CHAPTER 2: COMMENT DOCUMENTS This chapter is a compilation of all the documents that the Department of Energy received during the public corn ment period on the Draft Programmatic Environmental Impact Statement for Tritium Supply and Recycling. The documents are keyed by number to table 1.3-3, Index of Commentors. The documents are presented by type in the order in which they were received On each document the first number represents the comment number within this document and the second number represents the issue summary code assigned to this comment. This number can be used to locate the summary and response relating to this comment. PUBLIC HEARING, APRIL 5,1995-LAS VEGAS, NEVADA FIRST MORNING SESSION-ENVIRONMENTAL EFFECTS 1/08.02 Downsizing in recent years has hurt the local economy. Work is needed immediately. The manpower (26,000 union workers are in the area) and expertise are here now. The project could and should begin immediately. 2/08.02 Workers and the local economy cannot wait until 2000 for the project to begin. Work is needed now. Downsizing has already hurt. 3/08.07 The economic multiplier for the Nevada Test Site (NTS) area should include not only indirect jobs, but also induced jobs (third level of job creation). 4/08.08 The Department of Energy (DOE) should not wait until 2000 to begin construction. NTS has the workforce in place right now and can begin immediately. There's a shortfall of work as it is, and there's a risk of losing more skilled workers if the project does not begin soon. 5/08.08 Work on the tritium supply and recycling facility should begin immediately at NTS. This will offset the ongoing downsizing and provide jobs and money to the local economy. The Programmatic Environmental Impact Statement (PEIS) should consider current and future downsizing in its socioeconomic analysis of the NTS area. The downsizing at NTS should be taken into account when making a decision as to the location of the tritium supply and recycling facility. 6/02.10 There is no experience in this area with the construction of a new, nuclear reactor facility. The facility should be built elsewhere, where there's more experience. 7/08.02 There is plenty of experience in this area with operating nuclear facilities. DOE should have confidence in the experienced, knowledgeable, and sizable workforce in southern Nevada. 8/02.02 The proposed solar facility for the generation of electricity could be used to supply the tritium supply and recycling facility with needed electricity. This would boost employment further. 9/04.02.01 DOE should consider the possibility of recharging the aquifer from which water is withdrawn for the tritium supply and recycling facility. 2-1 10/04.02.02 DOE should take every precaution to ensure that the tritium supply and recycling facility does not pollute the groundwater and surface water in the area. 11/10.02 Waste concerns need to be taken more seriously by DOE and the general public. There will be more spent fuel, more low-level waste, more hazardous waste and more sanitary waste. This is a short-term, as well as long-term, problem. Short-term, as well as long-term, costs are involved. 12/02.02 Electrical demands of the new tritium supply and recycling facility should not be a concern. A private company could take care of the electrical demands by running the proposed solar (photovoltaic) facility. 13/18.01 It is ironic that DOE would worry about the nonproliferation consequences of using a commercial reactor for defense purposes or about selling the electricity generated by a reactor whose real mission is defense related. The government and DOE's plan to build and run a new tritium facility has plenty of nonproliferation consequences itself. 14/12.01 DOE should analyze the consequences of its actions beyond 2050. The PEIS should take into account the consequences of the proposed action after 2050. 15/12.02 It seems that the Accelerator Production of Tritium (APT) will generate less waste and consume more water, while the other technologies will consume less water and generate more waste. How will these issues (waste and water) be weighted in the final decision? The PEIS should include a comparative analysis study on the benefits and risks involved with these two issues. DOE should outline how they will be weighted. 16/10.01 NTS is more suited to handle wastes (in particular, low-level waste [LLW]) than any of the other sites. NTS has much experience handling, managing, and storing different kinds of waste. The waste issue is not a problem for NTS. 17/13.06.01 The remoteness and size of NTS should be factors in the final decision. Due to its remoteness and size, NTS has advantages over the other sites in the areas of facility accidents, waste disposition/management (room for expansion), and radiation exposure. This should be studied and included in the PEIS analysis. 18/06.02 The desert tortoise is a threatened, not endangered, species. 19/08.02 There are many areas (communities) around NTS for workers to live in and commute to work. This is not a problem and should be seen as an advantage. 20/10.02 Currently, there is no way to dispose of spent fuel in the United States. Some of the proposed technologies generate spent fuel. This will mean more spent fuel for which we have no disposal method or final disposition. The PEIS should address this issue and include an analysis in the final PEIS. 21/13.09.07 The analysis in the PEIS is slanted in favor of the Savannah River Site (SRS) due to the existence of the recycling facility. For example, page ES-28 of the executive summary shows that 0 acres of land would be needed for a recycling upgrade at SRS. Does the PEIS, however, analyze the health and viability of the recycling facility in 2011? Will the recycling facility be functioning properly and safely in 2011? How old will the recycling facility be? In this way, the analysis is skewed. 2-2 22/13.00.15 The PEIS needs to make it more clear that the analysis for tritium need is based on new Start II stockpile levels, which is the most recent agreement for weapons reductions, and the associated reserve that needs to maintain the stockpile. SECOND MORNING SESSION - ENVIRONMENTAL EFFECTS 1/11.00.01 Radiation monitoring at NTS has been inconsistent over the past 30 years. The radiation baseline used in the PEIS is not accurate; therefore the radiation analysis is not accurate. DOE needs to ensure consistent monitoring in the future. The PEIS should take into account this inconsistent monitoring. 2/16.01 The accountability and responsibility for data gathering should be discussed in the PEIS. The accuracy and dependability of the data and the data gathering process should be examined in more detail. Chains of responsibility and those responsible for the data and the data gathering need to be discussed. 3/16.03 The public comment period for the PEIS is not long enough. There is not enough time from public disclosure of the PEIS until a decision is made. More time is needed for the public to review the scientific analysis and decision making process for a project that will span 50 years. The government and DOE should use a scientific time frame, instead of a political one, in the National Environmental Policy Act (NEPA) process. 4/16.12 The public should have access to the cost analysis and the weight given to the various costs associated with the project. Every subject and issue discussed in the PEIS should be looked at in cost terms as well. The cost analysis should mirror the PEIS analysis in this way. Lifecycle costs (cradle to grave) of all aspects of the facility should be included in the cost analysis. 5/15.03 DOE should focus on the national and public interest (Native American interest as well) inherent in the proposed action, not just DOE interest or the tritium interest. DOE needs to engage and involve the public on a much broader and deeper level. DOE should not make decisions which have such far-reaching impacts without explaining to the public that there is much uncertainty involved in the technical analysis and overall PEIS analysis (lack of operating experience for the APT and the Modular High Temperature Gas-Cooled Reactor (MHTGR), lack of knowledge of the future need for tritium, whether electricity could be sold from a defense related reactor etc...). 6/15.03 Much more public understanding of the issues and involvement are necessary. DOE should spend more money to engage the public, individual citizens. Impact and oversight funding should be provided to reach out to the public. Oversight funding for all environmental impact statements (EIS) is needed. Oversight money is needed to analyze the impacts of the proposed action on the citizens. 7/15.03 There needs to be a serious, public consensus development campaign to educate and inform individual citizens. Give the public more time and opportunity to become engaged. 8/15.03 Scientists and technical experts should be placed in direct contact with the citizens and kids. The educational needs of the general public are being ignored. There should be meetings with schools, churches, all aspects of the local community, to educate, engage, and involve each citizen. The public is being shortchanged. DOE should try a roundtable approach to its public meetings, instead of a hierarchical one. 2-3 9/15.03 Direct, DOE contact with the public should be expanded. The time frame of the direct, public involvement process should be extended. 10/02.01 The impacts to the electrical distribution system at NTS are not clear. Will there be major impacts or not? 11/08.07 Southern Nevada per capita income figures for 2010 may need to be adjusted. It seems that these figures are too low. 12/08.07 The PEIS should take into account tourism effects from the new facility (tourism may go down). DOE should analyze whether future development around NTS would be affected by the new facility (the new facility may interfere with future housing and development needs or the new facility may have unforeseen effects on, as yet, unbuilt housing). 13/14.01 DOE should consider the cumulative impacts of its decision on the entire Nuclear Weapons Complex. The proposed facility may affect not only the proposed site, but also the network of sites in the region (Idaho National Engineering Laboratory [INEL], NTS, Pantex Plant, and Oak Ridge Reservation [ORR] and SRS). 14/13.00.17 DOE should consider the molten salt reactor in its analysis. 15/01.04 The PEIS should include in its analysis the current and future value of the land surrounding NTS (the new facility could have an effect on its value). FIRST MORNING SESSION-PROJECT DESCRIPTION 1/13.00.05 Considers "triple play" alternative a political decision; feels inclusion of this option is late in this process. (Alternative is like breeder reactor, in which case it would conflict with Nonproliferation policy). If "triple-play" is considered, then it should be part of the PEIS. In addition, a lifecycle cost analysis should also be done (i.e. decontamination, decommission, waste management/storage, etc.). 2/14.01 Would like to see how the PEIS for Tritium Supply and Recycling relates to other PEISs in relation to costs, viability, etc. 3/13.06.03 Would like to see, if chosen, NTS produce tritium for commercial purposes in addition to its prime mission of producing tritium for the weapons program. 4/13.04.17 DOE should investigate alternative uses for, if chosen, the Accelerator technology, such as research and the production of medical isotopes. 5/13.00.07 Believes the U.S. should have two sources of tritium production for a strategic advantage, (e.g. an accelerator at NTS and facility at SRS). 6/13.04.05 If the accelerator technology is chosen, should consider solar energy as a source of at least some of the electrical power required to operate the accelerator. 7/13.00.11 DOE should consider siting the tritium supply and recycling facility outside of the existing nuclear weapons complex sites. 2-4 8/15.03 Should expand public review time. The public's time to review and offer comments for the decision making process is too short, especially if considering power sources such as solar energy for the accelerator technology. DOE does not have enough time to research the possibility of solar energy as a power source to be included as part of the accelerator's technology for evaluation before the EIS is due. SECOND MORNING SESSION-PROJECT DESCRIPTION 1/13.00.16 Should consider purchasing tritium from other sources such as commercial reactors or foreign countries like Russia. 2/13.06.01 NTS should be awarded the tritium mission because it has been longtime recipient of wastes and now wants to diversify operation's mission and Nevada's economy. States NTS has proper people and support to carry out this mission; has local university board able to be involved with NTS. In addition, NTS has strong safety record, security system, in-place contractors, interactions with unions, etc. 3/13.06.01 Should consider placing tritium production, recycling, stockpile stewardship, etc. all in one location. If this is considered, NTS should be the site to do so because it is equipped to handle such activities. 4/13.06.03 If accelerator technology is chosen, would like to see NTS be the recipient of it. This technology would be beneficial to the community (i.e. research, alternative uses). 5/13.00.07 Should select a technology that would produce the highest quality tritium as well as minimize waste generation. 6/15.03 Consider having the PEIS in computer format to enable the public to have greater and easier access to this information, e.g. Internet, CD-ROM, database. 7/15.03 Should use as many different mediums as possible to communicate to the public. Should also tell public entire "story" and spend more time clearly stating information to avoid any misperceptions. Should talk directly to the public, especially affected groups; should cover topics such as risk assessments, dangers of operations. 8/13.06.01 Should select NTS as the site. Most Nevada Congressional Representatives support NTS as selected site. 9/15.03 Surrounding Indian tribes would have liked to have been included in this process early on. Does not believe this EIS process truly takes into account the public's wishes. 10/04.02.02 Concerned that if NTS receives the project, the water will be affected. Water is crucial, and the Nevada area does not have enough of. 11/15.01 Considers the meeting format very useful and effective. 12/16.01 PEIS document should include section explaining differences between tritium and other nuclear type materials such as plutonium. 2-5 13/15.03 These public meetings should have had more publicity; for example, papers could have had pictures to "catch" the attention of readers. 14/15.01 In these meetings, presentations should have conceptual estimates of costs of alternatives. EVENING SESSION-OVERVIEW 1/16.01 All alternatives should be evaluated despite conflicts with policies because NEPA states that this be done. 2/14.02 NTS already has a mission as waste site; that it is now being considered for another operation is deplorable. FIRST EVENING SESSION-ENVIRONMENTAL EFFECTS 1/16.02 DOE and the U.S. Government should go beyond Strategic Arms Reduction START II so that a new tritium facility is not needed. Further stockpile reductions would allow DOE to use the tritium from the retired weapons, thereby eliminating the need for a brand new facility. This alternative has not been considered by DOE. Under the NEPA process the PEIS should analyze all reasonable alternatives. DOE should look at this alternative because it is reasonable. 