20Stewardship--Contained Firing Facility

20 Stewardship--Contained Firing Facility

20.01

The commentor asks how much CFF will cost.

Response: Design and construction of CFF is expected to total $53 million. While cost and whether and how the President and Congress should allocate funds for CFF is outside the scope of the PEIS, cost is one of the many factors which will be considered by decisionmakers in the PEIS ROD as it relates to CFF.

21 Stewardship--National Ignition Facility

The commentors believe the technical justification for NIF in the PEIS is poor and not cogent and the facility will only benefit an elite few. Commentors believe that NIF is the least relevant alternative as far as safety and reliability and it will provide only marginal information on reliability. Commentors question whether there are alternative means of obtaining each of the categories of data that NIF is intended to provide. Another commentor asks if DOE could identify a single past safety or reliability issue that NIF would have the ability to evaluate. The commentor states that the PEIS does not acknowledge that DOE cannot assure high confidence in achieving ignition at NIF and that construction of NIF should be delayed.

Response: The President has declared that the maintenance of a safe and reliable nuclear weapons stockpile will remain a cornerstone of national security policy for the foreseeable future. Changes to U.S. national security policies in the post-Cold War have placed two significant constraints on the way DOE has traditionally accomplished its statutory nuclear mission: the United States has declared a moratorium on underground nuclear testing, and has stopped the production of new-design nuclear weapons. In August 1995, the President declared that the United States was seeking ratification of a zero-yield Comprehensive Test Ban Treaty (CTBT). Within these constraints, the proposed actions in the Stockpile Stewardship and Management PEIS will enable DOE to maintain the core intellectual and technical competencies necessary to ensure the continued safety and reliability of the stockpile under a CTBT. In this situation, the United States needs a comprehensive computational ability and a set of experimental facilities that can replicate conditions expected to occur within a nuclear detonation. NIF is one of those experimental facilities. It is a key component of the Stockpile Stewardship and Management Program and is necessary to help maintain confidence in the reliability of the nuclear deterrent.

As stated in the appendix section I.2.2, the purpose and need for NIF is to achieve fusion ignition and to use inertial fusion technology for helping nuclear weapons scientists maintain the safety and reliability of the nuclear weapons stockpile in the absence of nuclear testing. Therefore, NIF experiments can be used to verify computer models associated with the reliability of nuclear weapons and assess the impact of age- or remanufacture-related changes in the weapon. NIF would reach temperatures and pressures closer to those in a nuclear detonation than any other technology and is the only facility in the program capable of fusion ignition. This national security mission is the principal justification for NIF; it is necessary to help maintain confidence in the reliability of the nuclear deterrent. However, the high energy density experiments proposed to be performed at NIF would also help determine if inertial fusion can be developed as a practical energy source. The challenging science at NIF would help attract the best scientists and engineers to work on these issues of national importance (appendix section I.2.2.3).

The facilities for enhanced experimental capability would complement each other and produce more sophisticated and comprehensive computer models which would be able to provide data on all processes in the seven relevant physical regimes (appendix section I.2.2.2) that occur in weapons. NIF was designed to be a minimum-sized facility that has a reasonable probability of achieving ignition and the same ability to access high temperatures and densities that occur in weapons materials. NIF would address weapons processes that occur in five of the seven regimes, including some of the processes that occur in weapons' primaries and secondaries. The purpose of NIF is to study isolated phenomena in weapons in the stockpile. In the future, the complex interactions which occur in the detonation of a complete weapon would be investigated through advanced computer modeling.

There is a high probability that NIF would achieve ignition and an even higher probability that NIF would achieve its weapon physics mission. A 1990 National Academy of Sciences study, Second Review of the Department of Energy's Inertial Confinement Fusion Program, Final Report, September 1990 (1990 National Academy of Sciences study) (cited as NAS 1990 in appendix I), concluded that the probability of achieving ignition was great enough to justify proceeding with the next steps in designing such a facility. It also recommended that DOE establish a standing review group to continue tracking progress in target physics. That group, the Inertial Confinement Fusion Advisory Committee, has followed the program for more than three years and concluded (Inertial Confinement Fusion Advisory Committee Report, January 1996) that there is a high probability of achieving ignition if NIF is built as currently designed.

