Weapons of Mass Destruction (WMD)

11.01

The commentor asks DOE to address a worst-case accident analysis for a "parking lot" nuclear weapons accident for Pantex and NTS, and asks how on a safety-to-the public basis DOE can justify operations at Pantex instead of at NTS. The commentor states that DOE is taking special mitigating actions at Pantex to keep site boundary dose under 100 rem per person in the event of an accident at Pantex. The same accident at the NTS Device Assembly Facility must be less than 1 percent of this, according to the commentor, since no one lives at the NTS site boundary. The commentor asks what the dose to the public is if there is an aircraft accident at Pantex, since that site is in the flight path of Amarillo airport and has a much greater risk of experiencing an accident than does NTS, which is in completely controlled airspace. Commentor asks how can DOE justify exposing the public to this additional risk in order to save money.

• Response: The accident analyses assume a hypothetical member of the public (the maximum exposed individual ) resides at the nearest site boundary. Based on the accident analysis for NTS and Pantex, the maximum exposed individual at Pantex would have a fatality risk of 5.6x10 -8 , while at NTS that risk would be 8.1x10 -9 . While it is true there is a lower risk at NTS than at Pantex, the risk at both sites is low. The potential for severe accidents including those involving an aircraft at Pantex, is provided in sections 4.5.3.9. Additional details on potential accidents are also given in appendix F and in a topical report: Supporting Documentation for the Accident Impacts Presented in the Stockpile Stewardship and Management Programmatic Environmental Impact Statement, (HNUS Report No. ARP-96-042) which has been placed in the DOE Public Reading Rooms near each site. The final selection of a site for the A/D mission will be announced in the ROD, which will take into account all relevant factors including accident risks.

11.02

The commentor asks why we use the year 2030 staff levels for radiation doses (section 4.3.2.9) and use 2005 for economic impacts.

• Response: The cumulative effects of both radiation and socioeconomics are calculated over a 25-year period from 2005 to 2030.

11.03

The commentor believes that DOE uses different risk standards for different programs (specifically Yucca Mountain versus other programs) and that the public does not understand the risks associated with DOE activities. The commentor voices concern over the 300 million curies (Ci) at NTS. The commentor urges DOE to use one risk standard in its analyses and educate the public about the risk numbers and what they mean.

• Response: To ensure a consistent set of risk standards in the preparation of environmental assessments (EAs) and EISs, DOE has established recommended guidelines for the preparation of human health impact sections in these documents (Recommendations for the Preparation of Environmental Assessments and Environmental Impact Statements, Office of NEPA Oversight, May 1993). The public and occupational health risk for normal radiological operations analyzed in the Stockpile Stewardship and Management PEIS uses the two dose-to-risk conversion factors for the public and workers recommended by DOE's Office of NEPA Oversight and established in the National Research Council's Committee on the Biological Effects of Ionizing Radiation Health Effects of Exposure to Low Levels of Ionizing Radiation BEIR V (BEIR V Report) published in 1990. These risk factors are 0.0005 deaths per person-rem to the general public and 0.0004 deaths per person-rem to workers (the lower number for workers accounts for the absence of children in the workforce).
  
  Appendix E, Human Health, presents a detailed discussion of the methodology used to determine the radiological impacts to human health. The appendix also includes a section on the development and use of the risk factors presented in the Stockpile Stewardship and Management PEIS.

11.04

The commentor believes that a 160-km (100-mi) radius would be more appropriate for the analysis of radiation health effects to the public.

• Response: The 80-km (50-mi) radius for calculating collective dose is a practical limitation for analytical purposes in this PEIS. NRC guidance requires that an 80-km (50-mi) radius be investigated for potential impacts to the population living within 80 km (50 mi) of a radiation source. Studies have shown that at some distance, frequently within 80 km (50 mi), the magnitude of variations in doses from background radiation becomes greater than the doses from radiological releases from DOE and NRC sites.

11.05

The commentor asks if the PEIS considers multigenerational problems in the analysis of cancer fatalities. The commentor also asks if the cancer statistics and studies from Chernobyl and Nagasaki are taken into consideration in the calculation of the PEIS cancer fatality numbers.

• Response: When modeling is performed to determine human health impacts, "nonfatal cancer" risks and "genetic (multigenerational) effects" risks are tabulated in appendix section E.2.1.2. Cancer statistics and studies from Nagasaki are included within the risk estimation parameters associated with presented cancer fatality numbers (refer to the BEIR V Report). The methodology outlining these "multigenerational effect" tabulations is presented in appendix section E.2.1.2 of the PEIS. The data available from the Chernobyl incident are still being analyzed and have not been used in the human health analyses investigated in this PEIS. However, national and international regulatory bodies continually review the results of new research in order to determine whether changes should be made to recommended dose limits.

11.06

Several commentors believe that DOE downplays the dangers of radiation and that the PEIS accident analysis tends to trivialize accidents. One commentor states that DOE should investigate the elevated levels of thyroid and breast cancer in Los Alamos, Bernalillo County, and surrounding towns. Another commentor disagrees, stating that cancer rates in Los Alamos are in line with cancer rates expected from a town at an elevation of 2,438 m (8,000 ft). Another commentor believes that DOE should initiate a series of health studies to determine the extent of contamination in the State of New Mexico. The commentor believes that these studies have not been carried out in the past because it would indicate public health problems.

• Response: The accident analyses were performed in accordance with DOE guidance (refer to the Office of NEPA Oversight document) . A set of accidents have been analyzed that include high-probability/low-consequence accidents as well as low-probability/high-consequence accidents that are not expected to occur during the lifetime of the facility but have been included to show the consequences of an accident. The levels of thyroid and breast cancer are discussed in section 4.6.2.9, Health Effects Studies. Additional information is presented in appendix section E.4.6. DOE puts a great deal of emphasis on protecting the public and occupational workers from radiation exposure. There are numerous promulgated DOE orders which establish conservative dose limits to both the public and workers at risk of exposure.
  
  In section 4.1.9.1, subsection on Epidemiological Studies, there is a statement that defines DOE's program to monitor health effects on workers and the public in the communities surrounding DOE facilities. An independent agency, Health and Human Services, has been conducting a health effects research program on DOE facilities under a 1991 Memorandum of Agreement. The National Institute for Occupational Safety and Health initiated a study in 1994, but does not expect results before 1997. However, extensive health studies have already been conducted on the public within the State of New Mexico in the counties surrounding both LANL and SNL, as well as workers within those facilities. Summaries of the results of the studies at LANL and Los Alamos County are presented under Health Effect Studies in section 4.6.2.9, with details presented in appendix section E.4.6. Summaries of the results of the studies at SNL and the surrounding county, Bernalillo, are presented in section 4.8.2.9 under Health Effects Studies, with details presented in appendix section E.4.8. All studies reported are referenced. Past and present radiation and hazardous chemical releases have been documented and are used as one of the bases for predicting future releases when the proposed actions, if approved, are implemented.
  
  The impacts of potential accidents at LANL are discussed in section 4.6.3.9. Figure 4.6.3.9-1 and tables 4.6.3.9-3 through 4.6.3.9-7 present the impacts of accidents. The graph in figure 4.6.3.9-1 indicates the probability of fatalities due to accidents associated with the proposed actions.

