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Volume 4

CHAPTER 1: Public Comment Process

1.1 Introduction

In February 1996, the Department of Energy (DOE) published the Draft Programmatic Environmental Impact Statement (PEIS) for Stockpile Stewardship and Management , which described and analyzed alternative ways to implement the proposed actions for the Stockpile Stewardship and Management Program. DOE developed the Program to provide a single highly integrated technical program for maintaining the safety and reliability of the nuclear stockpile in the absence of underground nuclear testing. The 60-day public comment period for the Stockpile Stewardship and Management Draft PEIS began on March 8, 1996, and ended on May 7, 1996.

During the comment period, public hearings were held in Los Alamos, NM; Las Vegas, NV; Albuquerque, NM; Oak Ridge, TN; Kansas City, MO; Livermore, CA; Washington, DC; Amarillo, TX; Santa Fe, NM; and North Augusta, SC. Figure 1.1-1 shows the locations and dates of the hearings. Five of those public hearings were joint meetings to obtain comments on both the Stockpile Stewardship and Management Draft PEIS and the Storage and Disposition of Weapons-Usable Fissile Materials Draft Programmatic Environmental Impact Statement (Storage and Disposition Draft PEIS) (DOE/EIS-0229-D, February 1996). Two of the joint meetings (Pantex Plant [Pantex] in Amarillo, TX and Savannah River Site [SRS] in North Augusta, SC) also included the Draft Environmental Impact Statement for the Continued Operation of the Pantex Plant and Associated Storage of Nuclear Weapon Components (Pantex Site-Wide Draft EIS) (DOE/EIS-0225-D, March 1996). In addition, the public was encouraged to provide comments via mail, fax, electronic bulletin board (Internet), and telephone (toll-free 800-number).

Attendance at each hearing, together with the number of comment summaries recorded, is presented in table 1.1-1. Attendance numbers are based on the number of participants who completed and returned registration forms and may not include all of those present at the meetings. In addition to comments received at the public hearings, comments were also received during the public comment period through the other means described above.

All public hearing comment summaries were combined with comments received by other means during the public comment period. Comments received by mail, fax, Internet, or telephone were date stamped and assigned a sequential document number according to origin (e.g., fax or mail) of the document. Chapter 2 of this volume contains copies of the documents DOE received. Table 1.1-2 provides an overview of the number of documents and comments submitted by each method. The document number codes that were assigned to each document based on the method of submission are given in parentheses in table 1.1-2. For example, all documents that were handed in at public hearings have document numbers beginning with SSM-H.

Table 1.1-2.-- Document and Comment Submission Overview

1.2 Public Hearing Format

The public hearings used a modified traditional hearing format which allowed for two-way interaction between DOE and the public and encouraged informed public input and comments on the document. Neutral facilitators were present at the hearings to direct and clarify discussions and comments. Court reporters were also present to provide a verbatim transcript of the proceedings and record all formal comments that the public wished to present. The transcripts are available in DOE Public Reading Rooms near each site and in Washington, DC. These transcripts have been marked with sidebars to identify specific comments and how the comments were categorized into issue codes.

The format used for each hearing included a Program overview, interactive discussions, and a summary session. There was also an opportunity for formal comment provided for any attendee who wished to read a prepared statement of no more than 5 minutes. The Program overview session opened with a welcome from a site representative, followed by an overview of the Stockpile Stewardship and Management Program by a DOE representative. After clarifying questions, the facilitator opened the interactive general question and discussion period. A notetaker was present at each session to document and consolidate comments for the preparation of the Stockpile Stewardship and Management Final PEIS. Following the question and discussion period, a summary session was held to present the major comments and issues identified in each discussion group. An opportunity for additional comments or clarification was provided at this time. Modifications to the format were made at each public hearing location to best fulfill special needs or requests from the attendees. Following the public hearings, comment summaries were prepared by the notetakers (see chapter 2) with the verbatim transcripts being used as a reference.