2/10.02 NTS has been a dumping ground for other sites' wastes for way too long. NTS is overloaded with wastes. Anew facility would just add more waste. NTS has enough problems with current waste management. DOE should build elsewhere. 3/08.02 Overall, the tritium supply and recycling facility will benefit Nevadans and their kids (especially minority communities), providing needed jobs and incomes. 4/04.02.02 Nevada is strapped for water as it is. The new facility would only consume more. DOE should consider the effects the new facility would have on local water needs. 5/15.03 It is a fact that in the past DOE has not fully disclosed nuclear testing and waste management practices (and their impacts on the public) at NTS. More public involvement and fuller disclosure regarding this facility are needed. 6/13.00.17 A new facility to produce tritium does not seem necessary. DOE should have continued to use the reactor that last produced the gas. DOE should fully consider this alternative, rather than build a brand new facility. 7/13.06.01 Southern Nevada has plenty of water. Employment concerns are more important. NTS and the existing workforce in the area are a perfect match for the tritium supply and recycling project. There is much expertise in the area for the construction and operation of the tritium supply and recycling facility. The existing infrastructure at NTS and safety record of local employees are also advantages. State senators Jack Regan, Ray Shaffer and Joe Neal, and representative Bob Price all support this project. DOE should take into account the inherent advantages at NTS and in the regional workforce. 8/04.02.03 Water should not be a concern. It seems that there is enough water in the area to keep the golf courses green. Jobs are more important. The local economy needs a boost. 2-6 9/04.02.02 DOE should consider the effect that other future projects at NTS (not tritium supply and recycling) will have on water consumption. DOE should be sure that the water allotment is adequate for all future projects. Has DOE analyzed in the PEIS the water consumption of other future projects and the consequences this may have for the region? Do the 2005 and 2010 numbers in the PEIS take into account all future water needs? 10/04.02.02 Full APT water usage will exceed local recharge rates. DOE should consider the consequences of this. 11/04.02.03 As far as water goes, NTS has its own basin and is self-sufficient. Water at NTS is never used for Las Vegas. The water issue is not a problem. 12/08.08 DOE should consider and tap into the local, experienced workforce (26,000 union workers). They have an excellent safety record and much expertise. DOE should be concerned that local people get the jobs, instead of folks from outside of the region. 13/08.02 NTS has been good to minority workers, providing much needed training and experience. Overall, work at NTS contributes to a solid education for the workers and prepares them for other responsibilities and tasks. 14/08.03 The construction jobs will only be temporary. DOE should consider this in its analysis. 15/08.02 DOE and the Department of Defense (DOD) supported Las Vegas in the beginning with jobs and money. They have been good to southern Nevada. Southern Nevada should welcome more work. 16/05.01 DOE should analyze the seismic risks to the tritium supply and recycling facility from future nuclear testing in the area. In general, DOE should consider seismic risks to the new facility. 17/11.00.04 Construction deaths (industrial accidents) will exceed cancer deaths from the tritium supply and recycling facility. The accident deaths in the PEIS result from radiological releases or accidents, not industrial accidents. The PEIS should account for industrial accidents. 18/13.00.02 There is not enough operating experience for the APT and MHTGR technologies. There needs to be more experience with these technologies so that a more accurate analysis of their impacts can be made. 19/08.03 The PEIS should include an analysis of the impacts to the local scientific and engineering community, trade schools, colleges, and research and development. It also should account for the scientists and skilled workers drawn to NTS because of the new facility. 20/08.02 Many families in the past have depended on DOE and DOD for support. People have sent their children to college with the money they brought home from DOE and DOD jobs. NTS and southern Nevada need the work. 21/12.02 The new tritium supply and recycling facility will cost taxpayers billions, produce more spent fuel for which there is no repository, and use too much water. These issues should be given more consideration and weight. 2-7 22/10.01 NTS has a top of the line LLW facility which has been receiving wastes from all over the country. DOE should consider the fact that NTS has been a repository for other sites' wastes. NTS deserves the project. 23/18.01 It would be silly for DOE to construct a tritium supply and recycling facility with the potential to produce electricity, and then not use that potential (and sell that electricity) due to nonproliferation concerns. The worst case scenario would be a facility that costs billions to the taxpayer, consumes electricity, and gives nothing back. Congress should reconsider the nonproliferation policy. 24/16.12 The public should be fully informed about the cost analysis. The cost analysis and its weight in the final decision should be fully disclosed and the public should have input. In particular, the public should be fully informed about the cradle to grave costs (including long-term waste costs, decontamination and decommissioning [D&D]) of the facility. This is taxpayers' money after all. 25/02.02 Solar generated electricity (from a proposed central receiving and photovoltaic facility) could be used for NTS. SECOND EVENING SESSION - ENVIRONMENTAL EFFECTS 1/04.01.01 DOE should be concerned about surface water discharge from the APT once-through cooling system. The PEIS should include an analysis of this discharge. 2/10.17 One of the slides indicates the need for a new organic mixed waste facility. What are the primary constituents of this waste stream? Is it the same as mixed LLW? DOE should clarify this. 3/17.01 A neutral regulatory body, such as the Nuclear Regulatory Commission (NRC), should be assigned oversight responsibility at the new facility. An "in-house" regulatory body, run by those who work at the facility or by those from DOE, would be unacceptable. DOE needs to resolve the regulatory issue and publicly disclose its decision. 4/09.05 DOE needs an emergency management plan/structure (for accidents on rail or road) for NTS. The responsibilities involved in such a plan should be clearly defined (Is it a local, state, or Federal responsibility?). DOE's planning in this area is not adequate enough. 5/09.01 A separate EIS is needed to deal with issues of transportation. DOE needs to address this issue in more detail. 6/13.04.01 DOE should choose the APT technology due to its low generation of wastes (compared to the other technologies). 7/11.00.35 Tritium occurs naturally and is far less toxic/deadly than plutonium. DOE should make sure the public understands this to avoid irrational fears about the gas. 8/10.05 DOE should consider in its analysis the planned liquid LLW facility at NTS. 9/02.01 The additional miles of railroad required for the reactors (not the APT, the overhead is wrong) should not be a factor in either the technology decision or the site decision. 2-8 10/10.01 NTS has many waste management advantages over the other sites (especially LLW capacity). NTS is isolated, has plenty of room for expansion, has diverse capabilities, and can store wastes for long periods of time. In addition, DOE has used NTS as a waste repository for other sites. DOE should consider all of these things when making a decision. 11/16.09 DOE should look at cost studies detailing transportation of LLW by rail. There may be money to be saved by using the railroad. 12/13.06.03 If selling electrical power (generated by the tritium supply and recycling facility) is viable at NTS, this should be considered an advantage for NTS. 13/13.06.03 Nevada needs electrical power. If it's cost-effective and viable, Nevada and NTS would welcome the additional electricity and savings from such a facility. 14/18.01 DOE should consider and needs to identify all nonproliferation issues associated with this project. 15/13.06.01 The air strips at NTS are an advantage (tritium is transported by air). 16/02.01 DOE needs to clarify whether there will be major site infrastructure impacts at NTS (particularly with regard to electrical needs). In addition, how will these site infrastructure and electrical needs weigh in the final decision? DOE should disclose and clarify such issues. 17/05.01 The NRC concerns itself with seismic and volcanic effects on new facilities. Seismicity and volcanism should be taken up in the PEIS. 18/17.01 DOE should be wary of allowing the state to set regulatory standards for the tritium supply and recycling facility. State standards are often too stringent. 19/13.06.01 Many projects have not been brought to NTS. It's about time that NTS received one. The existing infrastructure is ideal and southern Nevada is ready for more work. 20/10.01 NTS should be commended for its existing waste management facilities. If the project were brought here, no wastes would be transported offsite. The necessary facilities are all onsite. 21/09.08 DOD should share shipping knowledge with other agencies. 22/14.01 DOE Yucca Mountain and DOT should be sharing information and integrating. They should not be traveling down separate paths. FIRST EVENING SESSION-PROJECT DESCRIPTION 1/13.03.01 Supports the Advanced Light Water Reactor (ALWR) technology and NTS as selected site because this would provide extra energy and jobs and produce less waste. 2/10.01 NTS is technically suited to take wastes. 3/13.04.17 Should consider utilizing accelerator for other uses, such as duel-use tritium production and research. Especially would like to see it at NTS. 2-9 4/05.07 Should have seismic stability as one of the criteria for site selection. Considers accelerator more stable alternative. Accelerator has no waste production, therefore in the event of an earthquake, wastes would not be released. The other alternatives are more vulnerable. Compared to the other sites, NTS would be best suited site because of less seismic activity. 5/13.04.05 If accelerator selected, would like to see solar energy as potential power source. Considers NTS appropriate site if accelerator and solar energy system selected. 6/16.01 Should have lifecycle cost conducted on alternatives; this should be used in evaluating alternatives. 7/13.06.01 Should consider NTS as selected site because: safety record, low waste streams, remote location, arid climate, water sources, skilled work force, etc. 8/13.04.01 Believes accelerator is best technology for national security, because it would be capable of producing tritium quickly and continuously. 9/08.02 Would like NTS to be selected as the site for the mission because it would enhance the scientific, technical, and cultural community. 10/15.01 Likes format of these meetings. 11/09.02 Should consider transportation as one of the selection criteria; NTS would be suitable place because there is no need to transport wastes off site. Disposal options for all waste streams exist on site. SECOND EVENING SESSION-PROJECT DESCRIPTION 1/13.04.17 Would like accelerator to be used for other purposes such as research (co-benefit). 2/13.00.10 Should consider combination of wet/dry cooling technology at any type of facility selected for NTS. 3/16.03 Would like to see this process of technology and site selection of the tritium facility accelerated because the current work force will soon leave and take their experience with them; would be loss of talent. 4/13.06.01 Would like NTS to be the selected site because it has resources to support the mission. This site has the best historical record. In addition, it is capable of storing and minimizing wastes. NTS also has fewer problems with regard to environmental cleanup and a proven safety record. NTS is in a suitable climate for project. 5/18.05 Supports National Defense Policy and general mission of DOE. 6/13.06.01 NTS would be the most logical site because there is no need to transport wastes to a storage location. 7/13.04.01 Accelerator is good alternative for seismic stability because in the event of an earthquake there would be no waste releases to the environment and people would not be affected because of the remote location. 2-10 8/15.01 Evening sessions should be held at a later time, approximately 7:00 p.m. PUBLIC HEARING, APRIL 5, 1995-WASHINGTON, DC MORNING SESSION-ENVIRONMENTAL EFFECTS 1/02.01 The document should include a more accurate analysis demonstrating the existing power pools may (or may not) support the APT technology without constructing new power plants. If existing power pools need to be expanded to support the APT, the environmental impacts of constructing and operating a coal/gas power plant should be addressed in the document. 2/02.02 DOE should consider the development of solar enterprises at NTS as a possible source of electricity. 3/02.09 The document should include the fact that some of the technologies produce electricity to present a more evenhanded evaluation of the power pool analysis. 4/02.09 If a reactor technology is chosen, it would not require new electricity sources and should be noted as a benefit in the document. 5/11.00. 18 If the APT technology is selected and found to require additional power from a facility which will be constructed in the future, then the document's evaluation is short on latent fatalities from the associated electricity production. 6/02.04 The document should address how the APT may effect reserve electricity capacity within the proposed power pools. 7/11.00.05 The document should include information relating how DOE intends to monitor radiation health within a 50-mile radius. The techniques should be described in the document as well. 8/11.02.17 The values for radiation exposures and resulting fatalities for low/moderate accident consequences of the ALWRs are grossly wrong. This is a result of improperly used data for accident probability. The value used was 103 when 106 would have been a more accurate value. The document is biasing public perception with grossly conservative numbers which does not accurately reflect the safety of the ALWRs. 9/11.02.17 The DOE value for frequency of a high consequence accident is such an unlikely event and yields an unfair and exaggerated accident analysis. NRC would not even consider the 2.0x10^8 accident frequency value as reasonable and, therefore, the high consequence/low probability accident analysis appears biased against the reactor technologies. MORNING SESSION-PROJECT DESCRIPTION 1/13.00.17 DOE should consider other options, such as a fusion facility, in the PEIS for tritium production. 2/02.04 DOE needs to address the power load of the APT in the PEIS. 2-11 3/16.14 The cost analysis, schedule studies, and production assurance studies for each of the technologies should have been available with the Draft PEIS. Without the decision making elements the public does not feel that they can give complete comments without weighing all sections of the process together. 