11.07

The commentors refer to LANL section 4.6.3.9 and the following text, "The average annual dose to involved workers for this alternative would be 380 mrem. The dose to the entire facility workforce would be 55.6 person-rem. As stated in the methodology, section 4.1.9, all worker doses were referenced either from alternative-specific working group data reports or from the Radiation Exposures for DOE and DOE Contractor Employees 1992 Database which reports doses for similar types of operations...." A commentor asks if the 1992 database is representative for the projected years and if working group data contain situation-specific source terms and shielding considerations. Another commentor asks if linear extrapolation was used to determine the doses to the workers at LANL and SRS in the Summary section S.4.1. The commentor believes that these are overestimates of what would happen to the workers. The commentor asks if LANL ever had pit production capacity and if data on worker safety, accidents, and contamination were used in the PEIS. The commentor also asks how the radiation doses to workers calculated in the PEIS for pit fabrication at LANL compare to the doses that were observed at Rocky Flats when pit fabrication was performed there.

• Response: The conservative 380 mrem/yr dose to involved workers at LANL and SRS for pit fabrication operations was arrived at through direct measurement and calculation. In 1995, LANL started work on Defense Nuclear Facilities Safety Board Recommendation 94-1, processing a full load of pits for the pit surveillance program and the Cassini project. Many of the operations for these programs at LANL are considered comparable to "pit manufacturing" operations. The total annual dose for TA-55 personnel during full operations was 153.8 person-rem. By dividing this number by 405, the number of personnel who received a nonzero dose during that period (i.e., the hands-on workers and support personnel, but not office workers), the resulting average dose for plutonium manufacturing personnel is approximately 380 mrem per worker.
  
  Comparing the historic Rocky Flats Plant pit fabrication activities and doses to workers to the proposed pit fabrication mission at LANL would not be appropriate. The pit fabrication mission at Rocky Flats used a different process than the one proposed for LANL, and the production volume at Rocky Flats was much larger because of the larger stockpile levels at that time.
  
  LANL currently maintains a limited capability to fabricate plutonium components using its Plutonium Research and Development Facility and provides safety and reliability assessments of the stockpile (section 3.4.3.1). Sections 4.6.2.9 and 4.6.3.9 provide a description of the radiation and hazardous chemical environment at LANL, including descriptions of health effects studies, a brief accident history, and emergency preparedness considerations. Data on worker safety, accidents, and contamination at LANL were analyzed in the preparation of this PEIS. The safety analysis report prepared by LANL for the TA-55 plutonium operations was a source of considerable data used in this PEIS for identifying and estimating the impacts of accidents.
  
  The 1992 database is representative of worker dose data for the year 1992. This report provides a recent source of dose data through which estimations of potential doses to stockpile stewardship and management involved and noninvolved workers can be made. These doses are based on actual dosimeter measurements and therefore take into account existing shielding at the work site. The working group data report does contain source terms associated with this Stockpile Stewardship and Management Program activity.

11.08

The commentor asks what DOE considers to be an accident and if there is enough historical data to constitute a fair analysis of pit fabrication related accidents. The commentor asks if the analysis examines risks to the workers in the workplace. The commentor also asks if the accident modeling included real accidents at TA-55 reported to the Occurrence Reporting System.

• Response: DOE considers an accident to be an unplanned sequence of events that results in undesirable consequences. More information on accidents is provided in a DOE standard, (DOE DP-STD-3005-93 Proposed, Definitions and Criteria for Accident Analysis, DOE, March 8, 1993). Accidents that are of the highest concern have high consequences and low probabilities of occurrence and therefore have never occurred. However, even without historical data, techniques are available to predict the sequence of events that may lead to an accident and to estimate the accident's impacts. The PEIS contains an evaluation of the risk of accidental exposure of a hypothetical worker located at either 1,000 m (3,281 ft) or the nearest site boundary, whichever is smaller, to radioactive substances released during an accident. An important source of data for accidents at LANL is the safety analysis report recently prepared for TA-55, which includes any applicable accidents reported to the Occurrence Reporting System.

11.09

Commentors question the exposure limits for noninvolved and involved workers in the ORR table 4.2.3.9-2. Commentors are concerned that the exposure limits for noninvolved workers is higher than for involved workers and wants to know where the D&D workers are in the table. In addition, commentors are concerned with the quality of estimated health impacts to the general public.

• Response: The exposure limits (i.e., average worker dose) to the noninvolved worker represents the estimated average dose to all noninvolved workers from all radiological sources at ORR. Conversely, the average worker dose to the involved worker represents the estimated average dose from the downsized secondary and case fabrication three-shift operation only. The average dose to the involved worker does not include the average dose from all other sources. If one were to include the additional dose from all other sources at ORR, the average dose to the involved worker is expected to be slightly higher than the average dose to the noninvolved worker. D&D workers are not included here, because they are not present during the normal operation of the stockpile management alternative at ORR. Site-specific information was used in the preparation of this analysis.
  
  In regard to the integrity (quality) of the general public dose estimates, the analytical "worker dose" methodology and associated data used in the PEIS were independent of those utilized for public dose calculations. For public health impacts, an indepth assessment was made using the GENII computer code. This type of analysis uses site-dependent factors including meteorology, population distributions, agricultural production, and an assumed facility location on a given site.

11.10

The commentor questions the accident history in section 4.2.2.9, which states that the most noteworthy accident at Y-12 resulted in temporary radiation sickness for a few ORR employees. The commentor would like to know whether the employees involved in this accident view its effects as temporary radiation sickness.

• Response: All accidents at DOE facilities are investigated in detail in order to understand the root causes and to identify corrective actions to prevent their recurrence. The health of workers following an accident is closely monitored to ensure every opportunity is taken for a complete recovery. There are a number of DOE orders in effect to protect the health and safety of workers. The requirements for investigation and documentation of the circumstances surrounding an accident are specified in DOE O 232.1, Occurrence Reporting and Processing of Operations Information. Other DOE orders that address a worker's health and safety include DOE O 231.1, Environment, Safety, and Health Reporting, and DOE O 440.1, Worker Protection Management for DOE Federal and Contractor Employees.

11.11

Commentors express concern about the health of area residents. One commentor believes that the breast cancer rate in Livermore is the highest in the nation. Other commentors state that activities at LLNL have created plutonium pollution at nearby parks, tritium contamination of the water, and onsite contamination from leaking drums. Another commentor states that workers at LLNL are 400 percent more likely to develop malignant melanoma than the general public. The commentor also contends that the children of Livermore are 6 times more likely to develop skin cancer as a result of activities at LLNL.

• Response: The environmental impacts associated with radiological and hazardous chemical operations at LLNL are described in section 4.7.3.9, in appendix E for normal operations, and appendix F for potential accidents. The human health analyses presented for LLNL in the PEIS, conclude that "adverse health effects to the public and to workers will be small." This conclusion pertains only to the "alternatives" presented in the PEIS. Historical contamination and cancer incidences are discussed in section 4.7.2.9, the subsections on Accident History and Health Effects Studies.

11.12

The commentor states that the PEIS does not clearly differentiate the safety risks associated with each alternative if an accident were to occur.

