pantex is 1048/8
not the only site available for dismantlement or storage, why were
other DOE and DOD sites not adequately addressed? To state that no
DOD facility is "currently available" must be proved. Not
addressing the DOD facilities in full is a false conjecture.
To come to the conclusion that "there is no environmental benefit
to be tallied in packaging and shipping some or all of the pits to 1048/9
any other location for interim storage purposes" (viii) has no
credible basis from the information presented in the EA.
(4-5,4.4) Why is transportation of pits so much more dangerous than
entire warhead or component parts? Is shipping and handling
dangerous just for some materials? How dangerous is this stuff - 1048/10
DOE was shipping it before to RF, what is the difference now? If
there is danger in transportation, why were these problems not
addressed sufficiently? What about the transportation in to Pantex
at the present time? Is this not dangerous also?
(3-2, 4-2,A-3) "The majority ...packaged in AL-R8 containers, but
other approved containers may be used." What is the history of 1048/11
those containers? What are the "other approved containers"? A
thorough discussion of containers is imperative. Can these
containers be used for shipping and/or storage? What are the test
results on any of these containers? Pits change over time, what
happens to containers that change over time? With pits and 1048/12
containers changing over time, what are we looking at for the
future? Do you have any idea how these will react, either
individually or collectively, over time?
5.0... any serious dispersal of plutonium was not carefully
examined. 5.2... does not talk about risks to the general off-site 1048/13
population. Off-site ionizing radiation was not even considered.
No Emergency Preparedness plans were presented for off-site
communities in the event of a hazardous or toxic release.
6.2.5, Appendix F Aircraft Hazard Analysis does not present an
accurate account of aircraft over Zone 4. Wednesday, February 24,
1993, we sat right here in our home on the west side of Pantex with 1048/14
the Special Project Directors of the OTA Study on Dismantlement and
watched three C-5A's practice "touch and go" for three hours.
These aircraft fly directly over Zone 4. We have observed military
aircraft of all descriptions flying over Pantex for years. This is
regular military practice. Army helicopters regularly fly over
Pantex. We watch them, we know this is happening! What hazard
analysis do you propose for these aircraft?
7.0 Potential impacts on the Ogallala Aquifer... does not address
the possibility of cracks in the soil, from Texas Panhandle 1048/15
droughts, thereby creating faster pathways to the Ogallala. Why
were DOE LANL studies used and not studies done by local geologists?
According to NEPA, our basic national charter for protection of the
environment, "procedures must insure that environmental information
is available to the citizens before decisions are made and before 1048/16
actions are taken." Furthermore, it is stated that "ultimately, it
is not better documents but better decisions that count." "Federal
agencies shall encourage and facilitate public involvement in
decisions which affect the quality of the human environment.
We state this as a preface to our comments, because there is a lack
of sufficient, accurate information provided to warrant the
continuation of the present mission of the storage of plutonium at
Pantex. Furthermore, the public is not involved in the decision
making - we are only given a short time to "comment". Under NEPA
all information must be presented and all reasonable alternatives
must be defined. Alternatives are the heart of an EA, every
alternative should be discussed.
The focus presented in the Predecisional EA is too narrow, as only
one option was discussed. The presentation does not legally address
all alternatives. The only discussion is -STORAGE- as opposed to
looking at the full picture, the entire scope of the plutonium
issue or plutonium management, which is bigger than just storing
pits at Pantex.
The Executive Summary, vii, and 3-1 states "SAC magazines have not
been used previously for holding pits, and the multiple stacking 1048/17
configuration has not been used previously in SAC or Modified-
Richmond magazines." Our question is then why are you going to
store plutonium, with a half life of 24,000 years in a structure
which is not proven to be 100% safe for `holding pits'? What 1048/18
consideration is being given to the possibility of contamination to
the land, the air or the Ogallala? Is Zone 4 the only place the
DOE intends to `hold pits'? This is the only area discussed in 1048/19
the EA. What about the other structures, bays, etc.?
"The proposed action is to provide additional storage for an
interim time period, expected to within 6 - 10 years, for up to 1048/20
20,000 pits....at the Pantex Plant" What will happen in 10 years -
15 years - 20 years, etc.? Where is the plutonium going at the end
of 10 years - we want to know! This is not identified in the EA.
Where or what is being planned for this plutonium after 20 years.
DOE assumes there will be no problems, either human or mechanical
at any time during storage. All potential problems associated with 1048/21
storage need to be addressed.
For the EA to state that the proposed action would not result in
additional generation or management of wastes (vii) - evades the 1048/22
original issue being dismantlement - which is increasing so the
pits can be stored at Pantex and there is additional waste being
generated. The issue of waste management was not addressed in the
EA. This is a major issue and needs to be fully explored.
who have done in-depth studies on the Ogallala? LANL studies have
not correctly addressed the full scope of the aquifer and the 1048/23
potential impacts. DOE's previous record of contamination to
underground water supplies only reinforces the lack of
accountability in DOE studies.
7-2..."Field experiment ...suggests colloidal transport will not
enhance radionuclide transport enough to significantly affect 1048/24
groundwater quality" Hogwash, "suggest", "not enough" and
"significantly affect" have no place in a study of drinking water
for the people of the area. We are being fed a document prepared
by an agency that has no credibility in preserving present water
supplies at any of their other facilities.
To come to the final conclusion of "no significant threat to the
Ogallala Aquifer from plutonium dispersal" is simply conjectural.
8.0 All issues should have been discussed openly with federal, 1048/25
state and local agencies with local citizen input. To only have
kept the state agencies informed of the development of the document
undermines the integrity of the work of the state agencies.
DOE says they are committed to the environment, safety, and health
of workers and surrounding communities! Why push to dismantle 1048/26
warheads and expose the population to health and death risks?
It is the opinion of the membership of PANAL that this mission
requires a site specific environmental impact statement (EIS). It 1048/27
is our belief that an environmental assessment and FONSI is totally
inadequate. Dismantling 20,000 warheads and storing plutonium pits
at Pantex is a new purpose for Pantex (and a major federal action)
which significantly affects the quality of the human environment.
There is plenty of time to study every issue and alternative. A
Pantex EIS needs to address all the issues related to Pantex, the
alternatives, the capabilities of other facilities, plus any and
all environmental effects not only on-site and to workers, but also
off-site and to the agricultural economy. An EIS needs to address
the entire plutonium management issue. We request a draft document
for public participation, comment time and public hearings.
What we're going to do with plutonium pits needs to be ultimately
done only after a comprehensive, credible accounting is done by all
affected parties, state all federal agencies and technical experts.
When will the policy be made for the future use of the pits.
Thank you for the opportunity to comment on this document.
Sincerely,
Doris and Phillip Smith
Chairmen

Part 1049

PANHANDLE 2000
P.O. Box 9480 Amarillo, Texas 79105 (806)373-7925
March 12, 1993
The Honorable Howard Canter
Deputy Assistant Secretary for Reconfiguration
Office of the Assistant Secretary for Defense Programs
United States Department of Energy
1000 Independence Avenue, S.W.
Room 4B-014
Washington, D.C. 20585
Dear Howard:
Texas governor Ann Richards recently forwarded to Secretary of Energy Hazel
O'Leary the comments received by the State of Texas regarding the Environmental
Assessment of the proposed interim storage of plutonium at the Pantex Plant in Amarillo,
Texas. In her letter to Secretary O'Leary, Governor Richards requests an additional
extension of the deadline for comments to be submitted to DOE on the Environmental
Assessment to March 16, 1993. Panhandle 2000 supports the Governor's request for an 1049/1
extension, and would respectfully request that DOE favorably consider granting the
extension. The extension will provide State agencies and other interested parties sufficient
time to comment fully on the Environmental Assessment, and will allow all parties to feel
as though they have had their "day in court" with DOE on this issue. Granting the extension
will, in our opinion, foster support for DOE's final decision on interim storage, and will
demonstrate that the cooperative relationship with the State of Texas DOE has established
will continue in the new Administration.
We at Panhandle 2000 clearly support DOE's preliminary decision to house the
interim storage function at Pantex, and understand fully its importance in the context of the
full-blown reconfiguration plans. After carefully reviewing the comments submitted to date,
it is our opinion that the debate centers not on DOE's conclusion that no significant increase
in risk will occur from the additional storage, but merely on the data and methodologies 1049/2
used by DOE in its analysis. Such a debate, while important, should not serve to impede
DOE's plans regarding interim storage or final reconfiguration. Pantex continues to enjoy
strong support from State officials and residents, especially those from the Texas Panhandle.
We look forward to a swift resolution of the issues discussed in the comments, and
implementation of the plans for interim storage at Pantex.
The Honorable Howard Canter
March 12, 1993
Page 2
I also wish to express our support for the proposed plan to site a research facility at
the "plutonium site" selected by DOE in the reconfiguration process. We are hopeful
Secretary O'Leary will concur in this aspect of the reconfiguration plan and stand ready to
assist you in accomplishing this end. The heads of the University of Texas, Texas A&M
University, and Texas Tech University run formulating plans for a research consortium to
assist DOE in its research efforts, especially if Pantex is chosen as the site for this research
facility.
Finally, we have noted with interest the Secretary's recent decision to review the
Nonnuclear Reconfiguration Cost Effectiveness Study. We are willing to assist DOE in the
selection of the consultants charged with evaluating this decision if appropriate, and look
forward to working with your office on this issue.
Thank you for your consideration of our views. Please contact me if I can be of help
to you or your office. I hope to see you soon.
Yours very truly,
Jerome W. Johnson
JWJ/gb
xc: The Honorable Ann Richards
Governor, State of Texas
P.O. Box 12404
Austin, Texas 78701
The Honorable Bob Bullock
Lieutenant Governor
P.O. Box 12068
Austin, TX 78711
The Honorable Howard Canter
March 12, 1993
Page 3
The Honorable Bob Krueger
United States Senate
703 Senate Hart Office Building
Second and Constitution
Washington, D.C. 20510
The Honorable Phil Gramm
United States Senate
370 Russell Building
Washington, D.C. 20510
The Honorable Bill Sarpalius
Congress of the United States
House of Representatives
223 Longworth House Office
Washington, D.C. 20515
The Honorable Barry Combest
Congress of the United States
House of Representatives
1511 Longworth House Office
Washington, D.C. 20515
The Honorable Teel Bivins
State Senate
P.O. Box 12068
Capitol Station
Austin, Texas 78711
The Honorable John Smithee
Texas House of Representatives
P. O. Box 2910
Austin, TX 78768-2910
The Honorable David A. Swinford
Texas House of Representatives
P.O. Box 2910
Austin, TX 78768-2910
The Honorable Howard Canter
March 12, 1993
The Honorable Warren Chisum
Texas House of Representatives
P.O. Box 2910
Austin, TX 78768-2910
Mayor Keith Adams
P.O. Box 1971
Amarillo, Texas 79186
Mr. Tom Patterson
Amarillo Chamber of Commerce
P.O. Box 9480
Amarillo, TX 79105
Mr. Wales Madden, Jr.
Attorney at Law
712 West 9th Street
Amarillo, TX 79101

Part 1050

SENATOR TEEL BIVINS DISTRICT OFFICES.
DISTRICT 31 P.O. Box 9155
The Senate of Amarillo, Texas 79105
The State of Texas (806)374-8994
COMMITTEES P.O. Box 1673
Midland, Texas 79702
Finance (915) 682-0455
Education
Natural Resources CAPITOL STATION
Chair, Sub-Committee on Agriculture P.O. Box 12068
International Relations. March 22, 1993 Austin, Texas 78711
Trade & Technology (512)463-0131
TDD (512)475-3758
The Honorable Hazel R. O'Leary
Department of Energy
Washington, D.C. 20585
Dear Secretary O'Leary:
This letter is to commend you and your staff on the process you have implemented
regarding the Department of Energy's Predecisional Environmental Assessment for Interim
Storage of Plutonium Components at the Pantex Nuclear Weapons Facility in Amarillo,
Texas. As the Texas Panhandle's state senator, I'm sensitive to the issues you face as you 1050/1
deliberate the future of our nuclear weapons complex, including Pantex. My constituents
have the most to gain economically and lose environmentally from Pantex. To proceed
with any DOE plans for Pantex, it's important for citizens of that area, and the officials
who represent them, to have a high degree of confidence that DOE activities will be
conducted in a safe, environmentally sound fashion.
In the past, the public has been unable to have this kind of trust in DOE activities. I'm
delighted to see the new administration is operating in an open, cooperative manner. This
new openness is reflected in the approach your department took regarding the interim
plutonium storage issue at Pantex. You invited comments not only from state agencies
but also from other interested parties. To give everyone an opportunity to comment fully
on the issue, you extended the deadline for comments not once, but twice, when requested
by the state. The January 1993 briefing by top DOE staff for state officials and other
parties on the interim storage issue was very informative and exhibited the new
constructive dialogue encouraged by the department which is welcomed by the state.
Finally, DOE's offer to respond to all comments before proceeding with the plans,
although the department is not required to do so, build on the improved relationship
between DOE and the state.
I respectfully encourage you to continue this healthy dialogue after DOE responds to the
state's comments on the interim storage issue. Agreeing to sit down and discuss
differences, with the goal of resolving them, will ensure that the interests of both DOE
and the state are protected. Further, this dialogue would serve to resolve outstanding
issues in an expeditious manner and avoid a long, drawn-out "paper exchange." Although
this dialogue may conclude with differences of opinion on some small issues, I'm
confident that an accord can be achieved on the "big picture" items which will allow DOE
to proceed after taking the comments into account. I would appreciate being involved in
these meetings and will pledge my assistance and support to the process.
Thank you for your consideration of my views. I look forward to working with you in
the future to ensure that Pantex remains an important, growing and environmentally sound
facility for many years to come.
Yours Truly,
Teel Bivins
State Senator
TB/jh
cc: Governor Ann Richards
Lt. Governor Bob Bullock
Speaker of the House Pete Laney
Howard Canter
Deputy Assistant Secretary for Weapons Complex Reconfiguration
Office of the Assistant Secretary of Defense Programs
U.S. Department of Energy
1000 Independence Avenue, S.W., Room 4B-014
Washington, D.C. 20585
Daniel R. Rhoades
Director, Pantex Program Office
U.S. Department of Energy
Germantown Building
19901 Germantown Road
Germantown, Maryland 20545

Section II Letters Received on the Revised Pre-Approval Environmental Assessment and Public Meeting Volume II, Section II

Letters Received During The Two-Week Comment Period Following
The
 December 6, 1993 Public Meeting (December 6 to December 20,
1993)
Author/Organization                                             Dated
 1. O'Brien/Operation Common Sense                              December  6
 2. Osborne                                                     December 16
 3. Gustavson/Bureau of Economic Geology,                       December 20
    University of Texas
 4. Hutchison/Oak Ridge Environmental Peace                     December 20
    Alliance
 5. Gilliland                                                   December 13
 6. Graham                                                      December 16
 7. Chandler                                                    December 13
 8. McReynolds/Panhandle Area Alliance                          December 14
 9. Rossman                                                     December 13
10. Saunders                                                    December  9
11. Saunders                                                    December 17
12. Morrison                                                    December 13
13. Harpole                                                     December 13
14. Patterson/Amarillo Chamber of Commerce                      December 15