1.3 Organization of this Comment Response Document

This Comment Response Document has been organized into the following sections:

• Chapter 1 describes the public comment process and contains tables to assist readers.
• 2 contains notetaker-generated summaries of the comments received at the public hearings and scanned copies of comment documents received during the public comment period.
• Chapter 3 contains comment summaries and DOE responses by category.
• Tables are provided at the end of this chapter to assist commentors and other readers in locating individual comments regarding the Stockpile Stewardship and Management Draft PEIS. Once comments were received, they were categorized by issue (e.g., land resources or water resources) and assigned a category code. Table 1.3-1 lists the issue categories and corresponding category codes. Similar comments within the same issue category were then summarized and assigned a summary code.
  Table 1.3-2 identifies the individuals who attended public hearings and the pages where the notetaker-generated comment summaries from those hearings appear. Commentors interested in locating their comment document and reviewing how it was coded can use tables 1.3-3 and 1.3-4. Table 1.3-3 consists of a list of members of the general public who submitted comments. Commentors are listed by last name, with their assigned document numbers and the pages on which their comment documents appear. Table 1.3-4 consists of a list of state and local officials and agencies, companies, organizations, and special interest groups that submitted comments. The commentors in table 1.3-4 are listed by organization in alphabetical order with the names of the particular individuals who submitted those documents. For each commentor, the assigned document number and the pages on which their comment documents appear are listed.
  In some instances multiple duplicate documents were received from a commentor. As a result of the multiple submissions, documents were deleted and gaps exist in the numerical sequence for tables 1.3-5 and 1.3-6. Some commentors submitted documents which were classified as letter writing or postcard campaigns. These campaigns were conducted by various organizations and special interest groups to express either support or opposition to aspects of the Stockpile Stewardship and Management Program. Although many postcards and duplicate documents were received, only one document scan of each type is included in chapter 2. The names of commentors who participated in most campaigns are included in tables 1.3-3 and 1.3-4. However, the names of commentors who participated in two very large campaigns, identified as campaign 4 (SSM-C-004) and campaign 5 (SSM-C-005), are not provided due to their volume. Lists of these commentors are available in DOE Public Reading Rooms near each site and in Washington, DC.
  Table 1.3-6 is organized by summary code. Using the appropriate summary code, commentors can locate all of the comments that are reflected in each summary. The table also lists the page on which the comment summary and corresponding response appear and the pages on which the actual comment documents appear. Some comment documents presented in chapter 2 consist of multiple pages. The document page number given in tables 1.3-2 through 1.3-5 refers to the first page on which the comment document appears. The document page number given in table 1.3-6 refers to the page on which the individual comment begins within a document.
  Scans of the documents received during the public comment period are shown in chapter 2. A document number code was assigned to each comment document based on the method of submission. Documents that were handed in at public hearings, mailed, or faxed have document numbers beginning with SSM-H, SSM-M, and SSM-F, respectively. Some documents were mailed in as part of letter writing or postcard campaigns and were given document numbers beginning with SSM-C. Comments that were received over the telephone were transcribed and given document numbers beginning with SSM-P. No comments were received through the electronic bulletin board. Comments from elected officials were given document numbers beginning with SSM-E. Documents from elected officials are not indicated separately in table 1.1-2, but are included in the total document counts based on the type of submission. Elected officials' comments that were transcribed at public hearings and were not submitted in another form were given document numbers beginning with SSM-ET.