• Response: The composite risk value for accident impacts provided for each alternative in the main body of the PEIS and in appendix F can be used to differentiate the safety risks associated with each alternative. Appendix F also provides risk information for individual accidents in terms of accident consequences and probability of occurrence which can also be used to differentiate between alternatives. In addition, complimentary cumulative distribution functions are provided for each alternative at each site in the PEIS as an indication of the full range of probable impacts.

11.13

The commentor believes that none of the Draft PEISs have adequately addressed what would happen to the 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. The commentor thinks that the public's perception of the contamination would be such as to make local products unmerchantable not just for the immediately affected area, but for the entire Panhandle's products.

• Response: The likelihood of a significant accident that would impact the area's farm and ranch economy is very small. The PEIS identifies several potential accidents that can result in undesirable offsite consequences, measured in terms of the risk of cancer fatalities to the workers and members of the public. Secondary impacts of accidents affecting elements of the environment other than humans are also presented in a new section, appendix section F.4. This section identifies the extent of radiological releases due to accidents that may result in the contamination of farmland, surface and groundwater, recreational areas, industrial parks, cultural resources, or habitat of endangered species. The accident analyses were performed in accordance with DOE guidance (refer to the Office of NEPA Oversight document).

11.14

The commentor would like the PEIS to address the impacts which would result from a nuclear explosion, including the resulting deaths, the cancers created, and the spread of radioactivity.

• Response: The devastating effect of a nuclear explosion is clearly recognized and has been the driving force to prevent any accidental or intentional occurrence. Within the DOE system, strict compliance with DOE orders and procedures is enforced to minimize the probability of any technical or human cause of an inadvertent nuclear explosion. Some examples of applicable DOE orders are DOE O 452.1, Nuclear Explosive and Weapons Surety, and DOE O 452.2, Safety of Nuclear Explosive Operations. Inadvertent detonation of a nuclear weapon has a probability of occurrence which is much less than 10-7 per year or once in 10 million years and is not evaluated. The risk of an explosive dispersal of nuclear materials is evaluated for weapons A/D operations at Pantex and NTS where work is performed on nuclear components in the presence of explosive materials.

11.15

The commentor suggests that DOE provide additional information and clarity concerning the accident risk analysis. Another commentor believes that the accident analysis tends to trivialize accidents and notes that very low-probability events that have very catastrophic consequences are difficult to comprehend.

• Response: The accident analyses were performed in accordance with DOE guidance (refer to the Office of NEPA Oversight document). A set of accidents have been analyzed that include high probability/low consequence as well as low probability/high consequence events to show the range of possible impacts. The low probability/high consequence accidents are not expected to occur during the lifetime of the facility but have been included to show the worst possible consequences of an accident.

11.16

The commentor does not share DOE's confidence that operating its new weapons complex at surge capacity can be done largely without waste management and capacity difficulties, and more than proportionally increased risk of both routine and accidental releases of radioactive and hazardous materials and of worker exposures.

• Response: The PEIS analysis bounds potential environmental impacts by assuming operations at a surge capacity. This means greater wastes and greater radiation doses are assessed than we would normally expect. It provides a reasonable level of conservatism such that DOE can be confident that any impacts would stay within the bounding envelope provided in the PEIS.

11.17

The commentor views the reservations near Los Alamos, NM, as a "dump" (i.e., nuclear waste and radiation) and believes the populations are affected.

• Response: LANL health effects studies are presented in section 4.6.2.9 and appendix section E.4.6 of the PEIS. Several key facets of concern including cancer incidences among the general public (including those who may reside on the nearby reservations) have been addressed. Table 4.6.2.9-2 conveys data on the total annual radiological dose incurred to the LANL surrounding population (within an 80-km [50-mi] radius). The extremely small annual population-dose imparted in this table yields an associated cancer risk which is also very small (i.e., 0.0015 of one fatal cancer per year).

11.18

The commentor wants to know to what extent the analysis of cancer risk factors into different schools of thought. The commentor notes that others have different views on exposure to radiation and its effects. The commentor wants a balanced view in the PEIS.

• Response: To ensure a consistent set of risk standards in the preparation of EAs and EISs, DOE has established recommended guidelines for the preparation of human health impact sections in these documents (refer to the Office of NEPA Oversight document). The public and occupational health risk for normal radiological operations analyzed in the PEIS uses the two dose-to-risk conversion factors for the public and workers recommended by DOE's Office of NEPA Oversight and established in the BEIR V Report. These risk factors are 0.0005 deaths per person-rem to the general public and 0.0004 deaths per person-rem to workers (the lower number for workers accounts for the absence of children in the workforce). Appendix E, Human Health, presents a detailed discussion of the methodology used to determine the radiological impacts to human health. The appendix also includes a section on the development and use of the risk factors presented in the Stockpile Stewardship and Management PEIS.

11.19

The commentor asks if the PEIS projects what would be considered a safe dose of radiation in the future. The commentor notes that what we may have considered safe 25 years ago is much different based on today's knowledge.

• Response: Radiological doses during normal operations (to both the public and workers) associated with all future Stockpile Stewardship and Management Program activities would be well below regulatory standards established by the NRC and EPA. Over the last 20 to 30 years, enormous progress has been made in the study of biological effects resulting from radiation exposure; today's "conservative" exposure limits are a reflection of these research results. Over the past 25 years, a concept known "as low as reasonably achievable" has been the benchmark goal of all nuclear-oriented facilities licensed in the United States. Regularly "lowered" dose limits are a prime example of how much emphasis has been placed upon radiation safety in recent years. As to whether the dose limits will conservatively change in the coming years will be subject to the results of further data analyses, such as from the Chernobyl accident.

11.20

The commentor states that Savannah, GA, is known to be a cancer site. The commentor asks if the PEIS contains statistics on the amount of radiation that flows through Savannah via SRS plus the existing high cancer rate.

• Response: For the purposes of this analysis, a radius of up to 80 km (50 mi) around a site was investigated for potential radiological impacts to public health. The city of Savannah is beyond this 80-km (50-mi) zone (roughly 160 km [100 mi]) and therefore has not been analyzed for potential impacts from SRS radiological airborne releases. However, potential radiological impacts to the Savannah area through the drinking water pathway are routinely assessed via the monitoring of offsite water treatment plants at Beaufort-Jasper and Port Wentworth, which are both located in reasonably close proximity to the city of Savannah. The PEIS reports these normal operational radiological impacts (incurred from the liquid pathway) in table 4.3.2.9-2. These liquid doses include constituents from drinking water, sampled at the site boundary--downstream to the Atlantic Ocean (i.e., Savannah River). The cancer risks per year associated with these modeled liquid doses are extremely small (0.0008 of one fatal cancer is estimated within the total population under investigation). For further information on health risk studies involving communities around the SRS area, see appendix section E.4.3.

11.21

The commentor wants to know how old the epidemiological studies are that were used in the PEIS.

• Response: They began as early as 1942, but some reports are as recent as 1996.

11.22

The commentor is concerned that a direct link cannot be identified between SRS radiation releases and latent cancer. The commentor also states that at the same time, it cannot be proven scientifically that radiation from Federal facilities does not cause cancer.