Part 1

                       Operation Commonsense
----------------------------------------------------------------------
December 6,1993
The Honorable Hazel R. O'Leary
Secretary Of Energy
Department of Energy
Washington, D.C. 20585
Dear Secretary O'Leary,
      I have read the Department of Energy's response to comments
received from the State of Texas regarding the Environmental
Assessment for Interim Storage of Plutonium Components at Pantex.
It is apparent from your Department's response and the wide popular
support for dismantlement that there is little doubt this mission will
move forward and we join in supporting that goal. Our interest is to
ensure that the issues that create safety and environmental
problems as detailed in recent reports from the General Accounting
Office and the Office of Technology Assessment are properly
considered, even though they might impact either the speed of
dismantlement or the storage of the pits,
      We believe the Department's decision not to provide a
Environmental Impact Statement (EIS) on the Interim Storage is
wrong and is the result of political considerations rather than careful
application of the law. In an attempt to provide you with our basis for
this statement, I enclose a legal brief addressing critical and relevant
reasons why the law requires a EIS.
Box 9618 Amarillo, Texas 79105 - Phone 806-372-3877 Ext: 104 - Fax 372-7207
Operation Commonsense
Page: 2
December 6, 1993
              Your predecisional finding fails to properly address several
        significant areas: 1) The wide gulf between the University of Texas
        Department of Economic Geology's work on water mobility and
        recharge rates from the playa lakes to the underground aquifers and
        Los Alamos's characterization of those findings as "unreasonable
        and unrealistic".; 2) the failure to devote any detailed analysis to the
        possibility of terrorist attack. This ignores one of the foremost
        concerns of many experts; 3) The adequacy of the World War II
        bunkers for storage. Compared to nuclear store requirements as set
        forth by the Center for Energy and Environmental Studies at
        Princeton along with the Department of Nuclear Engineering at MIT,
        the bunkers are inadequate [see exhibit in our brief]; 4) The
        consideration of alternative sights for storage, either interim or
        longer term, is not-adequately explored. Hanford, as well as DOD
        sites, have been mentioned often as desirable by some experts. This
        is not a complete list but should point out some areas that haven't
        been adequately explored.
              We hope to meet with Department officials in order to explain
        in more detail our concerns. We will offer suggestions in a manner
        allowing the needs of the Department to be reconciled with the safety
        concerns of many citizens. We hope for a solution in the form of a
        storage plan that will allow dismantlement to proceed at a reasonable
        rate.
        Sincerely,
        W. H. O'Brien
  Box 9618 Amarillo, Texas 79105 - Phone 806-372-3877 Ext: 104 - Fax 372-7207
                             OPERATION COMMONSENSE
                              Application of NEPA
                        To Interim Storage of Plutonium
APPLICATION OF NEPA
TO THE PROPOSED INTERIM STORAGE OF PLUTONIUM PITS
AT THE PANTEX NUCLEAR WEAPONS FACILITY
NEAR AMARILLO, TEXAS
SUBMITTED TO THE DEPARTMENT OF ENERGY
AT AN ENVIRONMENTAL ASSESSMENT HEARING
DECEMBER 6, 1993
SUBMITTED BY:
SUSAN CURRIE
IN COOPERATION WITH:
OPERATION COMMONSENSE
                          TABLE OF CONTENTS
     I.  INTRODUCTION
     II.   APPLICATION OF NEPA
         A.    Purpose of NEPA
         B.    Statutory Requirements of NEPA
           1.    The Environmental Impact Assessment
                 a.   Purpose
                 b.   Requirements
           2.    Finding of No Significant Impact (FONSI)
                 a.   Purpose
                 b.   Requirements
           3.    The EIS
                 a.   Purpose
                 b.   Scope
                 c.   General Requirements
         C.    Review of the Decision Not to Prepare an EIS
           1.    General
           2.    Standard of Review
           3.    "Significance"
           4.    "Effect"
           5.    Alternatives
     III.  APPLICATION OF NEPA TO PANTEX NUCLEAR WEAPONS FACILITY
         A.    Proposal For Storage of Plutonium Pits
         B.    The EA Submitted by the DOE
           1.    General
           2.    Effects Not Addressed
           3.    The FONSIs
           4.    Discussion of Alternatives
           5.    Define the timetable for interim storage
           6.    Regulatory authorities
     IV.   CONCLUSION
                                      2
I.    INTRODUCTION
      On December 17, 1992, the Department of Energy (DOE) submitted an Environmental
Assessment (EA) for the proposed interim storage of 20,000 plutonium pits, scheduled to be
disassembled from nuclear weapons, at Pantex nuclear weapons plant near Amarillo, Texas.(1)
In its EA, the DOE claims that the plutonium pits will be temporarily stored at Pantex until a long-
term storage facility is designated in the DOE's Nuclear Weapons Complex Reconfiguration
Programmatic Impact Statement (PEIS).(2)  According to the EA, the DOE cannot postpone
disassembly until a long-term storage facility has been designated and constructed because
presidential initiatives, enacted at the end of the Cold War, promise to reduce the nuclear
weapons arsenal at a specified rate.(3)  Contending that there can be no significant variance
from this specified rate, the DOE argues that a temporary storage site must be utilized.
      The DOE has chosen Pantex as the site for temporary storage. Pantex, managed and
operated by Mason & Hanger-Silas Mason Company, Inc., has been in operation for more than
forty years. Its mission includes the assembly, stockpile testing, maintenance, modification, and
retirement of nuclear weapons.(4)  Until 1989, Pantex worked closely with another nuclear
____________________________
   (1)  U.S. Dept. of Energy, EA-0812, Environmental Assessment for Interim Storage of
Plutonium Components at Pantex (1992) [hereinafter EA].
   (2)  Id. at 2-1.
   (3)  Id. at 1-1. On this page of the assessment, the DOE states that the presidential
initiative is to reduce the nuclear arsenal from 20,000 warheads to 10,000 by the year
2000. To meet this goal, the DOE has established a disassembly rate of 2,000
warheads per year.
   (4)  United States General Accounting Office, Report to the Chairman, Environment,
Energy, and Natural Resources Subcommittee, Committee on Government Operations,
House of Representatives, "Nuclear Health and Safety: More Attention to Health and
Safety Needed at Pantex" (1991), at 2 [hereinafter GAO REPORT].
                                         3
weapons facility, Rocky Flats near Denver, Colorado. The Rocky Flats facility manufactured pits
which were sent to Pantex for assembly into nuclear weapons.(5)  Pantex would, in turn, send
disassembled pits to Rocky Flats for recovery and reprocessing of special nuclear material and
fabrication into new pits.(6)  In January of 1992, the Secretary of Energy permanently ceased
reprocessing operations at Rocky Flats, and since the pits were no longer being reprocessed,
the need for an alternative mode of disposal arose.(7)  No such alternative has yet been
designated, and the pits from disassembled weapons have remained at Pantex.(8)
     The DOE's position is that the pits should remain at Pantex in interim storage because
no other DOE or DOD facility can accommodate the pits on an interim basis safely and within the
necessary time frame.(9)  This argument is weak however, because Pantex's management and
safety record is marginal at best. Since 1989, Pantex has been criticized by OSHA and by a
DOE Tiger Team--a group of specialists assembled to assess the environmental, safety, and
health conditions at the plant--due to health and safety problems existing at the plant.(10)
According to a 1991 General Accounting Office (GAO) report, the problems include: [1]
incomplete safety analysis reports, [2] an inadequate radiation protection program, and [3]
______________________________
   (5)  EA, supra note 1.
   (6)  Id.
   (7)  EA, supra note 1, at 1-2.
   (8)  Id.
   (9)  EA, supra note 1, at 4-1.
   (10) GAO REPORT, supra note 4, at 3.
                                         4
violations of worker-protection standards.(11)  Due to Mason & Hanger's unsafe procedures at
the plant, the GAO report states that workers have negligently been exposed to radioactive
elements.(12) 
      The report discusses three particularly grave violations. First, in 1989, a radiation
specialist discovered that a worker had been contaminated with depleted uranium after coming
into contact with some black dust.(13)  In a subsequent investigation, it was discovered that
several workers had been exposed to this black dust--unaware of its radioactivity--and
nothing had ever been done about it.(14)
      Second, in May of 1989, there was an accidental release of tritium during disassembly
of a weapon, and several workers were exposed to tritium gas.(15)  The decontamination of the
disassembly facility will cost two to three million dollars.(16)  After reviewing the accident, the
Chairman of the Advisory Committee on Nuclear Facility Safety concluded that it should have
been anticipated. In his report to the Secretary of Energy, he stated, "There appeared to be no
plan to handle what must surely have be an anticipated accident. It is still unclear that effective
control of the situation by an adequately prepared response team ever took place."(17)  According
_______________________________
   11 GAO REPORT, supra note 4, at 3-6.
   12 GAO REPORT, supra note 4, at 7.
   13 GAO REPORT, supra note 4, at 7.
   14 Id.
   15 Id.
   16 Id.
   17 Id.
                                       5
to the GAO report, five workers were exposed to the tritium gas which could have been
prevented with the proper equipment and procedures.(18)
      The third incident occurred in October of 1990 when seven radiation technicians, who
were not wearing the proper protective clothing, received uranium oxide contamination to their
hands, shoes, and coveralls.(19)  This incident, like the previous two, could have been prevented if
the plant had taken safe and reasonable measures.
      In addition, a 1993 GAO report concludes that the disassembly schedule is too
ambitious due to the poor safety history of the plant.(20)  According to Victor S. Rezendes, an audit
manager at the GAO, "Pantex is probably one of the worst in terms of occupational safety and
health of any of the facilities."(21)  In addition, Kenneth E. Lightner, another GAO official, warns that
operations at Pantex involve significant safety hazards due to the close proximity of high
explosives to radioactive materials.(22) The report goes on to mention, as did the 1991 GAO
report, that Pantex still has not completed the required safety analysis reports, submitting in
total fewer than half, and that many of such reports would have addressed the disassembly of
bombs.(23)
________________________________
   (18)  Id.
   (19)  GAO REPORT, supra note 4, at 8.
   (20)  United States General Accounting Office, Report to Chairman, Environment,
Energy, and Natural Resources Subcommittee, Committee on Government
Operations, House of Representatives, "Nuclear Weapon Safety, Technical and
Manpower Issues Slow DOE Disassembly Efforts" (1993).
   (21)  GAO REPORT, supra note 20.
   (22)  GAO REPORT, supra note 20.
   (23)  GAO REPORT, supra note 20.
                                         6
      Improper management and safety practices are not Pantex's only shortcomings--the
plant is also a proposed superfund site. Hazardous solvents--including xylene,
trichloroethylene, toluene, as well as many others--have contaminated the environment to the
degree that the EPA is considering placing the plant on CERCLA's national priorities list.(24)
Millions of dollars must be expended to bring the plant into compliance with current
environmental mandates. And yet, in spite of these serious environmental problems, the DOE
contends that Pantex has conducted its activities safely and reasonably throughout its forty-year
existence.(25)
      Further, the DOE claims that disassembly and storage of the 20,000 plutonium pits will
have no significant impact on the environment, and that, therefore, they will not be required to
prepare an Environmental Impact Statement (EIS) under the National Environmental Policy Act
(NEPA). The only potential environmental impact conceded by the DOE is increased worker
exposures which they claim will be mitigated.(26)  The DOE concludes that, since there would be
no environmental impacts, packaging and shipping the pits to another location would not be
environmentally beneficial and, therefore, would not be cost-effective.(27)
      Given the dangers that necessarily accompany an action involving the mass storage of
highly dangerous, radioactive materials, and given Mason & Hanger's poor safety and
environmental record, the DOE's argument that NEPA's EIS requirement does not apply is not
____________________________
   (24) Federal Environmental Site Liability Records, Toxic Release Inventory System
(TRIS), by Environmental Data resources, Inc. (1992).
   (25) EA supra note 1, at 1-1.
   (26) EA supra note 1, at 4-1.
   (27) Id.
                                       7
convincing. Several potential impacts are involved in the mass storage of the pits, many of
which are not even mentioned in the EA, and those that the DOE purports to address are much
more serious than admitted. The DOE should, at the least, be required to draft a detailed EIS
that examines all potential risks honestly and thoroughly.
      The responsibility and obligation of the DOE under NEPA is established by the historical
purpose of NEPA and the case law interpreting the statute. This discussion focuses on the
purpose and requirements of NEPA, the case law interpreting NEPA, and, in light of that law, the
adequacy of the DOE's EA
II.   APPLICATION OF NEPA
      A.    Purpose of NEPA
      The National Environmental Policy Act (NEPA) requires federal agencies to prepare EISs
on actions which significantly affect the environment.(28) Enacted in 1969, NEPA has had a
profound impact on the actions of federal agencies; for, prior to the enactment of NEPA, they
generally were not required to consider environmental problems.(29)  Prior to 1969, the
environmental mandates that governed federal agencies were "mission-oriented. "(30)  According
to a leading environmental scholar, this "mission-oriented" system had to change for the
following reasons:
      ... Existing agencies were established to supervise the development of our
      natural resources consistent with the ethic which has prevailed throughout this
      country's history and, thus, they tended to overstress the benefits of
      development and to explore insufficiently the less environmentally damaging
   (28)   NEPA    102(2)(C), 42 U.S.C. section 4332(1988).
   (29)   Mandelker, NEPA LAW AND LITIGATION, section 1.01, at 1-1(1992).
   (30)   Mandelker, section 1.02, at 1-3.
                                         8
      alternatives to current methods of meeting their programmed objectives.(31)
So NEPA was enacted to regulate the decision-making of federal agencies.
      NEPA does not contain strict environmental standards or prohibitions on environmental
development, it requires federal agencies to consider the environmental impacts of their
actions.(32)  This appears to be the main purpose of NEPA. As Judge Skelly Wright, writing for the
court in Calvert Cliff's Coordinating Committee, Inc. v. Atomic Energy Commission(33), held:
"Perhaps the greatest importance of NEPA is to require... agencies to consider environmental
issues just as they consider other matters within their
mandates."(34)
      The Supreme Court, in Baltimore Gas and Electric Co. v. Natural Resources Defense
Council(35), elaborated on the purpose of NEPA:
      NEPA has twin aims. First, it "places upon the agency the obligation to consider
      every significant aspect of the environmental impact of a proposed action." ...
      Second, it ensures that the agency will inform the public that it has indeed
      considered environmental concerns in its decisionmaking process. ... Congress
      in enacting NEPA, ... required ... that the agency take a "hard look" at the
      environmental consequences before taking a major action. ... Congress did not
      enact NEPA, of course, so that an agency would contemplate the environmental
      impact of an action as an abstract exercise. Rather, Congress intended that the
______________________________
   (31)  Tarlton, "Balancing Environmental Considerations and Energy Demands: A
Comment on Calvert Cliffs Coordinating Committee, Inc. v. AEC," 47 Ind. L.J. 645
(1972).
   (32)  NEPA, section 105,42 U.S.C. section 4332(1988).
   (33)  Calvert Cliff's Coordinating Committee, Inc. v. Atomic Energy Comm'n, 449 F.2d
1109(D.C. Cir. 1971).
   (34)  Id. at 1112.
   (35)  Baltimore Gas and Electric Co. v. Natural Resources Defense Council 462 U.S.
87(1983).
                                       9
       "hard look" be incorporated as part of the agency's process of deciding whether
       to pursue a particular federal action.(36)
       In Robertson v. Methow Valley Citizens Council,(37)  the Supreme Court further elaborated
on the purpose of NEPA stating that "... NEPA itself does not mandate particular results.... If
the adverse environmental effects of the proposed action are adequately identified and
evaluated, the agency is not constrained by NEPA from deciding that other values outweigh the
environmental.... NEPA merely prohibits uninformed--rather than unwise--agency
action."(38)
       B.     Statutory Requirements of NEPA
              1.    The EA
                    a.     Purpose
       Federal agencies decide, in an informal, decision-making process, whether or not an EIS
is required.(39)  NEPA provides little guidance on this decision.(40)  As a result, the Council of
Environmental Quality (CEQ), created by NEPA, has passed regulations that elaborate on
NEPA's minimal requirements and provide a multifaceted environmental review process.(41)
___________________________
    (36)  Id. at 97-98, 100-101; See also Kleppe v. Sierra Club, 427 U.S. 390,409-410, nn.
18,21(1976).
    (37)  Robertson v. Methow Valley Citizen's Council, 490 U.S. 332(1989).
    (38)  Id. at 350.
    (39)  Mandelker, section 7.01; See also Scott, "Defining NEPA Out of Existence: Reflections
on the Forest service Experiment with `Case-by-case' Categorical Exclusion," 21 Envtl.
L. 807, 811 (1991).
    (40)  Mandelker, section 7.01.
    (41)  Id.; See also Scott, 21 Envtl. L. at 811.
                                        10
       The first stage of the review process is the preparation of an EA.(42)  Agency's can skip
this stage only if the proposed action is categorically excluded or the agency goes straight to the
preparation of an EIS.(43)  The purpose of the EA is to determine whether federal action has a
"significant" impact on the environment.(44)  If the agency determines that there is no
"significant" impact, then a FONSI must be prepared. If, on the other hand, the EA concludes the
impact would be significant," then the agency must prepare an EIS.
                    b.     Requirements