  1.4 How to Use this Comment Response Document
  

  This section and figure 1.4-1 will assist the reader in tracking comment documents and determining how they were responded to. Begin by locating the appropriate name or organization in table 1.3-3 (Figure 1.4.1, Step 1)or 1.3-4. Table 1.3-3 consists of private individuals who submitted comments. Table 1.3-4 is a list of organizations and public officials who submitted comments. Both of these tables also list the document number that was assigned to each comment document (Figure 1.4.1, Step 2)and the page number on which that document appears in chapter 2. In order to see what issue codes were assigned to the comments identified within a document, locate the document number in table 1.3-5 (Figure 1.4.1, Step 3). Table 1.3-5 contains information on the number of comments identified in each document, the issue code assigned to each comment, and the page number for the corresponding summary and response (Figure 1.4.1, Step 4)that appears in chapter 3. In order to locate other comments in chapter 2 that address the same issues as a certain document, or to locate comments that address a certain issue code, use table 1.3-6. Table 1.3-6 lists the summary codes (Figure 1.4.1, Step 5), the page on which the corresponding summary and response appears in chapter 3, and the page numbers on which each comment that was assigned that issue code appears in chapter 2.
  For example, if Cynthia Johnson wanted to track her comments, she would go to table 1.3-3 to find her name, corresponding document number (SSM-M-030), and the corresponding page on which her document appears in chapter 2 (page 2-275). On page 2-275, Ms. Johnson would find that her scanned document has been sidebarred and coded for summary number 40.06. After obtaining the comment document number SSM-M-030, she could use table 1.3-5 to locate the number of comments identified (one), the issue code that her comment was assigned (40.06), the summary page number on which the corresponding summary and response is found in chapter 3 (page 3-93), and the document page number (page 2-275). After obtaining the issue code from either the scanned document on page 2-275 or table 1.3-5, Ms. Johnson could use table 1.3-6 to see how her comment was categorized (nuclear weapons policies), and to locate the page numbers on which other comments that express similar concerns appear in chapter 2. Using table 1.3-6, Ms. Johnson would find that similar concerns were expressed in 80 notetaker-generated comment summaries and comment documents appearing in chapter 2 on pages 2-9, 10, 11, 30, 33, 34, 37, 39, 40, 41, 42, 46, 48, 49, 52, 53, 54, 56, 57, 58, 59, 60, 61, 62, 63, 65, 66, 67, 83, 95, 131, 165, 222, 230, 231, 232, 234, 237, 239, 240, 253, 260, 261, 272, 273, 275, 281, 282, 288, 295, 310, 344, 345, 448, 449, 454, and 458.

