Final Environmental Impact Statement for the Continued Operation of the Pantex Plant

CHAPTER 1 OVERVIEW

1.1 INTRODUCTION

In March 1996, the Department of Energy (Department or DOE) published the Draft Environmental Impact Statement for the Continued Operation of the Pantex Plant and Associated Storage of Nuclear Weapon Components. This draft environmental impact statement (EIS) examined the potential environmental impacts for three alternatives as described in chapter 3 of volume I. A Notice of Availability of the Draft EIS was published in the Federal Register (61 FR 15232) on April 5, 1996. The public comment period for the Draft EIS began on April 5, 1996, and was originally to end on July 5, 1996. However, at the request of stakeholders in the Amarillo area, the ending date was extended to July 12, 1996. The formal comment period thus ran for 98 days. DOE stated that any comments received after the end of the comment period would be incorporated to the extent practicable. Comments were accepted as late as July 29, 1996.

During the comment period, public hearings were held in Amarillo, Texas; North Las Vegas, Nevada; North Augusta, South Carolina; Albuquerque, New Mexico; and Richland, Washington. Each of these hearings was conducted in workshop format beginning with a presentation that provided an overview of the Draft EIS followed by opportunities for stakeholders to make comments or ask questions. In addition, a separate Technical Exchange Meeting was held in Amarillo with representatives of the State of Texas, City of Amarillo, Panhandle Water Conservation District No. 3, the University Consortium, the Amarillo Economic Development Corporation, and the Pantex Plant Citizens Advisory Board.

The workshop format of the meeting also allowed questions and comments from members of the public as well as the participants listed above. Verbatim comments were recorded at all meetings. In addition, the public was invited to submit comments via mail, toll-free facsimile, electronic mail (Internet), and toll-free telephone. If a comment was answered in the public hearing and needed no elaboration, it is not identified for a response in this EIS.

Attendance figures and transcript codes for each meeting are presented in Table 1.11. Attendance is only reported for those people who completed and returned registration forms and therefore may not include all those present at each meeting. The transcript codes correspond to the individual transcripts taken at each meeting. Those portions of the transcripts containing comments are presented in chapter 2 of this volume. Transcripts HT01 and HT02 contained continuous dialogues by individually identified commentors. Therefore, these two transcripts are sectioned by the associated individuals. The workshop format of the meetings made this too difficult to do with the other transcripts.

The National Environmental Policy Act (NEPA) requires Federal agencies to solicit comments on a Draft EIS from both government entities and the public, and to consider those comments in preparing the final version of the EIS. The purpose of this comment period is not to conduct a referendum on the eventual decision to be made by the Department, but to obtain input on the content of the EIS itself. As stated in the Council on Environmental Quality (CEQ) regulations for implementing NEPA, comments are to be as specific as possible and may address either the adequacy of the Draft EIS or the merits of the alternatives discussed or both (40 CFR 1503.3).

Frequently, during public comment periods, agencies receive statements of political viewpoints or personal feelings rather than comments specifically addressing the subjects of the EIS (i.e., descriptions of alternatives and the environmental analyses of the alternatives). While any citizen has the right to express his or her viewpoint, those expressions are useful in the NEPA process only to the extent that they focus on points that need to be clarified or revised in the final descriptions of alternatives or environmental impacts.

For clarity within the discussions that follow, statements collected during the comment period were identified as "comments" when they specifically relate to the discussions of the alternatives and environmental analyses within the EIS. The Departments responses to these comments are provided in this volume of the EIS. Conversely, general expressions of convictions, personal opinions, or support for or opposition to the continued operation of Pantex Plant are termed "remarks" and are acknowledged, but are not provided with individual responses in the EIS.

Transcripts were made at each public meeting. In addition, comments and remarks were received via mail, electronic mail (i.e., Internet), facsimile, and orally. All of these comments and remarks were recorded on paper and are hereafter referred to as comment documents, regardless of whether the content was in the form of comments or remarks. Each of the comment documents was date stamped and assigned a document number according to its origin (e.g., Federal Government; State Government; transcripts of public meetings; letters and cards from organizations or private citizens, etc.).

Each comment document was then reviewed and each individual comment was categorized into one of 24 comment categories (see Table 1.12). Each comment was assigned a sequential comment number and entered verbatim into the computerized Comment Management System.

Two letter campaigns and a postcard campaign occurred during the comment period. A campaign is characterized by multiple submissions from private citizens or organizations of identically or nearly identically worded comments or remarks. Comment documents CO-001, PC-031, and PC-032, in chapter 2 of this volume, are examples of these campaigns. See Table 1.13 for a listing of members of the public and organizations that participated in these campaigns. The statements within an example document for each campaign were analyzed, identified, and categorized in the same manner as those within the other comment documents.

Some of the campaign documents had one or more additional remarks besides those in the example documents or were altered in other ways. Each of these documents was reviewed via the process described above. In each of the campaign documents, the comments or remarks that were the same as those in the example document (of that campaign) were assigned the identical comment numbers as those in the example document. However, any unique comment received its own comment number. By this procedure, repetitive comments were addressed only once within this volume of the EIS. The major themes of the campaigns are summarized in the following paragraphs.

One of the letter campaigns involving 26 participants (see CO-001 for example) discussed issues or made statements mostly applicable to other NEPA documents, particularly the SSM PEIS and the S&D PEIS. Statements that pertained to this Pantex Plant EIS included perceived benefits resulting from current and proposed expansion of Pantex Plant operations, including the benefits to the Amarillo economy. This campaign emphasized that regardless of the levels of activity at Pantex Plant, DOE must continue to manage its facilities in a "safe and environmentally sound manner" in order to protect the public and the environment. The campaign stated that Pantex Plant had a historical record of safely managing hazardous materials, including "safehousing" 8,500 pits, and, therefore, urged DOE to consider Pantex Plant favorably in making decisions related to the two PEISs and the Pantex Plant EIS. The campaign also advocated Pantex Plant as a cost efficient alternative for current and future work. A listing of individuals who sent in this campaign letter is provided in Table 1.1-3.

Another letter campaign involving 59 participants (see PC-031 for example) listed five perceived inadequacies of the Draft EIS. These included perceived shortcomings in the amount of information provided in cumulative impacts analysis and insufficient discussion of water usage impacts, challenges to assumptions used in the aircraft overflight analysis, a desire for building-specific detail in the analysis of site-wide impacts, and an assertion that it was unreasonable to consider placing "hazardous nuclear materials and the processing or storage of nuclear waste" above the Ogallala aquifer. This campaign included some statements or questions identified as individual comments. The names of the individuals who submitted one of these campaign letters are provided in Table 1.13.

In the postcard campaign involving 441 participants (see PC-032 for example), commentors expressed opposition to facilities "that handle nuclear waste or to processes that generate it" including "plutonium processing." Additionally, they voiced opposition to "bringing plutonium to Pantex from other sites" and to the possibility of "long-term storage of plutonium over the Ogallala Aquifer." This campaign concluded with a statement of preference for the type of jobs and development within the region that would not endanger workers, families, natural resources, and the reputation of the regions agricultural products. A listing of the individuals who sent in a postcard is provided in Table 1.13.

In addition, many of the letter and postcard campaign documents were altered or contained one or more statements added by the individual who signed the document. Those statements were considered, but mostly comprised remarks rather than comments on the EIS content. The statements included expressions of support for or opposition to Pantex Plant in general or specific aspects of plant operations, concern for any impacts to specific environmental resources, or criticism of alternatives being examined in this EIS and the PEISs.

DOE recognizes its responsibility to manage facilities and hazardous materials, including plutonium, with operational and environmental controls appropriate for protecting workers, the public, and the environment. DOE continues to work with the U.S. Environmental Protection Agency (EPA), State regulatory agencies, employees, unions, neighbors, and the general public in developing programs and commitments to further improve management of facilities and all hazardous materials, including wastes.

All of these plans and commitments at Pantex Plant have also been considered in the analysis of the alternative sites to determine if there are any conflicts or restrictions that would inhibit these sites from serving as suitable locations for interim pit storage. Impacts of present and future waste management and human health are discussed and analyzed in volume I, sections 4.13 and 4.14, respectively. As discussed in volume I, section 1.3.9 and 1.3.10 of this volume, and the previously mentioned sections of volume I, nothing was found that would inhibit Pantex Plant or the alternative sites from performing the required missions.

DOE understands the importance of the Ogallala aquifer as the principal source of water in the Texas Panhandle. DOE has monitored groundwater quality in the perched and Ogallala aquifers at Pantex Plant for the past 20 years. Impacts of present and future water consumption and quality are discussed and analyzed in volume I, section 4.6. As discussed in section 1.3.5 of this volume and volume I, section 4.6, nothing was found that would result in a significant impact to the Ogallala aquifer.

DOE believes the EIS adequately and reasonably addresses both the affected environment and any potential impacts to all environmental resources. As for the assumptions and accuracy of the aircraft overflight analysis, DOE has conservatively analyzed the various uncertainties that affect the overall level of risk that an aircraft crash could result in a release of radioactive materials. These issues are presented in volume II, appendix E, Aircraft Accident Analysis. The data, assumptions, and calculations represent the best available and most accurate representation of conditions at Pantex Plant.

The level of local support for the siting of facilities for interim pit storage, long-term storage of surplus and non-surplus fissile materials, disposition of surplus plutonium, and long-term continuation of stockpile stewardship and management activities is not part of the analysis of environmental impacts in accordance with NEPA and, thus, is not addressed in this Final EIS. However, the degree of community support, along with environmental impacts, mission requirements, cost, and technical factors, is considered in the Record of Decision.

1.2 ORGANIZATION OF THIS VOLUME

At the beginning of this volume is a section printed on green paper. These "green pages" are a guide to assist readers in quickly locating documents and comments of particular interest. With this guide, the reader can go directly to particular documents or comments without having to read the narratives of any chapter in this volume.

This Comment Response Document is organized into three chapters. Chapter 1 (this chapter) provides an overview of the entire document, including a brief discussion of the major issues that were raised during the comment period and a summary of the changes to the Draft EIS. Chapter 2 is a compendium of the comment documents received, annotated to show the comments that were identified for a response. Chapter 3 provides DOEs responses to the comments. The comments are grouped by resource/issue category so each commentor can easily see, in one section, his or her own comment along with all the comments that other people made about the same subject. Each comment is reproduced verbatim just before the response is provided, so the reader does not have to flip back and forth between the documents in chapter 2 and the responses in chapter 3.