       CEQ regulations define the EA as a "concise public document," the purpose of which is to
"briefly provide sufficient evidence and analysis for determining" whether to prepare an EIS or
a finding of no significant impact (FONSI).(45)  The majority of courts interpret this statute as
requiring federal agencies to accurately identify the relevant environmental concerns and take a
"hard look" at them(46)  Although this "hard look" requires the same kind of analysis that an EIS
would require, the analysis does not have to be as detailed as that in an EIS.(47)  Rather, the EA is
______________________________
    (42)  Id.
    (43)  Id. CEQ regulations define "categorical exclusion" as "a category of actions
which do not individually or cumulatively have a significant effect on the human
environment." 40 C.F.R. section 1508.4. The effect of this definition is to make the criteria for
determining if there is a significant impact equivalent to that for determining if the action
is categorically excluded.
    (44)  40 C.F.R. sections 1508.9 & 1508.13; See Scott, 21 Envtl. L. at 811; See also
Mandelker, section 7.04[3], at 7-25.
    (45)  40 C.F.R section 1508.9.
    (46)  Sierra Club v United States Dept. of Trans., 753 F.2d 120 (D.C. Cir. 1985); See
supra text accompanying note 32.
    (47)  Mandelker, section 8.01, at 8-3,8-4; See also Scott, 21 Envtl. L. at 811.
                                        11
like a "`mini' impact statement, requiring enough of an investment of agency resources to carry
out a preliminary environmental inquiry."(48)
       Perhaps the most important part of the required analysis in an EA is the consideration of
alternatives. Section 102(2)(E) of NEPA requires federal agencies to "study, develop, and
describe appropriate alternatives to recommended courses of action in any proposal which
involves unresolved conflicts concerning uses of available resources." Courts have interpreted
this to mean that agencies must consider alternatives even though they do not have to prepare
an impact statement--i.e., when only an EA is prepared.(49)
       Since the requirement to consider alternatives under the EA is very similar--if not
equivalent--to that under the EIS,(50)  the law regarding alternatives will be discussed in more
detail under the EIS subheadings, Scope and Requirements.
              2.    Finding of No Significant Impact (FONSI)
                    a.     Purpose
       If the agency determines in its EA that their proposal will have no "significant"
environmental impact, then the agency must prepare a FONSI.(51)  The purpose of the FONSI is to
give the reasons why the agency decided not to prepare an EIS.
_____________________________
    (48)  Mandelker, section 8.01, at 8-3, 8-4; See also Scott, 21 Envtl. L. at 811 (Although
sometimes called a "mini-EIS," the primary purpose of an EA is limited to providing
information and analysis to facilitate the EIS threshold determination.)
    (49)  E.g, National Wildlife Fed'n v. Appalachian Regional Comm'n, 677 F.2d 883 (D.C.
Cir. 1981); Marquez-Colon v. Reagan, 668 F.2d 611(1st Cir. 1981); Hanly v.
Kleindienst (II), 471 F.2d 823 (2nd Cir. 1972).
    (50)  Mandelker, section 9.05(1), at 9-37.
    (51)  40 C.F.R. section 1501.4(e).
                                        12
                    b.     Requirements
       CEQ regulations define the FONSI as a document "presenting the reasons why an action
... will not otherwise have a significant effect on the human environment and for which an
environmental impact statement therefore will not be prepared."(52)  Since courts have held that
mere "perfunctory or conclusory language will not be deemed to constitute an adequate record
and cannot serve to support the agency's decision not to prepare an EIS," the reasons must be
supported by sufficient data.(53)
       A FONSI is an example of informal decision making by agencies. If a FONSI is prepared,
no further study of the environmental consequences of the agency's action is required.(54)
              3.    The EIS
                    a.     Purpose
       If an agency determines in its EA that its proposal will have a "significant effect on the
human environment," an EIS must be prepared. One court described the purpose of the EIS as
follows:
       [The EIS] permits the court to ascertain whether the agency has made a good
       faith effort to take into account the values NEPA seeks to safeguard.... [I]t
       serves as an environmental full disclosure law, providing information which
       Congress thought the public should have concerning the particular
       environmental costs involved in a project.(55)
At first glance, this looks a lot like the purpose of an EA
    (52)  40 C.F.R. section 1508.13.
    (53)  Citizen Advocates for Responsible Expansion, Inc. (I-CARE) v. Dole, 770 F.2d
423,434(5th Cir. 1985).
    (54)  Sabine River Authority v. U.S. Dept. of Interior, 951 F.2d 669,677(5th Cir. 1992).
    (55)  Silva v. Lynn (II), 482 F.2d 1282 (1st Cir. 1973).
                                        13
       The main distinction between an EIS and an EA is that when an agency prepares an EIS,
the issue on review is whether the agency adequately considered the environmental
significance of its action.(56)  But when an agency submits an EA and FONSI, the issue on review is
whether the nature of the action is such that significant environmental impacts could occur.(57)
       Courts have struggled to understand this distinction, though.(58)  Perhaps the Seventh
Circuit, in Cronin v. U.S. Dept. of Agriculture(59)  most clearly distinguished the two in stating that
the EA is a "rough-cut, low budget environmental impact statement designed to show whether a
full-fledged environmental impact statement--which is very costly and time consuming to
prepare and has been the kiss of death to many a federal project--is necessary."
                    b.     Scope
       The scope of an EIS must be determined by the agency. Decisions on the scope will
include whether to consider actions individually or along with other related actions, as well as
which alternatives should be considered.(60)  If the agency decides to consider several related
actions, then it must prepare a "program" impact statement (PEIS). CEQ regulations help guide
agencies on whether to prepare a PEIS when several actions are involved.(61)
_____________________________
    (56)  Mandelker, section 8.06[4][a], at 8-76.
    (57)  Id.
    (58)  Id.
    (59)  Cronin v. U.S. Dept. of Agriculture, 919 F.2d 439,443(7th Cir. 1990).
    (60)  Mandelker, section 9.01.
    (61)  See 40 C.F.R. section 1502.4(b). The regulations refer to "broad" federal actions rather
than "program" impact statements. See also Mandelker, section 9.02.
                                        14
       As to the alternatives requirement, it has been called the "heart"(62)  and "linchpin"(63)  of
the EIS. Agencies grapple with this requirement because as the scope of alternatives widens,
the more likely the proposal will be unattractive.(64)
       NEPA contains two provisions which require the consideration of alternatives:
section 102(2)(E) and 102(2)(C)(iii). These will be discussed in more detail under the following
section.
                    b.     General Requirements
       Under section 102(2)(C) of NEPA, federal agencies must prepare an EIS for "major Federal
actions significantly affecting the quality of the human environment." CEQ regulations require
that the EIS discuss:
       (i)    the environmental impact of the proposed action,
       (ii)   any adverse environmental effects which cannot be avoided should the
       proposal be implemented,
       (iii) alternatives to the proposed action,
       (iv)   the relationship between long- and short-term uses of man's environment
       and the maintenance and enhancement of long-term productivity, and
       (v)    any irreversible and irretrievable commitments of resources which would
       be involved in the proposed action should it be implemented.(65)
The adequacy of an EIS depends on the agency's compliance with the above clauses.
____________________________
    (62)  40 C.F.R. section 1502.14.
    (63)  Monroe County Conservation Council, Inc. v. Volpe, 472 F.2d 693 (2nd. Cir.
1972).
    (64)  Mandelker, section 9.05[1], at 9-37.
    (65)  NEPA section 102(2)(C); See Mandelker, section 2.04.
                                        15
       The first two clauses require that an agency consider the environmental effects of its
actions. As to what "environmental effects" means, the CEQ has passed regulations defining
the term.(66)  It includes both direct and indirect impacts, as well as beneficial and detrimental
impacts.(67)  The scope of this term is discussed in more detail under "Review of a Decision Not
to Prepare an EIS," subsection 4.
       Clauses (iv) and (v) have been given less weight than intended and often have not even
been given independent consideration.(68)  One reason is that courts--in spite of section 102[2][C]'s
statutory directive--have not applied the requirements either individually or cumulatively to
agency discussions of environmental effects in impact statements.(69)  They have opted, instead,
for a "rule of reason" review,(70)  which has resulted in the omission of specific and important
considerations.(71)  The Second Circuit, in Sierra Club v. Corps of Engineers(72), articulated this
"rule of reason" standard of review as follows:
       [The EIS] must set forth sufficient information for the general public to make an
       informed evaluation,... and for the decisionmaker to "consider fully the
       environmental factors involved and to make a reasoned decision after balancing
       the risks of harm to the environment against the benefits to be derived from the
       proposed action." [The EIS gives] assurance that stubborn problems or serious
____________________________
    (66)  Mandelker, section 2.04, at 2-11.
    (67)  40 C.F.R. section 1508.8.
    (68)  Mandelker, sections 2.04, at 2-11,10.10[1], at 10-65.
    (69)  Mandelker, section 10.10[1], at 10-65.
    (70)  Mandelker, section 10.05.
    (71)  Id.
    (72)  Sierra Club v. Corps of Engineers, 701 F.2d 1011 (2nd Cir. 1983).
                                        16
       criticisms have not been "swept under the rug."(73)
Due to this type of review, clauses (iv) and (v) have often been overlooked.
       The third clause, however, has seldom been forgotten. Under this clause and, similarly,
section 102(2)(E), agencies are required--in both EISs and EAs--to consider alternatives to their
proposal.(74)  CEQ regulations require that agencies consider the proposal and the alternatives in
comparative form, rigorously exploring and objectively evaluating each.(75)  Under these sections,
conclusory language is insufficient.(76)
       As to the difference between sections 102(2)(C)(iii) and 102(2)(E), some argue that
section 102(2)(E) is the more stringent requirement. The Fifth Circuit, in Environmental Defense
Fund, Inc. v. Corps of Engineers(77), held that the purpose of section 102(2)(E) is--
       to insist that no major federal project should be undertaken without intense
       consideration of other more ecologically sound courses of action, including
       shelving the entire project, or of accomplishing the same result by different
       means.(78)
Section 102(2)(E) has been termed the most important requirement that agencies must meet
if they do not prepare an EIS.(79)  In addition, for agencies preparing an EIS, courts have suggested
_________________________________
    (73)  Id. at 1029.
    (74)  Mandelker, section 9.05(1), at 9-37.
    (75)  40 C.F.R. section 1502.14.
    (76)  Id.
    (77)  Environmental Defense Fund, Inc. v. Corps of Engineers of U.S. Army, 492 F.2d
1123(5th Cir. 1974).
    (78)  Id. at 1135.
    (79)  Mandelker, section 9.05(5), at 9-45.
                                        17
that the required discussion under section 102[2][E] be incorporated into the impact statement.(80)
      Under these two sections, analysis of certain types of alternatives is required-such as
the "no-action" alternative. Under the "no-action" alternative, agencies must examine the
environmental consequences of not undertaking their action.(81)  This analysis is required in both
EAs and EISs.(82)
      As to other types of alternatives that must be discussed, two opposing decisions
dominate the case law: District of Columbia Court of Appeals, Natural Resources Defense
Council, Inc. v. Morton(83)  and Vermont Yankee Nuclear Power Corp. v. Natural Resource
Defense Council, Inc.(84)  In Morton, the court took a "rule of reason" approach to alternatives,
requiring agencies to discuss alternatives outside the agency's jurisdiction or not authorized by
statute or administrative regulations.(85)  The CEQ regulations support this position for the most
part, only excluding consideration of alternatives requiring further legislative or executive
measures. The regulations basically codify the leading court of appeals cases,(86)  which state
that agencies must consider "reasonable alternatives not within the jurisdiction of the lead
_____________________________
    (80)  See Environmental Defense Fund, Inc. v. Corps of Engineers of United States
Army, 470 F.2d 289(8th Cir. 1972).
    (81)  40 C.F.R. section 1502.14(2).
    (82)  Mandelker, section 10.09(3).
    (83)  District of Columbia Court of Appeals, Natural Resources Defense Council, Inc. v.
Morton, 458 F.2d 827 (D.C. Cir. 1972) [hereinafter Morton].
    (84)  Vermont Yankee Nuclear Power Corp. v. Natural Resource Defense Council, Inc.,
435 U.S. 519(1978) [hereinafter Vermont Yankee].
    (85)  Morton, 458 F.2d 827.
    (86)  Mandelker, section 9.05[4], at 9-44.
                                        18
agency,"(87)  and the no-action alternative.(88)
      On the other hand, Vermont Yankee, although affirming the rule of reason approach,
gave it a more restrictive interpretation, implying that agencies do not have to discuss "primary"
alternatives--i.e., substitutes for agency actions that accomplish the same result in another
manner--that are not within the jurisdiction of the agency.(89)  In addition, the Court required
proponents of alternatives to make a preliminary showing that an alternative merits review,
before the agency must consider it.(90)  This showing is often too onerous for proponents;
agencies are usually the organizations with the expertise to suggest alternatives.(91)
      Cases that have discussed adequacy of alternatives have usually adopted the more
liberal rule of reason approach, sometimes limiting alternatives according to the purposes
served by the federal action.(92)  From this case law, basic guidelines have developed. Secondary
alternatives--i.e., alternatives requiring that the proposal be carried out in a more
environmentally sound way--are usually discussed.(93)  And many cases also discuss primary
alternatives--i.e., substitutes to the proposed action. However, the rule of reason in regard to
primary alternatives has been limited. For example, courts have ruled that speculative
_____________________________
   (87)  40 C.F.R. section 1502.14(c).
   (88)  40 C.F.R. 1502.14(d).
   (89)  Mandelker, section 9.05[3], at 9-43.
   (90)  Mandelker, section 9.05[4], at 9-44.
   (91)  Id.
   (92)  Mandelker, section 9.O5[7]; See also City of Angoon v. Model, 803 F.2d 1016, 1021(9th
Cir. 1986).
   (93)  Id.
                                        19
alternatives need not be discussed.(94)  In Seacoast Anti-Pollution League v. Nuclear Regulatory
Commission(95), the court held that the NRC was not required to consider out-of-state sites for a
nuclear power plant because the environmental advantages of these sites were theoretical, as
well as offset by environmental deficits.(96)
      Other alternatives which do not have to be considered include:
      *      infeasible alternatives,(97)
      *      alternatives that are the responsibility of a local government,(98)
      *      remote or unrealistic alternatives,(99)  and
      *      alternatives that require additional legislative or executive measures.(100)
      Once an agency decides which alternatives to discuss, it must prepare a record of
decision, specifying the alternatives that are "environmentally preferable."(101)  Whether an
_______________________________
   (94)  Id.
   (95)  Seacoast Anti-Pollution League v. Nuclear Regulatory Commission, 598 F.2d
1221 (1st Cir. 1979).
   (96)  Id.
   (97)  Olmsted Citizens for Better Community v. United States, 793 F.2d 201(8th Cir.
1986)(need not consider new facility as alternative to conversion); Friends of
Endangered Species, Inc. v. Jantzen, 596 F. Supp. 518 (N.D. Cal. 1984); Badoni v.
Higginson, 455 F. Supp. 641(D. Utah 1977). For more, see Mandelker, section 9.05[7], n. 71.
   (98)  Animal Defense Council v. Model, 840 F.2d 1432(9th Cir., 1988)(groundwater
recharge as alternative to water supply system).
   (99)  Natural Resources Defense Council v. Morton, supra.
   (100) Only one court has required additional legislative measures--Environmental
Defense Fund, Inc. v. Froehlke, 473 F.2d 346(8th Cir. 1974). The rest have not
required consideration of such alternatives. Mandelker, section 9.05[7], 9-55.
   (101) 40 C.F.R. 1502.2.(b).
                                      20
alternative is "environmentally preferable" may depend on such factors as economic and
technical considerations and agency statutory missions.(102)
      C.     Review of a Decision Not to Prepare an EIS
             1.    General
      When an agency decides not to prepare an EIS, they often wind up in court defending
their findings. This has resulted in an abundance of case law. The most frequently litigated
issue in such cases--which is relevant to the DOE's FONSIs for the Pantex proposals
whether the agency appropriately found that its action will not "significantly" impact the quality
of the human environment.(103)  Unfortunately, for several reasons, current case law provides
little guidance on this matter.(104)
             2. Standard of Review
      One primary reason for the confusion--at least as to decisions prior to 1989--is
that courts have struggled with the standard of review in regard to FONSIs because they involve
mixed questions of law and fact.(105)  Courts have discovered that the findings necessary to
determine the legal meaning of the term "significant" are often findings of fact within the
discretion of the agency.(106)  This means that in order to legally interpret the word "significant,"
__________________________________
   (102)  Id.
   (103)  Mandelker, section 8.06[4][a], at 8-75.
   (104)  Mandelker, section 8.01, at 8-3.
   (105)  Mandelker, section 8.02[3], at 8-9.
   (106)  Id.
                                      21
courts must review the agency's findings of fact.(107)  As a result, courts have ended up applying a
"reasonableness" standard of review, deciding issues of fact as well as law de novo.(108) 
      However, the Supreme Court, in Marsh v. Oregon Natural Resources Council(109),
established that the arbitrary and capricious standard of review was the appropriate
standard.(110)  Then it deferred to the agency on the grounds that the determination of
"significance" involved primarily issues of fact.(111)  The Court explained that deference to the
agency was proper because the dispute did not turn on either "the meaning of the term
`significant' or on the application of this legal standard to settled facts."(112) 
