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

CHAPTER 3 COMMENT RESPONSES

INTRODUCTION

Chapter 3 provides responses to all comments received during the public comment period.

Section 3.2 below explains how to find information in this chapter. However, the "green" pages at the very front of this volume also provide another, easily located set of instructions for locating documents and comments that are of particular interest.

ORGANIZATION OF THIS CHAPTER

The comments appearing in this chapter are categorized and organized according to their topic, or resource category. The sequencing of resource categories is as follows:

Alternatives (01)
Relationship to other EISs (02)
Infrastructure (03)
Land use (04)
Geology and soils (05)
Water resources (06)
Air quality (07)
Acoustics (08)
Biotic resources (09)
Cultural resources (10)
Socioeconomic resources (11)
Intrasite transportation (12)
Waste management (13)
Human health (14)
Aircraft crash (15)
Intersite transportation (16)
Environmental justice (17)
Irreversible and irretrievable commitment of resources (18)
Unavoidable adverse environmental impacts (19)
Relationship between short and long term effects (20)
Cumulative impacts (21)
DOE policy (22)
NEPA process and procedures (23)
Miscellaneous (24)

The parenthetical code after each of the above categories comprises the first two characters of comment numbers for that topic category. For example, all comment numbers relating to water resources begin with "06".

It should be noted that during the public hearings, DOE pursued a policy of suggesting, but not requiring, people to identify themselves whenever they made a comment. Whenever a person identified himself or herself, that identification was made in the record of the hearing. When the person did not identify himself or herself, an anonymous identification (such as unidentified speaker) was entered into the transcript. This policy allowed a person to choose whether he or she wished the public record to identify himself or herself with the particular comment. In addition, some of the postcards submitted had illegible signatures. Thus, for these two reasons, there are numerous comments attributed to unidentified commentors.

COMMENTS AND RESPONSES

In the following subsections, the comments and their responses are placed in Comment Number sequence as shown in the marginal code labeled "RC", for resource category. Thus all comments pertaining to alternatives (resource category "01") are listed together. Following them are the comments pertaining to the relationship of this EIS to other EISs (resource category 02), etc.

3.1 Alternatives

RC: 01.001

Doc: HT11/16

[At]...Kirtland Air Force Base...they already have how many [plutonium pits] stored...in the Manzano Mountains?... Because Ive been told otherwise that there [are] a lot of pits stored in the Manzano Mountains.

Response:

In confirmation to the response given at the public hearing, there are no pits stored in the Manzano Mountains as identified in volume I, section 5.5. The Manzano Weapon Storage Area was deactivated by the Department of Defense in June 1992, including deactivation of the Perimeter Intrusion Detection and Alarm System. Since 1990, intersite transportation of pits to Rocky Flats has discontinued. Pantex Plant remains the primary location for interim pit storage. The Manzano Weapon Storage Area is only being considered as an alternate interim pit storage facility. Selection of this site as an alternative is discussed in volume I, section 3.1.4.

RC: 01.002

Doc: HT11/17

So starting in the P-tunnel [NTS], would that mean that youd be opening it up where those tests happened and taking the pits into the assembly?

How far away from the actual tests are they stored from the sealed area?

Response:

Test areas at NTS would remain sealed and would not be disturbed. The side tunnels used for previous nuclear tests are all permanently sealed off. These areas are not expected to affect pit storage activities. Further, the Defense Nuclear Agency (DNA) nuclear explosives program has been suspended. Should the tunnel be used for pit storage and the DNA nuclear explosives program resume, a new tunnel could be created for that program.

RC: 01.003

Doc: HT11/18

How about the device assembly facility, what kind of place is that where the other pits are [stored]?

Response:

The following detail is provided in addition to the response given at the public hearing. The Device Assembly Facility (DAF) was constructed to perform assembly and disassembly of nuclear test devices and as a backup nuclear weapon assembly/disassembly facility to Pantex Plant. It is constructed with assembly cells and bays which could be used for pit storage. No pits are currently in storage at this facility.

RC: 01.004

Doc: HT11/28

Whats the difference between continuing the current mission and no action?

Response:

To reiterate the response given at the public hearing, there is no difference. The current mission is the No Action in this EIS.

RC: 01.005

Doc: HT14/1

Any plutonium or special nuclear material storage disposal program must be compatible and integrated with the Tri-Party Agreement commitments and milestones and should not affect the rate or funding of cleanup. The program would have the safe disposition of plutonium as a priority.

Response:

The Hanford Site Tri-Party Agreement is an agreement among the U.S. Environmental Protection Agency, Washington State Department of Ecology, and DOE for achieving the compliance with the remedial action provisions of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and with treatment, storage, and disposal unit regulation and corrective action provisions of the Resource Conservation and Recovery Act (RCRA). Pit storage operations are regulated by the Atomic Energy Act.

RC: 01.006

Doc: HT05/8

From an environmental standpoint, what changes when you go from 12,000 pits to 20,000 pits? You seem to have made a fairly substantial deal out of going from 12,000 to 20,000 [pits]. And I wondered if there was anything more to it than what youve just said. What should those of us concerned about the environment worry about going up to 20,000 pits?

Response:

To elaborate on the response given at the public hearing, no new construction of pit storage magazines would be required at Pantex as a result of increasing interim storage to 20,000 pits. Therefore, little to no changes in plant facilities and infrastructure, land resources, geology and soils, water resources, air quality, acoustics, biotic resources, cultural resources, socioeconomics, waste management, and environmental justice are expected.

Pit storage itself has no impact on the environment other than a small amount of radioactive exposure to workers, and should an accident occur, to the public. As Pantex Plant interim pit storage increases from 12,000 to 20,000, a person in the vicinity of Pantex Plant has a slight increase in fatal cancer risk (4.3 x 10-12) from potential aircraft crash plutonium dispersal accidents compared with the baseline annual cancer risk of 1.7 x 10-3.

Clarifying language regarding pit storage activities has been added to intrasite transportation and human health sections as Pantex Plant increases storage from 12,000 to 20,000 pits.

The commentor is referred to volume I sections on Impacts of Proposed Action (4.3.2, 4.4.2, 4.5.2,... 4.16.2) for additional information.

RC: 01.007

Doc: HT13/1

The document talks about the 120-odd bunkers and then it talks about the 41 [magazines] that are actually in the mountain, and on [page] 5-55, it says that more than 30 of these 41 magazines have a minimum overburden of 9 meters, and six pages later, it says 35, so I just first want to get some clarification about the bunkers that we are talking about.

How many are there, and is the positionand Nan may be able to answer this as well as the Major, is the position [such] that if storage happened at Manzano, only the bunkers with at least the minimum 9-meter overburden would be used?

So how many of the 41 [magazines] actually meet that standard?

Response:

Volume I, section 5.5, has been clarified to discuss only the 35 magazines with a minimum overburden of 9 meters (30 feet).

For the 20,000-pit storage option, approximately 25 of the 35 Type D magazines would be utilized. For the 8,000-pit storage option, approximately 10 of the 35 Type D magazines would be utilized.

The minimum 9-meter (30-foot) overburden was used to reasonably assess impacts for comparison purposes with the other interim storage alternatives. Volume I, section 5.5.1, discusses and analyzes the impacts of storage at Manzano.

RC: 01.008

Doc: HT13/6

I am interested in knowing, since there are 41 identified bunkers in the mountain, and 20 or so, up to 25 could be used if all 20,000 pits would come, what is the present and continuing mission for the other nearby bunkers? What would be in them? What would happen to them? What effect does storing pits have on those bunkers that could affect the mountain and the pit storage?

Are they going to be answered in the context of between now and the time of the final EIS?

Response:

To elaborate on the response given in the public hearing, the storage of pits in certain bunkers is not expected to impact the continuing mission of the other nearby bunkers. At Pantex Plant Zone 4, multi-purpose operations (i.e., storage of weapons, pits, components, high explosives, wastes, environmental monitoring supplies, maintenance equipment) all occur within the same area as pit storage without any problems. The storage of other materials in the remaining 81 bunkers at Manzano would continue. The "Phase I Environmental Baseline SurveyManzano Weapons Storage Area" contains brief descriptions of the storage activities at Manzano.

The environmental impacts of interim storage of pits at Kirtland Air Force Base are discussed and analyzed in volume I, section 5.5.

RC: 01.009

Doc: HT13/23

Does anybody else want to jump in before I go into some other things? How did the 20,000 number get established, 20,000 pits?

Why is that the bounding number since when we started dismantlement, we had considerably more warheads than that?

It is a public number that the United States in the 80s had well over 25,000 nuclear weapons. It is also a well-established number in the START II treaty, which has been ratified by the senate of the United States, that the goal would be down to 3,500 warheads. So on the face of it, we would dismantle more -- from dismantlement, we would have more than 20,000 pits.

Let me ask the question [a] little differently. Isnt it true that the 20,000 number was first used by the Department of Energy in an Environmental Assessment done three years ago, more or less, at Pantex, which was an environmental assessment that said, "Lets do this interim storage of 20,000 pits at Pantex?" That is the first place that I am aware of that the Department used that number. Is that not true?

That number is a pre-START II ratification number, and it appears to me it is a pre-START II number in any case, and the real question is to put it in the context of the sitewide. The sitewide says there is the potential of handling up to 2,000 weapons a year in terms of the analysis of the operation at Pantex, it talks about up to 2,000 a year, although it assumes that a more likely number is 1,000 a year during this ten-year time frame.

Isnt it the case,...in terms of Pantex and the numbers of pits, that during the next ten years, there could be more than 20,000 pits?

Response:

Regardless of the number of operations per year, interim storage of up to 20,000 pits would be consistent with dismantlement to START II stockpile levels. The EIS analysis assumes that combined activities of assembly, disassembly, and modification would not exceed operations on 2,000 weapons per year. For assessment of environmental impacts, the EIS examines impacts across a reasonable range of activity levels by assessing impacts of activity levels for operations on 2,000, 1,000, and 500 weapons per year.

Operations on these numbers of weapons per year represent a reasonable, but conservative estimate of work that may be required at the plant, based on current policy directives, and allow a set of defined tasks to be accurately analyzed. The operations on each of the weapons in these defined sets are assumed to be extensive (representative of full assembly or disassembly). Actual workload and range of tasks are well understood, and impacts of actual operations are expected to be encompassed by this conservative analysis. Accordingly, over 2,000 weapons per year may be worked on at Pantex Plant without exceeding the environmental impacts identified in this conservative bounding analysis. The 2,000, 1,000, and 500 weapons activity levels should not be considered specific limits.

RC: 01.010

Doc: HT13/24

Is 20,000 pits for interim storage actually a bounding number or, within the next ten years, could the number actually be higher than that? [This] is the specific issue I would like to see addressed [in the final EIS].

Response:

See discussion in section 1.3.1 of this volume regarding the basis for 20,000 pit storage limit. The number of pits stored at Pantex Plant would not exceed 20,000 without appropriate NEPA review.

RC: 01.011

Doc: HT13/25

Two questions in that regard: one is that if, in fact, the Department is taking the position that they would have to somehow supplement this or some other NEPA document before they completed 20,000, that should be expressly stated, and if that is not the Departments position, that specific statement needs to be made in this document and in the ROD.

Related to that, I would also request that the document analyze where the 20,000 number came from and how that would relate specifically to less than START II levels of dismantlement.

Response:

DOE may supplement or revise the Pantex EIS as a result of changes other than interim storage issues. However, DOE expects to review the environmental impact analysis contained in the Pantex EIS before the year 2007 as part of the agencys ongoing compliance responsibilities under NEPA, regardless of the number of pits placed into storage. In regard to the 20,000 storage level, see response to comment 01.009.

RC: 01.012

Doc: HT13/26

I am going to throw out something, that you drop [Manzano] from this project because it is not going to be a permanent storage [site]. You should get your act together and put [plutonium] where it is finally going to be. Put [plutonium] at one of the places that will be a permanent storage because of the fact that you, yourself, have said [Manzano] is only considered able to handle the plutonium and not others, and this is only interim. Well, just wait and put [plutonium] where it is finally going. Get your other plan together, decide it, pick a site and hold onto it until then.

Response:

See discussion in section 1.3.1 regarding site selection process and section 1.3.2 in this volume regarding site attributes.

RC: 01.013

Doc: HT13/31

How many bunkers are required for 20,000 pits?

Response:

Approximately 25 Type D magazines are required for interim storage of pits at Kirtland Air Force Base. At Pantex, 18 Modified Richmond magazines and 42 Steel Arch Construction magazines have been identified for storage of pits. Structures other than magazines would be used at other sites.

RC: 01.014

Doc: HT13/42

Is there a justification for continued exploration and alternative forms of high explosives [HE] at this point in time that would justify the health and environmental risk?

Response:

To elaborate on the response given at the public hearing, high explosives research and development, including testing, is an essential part of stockpile maintenance. As long as there is a stockpile, this function must be performed. The original Notice of Intent for the Pantex Site-Wide EIS (59 FR 26635) included the possibility of relocating some or all of Pantex Plant operations as part of the Relocation Alternative, including HE operations. Upon further review, it was determined that the relocation of operations, including high explosive operations, from Pantex Plant within the time period of this EIS does not meet the purpose and need for DOE to maintain minimum disruption of weapon disassembly operations. The commentor is referred to volume I, chapter 2, Purpose and Need for Action, for additional information. The Stockpile PEIS assesses alternatives for the explosive operations at Pantex Plant.

RC: 01.015

Doc: HT13/79

As I imagine the process then, they go through a series of disassembly of the can subassembly to separate the different layers of metal, et cetera, so the final storage of the can subassemblies, is that considered anywhere?

Response:

The Disposition of Surplus Highly Enriched Uranium Final Environmental Impact Statement discusses and analyzes the disposition of surplus canned subassemblies of highly enriched uranium (HEU) at Oak Ridge Reservation (ORR).

Only the transportation of HEU and depleted uranium components from Pantex Plant to ORR for storage, processing, and staging is addressed in this EIS.

RC: 01.016

Doc: HT13/87

Pantex has a high degree of public support in the region. In repeated polling, it has registered over 80 percent for continued operation of the plant. The discussions here tonight about the deficiencies in the high explosives program, I think, are misguided, and Pantex should be selected as a preferred alternative in the other PEIS, the SS&M PEIS, for continuation of high explosives.

I make those comments on the record as Bob Juba with the Amarillo Economic Development Corporation speaking with the endorsement of the city government of Amarillo.

Response:

The original Notice of Intent for the Pantex EIS (59 FR 26635) included the possibility of relocating some or all of Pantex Plant operations as part of the Relocation Alternative. Upon further review, it was determined that the relocation of operations, including high explosive operations, from Pantex Plant within the time period of this EIS does not meet the purpose and need for DOE to maintain minimum disruption of weapon disassembly operations.

Programmatically, for the longer term, consideration of the attributes of Pantex Plants high explosive capabilities, as well as each of the alternatives considered for siting high explosive operations, would be part of the decision process in the SSM PEIS.

RC: 01.017

Doc: HT13/80

I wouldnt be incorrect in assuming that there is much more processing of a can subassembly that has to go on before it is ready for some sort of storage and the processing involved in the plutonium pit once it is removed? Is that correct?

Response:

The Disposition of Surplus Highly Enriched Uranium Final Environmental Impact Statement analyzes the disposition of canned subassemblies of HEU at Oak Ridge.

RC: 01.018

Doc: HT12/26

Im curious [about] whats being done to upgrade and correct that before you talk about putting more there. Also, I have the general comment that storage at Pantex is, like a lot of other DOE programs..., really...only interim action. It really doesnt lead to anything. These pits eventually are either going to be in the strategic reserves, stockpile management program or the disposition program, and really youre a lot better off with bringing them...to Savannah River where you get this energy of feeding into other programs because Pantex is not an operating plutonium site. ...You just say, well, we dont really have nuclear facilities, we really dont have plutonium facilities. To do these other missions you need those. So my general comment is that you ought to look at putting them [the pits] at a functional plutonium site, [of] which there really only happens to be one.

Response:

The scope of the Pantex Plant EIS encompasses the ongoing operations, including interim pit storage, transporting pits to and storing on an interim basis at an alternative site (e.g. Savannah River Site), and transporting classified components between Pantex Plant and other sites. Pantex Plant already has capabilities to perform all these missions.

In addition, see discussion in section 1.3.2 of this volume regarding site attributes.

RC: 01.019

Doc: PC-006/1

Pits at Pantex are managed in facilities and operations [that] do not meet any of the DOEs standards for design and operation of nuclear facilities. Doubling the storage of pits under substandard conditions should not be considered a reasonable alternative.

Response:

Pit storage activities are not considered a high hazard operation as defined by the term "nuclear facility" in appropriate DOE standards. Storage magazines are defined as category 2 "non reactor nuclear facility." After repackaging of pits into AT-400A containers, the moderate hazard designation is further reduced.

DOE disagrees with the commentor that current pit management operations are substandard. The Pantex safety record is excellent. The environmental impacts of interim pit storage at Pantex have been discussed and analyzed, including potential Human Health impacts due to accident scenarios, in this EIS.

RC: 01.020

Doc: PC-024/3

P. S-7, left column, "No Action Alternative," 2nd paragraph, 5th line. The construction of the Hazardous Waste Treatment and Processing Facility should not be excluded under this alternative. Proposals, which make the No Action Alternative unreasonable under NEPA, should not be included.

Response:

In the March 1996 Draft version of the Pantex Plant EIS, the proposed construction of the Hazardous Waste Treatment and Processing Facility (HWTPF) was considered necessary for enhancing waste operational efficiency and safety and meeting regulatory requirements established in the Agreed Order. With offsite disposal shipments of mixed waste in 1994 and two shipments in 1996, as noted in volume I, section 4.13.2.3, and changes contained in the August 1996 FFCA Compliance Plan Annual Update document, construction of the HWTPF is no longer considered a regulatory requirement. However, without the HWTPF, waste treatment and processing capabilities remain greatly limited and do not meet the Departments purpose and need. This information has been incorporated throughout volumes I and II, as appropriate.

RC: 01.021

Doc: HT16/40

...my specific question relates to appendix H-14, where on the pit reuse facility it talks about the glovebox type operations and the glovebox bays that will be included in this facility. I guess I have a couple of questions related to that. How many glovebox type enclosures are currently operating at Pantex?

Response:

There were 9 gloveboxes in use at Pantex Plant in August 1996.

RC: 01.022

Doc: HT17/21

The other comment has to do with the assumption that in the no action alternative,...when you reach the 12,000 pits, disassembly would have to cease. Its really hard for me to believe that you [do] not have more creative minds in the Department of Energy than this. If you can justify interim storage of 12,000 pits at Pantex on the basis of an environmental assessment, I would surely think that you could find ways to justify interim storage of pits at other locations until all of the issues that need to be resolved are resolved.

Response:

See discussion in section 1.3.1 of this volume regarding the basis for 20,000 pit storage limit and section 1.3.2 of this volume regarding the relationship between the other EISs.

RC: 01.023

Doc: HT17/22

The unstated question, of course, is whether or not youre going to attempt to do processing of plutonium in the Panhandle. Thats the primary reason that I believe most people here are opposed to the storage. Its not so much the risk of storage, which is, at least to my estimates, not very great. Its the possibility that you will later use the Pantex facility as a staging ground for the processing of plutonium, either taking the contents of the pits and making them into fuel rods or perhaps reprocessing spent fuel rods.

Response:

The Proposed Action and alternatives for the Pantex EIS do not involve processing of pits into any other form. Nor do the alternatives of this EIS analyze a proposal for Pantex to reprocess spent fuel rods. In addition, see discussion in section 1.3.2 of this volume regarding the relationship of the S&D PEIS.

RC: 01.024

Doc: HT17/39

This document under review today does not meet the commitments made to the citizens of this area in DOEs agreement two years ago. The examination of alternative storage sites seems halfhearted at best. If the effort is brought short because of the threat to Albuquerque in using the existing Manzano Mountain facility, what are the citizens of Gray and Potter Counties to make of the governments regard for their safety.

Response:

In response to Item 1: As described in volume I, section 3.1.4, 60 DOD installations were screened by the Nuclear Weapons Council staff. With the exceptions of the Manzano Weapon Storage Area, located on Kirtland Air Force Base and Seneca Army Depot, the Council staff determined that none were feasible. In addition, see discussion in section 1.3.1 of this volume regarding the Site Selection Process.

In response to Item 2: 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 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.

RC: 01.025

Doc: HT17/41

...area residents are entitled to have a better idea of what the waste handling facility and the pit reuse facility really do imply for our future.

Response:

The commentor is referred to volume II, appendix H. The proposed waste handling facility would improve the Plants ability to handle its own wastes and enable fulfillment of the Agreed Order (Federal Facility Agreement) with the State of Texas. The pit reuse facility would not have the ability to process plutonium into any other form. It would merely support operations on the surface of the pits.

RC: 01.026

Doc: HT17/53

It has been really difficult for me to read things like...we have 12,000 pits at Pantex and no other [if] arrangements are made, then dismantlement will stop. It is a real frustration to read a line like that, and it feels very disingenuous. One of the reasons that citizens groups such as mine press so hard for this document and work so hard for those issues, is that we could not believe that the Department of Energy was going to take the posture of we either store them all in one place, we have no backup.

Response:

The No Action Alternative describes conditions that would result if the Department should not undertake to change the status quo. The No Action Alternative does not have to be reasonable, and frequently is not. Rather, the No Action Alternative is intended to provide a baseline for comparison. Frequently, as in this case, the consequences of continuing the status quo also serve to point out quite clearly that an action is needed. In the case of this EIS, the Department has a Proposed Action to put up to 20, 000 pits in storage at Pantex Plant, and an alternative of relocating up to 20,000 pits to one of four other sites for interim storage. The Department will not store pits at Pantex Plant beyond the current 12,000-pit level without examining the environmental impacts of storing an additional 8,000 pits. This EIS has been prepared in accordance with requirements of NEPA and CEQ Regulations specifically to allow the Secretary of Energy to make decisions that will permit continued dismantlement of all weapons retired from the stockpile as well as to continue other operations of the plant.

RC: 01.027

Doc: HT17/63

...in terms of Nans characterization that the reason to do the no action alternative is to provide a good baseline for what impacts of other alternatives and other actions would be, I think in numerous cases a [poor] job was done....

Response:

DOE believes the Pantex Plant EIS is an effective document. See response to comment 01.026.

RC: 01.028

Doc: HT17/67

...its inconceivable that you could be saying that continued storage at Pantex of pits, if that were to happen for the next ten years, would be done for that entire time in Zone 4. And so youre going to need to look explicitly in this document at the alternative locations for that, the impacts and effects of that, et cetera.

Response:

At Pantex, 18 Modified Richmond magazines and 42 Steel Arch Construction magazines have been identified for storage of pits. No new facilities are required to store up to 20,000 pits. Environmental impacts at the alternative sites have been discussed and analyzed in volume I, chapter 5.

New pit storage facilities and upgrades to existing pit storage facilities are within the scope of the S&D PEIS and SSM PEIS.

RC: 01.029

Doc: FG-003/1

The DEIS makes reference to "interim storage" of plutonium pits at three DOE sites (Nevada; South Carolina; Washington State) and a Department of Defense site at Kirtland Air Force Base, New Mexico. However, the DEIS did not define what constitutes "interim storage," either a fixed period of years or decades, or until a permanent storage facility is approved, upgraded or built. If possible, the Pantex FEIS should define the minimum and maximum time limits expected by DOE for "interim storage" (we recognize the difficulty in this because nuclear storage projects often run into problems that delay their proposed timeliness).

Response:

Interim storage refers to the time period until the long-term storage decisions are made and implemented.

RC: 01.030

Doc: FG-003/3

It would be helpful if the Final EIS could provide the tonnage of the 8,000 to 20,000 pits that would be relocated under the interim pit storage alternative. If allowable under the national security considerations, it is recommended that the FEIS quantify the weight in terms of plutonium [Pu], other nuclear material, and other constituents such as Resource Conservation and Recovery Act (RCRA) regulated hazardous waste.

Response:

The actual amount of plutonium contained in a pit is classified. Because of this, it is DOEs policy to present the amount of Pu at Pantex in terms of the number of pits. The composition of other nuclear material, metals, and other constituents in a pit is classified. However, there are no RCRA regulated wastes in the pit form.

RC: 01.031

Doc: MG-002/3

There is information that leads Clark County to question the intent of DOE to actively pursue action alternative of storage of pits at the Pantex Plant. The DEIS makes reference to extensive restoration work that is being planned or is in progress at the Pantex and Hanford sites. We question whether it is sound policy to conduct such environmental restoration work at Pantex, a majority [of] which will be completed by 2000, and then store the plutonium pits on site, even for the short term. Given this, it would appear the pit storage relocation alternative may be more attractive than is presently represented in the DEIS. And, the NTS may emerge as the most feasible site for such relocation, since it is relatively close to the Pantex Plant, there are minimal environmental restoration plans for the NTS [as compared to other candidate sites] and there are frequent mentions of the NTS as a disposal or storage site in other DOE EISs. For example, the Stockpile Stewardship and Management PEIS includes an alternative which describes the complete closing of the Pantex Plant with its capabilities relocated to NTS, Los Alamos and Lawrence Livermore facilities. The Pantex EIS does not address the implications of this alternative. This issue should be addressed in the final EIS and the Record of Decision.

Response:

Storage of pits does not generate environmental contamination. Environmental restoration activities are independent of the pit storage decision. These activities will continue whether pits are stored at Pantex Plant or not. 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 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. In addition, see discussion in section 1.3.2 of this volume regarding Site Attributes.

Cumulative impacts related to changes in Pantex Plant operations from decisions resulting from the SSM PEIS, the S&D PEIS, and the WM PEIS are presented in the Pantex Plant EIS.

RC: 01.032

Doc: PC-031/1

The promised analysis of alternative DOD storage sites looks only at the Manzano Weapons Storage Facility at Kirtland Air Force Base and seems to reject it since it is not included in the Storage & Disposition PEIS. As the facility is deemed technologically adequate, we may only conclude by inference from the very words of the document that the DOE takes a more cavalier attitude toward the safety of Panhandle residents than people who live in Albuquerque. The fact that more people would be threatened in the Albuquerque area in no way justifies placing that liability just 17 miles east of the city of Amarillo in the middle of such a highly productive agricultural area [that] is the beginning of a food chain reaching across the world. Those who assert otherwise are more persuaded by convenience or dollars than reality. Is DOE so awash in funds that it can afford building new facilities when Manzano Mountain is more than adequate? Taxpayers as well as local residents deserve a better explanation than exists in this document.

Response:

RC: 01.033

Doc: PC-025/7

The first two bullets in the second column on page 3-3 [volume I, section 3.1.1]. Where are security and nonproliferation activities? They are routine correct?

Response:

Security and nonproliferation activities are part of the routine activities performed by the plant along with waste management, infrastructure and building maintenance, etc., in the bullet addressing "continuing routine Pantex Plant activities.

RC: 01.034

Doc: PC-025/8

On Page 3-7 in second column in the second paragraph. It appears a loop hole exists for DOE in dealing with the backlog of stored pits. If a container availability problem exists (like the FL container problem on F-2) DOE could store 20,000 pits without shipping one pit and not violate this EIS. What would be the hard number before DOE would stop dismantlement to put pressure on the transportation end? Lacking cans for shipment seems to make relocation alternatives unreasonable and thus not meeting the intent of NEPA, please provide technical justification. This EIS is flawed because the alternatives are not "technically mature" to use a DOE phrase found in SSM and S&D for rejecting analyses of alternatives. Lack of cans appears to be a reasonably foreseeable impact, please assess. The 12,000 alternative is not possible under this EIS.

Response:

Under the Pit Storage Relocation Alternative, the number of pits in interim storage at Pantex Plant could be greater than 12,000 pits for a temporary period until enough of the planned new transportation containers are available. This is not a loophole since the impact analysis considers the bounding effects of having up to 20,000 pits at the Pantex Plant. DOEs stated Preferred Alternative is the Proposed Action to retain the interim storage for up to 20,000 pits at Pantex Plant.

DOE would not stop weapons disassembly under the Relocation Alternative even in the case that there would not be enough transportation containers available at any particular point in time. The reason for this is that the exact timeframe within which any of the candidate sites could be made ready and the 8,000 or 20,000 pits transferred can not be precisely determined. The need to continue the weapons operations at Pantex is independent of the interim storage issue. Therefore, the disassembly of weapons has not been tied to the pit relocation schedule and under the Pit Storage Relocation Alternative all weapons operations (e.g., disassembly, assembly, etc.) would continue to be performed at Pantex Plant.

The Pit Storage Relocation Alternative is reasonable under NEPA in that the technology for the storage containers is mature. DOE has the knowledge to build the containers and in fact has already built the test models. Furthermore, the Department already has a properly certified Type B container (the FL container), which could be produced if technical difficulties with the AT400A certification should arise. The impact of any delay in completing the required testing of the container and beginning manufacture would only be relevant if Pantex Plant did not have the capacity for interim storage of the number of pits which could accumulate while the plant waited for the containers to be manufactured. Since Pantex Plant has the capacity to safely store all 20,000 pits, there is no problem if there is a delay in receiving certified containers.

The only difference between the Pit Storage Relocation Alternative and the Proposed Action is the potential interim storage of pits at a site other than Pantex Plant. The impacts of the Pit Storage Relocation Alternative consist of those described for the Proposed Action plus those associated with the transfer operations. In other words, the impacts of the Pit Relocation Alternative include the impacts from the possible storage of up to 20,000 pits, and therefore, bound the impacts of the case where containers do not become available. The 12,000 pit limit only applies to, and is discussed under, the No Action Alternative. Under the No Action Alternative DOE would cease dismantlement once the interim storage level of 12,000 pits was reached.

RC: 01.035

Doc: PC-025/9

On Page 3-8 last bullet of page. If shipping cans are lacking, why is 8,000 considered reasonable?

Response:

As stated in volume I, section 3.1.3, the availability of shipping containers affects only the schedule of shipments, not the feasibility of the alternative.

RC: 01.036

Doc: PC-025/11

Three bullets in second column of page 3-8. The rationale contains several fatal flaws. The ability [that] includes past performance in securing pits, nonproliferation, and a safe and reliable stockpile should have been considered in qualifying the sites. Please reassess sites based on these new criteria. Please remember when addressing this comment DOE stated to great length how vital DOEs missions regarding nonproliferation, security, and a safe and reliable stockpile were. What is the National Academy of Sciences position on plutonium storage?

Response:

The DOE disagrees with the commentor that the alternative storage site selection process including Department of Defense facilities contains flaws or was not reasonable. Current Pantex pit storage operations were used as a baseline for comparison purposes. Security and nonproliferation activities are part of routine activities performed by Pantex Plant. Pit storage is a relatively simple function to performunlike manufacturing or chemical processing operations involving nuclear materials. All sites evaluated in this document currently perform, or have performed security functions for either similar materials or materials with similar security needs. All sites considered as alternatives would be capable of securely and safely storing pits and could accommodate nonproliferation objectives. The National Academy of Sciences has not addressed interim storage.

For an expanded discussion of the Pantex Plant Safeguards and Security Program, the commentor is referred to the Pantex Programmatic Information Document (Pantex 1996b).

RC: 01.037

Doc: PC-029/2

Taking nuclear weapons apart at Pantex may make sense, but surely a better site for storage can be found. What do you think? I look forward to the seeing the better alternatives in the final Environmental Impact Statement.

Response:

See discussion in section 1.3.1, regarding the site selection process.

RC: 01.038

Doc: PC-027/1

Your glossy presentation books dont actually offer much choice or many alternatives. In fact, the choices and alternatives are very limited.

Response:

See discussion in section 1.3.1, regarding the site selection process.

RC: 01.039

Doc: PC-027/3

Regarding your proposal to use Kirtland Air Force Base/Albuquerque as a pit storage site. Albuquerque is the largest city in our state. It is close to Kirtland AFBthey are separated only by a gate guarda person can place one foot in Albuquerque and the other on Kirtland Air Force Base. Its like storing nukes in the middle of a city. The highways are busy and prone to accidents. The airport is busy too. One accident and youve lost a major population center. Your publication gives the impression that there is more separation than there actually is between the base and the city. It takes only a few minutes to drive from the city to the Manzano site on the base. Many people work on the base, it is a large local employer. The city and the base actually touch and the city grows every day. Albuquerque may have been a small town when the bomb was developed 50 years ago. It isnt small anymore.

Response:

In response to Item 1: The locations of Kirtland Air Force Base and the Manzano Weapon Storage Area in relationship to the City of Albuquerque are properly depicted in the Pantex Plant EIS.

In response to Item 2: The EIS, in volume I, section 5.5.1.12, discusses and analyzes an aircraft accident at Kirtland Air Force Base Manzano Weapon Storage Area. With the minimum cover of 9 meters (30 feet) of overburden, the aircraft impact analysis shows potential accidents even with military aircraft carrying conventional bomb loads, not a credible threat to pit storage at the Manzano Weapon Storage Area.

In response to Item 3: 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 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.

RC: 01.040

Doc: SG-003/23

Page 3-2, Section 3.1.1 Proposed Action: Care should be taken to ensure that the continued operation of Pantex Plant activities including "quality assurance testing of weapon components and the research and production of weapon components" is conducted in a fashion that will not increase DOE s liability for injury to natural resources.

Response:

DOE recognizes that all its facilities require varying levels of operational and environmental controls to protect the workers, the public, and natural resources. 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 natural resources. Nothing was found which would inhibit Pantex Plant from performing the missions stated in the Proposed Action.

RC: 01.041

Doc: PC-028/1

Page 5-7, 2nd column, 2nd para - It is not correct to state "and KAFB, near Albuquerque New Mexico-" Comment: KAFB is the southern boundary of Albuquerque, it is a joint use airport, (part of the city) - it is a part and adjacent to Albuquerque. Albuquerque is a major sized city, while the other candidate sites are located away from major cities. You should give major consideration to either keeping Pantex as the only site, or consider the other two choices.

Response:

KAFB adjoins the city limits of Albuquerque, but is not part of the city. A portion of the airport is under control of the city, but not all of the airport facilities are. See discussion in sections 1.3.1 and 1.3.2, of this volume.

RC: 01.042

Doc: CO-007/2

With all of the research, development, manufacturing and deployment poured into bomb-making, we are very short on environmentally sound methods for storage and disposition. Instead of the euphemistically named and costly program that is before us, we should be considering a "green" Manhattan II. The requirements for dismantlement should be to: 1) dispose of the components in such a way that they are not and could not be used in a bomb again, and 2) minimize, rather than contribute to, or perpetuate the waste stream of radioactive materials.

Response:

In response to Item 1: The Atomic Energy Act requires DOE to sanitize weapon components that are no longer needed through a process of destroying or removing classified or other controlled matter and to demilitarize weapon components through a process that results in an irreversible modification or destruction of a weapons component or part of a component to the extent required to prevent use in its original weapon purpose.

In response to Item 2: The Pantex Plant Pollution Prevention/Waste Minimization Program originally implemented in 1991 has significantly reduced waste volumes. The success of the program was instrumental in being awarded the Presidents Closing the Circle Award.

Final disposition of weapon-usable surplus plutonium is within the scope of the S&D PEIS.

RC: 01.043

Doc: CO-005/10

The Agency should re-evaluate the risks to workers from low level radiation exposures using the risk factors reported in these studies. Such a reanalysis would highlight the uncertainties associated with making predictions about the health effects of low level ionizing radiation. The issue of uncertainty in scientific theory is currently glossed by the misleading use of data from only one side of the debate.

Response:

See response to comment 14.129. The DOE understands that uncertainties exist in the methodology for evaluating human health risks. As discussed in volume II, appendix D.6 a degree of conservatism has been introduced to the calculations as a result of these uncertainties. However, DOE believes that the analysis presented in this EIS is reasonable for evaluating environmental impacts of the alternatives.

RC: 01.044

Doc: PC-033/3

Page 5-55, Kirtland Air Force Base. Under the Pit Storage Relocation Alternative (section 3.13) the pit storage function currently carried out at Pantex Plant would be transferred to another site. The Manzano Weapons Storage Area (WSA) is the candidate storage site at the Kirtland Air Force Base. After reviewing pages 5-55 through 5-75, I believe that the Manzano WSA would be the ideal location for the storage of the plutonium pits. The Manzano Mountain facility has the structure in place (storing office furniture at present); security is available; aircraft seem not to fly in a direct pathway to the WSA; water, air, and soil should not be adversely affected; and the local population should be better protected from accidental releases in this type of facility with the 30 foot coverage and better structure of the magazines. Some of the magazines at Pantex are 40 years old and have been proven to be unreliable for plutonium storage. I am referring to the heat build up in some of the magazines this past year and the installment of air conditioning units. Protection from aircraft intrusion is not as great at Pantex, or terrorist missiles and/or bombs. Security has been proven to be very lax at times at Pantex and the proximity of the plant to the Amarillo International Airport (which is also used for military training flights), is also a concern. What are the reasons for not choosing Manzano WSA over Pantex if that is a reality? If the DOD enters into a Memorandum of Understanding (MOU) with the DOE and Manzano is used for pit storage, would the employees in charge of the Manzano WSA be employees of DOE or DOD?

Response:

See discussion in section 1.3.1, regarding site selection process.

DOE is currently studying the air conditioning option in four pit storage magazines. By providing air conditioning, DOE seeks improved climate control through reduction in the range of seasonal and daily temperature fluctuation. DOE may choose to provide air conditioning to all pit storage magazines based on these test results. DOE is fully committed to improve Pantex Plants safe and reliable pit storage operations. Like the recent Stage Right storage configuration enhancement and the proposed AT-400A pit storage container project, the air conditioning option is expected to enhance storage operations. The fundamental safety design of the magazines is the physical structure of the magazines not air conditioning, Stage Right, or AT-400A containers. These enhancements are improvements to a sound pit storage management at Pantex Plant. Expect DOE to continue increasing the safety envelope.

The DOE and Pantex Plant take security issues very seriously. Please note the numerous safeguard and security enhancement projects listed in appendix D of the Pantex Plant Programmatic Information Document (Pantex 1996b).

The risks associated with aircraft accidents have been discussed and analyzed in volume I, section 4.15.

If Manzano is selected to conduct interim pit storage activities, the pits would remain under DOE control.

3.2 Relationship to Other Environmental Impact Statements

RC: 02.001

Doc: HT02-08/4

The agreement to evaluate alternative storage sites for pits, specifically Department of Defense sites, seems to have been an insubstantial one since that site is not included in the actual storage EIS. If, as implied in the analysis, Manzano mountain becomes ineligible because of the threat such a facility represents to Albuquerque, what are we to make of the governments concern for the residents of the Panhandle?

Response:

As described in volume I, section 3.1.4, 60 DOD installations were screened by the Nuclear Weapons Council staff. With the exceptions of the Manzano Weapon Storage Area, located on Kirtland Air Force Base (at Albuquerque, New Mexico) and Seneca Army Depot (at Romulus, New York), the Council staff determined that none were feasible. Subsequently, it was determined that Seneca Army Depot would not be available as a candidate site for pit storage. In addition, see discussion in section 1.3.1 in this volume, regarding the site selection process.

For a discussion on the selection process for long-term storage of plutonium the commentor is directed to chapter 2 of the S&D PEIS.

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 has worked with EPA, states, employees, unions, stakeholders, and the general public to develop programs and commitments to better manage its facilities and all hazardous materials. All of these plans and commitments have been reviewed to determine if there are any conflicts or restrictions which would inhibit the Pantex Plant from serving as a good location for the facilities proposed in the EIS. Nothing was found which would inhibit the Pantex Plant from performing the missions stated in the Proposed Action.

RC: 02.002

Doc: HT14/5

A systems analysis approach should be utilized to select the most effective method for processing [of plutonium] and interim storage [of pits]. This analysis should adequately address public and worker health and safety and environmental issues.

Response:

Processing of plutonium is not within the scope of the Pantex Plant EIS. The systems analysis approach is typically utilized in obtaining licenses, permits, and compliance assurance certification prior to operation of facilities. The systems analysis approach is not typically used in NEPA analysis. The Pantex Plant EIS has addressed public and worker health and safety and environmental issues. Moreover, the focus of the decision in this EIS is the location of the interim storage not the method. A standardized storage method (Stage Right) is evaluated in this EIS in order to compare the impacts at different candidate sites.

RC: 02.003

Doc: HT01-05/1

Based upon these reasons, I respectfully urge DOE to designate Pantex as the preferred alternative site for all existing and new stockpile management and stewardship functions as well as consolidation of all plutonium storage and disposition and any related functions.

Response:

See discussion in section 1.3.2 in this volume, regarding the relationship between the PEISs and the Pantex Plant EIS.

RC: 02.004

Doc: HT01-04/2

The EIS that deals with missile materials, storage, and disposition is one that I have spent a good deal of time with. On the topic of storage, I feel like that were seeing that Pantex in its current role is ideally sited for storage of plutonium pits. If it is anticipated that storage would...continue to be in that form, I dont think theres any question that Pantex, which is already contemplated to have...or will have 21,000 pits in storage.... But certainly the vast majority of the pits in storage at Pantex, it makes sense to continue that function in that location.

Response:

See discussion in section 1.3.2 in this volume, regarding the relationship between the PEISs and the Pantex Plant EIS.

RC: 02.005

Doc: HT07/1

I just want to follow up and get the distinction, then, that the storage of up to 20,000 pits, those pits are what Im going to call sealed, but youre talking about material that wont be sealed or will be packaged in some other fashion?

Response:

To elaborate on the response given at the public hearing, each pit is hermetically sealed inside a protective cladding which is bonded to the plutonium. In the future, these pits will be stored in containers known as AT400A. AT400A storage configuration provides double shell container protection or, in the words of the commentor, a "sealed" package. Currently, pits are stored in ALR8 containers. Pits are encased by metal. For weapons-usable fissile materials not in pit form, DOE would require similar multi-layer "sealed" package containment. DOE recognizes that all its hazardous materials, including plutonium, require proper packaging to protect the workers, the public, and the environment.

RC: 02.006

Doc: HT13/15

Is there a reason why it is only being looked at as interim and not long term, or why is it suitable for one and not the other?

Response:

See discussion in section 1.3.2 in this volume, regarding the relationship of the S&D PEIS and Pantex Plant EIS.

RC: 02.007

Doc: HT13/22

You may not want to talk about this, but it seems like the Department is taking the position that these workers doses that we just talked about are inevitable, because even if the pits stay at Pantex, they will still have to be loaded out of Zone 4 and moved again, because the disposition PEIS says even if they all stay at Pantex, they would be loaded into Zone 12, is that correct?

Response:

To elaborate on the response given at the public hearing, the Department of Energy, through its contractor Mason & Hanger Corporation, is fully committed to the As Low As Reasonably Achievable (ALARA) program at Pantex Plant to help limit the number of personnel occupational exposures and public/environmental exposures to radioactive material. The majority of Pantex Plant workers receive no radiation exposures (zero dose) during normal operations. DOE Order 5480.11 and 10 CFR 835 specify a limit of 5 rem per year for occupational workers.

DOE recognizes to meet interim storage requirements, pits currently in storage at Pantex Plant would require workers to handle radioactive materials including Zone 4 and Zone 12 pit transfers. This exposure has been discussed and analyzed in the EIS. DOEs commitment to reduced exposures, includes the improved pit storage capabilities with the Stage Right automated pit storage system. When fully implemented this year, this system will significantly reduce Zone 4 worker exposures. The Stage Right system uses a remote-controlled forklift to retrieve, place, and inspect Pantex Plant pit storage facilities, thus reducing hands-on radioactive material management.

RC: 02.008

Doc: HT13/27

I have a question or statement relating to how the sitewide and the two PEISs, the [storage] and disposition and the stockpile stewardship PEIS, are relating. We just spent a lot of time working on bringing people from all over the state to the stockpile stewardship hearings, and the main topic of discussion is plutonium pit fabrication at Los Alamos, and here we are talking about thousands and thousands of plutonium pits being dismantled.

It seems to me like the left hand doesnt know what the right hand is doing. One hand is trying to figure out what to do with pits, and the other hand is creating more. Is that something that can in some way be tied in...if we have...pits, it seems to me confusing that we would need to retool them to different specifications.

Response:

See discussion in section 1.3.2 in this volume, regarding the relationship of the PEISs and the Pantex Plant EIS. For the purpose of clarification, weapons are dismantled, not pits. The intact, encased plutonium, or pit, from a dismantled weapon is placed in storage.

RC: 02.009

Doc: HT13/29

... Two points I want to make are, one, the fact that we have such difficulty in figuring out what to do with 20,000 pits, which I certainly do and would hope that everybody here is, on the one hand, glad that we are getting 20,000 pits out of bombs. That is a good thing, but the fact that what comes from the good thing of having fewer warheads armed and able to destroy the world several times over is another problem, which is what to do with the 20,000 pits.

It is even more complicated because, as has already been stated, it would be one thing to say we know what to do with the 20,000 pits in the short term because we know what it do with the 20,000 pits in the long term. We know what the disposition is. In fact, we dont know what the disposition is.

I have talked about it in another context, so I will just summarize, I have no confidence that the disposition PEIS in fact is adequately analyzing or is going to come up with a possible reasonable solution for longer term what to do with those 20,000 pits. So I think it is something that some of us in the public and hopefully people in the federal government will pay a lot more attention to in the future.

Response:

See discussion in section 1.3.2 in this volume, regarding the relationship of the PEISs and the Pantex Plant EIS.

RC: 02.010

Doc: HT13/81

Have they decided what they are going to be doing with the metal components from Oak Ridge once they have disassembled the secondaries to the point that they could go into storage that is equivalent to what the plutonium storage would be, and would these sites possibly be considered in the future for storage of components of the secondaries the way we are currently looking at storage of the primaries?

Response:

The Disposition of Surplus Highly Enriched Uranium Final Environmental Impact Statement discusses and analyzes the disposition of surplus HEU at Oak Ridge. In addition, see discussion in section 1.3.2 in this volume, regarding the relationship of the PEISs and the Pantex Plant EIS.

RC: 02.011

Doc: HT13/82

They were not planning on shipping any of those components that are disassembled from the secondaries back to Pantex or Albuquerque...it is all going to stay at Y-12 and Oak Ridge?

Response:

See response to comment 02.010.

RC: 02.012

Doc: HT13/83

You understand my general concern is, you develop a bunker that can store a pit in a storage vessel, then you have got a bunch of spherical uranium or plutonium in the secondary components that need to go in at some point in a storage bunker inside a container format. Wouldnt we be looking at the potential of once we put, for example, an Albuquerque bunker system into process, wed be looking at potential in the future getting more than just primary pits and looking at potentially getting a variety of others?

So the can subassemblies would be going into underground storage at Oak Ridge?...

Response:

See response to comment 02.010.

RC: 02.013

Doc: CO-010/1

... We do not believe that the community and stakeholders would support such an action by the Department unless the site were also to be utilized for the processing of the plutonium to a stable form for safe interim storage. Hanford would also be an ideal site for the processing of the excess plutonium either for vitrification of fabrication into reactor fuel for irradiation prior to disposal.

The site has the capability by operation of either or both the Fast Flux [Test] Facility (FFTF) and the WNP-2 Nuclear Power Plant on mixed oxide cores to dispose of a substantial portion of the excess plutonium within the foreseeable future. This capability when coupled with the available mixed oxide fuel fabrication capabilities of the Fuel and Materials Examination Facility (FMEF) offers a single site processing and irradiation for disposal capability not found at other potential storage sites. We believe that the Draft EIS should be revised to objectively evaluate this option in conjunction with the excess weapons disposal Draft EIS.

This area would be expected to be supportive of an excess plutonium storage and disposal mission provided that the related processing and fabrication tasks were also assigned here. Submitted herewith for the record is a position statement recently adopted by the Hanford Advisory Board [that] relates to the disposal of excess weapons materials by irradiation in the FFTF. The Hanford Advisory Board is a DOE sponsored stakeholder group representing various interests in the states of Oregon and Washington. This statement is consistent with the position we have stated above on this subject.

Although the storage of excess weapons plutonium at Hanford in available facilities without further processing or utilization is probably significantly more economical than the construction of new facilities at other sites, we do not feel that this is in the best interests of the community unless a concurrent processing mission was assigned to the site. A single purpose storage mission would be opposed due to the potential conflict of other diversification initiatives.

Response:

DOE believes the interim storage alternatives covered under the Pantex EIS are a reasonable management course for plutonium in pit form. In addition, see discussion in section 1.3.1 in this volume, regarding the site selection process, and section 1.3.2 regarding the relationship between S&D PEIS and Pantex Plant EIS.

RC: 02.014

Doc: PC-024/5

Page S-10, right column, "Related National Environmental Policy Act Studies" The Pantex FEIS should reflect delays in other EIS such as the SS&M PEIS and the NTS EIS.

Response:

The purpose of the summary is to inform the public that several NEPA documents, including SSM PEIS and NTS EIS, are ongoing and could have impacts at Pantex Plant. The schedule of decisions in those documents does not impact the assessments contained in the Pantex Plant EIS. Cumulative impacts related to changes in Pantex Plant operations from decisions resulting from the SSM PEIS, the S&D PEIS, and the WM PEIS are presented in the Pantex Plant EIS.

RC: 02.015

Doc: PC-024/6

Page S-13, left column, boldface. The title and the DOE control number for the NTS EIS should be corrected to reflect changes that were made over six months ago.

Response:

The section has been corrected.

RC: 02.016

Doc: PC-024/7

Page S-13, right column last three lines. This statement should indicate more than the existing waste connection. It should mention the proposals to store plutonium-239 pits there.

Response:

Consideration of interim storage and long-term storage of pits is not within the scope of the NTS Site-Wide EIS. See discussion in section 1.3.2, in this volume.

RC: 02.017

Doc: PC-024/11

Page 5.6, left column, 3rd paragraph. It mentions that "[t]he P-Tunnel is also being proposed for the long-term storage and disposition of weapons-usable fissile materials." The folks at the NTS are trying to sell the use of limited tunnel space for two different purposes at the same time. It is unlikely that it will be used for both purposes and therefore the competing EIS purposes need to be addressed.

Response:

One of the alternatives in the S&D PEIS is long-term storage and disposition of weapons-usable fissile material in the P-Tunnel at NTS. The 20,000 pits that are addressed for interim storage in the Pantex Plant EIS are part of the inventory of weapons-usable fissile material in the S&D PEIS. Selection of P-Tunnel for interim storage of pits and long-term storage of weapons-usable fissile material would not be using limited tunnel space for two different purposes, but rather for the same purpose.

RC: 02.018

Doc: CO-006/2

In the Draft S&D PEIS, DOE characterizes Pantex as having the "greatest potential" to experience adverse cumulative impacts from an increased role in plutonium storage and disposition.... These conclusions also totally contradict those contained in the SWEIS which characterize the impacts as "minimal" and "negligible." It is imperative that DOE correct the inaccurate mischaracterizations before making its final decisions for plutonium storage and disposition missions.

Response:

Environmental impacts associated with interim storage of pits are within the scope of the Pantex Plant EIS. Environmental impacts associated with long term storage and disposition are within the scope of the S&D PEIS. The analyses presented in the two EISs are both correct since disposition would introduce plutonium processing not currently done at Pantex.

RC: 02.019

Doc: HT16/7

I really would like to understand why you [have] all...those cumulative impacts in here like you have, for instance, on...page 4-239, where youre talking about the Storage and Disposition PEIS. And the last sentence in there is: All doses would be within radiological limits and well below levels of natural background radiation, et cetera.... This document has consistently referred back to the three PEISs and made...statements about impacts that it doesnt seem to me [that] this document has the information to do. Can you...talk to me a little bit about that? It [the EIS] gives the impression youre making solid judgments that I dont think the information is sufficient to do.

Response:

The Pantex Plant EIS has detailed information on the impacts of continued operations at Pantex Plant. Each PEIS has detailed information about the impacts of its subject programs. The cumulative impact sections in the Pantex EIS incorporates the information from the PEISs by reference and presents the total cumulative impact. Incorporating information by reference is part of the NEPA analysis process. The "Cumulative Impacts" sections of this EIS address to the extent possible information relevant to Pantex Plant. For detailed discussions of environmental impacts evaluated in the other PEISs, the commentor is referred to those documents.

RC: 02.020

Doc: HT16/9

The second issue I raise, though, is, for a number of the types of operations that are being talked about for the futureplutonium conversion facilities, plutonium processing facilities, MOX fuel facilities, a new revolutionary [evolutionary] light water reactorthere really [is] no history. There [is] no good history to go on in terms [of] what the actual releases are. So youre basing your analysis on what the current or assumed regulatory levels are going to be, [not] on, in fact, historic performance. And so the point is that you should be quite clear about that, which I think, in some cases, its really not. For example, on page 4-239 that Ms. Gattis just mentioned to you, I think it would be very helpful if you would just say, in terms of some of these facilities, there isnt historic data to base it on, so we are basing our analysis on these plants [that] are assumed to operate within the applicable regulatory limits.

Response:

See response to comment 02.019.

RC: 02.021

Doc: HT17/24

I would much prefer to see the Nevada Test Site deal with that particular material [plutonium] as the last residue of a very difficult part of this countrys history and one [that] we are better off dispensing with, not continuing into the future.

Response:

See discussion in section 1.3.2 in this volume, regarding site attributes.

RC: 02.022

Doc: HT17/27

Hearing tonight about transferring plutonium processing from Rocky Flats, which was judged by a DOE report the site most likely to constitute a threat to human life, a nine on a scale of ten, followed closely by Pantex, which was an eight on a scale of ten, gives me some pause for thought. Both of those sites were rated ahead as threats to human life over the notoriously contaminated Hanford complex.

Response:

See response to comment 02.001, regarding hazardous materials.

RC: 02.023

Doc: HT17/46

...I appreciate the fact that some of the things that I mentioned may be covered in other documents, but I believe that this study itself has to deal with those things. It will be making some of those decisions in the fact that it does include those other documents, and I feel like it has inadvertently left out some of those issues, and that needs to be more carefully addressed.

Response:

See response to comment 02.019.

RC: 02.024

Doc: HT17/72

...if the nuclear waste that is at such places such as Rocky Flats and that has been refused by governors of other states is to be...brought down here, I assume there will be the same problems as there are at other places, and it probably just needs to be looked at a little bit more carefully.

Response:

The WM PEIS addresses DOE programmatic waste management issues and alternatives. In addition, see response to comment 02.001 regarding hazardous materials.

RC: 02.025

Doc: PC-017/12

Page 4-82 states that pit reuse is not a current activity at Pantex Plant. Can you assure us that the reuse will never become an activity at Pantex? Is reprocessing, MOX, or other potential pit activities ever to be an activity at Pantex? If so, should not those issues be considered and studies on their effects on health and safety for workers, neighbors, and agricultural workers, the potential contamination of our water, air, and agricultural activities and products be addressed before the future at Pantex is determined?

Response:

Noninvasive activities connected with pit reuse are part of the Proposed Action. See the discussion in section 1.3.2 in this volume, for further discussion of the plutonium activities addressed in the S&D PEIS.

RC: 02.026

Doc: SG-012/9

One alternative considered in the DEIS could have been placing plutonium in a permanent disposal, deleting interim storage (especially at Manzano WSA) as an alternative.

Response:

See discussion in section 1.3.2 in this volume, regarding S&D PEIS. In addition, see response to comment 02.001 regarding site selection.

RC: 02.027

Doc: MG-002/4

For example, the Stockpile Stewardship and Management PEIS includes an alternative which describes the complete closing of the Pantex Plant with its capabilities relocated to NTS, Los Alamos and Lawrence Livermore facilities. The Pantex EIS does not address the implications of this alternative. This issue should be addressed in the final EIS and the Record of Decision.

Response:

See discussion in section 1.3.2 in this volume, regarding SSM PEIS.

RC: 02.028

Doc: SG-003/11

In the Summary, page S-11, right column, the discussion on Stockpile Stewardship and Management Draft PEIS omits the "Downsize Pantex with transfer of HE Operations" option briefed as a preferred alternative at the April 22-23, 1996 meetings. The Stockpile Management Preferred Alternatives Report, pages l7 through 20 discusses fiscal impacts related to the transfer of HE operations for fiscal years l996 through 2020. If this issue is anticipated to impact the Texas Panhandle during the tenure of the Pantex SWEIS, the effect of transporting a large number of HE components over the roadways needs to be included.

Response:

See discussion in section 1.3.2 in this volume, regarding the SSM PEIS.

RC: 02.029

Doc: SG-003/12

In the Summary, page S-12, right column, the Light Water Reactor disposition alternative from the Storage and Disposition of Weapons-Usable Fissile Materials PEIS has not been removed, although it was indicated in the April meetings that the [Light Water Reactor] (LWR) was no longer being considered for Pantex. This issue requires clarification.

Response:

Final disposition of plutonium alternatives are within the scope of the S&D PEIS. Since the Record of Decision on this PEIS has not yet been announced, LWR continues to be discussed in the cumulative impact section of this EIS.

RC: 02.030

Doc: SG-010/1

In reference to interim storage of plutonium pits at Pantex, Nevadas position on this issue continues to be that DOE should adopt a proposed action for the permanent disposition of surplus plutonium pits before selecting new interim or long-term storage sites for this long-lived material. In addition, to reduce duplication in storage, transportation, and security costs and to address risks associated with the proliferation of weapons-grade plutonium, DOE should consider adopting a program that combines materials disposition (e.g., plutonium vitrification) with long-term plutonium storage.

Implementing the Proposed Action as defined in the DEIS would enhance such a program; it would also help prevent redundant shipping campaigns of plutonium bearing material on public roads and highways. This is important since excessive transportation of plutonium on public roads remains controversial and is generally unacceptable to the public. For all of these reasons, officials in Nevada have long stated that "DOE should link long-term materials consolidation and management with options for final materials disposition."

Response:

A description of the transportation of pits and the expected increase in risk is presented in volume I, section 4.16.

RC: 02.031

Doc: SG-010/4

As previously suggested, State officials in Nevada believe that DOE should link long-term fissile materials consolidation and storage with options for final materials disposition, and we believe the proposed action presented in the Draft EIS for Pantex supports this concept. As such, we continue to advocate a strategy that would bring together long-term pit storage with one or more of the plutonium disposition treatment options being considered in DOEs Storage and Disposition PEIS.

Response:

See discussion in section 1.3.2 in this volume, regarding S&D PEIS.

RC: 02.032

Doc: PC-030/1

While I am reasonably comfortable with interim storage of plutonium pits, I believe that facilities for long-term storage should not be constructed at Pantex or any other site when there is already an adequate facility at the Manzano Weapons Storage Facility at Kirtland AFB in Albuquerque.

Response:

See discussion in section 1.3.2 in this volume, regarding S&D PEIS.

3.3 Facilities and Infrastructure

RC: 03.001

Doc: HT13/3

The document [page 5-55] also says that construction began June, 47, and became operational in April of 50, so that would essentially say that the bunkers we are talking about are more than 45 years old. My specific question is, what is the design life of those bunkers?

Response:

Design life is a construction criteria specification rather than an operational capability criteria. More appropriately, the remaining life cycles of the bunkers, like those magazines currently at Pantex, are typically greater than 30 years. Design life of facilities can be extended with routine maintenance. The Nuclear Weapons Council Staff, using DOE Site Screening criteria, determined the degree of construction required to adapt existing Manzano facilities for the pit storage mission as feasible. Although Manzano is not the preferred alternative, if selected and prior to the operation of pit storage activities, DOE would complete a Safety Analysis Report and Operation Readiness Review to further document the safety of the facilities.

RC: 03.002

Doc: HT13/5

... The design question is an important one, I think, from a variety of standpoints. So my request would be that we get some more detailed design and engineering analysis of the bunkers in terms of design life, design capability. The major had said some of them [the bunkers] need to be upgraded. It seems to me we need to have more specific information on those things.

I didnt see any references in the document that give me that kind of detail, so if I have missed it, Id like somebody to tell me if there is a document that describes it. Id like to know what it is. If there isnt a document that describes it, Id like to know how that information is going to be presented.

Response:

See response to comment 03.001. During the selection process, as discussed in volume I, section 3.1.4, several of the magazines at Manzano were visually inspected and found to require only very minor work, such as adjustments or replacement of doors. The great majority of any upgrades that would be needed to use the Manzano Weapons Storage Area is actually not to the magazines themselves, but to reactivate the security fence sensor system. While the fence itself is intact, the computer and sensors used to detect intrusion would need upgrades. The selection process documentation is available upon request.

RC: 03.003

Doc: HT12/20

Does Pantex conduct a plutonium storage operation in facilities that are considered to be nuclear facilities, rated nuclear facilities, and...that conform to the DOE orders for nuclear facilities 6431A, for instance?

Response:

Yes, pit storage magazines are defined as Category 2 "non reactor nuclear facility" in appropriate DOE standards. In addition, see response to comment 01.019.

RC: 03.004

Doc: PC-024/9

P. 5-3, left column, last line. The Final Pantex EIS should clearly explain the real reasons for the existence of the DAF and the P-Tunnel complex. The $100 million Device Assembly Facility was designed and constructed in anticipation of an expanded nuclear explosive testing program at the [Nevada Test Site (NTS)]. It was intended to be the assembly point for the nuclear explosive devices. Since our nuclear test moratorium went into effect in 1992, its primary mission ended about 3.5 years before it was completed. It is now being used to assemble nuclear and nonnuclear devices which involve large amounts of high-explosives. The Pantex DEIS does not address any compatibility problems associated with pit storage and high-explosive assembly work at the DAF.

Response:

The selection of site alternatives for interim pit storage was accomplished by developing site suitability criteria, applying the criteria to candidate sites, and determining the best sites to represent the range of reasonable site alternatives. The selection of site alternatives is discussed in volume I, chapter 3. The Pantex Plant has been identified as the preferred alternative.

Volume I, section 5.2 discusses the DAFs original mission and notes the design of the DAF was based on the Pantex Plant designs for nuclear explosive operations. The original design of the DAF includes both nuclear explosive operation and a pit storage capability.

The current mission of the DAF is to maintain readiness to resume nuclear testing, if required, for national security. Only a portion of the DAF will be dedicated to that mission. The remainder could be made available for storage of up to 8,000 pits. Long term nuclear explosive contingency operations and NTS alternatives are within the scope of the SSM PEIS.

Volume I, section 5.2 also discusses the P-Tunnels original mission and design.

RC: 03.005

Doc: PC-024/10

The P-Tunnel complex was constructed for the Defense Nuclear Agencys (DNA) nuclear explosive test program which also ended in 1992. The tunnel complex was an alternate, and often much more expensive, way of performing underground nuclear explosion tests. Cost per test were often in the range of many tens of millions of dollars. Several DNA nuclear explosives test were conducted in this tunnel complex. Page 5-7, Figure 5.2.3.--Layout of P-Tunnel at the Nevada Test Site., contains a drawing of the existing complex. This map drawing should point out the locations and names of the nuclear test waste cavities. This, or a updated version of this map, should indicate where, in the vast tunnel complex, the proposed pit storage would take place. The Pantex DEIS makes no mention of where, in the many miles of tunnels, the pits might be stored, The NEPA FEIS should provide such information.

The DNAs nuclear explosive program has been suspended.

The side tunnels used for previous nuclear tests are all permanently sealed off. Disclosure of their location on the map is not necessary since they would not have any effect upon pit storage (in the main tunnel) or on the Stage Right equipment and operators. For pit storage, P-Tunnel would require minimal facility upgrades (primarily the installation of guide rails for a Stage Right forklift). The P-Tunnel alternative is well suited for the Stage Right equipment and techniques successfully implemented at Pantex.

In addition, see response to comment 03.004.

RC: 03.006

Doc: PC-023/5

I hope that the Department of Energy has thoroughly inspected buildings on site [that] have been subjected to such energy from explosive testing over many years of Pantex Plant operations. Structural integrity of Pantex Plant facilities, especially storage locations for plutonium pits, is extremely important to the safety of Pantex employees and area residents.

Response:

Volume I, section 4.3 discusses and analyzes environmental impact alternatives on plant facilities and infrastructure. Pantex Plant annually publishes a Capital Assets Management Process Report which includes rating each facilitys condition and remaining lifecycle. Pantex Plant facilities and infrastructure are subject to numerous internal and external audits, inspections, reviews, and surveys on an annual basis. DOE understands and is committed to the safety of Pantex employees and area residents.

RC: 03.007

Doc: HT17/64

... In looking at what the range of activities would be to even continue on with those current missions that are outlined for the next ten years, I really dont think that in that period of time you would think that you wouldnt need to do a number of other upgrades and changes in your facilities besides the six that are specifically mentioned in this document. And I think you need to do a much better job of analyzing...the age of buildings...[if] youre going to keep going with continuing operations over a ten-year period of time that you say that this document covers.

Response:

DOE considers sitewide NEPA documentation to be living documents requiring periodic review and updates as appropriate. Tiered NEPA documents may also be needed. DOE has an established NEPA program to handle issues regarding routine upgrades and maintenance of DOE facilities. Since 1990 Pantex Plant, has initiated 354 environmental checklists and NEPA related documents. 206 of the 354 were identified as upgrades, repairs, improvements, and maintenance related activities. Additional language has been added to volume I, section 4.3.1.

Most projects for upgrades, repairs, improvements, and maintenance are relatively small in size and scope and do not require performance of an Environmental Assessment or EIS. Larger projects, such as the six evaluated in this EIS must proceed to the conceptual design phase before sufficient information is available for adequate analysis. The six facilities evaluated in this EIS, represent the only foreseeable major projects that currently have sufficient maturity of conceptual design to allow assessment of environmental impacts.

RC: 03.008

Doc: PC-025/3

Why is infrastructure included in environmental impacts and as an additional consideration? Like my comments on SSM and S&D, if national security and nonproliferation [are] so important, why arent the environmental impacts discussed in the infrastructure section as a capability, assets, problem, etc. in this document?... Does Pantex out perform its alternative sites on these issues? If so, the decision maker needs to know to make a reasonably informed decision.... Why isnt security capabilities addressed in infrastructure impact analysis so impacts can be reviewed and decide a true course of action? DOE should consider redoing infrastructure analysis to include security related environmental impacts.

Response:

In determining reasonable relocation alternative sites, as discussed in volume I, section 3.1.4, the DOE Site Screening Committee and the Nuclear Weapons Council Staff screening methodology included assessment of the degree of construction required and the degree of isolation. Thus, the security capabilities were assessed. Current Pantex pit storage operations were used as a baseline for comparison purposes. Security and nonproliferation activities are part of routine activities performed by Pantex Plant. All sites considered as alternatives would be capable of securely and safely storing pits.

Volume I, sections 4.3.2, 5.2, 5.3, 5.4, and 5.5 discuss and analyze alternative site facilities and infrastructure including security assets (e.g., material access control) in the EIS.

For clarification, the phrase "... national security, and infrastructure." has been changed to "... national security, and site specific factors (e.g., local and political support, intellectual and technical competencies).

An expanded discussion of the Pantex Plant Safeguards and Security Program is available in the Pantex Plant Programmatic Information Document (Pantex 1996).

RC: 03.009

Doc: PC-025/12

On Page 4-11. What level of security is the burning ground, zone 10, and firing sites under? The nonshaded area of DOE owned property is under what level of security? The DOE leased property shading is not found in the legendwhat level of security is this?

Response:

DOE cannot disclose levels of security involving nuclear weapons sites or facilities.

RC: 03.010

Doc: PC-025/13

Page 4-16. Should it be waste management activities utilities?

Response:

Yes, the word utility has been made plural.

RC: 03.011

Doc: PC-025/14

Page 4-18. Why Pit Storage Activity? Section 4.4, 4.5, etc. use Activities. In Waste Management Activities. Why no discussion about RCRA Closures?

Response:

The section title has been changed to "Pit Storage Activities." RCRA Closures are included in volume I, section 4.3.2.1, Environmental Restoration.

RC: 03.012

Doc: PC-025/15

Page 4-18. Why Environmental Management? Section 4.4, 4.5, etc. call it Environmental Restoration?

Response:

The title and introductory sentence have been changed to read "Environmental Restoration" to be parallel with sections 4.4 and 4.5 of volume I.

RC: 03.013

Doc: PC-025/16

Page 4-16 uses Environmental Restoration. Should page 4-18 include closures, page 4-16 does.

Response:

See response to comment 03.012. The text on page 4-18 of volume I of the Draft EIS states that the impacts are the same as those described on page 4-16. No change was made to the EIS.

RC: 03.014

Doc: PC-025/17

General comment in section 4.3. ...Why isnt more presented about nonproliferation and sanitization and demilitarization in this section? Please include environmental impact analysis of these issues in the infrastructure section based on methodology definition on page 4-3 as a support requirement and SSM & S&D emphasis to the issues. How are nonproliferation and sanitization and demilitarization infrastructure effected by the varying levels of activities as required by methodology on page A-l? Is there a backlog? What are the environmental impacts?

Response:

The environmental impacts from sanitization and demilitarization operations have been incorporated into impacts addressed in Air Quality and Waste management. Sanitization and demilitarization operations of high explosives at the Burning Ground are included in the air quality modeling. Solid wastes generated in the sanitization and demilitarization of weapon components are included in the waste volume projections for the three levels of weapon activities. To account for fluctuations in waste generation rates a 10% margin was used in the analysis.

RC: 03.015

Doc: PC-028/10

Page 5-58, para. 5.5.1.1. The recommendation to utilize the Manzano WSA facilities ignores a very real condition. The Manzano WSA was built in the mid 40s to 50s. Much of the facilities have not been improved over the years. The major plants have water leakage problems along with the storage magazines. The electrical system is outdated and has chronic problems, the fence security system and fence are in need of major repair and upgrade. The facilities infrastructure, except for the Phillips Lab R&D facility at Manzano, [has] been economically neglected and this is why Manzano WSA is not being utilized at historical or design levels. There will be significant cost, overlooked in the Draft EIS, in putting a pit storage area on KAFB.

Response:

The conditions described apply to Plants 1 and 2 and their associated tunnels which would not be used for pit storage. The magazines that would be used for pit storage are not connected to those problem facilities and are, in fact, in excellent condition. See response to comment 03.002 regarding the upgrade to the fence.

3.4 Land Resources

RC: 04.001

Doc: HT02-08/3

There is again no consideration of the most basic industry of the Panhandle, agriculture.

Response:

The EIS has been revised to expand the discussion on agriculture in sections 4.4, 4.5, 4.6, 4.9 and 4.11 in volume I of this EIS. Additional information on these sections is provided in the Land Resources section of the Pantex Plants Environmental Information Document (Pantex 1996). The proposed action is not expected to adversely impact the agricultural industry of the Panhandle.

RC: 04.002

Doc: CO-008/36

Page 4-40, Paragraph 1, "By virtue of 30 TAC 335.557 (3), the future land use designated at Pantex Plant is nonresidential." How are current agricultural activities on DOE owned land classified?

Response:

The classification of future land use is a process related to the environmental restoration process as it relates to clean-up levels. This comment specifically addresses the soil and sediment quality at solid waste management units on Pantex Plant, as discussed in volume I, section 4.5.1.3 of this EIS. Neither RCRA nor CERCLA govern agricultural activities at Pantex Plant. However, both RCRA and CERCLA drive environmental restoration activities on DOE property. Both have provisions to protect natural resources at Pantex Plant.

RC: 04.003

Doc: HT12/3

Today at SRS we have a good future use plan. I am concerned that all of the other sites might not have a similar plan. Our SRS future use plan is an effort to ...maintain the largest national wildlife research area in America. I hope the undeveloped areas at all of the sites have that same protection for their wildlife. With SRSs future use plan, all future development is restricted to only areas that have had prior development. No undisturbed areas are to be developed.

I wish that DOE would make this a DOE-wide policy. I know how developers prefer to build on undeveloped land and are reluctant to take land previously used and reclaim it for new development. Future development on all DOE sites start the trend in America to build new on old abandoned sites.

Response:

The DOE Land and Facility Use Planning process (DOE P 430.1) outlines future site development and reuse based on the shared long-term goals of the Department, the sites, and the stakeholders. Pantex Plant has a Multiple-Use Land Plan which addresses continued land-applied chemical use and grazing in sensitive areas of the Plant as well as a Site Development Plan (DOE 1995j) which addresses the present and future framework for site operations. Four of the playa lakes at the Pantex Plant Site and Pantex Lake have been designated as wetlands. These areas are intended to protect and/or ensure surface water quality and allow compliance with applicable air, water, and other natural resources quality requirements, as well as protecting historical and archaeological sites and ecological resources. The facility construction and modifications presented in the Proposed Action alternative all occur on previously disturbed areas within Zones 11 and 12.

RC: 04.004

Doc: HT12/5

This has to do with the future use of SRS. ...by the way, I just wrote a book on environmental uses of the Savannah River Site.... So Ive done a little research, its just not off of the top of the head sort of thing. But what I want you all to keep in mind is that if we look at a primary use which is industrial,...nuclear or non-nuclear, you can do a lot of things using the land use concept and multiple use, okay? Youve got the primary use right here [that] would be the project that you all are talking about now. And as you go out from this primary area the protection increases.

Are you all aware of this Land-Use Baseline Report that was put out? Well, I want to submit that for you all to look at and read, okay. ...Its a synopsis of what the attributes of the Site are.

Response:

The potential interim storage of pits at Savannah River Site (SRS) is in accordance with the Land Use plans at the site. DOE has reviewed and considered the Land Use Baseline Report in evaluating the impacts.

RC: 04.005

Doc: HT12/37

Savannah River can take these projects and it wont affect the environment. As a matter of fact, if you use a careful planning you can take these projects, put them in the core, weve got 310 square miles, put them in the core and even increase environmental activities in these four or five areas. Does that help?

Response:

The Pantex EIS concluded that use of this federal facility will not affect current missions at SRS, nor will it affect the multiple environmental uses of the site.

RC: 04.006

Doc: PC-024/8

Page 5-3, left column, "The Nevada Test Site," 3rd line. Change the word "owns" to "operates". Change 350,000-hectare to 322,195-hectare and change 864,000-acres to 796,160-acresthe later values are the legal values.

Response:

Text and land area in section 5.2 have been changed in the final EIS with data from the Draft Environmental Impact Statement for the Nevada Test Site and Off-site Locations in the State of Nevada (DOE 1996c). We now state that NTS encompasses approximately 3,500 square kilometers (1,350 square miles) of land area reserved to the jurisdiction of the DOE.

RC: 04.007

Doc: PC-024/16

And finally, I should mention that all the maps of the Nevada Test Site, that are presented in this document, need to be corrected before the Final Pantex EIS is issued. The maps should show the block of land that was withdrawn under Public Land Order 1662, that was to be used in connection with the NTS (23FR 4700). A proper map of the test site can be found on page 4-10 of the "Draft Environmental Impact Statement for the Nevada Test Site and Off-site Locations in the State of Nevada," January 1996 (DOE/EIS 0243).

Response:

The NTS maps have been corrected to include the block of land withdrawn under Public Land Order 1662.

RC: 04.008

Doc: HT17/42

The tremendous growth of agribusiness, especially the fed beef industry and beef processing industry in the Texas Panhandle, has occurred during the time span that Pantex has been operating. I think thats pretty good evidence that agribusiness and Pantex can coexist successfully on both counts. I think its really unfair to couch things as being either pro Pantex or pro agriculture, because they farm onsite at Pantex, they farm around Pantex, theres no problem with the crops that are raised there, and people need to look at the big picture.

Response:

This EIS is being prepared in response to the National Environmental Policy Act, which requires a thorough assessment of any Federal undertaking that may significantly impact the environment, the populace and the local area. Serious consideration is given to existing and potential impacts to all areas, including agriculture, prior to making a decision on a proposed action. This is a method of looking at the "big picture" through documented, and comparative, research and analysis.

RC: 04.009

Doc: HT17/45

...it was very distressful to [me] and other people that had noticed that farming and agriculture, as important as it is, was basically ignored in a lot of these documents or barely mentioned, possibly four paragraphs, a little over, in this document that I noticed.

Response:

Agriculture is discussed in volume I, sections 4.4, 4.5, 4.6, 4.9 and 4.11 of this EIS. These sections have been updated with additional information concerning the regions agricultural base.

RC: 04.010

Doc: PC-025/18

... Is Pantex zoned for agriculture, ranching, water utility, irrigation, treatment, disposal, industrial, residential...? Please analyze the above operations for zoning compatibility including this example: If the plant is not zoned for residential use, does the fire department qualify as residential?

Response:

Zoning is characteristically done in municipalities. Pantex is not inside the boundaries of a municipality. The Pantex Plant is not a residential area. The Plant has a fully staffed fire department located in Zone 12 North. See discussion in section 1.3.3 in this volume.

RC: 04.011

Doc: PC-025/19

On page 4-22. Recommend detailing the location of schools and elderly meeting places including elderly care facilities. It seems to me children and elderly are sensitive areas.

Response:

Because the impacts to the baseline population as a whole are so minute, looking at individual populations is not warranted. However, the 134 primary and secondary schools and the 6 institutions for higher education in the region of influence together with the 27 nursing/convalescent homes in the 9 county region have been included in section 4.4.1.2. in volume I.

RC: 04.012

Doc: PC-025/90

Land Resources assessment methodology is flawed because it does not assess decontamination and decommissioning programs, as stated. There is a flaw since no zoning analysis exists in the analysis to prove or disprove incompatibility. [Where] is an analysis of the Deed?

Response:

At this time no plans have been finalized for the decommissioning of any facilities at Pantex Plant. The designation of facilities is pending decisions regarding the future of Pantex Plant being made in the SSM PEIS. Legal documents concerning land rights were examined and are mentioned in volume I, the summary, chapter 1 and section 4.4.

RC: 04.013

Doc: CO-008/37

Agricultural activities are one aspect of the Pantex Plant. These agricultural operations impact Pantex Plants natural resources [considerably] and yet have received only cursory mention in various sections in the [EIS]. Because agricultural activities have not been detailed in the document as a continuing operation of Pantex, are agricultural activities not to continue on the publics Federal land, or has the public subtly been denied the opportunity to comment on this use?

Response:

DOE owns approximately 2,596 hectares (6,421 acres) of land currently used for agricultural purposes within the combined Main Plant and Pantex Lake areas. These areas are managed by Texas Tech University (TTU) through a service lease agreement with DOE. TTU in turn subleases to local farmers. These local farmers can produce crops or raise cattle. Agricultural activities on DOE property can be limited to the extent necessary to meet Pantex Plant mission needs. However, at this time there is no documentation that suggests that agricultural activities on Pantex Plant will be discontinued. For the impact of this agriculture to soils at Pantex see volume II, appendix I. For impacts to water usage see the discussion in volume I, section 4.1.6.1.

RC: 04.014

Doc: PC-027/5

Before planning to use the Manzano area as a "pit storage" site, coordinate with the base tenants to include Phillips Laboratory. The Manzano area is used for some research and development which may or may not be compatible with the your proposed nuclear pit storage.

Response:

The tenants that will be affected by the interim storage of pits at the Manzano WSA have been considered throughout the EIS process (refer to volume I, section 5.5). Further coordination with these tenants will be initiated if interim storage at this facility is chosen in the Record of Decision. See also response to comment 04.015.

RC: 04.015

Doc: PC-028/3

Page 5-58, 2nd column, para 5.5.1.2. The statement that Manzano WSA is currently being used, in part, [to store] furniture and documents is entirely misleading. Phillips Lab has a major R&D operation in the WSA. The addition of a pit storage facility will have a major impact on access to R&D operations and dramatically change the security posture within WSA.

Response:

The discussion cited focused only on the current uses of the magazines that would be potential locations for pit storage. There are other facilities in Manzano WSA, as the commentor states, but those facilities would not be used for or affected by pit storage.

RC: 04.016

Doc: SG-010/3

In an unrelated issue, we note that the Nevada Test Site is described in the DEIS as a "government owned, contractor-operated facility, currently managed by Bechtel Nevada [and] DOE owns the 864,000 acre site in Nye County, Nevada." This statement is incorrect. DOE does not "own" the Nevada Test Site. The Test Site occupies public lands that have been withdrawn for nuclear testing purposes only. The Final EIS for Pantex must acknowledge that the Public Land Orders for the Test Site do, in fact, limit the use of the site to weapons testing and related research and development facilities only. Moreover, when the Nevada Legislature ceded its jurisdiction to the public lands that now comprise the site, it did so on the basis of certain stipulated uses (i.e., nuclear testing) as defined in the Public Land Orders. Thus, while many believe the lands comprising the Nevada Test Site are federal lands, they are in fact public lands that have been withdrawn for a specific national defense purpose, and that purpose does not include long-term storage of fissile materials, [nor] development of any major disposition technologies such as plutonium immobilization.

Response:

The suggested change was incorporated into volume I, section 5.2.

RC: 04.017

Doc: CO-005/2

In analyzing impacts in this document, the most important issue has to be the region in which the Pantex Plant is located. With the mission of Pantex and related activities being conducted in the heart of production agriculture and the beginning of the food chain, the presumption that these activities do not impact agriculture must be fully assessed.

Response:

See response to comment 04.009.

RC: 04.018

Doc: PC-033/6

I would suggest that the DOE investigate this area further and include more in depth information in the final [EIS], (i.e., land devaluation in the immediate vicinity of the Pantex Plant, comparing past land values to current values and then future approximate values if various facilities/functions are located here; land use or crop restrictions; monitoring information of the offsite vegetation and soils; and possible additional land use requirements/acquirements for various facilities if located here). I have enclosed a DOE generated land use map of the Pantex Plant for your reference.

Response:

NEPA does not require, nor is it customary for NEPA documents to include market analyses. The land use associated with the new facilities proposed in this EIS are discussed in volume I, section 4.4. Additional information about agriculture in the region has been added to this and other sections. Information from soil monitoring activities can be found in volume I, section 4.5. Land use requirements/acquirements for future Pantex Plant facilities are performed as-needed when projects or facilities are projected.

3.5 Geology and Soils

RC: 05.001

Doc: CO-008/32

Pages 4-38 and 4-39. These pages show that soil quality in many sites has been affected. How much soil has been affected? For example, table 4.5.1.3-1, page 4-38, lists 37 sites that have been affected by "burning ground." What is the size of each of these sites?

Response:

Details about each site at Pantex Plant are not included in the EIS. Each grouping of sites is described in general. The decisions being evaluated in this EIS neither affect nor are affected by the environmental restoration program that is addressing the contamination at these sites. The RCRA Facility Investigation (RFI) reports that are being drafted concerning these sites will include tremendous detail concerning these sites. These reports will be available to the public after approval by TNRCC. The amount of detail requested by the commentor is inappropriate to include in the EIS for each group of sites. The information is provided below in response to the comment but will not be included in the main text.

The Burning Ground Assessment includes the Burn Pads (SWMUs 14-27), the Burn Trays (SWMUs 28-36), Landfills (SWMUs 37-44), the Burn Cages (SWMUs 45-46), the Solvent Pit (SWMU 47), the Solvent Pans (SWMUs 48-51), the Burn Rack, and Flashing Pits (SWMU 52). The individual Burn Pads were constructed of a 1-foot thick clay layer over an approximate 15 by 15 feet area, and are approximately 75 feet apart. The Burn Trays are approximately 75 feet long by 10 feet wide by 1 foot deep, and are raised 2 feet above the ground. The landfills associated with the Burning Ground exist as cells, and are approximately 100 to 200 feet long by 20 to 30 feet wide and range from 6 to 23 feet deep. Per the RFI, report the estimated volume of soils that have constituents above the decision criteria set forth for Risk Reduction Standard 2 is approximately 86,000 cubic yards. (Risk Reduction Standard 2 requires removal and/or decontamination of all waste, waste residues, leachate, and contaminated media to standards and criteria such that any substantial present or future threat to the human health or environment is eliminated.) The area of soils around the Burn Pads, Burn Cages, and Burn Racks with the constituents potentially above the decision criteria was defined by a 40 feet radius. The distribution of contaminants present at the Burning Ground vary to depths greater than 20 feet below ground surface.

RC: 05.002

Doc: CO-008/33

Page 4-41, Paragraph 2. This paragraph states that the soil had been contaminated to a depth of 20 feet. It would be very useful for the report to indicate, if the information is available, how the amounts of contamination are changing with time. For example, the amount at 20 feet may be increasing if downward movement from the surface is occurring, or it may be decreasing if degradation is occurring. What are the trends?

Response:

Given the environmental conditions and chemical factors at the Burning Ground, the amount of infiltration, and the sorption capabilities of the contaminants of potential concern (COPCs) and their degradation products, vertical migration of the COPCs in soils and sediments identified at the Burning Ground can be expected to be limited. It is unlikely that COPCs will migrate laterally or vertically much farther than the current extent. With recharge up to 3.24 in/yr possible below playas, from an annual precipitation of 19.1 inches near Amarillo, RDX would travel approximately 27 feet per 100 years. Considering the above playa infiltration rate exceeds the higher-ground recharge rate, migration could be expected to be even less in nonplaya areas. Biodegradation will lessen transport of the organic COPCs as well. Present conditions affirm the fact that contaminants have not typically traveled more than 10 or 20 feet from their source, and they have had up to 45 years to migrate.

RC: 05.003

Doc: CO-008/34

Page 4-41, Paragraph 2. There was no mention of soil remediation processes. Please describe the number of processes that have been undertaken, or planned, for soil remediation that could be used to enhance the natural degradation processes of the contaminants present in the soil. Although extensive monitoring has occurred there seems to be a minimum number of restoration studies.

Response:

The environmental restoration process at Pantex Plant is still mostly in the investigation phase. Subsequent to this phase would be the remediation phase. Currently, potential remediation activities are being developed and recommended to TNRCC, which has the approval authority.

RC: 05.004

Doc: CO-008/35

Page 4-29, Paragraph 1. Please provide a citation for "Caprock Caliche."

Response:

The citation to the reference (Pantex 1996) has been added to volume I, section 4.5.1.

RC: 05.005

Doc: CO-008/71

Page 4-37, Paragraph 2. The letters from EPA and TNRCC documenting their approval for the RCRA methodology undertaken by Pantex Plant should be cited.

Response:

The approval of the methodology is through the issuance of the hazardous waste permit. This language has been incorporated into volume I, section 4.5.

RC: 05.006

Doc: CO-008/72

Page 4-41, Paragraph 2. Please correct typographical error, next to last sentence: "Phase II characterization data is (are)..."

Response:

Correction has been made.

RC: 05.007

Doc: CO-008/73

Page 4-42, Paragraph 3. "The OSTP received waste water from Amarillo Air Force Base and Pantex Plant." Did it also receive waste water from Bell helicopter and the Amarillo Airport?