• Response: In 1984, Sauer and Associates examined mortality rates in Georgia and South Carolina by distance from SRS (see Volume I, chapter 6, SR duPont 1984b). Rates for areas near the plant were compared with U.S. rates and with rates for counties located more than 80-km (50-mi) away. Breast cancer, respiratory cancer, leukemia, thyroid cancer, bone cancer, malignant melanoma of the skin, nonrespiratory cancer, congenital anomalies or birth defects, early infancy death rates, stroke, or cardiovascular disease in the populations living within 80 km (50 mi) of the plant did not show any excess risk compared with the reference populations. Historical data and associated statistics have indicated that there have been essentially no significant health risk increases as a result of normal operation radiological releases. EPA and NRC regulatory standards are designed to protect the public from potential health impacts resulting from normal operational radiological releases.

11.23

The commentor wants to know the impact of radiation as a result of the Stockpile Stewardship and Management Program on children, particularly birth defects. Another commentor believes that the PEIS's risk analysis is one-dimensional and not accurate; it cannot take into account the future legacy of radioactivity, the future health and genetic consequences, or the environmental impacts.

• Response: Radiological impacts to the public (including children) from planned Stockpile Stewardship and Management Program activities are presented in section 4.3.3.9 of the PEIS. Modeling has shown that potential doses to adults and children alike, would be extremely small (billions of times lower than that incurred from natural background radiation). Appendix section E.2.1.2 of the PEIS presents risk estimations for "genetic effects." The risk of incurring these effects are even smaller than that for fatal cancer (about 75-percent smaller).

11.24

The commentor asks for the basis of the assumption that, in the accident scenarios, the worker is assumed to be a kilometer away.

• Response: In general, exposures to workers decrease with increasing distance away from the location of the accident. The evaluation of impacts to noninvolved workers (i.e., workers that are located on the site independent of the proposed action) assumed a hypothetical noninvolved worker located at 1,000 m (3,281 ft) from the location of the accident or the nearest site boundary, which ever is closer. For distances less than 1,000 m (3,281 ft), modeling techniques are less effective because of the effects of buildings on meteorology and dispersion.

11.25

Referring to the uncertainty of potential, long-term health effects due to exposure at Pantex, the commentor would like to know how DOE can be so sure of the consequences of future missions that may be brought to the site.

• Response: Section 4.5.2.9 presents a discussion of health effects studies which have been previously conducted in the communities surrounding Pantex. These studies indicated that there have been no significant excess cancer mortality incidences in the Pantex area; thus, there have been no verifiable indicators as to any short- or long-term health impacts at the Pantex 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. In addition, DOE orders and required standard operating procedures have been established in order to ensure the safe and reliable operation of DOE facilities. The planned stockpile management program options at Pantex would not alter these circumstances. DOE's utilization of radiological dose modeling techniques quantitatively estimates exposure to the public and workers as a result of potential future stockpile management missions. Appendix section E.2.2 describes the methodology used to estimate radiological impacts during normal operations from DOE facilities analyzed in the PEIS such as tritium in the environment.
  
  The risk analysis employed in the PEIS for normal radiological releases takes into account the potential future health consequences which may occur from planned Stockpile Stewardship and Management Program activities. Expected radiological release quantities from each Program alternative are modeled to determine potential doses which may be incurred to members of the public in future years. Hypothesized future residential populations are included within the calculations in an effort to calculate future population-dose values. The future "behavior" (or "legacy") of radiological material(s) related to Stockpile Stewardship and Management Program operations are analyzed for anticipated characteristics which are to be expected over the coming years, including: decay rates, transport through air and water media, and uptake frequencies. When modeling is performed to determine human health impacts, "genetic consequences" can be calculated from information presented in appendix section E.2.1.2 of the PEIS. The risk of incurring "genetic effects" is even smaller than that for fatal cancer (about 75-percent smaller).

11.26

The commentor, a landowner near Pantex, is concerned about the integrity of her property and her personal safety, claiming that past accidents and explosions at Pantex have adversely affected her and others in the neighborhood of Pantex.

• Response: All facilities at Pantex and other DOE facilities are operated in strict compliance with DOE orders to minimize the chances of an accident that would release radioactivity to the surrounding area and to also mitigate the effects of a release if one were to occur. Any accident that has occurred is thoroughly investigated to identify its cause. Corrective actions that minimize or eliminate any repetition of the accident are also identified and implemented to maintain operations that are safe for workers and the public. For the preparation of the PEIS, a variety of potential accidents that may be initiated by operational causes, such as an explosion, or by natural phenomena, such as earthquakes, were identified and their impacts estimated using appropriate analytical methods. The results, as well as the history of Pantex accidents, are discussed in section 4.5.3.9 of the PEIS.

11.27

The commentor states that Santa Fe is the capital of New Mexico and therefore has an increasing populace. The commentor is concerned that the area surrounding LANL is very near Santa Fe. The commentor feels possible contamination of the water, groundwater, and radioactive accident or sabotage, if they would occur, would make Santa Fe and the surrounding area uninhabitable. Another commentor suggests that the mere perception that an accident is possible could damage the tourist industry in New Mexico. Other commentors state that one nuclear accident would destroy the tourist, manufacturing, and agrarian industries in the State of New Mexico.

• Response: For the PEIS, a variety of potential accidents that may be initiated by operational causes or by natural phenomena, such as earthquakes, were identified and their impacts estimated using appropriate analytical methods. The results are documented in the PEIS. Appendix section F.4 discusses the secondary accident impacts to these types of resources for each site. In addition, other recent NEPA reviews for prior or interim actions (such as the Dual Axis Radiographic Hydrodynamic Test [DARHT] Facility EIS, DOE/EIS-0228) have analyzed the potential impacts of specific hypothetical facility accidents on the environment around LANL, including Santa Fe.

11.28

The commentor states that the PEIS needs to document more fully why the assumptions associated with the PEIS accident scenarios are reasonable, and how these assumptions and other inputs are used by the Melcor Accident Consequence Code System model.

• Response: Additional information on accident scenarios and source terms for the accidents described in the PEIS are documented in a topical report (refer to HNUS Report No. ARP-96-042), which has been placed in the DOE Public Reading Rooms near each site. The Final PEIS contains an expanded discussion to further explain how data and assumptions are used by the Melcor Accident Consequence Code System model.

11.29

The commentor refers to the ORR section 4.2.3.9, Radiation and Hazardous Chemical Environment, and asks if it is true that hazardous impacts would be reduced to zero as a result of secondary and case fabrication phaseout, unless we completely greenfield the site, including recovery of material from burial grounds.

• Response: Phaseout of these activities would reduce the added burden (beyond No Action) to zero because only other unrelated No Action activities would remain.

11.30

The commentor refers to the ORR table 4.2.3.9-4 and asks how accident numbers were generated, and states that it is not clear why the probability of a significant beryllium oxide release is so high.

• Response: Additional information on accident scenarios, frequencies and source terms for the accidents described in the PEIS is documented in a topical report (refer to HNUS Report No. ARP-96-042), which has been placed in the DOE Public Reading Rooms near each site. The accident scenarios and related parameter values are based on safety analyses of facilities that perform operations at Y-12. The probability of a release is conservatively high in order to bound the impacts of the event.