To fulfill its mission in stockpile stewardship, NIF is designed to achieve ignition and, in addition, to perform experiments at high temperatures and densities using the laser energy alone. Many of the needs of the weapons program can be met with these ignitionless experiments. Indeed, experiments are planned well before it is expected that ignition is likely to occur. Ignition would enhance NIF's capabilities for weapons studies but NIF is not necessary for many of them. In 1994, the JASONs group of independent academic scientists reviewed the science-based stockpile stewardship program and concluded that NIF is "... the most scientifically valuable of the programs proposed for SBSS [science based stockpile stewardship]..." In 1996 JASONs reiterated this position and stated its "... support for proceeding to the next step of achieving ignition with NIF because of NIF's expected value to science-based stockpile stewardship as well as its collateral scientific and energy interest." In summary, the Inertial Confinement Fusion Program and NIF have been reviewed by many independent expert groups, such as the National Academy of Sciences, Inertial Confinement Fusion Advisory Committee, and the JASONs, over the years and all have endorsed moving ahead quickly with a facility as currently designed.

A projection from past experience with the stockpile (Stockpile Surveillance: Past and Future, SAND95-2751, January 1996) indicates that there will be cases that will require a weapon scientist to make a judgment about a change that could affect safety or reliability. NIF would be able to help with many of them.

If NIF would not achieve ignition, the environmental impacts associated with construction would not change; however, the potential environmental impacts associated with operation could be smaller, but probably similar, to those presented in the PEIS. Delaying the construction of NIF would not cause any planned differences in the inertial confinement fusion R&D nor change the environmental impacts which are described in the PEIS.

21.02

A commentor notes that with respect to environmental impacts the public should be skeptical with the statement "... there will be no significant impacts." Another commentor notes that LLNL's environmental report claims "no significant impact" yet over a million Ci of radiation has been released in the air. The commentor states that 120 cancers and 60 cancer deaths resulted from the top 10 accidents that occurred at LLNL. A commentor points out that tritium levels in rainwater and drinking water in Livermore has been measured to be over seven times the acceptable level. The commentor also points out that plutonium-contaminated soil was discovered at a local playground.

Response: Over the past 40 years of operations at LLNL, tritium gas was released as a result of accidents and normal operations. The releases consisted of mostly tritium gas which is much less of a hazard to human health than tritiated water which can be absorbed more easily into the body. Additional information concerning radiological health impacts can be found in appendix section E.2 of the PEIS.

The 1994 LLNL Environmental Monitoring Report states that the tritium activity levels in drinking water in the Livermore Valley are less than 1 percent of the EPA drinking water standard. Over the past 40 years, there was one rainwater sample that read seven times the EPA guideline for tritium in potable water. This occurrence may have been caused by tritium releases during cleanup operations.

There is some groundwater (not drinking water) tritium contamination greater than EPA standards for drinking water under the eastern portion of the LLNL site. However, the tritium in this groundwater will decay (due to radioactive disintegration) to levels well below EPA standards before it leaves the site boundary. Therefore, it presents no health impact to humans or the environment. In addition, LLNL monitors the groundwater under the site on a regular basis (as reported in the annual LLNL Environmental Monitoring Reports) and can ensure that the public will not be exposed to tritium at levels that exceed EPA standards. Additional information concerning accidental release can be found in a report by Myers, et al., Health Physics Aspects of a Large Accidental Tritium Release, published in 1993.

Routine releases from NIF are estimated to be about 30 Ci/yr (0.003 g/yr), which is roughly 100 times lower than the routine average annual releases that took place from the LLNL tritium facility prior to 1989. Therefore, the use of standard risk coefficients for the extremely low doses and dose rates under discussion in the PEIS is at the least, extremely health conservative, and may, in fact, be significantly overestimating the risks (if any) associated with such low doses.