  1.5 Changes from the Draft Programmatic Environmental Impact Statement
  

  In response to comments submitted after issuance of the Stockpile Stewardship and Management Draft PEIS, and due to additional technical details not available at the time of issuance of the Draft, Volumes I, II, and III of the Stockpile Stewardship and Management Final PEIS contain revisions and changes. The revisions and changes made since the issuance of the Draft PEIS are indicated by a double underline for minor word changes or by using a sidebar in the margin for paragraph or larger changes. In addition, Volume I and each appendix in Volume III provide a unique reference list to enable the reader to further review and research selected topics. These referenced documents and transcripts from the public hearings on the Draft PEIS may be reviewed or obtained for review in DOE Public Reading Rooms. A brief discussion of the more significant changes is provided in the following paragraphs.
  Alternatives Considered but Eliminated from Detailed Study and Related Issues. In response to public comments expressing a concern DOE had not analyzed a reasonable range of alternatives, section 3.1.2 of Volume I was expanded. The changes were in response to specific questions concerning compliance with treaties, stockpile size, maintenance and remanufacturing options, and the stockpile stewardship alternatives, including No Action. The discussions in section 3.1.2 provide greater detail and more clarification on why alternatives were eliminated from detailed study in the PEIS. Together, chapter 2 and section 3.1.2 of Volume I explain the framework and the constraints of national security policy that have shaped the proposed actions and reasonable alternatives for the PEIS.
  No Action Alternative. Several commentors did not think that the No Action alternative was clearly explained in the Draft PEIS. More specifically, they were not sure which existing facilities at Los Alamos National Laboratory (LANL), Lawrence Livermore National Laboratory (LLNL), Sandia National Laboratories (SNL), and the Nevada Test Site (NTS) were part of the ongoing stockpile stewardship program. As a result, the description of No Action was modified in Volume II, appendix A (Stockpile Stewardship and Management Facilities) to include a listing of major DOE Office for Defense Programs (DP) function facilities at LANL, LLNL, SNL, and NTS. Additionally, the discussion of impacts of No Action at LANL (Volume I, section 4.6.3) was revised as appropriate to include the effects of the Dual Axis Radiographic Hydrodynamic Test (DARHT) Facility.
  Socioeconomics at Oak Ridge Reservation, Kansas City Plant, and Pantex Plant. Based on public comments and revised workforce size estimates, the socioeconomic impact sections for the downsizing alternatives at Oak Ridge Reservation (ORR) (Volume I, section 4.2.3.8), Kansas City Plant (KCP) (Volume I, section 4.4.3.8) and Pantex (Volume I, section 4.5.3.8), have been revised. The analyses were also expanded to cover the "base case single-shift" options in greater detail. At these three sites, downsizing of existing facilities is the preferred alternative. For such downsizing, the "base case single-shift" scenario represents the bounding analysis for the workforce. The change in worker estimates did not cause any of the major indicators in the socioeconomic analysis to change in any significant manner.
  Accident Impacts at Pantex Plant. The analyses of impacts due to an aircraft impact and resulting release of plutonium by a fire or an explosion were modified to include more updated data on probability and source terms developed for the Pantex Site-Wide EIS. Volume I, section 4.5.3.9, and Volume II, appendix sections F.2.1.1 and F.2.1.2, were revised to incorporate the new analytical results. Based on the updated data, the potential impacts and risks to the public from the composite accident presented in the PEIS would be less than previously reported in the Draft PEIS. This change was not significant.
  Normal Operation Radiological/Chemical Impacts. The discussion of the normal operation radiological affected environment for LANL, Volume I, section 4.6.2.9, has been updated to include data from Environmental Surveillance at Los Alamos During 1993 (LA-12973-ENV, October 1995). The normal operation radiological impact sections 4.2.3.9, 4.3.3.9, and 4.6.3.9 in Volume I have also been revised to include the contribution of recent facilities at ORR, SRS, and the new environmental surveillance data for LANL. The chemical health effects sections in Volume I, 4.6.3.9 for LANL and 4.7.3.9 for LLNL, were revised based on new analyses using updated dispersion rates. Tables in Volume II, appendix section E.3.4, supporting these sections were also updated. The majority of these changes affected the No Action alternative analyses. None of the changes to these sections significantly changed the analysis of impacts for the "action" alternatives.
  Cumulative Impacts. Volume I, section 4.13, Cumulative Impacts, has been modified to incorporate a discussion of normal operation radiological impacts and other changes based on more recent data from National Environmental Policy Act documents and Record(s) of Decision. The changes to this section did not have a meaningful effect on the analysis/comparative evaluation of alternatives.
  Los Alamos National Laboratory Water Resources. Changes were incorporated in Volume I, section 4.6.2.4, Water Resources, for LANL based on more recent water use and water quality data. The Draft PEIS had erroneously stated that the LANL water allotment would be fully used by about the year 2000. The Final PEIS correctly reports that this allotment would be fully used by about the year 2052. This change did not have a meaningful effect on the analysis/comparative evaluation of alternatives. Minor revisions reflecting the baseline changes were also made to the LANL water resources impact discussion in Volume I, section 4.6.3.4.
  Health Effects Studies. Appendix section E.4 in Volume II outlining epidemiological studies at the alternative sites was rewritten to provide more detail and incorporate more recent and other applicable studies. Although these epidemiology sections do not affect the environmental analysis of future stockpile stewardship and management missions, they do provide relevant information regarding potential health effects from past actions. These changes did not have a meaningful effect on the analysis/comparative evaluation of alternatives.
  New Section. A new section has also been added to the Final PEIS (Volume II, appendix section F.4, Secondary Impacts of Accidents). This section evaluates the secondary impacts of accidents that affect elements of the environment other than humans (e.g., farmland). The section was added because of public The results of this analysis show that secondary impacts from accidents would generally not extend beyond site boundaries, except at Pantex and LLNL, where it is possible that some surface contamination could occur. This new analysis did not have a meaningful effect on the analysis/comparative evaluation of alternatives.