      The 9th Circuit in Greenpeace Action v. Franklin(113)  interpreted Marsh to mean that,
when the facts concerning the impact are disputed facts, and "specialists express conflicting
views, an agency must have discretion to rely on the reasonable opinions of its own qualified
experts even if, as an original matter, a court might find contrary views more persuasive."(114)
The court went on to state, "Once we are satisfied that an agency's exercise of discretion is truly
______________________________
   (107)  Id.
   (108)  Marsh v. Oregon Natural Resources Council, 490 U.S. 360(1989); Mandelker,
section 8.02[3], at 8-10.
   (109)  Marsh v. Oregon Natural Resources Council, 490 U.S. 360(1989).
   (110)  Id.
   (111)  Id.
   (112)  Id. at 376.
   (113)  Greenpeace Action v. Franklin, 982 F.2d 1342(9th Cir. 1992).
   (114)  Id. at 1350.
                                      22
informed, `we must defer to that informed discretion.'"(115) 
      Whether an agency is "truly informed"--or, in many cases, being forthright--is
probably one of the main reasons why courts have struggled over the years with the legal
meaning of "significance" and why many have felt compelled in some cases to review some of
the factual determinations de novo.(116)  Unfortunately, Marsh may result in a one-sided
determination, where agencies have nearly complete, unchecked power to pursue actions
which, under a "reasonableness" standard, would never have withstood review.
             3.    "Significance"
      A second reason that current case law provides little guidance on the requirements of
FONSIs is that few courts discuss--or concur on, for that matter--the threshold level of
"significance" that requires the preparation of an EIS.(117)  CEQ regulations have attempted to
define "significantly" as follows:
      "Significantly" as used in NEPA requires considerations of both context and
      intensity:
      [a]    Context. This means that the significance of an action must be analyzed
      in several contexts such as society as a whole (human, national), the affected
_____________________________
   (115)  Id.
   (116)  See Save Our Ten Acres v. Kreger; 472 F.2d 463,466(5th Cir. 1973)("... the
spirit of the Act would die aborning if a facile, ex parte decision that the project was
minor or did not significantly affect the environment were too well shielded from
impartial review."). But in Sabine River Authority v. U.S. Dept. of Interior, 951 F.2d 669,
677(5th Cir. 1992), the Fifth
Circuit ruled that, in light of the Supreme Court decision in Marsh v. Oregon Natural
Resources, 490 U.S. 360(1989), the appropriate standard of review in cases involving
an agency's decision not to prepare an impact statement is the arbitrary and capricious
standard.
   (117) Mandelker, section 8.06[4][a], at 8-76.
                                        23
      region, the affected interests, and the locality. Significance varies with the setting
      of the proposed action....
      (b)   Intensity. This refers to the severity of the impact.... The following should
      be considered in evaluation of intensity:
             (1)   Impacts that may be both beneficial and adverse. A
             significant effect may exist even if the Federal agency believes that
             on balance the effect will be beneficial.
             (2)   The degree to which the proposed action affects public
             health or safety.
             (3)   Unique characteristics of the geographic area such as
             proximity to historic or cultural resources, park lands, prime
             farmlands, wetlands, wild and scenic rivers, or ecologically critical
             areas.
             (4)   The degree to which the effects on the quality of the human
             environment are likely to be highly controversial.
             (5)   The degree to which effects on the quality of the human
             environment are likely to be highly uncertain or involve unique or
             unknown risks.
             (9)   The degree to which actions may adversely affect an
             endangered or threatened species or its habitat....
             (10) Whether the action threatens a violation of Federal, State,
             or local law....(118)
Many courts, however, have shied away from these structured CEQ regulations and adopted
more generalized tests for "significance"; as a result, the tests vary greatly.
      Perhaps the most popular of such tests is that adopted by the court in Hanly v.
Kleindienst (II).(119)  In Hanly--decided before the CEQ regulations were passed but,
__________________________________
   (118)  40 C.F.R. section 1508.27.
   (119)  Manly v. Kleindienst (II), 471 F.2d 823 (2nd Cir. 1972).
                                              24
nonetheless, still followed--the majority adopted this tow-part test:
      (1) The extent to which the action will cause adverse environmental effects in
      excess of those created by existing uses in the area affected by it, and (2) the
      absolute quantitative adverse environmental effects of the action itself, including
      the cumulative harm that results from its contribution to existing adverse
      conditions or uses in the affected area.(120)
The test emphasizes baseline factors and the cumulative impact of the action when considered
alone and in relation to the overall environmental condition of the area. Although this test is
probably the most widely followed, many courts have adopted completely different views of
"significance," such as the D.C. Circuit and the Fifth Circuit
      The D.C. Circuit, since Maryland-National Capital Park & Planning Comm'n v. U.S. Postal
Service,(121)  requires an impact statement when the environmental effect is "arguably"
significant. The court has the following four criteria for determining the adequacy of a FONSI:
      (1)    whether the agency took a `hard look' at the problem;
      (2)    whether the agency identified the relevant areas of environmental
      concern;
      (3)    as to the problems studied and identified, whether the agency made a
      convincing case that the impact was insignificant; and
      (4)    if there was an impact of true significance, whether the agency
      convincingly established that changes in the project reduced it to a minimum.(122)
These criteria focus more on the process the agency goes through to determine "significance"
______________________________
   (120)  Id. at 830-31.
   (121)  Maryland-National Capital Park & Planning Comm'n v. U.S. Postal Service, 487
F.2d 1029 (D.C. Cir. 1973).
   (122)  Id. at 1040.
                                        25
than on the substantive definition of the term.(123)
      The Fifth Circuit's definition of significance, set out in Save Our Ten Acres v. Kreger,(124)  is
even less comprehensive than the D.C. Circuit's. The court gave the following criteria:
      [I]f the court finds that the project may cause a significant degradation of some
      human environmental factor (even though other environmental factors are
      affected beneficially or not at all), the court should require the filing of an impact
      statement....(125)
This implies that an effect can be "significant" even though it has limited environmental
impact.(126)  But the test is very general and remains unclear. Like the other tests, the 5th
Circuit's fails to spell out sufficient, definite substantive criteria.
      So courts and agencies alike struggle with the meaning of "significance" and there is
little guidance in current case law.
            4.     "Effect"
      Another recurring issue on review is what is included in the term "effect." CEQ
regulations define the term broadly to include ecological, aesthetic, historic, cultural, economic,
social, and health effects,(127)  but often courts do not follow this guideline.
      Direct "effects" of an action are usually held to be within NEPA as well as secondary and
indirect effects.(126)  An indirect effect is defined as a "reasonably foreseeable" effect that is "later
___________________________________
   (123)  Mandelker, section 8.06[4][c], at 8-80.
   (124)  Save Our Ten Acres, supra note 116.
   (125)  Id. at 467.
   (126)  Mandelker, section 8.06[4][c], at 8-80.
   (127)  40 C.F.R section 1508.8.
   (126)  Mandelker, section 8.07,
                                         26
in time or farther removed in distance" than a direct effect.(129)  Speculative indirect and
secondary effects are generally not covered by the statute. Issues often arise, though, as to
whether an effect is speculative.
      Often, effects have a low probability of occurring but severe consequences in the event
they do occur, such as nuclear accidents. CEQ regulations require an analysis of these low-
probability/severe-consequences type of risks, provided such analysis is reasonable as defined
by the regulations.(130)  On review, surprisingly little attention has been paid to such risks.(131)
Perhaps the leading case on low-probability risk analysis is New York v. United States
Department of Transportation.(132)  In this case, the court addressed risks in regard to the
transportation of radioactive materials on public highways. The court undertook a "risk
assessment," defined as an "estimate of both the consequences that might occur and the
probability of their occurrence."(133)  The court concluded that an agency was not exempted from
having to prepare an impact statement because the effects of its proposal were "only a
possibility"; but, in such cases, the agency should be accorded "some latitude" when
determining whether an impact statement is necessary.(134)  So just because the effects of an
___________________________
   (129)  40 C.F.R. 1508.8(b).
   (130)  40 C.F.R. section 1502.22. This regulation replaces the previous "worst case analysis"
requirement.
   (131)  Mandelker, section 8.07[10].
   (132)  City of New York v. United States Dept. of Transportation, 715 F.2d 732 (2nd Cir.
1983).
   (133)  Id.
   (134)  Id.
                                        27
action are uncertain does not automatically mean that an impact statement should not be
prepared.
      A second issue courts have addressed is whether NEPA covers psychological effects. In
Metropolitan Edison Company v. People Against Nuclear Energy,(135)  the Supreme Court
established the following causation test for determining NEPA's applicability:
      To determine whether... [NEPA] requires consideration of a particular effect, we
      must look at the relationship between that effect and the change in the physical
      environment caused by the major federal action at issue.(136)
Applying this test, the Court concluded that the psychological effects of restarting the Three
Mile Island nuclear reactor were not covered under NEPA The Court reasoned that NEPA was
limited to the physical environment and stated:
      ... risk of an accident is not an effect on the physical world. In a causal chain from
      renewed operation of... [the nuclear reactor] to psychological health damage,
      the element of risk and its perception by PANE's members are necessary middle
      links. We believe that the element of risk lengthens the causal chain beyond the
      reach of NEPA.(137)
      Just exactly what the court meant by this decision is unclear. It seems that all risks
would fall under the same reasoning and, therefore, escape analysis. The Court attempted to
distinguish this particular psychological effect by pointing out that risks of environmental change
must be considered, but not effects caused by a reaction to the risk itself. However, in this case,
nearby residents were being exposed to low-level radiation as a result of the restart of the
_____________________________
   (135)  Metropolitan Edison Co. v. People Against Nuclear Energy, 460 U.S. 766(1983).
   (136)  Id. at 773.
   (137)  Id. at 775.
                                        28
reactor; this caused at least some of the psychological effects.(138)  The psychological trauma was
not merely a reaction to the risk. So the Supreme Court's argument is neither persuasive, nor
clear. To give this case meaning, the result might be to exclude psychological effects altogether
even though that does not appear to have been the Supreme Court's intent.
      A third issue courts have often encountered is whether an impact statement is required
if an action is controversial. This issue arose since, under the CEQ's definition of "significantly,"
agencies must consider the degree to which the effects are controversial. Courts have
generally agreed, however, that requiring an impact statement due to the controversial nature
of an action does not comport with the aims of NEPA.(139)
             5.    Alternatives
      The adequacy of an agency's discussion of alternatives is often an issue on review. The
case law on this topic is described, supra, under the EIS subsection, Requirements.
III.   APPLICATION OF NEPA TO PANTEX NUCLEAR WEAPONS FACILITY
      A.     Proposal For Storage of Plutonium Pits
      In three nuclear weapons policy declarations (dated September 27,1991, January 21,
1992, and June 16,1992], President Bush expressed his intent to reduce the nuclear
weapons arsenal. These reductions were made into directives through joint DOD/DOE
commitments, which promise to reduce the nuclear weapons stockpile from in excess of
20,000 warheads to fewer than 10,000 before the end of the century. This translates into a
reduction of 2,000 per year. The DOE proposes to store all plutonium pits--composed of
______________________________
   (138)  Id.
   (139)  Manly v. Kleindienst (II), supra; See also Mandelker, section 8.07[11], at 8-103.
                                        29
hermetically-sealed, metallic outer shells, surrounding a core of solid plutonium--at Pantex on
an interim basis until a long-term storage facility is available.(140)
      The DOE states that their proposal will result in the following:
      *     An increase in the number of pits stored, up to 20,000;
      *     A reallocation of the number and type of magazines that can be available
            for interim storage;
      *     A change in the historically used staging/storage configuration to allow
            increased operational flexibility and efficiency (multiple stacking);
      *     A storage period not to exceed the time required to implement the
            decisions in the PEIS/ROD regarding long-term storage and/or disposition. This
            is expected to be within a timeframe of 6-10 years.
Just exactly what the DOE means by the above four statements is unclear. The language that
they use is misleading and ambiguous throughout the EA
      B.    The EA Submitted by the DOE
             1.    General
      The EA submitted by the DOE is questionable for several reasons in light of the NEPA law
previously discussed. At least five main problems surface: (1) the DOE did not accurately
identify many of the possible "significant" effects of their actions; (2) the DOE underestimated
the "significance" of many environmental effects; (3) the DOE's discussion of alternatives was
incomplete and unsatisfactory; (4) the DOE failed to clearly define the interim storage period; (5)
the DOE should outline the proper regulatory authorities.
      Each of these issues is addressed below.
             2.    Effects Not Addressed
___________________________
   (140)  EA, supra note 1, at 1-1.
                                        30
      As stated earlier, NEPA requires agencies to take a "hard look" at the environmental
consequences of their actions.(141)  This "hard look" includes accurately identifying the
"significant" adverse environmental "effects."(142)  As the CEQ regulations and case law have
shown, the term "effects" consists of direct and indirect impacts, including immensely adverse
environmental consequences that have a low probability of occurring. In the EA, they fail to
identify several such environmental effects.
      The accidents that the DOE purports to consider include earthquakes, external
explosions, missiles, tornados, forklift accidents, and small aircraft crashes.(143)  Other risks,
though, like corrosion and internal fires, are erroneously dismissed as not "credible."(144)
      As to corrosion, the DOE states that "there is no mechanism to cause corrosion that
would lead to the degradation of the pit containers."(145)  However, just recently, a "corrosion-
resistant" metal shell surrounded by "positioning material (Celotex)" encasing a pit ruptured
and began to leak plutonium. Workers had to be evacuated and the facilities
decontaminated.(146)  Since the inner metal shell was encased in a pit, it logically follows that
forces other than physical impacts, i.e. corrosion, led to the accident. This risk should be
addressed and the environmental impacts analyzed. With 20,000 plutonium pits being sent to
___________________________
   (141)  See supra, p. 8.
   (142)  Id.
   (143)  EA, supra note 1, at 6-4.
   (144)  Id. at A-3 & A-5.
   (145)  Id.
   (146)  Jim McBride, "Engineers lake Plutonium Pits Apart for Tests," Amarillo Globe
News, 18 Feb. 1993.
                                        31
one location, the potential for such leaks is great.
      Similarly, internal fires should be discussed. The DOE states that no uncontained
combustible materials are within the magazines, so this potential accident does not warrant
discussion. But the DOE does not consider fires from objects, such as forklifts, that enter the
storage igloos. There is no discussion of what exposure to abnormally high temperatures would
do to the drums and their contents. This risk should also be discussed.
      Most importantly, though, the DOE ignored what are perhaps the gravest impacts
caused by this proposal: (1) the potential for terrorist attack since almost all plutonium
removed from nuclear weapons will be stored at one location and (2) the effect of a large airline
crash into one of the magazines.
      Given that the DOE's proposal contemplates stockpiling all plutonium pits--notoriously
the most dangerous component of nuclear weapons--at one location, it is surprising, if not
suspicious, that the DOE has omitted any discussion of the terrorist threat and the potential
effect of a terrorist attack on the facility. Damage from missiles due to explosions in nearby
facilities is evaluated, but there is no discussion of missiles detonated within or near the
magazines or striking the structures from the air.
      Strategically, the DOE's decision to store all plutonium in one location is highly
questionable. Alternatives of delaying disassembly or at least distributing the storage among
various facilities would be much wiser than storing all plutonium at one location and making the
site an enormously attractive terrorist target. This concern was cited by John F. Ahearne, a
nuclear expert who studied the nuclear weapons industry for four years as chairman of an
independent advisory group. At a Senate hearing on the subject, Dr. Ahearne warned that
                                      32
putting such quantities of plutonium at one site would present a terrorist threat.(147)  He stated,
"It seems imprudent to establish the concept here that it's quite acceptable to store large
quantities of plutonium in one place."(148)
      As Chief Judge George Edwards of the D.C. Circuit wrote in NRDC v. NRC,(149)  "Both in
storage and in transit, separated plutonium requires the most careful... measures ... against
theft by non-state actors." The D.C. Circuit ruled in NRDC v. NRC that the NRC abused its