11.31

The commentor notes, with regard to nuclear weapons "safety," that morbidity and mortality in the cleanup crews at nuclear weapons accidents have not been studied, and long-term effects at these sites are unknown. The commentor states that with these possible exceptions, no one is known to have ever been injured from a nuclear weapon in an accident. Another commentor states, with regard to nuclear weapons "safety," that a risk of death from a nuclear weapons accident appears to be about a million times smaller than other causes of accidental death and about 100 to 1,000 times smaller than the public health risks from exposure to environmental pollution at current health standards.

• Response: The PEIS presents a full disclosure of all the human health risks associated with each of the alternatives based on best available data. All new construction and modifications to existing structures would meet or exceed applicable environmental, health, and safety standards for the public and workers. Because of these factors, the measures taken by DOE to limit impacts to human health from normal operations, and to prevent accidents which would impact human health, the analysis in this PEIS shows the risks associated with these technologies to be low.

11.32

The commentor contends that the analysis of radiological impacts is too limited. It omits entirely the impacts of radioactive releases on aspects of the biosphere other than human health (see section 4.1.6). The commentor states that the analysis for radiation releases for normal operations of the proposed stockpile stewardship and management facilities is difficult to follow, and appears to be based on assumptions which may substantially understate potential impacts. The explanation of the health effects calculations in appendix E states that source terms for radiological releases are for "stockpile management alternatives," and there is no reference to or data for releases from stockpile stewardship alternatives provided in appendix section E.2.3. The source terms include "only atmospheric releases, because liquid radiological discharges are not expected from any of the alternatives at any of the sites" (appendix section E.2.3). The commentor believes there is no explanation of why this is so.

• Response: As discussed in section 4.1.6 of the PEIS, impacts on biotic resources from the release of radionuclides would be expected to be less than that on the human population based on studies which have shown humans to be the most sensitive organism to radiation release.
  
  Regarding the analysis of radiation releases for normal operations, section 4.1.9.1 discusses the methodology that was employed to estimate potential impacts. Appendix E provides greater detail of how health effects were estimated, including the reasons why the analysis in the PEIS is conservative.
  
  The source terms for radiological releases from stockpile stewardship alternatives are not included in appendix E of the PEIS. Because each of the stockpile stewardship facilities are addressed in greater detail in appendix I (NIF), appendix J (CFF), and appendix K (Atlas), source term information for each of these facilities is addressed in those appendices, as appropriate.
  
  The statement, "source terms include only atmospheric releases because liquid radiological discharges are not expected from any of the alternatives at any of the sites" found in appendix section E.2.3 of the PEIS is correct. During normal operations, no liquid releases of radionuclides are expected. This is because the facilities are designed to have no liquid radionuclide discharges.

11.33

The commentor cites section 3.7.1, Stockpile Management, "Worker exposure to radiation is expected to be about equal" and asks if it is reasonable to believe that NTS workers might receive higher doses for several years because of the lack of experience compared to Pantex workers. Commentor believes nothing replaces actual experience and thinks DOE should consider a learning curve at NTS.

• Response: The worker dose estimates presented (i.e., the 10 mrem/yr) are tabulated via historical worker dose data for comparable operations. These data provide the most accurate values available for the planned program activities being analyzed in the PEIS.

11.34

The commentor cites section 4.1.9.1, Hazardous Chemical Impacts, and asks why CERCLA guidance was used. Commentor does not believe the CERCLA guidance bounds the issue because the higher risk occupations such as medical personnel, fire fighters, radiation workers, HE workers, roofers, machine operators, security personnel, and such would not be covered.

• Response: This section has been modified to reflect that CERCLA does not override the Occupational Safety and Health Administration's (OSHA) regulations for workers and EPA guidance for calculating risk to the public and workers relative to cancer risk. Instead, CERCLA should be correctly used in setting the cancer deminimus risk of 10 -6 and the range of acceptable cancer risks for specific carcinogens based on how they are used and their mechanism of action (i.e., threshold versus nonthreshold carcinogens); the range of 10 -4 to 10 -6 specified under CERCLA covers the chemical-specific assessment as to whether a cancer risk is acceptable. Calculations for worker exposures were always done based on OSHA regulations for exposures to noncarcinogens and guidance for safety required for carcinogens.

11.35

The commentor believes, contrary to the statement in appendix section E.3.1, that exposure to hazardous chemical releases to surface water, groundwater, and soils should be included when assessing the risk to the public and site workers.

• Response: The text cited by the commentor in appendix section E.3.1 refers to conditions under normal operations. Under such conditions hazardous chemicals are not released into surface water or groundwater or onto soil; therefore, inhalation is assumed to be the only route of exposure. For accident scenarios involving the release of hazardous chemicals into the environment, refer to appendix F, Facility Accidents.

11.36

The commentor expresses concern that the hazard indexes and total cancer risk provided for the phaseout alternative at Pantex (appendix table E.3.4-12) are not properly evaluated. The commentor points out the risks for the phaseout of Pantex are lower than the risks cited for the other programmatic alternatives, with the exception of the A/D and HE fabrication alternative, which essentially equal the risk of the phaseout alternative. However, the amounts of hazardous and mixed LLW generated during phaseout of Pantex are anticipated to be 100 to 1,000 times greater than the other alternatives (tables 4.5.3.10-2 and 4.3.5.10-3). According to the commentor, section 4.5.3.9 of the PEIS states that no hazardous chemical emissions are anticipated for the phaseout alternative at Pantex, and the hazard index and cancer risk to the public and onsite workers would be zero. The commentor believes that it is more reasonable to assume that some exposure will occur during a phaseout of Pantex when over 6 million m 3 of waste is generated.

• Response: The fact that all hazardous chemical emissions are lower than other programmatic alternatives is attributed to the emissions that would no longer occur should this activity cease (i.e., the greater the contribution of an activity the more the reduction when it is phased out). In fact, table 4.5.3.10-2 shows that there is a reduction in solid hazardous waste generated from No Action and no change in liquid waste from No Action whereas solid mixed LLW is reduced and liquid wastes are reduced slightly. However, disposing of wastes using state-of-the-art technologies is not expected to result in increased releases to the environment. In fact, as is shown by appendix table E.3.4-12, the hazard indexes would be between 4- and 5-fold below a safe level (1.0) and the cancer risks contributed would be 2 to 3 orders of magnitude below that in the general unexposed population.

11.37

The commentor refers to the NTS section 4.9.2.9, Radiation and Hazardous Chemical Environment, and suggests that the word "radioactivity" be removed, and the phrase "radioactive activity level" be inserted before the word "approximately." The commentor also suggests the words "were accidental" be replaced with "was an accidental release" in the sentence. The commentor further states that the NTS Accident History is inaccurate and has been manipulated to exclude the Baneberry venting accident (1970), and that NTS atmospheric tests released 1.2x10 10 Ci into the atmosphere.

• Response: The releases from underground tests stated in the Draft PEIS are for the period from 1971 to 1988. Tests prior to 1971 were the cause of releases totaling 25,300,000 Ci, which includes the Baneberry release in 1970 (6,700,000 Ci). The discussion of NTS accident history has been expanded in the Final PEIS to include the Baneberry release and other atmospheric test releases. Additional details on accidental releases are documented in the report, The Containment of Underground Nuclear Explosions, Congress of the United States (OTA-ISC-414, October 1989).