1.3 DISCUSSION OF MAJOR ISSUES AND CHANGES TO THE DRAFT EIS

There were 24 categories of comments and a total of 3,753 comments/remarks received. Nearly three-fourths of them were duplicate submissions as a result of the two letter and one postcard mail-in campaigns with a total of 526 participants. Every comment received was considered in the analysis. Each comment was individually reviewed and a response to each is provided in chapter 3 of this volume. There were several categories of comments that were of broad interest or concern. These topics, categorized as "major issues," are listed below in the order in which the topics appear in the EIS:

Alternatives.
Relationship to Other EISs.
Land Use.
Geology and Soils.
Water Resources.
Air Quality.
Socioeconomic Resources.
Intrasite Transportation.
Waste Management.
Human Health.
Aircraft Crash.
Intersite Transportation.
Environmental Justice.
DOE Policy.
NEPA Process and Procedures.
Out of Scope.

The subsections that follow provide summary discussions of those major issues, organized by topic.

1.3.1 Alternatives

Many comments questioned the adequacy of the process used to select site alternatives, as well as the impact analyses of those alternatives. Additional commentors questioned DOEs rationale and objectiveness in assessing Department of Defense (DOD) relocation alternatives since the Long-Term Storage and Disposition of Weapons-Usable Fissile Materials (S&D) PEIS considered DOD facilities to be infeasible.

Many comments questioned the legitimacy of the 20,000 pit storage limit because, reportedly, the U.S. stockpile was greater than 25,000 weapons. Other comments questioned the 20,000 number because the START II treaty commits to a ceiling of 3,500 deliverable weapons. Concern was expressed that the START II commitments could result in interim pit storage exceeding the 20,000-pit limit. In addition, commentors felt the storage limit was inaccurate because 2,000 weapon disassemblies per year for 10 years (plus the current inventory) could result in interim storage of more than 28,000 pits.

Site Selection Process

The scope of the Pantex Plant EIS included evaluation of potential DOE and DOD sites serving as alternative pit storage sites. A DOE Site Screening Committee systematically assessed a large number of candidate sites to determine the range of reasonable alternative sites. To screen candidate sites, DOE applied exclusionary (e.g., under DOE control through at least 2007) and favorability criteria (e.g., degree of construction required to adapt existing facilities for the pit storage mission). As a result, DOE identified the Device Assembly Facility and P-Tunnel at the Nevada Test Site (NTS), the Fuels and Materials Examination Facility at Hanford Site, and P-Reactor at Savannah River Site (SRS) as reasonable DOE alternatives for interim pit storage.

In parallel, 60 DOD installations were screened by the Nuclear Weapons Council staff. The Council staff determined that only the Manzano Weapons Storage Area (WSA), located on Kirtland Air Force Base (KAFB) (at Albuquerque, New Mexico), and Seneca Army Depot (at Romulus, New York) were feasible.

Subsequently, the Air Force agreed to become a Cooperating Agency in the preparation of this EIS regarding the Manzano WSA. However, because Seneca Army Depot was approved for closure in September 1995, in accordance with the Defense Base Closure and Realignment Act of 1990 (Public Law 101-510), this facility was not available as a candidate site.

After a site visit to validate suitability, the Manzano WSA was determined to be a reasonable alternative site for interim storage of plutonium in pit form. DOE believes the interim storage alternatives evaluated in this EIS, including the Manzano WSA, represent a reasonable management course for interim storage of plutonium in pit form.

Basis for the 20,000 pit storage limit

As originally discussed in the January 1994 Environmental Assessment for Interim Storage of Plutonium Components at Pantex (DOE/EA-0812), the Nuclear Weapons Stockpile Memoranda and corresponding planning and production documents direct the retirement rates for weapons held in DOD custody. In response, DOE has determined the need for interim storage of up to 20,000 plutonium pits.

Chapter 2 of the SSM PEIS discusses in detail the national security policies, responsibilities, strategies, and directives placed upon DOE. For the reasonably foreseeable future, eight principal drivers were used for defining the direction and scope of the U.S. nuclear weapons stockpile. Of the eight, the Strategic Arms Reduction Treaty (START) II protocol is the most useful in helping define a specific time period to bound the reasonably foreseeable future.

The START I treaty and the START II protocol only control the number of strategic nuclear weapons that can be loaded on treaty-specified and verified strategic missiles and bombers. These deliverable nuclear weapons are limited to 6,000 by the START I treaty and 3,500 by the START II protocol. The treaties do not control the total stockpile or the composition of strategic and nonstrategic nuclear weapons. The U.S. stockpile will be larger than 6,000 under START I and 3,500 under START II because the stockpile includes retaining weapons for nonstrategic nuclear forces, DOD operational spares, and spares to replace weapons attrited by DOE surveillance testing. Additional language has been added to volume I, chapters 1 and 3 to clarify this issue.

However, should treaty commitments, Presidential directives, or congressional legislation further reduce the weapons stockpile and increase the need for additional storage above the 20,000 number, DOE would address the environmental impacts in future NEPA documentation.

1.3.2 Relationship to Other EISs

The majority of comments illustrated a need for clarifying the relationship of this Pantex Plant EIS with respect to DOEs other major PEISs (i.e., Waste Management [WM] PEIS, SSM PEIS, S&D PEIS) and two Site-Wide EISs (i.e., NTS EIS and Los Alamos National Laboratory (LANL) EIS). Commentors also asked for more simplified documents and help in improved public understanding of the relationships between DOEs major PEISs and EISs. A commentor questioned the reason the SSM PEIS evaluated complete closure of the Pantex Plant, when this Pantex Plant EIS did not.

Other commentors expressed a wide range of reasons for selecting (preferred alternatives) or eliminating sites under consideration in each of the DOE PEISs and Site-Wide EISs mentioned above.

Relationship of Pantex Plant EIS to Other NEPA Documents

The WM PEIS, the SSM PEIS, the S&D PEIS, the NTS EIS, the LANL EIS, and the Pantex Plant EIS relationships are described in chapter 1 of each document. Their respective summaries provide simplified, descriptive information relevant to the decisions impacting each of the six EISs. However, all six documents address issues that are extremely complex and there is a limit to the degree that these issues can be simplified without losing scientific and programmatic validity. At the same time, DOE has attempted to better clarify the relationships through the addition of text to volume I, sections 1.7.1 through 1.7.5.

Continued operation of Pantex Plant and associated storage of nuclear weapon components, including interim storage of plutonium pits, are within the scope of this EIS. The Pantex Plant EIS does not include operations for processing or reprocessing of plutonium. Long-term storage of surplus and non-surplus fissile materials, including plutonium pits currently in interim storage at Pantex Plant are within the scope of the S&D PEIS.

The S&D PEIS evaluates alternatives for the long-term storage of weapons-usable fissile materials and for the disposition of weapons-usable plutonium declared surplus to national defense needs by the President. Long-term continuation of stockpile stewardship and management missions, including Pantex Plant assembly, disassembly, and high explosive (HE) operations, are within the scope of the SSM PEIS. The SSM PEIS evaluates environmental impacts of alternatives including downsizing of sites, relocation of missions, complete closure of sites (e.g., Pantex Plant, Kansas City Plant, Oak Ridge Reservation) and the capability to fabricate new pits and process and reprocess (e.g., reuse) existing pits.

Detailed discussions of DOEs purpose and need for action, range of alternatives, and other EIS relationships are provided in each PEIS. Detailed discussions defining differences in interim storage criteria and long-term storage criteria; "surplus pits" versus "strategic pits"; and disposition alternatives are also presented.

1.3.3 Land Use

Numerous concerns were expressed regarding the potential harm to croplands, livestock, and agribusiness from the potential contamination of the soil and water surrounding Pantex Plant. Concern was also expressed over the brevity of text devoted to discussion of agriculture and agribusiness within the Texas Panhandle.

The Pantex Plant EIS describes land use within an 80-kilometer (50-mile) radius of Pantex Plant. Rural, urban, agricultural, commercial, residential, industrial, institutional, and recreational land uses are discussed.

Land use in the 80-kilometer Region Of Influence (ROI) is predominately agricultural. The majority of this area is rangeland located along the Canadian River drainage to the north and along a tributary of the Red River to the south of the plant. Cropland is the second largest category of land use, with areas containing both dryland crops and irrigated land. Commercial, residential, industrial, and institutional areas are centered around the population centers, and represent a small part of the total land use within the ROI. Livestock operations in this area are represented by dairy operations and beef cattle in feedlots, as well as open range grazing. Four dairies and one creamery are located within the area. Carson County, located within the ROI, is among the top counties in Texas for production of wheat, grain and sorghum, and is a substantial contributor of corn crops. The counties of Castro, Deaf Smith, Hansford, and Swisher are the areas that contain the greatest number of cow-calf units within the ROI.

The major employers in the area are service industries, retail trade, manufacturing, public utilities, construction, wholesale trade, finance and realty, public administration, and agriculture. While agriculture is not the major employer in the ROI, it is an important industry. The concerns of the farmers and livestock growers in the vicinity of Pantex Plant are important to DOE. The future plans for the plant are regulated by various environmental protection measures to monitor the use of the Ogallala aquifer and the possibility of contaminants migrating into the rich soil of the Panhandle area. The continued operations at Pantex Plant are not expected to alter the environment of the surrounding area. Likewise, the construction or modification of the six proposed facilities will not significantly change the existing environment. The interim storage of 12,000 to 20,000 pits at the plant would not increase the potential for contamination at the site, or in the surrounding ROI. However, the commentors concerns are appreciated, and several sections of the Final EIS, including volume I, section 4.4, Land Resources, have been augmented with additional information and analysis concerning the agricultural practices within the ROI.

1.3.4 Geology and Soils

One significant issue is whether there are geologic faults in the Pantex Plant region that are, or may be, "capable" under the definition of 10 CFR 100 Appendix A and, therefore, Pantex Plant may be an unsuitable location for nuclear facilities.

Another issue raised was the possibility of salt dissolution resulting in sinkholes and fractures in the immediate vicinity of the Pantex Plant.

Other commentors requested more information about soil contamination and what will be done to clean these areas of contamination.

Geology

A description of regional geology, including the location of geologic faults, has been added to volume I, section 4.5.1. A geological cross-section of the region has also been included. This cross-section shows the fault in the Permian rocks deep beneath Pantex Plant.