discretion in promulgating a set of rules establishing a system for assessing the environmental
impact of the uranium fuel cycle. The court held that the rules subverted the purpose of NEPA,
allowing scant consideration of the uncertainties of long-term isolation of high-level, transuranic
waste, as well as health, socioeconomic, and cumulative effects of fuel cycle activities, including
terrorism.(150)  In his concurring opinion, Chief Judge Edwards warned:
      Terrorists might choose the nuclear industry as a target to exploit the mystique
      that surrounds nuclear weapons. The threat of nuclear terrorism may be used
      to extort money, secure the release of prisoners or publicize a particular cause..
      ..[T]he United States confronts many hostile powers, some with vast wealth and
      the consequent ability to train and arm desperadoes or to bribe and corrupt
      personnel connected with either private or government aspects of the nuclear
      cycle. ... I assume that theft by stealth or force of sufficient plutonium to
      fabricate a bomb and its subsequent employment by threats or fact of explosion
      would constitute a "release." In my view, the threat of such a "release" is
      anything but "insignificant."(151)
______________________________
   (147)  February 25,1992 Senate hearing before Governmental Affairs Committee
chaired by Senator John Glenn "Impact of Nuclear Disarmament on the Department of
Energy"
   (148)  Id.
   (149)  NRDC v. NRC, 685 F.24 459 (D.C. Circuit 1982).
   (150)  Id.
   (151)  Id. at 514-6.
                                        33
      The potential for terrorism at Pantex will rise dramatically if the DOE enacts its proposal
and all 20,000 plutonium pits--almost the entire nation's store of plutonium--are stored there.
As Chief Judge Edwards holds, the threat of terrorism is anything but insignificant. And, under
the DOE's proposal for Pantex, the potential for terrorism could not be greater, especially since
the DOE proposes to amass all plutonium pits at one site in above-ground igloos designed to
hold far fewer pits and only on an inventory basis. If NEPA upholds its purpose, the DOE should
consider this threat of terrorism in an EIS.
      In addition, the DOE mentions the possibility of airline crashes into magazines but
dismisses such effects as insignificant, evaluating the effects of light aircraft crashes but not
military or commercial aircraft crashes. However, Pantex is located near the flight path to
Amarillo's airport.(152)  The DOE implies, though, that since 62% of the traffic is composed of light
general aviation, only the possibility of light aircraft crashes needs to be evaluated.(153)  They
dismiss accidents involving larger aircraft as "beyond extremely unlikely."(154)
      But the possibility of large aircraft crashes poses a real threat to the environment,
especially given the large amounts of plutonium stored so densely in one location. And
strangely, the DOE concedes this risk by evaluating what effects such an accident would have on
the Ogallala Aquifer.(159)  No doubt, however, the environmental effects to the land, people, and
__________________________________
   (152)  See EA, supra note 1, Figure 5.1, "Pantex Plant Location," at 5-3. See also EA,
Figure E-1, "Relationship of Flight Path to Impact Areas," at E-10.
   (153)  EA, supra note 1, at 6-6.
   (154)  Id.
   (155)  Los Alamos National Laboratory, "Potential Ogallala Aquifer Impacts of a
Hypothetical Plutonium Dispersal Accident in Zone 4 of the Pantex Plant," p.2 (1992).
This document is part of the EA.
                                        34
water supplies would be devastating if such an accident occurred. As the EA states, a
plutonium particulate plume would fall on much of the Southern and Central High Plains--i.e. a
substantial portion of North Texas and parts of New Mexico.(156)  Therefore, this risk is sufficient
to require the DOE to prepare an EIS.
      Water issues remain unresolved by the EA as the Los Alamos reply to State of Texas
comments on water mobility and recharge rates as they might threaten underground water
aquifers, are largely ignored. The Department of Economic Geology at the University of Texas
has spent four years understanding and defining the areal extent and hydraulic continuity of the
perched aquifer in the region of the Pantex plant and the possible implications to the Ogallala
aquifer.(157)  DOE dismisses this work out of hand as unreasonable and unrealistic.
      The DOE also failed to evaluate the safety of the magazines at Pantex, constructed in
World War II, in light of present-day requirements for a modern, safe nuclear store, such as
those requirements set out in a study by the Center for Energy and Environmental Studies at
Princeton and the Department of Nuclear Engineering at MIT. [Exhibit] Moreover, the stability of
plutonium over long periods of time was not addressed. This poses an unknown threat since
models defining the stability of plutonium over long periods of time have been inadequately
tested.(158)
      Lastly, the DOE ignored psychological effects to the community caused by the increased
storage of pits. Perhaps this is because, as noted earlier, the Supreme Court ruled in
_______________________________
   (156)  Id.
   (157)  July 1993 "Milestone Report / The Areal Extent and Hydraulic Continuity of
Perched Ground Water in the Vicinity of the Pantex Plant" By W.E. Mullican III et. al.
   (158)  "Science and Global Security", 1992, Volume 3, pp. 1-53
                                        35
Metropolitan Edison Company that reaction to risks is not an "effect," only reaction to
environmental change is.(159)  However, applied to the proposal for Pantex, the DOE states that
under 1991 figures, people outside the boundaries of Pantex could be exposed to
approximately .16mrem of excess radioactivity. So the proposal would cause an environmental
change. The psychological effects on the community caused by this environmental change
could easily be judged significant since recent studies show that exposure over an extended
period of time to low-level radiation causes cancer.(160)  Based on this scientific evidence, people
in the community are justified in feeling fear and anxiety about the health effects of the DOE's
proposal, and these psychological effects should be viewed as significant.
      The impact to the business future of Amarillo and the Panhandle is illustrated with the
results of a recent business survey done for Operation Commonsense by a Duke university
pollster. [Exhibit B] The results establish a significant impact to future business development
solely from the knowledge of the plutonium store and possible processing function.
             3.    The FONSIs
      Experts disagree with the DOE's findings that certain effects of its proposal are not
"significant." If the DOE's findings in this case are reviewed by the Fifth Circuit, the court, as it
held in Sabine River Authority v. U.S. Dept of Interior, would likely defer to the DOE on its
findings.(161)  This is because the harm that the DOE concedes--which is solely increased
worker exposures--would be the only finding the court could question regarding
_________________________
   (159)  See supra, p. 30-31.
   (160)  Gibbons, Science News, "Low-level radiation: higher long-term risk? (cancer
linked to ionizing radiation), v. 139, n. 12, p. 181 (March 23,1991).
   (161)  See supra, p. 28.
                                        36
"significance," since all other inquiries require questioning the DOE's fact-finding.(162)  And, in
regard to worker exposures, the DOE claims that proper safety measures would adequately
mitigate the harm, so a determination of "significance" would be unlikely.(162)
      If the DOE's findings are reviewed by the D.C. Circuit, though, given that the court
requires an impact statement when the impact is "arguably significant,"(164)  the review might be
more favorable.
            4.    Discussion of Alternatives
      The DOE discusses alternatives to its proposal in section four of the EA, devoting only five
pages to the topic. As previously noted, section 102(2)(E) requires rigorous exploration and
evaluation of alternatives even if no EIS has been prepared.(165)
      However, the DOE devotes less than half a page to discussion of the no-action
alternative, dismissing it as violating the weapons reduction initiatives.(166)  The DOE does not
discuss the consequences of ceasing disassembly pending the identification and approval of a
long-term storage site. Halting disassembly until a safe storage facility is constructed might
very likely be preferable to stuffing magazines at Pantex beyond their intended capacity in
dangerous, make-do configurations.
____________________________
   (162)  Given the standard of review under Marsh as articulated by the 9th Circuit in
Greenpeace Action v. Franklin, supra, page 23, the court could determine that the
DOE's findings were "uninformed."
   (163)  See EA supra note 1, Appendix F.
   (164)  See supra, p. 26-7.
   (165)  See supra, p. 16-17.
   (166)  EA, supra note 1, at 4-1 & 4-2.
                                        37
      In addition, the DOE cites inadequate reasons--e.g., time pressure and the
convenience of leaving the pits at Pantex--to discount the other DOD and DOE facilities as
possible storage sites. Throughout the EA, the DOE dismisses each facility, stating that they
would all require modifications, and subsequently concludes that Pantex could accommodate all
of them using a multiple stacking configuration. But the mere fact that other facilities would
require modifications does not justify dismissing them as alternatives, especially since the
Pantex facilities were not designed to store anywhere near the number of pits the DOE intends
to store in them.
      Also, the DOE contends that some facilities, such as Hanford, are such environmental
disasters that it would not be "reasonable or appropriate" to send the pits there.(167)  But Pantex
is a candidate for CERCLA's NPL,(168)  so if the environmental condition of a site is a factor in
choosing a storage facility, Pantex should not be a preferred choice.
      The DOE's discussion of alternatives is simply too brief. Each alternative should be
evaluated in more detail as required by section 102(2)(E). For example, alternative modes of storage
should be evaluated. Storing the pits above ground in igloos may create risks of accidents that
don't exist for underground storage facilities. In addition, placing the facility above the largest
aquifer in the United States obviously may not be the most prudent alternative.
            5. Define the timetable for interim storage
      The DOE proposal for interim storage fails to provide a reasonable standard for
"interim". me proposal must provide a set timetable for dates the storage started and dates
____________________________
   (167)  Id. at 4-3.
   (168)  See supra, note 20.
                                        38
the interim storage will stop. A final destination for the permanent storage should be provided
within a reasonable and clearly defined timetable and penalties and recourse should be defined
for failure to meet those deadlines.
            6. Regulatory authorities
      Regulatory authorities should be granted by DOE with complete unrestricted access to
the Pantex plant. Additionally DOE should grant "shut down" authorities to those same
regulatory agencies in the event any actions by DOE or DOE contractors should threaten the
safety of the community. DOE and the Pantex Plant should be subject to the same laws applying
to the commercial nuclear industry.
IV.   CONCLUSION
      The DOE's EA is inadequate. The DOE should be required to prepare an EIS, discussing,
in detail, every potentially significant effect and feasible alternative. The seriousness of this
proposal should not be overlooked. In the event of an accident, the location of Pantex, coupled
with the mode of storage--being stored above ground, over the Ogallala aquifer, in
experimental multiple stacking configurations--could mean that the property and citizens of
the state of Texas and many in New Mexico would be severely harmed. These risks simply
cannot be overlooked on the basis of convenience and deadlines. Although the operations of the
DOE may be viewed as supremely important, no agency is above the law. If NEPA still upholds its
stated purpose, proposals such as this should be suspended, pending a thorough and complete
analysis in an EIS.
                                        39
                                   EXHIBIT A
Excerpts from technical papers on plutonium storage/Center and Environmental Studies, Princeton
University, Princeton, New Jersey/Department of Nuclear Engineering, Massachusetts Institute of Technology
                VERIFICATION ARRANGEMENTS FOR A PLUTONIUM STORE
       For a storage facility for plutonium in a single type of storage container,
assuming that construction features afford significant containment, the safeguards
provisions may be based upon verification of the amounts declared for each
container and subsequent application of containment and surveillance to confirm
the continued presence of the materials in the Store. Remeasurement and periodic
re-examination of the facility structure, and equipment would be carried out. The
following systems would be applied:
       Application of optical surveillance in the transfer areas and storage halls,
       incorporating pattern recognition, radiation and electromechanical sensors
       to trigger intelligent rerording and to facilitate systematic review, and
       incorporating redundant systems and/or components tc] enhance reliability,
       Neutron gate monitors at all entry and exit points to detect the presence of
       any plutonium passing the monitors and the direction of passage.
       Storage Container Assay Systems, based on high-level neutron coincidence
       assay methods, installed in the transfer routes and operated so as to
       measure the plutonium content of all containers transferred into the Store or
       transferred out, and to periodically remeasure the contents of selected
       containers to ensure that the verification systems had not be deceived or
       circumvented If the storage facility is to be automated, the Storage Container
       Assay system will operate continuously in an unattended mode following the
       arrangements used in some plutonium fabrication facilities. Note without
       isotopic verification, such measurements could provide assurance that after
       initial measurement there is no tampering with the contents.
       High resolution gamma ray spectroscopic analysis equipment, to confirm
       declared plutonium isotopics and americium content, (Note: the provisions
       for isotopic verification may be changed to reflect the sensitivity of the
       materials if a determination were made that such measurements might
       disclose weapon data.)
       Bulk determination by weighing and sample taking for laboratory
       analysis of elemental and isotopic composition is normally required, however,
       the circumstances of storage and the sensitivity of the materials may affect
       whether such provisions would be applied for the Storage of plutonium and/or
       HEU transferred from military inventories.
       A potential additional containment/surveillance system may be applied in the
       storage area, given the value of the materials in question. Such a system
       might be seals on individual containers (although the effort required to apply
       and service the seals is substantial), or area monitors which might be based
       on neutron field mapping or infrared mapping, for example.
Cost of Storage
    Storage of plutonium will be costly. The storage facility must be able to resist
penetration by explosives, have fire suppression and cooling systems (especially if the
plutonium is in metal form), and be equipped with a variety of sensing systems. In
addition, there will be continuing high labor costs due to the large guard force.
However, very little specific information is publicly available on the costs of large
plutonium stores such as those at La Hague and Sellafield. Costs of $1-2 per gram of
plutonium per year have been published, but without further explanation. Information
gleaned from interviews with utilities suggests that, in practice the prices charged by
reprocessors for plutonium storage may be higher than this, even approaching $4 per
gram per year.
      Plutonium stores must, of course, be made relatively resistant to clandestine
diversion by subnational groups. Strict physical and administrative control must be
maintained by keeping a constant heavy guard, severely restricting access to the store
and requiring that those who enter the store exit through portals equipped with
detectors sensitive to the neutrons emitted by plutonium. Plutonium containers could
be tagged and sealed after their contents have been assayed and their gamma
emissions measured to assure without a new assay being required that their contents
have not been tampered with in storage. Such arrangements would effectively
address subnational threats and, with regular international inspection, should inspire
confidence in the international community that no state diversion is taking place.
                                   EXHIBIT B
To:               W. H. O'Brien
From:             Adam Jones
Date:             August 23, 1993
Subject:    Operation Commonsense Business Poll
      I have completed a survey of 51 businesses taken between
August 16 and August 20th. The respondents were randomly
selected among businesses with at least 100 employees from the
Dun and Bradstreet directory. The poll surveyed companies with
150 employees up to 30,000 employees. The range of business
types was broad, including a diversified assortment of commercial
enterprises.
      The purpose of the poll was to determine the positive and
negative factors that would influence each company in their
decision to move, expand, or relocate. Amarillo was not
mentioned in the survey, but it is obvious that most of the
positive factors are present in Amarillo. This poll presents
some factors considered negative, included nuclear storage and
plutonium processing, in an attempt to gauge the impact the
acceptance of the plutonium option at Pantex might have on future
business development.
      The results of this poll clearly demonstrates that inclusion
of the plutonium option in the Pantex expansion would have a
serious impact for future business development. According to the
poll 72% of the businesses surveyed said the presence of a
nuclear storage facility and plutonium processing plant would
have a negative impact on their decision to expand or relocate in
such an area. The presence of a nuclear storage facility and
plutonium processing plant was given the highest negative rating
among the businesses surveyed.
      Among the positive factors, businesses cited low worker's
compensation costs, low local taxes, and inexpensive land and
capital cost as the most important considerations when expanding
or relocating. Access to an interstate highway, clean air and
water, and low crime also received favorable responses.
      Interestingly, the survey confirmed the entrance of
environmental firms into the mix of businesses. Nuclear storage
facility and plutonium processing plant actually received a
couple of positive impact responses from companies involved in
environmental restoration.