4/16.12 There exists concern that the cost analysis, schedule studies, and production assurance studies will not be available to the public early enough to review and comment on before the Record of Decision (ROD) is issued. If these decision-making elements are not available to the public until the Final PEIS is published, then there needs to be more time available for comment than the minimum 30 days before the ROD. 5/13.00.14 The PEIS should include what else, if anything, the tritium facility would be able to produce/dispose of when or if tritium is no longer needed. 6/15.07 Concerned that there will not be an opportunity to comment on the decision made by the Secretary. There needs to be an opportunity for the public to comment on the ROD. 7/15.07 Concerned that public participation will not be included during the decision process. How will DOE assure the public that the their input has been included in the decision process? 8/13.00.14 The tritium facility should be sized to START II levels, which is the most recent agreement for weapons reductions, and designed for flexible adaptation to further changes in the required stockpile levels. 9/13.00.15 The PEIS should clearly explain that the tritium reserve stockpile includes tritium for the reserve of active weapons only. Active weapons meaning the weapons at the stockpile level and not used for weapons that are currently inactive or dismantled. 10/19.01 Concerned that DOE is spending large amounts of money on a project that could be canceled. What is going to be done to ensure that it does not happen as in other canceled DOE projects? 11/13.04.16 The PEIS should include any information gained from the New Production Reactor that has been helpful with the APT, and the relationship between the APT and the New Production Reactor. 12/13.09.06 Concerned that the cooling tower at SRS is not going to be evaluated in the decision process. If the technology chosen needs a cooling tower similar to the SRS tower than that needs to be part of the site decision process. 13/02.01 The PEIS should include a section on the environmental impacts associated with buying electricity from power pools outside the area of each of the five proposed sites. 14/14.01 DOE should postpone the technology decision until after the Fissile Material Disposition PEIS has been completed in order to know the recommended process of disposing of plutonium. 15/13.00.05 DOE should address the environmental impacts and cost/benefits for a tritium production reactor and for a reactor that produces tritium and burns plutonium. 16/13.04.01 General Atomic is an advocate of a government-operated APT. 2-12 17/22.01 The cost to the government of a privately financed reactor proposal needs to be included in the cost analysis. 18/02.01 The PEIS needs to include a discussion of the existing power pools and how it will affect the environment if the APT is chosen. 19/13.00.05 The benefits of electricity production from a reactor is not adequately presented in the PEIS. 20/13.00.05 Concerned about how DOE will inform the public on the cost/benefits of a privately or publicly owned multipurpose reactor. 21/13.00.05 A multipurpose reactor makes the most sense. AFTERNOON SESSION-ENVIRONMENTAL EFFECTS 1/16.07 The cost analysis and production assurance documents seem to be more important decision- making factors than the PEIS document. 2/14.01 The PEIS for Tritium Supply and Recycling should be coordinated with the Long-Term Storage and Disposition of Weapons-Usable Fissile Material PEIS. If a reactor technology is chosen to produce tritium, then it should be evaluated for the potential to reduce plutonium stockpiles as a reactor fuel. If this path is not taken and the two programs are tied together separately, new issues, which were not raised during the two analyses, may arise. AFTERNOON SESSION-PROJECT DESCRIPTION 1/13.04.01 The biggest advantage of the APT is its ability to be turned on/off. PUBLIC HEARING, APRIL 12, 1995-POCATELLO, IDAHO MORNING SESSION-ENVIRONMENTAL EFFECTS 1/02.04 The additional electricity used by the APT technology may require a new power plant. There would be environmental impacts associated with this new power facility. The PEIS should discuss these additional impacts. The other technologies avoid these additional impacts because their electrical consumption is less. The PEIS should discuss this avoidance as well. 2/02.01 The PEIS should consider various energy sources (nuclear, coal, hydro etc.) for additional power at INEL (if an additional power plant is necessary). The choice for additional power could be based on the composition of the regional power pool. 3/13.04.09 The effects of evaporative cooling on the environment (from the APT technology) should be analyzed in the PEIS. 4/08.01 DOE should be concerned about the quality of jobs and benefits that will come with a new tritium facility (regarding the new jobs at the facility itself). The PEIS should discuss this quality level. The commentor was comparing the types of jobs that Were associated with 2-13 various cleanup activities at the INEL (generally less technically demanding) with the jobs previously provided with more complex and higher technology projects. The commentor was hopeful that the tritium facility would require the higher-level and higher-paying types of jobs. 5/11.02.17 DOE could do a better job of explaining the human health effects from the proposed facility. The differences between actual deaths, probability, and risk should be clarified and made apparent in the PEIS. 6/11.02.17 The PEIS should put the human health numbers in perspective by comparing the numbers to other activities which carry a cancer risk. This should be done, however, without trivializing or minimizing the actual risk that comes with the new facility. 7/10.08 The large volume of spent fuel waste associated with the MHTGR technology (80 yd3) includes the moderator: The MHTGR does not produce more fission products than the other reactor technologies. The Final PEIS should explain this. 8/10.08 It is not clear that additional storage space (over and above that required by the other reactor technologies) would be needed for the 80 yd3 of spent fuel generated by the MHTGR. This is due to the thermal (criticality) requirements of storing spent fuel. The Final PEIS should mention this. 9/10.16 The Final PEIS should express LLW in curies or mass units (in addition to yd3 and acres^3). 10/19.01 The money to be spent on the new tritium facility is a poor allocation of taxpayer funds. We should not be spending billions on a facility that may not be needed in the future. The future developments in arms control or the world situation may be such that we can make further reductions in the nuclear weapons stockpile and obviate the need for a new facility. 11/18.01 The United States should be a leader in disarmament and peace. We are sending the wrong message to the rest of the world, with serious nonproliferation consequences, by building a new tritium facility. 13/13.00.20 The United States should go beyond the START II treaty so that a new tritium facility is not needed. The PEIS should include an analysis of a fewer weapons or no weapons alternative and the consequences this alternative would have on tritium needs. 13/13.00.05 The tritium facility is not necessarily a revenue loser, with only a defense mission. In particular, the triple-play reactor could generate revenue by selling electricity and dispose of plutonium, providing great mission flexibility. These facts should be seen as advantages for the triple-play reactor. 14/13.00.05 DOE could settle the nonproliferation issue raised by the sale of any energy related products of DOE tritium facility to the commercial sector by selling the steam that the tritium facility produces and letting an independent power producer run the steam and power generation plant. 15/14.01 The decisions about the tritium facility and plutonium disposition should be made at the same time to allow for a solution that satisfies both missions. The tritium EIS and plutonium disposition EIS should not be separated. 2-14 MORNING SESSION-PROJECT DESCRIPTION 1/13.00.17 Would like to see phased approach to all alternative technologies. 2/13.00.23 Reconsider having current schematic drawings in the PEIS reflect New Production Reactor designs. 3/18.01 Should look at no need for weapons; therefore no need for tritium. In addition, there is no long- term solution for storage of wastes. Considers money spent on this program is wasteful; it could be spent on waste management. 4/13.00.05 The technology type should be the primary criterion for this process. In particular, a technology that could provide a side benefit such as production of electricity would have advantages over others. 5/16.01 Need to clearly explain operating scenarios in the PEIS (for the sites). EVENING SESSION-OVERVIEW 1/16.01 Would like to see cost analysis of waste disposal in the PEIS. EVENING SESSION-ENVIRONMENTAL EFFECTS 1/10.02 Before the United States embarks on a new nuclear project, it should be sure that current and past projects have been cleaned up adequately and that the wastes from those projects have been disposed of economically and in an environmentally sound manner. 2/10.07 The PEIS should include an analysis of long-term waste management costs. These costs should include managing the wastes throughout the life of the facility and managing them after the facility is closed (after 2050). 3/10.37 The PEIS should use metric tons of heavy metal for the spent fuel numbers. This would make comparisons to spent fuel numbers in other documents easier. 4/22.02 DOE should revisit its nonproliferation policy. Specifically, they should consider using commercial light water reactors to produce tritium (by installing lithium targets in existing commercial reactors). 5/22.02 It would be wasteful not to use the tritium facility to produce electricity. DOE should reconsider its nonproliferation policy. 6/22.02 The PEIS is an appropriate place to revisit and reconsider national policies, such as the nonproliferation policies. DOE should revisit and clarify its nonproliferation policies (commercial uses of nuclear energy versus defense uses of nuclear energy) in this PEIS. 7/22.02 The policy of separating commercial (peaceful) and defense uses of nuclear energy has been a good one. DOE should preserve this policy. 2-15 8/15.03 DOE should have consulted with the Shoshonees before the draft process began. 9/04.02.04 DOE should further analyze the possibility of accidental discharges into the aquifer which lies below the INEL. The analysis should include the effect an earthquake would have on this possibility. DOE should identify in the analysis all possible pathways through which discharges could reach the aquifer. 10/04.02.04 The projected groundwater usage for INEL in 2010 may need to be adjusted. DOE may need to change this number based on future site projects and needs. The commentor feels that the projections for INEL water usages were too low. 11104.02.04 INEL's water allotment may change by 2010. DOE should investigate this possibility and allow for the change in its groundwater analysis. 12/18.01 There is no justification for this new tritium facility because the United States does not need thousands of nuclear weapons to maintain a nuclear deterrent (tens of weapons would be adequate). The United States should consider a policy of fewer weapons. 13/13.00.20 Tritium is not necessary for the functioning of nuclear weapons. They simply turn the weapons into "designer" weapons. DOE should analyze a no-tritium weapons alternative. 14/19.01 The tritium facility is a terrible investment for the taxpayers. The United States should be using its money to clean up the existing waste situation, not to create new ones. 15/18.01 The United States should be reducing its stockpile further and should be a leader in disarmament and peace. Constructing a new, nuclear facility sends the wrong message to the rest of the world. 16/13.00.14 There are other uses for tritium (peaceful) which the PEIS should discuss. There is a commercial market in the United States for tritium and DOE should consider using the tritium facility for commercial (nondefense) purposes in addition to its primary mission of producing tritium for weapons enhancement. 17/13.00.20 DOE should study a no-weapons or fewer-weapons alternative in the PEIS. 18/18.01 If it is true that in the past the United States has sold tritium produced for defense use to commercial users (even if it's a small amount), then we must rethink our nonproliferation policy and develop and follow one that is consistent. Otherwise, we are hypocritical. 19/20.09 The United States should be concentrating on existing cleanup issues and the current nuclear situation. We should not be embarking on new nuclear adventures that may prove unnecessary just five years down the road. Let's wait until 2000 and see what the landscape looks like then. By rushing headlong into the project now, we are precluding some feasible alternatives (using tritium from additional retired weapons). This kind of action is precisely what led to the arms race/buildup in the first place. 20/20.09 Another advantage of waiting on the project would come from the advances in technology. 21/18.08 The United States should disclose what it considers a "safe and reliable nuclear deterrent." How many weapons are we talking about? What are the precise numbers (in weapons) that are 2-16 driving this entire project? DOE should provide a "declassified" nuclear weapons stockpile plan to each citizen so that he or she knows what is going on. 22/18.01 Constructing a new, nuclear facility sends the wrong nonproliferation message to the world and encourages others to do as we do. 23/20.03 DOE should not even continue with its engineering studies that are scheduled for the next five years. This will just be an additional burden on the taxpayers. If they decide to proceed with the studies, it will mean that the tritium facility will be built. This is not fair to the citizens who think the facility should not be built. EVENING SESSION-PROJECT DESCRIPTION 1/18.01 Should not consider the technologies Heavy Water Reactor (HWR) and MHTGR because these alternatives would conflict with the nonproliferation policy. 2/18.01 The PEIS should acknowledge that the alternatives being considered are inconsistent with other nonproliferation policies of the U.S. In particular, it is inappropriate for the U.S. to ask other countries to forgo the use of highly enriched uranium and return spent fuel given to them in the past, yet propose two alternative technologies in the PEIS which would require the use of highly enriched uranium. 3 No comment identified. 4/13.00.17 Although the tritium program conflicts with nonproliferation policies, DOE should consider having technology alternatives which reuse spent fuel; spent fuel could be a resource. Other countries are currently doing so. 5/16.01 Supports cost analysis that is now underway. 6/13.00.36 The PEIS should include analysis of reasonable alternatives which may conflict or differ from current Federal policies. 7/16.01 The PEIS should have indicated the number of weapons that will constitute START II treaty levels and also the number that constitute a genuine deterrent; the public must have this amount in order to make a decision. Not having this amount published violates NEPA. In addition, an unclassified version of the Nuclear Weapons Stockpile Memorandum and Nuclear Weapons Stockpile Plan should be included. 8/18.01 Believes the United States' current nuclear stockpiles and planning are not deterrents at all; this action of building a tritium supply and recycling source is setting a bad example to other countries. Should reexamine the impact of a new tritium source on nonproliferation. 