Response:

The Old Sewage Treatment Plant (OSTP) did receive wastewater from both Bell Helicopter and the Amarillo Airport. The sewer pipeline was then cut so that effluent from the Amarillo Airbase complex flowed into Playa 5. A pump or lift station sent the wastewater on to the OSTP. This continued until approximately 1987 when the newer Wastewater Treatment Plant was brought on-line and the previous agreement maintained by the DOE with the City of Amarillo was discontinued. The EIS has been amended to include this information.

RC: 05.008

Doc: CO-008/74

Page 4-43, Paragraph 2. Potential sources of contamination to Zone 12 groundwater includes the Burning Ground. It would seem that the Burning Ground is too distant to the Zone 12 groundwater location. Please clarify.

Response:

The Draft RCRA Facility Investigation Report for Groundwater in Zone 12 at the DOE Pantex Plant identified the Burning Ground as a potential source of contamination to Zone 12 Groundwater. This is based on the presence of contaminants at depth in soil borings which potentially could leach into the perched aquifer with time. However, to date, groundwater investigations as discussed in volume I, section 4.6, Water Resources, indicate that there is no evidence of hydraulic connection between the perched aquifer in the vicinity of the Burning Ground and the perched aquifer under Zone 12.

RC: 05.009

Doc: CO-008/75

Page 4-43, Paragraph 3. Please provide a map of the landfills locations. Please correct typo in sentence "Characterization data indicates (indicate)..."

Response:

A map of landfill locations has been provided in volume I, section 4.5.1. The typo has been corrected.

RC: 05.010

Doc: CO-008/76

Page 4-43, Paragraph 3. "However, maintenance caps will be placed as needed over selected landfills as a voluntary measure to prevent potential water infiltration." If they are needed, would it be voluntary?

Response:

The term "voluntary" has been replaced by the term "proactive" to clarify that these actions are taken in advance of any possible direction from the regulator.

RC: 05.011

Doc: CO-008/77

Page 4-43, Paragraph 4. Inaccurate descriptions should be corrected: "The ditches also receive untreated industrial waste waters from Zones 11 and 12."

Response:

All available references state that only treated wastewaters for Zones 11 and 12 are placed in the ditches.

RC: 05.012

Doc: CO-008/78

Page 4-43, Paragraph 4. Inaccurate descriptions should be corrected: Playa 4 also receives industrial and storm water effluent from Zones 11 and 12. Playa 2 receives industrial and storm water effluent from Zone 11. All of the playas receive storm water from agricultural areas.

Response:

Pantex Lake and Playa 4 do not currently receive industrial wastewater discharges nor does Pantex Lake receive storm water runoff from Pantex Plant.

RC: 05.013

Doc: CO-008/79

Page 4-44, Table 4.5.1.3-2. Inaccurate descriptions should be corrected:

Flow system 1 consists of Playa 1 and the unlined man-made ditches that direct runoff and waste water discharge away from Zones 4, 11, and 12 to this playa.

Flow system 4...away from Zone 11 and Zone 12 south (insert) to playa 4.

Flow system 5 also includes Pantex Lake (which received effluent from OSTP via pipeline in prior years).

Response:

According to the September 1995 Ditches and Playas RFI (USCOE 1995f), Flow System 1 does not include direct runoff from Zone 4. The inconsistency of not stating that the ditches are man-made and that they direct runoff and wastewater discharge away from Zones 11 and 12 has been corrected. In regard to Flow System 5, page ES-3 of the September 1995 Ditches and Playas RFI indicates that Pantex Lake is a part of Flow System 5. This has been added to volume I, Table 4.5.1.3-2.

RC: 05.014

Doc: CO-008/80

Page 4-45, Paragraph 3. Statements are not clear. "Characterization data indicated that contaminant levels were below remediation goals for all but two sites." Does this refer to 2 of the 12 sites in the AL-PX-11 group, or 2 locations within the HE burn site discussed in greater detail? If the 2 sites excepted are indeed 2 of the 12 sites, then they should be described and discussed, at least in the same detail as was the HE burn site.

Response:

This reference is to 2 of the 12 sites in the AC-PX-11 grouping. Additional discussion of the status of these 2 sites has been added to volume I, section 4.5.1.

RC: 05.015

Doc: CO-008/81

Page 4-45, Paragraph 4. Please correct typo. "Characterization data is (are)..."

Response:

Correction has been made.

RC: 05.016

Doc: CO-008/82

Page 4-45, Paragraph 4. What location was selected for environmental sampling for the DDT spill? At the building or at the playa?

Response:

According to Figure 25-1 of the August 1995 Miscellaneous Chemical Spills and Release Sites RFI (USCOE 1995e), samples for the Building 12-35 DDT release were taken to the north and west of the building, and not at the playa.

RC: 05.017

Doc: CO-008/83

Page 4-46, Paragraph 1. Where is "the denuded [area] near Playa 1" located and what is the cause of its being denuded?

Response:

The denuded area is the former location of an electrical transmission line pole, where annual hand-applied herbicides were reportedly applied for weed control. The site is circular in shape and covers an area of approximately 0.90 acres. The term "denuded" has been clarified by replacing it with "a somewhat barren area where herbicides were applied".

RC: 05.018

Doc: CO-008/84

Page 4-47, Table 4.5.1.3-3. Under SWMU #143 Recommendations: "This area has not been characterized to background for several analytical groups, including pesticides, PCBs, and metals." Please clarify. Does this mean that sampling and analyses have not disclosed concentrations that are consistent with background concentrations (i.e., have exceeded background values), or that sampling and analyses have not been done for these groups of constituents?

Response:

According to page 6-18 of the August 1995 Miscellaneous Chemical Spills and Release Sites RFI (USCOE 1995e), the nature of contamination has been identified on the basis of detected constituents and Risk Drivers. However, the extent of contamination has not been fully defined. Data collected during the RFI indicate that concentrations are now below their Practical Quantification Limits (PQLs). This conflicts with the results of past investigations. It is for this reason that further sampling is recommended to define the extent of constituents identified as contaminants of concern.

RC: 05.019

Doc: CO-008/85

Page 4-49, Table 4.5.1.3-3. Under AOC #15, DDT release at Bldg. 12-35, exactly where did the sampling take place?

Response:

According to Figure 25-1 of the August 1995 Miscellaneous Chemical Spills and Release Sites RFI (USCOE 1995e), samples for Building 12-35 DDT release were taken to the north and west of the building.

RC: 05.020

Doc: CO-008/86

Page 4-49, Table 4.5.1.3-3. Please correct typo, Building 12-5 sump Recommendations: "Additional data is (are)..."

Response:

Correction has been made.

RC: 05.021

Doc: HT13/4

In the EIS, it doesnt show that there are the three faults that go through this stupid mountain, and yet, it is well documented on many geologic reports that there are three major faults that go through the Manzano weapons storage facility.

My question...is if these facilities are 45 years old, they obviously were not built with the current technological skills that go along with earthquake-type design. To me, that is a major concern.

Response:

According to our references, there is no evidence that indicates that any of the three faults in the vicinity of the Manzano Storage Facility are capable faults. A capable fault has one or more of the following characteristics (c.f., 10 CFR 100 Part A): 1) Any movement in Holocene time in the last 10,000 years, 2) more than one movement in the last 500,000 years, 3) demonstrably associated with seismic activity, and, 4) structural relation to another structure shown to be capable.

RC: 05.022

Doc: HT17/25

There is no such thing as nonhazardous seismic hazards. My research into the geological aspects of the Pantex Plant have uncovered some alarming assumptions made by past experts under contract for the DOE. Because a list of specifics is rather long, I have prepared a separate report for your review that will be included in my written comments. The 1995 fault study submitted by the DOE basically suggests that local underground erosion is a primary feature at the Pantex Plant and doesnt delve very deeply at all into the primary feature that occasionally rocks with earthquakes three states at a time. That Pantex is magically divorced from this phenomenon at its property lines and the Whittenburg trough is all but ignored.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.023

Doc: HT17/26

The secrets and lies concerning geology, hydrology, past contamination, current contamination, current pathways, future protections continue. I am willing to go along with the Save the Ogallala Folks, for what good is it to have an unsaved Ogallala, but Im not going to pretend we have anything even remotely close to a pristine situation at the Pantex Superfund Site. We are already in a situation where we just have to drink our poison in small amounts and learn to like it. The massive amount of data contained within the studies done by the Texas Bureau of Economic Geology, the Argonne National Lab, and others prove this. The recent samples showing RDX hits in the Texas Natural Resource Conservation Commission lab test prove this. We would be ignorant to sight future emissions at Pantex without first reviewing the geological hazards truthfully and openly.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.024

Doc: HT17/70

... I understand that we may comment a bit on the cumulative impact from the three PEIS documents, and the Pantex Plant and associated storage of nuclear weapon components PEIS is one that I havent taken as much note of as the other two PEIS documents, but I understand that in this document there...are some omissions [that] have been brought out. One of which, it has been noted that theres nothing said about the Superfund Site projects in the study, and it would seem that might be something important to look at. All of us around here notice the recognition of the Ogallala aquifer, as it is probably, in the United States, the largest fresh water aquifer.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.025

Doc: HT17/71

Its been said that Pantex is using some open and unlined ditches to dispose of waste water, and that should be addressed.

Response:

The use of unlined ditches and the impacts to the soils and groundwater are discussed, respectively, in volume I, sections 4.5.1 and 4.6.1.

RC: 05.026

Doc: FG-003/10

A number of contaminants have been identified in the soil and groundwater (table 4.5.1.3.3-3) at the existing site. The Final EIS should document what measures have been taken to avoid potential contamination by the sources identified.

Response:

The sources identified in the subject table are solid waste management units (SWMUs). Under RCRA most SWMUs are inactive sites and are not, therefore, active sources. However, contamination in the soil could act as a source for groundwater contamination. Therefore, these sites are under the environmental restoration programs scrutiny. See discussion in section 1.3.4 in this volume.

Recommendations have been made to the regulator as to potential remedial actions. These recommendations have been summarized in volume I, section 4.5.1. These recommendations are still in draft stage and have not been approved by the regulator. Active sources operate under permits and are monitored for compliance.

RC: 05.027

Doc: FG-003/12

The DEIS (volume I, p.5-16) states that earthquakes pose the greatest natural threat to storage of plutonium pits at NTS. The Cane Springs Fault was identified as the most significant seismic risk. However, the DEIS indicates that four faults in the NTS vicinity (Mine Mountain Fault) "are capable of generating earthquakes of up to 0.85g," which is an 8.5 quake on the Richter scale. According to the Tritium FEIS (volume I, p. 4-117), the maximum credible earthquake on the Cane Springs Fault is three to five miles from the Device Assembly Facility.

The FEIS should recognize that the P-Tunnel at the NTS is due west of two parallel faults, the Carpetbag Fault approximately five miles away and the Yucca Fault approximately seven to ten miles away. The Tritium FEIS (volume I, p. 4-117) describes both the Yucca and Carpetbag Faults as "capable faults," as defined by the Nuclear Regulatory Commission regulations 10 CFR Part 100, Appendix A. However, the Tritium FEIS reported that the "possible magni- tude, intensity, and acceleration of earthquakes along the Yucca and Carpetbag faults have not been estimated." The DEIS gives the impression that quakes along any of the four faults in the NTS area could have an 8.5 magnitude on the Richter scale (volume I, p. 5-16).

Response:

When a facility specific study of all faults in the region has not been made, the DOE Standard for Natural Phenomena Hazards Design and Evaluation Criteria for DOE Facilities (DOE 1994u) dictates using the largest earthquake expected in the region and assume it can happen anywhere in the region.

RC: 05.028

Doc: PC-025/21

On page 4-39. Drop figure and place more detailed maps in appendix. Recommend using an example map in its place and refer to the appendix. The figure is silly. Otherwise include the location of the ditches and groundwater for completeness. Where is a comprehensive list of titled SWMUs in this EIS?

Response:

A figure detailing the ditches and playas flow system at Pantex Plant has been added to volume I, section 4.5.1, for completeness. A comprehensive listing of titled SWMUs is located in the Pantex Plant Environmental Information Document (Pantex 1996).

RC: 05.029

Doc: PC-025/22

On Page 4-51, Environmental Restoration Activities. Question, "completed by 2000" is not consistent with other statements in the document.

Response:

The year 2000 is correct and has been made consistent throughout the document.

RC: 05.030

Doc: PC-025/23

On Page 4-51, Waste Management Activities. The burning ground is an open area where fumed materials including metals, radioactive elements, etc. are released to the atmosphere and settle to the ground in the form of dust, water vapor, etc. and you state you do not expect impacts to the soil. How can that be...?

What is the representative contaminant deposition rate to the playas and burning ground?

Does HE explode while being burned and chunks of things get spread about?

Is it possible pieces sit around for years?

Further, you state on page 4-52 the material is typically nonhazardous, how did the burning ground get contaminated? Please state you do not know or what the facts are.

Page 4-52, what is the source of the table?

Response:

Volume I, section 4.2, where the assessment methodologies for Geology and Soils are discussed, has been clarified to better illustrate how impacts to geology and soils were assessed. Geological impacts consist of impacts to geological features from plant operations and impacts to the plant operations from geological conditions or events. The search for geological features that could have been affected by plant operations identified only surface water and groundwater. These are discussed in volume I, section 4.6, Water Resources. Seismic events and salt dissolution are the only identified geologic features that could affect plant operations. These issues are discussed in volume I, section 4.5, Geology and Soils. Discussion of soils includes impacts to the soil and impacts to humans from the soil. Potential impacts to the soil included any activities that would result in erosion or removal of valuable soils from agricultural production. These issues are discussed in volume I, section 4.4, Land Use. Impacts from contaminated soil included potential affects on human health.

Contaminated soil within the Burning Ground is discussed in volume I, section 4.5.1.3. There are three potential pathways for any contamination in the soil to affect human health: getting into groundwater, blowing as dust, and uptake by crops. Volume I, section 4.6, Water Resources, describes contaminated groundwater, and volume I, section 4.7, Air Quality, describes the levels of contaminants detected. Crops outside the Burning Ground have shown no contaminants at or above levels of concern. No crops are grown on the Burning Ground.

Contaminant deposition rates were not modeled. The air quality modeling of Pantex Plant activities, including the Burning Ground, was performed to evaluate inhalation which is the overwhelmingly risk-significant pathway. Please refer to volume I, section 4.7, Air Quality, for further information.

When high explosives (HE) is burned it does not generally explode; however, it is known to happen. Safety procedures at the Burning Ground take the risk of explosion into account. When the HE does explode some chunks can get dispersed within the Burning Ground.

The statement made on page 4-52 was incorrect. This section has been modified to read, "These wastes include treated wastewater from the Wastewater Treatment Facility, and construction debris located onsite in a Class 3 landfill. Residuals from the Burning Ground are disposed of in accordance with the specifications of the hazardous waste permit."

The source for each facilities area (PC 1995g) is given in volume I, Table 4.4.2.21. Additionally, this source has been added to the table.

RC: 05.031

Doc: PC-025/91

Geology and soils methodology is flawed since it does not describe what the assessment process is for the assessment. The section dictates what the impacts are. Thus DOE has prejudged the results. The assessment does not address the decontamination and decommissioning program, as stated.

Response:

See response to comment 05.030. At this time no plans have been made for the decommissioning of any facilities at the plant. Any future plans would have to undergo cultural resource and NEPA review before implementation. More detail can be found in volume I, section 1.2.2.1.

RC: 05.032

Doc: PC-016/1

In April of 1995, a study concerning fault identification at the Pantex Plant was sponsored by Mason & Hanger-Silas Mason Co., Inc. (M & HSM), a contractor for the Department of Energy (DOE), in order to satisfy a Note of Deficiency pertaining to a hazardous waste permit application for the Pantex Plant located near Amarillo, Texas. Unfortunately, because this study was under an important deadline to satisfy a requirement of a vital permit for continuing operations, it lacks the benefit of having undergone critical peer review. The data is interpreted and a conclusion is drawn using the opinion of only one expert: Daniel McGrath. The other experts mentioned in reference are not on record as sharing the conclusion he reaches. In fact, one of the geologists mentioned in reference has gone on public record supporting a totally opposite conclusion from the one reached in this study. The DOE fault study is also: incomplete, poorly argued, erroneously formatted, concluded in haste, and thus; invalid.

The Fault Study contains multiple references to an investigation carried out by a team from the Argonne National Lab. The use of references attempts to support the conclusion that Pantex does not sit on top of a fault. Yet, in an apparent contradiction, the Draft RCRA Zone 12 Groundwater Assessment, dated November 1995, and prepared by Argonne, clearly addresses the existence of a major fault beneath the Pantex Plant. The Argonne report includes a powerful [visual] aide that depicts a deep, substantial fault they identify as the Whittenburg Trough. It would seem to be obvious even to the most uninformed person that the experts from Argonne wished to draw attention to this feature. The expert for the DOE correctly states that hydrogeological characterization studies conducted by the Texas Bureau of Economic Geology (TBEG) have focused on mechanisms that would allow for rapid transport of contamination to the Ogallala aquifer. He also includes the fact the faults would provide such a mechanism for the rapid transport of water. But the TBEG reports are oddly silent concerning the word faults, and do not directly address any argument for or against the existence of a fault at Pantex.

Do we have movement in the Holocene time in the last 10,000 years? Answer: Yes. "Holocene faulting has occurred on one portion of the Amarillo Uplift-Wichita Uplift structure and may have occurred on another part of the same structure in Potter County." And: "USR/Blume (1976) cite a Holocene (last 10,000 years) fault scarp 4 miles long, 20 miles northwest of Pantex Plant, on the Amarillo Uplift. Where the Amarillo Uplift extends into Oklahoma, about 150 miles from Pantex Plant, the Meers Fault also has a Holocene scarp. These two examples of Holocene faulting along the Amarillo Uplift structure show the presence of some level, although clearly not intense, of the tectonism along this Paliozoic uplift."

Do we have more than one movement in the last 500,000 years? Answer: Yes. As stated above, "...a Holocene fault scarp 4 miles long, 20 miles northwest of the Pantex Plant, on the Amarillo Uplift...within the last 10,000 years..."

Do we have demonstrated associated [seismicity]? Answer: Yes. "...recent 11-year span, from January 1, 1977 to March 31, 1988, more than two dozen quakes measuring 2 or higher on the Richter scale were detected in the Texas Panhandle and South Plains, Oklahoma Panhandle and far Western Oklahoma, and the southernmost strip of Kansas...quakes estimated to be 4 to 4.5 on the Richter scale occurred on March 27, 1917; July 30, 1925; July 20, 1996; February 20, 1974;...and others during 1934, 1948, and 1959..." And: "... Since local records began in 1882, there have been four earthquakes in the Plant area. These occurred on March 27, 1917; July 30, 1925; June 19, 1931; and July 20, 1966..."

Do we have a structural relationship to another structure that has been shown to be capable? Answer: Yes. "... Holocene faulting has occurred on one portion of the Amarillo Uplift...and may have occurred on another part of the same structure in Potter County." And: "An assessment of natural hazards at Pantex Plant (Jacobs 1993) lists "three major subsurface faults and minor surficial fault" in the area of the Plant, as follows: (1) 155 miles long, about 25 miles north of site, (2) 43 miles long, [about] 5 miles [south] of site, (3) 40 miles long, about 7 miles north of site, (4) 4 miles long, about 20 miles northwest of site, surficial, USR/Blume (1976) have suggested that faults (3) and (4) may connect."

If a capable fault must show one or more of the above [characteristics], and we have just shown that all four characteristics are demonstrated, then it stands to reason that we have a capable fault. Fortunately for all of us, recent seismic activities at and near Pantex have been light to moderate. Pantex is currently classified as being in Earthquake Zone Number 1. Ponder the very wise message contained within the following quote: "Seismic hazards, most notably active faults, are considered unacceptable for [nuclear] facilities such as the Pantex Plant"- Daniel McGrath, Soil Scientist April 1995.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.033

Doc: PC-016/2

"Do we have earthquakes here?" Answer: Yes. (Page 3.)

"Do our core samples at the Pantex Plant show contrasting vertical and horizontal layers?" Answer: Yes. (TBEG, Argonne, McGrath.)

"Do we have evidence that the Pantex Plant is near an epi-center for earthquakes?" Answer: Yes. The only local quake on record during this century that successfully damaged a man-made structure occurred in Panhandle, Texas. Panhandle is the closest town to Pantex. The strongest local quakes occurring during this century are said to have had epi-centers located about 10 to 20 miles from the Pantex Plant. (Page 3.)

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.034

Doc: PC-016/3

"Do we have groundwater samples showing differences that can sometimes indicate a fault?" Answer: Yes. According to the DOE expert, water in the [Dockum] group beneath the Pantex Plant is significantly better than the water found in other area [Dockum] wells. This fact indicates that the Ogallala aquifer is not a confined aquifer. The Ogallala aquifer may be contributing to a more rapid recharge to the [Dockum] waters beneath the plant due to a fracture or fault. The TBEG report of May 1995 describes a large "channel" that is allowing water to flow faster near the top of the "middle Ogallala perching horizon." Further studies would tell us more about the lower horizons.

Response:

Though the water quality in the Dockum Group aquifer beneath the Pantex Plant is relatively good, this does not necessarily indicate a fault, but it points to the intermixing of waters from the Ogallala aquifer and the Dockum Group aquifer. This intermixing could result from the movement of water as it is pumped from the Ogallala aquifer. For more detail about the faults see discussion in section 1.3.4 in this volume.

RC: 05.035

Doc: PC-016/4

"Did the ground radar type of studies confirm that we have sharply tilted vertical soil layers beneath the Pantex Plant?" Answer: Yes. And further study would provide more description of these layers.

Response:

This does not necessarily mean that there is a fault or tectonic activity. Subsidence can cause deformation below the surface of the strata layers which can complicate reaching conclusions about tectonic deformation. The commentor suggests further study of the deformation to further define the seismic risk to Pantex Plant. DOEs current conservative assessment of seismic risk does not require this specific information. The current risk assessment is discussed in volume I, section 4.14, Human Health.

RC: 05.036

Doc: PC-016/5

"Do we have sink spots (subsidence) at the Pantex Plant?" Answer: Yes. The playas at Pantex are "sinks". Subsidence has influenced the development of many of the larger playa basins at the Pantex Plant.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.037

Doc: PC-016/6

"Did the expert for the DOE overlook the fact that he proved the case demonstrating the characteristics of a capable fault?" Answer: Yes. Unfortunately, when scientific papers are not shared with other experts, even a good scientist can make a big mistake. A process called "peer review" involves many experts getting together to see if somebodys idea is right or wrong. "Peer review" is pretty important to scientists, because they can look [a little] silly if they go on record with bad information or wrong ideas. Because we cannot control earthquakes, experts try to look very hard to identify the safest places to build important buildings such as the ones at the Pantex Plant. Experts agree that geological faults are not the safest places to build important buildings on. Buildings that handle very dangerous nuclear materials and hazardous chemicals are not supposed to be built on a capable fault.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.038

Doc: PC-016/7

"Do we have experts who have indicated that the Pantex Plant was built on a geological fault?" Answer: Yes. On January 8,1994, a [petroleum] geologist named Greg Wilson talked about his studies into the High Plains area. He indicated that Pantex was on a fault, and thought more studies should be done to prove this. Other experts from the Argonne National Lab have included maps in their studies that show a picture of a deep fault beneath the Pantex Plant. An expert from TBEG has shown that subsidence has played a part in the formation of playas on the High Plains. Some experts use very clear language to explain their positions, and some do not. Sometimes experts like to use very big, difficult words if they dont want to answer a question. We need to be careful about becoming confused when experts talk, and learn to look more carefully at the facts.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.039

Doc: PC-016/8

A hard look at the facts concerning the sub-surface surface conditions at the Pantex Plant, in the present (here and now) time is in order. Nearly every branch of specialized investigation is required to do this. Capable engineers, physicists, geologists, hydrologists, chemists, biologists seismologists, and [historians] all need to be consulted to clarify the current situation.

If academia chooses to mismanage the vast body of information that has been generated in recent investigations into the Pantex Plant, and deliberately presents a false model of the circumstances beneath the Pantex Plant, then they will also predict a false outcome. Anticipating change and predicting outcomes was once solely the responsibility of "seers" and prophets. But science, of its own [curiosity], evolution, and arrogance now shares a responsibility for predicting accurate outcomes. The genie cannot be put back into the bottle, but perhaps the genie can be better understood and better [disciplined]. If each branch of the sciences now met openly to discuss and review the current information generated by the investigations conducted recently at the Pantex Plant, a more useful "band-aid" might be applied to the wound.

Neither the expert or the non-expert should become "lulled into complacency" just because the strength of local earthquakes during this century have been light to moderate. Geological fault-science has proven that the ground shakes hardest along fault lines. Although new or unknown faults can also surprise experts by suddenly becoming seismically active, known faults simply should not be ignored. If the tectonic activity continues to increase substantially along the Pacific Rim, it could affect tectonic activity as far away as places like the Panhandle of Texas. Assessing geological sensitivity for the purpose of siting work with dangerous actinides is urgent and vital. Earthquake activity both at and around the Pantex Plant has been fairly consistent since records started a century ago. Not a single decade has passed in the Panhandle that some amount of seismic activity has not occurred. Above all, the contamination concerns may become secondary to criticality concerns, as a chain reaction in a geological setting would generate radiation and extreme heat in addition to releasing fission product contamination. As some experts very well know, it only takes small amounts of certain actinides suspended in water to achieve criticality. Because of the instability of the Amarillo Uplift/Whittenburg Trough/Potter County Fault connection to the Pantex Plant, and the threat the surface and groundwater may present to certain actinides indicated to already be trapped in the soil, appropriate actions need to be taken promptly.

Response:

The EIS has examined the affected environment and the environmental consequences at Pantex Plant. This examination was completed by a broad range of professional disciplines (please see volume I, chapter 8, List of Preparers, for further information).

RC: 05.040

Doc: SG-003/25

Page 4-3, section 4.2, Impact Assessment Methodologies, geology and soils: Impacts should be assessed on the destruction of any geologic feature, not just those specified unique.

Response:

The Impact Assessment Methodologies for Geology and Soils has been clarified. The uniqueness of a feature is taken into account in assessing the significance of any potential impacts. See response to comment 05.030.

RC: 05.041

Doc: SG-003/65

Sections 4.5 and 4.6, which describe water resources and geology and soils, do not provide sufficient information for the reader to determine if environmental impacts could result from continued operations and storage of nuclear weapons at Pantex.

Response:

Sections 4.5 and 4.6 in volume I have been updated with additional data, new permit requirements, and descriptions of corrective action measures.

RC: 05.042

Doc: SG-003/67

Some of the maps in this document are used without referencing or obtaining permission of the author. Figure 4.5.1.2-1 was published by Gustavson (1981), but attributed to DOE (1981). Figure 4.5.1.2-2 was prepared by Davis, Pennington and Carlson (Davis 1989), but attributed to DOE 1995.

Response:

The citations for both figures have been revised to give credit to the primary authors.

RC: 05.043

Doc: SG-003/68

Page 4-27, Geomorphology, para. 1, ln 13. It is inaccurate to state that playa could play a role in the contamination of groundwater at Pantex Plant. Playa basins and ditches have been shown to be the sites where contaminated surface water is recharged to the subsurface (Gustavson and others, 1995).

Response:

The sentence in question has been revised in volume I, section 4.5.1.1. Neither the original nor the current statement implied that contaminated surface water is recharged to the subsurface. However, noncontaminated water applied over areas of contaminated soil have the potential to pick-up contamination from the soil and transport the contamination to groundwater.

RC: 05.044

Doc: SG-003/69

Page 4-27, Stratigraphy. para. 1, ln 4. The Blackwater Draw and Ogallala Formations beneath the Pantex Plant are not lithified and therefore are not rocks. The correct term is sediments. Rephrase sentence to "The stratigraphy of the sediments and rocks..."

Response:

Sentence has been modified to read: "The stratigraphy of the sediments and rocks beneath Pantex Plant is discussed in descending chronological order from more recent layers (surface deposits) to Permian -age layers (salt deposits)."

RC: 05.045

Doc: SG-003/70

Page 4-27, Stratigraphy, para. 2, ln 6. The upper unit of the surface Soil (Pullman clay loam) of the Blackwater Draw Formation is the A horizon and it contains no caliche. The first soil carbonate is found at a depth of about 24 inches in the upper part of the B horizon (US Department of Agriculture, Soil Conservation Service, 1972, Pullman Series: Established Series, 4 p).

Response:

The information has been incorporated into volume I, section 4.5.1, and the sentences have been revised accordingly.

RC: 05.046

Doc: SG-003/71

Page 4-29, Stratigraphy, para. 1. The variable lithologies of the Ogallala and Blackwater Draw Formations are not described. These descriptions should include a brief discussion of the complex heterogeneity of the Ogallala and Blackwater Draw because the variation in sediment types controls groundwater flow in the formation.

Response:

A more detailed discussion of the variable lithologies of the Ogallala and Blackwater Draw Formations has been incorporated into volume I, section 4.5.1.

RC: 05.047

Doc: SG-003/72

Page 4-29. Sentence describing the lower part of the Ogallala implies that the fine-grained zone is the base of the lower Ogallala and generally confuses channel deposits above the fine-grained zone (which actually falls within the middle part of the Ogallala) with predominantly fluvial Ogallala sediments within the lower part of the Ogallala [from] below the fine-grained zone.

Response:

See response to comment 05.046.

RC: 05.048

Doc: SG-003/73

Page 4-29, Stratigraphy, para. 1, ln 29. The fine-grained zone is not a sandstone. Limited available core from the fine-grained zone shows interbedded sands, silty sands, and muds. Because of the variability of sediments in this unit, the vertical hydraulic conductivity varies by 3 orders of magnitude. Geophysical logs and core show that at least part of the fine-grained zone consists of fining upward sequences of fine sand, silty to clayey sand, and mud. Furthermore, these sediments are not lithified; thus, they are not sandstones.

Response:

See response to comment 05.046

RC: 05.049

Doc: SG-003/74

Page 4-30, Figure 4.5.1.1-2. Well PXSB-03 is not just coarse sand. There are about 50 feet of sand and gravel near the bottom of the well.

Response:

This map has been deleted. A sentence has been added which refers readers to Figure 4.6.1.23 in volume I, section 4.6.1. This figure is a geologic cross-section of the lithology beneath Pantex Plant.

RC: 05.050

Doc: SG-003/75

Page 4-31, para. 3, ln 1. Salt dissolution and accompanying subsidence or collapse are rapid processes on a human time scale. More than 2,000,000 tons of salt are dissolved each year along the eastern margin of the High Plains in the Texas Panhandle. Furthermore, about 2 years ago a very large sinkhole (250 ft wide and more than 60 ft deep) formed in northeastern Hall County, which like the Pantex Plant lies in the salt dissolution zone shown in figure 4.5.1.21. Development of this sinkhole was described in the Amarillo newspaper.

Response:

Estimates of salt dissolution rates along the eastern escarpment of the Southern High Plains were tabulated in Regional Dissolution of Permian Salt in the Anadarko, Delhart and Palo Duro Basins of the Texas Panhandle (Gustavson, et al, 1980). Although no estimates were provided for Carson County, mean salt dissolution rates ranged from 1.0312 x 10-5 feet per year for a site in Potter County to 5.6674 x 10-5 feet per year for a site in Armstrong County. Assuming that this range is applicable to salt dissolution rates at Pantex Plant, then approximately 0.002 to 0.006 of one inch of salt dissolution would occur during the entire 10-year time frame covered by this site-wide EIS. For additional discussion of salt dissolution, please refer to section 1.3.4 of this volume.

RC: 05.051

Doc: SG-003/76

Page 4-31, para. 3, ln 1. No attempt is made to describe the role of salt dissolution and subsidence in the formation of playa basins. High solute loads in streams draining the region indicate that these processes are active regionally. No mention is made of the potential effects, if any, of dissolution-induced subsidence at the plant.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.052

Doc: SG-003/77

Page 4-31, para. 3, ln 11. While it is true that sinkholes or fractures associated with salt dissolution have not been described in Carson County, several playas on or near the Pantex Plant have been associated with dissolution induced subsidence. Furthermore, sinkholes or fractures have been identified in adjacent Armstrong and Donley Counties to the south, in Potter County to the west, and in...

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.053

Doc: SG-003/78

P. 4-32, Figure 4.5.1.2-1. Gustavson (1981) who compiled the information on which this map is based, showed that sinkholes or fractures have been recognized in Oldham, Potter, Donley, Briscoe, Motley, and Dickens Counties in addition to the counties shown here.

Response:

The referenced figure, Figure 4.5.1.23 (formerly Figure 4.5.1.21 in the Draft EIS) "Zones of Active Salt Dissolution and Counties in which Sinkholes and Fractures Were Identified (DOE 1981)", was checked for accuracy against the original figure contained in the reference document, "Impact of Evaporite Dissolution and Collapse on Highways and Other Cultural Features in the Texas Panhandle and Eastern New Mexico (Gustavson 1981)." There were no mistakes in the translation of this figure. Another figure in this reference cites that there are no sinkholes, collapse depressions, or fractures/faults in Donley, Motley, or Dickens counties. This document did not contain additional information in the text to say that there were sinkholes or fractures in any of the counties mentioned in the comment (i.e., Oldham, Potter, Donley, Briscoe, Motley, and Dickens counties).

RC: 05.054

Doc: SG-003/79

Page 4-33, para. 2. Davis, Pennington, and Carlson (1989) reviewed in considerable detail the history of earthquakes in the Texas Panhandle. Events are shown using the Richter scale.

Response:

The commentor is correct when citing that Davis, Pennington, and Carlson (1989) reviewed the history of earthquakes in the Texas Panhandle in detail. These authors wrote a document, "A Compendium of Earthquake Activity in Texas," which was referenced in the Pantex Plant Environmental Information Document (Pantex 1996).

RC: 05.055

Doc: SG-003/80

Page 4-33, Soil Types, para. 2 or 3. No attempt is made to point out that Randall clay soils are Vertisols and that deep desiccation cracks and root tubules, which are potential pathways for recharge, are characteristic of these soils. Furthermore, these soils have a udic moisture regime, which means that water moves down through the soil at some time in most years. That is, recharge occurs through even these clay soils.

Response:

Further detail on Randall and Pullman soils has been incorporated into volume I, section 4.5.1. The following text has been added about Pullman soils, "This soil is classified as a Mollisol, which is noted by wide deep cracks throughout the year. These cracks aid in groundwater recharge. The major uses for these soils are grazing and dryland farming." The following text has been added about Randall soils, "This soil is classified as a Vertisol, which contains a large amount of clay and has cracks at some time of the year."

RC: 05.056

Doc: SG-003/81

Page 4-33, Soil Types. In the discussion of soil sampling activities, there is no mention of the preliminary soil sampling that took place as a result of the May 1989 tritium release. This is a significant problem resulting from this omission for two reasons. First, there is no mention of this event or the known areas of contamination within these report. Second, there have still not been any characterization efforts completed beyond the initial preliminary assessment, to determine the amount of contamination from this tritium release. This lack of characterization continues despite, at least using one data set, the apparent increasing tritium levels in perched groundwater in the area of playa 1.

Response:

Soil sampling took place as the result of the tritium release at cell 12-44-1. This sampling was nonroutine and was reported in the Annual Site Environmental Reports (ASERS).

This incident is not discussed in the Geology and Soils section, but it is discussed in the Human Health section.

There have been three types of prior evaluations of cell 12-44-1 and its releases. The first evaluation was to calculate offsite doses to a maximally exposed individual, as required by both DOE 5400.1 and 40 CFR 61. The second type of evaluation was to characterize the contamination of the cell to plan for radiation protection measures during decontamination activities. The third type of evaluation was to implement routine air monitoring and conduct special purpose soil and vegetation sampling in the vicinity of cell 12-44-1.

Volume II, appendixes C and I incorporate water and soil sampling information. For more information regarding radionuclide sampling, please see these sections.

RC: 05.057

Doc: SG-003/82

Page 4-35, Figure 4.5.1.2-2. Pantex is incorrectly located on the map. The correct location is approximately 1/4-inch to the northeast of the center of the black square or immediately adjacent to the system of faults and earthquake locations that mark the buried Amarillo Uplift. The city of Amarillo is not located on the map.

Response:

Corrections have been made to volume I, Figure 4.5.1.22.

RC: 05.058

Doc: SG-003/83

Page 4-50. The statement is made that there is no surface expression of sinkholes or fractures associated with salt dissolution in Carson County. We argue that, based on seismic data at the plant, the playas themselves are a sinkhole-like expressions of salt dissolution.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.059

Doc: SG-003/84

Page 4-50, [Weapons] Related Activities, para. 2, ln 2. The statement is made that the "potential impacts due to subsidence (resulting in sinkholes and/or surface rupture) are considered negligible because salt dissolution is a slow process relative to human activities." While the rate of salt dissolution may be slow relative to geologic time, the surface expression of salt dissolution can be catastrophic and result in the loss of life and property. Another inaccurate statement in this same paragraph refers to the absence of sinkholes in Carson County. Paine (1994) demonstrated that many playa basins in the vicinity of the Pantex Plant formed as a result of surface subsidence over areas of salt dissolution. In this context playa basins are similar to sinkholes found elsewhere in the salt dissolution zone. Thus, it is inaccurate to imply that there are no subsidence features in Carson County by simply stating that there are no sinkholes. A better approach would be to explain that sinkholes are the product of catastrophic, rapid collapse into an underground cavern. Playa basins on-the-other-hand formed in part as the result of relatively slower surface subsidence over areas of salt dissolution.

Response:

See discussion in section 1.3.4 in this volume.

RC: 05.060

Doc: PC-030/4

The contaminated soil should be cleaned as soon as possible to mitigate flushing caused by storm run-off.

Response:

Investigations of the ditches and playas, related to the potential for contamination, and the development of remediation plans are ongoing through the Pantex Plant environmental restoration (ER) program (Pantex 1996: 5.2). Volume I, section 4.5.1.1, has been revised to incorporate this information.

RC: 05.061

Doc: PC-033/4

In the Draft [EIS] I did not find the impact on area farmers when they are plowing, planting, or harvesting the crops in the possibly contaminated soils of the Pantex Plant property. If this information is available, I would like a copy please, and if it is not, I would like to have this included in the Final EIS.

Response:

Volume I, section 4.5.1.3 discusses the soil and sediment quality as a result of the sampling at the Pantex Plant. The sampling that took place occurred on the property belonging to the Pantex Plant not Texas Tech University. Agriculture activities, as related to soil quality, would not impact the health of the farmers who work the land.

3.6 Water Resources

RC: 06.001

Doc: HT11/26

Can you talk at all about water usage...for the dismantlement of the 20,000 pits at Pantex?

Response:

To elaborate on the response given at the public hearing, this information on weapons dismantlement is summarized in volume I, section 1.2.2.1. Volume I, section 4.6.2.3, has been modified to include this detailed information for clarification purposes.

RC: 06.002

Doc: HT11/27

But the Pantex Plant feels that there is enough water to disassemble the entire 20,000?

Response:

Yes, groundwater resources are available for continued operations at Pantex Plant. The plant uses only a small percentage of the groundwater resources of Carson County. See discussion in section 1.3.5 of this volume for details.

RC: 06.003

Doc: HT05/1

On page 4-13 it's stated, and I quote, that the City of Amarillo has pledged 5,526 million liters of water, or 1.6 million gallons per year as a potential part of the Pantex expansion.

a. All my questions are [on] the disposition issues considered expansion missions and,

b. Where is the City of Amarillo planning to withdraw that amount of water from?

Response:

To elaborate on the response given at the public hearing, the City of Amarillo pledged 5,526 million liters of treated wastewater per year for the tritium supply mission, which required large quantities of water in excess of the plants production capacity. However, the decision has been made not to locate the mission to Pantex Plant. The tritium supply mission has since been assigned to the Savannah River Site.

a. Disposition missions were not part of the tritium supply mission for which the pledge was made. However, the City of Amarillo would likely extend the same pledge for any new, large missions that might need such quantities of water. The continued operations discussed in the Pantex EIS would not require the quantities of water discussed for the tritium supply alternative and, therefore, would not require the use of the pledged water.

b. If there were a mission that required large quantities of treated wastewater, the City would develop reclaimed wastewater from the City of Amarillo Hollywood Road Wastewater Treatment Plant. The use of reclaimed wastewater could curtail the annual withdrawal rate from the Ogallala aquifer.

RC: 06.004

Doc: HT05/2

And, if...[pledged water] were to come from Carson County, where we already experience significant groundwater declines, it would mean that, if this total amount was used,...a 23 percent increase in groundwater withdrawals from that area.

Response:

The pledged water would come from treated wastewater, not groundwater. See response to comment 06.003 for additional details.

RC: 06.005

Doc: HT05/3

I know the City has extensive groundwater rights. My main question is whether and what criteria and how long is the pledge good for and those kind of things?

Response:

See response to comment 06.003.

RC: 06.006

Doc: HT05/4

So it's an ongoing offer? So there's no time frames?

Response:

See response to comment 06.003. We understand that the offer is only contingent upon new work (jobs) being brought to the plant.

RC: 06.007

Doc: HT05/5

... I think it's...a typographical error or something. But, in reading on Page 4-78, it was going into the agricultural uses in Carson County. And they had stated in that that there [were] 8,550 acres of irrigated agriculture in Carson County.

And a check with the Farm Service Agency, which is a Federal regulatory agency, on the amount of acres in 1995 was 63,500 acres. Your withdrawal figure seems to be somewhat within range, but your acres are quite a bit off.

It's the Farm Service Agency [that] used to be ASCS. It's the government's regulatory agency for the Federal Farm Program. And they keep it down to the 10th of acres, so I know that they're correct.

Response:

On May 30, 1996, we received updated (1995) data from the Panhandle Ground Water Conservation District (PGWCD) and the Farm Service Agency, which reported a total of 63,629 acres were irrigated in Carson County in 1995. PGWCD estimated a corresponding total irrigation pumpage of 81,702 acre-feet (26.6 billion gallons) in Carson County in 1995. Volume I, section 4.6.1.2, has been updated with this information.

RC: 06.008

Doc: CO-008/62

Page 4-234, Paragraph 4. In light of the BEG study, please define the statement, "hypothetical plutonium dispersal accident does not pose a significant threat to the Ogallala aquifer."

Response:

Accident scenarios meet the risk limitation criteria discussed in volume I, section 4.14. The source of the referenced Bureau of Economic Geology (BEG) study are stakeholder comments, submitted by BEG through the State of Texas (February 25, 1993), in an Environmental Assessment describing current weapon staging and proposed component interim storage operations in Zone 4 of Pantex Plant and a related supplemental report entitled "Potential Ogallala Aquifer Impacts of a Hypothetical Plutonium Dispersal Accident in Zone 4 of the Pantex Plant" (LANL 1992). The Los Alamos National Laboratories (LANL) report assumed an average recharge rate of 3 centimeters per year. In their stakeholder comments on the LANL report, BEG commented that recharge rates ranging from 1.3 to 8 centimeters per year may be more applicable for the LANL study. BEG also raised additional questions regarding travel time estimates calculated in the LANL study including, the effects of focused recharge, recharge rate estimates of 15.2 to 63.3 centimeters per year based on dating tritium concentrations in groundwater, and calculation of a "conservative" velocity for determining contaminant transport. DOEs responses to BEGs and other stakeholder comments are provided in the "Environmental Assessment for Interim Storage of Plutonium Components at Pantex and DOE Response to Comments on the Pre-approval Environmental Assessment and the Revised Pre-approval Environmental Assessment and Public Meeting," volume I, section E, (DOE 1994w). This document is available for review in area public reading rooms.

RC: 06.009

Doc: CO-008/87

Page 4-55, Paragraph 6 (last paragraph and continuation on page 4-57). Treated and untreated industrial discharges and stormwater, from both agricultural and industrial areas, are directed to Playas 1, 2, and 4. [See Table 4.6.1.1-2 page 4-59....]

Response:

According to the 1995 Environmental Report for Pantex Plant (DOE 1996f:111), all effluents from plant operations are treated and, along with some noncontact industrial discharges (e.g., steam condensate), are directed into ditches that drain to Playas 1, 2, and 4. Runoff from the southern portions of Zones 11 and 12 flow into Playa 4. Volume I, section 4.6.1.1, and volume I, Table 4.6.1.12, have been modified to reflect this updated information.

RC: 06.010

Doc: CO-008/88

Page 4-56, Figure 4.6.1.1-1. Please check figure for Pantex Lake. The figure provided does not appear to be Pantex Lake. Please show full extent of Pantex Lake.

Response:

The referenced figure includes only the western portion of the Pantex Lake floodplain, set to scale. There are no current or proposed activities to be conducted at Pantex Lake. Therefore, the full extent of Pantex Lake was not included in the figure in the Draft EIS. Figure 4.6.1.12, showing the full extent of Pantex Lake, has been added to volume I, section 4.6.1.1.

RC: 06.011

Doc: CO-008/89

Page 4-57, Paragraph 5 "Flow from the WWTF is small but continuous." What quantity is "small?" This term seems inappropriate and subjective. Please quantify.

Response:

The National Pollutant Discharge Elimination System (NPDES) Permit (No. TX-0107107) specifies a 0.65 million gallons per day daily average discharge limitation for Outfall 001. This permitted average daily discharge has been included in volume I, section 4.6.1.1.

RC: 06.012

Doc: CO-008/90

Page 4-60, Paragraph 2. At what cost is potable water provided to TTU?

Response:

The Pantex Plant provides Texas Tech University (TTU) with water for grazing cattle under a service agreement with TTU. Water is sold to TTU at a negotiated price per the interagency agreement between DOE/AAO and TTU.

RC: 06.013

Doc: CO-008/91

Page 4-61, Paragraph 6. Requirements provided for the "TNRCC draft permit" seem unusually similar to the current permit. Please provide updated permit information.

Response:

A summary of requirements of the Final NPDES Permit (No. TX-0107107) have been discussed in volume I, section 4.6.1.1, and are provided in volume II, appendix C.

RC: 06.014

Doc: CO-008/92

"As discussed in section 4.6.1.1, surface water discharge permits have been in effect since the late 1980's..." According to information you provided, a permit was first issued in 1980 (which is not "late").

Response:

The sentence has been modified to state, "surface water discharge permits have been in effect since 1980...".

RC: 06.015

Doc: CO-008/93

Page 4-58, Table 4.6.1.1-1. Why were Burning Ground structures not considered?

Response:

The Natural Phenomena Hazards Modeling Project: Preliminary Flood Hazards Estimates for Screening Department of Energy Sites: Albuquerque Operations Office, (LLNL 1988), states that there are no structures located near Playa No. 3. Structure elevations are not referenced in the Pantex Plant Floodplain Delineation Report (DOE 1995c). Although the elevations of Burning Ground structures were not included in these floodplain studies, they have been added to volume I, Table 4.6.1.11, as requested. The only structures that currently exist above ground at the Burning Ground are the Explosive Burn Trays. These structures have a height of 2 feet above ground surface and an approximate surface elevation of 3,572 feet above mean sea level. The Explosive Burn Trays are outside of the 100- and 500-year delineated floodplains for Playa 3, and are therefore in compliance with 40 CFR 264.18, location standards for floodplains.

RC: 06.016

Doc: CO-008/94

Page 4-13, Paragraph 4, "The City of Amarillo has pledged 5,526 million liters per year (1,460 million gallons per year) as a part of potential plant expansion." Are disposition missions considered expansion?

Where is the City planning to withdraw this amount of water? If it were to come from their Carson County Well Field, it would be a 23 percent increase in current pumping and would significantly add to the excessive drawdown problem in that area.

What are the timeframe and conditions of the pledge?

Response:

See response to comment 06.003.

RC: 06.017

Doc: CO-008/95

Page 4-78, Paragraph 2. "In 1989, 760 irrigation wells in Carson County pumped 115 billion liters (30.5 billion gallons) to irrigate approximately 3,460 hectares (8,550 acres). This is incorrect. A check of Farm Service Agency irrigated acres in Carson County revealed 63,500 acres in 1995.

PGWCD estimated irrigation pumping of 26.3 billion gallons of water pumped in 1995.

Response:

See response to comment 06.007.

RC: 06.018

Doc: CO-008/96

Page 4-78, Paragraph 4. "Pantex Plant is located [in] Panhandle Groundwater Conservation District No. 3, which has the authority to require permits and limit the quantity of water pumped. Presently, the Panhandle Groundwater District does not limit the quantity of water pumped." That statement is true for wells drilled and in use prior to July 19, 1995. For new wells, drilled after July 19, 1995, a landowner whose well produces annually more than 350,000 gallons of water per acre owned, on a section by section basis, will be required to obtain a High Production Permit from the District.

Response:

The sentence, "Presently, the Panhandle Groundwater Conservation District does not limit the quantity of water pumped" has been modified to state, "Historically, the Panhandle Groundwater Conservation District...". Another sentence has been added that states, "However, for new wells drilled after July 19, 1995 that produce annually more than 1.3 million liters (350,000 gallons) of water per acre owned, on a section by section basis, landowners will be required to obtain a High Production Permit from the Panhandle Groundwater Conservation District."

RC: 06.019

Doc: CO-008/97

... Please define the extent and migration of the contamination. More information is needed to define the extent of the perched aquifer and whether it is in communication with the Ogallala aquifer.

Response:

Discussion of the extent and migration of contamination in the perched aquifer has been updated to reflect the most recent data available at the time of publication. Additional information, discussed in section 1.3.5 of this volume, has also been included in volume I, section 4.6.1.2.

RC: 06.020

Doc: CO-008/98

... Are fissures present that would allow movement of the perched water to enter the Ogallala aquifer?

Response:

The term "fissure" refers to cracks, breaks, or fractures in rock. The Ogallala aquifer consists primarily of unconsolidated sand, silt, clay, and gravel. Unconsolidated materials are not prone to the development of fissures. However, there is the potential for groundwater from the perched aquifer to move downward toward the Ogallala aquifer through voids between unconsolidated sand, silt, clay, and gravel particles. Coarse-grained gravels and sands transmit water faster than fine-grained silts and clays. Fine-grained material creates localized perching zones that limit the downward vertical movement of infiltrating groundwater, as discussed in volume I, section 4.6.1.2.

RC: 06.021

Doc: HT02-04/4

Records show that Pantex is monitored for some 160 different contaminants. And why is it being monitored for these contaminants? Because they didnt know it, but they sent it into the groundwater. And I am addressing you as Pantex, but this forum also needs to address the fact that these discharges are only monitored, contaminant by contaminant.

Response:

Pantex Plant has several ongoing routine and non-routine monitoring programs to identify the contaminants of air, soil, surface water, and groundwater.

Volume I, section 4.5.1.3, and volume II, appendix I, discuss the surveillance programs for soil and environmental restoration activities. Volume I, Table 4.5.1.33, and Table I.1.2.13, volume II, Table I.1.2.13 characterize the soil contaminations and quantify them.

Volume I, sections 4.6.1.1 and 4.6.1.2, and volume II, appendix C, discuss and quantify the chemical constituents that exceed surface water and groundwater quality decision criteria.

Ambient air quality is described in volume I, section 4.7.1.3 and volume II, appendix B. Volume I, Tables 4.7.1.34 and 4.7.2.12, identify the air pollutants emitted from site-wide Pantex Plant operations and quantify them, contaminant by contaminant.

RC: 06.022

Doc: CO-008/99

Page S-15, Table S-1. The table on page S-15 should show percentages, to give the reader perspective on water use.

Example:

a. Plant used 230 million gallons in 1995.

Texas Tech Farms used 66 million gallons (29%) of the total usage.
Nuclear weapons operations used 163 million gallons (71%).

b. City of Amarillo consumed 16 billion gallons of water in fiscal year 1995.

c. Pantex Plant including Texas Tech Farms used 1.4% as much as the City of Amarillo and 1% of water use went for nuclear weapons.

d. Considering the water also used for irrigation, the plant withdrew 0.6% of the regional withdrawal from the Ogallala aquifer. Nuclear weapons operations consumed 0.43% of the regional withdrawal.

Pantex 1995 Water Usage, Reference: Draft EIS for the Continued Operation of the Pantex Plant and Associated Storage of Nuclear Weapon Components, March 1996, page S-15.

Response:

Table S1 is intended to be a summary comparison of environmental impacts at Pantex Plant. It is not a summary of baseline conditions for the various resource areas. As a result, the recommended change to Table S1 is not applicable to the intended purpose of the table. However, this recommendation has been applied to the information presented in volume I, Table 4.6.1.23. Information in volume I, Table 4.6.1.23, has been updated with available data and percentages for 1995.

RC: 06.023

Doc: CO-008/100

Page 4-63, Figure 4.6.1.2-1. Why are drinking water sampling locations (at the tap) provided on a figure titled to depict monitoring wells?

Response:

Drinking water locations have been omitted from the referenced figure (Figure 4.6.1.22) in volume I. In addition, this figure has been retitled, "Groundwater Monitoring Locations, Pantex Plant Site".

RC: 06.024

Doc: CO-008/101

Page 4-65, Paragraph 2. "The complete lateral and vertical extent of perched aquifers are being defined." Please clarify.

Response:

The "lateral and vertical extent" refers to the aquifers location, shape or geometry, and depth. An expedited site characterization for the Pantex Plant Zone 12 groundwater was conducted to develop a working model of the perched aquifer. Specific objectives included characterizing the extent of the perched aquifer, nature of groundwater recharge, direction of groundwater flow, groundwater contamination, and identification of potential receptors. The findings of the expedited site characterization are presented in the Draft RCRA Facility Investigation Report for Groundwater in Zone 12 at the DOE Pantex Plant (Argonne 1995a). The word "complete" has been omitted from the referenced sentence in volume I, section 4.6.1.2.

RC: 06.025

Doc: CO-008/102

Page 4-69, Paragraph 2. Please correct typo, "the conclusion drawn from this (these) data..."

Response:

Correction has been included in volume I, section 4.6.1.2.

RC: 06.026

Doc: CO-008/103

Page 4-69, Paragraph 6. Concerning the depth to groundwater calculations, were calculations made on the leased and owned land or just owned land?

Response:

Depth to groundwater calculations included the available data for owned land (i.e., the main Pantex Plant).

RC: 06.027

Doc: CO-008/104

Page 4-69, Paragraph 4. "Although the effectiveness of the fine-grained zone to act as a barrier to vertical groundwater movement is not fully understood,..." The word "barrier" should be changed to "retardant," to more correctly describe movement.

Response:

The text in volume I, section 4.6.1.2, has been revised.

RC: 06.028

Doc: CO-008/105

Page 4-71, Paragraph 1. What does the statement, "In 1990, the recoverable volume of water in storage and available for use in the Ogallala aquifer was estimated at approximately..." refer to? Does it refer to that volume beneath Pantex, contained in the High Plains Aquifer, or the entire multi-state regional "Ogallala" aquifer? Please clarify.

Response:

The estimate refers to the recoverable volume of water in storage in the Ogallala aquifer in the High Plains Aquifer System. The estimate was calculated using an aquifer simulation model of the High Plains Aquifer System, originally constructed in the early 1980s and updated and revised in 1990, to predict future aquifer conditions. Additional information is provided in Peckham and Ashworth, 1993, "The High Plains Aquifer System of Texas, 1989 to 1990 Overview and Projections." The phrase "in the High Plains aquifer system (TWD, 1993)" has been added to the end of the last sentence in the above-referenced paragraph in volume I, section 4.6.1.2.

RC: 06.029

Doc: CO-008/106

Page 4-75, Paragraph 1. "It is highly likely that this and other earlier releases contributed to the high concentrations of chromium..." (1976-1986). Are further investigations to be done to identify the source, or is it to be accepted as is? 1976-1986 seems rather recent to be the major contributor to the perched aquifer contamination problem. Verify dates and any other sources of chromium.

Response:

Ongoing chromium investigations include determining whether elevated chromium levels could have been caused by the amount of chemicals used for conditioning cooling water during the towers operational period (1950 to 1964), conducting chromium anion exchange and column studies to determine whether ion exchange resins would be an effective treatment technology, and geochemical modeling to predict the fate and transport of chromium species in groundwater. This information has been added to volume I, section 4.6.1.2.

RC: 06.030

Doc: CO-008/107

Page 4-77, Paragraph 2. "Investigations to determine the potential for contaminant migration to the Ogallala aquifer from Pantex Plant are ongoing." Please provide more specific information as to what investigations are ongoing or planned.

Response:

DOE has investigated the potential for contaminant migration to the Ogallala aquifer from Pantex Plant in homestead wells that are located southeast of the plant boundary. Seven abandoned homestead wells have been sealed in order to prevent potential pathways of contamination into the Ogallala aquifer under the Groundwater Protection Project. A summary of the purpose and scope of the Groundwater Protection Project has been provided in volume I, section 4.6.1.2.

RC: 06.031

Doc: CO-008/108

Page 4-77, Table 4.6.1.2.-3.

a. Under "Source," the Carson County Well Fields should be clearly identified as "City of Amarillo's Carson County Well Fields."

b. Does Carson County irrigation use (1989) include gallons used by TTU for irrigation at Pantex?

Response:

a. Correction has been included in volume I, section 4.6.1.2.

b. Updated information has been provided in volume I, section 4.6.1.2. The totals for water use in the county do not provide a list of individual uses so it is unknown whether TTU usage is included.

RC: 06.032

Doc: CO-008/109

Pages 4-78, 79, Paragraph 5. Because the TNRCC and EPA requirements in the new permits will be quite different from the requirements of the permit complied with in 1994, it seems that the logic in this paragraph may be faulty. A statement that all parameters in the proposed draft permit have been met for x-number of years would be more persuasive. Please update with current permit information.

Response:

Information from the Final NPDES (June 1996) has been summarized in volume I, section 4.6.1.1, and is presented in volume II, appendix C. Surface water decision criteria have been revised in accordance with the required permit limits for the Final NPDES and TNRCC Wastewater Discharge Permits. The referenced text in volume I, section 4.6.2.1, has been omitted from the paragraph.

RC: 06.033

Doc: CO-008/110

Page 4-79, Paragraph 4. The statement "Groundwater contamination has occurred in the perched aquifer as a result of past site-related activities, primarily through spills and unintentional releases," is not consistent with information provided by Pantex Plant. Past practices were past practices. Rather than try to explain them as spills and accidents, a more positive statement would be to provide some of the great strides that Pantex Plant has made in the past seven years to correct these practices and investigate and begin to correct the extent of problems created by past practices.

Response:

The text has been modified to state, "Groundwater contamination has occurred in the perched aquifer as a result of past site-related activities. For the past seven years, the Pantex Plant Environmental Restoration 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. These activities to investigate historical sources of contamination and correct the extent of problems created by past practices will continue in the future."

RC: 06.034

Doc: CO-008/111

Page 4-80, Paragraph 6. Please specify the "current activities" of UT Austin, TBEG, and TTU Water Resources Center.

Response:

The "current activities" of University of Texas at Austin, Bureau of Economic Geology, and Texas Tech University Water Resources Information Center that are being referred to in the subject text include:

· Conducting a perched aquifer tracer test at the Pantex Plant Zone 12 treatability site to evaluate the efficiency of groundwater recirculation for remediation, determine potential retardation effects on high explosives from the injection of treated wastewater, and to predict long-term performance of the remediation system.

· Soil vapor extraction modeling and conducting a tracer test in unsaturated sediments above the perched aquifer to predict the efficiency of soil vapor extraction.

· Investigating microorganisms for high explosives degradation.

· Bioremediation investigations and ecological risk assessments.

· Chromium investigations that include determining whether elevated chromium levels could have been caused by the amount of chemicals used for conditioning cooling water during the towers operational period (1950 to 1964), chromium anion exchange and column studies to determine whether ion exchange resins would be an effective treatment technology, and geochemical modeling to predict the fate and transport of chromium species in groundwater.

Volume I, section 4.6.1.2, has been updated accordingly.

RC: 06.035

Doc: CO-008/112

Page 4-82, Paragraph 7. Is the effluent volume a condition of the proposed draft permits?

Response:

The NPDES permit has daily average and daily maximum effluent volume limitations of 0.65 and 0.82 million gallons per day respectively for Final Outfall 001. The permit also has reporting requirements for daily effluents at other outfalls. Specific Pantex Plant NPDES permit requirements are tabulated in volume II, appendix C.

RC: 06.036

Doc: CO-008/113

Page 4-83, Paragraph 1. "Since about 82% of the groundwater withdrawal in Carson County is for irrigation, conversion to dryland farming could have a major beneficial effect on the current rate of aquifer drawdown." Under Texas Law, groundwater is private property. This statement refers to property owned by others and is inappropriate and irrelevant to the SWEIS. Please withdraw this statement.

Response:

Statement has been omitted from volume I, section 4.6.1.2.

RC: 06.037

Doc: HT02-04/2

We cannot fix a problem we are not permitted to face. I call on the DOE, Mason & Hanger, the unions, the DOD, the City of Amarillo, and the State of Texas to correct, once and for all, this unethical situation that prohibits documents such as the Zone 12 Groundwater Assessment proposed by Argonne National Lab from being easily available to the general public as well as to our civic leaders.

Response:

The Environmental Restoration program or cleanup process is governed by Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), or both, and their associated regulations. Both sets of regulations govern how environmental contamination is defined, characterized, and remediated. Following sampling, analysis, and characterization, a draft report that describes the data, analysis, and cleanup recommendations is sent to the regulator. After review by the regulator, subsequent revision of the report, and final approval by the regulator, the final report is made available to the public. The approval of the report includes approval of the recommendations.

The RCRA Facility Investigation (RFI) for groundwater in Zone 12 at Pantex Plant is not currently available to the public and there is no timeframe for providing this document to the public. The State of Texas is reviewing this document and has yet to respond. DOE will not release the RFI until receiving State approval.

RC: 06.038

Doc: HT13/7

Another thing is the water and the springs in the mountain. Dry as it seems all around here, particularly when we don't have any rain, there is actually water in the mountain. There is an intriguing sentence on page 5-59 in the document that says some magazines show evidence of water intrusion.

I am interested in knowing to what extent the water intrusion affects any of the 41 in the mountain and how many of the ones that potentially -- well, let's start with that. How many of the 41 are affected by water intrusion?

Response:

A survey of unlocked magazines was conducted at the Manzano Weapons Storage Area at Kirtland Air Force Base in March 1993 to identify magazines that exhibited evidence of water intrusion. The survey revealed that 41 magazines were found to be dry, 21 showed at least some evidence of water intrusion from leaks or seeps, 59 were locked, and 1 was sealed. It should be noted that the degree of water intrusion is characterized more accurately as small, shallow puddles rather than flooding.

RC: 06.039

Doc: HT13/8

Do you know what the causes of the water intrusion in the two were? Is it [a] water source? Is it flaws, engineering flaws, or cracks in the facility, or why is it and how is it that the water came in? The obvious follow-up is how do you know that there won't be similar problems in any or all of the other 39?

Response:

The exact cause of a small amount of water in storage magazines at the Manzano Weapons Storage Area at Kirtland Air Force Base was not determined. The water could have seeped in through small holes in the roof, walls, or floor joints, or through the chimneys which vent the magazines to the atmosphere. In any event, the obvious excellent condition of the visible interior of the magazines (walls, ceilings, floors) and the very small water puddles observed on the otherwise dry floors suggest that very little work would likely be required to make the magazines suitable for pit storage. The magazine interiors actually look much younger than their actual age.

RC: 06.040

Doc: PC-011/1

To expand Pantex's role to accommodate any or all of the above is to me grossly irresponsible in view of the fact that the plant lies above the largest fresh water aquifer in the U.S., and that said aquifer is the lifeblood of this area's agriculture industry. Why the Ogallala aquifer has not been classified as a Class 1 water source is a puzzlement to me.

Response:

Texas enacted a groundwater law in 1949 that authorized the formation of local districts having the power to make and enforce regulations governing groundwater withdrawal. By virtue of this law, Texas has given the power of regulation to local groups, thus placing the responsibility for regulation at the lowest possible governmental level capable of performing the desired functions (USGS 1976). The Texas Water Code section 52.024 grants the Texas Water Commission (predecessor to the TNRCC) the authority to designate Underground Water Management Areas in the State of Texas in the form of a rule to protect groundwater resources. Groundwater resources in the area governed by the Panhandle Groundwater Conservation District, including the Pantex Plant area, have not been designated as Class I or a critical area. This text has been added to clarify volume I, section 4.6.1.2.

RC: 06.041

Doc: PC-011/3

It is a further contention by Pantex boosters that no substantial water pollution has occurred except for the perched water above the Ogallala aquifer. On June 27, 1995, a water sample was taken from one of my windmill wells and submitted for analysis. The results yielded the following information:

For 16 high explosives tested for, results were below PQL [Practical Quantification Limits]. For gross alpha, gross beta, Pu 239/240, Ra 226/228, Sr-90, tritium U 234/238 -- detected, but below Safe Drinking Water Act maximums.

How much will these levels rise if Pantex's role is expanded? Is it something we are willing to risk? Is it truly necessary for the viability of Amarillo's or the Panhandle's economy? Is short term economic prosperity worth eternal contamination?

Response:

The TNRCC detected low levels of high explosive contamination in a domestic Ogallala well located southeast of the Pantex Plant boundary; however, efforts to mitigate further contamination have been completed as discussed in section 1.3.5 of this volume. The well in question has been properly plugged and abandoned under the supervision of the TNRCC and a replacement Ogallala well has been drilled and completed in order to prevent further potential cross-contamination of the Ogallala aquifer. Pantex Plants Groundwater Protection Project addresses these and future steps to assure the integrity of offsite groundwater quality. Volume I, section 4.6.1.2, has been updated and includes additional information regarding the Groundwater Protection Project. The scope of this EIS does not include expansion of Pantex Plants role.

RC: 06.042

Doc: TG-001/1

There should be an addition to Table 6.5-4 in the Water Resource row. This table in the Draft EIS has only the New Mexico State environmental statutes. Of these 19 Pueblo Indian Tribes, six have received EPA approval for water quality standards under the treatment of State designation. These six are Isleta Pueblo, Sandia Pueblo, San Juan Pueblo, Santa Clara Pueblo, Picuris Pueblo, and Nambe Pueblo. And of the six, Isleta Pueblo is the closest in proximity and downstream on the Rio Grande river from the Manzano Weapon Storage Area at the Kirtland Air Force base, which is one of the alternative sites. Other Pueblo tribes have draft water quality standards that they anticipate approval [for] soon.

Response:

Thank you for your observation. Table 6.54 in volume I, has been modified accordingly.

RC: 06.043

Doc: PC-034/12

... In volume I,...4.6, Water Resources (p.4-57) it is stated that "Playas have also been identified as possible sources of focused recharge to the groundwater flow system at Pantex Plant. Unlined ditches have been used to dispose of wastewater and stormwater in the past."

As written, the implication is that the Pantex playas recharge the total groundwater system, which includes the Ogallala aquifer. This is not true. At Pantex Plant the playas have been identified as...possible [sources] of focused recharge to the perched aquifer, and unlined ditches have been used to convey wastewater and stormwater.

Response:

Volume I, section 4.6.1.2, has been modified accordingly to state, "At Pantex Plant the playas have been identified as a possible source of focused recharge to the perched aquifer and unlined ditches have been used to convey wastewater and stormwater."

RC: 06.044

Doc: PC-034/13

... In August 1995, EPA issued a draft NPDES permit for the Pantex Plant, yet in volume I (pp. 4-61 and 4-62) very little information regarding the substance of this draft NPDES Permit is presented.

Question: Why? And why does this section on NPDES Permits contain superfluous information about three-year old TNRCC draft permits on surface water discharges?

Response:

Volume I, section 4.6.1.1, and volume II, appendix C, have been updated to present information from the Final NPDES and TNRCC Wastewater Discharge permits.

RC: 06.045

Doc: PC-024/14

Page 5-12, left column, "Impacts of Facility Upgrades," last five lines. No mention is made, in this report, concerning the radioactive trititated water that drains out of some of the tunnels and collects in ponds outside the tunnel entrances. Nor is there any mention of the possible collection of gaseous radionuclides in the tunnels that could originate from the waste in the expended test cavities.

Response:

With respect to the tunnels at Nevada Test Site, the only tunnel that is being considered for storage of plutonium pits is P-Tunnel. There is no drainage out of P-Tunnel. Upon completion of a weapons effects test, and the recovery of the data, the area is sealed to prevent radionuclide migration.

RC: 06.046

Doc: PC-023/2

With respect to water resources and water quality, I understand that groundwater and surface water contamination has been attributed to past activities at Pantex Plant. Heavy metals, solvents, etc. found in excessive concentrations in the perched groundwater can be linked to poor disposal practices in the past, and improved waste handling should limit future contamination. However, since soils in recharge areas (including playas and ditches) are contaminated, the contaminants can continue to move to the perched aquifers. I am concerned about the quality of water in some relatively shallow domestic wells in the vicinity. Your report states that at least two domestic wells draw water from perched groundwater.

Response:

Pantex Plant has worked very closely with EPA Region VI and the 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 that are protective of human health and the environment. An additional condition of the TNRCC requires Pantex Plant to conduct a study to determine the feasibility of eliminating or minimizing discharges to playa lakes and open ditches or improving the quality of discharge. In addition, DOE is conducting a Groundwater Protection Project to alleviate the potential for groundwater contamination.

RC: 06.047

Doc: PC-023/3

... It is possible that the water in the perched sources can move to the Ogallala aquifer. The hydraulic gradient of the Ogallala in the vicinity of Pantex indicates well drawdown under Pantex Plant toward the City of Amarillo well fields in Carson County northeast of the plant. In other words, contaminants that leach to the Ogallala under Pantex will likely move toward the wells supplying water to the City of Amarillo. The City of Amarillo has pledged up to 1,460 million gallons per year to Pantex Plant, up from the 221 million gallons used in 1994. If pumping rates from these well fields increase, the well drawdown will increase, thereby increasing the hydraulic gradient and increasing the rate of movement of these contaminants toward the city's water supply.

Response:

The 1,460 million gallons per year of water that was offered by the City of Amarillo refers to reclaimed wastewater from the Hollywood Road Wastewater Treatment Plant, not groundwater supplied from the Carson County wellfield, as discussed in the response to comment 06.003.

RC: 06.048

Doc: HT16/16

My main concerns about the discussions of the perched aquifer and the Ogallala aquifer have to do with the limited amount of information that is available describing the limits of the perched aquifer to the south and southeast. And I'm also concerned about the lack of discussion of leakage of perched aquifer waters through the perching horizon. In my reading of the Draft EIS, these two issues are not treated with any...kind of detail. And I would like to know if there's any additional information available that may be added into the final statements. We don't know for sure, for example, what happens to perched...aquifer waters when they reach towards the limit of the perching horizon. Are they simply flowing off the edge of the perching horizon and then into the Ogallala aquifer, or is it possible in some cases that the southern margins of the perched horizon are more or less continuous or sort of flow into the Ogallala aquifer.

Response:

An expedited site characterization was conducted in 1994 and 1995 to characterize the extent of the perched aquifer, nature of recharge, and direction of groundwater flow. The results of the investigation are included in the Draft RCRA Facility Investigation Report for Groundwater in Zone 12 at the DOE Pantex Plant (Argonne 1995a). Data collected during the expedited site characterization were used to predict contaminant movement and to evaluate cleanup options for perched groundwater; the results of this study are reported in Two-dimensional Groundwater Flow Model and Design Tool for Evaluation of Remedial Options for Perched Groundwater at Pantex Plant (Battelle 1996a). Additional investigations are being conducted on private property south and southeast of Pantex Plant. The primary area of concern in this modeling effort is the perched aquifer underlying Zones 11 and 12 and the area east and southeast of the plant boundary.

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 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 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 210 to 290 feet below land surface in the perched aquifer and from 340 to 460 feet in the underlying Ogallala aquifer.

The information provided in this response has been added to volume I, section 4.6.1.2, for clarification.

RC: 06.049

Doc: HT16/23

On Page 4-57, the first paragraph is somewhat confusing. We'd like to see a statement [that] clearly states that Pantex did at least historically discharge [to] Playa 5. It's implied in the statement they have in the first paragraph. We would like to see it just a little more clear cut. With regard to Ogallala contamination, I understand the EIS had been written before we discovered some slight amount of contamination in the Ogallala proper. Since the EIS hasn't come out in its final version, I think it ought to be revised to go ahead and reflect the conditions we know about now.

Response:

According to the Pantex Plant Environmental Information Document (Pantex 1996), no industrial discharges from Pantex Plant have ever entered Playa 5.

Discussion of contaminants of concern detected in the Ogallala aquifer has been addressed in the Final EIS.

RC: 06.050

Doc: HT16/24

With regard to the Ogallala, the homestead wells, the EIS should note that the low vertical permeability of the fine-grained zone may be compromised by these abandoned homestead wells that have been found on the Pantex site. These wells could provide contaminant pathways through the fine-grained zone to the Ogallala.

Response:

See discussion in section 1.3.5 in this volume regarding the efforts concerning the homestead wells in the Pantex Plant groundwater protection program.

RC: 06.051

Doc: HT16/25

With regard to the facility boundary, the EIS should mention that DOE will take whatever action is practicable to clean up the groundwater to residential drinking water standards beyond the facility boundary. ...On Page C-2 there's a statement that...the Texas State Surface Water Quality Criteria do not apply to Pantex playas. But if you go through the Risk Reduction Rules, 30 Texas Administrative Code, Subchapter S, Chapter 335, you'll note that Texas Surface Water Quality Criteria [do] apply to the Pantex playas surface water quality values. The surface water quality determined in accordance with Risk Reduction Rules [takes] precedence over the risk based concentration guidelines from EPA Region 3, which was cited on section C.1.2. The list of decision criteria doesn't list the Texas Risk Reduction Rules, which also include Texas Surface Water Quality Criteria and drinking water standards and so forth. ...Since the EPA Region 3 guidelines don't apply to Pantex, which is in EPA... Region 6...and we have the Texas Risk Reduction Rules and the Texas Surface Water Quality Criteria, all of which do apply, we'd just as soon you drop the EPA guidelines and substitute the Risk Reduction Standards. This gets to be a problem later on.

In Table C.1.2-1, some of the values cited apparently cite the EPA Region 3 guidance. For instance, the standard for antimony should be 0.006 milligrams per liter, based on the Risk Reduction Rules, which refers it back to the Safe Drinking Water Act, rather than the 0.15 milligrams per liter cited by EPA Region 3 guidance. So, because we're using the wrong guidance, we're getting the wrong numbers cited in the EIS. Standards for gross alpha activity, according to the Risk Reduction Rules, should be 15 picocuries per liter rather than...N/Anot applicable. That was cited in the table. No water quality standard is provided by the Texas Surface Water Quality Criteria; therefore, the Risk Reduction Rules specify use of drinking water standards which are based on the Federal Safe Drinking Water Act. Proposed drinking water standards should be 50 picocuries per liter or 4 millirems per year for beta particle activity....

And the TNRCC requests that DOE revise Table C.1.2-1 to cite the more stringent surface water quality standards for radionuclides that are developed in accordance with the Risk Reductions Rules. As such, the standard for plutonium-239/240 would be 2 x 10-8 microcuries per milliliter, based on the TRCR standards. ...they come out of the Bureau of Radiation Control, Texas Department of Health. Radium-226 and -228 should be 6 x 10-8 microcuries per milliliter, again, based on the drinking water standards, Federal drinking water standards. Tritium should be 1 x 10-3 microcuries per milliliter, based on the TRCR standards. Uranium-234 and -238 would be either 3 x 10-7 microcuries per milliliter, which is a TRCR standard, or 20 milligrams per liter, proposed drinking water standard, whichever is more stringent.

Response:

DOE has completed a Groundwater Protection Project to cleanup the groundwater to residential drinking water standards beyond the facility boundary, as discussed in section 1.3.5 of this volume. The purpose and objectives of the Groundwater Protection Project have been addressed in volume I, section 4.6.1.2.

Surface water quality decision criteria issues are summarized in section 1.3.5 of this volume. In the Draft Pantex Plant EIS, EPA Region III Risk Based Concentrations (RBC) Guidelines were used as a 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 radionuclides. As a result, EPA Region III RBC Guidelines were used as decision criteria for the following constituents: antimony, beryllium, boron, cobalt, molybdenum, nitrite, strontium, tin, vanadium, 3,3-dichlorobenzadine, 4-methylphenol, acetone, benzoic acid, chloroform, ethylbenzene, methylene chloride, phenol, toluene, total xylenes, HMX, RDX, and ammonia. Of these constituents, the following are now regulated in the NPDES and TNRCC Wastewater Discharge Permits: antimony, beryllium, cobalt, molybdenum, HMX, RDX, and ammonia. EPA and TNRCC determined which constituents would have recording requirements and/or permit limits specified in the NPDES and Wastewater Discharge permits based on a review of the most recent surface water quality data available for the main outfalls and internal outfalls. The most recent analytical data at the time of regulatory review were from 1993. The TNRCC calculated effluent limitations that were based on the Texas State Water Quality Standards (30 TAC 307). The actual effluent limitations, cited in the permits, are more stringent that those calculated by the TNRCC and reported in its Fact Sheet. As stated in the NPDES Permit, EPA has accepted the statistical calculations provided by Pantex Plant and has established metal limitations on case-by-case basis through best professional judgment under 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 has conducted analyses for the following constituents that were not specified in the permit: nitrite, strontium, vanadium, 4-methylphenol, 3,3-dichlorobenzadine, chloroform, ethylbenzene, methylene chloride, phenol, toluene, acetone, benzoic acid, xylene, boron, and tin. By monitoring for these additional constituents, Pantex Plant is providing additional assurance that any changes in chemical constituents and their relative concentrations are protective of human health and the environment.

NPDES and Wastewater Discharge permit requirements have replaced RBC Guidelines from EPA Region III as decision criteria. Refer to volume I, section 4.6.1.1, and volume II, appendix C.

The Atomic Energy Act authorizes DOE 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 for 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." As a result, the Risk Reduction Rule and drinking water standards are not applicable decision criteria for surface water quality at Pantex Plant. The 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.

RC: 06.052

Doc: HT16/26

My question refers to -- it's on Page 4-78. And you recognize, and I quote, groundwater management is a responsibility of local jurisdictions through groundwater management districts. The Pantex Plant is located in Panhandle Groundwater Conservation District Number 3, which has authority to require permits and limit the quantity of water pumped. And, in view of this statement in the document, why have you chosen not to register the perched water production wells and the monitoring wells in compliance with Rule 4 of the Panhandle Groundwater Conservation District? It does not require permitting, but it does require registering and a semiannual report of any water quality analysis that were taken from the monitoring wells.

Response:

DOE is working with the Panhandle Groundwater Conservation District Number 3 to resolve this issue.

RC: 06.053

Doc: HT16/27

... I'd like for one of the DOE people to characterize to me how the system failed when, on a meeting on May 13th with Johnny Bolin [Guelker] and Danny [Dan] Ferguson of DOE, Boyd Deaver from the TNRCC here in Amarillo and myself, agreed that it was in everyone's best interest to not plug the Lee Cockrell windmill located off site. And then, two days later on May 15th, it was related to me that that well was plugged. And I just wondered where the system failed and what has done to correct it.

Response:

The windmill well was plugged by mistake. It has been redrilled and sampled for chemical analysis.

RC: 06.054

Doc: HT16/28

When you were making the presentation on the water, you said that radionuclides were significantly below DOE standards. Does that mean that they are detectable?

Response:

Many radionuclides are naturally occurring in soils and groundwater. Activities of radionuclides detected in Pantex Plant groundwater samples were within the range of natural background water chemistry.

RC: 06.055

Doc: HT17/19

... I'm concerned, as Ms. Smith is, with the threat that I see to the farmer in this community. When we see already that some of this stuff has leached down into the Ogallala aquifer, and people...keep shooting off them test things out there and all that, and they have all them cracks and stuff in the ground.

Response:

Pantex Plant is currently conducting groundwater treatability investigations in conjunction with their ongoing environmental restoration program efforts. Contaminated groundwater is pumped out of the perched aquifer, treated in a carbon-filtration system to remove high explosive contamination, and then pumped back into the perched aquifer. When the treated groundwater is reintroduced into the perched aquifer it flushes and displaces the existing contaminated groundwater, moving it toward the treatment system wells for cleanup. As stated in comment 06.020, the subsurface sediments in the Ogallala Formation consist of unconsolidated sand, silt, clay, and gravel; there are no cracks or fractures. Groundwater moves through void spaces between unconsolidated sand, silts, and gravels, and is being treated at an approximate rate of 42,000 gallons per day.

RC: 06.056

Doc: HT17/40

Pantex is a Superfund Site. We now have confirmed contamination in the Ogallala Aquifer. It would seem that before we rush headlong into new missions, bringing new waves of radioactive pollution to this plant, that the document should at least address the effort to mitigate pollution already onsite. It really doesn't.

Response:

Additional information, including a description of the Groundwater Protection Project and Corrective Action Plan for ditches and playas has been added to volume I, section 4.6.1.2. For additional detail, see discussion in section 1.3.5 of this volume.

RC: 06.057

Doc: HT17/56

... There is no recognition that the Ogallala aquifer is the only source of groundwater for the entire Texas Panhandle, the South Plains, and parts of seven other Midwestern states. The siting of hazardous and radioactive operations over this finite water source is totally unacceptable. There is no substitute for water.

Response:

See discussion in section 1.3.5 of this volume. The following sentence has been added to the description of the Ogallala aquifer: "The Ogallala aquifer underlies the whole of the Texas Panhandle, the South Plains as well as parts of New Mexico, Oklahoma, Colorado, Kansas, Nebraska, Wyoming, and South Dakota."

RC: 06.058

Doc: PC-017/10

There are at least seven playa lakes just off the Pantex site on all sides of the plant. Rainwater runs off the plant site into barrow ditches around the plant and drain into those offsite playas. This drainage is not addressed in the PEIS. The Pantex lake receives none of the runoff. Why were the other playas excluded? The watershed on the south of Lake Meredith, a reservoir for 13 cities, begins on the northwestern corner of Pantex. Water from that section of the plant (where the various EIS's show a nuclear reactor or two may be constructed) runs into Lake Meredith.

Response:

EPA Region 6 NPDES Permit No. TX-0107107 authorizes Pantex Plant to discharge to the waters of the United States, under specified effluent limitations and monitoring requirements. According to this permit, the discharge from Pantex Plant is directed into four playa lakes, located adjacent to the waterbody of McClellan Creek, which flows into the North Fork of the Red River (Waterbody Segment Code No. 0224 of the Red River Basin). There are no known surface water connections that could transport potential contaminants from Pantex Plant into the Canadian River. Due to the flat, level topography of the Pantex Plant, streams are not well developed on the landscape and surface waters drain to the playa basins, as discussed in volume I, section 4.6.1.1. In the event that contaminants were transported by surface runoff, the contaminants would remain within the designated watershed (Pantex 1996).

RC: 06.059

Doc: PC-017/11

Page 4-79. Use of water from the perched aquifer and also the Ogallala aquifer is just not true, as contamination is in the domestic wells of a neighbor to the east of the plant and a well to the south of the plant. Why are false statements being made? What measures are being taken to clean up the water offsite? This contamination must be coming from the "Pantex AQUIFER." Pantex aquifer is a result of the waste being run into on site playas. How will the contamination of the Ogalala be cleaned? How do you determine "insignificant" amounts? Does DOE define "insignificant" as anything or amount the DOE does not want the public to believe may be harmful? Can "insignificant" amounts become "significant" if ingested or exposed over long terms? What is the long-term effect on health and safety?

Response:

Minute traces of high explosive contaminants were detected in the Ogallala aquifer after publication of the Draft Pantex EIS. Volume I, section 4.6.1.2, has been amended to provide the updated information. The relation between the past practices and contamination of the perched aquifer is discussed in detail in section 1.3.5 of this volume. The significance of the amounts of any contaminants is considered by comparing the concentration to regulatory standards which are based, in part, on health effects. Five years of surface water and groundwater quality data have been compared to site-specific permit limits, DOE derived concentration guides for radionuclides and Federal and State decision criteria. Concentration limits have been based on State and Federal drinking water regulations and health advisories.

RC: 06.060

Doc: FG-003/4

Page 4-57, second paragraph: In this paragraph and at other places in the text it is asserted that the discharge water from the plant meets the surface water quality permit requirements. Because it is acknowledged in the document that leakage from waterways and playas enters the ground, EPA guidelines for groundwater quality are of concern here. Under EPA's "Strategy for the 90's" report of the Ground Water Task Force, the Maximum Contaminant Levels (MCLs) established under the Safe Drinking Water Act (SDWA) are to be used as reference points in evaluating groundwater quality. This Draft EIS also recognizes the significance of these MCLs when it lists them as "decision criteria" for ground water analyses presented in volume II. The requirements under the National Pollutant Discharge Elimination System (NPDES) do not include all of the contaminants for which MCLs have been set for public water supply systems under the Safe Drinking Water Act and in many cases the limits set under NPDES are higher than those under the SDWA. Under these circumstances, we recommend that Pantex consider protecting the groundwater by either lining the ditches and playas with the level required to maintain, or restore to, SDWA MCLs in the groundwater. Discussion on this matter should be included in the Final Statement.

Response:

Detailed information regarding the status and conditions of wastewater discharge permit limits is provided in section 1.3.5 of this volume. TNRCC Wastewater Discharge Permit No. 02296 (as amended) requires that within one year of the effective date of the permit (June 14, 1996), Pantex Plant must conduct a study that determines the feasibility of eliminating or minimizing discharges to playa lakes and open ditches or improving the quality of discharge. The study should, at a minimum, include the following proposals:

(1) upgrading existing treatment facilities or constructing new treatment facilities to ensure no groundwater quality effects from discharges to playa lakes and ditches,

(2) construction of synthetically-lined impoundments to confine treated effluent and a closed collection system from all process areas to the treatment facilities,

(3) establishment of an irrigation disposal site and accompanying disposal practices plan to eliminate discharges to the playa lakes,

(4) establishment of a reuse and conservation program for all process wastewaters, thereby eliminating any industrial effluent discharge to the playa lakes and ditches, and

(5) development of a schedule for completion of proposals or any other proposals deemed feasible by the permittee.

A Groundwater Contamination Assessment Report is being developed as part of the RCRA Facilities Investigation Work Plan, in association with the Draft RCRA Permit. Discussion of the requirements of the applicable wastewater discharge permits has been updated in volume I, section 4.6.1.1, and volume II, appendix C.

RC: 06.061

Doc: FG-003/5

Page 4-62, last paragraph: The first bullet describes "unsaturated sands of the Blackwater Draw Formation and upper Ogallala" at the surface, but the diagram on page 4-64 indicates that the Blackwater Draw Formation consists of clay. This inconsistency should be clarified in the Final Statement.