The commentor refers to levels of plutonium that were detected in soil samples taken from Big Trees Park in Livermore. The plutonium levels in two of the 16 areas sampled in the park were found to be above the normal range of global fallout levels (from aboveground nuclear weapons testing many years ago). The soil in this park was investigated for plutonium in 1995 as a joint effort among LLNL, EPA, and the California Department of Health Services. The investigation of park soils also involved various community stakeholders--the city of Livermore, the park and school districts, the local homeowners association, and Tri-Valley Citizens Against a Radioactive Environment. The investigation found that there is no soil at the park that has plutonium levels above the current EPA risk-based preliminary remediation goal of 2.5 pCi/g for residential areas. The EPA concluded that there is no health risk from this plutonium and that no remedial action is necessary.

21.03

Commentor wants to know what the key factors were in the NIF preferred alternative decision and if the timetable for NIF is the same as the PEIS.

Response: The Secretary of Energy stated in a press release in October 1994, "Lawrence Livermore National Laboratory was chosen as the preferred site because it contains the Nation's leading experts in large laser facilities. Lawrence Livermore National Laboratory has constructed five consecutive versions of the world's largest laser, including the currently operational Nova laser. The National Ignition Facility would be the successor to Nova. Alternative sites will be examined, and a final site selection will be not be made until completion of the National Environmental Policy Act process, which includes public meetings." In the letter approving Key Decision 1 (approval for start of a major new project), the Secretary supported the statement "The National Environmental Policy Act requires that any preference related to the siting of a facility be stated by the Department of Energy. Given the resident technical expertise and existing infrastructure at LLNL, we believe that Lawrence Livermore National Laboratory is preferable at this time to other candidate sites."

Following completion of the Final PEIS, but at least 30 days after it is issued, DOE will issue an ROD. The ROD will explain all factors, including environmental impacts, that DOE considered in its decisions for NIF. The timetable for NIF is within the envelope for the PEIS. It is anticipated that NIF would be constructed between late 1996 and 2002, with operations commencing in 2003.

21.04

Several commentors do not support NIF, a new experimental $4.5 billion facility, feeling that it is not the policy direction the United States should undertake and the public should inform elected officials that NIF is not necessary. Some commentors disapprove of the funding allocation on the basis that NIF competes for funds with cleanup programs and waste management. Other commentors feel it costs too much and the funds could be better spent on health care, social services, low-income housing, education, and infrastructure. Still others prefer funds spent on socially beneficial programs, such as conservation, renewable energy, and clean cars.

Response: The cost of NIF is estimated at $1.1 billion for construction (including escalation and contingency) through 2002. After construction is complete, NIF operating costs are anticipated to be $60 million per year (in fiscal year 1996 dollars) to provide approximately 600 experiments per year. The incremental cost of the Inertial Confinement Fusion Research Program is estimated to be $55 million per year (in fiscal year 1996). Cost is one of many factors which will be considered by decisionmakers in the ROD for NIF.

DOE has the responsibility for ensuring the safety and reliability of the downsized U.S. nuclear weapons stockpile, a policy priority for the President and Congress. Congress determines how the funds are allocated among programs.

21.05

Commentors believe that the discussion of NIF in the PEIS is inadequate in scope and content. A commentor believes that a reasonable range of alternatives is not provided for the NIF in the NEPA context. The commentors also question whether there are alternative means of obtaining each of the categories of data that NIF is intended to provide. A commentor states a fair and impartial environmental analysis of NIF, as required by NEPA, should include the extensive concomitant environmental impacts from the potential for nuclear weapons proliferation resulting from the spread of inertial confinement fusion technology and the environmental impacts from the successful deployment of fusion as a commercial power source. Several commentors state that in regard to the site-specific review of the various stockpile stewardship facilities, and NIF in particular, that it is inappropriate to include site-specific reviews in the PEIS.