9/13.00.01 Supports "No Action Alternative." 10/20.01 Feels that this is a DOE mission similar to DOD mission in Vietnam and this mission is morally wrong. In addition, like the Vietnam War, the public is not receiving all the information (e.g. nuclear deterrent number) they need to influence governmental decision makers. 2-17 PUBLIC HEARING, APRIL 12, 1995-OAK RIDGE, TENNESSEE MORNING SESSION-ENVIRONMENTAL EFFECTS 1/11.02.17 The accident frequency rates for the HWR and ALWR are not accurate. 2108.03 DOE should be concerned that the projected employment figures may not be accurate since new jobs may be staffed by former employees of since shut down DOE facilities. 3/13.04.02 DOE does not consider the use of fissile material in the APT design as a source of neutrons for the eventual bombardment of target material. If DOE does consider a fissile neutron source, the electricity requirements would be much less but this would also produce radioactive wastes. By avoiding an investigation of the tradeoff between the power needs and the resulting environmental impacts, DOE appears to have assumed a political position in avoiding a uranium, fissionable neutron source. Nevertheless, DOE should have a more complete assessment including an APT design with a uranium neutron source weighed against potential environmental impacts. 4/10.18 ORR is under scrutiny for LLW storage practices, especially in the siting of LLW, and this may present an obstacle for similar plans in the tritium supply and recycling project. 5/10.06 Disposal of spallation products in the APT design should comply with NRC and the Environmental Protection Agency (EPA) standards since minute but extremely hazardous radioactive elements may be produced. 6/11.02.17 The ALWR low/moderate consequence accident assumptions are inconsistent with NRC standards. DOE must be careful to state what probabilities were used from NRC reports, such as a probability value from a worst case scenario Safety Analysis Report, because these would lead to misleading values of consequences. 7/11.02.17 No reactor would be licensed if it resulted in 1,500 fatalities. 8/11.01.01 There is a three order of magnitude difference for the release of tritium between the MHTGR and ALWR. MORNING SESSION-PROJECT DESCRIPTION 1/13.00.02 The PEIS needs to include more safety information related to the four technologies. The safety reports for each technology should be made available to the public. 2/13.04.17 The PEIS needs to include any advantages of using the APT and what is needed to decommission the APT. 3/13.04.03 Accelerators use spallation to produce tritium. However, this technology has only been researched using low power. The proposed APT will need to use high power and there is concern that the target will not be feasible. 4/13.00.02 As research and development progresses for the APT, costs will change. The APT has many uncertainties and this needs to be reflected in the cost estimates. 2-18 5/13.00.02 The APT has many uncertainties due to the lack of research and development. The MHTGR has been more thoroughly researched and developed compared to the APT, but the ALWR has the least amount of uncertainties. ALWR seems to be the best choice. 6/18.01 DOE should consider having no weapons and no production of tritium. 7/13.04.03 The PEIS should include the research and development of safety for the APT. 8/11.02.17 The comparison in appendix F between the probability of accidents for the APT and the reactors is not fair. The probability of accidents for the APT is 106 while the probability of accidents is in the hundreds for the reactors. 9/13.00.02 There is concern how cost versus efficiency/reliability is going to be compared for the four technologies. 10/13.00.02 The PEIS needs to include information on the reliability of the technologies. 11/02.08 DOE needs to get cost estimates from commercial electrical companies, and find out if the power pools can support the APT electrical requirements. 12/14.08 The PEIS should include a section on whether DOE will be selling electricity and how that will affect the commercial electrical companies in the area. 13/02.08 If the APT is supplied by a commercial electrical company(s), then DOE needs to consider what would happen if the electricity were cut off (i.e. how reliable are the commercial electrical companies). 14/02.04 The PEIS should include what size nuclear reactor would be needed to supply electricity for the APT. 15/02.04 The risk analysis needs to take into account the additional risk if a power plant was needed to produce the needed electrical power for the APT. 16/13.00.19 DOE should take advantage of the commercial reactors by purchasing a reactor to produce tritium rather than building another reactor. 17/14.01 There needs to be interaction between the PEIS for Tritium Supply and Recycling and the Fissile Material Disposition PEIS with respect to using a reactor (triple-play reactor) to burn plutonium and produce tritium and electricity. 18/13.00.19 DOE will save money by purchasing a commercial reactor to produce tritium and burn plutonium. 19/22.01 There needs to be a cost estimate for a tritium production and plutonium disposition facility together and a cost estimate for each facility separately. Finally, DOE needs to compare the three cost estimates. 20/11.00.21 There is concern about the creation of gamma radiation from spallation. 21/10.26 Concerned with what DOE is going to do with the waste from the production of tritium. 2-19 22/18.01 DOE should stop making nuclear weapons because DOE does not know of an environmentally safe process to dispose of the waste products from this activity. 23/10.25 DOE needs to consider if new processes, management/handling criteria, or containment will be required to dispose of the spent lead and tungsten targets from the APT. 24/10.26 The PEIS should include a discussion of the different types of wastes from the four technologies and how DOE is going to dispose of these wastes. 25/13.04.09 There is concern that activation products from spallation will contaminate part of the APT tunnel. If the tunnel is contaminated then the PEIS should include an analysis on the uncertainties with respect to the amount of contamination to the tunnel, whether or not the contamination will interfere with maintenance of the tunnel, or whether tunnel components will need to be decommissioned, and make it clear if the contaminated tunnel is included in the waste sections of the PEIS. 26/13.00.17 DOE should upgrade the K-Reactor at SRS for tritium production rather than build a new reactor. It would be cheaper and quicker to put the K-Reactor back on-line. 27/13.09.01 DOE should consider using the existing infrastructure at SRs for the tritium production facility which would save DOE money. 28/13.00.39 The cost of not using SRS for tritium production and recycling should be included in the cost analysis. 29/16.10 DOE should consider the advantages of using existing DOE sites infrastructure in the cost analysis for tritium production and recycling. 30/16.12 There is concern that the public will not get the cost analysis for the four technologies in time to give comments. The cost analysis should include decommissioning and revenues associated with any of the technologies, and any cost overruns with the APT. EVENING SESSION-OVERVIEW 1/12.09 On March 15, 1994, Dr. Harold Smith relayed to the House Appropriations Subcommittee on Energy and Water Development that tritium requirements are based on START I stockpiles and not START II stockpiles as DOE claims today. Contact Dave Hedgepeth at (615) 321-9091. EVENING SESSION-ENVIRONMENTAL EFFECTS 1/03.01 The document should clearly state where the data for each technology originated for the emissions analysis. 2110.11 The tritium supply and recycling project would add only an incremental increase in wastes compared to previous DOE projects which have contaminated ORR. This seems to position ORR as a likely candidate by avoiding more prominent impacts at another site. 3/11.00.12 Risk assessments for the project may be insufficient considering the health effects at ORR are significant. 2-20 4/11.00.13 There is new scientific evidence that there exists a threshold of radiation and this may not be able to be accounted for in the document. 5/10.18 There is much uncertainty about the location of an onsite LLW storage facility since there is no progress on the storage problems that already exist at ORR. 6/10.02 Today's problem pertaining to waste disposal was considered not a problem of the future during discussions in the early 70s. This public assurance was false and the issue has yet to be resolved. 7/10.02 The reactor technologies present waste management problems since there are no methods to handle the wastes of the reactor technologies. 8/13.04.05 If the APT is the selected technology, DOE should assess the option of operating the APT at night and other off-peak hours to reduce operating costs. 9/03.01 If a nuclear reactor facility is selected, DOE should aim to limit air exposures to more stringent standards than those currently established. The air exposures should not exceed one-tenth of the existing standards to avoid future shutdowns in the event these standards are not achieved. 10/18.01 As a resident of ORR, I disapprove of weapons of mass destruction and am not an advocate of DOE mission. 11/04.02.07 In the western United States, the Pleistocene groundwater loss is a complex issue. Recent studies have shown a decline in groundwater levels and this suggests that the groundwater in this region is a nonrenewable resource. 12/08.10 In the past, DOE often over exaggerated the number of potential jobs associated with a proposed project to strengthen the selling point of the project. When compared to the New Production Reactor project, the Tritium Supply and Recycling Program seems to have a longer employment period making the Tritium Supply and Recycling Program attractive in job-starved regions. In addition, the predicted projections may not be representative of the number of people in the region that benefit from the project. It seems grossly exaggerated that 12,000 jobs would be created in the ORR region. 13/11.00.12 The document should include the projected construction worker fatality rates in the human health section. 14/08.03 The document should detail the number of jobs lost in regions which are not awarded the tritium supply and recycling project at their site. EVENING SESSION-PROJECT DESCRIPTION 1/13.00.16 DOE should tell Russia to sell all the tritium they can at this time or otherwise we will build a reactor that will produce tritium. If they sell, then the United States would not be relying on Russia for defense purposes. The tritium purchased from Russia probably won't last for the next 50 to 60 years, but by the time the U.S. would need more tritium, there might be a new and better technology available for tritium production or the existing stockpile may be reduced even further. 2-21 2/13.00.16 DOE should consider purchasing tritium from foreign countries because this option would not only benefit the United States but would give some of the poor countries the needed revenue for their country. 3/13.00.17 DOE should consider putting the K-Reactor at SRS back on-line because it could keep up with the tritium needs if started immediately, and this would give time for a new technology to be developed or for a decision to decrease the nuclear weapons stockpile again. 4/13.09.06 The cooling tower at SRS should be included in the analysis of the PEIS for Tritium Supply and Recycling. 5/22.02 The United States should not use commercial reactors for the production of tritium because the United States has asked other countries not to use their commercial reactors for national security. 6/13.00.16 DOE should consider buying tritium from foreign countries at different times to attain the needed tritium. This could be possible if DOE really wanted to consider this option. 7/13.00.19 DOE has many reactors with a multitude of waste and environmental problems. Therefore, the PEIS should consider more closely the use of an existing commercial reactor, which might help prevent further environmental problems. 8/22.02 DOE should consider using a commercial reactor for producing tritium because it would save large amounts of money compared to building a new tritium production facility. 9/10.13 DOE should consider the possibility of reprocessing tritium from spent fuel. 10/13.04.03 The APT is unreliable and should not be used because there has never been an accelerator that has run on a continuous basis, ever produced the amount of tritium required by the existing stockpile, or ever used a high energy beam being considered. 11/13.04.03 DOE should be cautious about the APT and should not consider building it until more research and development has been done to show it is reliable. 12/13.00.02 DOE should build a small accelerator to test before they build a full size one that may or may not work which would be a waste of money. 13/14.08 If DOE is going to sell electricity then they will be competing with the private electrical companies. 14/13.00.02 Reliability is most important when choosing a technology. 15/13.00.14 The need for tritium may be reduced in the near future, therefore the PEIS should include other uses (secondary) for the chosen technologies. 16/13.00.32 The MHTGR should not be considered due to the amount of spent fuel it generates, the APT is too unreliable to be considered, and the HWR produces too much low-level waste. 17/13.00.17 DOE should consider using a commercial boiler reactor with lithium to produce the needed tritium for the nuclear stockpile and reserve. 2-22 PUBLIC HEARING, APRIL 20, 1995-NORTH AUGUSTA, SOUTH CAROLINA AFTERNOON SESSION-OVERVIEW 1/13.09.01 There is a national movement to get back to the Constitution. We still have people concerned with animals and the environment while our number one concern should be burning plutonium to prevent the proliferation of fissile materials. We can burn the plutonium in a reactor and simultaneously produce tritium at SRS. SRS should be the chosen site because there is a concern that the people with the most experience in operating reactors for tritium production would be lost to early retirement. 2/15.04 Politicians from Georgia are not listed as officials to contact and there is concern as to how much influence politicians from Georgia will have on the final decision. 3/16.12 The PEIS affords the public an opportunity to respond to environmental impacts but the public should also have an opportunity to respond to other decision making factors, such as the cost analysis and the production assurance analysis. 4/18.01 The Nonnuclear Proliferation Treaty is to be renewed this year while the United States intends on continuing the tritium supply and recycling project. The United States should concentrate on nonproliferation and is not moving fast enough to dismantle weapons. The Tritium Supply and Recycling Program is untimely and contradicts the aims of the Nonnuclear Proliferation Treaty. 5/13.09 SRS has 40 years experience and environmental compliance with tritium. SRS contains extensive infrastructure to integrate DOE tritium requirements in addition to the strongest public and political support. The workers at SRS have the experience and knowledge to accomplish DOE's mission. There exists a new modern recycling facility which may support a tritium source. In the future, it would be easier and cheaper to site other programs in conjunction with the Tritium Supply and Recycling Program at SRS. 6/15.05 Despite many recent changes in the world, DOE, for political reasons, is forced to build a reactor which was promised during the 80s. Chapter 2 of the PEIS for Tritium Supply and Recycling needs to be expanded because the public has the right to know how much tritium is needed at the taxpayer's expense. 