10 CFR 100 appendix A contains guidance on the siting and design of nuclear reactors. Since there is no reactor at Pantex Plant, and this EIS does not consider any proposal to locate a reactor at the plant, this guidance can only be applied in a general way to the facilities at Pantex Plant. The guidance includes criteria to determine the area in which faults should be investigated, how the faults should be evaluated, and how those evaluations should be taken into consideration in the design of the facility. 10 CFR 100 appendix A does not forbid the siting of facilities near faults, even faults that are determined to be "capable" in accordance with the guidance. It does, however, require that the facility be designed to be able to withstand the effects of earthquakes from the faults.

There have not been any comprehensive studies performed in accordance with the criteria of 10 CFR 100 appendix A to determine the capability of each of the faults in the region. Pantex Plant does, in fact, lie on a deep subsurface fault. However, there is no evidence that this fault extends into the more recent rocks and sediments; therefore, the cross-cutting principle can be used to determine that this fault has not been active since the Permian era, about 286 million years ago. In the absence of these studies, the procedure used for evaluating the risk from earthquakes to Pantex Plant assumes that the largest earthquake expected in the region can happen anywhere in the region (DOE 1994aa).

Risk analyses of existing facilities take into consideration the robustness of the facility and the frequency of the earthquakes. The risk of a release of radioactive material resulting from earthquakes has been assessed for Pantex Plant. volume I, section 4.14 presents the accident scenarios that resulted from a screening of potential accidents at Pantex Plant. A suite of 11 accident scenarios were identified as risk significant. These accidents included both high-frequency low-consequence events, such as those that occur during normal operations, and low-frequency high-consequence events, such as aircraft crashes and seismic events.

Four scenarios discuss the risks associated with the release of radioactive material due to seismic events. There is no plausible scenario in which criticality could occur at Pantex Plant due to actinides present in soils interacting with surface groundwater. Section 4.5.1 in volume I contains a description of regional seismicity. The Pantex Plant Environmental Information Document (Pantex 1996f) contains a more detailed description. Additional details on the assessment of risk in this EIS can be found in volume II, appendix D.

Salt Dissolution

Salt dissolution is a process that has resulted in major post-Permian structures. In Carson County, a large depression is filled with sediment of the Ogallala Formation. Presence of the Ogallala deposits in the depression indicates that the basin existed prior to Ogallala time and that the local dissolution was underway prior to or during the deposition of the Ogallala Formation (Pantex 1996). Recent work (TBEG 1994a) using shallow seismic data has determined that the structure beneath the playas at Pantex Plant shows subsidence of Ogallala strata attributed to dissolution of underlying salt beds.

Considerable attention has been given to the possible origin of playas. A summary of playa development is provided as follows: "These landforms are the result of a series of intermittently active processes, including wind, fluvial erosion and lacustrine deposition, pedogenesis, dissolution of soil carbonate, salt dissolution and subsidence, and animal activities, that collectively produced the typically shallow and roughly circular playa basins on the High Plains. We infer that playa basins are stable landforms that, once initiated, remain as part of the landscape" (Gustavson, 1994).

Playas are not sinks or sinkholes. For a sinkhole, the actual hole in the ground results from an abrupt collapse of the underground cavity that resulted from the dissolution of salt. While the formation of the sinkhole can happen within days, the cavity that is the cause of the sinkhole is the result of dissolution taking place over geologic time. An example of a sink, involving 2.0 x 10⁶ tons of material, occurred in Hall County in 1994. There is no evidence for, nor expectation of, the formation of sinkholes at Pantex Plant. There is no plausible scenario for the release of hazardous materials even if a sinkhole of similar size occurred at Pantex Plant beneath a magazine containing pits. Since recorded history in the Texas Panhandle, there are no accounts of industrial complexes, buildings, etc., incurring damage as the direct result of sink holes. None of the playas at or near Pantex Plant are the direct result of sinkholes. Playa formation is hypothesized to be the collective result of numerous processes, both physical and chemical.

Soil Contamination

The scope and mission of the Pantex Plant environmental restoration (ER) program is to: assess all inactive sites, which includes solid waste management units; determine the nature and extent of contamination; and perform remediation to eliminate any substantial present or future threat to human health and the environment. Additionally, Pantex Plant currently plans to perform advanced remedial actions (i.e., interim and voluntary actions) where feasible. Remediation activities are currently underway on ditches and playas while a groundwater treatability study is being conducted to determine the most effective method(s) to clean up contaminants (e.g., RDX) detected in the perched groundwater. The treatability system began operating just eight months after the initial boundary contamination was discovered. The treated water now meets drinking water standards as confirmed by co-sampling conducted by the Texas Natural Resources Conservation Commission (TNRCC) (Pantex, 1996; Pantex 1996c).

The ER program is currently being conducted under the Resource Conservation and Recovery Act (RCRA) in accordance with the Hazardous Waste Permit and EPA and State of Texas regulations, with a goal of gaining full public, trustee, and regulatory agency acceptance. All decisions and determinations associated with the ER program are made in negotiation with the regulators. The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (Superfund) also applies to Pantex Plant because EPA placed Pantex Plant on the National Priorities List on May 31, 1994. Negotiations are currently underway with EPA and the State of Texas to integrate the CERCLA and RCRA processes. The current plan is to complete the remediation process in such a way as to satisfy both RCRA and CERCLA requirements. The Pantex Plant ER program is detailed in the Pantex Plant ER Program Facility Action Plan (DOE 1995e). This plan establishes an aggressive remediation schedule with a goal of initiating remediation at all sites by the year 2000, thereby meeting the State of Texas "Clean Texas 2000 Initiative."

The latest data on soil contamination has been incorporated into this Final EIS. Volume I, section 4.5.1 provides additional details about specific ER projects.

1.3.5 Water Resources

The primary issues and concerns related to water resources included:

· The status and conditions of wastewater discharge permits;

· Surface water quality decision criteria used in the Pantex Plant EIS;

· Wastewater discharge into ditches and playas;

· The nature and extent of groundwater contamination in the perched and Ogallala aquifers;

· The importance of the Ogallala aquifer as a valuable regional groundwater resource; and

· The status of environmental restoration programs, such as groundwater contamination prevention, corrective actions, and cleanup.

Status and Conditions of Wastewater Discharge Permits

Discussion of the status and conditions of wastewater discharge permits for the Pantex Plant has been updated in volume I, section 4.6.1.1 and volume II, appendix C. Because the State of Texas applies regulations through concentration limits specified in permits, the decision criteria for surface water compliance is based on the permit limits established in the National Pollutant Discharge Elimination System (NPDES) Permit and Wastewater Discharge Permit for Pantex Plant. Pantex Plant has worked very closely with EPA Region 6 and TNRCC to produce wastewater discharge permits (EPA NPDES Permit No. TX-0107107 and TNRCC Wastewater Discharge Permit No. 02296) that provide stringent wastewater discharge requirements and are protective of human health and the environment. The Pantex Plant wastewater discharge permit limits meet or exceed applicable requirements for surface water.

TNRCC calculated effluent limitations that are based on the Texas State Water Quality Standards (30 TAC 307). The actual effluent limitations, cited in the permits, are more stringent than those calculated by the TNRCC and reported in its Fact Sheet. As stated in the NPDES Permit, EPA accepted the statistical calculations provided by Pantex Plant and has established metals limitations on a case-by-case basis through best professional judgment under Section 402 (a) of the Clean Water Act for best available technology economically available. In addition to the constituents that are regulated in the permits, the Pantex Plant Environmental Protection Department also monitors for other chemical constituents to provide additional assurance that any changes in water quality are protective of human health and the environment.

Surface Water Quality Decision Criteria

Suspected contaminants of concern were determined by comparing tabulated annual average values to the following defined surface water quality decision criteria:

Texas State Water Quality Criteria for fresh water acute aquatic life protection and human health protection for water and fish.
EPA Region 6 NPDES Permit (No. TX-0107107) and TNRCC Wastewater Discharge Permit (No. 02296).
DOE Derived Concentration Guides (DOE Order 5400.5) for radionuclide health standards.

The Texas State Water Quality Criteria for Aquatic Life and Texas State Water Quality Criteria for Human Protection are used as decision criteria for comparative purposes. EPA Region 3 Risk Based Concentrations (RBC) guidelines were used in the Draft Pantex Plant EIS as surface water quality decision criteria only for those constituents that did not have established surface water quality standards, Pantex Plant wastewater discharge permit limits, or DOE Derived Concentration Guides (DOE Order 5400.5) for radionuclide.

However, because the EPA NPDES and TNRCC Wastewater Discharge permits have been finalized, the NPDES and Wastewater Discharge permit requirements have replaced the RBC Guidelines as decision criteria in volume I, section 4.6.1.1 and volume II, appendix C. EPA and TNRCC determined which constituents would have recording requirements and/or permit limits specified in the NPDES and Wastewater Discharge permit, based on a review of the most recent surface water quality data available for the main outfalls and internal outfalls at Pantex Plant.

TNRCC Permit Fact Sheet (TNRCC 1995a) states that the known uses of the receiving waters are high quality aquatic life use and contact recreation. The uses for the unclassified waters are intermittent playa lakes with no significant aquatic life uses. Acute aquatic life criteria apply. There is no reference to drinking water standards or Risk Reduction Rules being applicable criteria for Pantex Plant surface water in either the TNRCC or EPA permits or their respective Fact Sheets.

The decision criteria for radionuclide constraints are the DOE Derived Concentration Guides (DOE Order 5400.5) under the Atomic Energy Act of 1954 (as amended) (42 U.S.C. 2011). DOE is authorized to protect public health and safety and the environment in conducting programs, such as Pantex Plant operations. The purpose of DOE Order 5400.5 is "To establish standards and requirements for operations of the DOE and DOE contractors with respect to protection of members of the public and the environment against undue risk from radiation."

It is DOEs objective to operate its facilities and conduct its activities so that radiation exposures to members of the public are maintained within the limits established in this Order and to control radioactive contamination through the management of real and personal property. It is also a DOE objective that potential exposures to members of the public are as far below the limits as is reasonably achievable and that DOE facilities have the capabilities, consistent with the types of operations conducted, to monitor routine and non-routine releases and to assess doses to members of the public. In addition to providing protection to members of the public, it is DOEs objective to protect the environment from radioactive contamination to the extent practical.