Response:

The referenced discrepancy has been clarified by referring to "Unsaturated sands and clays..." in volume I, section 4.6.1.2.

RC: 06.062

Doc: FG-003/6

Page 4-65, third paragraph: It is stated that the perched aquifer "exhibits radial flow." By way of clarification, the Final EIS should note that the flow is radial from Playa #1, suggesting that the playa is a major source of recharge locally.

Response:

Comment noted. The phrase "from Playa 1" has been added to the referenced text in volume I, section 4.6.1.2.

RC: 06.063

Doc: FG-003/7

Page 4-67: The map illustration depicts a domestic water well to the southeast of the Pantex property, just outside the area of the perched aquifer. The well appears to be in the flow area of the perched aquifer. The well appears to be in the flow direction of the groundwater in the perched aquifer and may be in danger of contamination from groundwater in the perched aquifer. The Final EIS should identify the boundaries of the contaminated perched aquifer and establish what risk may exist, if any, for the potential contamination of the Ogallala aquifer.

Volume I, section 4.6.1.2, has been updated with the most current information available.

RC: 06.064

Doc: FG-003/8

Page 4-71, third paragraph: It is indicated here that the quality of surface water being discharged is described earlier at section 4.6.1.1. However, there is no description of the discharge water quality at the point cited. It would be helpful if the FEIS could provide a complete description of the discharged water chemistry within the text.

Response:

A comprehensive description of the discharged water chemistry is provided in volume II, appendix C. The referenced text has been modified to refer the reader to volume I, section 4.6.1.1, and volume II, appendix C, where descriptions/tabulations of the discharge water chemistry are provided.

RC: 06.065

Doc: FG-003/9

Page 4-72, second paragraph: It is difficult to visualize all the information about water quality and contaminant locations described here. [It] would be helpful to have one map to display this information in the Final Statement. It would also be helpful if the FEIS could have a section describing the past and current chemical quality of discharges. Section 4.6.1 makes a general attempt at this goal but is too generalized. The Final Statement should list specific contaminants and major components of water chemistry, and describe any changes through time. A table showing concentration ranges, averages, etc., would be appropriate for this discussion.

Response:

This type of information (specific contaminants and major components of water chemistry, source areas, and changes in concentrations through time) is compiled in the Draft RCRA Facility Investigation (RFI) and will be available to the public upon final regulatory approval. Figure 4.6.1.27 has been added to volume I, section 4.6.1.2 to show the distribution of RDX concentrations in the perched aquifer. Information regarding past chemical discharges are discussed in volume I, sections 4.5.1.3 and 4.6.1. Table 4.6.1.22 in volume I lists source areas of suspected contaminants of concern to groundwater resources. Water quality summary tables that show average and maximum concentrations for a 5-year timeframe are provided in volume II, appendix C.

RC: 06.066

Doc: FG-003/11

Two sites at the Nevada Test Site (NTS) were assessed for the interim storage of plutonium pits, the P-Tunnel area and the Device Assembly Facility area. The Pantex DEIS (volume I, p. 5-8) indicates that groundwater at the two NTS sites is characterized by a "deep water table," although depth to groundwater is not specifically quantified in the DEIS. A prior Department of Energy EIS reviewed by EPA Region 9 (FEIS, Tritium Supply [and] Recycling, October 1995, volume I, p. 4-114) stated that the depth to groundwater at NTS ranges from 500 to 2,400 feet. The tritium FEIS also indicated that "there are...areas of perched water that lie at considerably shallower depths" at NTS.

Response:

The referenced sentence in volume I, section 5.2.1.4, has been modified to give the range of depths to groundwater. The Pantex EIS only deals with the interim storage of pits at the Device Assembly Facility, located adjacent to Yucca Lake, and P-Tunnel at Ranier Mesa. The plutonium pits would be containerized and stored in these existing facilities. As a result, groundwater resources would not be affected by these storage activities.

RC: 06.067

Doc: FG-003/14

The Pantex FEIS should discuss whether either of the areas is characterized by "perched water...at considerably shallower depths..." as described in the Tritium FEIS. If so, the groundwater impacts that are reasonably foreseeable should the plutonium pits be damaged in a quake.

Response:

Plutonium pits would be placed in sealed containers that are designed to withstand impact. Thus, the contents are not expected to come into contact with groundwater.

RC: 06.068

Doc: HT17/69

... I understand that...in this [the Pantex EIS] there...are some omissions which have been brought out. ...It has been noted that there's nothing said about the Superfund Site projects in the study, and it would seem that that might be something important to look at. All of us around here notice the recognition of the Ogallala aquifer, as it is probably, in the United States, the largest fresh water aquifer.

Response:

As stated in volume I, section 6.4, Pantex Plant is working with the EPA and TNRCC to develop a tri-party Federal Facility Agreement to outline reporting requirements, schedules, and funding for the Environmental Restoration Program. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) efforts are being integrated into the existing Resource Conservation and Recovery Act (RCRA) Facility Investigations, corrective measures studies, and corrective measures implementations that are described in volume I, sections 4.5.1.3, 4.6.1.1, and 4.6.1.2. Language describing the extent of the Ogallala aquifer has been added to volume I, section 4.6.1.2.

RC: 06.069

Doc: PC-025/24

On Page 4-56, buildings listed do not appear to match diagram on page 4-243. Figure appears to be crowded with information. Recommend simplification.

Response:

Figure 4.6.1.11 in volume I has been revised and simplified.

RC: 06.070

Doc: PC-025/25

On Page 4-60. Please explain. If a playa is a wetland [and] a wetland is considered waters of the United States...why is a playa not [considered] waters of the State?

Response:

In 1990, Pantex playas 1 through 4 and Pantex Lake were determined to be jurisdictional wetlands by the U.S. Army Corps of Engineers, and are therefore considered to be waters of the United States subject to protection by the National Pollutant Discharge Elimination System (NPDES). TNRCC Permit No. 02296 has been amended (effective June 14, 1996) in accordance with the EPA Region VI NPDES Permit No. TX-0107107 that became effective on June 1, 1996. Volume I, section 4.6.1.1, has been updated to discuss the terms and conditions of these new permits.

RC: 06.071

Doc: PC-025/26

... Do the number of wells located on the Pantex site represent significant pathways to increased groundwater contamination? What measures are taken to control this pathway? In the event of a plutonium accident what is the possibility that the well is open and plutonium enters the groundwater through the monitoring system? Assuming the well was open during an accident, what is the release to the groundwater? What is the impact if Pantex loses groundwater usage? Adjacent land owners?

Response:

The low vertical permeability of the fine-grained zone could potentially be compromised by abandoned homestead wells that could provide contaminant pathways through the fine-grained zone to the Ogallala aquifer. As a precautionary measure, DOE has identified and sealed abandoned homestead wells in order to prevent potential pathways of contamination into the Ogallala aquifer under the Groundwater Protection Project. These precautionary measures and other key aspects of the Groundwater Protection Project are discussed in volume I, section 4.6.1.2. In the event of plutonium accident, the plume would have to pass over the open well at the times it was open. This probability would be an order of magnitude less than the probability of a plutonium accident (see volume I, section 4.14). The amount of plutonium that could get into an open well is difficult to predict. Based on the small cross-section of the well and the large area over which plutonium would be spread in an accident, the amount would be very small.

RC: 06.072

Doc: PC-025/27

On page 4-63, why was OW-WR-20 utilized in cross section when the cross section should go from 6-1003 to 6-1004 to 6-1005? Why was 6-1015 left out? What are the impacts if these wells are utilized? What is the quality of the hydrostatic cross section input data (i.e. well logs)?

Response:

The referenced cross section was taken from DOE 1994nn. OW-WR-20 was utilized because the water quality of this well is discussed in volume I, section 4.6.1.2. Perched monitor well 6-1015 was not included in the cross section on the original reference and was not available at the time of publication of the Draft Pantex EIS. The referenced cross section has been replaced with an updated north-south trending cross section (Figure 4.6.1.23) that shows the axis of the paleochannel.

RC: 06.073

Doc: PC-025/28

On Pages 4-66 and 4-67. Why did you change nomenclature on PM-21 (466) and OW-WR-21 (467)?

Response:

Figure 4.6.1.2-3 in volume I has been revised to refer to OW-WR-21, rather than PM-21.

RC: 06.074

Doc: PC-025/29

On Pages 4-66 and 4-67, why arent wells PXSP-OIA, PXSP-03, PXSP-04, etc. listed in appendix C, table C.2.1-1? What level of QA has been completed on this section? Please include QA/QC certification documentation in appendix including signatures of key QA/QC personnel. Please provide documentation assuring QA/QC measures were implemented, met established goals, and necessary certification exists.

Response:

The Draft Pantex EIS was prepared with available information supplied by Pantex Plant. The references for Figures 4.6.1.23 and 4.6.1.24 in volume I are provided in the referenced text. Data from all referenced well logs that were made available by the time of publication were utilized and included in volume II, appendix C. The administrative record includes files that provide QA/QC certification documentation. Volume II, appendix C has been updated with additional information that has become available since the publication of the Draft Pantex EIS.

RC: 06.075

Doc: PC-025/30

On page 4-67, why are wells off the Pantex Plant lacking well numbers?

Response:

The locations of offsite wells are shown. These wells are on private land and data from these specific wells are considered private. Data have been provided to the extent practicable. Well numbers are provided for all onsite wells that are monitored by the Environmental Protection Department or by the Environmental Restoration Program. Inclusion of well numbers would not serve any purpose for this document. Please note that a map showing all vicinity wells has been added to volume I, section 4.6.1.2 (Figure 4.6.1.21).

RC: 06.076

Doc: PC-025/31

... Table 4.6.1.2-1, page 46-8. What is the reason the realistic estimate is an order of magnitude larger than the most conservative?

Response:

Aquifer performance tests were used to estimate groundwater velocities. The results of these aquifer tests are highly variable and are dependent on the testing location and relative heterogeneities in the subsurface sediments from one location to another, the duration that the test is run, variations in testing procedures, and the method of analysis. These variations in aquifer performance testing lead to differences in groundwater velocity estimates.

RC: 06.077

Doc: PC-025/32

... What is the source of the statement "These perched zones are believed to be hydraulically separate from the perched aquifer in Zone 12 at Pantex Plant?"

Response:

The referenced statement was provided as a personal communication (February 1996) from the Pantex Environmental Restoration (ER) Department, based on the best available information at the time of publication of the Draft Pantex EIS. Volume I, section 4.6.1.2, has been updated with additional information that has been provided by the Pantex ER Department since February 1996.

RC: 06.078

Doc: PC-025/33

And Page 4-69 in Ogallala aquifer section. Vicinity of ROI, more accurate?

Response:

The referenced text has been modified to state, "The Ogallala aquifer is the principle aquifer and major source of water in the vicinity of Pantex Plant and surrounding region of influence," and "The Ogallala aquifer underlies the Texas Panhandle and the South Plains, as well as parts of New Mexico, Oklahoma, Colorado, Kansas, Nebraska, Wyoming, and South Dakota."

RC: 06.079

Doc: PC-025/34

... Why aren't wells OW-WR-23, and 28 listed in Table C.2.1-1? Does OW-WR-40 leak water to the perched from the contaminated Playa l? Is OW-WR-40 above or below the floodplain? Are any of the well heads located in the Pantex Plant or vicinity below any floodplain? What are impacts if there are [any]?

Response:

OW-WR-23 and OW-WR-28 are not wells. They are drinking water sampling locations at Buildings 12-2 and 12-6 Cafeteria respectively. The referenced figure has been corrected. Monitoring well OW-WR-40 is screened (or open to groundwater flow) from 580 to 610 feet below ground surface, within the Ogallala aquifer. The fine-grained zone occurs well above the screened interval at a depth of 252 to 356 feet below ground surface. Because the well is only screened in the Ogallala aquifer, the thickness of the fine-grained zone, and the vertical distance (over 200 feet) between the perched aquifer and the Ogallala aquifer, OW-WR-40 does not leak water to the perched aquifer from Playa 1. Based on our review of five years of data, Ogallala monitor well OW-WR-40 only exceeded decision criteria for one constituent, iron, during 1990, 1991, and 1993. However, no contamination from high explosives, organic compounds, or radionulcide contaminants of concern have been detected in this well. According to the 1995 Environmental Report for Pantex Plant (Pantex, 1996c:87), "There was no indication of contamination by radiological constituents, metals, explosives, or organic compounds in Ogallala monitoring wells, and there was no evidence of contaminated groundwater from the overlying perched zone reaching the aquifer." Details regarding the protection of cross-contamination from homestead wells are addressed in section 1.3.5 of this volume.

RC: 06.080

Doc: PC-025/35

Page 4-76. I'm confused, how can a zone be a source but a landfill is a location? What does 12-5W, etc. mean? What is OSTP?

Response:

The "source" refers to the particular area of the plant where contaminants of concern potentially originated. The "location" refers to the specific building, landfill, leach bed, etc. within that source area. Designations such as 12-5W refer to specific buildings within the respective zone, (e.g., Building 5W in Zone 12). OSTP is the acronym for the Old Sewage Treatment Plant. Acronyms are defined in the EIS with their first usage and in the list of acronyms and abbreviations.

RC: 06.081

Doc: PC-025/36

Appendix C is difficult to review in support of section 4.6 because DOE flip-flops the nomenclature for well numbers. As an example, table C.2.1-1 [has the] well ID as 15-20, but C.2.2-3 [has] PR-16, please standardize. On page 4-77 isn't it three wells for lead: PR-16, OM-39, and PR-41?

Response:

Primary well numbers have been standardized for clarification. The referenced text in volume I, section 4.6.1.2, has been modified to state "...and lead in three wells...".

RC: 06.082

Doc: PC-025/37

Page 4-78. What is the source of the 704 million liters? What is the source of the 760 irrigation wells? What is the source of the two private wells? Do you suspect more? What would be the impact of more perched wells?

Response:

The referenced text has been updated and revised. The updated source of data for Pantex Plant wells is the 1995 Environmental Report for Pantex Plant (Pantex, 1996c). Updated irrigation well data was provided by Panhandle Groundwater Conservation District No. 3 and the Farm Service Agency. The impact of more perched wells would be dependent on the wells intended use. Perched monitoring wells provide additional sources of information about the water quality, potential contaminants of concern, and changes in chemical concentrations with time. Recovery wells are being used to pump contaminated groundwater out of the perched aquifer for treatment. However, if contaminated groundwater within the region of influence were used for domestic or agricultural uses, several potential pathways of exposure (e.g., ingestion, bathing, other potable water or agricultural uses) could result. DOE has conducted a Groundwater Protection Project as a mitigation measure. For additional information about private perched wells, see discussion in section 1.3.5 of this volume.

RC: 06.083

Doc: PC-025/38

Page 4-79, "the quality of the wastewater discharge is such that it will not degrade..." What is the source of the statement? Please explain position in greater detail. Doesn't the playa carry contaminants to the Ogallala? If (regionally) perched water is used to supply cattle with water, would WWTF water be used as cattle drinking water. If not, how can the above statement be true?

Response:

The quality of wastewater discharge will not degrade the perched and Ogallala aquifers, because the wastewater discharge is regulated through the EPA Region VI NPDES Permit and TNRCC Wastewater Discharge Permit. For additional information regarding these permits refer to section 1.3.5 of this volume and the updated discussion in volume I, section 4.6.1.1. Surface water outfalls are monitored to assure that the discharge water quality is within the specified permit limits. Similarly, perched and Ogallala groundwater is monitored in onsite and offsite locations to assure that human health and the environment are being protected. The hydrology and recharge of the perched aquifer is very complex and the effects upon the vadose zone from continual discharge of water into the existing lakes and drainage ditches does not necessarily result in contaminated groundwater being driven into the Ogallala. The trace levels of high explosive constituents that were detected in an offsite private well were believed to be due to special circumstances; see discussion in section 1.3.5 of this volume. Environmental Restoration (ER) investigations, conducted at or before the time of publication, have indicated that the extent of offsite contamination detected in the perched groundwater has been limited to within one-half mile southeast of the main Pantex Plant Site boundary. The ER program is currently conducting corrective actions, such as interim measures to remove "hot spot" areas of contaminated soils, to protect human health and the environment as discussed in section 1.3.5 of this volume.

RC: 06.084

Doc: PC-025/39

In Table 4.6.2-1, are margins included? Why is the liter conversion included?

Response:

The annual rates referenced in volume I, Table 4.6.21, include a 10 percent margin. Liter conversion is included to comply with DOE policy.

RC: 06.085

Doc: PC-025/40

Table 4.6.2.2-1 and Table 4.3.2.2-1 have different sources.

Response:

No, both tables have a common source: Banner, E., Data Needs for the New Projects at Pantex Plant SWEIS request for information supplied by M. Lincoln, Battelle Pantex, Amarillo, TX, May 17, 1995 (PC 1995g).

RC: 06.086

Doc: PC-025/41

In section 4.6.2.2, starting on page 481: What are the sources of water use in each of the 6 projects?

Response:

The source of water for the new facility construction and upgrades, discussed in volume I, section 4.6.2.2, would be Pantex Plant wells. As stated in section 1.3.5 of this volume, the upper bounding conditions (i.e., 2,000 weapons level) would result in a projected annual groundwater withdrawal of 1,011 million liters (267 million gallons), or an increase of 64 percent over FY 1995 water use. Furthermore, under the 2,000 weapons scenario, Pantex Plant groundwater withdrawals would only account for 0.8 percent of the total estimated annual groundwater withdrawals in Carson County.

RC: 06.087

Doc: PC-025/92

Water resources methodology is flawed since the analysis is based on examining permitted discharges of the NPDES system for which Pantex does not have a permit (the permit is pending). Groundwater analysis is flawed since groundwater quality within the [region of influence] ROI [is analyzed] but the analysis does not include other industrial, commercial, petroleum exploration (especially saltwater intrusion, and secondary recovery impacts), CERCLA and RCRA sites contaminating the groundwater. The analysis does not analyze the contamination of the groundwater by underground storage tanks or agriculture nitrates. This information is readily available through the State of Texas. Your methodology specifically calls for ROI analysis of readily available information. The analysis is further flawed because of the lack of analysis of playas within the ROI. Finally the analysis ignores the number of wells located in the ROI as potential contamination pathways to the Ogallala or whether any of these wells [are] resident in a floodplain. The analysis does not include ROI damage from farming and livestock (e.g., nitrogen, pesticides, herbicides, insecticides).

Response:

Impact Assessment Methodologies are provided in volume I, section 4.2. Cumulative impacts include impacts of continued operations at Pantex Plant combined with other reasonably foreseeable projects that could impact the environment at the plant site or in its region of influence (ROI). These include programs examined in Programmatic EISs for waste management, stockpile stewardship and management, and the storage and disposition of weapons-usable fissile materials. Information about new Federal proposed projects was sought, however, no information was forthcoming. The ROI for water resources includes Pantex Plant and the surrounding area that could potentially be impacted by plant operations. The ROI for surface water is the onsite playas and ditch system, and floodplains delineated by the Army Corps of Engineers, as discussed in volume I, section 4.6.1.1. The ROI for the perched aquifer is based on the extent and migration of contaminants, and is discussed in detail in volume I, section 4.6.1.2. Although the ROI for the Ogallala aquifer has not been quantifiably defined, it is limited to the extent of drawdown in Pantex Plant wells. The quantity of groundwater pumped from Pantex Plant wells is significantly less than for irrigation and for municipal water use, as discussed in section 1.3.5 of this volume. Volume I, section 4.6.1.2, has been updated to address sealing homestead wells located in the ROI that could provide potential contamination pathways to the Ogallala. Damage from other land and water applications outside of the ROI is beyond the scope of this document.

RC: 06.088

Doc: CO-008/114

C-6, Table C.1.2-3. Results from sampling and analyses from Bushland are provided as "background". Because some concentrations of analytes from Bushland samples exceed those measured in Pantex samples, how do you justify presenting these data as "background"?

Response:

The control well at Bushland is completed in the Ogallala aquifer upgradient from Pantex Plant and is, therefore, unaffected by plant operations (Pantex 1995c:82).

RC: 06.089

Doc: CO-008/115

C-11, Table C.1.2-3. Provide a table that cross-references location descriptions for surface water. This would allow readers to recognize the locations at which samples reportedly exceeded or lacked water quality criteria (this table). (Table C.2.1-1 on page C-21 provides similar cross-reference information for the water wells.) Some of these locations appear to be playas, waters of the U.S., but it is difficult to tell from the descriptions.

Response:

The requested information is provided in volume I, Table 4.6.1.1-2.

RC: 06.090

Doc: CO-008/116

C-13, Table C.1.2-3. Hexavalent chromium is shown to exceed the "standard" for 12-17 N, OW-WR-34, and Z-12-S. What was the total chromium for these same samples (i.e., did the concentrations of hexavalent chromium in these samples exceed the measured concentrations of total chromium in the same samples? [in which case the reported concentrations of hexavalent chromium may be exaggerated].)

Response:

Average hexavalent chromium concentrations that exceeded the decision criteria (and year of exceedance) are listed below:

· 12-17-N - 0.12 mg/L (1990)

· OW-WR-34 - 0.20 mg/L (1994) Bushland control sample.

· Z-12-S - 0.2 mg/L (1990)

The following are corresponding average total chromium concentrations:

· 12-17-N - 0.12 mg/L (1990)

· OW-WR-34 - 0.009 (1994) Bushland control sample.

· Z-12-S - 3.5 mg/L (1990)

Note that the hexavalent chromium concentration appears to be exaggerated on the Bushland control sample.

RC: 06.091

Doc: CO-008/117

C-28, Table C.2.2-1,...third line up from the bottom. The line reads "Parameter Units STD RRS." Is this an error?

Response:

Yes, this was an error and the referenced line has been deleted in volume II, Table C.2.21.

RC: 06.092

Doc: PC-026/1

Evidently Pantex continues to use open, unlined ditches to dispose of wastewater and storm water [that] discharges into the playas onsite. ...They are contaminated, and the Ogallala aquifer can also become contaminated. This is very scary.

Response:

Wastewater discharge permit requirements, upcoming investigations, and interim corrective action measures are summarized in section 1.3.5 of this volume. The EIS has been updated accordingly.

RC: 06.093

Doc: PC-029/1

It seems to me that storing radioactive substances over the Ogallala aquifer is not a good idea. Is it true that high explosives from Pantex have been found in the Ogallala? Have wells in the area been contaminated with plutonium?

Response:

See discussion in section 1.3.5 of this volume.

RC: 06.094

Doc: SG-002/1

The TNRCC is concerned that contamination in the perched aquifers beneath the site indicates that past and present industrial discharge practices at the Pantex facility have not been fully protective of natural resources at the site. The DOE should [ensure] that the threat of increased contamination to the Ogallala aquifer and contaminant exposure to ecological receptors is limited to the maximum extent practical.

Response:

See discussion in section 1.3.5 of this volume and response to comment 06.051.

RC: 06.095

Doc: SG-003/18

The TNRCC is concerned that contamination in the perched aquifers beneath the site indicates that past and present industrial discharge practices at the Pantex facility have not been fully protective of natural resources at the site. The DOE should insure that the threat of increased contamination to the Ogallala aquifer and contaminant exposure to ecological receptors is limited to the maximum extent practical.

Response:

See discussion in section 1.3.5 of this volume and response to comment 06.051.

RC: 06.096

Doc: SG-003/21

The Trustees do not oppose the DOE plan to construct an expanded Hazardous Waste Treatment and Processing Facility (HWTPF). However, contamination in the perched aquifers beneath the site [indicates] that past and present industrial discharge practices at the Pantex facility have not been fully protective of natural resources at the site. A treatment facility that is constructed and maintained properly will prevent further injury to natural resources. In addition, the increase of industrial discharge volume to 2.9 million liters may exacerbate contamination problems if additional measures are not taken by DOE to protect valuable groundwater resources. DOE should [ensure] that the threat of increased contamination to the Ogallala aquifer and contaminant exposure to ecological receptors is limited to the maximum extent practical.

Response:

A treatment facility, such as the HWTPF, that is constructed and maintained properly will prevent further injury to natural resources. Additional measures that are being taken to ensure that the threat of increased contamination to the Ogallala aquifer and contaminant exposure to ecological receptors is limited to the maximum extent practical are discussed in section 1.3.5 of this volume.

RC: 06.097

Doc: SG-003/24

Page 4-2, Affected Environment. The document states that an area of 50 miles surrounding the Pantex site will be considered the region of influence. The Trustees are concerned that this area will not encompass the potential area of natural resources that could be impacted since: a) the lateral extent of the perched aquifer has not been determined, and b) documented contamination in the Ogallala and its flow direction provide the potential for this contamination to impact various environmental receptors outside this radius.

Response:

Environmental restoration investigations, conducted at or before the time of publication, have indicated that the extent of offsite contamination detected in the perched groundwater has been limited to within one-half mile southeast of the main Pantex Plant site boundary. The distance of 50 miles is traditionally used as the maximum extent of a region of influence for NEPA documents.

See response to comment 06.087.

RC: 06.098

Doc: SG-003/26

Page 4-3, Section 4.2 Impact Assessment Methodologies, water resources: The qualitative assessment of water quality impacts from wastewater and stormwater runoff does not adequately address potential impacts to surface water and groundwater resources at the Pantex Plant. Furthermore, it does not consider existing contamination in the sediments, surface water, and groundwater and their cumulative impacts. The text should be corrected to reflect what actions would be necessary to thoroughly address the potential impacts to these natural resources.

Response:

Volume I, sections 4.5 and 4.6, have been updated with additional data, new permit requirements, and descriptions of corrective action measures.

RC: 06.099

Doc: SG-003/29

Page 4-55, Affected Environments. The text states that there is [no] evidence that contaminants found in the perched zone have migrated to the Ogallala aquifer. This is inaccurate and should be corrected to reflect that there is documented contamination in the Ogallala aquifer.

Response:

Groundwater quality sampling that was conducted after the publication of the Draft Pantex EIS indicated that contaminants found in the perched zone had been detected (in small amounts) in the Ogallala aquifer. Volume I, section 4.6.1.2, has been updated to report potential contamination in the Ogallala aquifer. For additional information, refer to the summary provided in section 1.3.5 of this volume.

RC: 06.100

Doc: SG-003/30

Page 4-62, Section 4.6.1.2 Groundwater. While the discharges that are permitted by EPA and TNRCC have protective standards [that] presently do not allow excessive levels of contaminants, existing contamination is already present in the perched aquifer and the playas. Therefore, the continual discharge of wastewater provides a hydraulic head potentially driving those contaminants into the Ogallala. Contamination in the Ogallala has been documented and more stringent actions are required in order to prevent further migration of contamination [that] could result in greater injury to an extremely valuable groundwater resource.

Response:

We disagree. The hydrology and recharge of the perched aquifer is very complex and the effects upon the vadose zone from continual discharge of water into existing playa lakes and drainage ditches do not necessarily result in contaminated groundwater being driven into the Ogallala. The Ogallala contamination which is referenced is believed to be due to special circumstances (cross-contamination through an open bore homestead well). This well and six other homestead wells have been sealed under the Groundwater Protection Project. See discussion in section 1.3.5 of this volume and section 4.6.1.2 of volume I for additional information.

RC: 06.101

Doc: SG-003/31

Page 4-69, Section 4.6.1.2 Groundwater, Perched Aquifer portion. See comment #9.

Response:

See response to comment 06.099.

RC: 06.102

Doc: SG-003/32

Page 4-72, Groundwater Quality. The absence of trinitrotoluene in the perched aquifer may not be due to a reduction in the discharge of this contaminant, but rather an indication of it breaking down to degradation compounds in the environment. Also, the text states that levels of trichloroethene occurring at the site barely exceed the Risk Reduction Standards (RRS) decision criteria of 5 micrograms per liter. Data used to make this determination may not be representative of actual levels of contamination at the site. To accurately determine what is occurring at this site, properly screened intervals in groundwater monitoring wells to accurately measure "sinking chemicals, metals, radionuclides and high explosives," as well as the proper suite of analyses, should be employed for all potential contaminants of concern.

Response:

Concur, evidence of natural attenuation and degradation of high explosive compounds including trinitrotoluene has documented during the treatability studies. The maximum concentration of trichloroethene (i.e., trichloroethylene) has consistently occurred in the perched aquifer south of Zone 11 in monitoring well PTX08-1005 as discussed in the Draft RCRA Facility Investigation Report for Groundwater in Zone 12 at the DOE Pantex Plant (Argonne 1995a). In order to define the stratification of contaminants within the perched aquifer, due to different densities of the contaminants, it is necessary to sample at discrete intervals and depths. Volume I, section 4.6.1.2, has been revised accordingly.

RC: 06.103

Doc: SG-003/33

Page 4-78, Section 4.6.2.1 Impacts of Continued Operations, Weapon-Related activities, Surface water. A thorough evaluation and consideration of existing contamination in surface water and sediments of receiving waters at the Pantex site is needed to adequately assess the potential impacts of wastewater discharges. Cumulative impacts of preexisting contamination and projected waste loads must be considered.

Response:

See discussion in section 1.3.5 of this volume.

RC: 06.104

Doc: SG-003/34

Page 4-80, Section 4.6.2.1, Groundwater. The TNRCC permit does not include radionuclide parameters. In order to prevent further injury to natural resources, DOE regulatory oversight should be shared with another appropriate agency....

Response:

See discussion in section 1.3.5 of this volume and response to comment 06.051.

RC: 06.105

Doc: SG-003/35

Ogallala ContaminationThe EIS should be revised to reflect that the Ogallala has been impacted by Pantex operations, as evidenced in recent contaminated samples obtained from Mr. Cockrell's private off-site wells.

Response:

Although low levels of high explosive contamination have been detected in a domestic Ogallala well located on the Cockrell ranch, efforts to mitigate further contamination have been completed. The well in question has been properly plugged and abandoned under the supervision of the TNRCC and a replacement Ogallala well has been drilled and completed in order to prevent further potential cross-contamination of the Ogallala aquifer. Additional information regarding the Groundwater Protection Project has been included in volume I, section 4.6.1.2.

RC: 06.106

Doc: SG-003/36

Homestead WellsThe EIS should note that the low vertical permeability of the fine-grained zone may be compromised by abandoned homestead wells. These wells could provide contaminant pathways through the fine grained zone to the Ogallala. The potential for this to occur has been demonstrated at the Cockrell farm east of the Pantex Plant.

Response:

Efforts to identify and evaluate abandoned homestead wells in order to prevent potential pathways of contamination into the Ogallala aquifer have been completed under the Groundwater Protection Project.

RC: 06.107

Doc: SG-003/37

Facility BoundaryThe EIS should mention that DOE will take whatever action is practicable to clean contaminated groundwater to the residential drinking water standards beyond the facility boundary (page 4-69).

Response:

See discussion in section 1.3.5 of this volume and response to comment 06.051.

RC: 06.108

Doc: SG-003/40

Pantex Plant PlayasThe Risk Reduction Rules (RRR) (30 Texas Administrative Code (TAC),...335, Subchapter S), which include references to the Texas State Water Quality Criteria (30 TAC...307), do apply directly to the Pantex Plant Playas, contrary to the statement on page C-2.

Response:

Refer to the discussion of surface water quality decision criteria presented in section 1.3.5 of this volume.

RC: 06.109

Doc: SG-003/41

Surface Water Quality ValuesThe surface water quality values determined in accordance with the RRR take precedence over the Risk Based Concentration Guidelines from EPA Region 3 (Section C.1.2). The EPA Region 3 Guidelines are not appropriate standards to apply when values are available in the Texas Surface Water Quality Criteria, the Federal Safe Drinking Water Act, or the Texas Regulations for Control of Radiation (TRCR) (30 TAC...336).

Response:

Refer to the discussion of surface water quality decision criteria presented in section 1.3.5 of this volume.

RC: 06.110

Doc: SG-003/42

Tables C.1.2-1 through C.1.2-3the standards listed in Table C.1.2-1 should cite values based on the RRR, rather than EPA Region 3 Guidance. For instance, the standard for antimony should be 0.006 milligrams per liter (mg/L), based on the RRR, rather than 0.015 mg/L cited for EPA Region 3 Guidance. The standard for gross alpha activity, according to the RRR, should be 15 picocuries per liter (pCi/L), rather than N/A. No water quality standard is provided by the Texas Surface Water Quality Criteria; therefore, the RRR specify use of the drinking water standard. The proposed drinking water standard of 50 pCi/L (4 millirems per year) should also be cited for beta particle activity. The TNRCC requests that DOE revise Table C.1.2-1 to cite the more stringent surface water quality standards for radionuclides that are developed in accordance with the RRR. As such, the standard for plutonium-239/240 would be 2E-8 microcuries per milliliter (mCi/ml), based on the TRCR standards. Radium-226 and Radium-228 would be 6E-8 mCi/ml, based on proposed federal Drinking Water Standards. Tritium would be 1E-3 mCi/ml, based on the TRCR standards. Uranium-234 and Uranium-238 would be either 3E-7 mCi/ml, the TRCR standards, or 20 mg/L, the proposed Drinking Water Standard, which ever is more stringent.

Response:

Refer to the discussion of surface water quality decision criteria presented in section 1.3.5 of this volume and the response to comment 06.051.

RC: 06.111

Doc: SG-003/43

Constituents of ConcernThe constituents of concern for groundwater should not be limited to those constituents that exceed risk based concentrations (Section C.2.2, page C-4). In addition, the nature and extent of contamination must be based on background values or laboratory Practical Quantitation Limits (PQL), rather than risked based values. These issues were addressed in DOE's revised Sampling and Analysis Plan and the TNRCC's subsequent approval with modification.

Response:

Water quality data from an Ogallala water supply well at Bushland provides regional background groundwater quality data, as discussed in volume II, appendix C, section C.2.2. Volume II, Table C.2.23, presents a tabulation of water quality sampling data collected from Pantex Plant Ogallala aquifer wells that exceed decision criteria. TNRCC and EPA Drinking Water Standards and DOE Derived Concentration Guidelines were used as the decision criteria, rather than background values or laboratory Practical Quantitative Limits because the Drinking Water Standards and DOE Derived Concentration Guidelines are regulated to be protective of human health.

RC: 06.112

Doc: SG-003/62

The sections that deal with Geology and Soils and with Water Resources are generally well done. One issue that is still not adequately covered relates to the perched aquifer. The extent of the fine-grained zone which forms the perching layer is not known. The question of what happens to the perched aquifer is not discussed. Does the fine-grained zone pinch out with the perched aquifer groundwater flowing off the side, down to the Ogallala? Alternatively, will [groundwater in] the perched aquifer eventually migrate through the fine-grained zone and down to the Ogallala? All that the Draft EIS acknowledges is "Recharge to the area aquifers is not fully understood."

Response:

Additional updated information regarding the nature and extent of groundwater contamination in the perched and Ogallala aquifers is presented in section 1.3.5 of this volume. Discussion in volume I, section 4.6.1.2, has been revised for clarification.

RC: 06.113

Doc: SG-003/63

Groundwater was not considered as a pathway for exposures potentially impacting human health. An obvious concern of some people in the area is contamination of the Ogallala from plant activities. In what way were groundwater scenarios considered, and what pathway assumptions were used?

Response:

Groundwater as a potential pathway for exposure was discussed in volume I, section 4.14.2.1. Potential consequences to the Ogallala aquifer from an accidental plutonium release were investigated in conjunction with a Safety Analysis Report and an Environmental Assessment, which included a study by Los Alamos National Laboratory (LANL 1992). The hypothetical accident was assumed to be a high-temperature fire caused by a jet plane impact into a Zone 4 storage magazine containing nuclear weapons components, and the subsequent release and ignition of jet fuel, leading to dispersal of plutonium. Four potential elements of concern were identified: plutonium, americium, neptunium, and uranium. Of these four, plutonium was determined to pose the greatest risk. Los Alamos National Laboratories used the conservative assumption that the hypothetical jet fuel fire could disperse fine particulate plutonium downwind of Pantex Plant for a maximum distance of 50 miles. Prompt decontamination efforts could reduce radiation levels to 0.2 microcuries per square meter. Plutonium and decay products could infiltrate downward toward the Ogallala aquifer. The model assumed an average recharge rate of 1 inch per year (10 times the High Plains average), and that infiltrating recharge water would reach the Ogallala aquifer at depths ranging from 50 to 400 feet. These analyses were conservative because the "worse-case" scenarios were based on a depth to the water table of 50 feet whereas, at Pantex Plant, the typical depth to the top of perched groundwater is approximately 270 feet and the depth to the Ogallala aquifer ranges from 340 to 460 feet. For water table depths of 200 and 400 feet, LANL calculated plutonium travel times of 305,000 and 610,000 years, respectively. Interactions with both surficial materials and the unsaturated portion of the Ogallala Formation would be expected to make plutonium move at a rate slower than the infiltrating water. During the transport time, radioactive decay would be expected to further reduce plutonium concentrations. Current knowledge of the perched aquifer leads to the expectation that where the perched aquifer is present, the downward movement of plutonium would be further reduced, because the low permeability fine-grained zone would impede downward flow and potential contamination would be more likely to move horizontally in the perched aquifer.

RC: 06.114

Doc: SG-003/64

Table C.2.2-2 in volume II provides data on chemical concentrations measured in the perched aquifer. A great deal of data is here, but I do not believe that it represents all available data. The Draft EIS should explain what data was used and what data was not used, and why.

Response:

Evaluation of baseline surface water and groundwater quality is based on a review of all available data tabulated in the Pantex Plant annual site environmental reports (ASER) for a five-year period, from 1990 through 1994. Surface water quality data were collected from 29 onsite sampling locations from 1990 to 1993; surface water samples were collected from only 17 of these sampling locations in 1994. The surface water data collected over the past five years does not include every sampling location each year, because some locations only have sufficient water to sample during storm events. Groundwater quality monitoring data were collected from over 20 onsite sampling locations, including wells completed in the perched and the Ogallala aquifers. It should also be noted that the groundwater data collected over the four years do not include every sampling location each year. In 1995, 78 groundwater monitoring wells were sampled. In addition to the ASERs, available U.S. Corps of Engineers (COE) quarterly groundwater monitoring reports were reviewed. Quarterly groundwater monitoring was conducted to characterize the groundwater quality and extent of contamination in the perched aquifer, in association with the Ditches and Playas RCRA facility investigation for Flow System 6. It should be noted that the water quality constituents that were analyzed for the COE investigation are not always the same constituents that are analyzed for the ASERs. One offsite location, Bushland Playa at the USDA Agricultural Experimental Station west of Amarillo, was used as a control sample to give some insight on background surface water and groundwater quality.

All available surface water and groundwater data from the ASERs were compiled into two cumulative data tables, one for surface water quality data, and the other for groundwater quality data. The data were evaluated through a process of elimination whereby all parameters with values below the detection limits or those reported as not sampled, not presented, or holding time exceeded were omitted from the water quality data under consideration. For the radionuclides, levels of uncertainty (reported +/- the measured value) were omitted so the data could be processed. The remaining data were then exported into a data management system to speed data manipulation and to reduce the chance of human error. The surface water and groundwater quality data were then sorted by location, parameter, and average value. Contaminants of concern (COC) were determined by comparing tabulated annual average values to the decision criteria presented in volume II, appendix C. Volume II, Tables C.1.23, C.1.24, C.2.22, and C.2.23, present values that are greater than or without defined water quality criteria for the five years of water quality data.

RC: 06.115

Doc: SG-003/66

Response:

Volume I, sections 4.5 and 4.6, have been updated with additional data, new permit requirements, and descriptions of corrective action measures.

RC: 06.116

Doc: SG-003/85

Page 4-55, Affected Environment, para. 2, ln 19. The statement is made that there is no evidence that the contaminants found in the perched aquifer have migrated to the Ogallala aquifer. Only a few (2 or 3) Ogallala aquifer monitor wells are located in areas where there is perched groundwater present. There are no Ogallala monitor wells beneath badly contaminated areas such as Zone 12, so there are no data on which to base the conclusion that no contamination has occurred. Furthermore, the unsaturated zone between the Ogallala and perched aquifers has not been sampled so it is not known if these waters and sediments have been contaminated.

Response:

Volume I, section 4.6.1.2, has been updated with additional information regarding the perched and Ogallala aquifers. For additional information, see discussion in section 1.3.5 of this volume.

RC: 06.117

Doc: SG-003/86

Page 4-62, Groundwater, para. 1: There is no discussion of sediment heterogeneity, which strongly affects groundwater flow rates.

Response:

Discussion of the effects of heterogeneous sediments on groundwater flow rates has been added to volume I, section 4.6.1.2. See response to comment 06.076.

RC: 06.118

Doc: SG-003/87

Page 4-63, Figure 4.6.1.2-1. Why are there no monitor wells in the area of Playa 4? Considering all of the discharge that has occurred from Zone 12 south to Playa 4, it would seem appropriate to determine the nature of the hydrogeology in this area.

Response:

Playa 4 and the majority of its watershed are located on property owned and managed by Texas Tech University. DOE has no jurisdiction to place monitoring wells near Playa 4. There are monitoring wells in place on the DOE owned property north of Playa 4. Additionally, the Ditches and Playas Solid Waste Management Unit process is currently collecting samples from the area of concern noted in this document. Soil and water characterization of the ditches on DOE owned property that leads to Playa 4 are ongoing (PC 1996x).

RC: 06.119

Doc: SG-003/88

Page 4-65. Perched Aquifer, para. 2, ln 1: Contrary to this confusing statement, there are areas at Pantex where perched groundwater is present, but where gravel channels are not present and vice versa. The presence of gravel channels does not control the presence of perched aquifers; it is the presence of a stratigraphic horizon (in this case the fine-grained zone) with a vertical hydraulic conductivity lower than the flux of recharge water moving through the unsaturated zone. It is quite obvious that if the gravel channel were underlain by a coarse sand then no perched aquifer would have formed.

Response:

A stratigraphic horizon with a low vertical hydraulic conductivity, such as the fine-grained zone, is necessary for formation of a perched aquifer. This clarification has been made in volume I, section 4.6.1.2.

RC: 06.120

Doc: SG-003/89

Page 4-69, para. 4, line 6. If the spread of contaminants in the perched aquifer is limited to the confines of perched aquifer in buried channel deposits, then why are there so many perched aquifer monitor wells in Zone 12 with contaminants, but located outside the gravel channel as mapped on page 4-66? It seems obvious that something other than gravel channels is, at least in part, controlling flow in the perched aquifer and that contaminants are present in perched aquifer water outside the gravel-filled channel.

Response:

There are heterogeneities in the subsurface sediments that result in preferencial subsurface flow. The horizontal flow of perched groundwater is controlled by the fine-grained zone that limits the downward movement of groundwater, as briefly discussed in section 1.3.5 of this volume and in the response to comment 06.119.

RC: 06.121

Doc: PC-028/2

Page 5-8, 2nd column, 3rd paragraph:...The water usage and wastewater production are of a major concern in New Mexico and Albuquerque. The State is experiencing a major drought along with Albuquerque. Any additional water usage by KAFB drains the already lowering aquifers in Albuquerque. Go elsewhere!

Response:

The Pantex EIS only deals with the interim storage of containerized pits at the Manzano Weapons Storage Area at Kirtland Air Force Base. As a result, groundwater resources would not be affected by these interim storage activities. Only the guard force and operations personnel (about 150 people) would need water.

RC: 06.122

Doc: PC-028/4

Page 5-58, para 5.5.1.4: Any additional water usage, by any operation puts additional demands on a drought ridden state. Additionally, Albuquerque is experiencing dwindling water supplies in their aquifers to include KAFB. Any additional water usage, even for pit operations, is not necessary since DOE can select on the other alternatives and should.

Response:

See response to comment 06.121.

RC: 06.123

Doc: HT17/73

It would be IGNORANT to site future missions at Pantex without first reviewing the geological hazards truthfully and openly. It would be doubly ignorant to continue trying to hide contamination facts as they relate to the Ogallala today. The recharge rate is MUCH faster than folks believed it to be a few years ago, and MUCH faster than what is being publicly acknowledged today.

Response:

Numerous scientific investigations have been conducted to determine the geologic and water resource characteristics at and in the vicinity of Pantex Plant. Volume I, section 4.5, addresses the geologic conditions and potential for seismic activity. Volume I, section 4.6.1.2, discusses the hydrogeologic conditions, including ranges of groundwater velocity and recharge estimates, based upon the most up-to-date information available at the time of publication. The Environmental Restoration Protection Program will continue to monitor existing conditions and perform corrective actions as needed.

RC: 06.124

Doc: CO-007/1

... Two very important negative impactsthe drawdown from the already dropping water reserves and the contamination into it. The proposal gives inadequate information and inadequate protection of the crop-feeding resource in the agriculturally rich eight state region where the Ogallala is locatednot to mention the water supply for Amarillo.

Response:

The importance of the Ogallala aquifer as a valuable regional groundwater resource supply is discussed in section 1.3.5 of this volume.

RC: 06.125

Doc: PC-030/3

No additional water should be channeled to the open ditches and playas at Pantex because it will accelerate the flushing of contaminants into the soil and eventually into the aquifer.

Response:

See discussion in section 1.3.5 of this volume and response to comment 06.060.

RC: 06.126

Doc: CO-005/4

A second major flaw in the document is the omission of the importance of the Ogallala aquifer to this area. As the single groundwater supply for 46 counties in the Texas Panhandle and the source of water for parts of seven midwestern states, it is paramount that nothing be done to damage this priceless resource. What could be more important in an environmental document than a detail analysis of the water source, the future supply and the impacts to this source from present activities at Pantex. To ignore the tremendous impact that Pantex has already induced on this finite water source is inadmissible. We ask that you provide detailed analysis on the effects of Pantex activities on the Ogallala (which includes the perched layer), the complete scope of contaminants, the combined effects of these contaminants and how different constituents react in varying soils and water.

Response:

See discussion in section 1.3.5 of this volume. Additional information has been included in volume I, section 4.6.1.2.

RC: 06.127

Doc: CO-005/5

We ask that the studies from the Bureau of Economic Geology (BEG) be included as part of the Pantex EIS. Why were the results of the years of work done by BEG not included in the draft document? These are valuable studies with extremely telling results. Provide the reports, analysis and statements produced by BEG in their study at Pantex in the final document.

Response:

Many of the Bureau of Economic Geology (BEG) reports have been cited in the Pantex Plant EIS. BEG reports are included in the administrative record and are available to the public.

RC: 06.128

Doc: PC-008/3

Plant used 230 million gallons in 1995.

Texas Tech Farms used 66 million gallons (29%) of the total plant water usage.
Nuclear weapons operations used 163 million gallons (71%).

Amarillo Water District consumed 16 billion gallons in FY 1995.

Pantex Plant including Texas Tech Farms used 1.4% as much water as Amarillo District. Nuclear weapons operations used 1% of the water used by Amarillo. Considering the water also used for irrigation, the Plant withdrew 0.6% of the regional withdrawal from the Ogallala aquifer.* Nuclear weapons operations consumed 0.43% of the regional withdrawal.

*Draft Environmental Impact Statement for the Continued Operation of the Pantex Plant and Associated Storage of Nuclear Weapon Components, March 1996, page S-15.

Response:

Comment noted.

3.7 Air Quality

RC: 07.001

Doc: HT02-05/1

[The Proposed Action] is inappropriate for the reasons that winds and storms here are very strong and tend to have...more far-reaching effect[s] than they do in other parts of the country.

Response:

This EIS only assesses the impacts of relocating interim pit storage. The potential relocation of other Pantex Plant operations is assessed in the SSM PEIS. The meteorology and climate (regional and local) at Pantex Plant are discussed in volume I, section 4.7.1 of this EIS. The climatic characteristics of the Pantex Plant area were taken into account in assessing the impacts of air pollutants from normal operations (see volume I, section 4.7) and from accidents (see volume I, section 4.14). The climactic characteristics of each of the other sites being considered for interim storage of pits were also taken into account in assessing impacts (see volume I, chapter 5).

RC: 07.002

Doc: HT02-04/5

The use of strontium-90 to test containment at the Firing Sites is an unacceptable, unpleasant fact to me. Please tell me more about this, as well as the other open air experiments conducted at the site.

Response:

In 1977, one test at Firing Site-15 involved the use of high explosives containing strontium-90 as a tracer. It was later determined that the lagoon was contaminated with strontium-90. During a 1987 study, grab samples were collected in the potentially affected area around the site. Strontium-89/90 averaged 0.398 pCi/g. Another investigation was conducted at the site in 1995 (PC 1996w). All potential radioisotopes were analyzed for, including uranium (U), thorium (Th), beryllium (Be), cesium (Cs), and strontium (Sr). These concentrations were found to be well below the Nuclear Regulatory Commission (NRC) and Texas Department of Health (TDH) soil contamination limits. Detected activities ranged from 0.43 to 1.8 pCi/g for Be-7; from 0.34 to 0.01 pCi/g for Cs-137; and from 0.14 to 0.86 pCi/g for total Sr isotopes. The NRC criteria for no further action were used for thorium, uranium, cesium, and strontium.

RC: 07.003

Doc: HT02-04/6

[Depleted Uranium] DU particles from test explosions at the Firing Site spread into the air, land, and water offsite. DU is toxic and radioactive. While I thank you for starting to clean it up, once again, I must say, tell us more.

Response:

Up until the mid 1980s, test firings were performed in the open areas at the firing ranges, resulting in the dispersion of DU in the immediate area of the firing sites.

Soil and Sediment Quality, volume I, section 4.5.1.3, discusses the general environmental restoration process. Volume I, section 4.5.1, discusses the DU contamination at Firing Sites 4, 5, and 10. A request has been submitted to TNRCC to remove the four currently active Firing Sites from the Pantex Plant Environmental Restoration program. Firing Sites 4, 5, and 10 have a low uranium-234 to uranium-238 ratio. An interim corrective measure is being conducted on Firing Site-5 to remove surface DU contamination. Subsequent confirmation sampling and risk assessment will be conducted at Firing Site 5. Confirmation sampling will be conducted to confirm that protective levels have been attained and no further action will be required.

For further information see volume II, section I.1.2.4 and Table I.1.2.11.

RC: 07.004

Doc: HT16/17a

One of the items that [was] mentioned was that one of the pollutants that we monitor for is [total] suspended particulates, which is no longer true because there is no standard for total suspended particulates, so we stopped monitoring for [them]. Although we take samples, those filters are forwarded to the Bureau of Radiation Control for radionuclide analysis.

Response:

The language in volume I, section 4.7.1 has been revised to say that TNRCC no longer monitors for total suspended particulates.

RC: 07.005

Doc: HT16/17b

And the other item that was mentioned was that we monitor for metals. Again, we don't on a regular basis analyze for metals. We did take a sample in 1993 for about 30 days30 samples. And then we analyzed for about 20 different metals through kind of a screening method. There aren't any concerns there or we haven't been able to identify any. So we have not done any additional analysis for metals.

Response:

Text in volume I, section 4.7.1 has been revised to reflect that metals are not routinely monitored.

RC: 07.006

Doc: HT16/18

And with regard to air quality impacts, both for No Action Alternative or the consolidation alternative, the non-radiological air quality impacts will be minimal. Only potential is for particulates if more construction activity takes place due to consolidation alternative. And, as the EIS mentions, that if that happens, that mitigation measures will be used to control the particulate emissions. And I think that is a TNRCC-accepted method of control for particulate emissions.

Response:

Volume I, section 4.7.2.2 discusses the emissions from construction activities and volume I, section 4.7.6 discusses the potential mitigation measures to reduce emissions. Regarding the variance between monitoring data and modeling results, see discussion in section 1.3.6 of this volume.

RC: 07.007

Doc: HT16/19

I would like to bring up some inaccurate statements in the EIS that need to be corrected. In Table 4.7.1.31 there's a footnote discussing the National Ambient Air Quality Standards, and I think that statement is not accurate, because for ozone and PM10 the standard...is determined by statistical methods. And that is based on expected exceedances over a 3-year period. And if...in a 3-year period, the number of exceedances or expected exceedances, averaged over the 3-year period has to be one or less, otherwise that area is considered non-attainment for that pollutant. For sulfur dioxide and nitrogen oxide annual standards and for lead, the quarterly standard, are not to be exceeded. And carbon monoxide, there are two standards, the 1-hour standard and the 8-hour standard. And [for] sulfur dioxide, a 3-hour standard and a 24-hour standard can be exceeded only once per calendar year. And the statement in the EIS does not make that clear. And on page 493, there is a statement that says that Air Quality Control Region 211 is designated by EPA as better than National standards for total suspended particulates. That statement is incorrect because when EPA established new standards for PM10 for (inaudible) particulates, the standards for PM10 were taken out. So there is no more National standard for TSP. On the same page, 493, there is a discussion about methylene chloride found in our monitoring at 213 parts per billion by volume on July 6th, 1993. But there is no mention made that this concentration was seven times the effects screening level established by TNRCC. Although, further review and analysis by our staff, toxicology and risk assessment staff, concluded that this one-time health episode would not result in any long-term health effects. There is greater discussion about the slightly above ESL concentration of dichloroethane, whereas the discussion on methylene chloride was left out. Another point I want to make is that in our four years of monitoring at Pantex we have found a number of exceedances of PM10 National Ambient Air Quality Standards. Although the modeling done by both TNRCC and the EIS staff did not predict any possible PM10 violations, actual exceedances happened. They could be due to blowing dust or localized earth-moving activities. But that is precisely the kind of scenarios anticipated in the consolidation alternative if additional construction activity takes place. The EIS addresses this issue in section 4.7.6.

Response:

This comment discusses four individual points. Each of the points is addressed in turn.

1) The footnotes containing the discussions of the standards associated with each of the pollutants have been revised in accordance with the comment and the TNRCC Monitoring Operations Division reference "Smarter Air Monitoring for Texas" (TNRCC 1994b).

2) The text discussing the standard for TSP has been deleted.

3) The discussion of the methylene chloride exceedance in section 4.7.1 in volume I has been amended. The following sentences have been added. "The concentration was approximately seven times the ESL (30 ppbv) established by TNRCC.... In the case of the 1993 methelyne chloride exceedance, the TNRCC Toxicology and Risk Assessment Section stated that the one exceedance was not expected to result in any long-term health effects."

4) See section 1.3.6 of this volume for a discussion of the variance between PM10 monitoring data and modeling results.

RC: 07.008

Doc: HT16/20

Our modeling staff reviewed the modeling results that [were] given in the EIS. The TNRCC did clean air modeling in 1995 under the agreement in principle. And our staff used a different methodology to do the modeling for [the] Pantex site-wide modeling. And the EIS staff...use the same model, the Industrial Source Complex model, but they used a different methodology to do the modeling. But the conclusions that were arrived at by both models were the same, that only alcohols exceeded the effects screening levels. And when it was modeled for outside the Pantex boundary, there was no exceedance of the standard or the guideline ESL. So that sort of validates the model, that two different groups of people modeled the same emissions using different approaches, but [came] up with the same conclusion. However, by reviewing the input into the models our staff found that a number of emission points were left out in the modeling that the EIS staff conducted, like the carbon monoxide emissions from emission points 54, 85, and 160. Some of them are very minimal emissions. But, for example, emission point 160 is a natural gas boiler. It has the emissions of 13,000 pounds per year, which was not included in the EIS modeling. The same thing, from the same boiler, the NOx emissions, the nitrogen oxide emissions, 53,000 pounds a year, that was not included in the EIS model.

Response:

Emission points 54, 85, and 160 were active at the time TNRCC performed their modeling, but had become inactive by the time the modeling was performed for this EIS. For a general discussion of the differences between the two modeling efforts, see section 1.3.6 in this volume.

RC: 07.009

Doc: HT16/21

... There were a number of hazardous air pollutants that were left out in the EIS modeling, which the TNRCC staff used in their modeling.

Response:

The air quality modeling for this EIS included all current and future hazardous air pollutants. However, some of the pollutants had such negligible concentrations that they were screened out of the tables placed in the Draft EIS. In the Final EIS the tables have been expanded to include all of the hazardous air pollutants. See also the discussion in section 1.3.6 of this volume.

RC: 07.010

Doc: HT16/22

... We have had some PM10 exceedances, although [they] happened at the property, they are not considered a violation of the National Ambient Air Quality Standards. But that is one thing that needs to be taken into consideration when this expansion or consolidation alternative is considered, that some mitigation measures will be employed to avoid exposure to the workers or even potentially to the neighboring residents.

Response:

See discussion in section 1.3.6 of this volume.

RC: 07.011

Doc: HT16/29

Are all the known emissions for Pantex included in a list in this document, regardless of whether or not there's a standard that it was tested for, or do we only talk about things that there's a standard that applies that you pick up in monitoring? Or are they only monitored for if there's a standard and if there's no standard they're not tracked...? ...I would be interested, and would like even to request, it would be nice if this document gave us a good thorough picture of the plant, regardless of, perhaps, health effects or whatever, just what the emissions are. And, if there are no health effects attached to certain things, that's nice if you can specify that or just that there's not a standard, or whatever. But it would be nice to have a better picture, a clearer picture, of this plant as it currently operates.

Response:

See response to comment 07.009, and section 1.3.6 of this volume.

RC: 07.012

Doc: HT16/30

... When we reviewed the emissions data that they have reported in Appendix B and the emissions inventory that was submitted to us for our AIP modeling, there were a number of hazardous air pollutants, about 50 of them, that were left out. And, as I said, they are not very high quantities, but they were mentioned in the emissions inventory that was submitted to us, but it is not included in the EIS.

Response:

See response to comment 07.009 and discussion in section 1.3.6 of this volume.

RC: 07.013

Doc: PC-031/2

Some of the most glaring deficiencies and omissions include the continuing use of the Burning Ground with no alternative examined. This facility is not technically acceptable and this document ignores the agreement with our citizen groups to analyze alternatives. The air modeling is inadequate, by the words of the document itself. How could DOE expect credible results with no modeling for residences on the south side of the Plant? There are still no monitors either at the perimeter or outside the plant measuring emissions that are not radiological.

Response:

There are several misunderstandings revealed in this comment. The facts are that:

1) Pantex Plant did conduct a Best Available Control Technology (BACT) of several existing or developmental alternatives to open burning/open detonation. The analysis concluded that controlled open thermal treatment with existing administrative controls constituted BACT. Thus, the plant proposes to continue that activity in this EIS. Since that study was completed, further development of procedures for chemical treatment has warranted further investigation of a base hydrolysis treatability study. Volume I, section 1.2.2 and volume II, section G.3.8 contain additional information on this subject.

2) As stated above, the Burning Ground is not only technically acceptable, but technically the best available method of sanitizing HE components as well as for treating HE-contaminated waste material.

3) The air modeling is not "inadequate, by the words of the document itself." The air modeling for this EIS was performed using EPA approved models, a TNRCC approved data set for meterology and mixing heights, and a comprehensive set of emissions sources and emissions rates. The conclusions of the air modeling are consistent with those of other modeling efforts independently conducted by another contractor and by TNRCC.

4) The air quality modeling included analysis for receptor locations spaced at 100 meter intervals along the north, west, and east boundaries of Pantex Plant. On the south side of the plant, the receptor line was positioned to include most of the property leased from TTU. See Figure 4.7.1.31 in volume I for a graphical depiction of the "fence line" receptors. Any air pollutant concentrations emitted by the plant would have to cross these receptors before reaching an off-site residence. In addition, the modeling did include several residences on the south side of the plant. Some "residences" shown in Figure 4.7.1.31 of the Draft EIS were inadvertently depicted at incorrect locations. This has been corrected in the same figure of the Final EIS. It should be noted, however, that the residence locations used in the actual computer modeling were correct and the analysis of concentrations at residences is valid.

RC: 07.014

Doc: PC-025/42

On page 4-94, The Target Range is where you explode nuclear devices?

Response:

Nuclear devices are not exploded anywhere at Pantex Plant. The Target Range indicated in volume I, Figure 4.7.1.31 is used to conduct live fire training for security personnel with duty sidearms, sub-machineguns, and shotguns.

RC: 07.015

Doc: PC-025/43

Pages 4-96 and 4-99. What are the sources of the information in the tables?

Response:

The sources of information for Table 4.7.1.33 are the Pantex Plant Environmental Information Document, Pantex Plant Emissions Inventory, and TNRCC Effects Screening Levels and the Clean Air Act.

For Table 4.7.1.34, the sources are TNRCC Air Quality Modeling Guidelines and calculations performed with ISCST2 and ISCLT2 models.

In the Final EIS both tables have been annotated to list these sources.

RC: 07.016

Doc: PC-025/44

General comment on section 4.7: Poor QA/QC of data has occurred in appendix B supporting section 4.7. Examples included below of showing incorrect data are as follows: page B-44, chromium, 45.4 kg, 1000, l hour; page B-44, chromium, 363 kg, 1 hour, page B-45, cresol, 1,000, annual, #11; page B-45, cresolic acid, annual, #11; page B-46, ethyl benzene; page B-48, HF, 363 kg, 24-hour, #3; page B-49, ketone, 363 kg, annual, 8, 10; ketone 363 kg, 1 hour, #2; Page B-50, methylene chloride, annual, #2; page B-50, naphthalene, 45.4kg, 1 hour, #5; page B-51, NO2, 45.4 annual, is totally incorrect; page B-51, NO2, 363 kg, #1, #2, #5, #9, #11; page B-5 1, NO2 BGU, is totally incorrect. Page B-52, toluene, 500, I hour, #10; page B-52, trichloroethylene, annual, #8, #9, #10, #11. These are only examples determined by visual inspection of data presented in appendix B not actual calculations. What level of QA/QC was completed? What level is required? Please provide QA/QC documentation including signatures assuring certification of data quality. What proof does DOE give that the analysis is of good quality? I believe DOE will blow off my comments in SSM, S&D, and Pantex projects regarding QA/OC. I believe I am presenting evidence that the QA/QC is technically substandard. Prove I'm incorrect.

Virtually every page of the table is incorrect to some degree.

Table B.4.11 has numerous concentrations reported with identical roots but orders of magnitude difference. This is highly unlikely and points to poor QA/QC. Cresol residence #l is in error. HF exponents are in error. Ketone exponents are in error. Lead is incorrect in the 3rd quarter.

Response:

The QA/QC process used for the preparation of this EIS was conducted in accordance with a Quality Assurance Program Plan tailored for the preparation of this EIS and consistent with DOE Order 5700.6c. The process involved multiple levels of review, both internal and external to the team preparing the document.

The specific section cited in your comment, appendix B, relates to air quality analysis. Preparation of that particular section entailed the analysis of 3.8 million data elements from which the tables you cited were prepared. During the preparation of those tables, there were typographical errors introduced due to misreading of the authors handwriting. The same misreadings that occurred during the word processing step occurred during the reviews, with the effect that the typographical errors in data were not caught by reviewers. Following the discovery of this problem with the particular authors handwriting, the review process was modified to ensure that the entries in the tables of the Final EIS were rechecked against the original data set.

It should be noted that while the Draft version of appendix B contained typographical errors in tables containing thousands of data entries, the air quality modeling and the analysis of modeling results as reported in both the Draft EIS and this Final EIS is still valid. Separate, independent modeling efforts by a different DOE contractor and by the TNRCC, using compatible, but slightly different methodologies, produced results in close agreement with the modeling performed for this EIS. None of the three independent modeling efforts found that any individual pollutant concentrations exceed air quality standards or Effects Screening Levels at the Pantex Plant boundary. The Draft EIS and TNRCC modeling did show that alcohols as a group would exceed a conservatively selected Effects Screening Level of 100 micrograms per cubic meter. Subsequent analysis to prorate the total alcohol concentration according to the quantity on hand of individual alcohols showed that none of the individual alcohols exceed their respective ESLs at the Plant boundary.

RC: 07.017

Doc: PC-025/45

Request extra public review time due to poor quality. I am concerned the input data to the modeling is questionable due to errors noted in tables above. What assurance does DOE provide to certify input data is accurate? What methods were used to qualify input data? What QA/QC documentation exists for input data? Specifically, what level of quality exists for estimated emissions rates?

Response:

Under regulations established by the Council on Environmental Quality, at least 45 days must be provided for public review of a Draft EIS (40 CFR 1506.10(c)). In response to stakeholder requests, DOE extended the public comment period for this EIS to 98 days.

The models used for air quality analysis are the Industrial Source Code Models (ISC-ST and ISC-LT) developed and approved by the Environmental Protection Agency. The input data for air quality modeling was obtained from two sources. Input data for meteorology and mixing heights were standardized data sets approved by the TNRCC. The input data for emissions inventory was developed by Pantex Plant for use by TNRCC. These data were developed by Pantex Plant under a DOE-approved, NQA-1 Quality Assurance Plan that meets requirements of DOE Order 5700.6c. The input data sets have been reviewed by TNRCC as well as by technical experts of Pantex Plant and DOE.

RC: 07.018

Doc: PC-025/46

General comment for section 4.7. Tables lack sources.

Response:

Sources have been added to tables in the Final EIS.

RC: 07.019

Doc: PC-025/47

Page 4-112. Please explain why the paper incinerator listed on page B-17, the wastewater treatment facility's SO2, and landfill activities PM10 are not included?

Response:

The paper incineration emissions (CO, NO2, and PM10) were included within weapons related activities. Wastewater facility and landfill activities are not considered significant sources of pollutant emissions; hence, are not included.

RC: 07.020

Doc: PC-025/93

Air does not assess methane releases from activities (oil, gas, and livestock industries) in the ROI. Air does not include SO2 releases in the ROI.

Response:

Only the criteria pollutants (SO2, CO, NO2, PM10, Ozone, and Lead) and some VOCs are regulated by EPA (Under the Clean Air Act) for Air Quality Control Region 211. Table 4.7.1.37 presents the SO2 releases in the ROI. Methane is not listed under the Clean Air Act, but is listed under TNRCCs list. Modeling results for Methane have been added to the Final EIS.

RC: 07.021

Doc: CO-008/137

Include a list of all air emissions onsite.

Response:

Volume I, section 4.7.1 (Table 4.7.1.33) has been expanded to include all chemical air emissions which are of potential significance in air quality analysis. The table shown in the Draft EIS omitted some of these emissions based upon modeling results which showed negligible emissions impacts. However, as a result of this and similar other comments, those chemicals are now shown in the tables.

RC: 07.022

Doc: CO-008/138

Have all available emissions been used in the model?

Response:

Yes, all emissions sources have been modeled.

RC: 07.023

Doc: PC-027/7

... Page 5-73, Air Quality. Albuquerque managed to get off the EPA air monitoring programif we hadn't gotten off we would have been in trouble. All winter long, Albuquerque citizens are not free to build fires in their fireplaces or woodstoves any time they want to, we get fined for burning on a "No Burn" day. We have many "No Burn" days. Our houses are checked to see if smoke is coming out of the chimney on No Burn" days. There is a telephone number to call to get a recorded message about whether we can burn a fire or not. We have to buy special gasoline for our cars in the winter time and we are nagged constantly about car pooling, etc., to cut air pollution, [encouraged] to have "no drive" times in order to improve air quality. The information you present about the air in this area is not complete because it doesn't reflect the constraints we have to work at in order to achieve acceptable air. The city, county, and citizens work hard to get to this point. You plan to drive 120 vehicles 365 days a year and 30 vehicles 255 days a year making 30- and 50-mile trips and say that your contribution to bad air would be negligible. I don't know -- we're really borderline on meeting the clean air specs and have to work hard to hold the line.

Response:

DOE acknowledges the efforts of Bernalillo County citizens and government to control air pollution. The effectiveness of that effort has resulted in a change in status from "nonattainment for CO" to "maintenance for attainment."

Volume I, Table 5.5.2.31 shows the comparison of the total pollutants (such as CO, NO2, VOC, SO2, and particulates) that will be emitted from the vehicles related to pit storage along with the respective total pollutants emitted in the Bernalillo County. These data show that the pollutants emitted from these additional vehicles would be negligible.

RC: 07.024

Doc: SG-003/44

The footnote on National Ambient Air Quality Standards (NAAQS) in Table 4.7.1.31 in Volume 1 is inaccurate. Both ozone and PM10 NAAQS are based on expected exceedances, meaning that non-sampling days must be accounted for when calculating attainment determination. The NAAQS is attained when the expected number of days per calendar year, averaged over a 3-year period, with maximum hourly average concentration for ozone and 24-hour average concentration for PM10 above the standard is equal to or less than one. SO2 annual, NO2 annual, and lead quarterly NAAQS are not to be exceeded. CO 1-hour and 8-hour and SO2 3-hour and 24-hour standards cannot be exceeded more than once per calendar year.

Response:

See response to comment 07.007.

RC: 07.025

Doc: SG-003/45

In the discussion of air monitoring results on page 4-93 in volume 1, it is stated that methylene chloride was found at 213 ppbv on July 6, 1993. There is no mention that this concentration was 7 times the effects screening level (ESL). Further review and analysis of the methylene chloride data by Toxicology and Risk Assessment staff concluded that this one-time episode would not result in any long-term health effects. Although there is detailed discussion of slightly above ESL concentration of 1,2-dibromoethane, this additional discussion on methylene chloride is left out.

Response:

See response to comment 07.007.

RC: 07.026

Doc: SG-003/46

TNRCC air monitoring at Pantex has found a number of exceedances of the PM10 NAAQS. Although modeling by TNRCC and the EIS staff did not predict possible PM10 violations, actual exceedances happened mainly due to blowing dust and localized earth moving activities. Precisely these kind of scenarios are anticipated in the Consolidation Alternative if additional construction activity takes place at Pantex. The EIS addresses this issue in section 4.7.6 on page 4-118 by stating that mitigation measures will be undertaken to alleviate temporary dust emissions from construction activities. These are standard TNRCC-approved mitigation measures for particulate emission control.

See discussion in section 1.3.6 of this volume for explanation of variance between PM10 monitoring data and modeling results.

RC: 07.027

Doc: SG-003/47

TNRCC Modeling staff reviewed Appendix B, Air Quality Analysis, of the Sitewide EIS and their comments are submitted separately. Additionally, the EIS used the same model, the Industrial Source Complex Model, that the TNRCC used for modeling Pantex emissions. EIS modeling was performed in accordance with the EPA guidance document, "Guidelines for Air Quality Models" (revised) and TNRCC guidance document, "Air Quality Modeling Guidelines." The modeling approach used by the EIS is different from the one used by TNRCC. However, both models arrived at the same conclusion.

Response:

See section 1.3.6 of this volume for a general discussion of the differences between the EIS and TNRCC modeling efforts.

RC: 07.028

Doc: SG-003/48

TNRCC used a tiered modeling approach that included a blend of screen and refined modeling techniques because of the large number of fugitive emission locations, buildings, and pollutants, whereas the EIS modeling used a refined dispersion model to accommodate the large number of emission sources and pollutants.

Response:

See section 1.3.6 of this volume for a general discussion of the differences between the EIS and TNRCC modeling efforts.

RC: 07.029

Doc: SG-003/49

In the TNRCC approach, the TNRCC modeling results were added to the results of the modeling conducted by Radian Corporation in support of a permit application. Radian modeling addressed predicted impacts of emissions from the burning ground and container storage area. Therefore, TNRCC used an additive modeling approach to account for emissions from some of the buildings to assess plant wide emission impact. Using this approach, TNRCC modeling concluded that no predicted exceedances of the criteria pollutant impact public health. The maximum concentrations of alcohols predicted at the property line was slightly above the ESL, but concentrations of alcohols predicted at the nearest residence was below the ESL.

Response:

See section 1.3.6 of this volume for a general discussion of the differences between the EIS and TNRCC modeling efforts.

RC: 07.030

Doc: SG-003/50

Using a different approach, EIS modeling also concluded that there would be no exceedance of the NAAQS for criteria pollutants and that the only hazardous air pollutant that exceeded its ESL was alcohols. Again, predicted maximum concentrations of alcohols for 11 residences located near Pantex were below ESL.

Response:

See section 1.3.6 of this volume for a general discussion of the differences between the EIS and TNRCC modeling efforts.

RC: 07.031

Doc: SG-003/51

The nonradiological air quality impacts due to the No Action Alternative and the Consolidation Alternative will be minimal, especially if mitigation measures are taken to control particulate emissions due to increased vehicular traffic and construction activity.

Response:

Your observation is correct.

RC: 07.032

Doc: SG-003/52

Data reviewed were contained in Tables B.3.6-1 through B.3.6-9 and Tables B.4.1-1 through B.4.2-3 of the EIS. Please note that no modeling input and output files were available to assist in our review. Therefore, a comparison was made of the emission rates and results presented in the EIS to the emission rates and results reported in the TNRCC's Modeling Analysis of the Pantex Plant Amarillo, Texas, dated June 1995.

Response:

While the complete modeling input and output files are too voluminous to include in the EIS, the emissions rates are the key ingredient since the modeling equations and the meterology and mixing height data are identical to those used by TNRCC. As described in the response to comment 07.009, the emissions inventory displayed in the Final EIS has been expanded to include all pollutants emitted by Pantex Plant.

RC: 07.033

Doc: SG-003/53

Some of the sources modeled by the TNRCC were not listed in Table B.3.6-1 of the EIS, so we assumed they were not modeled. However, in the TNRCC analysis the predicted concentrations for the pollutants emitted from the omitted sources, plus all other applicable sources, were less than the respective National Ambient Air Quality Standard (NAAQS). Following is a list of pollutants and omitted sources: CO emissions from EPNs 54, 85, and 160; NO2 emissions from EPNs 85, 157 and 160; and PM10 emissions from EPNs 157 and 160.

Response:

The cited sources are no longer active at Pantex Plant and were not included in the modeling. See response to comment 07.008, and for a general discussion of the differences between the two modeling efforts, see section 1.3.6 of this volume.

RC: 07.034

Doc: SG-003/54

All predicted concentrations in the EIS were less than those reported by the TNRCC except for alcohols, hydrogen chloride, methylene chloride, and PM10. Except for alcohols, the concentrations for all pollutants were below the respective Effects Screening Level (ESL) or NAAQS. The predicted concentration for alcohols was only slightly higher than the TNRCC-predicted value and less than twice the ESL.

Response:

See section 1.3.6 of this volume for a discussion of differences in the modeling efforts.

RC: 07.035

Doc: SG-003/55

The EIS Tables B.4.2-l and B.4.2-2 do not include all the pollutants reviewed by the TNRCC. Therefore, we assumed that the EIS did not include an evaluation for them. However, the TNRCC reported in its analysis that no concentrations for these pollutants were predicted to exceed an ESL or state standard. The omitted pollutants follow: 1,3,5-Trinitrobenzenel-Butanol, 2,4,6-Trinitrotoluene, 2,4-Dinitrotoluene, 2,6-Dinitrotoluene, 2-Nitronaphthalene, 2-Ethoxyethanol, Acetone, Acetylene, Aluminum, Ammonia, Barium, Benz(a), anthraceneBenz(a), pyrene, Bismuth, Butadiene, Butane, Butene, Calcium, Chlorinated Fluorocarbon, Copper, Cyanogen, Cyclohexane, Cyclohexanone, Dimethylformamide, Dioxane, Ethane, Ethyl Acetate, Ethyl Ether, Ethylene, Formic Acid, Iron, Isobutane, Isobutanol, Ketene, Lithium, Magnesium, Methane, Methane, dichloroN-Butyl, Alcohol, Non-F Solvents, Ortho-dichlorobenzene, Propane, Propene, Pyrene, Pyridine, Silicon, Tetrahydrofuran, Titanium, Total Suspended Particulate, Trichlorofluoromethane, Trichlorotrifluoroethane.

Response:

The maximum fenceline concentrations of the pollutants, both those listed in the Clean Air Act and those listed by TNRCC (as stated above in the comment) were modeled and compared to appropriate TNRCC ESLs. However, only the results for those chemicals that are listed under the Clean Air Act, as amended (Nov 1990), and alcohols, as a group, which exceeded its ESLs were reported in the Draft EIS. All of the maximum fenceline concentrations for all of the chemicals emitted by Pantex Plant, including those listed by TNRCC and used in its modeling, have been included in volume I, section 4.7 and volume II, appendix B of the Final EIS.

RC: 07.036

Doc: SG-003/56

On Page 4-93, Paragraph 2, 2nd Sentence: "AQCR 211 is designated by EPA as "better than national standards" for total suspended particulates..." To our knowledge there is no national standard for total suspended particulates. EPA replaced the Total Suspended Particulate standard with the particulate matter standard during the late 1980's.

Response:

Commentor is correct. The text in volume I, section 4.7.1 has been revised.

RC: 07.037

Doc: SG-003/57

On page 4-95, paragraph 5, 2nd sentence, there is a typographical error: "TRNCC" should be changed to "TNRCC".

Response:

Correction has been made.

RC: 07.038

Doc: SG-003/58

Page 4-95, Air Quality Modeling, corresponding tables. It is not clear in the narrative whether the air dispersion modeling referenced was conducted as part of the Agreement in Principle or as part of the permit application submitted by the DOE.

Response:

Modeling was performed to fulfill the NEPA requirement to present impacts for current operations as well as predict those associated with the future operations being evaluated in the EIS. The monitoring data were not comprehensive enough to create a baseline or to estimate the potential impacts of future operations to the surrounding population.

RC: 07.039

Doc: SG-003/59

Page 4-97, Table 4.7.1.3-4. The following ESLs need to be corrected: Ethene, Trichloro:135 ug/m3 for the annual ESL1350 ug/m3 for the 30-minute ESL.

Response:

Table 4.7.1.3-4 in volume I of the Draft EIS has been expanded and appears as Table 4.7.1.3-5 in the Final EIS. The chemical "Ethene, trichloro-" in the Draft EIS appears as "Trichloroethylene" in the Final EIS. We have inserted the annual and 30-minute ESLs as requested.

RC: 07.040

Doc: SG-003/60

Page 4-98, Table 4.7.1.3-4. The following ESLs need to be corrected: Methanol:262 ug/m3 for the annual ESL2620 ug/m3 for the 30-minute ESL.

Response:

Methanol is listed in the TNRCCs ESL list as Methyl Alcohol, which has the same ESLs as mentioned above. The ESL for Methonol has been added as mentioned in the comment.

RC: 07.041

Doc: SG-003/61

Page 4-99, Table 4.7.1.3-4. The format of the ESL should be converted to be consistent with the other ESLs represented in the table (e.g., 135 ug/m3 should be 1.35 x 10E2).

Response:

Changes have been made as requested for consistency.

RC: 07.042

Doc: CO-008/136

Are TNRCC air monitoring results included [in] the air quality calculations? If so, please cite.

Response:

Air monitoring results of TNRCC are described in volume I, section 4.7.1.

3.8 Acoustics (Noise)

RC: 08.001

DOC: PC-023/4

The EIS reported that risks to the public from acoustics and natural seismic activity are low. However, the report does not address structural damage to homes and buildings on and offsite of the plant that have occurred due to explosions. One home offsite of the plant suffered significant damage to its foundation, walls, roof supports, and plumbing as a direct result of a planned explosion at Pantex Plant. The "shock" energy from the explosion which caused the damage is similar to energy associated with acoustics and seismic activity.

Response:

Volume I, section 4.8.1.3, describes the noise from high explosives detonation. During 1994, Pantex Plant detonated 60 charges of HE. The maximum charge exploded was 55 pounds. Noises from HE detonations were modeled by using the model BLASTO. The results are summarized in volume I, section 4.8.1, Table 4.8.1.31. Almost any wind speed from the south quadrants could be expected to give at least 140 dB overpressure from a 55-pound HE burst at Firing Site-4. The nearest residences, 1 and 2, which are both just north of the site boundary, can feel discomfort due to the noise created by this detonation. Window damage would rarely occur, but there could be interior plaster cracking depending on its age. Objects might occasionally be rattled from shelves, but damage to the foundation, roof supports, and plumbing will not occur due to this kind of explosion (55 pound HE detonation).

RC: 08.002

DOC: PC-017/6

Last October 4, 1995, a very large explosive charge was set off for an emergency management drill. Our home received major damages. We would have been better off to have torn our home down and rebuilt from the ground up. We were originally told that the charge was 110 pounds of explosive. Later, plant officials have said only 80 pounds of explosive was used. This was set off about one-half mile southwest of our home. We are now learning of other neighbors who have damages that possibly resulted from that explosion. Throughout the many years of living next to Pantex, the testing of high explosives probably caused damages to our homes resulting in cracking, breakage, etc. The regular shaking and jarring could not possibly do our homes and property any good.

Response:

In October 1995, a charge greater than 55 pounds of HE was detonated. Pantex Plant does not plan to explode charges larger than 55 pounds of HE in the future. Should a larger charge be exploded in the future, the plant would perform appropriate NEPA review for that charge.

RC: 08.003

DOC: PC-025/48

Page 4-125, what are the impacts to animals especially birds as a result of these detonations? [Aren't] detonations generally used by construction industry to chase off nesting birds?

Response:

Detonations have been shown to disperse animals from a given area. However, these dispersals and the impacts are usually considered temporary in nature. Many devices (including detonation) have been used with various degrees of success for bird control by some firms and agencies. See section 4.9, Biotic Resources, for a discussion of animals at the Pantex Plant.

RC: 08.004

DOC: PC-033/2

... On page 4-122 the map shows a noise measurement location marked "B" that is fairly close to the target range. The table on page 4126...lists these locations as having been tested on 9-9,15, and16, respectively. Could you please tell me if these were the times when qualifying was taking place at the target range, or were these just normal practice days? If the qualifying was taking place I would like to see earlier and later times of day for the readings. It seems very loud at my house when they are qualifying and they generally start very early in the morning, approximately 5-6 a.m. and sometimes are firing late at night, approximately 10 p.m. Could you please let me know also where that measurement location "B" is for certain? If it is close to my house, where it is located and what it looks like?

Response:

Volume I, section 4.8.1, Table 4.8.1.11 and Figure 4.8.11, show that noise measurements were made at location "B" (close to the target range). These measurements included the peak sound level from the vicinity of the target range. These measurements were made at 1:07 p.m. (9/9/94) and 8:40 a.m. (9/15/94). No noise measurements were performed on 9/16/94. The peak value of sound was 47 dB at 4,000 Hz. The locations A and E are also close to the target range (volume I, section 4.8.1, Figure 4.8.11). Sound measurements were made at location A, on 9/9/94, at 9:45 a.m., 10:05 a.m., and 1:40 p.m. The Leq measurements were 42, 48, and 43 dB respectively. Sound measurements were also made at location E, on 9/15/94, at 9:45 a.m. and 10:00 a.m. The Leq measurement at location E was 43 dB and the peak value of sound was 42 dB at 4000 Hz. The measurements were made with portable instruments. The measurements were made close to residences L4 and L5.

3.9 Biotic Resources

RC: 09.001

Doc: CO-008/19

Page 4-135, Paragraph 3: "Radiological surveys of beef cattle raised..." Please clarify this statement and provide the citation. What type of studies were done, when were they conducted, and by whom?

Response:

Radiochemical studies were conducted comparing cattle grazed on Pantex Plant Site with control cattle grazed at the Bushland Experiment Station west of Amarillo. The beef cattle food chain pathway was investigated by analyzing soil, native vegetation, grain, and cattle tissue samples. The study determined that meat (from cattle) grown on or near Pantex Plant did not represent a radiological hazard to the public because levels of these radionuclides were far below accepted guidelines.

The study was conducted in 1981 at three locations: a pasture 1-mile west of the Burning Ground at Pantex, the Texas Tech feedlot in the southwestern part of the Pantex Plant Site, and the Texas A&M Experiment Station at Bushland (west of Amarillo).

The study involved 11 scientists including L.C. Hollis (a veterinarian from the Texas A&M Veterinary Diagnostic Lab in Amarillo), J. M. Horton (Director of the Killgore Beef Cattle Center in Panhandle, Texas), and nine staff scientists from Los Alamos National Laboratory.

The statement in volume I, section 4.9.1.1, was based on a report entitled Supplemental Documentation for an Environmental Impact Statement Regarding the Pantex Plant, Agricultural Food Chain Radiological Assessment (LLNL 1982). This report, published in December 1982, was prepared in support of the 1983 Pantex EIS. Section 4.9.1.1 has been revised to reference this study and the following text has been added to this section in this EIS, "The study indicated that if beef consumption of 79 kg/yr is assumed then the 50-yr dose commitment to an adult from ingestion of ground beef at 1.6 x 10-4 pCi/g weight would be 0.2 mrem to bone, 0.01 mrem to kidneys, and 0.01 mrem to liver. These values are 500 times below the radiation dose each year from natural background."

RC: 09.002

Doc: CO-008/20

Page 4-139, Paragraph 1: Please clarify whether the type of "stock tank" is an earthen structure on one of the drainage-ways to the playa or is a galvanized or metal structure.

Response:

This stock tank is an earthen pit, approximately 5 to 6 feet deep.

RC: 09.003

Doc: CO-008/21

Page 4-139, Paragraph 2: "There are five playa Wetlands in the vicinity of Pantex Plant Site..." Do you mean 5 playas designated as wetlands? There are many more than 5 playas in the vicinity of Pantex.

Response:

Your interpretation is correct. The text in volume I, section 4.9.1.3, has been modified to read "There are six playas on DOE owned or leased land in the vicinity of the Pantex Plant Site. Playas 1, 2, and 3 on the main plant; Playas 4 and 5 on land leased from Texas Tech University; and Pantex Lake". The statement in the Draft EIS was based on the Wetlands Delineation study by Herrera Environmental Consultants published in 1995 (MH 1995) which delineated Playas 1-4 and Pantex Lake in accordance with guidelines in the Army Corps of Engineers Wetlands Delineation Handbook (USCOE 1987). Playa 5 has not been delineated.

RC: 09.004

Doc: CO-008/22

Page 4-140, Paragraph 2: Please correct typo "P. amphibum."

Response:

P. amphibum now reads P. amphibium.

RC: 09.005

Doc: CO-008/23

Page 4-142, Paragraph 1: How do you explain the significant decline from the 1993 to the 1995 floristic survey in the Echniocereus viridiflorus population?

Response:

Dr. Marshall Johnson (who conducted these floristic surveys) noted a decline in all age classes of this cactus, from 200 in June 1993 to 50 in July 1995 and then an increase to approximately 75 in September 1995. He stated that the cause of the decline was unknown but said one could speculate that "(1) a high mortality rate prevails among the seedlings; (2) the greater luxuriance of the growth of HPG grass and forbs obscured the presence of the smaller plants as compared to their possibly higher level of visibility in June; or (3) a combination of (1) and (2) above."

RC: 09.006

Doc: CO-008/24

Page 4-142, Paragraph 2: In the statement, "wetland resources would benefit from continued operations since officials are taking steps to...," what specific steps have been agreed upon?