Part 2

COMMENTS ON D.O. E. RESPONSE TO AIRCRAFT HAZARD ANALYSIS REVIEW
by
J. M. Osborne
I am writing in regard to the D.O.E. responses to comments on the Aircraft Hazards Analysis
of the Environmental Assessment. In particular, I wish to clarify a number of points that were
apparently not clear to the D.O.E. responders. Additionally, I would like to raise points that I
previously neglected to raise in my comments.
I am an aerospace engineer specializing in propulsion and aircraft performance. I earned my
Bachelor of Science degree at Texas A&M University and have worked in the aerospace industry since
1983. More specifically, I have worked in the general aviation industry since 1985 and have participated
in a number of aircraft certification programs. I am currently employed by an aircraft manufacturer,
where I am involved in aircraft and propulsion system performance analysis and the interpretation of
flight test data.
The Aircraft Hazards Analysis focuses on the scenario of a light, general aviation aircraft
weighing 3500 pounds and impacting at 80 miles per hour. My comments were that this scenario was
unrealistic due to the mis-definition of general aviation and the use of incorrect units in defining aircraft
stall speeds. As the D.O.E. response to my comments states, the 3500 pound aircraft was chosen due to
the higher rate of in-flight accidents involving this category of aircraft. While it is correct that single-
engine aircraft have a higher inflight accident rate than other categories of aircraft, my point still stands
that the aircraft that routinely overfly the Pantex Plant are not in this category. Moreover, despite the
contention that since the plant is more than 5 miles from the runway the only the inflight phase need be
considered, the heavy transports and other military aircraft overflying the plant are indeed on approach to
landing. At the point in time that the transports, in particular, pass over Pantex, they have lowered their
landing gear, extended their flaps and slowed to their approach speed. These factors make them
vulnerable to the kinds of accidents that occur during the landing phase of flight - even if they are 8 miles
from the runway.
In addition, military combat and training aircraft utilizing Amarillo International Airport are not
normally destined to terminate the flight in Amarillo. Though they may be handled as a single flight, the
T-37 and T-38 trainers operating in the Amarillo International Airport control area are often executing
practice approaches or touch and go landings resulting in numerous overflights of Pantex. The same can
be said for many of the operations conducted by transport or combat aircraft in the Amarillo area.
The Aircraft Hazards Analysis bases the accident rate for military aircraft on data for a period
from 1976 through early 1992, missing a number of major military accidents. Admittedly, these
accidents due not fall in the analysis time constraint, but this fact alone does not change the fact that they
occurred. No data are presented for F-16 aircraft in Appendix E of the Environmental Assessment,
despite the large number of accidents involving these single-engine aircraft. Additionally, the B- 1
accident at Edwards AFB in the early to mid 1980's (1984 ?) was not included. Though this was a B-
1A, it was in B-1B configuration with some exceptions and should probably be included in the statistics.
In assessing the hazard presented by aircraft coming down within the boundaries of the Pantex
plant, the impact angle was assumed to be 15 degrees, marginally consistent with a forced landing under
controlled flight. No evident accounting for higher angle descents is made. The 15 degree angle impact
was assumed to be followed by a slide which was, for purposes of analysis assumed to be on a smooth
surface. From the discussion provided in the Aircraft Hazards Analysis, it appears that the data used was
for aircraft sliding on sand or on concrete, consistent with accidents on gunnery ranges or wheels up
landings, respectively. The statement is made that the area of the plant is made up of terrain that appears
level in a macroscopic sense, but is in fact fairly rough. This is in conflict with currently recommended
procedures in the event of a landing of an aircraft known to have its gear retracted. While it was at one
time suggested that landing beside the runway on the grass was best, current practice is to land on the
runway to maximize the decelerating effects of friction. In short, low grasses such as those common to
the Texas Panhandle offer lower coefficients of friction than those of a concrete runway or a sandy
surface.
In responding to my comments, the D.O.E. responders refer to my mention of a standard 3-
degree glide slope. Contrary to the apparent understanding of the D.O.E., I did not intend that to be
used as an impact angle. This angle was used in order to deduce an expected altitude of 2300 feet above
ground level for an aircraft on approach to the runway at Amarillo International Airport. As I stated, an
aircraft descending from this altitude in an uncontrolled manner will likely impact at an angle much
higher than 3 degrees or 15 degrees.
In my initial commentary, I pointed out the incorrect use of 80 miles per hour as a representative
initial speed for a 3500 pound aircraft with the accompanying underestimation of impact energy. I
recognize that a light weight aircraft that this discrepancy is probably insignificant. My point is that
obvious errors such as this indicate a more general lack of understanding of the material involved in the
analysis. Additionally, in revisiting the material while reading D.O.E. responses to my comments, I
note that according to Appendix F for the Environmental Assessment, that penetration of the bunkers
only requires an energy of 0.0000038 pound feet per second. If this is true, all of the analysis of
penetration hazards due to aircraft or large insects falls apart. I would sincerely hope that the exponent
in this case was meant to be a positive rather than a negative value.
Finally, I wish to bring up three additional points that I failed to discuss either in my initial
commentary or in the public hearing in Amarillo on 30 September 1993. The first is the possibility for
penetration of storage facilities by objects separating from aircraft overflying the plant. Included here
would be landing gear components, such as wheels and tires, and podded engines. Both have been
known to separate from aircraft in flight and not result in an accident. Normally an engine separation
would be referred to in reporting as an accident due to the expense of damage being in excess of
$500,000, but a wheel separation would likely be considered an incident. A 7900 pound engine falling
from a C-5B at 2300 feet would certainly be capable of significant damage to a storage facility.
Secondly, the long runway at Amarillo International Airport makes it a very attractive
destination for an aircraft forced to divert to an emergency field due to mechanical difficulties. Under
such circumstances, a pilot will normally elect to make a very long final approach in order to avoid
maneuvering at low altitudes and speeds. Such a scenario could put an aircraft in distress in a flight path
passing over Pantex. Additionally, under these emergency conditions, the pilot may ignore the
prohibited airspace adjacent to Pantex. These factors would imply a somewhat higher probability of an
accident than for the country at large.
Lastly, I wish to question the designation of probability bands quoted in the Aircraft Hazards
Analysis. In the analysis, accident rates of less than 10e-2 per year are considered "likely", less than this
but more than 10e-4 are called "unlikely", and less than 10e-4 but more than 10e-6 is called "extremely
unlikely". While I do not have a ready reference, I believe that, for aircraft certification purposes,
"unlikely" is considered to be a probability of less than 10e-7 per flight hour, "highly unlikely" is less
than 10e-9 and "extremely unlikely" is 10e-13. A reconciliation of these levels would be helpful.
In conclusion, while I realize that the chances of an aircraft accident with in the confines of
Pantex are remote, I don't believe that the analysis performed in support of the Environmental
Assessment is adequate to make the conclusions contained therein. The assumptions utilized were,
primarily correct for air traffic in general, but the specific assumptions addressed above are faulty in the
case of the Pantex area due to its proximity to an unusually long runway with a high level of training
activity. I sincerely hope that my comments will be of use in improving the quality of analysis
performed in future stages of the evaluation process.
Figure (Page 3 of Part 2 Hand writing text)