Wastewater Discharge into Ditches and Playas

TNRCC Wastewater Discharge Permit No. 02296 (as amended) requires that within one year of the effective date (June 14, 1996) of the permit, Pantex Plant must conduct a study to determine the feasibility of eliminating or minimizing discharges to playa lakes and open ditches or improving the quality of discharge. A thorough evaluation of existing contamination in all drainage ditches and playa basins is currently ongoing. Methodologies and plans for implementation are discussed in the Ditches and Playas Interim Corrective Action Work Plan (Stroller 1996). Information regarding this work plan has been summarized in volume I, section 4.6.1.1. The results of those investigations, as well as the effect of continued discharge are pending review (Alternative to Discharge at Playa 1). Pantex Plants Environmental Protection Department conducts environmental monitoring on a routine basis to ensure that permit limits are not exceeded. The results of environmental monitoring activities are summarized and presented in annual environmental reports that are available to the public.

Nature and Extent of Groundwater Contamination in the Perched and Ogallala Aquifers

An expedited site characterization was conducted in 1994 and 1995 to determine the extent of the perched aquifer, nature of recharge, and direction of groundwater flow. Data collected during the Pantex Plant expedited site characterization was used to predict contaminant movement and evaluate cleanup options for perched groundwater. The perched aquifer occurs as a result of localized groundwater mounds that form beneath the playas from focused surface water recharge. The existence of the perched aquifer is also dependent on the occurrence of a fine-grained zone, reported to be approximately 9.1 to 33 meters (30 to 110 feet) thick. This fine grained zone impedes the downward movement of infiltrating groundwater. The fine-grained zone has an irregular surface, and generally occurs 90 meters (300 feet) below land surface.

Where the fine-grained zone is present, perched groundwater collects in sand and gravel deposits that form subsurface channel features. The perched aquifer is thickest beneath Playa 1, which is considered to be a source of focused recharge to the perched aquifer. Groundwater in the perched aquifer is considered to flow radially away from Playa 1. Recharge varies laterally between playa, interplaya, and drainage ditch environments. It is important to note that the perched aquifer is stratigraphically higher (closer to the surface) and not directly hydraulically connected with the underlying Ogallala aquifer. The depth to groundwater ranges from 64 to 88 meters (210 to 290 feet) below land surface in the perched aquifer and from 104 to 140 meters (340 to 460 feet) in the underlying Ogallala aquifer.

Additional investigations have been conducted on private property south and southeast of Pantex Plant. DOE has completed a Groundwater Protection Project that investigated the potential for contaminant migration in homestead wells that are located at Pantex Plant and southeast of the plant boundary. Although low levels of HE contamination were detected by TNRCC in a domestic Ogallala well located on private property southeast of Pantex Plant proper, efforts to mitigate further contamination have been completed. The well in question has been properly plugged and sealed under the supervision of the TNRCC. A replacement Ogallala well has been drilled and completed to prevent further potential cross-contamination of the Ogallala aquifer. Information regarding Pantex Plants Groundwater Protection Project is presented in volume I, section 4.6.1.2.

Importance of the Ogallala Aquifer as a Valuable Regional Groundwater Resource Supply

The Ogallala aquifer is the principal aquifer and major source of water for the Texas Panhandle and the South Plains, as well as parts of New Mexico, Oklahoma, Colorado, Kansas, Nebraska, Wyoming, and South Dakota. Water use at Pantex Plant accounted for only 0.7 percent of the total estimated water use in Carson County for 1995. In 1995, Carson County irrigated 25,751 hectares (63,629 acres), using 101 billion liters (26.6 billion gallons) per year, or an average annual withdrawal of 1.6 million liters (0.42 million gallons) per acre.

Pantex Plant is located on approximately 3,700 hectares (9,100 acres) of DOE land. If Pantex Plant property were used for agricultural, rather than industrial uses, then approximately 3,600 hectares (8,900 acres) could require irrigating, assuming that the approximate area of the three onsite playas [79.7 hectares (197 acres)] were excluded. Under such circumstances, approximately 14 billion liters (3.7 billion gallons) per year of groundwater might be withdrawn for irrigation. The plant pumped 618 million liters (163 million gallons) for industrial or domestic uses in 1995. As a result, agricultural activities at Pantex Plant could require up to 23 times as much water if used for typical Carson County agricultural activities.

Under the upper bounding conditions of the 2,000 weapons level, annual groundwater use projections are 1,011 million liters (267 million gallons) per year. This represents an increase of approximately 64 percent over the plants industrial and domestic water uses of 618 million liters (163 million gallons) in 1995. In Fiscal Year (FY) 1995, Pantex Plants actual water usage was approximately 33 percent of the plants total groundwater production capacity. For the 2,000 weapons scenario, the projected water usage is 53 percent of the plants total capacity of 1,890 million liters (500 million gallons). Furthermore, for the 2,000 weapons per year scenario, Pantex Plant groundwater withdrawals would only account for 0.8 percent of the total estimated annual groundwater withdrawals in Carson County.

Status of Environmental Restoration Programs for Water Resources

Pantex Plant maintains an Environmental Protection Department and an ER program to monitor soil and water quality so that any present or potential threat to human health and the environment is identified and can be corrected. Groundwater contamination has occurred in the perched aquifer as a result of past site-related activities. For the last seven years, the Pantex Plant ER program has assessed inactive sites, conducted investigations to determine the nature and extent of contamination, and implemented remediation strategies to eliminate any present or future threat to human health and the environment. DOE implemented a Groundwater Protection Project to clean up the groundwater to residential drinking water standards beyond the facility boundary. The purpose and objectives of the project are discussed in volume I, section 4.6.1.2.

Remediation activities that are currently underway at Pantex Plant include contaminated soil removal in the vicinity of on-site ditches and playas and a groundwater treatability study to determine the most effective method(s) to clean up perched groundwater. The treatability system began operating just eight months after the initial boundary contamination was discovered. The treated water now meets drinking water standards, as confirmed by co-sampling conducted by the TNRCC (Pantex, 1996; Pantex 1996c). Evidence of natural attenuation and degradation of high explosive compounds, including trinitrotoluene (TNT), have been documented during the treatability studies (PC 1996n).

Summary of Changes to the Draft EIS

Volume I, section 4.6.1.1 has been updated to discuss new EPA NPDES and TNRCC Wastewater Discharge permit requirements, revised surface water quality decision criteria, and corrective measures for wastewater discharge into ditches and playas. Volume I, section 4.6.1.2 has been updated with new information regarding the nature and extent of groundwater contamination in the perched and Ogallala aquifers and the status of ER projects, such as groundwater contamination prevention, corrective actions, and cleanup.

1.3.6 Air Quality

One of the principal air quality issues centered on the comparison of the results of the TNRCC air modeling and the modeling performed for this EIS. A related concern was that a significant number of air pollutants were perceived as left out of the EIS modeling. TNRCC, in reviewing the emissions sources and pollutants reported in the Draft EIS, did not find 8 emissions sources and 51 hazardous air pollutants that were on the TNRCC list. Another issue was the variance between the modeling results, which showed no exceedances for particulate matter (PM10), and the air sampling data collected by TNRCC, which showed a few exceedances of the National Ambient Air Quality Standard (NAAQS).

One of the most frequently mentioned concerns was the fact that there was no discussion of any continuing efforts to develop an alternative to the Burning Ground.

Another issue was the placement of monitoring stations at Pantex Plant and the location and adequacy of the modeling performed for the residences surrounding the plant.

Air Modeling

The air modeling for the EIS indicates that alcohols exceeded the TNRCC Effects Screening Level (ESL) at the plant boundary and at one of the nearby residences. The TNRCC air modeling indicated that alcohols would exceed the ESL at the plant boundary, but not at the nearby residences. The TNRCC modeling was based on a screening process whereby all pollutants were assumed to be located at one point and calculations were made to determine resulting concentrations at the fence line.

The EIS air modeling used the actual locations of each source emission and modeled the resulting concentrations at the fence line produced by simultaneous emissions of all pollutants from their respective sources. The results were very comparable to the TNRCC study, with both modeling exercises indicating that only alcohols exceeded the ESL at the fence line. This outcome was affected by the fact that, at the time, the specific emission rates of each type of alcohol at each source were not available. Therefore, in the EIS modeling, all of the alcohols for which individual emission rate information was not available were modeled together as a group and compared to the ESL for the individual alcohol that had the lowest ESL. Because the 1-hour ESLs for the specific alcohols used by the plant vary from 101 to 18,800 mg/m3 (micrograms per cubic meter), this was a very conservative assumption.

Since the Draft EIS was published, the quantity of each type of alcohol in the group present at the plant has been determined. In actuality, of the 19 types of alcohols used by the plant, only one (1-octanol) had an ESL less than 600 mg/m³. The quantity of 1-octanol present at the plant is only one gallon, which represents less than 0.05 percent of the total quantity of alcohols at the plant. Conversely, the two types of alcohols stored in greatest quantities at the plant are 2-propanol (isopropyl alcohol) and methanol (methyl alcohol), which comprised 1,105.1 gallons (63.2 percent) and 456 gallons (26.1 percent), respectively, of the plant inventory. The 1-hour ESLs for isopropyl alcohol and methanol are 7,856 and 2,620 mg/m³, respectively. The third most common form of alcohol at the plant is ethyl alcohol, which had an inventory of 107.3 gallons (6.11 percent of the plant inventory) and has a 1-hour ESL of 18,800 mg/m³.

To divide the previously modeled concentration for the group of alcohols into the specific types and quantities of alcohols that could be emitted, the total concentration of all alcohols was then prorated by the percentage of each type of alcohol that is present at the plant. The concentrations thereby derived for each alcohol were then compared to the ESLs for the specific alcohols involved. The result is that no alcohols exceed their respective ESLs at any point on the fence line or at any offsite residence modeled. Volume I, section 4.7.1 and volume I, Table B.4.1-2 have been revised to reflect these changes.

Following receipt of a list of those sources and emissions included in the TNRCC modeling, checks were made against the EIS modeling database. All eight of the sources at issue were formerly used facilities that were inactive by the time the EIS modeling was performed. All but three of the pollutants modeled by TNRCC were also modeled during the preparation of the EIS. The maximum fence line concentrations of the pollutants, both those listed in the Clean Air Act (42 U.S.C. 2011) and those listed by TNRCC, were compared to the appropriate TNRCC ESLs. However, only the results for those chemicals that are listed under the Clean Air Act, as amended (Nov. 1990), and those that exceeded their ESLs were reported in the Draft EIS.