7/18.07 The government continues to practice "pork barrel economics" by suggesting the possibility of a multipurpose reactor which can dispose of plutonium, produce tritium and generate electricity. In addition, a multipurpose reactor would send a contradictory message to the international community. The United States would utilize a defense mission to produce commercial electricity while encouraging other nations to support nonproliferation. 8/16.17 The decision making process is not truly a public involvement process. The public does not vote and, therefore, the public does not have an opportunity to decide how tax dollars are spent. 9/13.09.01 The United States must maintain the capability to dismantle terrorist-backed governments to prevent attacks on the United States. Tritium is essential as a nuclear deterrent and it needs to be produced soon. If SRS is not awarded the Tritium Supply and Recycling Program, it would be a crime. There exists a talented work force at SRS and the community support is 2-23 unparalleled. DOE should seriously consider the multipurpose reactor but SRS should be the site, irrespective of the preferred technology. FIRST AFTERNOON SESSION-ENVIRONMENTAL EFFECTS 1/13.00.39 The cost of upgrading the recycling facility at SRS is insignificant and should be considered a benefit. 2/13.00.39 DOE seems to have decided to build a recycling facility wherever the tritium source is built. Since a recycling facility already exists at SRS, the benefit is obvious. 3/08.04 There exists a qualified work force at SRS with 40 years of experience. This should be noted as a benefit in the PEIS. 4/11.00.07 The comparison of health effects between the APT and the reactor technologies is not a fair comparison. The human health effects which result from the high electromagnetic effects of an APT is unknown. The American Nuclear Society would not accept the comparison. In addition, the history of the five reactors at SRS has shown an excess of leukemia. The human `health section would not be accepted by professionals in epidemiology. DOE is presenting a narrow analysis to the public by only displaying radiation exposure. 5/11.00.10 More fatalities will occur as a result of electrical accidents than from nuclear radiation. 6/15.10 Public interaction meeting is an impressive idea by DOE. In the past DOE has deviated from decisions stated in RODs. As a taxpayer, DOE should commit to their decision stated in the ROD instead of changing the decision and wasting money. 7/11.00.09 The PEIS should display the current regulatory limits to be met, the history of the regulatory limits, and predict what these limits may be in the future. 8/22.02 Commentor wants DOE to assess whether the multipurpose option would breach the long- standing policy of separating commercial and defense facilities. 9/02.04 The large electrical consumption of the APT seems to be a major discriminator among the technologies. 10/13.09 NTS requires the greatest infrastructure upgrade while SRS requires the least. This difference should be noted as a discriminator and a benefit for SRS. 11/16.05 DOE should hold each site to equitable standards in the analysis of environmental compliance while cost factors should be weighted less as far as a decision making factor. SECOND AFTERNOON SESSION-ENVIRONMENTAL EFFECTS 1/13.00.37 The reactor technology is a proven technology while the APT is not. 2/10.14 The document does not adjust the environmental impacts for storage of spent fuel as a function of heat. Spent fuel storage is a function of heat and, therefore, the less heat generated by a reactor requires the least amount of storage. 2-24 3/10.02 Disposal of nuclear wastes is the most pressing international issue. There is a need to solve the problem of nuclear wastes. 4/10.15 DOE should present the percentage of spent fuel it must handle in the Tritium Supply and Recycling Program to the total amount of spent fuel it currently handles. This would present a more accurate perspective of the differences between the reactor technologies and the APT because these wastes may not present a significant increase in the amount of wastes currently handled. 5/02.03 Reactors should be credited in the PEIS for not creating impacts at a distant location from their operation. 6/02.04 The PEIS should assume the APT will need a new facility to sustain the required amount of electricity. To present a fair analysis in an environmental document, the generator which impacts the environment the greatest in the power pool region should be evaluated. Then assess the environmental impact of the new generator in the region, built specifically to support the APT, and present the results in the PEIS. It should be assumed the offending generator, usually a coal-fired plant, would then be taken off-line. 7/02.04 If the APT is the selected technology, the potential cost of constructing an extra power plant should be accounted as an extra cost. A multipurpose reactor would burn plutonium and produce waste but may also facilitate the shut down of the environmentally hazardous generator within the power pool. 8/13.00.05 The electricity requirement for the APT is large and the design is unproven. DOE should consider the multipurpose reactor. 9/02.04 The excess capacity for regional power pools is not extra electricity but electricity needed by these power pools. DOE projections for future growth in power pool regions may be inaccurate and this may cause utilities to build new facilities if an APT is chosen. 10/13.04.07 The document seems to unfairly bias the APT and this must be corrected to create fairness among the technologies. 11/13.04.03 The uncertainties in the undeveloped design of the APT is an unknown factor which will create an exponential amount of problems in the future. 12/13.09.05 The Defense Waste Processor is not included under SRS in the table in the executive summary. 13/13.09.01 There is 150 percent unanimous support for the multipurpose reactor at SRS because of what is does in addition to tritium production. 14/14.01 By separating the Tritium Supply and Recycling and Fissile Material Disposition Programs, which DOE has stated may intersect if a reactor technology is chosen, DOE may find that another costly analysis may be required to analyze a multipurpose reactor. 15/14.01 The Tritium Supply and Recycling and Fissile Material Disposition Programs may prove to have greater environmental impacts than a multipurpose reactor which would fulfill both missions. DOE should investigate the environmental impacts of a multipurpose reactor in more detail to create a fair comparison. 2-25 16/14.01 As a matter of national security, the disposition of plutonium should be addressed before we decide to produce tritium. The plutonium issue should be resolved first because DOE may not need tritium if this issue is addressed. Also, the multipurpose reactor is not fully analyzed in the document. 17/15.07 The public does should have an opportunity to input on other decision making factors. 18/13.09.01 Irrespective of the chosen technology, SRs should be the site because there exists the expertise, experience, and most likely the lowest cost. The cost analysis should be viewed by the public with an opportunity to comment. 19/15.07 The public should have an opportunity to review other decision making analyses before a preferred alternative is issued. 20/13.09.03 The document should have an analysis of the relative environmental effects if the tritium mission at SRs is terminated. 21/13.09.01 People have rights which should not take a backseat to the environment. SRS should be awarded as the site for the tritium mission since the site already deals with nuclear fuel and wastes from all over the world. 22/13.09.01 The location of an existing tritium recycling facility should be considered a site discriminator in favor of SRS. 23/08.04 If the tritium recycling responsibilities were removed from SRS, more than 800 people would lose their jobs, engendering long-term impacts at SRS. 24/11.00.03 Recent epidemiological research suggests that a large influx of people in a region may lead to higher rates of leukemia. This unknown phenomena may result from viral transmissions in an unstable population. The document should attempt to include this in the human health section. FIRST AFTERNOON SESSION-PROJECT DESCRIPTION 1/13.00.18 The ALWR is not the most efficient technology for producing electricity (thermal). The MHTGR is more efficient. 2/13.04.03 The public does not have much confidence in the APT when DOE still needs 3 to 4 years of research and development on it. DOE should not make a decision on the APT technology until this technology is more reliable. 3/13.02.01 The PEIS should include a section describing the uncertainties related to the MHTGR. 4/13.00.17 DOE spent over $1 billion on the K-Reactor at SRS and should consider upgrading this reactor rather than spending another billion dollars or more on a new technology to produce tritium. 5/13.04.17 The PEIS should discuss any benefits of using an accelerator over a reactor (i.e. any other use than for producing tritium, burn plutonium, etc.) 6/14.01 The PEIS should describe if and/or how the Stockpile, Stewardship and Management PEIS will impact the decision on technical and site decision on tritium recycling. 2-26 7/14.01 How can DOE make a decision on the PEIS for Tritium Supply and Recycling when they have not made a decision on what sites to evaluate for the Stockpile Stewardship and Management PEIS. 8/13.09.01 Aiken Commerce Board supports a decision to place tritium supply and recycling at SRS. 9/14.01 How will the decisions on the Stockpile Stewardship and Management and Fissile Materials Disposition PEISs affect the time structure for the PEIS for Tritium Supply and Recycling decisions. 10/14.01 The PEIS should include a section combining the impacts associated with burning plutonium, producing tritium and electricity (triple-play reactor). The PEIS should also compare those impacts to producing tritium and burning plutonium separately. 11/14.01 DOE should delay the decision on tritium supply and recycling until a decision has been made on plutonium disposition. 12/14.01 The best decision could be the triple play reactor which is not being fully evaluated in the PEIS. The PEIS should more thoroughly evaluate the triple-play reactor. 13/16.11 The representatives in Congress need to have more input into the Secretary's decision on the PEIS for Tritium Supply and Recycling. 14/13.04.03 There is concern that if (after 3 to 4 years of research and development) the APT is still considered unreliable that this delay in constructing a new tritium supply facility could jeopardize our Nation's national security. 15/16.12 There is concern that the cost analysis, schedule studies, and production assurance studies will not be available in time for public comment. 16/16.12 DOE should consider having a formal process allowing the public to comment on the cost analysis, schedule studies, and production assurance studies. 17/13.00.02 There is a very high risk associated with large projects that have never been tested at full scale. DOE should not be considering marginal technologies. 18/02.01 The PEIS does not include impacts associated with the high power need of the APT. 19/13.00.14 If the APT were constructed and a few years later tritium was no longer needed, what would be the function(s) of the APT. The PEIS should include a section discussing this area of concern. 20/13.00.14 The PEIS should address the relative functions of each technology if tritium was no longer needed. 21/13.00.05 DOE needs to develop a cost/benefit ratio for the multipurpose reactor. 22/13.00.05 We need to consider getting rid of the plutonium problem in this country. DOE needs to seriously consider the triple-play reactor for production of tritium, disposition of plutonium, and production of electricity. 2-27 SECOND AFTERNOON SESSION-PROJECT DESCRIPTION 1/13.00.20 DOE should consider not making anymore tritium for nuclear weapons as an alternative. 2113.00.20 The United States has not used tritium enhanced nuclear weapons for many years. DOE should consider convening back to the old style nuclear weapons. 3/18.07 DOE should consider using a plutonium trigger for weapons less than 20 tons of TNT equivalent. This portion of the arsenal would not need to use tritium, therefore the time needed for tritium production would be increased. 4/13.04.22 The PEIS needs to include a section explaining the source of helium-3 for tritium production and any impacts with the use of this isotope. 5/04.02.10 The PEIS needs to clarify the term n/a for the closed loop cooling system for the APT. Does it mean that the APT will not be located at a dry site? 6/16.01 DOE should consider the operating records of the individual sites as a criteria in the PEIS. 7/13.09.04 SRS is not the place to put the tritium supply facility. 8/16.01 The operation experience and expertise of each of the sites needs to be highly considered in the PEIS decision. 9/13.04.22 DOE should reconsider the selling of helium-3 because it may become a rare item for tritium production. 10/13.04.22 DOE needs to estimate the amount of helium-3 available and the percentage that will be recycled in order to know if there will be enough helium-3 for tritium production into the year 2060. These estimates need to include a safety factor for lost helium-3, and will there be enough available helium-3 in the case of an national emergency. 11/18.04 DOE should consider making excess tritium and selling it to other countries to offset the cost to the tax payers. 12/16.08 The design status of each of the technologies should be available to the public. 13/12.05 The PEIS should include a table listing the key discriminators for each of the technologies independent of the sites. 14/13.00.40 The unclassified graph of the Estimated START II Tritium Inventory and Reserve Requirements needs to be more clearly explained. Does the graph take into account the unavailability of tritium for the next 15 years, and is this a conservative estimate. EVENING SESSION-ENVIRONMENTAL EFFECTS 1/02.04 The PEIS should evaluate the impacts of a power source which would most likely need to be constructed to support the electrical requirements of the APT. DOE should analyze the impacts 2-28 of a hydroelectric generator, probably the most environmentally safe, and a coal generator, the least environmentally safe, and then average the impacts to present in the document. 2/13.04.05 If the APT is the chosen technology, DOE should consider a hydroelectric generator to support the capacity margins in the power pool. 3/10.06 If the APT is selected, wastes produced from a coal plant to support the APT electricity requirements should be included in the waste analysis. 4/13.04.05 If the APT is selected, DOE should consider the construction of a power source onsite to support the APT's electricity requirements. 5/11.00.07 The document should include the health risks of the electromagnetic radiation produced by the APT. 6/11.02.17 The values of the consequences presented in the human health section seem inconsistent with past analyses, especially the unusually low values for the MHTGR. 