Response: DOE believes that appendix I, the National Ignition Facility Project-Specific Analysis, was adequate. The NIF project-specific analysis assessed the direct, indirect, and cumulative environmental impacts of the proposed action (appendix section I.3.2), which is to construct and operate NIF (two operational options--Conceptual Design Option and Enhanced Option) and the No Action alternative (appendix section I.3.3). NIF was designed to be the minimum-sized facility that has a reasonable probability of achieving ignition and achieving its high temperature density weapon physics goals. No other known technologies are capable of achieving ignition and the high temperatures and densities that occur in weapons materials. Specifically, the pulsed-power technology alluded to in a commentor's letter is not a substitute for NIF capabilities. In general, high intensity laser facilities, like NIF, can achieve temperatures and pressures closer to those in a weapon than can pulsed-power facilities. On the other hand, pulsed-power facilities can put more but less concentrated energy on target than laser facilities, and are, therefore, able to follow certain phenomena for longer times, albeit at much lower temperatures. Thus, rather than providing the same capabilities, laser and pulsed-power facilities complement one another. There are no other design alternatives that would enable NIF to perform its intended mission, therefore, no others were assessed. Thus, the only alternatives that are judged reasonable are to build NIF or not to build it, and if so, where. These two alternatives were explained in detail in appendix I.

Section 1.5 of the PEIS explains the DOE NEPA strategy for the Stockpile Stewardship and Management Program. During the second phase of the NEPA strategy, which would follow the ROD, DOE would prepare any necessary tiered project-specific NEPA documents to implement any programmatic decisions. However, for the three facilities in the proposed action for stockpile stewardship--NIF, CFF, and Atlas--the Stockpile Stewardship and Management PEIS is intended to include sufficient project-specific analyses to complete NEPA requirements for siting, construction, and operation, and thus, satisfy both phases of the NEPA strategy. Including the project-specific analyses for the three facilities in the PEIS does not prejudice the programmatic review. In addition, the CEQ regulations do not preclude this approach.

NIF is not capable of being a prototype for a commercial inertial confinement fusion reactor. As stated in the Justification of Mission Need, the purpose of NIF is to achieve fusion ignition and to use inertial fusion technology for helping nuclear weapons scientists maintain the reliability of the nuclear weapons stockpile in the absence of nuclear testing. This national security mission is the principal justification for NIF. However, the high energy density experiments done at NIF would also help determine if inertial fusion can be developed as a practical energy source. In this context, obtaining ignition on NIF at the lowest laser energy possible would be an important set of experiments. If this is successful, other experiments would study target science that is applicable to any laser or particle accelerator driver that may be used in the future to study inertial confinement fusion as an energy source. NIF experiments could also provide the data necessary to design an engineering test facility, which would be the true engineering basis for a commercial reactor.

A comparative study of the four driver concepts under consideration (Laboratory Microfusion Capability Study Phase I Report, DOE/DP-0069, April 1989)--the solid state laser, the krypton flouride laser, the heavy ion accelerator, and the light ion driver--was done in the late 1980s for what was called the Laboratory Microfusion Facility. This study provided a technical analysis of each driver, a description of their respective research programs, their status, cost, and, in general, the features asked for in the above comment. The Laboratory Microfusion Facility was designed to achieve ignition and high gain, with fusion yields of 200 to 1000 megajoules (MJ), a much larger facility than NIF. During 1989 and 1990, the National Academy of Sciences reviewed the Inertial Confinement Fusion Program and all of these drivers. It was given the information from the previous comparative study. Some of the drivers required several intermediate facilities before the technologies would be mature enough to propose as the driver for a machine of the scale required. In its 1990 study, the National Academy of Sciences recommended that DOE plan on building an ignition facility (eventually this was called NIF) rather than the Laboratory Microfusion Facility and it recommended that DOE pursue this option quickly. Indeed, it suggested that start of the project be in 1992. Finally, the study also concluded that the only driver capable of achieving ignition within the next decade or so is the neodymium glass laser.

DOE accepted the recommendations of the 1990 National Academy of Sciences study and began concentrating resources on NIF, driven by a neodymium glass laser. Four inertial confinement fusion laboratories participated in the conceptual design study for a neodymium glass driven NIF. A prototype beamline of the NIF neodymium glass laser was built and tested successfully. While there has been progress in all driver technologies since the 1990 National Academy of Sciences study, it is clear that the neodymium glass laser's readiness to perform the NIF mission has grown faster than that of any other driver. Thus, for NIF's mission, the neodymium glass laser was judged to be the only reasonable option that would meet program goals.