In addition, the results for criteria air pollutants were also reported. All of the maximum fence line concentrations for all of the chemicals TNRCC used in its modeling have been included in volume I, section 4.7 and volume II, appendix B of the Final EIS to provide a complete picture of all pollutants. There were three pollutants that had not been included in the modeling: dimethylformamide, ketene, and total suspended particulates (TSP). The first two have been added to the modeling results in the Final EIS. The third pollutant was included in the PM10 modeling, as there is no longer a standard for TSP. Changes have been made in the Final EIS to reflect this information.

The variances between PM10 monitoring data and modeling results are explained by several factors:

The dust particles causing the monitoring exceedances could well have occurred as a result of offsite agricultural operations (or relatively short-duration construction activities onsite) and simply blown across the air sampling stations along with the plant emissions. It is not possible for the model to account for offsite generated particulates that combine with onsite emissions.
The air sampling stations are located well inside the fence line of the plant, whereas the modeling results were reported at the fence line, further from Pantex Plant sources. With the greater distance from sources, concentrations at the fence line would be expected to be lower than onsite.
The meteorology for modeling was that for 1988, as standardized by TNRCC. The air samples showing exceedances, however, were taken in the 1992-1995 period.

Burning Ground Alternative

The Burning Ground is used to sanitize explosives components/materials and treat explosives waste and materials contaminated with explosives. It is operated under RCRA regulations for HE waste treatment. Air emissions from the ongoing Burning Ground activities are subject to general air quality conditions established in the Hazardous Waste Permit. The permit states that this facility shall be operated in accordance with and subject to the applicable provisions of the Texas Solid Waste Disposal Act and the Texas Clean Air Act as amended, Chapter 382 of the Texas Health and Safety Code, and all applicable rules, regulations, and orders of the TNRCC. The resulting ash shall be managed so as to not cause or contribute to a condition of "air pollution" as defined in subchapter 382.003 of the Texas Health and Safety Code.

As stated in the Draft EIS, the plant conducted a study in 1994 that determined that the Burning Ground is the Best Available Control Technology. However, after discussions with stakeholders, the plant initiated another study to further examine base hydrolysis as a future technology to sanitize and demilitarize HE components as well as to treat HE residues. This clarification has been added to the Final EIS. Alternative HE disposal methods are discussed and analyzed in volume II, appendix G.

Air Monitoring and Concentrations at Residences

Under an Agreement in Principle between DOE and the State of Texas (November 1991), TNRCC implemented a non-regulatory air monitoring program at Pantex Plant and determined placement of monitors. The results of the monitoring program are discussed in volume I, section 4.7.

To supplement this monitoring program, air quality modeling was performed for the EIS. The air quality modeling analyzed the concentrations at the residences surrounding the Pantex Plant, including several residences on the south side of the plant. The location of the residences used in the modelling was correct. The incorrect map has been replaced with a new map showing locations of all the residences modeled (see volume I, section 4.7.1.3).

1.3.7 Socioeconomic Resources

Commentors questioned the use of different employment multipliers in the Pantex Plant EIS, SSM PEIS, and S&D PEIS.

Commentors expressed concern about cumulative impacts to the economy because of past and future closures of Federal facilities or operations. For example, the future closure of the U.S. Department of Interiors Bureau of Mines Helium Plant, the Amarillo Air Force Base closure in 1968, the Bell helicopter plant closure in 1990, and the cancellation in 1988 of the DOE program for a mine geologic repository for spent nuclear fuel and high-level radioactive waste in Deaf Smith County.

Commentors stated that agriculture forms the basis for the long-term economy of the Texas Panhandle. Related concerns were about potential impacts to the agricultural economy and tax revenues. Other concerns were about damage to the reputation of agricultural products from Pantex Plant activities or related accidents. Commentors asked for more emphasis on these issues in the Final EIS.

When looking at the 500-weapons employment level, some commentors were concerned about the impact on future revenues for governing bodies compared with current revenues. Commentors asked that additional analyses on tax revenues be added to the Final EIS. There was also concern over the loss of jobs if Pantex Plant is downsized, creating economic impacts and outmigration.

Economic Modeling

The SSM PEIS, S&D PEIS, and Pantex Plant EIS all use the U.S. Bureau of Economic Analysis regional economic model known as Regional Input-Output Modeling System (RIMS II) as the basis for employment and income impact analysis. This nationally recognized model is used by government agencies, university researchers, and private economists throughout the country to measure regional economic impacts. It is designed to be sensitive to differences in the economy from one region to another.

The differences in the employment multipliers presented in the three documents are not because of the models used but because of the differences in the inputs provided to the models by the authors of those documents. These inputs relate to a number of factors, including the size of the ROI, the type and mix of activities involved in the projects being considered; the number of direct employees needed; the average income per employee or total payroll; the money spent on local purchases of goods and services to support Pantex Plant operations or construction and operation of new facilities; the money spent by Pantex Plant workers in the local economy; and the average wage rate applied to direct and indirect workers.

Differences in these inputs at different points in time can generate different indirect employment multipliers. The type and mix of activities involved in the programs described in the three referenced documents are different and each requires significantly different inputs which may or may not be locally available within the ROI. This also contributes significantly to different multiplier values in the three documents.

One commentor expressed concern about the employment multiplier of 2.65 used in the Pantex Plant EIS, which is different from the 3.87 multiplier used in a study conducted for the Amarillo Economic Development Corporation.

As stated before, DOE chose to use the RIMS II model as the basis for employment and income impact analysis. Pantex Plant is a major contributor to the employment in the region. However, the employment multiplier is a derived value and would differ even when the same researcher is looking at different industrial activities. We believe that a multiplier of 1.65 indirect jobs for each direct Pantex Plant job, which translates to a total job multiplier of 2.65, is more realistic when considering the proposed and alternative actions being analyzed in the Pantex Plant EIS.

Cumulative impacts include the incremental impacts of the actions when added to other past, present, and reasonably foreseeable future actions. A discussion of the past activities affecting the ROI, such as the closure of the Amarillo Air Force Base in 1968, the cancellation of the DOE geological repository program in Deaf Smith County in 1988, and the closure of the Bell Helicopter Plant in 1990, has been added in volume I, section 4.11.1.5 of this EIS. These impacts are reflected in the baseline employment and population estimates that form the basis for evaluation of impacts from the proposed action and alternatives. Thus, impacts resulting from the cancellation of the repository program in Deaf Smith County on the Pantex Plant ROI, for example, have been addressed in the description of the affected environment and are reflected in population projections for the No Action Alternative. Cumulative economic impacts of planned or reasonably foreseeable DOE actions have been discussed in volume I, section 4.11.5.

As mentioned under Cumulative Impacts in volume I, section 4.2, information on other Federal (non-DOE), State or local projects including private developments was sought through contacts with Federal and State regulatory agencies, the Amarillo Economic Development Corporation, the Panhandle Municipal Water Authority, and the City of Amarillo. This effort yielded only one project (future closure of the Helium Plant) that would contribute to the cumulative impacts in the Pantex Plant ROI.

Agricultural Economy

Risk assessments conducted in the Pantex Plant EIS have shown that plant activities do not adversely impact agricultural operations in the ROI. This is clearly indicated by the growth of the agricultural economy in the ROI over the past several decades since Pantex Plant has been in operation.

The contribution of agriculture to the regional economy of the Texas Panhandle is described in volume I, section 4.11.1.5 of the EIS. It evaluates and summarizes available data for both farm and non-farm workers. Volume I, Table 4.11.1.52 presents data on growth of the agricultural industry in the region from 1950 to 1992. In summary, the value of crops grown and sold in the ROI has increased by 151 percent, relative to the 142 percent increase in the Producer Price Index for Crude Foodstuffs and Feedstuffs. Additional information on economic impacts to agriculture has been provided in volume I, section 4.11.

Tax Revenues and Jobs

At the 500 weapons activity level, the Pantex Plant workforce would be reduced by 1,400 workers, Additionally, another 2,351 indirect workers could lose their jobs in the Pantex Plant ROI. For analysis purposes, it was assumed that all direct workers and 50 percent of the indirect workers would leave the Pantex Plant ROI as a result of this action. With a household size of 2.85, this would mean an outmigration of 5,796 persons. It was further assumed, for simplicity in calculation, that all workers live in the City of Amarillo. Based on the current per capita revenue of $457, the revenue loss in the City of Amarillo would be approximately $2.8 million or approximately 3.6 percent of the total revenues of the City in 1994.

In reality, this number would be lower since some of these workers do not live in Amarillo and the per capita revenue generated in the ROI counties is generally lower than in the City of Amarillo. Also, not all unemployed workers, particularly the indirect workers, are likely to leave the Pantex Plant ROI immediately or even over a longer period. Additional information on impacts to overall tax revenues has been provided in volume I, section 4.11.2.1.

The Record of Decision for the SSM PEIS will identify whether Pantex Plant would be downsized or not. If downsizing does occur, the affected communities can request DOE to provide financial assistance for community assistance and planning.

DOE will, in any event, keep the public informed of its actions on a regular basis and soon after any decision is made. Any decision that would result in downsizing would require a formal workforce restructuring plan and additional public participation opportunities in accordance with National Defense Authorization Act of 1993 (Public Law 102-484). The DOE Office of Community and Worker Transition has the capability to help the facility and community transition in the case of downsizing. The office oversees DOE policies to facilitate worker transition, including worker retraining, education, and relocation assistance.

A reduction to the 500 weapons activity level could contribute to a combined loss of 3,715 jobs (1,400 direct plus 2,315 indirect jobs). This would increase the unemployment rate in the ROI from approximately 4.1 percent to 6.2 percent and could trigger outmigration. Compared to the total employment of 107,000 in Amarillo (ACC 1996), this reduction would represent approximately 3.5 percent of the Amarillo area employment and 3.7 percent of its total personal income of $3.65 billion in 1994.

It should be noted that reduced workforce at Pantex Plant, or even the closure of the plant, would not necessarily result in instant outmigration of population. Even after the closure of the plant, workers would continue to be employed at the site for decontamination and decommissioning of plant facilitates over a number of years.

1.3.8 Intrasite Transportation

The majority of the comments regarding Intrasite Transportation were requests for additional site-specific information or clarification of various topics. Several comments requested information regarding onsite vehicle accidents at KAFB.

A number of comments were received relating to the pyrophoric nature of plutonium and whether this is an issue of concern for pit storage. Additionally, many comments requested further information on pit and pit container surveillance.

A number of commentors requested additional clarification on the scope of dosimetry estimates provided in volume I, section 4.12.