7/11.02.17 The consequence values in the human health section are so varied because the frequency value used in the analysis is so large and unrealistic. The probability values are sensitive to the design and frequency. The more unrealistic frequency value would yield even more fatalities in the analysis. The risk values in the human health section are the more important figures and these values are extremely small, irrespective of the technologies. 8/11.02.17 In order to present perspective for the risk values, the risks of smoking, living in a brick house, and other various commonplace figures should be included in the document. 9/11.00.11 The fatality figures presented in the document are misleading because there is such a large disparity between the technologies. 10/11.02.17 The document should integrate the risks of all potential accidents identified instead of the two individual events analyzed. 11/11.00.14 Risks depend on the choices people make. For instance, radiation may cause cancer but people may choose radiation to cure cancer. 12/12.10 The document should include an analysis on safety, focusing on past performance of the potential sites. 13/04.02.07 The document should adjust the values for water usage at the sites since these values depend on the relative humidity at the sites. 14/13.00.05 Proliferation of fissile material is the greatest national security issue. The United States is responsible for preventing the spread of plutonium to terrorist groups. The Los Alamos National Laboratory has determined that plutonium cannot be deposited for safe storage in a geologic repository. The United S[ates may prevent the spread of plutonium by burning it in a multipurpose reactor while reaping the benefits of electricity and producing tritium. 2-29 EVENING SESSION-PROJECT DESCRIPTION 1/13.09.11 The tritium supply and recycling facility should be placed at SRS because SRS has the land mass, site infrastructure onsite and offsite, cost record, safety record, community and state support. The people at SRS are committed and really want the facility put at SRS. 2/13.09.01 The State of Georgia supports SRS and the placement of tritium supply and recycling facilities at SRS. SRS has the infrastructure to support this facility. Georgia wants the recycling mission to be finished at SRS and this is the right time and place to put the tritium supply and recycling facility at SRS. 3/13.09.01 SRS has many trained laborers. The weather at SRS allows these laborers to work 12 months a year, as some places only allow 6 months of work a year due to inclement weather. 4/18.15 The public is concerned about the associated impacts to tritium supply and recycling if Start II is not ratified. 5/13.00.14 The PEIS needs to include a section addressing the benefits of each technology in the event that tritium is no longer needed. 6/13.04.17 DOE should consider the use of research accelerators to produce the needed tritium. 7/13.04.11 The PEIS needs to include a section describing Plan B in the event the APT is not ready after research and development was completed. 8/13.04.03 There is concern that the APT will suffer like the super collider because of all the uncertainties. 9/13.00.37 The ALWR or HWR should be chosen for tritium production rather than spending the tax payers money for research and development on a technology that has so many uncertainties. 10/13.00.37 The APT should be studied on the side, and a reactor should be used to produce tritium because it is a proven technology. 11/13.00.37 A reactor would be the best choice because the laborers are knowledgeable about reactors and there will not have to be as much training involved with a new reactor facility. 12/18.04 The PEIS needs to include a discussion of the effects of producing and selling electricity commercially. 13/13.00.05 The multi-purpose reactor is the best choice because it can produce tritium and dispose of plutonium. 14/13.04.06 The cost of disposing of plutonium needs to be included in the cost of the APT, since the APT is not capable of burning plutonium. 15/13.00.37 There is no reason to do more research and development with the APT when there are reactors that are proven to be reliable. 2-30 16/13.04.03 DOE should not be considering the APT because it has been proven not to work on a commercial level. DOE needs to consider the technical risk of operating its own fabrication fuel facility. 17/13.02.01 The MHTGR looks great on paper but does not work in reality. 18/22.03 The United States helped Canada design their CANDU reactors, and told Canada that we would take back the plutonium. Now Canada wants the United States to take their plutonium, make mixed-oxide fuel, and give it back to Canada to burn in their reactors. The United States must stop subsidizing the CANDU Reactor in Canada. 19/16.01 DOE must assess a cost to the risk of each technology. 20/04.28 A cost/benefit ratio needs to be included with the APT. 21/16.01 Would like to have a lifecycle cost of each technology included in the PEIS. 22/16.01 The cost of retraining the laborers who will be working in the facility needs to be included in the cost of each technology. 23/13.09.01 It took 10 years to get a training program that worked well in SRS. It would cost a lot of money for another training program to be developed at another site. Therefore, the tritium facility needs to be located at SRS. 24/13.09.01 SRS has the site infrastructure to support any of the four technologies. It would make no sense for DOE to place the facility at any other site besides SRS. 25/13.09.01 SRS is capable of supporting the APT if DOE concludes that it would be the best technology for tritium production. 26/13.09.01 SRS is the most pro-nuclear community and this community really wants tritium supply and recycling to be placed at SRS. 27/13.09.01 The tritium supply and recycling facility should be placed at SRS because SRS has a 40 year track record with producing large quantities of tritium. PUBLIC HEARING, APRIL 20,1995-AMARILLO, TEXAS FIRST AFTERNOON SESSION-ENVIRONMENTAL EFFECTS 1/04.02.05 DOE should consider in the PEIS any temperature effects in the play as from any wastewater discharges. 2/02.04 DOE has used the wrong power pool in its analysis of the electrical needs of each technology. Southwest is the correct provider. The percentages shown as "percent power pool capacity margin" on the overhead may be incorrect. 3/04.02.01 DOE should consider other sources of water for the tritium facility. In particular, using wastewater from the city of Amarillo or Pantex itself is a viable alternative. 2-31 4/04.02.01 DOE should make as many technical and/or efficiency improvements in the APT technology as possible in order to reduce water usage. 5/04.02.01 The Final PEIS should include in its water resources section all alternatives that would reduce groundwater usage (using wastewater, improvements in the technologies, using closed loop cooling for the target end of the APT). This should be done to inform decision makers more fully and to portray the Pantex water resources analysis in a better light (as compared to other sites). 6/10.29 DOE should include in the Final PEIS an analysis of any effects a pipeline carrying wastewater from Amarillo to Pantex would have on the environment and surrounding communities. A cost analysis on this pipeline should be done as well. 7/04.02.02 DOE should consider the other parties at risk due to the new facility's enormous water consumption. These parties include farmers, the city of Amarillo, and other water users in the area. There may be additional costs (financial, environmental, and other) resulting from the aquifer drawdown and the PEIS should fully cover these costs. 8/04-02.02 If alternative sources of water are not available (wastewater, using closed loop cooling for the APT), there will be significant drawdown of the aquifer. DOE should analyze the effect this drawdown would have on the surrounding community and any private and public wells. In particular, DOE should ensure that nobody's water "runs dry." 9/04.02.01 DOE should take a look at the city of Phoenix's model of water usage. 10/04.02.01 DOE should include in the Final PEIS the number of gallons of wastewater available for the tritium facility. 11/04.02.01 DOE should answer the following question in the Final PEIS: would the aquifer drawdown be zero or negligible if wastewater were used for the tritium facility? 12/02.01 In the Final PEIS, DOE should clearly indicate that additional water will be needed due to increased electrical demand (including the amount of water a new power plant would consume). In general, DOE should include directly in its environmental section the environmental effects from increased electrical consumption or a new power plant. 13/04.02.10 DOE has overstated by 50 percent the water requirement for the natural-gas-fired power plant. 14/04.02.02 DOE should consider the increased water consumption resulting from the construction and operation of the facility itself. 15/10.03 DOE should be alarmed by the massive increase in LLW generation (from 25 yd3 per year to 15,980 yd3 for HWR). How many additional shipments will this require and is there enough room for this amount? 16/18.09 The pertinent facts seem to be obscured from the public. How many weapons and how much tritium are actually needed? The public should be aware of the actual numbers. More analysis should be performed on actual tritium and weapons needs. In particular, further reductions could be made, thus eliminating the need for a new facility. 2-32 17/13.00.15 Even if START II levels were cut by 50 percent, a need for tritium would still exist. A plan to meet that need would still be necessary. 18/13.08.01 Public support (as shown in various polls) is over 80 percent for the missions and activities at Pantex. 19/18.01 In the Nuclear Nonproliferation Treaty the United States made a commitment to reduce its stockpile and eventually eliminate all of its nuclear weapons. If the United States proceeds with this project, the wrong message will be sent to the other nations that are parties to the treaty. Based on our inconsistent action, they may decide to renege on their commitments as well. The United States should pursue a nuclear weapons policy that is consistent with the Nuclear Nonproliferation Treaty. 20/11.00.24 The risk assessments from exposure to hazardous chemicals at Pantex are incorrect. Refer to volume II, table E.3.428. The 0.01 number for total cancer risk is incorrect. DOE should check all the numbers in this table and make sure they performed the correct analysis. 21/02.05 A more detailed examination of the proposed transmission line for the tritium facility is necessary and should be included in the Final PEIS. For example, what route will the line take into Pantex? Will it be underground or above ground? Will it disturb anything? How much will it cost? 22/13.06.04 In the chemical inventory section for the proposed sites, the PEIS lists no chemicals for NTS. NTS must use some chemicals during its operations. DOE should check into this matter further. 23/13.00.15 Future tritium and weapons needs are based on the START II treaty. It is obvious from that treaty that we must begin the planning and implementation stages for the tritium facility now if we wish to meet those needs. 24/13.08.03 Certain people are using fear tactics in their campaign for the tritium facility. They claim that the Pantex area will suffer economic devastation if the tritium supply and recycling or plutonium disposition projects do not come here. This fear mongering is inappropriate. Pantex is ridiculed across the country for welcoming these projects and yet it continues to encourage them. The many negative effects from the tritium supply and recycling facility should be fully acknowledged by these people, especially the drawdown of the aquifer. 25/13.08.01 The business community in the Pantex area certainly does not feel ridiculed and does not believe that the presence of the Pantex site is a disincentive for business in general. The business community is in favor of more work at Pantex. 26/10.10 The additional solid waste from the new facility would not have a substantial impact on the landfill in Amarillo. It is but a small fraction of current capacity. The fact that the landfill's design life would be reduced should not be seen as a negative. 27/10.29 DOE should look at the effects and costs of a pipeline that would carry wastewater from an off- site treatment plant to the new tritium supply and recycling facility. If DOE considers using wastewater a viable alternative, it must also consider the effects of implementing that alternative. 28/13.04.10 The APT worker numbers (for construction and operation) are the lowest among the technologies. It seems, however, that the costs related to these workers may be on the low side. 2-33 SECOND AFTERNOON SESSION-ENVIRONMENTAL EFFECTS 1/07.02 A more evenhanded and consistent analysis of cultural and biotic resources in the executive summary and the PEIS is needed. There are subtle discrepancies in the analysis between the sites, and Pantex is unfairly penalized due to the use of biased language. DOE should check these sections for unnecessary bias and use consistent terminology and language. 2/06.02 The executive summary indicates the bald eagle could lose nesting habitat. This is not accurate and should be changed in the Final PEIS. 3/02.01 Although the increase in electrical demand may not have a substantial effect on the local or regional power pool capacity margin, it will have a substantial effect on the environment and on the cost of each technology. These effects should not be de-emphasized just because they are secondary effects from a power facility that will be used to support the tritium supply and recycling facility. They should be seen as direct effects. 4/02.02 DOE should consider alternative energy sources (wind and solar) for the additional power that is required for the tritium supply and recycling technologies. 5/13.00.42 DOE should consider using the coolant (water) from the tritium supply and recycling facility in the steam generation plant at Pantex. This could potentially save fuel. 6/04.02.01 DOE should consider using closed loop cooling for the target end of the APT. This would conserve much water. 7/04.02.05 The playas are referred to as dry lakes in the PEIS and yet they may be recharge areas for the aquifer. High explosives and nitrates have been found in the aquifer, indicating that this may indeed be the case. (Another person disagreed with this and said that the playas are not recharge areas.) DOE should investigate the connection between the playas and the aquifer. 8/04.02.07 In the PEIS, aquifer water levels should be shown as depths, not only as elevations. 9/04.02.01 The PEIS exhibits a bias against Pantex in the water resources section. It mentions that drawdowns would adversely affect the aquifer, but fails to mention that wastewater discharges could possibly recharge the aquifer. The PEIS should discuss this potential benefit. 10/04.02.05 Wastewater discharges into the playas are portrayed as degradations in the PEIS, but they may actually sustain species and play a beneficial role. Some of the play as may not exist at all if it weren't for the wastewater discharges. 11 No comment identified. 12/08.11 It appears that DOE has used the wrong economic multiplier on their overheads. The PEIS should be checked for this mistake as well. 13/08.03 In its economic analysis, DOE should consider jobs that will be created at facilities which will support the planning and engineering studies necessary for the tritium supply and recycling facility (for example Los Alamos). 