Response:

A 29 May 1996 response from the U.S. Fish and Wildlife Service (FWS) stated the FWS "fully support Pantexs proposed plans to manage portions of plant property for the benefit of native resident and migratory wildlife species, including the proposed playa basin management plans. As described in the biological assessment, the Pantex Plant and surrounding area currently contains and supports significant wildlife resources, but with proposed management, the area has the potential to support an even higher diversity and number of native plant and animal species, to the mutual benefit of both humans and wildlife." Appendix E of the 1996 Biological Assessment for the Pantex Plant (DOE 1996d) includes the following management plans alluded to in the 29 May 1996 FWS letter that are being used to protect wetlands at Pantex Plant:

· Interim Guidance Document for Pantex Plant Playas.

· Management Plan for Playa 2 Management Unit: Phase One.

· Natural Resource Management Plan for Pantex Plant, Amarillo, Texas.

· Management Plan for Revegetation of Playa Buffer Areas and Formerly Cultivated Areas.

· Update for FY94, Groundwater Protection Management Program Plan, Pantex Plant.

· Land-Applied Chemical Use Plan for the Pantex Plant.

RC: 09.007

Doc: CO-008/25

Page 4-142, Paragraph 5: Please correct typo, last sentence. "...but these impacts would not (insert "be") considered significant."

Response:

Suggested change has been made in the FEIS.

RC: 09.008

Doc: CO-008/26

Page 4-143, Paragraph 4: In the statement, "Environmental protection activities currently ongoing at the plant meet all regulatory requirements of FWS," please cite the letter from FWS.

Response:

Environmental protection measures currently ongoing at Pantex Plant support sections 2(b) and 7(a) of the Endangered Species Act (ESA) which requires protection of threatened and endangered species. A biological assessment submitted by Pantex Plant officials on 9 May 1996 fulfilled section 7 ESA requirements for Federal agencies to consult with the U.S. Fish and Wildlife Service (FWS). A 29 May 1996 response from the FWS commended "Pantex for developing a comprehensive and complete BA (biological assessment), and concur with your assessment that the proposed action is not likely to adversely affect any Federally listed threatened or endangered species." This letter is included in volume II, appendix J.

RC: 09.009

Doc: SG-009/1

While we recognize Pantex efforts to discover the amount and extent of the historical contamination and Pantex current contaminant reduction in progress, we are concerned about impacts to wildlife from historic contamination listed in the report. Due to the unknown extent of the historical contamination, TPWD requests Pantex continue to describe the extent of contamination and encourages efforts to clean up or rectify the contaminant impacts. Consider incorporating a timeline showing past efforts and future efforts in contaminant identification and cleanup. If available, please send Joan Glass of our staff copies of completed reports describing potential wildlife impacts.

Response:

The status of the contamination clean up effort is discussed in volume I, section 4.5.1.3 (Soil and Sediment Quality), with additional information provided in chapter 15 (Environmental Restoration) of the Environmental Information Document (EID) (Pantex 1996). A number of wildlife studies have been conducted at the Pantex Plant to identify resident and migratory species, in particular reptiles, birds, and mammals. Faunal studies summarized in volume I, section 4.9 (Biotic Resources), and chapter 7 (Ecology) and chapter 16 (Radiation and Hazardous Chemical Environment) of the EID, do not indicate significant contamination impacts to wildlife from Pantex operations. A time line has been added to volume I, section 4.5.1.3 summarizing previous and future clean-up activities. A copy of the Pantex Biological Assessment (DOE 1996d) is being sent to Ms. Joan Glass.

RC: 09.010

Doc: SG-009/2

TPWD is also concerned about the unidentified minnow species from Pantex Lake. Because there are 6 Federally listed Notropis with 2 additional State listed Notropis species, the minnow species should be identified by a competent scientist. You may request assistance in identification of the minnow by contacting the TPWD Freshwater Studies Program aquatic biologist, Kevin Mayes at (512)7546844. Upon contacting Mr. Mayes for identification, a minimum of 5 specimens can be send to him at 300 C.M. Allen Parkway, Bldg. B, San Marcos, TX 78666.

Response:

Pantex Plant personnel re-sampled the stock tank near Pantex Lake. No specimens of Notropis were found, but a number of fathead minnows (Pimephales promelus) and one black bullhead (Ictalurus melas) were collected. It is unknown whether the identification referenced on page 4139 of the Draft Pantex EIS was a misidentification, but that possibility is being investigated.

RC: 09.011

Doc: PC-034/11

Comment (and background information):

In Volume I, 4.2 "Impact Assessment Methodologies" (p. 4-4), under "Biotic Resources," it is stated that "Impacts to wetlands are mostly related to the potential discharge of contaminants to the playas."

Question:

How can impacts to wetlands be related to potential discharges of contaminants? Only actual discharges can have impacts!

Response:

The sentence has been revised to read "Impacts resulting from wastewater discharge into a wetland system are evaluated, recognizing the effluents would be required to meet Federal and state standards."

RC: 09.012

Doc: PC-025/49

Table 4.8.1.31, what is the impact to a human without ear protection over a 1/4 mile range? A lifetime for residents?

Response:

Airblast noise resulting from detonation of HE is impulsive in nature and generally less than a second in duration. Personal exposure to 140 dB (from 55 lb of HE) would not be anticipated to cause hearing damage from single impulse events. OSHA provides guidelines to ensure worker protection in elevated noise environments. Workers are not anticipated to have hearing impairment at a distance of 1/4 mile from Pantex activities. The modeling results provided in volume I, section 4.8.1, Table 4.8.1.31, were derived from data collected by Pantex personnel.

The OSHA 8-hour time weighted threshold limit value for a 140 dB exposure is 28 seconds. In 1994, 60 detonations of high explosives occurred from charges weighing 5 to 47 pounds. Due to the limited number of high explosive detonations done each year and the short duration of each (i.e., less than 1 second), lifetime residents are not anticipated to be adversely affected by high explosive detonations as currently conducted. As noted in volume I, section 4.8.1.3, additional NEPA review would be conducted if charges in excess of 55 pounds are detonated.

RC: 09.013

Doc: PC-025/50

Section 4.9. Given the semi-arid climate, what impacts have occurred as a result of fires in the recent past? If fires have occurred in the past why isn't it included in the affected environment? Does Pantex use controlled burns to control vegetation? What is the impact? Does the plant dredge the playa systems? What is the impact? Is there a need to dredge in the near future?

Response:

The commentor asked seven questions which are answered in order. Wildfires have occurred in the Pantex Plant vicinity in the past. Property owned or controlled by DOE has been burned by uncontrolled wildfires. There is no mechanism to assess the impacts of past burns. Controlled burning is not used for vegetation control on DOE-owned land. Playas on DOE-owned land are not routinely dredged. Playa 1 was deepened to increase water storage capacity before it was designated or delineated as a jurisdictional water of the U.S. (wetland).

RC: 09.014

Doc: PC-025/51

Page 4139. There appear to be more than five playa lakes in the vicinity of Pantex Plant (see page 4-56 of this EIS). Pratt Lake, Pantex Lake, and several to the north and south of the site, please comment. Page 4142. Pit Storage Activities. Please describe non-adverse impacts to biotic resources.

Response:

Only playas at the Pantex Plant Site and Pantex Lake were investigated under biotic resources. See response to comment 09.003. Pratt Lake is discussed in section 4.6 (Water Resources) and included in volume I, Figure 4.6.1.11 (Primary Outfalls and Floodplains at Pantex Plant Site). Also see response to comment 06.058.

RC: 09.015

Doc: PC-025/52

Page 4-142. ER activities. "...would not considered significant."?

Response:

The sentence has been revised to insert "be" between "not" and "considered."

RC: 09.016

Doc: PC-025/53

Page 4-142. Waste Management: "... will have a long-term beneficial impact on plant and animal species?" Landfills and an open burning activity that fumes metals and radioactivity are considered beneficial? Please provide documentation supporting statement. Any direct impacts to non-threatened, non-endangered species or non-wetlands? Please provide documentation supporting position.

Response:

Volume I, section 4.13 (Waste Management) summarizes waste management activities to collect and dispose of hazardous, nonhazardous, radioactive, low-level radioactive mixed hazardous wastes in accordance with the Pantex Plants Resource Conservation and Recovery Act (RCRA) Part B Permit. Volume I (Air Resources), section 4.7, summarizes air emissions at the Burning Ground. Data on the onsite construction debris landfill and burning ground emissions indicate that they are being conducted in accordance with RCRA and Clean Air Act guidance. One of the intents of RCRA waste management regulations is to minimize adverse impacts to plants and animals. Recognizing that waste cannot be simply ignored, the implementation of regulated forms of treatment and disposal is more advantageous than the practices prevalent throughout American industry prior to the 1970s.

RC: 09.017

Doc: PC-025/94

Biotic Resources [section] does not analyze the number of playas within the ROI.

Response:

See responses to comments 09.003 and 09.014. Volume I, section 4.2 has been revised to indicate that the ROI for biotic resources was restricted to investigation of flora and fauna at the Pantex Plant Site and the nearby Pantex Lake, which is also owned by DOE. Also see response to comment 06.058.

RC: 09.018

Doc: SG-003/7

This comment is a duplicate of comment 09.011.

RC: 09.019

Doc: SG-003/27

Page 4-4, Biotic Resources: The text states that U.S. Fish and Wildlife Service and appropriate State agencies have been used in the process of determining whether Pantex Plant operations would impact any plant or animal. This is incorrectly stated. The Trustees understand that an ecological screen has not yet been completed for this site and an ecological risk assessment has not been performed. The text should be corrected to reflect what has actually been assessed at this site and which agencies were involved.

Response:

A Biological Assessment (BA) of the Pantex Plant was submitted to the U.S. Fish and Wildlife Service (FWS) by the Amarillo Area Office on May 9, 1996 in accordance with section 7 interagency consultation requirements of the Endangered Species Act (ESA). See response to comment 09.006 regarding the favorable FWS reply. The BA was prepared in accordance with ESA guidance and may not meet the requirements for a Natural Resources Damage Assessment required under Section 107 of the Comprehensive Environmental Response Compensation and Liability Act. However, Pantex officials have had meetings with attendance by EPA, TNRCC (representing the Texas Parks and Wildlife Office), and the Texas General Land Office. This additional information has been incorporated into volume I, section 4.2 (Biotic Resources subsection) and chapter 6 (Environmental Compliance Requirements for Implementing the Proposed Action and the Alternatives).

RC: 09.020

Doc: PC-028/8

The Biotic Resources (para 5.5.1.7) and cultural resources (para 5.5.1.8) will be in [a] higher risk category. The higher risk not only includes possible contamination, but even more probable, the damage caused by increase of related activities like facility preparation, transportation to and from, and even from the additional 150+ humans to be placed on or about the Manzano WSA full time. Select another site, not KAFB.

Response:

The analysis of both biotic (volume I, section 5.5.1.7) and cultural resources (volume I, section 5.5.1.8) leads to the conclusion that no impacts to these resources are to be expected by the relocation alternative. However, the decision to relocate or not would be made after consideration of environmental, cost, and other technical factors.

3.10 Cultural Resources

RC: 10.001

Doc: CO-008/27

Why were the agricultural based lifestyle and the community of Panhandle, as a cultural impact, not evaluated? Most people in the region are only one generation removed from the farm or their grandparents were farmers. Also, the supportive business and families are involved in this culture. The culture in general, and the resources associated with it, were not mentioned.

Response:

Volume I, section 4.10 addresses the prehistoric and historic resources within the boundaries of Pantex Plant. Twelve historic agricultural sites have been recorded within the plants boundaries.

The community of Panhandle is located approximately 16 kilometers (10 miles) east of Pantex Plant, and is thus outside of the area addressed by section 4.10. A discussion of impacts to the agriculturally based lifestyle of this community is out of scope for this section. An ethnographic discussion of agricultural lifestyles and resources as a "culture" are likewise considered to be out of scope in this section of the EIS. Agricultural resources within the plant boundaries and the ROI are discussed in volume I, sections 4.4, Land Resources; 4.5, Geology and Soils; 4.6, Water Resources; and 4.11, Socioeconomic Resources.

RC: 10.002

Doc: HT13/37

... Is it your position that [this EIS] adequately analyzes archeological sites for historic preservation purposes [at the Manzano Weapons Storage Area]?

Response:

To elaborate on the response given at the public hearing, the comment is concerned with cultural resources at the Manzano Weapons Storage Area (WSA) on Kirtland Air Force Base (KAFB). The KAFB Environmental Management Division has coordinated historic preservation efforts, including all cultural resource surveys and findings within the Manzano WSA as well as the base. Twenty-seven archaeological sites have been located within the WSA by a 100% ground survey conducted by Argonne National Laboratories. As discussed in volume I, section 5.5.1.8, 22 of these sites have been recommended for inclusion or eligibility to the National Register of Historic Places.

RC: 10.003

Doc: PC-034/14

Comment (and background information):

In volume I, ¤4.10.1.2 "Native American Groups" (p. 4-150), it is stated that "An inventory of traditional Native American sites identifying features such as petroglyphs, ceremonial areas, or sacred sites has not been conducted nor have any such sites been identified at Pantex Plant (DOE 1995K:4-280)." This statement is incorrect! Numerous archaeological surveys have been conducted on both DOE-owned and DOE-leased land for the purpose of identifying and recording of all Native American sites including any petroglyphs, ceremonial, or sacred sites. That part of the sentence that states no such traditional sites have been identified is correct. It is worthy of note that the stated reference is incorrect both qualitatively and quantitatively! Page 4-280 of the given reference discusses Oak Ridge National Laboratory; however, when one turns to page 4-300 of that reference one finds: "Native American resources associated with these groups have not yet been identified at Pantex, but the remains of temporary campsites, hunting locations, ceremonial locations, or isolated burials are possible."

Question: How can these words be used as a reference for the statement in the Pantex SWEIS? And why doesn't DOE know that these surveys have been conducted?

Response:

The discussion of Traditional Cultural Properties (TCPs) is misleading as presented in the draft document and has been clarified. The identification of TCPs, as differentiated from archaeological or historical features, has been conducted through consultation with the 10 tribes with recognized potential ties to the area. There have been numerous cultural resource (archaeological and historical) surveys conducted at Pantex Plant that are discussed in volume I, section 4.10, and these surveys have no doubt identified features that could be TCPs. TCPs are identified through specific studies conducted to address properties or areas that are important in a communitys historically rooted beliefs, customs, and practices. Studies of this type would typically entail a detailed ethnographic study involving consultation with Native American Groups with traditional or ancestral ties to the area which is now Pantex Plant, and possibly field inspections with these individuals prior to, or associated with, any survey project. This consultation is important as many TCPs may not be discernible as such to anyone but a knowledgeable member of the group that ascribes significance to them.

The reference to page 4-280 is a typographical error. Page 4-280 was the location of the referenced section in the draft document. The correct page number is indeed 4-300 in the Final Programmatic Environmental Impact Statement for Tritium Supply and Recycling (DOE 1995k). This has been corrected in the final version of the Pantex EIS.

The words used as a reference in the Pantex EIS are accurate, and represent the status of known resources belonging to historic Native American groups that occupied or utilized the Pantex region. There is a possibility that campsites, hunting areas, ceremonial sites and isolated burials may be discovered within the land that comprises the Pantex Plant. It is also possible that native plants with traditional medicinal or spiritual uses, landmarks important in religion, myth or visions, or areas of supernatural connotations that are kept secret until they are threatened, could be located within this area of land on the Texas panhandle. Cultural resource management involves much more than the survey and excavation work that DOE has conducted at the plant. It is an on-going management tool that traces and protects history and prehistory, as well as protecting the concerns of current Native American peoples.

RC: 10.004

Doc: HT17/33

I am a member of the Cheyenne-Arapaho Tribes of Oklahoma, which is a Federally recognized tribe. I did receive a letter dated September 15th, 1994 in regard to a summary notification of Native Americans. They mentioned several tribes on there, and in going through this letter I noticed that the Northern Cheyenne was not on here; neither was the Northern Arapaho Tribe. I would ask that they be included in this Environmental Impact Statement.

Response:

The Northern Cheyenne and the Northern Arapaho Tribes have been included in chapter 9, the List of Agencies, Organizations, and Individuals to whom copies of the EIS are sent.

RC: 10.005

Doc: HT17/34

There's a lot of concerns as far as being a member of the Plains Indians Tribes. ...We have a lot of historical and traditional cultural properties related to this area, all the way down from...the northern Dakotas down to the Palo Duro Canyon. So, we do have some sites that are significant to us,...and I am concerned about this. ...I would ask that you continue to address this on a government-to-government type basis and consult with the Federally-recognized tribes

Response:

Cultural resources addressed in the Pantex Plant EIS only address known or suspected areas or features within the boundaries of the plant. These are discussed in volume I, section 4.10 of the document. Areas of traditional cultural properties (TCPs) have not been identified by past inventories or research within the plant boundaries; however, TCPs of importance to varying Native American Groups are located throughout the plains. DOE respects and protects the TCPs when they are identified, and will continue to consult on these issues with Native American tribes, governments, and groups.

RC: 10.006

Doc: HT17/35

...there are other tribes out there that are not Federally recognized who you might consider consulting with as well.

Response:

Consultations are made between the DOE and Federally recognized Native American Tribes, governments and groups, as well as Pan-Tribal groups such as the Owens Valley Board of Trustees.

RC: 10.007

Doc: HT17/36

There's a lot of other concerns that I have, especially with the vegetation within the area. I also have some concerns with the potential adverse [effects from] inadvertent discoveries of artifacts or human remains that may be there.

Response:

As discussed in volume I, section 4.10.2, any discovery of subsurface cultural features or artifacts identified during land disturbance activities will be appropriately mitigated after consultation with the State Historic Preservation Office (SHPO). Typically, in discovery situations, ground disturbing work is halted until a decision can be made between the consulting officials as to avoidance, collection, testing, or excavation. If human remains are located the requirements of the Native American Graves Protection and Repatriation Act (NAGPRA) are followed; work is halted and the Pantex Cultural Resource Media Manager, the Texas SHPO, and concerned Native American Tribal groups and governments are immediately notified. Construction activities are not resumed until the remains are removed by a tribal member, archaeologist or coroner. It may also be decided to leave the remains in place, reroute the construction, and avoid further disturbance to the site. These decisions are made on a case-by-case basis.

There have been no vegetated areas or specific plants identified to-date within the boundaries of the Pantex Plant that have been identified as traditional cultural properties. Traditional use of specific plants for religious or medicinal purposes as well as harvesting areas may be identified as areas of future concern, but these have not been identified.

RC: 10.008

Doc: HT17/37

I am the designated NAGPRA representative for the Cheyenne Tribe. I don't know if any of you are familiar with the Native American Graves Protection and Repatriation Act of 1990. And that was one of my other concerns, that I noticed that it was cited inside this study, but it wasn't really in detail.

Response:

DOE is knowledgeable of the Native American Graves Protection and Repatriation Act (NAGPRA) and will abide by its direction if mortuary remains or related cultural items are located within Pantex Plant. The rights of lineal descendants and members of Indian Tribes to Native American human remains and funerary objects with which they are affiliated will be instituted when and if these remains are located. Consultation with the appropriate State, Federal and Tribal representatives will be instituted and if requested, reburial or a transfer of ownership of the items will be instituted. NAGPRA is mentioned in volume I, section 4.10, but is not discussed in detail as no human remains have been located on Pantex Plant Site.

RC: 10.009

Doc: HT17/38

And I did note...in this letter that there [were] scheduled visits to the tribes, and I would just like to ask if those visits have occurred, and if they have occurred, I would like to request copies of the comments that were received from those tribes.

Response:

The Pantex Plant Cultural Resource Manager visited the 8 Native American tribes listed in volume I, section 4.10.1.2 on June 22, 23, and 24, 1994. The tribes did not submit comments regarding these visits.

RC: 10.010

Doc: PC-027/6

Reference historic and prehistoric resources in the Summary (Page S-24) and in the volume I - Main Report page 5-59, item 5.5.1.8: "Twenty-seven historic and prehistoric archaeological sites have been found in the Manzano WSA. Of these sites, 8 have been recommended for inclusion in the National Register of Historic Places and 14 others are considered to be potentially eligible for inclusion." Noted that you said there would be no impact to cultural and paleontological resources, but they may be so locked up because of security requirements that nobody will be able to see them. I would think that inclusion in the National Register of Historic Places might involve the possibility of a visit or a look at the site. Will that be possible if strengent security requirements are in effect?

Response:

The Manzano WSA is a secured area. Sandia National Laboratories provides security to the facility and it is not available for public access without approval. This policy would continue whether Manzano WSA is chosen for interim pit storage or not.

RC: 10.011

Doc: PC-028/5

Page 5-58, para 5.5.1.8Comment: By placing the Pit storage area within Manzano WSA, the increased security will certainly reduce, even prohibit scientific and public access to the 27 historic sites. Consider the other alternative sites which do not present this type of problem.

Response:

At present, the Manzano WSA is a secured access area. Scientific and public access to the area must be obtained from the U.S. Air Force. If this area is chosen for pit storage, access to the 27 historic sites is not expected to change. The Secretary of Energy will consider the environmental impacts of each alternative along with mission requirements, technical factors, and public interest before issuing the Record of Decision.

RC: 10.012

Doc: PC-028/9

The Biotic Resources (5.5.1.7) and cultural resources (5.5.1.8) will be in higher risk category. The higher risk not only includes possible contamination, but even more probable, the damage caused by increase of related activities like facility preparation, transportation to and from, and even from the additional 150+ humans to be placed on or about the Manzano WSA full time.

Response:

RC: 10.013

Doc: PC-033/7

I request a copy of the transcripts or notes taken from meetings with any of the affected tribes mentioned in the Draft SWEIS. Gordon Yellowman commented at the recent hearing on June 25, 1996 and asked for a copy of the meeting notes. Nan Founds replied stating that they did not visit the individual tribes, but sent them a letter. She will send him a copy of the letter and comments received. I am requesting copies of this [letter] and the comments received.

Response:

Comment noted. Refer to response to 10.009.

3.11 Socioeconomic Resources

RC: 11.001

Doc: HT03/1

Yes, there is one confusion factor, looking at all three PEISs, and that is they use different multiplications for the number of direct jobs versus the impact in the community.

Response:

To elaborate on the response given at the public hearing, a number of comments relate to the economic multipliers used in the Pantex EIS, SSM PEIS, and S&D PEIS. (Refer to Comment 11.016 which has been repeated by various commentors.) A general explanation of the multipliers is provided below to avoid duplication of responses to all such comments. Further details are provided in response to specific comments later in this section.

All three documents referenced by the commentor 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 model is used by government agencies, university researchers, and private economists 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 input provided to the models by the authors of those documents. These inputs relate to a number of factors including the size of the region of influence, the type of activity involved in the projects being considered (assembly/disassembly versus construction of a light water reactor, for example), 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 operations or construction and operation of new facilities, the money spent by the Pantex Plant workers in the local economy, and the average wage rate applied to indirect workers. Since all inputs to the model are converted into dollars, different wage rates applied to direct and indirect workers can alone generate different indirect employment multipliers. The activities involved in the three programs described in the three referenced documents are different and each requires significantly different inputs which may or may not be available within the region of influence (ROI). This also contributes significantly to different multiplier values in the three documents.

RC: 11.002

Doc: HT10/2

The question is, why is there no cumulative impact analysis in the socioeconomic impact analysis of past actions, like the cancellation in 1988 of the DOE program of a mine geologic repository for spent nuclear fuel and high-level radioactive waste in Deaf Smith County? That particular action was an action that [caused] a great economic disaster here in the [Texas] Panhandle region. And right now we are just barely coming out of..., or just towards the end of coming out of, that particular recovery from that particular action.

Response:

Cumulative impacts include the incremental impacts of the actions when added to other past, present, and reasonably foreseeable future actions. Socioeconomic impacts of past actions, though not discussed individually by projects, are reflected in the baseline employment and population estimates which form the basis for evaluation of impacts from the proposed action and alternatives. Thus, any impacts from the cancellation of the repository program in Deaf Smith County on the Pantex ROI would already have been included in the description of the affected environment and the projections under the No Action Alternative. Cumulative economic impacts of concurrent DOE actions for which sufficient information was available have been discussed in volume I, section 4.11.5. As mentioned on page 4-7 of the Draft EIS, information on other Federal (non-DOE), state or local projects including private developments was sought through contacts with federal and state regulatory agencies, Amarillo Economic Development Corporation, Panhandle Municipal Water Authority, and the City of Amarillo. This effort yielded only one project (future closure of Helium Plant) that would contribute to the cumulative impacts in the Pantex Plant ROI. Cumulative impacts of this project have been included in volume I, section 4.11.5.4.

RC: 11.003

Doc: HT10/3

And then the more recent announcement of closure of the U.S. Department of Interiors Bureau of Mines Helium Operation. [This is] not addressed anywhere under cumulative impacts.

Response:

Volume I, section 4.11.5.4. has been expanded to note that the Helium Operations Plant, a facility that employs approximately 175 people, will be downsized (employing 30 to 40 workers). As a result of Congressional legislation, on October 9, 1996, the President signed the Helium Privatization Act of 1996 directing helium operations to discontinue production and sale of refined helium by no later than 18 months from the date of enactment (i.e., April 1998). The downsizing will occur over the next 18-months.

RC: 11.004

Doc: HT08/1

... It will hurt the economy of this city to have another payroll eliminated... Already gone are the Air Force base, the helicopter plant, the helium plant, and Pantex. What next? Cutting the payroll of this city further, I am against wholeheartedly.

Response:

The decisions to close federal facilities or operations are made by different federal agencies in the context of national policies. DOE has considered the cumulative economic impacts of these past actions in the baseline evaluation of the existing environment. DOE will further consider economic impacts in the decision-making process for projects for which it is responsible. See response to comment 11.002.

RC: 11.005

Doc: HT11/19

Well, one concern that Id like to state is in your risk assessment, [which is based] on 1990 census figures.... Because Las Vegas itself has changed so much in the past six years, I think that...the 1990 census figures probably arent...the ones to use.

Response:

Las Vegas has grown substantially since the 1990 census was taken. However, risk analysis requires population data by the smallest geographical units of the city or the region of influence such as Census Tracts or Census Blocks. In fact, it is further broken down by sectors within a 80 kilometers (50-mile) radius circle from the project site in order to identify the potential number of people who may be at risk at different distances from the project site. Only the 1990 census information is available at that level of detail (census tract and block level) and is, therefore, utilized in risk assessment to provide a consistent basis for comparison of sites in different states.

RC: 11.006

Doc: HT11/32

We also, depending upon the number of shipments and nature of the shipments,...are concerned here with perceptions of risk and possible consequences of that on the tourism industry. This is...the mainstay of Nevada economy, and if there were to be an incident or accidents on the interstate, especially near The Strip, this could have various severe consequences, economic consequences.

Response:.

Nuclear materials have been shipped to the Nevada Test Site (NTS) since the early 1950s. Radioactive waste has been shipped to the site since 1961. There is no historical evidence that perceptions associated with nuclear material or waste shipments to the NTS have affected the economy of Las Vegas or resulted in a deterioration of tourism in Las Vegas. In fact, the Las Vegas area has experienced remarkable growth over the past three decades. Tourism in southern Nevada has increased from 21 million visitors in 1990 to a forecast 31 million in 1996. Therefore, there is no reason to conclude that future shipments to NTS would adversely affect tourism industry or the States economy.

Since its establishment in 1975, the DOE Transportation Safeguard Division has accumulated more than 119 million kilometers (74 million miles) over the road experience in transporting DOE owned cargo without any accidents that resulted in release of radioactive material. Section 6.3 of the Pantex Plant Safety Information Document provides a listing of accidents resulting in damage to safe secure tractor trailers (Pantex 1996a).

RC: 11.007

Doc: HT14/6

But Im wondering just in the general proximity how many jobs, if any, will this create for the Tri-Cities.

Response:

To elaborate on the response given at the public hearing, as stated in volume I, section 5.4.1.9, approximately 150 additional personnel would be required for the interim storage of pits at the Hanford site. This number represents less than 1.0% increase in the total Hanford Site workforce. Most of the workers can be hired locally.

RC: 11.008

Doc: HT02-02/1

I have come to speak on health and safety issues, as well as the feasibility of having plutonium, other nuclear materials, and other types of hazardous materials and chemicals in our front yard,...over the areas major water supply, and in this very productive and vital agricultural area[a] major food sourcefor the nation as well as the world just for Amarillos "[powers] that be" to possibly create a few more jobs and wealth for themselves.

Response:

The Pantex EIS has been prepared to evaluate the environmental impacts (including health and safety) of continued operations of the Pantex Plant irrespective of whether they occur in the rural areas surrounding the plant site or in Amarillo. DOEs goal is to meet its mission requirements in a manner that protects the public, workers, and the environment; job creation may be an additional benefit but is not the primary objective of any of the proposed alternatives. See response to comment 14.018.

RC: 11.009

Doc: HT01-08/2

Likewise, we believe that Pantex can be a site where good, high-paying jobs are created in a work environment that includes potentially dangerous materials. When measured in terms of payroll, Pantex is by far the areas largest employer. With 3,500 employees at the plant, a job multiplier of 3.87 shows that Pantex is responsible for a total of over 13,500 jobs in this region. This multiplier was established by Dr. Ray Perryman at Southern Methodist University. The multiplier reflects the fact that the money that Pantex brings into the local economy supports many retail, medical, educational, finance, insurance, and real estate jobs. All told, employment related to Pantex represents over 12% of all jobs in the Amarillo metropolitan area. I urge the DOE to correct the socio-economic impact portions of all three EIS documents to accurately reflect the impact of Pantex on our local economy.

Response:

DOE chose to use the U.S. Bureau of Economic Analysiss 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 United States.

Pantex is a major contributor to the employment in the region. However, as explained in response to comment 11.001, 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 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 EIS. Dr. Perrymans analysis (see Amarillo Economic Development Corporation Release dated August 3, 1993 [AEDC 1993] and Perryman Consultants, "Analysis Shows Pantex Plant Adds a Billion in Revenues and Thousands of Jobs to Amarillo Economy," Press Release [Perryman 1993]) does not identify any specific job multiplier. In one place, he mentions that Pantex Plant employs 3,100 persons. Then he estimates that the total employment resulting from Pantex Plant operations is 11,688. This gives us a job multiplier of 3.77. (The commentor, using the rounded figure of 12,000 instead of 11,688, arrives at a multiplier of 3.87.) In the same article, however, Dr. Perryman states that Pantex Plant expansion by 2,400 jobs would result in 5,312 total additional jobs. This would imply a job multiplier of only 2.21, not 3.87. Should it be assumed that he is using two job multipliers because in the Pantex Plant expansion scenario, he is looking at different activities (industries) at the plant, which include peaceful uses for plutonium, operation of a linear accelerator, and long-term storage of plutonium and not the current operations of assembly and disassembly of weapons. Your comments have been considered by the SSM PEIS and S&D PEIS authors and are addressed in their respective comment response documents.

RC: 11.010

Doc: HT01-08/1

And theres not enough words to say how important Pantex is to our job situation in Amarillo. If you use a multiplier index in the total take on our economy, were talking about [13,500] jobs out of the 3,500 job base that is at Pantex. Needless to say, from our standpoint, whats truly important to this area from an economic standpoint, we strongly urge the DOE to do everything they possibly can at the Pantex site.

Response:

The Department will consider economic impacts along with other environmental impacts, mission requirements, costs and technological considerations in the Record of Decision.

RC: 11.011

Doc: HT07/2

One of the reasons that employment increased at Pantex by about a thousand people was not so much for the increased work in dismantlement, but to invoke a safety culture at Pantex. A lot of these safety infrastructure programs are independent of the number of units youre doing. Whether you have one weapon or a thousand, you still need your conduct of operations, you still need your safety analysis, you still need your safety question determination, et cetera. And none of the numbers Ive seen seem to take into account that you have a base line infrastructure that you cant go below without losing the safety culture. Id like you to respond to that.

Response:

To elaborate on the response given at the public hearing with Pantex EIS specific information, the decrease in the number of jobs from 3,800 workers at the 2,000 weapon activity level to 3,000 workers at the 1,000 weapon activity level and 2,400 workers at 500 weapon activity level is less than it would be if reduction were in proportion to the reduction in dismantlement. This is mainly because the numbers reflect a baseline infrastructure and safety-related workforce which would remain at Pantex regardless of the volume of weapon disassembly activities. Safety at Pantex Plant is given highest consideration and will continue to be given the same consideration in the future.

RC: 11.012

Doc: HT07/3

My response to that, is that it was looked at...without looking at the plant as a total. ...The way the questions were asked, for the specific operations, we gave the numbers, but no one asked the questions about what it would take to maintain your overall safety infrastructure. I believe thats true.

Response:

See response to comment 11.011.

RC: 11.013

Doc: CO-008/65

Page 4-172. It is stated that the work force could reach 10,220. This is based on all Weapons and Disposition activities being done at Pantex. Please discuss in a manner that shows the time frame break down between construction, weapons and disposition work, and the possibility that everything will not be done at Pantex.

Response:

A workforce of 10,220 represents the cumulative (maximum) workforce assuming that current operations and waste management activities at Pantex Plant would continue when activities relating to the storage and disposition of weapons-usable fissile materials reach their full operational level. The referenced paragraph on page 4172 of the Draft EIS also indicates that disposition activities cannot start earlier than 10 years from the date a decision is made selecting Pantex Plant as the site for disposition activities. Construction of a completely new reactor could take even longer. However, it should be noted that this discussion is relevant only in the event that Pantex is chosen as the site for long term storage and disposition of weapons-usable fissile materials. That issue is the subject of the S&D PEIS, not the Pantex EIS.

RC: 11.014

Doc: CO-008/66

Page 4-172. Provide a work force break down by year and activity. If downsizing is required, and exceeds attrition, please provide a downsizing plan.

Response:

Although impacts of various levels of downsizing are evaluated in the Draft EIS, a realistic downsizing plan cannot be developed until a record of decision is issued by the Department identifying the level of activity and associated choice regarding new or upgraded facilities at the Pantex Plant. This decision will not be made before the Final EIS for the Pantex Plant is published. The Department will, however, keep the public informed of its actions on a regular basis and soon after a decision is made. Any decision that would result in downsizing would require a formal Workforce Reduction Plan and additional public participation opportunities in accordance with the National Defense Authorization Act of 1993 (Public Law 102-484).

RC: 11.015

Doc: CO-008/67

Page 4-172. Knowing that all of the above activities are likely to be limited to 10 to 30 years, if there is an adverse impact from Pantex downsizing, is there money available to the Pantex ROI for long-term community assessment and planning?

Response:

The Record of Decision on the S&M PEIS will identify whether Pantex Plant would be downsized or not. If downsizing does occur, the affected communities can request the DOE to provide financial assistance for community assistance and planning. The DOE Office of Community and Worker Transition can be approached to obtain help for the facility and community transition in case of downsizing.

RC: 11.016

Doc: CO-008/68

Page 4-172. The socioeconomic analysis of the three EISs [is] not consistent. The SWEIS Summary (page S-17) assumes 1.65 indirect jobs in the region for every [job] at Pantex. The SSM PEIS (page S-32) assumes 1.16 and S&D PEIS (page 4-205) assumes 3.51. Please explain these differences. Why didnt the DOE use the analysis of the Amarillo Economic Development Commission (AEDC), which is based on local knowledge of the area? Their analysis gives a ratio of 2.87 to 1 (REF. Chamber Quarterly, 2nd Quarter, 1996, Amarillo Chamber of Commerce.)

Response:

Refer to the responses to comments 11.001 and 11.009 for general explanation of multipliers. The referenced article in Chamber Quarterly (ACC 1996) states that AEDC uses a multiplier of 3.9 for jobs at Pantex and goes on to state that the 1,600 jobs projected to be phased out at Pantex could ultimately result in a total loss of 4,600 jobs in all areas of Amarillo economy. If this statement is correct, the number of indirect jobs would be 3,000 (4,600 total jobs minus 1,600 direct jobs = 3,000 indirect jobs), or 1.88 times the direct jobs. The comparable number in the Pantex EIS is 1.65 indirect jobs for each direct job. Please refer to Final SSM PEIS and S&D PEIS for their responses to your comment.

RC: 11.017

Doc: CO-008/69

Page 4-172. In the draft SWEIS Summary (page S-17, Table S-1), it is stated that at the 500 weapon activity level, Pantex "would support 2,400 direct jobs and 3,949 secondary jobs" and that "personal income additions to the economy would be reduced to $356 million annually." Please explain why this degree of economic loss would not only be an adverse but a Significant Adverse Impact to the community.

Response:

The statement in volume I, page S-17 is a summary of the description provided in volume I, section 4.11.2.1 (p. 4-167 of the Draft EIS), which indicates that a combined loss of 3,715 jobs (1400 direct+2,315 indirect jobs) would increase the unemployment rate in the region of influence from 4.1 percent to approximately 6.2 percent and could trigger out-migration. The reduction of personal income from $564 million at 2,000 weapon activity level to $356 million at 500 weapon activity level would mean a loss of $208 million or 37 percent of the personal income generated by the 2,000 weapon activity level. Compared to the total employment of 107,000 in Amarillo (Ref. Chamber Quarterly, 2nd Quarter, 1996, Amarillo Chamber of Commerce [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. These impacts would, no doubt, be adverse and may be considered significant by some members of the community. The text in the Final EIS has been revised to include this statement. The article in the Chamber Quarterly referenced above, suggests that the jobs added in the next 6 to 7 years would reduce the impact of this job loss.

RC: 11.018

Doc: CO-008/70

Page 4-165. At the 500 weapon activity employment level, what would be the impact to the revenues for the governing bodies within the Pantex ROI, compared with the current revenues presented in table 4.11.1.6-1 (page 4-165)?

Response:

At the 500 weapons activity level, Pantex workforce would be reduced by 1,400 workers. Additionally, 2,351 indirect workers may lose their jobs in the Pantex region of influence. For analysis purposes, we have assumed that all direct workers and 50 percent of the indirect workers leave the Pantex region of influence as a result of this action. Further assuming, for simplicity in calculation, that all workers live in the City of Amarillo and based on the current per capita revenue of $457, the revenue loss in the City of Amarillo would be approximately $2.8 million about 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 counties of the region of influence is generally lower than in the City of Amarillo. Discussion in volume I, section 4.11.2.1 has been expanded to include potential impacts on population and tax revenues.

RC: 11.019

Doc: HT13/17

One of my biggest complaints about the document, which strangely enough some of us do actually read it, a lot of times, under the affected environment, you list everybody all the way from Rio Rancho to Belen and everybody to the west. There are people who live east of Manzano Base. It is the fastest growing area other than Rio Rancho, and this is something that needs to be brought up.

Response:

As shown in volume I, section 5.5, Figures 5.5.2.1-1 and 5.5.2.2-2, population living within a 80 kilometers (50-mile) radius from the Manzano Weapons Storage Area (WSA) has been considered in the analysis. People living east of Manzano WSA are, therefore, included in the analysis.

RC: 11.020

Doc: PC-013/1

It will hurt the economy of this city to have another "pay roll" eliminated. The main 4 plans under plans to dispose of, and those already gone are - the Air Base.

Response:

See responses to comments 11.002 and 11.004.

RC: 11.021

Doc: PC-012/1

Section 4.11.5 on page 4-170 in volume I, Main Report is titled "Cumulative Impacts" and is referring to Socioeconomic Resources. It states that "This section describes the cumulative impacts on Pantex Plant. Cumulative impacts include the impacts of continued operations at Pantex Plant combined with impacts associated with the activities described in the Waste Management Draft PEIS, the Stockpile Stewardship and Management Draft PEIS, or the Storage and Disposition of Weapons-Usable Fissile Materials Draft PEIS."

The Council on Environmental Quality Guidelines published in 40 CFR ¤1500-1508 define Cumulative impact in ¤1508.7 as follows:

"Cumulative impact is the impact on the environments (emphasis added) which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time."

Question: Why is there no analysis of the incremental socioeconomic impact of this action, on the Pantex socioeconomic region of influence, when added to other past and present actions such as the cancellation, in 1988, of the DOE program of a mined geologic repository for spent nuclear fuel and high-level radioactive waste in Deaf Smith County, and the more recent announcement of closure of the U.S. Department of the Interiors Bureau of Mines Helium Operations?

Response:

See responses to comments 11.002 and 11.004.

RC: 11.022

Doc: CO-002/1

In the draft SWEIS (p. S-17) it is stated that at the 500 weapon activity level Pantex "would support 2,400 direct jobs and 3,949 secondary [jobs]," and that "personal income additions to the economy would be reduced to $365 million annually."

Please explain why this degree of economic loss would have not only an adverse, but a significant adverse, impact on the community.

At the 500 weapon activity employment level, what would be the impact on revenues for the governing bodies within the Pantex region of influence compared to the current revenues present in table 4.11.1.6-1 (p. 4-165)?

Response:

See responses to comments 11.017 and 11.018.

RC: 11.023

Doc: CO-002/2

In Section 4.11.5 "Cumulative Impacts," referring to socioeconomic resources (p. 4-170), it is stated, "This section describes the cumulative impacts on Pantex Plant. Cumulative impacts include the impacts of continued operations at Pantex Plant combined with impacts associated with the activities described in the Waste Management Draft PEIS, the Stockpile Stewardship and Management PEIS, or the Storage and Disposition of Weapons-Usable Fissile Materials Draft PEIS."

The Council on Environmental Quality Guidelines published in 40 CFR ¤1500-1508 define cumulative impact as follows (¤1508.7). "Cumulative impact is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonable foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result [from] individually minor [but] collectively significant actions taking place over a period of time." (Emphasis added)

Why is there no socioeconomic analysis of the incremental impact of this action on the Pantex socioeconomic region of influence (ROI) when added to other past and present actions, such as the cancellation and shutdown in 1988 of the DOEs high-level nuclear waste repository in Deaf Smith County, and the more recent announcement of closure of the U.S. Department of the Interiors Bureau of Mines Helium Operations in Amarillo?

Response:

See responses to comments 11.002 and 11.004.

RC: 11.024

Doc: CO-002/3

The socioeconomic analyses of the three EISs are not consistent. The SWEIS (p. S-17) assumes 1.65 indirect [jobs] in the region for every job at Pantex. The SSM PEIS (p. S-32) assumes 1.16, and the S&D PEIS (p. 4-205) [assumes] 3.51.

Response:

See response to comment 11.001.

RC: 11.025

Doc: CO-002/4

The Amarillo Economic Development Commission (AEDC) analysis, based on local knowledge of the area and a regional impact study performed by Dr. Ray Perryman of Southern Methodist University, gives a [ratio] of 2.77 additional jobs in the region to every 1 Pantex job (for a total job multiplier of 3.77).

Response:

See responses to comments 11.001 and 11.009.

RC: 11.026

Doc: CO-009/5

In fact, the impact of Pantex employment in the region of influence is highly significant to the region. Measured in terms of total payroll, Pantex is by far the areas largest employer. The reasonable job multiplier developed by Dr. Ray Perryman at Southern Methodist University, a multiplier of 3.87, applied to the some 3,500 employees at Pantex, suggests the site is responsible for a total of over 13,500 jobs. Employment related to Pantex represents over 12% of the jobs in the Amarillo metropolitan area.

Incidentally, the three subject EISs inconsistently analyze the indirect jobs created in the region by Pantex employment: The site EIS assumes 1.65 indirect jobs for each job at Pantex; the stewardship and management EIS assumes 1.16; the storage and disposition EIS, 3.51 (by far, the most consistent with Dr. Perrymans, which is the same, regional-experience-based multiplier employed by the Amarillo Economic Development Commission).

Certainly, we consider a potential 10% to 12% reduction in metro-area employment a major loss, and by no means a "negligible" concern. We strongly urge the Department to correct the socio-economic impact portions of all three EIS documents to accurately reflect the impact of Pantex employment in its region of influence.

Response:

See responses to comments 11.001 and 11.009.

RC: 11.027

Doc: PC-034/8

Table 4.11.1.6-1 presents revenues for the governing bodies within the Pantex ROI (p. 4-165). If Pantex is reduced to the 500 weapons activity level, what would be the impact to these revenues?

Response:

See response to comment 11.018.

RC: 11.028

Doc: HT17/1

I think the DOE has done a pretty good job of describing our economy; however, I think on the impact section there are some weaknesses. Its more of a descriptive document about our economy than it is a projection of what the impacts of Pantex might be on the economy. I know youve used a number of figures for your job multiplier, in terms of how many jobs in the economy exist as a result of the operations at Pantex. Is that a regionally sensitive multiplier that youve come up with, or is that something thats just standard across the board for the nation?

Response:

The socioeconomic impacts associated with the alternatives at the Pantex Plant extend beyond the city of Amarillo and include all the jurisdictions within the four-county region of influence. The database used for the socioeconomic study was developed using information from the Department of Commerce and Labor, as well as financial reports provided by cities and counties. The impacts were measured using the latest version of Regional Input-Output Modeling System II (RIMS II), a model developed by the U.S. Bureau of Economic Analysis. The model is used by Government agencies, university researchers, and private economists to measure economic impacts and is available for every economic region in the nation. It is designed to be sensitive to differences in the economy from one region to another.

RC: 11.029

Doc: HT17/2

I think there is some weakness [in] looking at the effects on certain sectors of the economy. In particular, I would note it [the EIS] doesnt talk a lot about [the effects on] retail sales and employment in the retail sector, which has been a tremendous growth portion of our economy over the last five years.

Response:

The socioeconomic impacts associated with the alternatives at the Pantex Plant are described in terms of total earnings (salaries and wages to employees) and total personal income. It is true that impacts on individual sectors of the economy are not analyzed. However, the text in volume I, section 4.11.2.1, states that most of the secondary jobs in the local economy are in the retail trade and service sectors.

RC: 11.030

Doc: HT17/3

It [the EIS] doesnt look extensively at wholesalers and industrial suppliers, many of whom supply [products] to Pantex, but also associated with industry in general. We wouldnt...have the diversity of industrial supply companies in Amarillo without Pantex, and I think that should be taken into account.

Response:

See response to comment 11.029.

RC: 11.031

Doc: HT17/4

...perhaps the most important [aspect] would be the impact, if there were significant job losses. And I know this EIS doesnt contemplate it, but if there were significant job losses beyond whats mentioned, even in terms of looking at the [1,000 weapons] per year, let alone the [500 weapons], the real estate sector would suffer considerably.

Response:

The job losses resulting from reduced weapon activity level are discussed in volume I, section 4.11.2.1 and the job losses resulting from the closure of the plant are summarized in volume I, section 4.11.5.2. The loss of approximately 3,700 direct and indirect jobs would certainly impact the real estate sector, but it should be noted that not all unemployed workers, particularly the indirect workers, are likely to leave the Pantex region of influence immediately or even over a longer period. The text in volume I, section 4.11.2.1 has been expanded to include these effects.

RC: 11.032

Doc: HT17/5

... I think we have some pretty good historical data in Amarillo on what happens when theres large outmigrations in number of jobs and in population. You can look back to what happened when the air base left town or look back in the late eighties, what happened to our economy.

Response:

Comment noted. The text in volume I, sections 4.11.1.1 and 4.11.1.5 has been revised to incorporate population and economic changes occurring prior to 1990.

RC: 11.033

Doc: HT17/6

Id also ask that maybe additional analysis could be done on the tax revenue portions.

Response:

See response to comment 11.018. The text in volume I, section 4.11.2.1 has been revised to add a discussion of tax revenues.

RC: 11.034

Doc: HT17/7

Again, going back to the problems that happen when you talk about severe job losses in the manufacturing sector of the economy. In terms of real estate, it would have a dramatic effect on all the cities in the region and their ability to raise revenue through property tax. ...There is discussion of the citys revenue capacity in the document, but I think it could be strengthened. Counties are also very dependent in Texas on property tax. In fact, Texas counties are nearly completely dependent on property tax revenues. So, they suffer severely when there are declines in property tax values. Finally, school districts, which arent mentioned at all in the document,...are also very sensitive to property tax issues. Changes in the property value can have interesting effects in Texas because of our school equity financing law. Ill note that the Canyon School District, which is in the Region of Influence, is already looking at a million dollar deficit because of certain property tax issues.

Response:

See response to comment 11.018. The text in volume I, section 4.11.2.1 has been revised to add a discussion of tax revenues.

RC: 11.035

Doc: HT17/8

The City of Amarillo...in 1989, passed a half cent sales tax to reduce the property tax. So, in essence, they shifted their taxation burden from property taxes, to some degree, to retail sales. If retail sales do not grow at least at the inflation rate, that translates into an actual, in essence, reduction in the funds available to operate the city.

Response:

Comment noted. Retail sales would be reduced if the weapon levels are reduced to 1,000 or 500 per year. The reduction in worker earnings and personal income are discussed in volume I, section 4.11.2.1.

RC: 11.036

Doc: HT17/9

In looking at the government debt section of the document, the majority of the debt was listed as the City of Amarillo. I think theres 55 million dollars of debt. That is primarily revenue bond debt...that is financed through utility fees. Its not dependent on general revenue taxation at all.

Response:

Comment noted. Socioeconomic analysis in volume I, section 4.11.2.1, has been revised to provide a better discussion of population change and tax revenue.

RC: 11.037

Doc: HT17/10

...I think there needs to be some analysis on what effect this might have on water consumption, on water revenues in the city, because thats what backs those revenue bonds that...secure the debt that youve mentioned in there.

Response:

Additional information on impacts to overall tax revenues has been provided in volume I, section 4.11.2.1. Impacts on individual sources of revenues are not provided because they depend on annual budgetary processes and are too speculative to be included in this EIS.

RC: 11.038

Doc: HT17/11

Finally,...maybe most importantly is population outmigration. Cities tend to be in a growth mode, they tend to plan on future growth. As happened in Amarillo in the sixties and again in the late eighties, when you have outmigration, it dramatically affects all sectors of the economy, particularly retail and otherwise.

Response:

Volume I, section 4.11.2.1, provides socioeconomic impacts which could occur as a result of population inmigration. It should, however, be noted that reduced workforce at Pantex Plant or even the closure of the plant would not 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 facilities over a number of years.

RC: 11.039

Doc: HT17/13

The population figures that you just showed on your slides, I found...in Volume I, on page 4-155. Theres some conflicting population estimate numbers for the Region of Influence given in the section dealing with accident risk estimates and fatal cancer estimates. The numbers that are given there are 267,107 [for] population in the Region of Influence. And Im wondering what the difference is in those estimates.

Response:

In the NEPA process regions of influence (ROI) are defined in relation to the potential for an environmental aspect to be affected. For health risk analysis, whereby contaminants can be dispersed over large geographical areas by weather phenomena or surface features such as rivers, streams, etc., traditionally such potential impacts are assessed within an 80 kilometer (50 mile) radius of the facility of interest. On the other hand, studies have shown that people tend to spend money in the communities where they live. Thus the socioeconomic ROI, for NEPA analysis is traditionally analyzed by defining the political (and census) boundaries within which at least 90 percent of a sites workers live. For the Pantex Plant, 96 percent of workers live in Carson, Potter, Randall, and Armstrong counties. Thus these four counties comprise the socioeconomic ROI for Pantex Plant.

Since the 80 kilometer circle for the human health (accident) analysis includes 14 counties, it has a larger population than the 4-county socioeconomic ROI.

RC: 11.040

Doc: HT17/14

I neglected to mention one aspect that I think should be taken into account on all the EIS documents for all sites, and thats the effect on nonprofit agencies that rely on contributions of the employees at the plant. You would have a decline in the revenue to those nonprofit agencies; at the same time, youd have economic hardships, creating a larger need for those services.

Response:

Discussion in volume I, section 4.11.2.1 has been expanded to include the potential effect on non-profit agencies due to downsizing.

RC: 11.041

Doc: HT17/16

I think that we felt,...especially looking at your view graph here, that you have brought it down to within just a four-county area for the Region of Influence. And yet for all the other study that was done throughout the document, it is a much wider [area], as was noted by Joe Martillotti.

Response:

See response to comment 11.039.

RC: 11.042

Doc: HT17/17

...the magnitude of the impact of agriculture was really not addressed and the importance that agriculture has played in this area and the stability of the area. And when the air base was phased out, it was agriculture that brought this part of the State of Texas, or that kept it alive and kept it going. ...One of every four dollars of cash receipts from the State of Texas in total revenue comes from crops and livestock that are produced in this part of the State. Right here in...the High Plains Trade Area, if these counties were detached from the rest of the State of Texas, this [area] would rank number one [nationally] in the fed cattle...production. These are very important items for this area, because youre right in the middle of a prime agricultural area. The cereal crops that are grown here are shipped all over the world. For any product that we raise here, if there is the slightest hint of any contamination, that could devastate this total area. I dont know how many of the other facilities are situated in an area that is a bread basket as much as this area is. I dont think that that was brought out in this document. One of four people is employed in [an] ag-related job in this area. And for anything to happen in agriculture would devastate the area.

Response:

The Department of Energy recognizes the importance of both agriculture and Pantex Plant jobs in the Panhandle economy. The Department has programs of environmental stewardship to protect the environment in general and neighboring farms, ranches, and communities in particular. The analyses in this EIS demonstrate that the Pantex Plant and agriculture can not only coexist, but mutually and beneficially contribute to the economic and social fabric of the region.

The contribution of agriculture to the regional economy of the Panhandle has been expanded in volume I, sections 4.4 and 4.11.

RC: 11.043

Doc: HT17/18

... I think that its extremely important to realize that even for the State of Texas, the importance agriculture plays has a tremendous effect upon the revenue that the State of Texas receives. So that even though in this document, which is a nuclear document, it may seem a little strange to address agriculture, I think that a complete risk analysis needs to be done with regard to just exactly what could happen with regard to the future for this area. I know that in 1991, when we first began looking at this issue, that the total impact of agriculture in this area was about three billion dollars, and now that has increased to between five and six billion dollars, and with an economic multiplier its [in] excess of 12 billion dollars. So, youre looking at a tremendous figure there that could stand a chance of being hurt in some way. So, wed like to see that addressed.

Response:

See response to comment 11.042.

RC: 11.044

Doc: HT17/55

In our study of this document, we find that it fails to address the magnitude of agriculture in the Pantex ROI. In this, the heart of production agriculture, it is unthinkable for agriculture, the viable, stable, and essential industry of the Texas Panhandle, not to be appraised. When considering continued and new [missions] at Pantex, work with radioactive, toxic, and hazardous materials, omitting a detailed analysis of the agricultural economy, the basis for economic stability in this area, is a significant impropriety. The dollar value of the agricultural industry to the Panhandle economy is in excess of six billion dollars, creating a local economic activity in excess of 12 billion per year. The State of Texas cannot afford a loss in State revenues from High Plains agriculture.

Response:

See response to comment 11.042.

RC: 11.045

Doc: PC-017/1

What kinds of studies (if any) have been conducted to learn the effects of the proposed actions -- storage of large amounts of plutonium, chemicals, nuclear waste, uranium and other toxic substance and/or the [processing]/reprocessing of those substances on agriculture production, sales, uses, etc? What were the results of such studies if any have been made? Agriculture is mentioned very briefly in the EIS. Agriculture is the major industry in the Texas Panhandle and the only industry near the Pantex Plant.

Response:

Risk assessments conducted in the Pantex EIS as well as in the SSM PEIS and S&D PEIS have shown that Pantex Plant activities do not adversely impact agricultural operations in the region. 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. Pantex Plant routinely conducts environmental monitoring and the results are summarized in its annual site environmental reports (see references to these reports in the Pantex Plant Environmental Information Document, [Pantex 1996]). One special study dealing with radiological effects on beef cattle was conducted in 1982. It was published as a Supplemental Documentation for an Environmental Impact Statement Regarding Pantex Plant, Agricultural Food Chain Radiological Assessment (LANL 1982). Refer to volume I, section 4.9.1.1 of the Pantex EIS and response to comment 09.001 for additional details. Additional agricultural documentation has been added to volume I, sections 4.4 Land Resources, 4.5 Geology and Soils, 4.6 Water Resources, 4.9 Biotic Resources, and 4.11 Socioeconomic Resources.

RC: 11.046

Doc: PC-017/3

What studies have been made on the long-term effects of those activities being proposed or possibly being proposed on our agricultural products? When were such studies made? How were they done? What results were found? Where were they done? Were neighboring farmers and ranchers consulted? Who? Major plans for the future of Pantex cannot be made until such studies are made and found to be positive.

Response:

See responses to comments 11.045 and 09.001.

RC: 11.047

Doc: PC-025/54

Page 4-155. Given the fact that this is 1996 and the section uses 1990 data, has a significant change occurred in population since 1990 and the socioeconomic parameters to warrant estimating the affected environment closer to 1996 time frame? How many visitors to Amarillo are there each year? Is that important? If I-40 closes due to [a] Pantex accident, what are the impacts to East/West Interstates?

Response:

We agree with your comment that Amarillo has grown substantially since the 1990 census was taken. Population change from 1990 to 1995 and estimates of population for the year 2005 are presented in volume I, section 4.11.1.1 of the EIS. Impacts of downsizing have been measured against the more recent population estimates available for 1995 and have been included in the expanded text of volume I, section 4.11.2.1. We do not have data on number of visitors per year, but the money they spend is in the economic statistics. Probability of accidents on interstates used for carrying nuclear materials and their impacts have been presented in volume I, section 4.16, Intersite Transportation of Nuclear and Hazardous Materials.

RC: 11.048

Doc: PC-008/1

The socioeconomic analyses of the three EISs are not consistent. The SWEIS (p. S-17) assumes 1.65 indirect jobs in the region for every job at Pantex. The SSM PEIS (p. S-32) assumes 1.16 and the S&D PEIS (p. 4-205) assumes 3.51. Please explain these differences. Why didnt the DOE use the analysis of the Amarillo Economic Development Commission (AEDC), which is based on local knowledge of the area? Their analysis gives a ratio of 2.87 to 1 (REF. Chamber Quarterly, 2nd Quarter, 1996, Amarillo Chamber of Commerce).

Response:

See response to comment 11.016.

RC: 11.049

Doc: SG-010/6

Research has demonstrated that nuclear-related activities such as radioactive material transportation have the potential to result in significant socioeconomic impacts. These impacts originate in intense negative perceptions and avoidance behaviors by the public, and public and media interests in "things nuclear" makes it almost certain that these negative perceptions will adversely affect a communitys quality of life and subsequently its commercial, residential, and business investment opportunities. Thus, we contend that DOE should do everything possible to limit the movement of these dangerous materials.

Response:

DOE is very sensitive to public perceptions of nuclear-related activities such as radioactive material transportation and has established strict guidelines for transportation of such materials.

See response to comment 16.045 for the safety record of nuclear materials shipments over the past 20 years.

RC: 11.050

Doc: CO-005/1

We are greatly troubled by the fact that agriculture was totally discounted as the major economic stability of the entire area and the second-largest industry in the State. Providing a job for one in every five Texans and generating more than $40 billion annually for the State of Texas, agriculture cannot be slighted in this document. Beyond the economic consideration is something we must never forgetAGRICULTURE PRODUCES THE ESSENTIALS OF LIFE. As long as people need food, housing and clothes, they will need and depend on agribusiness. This factor was ignored in this environmental document, thus creating a document that is flawed in its most basic conjecture.

This High Plains Trade Area, which encompasses the northernmost 26 counties in Texas produces close to $6 billion annually in cereal crops and livestock, of which $3.25 billion annually is in value-added industry, and creates local economic activity in excess of $12.5 billion.

This region produces 96.8 percent of the States sugar beets, 85 percent of its fed beef, 48.4 percent of its corn and 47.5 percent of its wheat. Over 100,000 jobs are generated by High Plains agriculture.

Response:

See response to comment 11.042.

RC: 11.051

Doc: PC-033/5

The agricultural industry and adverse impacts on this industry, as far as I could tell, have been included in only four paragraphs in the Draft SWEIS. In this High Plains Trade Area agriculture plays a major role in the economic stability and I feel should warrant more in depth study as to the adverse impacts on such a valuable industry than are dedicated in this Draft SWEIS.

Response:

The contribution of agriculture to the regional economy of the Panhandle has been expanded in volume I, sections 4.4 and 4.11.

3.12 Intrasite Transportation

RC: 12.001

Doc: HT13/19

In the document on [pages] 5-60 and 5-61, you talk about intrasite transportation within the bounds of Kirtland Air Force Base. There is no discussion here, and again, no reference documents, that describe any transportation-related accidents within the bounds of the base.

I am interested in information [on] varying kinds of accidents ranging from fender-benders to other kinds of accidents that would have happened within the bounds of the base [and] over whatever period of time you have that information.

Response:

Accident statistics are maintained by the U.S. Air Force. For 1995, there were a total of 271 vehicle accidents within Kirtland Air Force Base (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 of vehicle accidents involving pit shipments was considered in the EIS analysis. It was concluded that it is not reasonably foreseeable that an accident on KAFB would occur with the severity necessary to lead to 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 may 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 do not pose a threat to the SSTs while on KAFB.

RC: 12.002

Doc: HT13/20

That wasnt my question. My question was what documentation exists of transportation accidents within the bounds of the base?

DOE has got documents. If the Air Force has documents, that is fine. I want to know what exists because there is nothing referenced in this document, in the sitewide.

Response:

See response to comment 12.001.

RC: 12.003

Doc: HT13/21

I will be glad to get to the accident scenario in a little bit, but my question hasnt been answered. Just to sort of add to it, there is some interesting numerical information in chapter 4 about actual numbers of transfers internally within Pantex. There is not that same kind of information in this document about Manzano, and that is the kind of information I am looking for. ...So...my specific question...is as you were looking at intrasite transportation issues, did you receive, did you have access to, did you look at actual transportation analysis of accidents, transportation accidents, not necessarily dispersal accidents, just accidents within the bounds of Kirtland Air Force Base?

Response:

See response to comment 12.001.

RC: 12.004

Doc: HT13/77

Are you all, in this document, proposing that the pits currently [in] AL-R8 containers, be transferred into AT-400 containers in this interim timeframe?

What is that timeframe? Over what period of time would that transfer be done?

Response:

DOE is planning on repackaging pits into AT400A during the period analyzed by this EIS. Pit repackaging is currently scheduled to begin in late 1996 or early 1997. Repackaging of the pit inventory at Pantex Plant is expected to take longer than 5 years.

RC: 12.005

Doc: HT12/15

What is the intent of the hole, the square [in the Stage Right pallets]?

Response:

Discussion of the Stage Right pallets is included in volume II, appendix F.

RC: 12.006

Doc: HT12/17

[In] the newer method of staging, [is there a] forklift [driver] on the forklift?

Response:

To elaborate on the response given at the public hearing, DOE has introduced an automated guided vehicle to replace the stage right shielded forklift that has been used for operations within pit storage magazines. The use of the automated guided vehicle eliminates the need for personnel inside the pit storage magazines for inventories and inspections.

RC: 12.007

Doc: HT12/18

You said when I load these things Im going to put them in a Type A container. Type B container, okay, fine. Now, you never said Im going to take them out of that Type B container. So Im assuming theyre stored in a Type B container which is suitable for drop [of] 30 feet or puncture and so forth. How in the world is a forklift going to ram a hole through it?

Response:

To elaborate on the response given at the public hearing, certification testing requirements for Type B packages are described in volume II, appendix F, section F.2.3. After consideration of the range of operational accidents that could occur, a bounding forklift accident scenario was developed. This accident could occur when a 20,000-pound forklift traveling at 5 miles per hour strikes a horizontally positioned container that is fixed. The impact would occur between the boom of the forklift and the container.

RC: 12.008

Doc: HT12/19

Okay, how many forklift operations [have] occurred?

Response:

There is no record of the number of past forklift operations, but there have probably been at least 10,000, none of which resulted in a puncture of a pit container.

RC: 12.009

Doc: HT12/27

Public Speaker: Thats, you know, the structures are ventilated, the atmosphere --

Unidentified Speaker: And thats -- they are not in containment.

Public Speaker: And, in fact, theyre [unintelligible] out in here that the storage container, you know, is not sealed so its not a containment barrier either.

Unidentified Speaker: Wait a minute. The storage container is not sealed?

Public Speaker: ALR8s being unsealed the ALR8 container does not --

Unidentified Speaker: Theyre sealed containers. And the other point is that regardless of which option were going to the AT400-A, which have the pit which is clad, the inner vessel which is welded, and then you have the outer canister. So actually thats layers of containment there and thats what were going to in terms of the AT400-A.

Response:

To elaborate on the response given at the public hearing, all pits are hermetically sealed within a metal clad. The ALR8 container is sealed but does not have an inert atmosphere surrounding the pit. The AT400A will provide an inert atmosphere as a defense-in-depth measure in addition to the pit clad. Further information on pit container design is provided in volume II, appendix F.

RC: 12.010

Doc: PC-034/1/2

In the Summary, Table S-1, under intrasite transportation, presents person-rem information (page S-18). The table is supported by Section 4.12 in the main text. An underlying baseline person-rem appears to be incorporated into the estimates for the Proposed Action alternative. Neither the main text nor the table clearly states the assumptions used. The person-rem shown for the Pit Storage Relocation alternative adds the estimated person-rem for pit storage relocation and the person-rem from the 2,000, 1,000, and 500 weapons levels under the Proposed Action alternative.

Thus, while implementing the Pit Storage Relocation alternative, Plant workers are assumed to receive the person-rem associated with the Proposed Action alternative. The radiation exposures for individual workers for the alternatives are within regulatory guidelines and do not have any public health significance.

Response:

The dose estimate presented includes not only the expected doses from weapons operations 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 interzone transfers of 12,000 pits as part of the pit repackaging project.

The environmental impacts of interim pit storage at Pantex have been discussed and analyzed in the Pantex EIS. The Department of Energy, through its contractor Mason & Hanger, is fully committed to the As Low As Reasonably Achievable (ALARA) program at Pantex Plant to help limit the number of personnel occupational exposures and public/environmental exposures to radioactive material. The majority of Pantex Plant workers receive no radiation exposures (zero dose) during normal operations.

Response:

The environmental impacts of intersite transportation of plutonium pits including each of the four alternative sites have been discussed and analyzed in the Pantex EIS. DOE considered the Relocation Alternative as reasonable. However, DOE has determined continuing interim plutonium pit storage at Pantex Plant as the preferred alternative.

Costs are not analyzed as part of the environmental impacts.

RC: 12.011

Doc: PC-034/3

In Table S-1 for the Proposed Action alternative, 50 workers receive 61 person-rem for 2,000 weapons. Next, 50 workers receive 48 person-rem for 1,000 weapons. Finally, 50 workers receive 41 person-rem for 500 weapons. How does one scale these numbers? The same type of calculations are made for the No Action alternative. Again, the numbers for person-rem do not follow the amount of work. Why dont the workers receive only one half the amount of person rem for a one half decrease in the work? Is there a certain amount of radiation that they receive no matter what?

Response:

See response to comment 12.010.

RC: 12.012

Doc: PC-034/4

In the Pit Storage Relocation Alternative, the amount of person-rem from the Proposed Action alternative appears to be added to what happens for pit storage relocation. How can one add the person-rem for these two alternatives? Is the same person-rem used two different times?

Response:

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

RC: 12.013

Doc: HT15/46

Its not clear to me that the document reflects worker exposures of workers who have been dealing with pit storage in Zone 4 West. So Id like to have some clarification about what is and isnt included in terms of the numbers that youre giving in the documents.

Response:

The 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 are provided in volume I, section 4.12.1, of this document. This historical dosimetry data were correlated with historical material transfers to estimate impacts from future operations.

RC: 12.014

Doc: HT15/47

So whats included in as transportation staging includes the workers in Zone 4 as well as the Zone 12 workers involved in those two sites? Im just trying to clarify.

Yes, both Zone 4 and Zone 12 workers are included. The commentor is asking for clarification of the responsibilities and impacts for the department responsible for pit storage and handling activities. The Transportation and Staging Department is responsible for pit storage activities in both Zones 4 and 12 as well as interzone transfers of nuclear material. Historical dosimetry data and a description of responsibilities for this department are provided in volume I, section 4.12.1, of this document.

RC: 12.015

Doc: HT15/48

[Are] the calculations...for those [Transportation and Staging Department] workers...the 1993 to 1994 similar reading? When [is] the 1995 similar reading information going to be available and...included?

Response:

The Transportation and Staging Department had a cumulative dose of 3.642 person-rem for 1995. This information is provided in the Final EIS.

RC: 12.016

Doc: HT16/10

It just occurred to me just as I was listening to you talk about whether or not there would be less exposure if the pits were left onsite rather than transporting them and I wondered if the repackaging were not part of the long-term storage...[would then] be left onsite. And...if repackaging is a part of the action,...would [that] be part of the analysis also? Because it would provide the same worker exposure as taking it out of the bunkers and moving it to a new location.

Response:

Onsite movements of pits differ significantly from offsite pit shipments. Because of the limited speeds for onsite transfers, the restraint procedure required for pit containers is less complex and less time consuming than the restraint procedure for offsite shipments. Because of the additional complexity of the restraint procedure, dose estimates for offsite transfers are greater than the estimates for onsite transfers.

RC: 12.017

Doc: HT16/13

If Pantex is chosen for long-term storage, [would] workers...actually be exposed to the same activity bringing them out of the bunkers as they would if they were taken out and moved to another location?

Response:

It is a correct statement that there will be continued onsite movement of pits. A discussion of the pit transfers and the subsequent impacts occurring during the period analyzed in this document is provided in volume I, section 4.12. Onsite movements of pits differ significantly from offsite pit shipments. Because of the limited speeds for onsite transfers, the restraint procedure required for pit containers is less complex and less time consuming than the restraint procedure for offsite shipments. Because of the additional complexity of the restraint procedure, dose estimates for offsite transfers are greater than the estimates for onsite transfers.

RC: 12.018

Doc: HT16/14

My question has to do with Figure F-6.3.1 on Page F-19, appendix F. There is listed a variety of collisions that might occur during transportation which form the basis for the risk and the consequence analyses in that [appendix] and I note that aircraft collisions with the transport train have not been considered, or at least theyre not listed. The stage right trailer, the whatever trailer you would like to consider. I guess theres something hauling a trailer, so I think of it as a train. If were really looking at 30,000 movements a year, which was the number referred to earlier in the discussion, the total exposure of all of those targets averaged over a year may match the total exposure of a single storage facility, in terms of hours of vulnerability. So it relates to an observation that Ive had that, in analyzing the aircraft crash probability, theres been no consideration of the fact that the aircraft is only in a position to impact the target for a short duration, a very short proportion of its entire flight. Here weve got a slowly moving target thats only vulnerable for a short period of time and weve not worried about it. When youre moving the missile instead of moving the target, we worry about the sum total of all these passes. When were moving the target more slowly, we say, well, its in the open for such a short period of time that its negligible.

Response:

To elaborate on the response given at the public hearing, aircraft impacts into a moving vehicle containing weapons or weapons components were considered in the analysis. The potential for this accident is discussed in volume I, section 4.12.2. Assuming a trailer were continually parked within Zone 4, an aircraft impact frequency of less than 1 x 10-7 per year was calculated. The risk from this accident using a frequency of 1 x10-7 per year is presented in volume I, section 4.12.2.

RC: 12.019

Doc: HT16/42

In the document, it commented that 18 magazines are currently being used for pit storage. And then there was a chart that indicated pit storage magazines, 22 of them was all. And, yet...as of August 1995, [there were] 7,950 pits at the plant. And it just doesnt add up. We need to know where else the pits are at the plant. Youve got too many pits for too few magazines.

Response:

As of July 1996 there were just over 9,000 pits stored at Pantex. There are 22 Zone 4 magazines in Stage Right configuration. That is, magazines in which pits are palletized horizontally, in groups of 4 or 6, ALR8 containers (one pit per container). The Stage Right configuration utilizes the automated guided vehicle forklift. Of the 22 Stage Right magazines, 18 Modified Richmond magazines and 4 Steel Arch Construction magazines currently contain pits. Each of the 18 Modified Richmonds has 424 pits in it (212 per side), whereas, the 4 Steel Arch Construction magazines contain 252 pits each. In Zone 12, building 1244, Cell 8 can hold up to 288 pits, and the 1226 Pit Vault (PV) holds approximately 150 pits. The following table summarizes the these quantities:

FACILITY/STORED PIT QUANTITIES: 18 MR Magazines/18 x 424=7632; 4 SAC Magazines/4 x 252=1008; 12-44 Cell 8/288; 12-26 Pit Vault/150; TOTAL/9078.

It should be noted that the two Zone 12 facilities, 1244 Cell 8 and 12-26 PV, are not currently completely full. Thus, the total number of stored pits is something less than 9,078 (as of July 1996). Since the total changes day to day, exact figures were not available as this response was written, but these numbers indicate approximately 9,000 total pits currently stored at Pantex.

RC: 12.020

Doc: HT16/43

I also would like you all to clarifytheres a place where you say pits accumulated on site. I would like to know if theres a certain point at which a pit is designated as being in storage and if there is kind of an interim staging step where you can have some X number of pits.... If you dont mind, I would like to have clarity about how all pits are categorized, they fall into what categories, et cetera.

Response:

To elaborate on the response given at the public hearing, there is no specific interim staging step for pits designated for storage. When pits are removed from dismantled weapons they are placed in ALR8 containers (at this point they are counted as "stored" pits with respect to the 12,000 pit limit) and either palletized into Stage Right pallets in the dismantlement facility or temporarily staged in the 12-26 Pit Vault until a quantity exists to fill a pallet. Stage Right pallets hold 4 or 6 pit containers per pallet, depending on the pallet size. Full pallets are then transported from Zone 12 to Zone 4 and placed in one of the storage magazines.

With respect to pit categorization, pits at Pantex can be divided into four primary categories as follows:

· SurplusInterim storage pits, not intended for future defense programs use.

· Strategic Reserve Reserved for potential use in future defense programs.

· Enduring StockpileCurrent stockpile weapons spares or maintenance units.

· EvaluationSmall quantities of pits designated for quality assurance tests.

With the exception of enduring stockpile pits (limited classified quantities), all of the aforementioned pits are considered as "in storage" and counted with respect to the authorized limit of 12,000 pits currently allowed to be stored onsite at Pantex. See the response to comment 12.019 for details on current pit quantities stored at Pantex.

RC: 12.021

Doc: HT16/44

Something that also doesnt seem to be in the document is the air-conditioning thats being installed in some of the pit storage you use. Things like that, that have to do with current operation and status of the plant, wed like to understand better.

Response:

The comment is correct. Two Modified Richmond magazines in Zone 4 have air conditioners. Some pits have a maximum storage temperature which has been established by the design laboratory (Los Alamos or Lawrence Livermore National Laboratory). The air conditioning is provided to maintain appropriate temperatures during the summer months for these pits. Additional Zone 4 magazines may have air conditioning installed in the future. This information has been added to volume I, section 4.3.

RC: 12.022

Doc: PC-025/55

Page 4-174: According to Table 4.12.1.1-1, Pantex is stockpiling nuclear explosives or pit components in Zone 12. Please comment since interzone transfers dont balance.

Response:

The commentor is incorrect. DOE is not stockpiling nuclear explosives or pit components in Zone 12. The data in the referenced table refer to transfers occurring during 1994. The data do not include components that were brought to Zone 12 late in 1994 and returned to Zone 4 early in 1995.

RC: 12.023

Doc: PC-025/56

Page 4-174: In the magic numbers of 12,000 and 20,000, what is the maximum number of pit components that would not be included in the storage limits but would be managed in Zone 12 but not considered in storage under the definition of storage? Is this discrepancy accounted for in the analysis? Will these pits be in AT-400 containers? If a shortage of AT-400 containers exists would there be greater risk in Zone 12 management?

Response:

See response to comments 12.019 and 12.020. This small discrepancy is accounted for in the EIS risk analyses, since all calculations used the maximum facility limit quantities for evaluation purposes. It is planned that all pits will eventually be stored in AT400 containers. The order or priority of which pits will be repackaged first is not yet established. However, the risk assessments presented in the EIS were for ALR8 containers and constitutes a bounding analysis with respect to risk. Thus, any number of pits which get repackaged into AT400 containers would reduce the overall risk from pit storage regardless of whether they are in Zone 4 or Zone 12.

RC: 12.024

Doc: PC-025/57

Page 4-174. Has the analysis accounted for the aging of pits and aging of containers? If Pantex has pits from the fifties, forty years of material fatigue from the radiation, thermal, handling, and other adverse environmental conditions must be enormous. Has DOE accounted for this?

Response:

Pits have been under careful scrutiny for many years through various DOE programs, particularly the weapons Quality Assurance Testing Program, which includes the Pit Surveillance Program and an accelerated aging program to ensure that aging-related defects do not develop in pits. The same pits have already spent several decades under surveillance of DOE, the national laboratories, and the military in the field. Routine stockpile surveillance has been performed on the pits for 20 to 30 years in more hostile environments than Zone 4. All data indicate that pits and containers will not 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 failures in the pits and/or containers.

RC: 12.025

Doc: PC-025/58

In the Zone 4 West Activities section, on page 4-181. DOE estimates 20-22 containers would be removed for surveillance activities. Should a problem become evident, what is the maximum number of surveys possible? What are the impacts? Was this considered?

Response:

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. The same pits have already spent several decades under the surveillance of the DOE, the national laboratories, and the military in the field. A routine stockpile surveillance has been performed on the pits for 20 to 30 years in more hostile environments than Zone 4. All data indicates that pits and containers will not 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 failures in the pits and/or containers. Should a problem be detected additional surveillance would possibly need to be conducted, but it is not possible to determine the number that would need to be examined without knowing what type pit was affected and what the nature of the problem might be.

RC: 12.026

Doc: PC-025/59

Page 4-182. What is a small number? Several magazines?

Response:

In this case, a small number refers to one Zone 4 magazine. The impacts from this facility have been evaluated in the EIS.

RC: 12.027

Doc: PC-025/60

General comment in section 4.12: The tritium accident caused quantifiable radiological impacts to plant personnel, facilities, environment, and public. For comparison purposes, please compare tritium accident with intrasite transportation impacts. What is the maximum impact to plant personnel, facilities, environment, and public from tritium storage at Pantex? Has the explosive damage potential of stored tritium been evaluated?

Response:

Intrasite transportation impacts are described in volume I, section 4.12. Impacts to the workers related to the past tritium accident are discussed in volume I, section 4.14. All potential accidents involving tritium were explored. Volume I, section 4.14, discusses the risk dominant accidents involving tritium.

RC: 12.028

Doc: PC-025/61

... Section 4.12.2. Since Table 4.12.1.1-1 does not balance, where are the impacts to storage activities in Zone 12 from pits, CSAs, and tritium?

Response:

These components are located on an interim basis within Zone 12. Pits and Canned Subassemblies are stored on an interim basis prior to transfer to Zone 4. Canned Subassemblies are also stored prior to transfer to the Y-12 Plant at Oak Ridge. Tritium reservoirs are stored in the Tritium Vault within Zone 12. Radiological impacts related to these activities are included both in the worker dose estimates and the accident risk evaluation provided in volume I, section 4.14.2.

RC: 12.029

Doc: PC-025/62

General question. What are the continuing impacts to transportation workers resulting from past tritium accident?

Response:

Exposures to plant personnel from the small amounts of tritium offgassing from the past tritium accident in Cell 1 are discussed in volume I, section 4.14, of this document. The total amount of tritium emissions are at the limit of detection. As a result, it is not possible to calculate doses and consequences to the non-involved workers and the public with high confidence levels. To the extent practicable, the dose to the public has been estimated to be less than 1.33 x 10-4 person-rem per year, resulting in a risk of 6.65 x 10-8 excess LCFs. Practically speaking, the maximum dose to an individual non-involved worker or member of the public would be effectively zero.

RC: 12.030

Doc: SG-003/3

Table S-1 in the Summary, under intrasite transportation, presents person-rem information (Summary page-18). The table is supported by Section 4.12 in the main text. An underlying baseline person-rem appears to be incorporated into the estimates for the Proposed Action alternative. Neither the main text nor the table clearly state the assumptions used. The person-rem shown for the Pit Storage Relocation alternative adds the estimated person-rem for pit storage relocation and the person-rem from the 2,000, 1,000, and 500 weapons levels under the Proposed Action alternative. Thus, while implementing the Pit Storage Relocation alternative, plant workers are assumed to receive the person-rem associated with the Proposed Action alternative. The radiation exposures for individual workers for the alternatives are within regulatory guidelines and do not have any public health significance....

Response:

The exposures associated with intrasite transportation under the Proposed Action are the results of weapons transfers, pit transfers after weapon disassembly, and pit transfers from the repackaging of 20,000 pits. The exposures associated with the Relocation of Pits Alternative are the results of the same activities as the Proposed Action plus the loading of either 8,000 or 20,000 pits for offsite shipment. 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 12,000 pits as part of the pit repackaging project.

RC: 12.031

Doc: SG-003/4

In the Pit Storage Relocation alternative, the amount of person-rem from the Proposed Action alternative appears to be added to what happens for pit storage relocation. How can one add the person-rem for these two alternatives? Is the same person-rem used two different times?

Response:

The exposures to the workers associated with intrasite transportation are the result of several activities (see response to comment 12.030). Only a couple of those activities will vary with, and therefore scale to, the different weapons levels. The transfer of weapons for disassembly and the transfer of pits after disassembly will vary according to weapons levels. The transfer of pits for repacking will not vary according to weapons level.

Since activities associated with pit relocation (e.g., intersite transfers, SST loading) and the Proposed Action (e.g., continued weapon storage and transfer operations) will be performed, the doses associated with these activities are added.

3.13 Waste Management

RC: 13.001

Doc: HT11/22

... Are [there] currently any waste by-products involved that result from the disassembling process?

Response:

For an elaboration on the response given at the public hearing, see the discussion in section 1.3.9 of this volume.

RC: 13.002

Doc: HT11/23

Any nuclear waste by-products or radioactive waste? And is that waste studied in this EIS?

Response:

For an elaboration on the response given at the public hearing, see the discussion in section 1.3.9 of this volume.

RC: 13.003

Doc: HT11/24

So are most of the by-products stored onsite at Pantex?

Response:

To elaborate on the response given at the public hearing, currently, low-level waste (LLW) is stored onsite prior to shipment and final disposal at the Nevada Test Site. All low-level mixed waste (LLMW) is stored in accordance with the Agreed Order & Site Treatment Plan-Compliance Plan, 30 TAC 335, the RCRA Part B Permit and 40 CFR 260-280. In 1994, Pantex Plant disposed of 32.6 cubic meters (42.4 cubic yards) of LLMW through an offsite commercial landfill located in Utah. In 1996, a second shipment of LLMW was disposed at the same facility totalling 70 cubic meters (91 cubic yards). In September 1996, a third shipment was disposed at the same facility. Volume I, section 4.13, Waste Management, presents the above information, including the updated information regarding the 1996 LLMW disposal shipment. Eventually all stored LLMW would be disposed offsite. See the discussion in section 1.3.9 of this volume.

RC: 13.004

Doc: HT02-09/2

What will the DOE and "We" do with all the waste that will be generated for at least the next 20 years? There are no licensed facilities to accept the wastes that are piled up on facilities throughout the DOE Complex at this timewhy generate more than needs to be generated.

Response:

DOE is considering programmatic waste management strategies for the next 20 years under the WM PEIS. The WM PEIS considers economic and environmental impacts including local, regional, and decentralized management strategies.

Pantex Plant, through a combination of successful pollution prevention and waste avoidance techniques (see volume II, appendix G), and offsite disposal of approximately 103 cubic meters (133 cubic yards) of LLMW, has reduced the "piled up" inventory equivalent to the volumes generated during 19921995. Further reduction is expected in fiscal year 1997.

RC: 13.005

Doc: HT02-04/3

Pantex, the Superfund site, is currently operating under no [discharge] permit with the State of Texas.

Response:

See discussion in section 1.3.9 of this volume regarding past practices.

RC: 13.006

Doc: HT13/84

Reference page 6-4 in the draft where it talks about permitting, specifically permitting at Manzano if pit storage was done...I have several questions related to that. Has...the Department of Energy had discussions with the New Mexico Environment Department about what kind, if any, of permit modifications would be needed if the pit storage was done at the Manzano site?

... Does the Department have a position about whether pit storage would be subject to a RCRA permit at Manzano or any other site?

(Ms. Founds: Since this is not waste or surplus material, it would not be part of a RCRA permit.)

Reference page 6-4,...in the discussion...about permit requirements and the fact that Kirtland has an existing permit. It says that new permits or permit modifications could be required. Would you explain that statement in relation to the statement that you just made, Nan?

So will the final EIS have a clear statement about what RCRA permitting requirements the Department feels will be necessary at Manzano or any other site from a RCRA standpoint?

Just as a follow-up to complete the loop, and I have primarily been talking about the Manzano site, but the question really relates to that I was surprised that the draft singles out Kirtland for that on this page. The Pantex site, of course, also has a permit, so the question is, is the similar waste stream modification, to use your term, or waste stream results, would that be included at any site that had a RCRA permit?

To make sure I understand, you are saying that the existing Pantex Part B permit covers storage of 20,000 pits at Pantex?

RCRA waste might result from those kinds of operations, but that is not saying those are RCRA-type waste.

Response:

There are several reasons the New Mexico Environment Department may require RCRA permit modifications for both DOE and the Air Force. Since the Manzano Weapons Storage Area (WSA) has several Air Force Solid Waste Management Units as defined under RCRA, the responsibility for investigation, cleanup, and closure of the SWMUs would likely continue under Air Forces RCRA permit. However a language modification might be required that any new SWMU resulting from a DOE activity would be DOEs responsibility. The Manzano WSA is not currently DOE property (see 40 CFR 270 criteria), language addressing the Manzano WSA would likely be added to the DOE RCRA Part B permit and the Air Force RCRA Part B permit. New Mexico Environment Department is likely to consider these changes as Class 1 modifications covered under 40 CFR 270 to assure integration of the Kirtland Air Force Base and DOE permits. In addition, see discussion in section 1.3.9 of this volume regarding permit requirements.

Clarifying language has been added to volume I, section 6.5.

RC: 13.007

Doc: HT13/85

To follow up on that helpful comment, is there a document that exists that describes that analysis that you just gave?

My comment would be that prior to the time of the final, I would hope there would be some written-down analysis that would be either included in the EIS or referenced in a supporting document reference that provides this explanation that has just been made, because I dont see it in page 6-4 in the way I read it, and certainly, there is no document...or documents referenced on that page that provides that information.

Response:

See discussion in section 1.3.9 of this volume regarding permit issues. Clarifying language has been added to volume I, section 6.5, with a source.