KAFB Accident Experience

Vehicular accident statistics for KAFB are maintained by the U.S. Air Force. For 1995, there were a total of 271 vehicle accidents within KAFB; 241 were minor and 30 were major. A major accident involves a loss of life or damage in excess of $10,000. For 1994, there were a total of 283 vehicle accidents within KAFB; 233 were minor and 50 were major. The potential for vehicle accidents involving pit shipments was considered in the EIS analysis. It was concluded that it is not reasonably foreseeable that a vehicular accident on KAFB would occur with the severity necessary to result in a release of plutonium from an AT400A container within a Safe Secure Tractor Trailer (SST). As discussed in volume I, section 5.5.1, the controlled transportation route on KAFB does not contain threats that could create the severe environment required to lead to a dispersal of plutonium. In addition, base personnel traffic would be controlled as SST convoys pass through the base roads. Thus, other vehicles would not pose a threat to the SSTs while on KAFB.

Pit Pyrophoricity

Pyrophoricity is not a realistic concern during pit storage. Plutonium metal in large pieces (such as is present inside pits) does not burn upon exposure to air. Plutonium metal can be handled in air and is often processed and stored in normal air glove boxes. Spontaneous ignition only occurs when plutonium is present as particles less than 0.2 millimeter thick and then only on exposure to temperatures in excess of 150·C. Larger samples must be exposed to temperatures in excess of 500·C before ignition. Formation of such small particles is difficult.

Analysis of plutonium pits subjected to mechanical deformation or stress shows plutonium does not burn or spread as a result of chemical reaction with air. Plutonium oxide forms when plutonium metal or a compound of plutonium reacts with oxygen. The oxide forms an adherent layer on the metal surface and acts as a barrier that slows the rate at which additional oxygen can react. The oxide is the most stable compound of plutonium in an oxygen-containing environment.

Pits have been under careful scrutiny for many years through various DOE programs, particularly the Weapons Quality Assurance Testing Program, that includes the Pit Surveillance Program and an accelerated aging program, to ensure that aging-related defects do not develop in pits. A routine stockpile surveillance has been performed on the pits for 20 to 30 years in more hostile environments than Zone 4. Information from that surveillance indicates that containers will not be expected to degrade over the interim storage period.

The AT400A container is designed for a 50-year life. A pit and pit container surveillance program will continue for the AT400A container. This surveillance program will minimize the likelihood of undetected failure in the pits and/or containers.

Dosimetry Data

The DOE Transportation and Staging Department is responsible for pit storage activities as well as interzone transfers of nuclear material. Historical dosimetry data and a description of responsibilities for this department is provided in volume I, section 4.12.1. This historical dosimetry data was correlated with historical material transfers to estimate impacts from operations. The Transportation and Staging Department has a cumulative dose of 3.642 person-rem for 1995. This information is provided in volume I, section 4.12.1.3.

The dose estimate presented includes not only the expected doses from weapons transfers but also the expected doses from the interzone transfers of 20,000 pits as part of the pit repackaging project. The No Action Alternative dose numbers presented include not only the expected doses from weapons operations but also the expected doses from the interzone transfers of only 12,000 pits as part of the pit repackaging project.

The Proposed Action includes continued weapons operations and pit transfers for pit repackaging. For the pit storage relocation alternatives, both of these activities will be performed in addition to the activities associated with offsite pit shipments.

The offsite shipment of pits from Pantex Plant would require the removal of pits from the Zone 4 magazines and the loading and restraining of pits within an SST vehicle. The performance of these activities will increase the worker exposure total, as discussed in volume I, section 4.12.

1.3.9 Waste Management

Many comments questioned DOEs material management capabilities based on the Departments past history of managing hazardous materials like plutonium and wastes. Commentors questioned where all the waste would go, the lack of licensed facilities to manage DOE wastes, and management mistakes.

Several commentors asked what types of wastes and volumes of waste are generated during dismantlement operations and pit storage activities. Other commentors were concerned that relocation of pit storage activities would adversely impact candidate sites waste operations and environmental restoration activities.

Commentors questioned which activities were subject to RCRA regulation, permits, CERCLA regulation, and related impacts.

Waste Management (Including Hazardous Materials)

DOE recognizes that all its facilities and all its hazardous materials, including plutonium, require varying levels of operational and environmental controls to protect the workers, the public, and the environment. DOE is considering programmatic waste management strategies and solutions for the next 20 years under the WM PEIS to resolve vital waste management issues. Depending on the site, type of waste, and site management strategies, most waste disposal practices do not require licenses. Where DOE is required to obtain and maintain a license or permits (including Federal Facility Agreements and Agreed Orders), DOE continues to work with EPA, States, employees, unions, stakeholders, and the general public to develop programs and commitments to better manage its facilities and all hazardous materials, including wastes. All of these plans and commitments have been considered for the proposed sites to determine if there are any conflicts or restrictions that would inhibit these sites from serving as good locations for the facilities proposed in the EIS. Nothing was found that would inhibit Pantex Plant or the alternative sites from performing the required missions.

DOE understands the importance of the Ogallala aquifer as the principal aquifer and major source of water in the vicinity of Pantex Plant. Under the existing DOE environmental monitoring program, groundwater monitoring of the perched and Ogallala aquifer has been conducted at Pantex Plant for the past 20 years. Impacts of present and future water quality are discussed and analyzed in volume I, section 4.6. As discussed in volume I, section 1.3.5 and section 4.6, nothing was found that would result in a significant impact to the Ogallala aquifer.

Waste Types and Volumes

Pantex Plant generates primarily four categories of waste (low-level radioactive waste [LLW], low-level mixed waste [LLMW], hazardous waste [HW], and nonhazardous nonradioactive waste [NHW]) during the assembly and disassembly of nuclear weapons, certain maintenance and modification activities regarding the nuclear weapons stockpile, monitoring of nuclear weapons, and quality assurance testing of weapon components. Waste volume projections are provided in volume I, Table 4.13.1.23 and volume I, section 4.13.1.2, Waste Categories and Operations. Pit storage activities generate less than 1 cubic meter (1.3 cubic yards) annually of LLW, LLMW, HW, and NHW each. This small amount of waste would not impact current waste management and environmental restoration activities at candidate sites.

RCRA, CERCLA, Permits

DOE and regulatory organizations monitor the current hazardous material storage and surrounding environment. Pantex Plant operates under several permits, including operations at the Burning Ground. LLMW is managed in accordance with the Agreed Order and Site Treatment Plan-Compliance Plan, 30 TAC 335, the RCRA Part B Permit, and 40 CFR 260-280. LLW is managed in accordance with DOE requirements including the NTS Defense Waste Acceptance Criteria Certification and Transfer Requirement Program (NVO325).

In regard to past environmental management practices at Pantex Plant, in 1989 the EPA conducted a RCRA Facility Assessment resulting in a Consent Order to investigate and correct 144 solid waste management units. In 1991 the RCRA Facility Investigation was incorporated into the Pantex Plant RCRA Part B hazardous waste permit. Pantex Plant was placed on the Superfund National Priorities List in 1994. As restoration work continues, a tri-party Federal Facility Agreement is currently being negotiated to outline the reporting requirements, schedules, and funding for the ER program. According to the best available information, the majority of the ER activities are expected to be completed by the year 2000.

Pantex Plant continues to implement a Pollution Prevention/Waste Minimization (PP/WM) program to reduce environmental impacts through waste avoidance and waste minimization. This program was recently awarded the Presidents "Closing the Circle" award. Pantex Plant is one of only 22 Federal facilities to have won this award. Pantex Plant is also active in the Clean Texas 2000 pollution prevention program. Volume II, appendix G contains detailed information of the PP/WM.

The environmental impacts of waste management at Pantex Plant and the pit relocation alternative candidate sites, including the regulatory framework for LLW and LLMW, are discussed and analyzed in volume I, section 4.13, chapter 5, and chapter 6, as appropriate. KAFB is the only alternative storage site candidate that has a RCRA Part B permit issued to a non-DOE agency. If responsibilities for land and operations (all or in part) of the KAFB Manzano WSA changes from the Air Force to DOE, RCRA permit modifications would be required (see 40 CFR 270 criteria). These kinds of modifications are considered administrative in nature and require only regulatory agency approval.

NTS, SRS, and Hanford Site hazardous waste generation and mixed waste generation are covered under existing RCRA Part B permits or interim status permits. Clarifying language has been added to volume I, sections 5.5.1 and 6.5 regarding permitting issues, including mixed waste, as appropriate.

For DOE to continue to fulfill its responsibilities as mandated by statute, Presidential direction, and Congressional authorization and appropriation, the generation of solid waste including "nuclear waste" is an unavoidable result. Recently, in response to numerous public requests for independent regulatory oversight of radioactive source, special material, and by-product material, the Secretary has created an independent Working Group on External Regulation. This working group is presently reviewing various alternatives for external oversight of activities at DOEs nuclear facilities and is expected to submit a report by the end of 1996.

1.3.10 Human Health

Numerous commentors expressed their concern that all current and future operations at Pantex Plant be conducted in a safe and environmentally sound manner. This is the main thrust of essentially all the comments received on this topic. Many other comments questioned the origin of risk factors used to calculate health effects from radiological exposures. One commentor questioned why specific epidemiological studies were not discussed in the EIS. Several commentors questioned the adequacy of conclusions drawn from past epidemiological studies and expressed their desire for future studies.

Comments also were received regarding synergism between radiological and chemical exposure. Others requested further clarification of the risks from radiological exposure.

Health Effects

The primary purpose of the EIS is to provide the basis for DOE decision makers to make proper decisions regarding potential environmental impacts of current and future operations at Pantex Plant and alternative sites, taking into consideration all public concerns. DOE is committed to the safe operation of Pantex Plant, as well as the protection of the public, the environment, and the facility employees. Information regarding current and future operations at Pantex Plant are presented in various sections of the EIS as well as the Pantex Plant Environmental, Safety, and Programmatic Information Documents (Pantex 1996, 1996z, 1996a).

DOE uses risk factors that are recommended by both national and international radiological protection organizations. The public and occupational health risk for normal radiological operations analyzed in this EIS use the two dose-to-risk conversion factors for the public and workers established in the National Research Councils Committee on the Biological Effects of Ionizing Radiation BEIR V Report (NAP 1990). These risk factors have also been endorsed by the International Commission on Radiological Protection (IRCP), the National Committee on Radiation Protection and Measurements, the EPA, and the Nuclear Regulatory Commission. These risk factors are 0.0005 deaths per person-rem to the general public and 0.0004 deaths per person-rem for workers (the lower number for workers accounts for the absence of children in the workforce). This approach is consistent with other EISs prepared by DOE.