2-34 14/08.03 DOE should consider the transportation, electrical, water, and other environmental impacts from out-of-region people who come to work at Pantex and live in the area. 15/08.03 It is possible that workers may be brought in from other areas (not those immediately surrounding Pantex). Too many out of region workers could actually deflate the economy. DOE should, for each site, compare the need for skilled workers created by the new facility with the pool of skilled workers in the surrounding area. 16/08.03 The Tritium Supply and Recycling Program could spawn new production or fabrication facilities that would support the tritium supply and recycling facility and its operation. DOE should include this in the PEIS. 17/11.00.12 In addition to the cancerous effects of the new facility, there are also noncarcinogenic impacts. These include genetic, chemical, and toxic health effects. The PEIS should include an analysis of these as well. 18/11.00.12 The proximity of current and future schools and housing projects to the new facility should be fully analyzed in the PEIS. The commentor is specifically concerned about radiological risks to school and housing posed by the tritium supply and recycling facility. 19/11.00.10 DOE should take into consideration the fact that, in general, construction and operation workers are healthier than the general population. This fact may influence the conclusions of the human health section. 20/12.07 In the Final PEIS, DOE should include a description of the old tritium facility, its current and planned disposition, the wastes it generated, and a comparison between the old and new tritium facilities. This may help DOE learn from past mistakes and educate the public as to what can be expected from the new facility. 21/16.12 A D&D comparison (including financial costs) between technologies should be included in the Final PEIS. 22/01.02 It is seems that Site C and the area proposed for the tritium facility may infringe on land that was leased from Texas Technological University. DOE should consider any complications this may present. 23/15.07 DOE should tailor the comment response document so that people can track their own comments. This would allow people to see how and if their comments affected the PEIS. 24/04.02.07 DOE should ensure that an adequate number of drawing sites (for the groundwater) is available on site. 25/06.17 A more evenhanded and consistent analysis of biotic resources in the executive summary and the PEIS is needed. There are subtle discrepancies in the analysis between the sites, and Pantex is unfairly penalized due to the use of biased language. DOE should check these sections for unnecessary bias and use consistent terminology and language. 2-35 FIRST AFTERNOON SESSION-PROJECT DESCRIPTION 1/15.01 Would like to have "formal" comment sessions (traditional hearing format) in addition to this new meeting format. 2/15.07 Would like to see the PEIS be formatted to allow public commentors to easily identify DOEs responses to comments. 3/13.04.17 Supports current design to leave enough "space" (land) for expansion of the accelerator (if needed). This would enable additional tritium production for defense or commercial purposes. 4/13.00.05 Supports the reactor design because of its ability to be a power source; additional electricity is greatly needed in this area (Amarillo community). 5/10.26 Would like to see the PEIS further break down waste numbers for each technology. 6/13.04.01 Supports the accelerator design. 7/14.01 Should delay this decision on a tritium production facility to allow other EISs to reach the same stage. At that point, decisions should be made reflecting an integrated approach to all EISs. 8/14.01 If a ROD is made for tritium, then subsequent EISs should also reflect this decision. 9/04.02.01 Believes that there are alternatives besides "dry cooling" for Pantex. Supports the possibility of using treated city sewage water for cooling. The community is greatly concerned about groundwater, especially at the Pantex Plant; recycling of sewage wastewater would be a great source of water and would help preserve the aquifer. 10/10.03 Would like to see PEIS figures for wastes broken down by type, volumes, disposal methods, and costs. 11/04.02.01 There are "one-pass" technologies that use one-seventh the amount of water specified in the PEIS. 12/18.01 DOE should postpone this decision for tritium and wait until policies that are up for reevaluation (e.g. nonproliferation) are decided. The results of negotiation could significantly reduce the tritium requirement, and thus eliminate a need for a production facility. Would also like to see a good faith effort to bargain with other nuclear producing countries for tritium. SECOND AFTERNOON SESSION-PROJECT DESCRIPTION 1/04.02.01 Would like to see water recycled from sewage waste water be a part of environmental analysis. This option may give Pantex an extra advantage over its current analysis that water withdrawals would adversely affect ground water. 2/04.02.02 If groundwater is considered for use in NTS, then it may be a concern. 3/04.02.07 Would like to have documentation for reasoning behind numbers in PEIS, specifically groundwater numbers. 2-36 4/13.08.01 Local community is 80 percent in support of Pantex's programs and missions. 5/13.08.01 Would like to have tritium supply facility at Pantex because weapons are already assembled/disassembled there. Collocation would eliminate the need for transportation of any nuclear materials or wastes across state lines. 6/14.01 Would like to see consistency among PEISs. All EISs should have same assumptions. Decisions should also be coordinated. FIRST EVENING SESSION-ENVIRONMENTAL EFFECTS 1/05.01 DOE should ensure that no capable faults exist within the surrounding area. 2/13.00.05 DOE should sell or make good use of the electricity generated by some of the technologies. There is no good reason why DOE should waste this resource or reject its creation. 3/13.04.05 DOE should consider using the APT at night or during off-peak hours. This would save money and decrease peak usage. 4/04.02.01 The cooling mechanism for the APT could be closed loop. It is theoretically possible. There is no reason DOE could not employ this cooling technique on the APT. DOE should not dismiss this possibility out of hand. A great amount of water would be saved. 5/04.02.01 Dry years (years of light precipitation) are causing more drawdown than DOE indicates. DOE should be more concerned about drawdown effects. DOE should study the high plains area and the method of wastewater recharge that is being used there. 6/10.02 DOE should be concerned about polluting the playas with wastewater. 7/04.02.07 DOE should indicate where the drawdown is measured from. Is it one mile from the facility? Closer? Farther? There may be areas of greater drawdown that DOE has not observed. 8/04.02.02 Forty-three inches of aquifer drawdown is outrageous. The community will not stand for this. Farmers need this water more than DOE does. 9/04.02.01 Wastewater discharge from the Hollywood plant could negate the drawdown effect. 10/13.04.09 DOE should look at the evaporation generated by the APT's cooling system and any environmental effects associated with this evaporation. 11/13.00.38 DOE should look at the environmental effects resulting from the reactors' radiative cooling mechanism. 12/04.02.01 Using wastewater for cooling purposes should be seen as an alternative, not as a mitigation technique. It should be included as one of the options for cooling the tritium supply and recycling facility. 13/04.02.01 The water resources section in the executive summary (ES-31) unfairly favors the other sites. It notes that "drawdowns would adversely affect aquifer water levels" at the Pantex site. It does 2-37 not include an explanation for why this is so. DOE should add that the recharge rate for the Ogallala aquifer is smaller than the other sites' recharge rates. 14/04.02.01 The wastewater alternative and its potential should be shown simultaneously with the groundwater usage data and the corresponding drawdowns. Currently, the PEIS misleads the decision makers by showing them only one alternative (groundwater) for cooling purposes. There are, in fact, two power plants in the area which use wastewater as a coolant. 15/04.02.01 The water resources section has not been presented fairly for Pantex. The section lacks a discussion of other, viable alternatives for the tritium supply and recycling facility. This discussion would include using wastewaster and closed loop cooling (fully or partially). 16/04.02.01 DOE should take a look at the red bed drilling and pumping that are in process in and around Pantex. This type of drilling allows for the occurrence of drawdowns even when the tritium supply and recycling facility is not pumping. The red bed is the layer of rock beneath the Ogallala aquifer. 17/04.02.02 The water consumption rate for the tritium supply and recycling facility exceeds the recharge rate of the aquifer. DOE should be concerned about the needs of farmers in the area. It is a bad idea to use more groundwater. 18/03.01 DOE should be concerned about increased pollution levels and the effect these could have on visibility and air quality. 19/03.01 The pollution numbers should include pollutants from the additional power plant that may be needed (or additional pollutants from an increased electrical load). 20/02.01 DOE should include the size (physical and electrical) of the additional power plant that may be needed. 21/09.06 DOE uses inconsistent terminology in the intersite transport section of the executive summary. The wording of the "relative transportation risk of tritium" paragraphs should be changed to make this section consistent. SECOND EVENING SESSION - ENVIRONMENTAL EFFECTS 1/04.02.01 DOE should consider injecting treated wastewater into the aquifer. This would help balance the aquifer level. 2/04.02.01 The Hollywood Wastewater Plant and the Treatment Plant at Pantex could provide enough water for the APT. No groundwater would be used. DOE should seriously consider this. 3/08.05 The business community in Amarillo welcomes this project and the jobs that would come with it. The jobs would be filled by people from the community. Public approval of Pantex and its missions is over 80 percent. 4/10.03 DOE is using the wrong LLW figures in its "waste management" overhead. 2-38 5/16.12 DOE should include D&D environmental effects and financial costs in its environmental effects section. These effects and costs should not be shown in a later section. They should be shown up front. 6/16.12 The public should receive the cost studies and analysis with plenty of time for review before a decision is made. 7/22.02 DOE should revisit its nonproliferation policy regarding commercial and defense uses of nuclear energy. DOE should be able to produce and sell electricity from a facility whose primary mission is defense related. 8/02.04 There are cost and energy advantages associated with running the APT during off-peak hours. DOE should give this serious consideration. First Evening Session-Project Description 1/16.07 Would like to see maintenance and operation costs of different technologies in PEIS. This would be helpful in the decision making process. 2/13.04.17 Would like to see the possibility of a modular accelerator design. Would like to see it used for other purposes such as civilian research. 3/14.01 Would like to see all three EISs evaluated together, especially with regard to costs. For example, it makes sense to simultaneously evaluate the triple-play reactor, being considered in this EIS, and the Fissile Material Disposition EIS. 4/20.04 Supports DOE policy of not redesigning weapons to use less or no tritium. 5/16.03 Would like to have DOE work more closely with contractors in preparing EISs; would like to see more continuous involvement. It would eliminate the problem of contractors initially providing data and then having to take time to explain the data when the EIS, such as this draft, is produced. 6/15.01 Supports new meeting format. Second Evening Session-Project Description 1/10.09 DOE should not consider spent fuel as an asset. 2/10.02 Concerned about high level wastes from reprocessing and for storage. 3/13.04.17 PEIS should evaluate closed loop cooling as an option for accelerator technology. It could be done with engineering work. 4/12.04 When evaluating current designs, PEIS should consider terrorist attacks, i.e. aircraft attacks or trucks with weapons. 5/15.01 Supports this new meeting format. 6/13.04.17 In addition to main mission of tritium production, would like to see accelerator design, if implemented, be used for other purposes such as research or production of short-lived medical isotopes. 2-39 COMMENT LETTERS TSR-E-001 Figure (Page 2-40) TSR-E-002 Figure (Page 2-40) TSR-F-001 Figure (Page 2-41) TSR-F-002 Figure (Page 2-41) TSR-F-003 Figure (Page 2-42) TSR-F-004 Figure (Page 2-42) TSR-F-005 Figure (Page 2-43) TSR-F-006 Figure (Page 2-43) TSR-F-008 Figure (Page 2-44) TSR-F-009 Figure (Page 2-44) TSR-F-010 Figure (Page 2-45) TSR-F-012 Figure (Page 2-45) TSR-F-013 Figure (Page 2-46) TSR-F-014 Figure (Page 2-46) Figure (Page 2-47) TSR-F-016 Figure (Page 2-47) Figure (Page 2-48) Figure (Page 2-48) TSR-F-017 Figure (Page 2-49) Figure (Page 2-49) Figure (Page 2-50) Figure (Page 2-50) TSR-F-018 Figure (Page 2-51) TSR-F-019 Figure (Page 2-51) TSR-F-020 Figure (Page 2-52) TSR-F-021 Figure (Page 2-52) Figure (Page 2-53) TSR-F-022 Figure (Page 2-53) TSR-F-022 Figure (Page 2-54) TSR-F-024 Figure (Page 2-54) TSR-F-027 Figure (Page 2-55) TSR-F-029 Figure (Page 2-55) Figure (Page 2-56) Figure (Page 2-56) TSR-F-030 Figure (Page 2-57) Figure (Page 2-57) TSR-F-031 Figure (Page 2-58) TSR-F-032 Figure (Page 2-58) Figure (Page 2-59) Figure (Page 2-59) Figure (Page 2-60) Figure (Page 2-60) Figure (Page 2-61) Figure (Page 2-61) Figure (Page 2-62) Figure (Page 2-62) Figure (Page 2-63) Figure (Page 2-63) Figure (Page 2-64) Figure (Page 2-64) Figure (Page 2-65) Figure (Page 2-65) Figure (Page 2-66) TSR-F-033 Figure (Page 2-66) Figure (Page 2-67) Figure (Page 2-67) TSR-F-034 Figure (Page 2-68) TSR-F-035 Figure (Page 2-68) TSR-F-036 Figure (Page 2-69) Figure (Page 2-69) Figure (Page 2-70) Figure (Page 2-70) Figure (Page 2-71) Figure (Page 2-71) Figure (Page 2-72) Figure (Page 2-72) Figure (Page 2-73) Figure (Page 2-73) Figure (Page 2-74) Figure (Page 2-74) Figure (Page 2-75) Figure (Page 2-75) Figure (Page 2-76) Figure (Page 2-76) Figure (Page 2-77) Figure (Page 2-77) Figure (Page 2-78) Figure (Page 2-78) Figure (Page 2-79) Figure (Page 2-79) Figure (Page 2-80) Figure (Page 2-80) Figure (Page 2-81) Figure (Page 2-81) Figure (Page 2-82) Figure (Page 2-82) Figure (Page 2-83) Figure (Page 2-83) TSR-F-037 Figure (Page 2-84) Figure (Page 2-84) Figure (Page 2-85) Figure (Page 2-85) Figure (Page 2-86) Figure (Page 2-86) Figure (Page 2-87) Figure (Page 2-87) Figure (Page 2-88) Figure (Page 2-88) Figure (Page 2-89) Figure (Page 2-89) Figure (Page 2-90) Figure (Page 2-90) Figure (Page 2-91) Figure (Page 2-91) Figure (Page 2-92) Figure (Page 2-92) Figure (Page 2-93) Figure (Page 2-93) Figure (Page 2-94) Figure (Page 2-94) TSR-F-038 Figure (Page 2-95) Figure (Page 2-95) TSR-F-040 Figure (Page 2-96) TSR-F-041 Figure (Page 2-96) Figure (Page 2-97) TSR-F-043 Figure (Page 2-97) TSR-F-046 Figure (Page 2-98) Figure (Page 2-98) Figure (Page 2-99) Figure (Page 