Part 3

BUREAU OF ECONOMIC GEOLOGY
THE UNIVERSITY OF TEXAS AT AUSTIN
University Station, Box X * Austin, Texas 78713-75O8 (512)471-1534 or 471-7721 FAX 47l-0140
10100 Burnet Road * Austin, Texas 78758-4497
December 20,1993
U.S. Department of Energy
Pantex Program Office, DP-6.2
Washington, DC 20585
RE: Comments on the Environmental Assessment for Interim Storage of
Plutonium at Pantex
To whom it may concern:
The following are comments from the Bureau of Economic Geology on the
Environmental Assessment for Interim Storage of Plutonium Components at
Pantex (November 1993).
EXECUTIVE SUMMARY (p. ES-10: Comment 1. Para. 2)
1. Who are the soil scientists that agree that plutonium is relatively immobile?
Please provide references.
2. Where were their studies completed and were those soils comparable to
High Plains soils in mineralogy and texture?
3. What are remediable depths?
4. What steps has the DOE initiated to identify and document preferential
pathways that may exist in postulated area of contamination?
(P. ES-11: Comment 2. Para. 2)
The literature values used by Los Alamos Laboratory to estimate recharge
rates are largely from earlier studies. Many of these studies did not recognize
focused recharge through playas or did not accept this concept. In our opinion, a
recharge rate of only 3 cm/yr is unreasonable.
(P. ES-11: Comment 3. Para 2)
1. Understanding the importance of preferential flow is critical to determining
the depth of penetration of contaminants. Los Alamos National Laboratory
based its assessment on 7 published studies, of which 6 reported acceleration
factors of two or less. Were these studies completed in areas closely
comparable to the High Plains in terms of soil and sediment structure,
mineralogy, and texture? Please provide references.
(P. E-2)
The response to Comment 1 does not answer many of the Bureau's initial questions
and request for additional information. For example:
U.S. Department of Energy
December 20,1993
Page 2
1. We asked for the anticipated contamination levels prior to cleanup. These
were not provided.
2. We asked for evidence illustrating that if prior cleanups have been
successful, could this technology be applied to the Pantex area? Although
successful cleanup may have been achieved at Johnson Atoll, Eniwetok, and
the Nevada Test Site, these areas are not similar to the High Plains in terms
of climate, soil, or physiography. Some discussion of the applicability of this
technology would be helpful.
3. We requested some discussion on removal of contaminated soil. What is
remediable depth? Since enormous volumes of soil might need to be
removed, where would it be stored? How would it be removed? What
would happen to livestock, farm buildings?
(P. E-4: Comment 2. Para. 2)
The playa basin area, which is used to determine a concentration ratio for drainage
into playas, is not the same as 100 percent of upland surface and should not be
confused with this much larger area.
(P. E-6: Para. 2 and 3)
The Nativ (1988) report is a published refereed report that was available to the public
on January 20,1989, and distributed to subscribers and libraries shortly thereafter.
Therefore, it was available when the Turin Report was being prepared.
Sincerely yours,
Thomas C. Gustavson
Senior Research Scientist
TCG:lch
cc: R. Mulder, Governor's Office
J. Raney, BEG
R. Finley, BEG
QA

Part 4

01/17 `94 11:20 ID:DP-DP-6:2 00 FAX: PAGE 1
12/20/1993 17:18 6154269289 SOCM. PAGE 01
December 20,1993
United States Department of Energy
Pantex Program Office, DP-6.2
Washington, DC 20585
Dear Sir or Madam:
I am submitting these comments in response to the Department of Energy's Pre-Approval Environmental
Assessment of the storage of Plutonium Pits at Pantex, hoping they may assist the Department in
making a judicious decision which enjoys the support of the public.
Comments on the Pre-approval Environmental Assessment
of the storage of Plutonium Pits at Pantex
Specific comments:
Vol. 1, p.3-2
DOE proposes that a shielded forklift, now under development, would traverse a passive
guidance system and be used for storage, retrieval, etc.: the operator would be shielded in a specially
constructed cab.
It is not clear when this improvement will be available, nor is it clear if the Steel Arch
Construction buildings will be modified prior to any storage to accommodate the passive guidance system,
it is also not clear what functions the operator is responsible for - could the forklift be designed
to be entirely remotely controlled, thereby reducing possible worker exposure even more?
It is also not clear how repairs would be made on the forklift should it become disabled while
performing its duties inside the storage building. How would it be removed from the tracking system
and withdrawn from the building -- what would estimated worker exposures be during such an
operation?
Vol. 1, p. 3-2
The last paragraph on this page says the proposed action would not involve new facility
construction... long-term or permanent storage, or disposal of plutonium components at the Pantex Plant.
The statement that this proposed action would not involve long-term or permanent storage is
incredible on its face. DOE has no other plan or contingency for plutonium storage; DOE is already
planning to move pits from other "interim" storage at Rocky Flats to Pantex.
In fact, it is far more likely than unlikely that Pantex will become a de facto long-term storage
site; DOE's refusal to attach that term to the decision currently under consideration -- for political
reasons as much as anything -- does not change the reality. It also undermines DOE's credibility.
Resource support provided by the Oak Ridge Education Project
01/17 `94 11:21 ID:DP-DP-6:2 00 FAX: PAGE 2
12/20/1993 17:18 6154269289 SOCM PAGE 02
Hutchison/Pantex EA 2
Any serious suggestion that this decision does not support long-term storage at Pantex must
outline that length and the capacities this EA will cover, establishing an upper limit for the NEPA
coverage potential of this document. This should be accompanied by a schedule of future decisions about
storage and a full description of the process by which such decisions should be made -- both the NEPA
process and the other decision-making processes of DOE (political, fiscal, policy, etc.)
Vol. 1, p. 4-1
In paragraph 4.0, DOE introduces a discussion of the alternatives to the proposed action. Two
programmatic objectives are described -- one is "the programmatic goal" and the second is "the other
programmatic objective." It is appalling that protection of the environment and worker and public
safety and health are not included in this introduction as programmatic goals. DOE's words here betray
a skewed sense of priorities that must be corrected -- not only on paper for the EA -- but institutionally
at the plant and throughout the Department of Energy.
Vol. 1, p. 4-5
Paragraph 4.3 considers supplementing storage at Pantex with storage at other DOE sites in a
remarkably weak paragraph. DOE acknowledges that approximately 1,100 pits could be stored at
Savannah River (which could relieve the current sense of crisis surrounding Pantex's diminishing
capacity), and defends its decision not to further explore possible relief it Los Alamos and Hanford for
two reasons: in 4.2 (c) "no environmental benefit would be derived..." and 4.3 "It cannot be assured that
this alternative could meet the need for near-term interim storage." The EA must provide a more
comprehensive and honest evaluation of alternatives. The question is not simply whether or not
environmental benefit (here meaning worker exposure) can be derived, but whether adverse
environmental impacts can be avoided; the EA does not address this. The statement that "it can not be
assured that this alternative would meet the need..." raises the obvious question: can DOE assure that
this alternative would not meet the need? The EA must answer this question.
Vol. 1, p. 4-6
In consideration of other temporary storage options, footnote 11 offers this rationale: "Active
conventional weapons storage facilities are not reasonable, because the Department of Defense mission
would not be compatible with the Department of Energy's mission." This statement is the kind of
bureaucratic mush which rightly offends the public. Because the assertion is used to discount a very
real possible option for DOE's current dismantlement time crunch it must be fully explained. The public
deserves to know if mission incompatibilities truly make storage impossible at active conventional
weapons facilities or if this is an option that policy people within both agencies could resolve with
discussions and a decision. Surely the Department of Defense is partner in achieving the President's
goals for weapons dismantlement and is committed to safety and security of all weapons systems --
conventional or nuclear. Tell us what's going on here; a footnote is insufficient.
Vol. 1, p. 4-8
DOE explains in a footnote that storing pits at a DOD site would require an additional
expenditure for Type B shipping containers. It is not clear from the text or the footnote if such shipping
containers will eventually be purchased for the pits anyway (so they can be shipped from deployment
bases to Pantex, in which case the discussion here is moot) or if Type B containers are usually recycled
for reuse.
01/17 `94 11:22 ID:DP-DP-6:2 00 FAX: PAGE 3
12/20/1993 17:18 6154269289 SOCM PAGE 03
Hutchison/Pantex EA 3
Vol. 1, p. 4-9 (Table 4-1)
The right hand comments column in this table refers at one place to the "President's
dismantlement objectives" and in a second place to the "President's weapons reduction initiatives."
While I can imagine a difference, the EA should clearly spell out the differences between these two
statements.
Vol. 1, p. 6-2 (Table 6-1)
The phrase "100 percent corrosion inspection" is misleading and must be corrected. In fact, DOE
does not intend to inspect 100% of the containers for corrosion, but rather to do a random spot check; it is
not clear that this spot check will be sufficient monitoring of the integrity of the containers.
Vol. 1, p. 6-2 and p. 6-3
In the last full paragraph on p. 6-2 and the second paragraph below the table on 6-3 the EA
states "the natural incidence of fatal cancer in the total population is about 20 percent." This statement
is misleading in the extreme and must be corrected. The causes of cancer are unknown, but appear to be
many; science is only beginning to understand the role of genetics and the triggering mechanisms which
may act in the body. How many cancers are "natural" and how many are stimulated by environmental
insults, exposure to toxins, lifestyle choices, x-rays would at this point be pure speculation. Is lung
cancer caused by cigarette smoking, "natural"? What would be unnatural?
The word "natural" must be struck in both instances and at any other places where this
language is used. This sloppy language is an embarrassment to DOE and an offense to the public. It
suggests DOE is desperate to minimize the risks it adds to our cumulative burdens and also desperate to
minimize the public's clear understanding of considerations of health impacts.
In both the above cases, the stock paragraph states that "we're operating within guidelines,"
and does not actually indicate clearly what the exposure risk to a worker would be. The EA should give
precise numbers and not try to cover itself with administrative jargon; the workers and the public have
the right to decide for themselves what is acceptable, not to be reassured by an agency that they
needn't worry.
Vol. 1, p. 6-4
In paragraph 6.2, dealing with abnormal events/accidents associated with the Proposed
Action, DOE applies the art of Risk Assessment to plutonium pit storage at Pantex.
The best Risk Assessment practitioners acknowledge at the outset that theirs is a "soft science;"
Not only are the formulae used to calculate risk often generated from best guesses, but the information
then plugged into the formulae is also often the contractor's best guess. At the end of the process, the
formula provides us with the exponential quantification of the unquantifiable. Any assurance the
public might hope to feel as a result of this process is further undercut by the application of
comparative risk analysis, where we throw issues of consent out the window, mix apples and ocean
liners, and further pare the list of possible risks.
For the Pantex EA, the magical "one in a million" acceptability ceiling is invoked. DOE should
note that this ceiling has been arbitrarily determined by agencies responsible for public health and
safety and has not been subjected to public consent.
DOE further applies its formulae to potential abnormal events/accidents and eliminates from
further consideration any which come out less than one in a million.
Our own life experiences, to say nothing of history, demonstrate that one in a million events
occur regularly. When we are talking about something as critical as the security of plutonium pits, one
in a million is not safe enough.
01/17 `94 11:22 ID:DP-DP-6:2 00 FAX: PAGE 4
12/20/1993 17:18 6154269289 SOCM PAGE 04
Hutchison/Pantex EA 4
DOE suggests that because the potential for a large plane crashing into a pit storage igloo is
calculated to be less than one in a million, such a possible crash can be discounted. This is nonsense. In
addition to failure to adequately calculate the amount of air traffic into the Amarillo airport,
including training exercises by the military, DOE has not considered that at least one forced landing of
a heavy aircraft has already occurred at Pantex.
Furthermore, Amarillo's air traffic officials not that in 1992, the airport counted 91,000
landings/take offs. Over the next ten years, airport use will increase annually; it is obvious that
Amarillo will see one million flights in ten years. If the risk of a plane crash into the igloos is one in a
million, that means the likelihood of a crash in the next ten years is 100%.
DOE can quibble about size of aircraft, numbers of landings, even risk factors. Small private
craft can be discounted, numbers can be juggled, the event can be rated at one in ten million with good,
creative risk assessment. The accident still could happen, with disastrous results. I believe it is as
likely as not.
Or, as an alternative, DOE could relocate the Amarillo runway to avoid Pantex overflights.
This alternative, while expensive in the short-term, could be financially offset by comparison to the
alternatives -- at least in the same way DOE conjures up a $36,000,000 outlay for Type B shipping
containers when considering interim storage at a DOD facility.
Vol. 1, p. 6-4
The second paragraph under heading 6.2 does not end. After the first sentence, the writer
embarks on a journey into the forest of risk assessment jargon and, as far as I can tell, is still wandering
around in there searching for a phrase like "may be made." The contractor probably had to hire
someone else to complete the section. I suspect we may never see the first writer again, but I hope DOE
will make some effort to account for him or her. At the very least, that foray into the thicket of risk
assessment should be somehow closed. I admit it will be hard -- I felt myself in danger even as a reader;
I know those "standard practices" are really pretty sophisticated traps. When I saw one had been set
for mere convenience -- convenience???? -- I knew we were in a troublesome place.
Vol. 1, p. 6-5
The second paragraph under 6.2.4, Forklift Operational Accident, makes an assumption that, in
the case of a puncture of a container, plutonium would be uniformly dispersed, which is silly. Nature, of
course, is not uniform.
Clearly in this type of accident, which is credible, a worker would risk serious exposure. The
EA does not make clear if the forklift operator's shielded cab is also airtight -- it should be designed to
be -- and if the operator is wearing a respirator, which would seem a common sense worker safeguard
any time moving equipment is being used around pit containers.
The statement that a worker would receive "no immediate or long-term health effect to the
worker as a result of an accident of this type" is root supported by health studies to date.
Vol. 1, p. 6-6
DOE's discounting of a potential aircraft crash with the assertion which closes this section is
not acceptable. Having reviewed DOE's method and numbers, I remain unconvinced. It does not appear
that the Pre-approval EA adequately responds to the substantive concerns raised by commenters on the
draft EA.
01/17 `94 11:22 ID:DP-DP-6:2 00 FAX: PAGE 5
12/20/1993 17:18 6154269289 SOCM PAGE 05
Hutchison/Pantex EA 5
General Comment
From the perspective of a citizen whose skepticism of the Department of Energy is based on
years of experience with an agency which now admits (to its credit) that it has done a lot wrong; it is
unfortunate that DOE did not seek independent analysis of potential risks in those areas where it was
already clear the public was deeply interested -- potential aircraft accidents and potential
contamination of the Ogallala. The use of DOE labs to provide documentation, risk analysis, and
decision support may pass DOE's quality assurance requirements, but the practice does not pass public
Assurance requirements. It is even more disappointing because DOE has people who are smart enough to
know this.
Rebuilding public confidence in DOE is not only an arduous process, it is fraught with peril.
Months of good work can be undone by one week of sloppiness, when it looks like "the old DOE" again.
The Pantex EA is an example of the type of poor work, with DOE blundering ahead oblivious to public
concerns, that we have been hoping is in the past.
The Pantex EA process, which is being watched closely by activists around the country, not just
the good people of Texas, is not a case of citizens complaining just to complain. We come to the EA in
good faith. We had baseline concerns about DOE's selection of the EA as the tool to provide NEPA
coverage. Still, we engaged in the process as people who truly want dismantlement to continue --
though we are not as committed to an arbitrarily set pace as DOE officials appear to be. We have
raised legitimate concerns about issues covered in the EA on several occasions.
It is not clear that DOE is capable of an adequate response to those concerns -- that is a response
that allays our fears or enables us to see there is simply an honest difference of opinion. Instead, it
appears that DOE is determined to push ahead, to maintain its dismantlement schedule, and to cover
itself with a bad process and a worse document.
I urge DOE to continue its good work of restoring public confidence in the agency, even at the
expense of the pace of dismantlement. DOE has options which have not been adequately explored and
must take the time to do that -- not only so the public can see you are doing it right, but because the law
requires it. Anything less will not be acceptable to the public.
We are talking about plutonium pit storage -- one of the most critical issues facing humankind.
We must all do our absolute best work here - DOE and the regulators and the public. The alternatives
are far too dangerous. The current version of the Pantex EA is not our best work.
The increased pace of dismantlement provides an opportunity for DOE to shine -- by
developing with full public involvement, a coherent plan addressing all dismantlement activities and
storage and disposition questions for plutonium, tritium, highly enriched uranium and all other
weapons components. Other involved agencies should be gathered, with the public, at the table to
discuss options for final disposition; issues of international verification and transparency should be
integrated into the planning process. The gravity of the decisions now confronting us requires nothing
less.
Sincerely,
Ralph Hutchison, coordinator
Oak Ridge Environmental Peace Alliance