Both the BEIR committee and ICRP are independent organizations. As part of the development of risk factors, these organizations review appropriate epidemiological studies. Details on the epidemiological studies reviewed to develop the latest risk factors are available in the following document: BEIR V National Research Council, "Health Effects of Exposure to Low Levels of Radiation," National Academy Press, Washington, DC, 1990 (NAP 1990).

Past, present, and future health studies of Pantex Plant workers and the surrounding communities are described in volume I, section 4.14.1. To date, these studies indicate that there have been no significant excess cancer mortality incidences in the Pantex Plant area related to plant operations. There have been no verifiable indicators as to any short- or long-term health impacts at Pantex Plant. Public exposure to radiological effluents has conventionally been of extremely small dose due to DOE safeguards and the nature of the missions conducted at the facility.

DOE Headquarters Office of Epidemiological Studies initiated an epidemiological surveillance program at Pantex Plant in 1993 to address the current health status of the workforce. The program tracks and analyzes the occurrence of illness and injury on a continuing basis. Monthly data collection began on January 1, 1994; data and reports are issued on a semiannual basis. These reports provide an ongoing assessment of any health problems that may be associated with Pantex Plant operations. The Pantex Plant 1994 annual report is currently available.

One commentor referenced critiques of the 1985 Pantex Plant workforce mortality study (Geiger 1992). This document criticizes DOE epidemiological studies that compare health outcomes of DOE workers with those from the community at large.

Because workers tend to be healthier than the general public, potential adverse health outcomes from workplace radiological exposures may be missed in the comparison of DOE workers with the community at large (Healthy Worker Effect). The authors of the referenced Geiger report reanalyzed data from the 1985 Pantex Plant workforce mortality study with a proposed approach to account for the healthy worker effect. By using this approach, the authors suggested that numerous DOE epidemiological studies overlooked potential adverse health impacts. However, the approach suggested by the authors supports the conclusions of the 1985 mortality study (Aquavella 1985).

A follow-up of this 1985 mortality study is planned. The update will be conducted by National Institute of Occupational Safety and Health (NIOSH) as part of a research program funded by DOE under a Memorandum of Understanding with the Department of Health and Human Services. The follow-up study by NIOSH is scheduled to commence either in late 1996 or early 1997. The study will provide additional years of data on the mortality experience of Pantex Plant workers.

Chemical and Radiological Synergism

There is insufficient scientific evidence to quantify synergistic effects between radiation and chemical exposures, if any. Effects of these exposures are modeled individually using accepted scientific standards and models. The calculated effects from these exposures are shown individually to be extremely low.

Clarification of Radiological Risks

Volume I, section 4.14 provides an analysis of the potential health effects of the ongoing work at Pantex Plant and each of the alternatives. The health effects are expressed as excess cancer fatalities as a result of radiological exposures to workers and the public from normal operations and from accidents. The radiological exposures to the workers and the public can be estimated by models or by historical information. These exposures can be converted to excess cancer fatalities by using dose conversion factors.

Based on DOEs recommended risk factors of 0.0004 deaths per person-rem, an exposure of 330 person-rem will result in 0.13 excess cancer fatalities. A description of this calculation is provided in volume I, section 4.14. Another interpretation of this impact is the average number of excess cancer fatalities that would occur if numerous groups were exposed at this level. Because the value is small, the most likely impact from this exposure for an individual group is zero excess cancer fatalities. This description is provided in volume I, Figure 4.14.2.12, Evaluation of Risk. These two descriptions are entirely consistent. They differ only in the level of explanation.

1.3.11 Aircraft Crash

Many comments expressed concern regarding application of the Draft DOE Standard on Aircraft Crash Analysis, and why the values for hit probability changed from those presented in the 1993 Zone 4 Safety Analysis Report (SAR) and a 1994 Environmental Assessment (EA) (DOE 1994w).

Another frequent comment involved the consideration of the recent ValuJet crash in the analysis, including the consideration of this aircrafts high angle of impact (75 degrees).

Many citizen concerns involved the location of the Amarillo International Airport in relation to the plant. People also expressed concern about the number of flights taking-off and landing in connection with the modification and maintenance facility at the Amarillo International Airport.

Hit Probability

The 1993 Zone 4 SAR and 1994 EA results were found to be in error. The value of 1.85 x 10^-6 for hit probability was obtained through an incorrect application of the Solomon Model, and was later withdrawn from the safety basis for Pantex Plant. When this analysis was recalculated, the resulting value for hit probability was 1.95 x 10^-5. This low to mid 10^-5 range value agrees with the results obtained from two previous independent analyses conducted for Pantex Plant and also agrees with the results obtained for this EIS. Table 4.15.1.3-1 in volume I provides a comparison of results from these analyses.

Angle of Impact

Based on the recent tragedy of the ValuJet crash, commentors suggested that the analysis be redone with an impact angle of 75·, the estimated impact angle of this particular crash. The 15· impact angle used in the Draft EIS was chosen based on guidance provided in the July 1995 Draft DOE Standard (DOE 1995z). This value has been shown to be conservative. A sensitivity study was conducted using angles of impact ranging from 0· up to 90·. The results of this study indicated that the risks associated with high impact angles are approximately 10 times lower than those modeled for the Draft EIS because high impact angles result in zero skid distances. The results of the EIS analysis indicate that greater than 90 percent of the risk involves skidding aircraft.

Amarillo International Airport Operations

Pantex Plants is located near Amarillo International Airport. DOE, in association with the Federal Aviation Administration (FAA), is currently engaging in measures to reduce the number of overflights of Pantex Plant. These measures involve shifting the approach paths away from the plant, and include relocating the Very High Frequency Omni-Directional Radio Range with Tactical Air Navigation (VORTAC) and installation of a Global Positioning System (GPS). Currently, the Draft DOE Standard does not allow for consideration of these measures. It has been estimated that, when taken into account, the proposed overflight reduction measures could result in an 82 percent total relative risk reduction.

All of the post-maintenance flights referred to by the commentors must file with the FAA before an aircraft can embark. These aircraft must meet all of the same FAA requirements applicable to other aircraft. An experienced, certified crew will check the aircraft prior to the flight. These flights are included in the Radar Airspace Monitoring System (RAMS) data and FAA take-off and landing operations data for the Amarillo International Airport. These aircraft will be taking-off into the wind just like all other aircraft. The percentage of take-off operations on Runway 04, the main runway, (35.9 percent) was obtained from the windrose.

1.3.12 Intersite Transportation

Many commentors requested more information regarding the routes used by DOEs Transportation Safeguards Division (TSD) for hazardous material shipments. Additionally, many comments requested further information regarding the interaction between TSD and State and local agencies.

Several other commentors requested more information about the AT-400A transportation container.

TSD Operations

TSD operations comply with the requirements of 49 CFR 177 for selecting, notifying drivers thereof, and adhering to preferred routes. The majority (90 percent) of TSD travel is over interstate highways. The remaining 10 percent is over routes that meet specified conditions for deviating from the preferred route. Regulations permit deviation from the preferred route when necessary for safety or security. TSD personnel are briefed on construction, congestion and severe weather along the route prior to travel. TSD crews make every effort to alter a route or change travel time to avoid potential traffic hazards.

Federal regulations permit TSD deviation from the requirements regarding notification of the routes used. Routes used are classified, compartmented information that may not be disseminated except to persons with appropriate security clearance and a need to know.

TSD directs and manages an emergency management drill and exercise program that involves facility personnel, resources, and offsite elements. To stay proficient in all aspects of TSD convoy operations, TSD annually plans, implements, monitors, and performs follow-up analysis for couriers called in-service training (IST). For each iteration of IST, TSD invites participation from State police agencies. These police agencies train with TSD in all aspects of the program, but TSDs primary interest is in their participation in convoy tactical training with emphasis on law enforcement link-up in the case of an emergency. The present (FY 96) IST program has both Arkansas and Missouri State Police participation. In FY 95, the Arizona State Police and the Oklahoma State Police participated, and in 1994 the Texas Department of Public Safety participated.

TSD has a liaison program through which it communicates with law enforcement and public safety agencies throughout the country, making them aware of TSD operations. The liaison program provides law enforcement officers information to assist them in recognizing TSD vehicles should they be involved in an accident, and what actions to take in conjunction with the actions of the couriers in the rig and escort vehicles.

AT400A Containers

The design of the AT400A container is currently being finalized. There are only a few prototype containers in existence. The AT400A container is currently undergoing certification testing at Sandia National Laboratories (SNL). The performance criteria that the package designer must use to assess Type B packaging against empirically established hypothetical accident test conditions of the transport are prescribed in Nuclear Regulatory Commission regulations (10 CFR 71.73) and are discussed in appendix F of volume II.

Following certification testing by SNL, DOE will develop a Safety Analysis Report for Packaging (SARP) for the AT400A. The SARP provides DOE with a detailed safety analysis and risk assessment of the containers performance for its intended mission and expected useful lifetime. Following acceptance of the final SARP, DOE will issue a certification for the AT400A. The schedule for preparation of the SARP is not yet available.

To gain certification as a Type B package, the AT400A must pass the testing requirements developed by the Nuclear Regulatory Commission to ensure satisfactory performance under accident conditions. DOE has developed and will implement a pit and container surveillance program for the AT400A container. This program will evaluate the long-term performance of the container and the integrity of the pit.

Volume I, section 4.12 has been revised to include more information about the above topics.

1.3.13 Environmental Justice

Executive Order 12898 requires the analysis of environmental effects on low income and minority populations to include human health, social, and environmental effects. Commentors felt that the environmental justice analysis was limited to human health effects of the Proposed Action and did not include the social and economic effects as required by Executive Order 12898.

Commentors expressed concern regarding adequacy of training programs and safety information to workers and the community, especially regarding different literacy rates and/or primary language difficulties that might exist among disadvantaged populations.

There was also concern regarding the radiation exposure to workers and the minority community.

Environmental Justice Analysis

Social and economic (socioeconomic) impacts of the continued operations at Pantex Plant have been considered in volume I, section 4.11, Socioeconomic Resources. In volume I, section 4.17, Environmental Justice, the location of minority or low-income populations, identified on Figures 4.17.11 and 4.17.12 of the Draft EIS, leads to the conclusion that no disproportionately high social and economic impacts occur on minority or low-income populations from Pantex Plant operations. The text in the Final EIS has been revised to state this conclusion. Section 4.17.2 provides discussion of beneficial economic impacts to both majority and minority populations.