RC: 13.008

Doc: HT12/36

Public Speaker: I have a comment. Its a crosscutting issue, it should be brought up in each one. Im past chair of the CSRA Planners Group.... The State of South Carolina is concerned with any new project coming into the area if Yucca Mountain doesnt [come] about. And that really has to be addressed strongly. And Ive heard it from folks in the governors office and folks in the area around here that before we can have any of these, that issue should be solved at the policy level, like somebody [mentioned]...

Unidentified Speaker: Of States concern of moving additional operations here with South Carolina?

Public Speaker: Without their feeling that they will be a dumping ground.

Unidentified Speaker: Okay.

Public Speaker: And that Yucca Mountain should be the dumping ground or whatever, but...the issue is, lets not have it stop here. ...Each one of these projects should be looking at the waste issue and even DWPF is not supposed to have its glass containers stay here. So thats something that has to be stressed somewhere as a crosscutting issue. I know its not unfamiliar with [you].

Response:

See discussion in section 1.3.9 of this volume regarding hazardous materials.

RC: 13.009

Doc: CO-003/1

The acceptance of plutonium at Hanford should not delay, defer, or negatively impact Hanford cleanup.

Response:

See discussion in section 1.3.9 of this volume regarding hazardous materials.

RC: 13.010

Doc: PC-019/1

Enclosed is another problem associated with the plant pointed out by Amarillo Globe News. (Globe News, Article, "City Wont Search For Contaminated Glove," May 24, 1996.)

Response:

The specific issue referred to in the article is considered an isolated incident. Pantex Plant has resolved the issue with the City of Amarillo and the State of Texas.

RC: 13.011

Doc: HT16/32

...the hazardous waste permit 51289 [that] is issued by the TNRCC and mentioned on Page 4-189, the comment...should be amended because the brand new permit became effective February 16th, 1996. ...Section 4.13.1.3 on Page 4-79, some of the units identified in the third paragraph have now been closed and youll probably want this reflected in the EIS. On Page 4-147 and 148, these paragraphs should be reviewed by the low-level mixed waste team for updates on the current waste inventories, waste plans, and waste activities. Also, discussion of MTUs may need to be revised on these pages. ...weve issued the agreed order, site conception. Its an agreed order issued October 2nd, 1995 concerning mixed waste. Im not sure thats fully reflected in the EIS.

Response:

Clarifying language has been added throughout the EIS regarding approval of the Class 3 modification dated 2/16/96 and the relationship with the Agreed Order. The offsite disposal of low-level mixed waste has been updated. Another change included deletion of volume I, table 4.13.2.21, with the salient information being incorporated in the text.

RC: 13.012

Doc: HT16/34

...on Page 4-197, first column, first full paragraph, when you describe: In Zone 4, two magazines, eight permitted conex boxes and 25 conex boxes are used for storage of low-level waste. I think I understand that better now. It was very confusing to me when I read it. So eight of the conex boxes are permitted and the other 25 are just the surge capacity thats been added without any permitting process?

Response:

As a result of the recent Class 3 modification dated 2/16/96, clarifying language has been added throughout the EIS, including section 1.3.9 of this volume.

RC: 13.013

Doc: HT16/35

Theres a sentence in the middle of that paragraph that says: Stormwater discharge associated with industrial activities is discharged to the playas on site. I dont know what that means. Can you help me there? I didnt know that stormwater discharge was used in industrial activities.

Response:

The phrase "Stormwater discharge associated with industrial activities" is regulatory language contained in the National Pollutant Discharge Elimination System (NPDES) permit. The sentence was simplified to read "Stormwater drains to the playas onsite."

RC: 13.014

Doc: HT16/36

...on Page 4-204 where you do your cumulative thing with the PEISs again for the disposition alternative. You list the types of wastes that will be involved in that alternative. And even though a reactor, a nuclear reactor, is kind of the bounding case there, theres no high-level waste mentioned in category of waste that will be generated under that option. I think maybe you may need to add high-level waste or spent fuel storage or something thats going to be impacted under that.

Response:

Commentor is correct. The clarification has been added to volume I, section 4.13.5.

RC: 13.015

Doc: HT16/37

...since the contested case hearing negotiations got mentioned, in the settlement agreement there was a much appreciated and significant commitment on the part of the DOE to at least examine one alternative to the burning grounds, an alternative method of incineration of those wastes. Its not mentioned in this document. It should be.

Response:

Additional language examining the continued study of an alternative disposal method has been added to volume I, sections 1.2.2 and 4.13.1, and volume II, appendix G of the EIS.

RC: 13.016

Doc: HT16/38

It says new facility construction and upgrades are not expected to impact waste operations. One of the things that I have a concern about in this document is the pit conversion and reuse facility, one of the two new facilities that are covered by this document, which we dont seem to learn a great deal of detail about, in terms of what it generates in waste streams, et cetera. And, when you went through this viewgraph, I seem to infer from what you said that this statement was based, in part, on new facilities, I assume waste handling facilities, that had been built on site. And so Im asking you, is my concern a basis of definition of what impact is or what? I mean, how [do] we bring these kind of broad blanket assumptions back into a document where youre talking about dust particles when you do construction and then you assert that theres no impact. ...I mean, how do we relate this broad assertion to the fact that we have new plutonium handling functions that are going to come onto the plant in this document in this new facility and we have new kinds of hazardous waste operations that are coming on the plant with the other new facility? How can we say that that has no impact?...if youre talking about negative impact as opposed to impact, its not accurate to say that it has no impact. Maybe your assessment is that none of it is a negative impact. Is that an accurate interpretation?

Response:

To elaborate on the response given at the public hearing, the impacts of new facility construction and upgrades on waste management are discussed and analyzed in volume I, section 4.13.2, and volume II, appendix H, including the Pit Reuse Facility. The six projects presented in the EIS are the Hazardous Waste Treatment and Processing Facility, Pit Reuse Facility, Gas Analysis Laboratory, Material Compatibility Assurance Facility, Nondestructive Evaluation Facility, and Metrology and Health Physics Calibration and Acceptance Facility.

As described in volume II, appendix H, the Pit Reuse Facility operations are limited to casing enhancements, cleaning, weighing, radiographing, leak checking, inspection, and backfilling. These activities are not considered plutonium processing or reprocessing. Plutonium processing and reprocessing are not within the scope of the Pantex Plant EIS (see the Stockpile Stewardship Management PEIS).

RC: 13.017

Doc: HT16/41

On the Federal Facility Compliance Act, this was being drafted when this draft document was made. And the document says that the impact of this is...unknown at this time. I want to know if theres been an update on this or will...there be more information forthcoming?

Response:

As discussed in section 4.13, Waste Management, the Federal Facility Compliance Act Final Site Treatment Plan was approved by TNRCC in September 1995, and an Agreed Order was issued October 2, 1995. In addition, the tri-party Federal Facility Agreement (FFA) continues to be negotiated (as of September 1996) regarding restoration activities. As discussed, impacts of an FFA remain unknown. Updated information has been incorporated in volume I, section 4.13.

RC: 13.018

Doc: HT17/68

...its been pointed out several times that this document intentionally didnt try to deal with the permits that have been issued between the time that the document was being written. The concern that I have, however, is...that it be explicitly stated, not just in a chart showing the duration of the permits, but explicitly stated that the permits that were talking about here, the existing permits that you will be talking about, will all...need to be renewed, revised [again] during the ten-year time frame of this document.

Response:

DOE understands that the permits routinely undergo revision or renewal during the EIS timeframe. Volume I, section 4.13.1, presents the Pantex Plant permits, including effective date and expiration dates. Should renewed or modified permits result in NEPA related compliance issues, DOE will address those issues at that time. As indicated in volume I, section 4.13, Pantex Plant successfully renews and modifies existing permits, as necessary.

In addition, see general discussion in section 1.3.9 of this volume regarding permits.

RC: 13.019

Doc: SG-012/1

Some of the actions appear to (potentially) be in conflict with NMED laws and regulations.Vol. I, page 6-4, 6.5 Pit Storage Sites, under the paragraph referring to Kirtland Air Force Base. The U.S. Department of Energy (DOE) must be in compliance with the Federal Facility Compliance (FFC) Order issued by New Mexico under the provisions of the Federal Facility Compliance Act. The FFC Order has jurisdiction over generation and storage of mixed waste and site treatment plans for its disposition (p. 5-60, 5.5.10 Waste Management, "The pit storage operations would generate less than 1 cubic meter (1.3 cubic yards) of mixed, low-level, and hazardous wastes.")

Response:

Clarifying language has been added to volume I, section 5.5 and chapter 6.

RC: 13.020

Doc: SG-012/2

Mention of the New Mexico unilateral FFC Order is not included in table 6.5-4.

Response:

The New Mexico unilateral Federal Facility Compliance Order was added to the table.

RC: 13.021

Doc: FG-003/2

EPA suggest that Appendix G should reference the requirements of Executive Order 12902, Energy Efficiency and Water Conservation at Federal Facilities (March 8, 1994), particularly for the six new construction projects at Pantex listed in table 3.1.1.1-1 (gas analysis laboratory, materials compatibility assurance facility, etc.). Section 306 of Executive Order 12902 contains specific requirements regarding the construction of new facilities owned by the United States. Additionally, the Final EIS would be strengthened if it could discuss whether this Executive Order has any implication on the proposed interim storage of plutonium pits in Nevada, South Carolina, New Mexico, and Washington State in terms of energy and water conservation.

Response:

Additional information has been added to volume II, appendixes G and H regarding Executive Order 12902. For the purpose of bounding the NEPA analysis, current levels of energy and water consumption were used to compare alternative site impacts. The actual design of the proposed facilities includes an energy conservation analysis with life cycle costing.

RC: 13.022

Doc: PC-025/4

On Page 1-16 in column two in the first paragraph. What is the definition of abnormal? Is the chance of a similar accident greater than 1 in a million? If not, I would argue with DOE risk numbers that the incident is not abnormal. For consistency use risk assessment language for "abnormal." "Abnormal" means nothing. Use unlikely, extremely unlikely, etc. If this incident occurred, what calculations prove the event is abnormal? What number of similar operations were completed before the event occurred? How do you justify orders of magnitude difference between theoretical and actual experience, if one exists? Why does the WM PEIS identify Pantex as a TRU waste generator (see appendix) if Pantex is "Abnormal?"

Response:

The statement "Pantex currently is custodian of significant volumes of LLMW, LLW, and TRUW," found on page 12-1 of volume II of the Draft Waste Management PEIS is incorrect. Pantex Plant currently manages three drums of TRU waste as discussed in volume I, section 4.13.1.

The phrase "generated from an abnormal weapons dismantlement incident" has been deleted.

RC: 13.023

Doc: PC-025/63

See section 4.13. Why only to 1994 for data? DOE reports annually, correct? Status of permit modification? What impacts are expected? What is status of EPA CERCLA negotiations?

Response:

Updated information has been incorporated in volume I, section 4.13. This includes adding 1995 data to Table 4.13.1.21. The 1996 shipment and disposal of low-level mixed waste to Utah has been incorporated. Impacts were reevaluated based on the updated information and presented in volume I, section 4.13.2. The permit modification was approved on February 16, 1996. The EPA Comprehensive Environmental Response, Compensation, and Liability Act negotiations are continuing.

RC: 13.024

Doc: PC-025/64

Table 4.13.1.2-2. Why no margin for ER wastes? ER wastes are the most unpredictable!

Response:

A 10 percent margin has been added to environmental restoration waste volumes.

RC: 13.025

Doc: PC-025/65

Table 4.13.1.1-2. In SSM and S&D, the number of burning ground facilities is expected to be reduced to one. Are the 9 trays and 3 pans expected to be closed in the near future like the cages and pits?

Response:

The Stockpile Stewardship Manangement PEIS and Storage and Disposition PEIS look at environmental impacts through 2055. On February 16, 1996, TNRCC approved a Class 3 modification which identifies DOEs operational needs for 9 trays, 3 pans, and 3 flash pads. The permit also identifies the need for these facilities through 2100, the expected year of final closure. The former flashing pits and cages are no longer operational and are undergoing RCRA closure per the permit. The RCRA closures are expected to be completed by fiscal year 1997.

RC: 13.026

Doc: PC-025/68

In sections mixed waste and hazardous waste on page 4-193. Where is all the explosive burning waste noted in section 4.7 and table 4.13.1.1-2?

Response:

For the purpose of NEPA analysis, waste categories (e.g. LLMW, HW, etc.) were used to assess waste management impacts. The commentor is referred to the Pantex Environmental Information Document for detailed waste stream information.

RC: 13.027

Doc: PC-025/69

Page 4-199. How accurate is the 1.45 factor? Why doesnt table 4.13.2.2-1 contain a margin?

Response:

The 1.45 factor represents the best available information. Table 4.13.2.21 of volume I has been deleted as noted in response to comment 13.011.

RC: 13.028

Doc: PC-025/70

Page 4-202. 14,000 LLW shipments over 20 years? Thats 700 a year, almost 3 shipments a week not including weekends. Is DOE hiding waste at Pantex, the numbers presented in tables 4.13.1.2-1 through -3 dont show this to be true? DOE is considering a landfill for at most 2,500 cubic meters over 10 years. Thats stupid! Why dont you landfill the NHW around 13,000 cubic meters over 10 years, 18,000 shipments of HW over 20 years? Thats 900 a year, almost one shipment every day not including weekends. Is DOE hiding explosive wastes? DOE should think about a hazardous waste landfill for the 2,000 cubic meters over 10 years.

Response:

Volume I, section 4.13.5.1 has been completely rewritten. The WM PEIS information has been updated to reflect reduced waste volume projections.

RC: 13.029

Doc: PC-027/4

Reference page 6-17, volume I Main Report, Column Potential Applicability/Permits: The word "permit" was omitted from this page on New Mexico while it appeared in the South Carolina page 6-14 and the Texas page 6-12. I know that water permits are required for businesses and individuals and would assume that a government entity should also comply with the permit requirements, especially since this State has severe water problems. The word "permit" should be added for those New Mexico areas where a permit is required. I realize that laws differ from state to state, but there are some areas where permits are required here.

Response:

The table has been corrected to include the word "permit".

RC: 13.030

Doc: SG-003/38

Regulatory Oversight - The TNRCC would be more willing to embrace Pantexs mission within the State of Texas if DOE would promote independent regulatory oversight for radioactive source, special nuclear, or by-product material. We applaud DOEs willingness to share its information concerning radioactive contaminants; however, it is our opinion the public would be better served and potential waste management errors minimized if the oversight authority was shared with the TNRCC.

Response:

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 a Working Group on External Regulation. This Working Group is presently reviewing various alternatives for external oversight of activities at DOEs nuclear facilities and will submit a report sometime in 1996.

RC: 13.031

Doc: PC-030/2

DOE should move with all possible speed to cease using the Burning [Ground] for waste management at Pantex.

Response:

The Pantex Plant continues to implement a Pollution Prevention/Waste Minimization Program to reduce environmental impacts through waste avoidance and waste minimization. Appendix G of volume II contains detailed information of the PP/WM Program. As discussed in volume II, section G.3.2, Pantex Plant, in 1994, as a result of a new procedural control reduced HE-contaminated hazardous waste by 99%. As discussed in volume II, section G.3.8, in March 1994, a formal literature search was conducted to investigate treatment/processing methods for HE other than open burning-open detonation. The Best Available Control Technology (BACT) analysis concluded that controlled open thermal treatment with existing administrative controls constituted BACT. The alternatives were determined to be either technically infeasible or economically infeasible.

However, as part of the Pantex Plant continuing effort to reduce pollution and minimize waste, DOE continues to study potential alternatives to open burning of energetic materials at the Pantex Burning Ground (e.g., commercial resale, base hydrolysis treatability study). This additional information has been incorporated in volume I, section 4.13, and volume II, appendix G.

RC: 13.032

Doc: PC-033/1

Page S-6, col. 1, par. 1: It states that "Pantex also generates and manages recyclable materials." What are these [materials] and where are they recycled to? Do these include the various barrels of miscellaneous bolts and nuts that are sold at auction or to salvage what the general public can purchase? These barrels have been known to contain various parts that are far from nuts and bolts and are apparently parts of disassembled weapons and other confidential tags and various seals included in these barrels of supposedly recycled materials that I have been told by plant employees are confidential makeup and design. How did these materials make it into a barrel of miscellaneous bolts and nuts at a salvage yard and what are the procedures for recycling these bolts and nuts? Can any individual purchase these, and if so what is to keep them from copying the design and makeup of these parts?

Response:

Volume II, appendix G, addresses the current status of Pantex Plants Pollution Prevention and Waste Minimization program. Scrap metal or "nuts and bolts" can be recycled and are recycled through various outlets depending on the value of the metal. In some cases due to liability concerns scrap metal is only sold to operators of smelters to ensure the "nut and bolt" is melted down.

The materials contained in weapon components in whole or in part are routinely recycled. In cases were the weapon components are classified (i.e., contain information subject to Atomic Energy Act regulation) or have the potential for military-proliferation value, Pantex Plant is required by law to demilitarize and sanitize (D&S) weapon components. Examples of D&S processes are presented in volume I, section 1.2.2, Disassembly of Nuclear Weapons. After the D&S process, the resulting materials can be recycled. The Pantex Plant uses written procedures for identifying weapon components requiring D&S, D&S processes, and releasing of D&S materials. Volume II, table G.3.71, in appendix G of the EIS, shows that 41 metric tons of "weapons metals" have been recycled with a salvage value of 2.1 million dollars.

3.14 Human Health

RC: 14.001

Doc: PC-018/1

There are over 1 million people living in this area. All of the above would be in danger of contamination if an accident did occur at Pantex.

Response:

The Pantex region of influence (ROI) for potential accidents includes an 80-kilometer (50-mile) radius surrounding the plant. An ROI with a diameter of 80 kilometers is the usual ROI for accident analyses in NEPA documents and Safety Analysis Reports. The population in the Pantex ROI is estimated at 267,107 persons. A representative range of accidents including accidents that could result in the release of nuclear materials to this population has been evaluated in this EIS. The impacts from potential accidents at Pantex Plant to people in the area including the risk from contamination are discussed in volume I, section 4.14.

RC: 14.002

Doc: PC-009/1

My question relates to DOE/EIS-0225D, Page 5-12, second column, second paragraph, line 6. The document states starting at line 5: "With an additional 0.11 LCF from pit handling, the total risk of *latent cancers among workers at the P-Tunnel would increase by 1.8 percent."

All references to latent cancers in that section titled "Impacts of Storing 20,000 Pits", refer to LCFs, latent cancer fatalities, except line 6 as indicated above by a "*". Does the increase of 1.8 percent refer to "latent cancers" as it states, or to "latent cancer fatalities" as the rest of the section would seem to imply.

Response:

The commentor is correct. The increase refers to latent cancer fatalities, not latent cancers. The text has been revised.

RC: 14.003

Doc: HT11/1

... How many years is this [plutonium] considered to be actually hazardous waste?

Response:

To elaborate on the response given at the public hearing, plutonium in pit form is not considered a hazardous waste. Weapons-grade plutonium is made up largely of plutonium-239, which has a half-life of approximately 24,000 years. After 24,000 years, one half of the plutonium will still be present. The standard calculation is that 10 half-lives or 240,000 years are required before all of the plutonium is decayed. Whether the plutonium is hazardous depends on its location relative to human receptors.

RC: 14.004

Doc: HT11/2

... If the half life is 24,000 years, wouldn't the actual hazard be much longer than that?

Response:

See response to comment 14.003.

RC: 14.005

Doc: HT11/3

What was the consideration of the maximally exposed individual?...[From] 6.6 rem, which I assume is the forklift driver or whoever punctures this thing,...we go all the way down...to the public exposure.... Public exposure would not be safe 100 milligrams per year, and I was wondering how we went from one number to the other just like that?

Response:

To elaborate on the response given at the public hearing, the involved worker (forklift driver) is estimated to receive 6.6 rem of dose commitment when a pit is punctured. This dose commitment is over a 50-year period due to the inhalation of plutonium oxide dust released during the forklift accident. The amount of plutonium oxide released is about 0.6 milligrams. This release is then transported and dispersed by the wind. An individual at the site boundary would also inhale some of the plutonium dust if located directly downwind from the release. The dose commitment that the maximally exposed offsite individual receives is much less due to dispersion and deposition of the plutonium dust during its movement from the release point to the site boundary.

RC: 14.006

Doc: HT11/4

And that [maximally exposed individual] person is really the person hanging around for 24 hours a day?

Response:

To elaborate on the response given at the public hearing, the maximally exposed individual is a hypothetical person who is assumed to be at the site boundary for 24 hours a day.

RC: 14.007

Doc: HT02-02/2

It may be safer than other sites, but we can prove that accidentsat least I hope the incidents that have affected us personally were accidentshave happened that [have] endangered our property as well as our personal safety and others in the neighborhood of Pantex Plant.

There have been numerous major fires on the site, three of four within the past two years. We took cold drinks and ice to the firemen on various occasions. We have had cast steel shrapnel chunked at us. We have picked up some 300 to 400 pounds of a naval breech block, one piece weighing 59 pounds. Some of this shrapnel was found some one and one-half to two miles from where it was exploded. We have had tractor tires ruined from it.

Through the years, we have had windows broken, pictures knocked off walls, et cetera. On October 4, 1995, a very large charge of explosive was set off to signal the start of an emergency management drill. This drill "test" broke our house, cracked the slab, rafters, walls, brick, shower, plumbing causing flooding of the basement, and other damages resulting in some $30,000 in repairs and replacement of carpets and other floor coverings, rebuilding the shower, cracks, et cetera. We also must have the house leveled.

Too many questions are yet unanswered by the studies that have been conducted. Granted, it would be impossible to anticipate all potential problems that may arise, but there does seem to be a lack of scientific research used for the study. It would appear that a conclusion has been drawn and figures to support that conclusion were used without any real scientific information.

Response:

Incidents or accidents occur at all active industrial plants and Pantex Plant is no exception. However, there have been no accidents at Pantex Plant which have endangered personal safety of the public in the plant vicinity. DOE is committed to the safe operation of Pantex Plant, as well as the protection of the public, the environment, and the facility employees.

Grass fires were considered as part of the EIS risk assessment. The specific examples mentioned in the comment were fires which were contained onsite and posed no threat to Pantex operations or offsite property.

With respect to the Naval breech block event, that was a one-time experiment (almost 30 years ago) which is now precluded from reoccurrence by administrative limits and procedures.

The analysis conducted for the EIS was done according to CEQ and DOE guidance in using the best information available and nationally accepted methods and models.

RC: 14.008

Doc: HT05/11

Could you speak more toward the latent cancer fatality issue... and discuss what is the most likely outcome?

If that's the actual expected...outcome, why isn't that put into your statement as the most important?

In other parts of the document, you indicate that the most likely outcome is zero cancers.

Well, I'm saying is you explain this in two different ways in your document. In this shorter version that you've put here in the narrative summary, you appear to attach some greater certitude to potential cancer risks than you do in the other sections, especially in the appendix, where you indicate that the most likely outcome is zero cancers.

And I'm saying, for purposes of explaining this to the community, the more appropriate explanation would be to indicate that the most likely outcome is zero cancers.

Response:

This discussion regards the interpretation of calculated risks from radiological exposures, for example, 0.13 cancer fatalities from an exposure of 330 person-rem. Further clarification of the interpretation of the calculated risks has been provided in the form of a discussion in section 1.3.10 of this volume.

RC: 14.009

Doc: HT05/12

Under the statement he was referring to, it said shipment of pits to an alternative site would increase radioactive exposure of the Pantex Plant by 113. Why would it increase if the pits are shipped to an alternative site?

Response:

The offsite shipment of pits from Pantex Plant would require the removal of the pits from the Zone 4 magazines and the loading and the restraining of pits within a Safe Secure Tractor Trailer vehicle. The performance of these activities will increase the worker exposure total.

RC: 14.010

Doc: HT05/13

What is the underlying base assumption of man-rem or person-rem exposure that you have ascribed to ongoing site work at the 500, 1,000, and 2,000 levels such that you would be able to extrapolate from these numbers exactly what is the base amount that you say they're going to get, irrespective of the number of weapons that they're working?

... I've tried to deconvolute your calculations and I can't do it.

As the person who supplied that data from the Pantex Plant, I'm not able to follow your calculations, nor do I see them stated anywhere in the documents.

I cannot extrapolate where there's a base of what they used to build up on some of these numbers when they compared from site to site. There are some assumptions that were made that are not stated when they made the calculation on what might happen, especially when you start looking at making movements to alternative sites.

... I want some additional information [in the EIS] on the assumptions that were made in reaching these calculations, such that someone reviewing it, not having the opportunity to speak to [authors of the document], could also see if their pencil-whipping of the data would be the same as his.

Response:

This discussion regards the dose estimates for the Transportation and Staging Department provided in volume I, section 4.12, Intrasite Transportation. The commentor requests clarification on why the estimates for worker exposures do not scale to zero for a weapons activity level of zero. The reason that this is not the case is because the dose estimates also include impacts related to interzone pit shipments required for the pit repackaging project. Thus, even at a hypothetical zero weapons activity level, there will still be worker exposures from pit transfers. Further clarification of this issue is provided as a discussion in section 1.3.8 as well as in volume I, section 4.12.

RC: 14.011

Doc: CO-008/38

Page 4-205, Paragraph 4 Exposure from inhalation is the only pathway assessed in Pantex SWEIS. Please discuss exposure through other pathways such as water, soil, and vegetation.

Response:

Additional alternative pathway discussions have been added to volume I, section 4.14.

RC: 14.012

Doc: CO-008/39

Page 4-208, Paragraph 2. Internal exposures, received when radioactive materials are deposited through inhalation, ingestion, absorption, are considered minor contributors to worker doses, therefore are not considered in this document. Please define "minor."

Response:

Historical evidence of external and internal exposures at Pantex is presented in the Pantex Plant Safety Information Document (Pantex 1996a). These exposures show that the internal exposure received by workers is typically a factor of 100 to 1000 less than the external exposure received by workers. The two to three orders of magnitude difference between these exposures is why it is considered to be a minor contributor to worker exposures.

RC: 14.013

Doc: CO-008/40

Page 4-207, Paragraph 2. Please list improvements/changes in work practices and scope that have been implemented to significantly reduce worker external exposure?

Response:

The As Low As Reasonably Achievable (ALARA) program implemented at Pantex Plant minimizes radiation exposure during performance of all radiological operations. Plant management and the Radiation Safety Department are constantly seeking ways to reduce exposures. As recently as January 1, 1996, exposure limits were reduced from 1 rem/yr to 900 mrem/yr for manufacturing personnel and 500 mrem/yr for the general plant population.

RC: 14.014

Doc: CO-008/41

Page 4-207, Paragraph 2. Please discuss the cumulative effects from radiological exposure, hazardous chemical, toxic releases and emissions on individual workers and the public population.

Response:

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.

Additionally, a useful measure of potential human health effects resulting from exposure to a combination of non-carcinogenic chemicals is the hazard index. Volume I, section 4.14.1.2, describes the basis and the evaluation of the hazard index for Pantex Plant. The hazard index calculation indicates that no adverse health effects are expected.

RC: 14.015

Doc: CO-008/42

Page 4-208, Paragraph 6. "Effects Screening Levels (ESLs) may be unrealistic, to state that none of the chemical concentrations exceed ESLs, therefore they are not expected to have adverse health effects to members of the public." What is the basis for this statement, when synergistic effects have not been evaluated?

Response:

See response to comment 14.014.

RC: 14.016

Doc: CO-008/43

Page 4-209, Table 4.14.1.2-1. Why are there no standards for 5 pollutants resulting from Plant sources in Table 4.14.1.2-1?

Response:

At the time the Draft EIS was produced, TNRCC had not established standards for the fixed pollutants. Since the publication of the Draft EIS, the TNRCC has published standards for Trichloroethylene and for Ketones. Volume I, Table 4.14.1.2-1 has been updated to reflect the new standards.

RC: 14.017

Doc: CO-008/44

Page 4-210, Table 4.14.1.2-1. The table lists significantly higher ESLs for several contaminants, i.e., MIK, and MEK. Please correct the inconsistencies from the table on page 4-209.

Response:

Page 4-210 was a continuation of table 4.14.1.2-1 in the Draft EIS, which began on page 4-209. The ESLs presented in volume I, section 4.14 are specific to each pollutant and are consistent with those presented in Table 4.7.1.3-4.

RC: 14.018

Doc: CO-008/45

Page 4-210, Table 4.14.1.2-1. Please address latent cancer probability resulting from releases and/or daily operations emissions. Describe cancers not linked to radiological exposures.

Response:

The radiological emissions from normal operations are described in volume I, sections 4.14 and 4.7. Modeling has shown that the doses to the public from these releases is small (6 x 10-5 mrem/yr for a maximum offsite individual from Pantex Plant sources compared to 334 mrem/yr from natural background radiation). This dose is considered a negligible individual dose by the National Council on Radiation Protection and Measurements. The yearly cancer risk from this exposure is estimated at 3 x 10-11. When compared with the baseline cancer risk in the vicinity of the Pantex Plant (1.7 x 10-3 per year), an individual has a much greater likelihood of incurring a cancer from sources other than Pantex Plant related emissions (e.g., from genetic predisposition, chemical exposure, diet, stress, and other sources of pollution). Cancer mortality statistics for the State of Texas are available in the Pantex EIS public information center.

The risk of cancer from chemical exposures to a hypothetical offsite individual is discussed in volume I, section 4.14. A hypothetical individual living at the plant boundary would have an increase in lifetime fatal cancer probability of 1.2 x 10-5 from exposures to carcinogenic chemicals released from Pantex Plant.

RC: 14.019

Doc: CO-008/46

Page 4-215, Paragraph 2. The June 1994 study by the Texas Cancer Registry, TDH, focused only on cancers of the breast, prostate, brain, thyroid, and leukemia. Other radiation-associated cancers, such as bone and lung were not included. Why? What about other types of cancers? Please include or justify other types not included.

Response:

The referenced health study was performed solely by the State of Texas. However, discussion with Mr. Barry Wilson of the Texas Department of Health, Cancer Registry Division indicated that the "Study of Cancer in Selected Counties Near the Pantex Nuclear Weapons Plant" (TDH 1994) report was performed "because of a request from environmental groups and media attention." The cancers studied were specifically requested by these groups.

RC: 14.020

Doc: CO-008/47

Page 4-215, Paragraphs 3 and 5. The epidemiologic study (Acquavella 1985) and the follow-up study conducted by NIOSH only looks at mortality ratios. Is there an on-going health surveillance, either mortality or incidence, for ex-workers of Pantex?

Response:

See discussion in section 1.3.10 of this volume regarding a planned follow-up study.

RC: 14.021

Doc: CO-008/48

Page 4-215, Paragraphs 3 and 5. Cancer is the only health issue addressed. What about all other health problems associated with nuclear and HE materials processes? Please explain.

Response:

The risk of latent cancers is consistently the major endpoint for mortality associated with nuclear and high explosive (HE) materials processes. The reasons for this focus include:

· Chemical hazards and impacts are analyzed in volume I, section 4.14 and are found to be small.

· Mortality from diseases other than cancer has not been consistently or significantly increased by radiation in human populations (BEIR V) (NAP 1990).

· Occupational dose limits (both for chemicals and radionuclides) are set such that deterministic effects (effects other than cancers) will not occur among adults if the dose limits are not exceeded (ICRP 1983).

· Genetic damage to worker progeny is not expected at exposure levels experienced at Pantex Plant (ICRP 1991).

· The maximum exposures to offsite individuals from potential accidents are not severe enough to cause deterministic effects (ICRP 1983).

RC: 14.022

Doc: CO-008/49

Page 4-216, Paragraph 2. The yearly incidence rates (refer to work place injuries) measuring Pantex safety programs compares Pantex to national industries. Is this a likely scenario? Why?

Response:

The frequency of workplace injuries provides clear indication of the severity of hazards encountered by the workforce at Pantex Plant as well as the viability of Pantex Plant workplace safety programs. The frequency of work place injuries at Pantex Plant compared to other industries provides a relative comparison both between the severity of hazards encountered at these different workplaces and the viability of workplace safety programs.

RC: 14.023

Doc: CO-008/50

Page 4-217, Paragraph 2. This paragraph states that a fire limited to the interior of a facility would only cause internal releases in the room of the fire. Where would those internal releases eventually go? Wouldn't they have to go external? Please explain.

Response:

As stated in volume I, section 4.14.1 high efficiency particulate air filters installed on ventilation system exhaust ducts will limit the amount of particulate radionuclides released to the environment.

RC: 14.024

Doc: CO-008/51

Page 4-218, Paragraphs 1 and 3. When and how will OSHA regulation of worker health and safety be implemented? What will the reporting mechanisms be?

Response:

The DOE and Occupational Safety and Health Administration (OSHA) have agreed to a temporary pilot project to facilitate the shift of worker protection to OSHA. Under a temporary pilot project agreed to by the two agencies, OSHA will regulate and oversee worker health and safety at the Argonne National Laboratory in DuPage, Illinois. During the pilot, OSHA will evaluate the current safety and health program at Argonne and respond to employee complaints.

Information obtained during the Argonne pilot project is expected to help the two agencies determine the resource needs of OSHA if it is to ultimately assume responsibility for worker safety and health at DOE facilities. While OSHA regulates and enforces worker health and safety at industrial and some government workplaces, current law exempts most DOE facilities from external regulation and enforcement. DOE internal regulations do, however, require all facilities to meet current OSHA standards.

RC: 14.025

Doc: CO-008/52

Page 4-218, Paragraphs 1 and 3. "DOE contractor operations at Pantex expose workers to hazardous constituents." Are workers fully aware of these exposures and of the combined effects to human health? Discuss in detail how workers are prepared for these exposures, consequences, and effects.

Response:

All hazardous materials at Pantex Plant are required to have a Materials Safety Data Sheet (MSDS) that describes the hazards of the material and the proper packaging, handling, and disposal of this material. All Pantex Plant employees are required to attend a hazards communication training course which trains them to read and interpret hazardous material labels and how to use an MSDS. Workers involved with specific activities such as hazardous chemicals, high explosives, and radioactive materials receive additional job-specific training.

RC: 14.026

Doc: CO-008/53

Page 4-218, Paragraphs 1 and 3. Daily routine emissions are not reported to the public. Shouldn't workers and the public be made aware of these routine emissions for human health reasons and environmental consequences?

Response:

Daily routine emissions are reported in volume I, section 4.14.2 for radiological emissions and volume I, section 4.7.1 for hazardous chemical emissions. Responses to comments 14.025 and 14.027 describe hazard communication with workers. Documents such as this EIS and site environmental reports provide hazard communication with the public.

RC: 14.027

Doc: CO-008/54

Page 4-219, 4.14.2.1. "The continuation of weapons-related operations at Pantex would result in the continuation of radiological exposure to plant workers." Have these workers been made aware of these health hazards? Do their families know the consequences of these health effects to themselves, also?

Response:

Radiological workers are required by federal law (10 CFR 835) to receive radiological worker training. Radiological workers are required under article 835.902 to be trained to ensure familiarization with the hazards they will encounter in the workplace. Uninvolved family members will not be exposed to radiation as a result of another family members employment at Pantex Plant. DOE is required to provide periodic reports to personnel of their individual dosimetry readings. This keeps workers informed of the level of exposure they have received and allows plant management to move personnel (e.g., expectant mothers) away from any operations that could be potentially harmful.

RC: 14.028

Doc: CO-008/55

Page 4-220, Table 4.14.2.1-1. The cumulative radiological doses and expected latent cancers to the public from normal operations have not been assessed. Why are these exposures not evaluated?

Response:

The radiological emissions from normal operations are described in volume I, section 4.14 of this document. Modeling has shown that the doses to the public from these releases is small (6 x 10-5 mrem/yr for a maximum offsite individual). This dose is considered a negligible individual dose by the National Council on Radiation Protection and measurements. The yearly cancer risk from this exposure is estimated at 3 x 10-11. When compared with the baseline cancer risk in the vicinity of the Pantex Plant (1.7 x 10-3 per year), an individual has a much greater likelihood of incurring a cancer from sources other than Pantex Plant related emissions (e.g., from genetic predisposition, chemical exposure, diet, stress, and other sources of pollution).

RC: 14.029

Doc: CO-008/56

Page 4-220, Table 4.14.2.1-1. The combined toxic chemical, radiological releases and emissions are not evaluated for workers or off-site populations. Why? Give exposure rates for both groups.

Response:

See response to comment 14.026 and discussion in section 1.3.10 regarding chemical and radiological synergism.

RC: 14.030

Doc: CO-008/57

Page 4-221, Paragraph 4. Not all accident scenarios are evaluated. Only a subset that contribute a large fraction of the total risk from Pantex operations are analyzed. Please give reasons why all potential scenarios are not evaluated.

Response:

All potential accident scenarios were not analyzed in detail because their contribution to risk was determined to be small. It is standard practice in risk assessment to identify and discuss those risks with the greatest potential to effect human health.

RC: 14.031

Doc: CO-008/58

Page 4-222, Paragraph 3. "For the risk significant scenarios for Pantex, the frequency and consequence assessments are performed on a site-wide rather than a facility-specific basis." What would the outcome be if assessment were facility-specific?

Response:

The risk for an individual facility would be lower because the site-wide risk is the summation of the risks of all facilities. It was the intent of the risk assessment to identify the total risk that the Pantex Plant poses to the surrounding communities.

RC: 14.032

Doc: CO-008/59

Pages 4-223 and 4-224, Figure 4.14.2.1-1. On the evaluation of risk, does DOE look at all types of cancers or only those noted in the workers study of 1985? If so, why?

Response:

This assessment looked at all cancers that cause fatalities. Nonfatal cancers were not assessed. See discussion in section 1.3.10 of this volume.

RC: 14.033

Doc: CO-008/60

Pages 4-223 and 4-224, Figure 4.14.2.1-1. What chemical and radiologic exposures are "non-involved workers" subject to? What steps are being taken to prepare these workers for unexpected health effects?

Response:

Daily routine emissions are reported in volume I, section 4.14.2 for radiological emissions and volume I, section 4.7.1.3 for hazardous chemical emissions. Radiological exposures to "non-involved" workers are discussed in volume I, section 4.14.2; chemical exposures to "non-involved" workers are discussed in volume I, section 4.14.1.2. Radiological doses during normal operations associated with future Pantex Plant activities would be well below regulatory standards established by the Nuclear Regulatory Commission and EPA and, as such, no non-stochastic health effects are expected. Hazardous chemical exposures during normal operations will be maintained below regulatory standards developed to prevent non-stochastic health effects.

RC: 14.034

Doc: CO-008/61

Pages 4-223 and 4-224, Figure 4.14.2.1-1. The document only analyzes accidents. Please include routine emissions from normal operations.

Response:

See response to comment 14.026.

RC: 14.035

Doc: CO-008/63

Page 4-237 - 239. The combined cumulative impacts resulting from adding the bounding alternative in the other three documents to the Pantex EIS do not fully address all health effects. Give the complete combined cumulative health impacts of all four documents. [This comment applies to all analyses.]

Response:

Combining the bounding alternatives would be useful only if the bounding alternative is chosen from all four documents. However, since it is likely that one or more of these documents would choose alternatives other than the bounding alternative, this format allows the readers and decision-makers the opportunity to combine these impacts appropriately.

RC: 14.036

Doc: CO-008/64

Page 4-239, Paragraph 6. Please provide a schedule for additional evaluations mentioned in this paragraph.

Response:

Pantex Plant operations are continually evaluated by numerous internal and external regulators both DOE and other federal agencies such as the Defense Nuclear Facilities Safety Board. Results from these evaluations are tracked in an issues management system which ensures the findings are incorporated in the work practices of Pantex Plant. Additionally safety analysis reports are reviewed on an annual basis.

RC: 14.037

Doc: HT13/39

Could you talk some about the scope of what the high explosive research program is and what the fatality rate has been over the last decade for workers who are messing around with high explosives?

Response:

Pantex Plant performs high explosive (HE) synthesis, formulation, machining, extrusion, testing, process development, and analytical operations in performing its HE research and development and production missions. The Pantex EIS Proposed Action includes the continued research and production of HE and weapons components.

On March 30, 1977, two high-order detonations of different types of HE occurred at Pantex Plant. The explosions occurred in Zone 11, Building 11-14A, Bay 8. This resulted in two immediate fatalities and ultimate fatal injuries to a third employee. At the time of the accident, Zone 11 was the plants high explosive development area. High explosives activities in this area included remotely operated pressing, contact machining (meaning the operator was very near the work being done and was not protected in the event of an explosion), and certain support functions for high explosive operations. Contact machining with personnel present is no longer permitted at Pantex Plant.

RC: 14.038

Doc: HT13/40

So is the Pantex Plant going to be planning to experiment with new types of high explosives as we look ahead in the coming years that the site-wide is supposed to cover?

Response:

See response to comment 14.037.

RC: 14.039

Doc: HT13/43

Secondly, related to that, there's been some discussion about a fatality related to the Lawrence Livermore incident. Nan, I [thought] you said the fatality occurred at Pantex. That is not necessarily what I thought I heard Dave say, so I wish that somebody would clarify that with as much information as you fully have so that it is clear to everybody.

Response:

See response to comment 14.037.

RC: 14.040

Doc: HT13/44

I would like to clarify for everyone there were three people killed at Pantex in 1977. If I remember correctly, two of them inside the building and one of them outside the building [were] killed, so what I would like to ask is how will a document like this handle a facility at Pantex that is known to be deficient?

There is a high explosives machining facility at Pantex that has public access and public parking too close to the building, and it does not meet the plant's current standards, so how is something like that addressed in a document like this?

Response:

The facility referenced does not have public access and does not have public parking. Recently plant personnel determined that a small portion of the nearest parking lot is slightly closer than current regulations allow. Those safety regulations establish "buffer zones" that are intended to keep noninvolved workers and the public far enough away from a high explosives facility that they would be expected to survive an accident. In the case cited, the only vehicles that are allowed to park in that area are Government vehicles driven by personnel with official business in the facility. This did not cause the facility itself to be deficient. Rather, it meant that the plant needed to take corrective action to satisfy regulatory requirements. Following the discovery, the plant personnel filed an "Occurrence Report". In accordance with the DOE policy on openness, this report was discussed at the next meeting of the Pantex Plant Citizens Advisory Board. Subsequently, the plant resolved the issue by removing that portion of the parking lot that was within the buffer zone.

Scenario #2 analyzes accidents involving accidental HE detonation. Because of facility design and buffer zones associated with HE facilities, impacts to non-involved workers are not expected.

RC: 14.041

Doc: HT13/45

.. You have a facility at Pantex that is a high explosives facility that the public can get too close to the building, and this is something that was brought before the Pantex Citizen Advisory Board a couple of months ago.
.. There is a parking lot too close to the building so that people who are outside the building could be injured by an accidental explosion; that is other workers at the plant that may not be working in the facility, but they can be near that facility because the buffer zone is not appropriate.

How does a document like this handle a deficient facility?...

Response:

See response to comments 14.040 and 14.043.

RC: 14.042

Doc: HT13/46

In theory, I want to understand how a site-wide EIS addresses a facility that is not [adequate]. Do you just do this generally? Also, when you find something specific, do you discuss it in this document in general, or do you turn it into a generalized accident scenario rather than addressing specifics?

Response:

See response to comments 14.040 and 14.043.

RC: 14.043

Doc: HT13/47

Let me express a concern that I think is related to this, and that is why -- let's keep on this point, because I don't think Nan is quite understanding the point, which is on the high explosives facility and the parking and also related to the gaps in the doors of the Zone 12 assembly/disassembly bays, there was analysis done related to this document.

However, I believe, and I would be delighted if anybody here can point me to it, I believe that neither of those specifics, the lack of buffer zone around high explosives and the specifics of the gaps and the mitigation efforts that have been taken, neither of those things, in fact, are included in this document.

[Ms. Bergman: The doors are.]

The discussion of the doors and gaps that were found and what was done is in this document? Where?

Response:

During preparation of the Draft EIS, Pantex Plant personnel discovered that particular assembly/disassembly cells had larger gaps between the edges of personnel and/or equipment doors and their frames than had been analyzed in prior studies. The cumulative gaps around the personnel and equipment doors of individual cells varied, but the worst case resulted in a total gap area greater than the 42 square inches that had been analyzed in previous Safety Analysis Reports. Since the gap area affects the amount of radioactive material that can be forced out of a cell by the air pressure of an explosive accident, plant personnel immediately reported the variance and initiated an Unreviewed Safety Question. To resolve the issue, the plant immediately implemented measures to reduce the amount of high explosives and plutonium allowed in the cell and then modified the doors to close the total gap area of each cell to less than 42 square inches. Additional modifications have been designed to further close the gap area of each cell to less than 5 square inches. These modifications have been approved and funded for implementation in Fiscal Year 1997. This Final EIS includes health risk analyses of cell accidents that portray the present design basis gap area (42 square inches) and the future gap area (5 square inches). See response to comment 14.040 for discussion of the buffer zone around the high explosives facility.

RC: 14.044

Doc: HT13/48

Where in this document does it specifically say that you have, in an existing high explosive facility, a parking lot that is closer to the building than what current DOE requirements are, and secondly, where in this document does it say that there were gaps around doors in virtually all of the major assembly/disassembly bays at Pantex that were there for up to 13 years? Where are those two statements in this document?

Response:

The buffer zone is not discussed. The problem identified has been corrected and does not change the impacts in the EIS. The door gaps are discussed as part of volume I, section 4.14, Scenario 1. See responses to comments 14.040 and 14.043.

RC: 14.045

Doc: HT13/49

What computer model did you use to assess the risk associated with transporting the pits from Pantex to Manzano?...

Response:

The ADROIT code was used to assess the risk associated with transporting the pits from Pantex Plant to Manzano; specifically, it is used to model transportation carried out in Safe Secure Tractor Trailers (SSTs).

RC: 14.046

Doc: HT13/53

Perhaps I have missed it in Volumes 1 or 2 for the discussion of the tritium risk [for] current and proposed activities in Pantex. I understand during disassembly, they have to take the tritium bottles off of the weapons, and sometimes there may be trouble with the valves being open that should be closed.

I didn't see any discussion in here of the number of times that a base had to be shut down because of tritium release setting off the monitors, and I didn't see any analysis of what the health risk was from the tritium exposures that happened during dismantlement in the current report.

I didn't see any more generalized analysis of an accident that [allows] tritium to go into a water form and escape from the building. Did I miss it somewhere, or is it not in here?

I didn't say "go off consistently," but I have heard there's been a number of incidents [where] tritium has escaped from a weapon that was under dismantlement.

I didn't see any accounting of the numbers of tritium releases that have happened inside.

How many times has there been tritium released during dismantlement to this point in time?

In your bounding scenario that you have got, you are ballparking how many times that will happen as we move ahead into the future?

Do you expect there to be a subsequent tritium accident where there is tritium released?

Is it the usual 1 x 10-4 when you have already had an accident that was 1 x 1?

What I am suggesting in my comment is really the failure to report accurately on the accidents that have already occurred at Pantex.

The failure to really have a full discussion of the accidents that have already occurred makes the public reader of these documents be somewhat skeptical about the extremely low estimates about accidents happening and extremely low estimates of health effects from the accidents that come about.

A more full discussion of the accidents that have already occurred, I think, would have contributed to a much greater sense of public credibility and that which I think you will be encountering through the rest of this process.

Response:

Tritium is a potential health hazard for personnel engaged in weapon assembly or disassembly procedures. During these procedures, the hazard of bodily tritium uptake by plant workers potentially exists due to potential contamination of weapon components by trace leakage of tritium gas from storage reservoirs in certain weapons. Valves on tritium reservoirs are closed during dismantlement. Workers involved in these operations are monitored for tritium uptake. The tritium bioassay program is in place to track tritium uptake by weapons workers. The bioassay program is also used to track the extent of any tritium releases. In 1993, the total tritium population dose was 0.183 person-rem with a maximum individual dose of 14 mrem. In 1994, the total tritium population dose was 0.115 person-rem with a maximum individual dose of 11 mrem.

Facilities where tritium operations are conducted are equipped with Radiation Alarm Monitoring Systems (RAMS) that provide prompt warning to plant personnel so that they can effect emergency procedures and minimize possible radiation exposures from the release of radioactive material. At times, a RAMS alarms because of system equipment failures not related to tritium releases; nevertheless, plant procedures dictate a facility evacuation anytime a RAMS is activated. Occurrence reports for inadvertent tritium alarm actuations are available in the public reading rooms in Amarillo and Panhandle. These alarm actuations do not involve tritium releases.

There is also a hazard from potential accidents involving tritium. Volume I, section 4.14, describes two risk significant accidents involving tritium: Scenario 5, Tritium Reservoir Failure from Internal Event, and Scenario 7, Multiple Tritium Reservoir Failure from External Event/Natural Phenomena. Scenario 5 involves the release of tritium as a gas and Scenario 7 involves the release of tritium as water vapor. Scenario 5 has occurred once in the past (reservoir discharge within Cell 1 in 1989); this event, with other past accidents, are described in detail in section 6.4 of the Pantex Plant Safety Information Document (Pantex 1996a). The impacts of this accident are described in section 4.7, Air Quality. The frequency of tritium releases at Pantex Plant is defined as "anticipated" and is estimated based on historical experience at approximately 2 x 10-2 releases per year at a 2,000 operational level. Mathematically, this frequency indicates a tritium release related to Scenario 5 every 100,000 operations. Even though this event is defined as anticipated does not guarantee its occurrence in the future. With adherence to procedures and proper training, Pantex Plant personnel work to minimize the likelihood of the reoccurrence of the Cell 1 tritium accident.

RC: 14.047

Doc: HT13/55

In your accident analysis, you have a puncture, so that is a puncture of one pit container, right?

Did you ever consider the possibility that there could be more than one?

Response:

Volume I, section 4.14.2.1, Scenario 6 examines the risk from plutonium release due to a forklift impact during pit handling. The physical configuration of pit containers precludes the possibility of puncture of more than one by a single forklift. The frequency of the event, however, accounts for all operations and thus considers all forklift activities.

RC: 14.048

Doc: HT13/56

What is the fire tolerance?

Response:

See discussion on Intrasite Transportation in section 1.3.8 of this volume regarding pit pyrophoricity.

RC: 14.049

Doc: HT13/58

We don't have any records about how these pits are going to hold up in the coming decade, so we need to invest multiple billions of dollars in doing research to see if problems could develop in these pits sometime in the next 10, 20, 30, 50 years. There is a lot of discussion about multiple billions of dollars going into trying to answer those questions.

Response:

See discussion on Intrasite Transportation in section 1.3.8 of this volume regarding the DOE pit surveillance program.

RC: 14.050

Doc: HT13/59

Currently, how many of those pits in storage are actually under surveillance or actually looked at visually each year of the 12,000 whatever it is pits in storage in Pantex? How many of them are actually taken out and looked at each year? Could you give us a ballpark idea?

Response:

Historically, pits have had few problems. With 20,000 pits in storage, approximately 20 pits per year will be inspected. These pits will be from different weapons programs. Approximately 22 AT400A containers will be tested yearly. Based on historically low problems with pits, DOE believes this surveillance program will minimize the likelihood of undetected failures.

RC: 14.051

Doc: HT13/60

What is the length of time that the current containers have been studied to see how effective their seal has been?

So what is the track record?

The reason why I ask is the similarity between the stockpile stewardship concern about what is going to happen to plutonium in the aging pit inside a very carefully sealed weapon where there's been decades of study of humidity, moisture, air pressure, materials compatibility...

With all this study, they are still investing multiple billions of dollars, because if you get a leak inside your pit, inside your container, inside your weapon, if there is even a pinprick air hole, you can get moisture introduced inside a weapon, and the moisture can cause all sorts of problems, and oxygen, as we know, with these materials can cause all sorts of problems, but somehow, those same sorts of problems could happen with the pit in storage, could it not, if the seal on the containers is broken?

I may be wrong about this, but apart from the risk of a criticality accident, a nuclear explosion, aren't there also risks from the plutonium meld getting oxidized, and isn't the oxidized metal more mobile than the metal itself in the shape and the form of the pit? Isn't there a flammability risk for the plutonium metal as well? I [thought] I understood there were those two potential risks.

Response:

See discussion on Intrasite Transportation in section 1.3.8 of this volume regarding pit pyrophoricity.

RC: 14.052

Doc: HT13/61

Are you saying there is no flammability risk for the pits that are in storage in the current containers?... So are you saying it is pyrophoric, meaning that it ignites on contact with air?

Response:

Plutonium in pit form is not pyrophoric. See discussion on Intrasite Transportation in section 1.3.8 of this volume.

RC: 14.053

Doc: HT13/62

So if your container developed, for example, a pinprick. If the seal on the pit developed a pinprick hole or rusting crack, then the plutonium metal became oxidized from the contact with the oxygen which it wasn't supposed to have, and you had some plutonium in an oxide form inside the plutonium metal pit, and if it was exposed to air, are you saying there is no flammability risk and no dispersal risk?

Response:

All pits are hermetically sealed within a metal clad. DOE has considered the potential for pit leakage during storage and has designed both a container and a surveillance program to minimize the likelihood of oxygen introduction into a pit. The AT400A will provide a container within a container, the inner container having an inert atmosphere as defense-in-depth measures in addition to the pit clad. Scenario 6 examines the risk from plutonium release due to a forklift impact during pit handling. The amount of material released in this event bounds any material released from a pinprick hole. Because the plutonium pit is made of plutonium metal, most of the plutonium remains in the storage container during a forklift accident. Less than 0.6 milligrams of plutonium oxide dust would be released from the storage container.

The possibility of intentional damage to pits within Zone 4 is minimized by an active personnel assurance program and a high level of security. DOE believes the policy, procedures, and security in place at Pantex Plant preclude the occurrence of the scenarios described by the commentor.

RC: 14.054

Doc: HT13/63

If you drilled a hole, for example, through your container, then you drilled a hole through a pit, and you left it sitting out in the sun for a couple of decades, there wouldn't be any problems whatsoever with any health or safety or environmental problems with the these stored pits? Is this what you are saying?

Response:

DOE believes the policy, procedures, and security in place at Pantex Plant preclude the occurrence of the scenario described by the commentor.

RC: 14.055

Doc: HT13/64

What is the difference between a drilled hole and a pinprick hole in terms of introduction of oxygen into a part of the nuclear weapon pit that wasn't designed to have contact with oxygen?...

Response:

All pits are hermetically sealed within a metal clad. DOE has considered this scenario and has designed both a container and a surveillance program to minimize the likelihood of oxygen introduction into a pit. The AT-400A will provide a container within a container, the inner container having an inert atmosphere as defense-in-depth measures in addition to the pit clad.

RC: 14.056

Doc: HT13/65

Isn't it true that the container in which the pit is placed is multilayered, there is metal, [there] is styrofoam, and there is stainless steel? We are not talking about going through the external wall of the pit container, and then you have got the pit right there.

Response:

Design features of both ALR8 and AT400A are provided in volume II, appendix F.

RC: 14.057

Doc: HT13/66

What if you puncture a pit, what happens then? How much of the pit would disperse? How would it actually get dispersed from a puncture? Would these be metal particles or oxidized?

Response:

Because the plutonium pit is made of plutonium metal, most of the plutonium remains in the storage container during a forklift accident. Less than 0.6 milligrams of plutonium oxide dust would be released from the storage container. The only pathway for release of this plutonium dust is through the opening caused by the forklift.

RC: 14.058

Doc: HT13/67

Over what length of time would that oxidation process and dispersal process happen if you have had a puncture through a pit?

... How would the dispersal occur? Would the process of oxidation actually suspend some of these particles into air spontaneously without it having to receive further kinetic energy?

Response:

See discussion on Intrasite Transportation in section 1.3.8 of this volume regarding pit pyrophoricity.

RC: 14.059

Doc: HT13/68

So if you, somebody, opened up 100 pits and poked holes in all of them. This kind of scenario like an internal sabotage scenario, somebody was really mad at the DOE for getting laid off from their job after serving their nation for 25 years in a job where they get picked on by the public all the time, and they went in and they opened 50 of these containers and poked holes in pits and walked out, what would the general scope of plutonium dispersal impacts be? Did I miss it somehow?

[What if this happened when] wind is blowing 50 miles per an hour?

But you have all the security around Pantex and the Kirtland base, and you don't consider that.

Response:

DOE believes that the high level of security and personnel assurance program at Pantex Plant will preclude the occurrence of the internal sabotage scenario described by the commentor.

RC: 14.060

Doc: HT13/72

Page 5-61 of the draft statement says that each of the bunkers at Manzano has the capacity to store up to 800 pit containers in a Stage Right configuration in you slide show. Has there been a Safety Analysis Report done on storing...up to 800 pits in those bunkers?

Response:

Safety analyses have been done for similar structures at Pantex Plant. These facilities have capacities of hundreds to thousands of pits. The Manzano bunkers being considered for use provide similar or better capabilities for storage than those previously analyzed at Pantex Plant. In any case, before DOE elected to move pits to Manzano, a full site-specific safety analysis report (SAR) would be developed for the proposed Manzano facilities.

RC: 14.061

Doc: HT13/73

Has the safety analysis report for storing pits in zone 4 at Pantex been updated since...the 1993 safety analysis report that was done at the time of the EA for interim pit storage at Pantex?

Response:

The Zone 4 safety analysis is being updated but is not complete.

RC: 14.062

Doc: HT13/75

Back to the ALR8 which is currently being used at Pantex, that has an oxygen atmosphere, and it is not a neutral atmosphere, it is not a sealed container, am I right?

You haven't put a special neutral helium in there, and you are not preventing oxygen from getting in there. It is just air, right?

... So what I would like to know is how this document accounts for not just as accident like if a forklift threw something, but a pit that has a minor flaw that you all had checked for but overlooked so that over time, years of storage, you once again have this, perhaps, pinprick sort of thing going on in a container where oxygen is present, so you have your plutonium to oxidize over time and perhaps surprise some worker when they open that canister at some later date.

How does this document evaluate that kind of scenario?

Response:

The AL-R8 pit container does not have a sealed inner container with an inert atmosphere. Additional details for the ALR8 container can be found in volume II, appendix F. The pit itself is hermetically sealed so oxygen does not have a route to the plutonium. Pits have been monitored over time and from a storage perspective no problems have occurred. DOE has considered this scenario and has designed both a container and a surveillance program to minimize the likelihood of oxygen introduction into a pit.

RC: 14.063

Doc: HT13/76

Do you stand by your earlier comment that about ten pits per year are all that are examined out of the almost 8,000?

That is the number that I think are destructively tested.

Response:

RC: 14.064

Doc: HT13/78

Where are the impacts, including radiation exposures, from that transfer to be discussed in the Pantex Draft EIS?

Just to clarify that you are getting information to use in the final, so there will be this further information you are talking about will be available before the final? I am trying to figure out essentially where it fits in.

Let me say what I understood you to say so you can correct me if I misheard. You are saying that any worker exposures, radiation exposures to workers, for this transfer from the ALR[8] to the AT400 is covered in the overall worker exposure analysis of operations in this document?

Is the operation is that operation, in terms of where it happens at Pantex, in terms of what facilities, et cetera, is that discussed in the document, and if so, where?

Is there a safety analysis report or other document that describes this transfer process?

I am asking you now to tell me which specific document that you are talking about.

Again, just so we are speaking the same language, those three documents that I heard you talk about are what I call the three background documents.

I dont recall, and if there are people here that know these documents better than I, that is why I am asking, I dont recall in any of those three background information documents that this transfer procedure is, in fact, described. If it is, I would like somebody who knows that to tell me, because I missed it, and Id like to read it.

Response:

At the time the Draft EIS was written, doses from the pit repackaging operations were estimated to be within the current cumulative doses for production workers. Since, the Draft EIS was published the design of the pit repackaging facility has been changed and is under development. Because of these changes, there is likely to be additional cumulative exposure to workers at Pantex Plant. Additional exposures due to the pit repackaging operation are described in volume I, section 4.14.

RC: 14.065

Doc: HT13/86

I want to go back to an issue that was brought up earlier about the accidents at Pantex and about supposedly deficient facilities at Pantex. I think it should be noted that [the high explosives] accident occurred nearly 20 years ago....

The practices have changed since that time. The facilities at Pantex for high explosives are extremely modern. They are the only facilities in the DOE complex that can perform this mission today without any modification. The parking lot problem is being addressed by management at the plant. It was brought up to the P[P]CAB in order to let them know that they are addressing that.

The door gap issue has been widely discussed in P[P]CAB meetings and in the community in Amarillo. I think that's been mischaracterized in the meeting tonight. I think that is being addressed by management at the plant.

I guess my comment would be both those issues have been raised in recent months concurrently with the production of this EIS, but near the end of the process at the time the draft was issued, I think it is unrealistic to expect very contemporary events that occurred near the end of the process to be addressed in this when they are really day-to-day management things that are being handled by plant management, and they are being done in concert with the P[P]CAB.

I will further comment that Pantex has an outstanding safety program. Pantex is used as a resource by employers in the Amarillo region for training information, for how to institute a safety program, and there is an extreme confidence in the safety and reliability of not only the weapons but the employers who handle those weapons at the plant.

Response:

See responses to comments 14.040 and 14.043. The two cases cited were the parking lot of the high explosives facility and the gap areas around the doors of assembly/disassembly cells. It is correctly noted that the problems were discovered by plant personnel, immediately reported to plant management, and promptly solved by plant action without accident or injury. These are success stories of how the safety program is designed to preclude accident and injury. The discussion of the door gaps is located in volume I, section 4.14, Scenario 1.

The Pantex Plant Cells are currently being operated within the safety basis defined in a Justification for Continued Operation (JCO). This JCO establishes administrative controls to minimize the consequences of a potential accident until the end objective of reducing the door gap area to 5 square inches is reached.

RC: 14.066

Doc: HT13/89

I have a request that is kind of similar to and follows along with actually both of the last two comments which related to this document, and that is that not only the history of safety practices at Pantex, but the history of safety practices at each of the alternative sites...included, because while it is not necessarily always specifically factored into your risk analysis that you do in these documents, from a public standpoint, the public is interested in evaluating the safety performance of facilities in terms of handling hazardous and radioactive materials.

There are lots of differing perceptions on the part of the public as to which facilities are safe and which facilities are dirty. The most helpful and objective way of having some analysis of that is actually having some comparative analysis of the historic practices at those various facilities so that it can be identified whether certain facilities may have a "better" or "worse" safety record.

It is not up to me or anybody else to say, "We suppose this," or, "We suppose that." There is some actual data that is released in unclassified form so that it could be available to the public, and so I would request that kind of information be done on all of the sites and included either in the document or a reference document that cites that.

Response:

The type of historic comparisons suggested cannot be realistically and meaningfully presented. The Department and its plant operators have extensive programs to identify and analyze potential accidents in order to develop techniques that both minimize the possibility of occurrence and mitigate the consequences should an accident occur. In like manner, when an accident does occur, root cause analyses are performed and changes are made to prevent recurrence. Because of these ongoing programs of safety analyses, facilities and procedures are continually improved. This means that the set of procedures and facility conditions present at any given time are likely very different from other times in history. Thus, a historical review of past accidents as an estimate of current safety is inherently flawed. This can be illustrated by the case of the explosive accident that occurred in 1977. This is the only explosive accident in the history of the plant that resulted in fatalities. The procedure that resulted in the accident was an operation in which a worker used a lathe to shape an experimental high explosive. The operator was killed in the resultant explosion, as were two other nearby personnel. Following that accident, the procedure and equipment were both redesigned to eliminate the cause of the accident. The procedure is now performed by a computer controlled robot to regulate pressure and under water to control the temperature of the process. The operator is no longer in the room when the process occurs. Thus, one cannot evaluate the safety of the current facility and its operations by the circumstances that were present in the past. Instead, safety analyses are performed by detailed examination of each step of the processthe physical and chemical characteristics of the materials and equipment used and the actions performed by humans and machines during the process. For each step of the operation, every event that could initiate an accident is systematically identified and the results of that occurrence are characterized. Motion and time studies, measurements, and historical data are used to assist in estimating how frequently an abnormal event (e.g., dropping a wrench) is likely to occur and what could occur as a result of that event. From this analysis, a calculation can be made to estimate the frequency of an accident. Then calculations are made to quantify the results of such an accident. This process results in the most scientifically defensible prediction of the risk of an accident under the actual circumstances present at the time.

RC: 14.067

Doc: HT13/18

Also, I wish the documents in the future would at least admit that we exist. Kirtland, in 1989, when they started the fire by accident, which was an accident, said that South 14 could be the fire break. ...At that time, there were 500 homes. Now, there are probably 750 to 1,000 families who live directly east of this facility. We would like some recognition of our concerns as well as the Four Hills residents.

Response:

Range fires do occur during dry seasons in New Mexico. However, the nature of the alternative to relocate interim storage of pits to the Manzano Weapons Storage Area at Kirtland Air Force Base would result in no fire hazard. The relocated pits would be sealed in stainless steel, welded shut, Type B containers (e.g., the AT-400A) and placed in a magazine tunneled into the granite of Manzano Mountain. The entrance to the tunnel and the interior storage magazine would be protected by heavy steel doors. There would be no high explosives or any other combustible material present inside the storage facility. Consequently, there is nothing in the storage facility which could be a fuel to either start or sustain a fire. Likewise, the pit would be shielded from any externally initiated range fire by the steel doors, the granite of the mountain, and its own protective stainless steel container. It would not be possible to either expose or burn the pit in any credible fire scenario. Thus, while a range fire might occur in the Kirtland area, the pits in the storage facility would not be affected or contribute in any way to the consequences of such a fire.

RC: 14.068

Doc: HT13/30

We have created some problems, quote, inadvertent problems, that we dare not create. The dangers associated with these plutonium pits in or out of warheads are going to last for a long time, and it is unfortunate that we didn't have a broader public discussion about all of these issues before a decision was made to even create the 20,000 plus warheads and what these unintended consequences would be.

I certainly hope as we talk about interim storage of pits, which frankly, for better or worse, is going to be a lot longer than ten years, and this document should more clearly state that kind of along the lines, Nan, that you, in fact, said in answer to Janna's question, but I don't really see that kind of comment reflected in here, so that is the kind of change that needs to be made in this document.

Response:

It is DOEs policy to evaluate site-wide NEPA documents at least every 5 years to determine whether the existing EIS remains adequate and whether to prepare a new site-wide EIS or supplement the existing EIS (10 CFR 1021.330).

RC: 14.069

Doc: HT12/6

Yes. According to your summary report there was a calculation of potential risks of -- the citizens of Savannah are within the range of the site for getting cancer over a estimated of 50 years. Was there -- did you-all calculate the -- not only the potential release of radiation coming from the Savannah River Site, but did you-all calculate the other plants that's releasing other types of chemicals and other types of radiation or other forms of radiation in combined with that which is coming from the Savannah River Site?

Because if you haven't and you only estimated the potential risk of cancer coming from the Savannah River Site, then there may be a greater risk of low-income people getting the repercussion [effects] of what we economically are trying to benefit from the Savannah River Site.

Response:

The scope of the Pantex EIS includes evaluating the impacts of storing either 8,000 or 20,000 pits at the P-Reactor at the Savannah River Site (SRS). The EIS concluded that no adverse health effects would be expected among the general public, including minority and low-income populations, as a result of normal storage operations. Evaluating the impacts from other operations in the vicinity of SRS is beyond the scope of this EIS.

RC: 14.070

Doc: HT12/7

... Well, in my opinion, that is not fair to the citizens of Savannah because now you're only projecting what Savannah River Site. This is supposed to be a total...assessment of what's going to -- a health assessment, what's going to take place.

So not only should it be calculated, the radiation that's going to be released from the Savannah River Site,...the total impact because say, for instance, we may have a better chance if the Savannah River Site was closed down, you know, instead of adding what radiation or what contamination would be released from the Savannah River Site, we may have a better chance of having a longer life span if we would close the plant down. So if there was a total calculation along with all the other plants along with Savannah River Site, then I think there would need to be more input in the study as far as health...is concerned....

Response:

See response to comment 14.069.

RC: 14.071

Doc: HT12/8

My concern is birth defects toward our children.... I've read in the past how different radiations...affect births, pregnancies of mothers, and I would like to know the same situation in this area.

Response:

Radiological impacts to the public (including children) from Pantex operations are discussed in volume I, section 4.14. Modeling has shown that potential doses to adults and children alike will be extremely small and as defined by the National Council on Radiation Protection and Measurements, they are negligible.

RC: 14.072

Doc: HT12/16

I assume that's gamma. The worker at what distance for that 6 rem?

Response:

The 6-rem worker dose from a forklift puncture is primarily alpha radiation due to the inhalation of plutonium dust. This 6-rem exposure is a 50-year dose.

RC: 14.073

Doc: HT12/21

You have done SARs on those facilities?

Response:

The Zone 4 magazines have an approved Safety Analysis Report. The SAR is currently being updated to the latest DOE Standard.

RC: 14.074

Doc: HT12/22

[Are you] familiar with plutonium vulnerability assessment done in November of 94? It says that operations of storage activities are continuing with a -- on the basis of a BIO instead of approved safety analysis reports.

Response:

The DOE Plutonium ES&H Vulnerability Assessment (DOE 1994cc) was performed to characterize ES&H vulnerabilities. An ES&H vulnerability is defined as a condition or weakness that may lead to unnecessary or increased radiation exposure of the workers, release of radioactive materials to the environment, or radiation exposure to the public. The study of Pantex Plant, completed in July 1994, identified four potential vulnerabilities: (1) explosion in an assembly cell dispersing plutonium outside of the cell/facility; (2) operational accident, human error, or equipment failure causing failure of the pit cladding or pit tube; (3) lack of experience concerning design and lack of knowledge of interim storage and aging of pits and RTGs; and (4) collapse of roof over Bay 27, Building 12-26 due to natural phenomena. The report stated that all handling of disassembled nuclear explosive components and sources containing plutonium at Pantex Plant are performed by trained and qualified individuals in accordance with operating procedures. Likewise, the report concluded that facilities containing the disassembled nuclear explosive components and sources are designed to withstand adverse conditions with minimal damage or release of plutonium. While the responses to these vulnerabilities are being addressed in other documents, this EIS discusses the relevant issues through accident scenarios. The risk from vulnerability 1 is addressed in volume I, section 4.14, accident Scenario 1. The risk from vulnerabilities 2 and 3 are addressed in volume I, section 4.14, accident Scenario 6. The final vulnerability is included as part of volume I, section 4.14, Scenario 3. It should be noted that the particular facility cited as vulnerable to natural phenomena (Bay 27, Building 12-26) is scheduled to be phased out this fiscal year. The operations performed in that building will be relocated to Building 12-104A after completion of an Operational Readiness Review. In view of the nature of the vulnerabilities identified, the actions taken by the plant, and the risk analyses of those vulnerabilities in Pantex Plant Safety Analysis Reports and in this EIS, there is sufficient information on potential environmental impacts (including human health impacts) for the Secretary to proceed with a Record of Decision on storage of 20,000 pits.

RC: 14.075

Doc: HT12/25

I think that also the other vulnerability noted for Pantex was that...Pantex is the only site, the only major plutonium site, that is identified as having a single barrier for plutonium....

Response:

All pits are hermetically sealed within a metal clad. The AL-R8 container is sealed but does not have an inert atmosphere surrounding the pit. The AT-400A will provide a container within a container, the inner container having an inert atmosphere as defense-in-depth measures in addition to the pit clad. Further information on pit container design is provided in volume II, appendix F.

RC: 14.076

Doc: HT12/29

... On page 5-33, you're talking about the worker at Savannah River health consequence and what you show...[as 4 x 10-3 to] the maximum exposed individuals. But you say the probability of a cancer from all causes to the general public is estimated to be twenty percent which implies that six of the thirty workers are going to develop cancer. Now, that doesn't sound like an insignificant consequence to me. That sounds like a significant consequence.

That's from natural causes. Let me comment that the paragraph is unclear. That's what I'm saying, okay. The paragraph is unclear. I know what it means -- what it should mean.

Response:

The text refers to the number of cancer deaths from all causes in the United States. Twenty percent of all deaths in the United States are attributable to cancer from all causes. The text has been changed to clarify the statement.

RC: 14.077

Doc: HT12/33

Work chart is totally confusing to me. And how a dose rate of one rem per year at one meter at the surface of the trailer, why does that affect the human dose based on geography?

Response:

The dose identified refers to the expected dose rate outside of a Safe Secure Tractor Trailer carrying pits. It is used to estimate population doses along pit shipment routes.

RC: 14.078

Doc: HT12/34

... What's the natural radiation dose?

Response:

Background radiation doses for the Savannah River Site are provided in volume I, section 5.3.2.

RC: 14.079

Doc: HT12/35

Now, I submit Pantex has a much higher background radiation than Savannah River. Now, you do not say we ought to move it to Savannah River in order to...decrease the number of people at Pantex, did you? Get the people out of that god-awful place.

Response:

The average dose from natural background radiation to an individual in the vicinity of Pantex Plant is 334 mrem/yr. The average dose from natural background radiation to an individual in the vicinity of the Savannah River Site is 312 mrem/yr.

RC: 14.080

Doc: CO-003/3

Any permit or plan approval for new Hanford programs/activities must be fully integrated and must comply with all State of Washington public health and safety rules and regulations.

Response:

Transition planning is described in volume I, section 5.1. Existing laws, regulations, formal agreements, and DOE orders will form the basis for transition planning and execution.

RC: 14.081

Doc: PC-011/2

None of the draft PEIS's have adequately addressed what would happen to this area's farm and ranch economy if a significant accident releasing substantial quantities of radionuclides were to occur regardless of how well it were to be cleaned up. I think the public's perception of the contamination would be such that it would make our products unmerchantable not just for the immediately affected area, but for the entire Panhandle's products.

Response:

Perceived risks are not easily quantified. The socioeconomic impacts of such perceived risks are even more difficult to evaluate. However, a statement characterizing this potential has been added to the appropriate sections of the Final EIS.

RC: 14.082

Doc: PC-006/2

Storage of pits at Pantex should not be [increased] until the findings of the [Plutonium] Vulnerability Assessment are resolved.

Response:

See response to comment 14.074.

RC: 14.083

Doc: PC-034/5

In Section 4.14.2.1 (page 4-219) and in Figure 4.14.2.1-1 (page 2-224), a quite classic error is made in explaining potential latent cancer fatalities. The error is to use risk estimates for exposures to large populations and to assume that applying that risk estimate to a specific group of workers allows for definitive conclusions about that group. In this example, the figure provides the correct explanation. The text is misleading and might cause confusion in the community by indicating that the 330 plant workers would suffer a certain number of cancers.

Response:

Further clarification of the interpretation of the calculated risks has been provided in section 1.3.10 of this volume.

RC: 14.084

Doc: PC-034/6

Health effects are important to understand. The section on continued operations talks about health effects for workers. A statement is made that workers would experience additional cancers.

In the figure, a different explanation is used. The statement in the figure is that an average number of cancers could occur if many groups of workers were exposed. The final statement was that the most likely outcome is zero cancers.

What is the average community member to think?

What is the correct explanation?

Response:

Further clarification of the interpretation of the calculated risks is provided in section 1.3.10 of this volume.

RC: 14.085

Doc: PC-034/7

The Department of Energy's Office of Emergency Management (NN 60) and the Office of Emergency Response (DP 23) fund the DOE's Atmospheric Release Advisory Capability (ARAC), which is housed at the Lawrence Livermore National Laboratory. ARAC's computer models, which have world-wide acceptance, have been called into service in many real-time responses to both real and potential accidental releases of radioactive material. The Three-Mile Island nuclear power plant (NPP) accident in 1978, the 1986 Chernobyl NPP disaster in the former Soviet Union, and the U.S. Air Force Titan II missile accident in Damascus, Arkansas are just a few examples. In addition, the ARAC models have been utilized in every nuclear weapons accident exercise (NUWAX), since NUWAX 79. Pantex Plant is an "ARAC Site" and is linked to the ARAC center in Livermore via a computer-to-computer connection. ARAC operators are familiar with Pantex operations and can respond in a matter of a few minutes with a computer model graphic output showing the trajectory of the plume of contamination in the event of an accident. When, an if, a real accident occurred at Pantex it would be the ARAC models and the ARAC capability that DOE would call upon to respond in real time.

... Since ARAC is funded by NN 60 and DP 23 and ready to respond to a radiological accident at Pantex, why did DOE choose to use a model like ERAD to assess consequences for this EIS?

Response:

The Atmospheric Release Advisory Capability (ARAC) is a U.S. government emergency assessment program designed to provide timely and credible assessment advisories to emergency managers for nuclear, chemical and biological hazardous releases to the atmosphere. ARAC uses a series of codes and models integrated into a coherent software system for automated communications, processing and management of both data and calculated assessment products. It uses real time meteorological data to identify populations at risk and enable mobilization for quick response. ARAC is not currently used for risk assessment purposes in a non-emergency situation to predict dose consequences.

The ERAD code was also funded by DOE to specifically address the radiological impacts associated with an explosive dispersal. ARAC uses a portion of the ERAD code for buoyant heated explosion cloud rise formulation. The ERAD code does have the capability to use climatological data in iterative computations to predict dose consequences required in NEPA documents.

RC: 14.086

Doc: PC-034/9

.. In Table 4.14.1.4-1, safety statistics for Pantex are compared to general industry, manufacturing industry and chemical industry (page 4-217).
.. Since the largest industry in the Panhandle is agriculture, should not the agricultural statistics be included here?

Response:

The purpose of Table 4.14.1.41, in volume I, section 4.14.4, is to compare the safety statistics for Pantex Plant with industries that are similar to the operations performed at Pantex Plant. This is the reason the statistics are compared to general industry, manufacturing industry, and chemical industry rather than agricultural industry.

RC: 14.087

Doc: PC-034/10

... Appendix D, Human Health, does very little to explain how the impact to human health are derived or calculated. This appendix is more of an explanation of the risk assessment methodology than human health.

Response:

Volume II, appendix D as well as volume I, section 4.14, Figure 4.14.2.1-1 provide detailed descriptions of the methodology followed to estimate human health impacts. Appendix D and section 4.14 discuss the estimated human health impacts associated with continued Pantex Plant operations. Both radiological and chemical impacts are described as well as other worker safety issues.

The risk assessment methodology presented in volume II, appendix D was utilized to identify the risk dominant impacts in terms of excess cancer fatalities from continued Pantex Plant operations. The human health appendix provides references to reports such as the BIER-V report which provides further details on the human health effects of ionizing radiation (NAP 1990).

RC: 14.088

Doc: PC-024/4

Page S-9, right column, top of third paragraph. I suggest that the release of chlorine gas, as the dominant accident scenario, may not be accurate. If the Pantex plant was targeted in a terrorist attack, that could prove to be much worse. Another point, is that the chlorine accident may have been considered for a 10-year period, but the plutonium-239 will remain a hazard for over a quarter million years.

Response:

The paragraph addressed begins with the sentence, "The dominant accident scenario in terms of release of hazardous chemicals to the public involves a release of 408 kilograms (900 pounds) of chlorine gas from the water treatment facility." The contention here is that for accidents involving hazardous chemicals (as opposed to radionuclides or high explosives), chlorine is the risk dominant hazard. Acts of terrorism are outside of the scope of the EIS, and are considered very unlikely due to the high level of security evident at Pantex Plant.

Other risk contributors are also assessed in the EIS, so the conclusion about chlorine does not preclude risk contributions from radioactive materials and high explosives. These risk contributors are summarized in volume I, Summary.

The concern that the chlorine accident may have been considered for a 10-year period is unnecessary. The frequency calculations used in the risk assessment are independent of how long a substance remains a hazard, and it is DOEs policy to evaluate site-wide NEPA documents at least every five years to determine whether the existing EIS remains adequate and whether to prepare a new site-wide EIS or supplement the existing EIS (10 CFR 1021.330) cited in volume I.

RC: 14.089

Doc: PC-024/13

Page 5-11, Table 5.2.2.11, Major Sources of Radiation Exposure in the Vicinity of the Nevada Test Site. This table should be removed because it contains unnecessary information and is highly misleading in other respects. The term "Vicinity" can, and is likely to, refer to areas [that] are dozens of miles from the test site, and upwind of the test areas that are at the far side of the vast test site.

Under the heading "Other Sources," is "NTS - environmental radioactivity," which is shown to be at least 1,000 times less than any other source including global "weapons test fallout" [in] which NTS was one of the primary sources.

This EIS was supposed to conform with all the requirements set forth in the "Agencies shall insure the professional integrity, including scientific integrity of the discussions and analysis in environmental impact statements" (40 CFR1502.24).

Response:

Volume I, section 5.2, Table 5.2.2.11 presents the radiation environment that individuals in the areas surrounding Nevada Test Site (NTS) receive on average. The term "Vicinity" refers to the areas surrounding NTS and the members of the public within these areas. These areas include both upwind and downwind areas from the test site.

Nuclear tests in the atmosphere at NTS have been confined to weapons having yields below 100 kilotons. All other atmospheric nuclear testing by the U.S. were made at the Eniwetok Proving Grounds in the Pacific Ocean. The predominate source of global weapons test fallout is from atmospheric testing of megaton-range detonations by the U.S. and the U.S.S.R. during the early 60s. A relative comparison between the NTS environmental radioactivity and the weapons test fallout was not made since both are less than 1 mrem and do not contribute significantly to the radiation environment in the vicinity of NTS.

RC: 14.090

Doc: PC-024/15

Page 5-17, left column, first line. Though such an incident may result "...in no significant short-term radionuclide releases to the exterior environment," the next quarter million years might tell a different tale. The mitigation analysis of such an event should not be left to whatever kind of society follows us.

Response:

Should P-Tunnel become the preferred alternative for interim pit storage, DOE would consider performing mitigation analysis for a tunnel collapse.

RC: 14.091

Doc: HT15/25

Under the description of the risk about plutonium on Page D-5, both [involved] workers...and the public are vulnerable to plutonium inhalation if an accident occurs that disperses it as respirable particles; for example, a fire or explosion. ...On Page D-23, there in the first column, first paragraph, it says the long-term exposure pathways and the liquid exposure pathways were not considered.

So we want to be sure, not only that you can take into accurate account types of flight and that type of thing. We want to make sure also that the consequences of [a plutonium] release on a population on-site or off-site are accurately taken into account. ...Long-term exposure [to plutonium has] to be a consideration with soil, farming, and water. ...I have certainly not done full justice to this document, but I raise these issues.

Response:

Details on alternative pathways have been provided in volume I, section 4.14.

RC: 14.092

Doc: HT15/34

For transportation of material, the listing of the accident scenario included environmental impacts for transportation [accidents]. In the evaluation of those accidents, it wasn't included in this event tree analysis.

Response:

The human health impacts from transportation accidents are described in volume I, section 4.16.

RC: 14.093

Doc: HT15/36

... It's really talking about the risk for inhalation of hazardous substances, as I understand the document. The risks for ingestion haven't been included in there.

The inhalation cancer risk is above the normal, except for 1.45 x 10-7.

Response:

The risks from ingestion of hazardous substances have not been included because the human health risk is dominated from exposures through inhalation.

RC: 14.094

Doc: HT15/37

... What was the assigned risk bin for accidents involving Ogallala aquifer?

Response:

No accidents were identified during the preparation of the Pantex Plant EIS as capable of contaminating the Ogallala aquifer. Risk bins were for human exposures. The pathway for human exposure form the Ogallala aquifer is not a significant contributor. Additionally, several studies indicate that plutonium disposed from accidents will not reach the aquifer.

RC: 14.095

Doc: HT15/38

... We had trouble, particularly when the Ogallala [aquifer] was involved,...multiplying the risks times the frequency that would happen. ...In other words, if you're considering 10 to the minus 7 or 8 or 9, that multiplied by the likelihood of the accident occurring...reduces the significance. The problem with reducing the Ogallala [aquifer] is [that] it would be such a catastrophic event, that we'd rather not allude to the risk by the possibility of the accident occurring.

Response:

See response to comment 14.094.

RC: 14.096

Doc: HT15/39

... I understand this EIS really evaluates the future activities at Pantex and several standard alternatives. So I think that approach is valid. But it seems that if the hazardous instances were discounted...because...the constituents' concern were limited, based on that, [were] not seeing above this particular level. Their evaluation was not carried forward.

My understanding is that the risk was posed only for inhalation pathways, [not] that that would be only added together.

Response:

The commentors understanding of the EIS appears to be correct. However, it is unclear as to whether or not the commentor has a concern with the EIS. Further detail on alternative pathways has been added to volume I, section 4.14.

RC: 14.097

Doc: HT15/40

Model for chlorine?

Response:

The chlorine release scenarios were modeled using the Emergency Prediction Information (EPI) code.

RC: 14.098

Doc: HT15/41

Did you base the probability of the accidents occurring on the data of accidents that have occurred in the past?

Would your analysis predict that there has been as many as one fatality in the plant due to a radiological release?

What would you say the probability is, based on the data that you have, that there would be a death from the radiological release at the plant by someone working in the plant?

Based on past experience with the plants, you do not project...any fatalities from a radiological accident?

Did you estimate any probability of this occurrence base upon previous experience?

But the radiological risks were regarded as negligible; is that correct?

.. if you calculated them, what was the probability that someone would incur a fatality on account of a radiologic incident, one in 10,000, one in a million?
.. what did you calculate the probability to be that any worker at the factory would die as a result of a radiological release?

Response:

The accident analysis evaluated historical data in addition to Pantex Safety Analysis Reports and other published safety documents. This is represented by the fact that scenarios involving accidental high explosives detonation and tritium reserve failures caused by an internal event are evaluated as being "anticipated." This means that they are expected to occur at least once within a human lifetime.

There have been no fatalities at Pantex Plant due to radiological releases. Also, no radiation-caused fatalities are predicted. Volume I, section 4.14, Table 4.14.4.11 lists the predicted number of excess latent cancer fatalities from Pantex Plant operations.

RC: 14.099

Doc: HT15/42

Have you ever heard of a case of Mr. Glen McGough? The data indicates that there actually has been a death due to a radiological accident at the plant. The exact cause of his leukemia was never exactly identified. And the court case was sealed in 1983 so that there never has been an attempt to find out if his particular death was due to a radiological release.

We've also got recent cases involving a man named John Bell who claims that his illnesses are due to a radiological release. And he also anticipates his demise soon. There may be some other cases. I have heard of a few.

In other words, without taking the actual records on people who have worked at the plant and doing anything, the probability that their deaths were in some way related to accidents that occurred in the plant, we have no reliable way of projecting how many deaths may occur in the future.

Response:

DOE has an ongoing worker health surveillance program. To date, there have been no verifiable indications of adverse health effects from employment at Pantex Plant.