11.38

The commentor refers to section 4.1.9.2, Facility Accidents, "Accident risk to collocated workers was calculated for a hypothetical worker at 1,000 m (3,281 ft) from the facility, or at the site boundary, whichever is closer." The commentor states that usually in EISs, EAs, and safety analysis reports, the collocated workers are located at a much closer distance, such as 100 m (328 ft) and then at increments to 1,000 m (3,281 ft). The closer distances provide a more conservative (and more realistic) risk analysis for accidents.

• Response: In general, exposures to workers decrease with increasing distance away from the location of the accident. The programmatic level evaluation of impacts to noninvolved workers (i.e., workers that are located on the site independent of the proposed action) assumed a hypothetical noninvolved worker located at 1,000 m (3,281 ft) from the location of the accident or the nearest site boundary, whichever is closer. For distances less than 1,000 m (3,281 ft), the screening model techniques used in the programmatic level analyses are less effective because of the effects of buildings on meteorology and dispersion. For site-specific assessments, specialized modeling techniques would be used for estimating exposures at closer distances.

11.39

The commentor refers to the LANL section 4.6.3.9, "... the presented noninvolved worker impacts were not modeled due to the unavailability of certain site-specific information. There also may be small risks to construction workers who are involved with tasks that are in close proximity to potentially contaminated areas." The commentor states the following: 1) noninvolved workers were not modeled; and 2) if risks to construction workers were not modeled, how can they be quantified as "small." If the source term of contaminated soil that they may be exposed to is a low activity or limited to a small area, it should be indicated in text. In addition, the commentor refers to the SNL section 4.8.3.9, "The presented total dose to noninvolved workers was not modeled due to the unavailability of certain site-specific information." The commentor states that radiological impacts to noninvolved workers were not performed.

• Response: Impacts to noninvolved workers and construction workers may be described in this manner because historical data and experience indicate that these workers would primarily be subjected only to radiation exposure from their designated job tasks. There are no verifiable "contaminated soil" source terms available to model radiological impacts to construction workers.
  
  A dose (impact) assessment for the LANL and SNL noninvolved worker was performed for the PEIS (sections 4.6.3.9 and 4.8.3.9, respectively). Noninvolved worker impacts were determined from information presented in the annually published report Compilation of Doses to Workers at DOE Facilities, for the year 1992. This report (database) provides a recent source of dose data from operations which are comparable to planned stockpile stewardship and management activities. Estimations of potential doses to stockpile stewardship and management workers were calculated from this historic record.

11.40

The commentor refers to the LANL section 4.6.3.9, "... there are potential impacts to involved workers who would be located in the facilities. Quantitative statements of these impacts cannot be made until design details are developed further, at which time the number and location of facility workers can be estimated to support accident impact analyses. However, depending on the type of accident, facility workers in close proximity to the point of the accident could receive high levels of exposure to radiation, with potentially fatal impacts." The commentor states that impacts to workers were not modeled for accident analysis, however, fatalities may occur and the number of deaths is not estimated nor projected.

• Response: The design and layout of facilities, operating procedures, protective features, training and other safety measures all serve to prevent the occurrence of accidents and mitigate its effects if one were to occur. This is not a discriminator for mission siting and not addressed at the programmatic level. However, for any alternative that is selected, tiered NEPA studies and safety analysis reports required before operations are permitted to commence, will include estimates of impacts to involved workers that are based on well-defined safety measures.

11.41

The commentor states that it is not clear whether DOE's risk assessment includes those hazardous constituents that do not meet the narrow definition of hazardous waste under RCRA or toxic substances under the Toxic Substances Control Act (TSCA). The commentor suggests DOE consider the risk posed to human health and the environment by what DOE defines as nonhazardous waste constituents (appendix table H.1.1-1).

• Response: DOE's risk assessment includes chemicals considered hazardous under RCRA or TSCA, and any others regulated by EPA or OSHA for which there is information that describes the nature of the hazard (e.g., National Institute of Safety and Health handbook, American Conference of Governmental Industrial Hygienists [threshold limit values and biological exposure indices], etc.). The nonhazardous waste constituents are not included in the assessment because they are not considered to pose a human health or environmental hazard. However, many of these constituents are considered in the air quality and water quality sections of the document.

11.42

The commentor refers to appendix section E.2.2 and the statement, "For use in design basis accidents, the 50-percentile option was used." The commentor states that the 50-percentile option depicts conditions that are "average." Usually in EISs, environmental assessments, and routine site analyses for risk from accidents, risks are analyzed under "worst-case" conditions, which are also known as 95-percentile conditions (when using certain codes). Accident risks were not analyzed under worst-case conditions in the PEIS, and an underestimation for accidents under extreme conditions could result.

• Response: The accident analyses were performed in accordance with DOE guidance. This guidance states that "Analyses generally should be based on realistic exposure conditions ... and characterize the "average" or "probable exposure conditions ..." and therefore the results in the Draft PEIS are based on 50-percentile meteorological conditions (refer to the Office of NEPA Oversight document, page 21). Other conservative assumptions are made in the accident analyses in order to bound potential impacts. In addition, a spectrum of accidents is evaluated ranging from low-consequence/high-probability events to high-consequence/low-probability events to reflect bounding-case impacts. The complimentary cumulative distribution functions included in the Final PEIS also show the bounding-case impacts.

11.43

The commentor refers to appendix F, Accidents, and states that solid uranium and plutonium liquid criticalities were modeled; however, no plutonium metal criticalities (solid) were analyzed. This accident analysis may not have been performed in the past; however, the accident scenario should be considered due to the projected increases in the number of pits under the "Pit Fabrication alternative." In addition, the commentor states that the methodology section should mention how the source terms for the criticalities are determined, and source terms should be listed by radionuclide and activity, not only as the number of fissions. From the information presented in the PEIS, the commentor says it is not possible to determine whether the criticality analyses are valid.

• Response: The PEIS identifies appropriate accident scenarios based on existing safety analysis reports and operating procedures which are analyzed to estimate bounding impacts. In this case, the liquid plutonium criticality was selected because it has higher impacts to workers and the public than a solid criticality. Additional information on accident scenarios and source terms for the accidents described in the PEIS are documented in a topical report (refer to HNUS Report No. ARP-96-042), which has been placed in the DOE Public Reading Rooms located near each site.

11.44

The commentor states that in appendix section E.4.6, the discussion revolves around an investigation undertaken to assess melanoma risk at LANL because of worker exposure to low-level ionizing radiation. The study was the result of "a reported three-fold excess of melanoma among laboratory workers" at LLNL in California. The study was applied to LANL because of the similarity of the work done at both labs. At the end of the first paragraph in column 2, it is stated that "the only significant association with diagnosis of melanoma for males was being a college graduate ... or having a graduate degree...." To the commentor, it follows obviously that the vast majority of workers at both LLNL and LANL are males who are college graduates or who have graduate degrees and that the workers at LANL are significantly at risk for melanoma resulting from exposure to low-level ionizing radiation. The commentor asks if workers will be informed of the risk, if this is an acceptable risk, and if anything can be done to diminish it.