2-99) Figure (Page 2-100) Figure (Page 2-100) Figure (Page 2-101) TSR-F-047 Figure (Page 2-101) Figure (Page 2-102) TSR-F-048 Figure (Page 2-102) Figure (Page 2-103) Figure (Page 2-103) TSR-F-049 Figure (Page 2-104) Figure (Page 2-104) Figure (Page 2-105) Figure (Page 2-105) Figure (Page 2-106) Figure (Page 2-106) Figure (Page 2-107) Figure (Page 2-107) Figure (Page 2-108) TSR-F-050 Figure (Page 2-108) TSR-H-001 Figure (Page 2-109) TSR-H-002 Figure (Page 2-109) TSR-H-003 Figure (Page 2-110) TSR-H-004 Figure (Page 2-110) TSR-H-005 Figure (Page 2-111) TSR-H-006 Figure (Page 2-111) Figure (Page 2-112) TSR-H-007 Figure (Page 2-112) TSR-H-008 Figure (Page 2-113) Figure (Page 2-113) TSR-H-009 Figure (Page 2-114) TSR-H-010 Figure (Page 2-114) TSR-H-011 Figure (Page 2-115) Figure (Page 2-115) TSR-H-012 Figure (Page 2-116) TSR-H-013 Figure (Page 2-116) TSR-H-014 Figure (Page 2-117) TSR-H-015 Figure (Page 2-117) TSR-H-016 Figure (Page 2-118) TSR-H-017 Figure (Page 2-118) TSR-H-018 Figure (Page 2-119) TSR-H-019 Figure (Page 2-119) Figure (Page 2-120) TSR-H-020 Figure (Page 2-120) Figure (Page 2-121) TSR-H-021 Figure (Page 2-121) TSR-H-022 Figure (Page 2-122) TSR-H-023 Figure (Page 2-122) TSR-H-024 Figure (Page 2-123) Figure (Page 2-123) TSR-H-025 Figure (Page 2-124) TSR-H-026 Figure (Page 2-124) Figure (Page 2-125) Figure (Page 2-125) TSR-H-027 Figure (Page 2-126) Figure (Page 2-126) TSR-H-028 Figure (Page 2-127) TSR-H-029 Figure (Page 2-127) Figure (Page 2-128) TSR-H-030 Figure (Page 2-128) Figure (Page 2-129) TSR-H-031 Figure (Page 2-129) TSR-H-032 Figure (Page 2-130) TSR-H-034 Figure (Page 2-130) TSR-H-035 Figure (Page 2-131) TSR-H-036 Figure (Page 2-131) TSR-H-038 Figure (Page 2-132) TSR-H-039 Figure (Page 2-132) TSR-H-040 Figure (Page 2-133) Figure (Page 2-133) Figure (Page 2-134) TSR-H-041 Figure (Page 2-134) TSR-H-042 Figure (Page 2-135) TSR-H-043 Figure (Page 2-135) TSR-M-001 Figure (Page 2-136) TSR-M-002 Figure (Page 2-136) TSR-M-004 Figure (Page 2-137) TSR-M-005 Figure (Page 2-137) TSR-M-006 Figure (Page 2-138) TSR-M-008 Figure (Page 2-138) TSR-M-009 Figure (Page 2-139) TSR-M-010 Figure (Page 2-139) Figure (Page 2-140) Figure (Page 2-140) TSR-M-011 Figure (Page 2-141) TSR-M-012 Figure (Page 2-141) TSR-M-013 Figure (Page 2-142) TSR-M-014 Figure (Page 2-142) TSR-M-015 Figure (Page 2-143) Figure (Page 2-143) Figure (Page 2-144) TSR-M-016 Figure (Page 2-144) Figure (Page 2-145) TSR-M-017 Figure (Page 2-145) TSR-M-019 Figure (Page 2-146) TSR-M-020 Figure (Page 2-146) TSR-M-021 Figure (Page 2-147) TSR-M-022 Figure (Page 2-147) TSR-M-023 Figure (Page 2-148) Figure (Page 2-148) Figure (Page 2-149) Figure (Page 2-149) TSR-M-024 Figure (Page 2-150) TSR-M-025 Figure (Page 2-150) Figure (Page 2-151) Figure (Page 2-151) Figure (Page 2-152) Figure (Page 2-152) TSR-M-026 Figure (Page 2-153) TSR-M-027 Figure (Page 2-153) TSR-M-028 Figure (Page 2-154) TSR-M-029 Figure (Page 2-154) TSR-M-030 Figure (Page 2-155) TSR-M-031 Figure (Page 2-155) Figure (Page 2-156) TSR-M-032 Figure (Page 2-156) TSR-M-033 Figure (Page 2-157) TSR-M-034 Figure (Page 2-157) TSR-M-035 Figure (Page 2-158) TSR-M-036 Figure (Page 2-158) TSR-M-037 Figure (Page 2-159) TSR-M-038 Figure (Page 2-159) TSR-M-039 Figure (Page 2-160) TSR-M-040 Figure (Page 2-160) TSR-M-041 Figure (Page 2-161) TSR-M-042 Figure (Page 2-161) TSR-M-043 Figure (Page 2-162) TSR-M-044 Figure (Page 2-162) Figure (Page 2-163) TSR-M-045 Figure (Page 2-163) TSR-M-046 Figure (Page 2-164) TSR-M-047 Figure (Page 2-164) TSR-M-048 Figure (Page 2-165) TSR-M-049 Figure (Page 2-165) Figure (Page 2-166) TSR-M-050 Figure (Page 2-166) Figure (Page 2-167) TSR-M-051 Figure (Page 2-167) Figure (Page 2-168) TSR-M-052 Figure (Page 2-168) Figure (Page 2-169) TSR-M-053 Figure (Page 2-169) TSR-M-055 Figure (Page 2-170) TSR-M-056 Figure (Page 2-170) Figure (Page 2-171) TSR-M-057 Figure (Page 2-171) TSR-M-059 Figure (Page 2-172) TSR-M-060 Figure (Page 2-172) TSR-M-061 Figure (Page 2-173) TSR-M-062 Figure (Page 2-173) TSR-M-063 Figure (Page 2-174) TSR-M-064 Figure (Page 2-174) Figure (Page 2-175) Figure (Page 2-175) Figure (Page 2-176) Figure (Page 2-176) Figure (Page 2-177) Figure (Page 2-177) Figure (Page 2-178) Figure (Page 2-178) Figure (Page 2-179) Figure (Page 2-179) TSR-M-065 Figure (Page 2-180) Figure (Page 2-180) TSR-M-066 Figure (Page 2-181) TSR-M-068 Figure (Page 2-181) Figure (Page 2-182) TSR-M-069 Figure (Page 2-182) TSR-M-070 Figure (Page 2-183) TSR-M-071 Figure (Page 2-183) TSR-M-072 Figure (Page 2-184) Figure (Page 2-184) TSR-M-073 Figure (Page 2-185) TSR-M-075 Figure (Page 2-185) TSR-M-076 Figure (Page 2-186) TSR-M-077 Figure (Page 2-186) TSR-M-078 Figure (Page 2-187) TSR-M-079 Figure (Page 2-187) TSR-M-080 Figure (Page 2-188) TSR-M-082 Figure (Page 2-188) TSR-M-083 Figure (Page 2-189) TSR-M-084 Figure (Page 2-189) Figure (Page 2-190) Figure (Page 2-190) Figure (Page 2-191) TSR-M-085 Figure (Page 2-191) TSR-M-086 Figure (Page 2-192) TSR-M-087 Figure (Page 2-192) Figure (Page 2-193) TSR-M-088 Figure (Page 2-193) TSR-M-090 Figure (Page 2-194) TSR-M-091 Figure (Page 2-194) Figure (Page 2-195) Figure (Page 2-195) Figure (Page 2-196) Figure (Page 2-196) Figure (Page 2-197) Figure (Page 2-197) TSR-M-092 Figure (Page 2-198) Figure (Page 2-198) TSR-M-093 Figure (Page 2-199) Figure (Page 2-199) Figure (Page 2-200) Figure (Page 2-200) Figure (Page 2-201) Figure (Page 2-201) Figure (Page 2-202) Figure (Page 2-202) Figure (Page 2-203) Figure (Page 2-203) Figure (Page 2-204) Figure (Page 2-204) Figure (Page 2-205) Figure (Page 2-205) TSR-M-094 Figure (Page 2-206) TSR-M-095 Figure (Page 2-206) TSR-M-096 Figure (Page 2-207) Figure (Page 2-207) TSR-M-097 Figure (Page 2-208) TSR-M-098 Figure (Page 2-208) Figure (Page 2-209) TSR-M-099 Figure (Page 2-209) Figure (Page 2-210) TSR-M-100 Figure (Page 2-210) TSR-M-101 Figure (Page 2-211) TSR-M-102 Figure (Page 2-211) Figure (Page 2-212) Figure (Page 2-212) TSR-M-103 Figure (Page 2-213) TSR-M-104 Figure (Page 2-213) TSR-M-105 Figure (Page 2-214) TSR-M-106 Figure (Page 2-214) TSR-M-107 Figure (Page 2-215) TSR-M-108 Figure (Page 2-215) TSR-M-109 Figure (Page 2-216) TSR-M-110 Figure (Page 2-216) TSR-M-111 Figure (Page 2-217) TSR-M-112 Figure (Page 2-217) Figure (Page 2-218) Figure (Page 2-218) Figure (Page 2-219) Figure (Page 2-219) Figure (Page 2-220) Figure (Page 2-220) Figure (Page 2-221) Figure (Page 2-221) Figure (Page 2-222) Figure (Page 2-222) Figure (Page 2-223) Figure (Page 2-223) Figure (Page 2-224) Figure (Page 2-224) Figure (Page 2-225) Figure (Page 2-225) Figure (Page 2-226) Figure (Page 2-226) Figure (Page 2-227) Figure (Page 2-227) Figure (Page 2-228) Figure (Page 2-228) Figure (Page 2-229) Figure (Page 2-229) Figure (Page 2-230) Figure (Page 2-230) Figure (Page 2-231) Figure (Page 2-231) TSR-M-115 Figure (Page 2-232) TSR-M-116 Figure (Page 2-232) Figure (Page 2-233) TSR-M-117 Figure (Page 2-233) Figure (Page 2-234) TSR-M-118 Figure (Page 2-234) TSR-M-119 Figure (Page 2-235) Figure (Page 2-235) TSR-M-120 Figure (Page 2-236) Figure (Page 2-236) Figure (Page 2-237) Figure (Page 2-237) TSR-M-122 Figure (Page 2-238) TSR-M-123 Figure (Page 2-238) TSR-M-124 Figure (Page 2-239) TSR-M-127 Figure (Page 2-239) TSR-M-128 Figure (Page 2-240) TSR-M-129 Figure (Page 2-240) Figure (Page 2-241) Figure (Page 2-241) Figure (Page 2-242) Figure (Page 2-242) Figure (Page 2-243) Figure (Page 2-243) Figure (Page 2-244) Figure (Page 2-244) Figure (Page 2-245) Figure (Page 2-245) Figure (Page 2-246) Figure (Page 2-246) Figure (Page 2-247) Figure (Page 2-247) Figure (Page 2-248) Figure (Page 2-248) Figure (Page 2-249) Figure (Page 2-249) Figure (Page 2-250) Figure (Page 2-250) Figure (Page 2-251) Figure (Page 2-251) Figure (Page 2-252) TSR-M-131 Figure (Page 2-252) TSR-M-132 Figure (Page 2-253) TSR-M-133 Figure (Page 2-253) Figure (Page 2-254) Figure (Page 2-254) TSR-M-134 Figure (Page 2-255) Figure (Page 2-255) Figure (Page 2-256) TSR-M-135 Figure (Page 2-256) TSR-M-136 Figure (Page 2-257) Figure (Page 2-257) TSR-M-137 Figure (Page 2-258) Figure (Page 2-258) TSR-M-138 Figure (Page 2-259) Figure (Page 2-259) Figure (Page 2-260) TSR-M-139 Figure (Page 2-260) Figure (Page 2-261) Figure (Page 2-261) TSR-M-140 Figure (Page 2-262) Figure (Page 2-262) TSR-M-141 Figure (Page 2-263) TSR-M-142 Figure (Page 2-263) Figure (Page 2-264) Figure (Page 2-264) Figure (Page 2-265) Figure (Page 2-265) Figure (Page 2-266) Figure (Page 2-266) Figure (Page 2-267) Figure (Page 2-267) Figure (Page 2-268) TSR-M-143 Figure (Page 2-268) TSR-M-144 Figure (Page 2-269) Figure (Page 2-269) TSR-M-145 Figure (Page 2-270) TSR-M-147 Figure (Page 2-270) TSR-M-148 Figure (Page 2-271) Figure (Page 2-271) TSR-M-149 Figure (Page 2-272) Figure (Page 2-272) TSR-M-150 Figure (Page 2-273) TSR-M-151 Figure (Page 2-273) TSR-M-152 Figure (Page 2-274) TSR-M-153 Figure (Page 2-274) TSR-M-154 Figure (Page 2-275) Figure (Page 2-275) Figure (Page 2-276) Figure (Page 2-276) Figure (Page 2-277) TSR-M-156 Figure (Page 2-277) TSR-M-159 Figure (Page 2-278) TSR-M-160 Figure (Page 2-278) TSR-M-162 Figure (Page 2-279) TSR-M-163 Figure (Page 2-279) TSR-M-164 Figure (Page 2-280) TSR-M-165 Figure (Page 2-280) Figure (Page 2-281) Figure (Page 2-281) Figure (Page 2-282) TSR-M-166 Figure (Page 2-282) Figure (Page 2-283) Figure (Page 2-283) Figure (Page 2-284) TSR-M-167 Figure (Page 2-284) Figure (Page 2-285) Figure (Page 2-285) Figure (Page 2-286) Figure (Page 2-286) Figure (Page 2-287) Figure (Page 2-287) Figure (Page 2-288) Figure (Page 2-288) Figure (Page 2-289) Figure (Page 2-289) Figure (Page 2-290) TSR-M-168 Figure (Page 2-290) Figure (Page 2-291) TSR-M-169 Figure (Page 2-291) TSR-M-170 Figure (Page 2-292) Figure (Page 2-292) Figure (Page 2-293) Figure (Page 2-293) Figure (Page 2-294) Figure (Page 2-294) TSR-M-171 Figure (Page 2-295) TSR-M-172 Figure (Page 2-295) Figure (Page 2-296) Figure (Page 2-296) Figure (Page 2-297) Figure (Page 2-297) Figure (Page 2-298) Figure (Page 2-298) Figure (Page 2-299) TSR-M-175 Figure (Page 2-299) Figure (Page 2-300) Figure (Page 2-300) TSR-M-176 Figure (Page 2-301) TSR-M-177 Figure (Page 2-301) TSR-M-178 Figure (Page 2-302) TSR-M-179 Figure (Page 2-302) TSR-M-180 Figure (Page 2-303) TSR-M-181 Figure (Page 2-303) TSR-M-182 Figure (Page 2-304) TSR-M-183 Figure (Page 2-304) Figure (Page 2-305) TSR-M-185 Figure (Page 2-305) Figure (Page 2-306) TSR-M-186 Figure (Page 2-306) Figure (Page 2-307) TSR-M-187 Figure (Page 2-307) Figure (Page 2-308) Figure (Page 2-308) TSR-M-189 Figure (Page 2-309) TSR-P-001 Figure (Page 2-309) TSR-P-002 Figure (Page 2-310) TSR-P-003 Figure (Page 2-310) TSR-P-004 Figure (Page 2-311) TSR-P-005 Figure (Page 2-311) TSR-P-006 Figure (Page 2-312) TSR-P-007 Figure (Page 2-312) TSR-P-008 Figure (Page 2-313) TSR-P-009 Figure (Page 2-313) Figure (Page 2-314) TSR-P-010 Figure (Page 2-314) Figure (Page 2-315) TSR-P-011 Figure (Page 2-315) Figure (Page 2-316) TSR-P-012 Figure (Page 2-316) TSR-P-013 Figure (Page 2-317) TSR-P-015 Figure (Page 2-317) TSR-P-016 Figure (Page 2-318) TSR-P-017 Figure (Page 2-318) TSR-P-018 Figure (Page 2-319) TSR-P-019 Figure (Page 2-319) TSR-P-020 Figure (Page 2-320) TSR-P-021 Figure (Page 2-320) TSR-P-022 Figure (Page 2-321) TSR-P-023 Figure (Page 2-321) TSR-P-024 Figure (Page 2-322) TSR-P-025 Figure (Page 2-322) TSR-P-026 Figure (Page 2-323) TSR-P-027 Figure (Page 2-323) TSR-P-028 Figure (Page 2-324) Figure (Page 2-324) TSR-P-029 Figure (Page 2-325) TSR-P-030 Figure (Page 2-325) TSR-P-031 Figure (Page 2-326) TSR-P-032 Figure (Page 2-326) TSR-P-033 Figure (Page 2-327) TSR-P-034 Figure (Page 2-327) TSR-P-035 Figure (Page 2-328) TSR-P-036 Figure (Page 2-328) TSR-P-037 Figure (Page 2-329) TSR-P-038 Figure (Page 2-329) TSR-P-039 Figure (Page 2-330) TSR-P-040 Figure (Page 2-330) TSR-P-041 Figure (Page 2-331) TSR-P-042 Figure (Page 2-331) TSR-P-043 Figure (Page 2-332) TSR-P-044 Figure (Page 2-332) TSR-P-045 Figure (Page 2-333) TSR-P-046 Figure (Page 2-333) TSR-P-047 Figure (Page 2-334) TSR-P-048 Figure (Page 2-334) TSR-P-050 Figure (Page 2-335) TSR-P-052 Figure (Page 2-335) TSR-P-053 Figure (Page 2-336) TSR-P-054 Figure (Page 2-336) TSR-P-055 Figure (Page 2-337) Figure (Page 2-337) Figure (Page 2-338) TSR-P-056 Figure (Page 2-338) TSR-P-057 Figure (Page 2-339) TSR-P-058 Figure (Page 2-339) TSR-P-059 Figure (Page 2-340) TSR-P-060 Figure (Page 2-340) TSR-P-061 Figure (Page 2-341) TSR-P-062 Figure (Page 2-341) TSR-P-063 Figure (Page 2-342) TSR-P-064 Figure (Page 2-342) TSR-P-065 Figure (Page 2-343) TSR-P-066 Figure (Page 2-343) TSR-P-067 Figure (Page 2-344) TSR-P-068 Figure (Page 2-344) TSR-P-069 Figure (Page 2-345) TSR-P-070 Figure (Page 2-345) TSR-P-071 Figure (Page 2-346) TSR-P-072 Figure (Page 2-346) TSR-P-073 Figure (Page 2-347) TSR-P-074 Figure (Page 2-347) TSR-P-075 Figure (Page 2-348) TSR-P-076 Figure (Page 2-348) TSR-P-077 Figure (Page 2-349) TSR-P-078 Figure (Page 2-349) Figure (Page 2-350) TSR-P-079 Figure (Page 2-350) TSR-P-080 Figure (Page 2-351) Figure (Page 2-351) Figure (Page 2-352) TSR-P-081 Figure (Page 2-352) Figure (Page 2-353) TSR-P-082 Figure (Page 2-353) TSR-P-083 Figure (Page 2-354) TSR-P-084 Figure (Page 2-354) Figure (Page 2-355) TSR-P-085 Figure (Page 2-355) TSR-P-086 Figure (Page 2-356) Figure (Page 2-356) TSR-P-087 Figure (Page 2-357) Figure (Page 2-357) TSR-P-088 Figure (Page 2-358) Figure (Page 2-358) Figure (Page 2-359) TSR-P-089 Figure (Page 2-359) Figure (Page 2-360) Figure (Page 2-360) TSR-P-090 Figure (Page 2-361) TSR-PC-002 Figure (Page 2-361) Figure (Page 2-362) Figure (Page 2-362) TSR-PC-003 Figure (Page 2-363) Figure (Page 2-363) Figure (Page 2-364) Figure (Page 2-364) Figure (Page 2-365) Figure (Page 2-365) Figure (Page 2-366) Figure (Page 2-366) TSR-PC-004 Figure (Page 2-367) TSR-PC-006 Figure (Page 2-367) Figure (Page 2-368) TSR-PC-008 Figure (Page 2-368) TSR-PC-011 Figure (Page 2-369) TSR-PC-012 Figure (Page 2-369) Figure (Page 2-370) TSR-NE-002 Figure (Page 2-370) TSR-NF-001 Figure (Page 2-371) TSR-NM-001 Figure (Page 2-371) TSR-NM-002 Figure (Page 2-372) TSR-NM-003 Figure (Page 2-372) TSR-NM-004 Figure (Page 2-373) TSR-NM-005 Figure (Page 2-373) TSR-NM-006 Figure (Page 2-374) TSR-NM-007 Figure (Page 2-374) TSR-NM-008 Figure (Page 2-375) TSR-NM-009 Figure (Page 2-375) Figure (Page 2-376) Figure (Page 2-376) TSR-NM-010 Figure (Page 2-377) TSR-NM-011 Figure (Page 2-377) TSR-NM-012 Figure (Page 2-378) Figure (Page 2-378) Figure (Page 2-379) Figure (Page 2-379) Figure (Page 2-380) TSR-NM-013 Figure (Page 2-380) Figure (Page 2-381) Figure (Page 2-381) TSR-NM-014 Figure (Page 2-382) Figure (Page 2-382) Figure (Page 2-383) Figure (Page 2-383) TSR-NM-015 Figure (Page 2-384) TSR-NM-016 Figure (Page 2-384) TSR-NM-017 Figure (Page 2-385) TSR-NM-018 Figure (Page 2-385) TSR-NM-019 Figure (Page 2-386) TSR-NM-020 Figure (Page 2-386) TSR-NM-021 Figure (Page 2-387) TSR-NM-022 Figure (Page 2-387) Figure (Page 2-388) TSR-NM-023 Figure (Page 2-388) Figure (Page 2-389) TSR-NM-025 Figure (Page 2-389) Figure (Page 2-390) Figure (Page 2-390) TSR-NM-026 Figure (Page 2-391) Figure (Page 2-391) TSR-NM-027 Figure (Page 2-392) Figure (Page 2-392) TSR-NM-028 Figure (Page 2-393) TSR-NM-029 Figure (Page 2-393) TSR-NM-030 Figure (Page 2-394) Figure (Page 2-394) Figure (Page 2-395) Figure (Page 2-395) Figure (Page 2-396) Figure (Page 2-396) Figure (Page 2-397) Figure (Page 2-397) Figure (Page 2-398) Figure (Page 2-398) Figure (Page 2-399) Figure (Page 2-399) Figure (Page 2-400) TSR-NM-032 Figure (Page 2-400) TSR-NM-033 Figure (Page 2-401) Figure (Page 2-401) Figure (Page 2-402) TSR-NM-034 Figure (Page 2-402) TSR-NM-035 Figure (Page 2-403) TSR-NM-037 Figure (Page 2-403) TSR-NM-040 Figure (Page 2-404)
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