The programs and facilities that make up the existing weapons program have evolved to their present state because of diverse technical, programmatic, and budgetary considerations. The present programmatic change is the need for improved science-basis to ensure the safety and reliability of our nuclear weapons within a zero-yield test ban. In the case of inertial confinement fusion, technical reviews by the JASONs and the Inertial Confinement Fusion Advisory Committee specifically questioned the technical status, issues, and activities mix of the program within the context of changed programmatic need. Neither the programmatic changes nor the technical reviews have provided any basis for defining a change in the existing program other than adding the significant new capabilities that NIF could contribute. The technical reviews provide a strong basis for continuing today's program and facilities except that the NOVA laser might reasonably stop operation after "NIF construction is well underway ..." (JASONs JSR 96-300 p.16).

Since there is no reasonable basis for defining an option for inertial fusion that is a reduction from today's program, no such option has been considered in the PEIS. Like most research programs, inertial fusion can be adjusted in pace and level of effort based on scientific findings or budget considerations. Any required changes in the program, including reductions, would be accommodated but there are no apparent break points for existing facilities and activities, in a programmatic or environmental sense, that suggest analysis of a particular reduced case.

The addition of an ignition facility to the program has been technically defined and endorsed since 1990. The addition of NIF is considered because it addresses science-based stockpile stewardship needs and is technically consistent with the logic and status of inertial fusion research. Technical reviews have not identified any alternatives to NIF for the mission needs. Any follow on facilities are, at present, too ill defined and speculative to analyze.

Issues such as the environmental impacts from nuclear weapons proliferation resulting from the spread of inertial confinement fusion technology and the environmental impacts from the successful deployment of fusion as a commercial power source are beyond the scope of the PEIS. Knowledge does not, in itself, have environmental impacts, and thus is not analyzed in the PEIS.

21.06

Many commentors support the NIF project on the basis of their perception that NIF would: 1) ensure world peace; 2) maintain a safe, reliable, and viable stockpile through science-based stewardship; 3) keep weapons scientists knowledgeable and equipped with the best available tools; 4) increase security of the United States; 5) continue the evolutionary process for eventual cessation of nuclear weapons and final disarmament; 6) not contribute to proliferation; 7) provide economic benefits; 8) create data on enhanced nuclear fusion energy; 9) help negotiations for the Nuclear Nonproliferation Treaty (NPT) and CTBT; 10) justify the need to eliminate underground nuclear testing; 11) create many employment opportunities in the region as a result of new fusion technology; and 12) have a benign environmental and safety impact with mitigation measures minimizing any possible impacts.

Response: The purpose of and need for the Stockpile Stewardship and Management Program, and NIF's role within a science-based stockpile stewardship program, are detailed in chapter 2 of the PEIS. The purpose of and need for the NIF project are detailed in appendix section I.2.1. NIF is one of the technologies that is enabling the United States to seek a CTBT. The study, The National Ignition Facility (NIF) and the Issues of Nonproliferation, Draft Study, Office of Arms Control and Nonproliferation, August 23, 1995 (citation: U.S. Department of Energy, 1995a in appendix I) concluded that NIF can contribute positively to the U.S. nonproliferation policy and arms control goals. NIF would perform a key role in ensuring the reliability of the Nation's nuclear weapons stockpile without the need for underground testing. Performing this function requires extensive research and experimentation in the areas of weapons physics and advanced computation that can only be provided at the proposed NIF. In addition, through the same scientific accomplishments resulting from stockpile stewardship, science and technological research endeavors can be advanced, including optics, lasers, materials, and measurement techniques, fostered by the challenges of constructing and operating this facility (appendix section I.2.3).