• Response: The commentor fails to mention that no excess risk for melanoma was detected at LANL among 11,308 workers between 1969 and 1978 (see Volume I, chapter 6, Lancet 1982a:883-884). Other studies clearly established no association between external radiation or chemical exposures in the workplace and melanoma. The association between melanoma and a college graduate or graduate degree (as the only association) then takes on lifestyle rather than work-related cause and effect (e.g., college graduates and those with graduate degrees have lifestyles that may differ from the general population, which could well be associated with how they spend their leisure time). DOE workers receive occupational safety and health training, which places a prime emphasis on "as low as reasonably achievable" principles. Through an "as low as reasonably achievable" program, workers are made aware of potential risks, and are trained to minimize (diminish) these risks to the lowest levels possible.

11.45

Commentors state that the New Mexico Environment Department is sometimes referred to by its previous name, Environmental Improvement Division, or by the incorrect form, New Mexico Health and Environmental Department. Examples of incorrect naming can be found in appendix section K.3.3.1 and table 5.3-4. The commentor states that these should all be changed to New Mexico Environment Department.

• Response: In accordance with the commentor's suggestions, these changes have been made in the Final PEIS.

11.46

The commentor identifies the following errors in appendix section E.4.6: there is repetition of the sentence "Population exposures are confounded by occupational exposures," and the word "countries" should be "counties."

• Response: Appendix section E.4.6 in the Final PEIS has been rewritten and the errors the commentor noted have been corrected.

11.47

The commentor identifies the following errors in appendix F: in section F.2.2.1, there is jumbled spelling of the word "national," and in section F.2.3.1, the sentence, "The fire releases the plutonium contamination from the inner surfaces of the gloves" should read "... the inner surfaces of the glovebox."

• Response: The spelling has been corrected in the Final PEIS. The contamination that is released is from the outer surface of the gloves that are in the glovebox. The statement has been modified in the Final PEIS.

12.01

The commentor believes that DOE has unfairly placed their nuclear facilities in low-income areas. The commentor notes that New Mexico, "the home of the bomb," has a low per capita income and a high minority population. Another commentor believes that the PEIS minority population maps for LANL and SNL have errors in them.

• Response: LANL and SNL were established in 1943 and 1945, respectively. These sites were selected, in part, due to their isolation from large population centers. The fact that the State of New Mexico has a relatively low per capita income played no role in siting these facilities and does not influence DOE decisions on whether to continue operating these facilities. Los Alamos and Bernalillo Counties, where most of the LANL and SNL workers reside, both had 1993 per capita incomes ($28,753 and $19,854, respectively), significantly higher than the average for the State of New Mexico ($16,346). The per capita income of these counties approached or exceeded the national average per capita income, of $20,800. Only one county (Rio Arriba) in either ROI had a per capita income significantly lower than the State of New Mexico. Less than 5 percent of the SNL workforce resides in Rio Arriba County.
  
  The environmental justice maps have been reviewed and revised, as appropriate. Several counties and census tracts were improperly categorized for both low-income and minority populations. The Final PEIS contains revised maps that are demographically correct.

12.02

The commentor states that DOE has polluted Western Shoshone land and that, as a result, cancer rates are high in the area. The commentor urges moving activities at the site elsewhere.

• Response: Appendix section E.4.9 describes epidemiological studies performed in the area around NTS, which includes the Western Shoshone land. These studies were performed to evaluate adverse health impacts on the exposed populations in Nevada and Utah from aboveground nuclear testing carried out by DOE at NTS in the 1950s. The results of the studies are inconclusive and contradictory. Underground testing that followed did contaminate land on NTS, but resulted in no additional exposure to surrounding populations. None of the proposed alternatives would result in adverse health impacts to the surrounding populations or cause disproportionate adverse health impacts to the Western Shoshone.

12.03

The commentor wants to know exactly what was analyzed under environmental justice in the Stockpile Stewardship and Management Draft PEIS, the Pantex Site-Wide Draft EIS, and the Storage and Disposition Draft PEIS.

• Response: Environmental justice is the equal treatment of all races, cultures, incomes, and educational levels with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. The environmental justice analyses examine the distribution of low-income and racial and ethnic minority populations in the areas surrounding the alternative sites. Demographic analyses are performed at the census tract level for the area within 80 km (50 mi) of the alternative sites. Proposed alternatives are assessed to determine if these populations would receive disproportionate adverse health and socioeconomic impacts.

12.04

Commentor asks if it is a Government policy to view certain demographic groups as less valuable or more expendable than institutions like SRS.

• Response: No, the Government has no such policy.

< 12.05

Commentor believes that African Americans and low-income populations are being affected by SRS activities.

• Response: The analysis of demographic data for the communities surrounding SRS, as well as the health data presented elsewhere in the document, shows that any air or chemical releases would not exceed the threshold of regulatory concern, and that these impacts would not disproportionately affect minority or low-income groups.

12.06

Commentor wants the impact analyses to include the combined exposure of not only SRS, but other non-DOE industrial uses on low-income and affected communities.

• Response: The PEIS assesses potential impacts from proposed DOE stockpile stewardship and management alternatives. The impacts of other sources of pollution are taken into account as a part of the No Action alternative in the human health analysis. For example, the air and water analyses evaluate whether incremental emissions from the proposed alternatives would lead to any exceedance of air and water quality standards. As noted in the document, DOE will operate in full compliance with all Federal, state, and local regulations. Furthermore, the impacts of other potential DOE and non-DOE activities are explicitly evaluated in section 4.13, Cumulative Impacts.

12.07

Commentor requests an explanation in the Comment Response Document regarding the apparent failure of the PEIS to comply with Executive Order 12898 Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, and President Clinton's memo to heads of all departments and agencies of February 11, 1994, on the subject of environmental justice in minority populations and low-income populations. The commentor states the PEIS did not address the social and economic effects, as required.

• Response: DOE is committed to full compliance with all provisions of Executive Order 12898. The environmental justice sections explicitly analyze the proposed alternatives at each alternative site to determine if any of the proposed actions would result in disproportionate adverse health impacts on low-income or minority populations. The PEIS also addresses socioeconomic impacts, including impacts to employment, income, housing, population, and public finances, for all of the proposed actions. The socioeconomic impact analyses indicate 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.

12.08

The commentor states that LANL has had, and threatens to continue to have, disproportionate impacts on the Pueblo of San Ildefonso, and that because of this, the issue of environmental justice is not given adequate attention in the PEIS. The commentor states that LANL's use and disposal of radioactive materials has caused serious contamination to the air, soil, and water, and continued operations threaten the destruction of sacred sites.

• Response: Continued operations of the LANL mission will be conducted in compliance with Federal, state, and local regulations. The PEIS assesses the potential health impacts from chemical and radioactive emissions during normal operations as well as from accidents. The analysis indicates there would be no disproportionate adverse health impacts to the Pueblo of San Ildefonso.

12.09

The commentor states that in the environmental justice sections of the PEIS, human health is covered, but no socioeconomic analysis is done.