RC: 14.100

Doc: HT15/43

... Based upon the actual history of the plant, could you have calculated fatalities in the future? And if the calculations that you make indicate extremely low probability of deaths in the future from radiological release, how reliable are your calculations since what we do have, what we actually know,...indicates a vastly greater risk than [what] even you calculated.

Response:

See response to comment 14.098.

RC: 14.101

Doc: HT15/44

... It bears some examination as to whether or not these particular cases are attributable to the fact that some of them were working at Pantex.

However, the point is that you've made a risk calculation. And in order to determine whether or not it's accurate, we need to identify cases which may be contributable. It's not so much that I fear what is current activity at Pantex. It's what I anticipate may be coming in the future if the plutonium processing occurs. And, in that case, we need to be exceedingly careful about the possibility of radiological production.

If we calculate now what may happen in the future and our calculations are inaccurate, we will probably be inclined to take a much greater risk in the future operations in the plant than we ought. I think you should give that consideration.

Response:

See discussion in section 1.3.10 of this volume regarding health effects.

RC: 14.102

Doc: HT15/45

I think it's worth noting that in one obvious example of an industrial accident which occurred at Pantex in 1979 that resulted in fatalities, neither the plant operator nor the Federal government was willing to take financial responsibility for the consequences of the accident.

Response:

DOE provides compensation and restitution where appropriate, in accordance with the governing law and/or Presidential direction.

RC: 14.103

Doc: HT15/49

I just need some help understanding about the consequence categories. When I looked at that, it struck me that this was an acute exposure, a one-time exposure type; is that correct, or am I misunderstanding?

Response:

Exposures from accidental releases of radioactive material are determined from the concentrations and types of material released. During the period following an accident, exposures are from direct radiation from the passing plume and from radioactive material deposited on the ground, inhalation from the plume, deposition on skin, and inhalation of resuspended ground contamination. The inhalation of resuspended contamination is calculated for the lifetime of the exposed individual. Once radioactive material enters the body, it remains there for various periods of time depending on decay and biological elimination rates. Tritium emits a weak beta particle and is biologically eliminated from the body over several weeks. Plutonium emits relatively high-energy alpha particles and is retained in the body for periods of several months to many years. This was accounted for in the EIS by calculating a committed effective dose equivalent, which is a 50-year committed dose, not an acute exposure. Obviously, when an explosion occurs, its impact apart from any associated radioactive release is limited to the timeframe of the explosion.

RC: 14.104

Doc: HT15/50

... I just wanted to understand what we're talking about when we talk about consequences. The consequences are greatly varied depending on the material we're talking about, just as you referred to. So sometimes you say the acute exposure is probably from an explosion. But, just as we talked about previously with aircraft and the probability of a...plutonium release getting into the soil, there are materials that are toxic. ...So I'm wondering, how do they take all those factors into account?

Response:

See response to comment 14.103. Additional details on long-term pathway issues has been added to volume I, section 4.14.1.

RC: 14.105

Doc: HT15/51

... The [exposures] through the operation of Pantex are in addition to, not other than, so as not to avoid one choice or the other. These are additions to exposure.

Response:

The exposures from Pantex Plant operations are in addition to those received from background sources. These exposures are discussed in volume I, section 4.14.

RC: 14.106

Doc: HT15/52

... Latent cancer fatality [risk factors] are all Greek to me. Would you talk to me about that?

I'm not sure that I know what CEDE is and what it means?

Response:

Based on recommended risk factors of 0.0005 deaths per rem in the general public and 0.0004 deaths per rem for workers, a latent cancer fatality risk can be calculated based on the amount of radiological exposure. Committed Effective Dose Equivalent (CEDE) refers to radiation doses received from radionuclides deposited in organs and tissues. Once deposited in organs and tissues, radionuclides provide a continual source of irradiation. To take account of this continuing irradiation of organs and tissues that occurs after the intake of radionuclides, the CEDE is defined. The CEDE is the time integral of the equivalent dose-rate in a specific tissue following intake of a radionuclide into the body. The CEDE is usually calculated for a 50-year period.

RC: 14.107

Doc: HT16/1

Along with that inhalation and the statement that was made in the document that DOE only addressed inhalation exposure, inhalation is the only pathway accounted for in the assessment of chemical and radiological airborne hazards from normal operations (page 4-205). Now, does this mean that there are exposure pathways of non-airborne hazards, for example, through groundwater contamination? And are these included in the analysis and where do we find them?

Response:

Detail on alternative pathways has been added to volume I, section 4.14.1.

RC: 14.108

Doc: HT16/2

Are there other pathways and accidents that are non-normal operations? Are these included in the accident analysis?

Response:

Detail on alternative pathways has been added to volume I, section 4.14.1.

RC: 14.109

Doc: HT16/3

The Acqua[v]ella Study I believe was referred to, the study on the workers at Pantex. Am I correct that this study compares workers to the community at large?...

Response:

The Acquavella study (Acquavella 1985) compared total and cause-specific mortality for Pantex Plant workers employed between 1951 and 1978 with expected mortalities based on U.S. death rates.

RC: 14.110

Doc: HT16/4

In the accident scenarios and analysis, it seems as though everything has to work 100 percent correctly all the time. ...Is there any built-in analysis for if something does not actually fall into place like it is supposed to?

Response:

Volume I, section 4.14.1.4 describes the mitigation features in place at Pantex Plant to prevent or minimize potential releases. These include multiple protective barriers and systems, reinforced buildings, and redundant safety features. Accident analysis begins with the premise that there has been an event in which some form of failure of the protective barriers or systems has taken place. Consequences are then calculated based on the type and degree of failure.

RC: 14.111

Doc: HT16/5

... Do you consider that there are different initiating events at different times that would cause a different sequence? And is there data that supports this claim?

Response:

For each facility and operation at Pantex Plant, DOE has developed or is in the process of developing a safety analysis report. In addition, other facility-specific safety analyses have been performed and documented. These documents were utilized to identify potential accidents at Pantex Plant. The frequency of internal (e.g., equipment failures or human errors), external (e.g., aircraft crashes), and natural phenomena (e.g., tornadoes and earthquakes) initiating events were evaluated for different facilities and operations. To bound the possible consequences, the amount of hazardous material available for release was taken to be the maximum allowed by facility limits, rather than what might be actually present.

RC: 14.112

Doc: HT16/6

... What is the Panhandle's background, as far as radiological exposure? What's the norm for the region?

From background sources 334 is the total natural [background radiation dose]?

So the 330 that you have here, is that in addition to the 334?

Response:

The natural background radiation in the vicinity of Pantex Plant results in an average dose to an individual of 334 mrem/yr. The 330 rem referred to here is the dose for all workers for ten years. Each worker is getting about 111 mrem/yr (0.111 rem/yr) in addition to the dose from background sources.

RC: 14.113

Doc: HT16/8

This document and, frankly, the other PEISs, don't have historic data on worker exposures at MOX fuel facilities that they're basing their projected impacts on. They don't use that kind of data. So when you come to the public and make statements like we're going to be within regulatory limits,...that doesn't have anything to do with you probabilities and your risks, because the probabilities and risks are not necessarily always related to the regulatory limits.

... I think one of the things that I would suggest is that you make clearer in the text of the document, particularly on the health issues, specifically how you're basing your analysis on historic data and where you really don't have much historic data or very limited historic data that you are, therefore, extrapolating to a 50-year CEDE or to a 10-year operational lifetime.

Response:

DOE has made this revision in the final EIS to ensure that the basis for the dose numbers is apparent.

RC: 14.114

Doc: HT17/28

My surveys of radiation and health around several different Texas nuclear facilities have impressed me with the failure of government and industry to study the health effects of such facilities in any meaningful way.

I'm happy to hear that there is another investigation of the Pantex area underway this summer by the Texas Department of Health in conjunction with ATSTR, but I believe that we need much more thorough going studies, including door-to-door surveys and follow-ups for former Pantex workers and residents of these counties.

Response:

See discussion in section 1.3.10 of this volume regarding health effects, including the planned follow-up study by the National Institute for Occupational Safety and Health (NIOSH).

RC: 14.115

Doc: HT17/29

I found it very instructive to do a simple analysis looking at all cancer mortality before the tritium accident in 1989, in which 40,000 curies were released, compared to the years after, for which I had data at the time [and] I did the analysis.

And there was approximately a doubling of the cancer death rates in Carson County after the accident compared to the four years before.

Response:

The estimated impacts of the past tritium accident are described in volume I, section 4.14 in relation to Scenario 5. The public impact from this accident is estimated at 8.0 x 10-2 person-rem. The hypothetical maximally exposed offsite individual exposure is estimated as 1.1 x 10-2 rem. This exposure would result in an increase in individual lifetime cancer probability of 5.5 x 10-6 compared with a lifetime fatal cancer probability from all other causes of approximately 20 percent for an average individual.

RC: 14.116

Doc: HT17/30

A 1979 study by...a group of University of Heidelberg scientists re-examined the U.S. experiments on which allowable emissions for nuclear facilities were based, and discovered,...in looking at the protocols of these experiments, that they were doctored from the beginning.

Soil was cooked so there were no microbes present, so the uptake of plants' radionuclides was minimized. And...the radiation was induced just before the plants were harvested, instead of into the soil from the time the plant was a seed, just as an example of the way in which science was acting to obscure the reality of radiation exposure to humans.

The German scientists concluded that the allowable emissions were too high by a factor of 100. So, I keep that in mind in thinking about the expansion of operations at Pantex.

Response:

Discussion of DOE Occupational Radiation Protection standard development can be found in 10 CFR Part 835.

The goals of current DOE radiation protection standards are based on two basic types of radiation induced health effects: stochastic and nonstochastic. Radiation-induced health effects that do not have threshold doses are referred to as "stochastic effects." Examples include cancer and hereditary effects. The objective of the radiation protection standards is to limit the probability of stochastic effects to acceptable levels. Nonstochastic effects can only be manifested if a threshold dose is exceeded; therefore, the objective of the radiation protection standards is to maintain personnel exposure below the threshold doses in order to prevent these effects.

DOE currently accepts the assumption that there is no threshold for stochastic effects. DOE also currently accepts the linear threshold model for stochastic effects. The linear threshold model assumes that any radiation dose increases a persons risk of cancer.

RC: 14.117

Doc: HT17/31

... I noticed a study of the area around Rocky Flats by Dr. Carl Johnson of the Jefferson County Health Department, who correlated plutonium levels in the soil with cancer increases around Rocky Flats. It was a very close correlation, which was corroborated later by the DOE's own studies.

The second article I found worrisome was the contention of the University of Colorado scientist who believes that there is no way you can completely capture fine plutonium particles and prevent them from escaping into the air around plutonium processing facilities.

Given that Panhandle agriculture, the Ogallala aquifer, and the health of many area residents who I'm coming to consider close friends [are] at risk in the event of contamination by plutonium, among other radionuclides that are released in plutonium processing, I would stress that the excess cancers that Dr. Johnson found, which were leukemia, lymph, lung, thyroid, testes, and breast cancers, which paralleled the cancers found in the survivors of the Japanese atom bombs, are of concern.

And would request that no expansion of Pantex operations be considered until thorough health studies, including door-to-door surveys and follow-ups, be conducted to examine the damage that I believe may have already been done to this area by previous emissions.

Response:

See discussion in section 1.3.10 of this volume regarding the planned follow-up study by NIOSH.

RC: 14.118

Doc: HT17/32

... The track record at Pantex does not give us great confidence that an expansion of an extremely dangerous operation could be handled with any more safety than we've experienced in the past.

Response:

DOE is committed to the safe operation of Pantex Plant, as well as the protection of the public, the environment, and the facility employees. The safety and health environment and impacts at the Pantex Plant are discussed in volume I, section 4.14. In addition, further information on Pantex Plant safety and environmental programs can be found in the Pantex Plant Safety Information Document and Environmental Information Document (Pantex 1996a, Pantex 1996).

The As Low As Reasonably Achievable (ALARA) program implemented at Pantex Plant minimizes radiation exposure during performance of all radiological operations.

RC: 14.119

Doc: HT17/44

... We were discussing earlier the effect, possibly the health effects on farmers that do farm on the plant site itself, [whether] that has been addressed in this document or not. We would like for it to be.

I know that my husband has done some farming on the plant site. Just the other day he was combining some wheat on the plant site. That stirs up the dust, it disturbs the soil.

Response:

Soil and vegetation sampling of these areas show no levels of pollutants that would be a hazard to farmers.

RC: 14.120

Doc: HT17/49

There has been considerable concern over the status of how the plant establishes its safety envelope, certain things like safety analysis reports that are being redone at Pantex. What is the status of updating the safety analysis reports so that you establish the safety of work for this plant?

Response:

Safety analysis reports (SARs) for Pantex Plant are being rewritten to DOE Order 5480.23. In accordance with that order, Pantex Plant has submitted a Basis for Interim Operations (BIO). The BIO includes the status of all SARs, a schedule for completion of the remaining SARs, and a summary/status of all Unreviewed Safety Questions. This report also defines the safety envelope, including compliance status. The DOE-approved BIO establishes the authorized safety basis for Pantex Plant. The latest BIO for Pantex Plant is available in the EIS reading rooms in Albuquerque and Amarillo.

RC: 14.121

Doc: HT17/50

... I think there needs to be a description of unreviewed safety questions, or unresolved.

I don't think it would hurt at all to have a chart listing what they've been in the past year or two, what are [still] pending, where we are on that.

Response:

The Pantex Plant Programmatic Information Document (Pantex 1996b) presents a listing.

RC: 14.122

Doc: HT17/51

What facilities are in compliance, and which ones aren't, with...DOE orders? And if there's been great change in recent history,...describe that change, that the orders were changed,...that [that] caused problems. Give it the context you want, but please give us more of the story to work with.

Response:

The Pantex Plant Programmatic Information Document (Pantex 1996b) presents a listing.

RC: 14.123

Doc: HT17/57

The approach to human health in the draft EIS is flawed. It uses only optimistic scenarios of exposure, statistical methods that obscure potential risks and problems. Evidence used is one-sided, a very theoretical presentation which suggests more exactness in scientific knowledge than is supportable and seems designed to lend credibility where it is not necessarily due. Moreover, the theoretical approach is difficult to [wade] through. It obscures and hides assumptions and it is meaningless to public concerns, because it is removed from everyday life experience.

Response:

The risk assessment and scenario for the EIS examined a wide range of scenarios which included failures in safety systems and emergency responses. For example, scenarios involving fires typically include failures in the fire protection system and emergency fire response crews in their event sequences. Most of the scenarios that are not initiated by external events are initiated by human errors such as dropping, improper forklift handling, or failure to follow a procedure.

Concepts of relative risk, frequency, and consequence may be both difficult to understand and removed from everyday life; however, such a theoretical approach to risk quantification is the only fair and equitable approach available. Prior epidemiological studies of Pantex Plant workers also disclose no excessive incidence of cancer at Pantex Plant. The inference from these studies is that the incremental risk to workers and the public from Pantex Plant operations are very small. Results from the more theoretical approach used in the EIS are consistent with these empirical conclusions.

RC: 14.124

Doc: HT17/59

The data are one-sided. The use of prior studies and data in the draft EIS present only one side of the scientific debate about the effects of low-level ionizing radiation.

The presentation is very lopsided. Studies not cited suggest health effects including leukemia, thyroid cancer, and multiple myeloma have been found in nuclear workers whose cumulative dose for their total working years was between 2.5 and 5 rem. On page 4-205, it is reported that the average annual dose of workers at Pantex is 111 millirem. If we take a worker who is at the plant for 25 years, then 111 millirem times 25 years is a cumulative dose of approximately 2.775 rem. This value is within the range for which health effects were observed in these studies. Moreover, if we take the Pantex control level of 500 millirem per year for most workers, 900...weapons operation workers, we get cumulative doses over a 25-year working life of 12.5 rem and 22.5 rem, respectively. These values are all much higher than the levels at which health effects are observed in these studies.

The agency should reevaluate the risk to workers from low-level radiation exposures using the risk factors reported in these studies.

Response:

See discussion in section 1.3.10 of this volume regarding the radiological risk factors.

RC: 14.125

Doc: HT17/60

... As the scientific uncertainty highlights, the standards used by EPA, NRC, and DOE are not protective standards. They are politically negotiated standards that allow workers and communities in the vicinity of a nuclear facility to bear a higher cancer risk for the social benefits that are believed to come from the facility.

Response:

See response to comment 14.116.

RC: 14.126

Doc: HT17/61

The Acquavella study referred to, of 1985, relies on a weak methodological approach and data sources that compares workers to the community at large. The cancer registry data are not a credible source of data for detecting radiation effects in the community surrounding nuclear facilities.

Response:

See discussion in section 1.3.10 of this volume regarding the radiological risk factors.

RC: 14.127

Doc: HT17/62

The draft EIS relies on inappropriate data to make risk estimates and comparisons in the communities surrounding the Pantex Plant. Again, the most optimistic picture is painted with selective use of evidence and methods. More rigorous studies are needed to more effectively estimate these risks.

Response:

See discussion in section 1.3.10 of this volume regarding the planned follow-up study by NIOSH.

RC: 14.128

Doc: PC-017/4

What studies have been made on the short-term and the long term health and safety of those of us living near the plant, agricultural workers on and around the plant, and the workers [at] the plant? Have past Pantex workers' health been studied? Have there been follow-up health studies been made on the workers? How were the health and safety studies done? When? What are the results? No decision of the future of Pantex can be made until answers to these questions are assessed. Answers can only be found after adequate studies have been made.

Response:

See discussion in section 1.3.10 of this volume regarding health effects inclusive of past, present and future health studies.

RC: 14.129

Doc: PC-017/5

We are told the activities at the plant have no and will not have any effect or at most limited effect on the Pantex workers and on the neighbors and agricultural workers, yet studies have not been made for those conclusions. We are relatively certain that past activities have been a serious threat to both workers and neighbors. The DOE and the contractors seem very reluctant to admit to those health and safety concerns. They appear to get very upset when any instances of health and safety get out. Why? Should not the public be kept informed of such matters? If not, why not?

Response:

Each year, the Pantex Plant publishes a Site Environmental Report. It includes a reporting of all impacts to the environment and the public. The Pantex Plant Safety Information Document (Pantex 1996a), contains a listing of past accidents and events and explanations of their consequences.

RC: 14.130

Doc: PC-017/8

Most of us cannot afford to spend anywhere near what the DOE can and does to keep from paying claims. [For] example, the John Bell compensation case in which Mr. Bell was made very ill because of uranium toxic fumes while he was drilling a uranium plug from a warhead. The DOE spent hundreds of thousands of dollars to keep from paying about a $85,000 claim.

Response:

See response to comment 14.102.

RC: 14.131

Doc: PC-017/9

In the event of a disaster that causes damages to our agricultural products and/or land, and/or inability to market our products because of possible contamination, will the DOE pay for those damages at a fair market value in a timely manner? Will they pay willingly without our having to take them to court? Will the DOE pay us for the lose of our top soil and clean the damaged soil?

Response:

See response to comment 14.102.

RC: 14.132

Doc: PC-017/14

Is there a greater risk to farmers who are plowing and working the soil and harvesting of crops near the site than to the general public? What studies have been done to determine the potential of greater exposure? Should not these studies be done? Is there a danger to our children playing in their [sandboxes] or their swimming pools?

Response:

See response to comment 14.119.

RC: 14.133

Doc: PC-017/15

Page 4-104 discusses collective dose to surrounding population in a 50-mile radius. Would not [people] living next to the plant, especially those downwind be expected to receive a greater dose than someone who lives in Vega to the west, up wind, and about 40 miles away? Would not people downwind receive higher doses than those generally up wind? If not, we ask for your proof.

Response:

People downwind of a release would receive a greater dose than those upwind of a release. People closer to the site will receive a greater dose from a release than a person in Vega.

RC: 14.134

Doc: SG-012/4

Vol. 1, page 5-65, 5.5.2 Resources Discussed in Detail, 5.5.2.1 Human Health, Impacts of Storing 20,000 pits, "The combined worker dose from unloading storage of 20,000 pits at the Manzano WSA would be 283 person-rem distributed over the 30 people directly involved material movement." If there is a collective effective dose of 283 person-rem, which is a sum of a population of 30 workers, then the average effective dose per worker is 9.43 rem. The maximum yearly allowable dose for radiation workers is 5 rem, according to DOE order 5480.11 "Radiation Protection for Occupational Workers" (1992, DOE). The projected radiation dose for these workers is in excess of the yearly allowable dose. The DEIS statement should be clarified and the calculation (inclusive of the population numbers) on person-rem provided.

Response:

The 283 person-rem projected exposure is for the transfer of 20,000 pits over an approximately 10-year time period. It is not, as the commentor suggests, a yearly exposure.

RC: 14.135

Doc: SG-012/5

The term "person-rem" should be defined in the glossary section.

Response:

This term has been added to Chapter 10.

RC: 14.136

Doc: SG-012/6

Vol. 1, page 5-65, 5.5.2 Resources Discussed in Detail, 5.5.2.1 Human Health, Impacts of Storing 20,000 Pits, and Impacts of Storing 8,000 Pits. Population doses and risk estimates from accidental releases are based on current populations. Pits are placed in interim storage for 20 years, for instance, and projected population growth is not reflected in the estimated doses (nor is risk) over this time period. Albuquerque has had a high increase in population in the last 20 years.

Response:

It is DOEs policy to evaluate site-wide NEPA documents at least every five years to determine whether the existing EIS remains adequate and whether to prepare a new site-wide EIS or supplement the existing EIS (10 CFR 1021.330).

RC: 14.137

Doc: SG-012/8

Does the close proximity of the pit storage to weapons presently stored in the Manzano WSA pose an increase in potential nuclear accidents? Why would they not pose a problem?

Response:

Weapons are not stored in the Manzano Weapons Storage Area.

RC: 14.138

Doc: FG-003/13

EPA believes that the FEIS should provide more documentation as to potential groundwater impacts should an earthquake harm the plutonium pit facility or render it inaccessible. In particular, we are concerned that DOE may have concluded that leaving the plutonium pits inside the P-Tunnel (should it collapse) may have less environmental impact than attempting to retrieve the pits from inside a collapsed P-Tunnel (due to wording in the Pantex DEIS that impacts to workers and the public from radionuclide releases would be "negligible" because the plutonium containers would be sealed inside the collapse tunnel). Additionally, potential NTS impacts to groundwater, such a scenario, were not discussed in the Pantex DEIS. We recommend that the FEIS provide more information of the depth to groundwater in the Device Assembly Facility and P-Tunnel areas and whether keeping plutonium pits in a collapsed tunnel may ultimately cause a migration of radioactivity to groundwater.

Response:

The analyses of this EIS focuses on immediate or near term effects on the environment and do not address potential impacts over hundreds or thousands of years. In this specific example, DOE has not concluded that, in the event of a tunnel collapse, pits should be left entombed rather than retrieved.

DOE would evaluate the circumstances of any accident after it occurred to formulate the appropriate response. Since the response to each accident is highly dependent upon the actual accident that occurs and the associated immediate risks, it is not appropriate to develop detailed accident specific plans in advance. General responses to emergency conditions are contained in the Nevada Test Site (NTS) emergency preparedness plans. Should the site be selected for interim storage, those plans would be updated to include the storage activities. A search is ongoing for more data on depth to groundwater at both sites.

RC: 14.139

Doc: FG-003/16

The Pantex Summary (Table S-2) identifies the environmental impacts associated with the alternative pit storage relocation sites. For NTS, the range of potential accident scenarios are limited to two: puncture of a pit due to a forklift accident and an aircraft crash. Potential seismic hazards at NTS are not recognized in Table S-2, as they were in Volume I. We, therefore, recommend that Table S-2 be modified to recognize NTS seismic hazards. Table S-2 should also reflect seismic conditions that may exist at the proposed interim pit sites in South Carolina, New Mexico and Washington State. Modifications to Table S-2 should be incorporated into the FEIS.

Response:

As discussed in volume I, section 5.2.2.1, the human health risk from accidents at the NTS is dominated by handling accidents. The contribution to risk from seismic events is negligible. As described in volume I, section 5.3.2.1, the relative risk from earthquakes at Savannah River Site is over two orders of magnitude below the risk from a forklift accident. Volume I, section 5.4.2.1 describes the relative risk from earthquakes at Hanford Site to be negligible. As described in volume I, section 5.5.2.1, radioactive release from a Manzano storage facility would not result from an earthquake as long as the rock overburden remained intact and the doors leading to the storage facility remained closed. As identified in volume I, Summary Table S-2, the risk at all four alternative sites is dominated by a forklift accident.

RC: 14.140

Doc: HT16/11

It just occurred to me just as I was listening to you talk about whether or not there would be less exposure if the pits were left on site rather than transporting them, and I wondered if the repackaging were not part of the long-term storage in that option if they were to be left on site. And,...if so, if repackaging is a part of the action, that would be part of the analysis also? Because it would provide the same worker exposure as taking it out of the bunkers and moving it to a new location.

Response:

Pits are planned to be repackaged into AT400A containers no matter which alternative is chosen. The onsite transfers required for this activity are discussed in volume I, section 4.12. Onsite movements of pits differ significantly from offsite pit shipments. Because of the limited speeds for onsite transfers, the restraint procedure required for pit containers is less complex and less time consuming than the restraint procedure for offsite shipments. Because of the additional complexity of the restraint procedure, dose estimates for offsite transfers are greater than the estimates for onsite transfers.

RC: 14.141

Doc: HT16/12

... If Pantex is chosen for long-term storage, then the workers would actually be exposed to the same activity, bringing them [the pits] out of the bunkers as they would if they were taken out and moved to another location.

Response:

RC: 14.142

Doc: PC-031/3

There is certainly no community health study upon which DOE can even base the assertions they make. The public, Pantex workers, and former workers deserve adequate health studies of the cumulative impact and adverse health affects resulting from combined exposures to radiological substances, hazardous chemicals, toxic releases, and daily emissions. DOE can not expect to be credible and has no basis to assert "no significant impact" until proper studies have been done.

Response:

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

RC: 14.143

Doc: PC-025/71

Page 4-205. Isn't it more accurate that the majority of Pantex Plant workers receive no detectable (or observed) radiation exposures?

Response:

The commentor is correct. There is a lower limit below which radiation exposures are nondetectable from background radiation.

RC: 14.144

Doc: PC-025/72

Section 4-14. What's the big deal with the analysis? The death rate for us all is 100 percent. In the event of a serious accident resulting in deaths, shortened life spans, loss of the Ogallala [aquifer], loss of agriculture, or other damages, what are DOE's commitments to citizens of Amarillo (and others) for the damages? Is the answer "Nothing, it was an act of god, war, the contractor was at fault?" I am serious when I ask this questionWhat are DOE and its contractors committed to should something go wrong? The people in Amarillo should know as well as the rest of us. Please don't answer the question with safety policy BS.... I want the answer to make the lawyers hurt a little bit from sticking their collective necks out. One hundred percent restitution? What the country can [bear]? What the lawyers can squeeze out? What the politicians can get? We the People will do what is right, just, and in the finest tradition of America? What is the insurance?

Response:

DOE would respond to immediate emergency conditions in accordance with the Pantex Plant Site emergency preparedness plans. The Department would evaluate the circumstances of any accident after it occurred to formulate the appropriate response. Since the response to each accident is highly dependent upon the actual accident that occurs and the associated immediate risks, it is not appropriate to develop detailed accident specific plans in advance. Long-term commitments in terms of clean-up levels or possible compensation would be in accordance with applicable laws, regulations, and direction by the President and Congress.

RC: 14.145

Doc: PC-025/73

Table 4.14.2.1-2. Frequency of Scenario uses carefully chosen words like Anticipated, Unlikely, et cetera. Please include the mathematical representation in the table...for the purpose of improved clarity. Please explain where the risk of a tornado is in table 4.14.2.1-2. Where is a [lightning] strike event? It is a well known fact that one is more likely to be hit by [lightning] than winning the lottery. Isn't a release of mercury likely? What about an accidental shooting? What is the risk of an employee being killed by an automobile onsite? Where is electrocution of an employee or a construction worker? What about confined space entry problem?

Response:

Natural phenomena events include weather-related occurrences (e.g., tornadoes and severe winds) and earthquakes. They are accounted for in the accident analysis by being included as initiating events that results in a failure and release (e.g., tritium reservoir failure). In volume I, section 4.14, Table 4.14.2.1-2, natural phenomena are identified as possible initiators in Scenarios 3, 4, 7, 8, and 10. The risk from tornadoes and lightening strikes is dominated by the risk from earthquakes for all sites. The other events mentioned in the comment (mercury release, accidental shooting, automobile casualty, electrocution, and confined space entry) are not risk dominant.

RC: 14.146

Doc: PC-025/74

Page 4-223. Should consider the Annual Risk to be calculated for the Texas Panhandle, I believe that is more representative of the Pantex area. Also consider showing the Annual Risks for Oklahoma, New Mexico, and Kansas.

Response:

The annual fatal cancer risk in Potter, Randall, and Carson Counties surrounding Pantex Plant is 1.7 x 10-3 LCF/year. Nationwide, the cancer risk is slightly higher. It is more appropriate to compare the Pantex Plant human health impacts with the annual fatal cancer risk in the vicinity of Pantex Plant since that is the area assessed in the EIS.

RC: 14.147

Doc: PC-025/75

In Scenario 7 on Page 4-231, how many reservoirs (or what percentage) fail during the scenario? Does the hydrogen released explode (like the Valujet oxygen problem) and propagate? What is the inventory of sympathetic explosive, flammable, and combustible material in the adjacent buildings to the vault. Any weapons in the adjacent buildings that could result in a Scenario 9 event? What about stored/moving to being stored pits that would be near the vault and result in a Scenario 8 event? Would the damaged reservoirs react like missiles? Would this result in further release from other reservoirs? If the vault is breached, are others killed due to the hydrogen gas fire and reservoir missiles? How many people would be killed by the concussion blast of the aircraft impact and flammable material explosions resulting after the crash? How many people are likely to be in the area? What documentation is available to prove all the tritium is not released in a massive explosion? The estimated number of tritium container breaches is consistent with plutonium container breaches resulting from an aircraft crash? Are the reservoirs designed stronger than the [plutonium] cans? In the event of a total release of tritium in the vault, a Scenario 8 event, and a Scenario 9 event, what is the probability and the consequence (in curies and fatal cancer probability)?

Response:

In Scenario 7, all of the reservoirs in the building are assumed to fail due to overheating. The hydrogen (tritium) release is oxidized in the flames but does not explode. The adjacent building 12-42 contains flammable and combustible materials which are ignited. These materials are the heat source that cause the reservoirs to fail. Due to the small size of the reservoirs, they would not behave like missiles.

During any aircraft crash, the number of people killed in the impact area would depend on the type of aircraft, time of impact, and typical occupancy of the structure being impacted. The assessment did not quantify the number of potential fatalities but only recognizes that fatalities would occur if such an event were to happen.

The tritium reservoirs are robust but are not designed to the same standards as the AT400A plutonium storage container. The risk associated with an aircraft impact into 12-42 South Vault is bounded by the risk of Scenario 7 because the frequency of Scenario 7 is greater than the frequency of an aircraft impact into 12-42 South Vault.

RC: 14.148

Doc: PC-025/76

What is the concussion blast resulting from impact? What is the kill zone from the impact and the resulting fire? What is the number of plant causalities?

Response:

See response to comment 14.147.

RC: 14.149

Doc: PC-025/77

The eleven scenario analyses are flawed since [they do] not allow for multiple scenarios resulting from one initial event. As an example, many aircraft accidents involve two planes; however, this analysis looks at only one impact location. Further, a plane could lose an engine, as it breaks apart, into a weapon magazine while the remainder slams into a pit storage facility. Aircraft impact into tritium vault resulting in damage to pit and or weapon being moved and in near vicinity of ground zero.

Response:

In the Draft DOE Standard for Aircraft Crash Analysis (DOE 1996g), the probability density function, used for computing the probability that an aircraft will crash, is based on national averages of all types of aircraft crashes including incidences where two aircraft were involved. Thus, this aspect has been considered in the methodology. In terms of the debris from one crashing aircraft striking multiple facilities, the analysis includes aircraft dimensions (wingspans), building dimensions (length, width, and height) and locations, and geometric factors which allow an aircraft to impact multiple facilities. The engines possess the density and structural integrity to cause significant building damage and were modeled as the primary penetrators for the facilities of interest. The rest of the aircraft is not as capable of causing building damage to the majority of the Pantex Plant facilities included in the analysis.

RC: 14.150

Doc: PC-025/95

Accident analysis is flawed because severe weather is not analyzed.

Response:

As discussed in volume I, section 4.14.2.1, severe weather is included in the evaluation of natural phenomena event initiators.

RC: 14.151

Doc: SG-003/1

In Section 4.14.2.1 (page 4-219...) and in Figure 4.14.2.1-1 (page 2-224), a classic error is made in explaining potential latent cancer fatalities. The error is to use risk estimates for exposures to large populations and to assume that applying that risk estimate to a specific group of workers allows for definitive conclusions about that group. In this example, the figure provides the correct explanation. The text is misleading and might cause confusion in the community by indicating that the 330 plant workers would suffer a certain number of cancers.

Response:

Further clarification of the interpretation of risks has been provided in section 1.3.10 of this volume.

RC: 14.152

Doc: SG-003/2

Health effects are important to understand. The section on continued operations talks about health effects for workers. A statement is made that workers would experience additional cancers. In the figure, a different explanation is used. The statement in the figure is that an average number of cancers could occur if many groups of workers were exposed. The final statement was that the most likely outcome is zero cancers. What is the correct explanation?

Response:

Further clarification of the interpretation of risks has been provided in section 1.3.10 of this volume.

RC: 14.153

Doc: SG-003/5

Appendix D, Human Health, does very little to explain how the impact to human health is derived or calculated. This appendix is more of an explanation of the risk assessment methodology than human health.

Response:

Duplicate comment. See response to comment 14.087.

RC: 14.154

Doc: SG-003/6

The U.S. Department of Energy's Office of Emergency Management (NN 60) and the Office of Emergency Response (DP 23) fund the DOEs Atmospheric Release Advisory Capability (ARAC) which is housed at the Lawrence Livermore National Laboratory. ARAC's computer models, which have world-wide acceptance, have been called into service in many real-time responses to both real and potential accidental releases of radioactive material. The Three-Mile Island nuclear power plant accident in 1978, the 1986 Chernobyl disaster in the former Soviet Union, and the U.S. Air Force Titan II missile accident in Damascus, Arkansas are just a few examples. In addition, the ARAC models have been utilized in every nuclear weapons accident exercise since NUWAX 79. Pantex Plant is an "ARAC Site" and is linked to the ARAC center in Livermore via a computer-to-computer connection. ARAC operators are familiar with Pantex operations and can respond in a matter of a few minutes with a computer model graphic output showing the trajectory of the plume of contamination in the event of an accident. When, and if, a real accident occurred at Pantex it would be the ARAC models and the ARAC capability that DOE would call upon to response in real time. Since ARAC is funded by DOE Headquarters and is ready to respond to a radiological accident at Pantex, why did DOE choose to use a model like ERAD to assess consequences for this EIS?

Response:

See response to comment 14.085.

RC: 14.155

Doc: SG-003/8

Enhancement of public safety, protection of public health and the prevention of environmental degradation are crucial factors for assessing Pantex Plant mission accomplishment. Texans must be assured that these issues will receive sufficient attention prior to any decisions regarding plant operations. Thorough and complete assessment of consequence analyses to a satisfactory confidence level is required to support the decisions under consideration.

Response:

See response to comment 14.118.

RC: 14.156

Doc: SG-003/9

In the Summary, page S-9, right column, it is stated that 8.1 E-6 Latent Cancer Fatalities (LCF) per year would result from and aircraft crash into a facility with a weapons high explosive detonation. Scenario 3, described in Volume I, page 4-229 conflicts with this statement, indicating that the increased risk is 1.8 E-11 latent fatal cancers per year. Table 3.14.2.l-4 in Volume I page 4-228, Excess Cancer Fatality Risk for Scenario 3 lists 5.1 E-6. These figures need to be verified, reconciled, and, if necessary, corrected.

Response:

The accident figures have been revised and verified.

RC: 14.157

Doc: SG-003/10

In the Summary, page S-10, left column, it states that from an aircraft crash into Zone 4 facilities, 1.5 E-6 LCF per/yr for 20,000 pits and 9.8 E-7 LCF per yr for 8,000 pits would result. Table 4.14.2.1-4, Volume 1, page 4.228, Scenario 9 lists 6.0 E-8 excess cancer fatality risk. For Zone 4 weapons storage, 6.8 E-7 LCF/yr is given on page S-10. Scenario 3 in Table 4.14.2.1-4 lists 5.1 E-6 excess cancer fatality risk. Page 4-250 lists the increase in fatal cancer risk as approximately 2.2 E-11 increase in fatal cancer risk (compared to a baseline risk of 1.5 E-3 per yr). These figures need to be verified, reconciled, and, if necessary, corrected.

Response:

These figures have been verified and have been corrected in the EIS. Scenario 9 risk estimates are dominated by a seismic event effecting Zone 12 rather than by an aircraft crash into Zone 4. The risk estimates for Scenario 3 include aircraft crashes into both Zone 4 and Zone 12 buildings. The fatal cancer risk referred to on page 4-250 of the Draft EIS is for an average individual which is obtained by dividing the risk to the entire population within the region of influence (ROI) by the number of people within the ROI.

RC: 14.158

Doc: SG-003/13

In the Summary, Table S-1, page S-20, gives a 4 E-l2 increase in fatal cancer risk, whereas in the same table, on page S-26 a duplicate entry gives 3 E-12. Volume I, page 4-229, Scenario 3 lists an increased risk of 1.8 E-l1 LCF per year. Table 4.14.2.1-4, Scenario 3 gives 5.1 Excess Cancer Fatality Risk. Volume II page 4-250, right column lists 2.2 E-11 increase in fatal cancer risk (per yr). These figures need to be verified, reconciled, and, if necessary, corrected.

Response:

The entry in volume I, Summary, Table S-2 on page S-26 of the Draft EIS is not a duplicate of the entry in Table S-1 on page S-20. The entry in volume I, Summary, Table S-2 of the final EIS addresses the impact from pit storage only. The entry in Table S-1 was in error and has been corrected. The accident excess cancer fatality risks have been verified.

RC: 14.159

Doc: SG-003/14

In the Summary, Table S-2, page S-25 right column, sixth line, between "in" and "0.04", insert "0.11 LCF and".

Response:

Agreed. The summary has been amended.

RC: 14.160

Doc: SG-003/15

In Volume I, page 4-l55, right column, the projected population in the ROI in 2055 ranges between 214,353 and 246,464. Figure 4.14.2.1-1, page 4.223 gives the ROI population of 267,107 for risk estimates. Volume II, page D-28, left column, gives the population in the ROI as 267,107 for fatal cancer estimates. An explanation of the different populations is necessary, or one of the ROI needs to be re-named.

Response:

The region of influence (ROI) for the socioeconomic analysis is defined on page 4-155 as the four counties surrounding Pantex Plant. The ROI for the human health analysis is the offsite population within an 80-kilometer (50-mile) radius of Pantex Plant as depicted in volume I, section 4.14, Figure 4.14.11. The text calling out Figure 4.14.1-1 in volume I has been modified by adding the following sentence so that the ROI for the human health analysis is more clearly defined: "This circular area surrounding Pantex Plant is the Region of Influence (ROI) for the human health analysis."

RC: 14.161

Doc: SG-003/16

In Volume I, page 4-215, right column, the statement concerning the Pantex Epidemiologic Surveillance 1994 Annual Report should be updated to indicate that the report has been released. (The l995 Annual Report may also be available by the time the Final Report is issued.)

Response:

Agreed. The EIS reflects the release of the 1994 Annual Report.

RC: 14.162

Doc: SG-003/17

In Volume I, page 4-223, Figure 4.14.2.1-l, fifth line from bottom, incorrectly refers to Table 4.14.2.1-3. The correct reference is Table 4.2.l.1-4. A similar error was noted in Volume II, Appendix E, page E-23, left column at the end of paragraph E.3.1.6.

Response:

Agreed. These corrections have been made in the EIS.

RC: 14.163

Doc: SG-003/39

... The risk from ingestion of hazardous substances should also be included when calculating risk to onsite workers. The EIS only accounts for risk from inhalation.

Response:

The risk from ingestion of hazardous substances was not included because the risk to onsite workers is dominated by the inhalation pathway.

RC: 14.164

Doc: HT17/74

Without better data from these types of analyses, large uncertainties remain embedded in the draft EISand these are not mentioned or addressed. These are different kinds of uncertainties than what I mentioned in #2 above. Those were scientific uncertainties. Now I am talking about uncertainties in the data. A third kind of [uncertainty occurs] in measurements (because of lack of precision in instrumentation).

Response:

A discussion of uncertainties and the method of incorporating uncertainties in the accident risk assessment is provided in volume II, section D.6.

RC: 14.165

Doc: HT17/75

There are also inter-individual sensitivity issues to the public. For example, studies (not reported in the draft EIS) have found that prenatal x-rays, averaging between 20 mr [and] 400 mr have been found to double the risk of childhood cancer (Stewart and McMahon). Other studies have found effects from low-level radiation exposure (e.g., Kerber 1993). By the way, on page D-4 the Agency states that "since nondestructive examination using x-rays and gamma rays is a well established industrial practice, this contribution to worker risk is negligible." It may be a well established industrial practice, but there are newer studies that suggest the risks of low-level exposure from x-rays may not be so benignthey clearly are not safe because, again, there is no safe level of radiation exposure.

Response:

The risk factors used in the EIS to estimate the health impacts of radiation exposure are obtained from the 1990 report of the National Academy of Sciences Committee on the Biological Effects of Ionizing Radiation, usually referred to as the BEIR V report (NAP 1990). The studies of Drs. Alice Stewart, Brian MacMahon, and Richard Kerber were included in their assessment of the health impacts. While the risks associated with nondestructive examination are negligible, nevertheless the worker exposure from this source is accounted for in the overall worker radiation exposure.

RC: 14.166

Doc: HT17/76

The draft EIS uses BEIR III and BEIR V reports (pages D-1 and D-2). The risk factors derived from these reports are based on the hypothetical man. Thus, they do not adequately account for inter-individual sensitivity to exposures of radiation. There is no analysis of inter-individual sensitivity in the draft EIS, except the insufficient claim that conservative numbers and scenarios are used. This is not an analysis of inter-individual sensitivity. It is a way of obscuring uncertaintiesagain. The DOE should recalculate risk factors using a more sophisticated analysis of inter-individual sensitivity among workers and men, women, childrenit is also an issue for environmental justice. For example, the composition of the workforce at Pantex is 20 percent minority (see below for more comments about environmental justice).

Response:

The risk factors presented in the BEIRV report have been endorsed by both national and international radiation protection organizations as the best description that can be provided at this time of the risk of cancer resulting from a specified dose of ionizing radiation. These organizations include the National Committee on Radiation Protection and Measurements and the International Commission on Radiological Protection. The risk factors utilized in the EIS have also been endorsed and adapted by other federal regulatory agencies including the Environmental Protection Agency and the Nuclear Regulatory Commission. Details of the uncertainties in these risk factors, including inter-individual sensitivity is available in the following report: BEIRV National Research Council, "Health Effects of Exposure to Low Levels of Radiation," National Academy Press, Washington, DC, 1990 (NAP1990).

RC: 14.167

Doc: HT17/77

The accident scenarios analysis presents the most optimistic view possible. All administrative control and safety programs are assumed to function properly at all times (e.g., air locks). Numerous examples of malfunctioning or improperly used safety and emergency response equipment and procedures, malfunctioning emergency back-up systems, human errors, et cetera have led to accidents in a variety of industriessome of them highly regulated, such as the nuclear power industry, aircraft carriers, offshore oil drilling facilities, airlines, space travel (space shuttle), et cetera. In many cases, the failures were of the type that were anticipated but they occurred in sequences or combinations that were not, or the failure rates turned out to be higher than anticipated. Many of the failures can be associated with "human reliability" issues (Tuler et al 1988, Tuler et al 1991, Tuler et al 1992, Kasperson et al 1995), and many...more.

Response:

See response to comment 14.123.

RC: 14.168

Doc: HT17/78

In the draft EIS there is no way to know how much attention was given to human error/reliability analysis in the evaluation of accident rates or consequences. As I noted above, the document assumes that all emergency response and administrative safety programs/control function at 100 percent at all times. Can the Agency provide data to support this claim? Do they have data about the rates of incidentshuman errors in different tasks that are relevant to this study? What is their definition of "recordable" (i.e., reportable) incidents? What is included in Table 4.14.1.4-1? What are the data for events which did not result in a lost worker day?

Response:

Human error/reliability was evaluated and is often the initiator for many of the scenarios addressed in the EIS. The document does not assume that all emergency response and safety systems function at 100 percent at all times. Pantex-specific data, nuclear industry data, and general industrial data were used to obtain human error rates for various tasks. Pantex Plant reports occupational injuries and illnesses in accordance with Title 29 CFR, Part 1904. As indicated in volume I, section 4.14, Table 4.14.1.41, not all recordable cases resulted in lost workdays.

RC: 14.169

Doc: HT17/79

The Agency should describe in detail its safety and emergency response plans and training programs for onsite employees and for offsite personnel (including those in the transportation system). Have any analyses/evaluations been conducted on the reliability and effectiveness of response? Can they supply data about the failure rates associated with the safety and emergency response elements (mechanical and human)?

Response:

The safety and emergency response plans and training programs for onsite employees and for offsite personnel (including those in the transportation system) are voluminous, and inappropriate for verbatim inclusion in the EIS. Moreover, the conservative accident consequence assessments in the EIS ignore worker and public evacuation. Hence, details pertaining to safety and emergency response plans and training programs are not germane to the EIS human health evaluations. Failure rates associated with the safety and emergency response elements (mechanical and human) are used as the basis for the accident risk assessment in the EIS.

RC: 14.170

Doc: HT17/80

Has the DOE completed task analyses of the high risk tasks; e.g., assembly and disassembly of pits and explosive components?

Response:

Detailed task analyses are completed on the assembly and disassembly of each weapon system. Pantex-specific data, nuclear industry data, and general industrial data were used to obtain human error rates for various tasks performed at Pantex Plant.

RC: 14.171

Doc: HT17/81

Generally, how has the DOE studied and evaluated human error in the tasks done at Pantex?

Response:

See response to comment 14.170.

RC: 14.172

Doc: HT17/82

In addition, the agency uses a baseline "activity level" of 2,000 assemblies, disassemblies, testings, et cetera per year. They say that the mix does not matter when calculating impactswhich I presume means risks from exposure from either incident free exposure or accident related exposure (page 3-2). There must be a failure rate in these tasks. It might be small but it is not zero. They may be initiating events for accidental exposures, or higher than normal "incident free" exposures. My question is whether there is any reason to believe that failure rates (human errors) in these tasks may be different? Is it "harder" to take a weapon apart than to put it together? I think of a bike or car, where bolts are stripped, pieces stick together, get old, et cetera. Can this happen? The mix of "activities" will probably change as dismantlement occurs. Does the Agency have disaggregated failure rate data for the different "activities" included in the operations done at Pantex? Produce the analysis showing that there are no differences in the failure rates associated with the different activities?

Response:

The mix of weapons operations refers to the relative portions of weapon assemblies and disassemblies. The risk from exposure is different between incident-free exposure and accident-related exposure.

There are differences between assembly and disassembly. Failure rates for the specific activities involved in the assembly and disassembly of particular weapon systems are classified. Bounding failure rates for the assembly/disassembly process were obtained from Pantex Plant safety documents.

RC: 14.173

Doc: HT17/83

Finally, I began this part by saying that the accident scenarios are all optimistic scenarios in the sense that no (or no significant) exposures result. The Agency should go through the exercise and show us what might be the effects of accidents that are not controlled perfectlywhat might be exposure pathways, exposure levels, and health effects of such a scenario? Even if the possibility is small, we would like to see what the consequences are.

Response:

See response to comment 14.123.

RC: 14.174

Doc: HT17/84

As you say, risk is the product of probability of occurrence and magnitude of consequences. What if worker exposure occurred because contamination did escape from air locks?

Response:

Consequences to involved and uninvolved workers are provided in volume I, section 4.14.

RC: 14.175

Doc: HT17/85

What accidents have occurred at the plant? As shown in Table 4.14.1.4-1, what were these accidents? Can the DOE provide us with descriptions and any results of post-accident evaluations (including the methods of evaluation)? What worked well in containing them, and what did not? In other words, what features of the accident were not anticipated to occur together or with high frequency?

Response:

The Pantex Plant Safety Information Document (Pantex 1996a) provides additional information on the accidents, incidents and off-normal or unusual occurrences at Pantex Plant. This information provides the basis for Pantex-specific accident and failure rates.

RC: 14.176

Doc: HT17/86

There is no system of community monitoring for contamination offsite? There is an implicit assumption that releases will only occur in controlled areas [or] that detection devices will observe every possible release. This does not seem to be a valid assumption.

Response:

Onsite monitors are placed to detect contaminates before offsite impacts occur. Soil sampling is ongoing to detect historical contamination.

RC: 14.177

Doc: HT17/87

There is no analysis (as far as I remember right now) of synergistic effects among radiation exposures and chemical exposures and among chemical exposures with different types of contaminants. The DOE should deal with this issue in the EIS, citing and evaluating studies that address synergistic effects of chemical exposures of different types. What analysis have they done to justify a claim that this is not a significant issue?

Response:

See discussion in section 1.3.10 of this volume regarding chemical and radiological synergism.

RC: 14.178

Doc: HT17/88

The DOE only addresses inhalation exposure. But this is a bit confusing. "Inhalation is the only pathway accounted for in the assessment of chemical and radiological AIRBORNE hazards from normal operations" (pg. 4-205). Does this mean that there are exposure pathways of non-airborne hazards? For example, through groundwater contamination? Are these included in the analysis anywhere? Likewise, are there other pathways in accidents (non-normal operations)? Are these included in the accident analyses? How? What data do you have to support the claim that airborne hazards and inhalation exposure is the only significant pathway?

Response:

Additional details on long-term pathway issues have been added to volume I, section 4.14.1.

RC: 14.179

Doc: CO-005/6

The entire approach to human health in the draft EIS is flawed. We are being asked to comment on a document which seems to be driven by the goal of reassuring the public that there are no health risks associated with the Pantex Plant. It uses only optimistic scenarios of exposure, statistical methods that obscure potential risks and problems, evidence used is one-sided, a very theoretical presentation which suggests more exactness in scientific knowledge than is supportable, and seems designed to lend credibility where it is not necessarily due.

Response:

See response to comment 14.123.

RC: 14.180

Doc: CO-005/7

Moreover, the theoretical approach is difficult to wade throughit obscures and hides assumptions and it is meaningless to public concerns because it is removed from everyday life experiences (e.g., pg. D-2, brief attempt to explain individual risk in terms of latent cancer fatalities).

Response:

See discussion in section 1.3.10 of this volume regarding radiological risk factors.

RC: 14.181

Doc: CO-005/8

The data are one-sided. The use of prior studies and data in the draft EIS present only one side of a scientific debate about the effects of low-level ionizing radiation. The [presentation is] very lopsided. Studies not cited suggest that health effects, including leukemia, thyroid cancer, and multiple myeloma, have been found in nuclear workers whose cumulative dose for their total working years was between 2.5 [and] 5 rem (Geiger et al 1992; Gilbert 1994; Kendall 1992; Kneale 1993; Wing 1991).

Response:

See discussion in section 1.3.10 of this volume regarding radiological risk factors.

RC: 14.182

Doc: CO-005/9

On page 4-205 it is reported that the average ANNUAL dose to workers at Pantax is 111 mrem. If we take a worker who is at the plant for 25 years, then 111 mrem x 25 years = a cumulative dose of approximately 2.8 (2.775) rem. This value is within the range for which health effects were observed in these studies. Moreover, if we take the Pantex control level of 500 mrem/year for most workers and 900 mrem/year of weapons operation workers we get cumulative doses over a 25-year working life of 12.5 rem and 22.5 rem, respectively. These values are all much higher than the levels at which health effects were observed in these studies.

Response:

See discussion in section 1.3.10 of this volume regarding radiological risk factors.

RC: 14.183

Doc: CO-005/11

Moreover, as the scientific uncertainty highlights, the standards used by EPA, NRC, and DOE are not protective standards. They are politically negotiated standards that allow workers and communities in the vicinity of a nuclear facility to bear a higher cancer risk for the social benefits that are believed to come from the facility. These standards should not be used to suggest that there are safe doses of radiationthere are NO safe doses of radiation. This is a commonly agreed point at this time in the scientific community.

Response:

See response to comment 14.116.

RC: 14.184

Doc: CO-005/12

The Aquavella 1985 Study relies on a weak methodological approach and data sources (e.g., it compares workers to community at large). The critiques of this study are discussed in more detail in Dead Reckoning by Geiger et al 1992.

Response:

See discussion in section 1.3.10 of this volume.

RC: 14.185

Doc: CO-005/13

More about one-sided data. Cancer registry data are not a credible source of data for detecting radiation effects in communities surrounding nuclear facilities (Sage 1994). This is a study that was done by Michael Sage, Director of CDC/ATSDR. Cancer registry data in Texas are discussed in the draft EIS on page 4-215.

Response:

Cancer risk data for the communities surrounding Pantex Plant were used to provide a relative risk comparison between the cancer risks posed by operations at Pantex Plant and the cancer risks from other causes. The effects of radiation exposure are modeled on national and international recommendations.

RC: 14.186

Doc: CO-005/14

The draft EIS relies on inappropriate data to make risk estimates and comparisons in the communities surrounding the Pantex plant. Again, the most optimistic evidence and methods. More rigorous studies are needed to more effectively estimate risksbetter exposure assessments, assessment of historical releases, and exposure pathways.

Response:

See response to comment 14.185.

RC: 14.187

Doc: CO-005/15

The draft EIS uses BEIR III and BEIR V reports (page D-1 - D-2). The risk factors derived from these reports are based on the hypothetical man. Thus, they do not adequately account for inter-individual sensitivity to exposures of radiation. There is no analysis of inter-individual senstivity in the draft EIS, except the insufficient claim that conservative numbers and scenarios are used. This is not an analysis of inter-individual sensitivity. It is a way of obscuring uncertainties--again. I would direct the Agency to a growing body of research literature on ways to address inter-individual sensitivity. The agency should recalculate risk factors using a more sophisticated analysis of inter-individual sensitivity. This is not just necessary for inter-individual sensitivity among workers and men, women, children--it is also an issue for environmental justice. For example, the composition of the workforce at Pantax is 20% minority.

Response:

See response to comment 14.166.

RC: 14.188

Doc: CO-005/16

Describe in detail the safety and emergency response plans and training programs for onsite employees and for offsite personnel (including those in the transportation system). What analyses/evaluations [have] been conducted on the reliabilty and effectiveness of response? Can DOE supply data about the failure rates associated with the safety and emergency response elements (mechanical and human)?

Response:

See response to comment 14.169.

RC: 14.189

Doc: CO-005/17

Have you completed task analyses of the high risk tasks; e.g., assembly and dissasembly of pits and explosive components? Generally, how has DOE studied and evaluated human error in the tasks done at Pantex?

Response:

See response to comment 14.170.

RC: 14.190

Doc: CO-005/18

The accident scenarios are all optimistic scenarios in the sense that no (or no significant) exposures result. Go through the exercise and show us what might be the effects of accidents that are not controlled perfectlywhat might be exposure pathways, exposure levels, and health effects of such a scenario? Even if the possibility is small, we would like to see what the consequences are. In your words risk is the product of probability of occurrence and magnitude of consequences. What if worker exposure occurred because contamination did escape from air locks? What accidents have occurred at the plant? What were these accidents as shown in Table 4.14.1.4-1? Provide us with descriptions and any results of post-accident evaluations (including the methods of evaluation). What worked well in containing them, and what did not? In other words, what features of the accident were not anticipated to occur together or with high frequency?

Response:

Duplicate comment. See response to comment 14.167.

RC: 14.191

Doc: CO-005/19

There is no analysis of synergistic effects among radiation exposures and chemical exposures and among chemical exposures with different types of contaminants. We ask that this issue be included in the EIS, citing and evaluating studies that address synergistic effects of chemical exposures of different types. What analysis have been done to justify a claim that this is not a significant issue?

Response:

See discussion in section 1.3.10 of this volume regarding chemical and radiological synergism.

RC: 14.192

Doc: CO-005/20

The agency only addresses inhalation exposure. But this is a bit confusing. "inhalation is the only pathway acounted for in the assessment of chemical and radiological AIRBORNE hazards from normal operations" (page 4-205). Does this mean that there are exposure pathways of non-airborne hazards? For example, through groundwater contamination? Are these included in the analysis anywhere? Likewise, are there other pathways in accidents (non-normal operations)? Are these included in the accident analyses? How? Provide the data to support the claim that airborne hazards and inhalation exposure is the only significant pathway.

Response:

Details on alternate pathways have been added to volume I, section 4.14.1.

RC: 14.193

Doc: PC-025/20

Also wetlands should be identified for the same reason. Like children and the elderly, arent wetlands sensitive areas requiring analysis? Since Pantex playas are points of recharge to groundwater, under an accident scenario, would not 1,000 playas in the ROI pose a significant pathway to the groundwater? If an accident occurred, what is the maximum amount of plutonium, risk to the public, and other impacts to the groundwater from the playa pathway? What is the impact if all groundwater in the ROI becomes contaminated with trace amounts of plutonium? Where are the nearest dairy cows? Should that be discussed due to high risk pathway to small children?

Response:

Additional detail on alternative pathways has been added to volume I, section 4.14 of this document.

3.15 Aircraft Accidents

RC: 15.001

Doc: HT05/6

... On the airplane accident scenario, was that scenario based on the flight paths now? Or did you take into effect that the flight paths could be changing when they get a new radar system out there at the Amarillo airport?

Will that show up in the final analysis, the final draft?

Response:

See discussion in section 1.3.11 of this volume.

RC: 15.002

Doc: HT05/7

I've heard that Delta [Airlines] no longer flies into Amarillo and that American Airlines has down-sized the aircraft that they're using. Does this have an impact on the numbers that you have provided? Is it being considered in future iterations of the model or what?

Response:

To our knowledge, a Delta Airlines shuttle continues to fly into Amarillo. Continental Airlines discontinued service into Amarillo. American Airlines used to fly MD-80s into Amarillo, but discontinued these in favor of Fokker 100s. This information will be accounted for in the RAMS data, but not necessarily in the FAA airport operations data because of the four categories this data is broken into. That is, although American Airlines replaced the MD-80s with Fokker 100s, they still constitute Commercial Air Carriers. The only difference that will be seen in the FAA data is whether or not American Airlines increases or decreases its flights per day into and out of Amarillo. Future iterations of the calculation will take this into account.

RC: 15.003

Doc: PC-021/1

It is implied that the probability of an aircraft hitting a facility would be unacceptable if it exceeded 10-7. DOT (FAA) Aircraft Systems Safety Analyses tend to place events with probabilities greater then 10-7 in the category of "improbable" and require that such an event not create any hazard. If the probability is the range, 10-9, it is considered "highly improbable" and the event may result in a hazard but no loss of life. An event of probability, 10-13, is considered "extremely improbable." No event that would be considered as "catastrophic" or resulting in the loss of life may exceed this order of magnitude in probability of occurrence. Since the perforation of or the scabbing of a structure containing nuclear weapons material is considered as having the potential for causing an explosion, this event must be considered as "catastrophic."

Response:

The value of 10-7 has been chosen by the DOE as a bounding value for aircraft accident analysis. The selected frequency categories used in the Pantex EIS are as follows:

· Anticipated (x ³ 10-2 per year)

· Unlikely (10-2 per year > x ³ 10-4 per year)

· Extremely Unlikely (10-4 per year > x ³ 10-6 per year)

· Not reasonably foreseeable (10-6 per year > x)

It can be seen that the value of 10-7 is on the fringes of the "not reasonably foreseeable" range. However, for conservatism, this value was used as a boundary. In the context of the Appendix E text, the value of ">10-7" implies falling into one of the above four ranges. Also see discussion in section 1.3.11 of this volume.

RC: 15.004

Doc: PC-021/2

The characterization of mode of operations is much improved over that in the original analysis, though I do have some question regarding the relative values of g. I find it somewhat surprising that the value for military aircraft is lower than that for commercial aircraft. This is particularly troubling since fighter, attack, and training aircraft tend to have a somewhat higher overall accident rate.

Response:

The analysis used for the Pantex Draft EIS aircraft accident analysis was that contained in the Draft DOE Standard (DOE 1995z) for "Accident Analysis for Aircraft Crash into Hazardous Facilities." The values used for the analysis came directly from this document. The values of g are part of the Solomon model which has been eliminated in its use in the Final EIS. In-flight aircraft were analyzed using the new non-airport model.

RC: 15.005

Doc: PC-021/3

The impact angle used in the analysis is 15 degrees. This approach ignores the possibility of higher angle impacts such as those demonstrated by the United Airlines Boeing 737 in Colorado Springs, the US Air Boeing 737 in Pennsylvania, the American Eagle ATR72 in Indiana, and more recently, the Valujet DC-9 in Florida. (Incidentally, at least three of these accidents occurred during the "in-flight" phase of flight.)

Response:

See discussion in section 1.3.11 of this volume. Additionally, the Final EIS uses guidance provided by the Draft DOE Standard (DOE 1996g) on aircraft crashes. This Standard uses even more conservative impact angles of five to seven degrees dependent on the flight mode and aircraft category. It should also be noted that the structural penetration calculations included aircraft striking the structures via skidding into the walls as well as direct hits onto the roofs. Direct high impact angle hits represent a small fraction of the risk.

RC: 15.006

Doc: PC-021/4

General aviation turbojets have wingspans of up to 90 feet.

Response:

The range of values listed in Table E.2.21 of volume II of the Draft EIS came directly from the Draft DOE Standard (DOE 1995z) for "Accident Analysis for Aircraft Crash into Hazardous Facilities." This value does not significantly affect the analysis results since the average weighted representative wingspan for aircraft near Pantex was used, and maximum wingspans were used for the other candidate storage sites. The Draft DOE Standard (DOE 1996g) wingspans are listed in Table E.2.21 of the Final EIS.

RC: 15.007

Doc: PC-021/5

I question the accuracy of the stated equation for the speed of sound in soil. This is stated as:

Cs = {(Es á g) Ö r}0.5 where

Cs = the speed of sound in soil (ft/sec)

Es = the modulus of elasticity of soil = 470,000 lb/ft2

r = the density of soil = 130 lbs/ft3

g = the acceleration due to gravity = 32 ft/sec2 (actually, g = 32.174 ft/sec2)

Using these values, I calculate the speed of sound in soil to be 340 ft/sec. I find this to be quite low in light of the Sea Level, ISA value for the speed of sound in air (1,116 ft/sec). Unfortunately, I do not have ready access to references regarding the values of Es and r.

Response:

Using the values provided, the speed of sound in soil does result in a value of 340 ft/sec. An independent source was reviewed for application of the speed of sound in soil and it indicated that the speed of sound in soil was approximately 39 percent of that in air. This value is dependent on the type of soil but shows the above overburden equation referred to by the commentor is applicable.

RC: 15.008

Doc: PC-021/6

It should be noted that the 4,800 feet Mean Sea Level (MSL) ceiling for the prohibited airspace over the Pantex Plant equates to approximately 1,200 feet Above Ground Level (AGL).

Response:

This has been corrected in the Final EIS.

RC: 15.009

Doc: PC-021/7

It is stated that helicopters have been omitted as a hazard "because they are forbidden from flying in the airspace over Pantex Plant and have little potential to penetrate facilities of interest." This is an incorrect statement. Helicopters are prohibited from operating over the Pantex Plant at altitudes of less than 4,800 ft MSL. They are free to overfly the plant at higher altitudes. Further, some helicopters operate at extremely high weights and flight speeds. For example, let me submit the Sikorsky MH-53.

Response:

According to information obtained from the Amarillo Tower, helicopters are prohibited from flying over the Pantex Plant at altitudes less than 4,800 MSL (1,200 AGL). The only exception to this rule is the Southwestern Public Service (SPS) helicopter which does powerline inspection and maintenance. However, they must call the Tower for permission to do so. Information obtained for the Draft EIS was incorrect, and as a result helicopters were not considered in the Draft EIS. Helicopters have been included in the Final EIS aircraft analysis.

RC: 15.010

Doc: PC-021/8

There is a typographical error in which the Saab SF340 is referred to as the SF34.

Response:

In reading aircraft data from the RAMS data, some aircraft designators are abbreviated. It is our understanding that the SF340 and the SF34 are the same kind of aircraft. The text has been modified in the Final EIS to read SF340.

RC: 15.011

Doc: PC-021/9

What category of operation do test flights by aircraft from the modification and maintenance facilities at Amarillo International Airport fall under?

Response:

See discussion in section 1.3.11 of this volume. These flights are included in the RAMS data and are included in the FAA data as part of the takeoff and landing operations at the Amarillo International Airport.

RC: 15.012

Doc: PC-021/10

RAMS data from 25 days in May 1995 were used to determine the spectrum of overflights on each high-altitude jetway. Since this data is recorded by computer, why was the sample only 25 days? What was the reasoning behind the choice of May 1995? Was this period truly representative, or was this selection made as a means of weighting a particular result? Seasonal changes in both air traffic and preferred routings could result in different answers.

Response:

At the time the analysis was completed for the Draft EIS, high-altitude RAMS data from 25 days in May 1995 was all that was available. The non-airport model in the Draft DOE Standard (DOE 1996g) does not require this data.

RC: 15.013

Doc: PC-021/11

Are stated distances to airways the distances to the airway centerline or to the edge of the airway. In general, federal airways extend 4 nautical miles to either side of the centerline. As they are defined by the VORTAC's, at some distances they may be somewhat wider than this minimum value.

Response:

The distances given are from the centerline of the airways to each of Zones 4 and 12. Airways are not considered in the Final EIS analysis.

RC: 15.014

Doc: PC-021/12

All commercial operations from Runway 04 were assumed to be bound for Dallas on the 105-degree airway. What about test flights from the maintenance and modification facility located [at the] Amarillo International Airport?

Response:

This conservative assumption was based on information obtained from the Amarillo Tower concerning the trend of aircraft taking off on Runway 04 to follow routes bordering the plant along Highways 60 and 683. With the issuance of the new Draft DOE Standard (DOE 1996g), there is no consideration of airways, so this assumption is not needed. See discussion in section 1.3.11 in this volume. The test flights are included in the RAMS data and are included in the FAA data as part of the take-off and landing operations at the Amarillo International Airport.

RC: 15.015

Doc: PC-021/13

Again, I am surprised that the value of g for military aircraft, particularly the small sub-category, is lower than that for air carriers. Again, combat and training aircraft tend to have a higher accident rate than airliners.

Response:

The analysis used for the Pantex Draft EIS aircraft accident analysis is that contained in the Draft DOE Standard (DOE 1995z) for "Accident Analysis for Aircraft Crash into Hazardous Facilities." The values of g are part of the Solomon model which has been eliminated in its use in the Final EIS. In-flight aircraft were modeled using the new non-airport model contained in the Draft DOE Standard (DOE 1996g).

RC: 15.016

Doc: PC-021/14

[The] general aviation turbojet wingspan is too small. Examples of up to 90 feet are easily found, especially in the ranks of new products.

Response:

The values listed in Table E.3.1.42 of volume II of the Final EIS are both Draft DOE Standard (DOE 1996g) and average weighted representative wingspans for aircraft flying around Pantex Plant.

RC: 15.017

Doc: PC-021/15

Airliner landing skid distance is given as 1,860 feet while general aviation turbojet landing skid distance is quoted as 37 feet. The landing speeds of both classes of aircraft are comparable so the skid distance must be treated as comparable. In fact, any general aviation aircraft that only skids 37 feet must have either been moving very slowly or impacted something very solid. With a 15-degree impact angle, this is unrealistic and misleading.

Response:

The values listed in Table E.3.1.42 of volume II of the Draft EIS came directly from the Draft DOE Standard (DOE 1995z) for "Accident Analysis for Aircraft Crash into Hazardous Facilities." They have been updated in the Final EIS per the latest version of the Draft DOE Standard (DOE 1996g).

RC: 15.018

Doc: PC-021/16

Impact velocities stated in table are unrealistic. A general aviation turbojet moving as slowly as 152 ft/sec (90 knots) is indeed in serious trouble. These aircraft are fully as fast as airliners and many military aircraft. If an airliner can impact the facility at 422 ft/sec (250 knots), it must be assumed that general aviation turboprops and turbojets can as well. These aircraft are certified to the same regulations (FAR Part 25) as air transports and tend to operate in a similar manner.

Response:

The values listed in Table E.3.1.47 of volume II of the Draft EIS came directly from support material for the Draft DOE Standard (DOE 1995z) for "Accident Analysis for Aircraft Crash into Hazardous Facilities." They have been updated per the latest version of the Draft DOE Standard (DOE 1996g). This support material is listed in the references at the back of Appendix E.

RC: 15.019

Doc: PC-021/17

Stated probabilities for damage exceed guideline maximum by two orders of magnitude.

Response:

The probability of damage is thus in the "extremely unlikely" range. The guidelines quoted by the commentor are FAA guidelines. This analysis used guidelines provided by the Draft DOE Standard (DOE 1996g).

RC: 15.020

Doc: PC-021/18

As you can see, there are still a rather large number of inaccuracies in the analysis. I recognize that the Aircraft Accident Analysis has been performed in accordance with the guidelines presented in the Draft DOE Standard, "Accident Analysis for Aircraft Crash into Hazardous Facilities." However, it is my contention that this methodology itself is still lacking in a number of areas.

Response:

The Draft DOE Standard (DOE 1996g) is in the process of being finalized. Based on the concerns raised at several of the public meetings, it has been revised accordingly.

RC: 15.021

Doc: PC-021/19

I cannot dispute the contention that the likelihood of an aircraft crashing into a facility containing nuclear material is remote. My question for you now is, what if the unlikely happens? If a light aircraft impacts an earth berm-protected igloo after sliding off most of its speed, the answer is most likely "nothing." Alternatively, if the aircraft is large and/or impacts the structure at a high velocity, the potential exists for a catastrophe of tremendous proportions.

Response:

While it is true that a large aircraft has the potential to damage a facility, this does not necessarily result in a release of radioactive materials since many of the critical Pantex structures have super stout construction and earth overburden. However, in the structural analysis methodology, consideration of super stout structures, using the given equations, results in a conservative structural assessment. See volume I, section 4.15.7, for a discussion of additional levels of conservatism in the Final EIS.

RC: 15.022

Doc: PC-021/20

Moreover, the analysis only predicts the probability of and partial damage potential of an accident. No attention is given to the scenario of an intentional crash into the facility by a suicidal pilot. Where once this would have been unthinkable, the events of recent years have shown that the unthinkable can and does happen. After all, who would have anticipated the bombing of the World Trade Center, the bombing of a Federal office building or the suicide of a distraught student pilot by crashing his airplane into the White House. As I pointed out in my comments on the Aircraft Accident Analysis, the prohibited airspace over Pantex extends only up to approximately 1200 ft above ground level. Under these circumstances, even basic single-engine general aviation aircraft beginning at a cruising speed of 90 knots (152 ft/sec) can go from legal flight to being imbedded in a hazardous facility in less than 8 seconds. There is simply no way to stop such an attack without undue danger to all air traffic in the area.

Response:

The Draft DOE Standard (DOE 1996g) states that it "does not include consideration of malicious acts (e.g., sabotage, terrorism, and war). The available data on aircraft crashes do not support statistical assessments of such acts. Further, such acts are not unique to aircraft, nor are they initiated by failures and errors associated with aircraft."

RC: 15.023

Doc: PC-021/21

Further, the recent Valujet accident in Florida leads me to raise the question of emergency use of the runways at Amarillo International Airport. The proximity of Amarillo to the major East-West routes and the availability of an extremely long runway makes for an attractive option in the event of an in-flight emergency. In such an event, an aircrew is permitted to waive all regulations in the attempt to perform a safe landing. With the prevailing southerly winds, and the location of the Pantex plant, the chances [of] an aircraft making an overflight of the hazardous facilities while already in a degraded state are extraordinarily high. Will the facilities at Pantex swallow and contain a crashing airliner as effectively as the Florida Everglades?

Response:

The Draft DOE Standard (DOE 1996g) is applied based on normal operations, as well as emergency conditions that may occur to aircraft in the vicinity of a given facility. These emergency conditions are accounted for statistically in the probability density function (pdf). The probability of hitting a facility is calculated based on these operations. The scenario described above would not be applicable to Pantex due to the difference in topography.

RC: 15.024

Doc: PC-021/22

The presentation of pages of probabilities does little to address the "What ifs" of the hazard presented by normal aircraft operations in the vicinity of hazardous facilities. Perhaps of more importance, these probabilities do nothing to address the possibility, though remote, of malicious intent. Further, normal aircraft safety analyses tend to address only the hazard to the aircraft and its occupants, with some consideration given to the event that injury might occur if the aircraft or its components strikes individuals on the ground. It is important to note that only limited damage to other than the aircraft itself is addressed. In the event that an aircraft hits and perforates a facility containing fissile material for nuclear weapons the potential for damage is not limited to the immediate vicinity. In this case, we are dealing with the potential for widespread impact, including regions far downwind of the accident site.

Response:

The Draft DOE Standard (DOE 1996g) states "The focus is on analyzing the risk posed to the health and safety of the public and onsite workers from a release of hazardous material following an aircraft crash. Thus, this is not a standard on aviation safety and does not consider the risk to the occupants of the aircraft, the risk to individuals inside a building affected by the crash into the building, or the risk to other individuals on the ground, either within or outside a facility boundary, who might be directly impacted by the crash... This standard does not include consideration of malicious acts (e.g., sabotage, terrorism, and war). The available data on aircraft crashes do not support statistical assessments of such acts. Further, such acts are not unique to aircraft, nor are they initiated by failures and errors associated with aircraft." Consequence analysis was completed for fissile materials release, regardless of the initiating event. This analysis can be found in volume II, section D.4.2.

RC: 15.025

Doc: CO-008/1

Page E-3, E.2.1. What is the relationship between the "j" value and the probability of the aircraft penetrating the magazine?

Response:

The only relationship between the "j" value and the probability of the aircraft penetrating the facility is the fact that the "j" index divides the aircraft into categories for use in the four factor formula for determination of hit probability. The category j = 1 "Commercial: Air Carrier" will have a larger engine weight and diameter than the category j = 6 "General: Fixed-wing, reciprocating, single engine" and thus may have the potential to penetrate a given facility.

RC: 15.026

Doc: CO-008/2

Page E-3, E.2.1. Why is the term "scabbing" used on page E-3, paragraph 1, when the term "spalling" is used on Page 4-249 to describe the same phenomenon? Please explain the different terms.

Response:

Spalling is a local damage that signifies the ejection of target material from the front face of the target. Scabbing is a local damage that signifies the peeling off (or ejection) of material from the back face of the target. The terminology on page 4-249 of volume I of the Draft EIS was incorrect and has been corrected in the Final EIS.

RC: 15.027

Doc: CO-008/3

Page 4-241, Paragraph 3. What is the monitoring procedure and the maximum time frame the magazines remain open?

Response:

Once magazines have undergone their periodic inventory check, they are locked up for 18 months. During this inventory, the doors to the facility are only open for a few hours. During the lockup time, the doors are monitored through alarms as to unauthorized entry. Limiting Condition of Operation (LCO) information in the Zone 4 SAR states that only three magazines are allowed open at one time.

RC: 15.028

Doc: CO-008/4

Page 4-241, Paragraph 3. Do pilots flying at night use the Pantex lights as a landmark, instead of using the [VORTAC]?

Response:

All pilot training programs must be approved by the FAA and flight instruction must be performed by an FAA licensed instructor. These flight training programs teach, among other things, fundamental techniques of flying and navigation as well as the rules of flight. All flights must be performed in accordance with either Visual Flight Rules (VFR) or Instrument Flight Rules (IFR). Both sets of rules govern flight at night, since the distinction is height of cloud ceiling and visibility (i.e., distance one can see) rather than whether it is day or night.

If a pilot were flying at night under VFR conditions, one would expect the pilot to take advantage of the lights of the Pantex Plant in the same way he or she would take advantage of other landmarks such as the lights of the Amarillo International Airport, lights of the City of Amarillo and other communities, lights of the prison, etc. That would be to use the spatial pattern of lights (and any unique aspects of particular light sources) as navigation reference points to determine ones position and enable the pilot to either confirm progress along the desired course or to make corrections to intersect the desired flight path. It should not be inferred that because the lights of Pantex (or any other visible location) are used as reference points, that the aircraft then flies over them. Rather, the lights are used to help the pilot mentally envision where the aircraft is in relation to where the pilot wants to be. It should also be noted that lights can be seen from great distances at night with the exact distance dependent upon the atmospheric visibility and aircraft altitude (above ground level at that point in time. Typically, under normal VFR conditions in the vicinity of Amarillo, the rotating beacon and the high intensity approach lights of the Amarillo International Airport would be visible from much further than 10 miles. Thus, under these conditions, there would be no need for a pilot to fly over the Pantex Plant or VORTAC as a means of finding his or her way to the airport for a landing.

If a pilot were flying at night under IFR conditions, one would not expect a pilot to use Pantex Plant as a landmark. Instead, the pilot would rely upon instruments inside the cockpit to navigate from point to point. Since the locations of cities and other ground installations such as the Pantex Plant do not appear on IFR navigation charts, trying to see and use the lights of Pantex as a navigation reference would be pointless. Instead, the pilot would seek to fly along the centerline of a particular directional signal from an FAA radio navigation facility, such as the Amarillo VORTAC.

RC: 15.029

Doc: CO-008/5

Page E-5, E-2.2. Why is the 15-degree impact angle used in the analysis and the possibility of higher angle impacts ignored. The Value Jet DC9 in the Everglades had an impact angle of about 75 degrees.

Response:

See discussion in section 1.3.11 of this volume regarding angle of impact.

RC: 15.030

Doc: CO-008/6

Page E-8, E-3.1, Paragraph 1 and Page E-11, E-3.1.2. Please add the statement, "The 4800 feet Mean Sea Level ceiling over the Pantex Plant equals to only 1200 feet above ground level."

Response:

Correction has been made in the Final EIS.

RC: 15.031

Doc: CO-008/7

Page E-11, E.3.1.2. Why state that helicopters are "omitted" as a hazard because they do not fly over the plant? Neighbors observe them flying over the plant regularly. Helicopters often operate at high weights and high speeds.

Response:

See response to comment 15.009.

RC: 15.032

Doc: CO-008/8

Page E-11, E.3.1.2. Are aircraft or post maintenance operational test flights from modification and maintenance facilities at the Amarillo Airport included in the report? These planes tend to circle over the plant repeatedly.

Response:

See discussion in section 1.3.11 of this volume regarding Amarillo International Airport operations.

RC: 15.033

Doc: CO-008/9

Page E-15, 3.1.3, Paragraph 1. Why were only 25 days in May, 1995, used? To give a more accurate picture of over-flights, why not use 30 days, 60 days, 6 months?

Response:

See response to comment 15.012.

RC: 15.034

Doc: CO-008/10

Page E-15, 3.1.3, Paragraph 1. Do the distances of Federal airways vary?

Response:

The widths of the Federal airways do vary. The high altitude beacon beam is projected upward from the ground, and it expands with altitude.

RC: 15.035

Doc: CO-008/11

Page E-15, 3.1.3, Paragraph 1. Are distances measured from the centerline or from the edge of the [VORTAC]? How far from the centerline do they extend?

Response:

The distances given are from the centerline of the airways to each of Zones 4 and 12. An airway model is not used in the Final EIS.

RC: 15.036

Doc: CO-008/12

Page E-15, E.3.1.3. It is a false assumption that all commercial operations from Runway 04 are always bound for Dallas on the 105-degree airway?

Response:

RC: 15.037

Doc: CO-008/13

Page E-15, E.3.1.3. How many test flights for the modification and maintenance facilities at the airport use Runway 04?

Response:

See discussion in section 1.3.11 of this volume regarding Amarillo International Airport operations.

RC: 15.038

Doc: CO-008/14

Page E-30, figure E.2.2-1. General aviation turbojet wingspans of up to 90 feet are common now, particularly among newer aircraft. Why are they not included?

Response:

See response to comment 15.006.

RC: 15.039

Doc: CO-008/15

Page E-33, Table E.3.1.4-2. The skid distance of airliners and turbojets are comparable. Airliners use 1860 feet, but 37 feet is used for general aviation turbojets. That being the case, a higher angle impact would be expected. The 37 feet at a 15-degree angle is unrealistic and misleading. Please reevaluate and define the aircraft categories and the skid distances of general aviation turbojets. Also, be consistent within the correlating tables, i.e. E.2.2-1 and E.3.1.4-2.

Response:

The values listed in Table E.3.1.4-2 of volume II of the Draft EIS came directly from the Draft DOE Standard (DOE 1995z) for "Accident Analysis for Aircraft Crash into Hazardous Facilities." Since turbojets are not the dominant risk, this value does not affect the analysis results. The Final EIS uses the Draft DOE Standard (DOE 1996g) which has updated skid distances.

RC: 15.040

Doc: CO-008/16

Page E-22, E.3.1.6, Paragraph 2. Is the crash scenario in [the] EIS different from that in Storage and Disposition PEIS? If it is, please explain why.

Response:

Yes, the crash scenario is different from that in Storage and Disposition PEIS. It is explained in volume I, section 4.15.5.3, that if any of the storage alternatives associated with this PEIS were implemented, there would be a change in the aircraft crash probability. Any of these alternatives would involve the removal of all pits from Zone 4, which would reduce the aircraft accident probability. For impact analysis, see the Final PEIS.

RC: 15.041

Doc: HT13/54

When you did your aircraft crash analysis from Pantex, you assumed it would be in what kind of container?

Response:

To elaborate on the response given at the public hearing, in the Draft EIS aircraft analysis, the ALR8 container was assumed. The AT400A would provide much more protection than the ALR8, thus the analyses presented are conservative.

RC: 15.042

Doc: HT12/31

... a large fraction of the accident analysis is directed towards airplane accidents airplane crash dispersing material. And you go through that at Savannah River, which is very improbable and low consequence should it happen, and you consider that a bounding accident. I question whether it is in fact a bounding accident for a Class I facility like the P-Area reactor. I don't know that you've analyzed the bounding accidents.

Response:

The aircraft crash scenario at the Savannah River Site is not a bounding accident for the P-Reactor. As is stated in the Final EIS, the probability of aircraft crash into the P-Reactor was calculated as 1.2 x 10-6 for all types of aircraft using the methodology outlined in the Draft DOE Standard (DOE 1996g). The probability of releasing material from P-Reactor, given the hit, was calculated as ² 9.2 x 10-9.

RC: 15.043

Doc: PC-024/12

Page 5-10, left column, Section 5.2.1.12, Aircraft Accidents, 1st paragraph. ...The airspace [over NTS] is now highly restricted due to the past nuclear testing program and the activities of the surrounding U.S. Air Force's Nellis Air Force Range (NAFR). This may not remain so if there are major changes in the operating status of these facilities [that] are now under review in respective EISs.

Response:

The issue of restricted airspace over NTS was revisited in the Final EIS.

RC: 15.044

Doc: CO-006/1

The 1994 "Finding of No Significant Impact" arising from the Environmental Assessment found an airplane crash/accident occurring at Pantex to be an "incredible event" not justifying the preclusion of additional storage at Pantex. Even so, the plant subsequently worked with the Department of Defense and the FAA to reduce flights paths over Pantex, and took other steps to ameliorate the situation. However, the Draft EIS does not account for the reduced flights thereby exaggerating the probability for airplane accidents at Pantex and their resulting impacts, and, incredibly, increases the probability of a crash from the 1994 "FONSI." In the recent hearings, Nan Founds responded to this concern by saying that DOE is formulating its own analysis not dependent on FAA data, but also stated there were serious problems with DOE's analysis, which would be addressed. In its initial analysis, DOE is ignoring not only credible work already completed, but also the obvious reduction in accident potential for use in determining the ES&H of siting new functions at Pantex. This undermines the perceptions for fair and equal criteria for use in accurately comparing the various sites under consideration. We urge DOE to correct the analysis and avoid the wrongful preclusion of Pantex for consideration of additional functions.

Response:

See discussion on aircraft crash in section 1.3.11 of this volume comparing results of the previous analysis.

RC: 15.045

Doc: HT15/1

... I pose a question for DOE. Why in the prepared draft environmental impact assessment did the analysis of aircraft accidents cease...at the four factor analysis? [I] request that, before the final EIS is published,...the probability risk assessment be conducted.

Response:

The aircraft analysis did cease with the four factor formula per se. However, the structural analysis results in Appendix E of volume II were used to determine the release probability. These release probabilities were then used in the Human Health sections to determine risk.

RC: 15.046

Doc: HT15/2

The analyses that have been done have been done on the basis of historical data. And the purpose of that analysis is to predict the likely impact on the future operations at Pantex. We know the future of some of the risk factors in the aircraft accident rating. We know, for example, that GPS approaches already exist, so some aircraft are now flying different routes. We know that the T-37 flights from Reese Air Force Base ceased this month. And we know that the T-37 flights, T-38 flights, and the B-1 flights from Reese will cease in December. So we know a number of the aircraft, that in the four factor model have driven this outcome of about 4 x 10-5 for probability of an aircraft accident in a year, will not exist in the future. And I recommend that in the final impact analyses, those things that we know be included in the analysis so that we can all together look at the most accurate possible aircraft accident prediction.

Response:

As it stands, the Draft DOE Standard (DOE 1996g) does not allow for the consideration of Global Position System (GPS) approaches and aircraft flying different routes. Also, until the RAMS data can reflect the change in these military aircraft, and until the Federal Aviation Administration (FAA) airport operations data reflect the change, there is no way to incorporate the change into the model and apply it to Pantex Plant. These changes would reduce the risk at Pantex Plant and therefore the EIS is conservative.

RC: 15.047

Doc: HT15/3

In the draft standard appendix, it [discusses] the generic crash rates for each aircraft category and subcategory [according to] accident reports published by the FAA in the RSD and by the United States military craft. ...You don't reference that published data. Is that data available and can we get a copy of that data?

Response:

The information is included as references in the "Data Development Technical Support Document for the Aircraft Crash Risk Analysis Methodology".

RC: 15.048

Doc: HT15/4

You said the evaluation techniques used to estimate crash rates are documented in References 1 and 2. But those references are also in the draft and they're not available to us here.

Response:

This information is located in the Technical Support Document, which followed approximately two months after the release of the Draft DOE Standard (DOE 1996g).