21.07

The commentors believe the NIF superlaser affords excellent nonweapons research opportunities into the potential of thermonuclear fusion energy without damaging the environment. Commentors believe advancing research into areas such as new energy sources are vital to our civilization considering there may be a lack of natural resources in the 21st century. A commentor states there is no programmatic discussion of the full Inertial Confinement Fusion Program and the follow-on facilities to NIF or other inertial confinement fusion programs in operation. Other commentors state NIF's justification of inertial confinement fusion as a commercial energy source is suspect because inertial confinement fusion cannot serve as the basis for a commercial reactor since it has high cost, low driver efficiency, and the needed repetition rate of target implosions cannot be obtained with neodymium glass lasers. The commentors also state that the NIF design should be modified to increase driver energy to a higher level to give a greater confidence that ignition could be achieved. A commentor believes that no nuclear waste will be generated because fusion will be studied, not fission. Another commentor notes that if NIF is to be used for civilian purposes like DOE claims, then let private companies compete for the funding for this program.

Response: Research opportunities and scientific and technological benefits would derive from NIF being a multipurpose, multi-use facility. NIF would be constructed for its national security and weapons research role, but it also would present the scientific community with a range of civilian applications. The unique properties of NIF are attracting a broad spectrum of interest from the international community for basic science applications. Although diverse programs of scientific and technological research have been conducted at large lasers in the United Kingdom, France, Germany, and Japan, information on equivalent research in the United States has been restricted because of past substantial classification requirements on much of the research and development associated with the Inertial Confinement Fusion Program.

Recent changes in U.S. classification guidelines have modified the atmosphere for research at NIF, with the result that U.S. scientists are designing programs of basic and applied research that could be accomplished openly at NIF. The NIF role in fusion energy would be to demonstrate ignition, optimize target gain curves, provide initial data on fusion reactor materials, and allow sound decisions to be made concerning inertial confinement energy development. These data would determine if inertial confinement fusion can be a viable source of electrical power in the future. NIF is not intended to be the basis for a commercial inertial confinement fusion reactor. The neodymium glass laser that would power NIF is recognized not to be a good candidate for a reactor. Several other drivers, including crystalline solid state lasers, krypton flouride lasers, heavy ion accelerators, and light ion diodes are under development. The National Academy of Sciences stated that ignition should be the next goal for inertial confinement fusion and that the only way to achieve that in the next decade or so is with a neodymium glass laser driver (1990 National Academy of Sciences study). The Inertial Confinement Fusion Advisory Committee stated that achieving ignition by any driver was the most important next step in development of inertial fusion energy.

NIF would also establish new capabilities in many other potential areas of study, including: astrophysics, hydrodynamics, material properties, plasma physics, radiation sources, radiative properties, and other potential applications, such as nonlinear physics, geophysics, other atomic physics applications, and optical physics. NIF could also spur high-technology industries in optics, lasers, materials, high-speed instrumentation, semiconductors, and precision manufacturing. Further discussion is included in appendix section I.2.3.

Any follow-on facilities to NIF are, at present, too ill defined and speculative to include. For accomplishing the mission of NIF, there are no reasonable alternatives.

Article IV of the NPT commits parties to facilitating the "fullest possible exchange of "... scientific and technological information" related to peaceful uses of nuclear energy. This commitment was included in the NPT at the insistence of nonnuclear weapons states that were concerned that they would suffer scientific and technological disadvantages compared to the nuclear weapon states.

Environmental impacts associated with the construction and operation of NIF are detailed in appendix sections I.4.1.2, I.4.2.2, I.4.3.2, I.4.4.2, and I.4.5.2. The comment that no nuclear work would be generated by NIF is incorrect; however, the small quantities of low-level radioactive wastes estimated to be generated by NIF can be handled by current or planned waste management capabilities at each alternative site for NIF.

21.08

The commentor suggests the unevenness of LLNL's early expenditure estimates, coupled with the rapid growth of spending a year ahead of when it would be expected to occur based on past projects, leads commentor to conclude that NIF may overspend early in the project cycle and may experience significant delays due to the attempt to "push" the project in the first four years.

Response: The proposed NIF funding profile is based on the annual funding necessary to construct a facility which begins operation in 2003. The apparent rapid growth of funding "a year ahead of when it would be expected to occur based on past projects" is required so that initial construction contracts and long lead procurements can be placed near the end of fiscal year 1997 for actual accomplishment during fiscal year 1998.