Human health impacts resulting from Pantex Plant operations are strongly tied to the geographic location of minority and low-income populations. If minority or low-income populations were concentrated in the immediate vicinity of the plant, there would be a possibility that such a population could be disproportionately impacted. The Pantex Plant EIS has analyzed the potential for offsite release in both routine and accident conditions and has not identified a release scenario that would cause a disproportionate effect on minority or low-income populations.

Concerns of all individuals, whether belonging to majority or a minority and whether living in urban or rural areas are taken into consideration within the overall context of the assessment of potential impacts on population in the ROI.

Training, Safety Information and Radiation Exposure

Health and safety issues are an important part of Pantex Plant operations and have been taken into consideration in this EIS. Occupational Safety and Health Administration and implementing DOE Orders address safety and health issues for all workers at Pantex Plant regardless of minority or income status, including radiation exposure. Operations at the plant expose workers to occupational hazards during the normal conduct of their work activities. Occupational safety and health training that includes specialized job safety and health training appropriate to the work performed is provided for all plant employees.

DOE and Pantex Plant have initiated a broad program of improving communication with the public by providing fact sheets, speakers, exhibits, information fairs, open houses, and presentations with material geared to elementary school students. In addition, specific inquiries can be made to the Pantex Plant information office to obtain further information on training programs and plant safety. Additional information on worker safety is provided in volume I, section 4.14.1.5.

1.3.14 DOE Policy

Numerous comments were received opposing the storage and reprocessing of plutonium at Pantex Plant. These individuals were concerned about the possibility that plutonium could contaminate the environment. They would like to see all operations in this area halted.

Concern was also voiced for additional independent regulatory oversight at the plant. TNRCC feels that the public would be better served, and that there would be less potential for errors in waste management, if oversight responsibilities at the plant were shared. There were suggestions that State and Federal Trustees should be consulted during the remedial process so that appropriate restoration activities could be incorporated into remedial actions at the plant.

Several commentors were concerned with the lack of specific information in the EIS regarding international controls and inspections of the pits at Pantex Plant and the alternate site locations.

Storage and Reprocessing

DOE is committed to the continuance of, and the continued development of, programs and directives to better manage its facilities throughout the Nation. DOE operation of Pantex Plant is conducted through varying levels of operational and environmental controls to protect the workers, the public and the environment. The probability of contamination from interim pit storage was determined to be unlikely based on the analysis performed in this EIS. The existence of the pits is a reality. Handling them with the utmost care and security until a long-term solution is available is the focus of this document. The Department is working to address present and future issues in the nuclear industry in a manner that benefits everyone.

Regulatory Oversight

There are numerous measures in place at the plant to monitor and update compliance standards for all phases of work performed. DOE has an ongoing commitment to work with EPA, TNRCC, stakeholders, and the general public to further the development of the Pantex Plant ER Program. The areas of personal safety to workers and the surrounding population, as well as numerous environmental regulations, are in effect to address these issues before they become concerns. To address this concern, the Secretary created a Working Group on External Regulation to review the alternatives for all activities conducted at DOEs nuclear facilities. A report from this working group is expected to be released in late 1996.

International Inspection

DOE has not yet established its procedures for international surveillance or inspections of pits. Details concerning the frequency of the inspections and the manner of inspections has yet to be established. Accessibility to the pit storage locations at pit storage sites will be addressed in future DOE policy. This issue was not considered to be a significant factor in the selection of Pantex Plant or any of the other four alternate sites.

1.3.15 NEPA Process and Procedures

Many commentors questioned whether they could trust the Pantex Plant EIS. Commentors expressed concern that too little information was presented, analysis was limited, and the document was too narrow in scope to adequately address the issues at Pantex Plant.

Numerous concerns were voiced regarding the effectiveness of the notification for the public hearings. Individuals felt that there was not enough advance notice of the meetings, that the scheduling was difficult for working people to attend, and that the announcement was not reaching a racially diverse representation of the concerned public.

Several comments were made regarding the lack of cost information relative to Pantex Plant and alternate sites. There was also concern that the significance of impacts was not uniformly discussed as required by the CEQ guidelines.

Other commentors noted that it was difficult to review two PEISs and the Pantex Plant EIS at the same time, due to the short review period and the size of the documents. It was also stated that the document is too complicated for individuals of limited education in the affected areas to read, and a request was made to find an alternate means of informing the public of the contents of the document.

Amount of Information Presented

The Pantex Plant EIS was prepared in accordance with the CEQ Regulations for Implementing the Procedural Provisions of the National Environment Policy Act (40 CFR 1500-1508) and DOE NEPA Regulations (10 CFR 1021). These regulations describe how to comply with the "action forcing" procedures of NEPA.

NEPA requires that the government assess any major Federal action that may significantly affect the quality of human environment. It requires the government to seriously consider these impacts and make that information available to public officials and citizens before decisions are made and actions are taken. The decision maker may, however, take into consideration not only environmental, but also economic, technical, and other factors, such as national security, before a final decision on project implementation is made. This decision is published in a ROD.

DOE has presented a "full and fair discussion of significant environmental impacts" and has "informed the decision makers and the public of the reasonable alternatives which would avoid or minimize adverse impacts or enhance the quality of the human environment." As directed, DOE has focused on significant environmental issues and alternatives, while reducing an accumulation of extraneous background data in the EIS. Sources of additional information are referenced throughout the EIS.

Public Notification

Public scoping and commenting requirements are addressed in 40 CFR 1501.7 and 1503, respectively. The Pantex Plant EIS followed this direction in its attempts to reach the broadest area of citizenry possible. Comments were requested from Federal, State, and local agencies, concerned citizen groups, and individuals who had expressed an interest during the scoping process or while the document was being prepared. Notices were publicized in the Federal Register, as well as in local newspapers and radio spots. Public hearings and meetings were held, fact sheets were distributed, and e-mail and telephone contacts were provided, as well as addresses of DOE personnel to whom citizens could mail comments and information requests.

In an effort to accommodate citizens work schedules, public hearings in Texas were held throughout the day, as well as late into the evening. Except for Nevada, all hearings were held with afternoon and evening sessions to encourage public attendance. DOE realizes that this is not a perfect system. There are some individuals that will not receive notification and that will not be able to attend the public hearings. Although the law does not require additional notification, DOE will take these concerns into consideration for future EISs.

Although the Notice of Availability for the Draft EIS was issued less than a month before the first public hearing was conducted, the comment period was extended to July 12, 1996, during which time the public could submit comments in writing, by telephone, at a technical information exchange meeting, or via electronic mail. CEQ regulations require a minimum comment period of 45 days. For this EIS, the Department extended the comment period to 98 days. Comments were accepted as late as July 29, 1996.

Each of the documents (SSM PEIS, S&D PEIS, and Pantex Plant EIS) had a public comment period, inclusive of public hearings/meetings as required by NEPA. During this time, the public was encouraged to comment orally at the hearings, in writing, by telephone, or by e-mail. The comment periods for these documents overlapped. It was felt that the public would be better served to have one meeting whenever possible to discuss as many of the documents as appropriate, depending on the geographical location of the meeting. This format also addressed prior stakeholder requests to reduce the number of meetings the public had to attend. The effort was intended to provide the public with as much information as possible and to allow for as long a comment period as could be scheduled.

The workshop format used for the public hearings was also a response to stakeholder requests for this type of format. The entire hearing structure, including the joint presentation of the three EISs, the workshop format, the time periods for formal testimony, the provision of space for displays by citizen groups, and the times for sessions, were planned in consultation with the Pantex Plant Citizens Advisory Board.

Cost and Other Information

The NEPA process is not a cost-benefit analysis process. Rather, the law requires that a NEPA document be prepared to ensure that environmental impacts are documented before any decision is made on a major Federal action. Costs are not required in order to assess environmental impacts. volume I, chapter 4 describes the affected environment and the potential environmental impacts expected from the continued operations of Pantex Plant, as well as the associated interim storage of nuclear weapon components. Non-environmental issues such as cost differences among the alternatives have not been developed for this EIS. The technical aspects of dismantling pits are information that is not available in public documents for security reasons. Plutonium processing is not an alternative covered in this EIS. Long-term management of the nuclear stockpile is within the scope of the SSM PEIS, while long-term storage and the final disposition of plutonium is addressed in the S&D PEIS.

The CEQ regulations require each Federal agency to interpret and administer the policies, regulations, and public laws in accordance with NEPA and the CEQ Regulations, and to implement procedures to make the NEPA process more useful to the decision maker and the public (40 CFR 1500.2). CEQ Regulations further state that "significantly" as used in NEPA requires considerations of both "context" and "intensity" (40 CFR 1508.27). Context means that significance of an action must be analyzed in several contexts, such as the society as a whole, the affected region, the affected interests, and the locality. Intensity refers to the severity of impacts and is examined using 10 criteria that are discussed in 40 CFR 1508.27. In other words, significance is a judgement rather than a defined outcome.

In consideration of the guidance contained in the CEQ regulations, DOE pursues a policy of presenting the facts regarding the potential environmental impacts of each resource area without drawing conclusions as to the significance of those impacts in the EIS itself. The reader is allowed to draw his/her own conclusions about the significance based upon the facts presented. Likewise, the decision maker considers the facts presented in each resource area, as well as the cumulative impacts in terms of both context and intensity. The judgement of the decision maker as to the significance of these impacts is then considered along with other factors such as national policy, Departmental mission, and technical considerations in making the decision on a course of action.

Several of the commentors have suggested a need for the government to develop a means of reaching individuals of limited education. DOE will continue its efforts to reach the broadest possible segments of affected populations when discussing its proposed activities.

1.3.16 Out of Scope

Many comments were received in support of continuation or expansion of the existing mission at the Pantex Plant. Other comments expressed a general opposition to plutonium processing or nuclear storage at the Pantex Plant.

Many comments were received that were outside the scope of this particular EIS. For example, comments about the underground testing of nuclear weapons at NTS are outside the scope of the Pantex Plant EIS. Out of scope comments were noted but not responded to in this EIS.

In addition, many remarks were not identified as individual comments. For clarity, statements collected during the comment period were identified as "comments" when they specifically relate to the discussions of the alternatives and environmental analyses in the EIS. The Departments responses to these comments are provided in this volume of the EIS. Conversely, general expressions of convictions, personal opinions, or support for or opposition to the continued operation of Pantex Plant are termed "remarks" and are acknowledged, but not provided responses in the EIS.

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