RC: 15.049

Doc: HT15/5

The methodologies that you used to convert FAA or military accident data into crash probability [estimates]. Is that methodology available for our review?

Response:

See response to comment 15.048.

RC: 15.050

Doc: HT15/6

... Until we've had a chance to look at your data and an opportunity to do analysis, how do we know that the crash probability distribution or the crash rates per landing probabilities reflects military operations, other military people, military pilots [in] this analysis?

Response:

See response to comment 15.048.

RC: 15.051

Doc: HT15/7

Were you able to determine the small military operations that are actually from Reese Air Force Base?

Response:

The number of small military operations from Reese Air Force Base could not be determined separately, but the total number of small military aircraft was determined.

RC: 15.052

Doc: HT15/8

The initiative Tom Williams spoke about in the reduction initiative, is that taken into account in your application to the standard in the EIS or will it?

Response:

See discussion in section 1.3.11 of this volume. Additionally, a brief statement in volume I, section 4.15.1.3, discusses a previous analysis of the relative risk reduction associated with the overflight reduction measures.

RC: 15.053

Doc: HT15/9

... "Small military [aircraft] tends to be the controlling hit probability in the environmental impact statement. [Since] there's such a wide variety of aircraft types, why can't we actually do the analysis subcategory. Why can't we actually identify individual aircraft types and use available crash rates?

Response:

This was done for large and small military crash rates in the Final EIS, and it did not change the results more than five percent.

RC: 15.054

Doc: HT15/11

... We've talked several times this morning about the safety factors. The safety factors are there and they're not quantified. Is it possible to produce a document that says this is our best estimate and this is the uncertainty that remains in the assessment?

Response:

The authors of the Draft DOE Standard (DOE 1996g) indicated that this could not be done.

RC: 15.055

Doc: HT15/12

Since these numbers as point estimates will be used to make your decision, I think it's important that we be able to tell the senior decision-makers when we have a lot of confidence in a number and when it's sort of a fuzzy number. When you stay conservative, you create another problem. If I focus exclusively on one risk in life to the exclusion of others, I can bring that risk to very near zero, but my risks in other areas go up.

Response:

For the Final EIS an effort was made to characterize the level of conservatism inherent in the aircraft crash analysis.

RC: 15.056

Doc: HT15/13

Given the limited availability of the final analysis numbers, I find it very difficult to try to guess what the impact might be in the refinement of the standard. And I haven't heard this morning any kind of estimates as to whether or not the refinement of the standard and the supporting documents might provide some clarification on this fuzziness Dr. Rock talked about, this conservatism. Is it generally agreed upon that there will be some reduction in that numerical risk probability or is there any kind of feeling that anyone has on this?

Response:

Due to the changes made in the Draft DOE Standard (DOE 1996g) and the additional level of detailed analysis, the risk results were shown to decrease. For the Final EIS an effort has been made to characterize the level of conservatism inherent in the aircraft crash analysis.

RC: 15.057

Doc: HT15/14

That does provide the decision-maker some measure of comfort, if you will, in the conservatism of the numbers, but it does the exact opposite to the local citizens. It provides them [with] a sense that the plant may not have been as safe as indicated over all the years that it's been in existence, which I don't believe is the case. I believe that there's a point somewhere in between that is more like the real answer to this problem. And that needs to be stated.

Response:

See discussion in section 1.3.11 of this volume comparing the results of the previous analysis.

RC: 15.058

Doc: HT15/15

... We're looking at two and a half months...for the information to be available to do those calculations and present that data. There won't be enough time to look at that and to say we accept this or we agree with this. It really places the state reviewers in a difficult position at this point. I think it's impossible, actually. And I'm wondering about the date that the EIS is driven [toward]...I think [there is] some question as to what dates they [EIS and other two PEISs] will be available.... Are they on track? Is this still concrete or is there a possibility that we might allow for more comprehensive review of the information to provide the level of certainty...

Response:

This comment was made prior to the availability of the Draft DOE Standard (DOE 1996g) for Aircraft Crash Analysis and its associated technical support documentation. Subsequently, the State of Texas formally requested an extension of the review and comment period for the aircraft crash analysis. At the time of this response, the Department had not reached a decision regarding the request for extension. As of July 22, the Draft Standard (DOE 1996g) was made available. To maintain the schedule for the Final EIS, the State of Texas reviewers were provided copies of the Draft Standard and invited to participate in the final analysis.

RC: 15.059

Doc: HT15/16

What we want is...accurate information in the EIS. And if that calls for a delay in order to get the right numbers in there, then we are going to formally request that the site-wide EIS delay until those right numbers are clear.

Response:

See response to comment 15.058.

RC: 15.060

Doc: HT15/17

If I hear you correctly, you're saying that you are driven by a deadline. And if later information comes in after that deadline you'll make those adjustments. And what we're saying is we're not bound to that deadline. We'd rather have the right information. And if that takes a couple of months, we're willing to move that deadline back.

Response:

See response to comment 15.058.

RC: 15.061

Doc: HT15/18

So it will give a range and best estimate and worst case estimate, and if we're really lucky, the lowest accident estimate? If you only put it in the introduction and you don't put it with the numbers so that the numbers are self-evidentall of us have had enough experience with the mediaI understand the headline will lead to an incorrect assumption.

Response:

This comment pertains to the Draft DOE Standard (DOE 1995z) and not to the Draft EIS. Due to the changes made in the Standard and the additional level of detailed analysis, the risk results were shown to decrease. For the Final EIS an effort has been made to characterize the level of conservatism inherent in the aircraft crash analysis.

RC: 15.062

Doc: HT15/19

... I want to thank the DOE for the hard work on reducing and minimizing the risks, to the extent possible. The committee that Tom Williams has worked on changed the approaches to the airport. But to build on the last comment there, I'm afraid that in a very important process like an EIS process,...(inaudible) and should be. I'm reminded somewhat of the scientific information that was put out by groups that later proved incorrect, like a food scare abut eggs are good for you or bad for you, whatever. We get these maybe presumptive announcements about the risk factor that don't concur necessarily with previous ones and they've not undergone the type of scrutiny that good science work demands. And that is what the State of Texas is asking for today, is to try and do that kind of peer review based on documents that will be coming in in the future. Going back to meet the consistency, people need to understand what the risks are and grasp that, including the new level of conservatism.... The accumulative effect of that [conservatism] changes the number radically from what was the risk published in previous studies. I think there needs to be, as Dr. Rock mentioned,...annotation in the document itself if you're going to remain fixed on those numbers. And I think the public deserves a very good explanation of why this number may not square with previous numbers, because the number of planes flying over there and the types of planes hasn't changed.

Response:

See discussion in section 1.3.11 of this volume comparing the results of the previous analysis.

RC: 15.063

Doc: HT15/20

If you know that steps are being taken to minimize that risk or the number of overflights over Zone 4 in the future, maybe there should be a number for what the risk will be in those outcomes if it is, indeed, reduced through mitigation steps. And I think those are things that could serve the public well and will make them feel more comfortable.

Response:

See discussion in section 1.3.11 of this volume regarding the Amarillo International Airport operations.

RC: 15.064

Doc: HT15/21

... I guess the only comment I had is [that] the numbers look very much different than they did in past studies. And what I'm hearing from you is [that] really things are extraordinarily conservative and minimized, but that's not what's conveyed in the text. ...Maybe there's some way to convey that more clearly in the text.

Response:

See discussion in section 1.3.11 of this volume comparing the results of the previous analysis.

RC: 15.065

Doc: HT15/22

... where you referred to the Zone 4 overflight work initiatives quantifying the results, does that mean this would be Volume 1? The initiatives are described in section 4.14.5.4, but there's no numbers applied there. There's no reduction, I guess, in the estimates.

Response:

The 82 percent reduction from the Overflight Working Group initiatives is documented in volume I, section 4.15.6. It is estimated that implementation of the MOU, the offset localizer, relocation of the VORTAC and 65 percent use of the GPS will result in an 82 percent cumulative risk reduction. This 82 percent reduction was estimated using the Solomon Model.

RC: 15.066

Doc: HT15/23

... It looks like there was a whole year that you were able to draw information off of, April 95 to March 96. [Why did you use] 244 days instead of 365?

Response:

The Draft EIS analysis used one year (1994) of FAA data to determine the number of airport operations and 76 days of RAMS data to determine the representative wingspans, engine weights, and diameters. For the Final EIS, six and one half years (January 1990 through June 1996) of FAA data were reviewed and the maximum number of aircraft for the four categories collected (Air Carrier, Air Taxi, Military, and General Aviation) was used. To characterize the representative wingspans, engine weights, and diameters, RAMS data from January 19, 1995 to January 18, 1996 was collected. For this time period 330 of 365 days of data were collected. The remaining 35 days were not available due to the equipment being moved or the RAMS system was not in operation. The missing 35 days would not change the results of the analysis. If 1995 FAA operations data are used instead of the maximum data, the probability of hitting a facility is reduced by 15 percent.

RC: 15.067

Doc: HT15/26

The other observation I'd like to make is that statistics are a fascinating thing. They are not a solution. They are no guarantee. So the aircraft crash probability to be quite low is one thing. But it is that such things don't happen can happen.

Response:

The comment author is correct. The Final EIS uses the best available model and data. The Department believes that the risks are quantified with sufficient accuracy to allow decision makers to make correct decisions.

RC: 15.068

Doc: HT15/27

I think the most impressive thing to me are the mitigation efforts that the Department is undertaking, as well as made. I want to know, is it possible that the Department of Energy will then stop those mitigation efforts and we will not try to move aircraft from flying over the plant.

Response:

The DOE is committed to the aircraft risk reduction issue. The mitigation measures will proceed regardless of the values presented in the EIS.

RC: 15.069

Doc: HT15/28

One of the effort of Pantex in moving overflights further toward the northwest corner of the plant, I can't help but observe that's where the nuclear reactor might be and that there are other facilities that are going to have to be taken into account so that we know this is considered under this aircraft crash analysis versus the aircraft analysis that related to the current EIS.

Response:

The risk of this potential facility to aircraft will be evaluated in tier NEPA documents to the Storage and Disposition of Weapons-Usable Fissile Materials PEIS should it become necessary.

RC: 15.070

Doc: HT15/29

... There are those times when there are accidents that do happen and that are beyond the control of any of the mechanical problems that possibly could go wrong with an aircraft. And this was just an issue that we were wondering if it has been factored in and how it was going to be factored in.

Response:

In this analysis, mechanical failure is one of the initiators considered in the aircraft accident analysis. Mechanical failure contributors are reflected in the crash rates presented in the Draft DOE Standard (DOE 1996g).

RC: 15.071

Doc: HT15/30

... Since there are maintenance and modification of facilities at the Amarillo Airport, there are planes that are out on test flights and they do a lot of circling. And we wondered were there considerations that these are not aircraft that are in tip-top flying shape given...in the document.

Response:

See discussion in section 1.3.11 of this volume regarding the Amarillo International Airport operations.

RC: 15.072

Doc: HT15/31

I think that where we really are having difficulty with this on test flight is, to our knowledge, they are not all the time actually perfect aircraft that are taking off. And I do appreciate this thing that they have to be in a certain condition. But that does not mean they do not have a problem at the time of test flight. And these considerations, we thought, needed to be brought out in the document.

Response:

See discussion in section 1.3.11 of this volume regarding the Amarillo International Airport operations.

RC: 15.073

Doc: HT15/32

I'd like to commend DOE and the FAA in their attempts to alleviate some of the concerns of the citizens on the probability of airplane crash in Zone 4 and Zone 12. I hate to show my ignorance in this, but could you, in plain English, tell us what the probabilities of a crash are? Is it one in a million? In previous studies that number was quoted around. Why has that increased? Does that take in those hit probability factors?

Response:

See discussion in section 1.3.11 of this volume. Additionally, the probability of an aircraft crash into Zones 4 or 12, as calculated in the Draft EIS, is 4 x 10-5 which is 40 in a million. The probability of an aircraft crash into Zones 4 or 12, as calculated in the Final EIS, is 3.1 x 10-5 which is 31 chances in one million. The corrected analysis, as well as other historic analyses, all agree that the aircraft crash hit probability for Pantex Plant is in the low to mid 10-5 range (approximately 10 to 40 chances in one million per year that an aircraft will hit Zones 4 or 12). It should be noted that hit probability is not an accurate representation of risk. Risk involves an aircraft crash which leads to a release of plutonium. Probabilities for an aircraft crash leading to a release are in the 10-6 range (approximately 1 to 9 chances in one million) or lower.

RC: 15.074

Doc: HT15/33

In past studies, that skid area has been factored and reduced. ...Which skid factors are you using to determine [skid distances]?

Response:

The recommended skid distances given in the Draft DOE Standard (DOE 1995z) for each aircraft category were used in the Draft EIS. In some cases skid distances were subsequently reduced in the case where one building was shielded by another. The Final EIS uses skid distances updated in the Draft DOE Standard (DOE 1996g), and considered one building shielding another.

RC: 15.075

Doc: HT15/10

We're told that the support documents, the driving coefficient that control the outcome of the four factor detailed analysis, will not be available for two months. And we're being asked to wait. It's an issue of we're being asked to trust the support documents are fine, but we're not in a position to see for external peer review. My question is, can they be made available in a fashion that will keep this process in a time line and give us a reasonable opportunity to do a technical peer review?

Response:

See response to comment 15.058.

RC: 15.076

Doc: HT17/43

We're also very encouraged to see that the Department of Energy has taken steps, working with the local government of the City of Amarillo and the State of Texas, in reducing the number of aircraft overflights. I think that show their good-faith efforts to try to operate in as safe a manner as possible. We also appreciate the Department of Energy's openness policy.

Response:

The Department will continue its good-faith efforts and openness policy in an effort to operate in as safe a manner as possible.

RC: 15.077

Doc: SG-012/3

Vol. I, page 5-63, 5.5 Kirtland Air Force Base, 5.5.1.12 Aircraft Accidents, "An analysis was performed to determine whether expected bomb loads (one to four 909-kilogram [2000-pound] bombs) could damage the Manzano storage magazines in the event of an airplane crash. With the minimum cover of 9 meters of granite and earth, the magazines cannot be damaged by any foreseeable aircraft events." Vol. II, page E-26, Aircraft Accident Analysis, E.3.2.4 Structural Calculation, "A survey of contour maps reveals that the approximate overburden for the Manzano WSA is approximately 3.05 meters." Based on the aforementioned information, it is unclear which of the above statements is correct. If the second statement is correct, then the minimum overburden is 3 meters, and the analysis of the bomb loads should be further considered as a plausible accident analysis. Although a bomb load may not have impacts below 9 meters of granite, it may impact 3 meters.

Response:

Commentor is correct. The minimum overburden at Manzano WSA is 9 meters. This error has been corrected in the Final EIS.

RC: 15.078

Doc: HT16/15

My question has to do with Figure F-6.3.1 on Page F-19, Appendix F.... There is listed a variety of collisions that might occur during transportation [that] form the basis for the risk and the consequence analyses in that [appendix]. And I note that aircraft collisions with the transport train have not been considered, or at least they're not listed. The stage right trailer, the whatever trailer you would like to consider. I guess there's something hauling a trailer, so I think of it as a train. If we're really looking at 30,000 movements a year, which was the number referred to earlier in the discussion, the total exposure of all of those targets averaged over a year may match the total exposure of a single storage facility, in terms of hours of vulnerability. So it relates to an observation that I've had that, in analyzing the aircraft crash probability, there's been no consideration of the fact that the aircraft is only in a position to impact the target for a short duration, a very short proportion of its entire flight. Here we've got a slowly moving target that's only vulnerable for a short period of time and we've not worried about it. When you're moving the missile instead of moving the target, we worry about the sum total of all these passes. When we're moving the target more slowly, we say, well, it's in the open for such a short period of time that it's negligible.

Response:

To elaborate on the response given at the public hearing, aircraft impacts into a moving vehicle containing weapons or weapon components were considered in the analysis. The potential for this accident is discussed in section 4.12.2 of volume I. Assuming a trailer was continually parked within Zone 4, an aircraft impact frequency of less than 1 x 10-7 per year was calculated. The risk from this accident using a frequency of 1 x 10-7 per year is presented in section 4.12.2 of volume I.

RC: 15.079

Doc: PC-025/78

Doesn't Amarillo have an airshow with flyovers during high risk maneuvers? Was this accounted for? If the incident rate for an airshow is higher than the general aviation conditions set forth in section 4.16, how does DOE justify [that] the current NEPA analysis meets the intent of NEPA. In the last ten years how many airshow (US and worldwide) accidents have occurred relative to section 4.15 parameters in determining frequency of crashes? Assuming an airshow high velocity impact with at least two impact scenarios per year over the period of this EIS, what are the impacts to the public from releases?

Response:

Amarillo International Airport does have airshows on occasion, with aircraft performing high risk maneuvers. However, the probability density function contained in the Draft DOE Standard (DOE 1996g) includes crash frequencies based on national averages, which include those as a result of airshow crashes. As a result, this scenario has been considered in the current analysis.

RC: 15.080

Doc: PC-025/79

In Scenario 7 on Page 4-231. What is the maximum tritium release in curies? Why isn't a direct high velocity aircraft crash into the vault considered?

Response:

Aircraft impacts into the tritium vault are considered in the analysis. However, aircraft impacts are not risk dominant compared with the seismic event. The typical source term for this event is 3.9 x 107 curies (Ci).

RC: 15.081

Doc: PC-025/80

General comment, section 4.15. The VORTAC serves no real purpose. A crippled plane goes where it wants to. What is FAA and DOE going to do if the only way to bring a crippled plane in is over the plant? Shoot the plane down?

Response:

RC: 15.082

Doc: PC-025/81

I would argue the total number of yearly flight operations is incorrect. Because neither the number of satellites or the Space Shuttle operations are included. I believe satellites have a nearly 100 percent orbital failure rate. Thus, a high velocity satellite impact is reasonable.

Response:

The Near Airport analysis outlined in the Draft DOE Standard (DOE 1996g) includes consideration of normal airport operations. Whereas the non-airport high altitude overflight model in the Standard considers impacts from high altitude aircraft. Spacecraft (the Shuttle, satellites, etc.) ground impacts are statistically insignificant compared to conventional aircraft flights. It should be noted that the majority of spacecraft burn up in reentry, prior to impacting the ground.

RC: 15.083

Doc: PC-025/82

Table 4.15.2-2 information seems impossible given the recent Valujet accident where the plane blasted through a limestone formation. If the impact forces of that plane were used in analyzing impacts at Pantex, what would change? Was the maximum velocity used in determining damage? Velocity is squared in the force equation correct? The calculations on page E-l9 are flawed by using slow moving aircraft. The LLNL report seems contrived to show the damage would be minimal by using the 70th percentile velocities turning takeoff or landing. NEPA requires you to assess reasonable situations. Since the probability of an aircraft crash is independent of the damage it causes. I would argue a high velocity impact of a massive plane is just as likely as a small plane at low speed, thus NEPA requires you to analyze the impact of the most damaging scenario, please comment.

Response:

See discussion in section 1.3.11 of this volume regarding angle of impact and response to comment 15.005.

RC: 15.084

Doc: PC-025/83

General comment, sections 4.15 and 4.16. Please provide information on the level of QA/QC defending the analyses of these sections. I would like the same information as requested on water and air quality sections of this EIS.

Response:

The QA/QC of the referenced sections of the Draft EIS, as well as the entire document was conducted in accordance with the Tetra Tech Quality Assurance Program Plan, document number CB-1000, May 22, 1995. The program is tailored for preparation of the EIS and to meet DOE Order 5600.6C and NQA-1 as appropriate. For detailed information, refer to these documents.

The assessments (including methodologies, models, and results) of aircraft accidents in section 4.15 of volume I were subject to a multiple level of technical peer review to ensure technical validity. Included in this review process was: (1) the analysts immediate supervisor, (2) the functional area manager, (3) technical experts from the Amarillo Area Office, and (4) technical experts from the Albuquerque Operations office.

Additionally, the assessments (including methodologies, models, and results) of aircraft accidents in section 4.15 of volume I were exposed to extensive peer reviews. These reviews included two workshops occurring over several weeks along with independent supporting analysis by the workshop participants. The participants included representatives from DOE, Sandia National Laboratories, Lawrence Livermore National Laboratory, Los Alamos National Laboratory, the Defense Nuclear Facility Safety Board, as well as nuclear safety experts from private organizations.

Additionally, these assessments were peer reviewed by DOE Headquarters Technical Safety Review Panel. This group is made up of safety experts throughout the DOE complex whose main responsibility is providing safety analysis guidance to Pantex Plant.

During the public review process, the assessments (including methodologies, models, and results) of the aircraft accidents in section 4.15 of volume I were reviewed by a group of independent scientists from Texas A&M University and the University of Texas.

RC: 15.085

Doc: CO-008/17

Pages E-5 and E-16, E.2.1 and E.3.1.4. Why is the value of "y" [g] for military aircraft lower than that for commercial aircraft?

Response:

See response to comment 15.015.

RC: 15.086

Doc: CO-008/18

Pages E-5 and E-16, E.2.1 and E.3.1.4. The proximity of Amarillo to the major east-west routes, and the availability of an extremely long runway makes for an attractive option in the event of an in-flight emergency for both military and commercial overflights. In such an [event], an aircraft is permitted to waive all regulations in the attempt to perform a safe landing. With the prevailing southerly winds, and the location of the Pantex Plant, the chances of an aircraft making an overflight of the hazardous facilities, while already in a degraded state, are extremely high. Will the facilities at Pantex be prepared for such an emergency?

Response:

The probability density function contained in the Draft DOE Standard (DOE 1996g) includes crash frequencies based on national averages. These crash frequencies are based on national statistics, which include emergency landings if they resulted in a crash. Thus this hypothetical scenario has been addressed in the analysis. Additionally, the FAA and DOE have established a "hotline" between the air traffic control tower and the Pantex Plant operations center to provide for immediate emergency communication should the need arise.

RC: 15.087

Doc: MG-001/1

I am concerned about the "plane crash" analysis. As Mayor, I have been deeply involved in efforts to reduce overflights over the plant, and other preventative measures. How can it be that the probability of a crash causing a release has increased since your 1994 Finding of No Significant Impact, after Pantex and the Amarillo Airport? Even the DOE officials at the hearings conceded that their analysis had serious problems, and needed to be corrected. I urge your office to correct these errors, and act to avoid wrongfully depriving Pantex of future functions for which it may be selected.

Response:

See discussion in section 1.3.11 of this volume regarding the results of the previous analysis.

RC: 15.088

Doc: SG-003/90

As of this date, July 11, 1996the eve of the closing of the comment period for the draft EISthose personnel from Tetra Tech responsible for preparing the Final EIS have not (1) received the DOE standard, (2) have not received the final technical support documentation, and (3) have [no] idea if the probability of an aircraft crash into a Pantex plutonium storage facility is 1 or 100 in a million. Therefore, at the close of this comment period, we can not verify their results because none is available. What is known is that everything published in the draft EIS will be changed based upon the new DOE standard.

Response:

See discussion in section 1.3.11 of this volume. Additionally, concerns 1 and 2 are correct. However, for the Draft EIS, Tetra Tech personnel calculated the probability of a crash into either Zone 4 or 12 [as] 4 x 10-5 or 40 in one million, which is similar in magnitude to what has been calculated in the past in previous aircraft crash analyses done for the Pantex Plant. This is documented in the Final EIS.

RC: 15.089

Doc: SG-003/91

The aircraft crash rates are fixed in the DOE standard; however, [we] do not have access to either the Technical Support Documentation nor the data from which the accident crash rates (usually reported as accidents per hundred thousand flying hours) have be calculated into a crash probability for each takeoff, for each landing, or an in-flight rate per square mile. This calculation requires many assumptions and several different steps. From interviews, we have determined that draft DOE standard does a credible job in establishing these crash rates. However, since DOE contractors have denied access to both the data and the technical support documentation, we request that that the following points of potential errors be addressed by the DOE contractor, reviewed by a competent authority, and be included in the Final EIS.

Response:

Crash rates are given in the Technical Support Documentation for the Draft DOE Standard (DOE 1996g), which has been made available.

RC: 15.090

Doc: SG-003/92

Military aircraft perform touch and go landings for proficiency training only with an instructor on board. Additional landing practice is accomplished as a low approach with the wheels not touching the runway. The civilian tower counts this low approach as two operations (1 takeoff and 1 landing) but no record of a landing is recorded in the military records. We request details of how this discontinuity in the raw data is accounted for in the DOE standard. We request that following data be published in the Final EIS for all military aircraft with significant impact at the Pantex facility: accident and crash rates per hundred thousand flying hours; average hours per sortie; average landings and low approaches per sortie; and number of crashes attributed to landing, takeoff, and in-flight categories.

Response:

Military records are not accounted for in the Draft DOE Standard (DOE 1996g). We do not plan to gather this information because the Draft DOE Standard does not use this information. The information contained within the Draft DOE Standard is based on FAA records. Crash rates for various aircraft categories are given in the Technical Support Documentation for the Standard, which has been provided to the commentor.

RC: 15.091

Doc: SG-003/93

It was pointed out in interviews that there are 422 off-airport crashes per year of general aviation aircraft in the United States [that] are considered in the calculation of the probability in-flight crash rate. This data may be true, but it would be overly conservative to assume the probability of crash into a vacant or farming square mile was equal to the probability of crash into a built-up [area] such as the Pantex compound. Many general aviation crashes are the result of engine failure, nearly all general aviation aircraft have flight controls that function without power and pilots are trained to attempt forced landings in those emergencies. No pilot given a in-flight situation where some flight control remains, would aim at the Pantex compound rather than away from the reinforced structures at the compound. Given the good weather conditions at Amarillo and the relatively open spaces surrounding the Pantex compound, the crash site cited in the DOE standard would be greatly reduced for the local application of in-flight general aviation aircraft.

Response:

The suggestion of reducing the crash rate cited in the Draft DOE Standard (DOE 1996g) for the local application of in-flight general aviation aircraft has been taken under consideration, but is conservative given the fact that this factor cannot be quantified.

RC: 15.092

Doc: SG-003/94

In general we feel the DOE standard is a tremendous improvement in accuracy over the previously used Solomon model for predicting the probability of an aircraft crash into a facility. The Solomon model was far too overly conservative in the estimate of the contribution of high altitude overflight aircraft. Since this new DOE standard corrects the in-flight contribution of the Solomon model, we would logically expect that the probability of an aircraft crash into the Pantex plutonium storage facilitates should decrease from previous studies that used the Solomon model. We request that the Final EIS provide some narrative description of the new calculation of hit probability in comparison to the previously conducted studies and a short justification for the differences in the findings.

Response:

Information on previous aircraft analyses is presented in section 4.15.1.3 of volume I of the Final EIS. This information is presented in both tabular and narrative form. See also discussion in section 1.3.11 of this volume.

RC: 15.093

Doc: SG-003/95

After reviewing the draft EIS and conducting interviews, we recommend that the DOE standard in its application to the Pantex facility be localized for the conditions and aircraft traffic in the following ways: A. The small military aircraft subcategory which makes up a large portion of the traffic at Amarillo Airport must be studied by specific aircraft types. The T-38 and T-1 aircraft, which are the dominate aircraft types in the traffic stream, must have separate hit probabilities as well as separate release probabilities.

Response:

The current analysis can treat all large and small military aircraft types on an individual basis for crash rates. There is a less than five percent difference in the results.

RC: 15.094

Doc: SG-003/96

B. The closure of Reese AFB in Lubbock, Texas by December 1996 will have a significant effect on the forecast T-1 and T-38 traffic at Amarillo Airport and therefore attempts must be made to use the actual forecast numbers rather that past history for these aircraft.

Response:

It is difficult to forecast what the closure of Reese Air Force Base will do to the numbers of T-1s and T-38s. These aircraft may relocate to another facility and yet still fly into Amarillo. An accurate description of the numbers of these aircraft would show up in the RAMS and FAA data. The current analysis is conservative with respect to the closure of this Base.

RC: 15.095

Doc: SG-003/97

C. The collection of RAMS data at Amarillo Airport has provided the Department with a very good record of the number and types of aircraft and their ground track in comparison to the Pantex facility. This data should be used when necessary to adjust DOE standard crash rates, which are based upon a total average of all airports throughout the United States. The takeoff ground tracks for Runway 04 do not follow the typical pattern assumed when the data was collected for the DOE standard.

Response:

The RAMS data has been used for the Final EIS to determine dominant aircraft on an individual basis to adjust the crash rates to be more representative. There is a less than five percent difference in the results.

RC: 15.096

Doc: SG-003/98

D. When Using the RAMS data, insure that military aircraft that are in formation be counted as multiple aircraft rather than as a single aircraft.

Response:

The RAMS data distinguish military aircraft flying in formation as individual aircraft. Each aircraft has a unique identification beacon that the RAMS records.

RC: 15.097

Doc: SG-003/99

The Pantex facility has super stout structures and consideration of the structural capacity and resistance to aircraft penetration should be accurately modeled.

Response:

Analysis of structures is done using the Chang equations provided in the Draft DOE Standard (DOE 1996g). Application of these equations to these super stout facilities gives a conservative result. Section 4.15.7, volume I of the Final EIS discusses this conservatism.

RC: 15.098

Doc: SG-003/100

The effective aircraft crash skid length should be localized to consider the local conditions at the Pantex facility.

Response:

See response to comment 15.074.

RC: 15.099

Doc: SG-003/101

The FAA and DOE have agreed to several mitigation measures to reduce the probability of aircraft impact into Pantex and we applaud those efforts. The draft EIS provided an estimate of the effectiveness of these measures using the Solomon model which were significant. Although the application of this new model in the DOE Standard will probably estimate the effectiveness of these measures as insignificant, we believe they are significant and should be estimated separately.

Response:

See discussion in section 1.3.11 of this volume. Additionally, the DOE is committed to the aircraft risk reduction issue. The mitigation measures will proceed regardless of the values presented in the EIS.

RC: 15.100

Doc: SG-003/102

We recommend that DOE continue to collect radar data at the Amarillo airport as a mitigation item for the Site Wide EIS. We highly recommend that the current method of tracking radar should be improved with DOE funding a state-of-the-art system that is equal to the noise monitoring systems installed at many major airports in the U.S. This system should be automated and integrated with a geographical information system and turned over to the airport for their use in airport planning.

Response:

It is anticipated that the RAMS project will continue, and the recommendation stated will be taken into consideration.

RC: 15.101

Doc: SG-003/103

First, let me start by observing that the Department of Energy (DOE) has created the best available models for assessing the probability of an aircraft accident at any point in the country. Second, DOE is to be congratulated for using their models in their Environmental Impact Assessments. Third, DOE is continuing to improve their aircraft accident models. Unfortunately, this continuous improvement poses difficulty for those who try to comment on the Draft EIS for Pantex. A major shift in modeling assumptions occurred between July 1995 and July 1996. The predicted annual risk of an aircraft accident in any square mile has increased as a result of changes in the model, not as a result of changes in the aeronautical environment in the vicinity of the Pantex Plant. The aircraft accident risk depends as much on the aeronautical environment as it does on the assumptions of the model used for predictive purposes. The final EIS must clearly portray both effects. It is important that this issue be addressed in the Executive Summary as well as in the EIS itself.

Response:

A major shift in the modeling between the July 1995 and July 1996 versions of the DOE Standard involved the consideration of in-flight/high altitude aircraft. The July 1995 Standard utilized a non-airway model, whereas the July 1996 Standard utilizes a non-airport model. The major difference between the two involves the combination of three terms of the four-factor formula [NPf(x,y)] in the non-airport model to give a DOE site-specific value to be used to calculate hit probability. Regarding the aeronautical environment, it is known that the number of T-38s flying into the Amarillo International Airport from Reese Air Force Base will decline when this base closes. This will most likely result in a change in the aeronautical environment indicated by the commentor. However, it is unknown whether these T-38s from Reese will migrate to another Base and still continue to use Amarillo Airport for their training. Until the RAMS and FAA data reflect this change in numbers of T-38s, the change cannot be reflected in the analysis.

RC: 15.102

Doc: SG-003/104

The discussion in the EIS points out that an Aircraft Accident can be an initiating event in a scenario that leads to public exposure to radioisotopes. Because this is a very unlikely event, the authors attempt to quantify the probability of the event. The Draft EIS used the Draft DOE Guidelines for Aircraft Accident Prediction (July 95, Revised). During the period of public comment, HQ DOE announced its intent to publish final guidelines, now promised for mid-July 1996. Further, DOE wants the Final EIS to be based on the final guidelines. The new paradigm is that aircraft accident locations are best predicted on the basis of the locations of previous accidents. The location probability density function is a smoothed average over the whole nation for en route accidents. For near airport accidents it is a smoothed function of all accidents as a function of distance and direction from a composite runway. This is a major change from the draft guidelines and prior accident models. These assumed the impact location would be near the point along an established "flyway" where an aircraft encountered difficulty and used probability factors with dimensions of accident probability per mile of flight. Preliminary calculations show that the new model predicts accident rates 2 to 10 times higher than the older models. Since the Pantex EIS will be the first to use the new DOE Aircraft Accident Guidelines, and since it may be used to compare predicted accident probabilities at Pantex to those at other DOE facilities, how does DOE intend to explain the changed paradigm to members of the public and to senior decision makers?

Response:

Since the release of the latest version of the Draft DOE Standard (DOE 1996g), it has been shown that the results for the aircraft crash analysis have decreased from the Draft Standard (DOE 1995z) and Draft EIS. The Draft DOE Standard (DOE 1996g) was applied to the alternative storage sites considered in the EIS. This was not done for the Draft EIS. Many of the previous analyses conducted for these sites were conducted with methodologies that have since been proven inadequate for a proper characterization of the risk due to aircraft crash.

RC: 15.103

Doc: SG-003/105

In cooperation with FAA, DOE has initiated several mitigation measures to reduce the probability of an aircraft accident involving Pantex facilities. These include moving the back course localizer 6 degrees west and creating GPS instrument approaches that move takeoff and landing operations more than 2 miles away from Pantex. Plans exist to move the VOR onto the airport from its present location near the Pantex fence line. This will reroute high altitude traffic away from Pantex facilities. Unfortunately, the new accident model, based only on the history of previous aircraft accidents, is unable to demonstrate reduced accident probabilities from mitigation measures. From conversations with Kamiar Jamali, DOE did not intend this model to be used for mitigation design. It is designed to provide a common basis for comparing one DOE location to another. Nevertheless, as existence proof for the benefit of mitigation measures, note that the White House is surrounded by a no-fly zone. Request that DOE insure that the final EIS give appropriate credit for mitigation measures completed and contemplated. See the next comment for a suggestion.

Response:

Please see response to comment 15.104.

RC: 15.104

Doc: SG-003/106

To better understand the true flight environment at Amarillo, DOE installed the RAMS system to record the flight tracks of every aircraft operating near the Pantex Plant. This data has been analyzed by Dr. Y.T. Lin of Sandia labs. In his paper, "Assessment of Aircraft Risk Reduction at Pantex Plant," he uses actual RAMS data to compute the probability density function for aircraft distance from Zone 4 for all recorded aircraft, Dr. Lin uses his data to make three relevant points: 1) It shows dramatic differences in overflight activity on days when the USAF is flying compared to days when there are no military flights. 2) Only a small fraction of all flights approach within 2 miles of Zone 4. 3) The daily total of high altitude and low altitude en route flights provide no clue as to the location of the VOR or of the FAA route structure. These flights are better modeled as uniformly distributed. Can Dr. Lin's approach to analyzing RAMS data be used to demonstrate efficacy of mitigation measures?

Response:

Dr. Lins approach could be used to analyze the effect of the mitigation measures. However, this would be inconsistent with the Draft DOE Standard (DOE 1996g), as written.

RC: 15.105

Doc: SG-003/107

The proposed DOE Standard 3014-96, uses a hierarchical accident analysis scheme starting with simple, conservative models and progressing towards complex, accurate models. A screening level of risk <1E-6/yr is recommended. If at any point in the progression, the aircraft crash probability falls below this level, no further analysis is required. It is presumed that other initiating events become more important than aircraft accidents at this probability level. There are two problems with this approach. First, it leads some to believe that only when the aircraft accident probability is below 1E-6/(sq mi/yr) has an adequate margin of safety been provided. Second, the base accident rate for general aviation aircraft is on the order of 500/yr over 4,000,000 sq mi, or about lE-4/(sq mi/yr). There are four other categories of aircraft in the DOE guidelines, each with their own accident rate: large military, small military, commercial air carrier and commercial air taxi. Thus, the total aircraft accident probability in the continental United States is above the screening rate, and full analysis is mandated by the DOE standard. DOE should very clearly explain the meaning of their screening level and of any aircraft accident probabilities computed for the Pantex EIS. The Pantex EIS will be the first to use the new geographic based guidelines. Other DOE laboratories and locations have analyzed their aircraft accident risk using earlier draft guidelines. Since DOE claims the aircraft accident model is designed to compare relative risk among DOE facilities, the revised predictions for all DOE sites should be included in the Pantex EIS. This means that the new guidelines need to be applied to all DOE operating locations so that Pantex can be viewed in proper relationship to the others.

Response:

The screening criteria has been more clearly defined in the Draft DOE Standard (DOE 1996g), and this Standard has been applied to all alternative sites in the Final EIS.

RC: 15.106

Doc: SG-003/108

Although the geographic modeling approach is an interesting exercise, the EIS should also contain complete Amarillo Aircraft accident data from 1970 to 1996. This data should then be explained in the context of the aircraft accident model. That is, based on the accident model, is the real experience an expected outcome? Suggest using the binomial distribution to estimate the confidence in the predicted accident rate. Use confidence interval principles to determine if the location and frequency of observed accidents are in reasonable agreement with the model.

Response:.

Your suggestion has been taken into consideration. Attempts have been made to quantify uncertainty and compare predicted results with historic accident data in the Final EIS.

RC: 15.107

Doc: SG-003/109

Personnel at HQ DOE understand the difficulty of explaining the aircraft accident probabilities to the public. In a lively discussion at SAIC on 9 Jul 96, hosted by Tim Haley and chaired by Kamiar Jamali, the suggestion was made that EIS analyses not report the aircraft accident probabilities. These probabilities are intermediate results from the model and do not indicate public health risk. An accident is merely a potential initiating event. The suggestion was that the EIS should focus on the release probabilities, instead. This movement from "hit probability" to "release probability" involves many intermediate layers of modeling. First, one must assume the angle of impact for the aircraft. Second, assume an impact velocity and compute the skid distance during which the aircraft retains sufficient kinetic energy to penetrate a storage magazine or transport trailer and storage container. Third, compute the probability that an aircraft will impact within the dangerous skid distance from the facility heading toward that facility. Fourth, compute the probability that a fire or a dense part of the aircraft will penetrate or destroy the facility. Clearly, the probability that all of the above events occur together is many orders of magnitude smaller than the simple probability that an aircraft hits near a critical facility or transporter. It is also clear that values assigned to the coefficient for each step affect the confidence interval about the point estimate of the release probability. The understandable tendency is to assign worst case values to all parameters to create an upper bound on the estimated release probability. For purposes of communicating to the public, it is desired to have an estimate of the central tendency, the median or the mean value of the release probability as well. Include both the worst case and the mean value of the release probability due to aircraft accidents. The difference between point estimates of the worst case and of the typical case will give public officials an internally consistent estimate of the safety factors built into the prediction algorithm used.

Response:

An effort has been made in the Final EIS to provide the requested additional information. It is our belief that the aircraft crash scenario was analyzed to the point where it was demonstrated that aircraft crash risk is one to two orders of magnitude less than other risks associated with Pantex Plant operations.

RC: 15.108

Doc: SG-003/110

Not all structures proposed for storage and handling operations at Pantex are constructed in the manner and with the materials assumed in the DOE structural vulnerability analysis. That analysis seems to assume standard rebar reinforced concrete construction techniques. At Pantex there are some facilities that are more stout and some that are less stout than the analysis in the draft EIS seems to assume. Bundling the stout structures into the analysis probably creates a pessimistic estimate of the true risk of release. Suggest DOE obtain data from a test involving crashing an F-4 into a section of a commercial reactor containment vessel. Use that data as a basis for assessing the likelihood that a small military aircraft crash could be an initiating event for a release incident in a stout structure. Then assess the effect on the overall risk to Pantex operations.

Response:

See response to comment 15.097.

RC: 15.109

Doc: SG-003/111

The present model seems to assume that an accident that results in internal spalling of a structure will produce a release. This assumption seems overly conservative for pits stored in approved storage or shipping containers. Again, the data from the F4 Crash Test may provide valuable clues to the appropriateness of the analytical assumptions in the release models. Clarify in the EIS the release probability from spalling incidents. This may be one of the factors leading to an overly pessimistic assessment of the consequences of an aircraft accident. Since pits will be stored without chemical explosives, spalling seems an unlikely source for damaging both the storage container and the cladding on the pit.

Response:

This suggestion has been included in the Final EIS. Concrete scabbing leading to release is more fully characterized and more accurate results are presented in the Final EIS.

RC: 15.110

Doc: SG-003/112

In the aircraft accident consequence analysis, the DOE model assumes that either a direct impact or a skidding impact can lead to a release. The model assumes that the aircraft (or its dense structures acting as kinetic missiles) retains dangerous velocities for the entire skid. In reality, the velocity slows continuously during the skid. The target area is computed from the actual facility dimensions, the aircraft wingspan and the skid distance. The skid distance is the dominant factor in target area. Why not use a linearly decreasing velocity as a conservative means for estimating remaining kinetic energy during a skid? This would dramatically reduce the area involved in target zones and would refine the point estimate of critical aircraft accident probability.

Response:

See response to comment 15.074.

RC: 15.111

Doc: SG-003/113

The structural damage modeling assumes all aircraft in a single FAA category pose similar risk to structures. These categories are useful for licensing, air traffic control and taxing purposes, but may not be ideal for accident analysis. For example, both a T-37 and an F-15 are included in the small military category. The T-37 has much less kinetic energy than an F-15, and has much smaller components that could become missiles. The damage potential of a T-37 matches that of many general aviation aircraft better than it does an F-15. Nevertheless, the default portions of the DOE guidelines treats them identically. Why does DOE use FAA categories rather that a more technical criteria to group aircraft? Suggest a product of wing loading and gross weight as a better metric. Aircraft with high wing loading always approach faster than those with low wing loading. Aircraft with high gross weights always have more stout pieces in their structures and engines than aircraft with low gross weights.

Response:

The FAA categories have been used in the Final EIS, in accordance with the Draft DOE Standard (DOE 1996g). However, use of parameters specific to a certain aircraft type have been utilized. For instance, the T-38 and other dominant aircraft are addressed separately. There is less than a five percent difference in the results.

RC: 15.112

Doc: SG-003/114

Dr. Lin's analysis of nearest point of approach for each flight trajectory provides an alternative for site-specific accident modeling. It is not likely that his work can be extended to a full analysis of RAMS data within the promised schedule for the final EIS. However, his work does suggest that a careful examination of consequence analysis assumptions may be in order. One is tempted to believe that aircraft flying directly over a facility may pose the greatest risk. However, any aircraft impacting a facility from within a cone above that facility must impact at a very large glide slope angle. At angles greater than 30 degrees, there is virtually no skid distance. Thus the facility floor plan is the target area for impact from above. Because this area is much smaller than that assumed in the DOE guidelines, the probability of this accident is much smaller. Can the distribution of the points of closest approach be used to determine both the slant range and the line of sight angle to critical facilities? The effective target area for each facility will depend strongly on the impact angle. This effect is not included in the DOE guidelines because they default to a specified point estimate of the impact angle. The basis for this assumption is apparently discussed in the technical support documents for the DOE Standard, but that is not yet published, and may not be published for several more months. A Monte Carlo analysis is likely the right means for accommodating this important effect.

Response:

A suggestion was made to the authors of the Draft DOE Standard to allow for the use of RAMS distances to the facilities of concern. The suggestion of a Monte Carlo analysis was taken under consideration. However, as the commentor has stated, these alternate methodologies are unlikely to be available with sufficient time to meet the schedule of the EIS.

RC: 15.113

Doc: SG-003/115

A full risk assessment of aircraft accident potential would include a term for a collision between an aircraft and a transport trailer, either on site during transport between structures or off site during cross country transport. No such term is evident in the draft EIS. Suggest that the probability of an aircraft accident impacting a transporter be computed. Due to the short duration of exposure while in transit, it is expected that this risk will be shown to be negligible compared with other risks associated with fixed storage facilities.

Response:

See response to comment 15.078.

RC: 15.114

Doc: SG-003/116

The tiered approach to aircraft accident modeling encourages the analyst to perform increasingly complex computations if the screening level has been exceeded in the prior step. The next step for the Pantex modeling effort involves using actual aircraft specific accident rates rather than using average accident rates for each of the identified five aircraft categories. It is also possible to use available accident rates for the most commonly observed aircraft in a category and to use the category specific rates for the remainder. If accident rates are assigned to specific aircraft (such as the USAF T-1, T-37 and T-38 aircraft), then verify that the appropriate rates are used for the remaining aircraft in that category. These may be derived from aircraft specific accident data or estimated by marginal analysis of the entire category to determine the portion of the accident rate appropriate to the remaining aircraft types.

Response:

Specific rates for large and small military aircraft have been used in the Final EIS. Results show a less than five percent change with additional level of detail.

RC: 15.115

Doc: PC-028/11

Per Vol II, page E-23, para E.3.2. There is [no] automatic fire detection capability nor prompt response from local firefighters. This is a serious problem even if the rock overburden would shield the pit storage area from aircraft crashes. There is still the ground attendant problems of [a] mix of ground vehicles and equipment and humans.

Response:

Any damage that could be inflicted on the Manzano WSA bunkers is dominated by the aircraft accident scenario. As is stated in section E.3.2.4 of volume II, the pit storage at Manzano will be done in certified Type B containers. Minor damage to the facility due to aircraft crash is not anticipated to cause damage to the containers sufficient enough to cause a plutonium release. As a result, any damage that could be caused by ground personnel or vehicle accidents is not sufficient enough to cause a plutonium release.

RC: 15.116

Doc: FG-002/1

Regarding the Pantex Site-Wide Draft Environmental Impact Statement, I believe the analysis of the "airplane crash" scenario is deficient. How can it be that the probability of a crash causing a release has increased since your 1994 Finding of No Significant Impact, particularly after Pantex and the Amarillo Airport have worked together to reduce overflights of the plant and taken other preventative measures? I urge the DoE to correct the analytical errors and act to avoid wrongfully depriving Pantex of future functions for which it may be selected.

Response:

See discussion in section 1.3.11 in this volume regarding the results of the previous analysis.

3.16 Intersite Transportation of Nuclear and Hazardous Materials

RC: 16.001

Doc: HT11/5

What would be the route that you would transport this to the test site?

Response:

For an elaboration on the response given at the public hearing, see discussion in section 1.3.12 of this volume.

RC: 16.002

Doc:HT11/6

What about...the freeway system?

Response:

For an elaboration on the response given at the public hearing, see discussion in section 1.3.12 of this volume.

RC: 16.003

Doc:HT11/7

Are these the transport system...highway route control monitors. Would they be managed so that they would fall into that category?... They can be managed such that they do not fall into the highway route control formula. If they fall into that category, we have lots of notifications for things like that. In fact, you have truck drivers in that situation that would not be allowed to leave their vehicles.

Response:

For an elaboration on the response given at the public hearing, see discussion in section 1.3.12 of this volume.

RC: 16.004

Doc: HT11/8

And then you would...be briefed on this if they were expecting to be highway routes. So my assumption is that they are not at this point expecting to load anything from highway routes in quantity. That doesn't have anything to do [with] Federal marshals; that has to do with notification of states....

Response:

For an elaboration on the response given at the public hearing, see discussion in section 1.3.12 of this volume.

RC: 16.005

Doc: HT11/12

How many shipments would come to the test site for the 8,000 versus the 20,000 container of pits?

Response:

To elaborate on the response given at the public hearing, the exact number of pit containers that would be transferred per Safe Secure Tractor Trailer is classified information. However, it would be between 20 and 30. This translates into between 400 and 600 shipments to transfer 12,000 pits.

RC: 16.006

Doc: HT11/13

And that would be over how long, what time period is that?

Response:

To elaborate on the response given at the public hearing, at the rate of approximately 2,000 pits per year, it would take about 10 years to relocate 20,000 pits and 4 years to relocate 8,000 pits.

RC: 16.007

Doc: HT11/14

And if there were an accident along the route, do you...have any emergency response ideas?...

Response:

To elaborate on the response given at the public hearing, the emergency response plans and programs for the Transportation Safeguards Division (TSD) are voluminous and inappropriate for verbatim inclusion in the EIS. In general, TSDs emergency response plans involve a tiered organizational response to radiological incidents. In Tier 0, local law enforcement and TSD couriers assess the severity of the accident and determine the need for radiological assistance. Tier I involves the deployment of Radiological Assistance Teams (RATs), a Regional Response Coordinator (RRC), and Public Affairs Office (PAO) personnel. These personnel will have appropriate monitoring and communications equipment to assess the radiological status of the incident. At Tier II, additional technical expertise is provided to the response group. At Tier III, the accident response group will assist in recovery, repackaging, and decontamination operations. These four tiers correspond, respectively, to the following levels: (0) no structural damage and no potential for public controversy, (I) status of unknown or limited damage, (II) excessive damage of Safe Secure Tractor Trailers (SST) or shipment, and (III) radiological release cleanup/repackaging required.

Additional national emergency response resources from around the Nation are available if the severity of an SST convoy incident warrants such a call.

RC: 16.008

Doc: HT11/15

And you'd be using common carriers or contract carriers?

Response:

To elaborate on the response given at the public hearing, commercial carriers are used for radioactive waste shipments from Pantex Plant to Nevada Test Site. Pits would be transported in Safe Secure Tractor Trailers.

RC: 16.009

Doc: HT11/20

The other thing is, during the risk assessment for transportation, was this the 1000 shipments over a six-year period? Was there any cumulative studies done on how that might impact with other shipments of waste proposed and currently planned through Nevada in terms of a cumulative impact risk assessment?

Response:

Details on cumulative impacts have been added to volume I, section 4.16.5.

RC:16.010

Doc: HT11/21

What would you say [is] the amount of shipments at this time per week into the Nevada Test Site?... Do you have an approximate [number]?

Response:

To elaborate on the response given at the public hearing, Pantex waste shipments are minimal compared with other sites that ship to the Nevada Test Site (NTS). The maximum yearly shipment to NTS from Pantex was 28 shipments. The projected shipment rate from Pantex is less than the average occurring over the past three years. More details of radioactive waste shipments to NTS can be found in the Waste Management PEIS or the NTS Sitewide EIS.

RC: 16.011

Doc: HT11/29

... Are they [of] legal weight?

Response:

To elaborate on the response given at the public hearing, Safe Secure Tractor Trailers (SSTs) are legal weight trucks. The class of general commerce vehicles that most closely matches the SST in physical characteristics and travel distribution is the 5-axle, tractor-semitrailer with a van cargo body and a 6080,000 pound gross combination weight.

RC: 16.012

Doc: HT11/30

What routes would you use?

Response:

See discussion in section 1.3.12 of this volume.

RC: 16.013

Doc: HT11/31

... My name is Russell Dibartolo;...I'm with the Clark County, Nevada Department of Comprehensive Planning, Nuclear Waste Division. And my particular area has to do with impact assessment and review of Department of Energy impact assessments or...environmental impact statement activities.

One of the major things that we have found with a number of Department of Energy EISs or environmental assessments is that we feel that they unrealistically limit their regions of influence that are studied. If you studied, for instance, the Nevada Test Site within a 50-mile radius, you are leaving out with regard to any potential impacts or risks, over a million people or two-thirds of the population of the State of Nevada when you're dealing with shipments to the Nevada Test Site.

So one of the major requests we would have of you, the individuals preparing this particular EIS and others within the DOE complex, is that you take a very good look at the space between the sites. The [area] between the sites, [which] in this case is the Clark County metropolitan area also known as the Las Vegas valley metropolitan area.

We're primarily concerned with the routing of this material. There are certain areas in Clark County that we know of that are very high in accident rates. We know that there are a number of areas in Clark County where there's construction anticipated on the interstate and U.S. highways. This construction program [is] to last about 10 years. We know there's a high correlation between construction, congestion, and accidents, and we would like you to take that into account.

Response:

The region of influence as defined for the Nevada Test Site is not the same as the population distributions used in the transportation risk modeling. The transportation risk model uses 1990 census block data to determine the population distributions along Transportation Safeguards Division routes.

See general discussion on intersite transportation in section 1.3.12 of this volume for routing information.

RC: 16.014

Doc: HT11/36

You should also know that the Nevada Test Site has established for their EIS process a transportation advisory group, and within that group is a smaller subgroup or team that's called a protocol working group. This particular working group has already provided recommendations and census recommendations among a number of local governments and other interested individuals or groups that have already been sent to the Department of Energy prior to the comment deadline.

They are already working and addressing this, and this particular protocol working group or transportation advisory group has turned out to be a very good vehicle for our interactions. ...It's Frank DiSanza who is head of that program.... He works with DOE Nevada, and...they have...brought together that group. That group meets on an as-needed basis, generally once every two months. The transportation advisory group meets usually about once every quarter, and that's been going on for probably a little bit more than a year.

And it came up for shipments such as this. There were shipments that were planned to come in through North Las Vegas. North Las Vegas by accident heard about them. Turns out that they were just a very few shipments going to the test site cutting across Craig Road, which is a convenient way...if you're going south on I-15 and you go north on U.S. 95, it's a very good cut-off.

North Las Vegas officials became very concerned about that, and I was working at the university then as a consultant and was brought in to help facilitate meetings. And...from the need that was seen for that, we developed this transportation advisory group, and it has worked very well.

Response:

See discussion in section 1.3.12 of this volume.

RC: 16.015

Doc: HT14/4

... The transportation of plutonium and special nuclear materials to Hanford storage will require careful planning of routes and consideration of weather emergencies to minimize the likelihood of an accident. Emergency preparedness for minimizing the impacts of an accident will require financial support from DOE for State, tribal and local involvement, including adequate equipment and training. When materials are shipped, timely notification should be provided to the transportation agencies.

Response:

See discussion in section 1.3.12 of this volume.

RC: 16.016

Doc: HT02-16/1

It is too dangerous to transport as well.

Response:

The risks associated with proposed pit shipments are described in volume I, section 4.16 of this volume.

RC: 16.017

Doc: HT13/16

... To clarify, who is doing the certification?

Response:

To elaborate on the response given at the public hearing, 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 these empirically established hypothetical accident test conditions of the transport are prescribed in the Nuclear Regulatory Commission regulations (10 CFR 71.73) and are discussed in volume II, appendix F of this document.

Following certification testing by SNL, DOE will develop a Safety Analysis Report for Packaging (SARP) for the AT400A. 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 SARP is not yet available.

RC:16.018

Doc: HT13/41

Will Lawrence Livermore and Los Alamos be shipping different sorts of compositions to Pantex and expecting them to do the machining and tooling?

[Unidentified Speaker: I would presume whatever the role that is identified for Livermore and Los Alamos in the stockpile stewardship and management that it will be supported by Pantex in their mission.]

Response:

To elaborate on the response given at the public hearing, transferring the HE fabrication mission from Pantex Plant to Los Alamos National Laboratory (LANL) and/or Lawrence Livermore National Laboratories (LLNL) would require an estimated 150 rebuilds to be shipped per year from the high explosive (HE) fabrication site to the weapons assembly/disassembly site. The accident risk from transporting this material would be no greater than the risk encountered by the public from industrys transport of similar explosives. Transferring all or part of the HE fabrication mission from Pantex to LANL and/or LLNL would require an estimated 12 round trips per year to transport HE materials including the return of scrap HE to the laboratories.

RC: 16.019

Doc: HT13/50

In that model, there are several options for how you input the human population numbers along the transportation route. Can you tell me,...for the input of population data into those model runs, which of those options were used? Are there some default values, such as rural is one person per square mile, urban is five persons per square [mile], suburban is 2.5, [or are there]...more specific ways to enter population data into the model?

Response:

The ADROIT code uses population information from the 1990 census. For incident free calculations, the uniform population density along transport routes was obtained by determining the maximum population density in census blocks perpendicular to each roadway segment extended out to 30 kilometers. This maximum population density was used as the uniform population density for that road segment. For accident calculations, 1990 census block data were used for the affected populations from postulated dispersal accidents.

RC: 16.020

Doc: HT13/51

The default values are also calculated from the 1990 census. I think my question was more specific in that we have this route, I-40, between Amarillo and Manzano, and I am wondering whether actual population data for, let's say, a quarter mile, approximately, on either side of I-40 between Manzano and Pantex, is that the sort of information that was used, or was it just the default value plugged in where the default value also comes with the [1990] census, but it is like a statewide average or a regional average for rural and suburban?

Response:

Please see response to comment 16.019.

RC: 16.021

Doc:HT13/52

Could you give me an answer in sufficient time so I could submit a written comment about the values before the deadline?

Response:

Please see response to comment 16.019.

RC: 16.022

Doc: HT13/57

I just want to make sure I understood. Would you repeat what you said about the drop onto a spike in terms of transportation testing?

Would you then explain why on page 4-256 of the document it says the puncture test is a free drop of 40 inches onto a 15-centimeter diameter steel pin?

Again, to clarify, because I am trying to understand what is the information people should rely on, on page 4-256, the 30-foot drop test [that] you talked about, and this is a quote, "a 9-meter (30-foot) drop onto an unyielding surface." It is not onto a pin or a spike. It is onto a flat, unyielding surface. I just want to clarify what you are saying in relation to what is in the document.

[Unidentified Speaker: In the document that was identified or accepted by the Department of Energy for its container certification, and I assume you are talking about the AT-400 certification, there are three tests that are done. One is a 9-meter or approximately 30-foot drop test. The other is a drop test on an unyielding object. The other test is a puncturing test where they drop it from a lesser distance, and I believe it is 40 or 50 centimeters, I am not sure, on the spike that they are talking about.]

These tests are done in sequence, and then there is also a temperature test. Those tests are done and required by the NRC for certification of over-the-road transport of special nuclear material.

[Unidentified Speaker: I do want to point out that in these documents, please go back for very specific measurements to the document.]

Response:

The testing requirements for certification of Type B packages is provided in volume II, appendix F.

RC: 16.023

Doc: HT13/69

So if you are transporting 8,000 pits, and somebody gets a hold of a shipment I forget how may pits are on the typical shipment.

[Ms. Founds: About 20.]

So somebody got a hold of 20 pits and decided to poke holes in them.

Response:

The threat of hijacking is taken seriously by DOE. The security policies, procedures, and resources in place minimize the threat to TSD shipments.

RC: 16.024

Doc: HT13/70

What is the material that is so powerful? How thick is this?

Response:

Design information for the AT400A container is provided in volume II, appendix F.

RC: 16.025

Doc: HT13/71

Somebody passed me this dice diagram, AL-R8, and this is what you were telling me was the container that was so secure that nobody could ever get a hole through it? It is a quarter-inch stainless steel, this new one that is proposed that isn't yet being used.... So you are saying you don't think it would be possible for anybody to get that container open following a transportation accident because of that quarter-inch of stainless steel? Well, again, the credibility of believing...that there would be no possibility whatsoever that that container could be breached under any sort of accident scenario.

Response:

Potential offsite transportation accidents resulting in plutonium dispersal from AT400A containers are described in volume I, section 4.16.4.

RC: 16.026

Doc: CO-003/5

The transportation of plutonium and special nuclear materials to Hanford storage will require careful planning of routes and consideration of weather emergencies to minimize the likelihood of an accident. Emergency preparedness for minimizing the impacts from an accident will require financial support from DOE for State, tribal, and local involvement, including adequate equipment and training. When materials are shipped, timely notification should be provided to transportation agencies.

Response:

See discussion in section 1.3.12 of this volume.

RC: 16.027

Doc: CO-010/2

An additional area of concern would be the "major issue" of transportation of the excess plutonium materials to the Hanford Site. We believe that the Draft EIS needs to more fully evaluate the hazards and mitigation measures [that] would need to be implemented in support of the transportation of significant amounts of these materials to the Hanford Site.

Response:

The Pantex EIS analyzed the risks associated with the shipment of pits to the Hanford Site. The EIS analysis considers all potential accidents that could lead to a release of hazardous material. The analysis considered all combinations (and inter-dependence) of puncture, crush, impact, and fire environments.

RC: 16.028

Doc: CO-006/3

Accurate comparisons between all sites under consideration should once again make Pantex the preferred site. Maintaining and expanding the interim storage facilities at Pantex would all but eliminate the significant transport costs, and the attendant environmental and political risks involved with moving these functions to [another] site. Eliminating the unnecessary transportation of radioactive materials, will translate into less cost and greater public safety and protection. Ignoring or miscalculating the risks and costs associated with weapons materials would be a serious omission.

Response:

A description of the transportation of plutonium pits and the expected increase in risk is presented in volume I, section 4.16. No attempt was made to estimate the cost of transporting pits.

RC: 16.029

Doc: HT15/35

I don't believe that there was the same degree of detail according to the review of hazardous material as there may have been to the radiological aspects of transportation. ...Aspects of transportation [are discussed], but not in the potential for explosion, potential for HAZMAT spill, those sort of things in transportation in the transportation section. And I didn't see those addressed as potential candidate scenarios.

Response:

All hazardous material shipments are transported via commercial carriers in full compliance with applicable DOT regulations. Pantex Plant type operations do not consume or produce large quantities of hazardous chemicals. Consequently, the risks associated with Pantex Plant hazardous chemical shipments are no greater than those associated with other industrial facilities. Further information on the types and quantities of hazardous chemical shipments associated with Pantex Plant operations is available in the Safety Information Document (Pantex 1996a).

RC: 16.030

Doc: PC-017/13

If transportation of toxic materials and/or radiation materials to other sites poses a threat to [people] along [the routes] of transportation and to other travelers along the roadways, why would the storage of those substances not pose a greater threat to the health and safety of residents and workers at or near Pantex? We will have long-term, 24 hours per day exposure, which will be much greater than the meeting of a fellow traveler along the interstate or the exposure of someone in a roadside park.

Response:

The storage of pits in Zone 4 magazines does not result in radiological doses to the communities surrounding Pantex Plant.

RC: 16.031

Doc: SG-012/10

Transportation of the pits is a very serious task. What assurances exist for safe transportation? For example, are the transporters meeting speed limits, obeying other traffic rules and using defensive driving techniques to reduce transportation risks? If drivers are [not] complying with safe driving techniques, accident risks are increased. These concerns should be addressed in the DEIS.

Response:

Armed Nuclear Materials Couriers accompany each shipment containing special nuclear material. They also drive the highway tractors and escort vehicles while operating the communications and other convoy equipment. Couriers are required to obey all traffic laws. Transportation Safeguards Division (TSD) makes every effort to ensure its convoys do not travel during periods of inclement weather. Should the convoys encounter adverse weather, provisions exist for the convoys to seek secure shelter at previously identified facilities. The TSD has also imposed a maximum 55-mile per hour speed limit on its convoys, even if the posted speed limit is greater.

RC: 16.032

Doc: MG-002/5

The Region of Influence (ROI) for the NTS alternative must be expanded to include the Clark County Urban Area through which all shipments are planned. As with other DOE EISs, the defined region of influence for the assessment of impacts is 50 miles. From Clark County's standpoint, this is a major flaw in the study since the bulk of the impacts would result from the transportation of the plutonium pits and not the storage itself. This is because the storage technology is relatively advanced and the possible NTS storage sites are [well] isolated and controlled. Use of the ROI practically guarantees findings of no impact. However, all highway routes that are under consideration for shipment of the plutonium pits pass through the most congested areas of the State of Nevada on roads that are undergoing major construction, and in areas where the number of accidents and accident rates are the highest in the State.

Response:

See response to comment 16.013.

RC: 16.033

Doc: MG-002/6

Perceptions of Risk. The interstate route [I-15] historically used for DOE shipments to the NTS and now being considered for the additional Pantex shipments is within one-half mile of the Las Vegas Strip and downtown area. This is among the most popular tourist destinations in the country. This means that over 3,000,000 tourists who visit this area annually would be exposed to transportation safety risks and may perceive the area as dangerous and/or one to avoid, even under incident-free operation. Should even a minor incident (e.g., unanticipated stoppage) or accident occur in this area, perceptions of its seriousness may be amplified to a point that fewer people may choose this area as their pleasure or business destinations. Even a minor downturn in the tourist cycle could have a devastating effect on the southern Nevada economy. Although the effects of perceived risk are not easily quantifiable, this variable must be taken into account as routes are screened and evaluated.

Response:

We agree that perceived risks are not easily quantified. The socioeconomic impacts of such perceived risks are even more difficult to evaluate. However, a statement characterizing this potential has been added to the appropriate sections of the EIS.

RC:16.034

Doc: MG-002/8

Accident Analysis and Emergency Management Measures. Another example of the serious constriction placed on impact assessment by a 50-mile ROI has to do with the analysis of accidents and need for emergency management measures. Because the ROI takes into account only on-site areas, the impacts are so small as to be judged insignificant, and transportation and emergency and emergency safety issues do not need to addressed. Further, the new storage/transportation container, the AT-400A, now under development, has not had real world experience and its operational characteristics and vulnerability to acts of terrorism are open to question. Again, this becomes insignificant if impacts are not being considered outside the narrowly-defined ROI. In summary, we feel that all impacts that have been addressed in the DEIS must be reconsidered using at least a 100-mile radius from the Mercury entrance to the NTS in order to arrive at a realistic appraisal of potential impacts of relocation of the pits to that site. This would lead to a realistic appraisal of potential impacts due to transportation, the most public aspect of siting a storage area for plutonium pits (and other waste) at the NTS.

Response:

See response to comment 16.013.

RC: 16.035

Doc: MG-002/9

While we accept the findings of the transportation risk analysis that is based on the probability of a occurrence times its consequences, we are not convinced of the validity of this approach for shipments to the NTS. The Clark County Urban Area, with Las Vegas as its hub, contains the major concentration of traffic and congestion in this mainly rural county. When the population, traffic, impedance, distance and other variables for links in the urban area are aggregated with those of all other links on a potential route, inside and outside Nevada, the relative weight and importance of the urban links is diminished. This then leads to a smoothing of the data and the usual result of insignificant risk. We ask that the DOE take another tack in assessing risk and resultant impact of transportation of nuclear materials, that of comparative risk assessment as endorsed by the U.S. Department of Transportation in its Guidelines for Selecting Preferred Highway Routes for Highway Route Controlled Quantity Shipments of Radioactive Materials, August 1992. This approach places emphasis on comparison of routes on variables that are important in decision-making processes, rather than on probability figures that are almost always insignificant and not interpretable to government decision-makers. For example, comparison may be made on exposure of special populations, impact on environmentally sensitive areas and even relative risk of negative perceptions. This type of analysis on prospective routes selected for analysis in cooperation with affected jurisdictions would provide understandable results and a higher level of confidence in DOE actions than is not the case. As you know, Clark County is willing to provide up-to-date information for your use in such an approach.

Response:

The transportation analysis used in the EIS evaluates accidents occurring in both rural and urban areas. The Pantex EIS evaluates impacts associated with the defined alternative of relocating pit storage from the Pantex Plant. Included in the analysis are impacts associated with transporting pits to alternative storage sites by DOEs Transportation Safeguards Division (TSD). DOE is not using the Pantex EIS to decide between routes that will be utilized by TSD and as such, comparative routing analysis is inappropriate for the Pantex EIS. Routes utilized by TSD are classified, compartmented information and may not be disseminated except to persons with appropriate security clearance and a need to know.

TSD operations are in compliance with the requirements of 49 CFR 177 for selecting, notifying drivers of, and adhering to preferred routes. The majority of TSD travel (90 percent) is over interstate highway; the remaining 10 percent is over routes that meet the conditions for deviating from the preferred route when safety or security dictate such deviation. Regulations permit TSD deviation from the requirements regarding notification of the routes used.

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.

There is no "smoothing" of the risk due to sparsely populated rural areas. The probability of a potential accident and the consequences of potential accidents are dominated by the urban areas.

RC: 16.036

Doc: SG-011/1

Please provide information on the metric ton amount of depleted uranium currently stored on the Oak Ridge Reservation (ORR) and the metric ton amount that will be shipped from the Pantex facility. Please provide the historical metric ton amount of depleted uranium at the ORR. Also provide information on the environmental impacts for the interim storage of depleted uranium at the ORR. The Division contends that if the historical levels of depleted uranium stored (interim) at the ORR are exceeded, additional NEPA documentation should be prepared to adequately address the impacts to human health and the environment.

Response:

The Pantex Plant EIS considers the environmental impacts associated with shipments of weapons and weapons components (including highly enriched uranium and depleted uranium) related to Pantex Plant operations. The record of decision for the Pantex EIS will detail DOEs plans for interim storage of plutonium components (pits). Impacts related to interim storage of depleted uranium at Oak Ridge Reservation are not relevant to the decisions resulting from the Pantex Plant EIS.

RC: 16.037

Doc: PC-025/10

If weapons are shipped around the world without an AT-400A style container, why does the [plutonium] require a special container? Doesn't a weapon pose the greater risk potential?

Response:

The risks associated with nuclear weapons shipments are discussed in volume I, section 4.14. Department of Transportation regulations and DOE orders require the use of a certified Type B package for plutonium pit shipments.

RC: 16.038

Doc: PC-025/84

General comment sections 4.15 and 4.16. Please provide information on the level of quality assurance/quality control (QA/QC) defending the analyses of these sections. I would like the same information as requested on water and air quality sections of this EIS.

Response:

The quality assurance/quality control (QA/QC) of the referenced sections of the Draft EIS, as well as the entire document, was conducted in accordance with the Tetra Tech Quality Assurance Program Plan (TT 1995). The program is tailored for preparation of the EIS and to meet DOE Order 5700.6C and NQA-1 (ASME 1994), as appropriate. For detailed information, refer to these documents.

The assessments (including methodologies, models, and results) of human health impacts for volume I, sections 4.14 and 4.16, as well as the aircraft accident assessment in volume I, section 4.15, were subjected to a multiple level technical peer review process to ensure technical validity. Included in this review process was: (1) the analysts immediate supervisor, (2) the functional area manager, (3) technical experts from the Amarillo Area Office, and (4) technical experts from the Albuquerque Operations office.

Additionally, the assessments (including methodologies, models, and results) of human health impacts for volume I, sections 4.14 and 4.16 as well as the aircraft accident assessment in volume I, section 4.15 were exposed to extensive peer reviews. These reviews included two workshops occurring over several weeks along with independent supporting analysis by the workshop participants. The participants included representatives from DOE, Sandia National Laboratories, Lawrence Livermore National Laboratory, Los Alamos National Laboratory, the Defense Nuclear Facility Safety Board as well as nuclear safety experts from private organizations.

During the public review process, the assessments (including methodologies, models, and results) of human health impacts for volume I, sections 4.14 and 4.16, as well as the aircraft accident assessment in volume I, section 4.15, were reviewed by a group of independent scientists from Texas A&M and the University of Texas.

RC:16.039

Doc: PC-025/85

If the FL container is the only certified container available for shipment purposes, would DOE use the FL container to ease the 12,000 limit on Pantex if the AT-400A is not available? Is this a reasonable alternative requiring DOE to analyze the use of the FL containers to prevent a shutdown at Pantex?

Response:

The alternatives considered in this EIS are container independent. However, DOE considers the AT400A container as the most likely to be used if the Secretary decides to choose a pit relocation alternative. DOE currently possesses a limited number of FL-containers (approximately 300). A significant fraction of these containers are in use at other facilities. The purchase of a large number of FL-containers is not practical from either a programmatic or a safety perspective. DOE has committed to the development of a container that will enable compliance with the latest Nuclear Regulatory Commission (NRC) Type B package certification testing requirements. The NRC recently modified the certification testing requirements for Type B packages. The AT400A is being tested to meet these newer, more stringent requirements. However, no data currently exist to prove that the FL-container will meet the newer requirements. The FL-container will retain its Type B certification based on previous certification testing. However, this certification will be valid only for those containers currently owned by DOE. DOE is committed to the development of a pit container that meets the latest regulatory requirements.

RC:16.040

Doc: PC-025/86

If the FL container is certified, why doesn't DOE order more FLs for storage purposes?

Response:

See response to comment 16.039.

RC:16.041

Doc: PC-025/96

... How many AT400A containers are in existence? Does this pose a problem, please analyze?

Response:

The design of the AT400A container is currently being finalized. There are only a few prototype containers in existence. Full scale production is expected to begin at Pantex Plant in late 1996 or in early 1997.

RC: 16.042

Doc: PC-025/97

... Is it not reasonable that the most harmful event is a collision [with] heavy truck resulting in a rollover and fire. It appears that the event tree is linear rather than dynamic. Thus the analysis overlooks the compounding effects and thus the maximum impacts.

Response:

All potential accidents that could lead to a release of hazardous material are included in the databases used in the analysis. The analysis considered all combinations (and interdependence) of puncture, crush, impact, and fire environments. Further detail on the methodology and supporting documents can be found in volume II, appendix F.

RC: 16.043

Doc: CO-008/118

... How will the Texas Department of Public Safety and local emergency medical services be handled in the Intersite Transportation Impact Assessment? Will the safety analysis developed by DOE be acceptable to the Texas Department of Transportation?

Response:

See discussion in section 1.3.12 of this volume.

RC: 16.044

Doc: CO-008/119

Page 4-262, Paragraph 3. Paragraph states, "These shipments are made in full compliance with all applicable DOT regulations." This is stated for hazardous material shipments on page 4-264, Paragraph 2, as well. As a general comment, the draft EIS makes assumptions about the equivalence of design requirements and operations. They assume that the design requirements for vehicles, packaging, etc. are met at all times. How do they know this? Numerous studies on compliance with regulations in the transportation industry show that there can be a significant difference between what is supposed to be and what actually is. Moreover, many of the databases that are used to assess the safety of hazardous materials transportation do not contain reliable and adequate data to make this assumption.

Response:

This statement that the draft EIS makes assumptions about the equivalence of design requirements and operations is incorrect. The analysis considers accidents resulting from improperly maintained equipment, human errors, and other failures to maintain vehicles properly. It is assumed in the analysis that DOE Transportation Safeguards Division (TSD) has accidents of similar severity and root cause as commercial trucking firms, which is a conservative assumption since TSD has not experienced an accident resulting from improperly maintained equipment. Further information on accidents considered and databases utilized can be found in the Sandia National Laboratories document "A Statistical Description of the Types and Severities of Accidents Involving Tractor Semi-Trailers," (SNL 1994b).

RC:16.045

Doc: CO-008/120

Page 4-262, Paragraph 3. Provide data about the operational reliability of the equipment, tasks, etc. and about the reliability of the inspection and monitoring systems upon which safety relies. Are there data about inspection and monitoring reliability? Has DOE assessed the completeness and reliability of the databases upon which they base their claims? Show with data that there is no significant difference between design and operations in this system. What are the data?

Response:

The clearest indication of the operational reliability of the Transportation Safeguards Division (TSD) transportation system is its historical accident rate. The TSD accident rate is significantly lower than those of commercial trucking firms. The operating history with Safe Secure Tractor Trailers (SST) transport is sufficiently long to define an overall tow-away accident rate. The mean estimate for the rate of tow-away accidents involving an SST is 6.6 x 10-8 per mile. The tow-away accident rate for general commerce vehicles that most closely matches the SST in physical characteristics and travel distribution is approximately 2 x 10-6 per mile.

It is assumed in the analysis that DOE TSD has accidents of similar severity and root cause as commercial trucking firms, which is a conservative assumption. Further information on accidents considered and databases utilized can be found in the Sandia National Laboratories document "A Statistical Description of the Types and Severities of Accidents Involving Tractor Semi-Trailers," (SNL 1994b).

RC: 16.046

Doc: CO-008/121

Page F-26, paragraph 2,...left [column].... It is fallacy to [say] that "Because of the stringent regulations...there has never been...." The stringent regulations contribute to the result of no documented deaths of significant injuries, but they are not the only reason. Luck, the smart response of personnel, and other intervening factors not related to the quality of training and inspection plays a role.

Response:

We agree with the comment as stated. Text has been changed for the Final EIS.

RC: 16.047

Doc: CO-008/122

Page F-26, paragraph 2,...left [column].... Did DOE assess how different combinations of "initiating events" may lead to accidents that could result in release of hazardous/radioactive materials? What combinations of factors were used? Was there any attempt in the study to look at this issue?

Response:

See response to comment 16.042.

RC: 16.048

Doc: CO-008/123

Appendix F, Tables and Figures F.5.1F.5.3. In the event of a large increase in [activities], how will the current system of transportation (including inspections, loading, packagingin short, all the activities associated with moving an object from one site to another) react? Will more inspections occur? Will more people be hired? Will more equipment be used? Or will the same number of inspections, equipment, and people be used to do more? How will this affect reliability in the system? (The research on human workload shows that increases in workload can increase failure/errors and that this may not occur in a linear fashion. Appendix F (tables and figures in F.5.1F.5.3) [is] based on 100 observations100 observations over how many years (i.e., what frequency of shipments)? Generally, there is good reason to suspect that as frequency of activities increase, one might observe more errors or more frequent errors.) Please provide clarification for exposure; i.e. what activity provides the most exposure. Clarify exposure incurred by the repackaging of pits.

Response:

The acceptance of a pit shipment campaign is not expected to increase accident occurrence in a non-linear fashion. The workload increase if pit shipments occur will not strain the resources of the Transportation Safeguards Division even at a maximum weapons activity level. The total workload will still be below peak levels of the past. In addition, TSD will operate using the same procedures, maintenance, and training as in the past. The 100 observations described in the document refers to a statistical sample not a number of physical inspections. The exposure incurred by the repackagement of pits will be discussed in volume I, section 4.14, of the Final EIS.

RC: 16.049

Doc: CO-008/124

Page 4-262, Table 4.16.1.1-3. Data from radioactive waste shipments are limited for the years 199294 only. Thus, one might expect that the "Annual exceedence probability" (Figures in F5.1F.5.3) would increase in the event the rates of shipping increase. What data were used to make the assumption that failure rates would increase in a linear fashion? How would the probabilities of accidents and the risks change if a non-linear relationship were assumed (increasing failures with increasing workloads and shipments)? Can DOE do this analysis? Why were data presented based on only 100 observations? Are there more data than these?

Response:

Figures F5.1F.5.3 refer to Transportation Safeguards Division (TSD) shipments, not radioactive shipments. The acceptance of a pit shipment campaign is not expected to increase accident occurrence in a non-linear fashion. The workload increase if pit shipments occur will not strain the resources of TSD even at a maximum weapons activity level. The total workload will still be below peak levels of the past. In addition, TSD will operate using the same procedures, maintenance, and training as in the past. The 100 observations described in the document refers to a statistical sample not a number of physical inspections.

RC: 16.050

Doc: CO-008/125

Page 4-269, Table 4.16.2.1-1. Do the +/- factors around the base rate cover the extra shipments that would occur to send the materials to other sites? The description of action plans state that 2,000 weapons assemblies/disassemblies per year is the current activity level. Is this the base shipment schedule?

Response:

The +/- factors around the base rate bound a workload of 2,000 weapons operations per year with the subsequent intersite transportation. The base rate refers to the currently planned activity level for weapons operations, which is less than 2,000 operations per year.

RC: 16.051

Doc: CO-008/126

Page 4-269, Table 4.16.2.11. When assessing the risks in a transportation system, was the entire system, from design of components, regulatory context, inspections and monitoring, to preparing material for transportation, to loading, to shipping, etc., considered? [If] not, explain. The reason this is important has to do with how failures/errors at one time in the system operation can affect subsequent events. For example, if someone drives off the road when transporting one load, the consequences only affect that single load of material. However, if there is an incorrectly designed or tested package (e.g. shipping container), it would affect all shipments using that package. This has occurred in the high-level radioactive waste transportation system.

Response:

The analysis was performed with a system perspective and considered all aspects of highway shipments. No attempt was made to model unidentified systematic problems. The DOE believes that the policies and procedures in place are sufficient to minimize the introduction of systematic problems into the DOE Transportation Safeguards Division system by correctly identifying and correcting any such problems that occur.

RC: 16.052

Doc: CO-008/127

Page 4-269, Table 4.16.2.1-1. Was a risk assessment completed for the total transportation system for improperly maintained equipment? Provide the data sources and the methodology used in this assessment. (It is not reasonable to assume that there will never be inspection failures.) How would such scenarios affect risk estimates?

Response:

Accidents with root causes of improperly maintained equipment were considered in the analysis. Further information on accidents considered and the databases used can be found in the Sandia National Laboratories document "A Statistical Description of the Types and Severities of Accidents Involving Tractor Semi-Trailers," (SNL 1994b).

RC: 16.053

Doc: CO-008/128

Page 4-256, Paragraph 1. There have been mistakes (errors) made in the design requirements and testing protocol of the DOT and NRC for packaging and testing, and thus in reported results. There are errors and failures in monitoring and inspections so that malfunctioning/corrupted packaging continue to be used although they do not satisfy the testing requirements. Has DOE addressed such scenarios in their analyses? If not, explain.

Response:

No attempt was made to model unidentified systemic problems. DOE believes that the policies and procedures in place are sufficient to minimize the introduction of systematic problems into the DOE Transportation Safeguards Division system by correctly identifying and correcting any such problems that occur.

RC: 16.054

Doc: CO-008/129

Page 4-256, Paragraph 1. Regarding the adequacy of databases on pages F-18 and F-22, prior studies suggest that they may not contain complete or reliable data in all cases. ...Does DOE account for such inadequacies in their assessments? For example, what is the uncertainty of these databases? Making assumptions that reflect the uncertainties, in the data resulting from their incompleteness and lack of reliability. Please reassess the risk.

Response:

Uncertainties in data and the means of quantifying these uncertainties are described in the following documents:

"A Statistical Description of the Types and Severities of Accidents Involving Tractor Semi-Trailers," (SNL 1994b).

"Determination of Influence Factors and Accident Rates for the Armored Tractor/Safe Secure Trailer," (SNL 1994a).

RC: 16.055

Doc: CO-008/130

Page F-19, Figure F.6.3.1-1. Safety analyses that do not directly address the role of human error in contributing to risks are weak. Human error is often found to be the single largest contributor to failure frequencies. This EIS seems to focus on mechanical failures. Is human error included in the failure rates that are used in event trees. How are they incorporated? How are assumptions made about human error rates in a greatly expanded transportation system (under scenarios of shipping pits to other sites and increased rate of dismantlement)?

Response:

Accidents resulting from human error are included both in the accident rate determination and in the accident severity determination. Further information on accidents considered can be found in the Sandia National Laboratories document "A Statistical Description of the Types and Severities of Accidents Involving Tractor Semi-Trailers," (SNL 1994b). The acceptance of a pit shipment campaign is not expected to increase accident occurrence in a non-linear fashion. The workload increase if pit shipments occur will not strain the resources of Transportation Safeguards Division (TSD) even at a maximum weapons activity level. The total workload will still be below peak levels of the past. In addition, TSD will operate using the same procedures, maintenance, and training as in the past.

RC: 16.056

Doc: CO-008/131

Page F-19, Figure F.6.3.1-1. How many more shipments would there be each year (approximately) if the pits are shipped to SRS, NTS, etc? How much larger/smaller are these rates than current rates? Are these different rates used to estimate different failure rates in the assessment? Would risk estimates change at all, if times of shipments were changed (e.g., night time vs. day time vs. afternoon only vs. weekends, etc)?

Response:

The exact number of shipments per year is classified information. However, the workload increase if pit shipments occur will not strain the resources of the Transportation Safeguards Division (TSD) even at a maximum weapons activity level. The total workload will still be below peak levels of the past. In addition, TSD will operate using the same procedures, maintenance, and training as in the past.

Operating environments, such as road type, road location, and time of day, play an important role in the observed accident rates of heavy trucks used in general commerce. These same factors influence the accident rate of the Safe Secure Tractor Trailers (SST) used by the Department of Energy to transport hazardous cargos within the continental United States. Because there is no limitation on the times that SSTs can travel, an average accident rate was determined appropriate for influence factors related to the time of day and days of the week. Additional details and discussions on how these influence factors were accounted for in the analysis is available in the Sandia National Laboratories report "Determination of Influence Factors and Accident Rates for the Armored Tractor/Safe Secure Trailer," (SNL 1994a).

RC: 16.057

Doc: CO-008/132

Page F-8. How many shipments are actually anticipated per year? If pits are shipped elsewhere, how would shipment rates differ from FY 1997?

Response:

The exact number of shipments per year by the Transportation Safeguards Division (TSD) is classified information. However, the workload increase if pit shipments occur will not strain the resources of TSD even at a maximum weapons activity level. The total workload will still be below peak levels of the past. In addition, TSD will operate using the same procedures, maintenance, and training as in the past.

See responses to comments 16.005 and 16.006.

RC:16.058

Doc: CO-008/133

Page F-8. What are the estimates for subsequent years? How much change will there be in the system rate of shipments over the assessed period of time? If they are being shipped to another location for storage, this would increase the number of shipments per year.

Response:

See response to comment 16.057. Additionally, see responses to comments 16.005 and 16.006.

RC: 16.059

Doc: SG-010/5

Embracing this strategy will reduce risks and risk perception issues associated with the unnecessary transportation of fissile materials on public roads and highways throughout the country. Clearly, a prolonged shipping campaign of plutonium pits along the Nation's highways, especially through large urban areas like Las Vegas, will cause significant adverse socioeconomic and cultural impacts even if no accidents occur.

Response:

See discussion in section 1.3.12 of this volume.

RC:16.060

Doc: PC-028/7

Kirtland Air Force Base also serves as an International Airport. Major highways almost borders KAFB to the west and north. This places the transport of nuclear pits on, about, and above KAFB/Albuquerque. The air traffic is extremely high and the highways are busy with Albuquerque, New Mexico, and Intra/Inter state traffic. The other alternative sites dont have this problem-select one of them.

Response:

All alternative sites involve shipment of pits over routes that pass through one or more cities with an international airport and busy highways. This is not unique to Kirtland Air Force Base (KAFB) or Albuquerque. A description of risk due to the transportation of pits to KAFB is presented in volume I, section 4.16.

3.17 Environmental Justice

RC: 17.001

Doc: HT08/2

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations, President Clinton's February 11th, 1994 memorandum for the heads of all departments and agencies requires an analysis of environmental effects on low income and minority populations to include human health, social, and economic effects. Why does the draft of all three documents analyze only the human health effects of the Proposed Actions and not the social and the economic effects as required by the Executive Order?