Part 5

                                    GILLILAND 
                                    GROUP
December 13, 1993
United States Depart. of Energy
Pantex Program Office, DP 6.2
Washington, D.C., 20585
We have reviewed your conclusions regarding the EA at our Pantex Plant and recommend the
following:
a.  A (FONSI) conclusion is entirely in order.
b.  Plutonium storage at this location is both safe and desirable.
Your public meetings held in Amarillo were efficient and well received. We respect and support
your efforts.
Sincerely,
Bill Gilliland
BG/ds
P.O. Box 750 * Amarillo, Texas 79105 * Telephone 806-374-8652 * Fax 806-374-3818 * 1201 S. Taylor * Amarillo, Texas 79101

Part 6

                                 Wm. L. Graham
                              2326 Lakeview Drive
                             Amarillo, Texas 79109
December 16, 1993
United States Department of Energy
Pantex Program Office
DP 6.2
Washington, D.C. 20585
Gentlemen:
I have recently reviewed your Environmental Assessment for the Interim Storage of
Plutonium Components at the Pantex Nuclear Weapons Plant. The study evaluates the
environmental impact of additional storage of plutonium at the Amarillo plant and
concluded that there is no significant impact as a result of that storage
I urge you to support the Environmental Assessment and the interim storage of
plutonium at the Pantex Plant.
Thank you for your consideration.
Sincerely,
William L. Graham
sgd

Part 7

John Chandler Ford
Office of the President
December 13, 1993
United States Department of Energy
Pantex Program Office, DP 6.2
Washington, DC 20585
Dear Reader:
I have reviewed and I support your recent draft copy of Environmental Assessment
(EA) for the Interim Storage of Plutonium Components at the Pantex Nuclear Weapons
Plant. Due to the findings in the above (EA) I request that you rule a "finding of no
significant impact (FONSI) as a result of the increased storage of plutonium
I appreciate DOE holding the public meeting in Amarillo, Texas on December 6, 1993 to
provide the public an avenue to become informed and involved in the process.
Sincerely,
John Chandler
President
              I-4O and Ross * P.O. Box 30219 * Amarillo, Texas * (806)376-4911

Part 8

     PAA    PANHANDLE AREA ALLIANCE
            Suite 1020 * Plaza Two *  Amarillo, Texas 79101 * (806)371-7577
                               December 14, 1993
United States Department of Energy
Pantex Program Office, DP 6.2
Washington, DC 20585
Dear Sirs:
On behalf of the membership of the Panhandle Area Alliance, a
private organization working for the overall business and
industrial expansion of the Texas Panhandle, we wish to register
our support for the Department of Energy and encourage you to rule
a Finding of No Significant Impact (FONSI) as a result of the
increased storage of Plutonium at the Pantex Plant.
Our organization feels we should support the findings and
conclusions reached in the Environment Assessment for the Interim
Storage of Plutonium Components at the Pantex Plant. We feel the
suggestions and conclusions reached by expert scientists in this
regard should be followed and support the interim storage o-f
Plutonium at the plant.
We would like to add that our organization feels that the DOE is
making every effort to do the job at Pantex in a safe manner,
following all safeguards, for benefit of our region. We also
appreciate DOE holding public meetings such as the one held on
December 6, 1993, so the general public may become involved and as
full informed of the facts as possible.
Respectfully,
David T. McReynolds
Executive Director

Part 9

GENE MESSER
FORD
                               December 13, 1993
United States Department of Energy
Pantex Program Office DP 6.2
Washington, DC 20585
Dear Sirs,
     I'm writing to thank you for the Environmental Assessment for the
Interior Storage of Petroleum Components at Pantex.
     We have reviewed the conclusions in the EA and support the findings
of the expert scientist as to safety in this project.
     We support the interim storage of plutonium at Pantex. It is also
important that the DOE held the public meeting in Amarillo on December
6th to provide an avenue to the public to become informed and involved
in the process.
                            Sincerely,
                            Mike Rossman
                            VP & GM
                            Gene Messer Ford of Amarillo, Inc.
MR/ah
       2530 S. Georgia * Amarillo, Texas 79109 * Telephone 806/355-7471

Part 10

Guyon H. Saunders
Member Panhandle 2000 - Pantex SSAB
December 9, 1993
Mr. Dan Rhoads
United States Department of Energy
Pantex Program Office DP 6.2
Washington, DC 20585
Fax: 301-903-9471
Dear Mr. Rhoads:
Thank you very much for inviting the public to participate in this week's briefing on the Environ-
mental Assessment for Interim Storage of Plutonium Components at Pantex. The well organized
and skillfully presented material was most instructive for those of us who are not regularly in-
volved in this kind of dialogue.
You are now at a decision point regarding the EA. "To find, or not to find--significant impact"
Perhaps a reading from the silent majority would now be helpful. You did not hear from this large
constituency on Monday evening because we are any less supportive of a finding of no significant
impact. It is simply not productive to line up scores of people to say we have complete confi-
dence in what the Department is doing and the way you are going about it.
At this juncture, when you must choose a fork in the road, you cannot ignore the more than 85%
of popular support the DOE has earned in this panhandle region. If I do not speak for these inter-
ested persons as individuals, I am certainly echoing the main stream of their sentiments as I con-
tinue in my comments on the specifics of the several points raised in the EA briefing.
Aircraft crash analysis. Expert testimony on the probability of a heavy aircraft crashing into a pit
storage zone is not substantially changed from the 1983 EIS. What has changed, by several or-
ders of magnitude, is the quantum leap in safety resulting from the removal of high explosives
from the target zone of the investigation. In 1983 it was "safe enough" for a plane crash to strike
stored nuclear warheads. In 1993, the population is relieved to know we have only well shielded
plutonium pits stored in bunkers as the possible end-point for a one-in-a-million-per-year acciden-
tal occurrence. Adding more pits to storage in no way increases the probability of a plane crash.
Therefore, the silent majority will sign off on the much reduced risk evaluated in the 1993 EA
when compared to the currently bounding risk inherent in the 1983 EIS.
Ogallala Aquifer. Expert testimony on the ability of the DOE to conduct environmental remedia-
tion following any conceivable kind of plutonium dispersion is icing on the cake of extremely low
probabilities that such a dispersion could occur in the first place. The silent majority will sign off
as informed citizens recognizing the infinitesimal risk of plutonium causing the slightest of harm to
the Ogallala aquifer.
Interim storage of plutonium pits. During the Monday night hearing, a Los Alamos Laboratories
scientist, Joe Martz, made a significant suggestion while answering a question raised by a member
of the public. In private conversations at the hearing and again in a phone conference with Mr.
1212 Ross, Amarillo, Texas Direct (806)371-2700 Fax (806)376-9520
Martz later this week, his suggestion has been enlarged to what could be a solution for the di-
lemma surrounding the word "Interim".
First, the definition of interim must be something more than an empty space between decisions.
Interim needs to be a associated with a physical property within plutonium pits and a relevant ref-
erence to an episode of actual time in the long-term storage process.
In the manufacturing process of Pu 239 there is a small quantity, usually less than 0.3%, of an im-
purity in the form of Pu 241. This less stable material decays with a half-life of 13.5 years into
americium which emits low-energy gamma rays in addition to the very low energy alpha particles
emitted by the pure plutonium Because Pu 241 has a very short half-life its transition from a plu-
tonium impurity to americium will peak in only 69 years. This means that, in a maximum of 69
years from manufacture date, all of the elements within the pit will have demonstrated their ulti-
mate characteristics and the predictability of their long-term performance is virtually assured.
Interim storage is defined, therefore, as that period in time from date of manufacture to 69 years
during which monitoring and physical access is required to ensure that the long-term decay proc-
ess will continue as predicted. In actual years, interim storage at Pantex will be from 44 to 49
years considering that plutonium pits prior to disassembly have already experienced from 20 to 25
years of "interim storage" while in the nuclear warhead. Each pit contains its own credentials:
manufacture date, reprocess date, disassembly date, interim storage date range and eligibility date
for long-term storage. By the time true "long-term storage" is ready to begin, the best scientific
minds in America will have determined the ultimate disposition of plutonium in the most re-
sponsible and practical manner.
The silent majority and perhaps even some of the vocal minority will buy into an understanding of
INTERIM bounded by physics as compared to the present INTERIM unfortunately linked with
uncertainty.
To conclude while thanking you for your patience, I'll summarize. The finding of significant im-
pact by the extensive research of the Environmental Assessment can lead DOE into only one rea-
sonable conclusion: The truly SIGNIFICANT IMPACT is that storage of plutonium pits as proposed
is orders of magnitude more safe than the already accepted risk of storing nuclear warheads at
Pantex in the 1983 EIS. For this reason the nation cannot even consider any delay in the disman-
tling of these weapons. It would be the ultimate irresponsibility if our nation choose to store an
excess of battle-ready nuclear weapons under the guise of a cautious approach to storing safely
encased pure plutonium in pits.
The immense lift in public-safety confidence caused by the announcement of a consortium of
world-class universities focusing on peaceful uses for plutonium should be solidified by an orderly
establishment of the Pantex National Research Laboratory.
The Stage Right storage process at Pantex should be approved just as soon as readiness authority
can be granted. As stated in the December 6 briefing, the rails for this storage process can be
installed by existing maintenance personnel at Pantex at substantial savings in expense and imple-
mentation time.
Interim storage after disassembly should be declared to be from 44 to 49 years depending on the
length of time the pit was stored in the weapon's warhead. Interim storage is defined as the first
PANTEX 19 DOC Page 2
stage of long-term storage during which increased monitoring and physical access is required be-
cause of decay of small amounts of plutonium 241 into americium. The maximum period for this
transition is 69 years.
As mentioned earlier, I am convinced that the vast majority of informed panhandle citizens will
find this process to be an acceptable risk greatly improved from that authorized in the current
bounding 1983 EIS.
Very truly yours,
Guyon Saunders
c: Secretary Hazel O'Leary, Fax: 202-586-7644
Mr. Bob DeGrasse, Fax 202-586-8403
PANTEX 19 DOC Page 3

Part 11

CORPORATE                                         Operator (806)376-4223
SYSTEMS                                              Guyon (806)371-2700
Twenty-five Years of Leadership                        Fax (8O8)376-9520
                                              17 December, 1993 - 3:50PM
          202-586-7644         Sec. Hazel O'Leary
          202-586-8403         Bob DeGrasse
          301-903-9471         Dan Rhoads
Dear Sec. O'Leary, Bob and Dan,
During the evening of our Pantex EA hearing for Interim Storage on December 6 here
in Amarillo, I promised Bob and Dan to put some ideas on paper. These having to do
with the broad acceptance of DOE activities throughout the panhandle area. The silent
majority is not silent because it is ill informed. It is well informed and well satisfied with
the progress you are making toward a safer, more effective nuclear materials
management program for our nation, and perhaps the world..
On Monday, you will receive signed copies of the enclosed Fax if you wish to include
these comments in the record of the EA briefing by the Dec. 20th deadline.
May God bless each of you and your families during this holy season. We prey that the
Christ child brings peace and joy to all of you and blessings to the work you are doing
for all of us.
Your many friends in Amarillo
Guyon Saunders
                                                          9300021186

Part 12

100 S. Philadelphia                                             #2 Industrial Blvd.
P.O. Box 9358                                                         P.O. Box 3332
Amarillo, Texas 79105-9358                                 Borger, Texas 79008-3332
806-373-1746                                                           806-274-7161
                                      BDC
                         Budweiser Distributing Company
                               December 13, 1993
      United States Department of Energy
      Pantex Program Office, DP 6.2
      Washington, DC 20585
      Dear Sirs:
      This letter is in regard to the recently released Environmental
      Assessment (EA) for the Interim Storage of Plutonium Components
      at the Pantex Nuclear Weapons Plant.
      I personally support the Department of Energy and request that
      the DOE rule a finding of no significant impact (FONSI) as a
      result of the increased storage of plutonium. I have reviewed
      the conclusions in the EA and support the findings of the expert
      scientist as well as the interim storage of plutonium at the
      Pantex Plant. I also appreciate that the DOE held the public
      meeting here in my hometown on December 6, 1993 to further the
      dissemination of information needed to make informed opinions
      concerning these issues.
      Thank you in advance for your consideration of my views on this
      subject.
      Sincerely,
      Dean Morrison
      President - Budweiser Dist. Co.
      Amarillo, Texas
                       "Making friends is our business"

Part 13

  December 13, 1993
  United States Department of Energy
  Pantex Program Office, DP 6.2
  Washington, DC 20585
  Dear Reader:
  I have reviewed and I support your recent draft copy of Environmental Assessment
  (EA) for the Interim Storage of Plutonium Components at the Pantex Nuclear Weapons
  Plant. Due to the findings in the above (EA) I request that you rule a "finding of no
  significant impact (FONSI) as a result of the increased storage of plutonium.
  I appreciate DOE holding the public meeting in Amarillo, Texas on December 6, 1993 to
  provide the public an avenue to become informed and involved in the process.
  Sincerely,
  Paul Harpole
  Vice President
                       John Chandler -  Ford, Hyundai
                       I-40 and Ross * P.O. Box 30219 * Amarillo, Texas 79120 (806)376-4911

Part 14

AMARILLO
CHAMBER OF COMMERCE
December 15, 1993
United States Department of Energy
Pantex Program Office DP 6.2
Washington, DC 20585
Dear Sir:
I have reviewed the Environmental Assessment for the Interim Storage of
Plutonium Components at the Pantex Nuclear Weapons Plant recently released by DOE.
I subsequently attended the December 6 Public Hearing regarding interim storage and
have otherwise continued to stay abreast of this subject as well as possible for a non-
scientific individual.
I am of the opinion that the Department of Energy has gone the long mile in
researching the interim storage issue and making the Department's findings available to
the public. I am in agreement with the scientific findings published in the EA that
additional plutonium storage does not elevate any risks that are already present. Further,
I am perfectly comfortable with the present level of risk and believe they are well within
expectations of a prudent individual. I support the proposed expansion of interim storage
of plutonium at Pantex.
Our community appreciates the chance to participate with DOE in this decision
making process. You enjoy a high level of confidence in Amarillo.
Yours very truly,
Tom Patterson
President & CEQ
P.O. BOX 9480 * AMARILLO, TX 79105
(806)373-7800 FAX (806)373-3909

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