• Response: The environmental justice section addresses potential disproportionate adverse impacts to minority populations and low-income populations. The socioeconomic analyses include impacts to regional economies, population, housing, and public finance characteristics. These impacts are determined at a regional level. The analyses performed for the PEIS indicate that none of the downsizing alternatives would result in significant economic impact on the affected regional economies. For those alternatives involving new workers at alternative sites, there would be small economic benefits. Therefore, there would be no environmental justice impacts. For the proposed phaseout alternatives, impacts would be larger but would still not be economically significant. Both the regional economic area and ROI around each site include areas where environmental justice principles apply. The impacts to these areas are included in the regional impact analysis.

12.10

According to the commentor, Executive Order 12898, requires special attention to be given to subsistence consumption of fish and wildlife. The commentor adds that the order requires Federal agencies to publish guidance reflecting the latest scientific information available concerning methods for evaluating the human health risk associated with the consumption of pollutant-bearing fish and wildlife. The commentor feels that consumption issues are important to address in the PEIS because of their uniqueness in minority and low-income populations and the detrimental range of impacts they may have. tion and waste management) of different programs. DOE should present this document to the public to increase their awareness of the overall impact of DOE activities.

• Response: Subsistence is defined as the traditional use by rural residents of wild, renewable resources for direct personal or family consumption as food, shelter, fuel, clothing, tools, or transportation. Subsistence populations heavily rely on local fish and wildlife to meet their food supply. DOE is unaware of any identified subsistence populations residing on or near any of the alternative sites.

  DOE also notes that because none of the proposed alternatives would lead to radiological releases to water, there would be no impacts to fish or other edible aquatic life in the areas surrounding the alternative sites. All chemical releases would be regulated by NPDES permits and would be in compliance with Federal and state regulations. Furthermore, chapter 4 in the PEIS evaluated doses to the surrounding population through air and liquid exposures for all of the proposed alternatives, including No Action. The analysis indicates that there would be no adverse dosproportionate impacts to minority or low-income populations.

13 Cumulative Impacts

13.01

The commentator expresses concern about the cumulative impact of different programs on local communities. The commentor urges DOE to adopt a "local community" perspective and create a document that would detail the cumulative impacts (e.g. in transportation and waste management) of different programs. DOE should present this document to the public to increase their awareness of the overall impact of DOE activities.

13.02

The commentor quotes from the cumulative impact section of the Council on Environmental Quality (CEQ) regulations and asks why past socioeconomic actions (that led to reductions in employment and that are still felt today) are not discussed in the cumulative impact section of the PEIS. Specifically, the commentor mentions 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.

• Response: Although the socioeconomic effects of past actions are not specifically addressed in the cumulative impacts section, these effects are reflected in the affected environment discussion for each site. As shown in appendix section D.2, Deaf Smith County is one of 26 counties included in Pantex's regional economic area; however, Deaf Smith County is not located within the ROI used in the PEIS. Information on the current and projected civilian labor force, employment, unemployment, personal income, and per capita income were considered for each of these counties in the PEIS. Yucca Mountain Site in Nevada has been selected for detailed study as the candidate for the Nation's first geologic repository. The disposal of HLW and commercial spent nuclear fuel in a radioactive waste geologic repository is discussed in the Environmental Assessment, Yucca Mountain Site, Nevada Research and Development Area, Nevada (DOE/RW-0073, May 1986). The impacts described in that EA are included in section 4.13, Cumulative Impacts, of this PEIS.

13.03

The commentor believes that DOE should look at the cumulative impact of the Stockpile Stewardship and Management, the Storage and Disposition, and the Pantex programs.

• Response: Section 4.13 of this PEIS discusses the cumulative impacts of the Stockpile Stewardship and Management Program, the Storage and Disposition Program, and other proposed actions. As stated in section 4.1.12, Cumulative Impacts, continuing DOE missions and any reasonably foreseeable changes to these missions are addressed as part of the affected environment baseline, or No Action. The Pantex Site-Wide Draft EIS which analyzes impacts associated with conducting nuclear weapons operations at Pantex for the next 5 to 10 years, is included in No Action for the PEIS. The ROD for this PEIS will determine which facilities at Pantex should be upgraded, downsized, or replaced as part of the Stockpile Stewardship and Management Program and will take into consideration all of Pantex's current and reasonably foreseeable activities.

13.04

The commentor argues that the Draft PEIS cumulative impacts analysis is more like an incremental impact analysis, illustrating the relative insignificance of the proposed action's contribution to ongoing, similar degradation of the environment, instead of determining the aggregate or cumulative effects of related impacts in order to judge whether those impacts, taken together, are significant. The commentor cites waste management as an example, contending that there is no real analysis of whether the proposed Draft PEIS alternatives, in combination with other foreseeable activities in the same area, will have significant waste management impacts. The commentor further states that the use of resources and impacts on the biosphere and on human health from routine and accidental releases from waste management facilities are not analyzed in the waste management cumulative impacts discussion for each site. The commentor also states that the cumulative impacts analysis is not done on an alternative-by-alternative basis, so it is difficult to compare alternatives to one another. The commentor calls the cumulative impacts analysis cursory and conclusory, offering no supporting analysis and no indication where such analysis could be found. The commentor cites section 4.13.1.1 where the cumulative impacts analysis for nonaccident radiological impacts for rebuilding the complex is one paragraph long.

• Response: Impacts from past actions and continuing actions contribute to the affected environment at each of the sites as described in sections 4.2.2 through 4.9.2. In sections 4.2.3 through 4.9.3, the impacts from continuing actions are presented in the No Action alternative. The impacts from the proposed action and the alternatives are also discussed in those sections to allow for comparison to the No Action alternative. Section 4.13 of the PEIS includes a site-by-site discussion of cumulative impacts, focusing not only on the future impacts from the Stockpile Stewardship and Management Program, but also on the future impacts from other reasonably foreseeable programs and actions. As discussed in that section, many other significant programs are included in that cumulative impact analysis, including Environmental Management and Materials Disposition Programs. That analysis focuses on those resources that were judged to have the greatest potential to be impacted. Depending on the particular site of concern, these resources included air quality, water resources, socioeconomics, radiation and human health, and waste management.
  
  The cumulative impact assessment was done for a bounding analysis on a site-by-site basis. This means that at a given site the contribution from stockpile stewardship and management alternatives was based on the maximum number of potential missions added to other programs' potential impacts at that site. The intent of the analysis was not to illustrate the relative significance of the Stockpile Stewardship and Management Program alternative impacts, but rather to determine whether the Stockpile Stewardship and Management Program potential impacts, in combination with other programs' potential impacts, could produce significant impacts.

13.05

The commentor questions where the supporting analysis was for the statements in the Draft PEIS that "all program totals would be within radiological limits to the public and the effects to workers would be small," and that "[c]umulatively, radiological impacts are expected to be within radiological limits."

• Response: Section 4.13 in the Final PEIS has been expanded to include tables identifying the normal operation cumulative radiological doses and resulting health effects for the potential stockpile stewardship and management alternatives at each site alongside other potential site activities.

13.06

A commentor questions cumulative impacts associated with accidents. Specifically, the commentor questions the potential radiological impacts associated with earthquakes affecting multiple facilities.

• Response: For purposes of analyzing the potential cumulative environmental impacts associated with accidents, the information presented is based on the conservative assumption that the worst consequence accident for the activity has occurred, based on existing NEPA analyses.