Response:

Social and economic (Socioeconomic) impacts of the continued operations at Pantex Plant have been considered in volume I, section 4.11, Socioeconomic Resources. In the Environmental Justice section, the location of minority or low-income populations, identified in volume I, Figure 4.17.11, and Figure 4.17.12, leads to the conclusion that no disproportionately social and economic impacts occur on minority or low-income populations from Pantex Plant operations. The text in the volume I has been revised to state this conclusion. Section 4.17.2 of the Draft EIS provides discussion of beneficial economic impacts to both majority and minority populations. A good example of adverse social and economic impacts on minority or low-income community would be from the construction of a freeway through such a community. In the past, many freeway projects have divided these communities into detached neighborhoods with loss of social interaction, economic loss from declining property values, and disruption of social and economic life resulting from forced relocation of residents from the project area. No such adverse impacts are generated by the continued operations of the Pantex Plant.

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

RC: 17.002

Doc: HT08/3

The socioeconomic [analysis] is a little bit different than the Executive Order covering what we just talked about, the environmental justice in minority populations. ...An analysis of the social and the economic [factors] have to go along with the health effects in the environmental justice analysis, not just the health effects.

Response:

See response to comment 17.001.

RC: 17.003

Doc: HT11/33

With regard to environmental justice, if you're shipping by -- through the interstate, or if you happen to use rail, both the interstate and the rail go along about the same route, more than 38 percent of the minority population of Clark County lives within a half mile of either of those routes. And so the impacts or risks might be a little bit higher.... Thirty-eight percent of the population along the railroad and interstate is minority or low-income. In Clark County the minority, low-income percentage is 11. So there's a substantial difference between the minority, low-income population along the routes and the general minority, low-income population of Clark County.

Response:

The environmental justice issue has been analyzed consistently within a 80-kilometer (50-mile) radius circle from the project location at each site under study. The issue of transportation safety has, however, been discussed in volume I, section 4.16, Intersite Transportation of Nuclear and Hazardous Materials. The routing of radioactive materials (including waste) being shipped on the nation's highways and roads is subject to regulations that are administered and enforced by the U.S. Department of Transportation. The primary objective of these regulations is to ensure that the motor vehicles transporting a regulated quantity of radioactive material are operated on routes that minimize radiological risk (49 CFR 397.101[a][1]). DOE will continue transporting radioactive materials in accordance with these regulations.

RC: 17.004

Doc: CO-008/28

The current definitions/criteria of environmental justice do not take into account the people in rural areas who are politically handicapped in comparison with a large urban center. The weight of the population in the urban area impacts elected representation to such a degree that the minority rural voters, in effect, have little voice, even when they are most highly impacted by decisions. Definitions that are based on race/ethnicity or income alone do not address this problem. This is the situation that exists around Pantex, where neighbors, no matter how well organized, cannot "outweigh" the numbers and interests of urban Amarillo.

Response:

Comment is noted. 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 the population within the project's Region of Influence. However, the analysis in the Environmental Justice section is provided to meet the requirements of Executive Order 12898, Federal Action to Address Environmental Justice in Minority Populations and Low-Income Populations. Although no final guidance for implementing the Executive Order has been issued by EPA, guidance issued by the Council on Environmental Quality and the Department of Energys own internal guidance were used to focus consideration of environmental justice on large enough groups belonging to minority or low-income populations and not on single or few rural voters. Communities in the Pantex region of influence have been defined as Census Tracts in the Amarillo urbanized area and rural Block Numbering Areas (BNAs) outside the urbanized area.

RC: 17.005

Doc: CO-008/29

This comment is a duplicate of comment 17.001.

RC: 17.006

Doc: HT13/32

... When you are considering environmental justice, do you also consider the number of nuclear projects that are already within a state?...

I mean it is like I am up in Los Alamos, and they want to move Rocky Flats operations to Los Alamos. They want to shoot missiles. They want to dump radioactive waste in the Rio Grande. They want to put midlevel waste at WIPP. They want to do morethey want to expand the Alamogordo testing range. Shouldn't that be part of environmental justice to look at how many nuclear projects there are already in the state?

Response:

The analysis in the Environmental Justice section is provided to meet the requirements of the Executive Order 12898, Federal Action to Address Environmental Justice in Minority Populations and Low-Income Populations. DOE follows site selection criteria for these types of projects. DOE looks at all projects currently existing and future projects across the country, and analyzes how they will affect a local area. Our analyses concluded that none of the proposed actions would result in either significant impacts to the entire affected populations or disproportionate adverse impacts to low-income or minority populations.

RC: 17.007

Doc: HT13/33

Isn't there an impact section that addresses the fact that there is no evidence that cumulative impacts will lead to a significant consequence to the people? Is that a part of the environmental justice?

Response:

Cumulative impacts have been discussed for each of the 17 environmental resources or issues in this EIS, including environmental justice.

RC: 17.008

Doc: HT12/4

And so, based on that, I have a comment that I am going to make later, but I think that it's really important particularly under the NEPA regulations and in effort by the Department of Energy to really bring the public more into this discussion that at some point we look at what is the weakness of our outreach strategy that does not allow us to bring more -- a diverse group of people from this area to these kinds of meetings.

Because based on what the gentleman just said -- and I just saw that in the summary that it does, in fact, state that a disproportionate burden would be borne by minorities as it's defined here and low-income people in this area, then they should be in greater numbers at this table to, one, learn what is at stake, what are the potential dangers, what are the benefits, et cetera, et cetera, but also to be here to raise their own questions and concerns and then be prepared to help make recommendations that will be factored into the final decision.

Because we can point to the successes of the plant, the positive role that it has played in this community, the fact that it is one of the largest employers, but there may be some other things that those regular citizens need to say that may in some way shape the final decision on these particular three EISs that's needed.

Response:

Your comment is noted. DOE has made significant changes in its community outreach programs and continues to improve upon its past practices in response to public input.

RC: 17.009

Doc: HT12/9

... I'm curious, are there additional government policies that certain demographic groups as being less valuable, more expendable, whatever the term may be in, humane terms, as opposed to other populaces with regard to institutions like SRS?

Response:

To elaborate on the response given at the public hearing, the Nation's nuclear program has evolved over the past five decades in the context of National security requirements. Locations of nuclear facilities were not determined by the racial or ethnic characteristics of the population in the communities where facilities were located. The Federal government has, however, become more aware of the fact that certain Federal programs in the past have resulted in disproportionately high environmental impacts on minority and low-income populations. The President, therefore, issued Executive Order, 2898, in February 1994, to give environmental justice special consideration in locating Federal facilities in future.

RC: 17.010

Doc: HT12/24

Okay. And then I had another question about the list, how come environmental justice is broken out and it's not included under cultural resources or socioeconomic resources? And having taught NEPA, we normally would put it under there and not have it by itself. And I noticed it was discussed in detail. There are only two things discussed in detail and the rest is [not]....

Response:

Your comment is noted. It is true that till recently, environmental justice was implicitly included in the socioeconomic resources, particularly in the social impact sections, when social impacts were evaluated separately from the economic impacts. With the issuance of the Executive Order 12898 in 1994, which calls for a discussion of environmental justice issue in all EISs, it has been given special attention and was, therefore, discussed in greater detail than has been the case in earlier documents.

RC: 17.011

Doc: HT12/30

Another comment is you claim here and also in the document of the Savannah River section fully evaluated environmental justice. And I read the two or three pages on environmental justice and there are a lot of facts, there are no conclusions. ...Your companion EIS [SSM PEIS] ...makes all kinds of erroneous conclusions on environmental justice.... But you don't make none. And let you claim you --

Response:

In accordance with Executive Order 12898, we conducted an analysis to determine whether the project (interim storage of plutonium pits) would have disproportionately high and adverse human health or environmental effects on the minority and low-income populations and concluded that no such impacts would occur. Please refer to the Stockpile Stewardship and Management PEIS for their response to your comment.

RC: 17.012

Doc: CO-002/5

This comment is a duplicate of comment 17.001.

RC: 17.013

Doc: SG-012/7

Vol. 1, page 5-69, 5.5.2.2 Environmental Justice. The entire section relies on 1990 census data. The "no impact" decision does not consider projected population growth in this location over the period of time that the pits may be in storage. Albuquerque, for example, has had a substantial increase in population during the last 20 years.

Response:

The Environmental Justice section requires breakdown of population by minority and low-income groups at the lowest possible geographical level, such as Census Tract or Blocks. The 1990 census is the only source which provides data consistently for Pantex and the other four sites (Nevada Test Site, Savannah River Site, Kirtland Air Force Base, and Hanford). It gave us a common basis for analysis throughout this EIS. Socioeconomic impacts for the Albuquerque area, including population changes, are discussed in volume I, section 5.5.1.9.

RC: 17.014

Doc: MG-002/7

... The population along the Interstate and nearby connectors includes a disproportionate number of minority and low-income individuals [38% minority and low-income, as compared to Clark County's 24%]. In addition, U.S. 95, the connector between the Las Vegas Urban Area and the NTS, serves the fastest-growing area of the country with regard to new residents and construction. Designation of a transport route for plutonium pits along this corridor may serve to slow down such growth or, possibly, result in a general lowering of property values. Use of a constricted ROI causes these important issues to be ignored. This is another example where a procedural convention virtually guarantees that potential impacts may not be identified.

Response:

See response to comment 17.003.

RC: 17.015

Doc: PC-025/87

General comment for section 4.17: What are the Minority and Low-Income areas by US congressional districts in the ROI? Does this show greater impact potential? What about by Texas legislature districts? Page 5-55 Materiel vs. Material?

Response:

Environmental Justice analysis for minority and low income areas looks within an 80-kilometer (50-mile) radius circle centered in the southwest corner of Zone 4 of Pantex Plant. Minority and low-income population is presented at the lowest possible geographical level, i.e., Census Tract and Block numbering areas in the rural areas to identify maximum impacts. Data by U.S. Congressional districts, which are generally larger then Census Tracts, would show fewer areas with concentrations of minority or low-income populations. Moreover, minority and low-income data are not available in sufficient detail at the Congressional district and legislature district level.

On page 5-55 the word material is spelled two different ways. The word spelled "materiel" used in the sentence "KAFB is an Air Force Materiel Command base..." means equipment, apparatus, and supplies, as guns and ammunition, of a military force. The word spelled "material" as used "nuclear material..." means the substance or substances out of which a thing is or can be constructed.

RC: 17.016

Doc: CO-008/30

How are individual minority sensitivities in the worker population assessed in the study? Do the training programs and safety information, materials to workers, and the community account for different literacy rates and/or primary languages? Does DOE have any data about the extent to which information about the Plant is known or understood, or the effects of radiation exposure are known/understood in the minority community? If so, provide the data.

Response:

Occupational Safety and Health Administration and implementing DOE Orders address safety and health issues for all workers at Pantex regardless of minority or income status, including radiation exposure. Volume I, section 4.17, Environmental Justice, discusses the potential for radiation effects on minority and low-income populations.

RC: 17.017

Doc: CO-008/31

Was exposure to contaminated clothing, for example by minority laundry workers, considered? If so, how?

Response:

Radiation and/or chemically contaminated clothing is not laundered but is disposed of in accordance with applicable regulations.

RC: 17.018

Doc: PC-008/2

This comment is a duplicate of comment 17.001.

RC: 17.019

Doc: PC-028/6

Page 5-69, para 5.5.2.2:...This section is listed as Environmental Justice. Of all the sites KAFB/Albuquerque has the highest, most diverse population, and putting the pit storage activity in KAFB adds [un]necessary risk to KAFB/Albuquerque.

Response:

The Manzano Weapons Storage area at Kirtland Air Force Base is one of the five sites which have been analyzed in this EIS to identify environmental impacts of pit storage. One of these five sites will be identified as the pit storage site by the DOE after taking into consideration environmental, cost, technical, and other relevant factors.

RC: 17.020

Doc: HT17/89

The document is designed, again, to reassure. 20% minorities in the workforce is presented as a benefit of good hiring practices. Minority populations are assumed to live too far away (17 miles) to have any risk associated with them. How was inter-individual sensitivity to the worker population assessed in the study? It does not look like it was.

Response:

Analysis in the Environmental Justice section is provided at the Census Tract and Block Numbering Area levels. These are the smallest geographical units for which minority and low-income data are available. Inter-individual sensitivity to the worker population is dealt with as an administrative concern by the Pantex Plant management and is out of scope of the EIS analysis.

RC: 17.021

Doc: HT17/90

Do the training programs and safety/information materials to workers and the community account for different literacy rates [and] primary languages? Does the agency have any data about the extent to which information about the plant is known or understood, or the effects of radiation exposure are understood in the communities, minority and not?

Response:

All maintenance and production technicians at the Pantex Plant must pass the Audit Basic Learning Examination (ABLE) which establishes, if passed, that they have the equivalent of an eighth grade English reading and math comprehensive level. U.S. citizenship is also required. All Pantex Plant employees, subsequent to hire, receive general employee training, which is given in English, covering general safety training at the plant to include basic understanding of radiation safety. 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. Pantex Plant also invites the general public to attend Pantex Plant Night each month to speak directly with plant personnel. The time and place is announced through the local media. In addition, specific inquires may be made to the Pantex Plant information office to obtain further information on training programs and plant safety.

RC: 17.022

Doc: HT17/91

The agency did not address the issue of radiation exposure to laundry workers, etc. offsite or onsite. Often these kinds of exposures are predominately to minority populations.

Response:

See response to comment 17.017.

RC: 17.023

Doc: HT17/92

How are transportation routes related to minority communities?

Response:

Transportation routes are selected with highest consideration given to public safety and security of the materials being shipped. Generally, these are interstate highways. Where DOE facilities are located away from interstates and alternate routes through communities are available, routes are selected to provide maximum safety and security and are not based on minority population distribution.

RC: 17.024

Doc: CO-005/21

This comment is a duplicate of comment 17.020.

RC: 17.025

Doc: CO-005/22

How was inter-individual sensitivity to the worker population assessed in the study? It does not look like it was. Do the training programs and safety/information materials to workers and the community account for different literacy rates, primary languages. In the communities, how and who provides the information? Provide any data about the extent to which information about the plant is known or understood, or the effects of radiation exposure are known/understood in the communities (minority and not)?

Response:

See response to comment 17.021.

RC: 17.026

Doc: CO-005/23

The document did not address the issue of radiation exposure to laundry workers, etc. offsite or onsite. Often these kinds of exposures are predominantly to minority populations.

Response:

See response to comment 17.017.

RC: 17.027

Doc: PC-010/1

If pits in SSTs travel through Hispanic neighborhoods, residents could perceive that a threat to their health and safety.

Response:

The specific routes used by Safe Secure Tractor Trailers are classified for National Security. Safe Secure Tractor Trailers may, however, travel as much through neighborhoods belonging to majority population as through minority populations, including Hispanic neighborhoods. Pantex-related intersite transportation activities will result in a maximum annual collective general population dose of 0.40 person-rem per year (4.0 person-rem for ten years of operations). The health and safety risks are, therefore, considered minimal and would not affect Hispanic neighborhoods disproportionately.

3.18 Irreversible and Irretrievable Commitments of Resources

RC: 18.001

Doc: HT12/2

I'm looking for a complete environmental assessment [that evaluates],...the total environmental picture including, as NEPA mentions repeatedly, impact on future generations and conservation of nonrenewable resources.

Response:

Volume I, section 4.18, discusses irreversible and irretrievable commitments of resources. Volume I, section 4.19, discusses unavoidable adverse environmental impacts. Radiological impacts are discussed and analyzed in volume I, sections 4.7, Air Quality and 4.14, Human Health.

3.19 Unavoidable Adverse Environmental Impacts

No comments received.

3.20 Relationship Between Local Short-Term Uses of the Environment and the Maintenance and Enhancement of Long-Term Productivity

No comments received.

3.21 Cumulative Impacts

RC: 21.001

Doc: HT10/1

My comment and question revolves around the term cumulative impact. As defined in the Council on Environmental Quality Guidelines, cumulative impact is the impact on the environment [that] results from the incremental impact of the action when added to other past, present and reasonably foreseeable future actions, regardless of what agency, Federal or nonfederal, or person undertakes such other action. Cumulative impacts can result from individually minor, but collectively significant actions, taking place over a period of time. That's the comment.

Response:

As directed by the Council on Environmental Quality, a scoping process was employed to identify the scope and "significant issues" that needed to be addressed. The "scope" is defined to include both "connected," "cumulative," and "similar actions." Cumulative impacts are addressed and discussed in each resource area as well as with the alternatives.

RC: 21.002

Doc: HT14/3

... Equity impacts must be addressed in the assignment of new nuclear materials, including plutonium, to Hanford.

Response:

This comment on equity impacts is part of the series of points specifically related to long-term plutonium storage and disposition. The concept of equity is very difficult to apply within the specific scope of this EIS because: 1) transfer of pits to Hanford Site would be only an interim action of no more than 10 years, 2) the Hanford alternative is limited to only 8,000 pits and it is not progammatically feasible to consider smaller amounts at multiple sites, and 3) long-term storage and non pit form plutonium and plutonium pits are within the scope of the Storage and Disposition PEIS.

RC: 21.003

Doc: CO-010/3

We are pleased to note that the Draft EIS has not identified any significant environmental impacts from the use of existing Hanford facilities for this potential mission.

Response:

Volume I, section 5.4.1, assesses the environmental resources at Hanford Site that have the possibility to be impacted. The analyses indicate that the impacts to the resource areas would be minimal.

RC: 21.004

Doc: CO-009/2

Fundamental to DOE's further consideration of the roles Pantex should play relative to the changing missions of the nuclear complex is the unequivocal recognition that even accumulatively, there would be NO significant adverse environmental impacts from retention and potential expansion of the variety of missions possible for Pantex.

The summaries of the relevant draft EISs do not report this fundamental conclusion explicitly; rather, in some instances, the summaries misrepresent that conclusion, reporting, instead, effectively minuscule environmental potentialities that are characterized as "adverse" only because they do not equate to measurable "benefits." We suggest the rote language of EISs should be expanded to recognize effectively neutral outcomes (not merely "beneficial" or "adverse" consequences).

Response:

Though the environmental "potentialities" (i.e., impacts) might seem "minuscule," 40 CFR ¤1502.2 states to "devote substantial treatment to each alternative considered in detail, including the Proposed Action so that reviewers may evaluate their comparative merits."

RC: 21.005

Doc: HT17/12

Finally, I think the overall weakness is probably in the cumulative impacts. You've broken down the process into bits and pieces, where you look at, if this happens you lose this many jobs, and if this happens you lost this many jobs. There's a real lack of effort to try to tie those together and integrate that and say worst-case, best-case. And I think that would be really helpful for the public at large to find out what the future of the plant is.

Response:

When the scoping period occurred for the Pantex EIS, there were numerous comments pertaining to socioeconomics (refer to DOE/EIS-0225-IP pages A-5 through A-9). These comments were then utilized to prepare the methodologies (see volume II, appendix A), which were then formulated into the body of the EIS. Many of the socioeconomic comments were related to the cumulative impacts of the Proposed Action and Alternatives. The Cumulative Impacts sections including volume I, sections 4.21, have been simplified for easier understanding.

RC: 21.006

Doc: HT17/47

...One sort of succinct thing to deal with is in your cumulative impact sections, where you try to encompass the PEIS's that are floating around out there, when you deal with the Storage and Disposition PEIS, you describe storage and speak to that. And then you describe disposition and characterize it as sort of your bounding case that includes a reactor, and when there's a reactor, there's a MOX fuel site, a processing site, et cetera, et cetera. I ask you all to rework your storage definition. Storage does not mean that we won't have processing at Pantex. ...That, too, can be the scenario under storage. But to have storage set all by itself is inaccurate and it just won't do.

Response:

The scope of this EIS includes interim storage of pits. The Stockpile Stewardship and Management and the Storage and Disposition PEISs evaluate long-term stockpile management and long-term storage and the final disposition of plutonium, respectively.

RC: 21.007

Doc: MG-002/2

The EIS must take into account cumulative impacts on Clark County that may result from the selection of the Nevada Test Site (NTS) as a storage or disposal site for a number of DOE activities. Given the approach taken in the DEIS that identifies only impacts from this one activity, it is not possible to reliably estimate the impacts to a geographic area of jurisdiction that may result from a number of initiatives taken by DOE. That is, even though other related NEPA studies for storage or disposal of nuclear materials. Based upon the fact that the NTS is mentioned prominently in a number of ongoing DOE EISs, this latter situation is a distinct possibility.

Response:

DOE recognizes the concerns as related to geographic cumulative impacts at the Nevada Test Site (NTS). The NTS EIS covers more specific issues concerning the cumulative impacts at this site; cumulative impacts from related NEPA studies at NTS are within the scope of the NTS EIS. For the Pantex EIS purposes, NTS was looked at in the context of interim storage, which had resulted in no significant impacts to the environment, in both its natural and physical aspects.

RC: 21.008

Doc: CO-008/135

... Page 3-4. Would the six referenced upgrades require new, or additional, environmental documentation if the Proposed Action is implemented?

Response:

There would be no additional environmental documentation for those six proposed projects. Page 3-3 of the EIS states, "Specifically, the Proposed Action includes...Performing all required facility upgrades, modifications, and replacement of facilities, and new proposed projects that are foreseeable at Pantex Plant, as described below." The section then goes on to discuss each of the six proposed projects.

RC: 21.009

Doc: SG-010/2

In reference to the detailed analysis of potential environmental effects at the two sites under consideration for pit storage at the Nevada Test Site (the Device Assembly Facility [DAF] and the P-Tunnel Complex), we concur that pit storage at either of these sites would not have any direct "significant" environmental impacts on existing environmental resources. We note that new construction at the Test Site would occur within existing facilities [inside the DAF or P-Tunnel complex] and/or on adjacent lands that are already disturbed. Because of this, we have purposely forgone a detailed review of the "direct" environmental impacts presented in the DEIS. There are, however, certain "indirect" and largely cumulative impacts that could result from pit storage at the Nevada Test Site. For example, if plutonium pits were placed in the P-Tunnel complex, local and/or regional earthquakes could pose significant seismic risks that might lead to tunnel collapse. In this regard, we concur that, if Nevada is selected for pit storage, a separate assessment of the risks associated with seismic events would be required.

Response:

If the P-Tunnel complex were to become the preferred option under the Relocation for Pit Storage alternative, DOE would consider performing a risk assessment for the facility.

RC: 21.010

Doc: CO-008/134

The combined cumulative impacts resulting from adding the bounding alternatives in the other three PEIS documents to the Pantex EIS do not fully address all the combined effects. Give the combined cumulative impacts of all four documents in each individual category of the document.

Response:

Each alternative relating to the PEISs and the Pantex EIS has been addressed individually. Due to the fact that there will be four RODs, the readers are given the opportunity to review the cumulative impacts at each site and for the proposed/alternative activities. In volume I of this EIS, section 4.21 and chapter 5 discuss both the environmental and cumulative impacts as related to each candidate site. For further information relating to other sites listed as alternatives, please refer to the other PEISs.

3.22 Department of Energy Policy

RC: 22.001

Doc: HT11/25

How many pits are ready to be stored right now...that [need] to be decommissioned so that they can be stored somewhere? How many weapons are ready to be dismantled?

Response:

The actual number of weapons ready to be dismantled is classified information. The Pantex EIS evaluates, as an upper bound, the impacts associated with dismantlement of 2,000 weapons per year. There are no pits waiting to be stored.

RC: 22.002

Doc: HT01-02/1

I'm also concerned that we're focusing just on dragging out the life of the current weapons without taking positive steps toward replacing them. And it will be all too soon before the end of their design life is upon us. I think we've got a real question whether we are able to build nuclear weapons again and how.

Response:

Development of replacement nuclear weapons is not part of the Proposed Action or alternatives discussed in the Pantex EIS.

RC: 22.003

Doc: HT13/9

... One of the issues that a lot of us are concerned about when it comes to pits, wherever they are, is the availability of not only local and State inspection of these facilities but international inspection.

[There is] a lot of concern about pits both here and in Russia and in other places.... Folks want to know how they are handled to make sure they are not being misused, reused, put back in because these are, after all, supposed to be surplus pits that are not supposed to be for weapons anymore.

Response:

No specific program for International Atomic Energy Agency or other international surveillance and/or inspection has been established. DOE has implemented security measures to ensure pits would not be subject to misuse during storage and still be available for inspection.

RC: 22.004

Doc: HT13/10

Surplus pits. Pantex is a CERCLA site, but Sandia isn't yet. The question though is, how would international inspection be accommodated at the Manzano site, that is both at Presidential directive in terms of the nonproliferation policy, and it is also something the rest of us are interested in. ...I am interested in knowing how the access and accessibility of the site would be for international inspection.

Response:

To elaborate on the response given at the public hearing, DOE has not yet established procedures for international inspection of pits. However, at this time there is no reason to believe that any facilities would need modification to accommodate inspection. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) designation does not affect the potential for International Atomic Energy Agency inspection of pits.

RC: 22.005

Doc: HT13/11

So you don't know, among the five sites [that] you have shown, if there are advantages or disadvantages from an international inspection standpoint?

Response:

To elaborate on the response given at the public hearing, that issue was not a significant factor in selecting Pantex Plant as the preferred alternative for interim storage of plutonium pits. Neither would it have been a significant factor if any of the five alternate sites had been selected. However, the Department considers international inspection to be equally facilitated by all site alternatives. Technical and policy issues, such as those pertaining to nonproliferation, are part of the decision making process, but are not required to be part of the NEPA document as noted in 40 CFR 1501.2(b), 1501(b), and 1505.2. However, the environmental factors, together with the policy and technical factors will be available to the decision maker at the time of the decision; not just the environmental factors.

RC: 22.006

Doc: HT13/12

Just to be clear, the pits, for whatever interim period of time they are at whatever facility they are, need to be inspectable. That doesn't necessarily mean that somebody can come in and physically look at the pits. There are ways that pits can be inspected without physically being able to require to divulge the shapes and those kinds of things.

So as an affirmative statement, and one of the many flaws in this document, from my standpoint, is the fact that it doesn't evaluate that issue, does not set up at any and all for the possible sites inspection criteria as a serious flaw....

Response:

See response to comment 22.003. Additionally, the Department considers international inspection to be equally facilitated by all site alternatives. Technical and policy issues, such as those pertaining to nonproliferation, are part of the decision making process, but are not required to be part of the NEPA document as noted in 40 CFR 1501.2(b), 1501(b), and 1505.2. However, the environmental factors, together with the policy, technical, and cost factors will be available to the decision maker at the time of the decision, not just the environmental factors.

RC: 22.007

Doc: HT13/13

... I would also argue that the policy of the United States set by the President is that surplus materials...are supposed to be subject to international inspection.

Response:

Final determination has not been made on whether specific pits are surplus or part of the strategic reserve. The Pantex EIS addresses interim storage of pits without regard to their ultimate disposition. Further, the Department considers international inspection to be equally facilitated by all site alternatives. Technical and policy issues, such as those pertaining to nonproliferation, are part of the decision making process, but are not required to be part of the NEPA document as noted in 40 CFR 1501.2(b), 1501(b), and 1505.2. However, the environmental factors, together with the policy, technical, and cost factors will be available to the decision maker at the time of the decision; not just the environmental factors.

RC: 22.008

Doc: HT13/28

I have another question. Will there be any difference in the level of transparency in the plutonium pit disposition process if the plutonium pits are sitting on a DOD or DOE site in terms of international surveillance or in terms of the public being aware of what is happening with pits? Is there any difference in what the public will know?

The Department of Energy's secretary does have a policy of greater openness, which is not something I have heard from the Department of Defense and don't expect to hear it from the Department of Defense. I am wondering where there will be some difference should be pits be at Kirtland.

Response:

The Kirtland Air Force Bases Manzano Weapons Storage Area is under consideration as an alternative storage site within the Pantex EIS. If this alternative is selected it will become a DOE facility and will be operated accordingly; thus there would be no difference with respect to surveillance, openness, or public awareness.

RC: 22.009

Doc: HT13/35

I guess the problem with the Department manager doing the risk [analysis] is that nobody trusts the Department of Energy. I think that if you had somebody independent doing the risk analysis, then it would be more palatable.

Response:

40 CFR 1502.24 requires agencies to ensure integrity of analysis in an EIS.

RC: 22.010

Doc: HT13/36

I appreciate all your efforts, but there is just such a long history of deception here that it is hard to overcome and believe and trust data that comes out of the Department, and I am sorry that is true.

Response:

The preparers of the Pantex EIS have devoted considerable effort to ensure the accuracy of data used. These efforts are intended to result in a credible document that can withstand scientific and legal scrutiny. See discussion in section 1.3.14 of this volume for a summary of actions the Department has taken to improve public trust during the preparation of its EIS.

RC: 22.011

Doc: HT12/10

... Right,...but everything seems to deal with policy. I mean, if we had some type of impact on the policy making from the beginning [because] it seems as if now [you] are backtracking and want some type of input from the community.... [You make decisions] behind our backs all the time and now you expect us to think [you are] not going to continue to do this behind our backs.... I'm sort of stuck on, why is it like that.

Response:

The Department is bound by the NEPA and the implementing Council of Environmental Quality regulations to not only allow, but actively seek, comments from Federal, State, and local agencies; Native Americans; citizens; and interested organizations. These efforts may appear convoluted and frequently result in many comments ranging from intense support for, to intense opposition to, a proposed action. See response to comment 22.005 for a summary of the actions the Department has taken to comply with NEPA and Council on Environmental Quality requirements.

RC: 22.012

Doc: HT12/11

... That's my concern as well. ...What's our input, how do we know this is going to count. You already did what you wanted to do without asking for permission, [and] you're going to continue doing that. ...This part is just [really] a bunch of bull crap, we're just here.

So how we know what's going to be the outcome and [what] is the true outcome. If we say right now we don't want...to deal with this anymore, is it going to take place, are you going to ship it somewhere else, [is it] going to happen where we don't want it to happen. Or it's already voted where it's going to go.

Response:

DOE disagrees that it ignores input from agencies, other organizations, or individuals. Each comment on the Pantex EIS receives careful analysis whether presented in person, in writing, or via another mechanism. Analysis of comments does not always warrant taking the action recommended in a particular comment. The DOE decision maker does see and consider the comment along with other environmental, technical, policy, and national security issues and factors as part of the decision making process.

RC: 22.013

Doc: CO-003/2

Appropriate local and regional public information and involvement programs must be conducted by the agencies to ensure that the public is fully informed of the risks, hazards, and impacts of such a program. This would be part of the national dialogue on all nuclear materials (noted above) prior to assignment of nuclear materials to a specific site.

Response:

By establishing the Storage and Disposition PEIS, Stockpile Stewardship and Management PEIS, and the Pantex EIS, consistent with Council on Environmental Quality regulations, developing reasonable alternatives subject to public comment, DOE does have confidence that a "national dialogue" has been reasonably established. DOE, with direction of the Office of the President, has attempted to raise the level of public awareness. Included in this national dialogue is an exchange of information as needed with State governors. DOE is proud to recognize the vast network of concerned, interested, and committed stakeholders throughout this nation.

DOE recognizes that all its facilities and hazardous materials, including plutonium, require varying levels of operational and environmental controls to protect workers, the general public, and the environment. DOE has worked with EPA, States, employees, unions, stakeholders, and the general public to develop programs and commitments to better manage its facilities and hazardous materials, including wastes. All of these plans and commitments (e.g., Tri-Party Agreement) have been reviewed 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 for interim pit storage. Nothing was found that would inhibit the alternative sites from performing the required missions, to include site cleanup.

RC: 22.014

Doc: CO-009/1

At this juncture in the proposed and appropriate downsizing of the nuclear complex, we again strongly encourage the Department and Administration to predicate all actions related to the nuclear complex on the conservative assumption that at least rogue-state or terroristic nuclear aggression against the United States is probable. U.S. vigilance and nuclear preparedness are key to coexistence with mad nations and persons. In turn, the Pantex Plant is, uniquely, a key to economically efficient continuing nuclear preparedness.

Response:

The President has declared that the maintenance of a safe and reliable nuclear weapons stockpile will remain a cornerstone of national security policy for the foreseeable future.

RC: 22.015

Doc: PC-024/1

Page S-4, right column, "Assembly of Nuclear Weapons," 11th line. Remove the word "classified" since virtually all the components in the "physics package" are classified. Check the DOE book "Drawing Back the Curtain of Secrecy" "Restricted Data Declassification Decisions 1946 to the Present (RDD-3), January 1, 1996. [Your] description should also mention the D-T Tube neutron generators.

Response:

The word "classified" has been removed. Adding the phrase "D-T Tube neutron generators" is not necessary for the purpose of summarizing the description of the "physics package." Volume I, section 1.2.2, contains an expanded description of the "physics package."

RC: 22.016

Doc: PC-024/2

Throughout the EIS replace the word "staged" with the word "stored."

Response:

DOE believes that the EIS reasonably differentiates "staging" and "storage" activities as presented in volume 1, section 3.1.1.

RC: 22.017

Doc: HT16/31

... It would probably be helpful to know where there are places where the plant is self-regulating, where there isn't an external regulator with regulatory authority, as opposed to oversight.

Response:

Per Council on Environmental Quality regulations, volume I, chapter 6, Environmental Compliance Requirements for Implementing the Proposed Action and Alternatives, presents Federal and State statues, regulations, and orders applicable to each site evaluated in the EIS. The chapter identifies the responsible agencies. In addition, see response to comment 22.018.

RC: 22.018

Doc: HT16/33

TNRCC would be more willing to embrace the Pantex mission within the State of Texas if DOE would promote independent regulatory oversight of radioactive source, special material and by-product material. We applaud DOE's willingness to share its information concerning radioactive contaminants; however, it is our opinion that the public would be better served and potential waste management errors minimized if the oversight authority was shared with the TNRCC. Now, we're well aware ofthis might be a little too brutalof DOE's legal obstructionist attitude for the State picking up regulatory authority over radionuclides. We understand we do not have the authority. We also understand that EPA in their assertive program do have the authority. And we are working now with the EPA to pick up that authority, at least to piggyback on to it, not that we can assume it or they can give it to us, but we can certainly hold hands, in a sense, partner with the EPA in their assertive program while this NPL is decided, to get some oversight on radionuclides, not that we feel like it's a great issue. The issue is not that we feel there's a bunch of contamination out there. The issue is solely that...we think that DOE would do a better job with oversight. It's not an issue for Pantex necessarily. We feel that Pantex has done a pretty good job, far better than some of the other DOE sites. It's strictly our ability to do what we are asked to do by the citizens of Texas, which is to regulate and to watch and to concur or not to concur. We don't want to hurt DOE. We don't want to hurt Pantex. We just want to do our job. ...We're in the middle of an FFA negotiation right now. And this will be an issue that we're not going to drop.

Response:

The Secretary has created a Working Group on External Regulation. This group is presently reviewing various alternatives for external oversight of activities at DOEs nuclear facilities and will submit a report sometime in 1996.

RC: 22.019

Doc: HT17/23

The world at this point needs alternative forms of energy, especially solar equipment, and it needs it very badly. Eventually we're going to have to decide which direction to go, whether we are going to go with nuclear power, and that would eventually involve some considerable reprocessing of plutonium or whether we will go for other means of electrical generation. I would like to see the Pantex Plant take the lead in producing alternative methods of generating electricity and not trying to deal with plutonium, which is essentially a waste material of the cold war and the nuclear arms race.

Response:

Final disposition of weapon-usable plutonium is within the scope of the Storage and Disposition PEIS. One alternative for disposition is using excess plutonium as fuel for nuclear reactors which would generate electricity. Although alternate energy sources are not included in the Proposed Action for the Pantex EIS, research on alternate energy sources is performed at a number of DOE facilities. A variety of information on the Departments alternate energy programs may be obtained by accessing the Internet home pages for the Alternative Fuels Data Center, the Energy Efficiency and Renewable Energy Network (EREN), and the Energy Information Administration. Alternative energy initiatives are included in "Department of Energy 1977-1994: A Summary History."

RC: 22.020

Doc: PC-017/7

Will the DOE repair and/or replace or pay damages for all these damages? Will the DOE pay for the months of inconvenience and nerve wrecking experiences we have been through?

Response:

The Department has a procedure for consideration of damage claims. Please contact Mason & Hanger Corporation legal department to initiate a claim. Resolution of the claim will be dependent upon a determination of the cause, extent of damage, and current law regarding liability. See response to comment 8.002 which immediately preceded comment 22.020 in the commentors letter of June 25, 1996. Comment 8.002 expresses concerns about alleged damage from a high explosives detonation on October 4, 1995.

RC: 22.021

Doc: FG-003/15

The Pantex FEIS should also outline DOE's intentions regarding the retrieval of plutonium pits in such a situation, as well as the feasibility of monitoring the pit storage facility. The DEIS (Volume I, p. 5-17) gives the impression that the plutonium pits would remain entombed.

We ask that the FEIS provide further discussion regarding the wording on page 5-17 of volume I, that "Some mitigation of a tunnel collapse would be needed after a major seismic event. A separate assessment of the risk associated with the mitigation would be necessary..." The Pantex FEIS should better define what is meant by "some mitigation" and a "separate assessment" (would the separate assessment be a NEPA document?). The FEIS should discuss what risks would be analyzed in the separate assessment: radionuclide emissions, worker health and safety, ground water contamination, etc.

Response:

The Departments response would be determined after consideration of the circumstances that exist after the collapse and evaluation of the risks to the environment, the public, and workers involved in any recovery action.

RC: 22.022

Doc: SG-002/2

We applaud DOE's willingness to share its information concerning radioactive contaminants; however, the TNRCC permit does not include radionuclide parameters. And as we have stated before, the TNRCC recommends that the DOE share regulatory oversight with another Federal or State agency to minimize the potential for further injury to natural resources.

Response:

See response to comment 22.018.

RC: 22.023

Doc: PC-027/2

I don't understand the need to store 20,000 pits anywhere. If we are dismantling the nuclear weapons, then we should get rid of the pits, not store them. People who know about nuclear [material] should have the knowledge and imagination to come up with some use for the pits. Perhaps some nuclear function could use that material for some purpose. I can't see why we should need so many for "strategic reserve and surplus". What is the idea behind this storage, to snap them back into nuclear weapons should we decide to change the rules?

Response:

DOE agrees with the commentor that final disposition is preferred over long-term storage as identified in the Purpose and Need discussion of the Storage and Disposition of Weapons-Usable Fissile Materials Programmatic Environmental Impact Statement (S&D PEIS). However, DOE is required to meet CEQ regulations prior to implementing the S&D PEIS programs including final disposition. The S&D PEIS discusses and analyzes the strategy and technologies for long-term storage and the final disposition of surplus weapons-usable plutonium.

RC: 22.024

Doc: SG-003/19

We applaud DOE's willingness to share its information concerning radioactive contaminants; however, the TNRCC permit does not include radionuclide parameters. And as we have stated before, the TNRCC recommends that the DOE share regulatory oversight with another federal or state agency to minimize the potential for further injury to natural resources.

Response:

See response to comment 22.018.

RC: 22.025

Doc: SG-003/20

However, the DOE is one of the Federal Trustees for natural resources and has the responsibility of protecting those natural resources from further injury on behalf of the public. In order to protect those natural resources from further injury, the Trustees recommend that the DOE incorporate more stringent environmentally protective practices at the Pantex Superfund site.

Response:

The Pantex Plant continues to implement a Pollution Prevention/Waste Minimization (PP/WM) program to reduce environmental impacts through waste avoidance and waste minimization. Volume II, appendix G, contains detailed information of the PP/WM program. The program was recently awarded the Presidents Closing the Circle Award.

In addition to the plants continuing effort to reduce pollution and minimize waste, DOE has agreed to further study potential alternatives to open burning of energetic materials at the Pantex Plant Burning Ground. Pantex Plant maintains a Resource Conservation and Recovery Act (RCRA) Contingency-RCRA Spill Prevention, Control, and Countermeasures (SPCC) Plan to responsibly protect Pantex Plant employees, the public, and the environment. The SPCC Plan is incorporated into Pantex Plant RCRA Part B Hazardous Waste Permit (HW-50284), which is subject to EPA and TNRCC regulatory oversight.

As discussed in the EIS, EPA and TNRCC share the responsibility for RCRA and Comprehensive Environmental Response, Compensation, and Liability Act requirements including the establishment of restoration levels. Volume I, chapter 6, has been expanded to address the issue of Natural Resource Damage Assessments.

In addition, see responses to comments 22.018 and 22.026.

RC: 22.026

Doc: SG-003/22

Page 1-12, volume 1, section 1.2.2.3 Environmental Restoration. The information communicated in this text does not necessarily constitute restoration of the natural resources that have been injured as a result of the releases of hazardous substances at this site. In order to perform actual environmental restoration, the nature and extent of contamination must be determined to evaluate the potential injuries to natural resources. After such a determination, and in cooperation with the other Federal and State Trustees, restoration projects should be designed that will appropriately compensate the public for injury to natural resources. Performing remediation as needed to comply with all appropriate regulatory requirements does not necessarily constitute compensatory restoration for injury to natural resources. In order to reduce DOE's residual liability for injury to natural resources, the State and Federal Trustees encourage DOE to continue to work with the Trustees during the remedial process so that appropriate restoration will be incorporated into remedial activities. Page 3-3 Performing environmental protection and environmental restoration activities. Please see specific comment #1.

Response:

DOE continues to work with EPA, TNRCC, employees, unions, stakeholders, and the general public to develop the Pantex Plant Environmental Restoration Program and its commitments to better manage its facilities and restoration activities. DOE is continuing to work with the trustees. As we move toward a Federal Facility Agreement, consultation will increase. Volume I, chapter 6, has been expanded to address the issue of Natural Resource Damage Assessments.

RC: 22.027

Doc: SG-003/28

Page 4-37 Environmental Restoration Process at Pantex Plant. See comment #l.

Response:

See response to comment 22.026.

RC: 22.028

Doc: PC-025/5

Of interest [is] why stored plutonium at Pantex [is] not considered solid waste as defined in 40 CFR 261.2 (a)(l), (a)(2), (a)(2)i, (a)(2)ii, (a)(2)iii, (2)(b), (2)(b)1, (2)(b)2, (2)(b)3, (2)(c), (2)(c)(1), (2)(c)(2), 2(d), or 2(e). Why open burning of HE is not RCRA treatment? When does stored plutonium meet the definition of land disposed (stored) as a solid waste? Why not if "accumulated speculatively", "inherently waste-like", scrap, dispositioned, recycled, studied, or burned? What would be the environmental impacts if stored plutonium meets the definition of a solid waste? I consider this a reasonable impact.

Response:

In response to Item 1: The Atomic Energy Act (AEA) of 1954, as amended, regulates plutonium storage. Furthermore, 40 CFR 261.4 (a)(4), the Resource Conservation and Recovery Act (RCRA) specifically excludes AEA source, special nuclear, or by-product material from regulation as a "solid waste." Therefore, stored plutonium is not a "solid waste" as defined by RCRA.

In response to Item 2: See response to comment 22.029.

In response to Item 3: As identified in response to Item 1 above, plutonium does not meet the definition of a solid waste and, therefore, land disposal restrictions in 40 CFR 268 do not apply.

In response to Item 4: The environmental impacts of stored plutonium are analyzed and discussed in this EIS. The environmental impacts of stored plutonium are independent of statutory and regulatory framework.

RC: 22.029

Doc: PC-025/6

The sixth dash on Page 3-3. Why arent HE components regulated by RCRA before burning? If I burn an experimental battery that contains lead and explosives but is a proprietary secret of my company, is that RCRA treatment? Request consultation with EPA and the U.S. Justice Dept. on the response.

Response:

Weapon components, materials, or parts of a component that are not being reused cannot be declared waste until they have been demilitarized and sanitized (D&S) in accordance with the Atomic Energy Act, as amended. Once materials are declared waste, they are managed in accordance with applicable Federal and State regulations. The environmental impacts from D&S operations have been specifically incorporated into impacts addressed in volume I, section 4.7, Air Quality, and section 4.13, Waste Management. D&S operations at the Burning Ground were included in the site-wide air modeling analysis. Solid waste generated as a result of D&S weapon components activities are included in the waste volume projections for the three levels of weapon activities. To account for fluctuations, waste projections include a 10 percent margin. D&S operations are part of the proposed continued operation of Pantex Plant as identified in volume I, section 3.1.1, and, therefore, D&S operations are bounded by environmental impacts presented in the Pantex Plant EIS.

RC: 22.030

Doc: PC-025/66

... Volume I, section 4.13. Are pits a solid waste?

Response:

No, see response to comment 22.028.

RC: 22.031

Doc: PC-025/67

... Page 4-193. Is demilitarization and sanitization of weapons components RCRA [treated]? Are classified weapon components that cannot be demilitarized and sanitized [and] sent to NTS, a solid waste? What is meant by declassified versus demilitarized and sanitized?

Response:

In response to Item 1: See response to comment 22.029.

In response to Item 2: See response to comment 22.029.

In response to Item 3: For clarification purposes "declassified" has been changed to "demilitarized and sanitized."

3.23 National Environmental Policy Act Process/Procedures

RC: 23.001

Doc: HT02-08/1

Combining these three documents into a single opportunity for public input, together with the very short amount of time much of the material has been available, does justice neither to the NEPA process itself nor to the people and agencies that wish to make reasoned responses to these documents. At least in the case of the Stockpile Stewardship as well as the Storage and Disposition, the documents are substantive enough to require careful analysis. It is also an unavoidable conclusion that the hearing process envisioned by NEPA has been transformed by DOE into a format they feel they can more effectively controlthat being the workshops. There is nothing wrong with workshops per se, but they do not meet the government's full responsibility to the public. That any of us at all are standing here to give testimony is only the result of citizen lobbying and the willingness of individuals to face down any obstacles to get their concerns into the public record.

Response:

Each of the documents has a public comment period, inclusive of public hearings/meetings as required by NEPA. During this time the public is encouraged to comment verbally 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 necessary, depending on the geographical location of the meeting. This format also addressed feedback 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.

For the record, the workshop format used for the public hearing is, in fact, 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 two-day afternoon and evening sessions were planned by the Pantex Plant Citizens Advisory Boardnot DOE.

RC: 23.002

Doc: HT02-08/2

The Site-Wide EIS, an effort brought about by citizen lobbying of the Department of Energy, has not really been in the public domain long enough for a detailed consideration. Unfortunately, the substance of the document itself may require much less time than the gravity of the issues warrants.

Response:

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, a technical exchange meeting, or via electronic mail. Council on Environmental Quality regulations require a minimum comment period of 45 days. For this EIS, DOE extended the comment period to 98 days. Comments were accepted as late as July 29, 1996.

RC: 23.003

Doc: HT02-07/1

I came over today trying to have an open mind, but I realize that after listening to the City, the State, Federal elected officials, this is a done deal. The most we can hope for is a safe facility.

Response:

The NEPA process requires a thorough evaluation of the Proposed Action, including a variety of alternatives. The decision to accept an alternative is not made by city, county, or Federal elected officials at public meetings such as this. The EIS evaluates the environmental effects of Pantex Plant operations as well as the effects associated with interim storage of pits at alternate locations. The final decision will be made by the Secretary of Energy, based on the findings in the document as well as public input from all areas (private, elected officials, organizations, etc.).

RC: 23.004

Doc: HT11/9

You don't happen to have a web site where we can access more information?...

Response:

We do not have a web site; however, the DOE Home Page can be accessed through the internet. The DOE Universal Resource Locator (URL) address on the internet is http://www.doe.gov. A list that links to DOE program offices can be found at http://apollo.osti.gov/html/servers/hqtitls.html. A map with DOE sites can be found at http://www.doe.gov/html/DOE/infolink/usdoemap.html. Additionally, specific inquiries on this EIS can be accessed through the Internet via nfounds@doeal.gov.

RC: 23.005

Doc: HT11/10

You have an internet address? Is that classified?

Response:

See response to comment 23.004. It is not classified.

RC: 23.006

Doc: HT11/11

What I wonder is, if I have any other questions, is there an area I can tap in and find frequently asked questions?

Response:

This Comment Response Document is one source for answers to frequently asked questions, another is the internet (nfounds@doeal.gov) and phone calls to the DOE EIS office in charge of this document (505-845-4351) or the Office of NEPA Policy and Assistance (1-800-472-2756). While we do not post a listing of frequently asked questions per se, DOE will respond to any questions that any member of the public may have. See response to comment 23.004.

RC: 23.007

Doc: HT11/34

... We were surprised by this meeting...maybe there was public information or scheduling announcement that we missed. But...no matter whether it's Pantex or [it] has to do with the people that are doing NTS, EIS or any of the EISs where Nevada Test Site is involved, we would like to have a mechanism set up whereby Department of Energy representatives and representatives of local governments that may be affected like Clark County can meet so that we can have a briefing...[to] prepare ourselves for statements [that] in many cases might be statements of support, given that certain mitigation measures are taken or at least addressed.

Response:

On June 5, 1996 a video conference call was conducted between DOE officials, NTS officials, representatives from the State of Nevada Department of Transportation, the States Advisory Board, and representatives from Clark County, including the Nevada Department of Comprehensive Planning, Nuclear Waste Division, to discuss the EIS and transportation issues. DOE plans to continue interaction with the State and local agencies to solicit their views before decisions are made.

RC: 23.008

Doc: HT11/35

And at this point I'd like to request a meeting among the management of Clark County, probably the Director of Comprehensive Planning, County Manager, and so on and representatives of Pantex to give us more detailed information. And I would like to also to request in your institutional program that there be periodic updates with identified state holders or units of local government that are affected.

Response:

See response to comment 23.007.

RC: 23.009

Doc: HT11/37

... The other major concern is...the initial interaction and the ongoing mechanism for ongoing communication, that clear communication makes things a lot easier on both sides.

The person that you might address any correspondence to with regard to establishing a meeting with Clark County is Richard Holmes, H-O-L-M-E-S. He's the director of the Department of Comprehensive Planning for Clark County. His telephone number is area code 702, 455-5175.

Response:

We appreciate this point-of-contact for Clark County. See response to comment 23.007.

RC: 23.010

Doc: HT14/2

... Appropriate local and regional public information and involvement programs must be conducted by the agencies to ensure that the public is fully informed of the risks, hazards and impacts of such a program. This would be part of the national dialogue on all nuclear materials prior to assignment of any nuclear materials to a specific site.

Response:

This is an excerpt from Advice No. 46 of the Hanford Advisory Board regarding the Storage and Disposition of Excess Weapons Usable Plutonium and Special Nuclear Materials. The NEPA process ensures that the public is involved in all phases of this type of large scale proposed project. Public hearings and comment periods allow an avenue for personal interaction with the individuals involved with these projects prior to a final decision concerning the assignment of nuclear materials to a specific site.

RC: 23.011

Doc: HT02-01/2

Technical analyses will be available later. Cost analyses will be available later. We do not have access to the information necessary to render an informed opinion, and the Department tells us that is how it will be. For instance, DOE defends the absence of cost information by stating that NEPA does not require a Federal agency to supply cost analyses in a draft document. To that, I say "So what." Such information is necessary to the discussion and so must be made available.

The same applies to technical information. It is not possible that the Department has so little information that it can not give a clearer description of what the operations for dismantling pits and processing plutonium will involve. And no citizen should be satisfied with being put in the position of guessing.

Response:

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 on the record before any decision is made on a major Federal action. Costs are not required in order to assess environmental impacts. Volume I, chapter 4, of the EIS 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 a cost breakdown between the alternatives have not been developed for the Pantex EIS. It should be understood that Pantex Plant does not dismantle pits. Issues associated with dismantling pits and plutonium processing are not covered in this EIS. Long-term management of the nuclear stockpile is within the scope of the Stockpile Stewardship and Management PEIS, while long-term storage and the final disposition of plutonium is addressed in the Storage and Disposition of Weapons-Usable Fissile Materials PEIS.

RC: 23.012

Doc: HT02-01/3

The decisions which these documents address are too important for us to allow the Department to go forward in this manner. Whether it is the case that the Department has the missing information yet is not revealing it, or whether the information is not complete, in either instance these draft documents are fundamentally deficient. The public deserves better. The law expects better. And the future must be based on something better.

Response:

The law requires consideration of all available relevant information. The information examined in this EIS is available to the public in two technical libraries established in Tetra Tech offices in Albuquerque, New Mexico, and Amarillo, Texas. These libraries contain more than 2,800 documents assembled in the course of preparing this EIS. The Pantex EIS provides a full and fair evaluation of all reasonable alternatives. Comments concerning the PEISs (Storage and Disposition, Stockpile Stewardship and Management, and Waste Management) are beyond the scope of this EIS; however, these concerns have been considered by the PEIS program staff and will be addressed in the PEIS comment response documents.

RC: 23.013

Doc: HT02-01/1

It was never the intention of our particular citizens' groups that you...not be able to respond. That's a misunderstanding that I hope we can clarify, and perhaps a rereading of the letters will serve to do that, letters that have been exchanged between the Department and four of the local citizens' groups.

Response:

The commentor is referring to the three DOE officials that were seated at the table with the meeting facilitator. These individuals participated as hearing officers, and as such, did not engage in dialogue or provide answers to the formal comments delivered by the 23 people that presented formal presentations. DOE officials did engage in dialogue during all the workshop sessions.

RC: 23.014

Doc: HT01-04/1

I have to admit that stacking EIS on EIS on EIS has gotten a little bit confusing, at least for me and my staff.

Response:

The review periods for these documents were scheduled to overlap because of similarities and scheduling issues. The Department realizes the difficulty to the public to review these EISs at the same time and greatly appreciates the effort. We will take this under advisement for future projects.

RC: 23.015

Doc: HT07/4

... I think that because the CEQ guidelines say that you are to identify what the significant impacts are, that if there are no significant impacts, you should state that in the EIS.

Response:

See section 1.3.15 in this volume for a discussion of significant impacts.

RC: 23.016

Doc: HT05/9

With the first reconfiguration EIS proposal six or seven years ago, there was one EIS [that] covered the reconfiguration of the nuclear weapons complex. I'd like to know what the Department's rationale is for dividing among a number of EISs what essentially is one overall decision, which is what to do with the nuclear weapons complex as a whole.

Obviously, your site-wide EIS is a part only of the decision about what to do with pits now and in the future. Why is it that the Department has elected to split up the EIS process and to do fragmented segments?

Response:

The Reconfiguration Study, published in January 1991, envisioned several major initiatives, the principal ones being relocation of the plutonium manufacturing operations at Rocky Flats Plant to a new facility at another site, consolidation of nonnuclear operations, and either downsizing and modernizing other nuclear and research and development facilities in place or pursuing maximum feasible consolidation (DOE 1991a). However, the specific concepts then envisioned were rendered inappropriate by major changes in world events, particularly, the collapse of the Soviet Union. In Response, the Department restructured the reconfiguration concept into several separate but related program decisions that could be clearly defined and examined in detail. The Department also found that it was too difficult to examine all the programs in one PEIS. Thus, the Department restructured the reconfiguration concept into programs for nonnuclear consolidation, tritium supply and recycling, and stockpile stewardship and management. Decisions on the first two have been made (following NEPA analysis) and the third is scheduled to be made in the fall of 1996. In addition, a PEIS was developed to address a new issuehow to provide long-term storage and disposition of surplus nuclear materials resulting from weapons dismantlement. The decision on that program is also scheduled to be made in the fall of 1996.

RC: 23.017

Doc: HT05/10

But I'd like my comment to go to the fact that what you have really done is made it impossible for the public to comment upon the overall program. You have no real programmatic environmental impact statement about which the public is instructed, educated and about which they can comment. And I seriously question whether the law really has been complied with.

Response:

As stated in the response to comment 23.016, the Department found that preparing one PEIS on the entire nuclear weapons program would have been so large and complicated that it would have been too difficult for anyone to digest.

RC: 23.018

Doc: HT02-15/1

I'll reiterate what some other people have already told you, that trying to deal with three documents, actually in less than 30 days that people have had all three of them together to compare, is clearly not an adequate amount of time. And one must conclude [that] either the Department of Energy is in a very big hurry and therefore they won't give an adequate [amount of] time for public comment, or that they don't understand the difficulty of dealing with three documents like this.

Response:

See response to comment 23.001.

RC: 23.019

Doc: HT02-15/2

... A number of people had expected that this format would also include time for DOE officials to respond on the record, and I continue to believe that that should be the case.

Response:

The "format" referred to is the presentation of formal comments at the Pantex public hearings in Amarillo, Texas. Individuals were given a 5-minute window to present a formal comment for the record, in front of DOE representatives. This was not meant to be a discussion session. The public was encouraged to discuss concerns with DOE representatives during the general (workshop) sessions as well as the individual EIS breakout sessions that were being conducted during the public hearings. We appreciate your input, and will consider your suggestions for future sessions. See response to comment 23.013.

RC: 23.020

Doc: HT02-21/1

Everyone who works at Pantex is there by their own choice. Why, now, should the opinions of such a small group receive so much focus?

Response:

DOE places equal importance on every individuals opinion, and upholds each individuals, agencys, or organizations right to be heard. As outlined by NEPA, the public comment period and the public hearings are held to facilitate this opportunity.

RC: 23.021

Doc: HT06/1

The first question is for all of the DOE and DOE contractor folks in the room, how many of them have completely read all three of the EISs? I see three, four, five, six, seven, eight hands, I think.

The point I would make is these folks, out of all the DOE and contractor folks in the room, these folks have had a lot longer to look at all three of these documents than the public [has had], and so you're putting the public in a very difficult position in terms of dealing with all these documents.

Response:

The draft EISs that are referred to in this comment were released for review by DOE and the contractors at the same time that they were released to the public. The review time for these documents is brief for the circumstances, but it is in accordance with that required by law.

RC:23.022

Doc: HT02-09/1

Many issues come into play in this very over-arching discussion. Not the least among them [is] the cost to us, the taxpayer, to produce these documents and to find them flawed in many ways. These documents are lacking important information in many areas that make it virtually impossible to even begin the discussion.

Response:

The draft phase of an EIS is designed to be a period when perceived shortcomings in the document are identified for resolution or further analysis. Public hearings and an accessible comment period provide an opportunity for individuals, agencies, and organizations to point out items that are unclear or situations and alternatives that may not have been addressed to the satisfaction of the commentor. A period of time exists between the draft and the final production of the document to address, and/or correct, these perceived shortcomings.

RC: 23.023

Doc: HT02-04/1

Are all of the important damage reports in the public domain, or are many vital documents concerning soil, air and groundwater contamination still being suppressed?

Response:

The Department provides to the public, upon request, any information that may be released under law. The law does exclude certain information relative to weapons design characteristics, for example, or that is exempt from disclosure by the Freedom of Information Act. Vital documentation has not been suppressed by the government; however, specific technical weapons information is not available to the public for security reasons.

Technical reports are located in the public reading rooms in Washington DC, Las Vegas, NV, Albuquerque, NM, Los Alamos, NM, Aiken, SC, Oak Ridge, TN, Amarillo, TX, Panhandle, TX, and Richland, WA. Inquiries concerning additional material concerning Pantex Plant can be directed to the DOE Albuquerque or Amarillo Area offices. Some environmental information is of a sensitive nature because of its relationship with certain projects, facilities, or missions. These reports are being studied and the information contained within them will be resolved after it is studied.

RC: 23.024

Doc: HT13/14

Just to clarify, I think it is legitimate to have varying selection criteria that go into less detail, but part of what an Environmental Impact Statement is required to do by law is to also evaluate the environmental impacts. So you could use potentially certain criteria to select the sites, but once you have selected them, whether it is Manzano, Nevada, Pantex, et cetera, you need to look at the environmental consequences.

Part of the consequences, both environmental because inspection is going to be important from not only an international, but frankly from a national confidential standpoint, is the availability and the accessibility and how inspection could work.

On the face of it, it seems to me, knowing something about all the five sites [that] you are looking at, that there are differing ways, at some sites, it would be easier to have international inspection, and some would be more difficult, and I think that should be analyzed.

Response:

The Department considers international inspection to be equally facilitated by all site alternatives.

RC: 23.025

Doc: HT13/34

I would suggest that [the] cumulative impact part of your Environmental Impact Statement should also include a cumulative psychological impact of all these projects on the people of New Mexico and how much people here are going to take before there is some kind of rebellion involved. We already know that cancer rates at Los Alamos, breast cancer rates, are 20 to 50 percent higher. We know that the child death rate there is higher than anywhere else in the state. We know a lot of bad things about Los Alamos.

We are looking at the rest of our state and wondering if the rest of our state is going to go that way, too, so I would suggest a psychological impact also be part of the cumulative effect of projects in an area.

Response:

Court precedents state that psychological impacts are not required for a valid NEPA analysis. The U.S. Supreme Court, in Metropolitan Edison Co., v. People Against Nuclear Energy (460 US 766 {1983}), held that psychological effects need not be considered in a NEPA evaluation. People Against Nuclear Energy, an organization of residents living in the area, claimed the commission should consider the severe psychological stress caused to its members by the nuclear reactor restart, especially in view of the failure of another reactor on the same site. While the Court did recognize that "human health may include psychological health," and conceded that risk to human health, including psychological health, came under NEPA, the Court believed that the psychological effects claimed raised policy questions that fell outside NEPA and that analysis of the psychological risks of the nuclear reactor restart were not required.

RC: 23.026

Doc: HT13/38

Well, I also feel that if Kirtland becomes your number one choice, that it is your obligation to hold a hearing here, not to just do this.

Response:

The hearing in Albuquerque fully complies with the letter and spirit of NEPA. Repetitive hearings on this same issue are at this time, considered neither necessary nor a prudent use of the publics time and taxpayers dollars. Should a new, and previously, unaddressed alternative or significant environmental impact be discovered, the Department would consider additional public meetings.

RC: 23.027

Doc: HT13/88

I just wanted to clarify the high explosive building with insufficient buffer. I used as an example what I would ask that this site-wide do, which is provide to people [with] an accurate description of the state of the plant, a Pantex Plant site-wide EIS.... I would like this document to contain an appendix or something that gives us an update on the status of the SARs at the plant, the facilities, and the status of whether or not they are in compliance with whatever DOE orders or whatever applies that DOE establishes to make these facilities meet whatever standards they have decided upon.

That is what I would like the site-wide to do. It is not to criticize the plant because in 1977, three people were killed, but it is telling that in 1996, you have a building that still has a similar problem, that people can get too close to it, so I would just like for this document to be complete enough that people can read the site-wide EIS and get an understanding of the plant and where it is going, mitigation, whatever is needed, and it goes forward from there. That is my question.

Response:

The Department has established policies to continually emphasize safety and encourage prompt resolution of any problems discovered. The cited incident is discussed in the response to comment 14.040.

RC: 23.028

Doc: HT12/1

First of all,...if I suggested it, I didn't mean to, that cost should drive the decision, but I think NEPA itself mandates that they [costs] be considered. If you've got two that are close together in environmental protection, you better know what they cost and maybeyou mentioned proliferation, which is the reason for all of this exercise. Timing, timing is not mentioned here.... It could have an impact on the decision and the costs.

Response:

See response to comment 23.011.

RC: 23.029

Doc: HT12/12

May I ask a policy question? By what process do you waive [weigh] strategic concerns against potential negative impact to local populations? I was just wondering [if there] was any particular formula, equation, process?

Response:

The Record of Decision represents a judgment weighing all relevant factors in the decision. There is no mathematical formula.

RC: 23.030

Doc: HT12/13

But are you...working with any type of independent entity that's not in total opposition to DOE but, just in case you did a case study, let's say for instance, cancer. And...are you...bringing in outside resources to say well, this is not what...we're finding.

Well...that's where the problem may be at, because you...hired them.... We're raising some very serious questions then. [You] should be able to fund us with money for us to be able to go out and find [our] own independent study, own independent researchers, the individual that will research our problem for us. And then [together] we could sit at a round table and...come up with an answer....

But...for [you] to appoint us someone or say, well, I [have] this person here [and] you can call him and he'll help you out. [But]...that's not going to work because that's no different than [you] sending out doing the independent research yourself.

Response:

The Department does fund outside research when deemed appropriate to investigate matters about which in-house information is insufficient for decision-making. The commentor is referred to EPAs Office of Environmental Justice. This office provides grants to organizations specifically to study environmental justice issues. This EPA money would be completely independent of DOE and would directly address the commentors issue. The last EPA notice of availability for funding was announced in the Federal Register on Thursday, June 13, 1996 (61 FR 30063), "Notice of Availability of FY 1996 Multimedia Environmental Justice Through Pollution Prevention Grant Funds." For further information, the commentor should contact EPA at (202) 260-4109.

RC: 23.031

Doc: HT12/14

... A more narrow question is, is there a way to challenge the ROD, not to necessarily change it although it may get changed in your process, but his specific question is, what is the procedure to challenge a ROD if you feel that that decision is against your community.

Response:

Public comments, as outlined in 40 CFR 1503, are actively encouraged by DOE. All comments received during review of the draft document have been published and responded to in this volume of the EIS. These comments must be addressed in an EIS as outlined in 40 CFR 1503.4. The public may appeal a decision under 40 CFR 1506.10 and make their views known even after the publication of the final EIS. If a substantial opportunity exists to alter the decision, the decision can be made and recorded at the same time that the EIS is published. This gives a 30-day parallel period when the EIS is under both appeal and review. "No action shall be taken until the decision has been made public" (10 CFR 1021.315) as required by the recently revised DOE NEPA Implementing Procedures, published in the Federal Register on Tuesday, July 9, 1996 (61 FR 36222). The decision can be made public by means such as a press release or announcement in the local media.

RC: 23.032

Doc: HT12/23

... On your evaluation list, I had a question about why you didn't discuss things in detail and why you did. For instance, the facilities in infrastructure at SRS are excellent,...but it says it's not discussed in detail.

Response:

Council on Environmental Quality regulations proscribe that NEPA documents avoid unnecessary detail. In the instance cited, there was no need for further detail.

RC: 23.033

Doc: HT12/28

What I'm hearing Rick say to you is that he's reading another DOE document that's not badly out of date and it's different than what [your] EIS is saying and what you're telling us here. And in order to go forward from here you need to take that document and...make a review against your EIS, correct and modify as necessary. Isn't that what you're saying, Rick?

Response:

This EIS contains the most current information available.

RC: 23.034

Doc: HT12/32

It is the conservatism that you put in the bounding accidents[they] are way too conservative. They need to have some credibility even though they are bounding accidents. You can't just assume, like the safety analysis does, everything is the worse, NEPA doesn't allow that. NEPA says that you will develop reasonable but bounding accidents and I concluded from reading it before Bob raised the question here earlier in the day that the accidents were not reasonable. They were bounding, certainly. ...I could have said that the guys consume...or inhale the pit and, therefore, that's bounding, but that's certainly [not] the intent of a NEPA process.

Response:

The accidents analyzed are both bounding and the most credible of accidents that safety specialists can conceive for the circumstances that exist.

RC: 23.035

Doc: CO-003/4

Equity impacts must be addressed in the assignment of new nuclear materials (including plutonium) to Hanford.

Response:

Equity along with environmental impacts, mission requirements, costs, and technical factors will be considered in the Record of Decision.

RC: 23.036

Doc: CO-009/3

(However, we do request that the Department include in the record "dockets" for these EISs the comments by SPS relative to listed potential environmental concerns recited in the draft Tritium Production-related EIS of 1995. In those comments, SPS rebutted the overly sensitive, generally not really site-specific but knee-jerk and ill-informed, and frequently inaccurate characterizations of environmental "concerns" about expanded missions at Pantex. Clearly, those earlier characterizations of possibly "adverse" impacts, especially those related to uses of groundwater, now are rejected by DOE. Nonetheless, a replete record supportive of the Department's April 23, 1996, publicly articulated conclusion that NO significant adverse impacts would result, is appropriate.)

Response:

Each NEPA document prepared by the Department contains the most accurate information available at the time the document is produced.

RC: 23.037

Doc: CO-009/4

We requestwe are tempted to demandthat fair and open cost comparisons among the alternative sites for each function be used in analyzing sites, and that such accountings be shared with the public that [has] demonstrated interest in the nuclear complex.

Response:

See response to comment 23.011.

RC: 23.038

Doc: PC-023/1

First of all, I appreciate that this report has addressed many concerns expressed by citizens groups with regard to previous reports. The writers and compilers of the report should be complimented on their efforts in this process.

Response:

Thank you for the compliment. The Department will pass it on to the responsible preparers.

RC: 23.039

Doc: PC-022/1

I would like to request [that] you hold public hearings in Albuquerque on the Pantex Storage of Nuclear Weapons Components, as our city is one of the possible sites.

Response:

The public hearing in Albuquerque was held on May 7, 1996.

RC: 23.040

Doc: HT15/24

We really are interested, as the State is as well, in seeing that the evaluations are good science, good process and all those things, because I don't think any of us are interested in having the numbers be unreasonable for any reason or uninformed for any reason. So that is a problem for us. We do like the idea of being able to read the document and understand thoroughly from what is in the document, that we do think it's clear; there are not terms that are used that are not explained.

Response:

Thank you for the comment. That is always our objective and intent.

RC: 23.041

Doc: HT16/39

... None of the documentation related to the pit reuse facility is available to the public in Albuquerque, which is where I live, because the DOE reading room has none of these documents available to the public.

Response:

The specific documentation requested contains data that cannot be released to the public.

RC: 23.042

Doc: HT17/15

... There is an environmental justice section;... there probably ought to be an economic justice section, also, because I think those at risk populations would feel the effect of an economic slow down, while at the same time those agencies that help them would really suffer in terms of available funds. And that's more of a blanket statement and I don't know if that really falls under what your tasked to do under NEPA, but I think it's a failing not only related to Amarillo, but to all the communities that [you] are looking at.

Response:

Economic impacts are addressed in volume I, sections 4.11, 5.2.1.9, 5.3.1.9, 5.4.1.9, and 5.5.1.9.

RC: 23.043

Doc:HT17/20

I only want to make two comments. And one is I guess to express frustration at being in the situation we're in so very often with Pantex and the Department of Energy in general of being asked to trust us; the documentation isn't complete, trust us; it's not ready yet, but it will be, trust us; we don't have the cost analysis yet, but it will come, trust us; it's classified, we can't tell you, but we assure you it's okay. And we find ourselves in this position time and time and time again.

Response:

This EIS has been prepared with the most current information available at the time of preparation. Many of the changes from the Draft EIS to the Final involve updating information that has become available recently. All references made in the EIS are available to the public, save those classified or otherwise restricted references. The use of restricted references has been kept to a minimum in this EIS.

RC: 23.044

Doc: HT17/52

I would like to know the legal connection, if any, of the information documents that you all have composed that go along with this site-wide [EIS]. There are three volumes that [you] have worked with, and I would like to know, when you sit down with a site-wide, do you really need to sit down with those three documents, too, to look at the whole thing? ...Legally, does this thing [EIS] have to stand by itself and are those merely reference documents and they haven't got the same stand-alone right?

Response:

The Final EIS is the only official NEPA document. The other documents mentioned are references used in preparing the EIS.

RC: 23.045

Doc: HT17/54

In your list of comments, scoping issues that were brought up in this document, [you] left off the nonproliferation concerns. And if you'll go back to your implementation, you will find out that in scoping, nonproliferation received more comments than human health, socioeconomics, transportation, air quality. It was very nearly at the top of the list.

Response:

Subsequent to scoping, the Department determined that there would be no changes to facilities necessitated by non-proliferation procedures. Therefore, there are no impacts to analyze.

RC: 23.046

Doc: HT17/58

We're forced here to comment on a very narrowly conceived document. We're in a [compromising] position, because we're forced to play on the Agency's ground, with no input into the design of a better draft EIS. Again, we're forced to be reactive, rather than to confront these issues up front in a collaborative, proactive manner.

Response:

A public scoping period was conducted in May and June 1994 to obtain public input into the scope and design of the EIS.

RC: 23.047

Doc: HT17/65

I think the document provides virtually no, none of the analysis that is necessary in terms of looking at the baseline operations of existing pit storage at Pantex. One of the things, one of the easy things that should be done...is taking your two and a half year old EA for pit storage of those pits and looking at what it said the impacts would be, [if] anything, other than the aircraft analysis, which seems to be the only thing you've even tried to look at, and saying, okay, over the last two and a half years what does the real data show up in terms of what's actually happened. What [if] those analyses were right, what [if they] were wrong, what [if they] were overly conservative, et cetera.

Response:

The 1994 Environmental Assessment for Interim Storage of Plutonium Components at Pantex was considered and utilized in the production of the Pantex EIS. Baseline operations were also considered by utilizing the information provided in the Pantex Plant Environmental Information Document (Pantex 1996), the Safety Information Document (Pantex 1996a), and the Programmatic Information Document (Pantex 1996b) that were created by the plant as resource material. See response to comments 23.012 and 23.053.

RC: 23.048

Doc: HT17/66

... I think it is both poor practice and, frankly,...hard to justify that in terms of looking at the baseline of existing impacts, the document provides no assessment of what the impacts of the operation have been to those nearby surrounding residents to the plant. There have been impacts, and they need to be analyzed. It's frankly disgusting that your only charting document of where these surrounding residences even are in the document are wrong, but there's much more wrong with the lack of analysis than that.

Response:

The Department believes that impacts have been properly assessed. The map in the Draft EIS did mislocate some residences. That has been corrected in the Final EIS. However, a check of the database shows that the grid coordinates of the residences in the air quality model are correct and that the effects described were correctly modeled and analyzed in the text.

RC: 23.049

Doc: PC-017/2

How can you determine the safety and purity of our agricultural activities and products if no thorough studies have been done?

Response:

The available information from past studies, along with the analyses performed in this EIS provide adequate assessment of potential impacts to agriculture and human health risks.

RC: 23.050

Doc: MG-002/1

We recognize that the DEIS follows the standard NEPA-mandated DOE format of identifying alternatives and then comparing and contrasting these alternatives by describing potential impacts on a number of environments. This standard format is well-recognized as a reliable and valid process to identify traditional impacts that may result from a major Federal activity such as that described in the DEIS. However, we feel that the approach falls short of addressing the concerns of those persons and institutions most affected by the proposed project, namely those located in proximity to the site of the proposed activity and those located along related transportation routes. Residents of Clark County and visitors to the area certainly fall within this definition and we would expect that their perceptions and concerns would be taken into account as the Pantex EIS is finalized and the record of decision is reached.

Response:

Volume I, chapter 4, addresses the affected environment and the potential environmental impacts in an 80-kilometer (50-mile) radius around the Pantex Plant. Section 4.11, Socioeconomic Resources, and section 4.16, Intersite Transportation, address the commentors specific concerns. Comments received in these areas have been considered and the final document has been updated where appropriate. All comments were considered in preparation of the Final EIS, which the Secretary considers in issuing the Record of Decision.

RC: 23.051

Doc: PC-025/1

In general, I do not understand how this EIS and its Proposed Action, No Action, and alternatives meets the intent of NEPA. Please explain how this 2,000, 1,000, and 500 level analysis meets the intent of NEPA. I believe the levels are not different enough to analyze, please comment. Plus don't the impacts at 2,000 cover 1,000 and 500 levels, please comment on this issue. Please explain why an EA or supplemental EIS aren't more appropriate. Please provide a technical response including regulatory citations detailing why this EIS meets the purpose of NEPA when the alternatives are so similar. Should the analysis look at one level of activity and then limit detailing the "what ifs" at higher and lower levels if necessary. This would possibly reduce the size of the document by 50 percent.

Response:

The Pantex EIS was prepared to support the Proposed Action of continued operations and interim storage of up to 20,000 plutonium pits at Pantex Plant in accordance with the guidance provided in NEPA (42 U.S.C. Section 4321 et seq.) and the implementing Council of Environmental Quality Regulations (40 CFR 1500-1508). An environmental assessment is not a viable option for the Proposed Action, since the Secretary of Energy made a commitment to the Governor of Texas at the completion of the Environmental Assessment of Interim Storage of Plutonium Components at Pantex Plant that the storage of plutonium pits would not exceed 12,000 pits prior to completion of additional analysis in an environmental impact statement (herein referred to as the Pantex EIS). The rationale for the 2,000, 1,000, 500 activity levels bounding the Proposed Action and alternatives is provided in volume I, section 2.2 of this EIS.

RC: 23.052

Doc: PC-025/2

On Page 1-14 in the second column in the last paragraph. If the decision will be based on cost, technology, national security, and infrastructure considerations, which documents covering cost, technology, and national security will be used? This implies the decision maker will use the information to make the decision without public comment. Does that meet the intent of NEPA? Will they be available to the public? Do the documents exist? When will these documents be completed?

Response:

The analysis for this EIS has been conducted in accordance with CEQ regulations (40 CFR 1500-1508). NEPA ensures that environmental issues associated with a decision are adequately addressed. Cost, technology, national security, and infrastructure considerations are other decision making factors that DOE anticipates relative to this Proposed Action. These documents are prepared as needed prior to the Record of Decision.

RC: 23.053

Doc: CO-005/3

Provide us [with] the data that proves DOE has not already contaminated our soil, air and water. Show us the documents where you have fully assessed the impact nuclear and high explosive activities have had and will have in the future on regional agriculture. Until agriculture is fully assessed, the impacts from the range of alternatives cannot be adequately scrutinized.

Response:

See response to comment 23.023. More than 1,000 documents on Pantex Plant were considered in preparing the EIS. These documents are available upon request from the Department. The Department has already provided baseline information in the form of three documents made available to the public. These documents are: (1) Programmatic Information Document (Pantex 1996b); (2) Environmental Information Document (Pantex 1996); and (3) Safety Information Document (Pantex 1996a).

3.24 Miscellaneous

RC: 24.001

Doc: HT02-22/1

... When we think of Pantex as people, 3,500 people, most of whom are very highly qualified, having a real appreciation for the quality of life for their families, here in Amarillo, we have excellent educational facilities from kindergarten all the way through to graduate level.

We have excellent cultural facilities, symphony, art, opera and so forth. We have excellent climate. We're just about the right size for people who want to really become an integral part of a good community to raise their families.

And of several different sessions that I have heard over the last few years, I don't recall having anybody express any concern about the fact that those 3,500 people who work at Pantex, whomever they may be, need to have a place to live and work in a place where they have a high quality of life.

And I think that is something that DOE needs to remember after they've considered all the technical aspects, all the hard, cold facts, that we've got to recognize that those 3,500 people have an excellent place in which to live and do their work and raise their families.

Response:

Thank you for your comment.

RC:24.002

Doc: HT13/74

... My comment...is that [the] safety analysis report [should] be made available as the previous safety analysis report for Zone 4 was made available to the public, and I specifically, Don Hancock, Southwest Research and Information Center here in Albuquerque, want to be [notified] when that safety analysis report is available.

Response:

The previous Zone 4 Safety Analysis Report (SAR) was released to the public in 1994 due to the fact that the Zone 4 Environmental Assessment cited this document heavily (DOE 1992f). As for future SARs, including the Zone 4, these documents are generally not available to the public due to the added cost in declassification. As for the EIS, this document relies heavily on the Programmatic Information Document (Pantex 1996b), the Environmental Information Document (Pantex 1996), and the Safety Information Document (Pantex 1996a).

RC: 24.003

Doc: HT17/48

Another piece, though, that really does trouble me is the lack of context that this document builds. Jerry Johnson, in his introductory remarks, did more to sort of put the context out when we first started this meeting this morning, when he talked about in 89 it was this, in 91 we were talking about expanding, and by the time we got to 93 we were doing thus and so. A few lines, and yet it put far more perspective about what the department had been through, the nuclear weapons program has been through, and what brought Pantex to where we are today. For instance, instead of saying Pantex used to do staging and now we do storage, I think it would not take many more words to say that Pantex [staged] plutonium components until 1989, when the Rocky Flats plant closed, and at that time it began to hold them, and then say when storage actually initially began.

Response:

The context is stated in the summary section of the Pantex EIS as recommended by CEQ 1502.12.

RC: 24.004

Doc: PC-025/88

... How many Information Document versions are there (i.e. 1995a, d, and h)? Why so many PCs? What does PC stand for? What does nd stand for? Is N441.1 correct?

Response:

There were numerous versions of the Information Documents (IDs). As the EIS was being produced, the most current ID was used; thus, the EIS lists different versions of the IDs. PC is an abbreviation for personal communication which was used as a reference; the abbreviation nd denotes no date. N441.1 stands for a DOE Order (N441.1) titled, "Radiological Protection for DOE Activities"; this Order is current as of March 1, 1996.

RC:24.005

Doc: PC-025/89

... Why only CDRs as source? Nothing better?

Response:

DOE procedures have tied NEPA into the project review and approval processes. As a result, money is generally not approved for detail design until certain stages are completed in the NEPA process.

How to Find a Comment Response in Chapter 3

The comment responses appearing in chapter 3 are categorized and organized according to their topic, or resource category. The sequencing of resource categories is as follows:

Alternatives (01)
Relationship to Other EISs (02)
Infrastructure (03)
Land Use (04)
Geology and Soils (05)
Water Resources (06)
Air Quality (07)
Acoustics (08)
Biotic Resources (09)
Cultural Resources (10)
Socioeconomic Resources (11)
Intrasite Transportation (12)
Waste Management (13)
Human Health (14)
Aircraft Accident (15)
Intersite Transportation (16)
Environmental Justice (17)
Irreversible and Irretrievable Commitment of Resources (18)
Unavoidable Adverse Environmental Impacts (19)
Relationship Between Short and Long Term Effects (20)
Cumulative Impacts (21)
DOE Policy (22)
NEPA Process and Procedures (23)
Miscellaneous (24)

The parenthetical number next to each of the above categories is the resource category identifier for that topic. For example, the resource category identifier for all comments in volume III relating to water resources is "06".

Table GP1 lists all of the resource code identifier numbers and all of the document numbers associated with each commentor. A commentor may go directly from the list of comment numbers to the Departments response to any of those comments. Comments and responses in chapter 3 are grouped by resource category and then by sequential comment number within the category. The combination of resource category and comment number is termed a "Resource Category" (RC) identifier. For example, the first comment in resource category "06" would be labeled "RC: 06.001". To facilitate ease of location, each comment (and its response) in chapter 3 is marked with its unique "RC" identifier in the left hand margin.

Table GP2 lists all comment numbers that appear in each comment document. To illustrate the use of Table GP2, suppose one had used Table GP1 to locate the letter written by Dana Porter. The Document Number shown in Table GP1 for Danas letter is "PC-023". Turning to Table GP2, one would then look for the entry "PC-023" under the left-hand column labeled "Document Number". That entry appears in the "Document Number" column on page GP17. For illustration, that portion of Table GP2 is shown below:

To the right of the document number entry are three more columns. The column labeled "Sequence Number" shows that in Dana Porters letter (PC-023) there are five comments (sequentially numbered 1 through 5). The column headed "Resource Category" shows that the first comment of Dana Porters letter is about resource category 23 (NEPA process and procedures), the second and third comments in that letter are about resource category 06 (water resources), the fourth comment is about resource category 08 (acoustics), and the fifth is about resource category 03 (infrastructure). The final column, labeled "Comment Number" tells the reader that Danas five comments are the 38th comment in resource category 23, the 46th and 47th comments in resource category 06, the first comment in resource category 08, and the sixth comment in resource category 03.

Continuing the example, suppose one wanted to see the responses to Danas two comments on water resources. One would note the resource category (06) and the comment numbers (046 and 047). Danas two comments on water resources would thus be marked as "RC: 06.046" and "RC: 06.047" in chapter 3.

To find these two comments and their responses, one would turn to the sixth section of chapter 3 (i.e., section 3.6) and scan through the Resource Categories in the left hand margin until finding "RC: 06.046", Danas first comment regarding water resources. At this point the reader will see Danas verbatim comment, along with the response to that comment. Immediately following that comment and its response is the entry for "RC: 06.047", which is Danas second comment about water resources.

Having found the entry "RC: 06.046", one will also find immediately under it an accompanying cross reference to the document number in which the comment originated. The marginal notations look like this:

RC: 06.046 Doc: PC-023/2

The marginal code labeled "Doc:" shows the document number and sequence number of this particular comment among all other comments that appear in that same document. In this example, the code "Doc: PC-023/2" means that this particular comment ("RC: 06.046") was the second comment in Document Number "PC-023". With this information, the reader may, if desiring to do so, go back to chapter 2 to view the source document and consider the context within which the comment was made.

When a person did not identify himself or herself, during the public meetings, an anonymous identification (such as unidentified speaker) was entered into the transcript. In addition, some of the postcards submitted had illegible signatures. Thus, for these two reasons, there are numerous comments attributed to an unidentified commentor.

In using this volume, note that resource category identifiers 03 through 21 also correspond to the sequence that those resource categories are analyzed within the affected environment and impacts analyses for Pantex Plant (in chapter 4 of volume I). In other words, a reader could know that since water resources has a resource category identifier of "06" and is located in the sixth section of chapter 3 (i.e, section 3.6) of volume III, that the main discussion of the Pantex Plant affected environment and impacts related to water resources can be found in the sixth section of chapter 4 in volume I (i.e, section 4.6). This correlation is intended to make it relatively easy for readers to use volumes I and III together in reviewing both the Final EIS text and the comments related to that text.

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Weapons of Mass Destruction (WMD)

CHAPTER 3 COMMENT RESPONSES

INTRODUCTION

ORGANIZATION OF THIS CHAPTER

COMMENTS AND RESPONSES

3.1 Alternatives

RC: 01.001

Doc: HT11/16

Response:

RC: 01.002

Doc: HT11/17

Response:

RC: 01.003

Doc: HT11/18

Response:

RC: 01.004

Doc: HT11/28

Response:

RC: 01.005

Doc: HT14/1

Response:

RC: 01.006

Doc: HT05/8

Response:

RC: 01.007

Doc: HT13/1

Response:

RC: 01.008

Doc: HT13/6

Response:

RC: 01.009

Doc: HT13/23

Response:

RC: 01.010

Doc: HT13/24

Response:

RC: 01.011

Doc: HT13/25

Response:

RC: 01.012

Doc: HT13/26

Response:

RC: 01.013

Doc: HT13/31

Response:

RC: 01.014

Doc: HT13/42

Response:

RC: 01.015

Doc: HT13/79

Response:

RC: 01.016

Doc: HT13/87

Response:

RC: 01.017

Doc: HT13/80

Response:

RC: 01.018

Doc: HT12/26

Response:

RC: 01.019

Doc: PC-006/1

Response:

RC: 01.020

Doc: PC-024/3

Response:

RC: 01.021

Doc: HT16/40

Response:

RC: 01.022

Doc: HT17/21

Response:

RC: 01.023

Doc: HT17/22

Response:

RC: 01.024

Doc: HT17/39

Response:

RC: 01.025

Doc: HT17/41