21.09

Commentors note that there are several varying estimates regarding the number of jobs which would be created each year by NIF and the regional economic impacts were misleading. One commentor notes that the regional economic impacts from building NIF cited in the Conceptual Design Report are inflated and misleading. According to the commentor, the regional economic effects of the construction and pre-operation of NIF will be small over the 7-year construction period. A large influx of construction employees during years 3, 4, and 5 of the construction period and a correspondingly large decrease in construction employees during 6 and 7 has the potential to create a boom-and-bust scenario in the Livermore region since approximately 1,200 people would move in and out during the last 4 years of the construction of NIF. The commentor states that the jobs will vary during each year of construction from 22 jobs the first year to 600 jobs the fifth year. The commentor contends that construction jobs would decrease to 120 by year 7 and only about 230 long-term jobs will stay at NIF.

Response: The socioeconomic analysis provides data on the peak number of jobs, in-migrating population, number of housing units required, increase in local jurisdiction (revenues and expenditures), and number of daily vehicle trips associated with the construction and operation of NIF. Several other sources have analyzed the impact of NIF on employment, and have reached different conclusions regarding the employment impact of the facility. The differences are attributable to different data, methodologies, and assumptions used in the studies. For example, the project-specific analysis supporting NIF in appendix I is of greater depth than that performed for the PEIS alternatives.

Socioeconomic impacts were measured using the latest version of RIMS II, an accounting framework model developed by the U.S. Bureau of Economic Analysis (section 4.1.8). The model is used by Government agencies, university researchers, and economists to measure economic impacts. The database used for the socioeconomic study was developed using the most recent information available from the Departments of Commerce and Labor, as well as financial reports provided by cities, counties, and school districts. The model estimates impacts occurring in the local area surrounding each site and those that occur in the regional and national economy as well. Appendix table I.3.6.1-1 provides a comparison of socioeconomic impacts across the five candidate sites.

Appendix section I.4.1.2.6 provides information on the effects of constructing and operating NIF at LLNL in the San Francisco Bay area economy. A number of related industries are located outside the San Francisco Bay area, and therefore, some of the economic benefits would be gained elsewhere in the U.S. economy. However, in terms of impacts across all industries that would provide inputs to NIF, the majority of employment created from construction at LLNL would occur in the San Francisco Bay area economy. The expected demand for housing for in-migrating construction workers is less than 2 percent of the housing units available, therefore NIF construction would not create a boom-bust effect in the local housing market (appendix section I.4.2.6). Text has been added in appendix I to explicitly address the issue of retained jobs.

The analysis performed for the NIF project-specific analysis (appendix section I.4.1.2.6) estimated that a total of 1,900 construction-related workers and their families would move into the LLNL area from the start of construction in 1996 to the peak in 1998. The project-specific analysis estimates that this would result in the demand for an additional 690 housing units in the area surrounding LLNL. Baseline projections show that 54,000 housing units would be available over this period in the local area, indicating that NIF-related in-migration would use less than 2 percent of locally available housing. It is unlikely, therefore, that NIF construction would create the boom-bust effect in the local housing market described by the commentor.

21.10

Commentors feel that jobs being created by NIF would be costly, not prosperous, come at the risk to other LLNL programs, ignore those created from technological inventions, and are at risk because of the annual budget process. Other commentors support NIF at LLNL and feel that NIF is a responsible project which would not be trivial work and should not be minimized.

Response: NIF would be a unique, state-of-the-art scientific facility whose primary mission would be to ensure the continued reliability of the nuclear weapons stockpile. Creating employment at the site chosen and for the surrounding economy is secondary to this objective. Many commercial facilities are likely to create more employment than NIF at a lower cost of investment, but many of these facilities do not have a research mission and none use comparable technologies. It is not, therefore, possible to compare the costs and benefits of NIF versus commercial facilities solely on the basis of the number of jobs created.

The estimates of employment impacts associated with NIF do not include the economic benefits of any additional new technologies and scientific enterprises that might result from experimentation at NIF and that could be transferred to the commercial sector. For example, no assessment was made of the potential economic benefits from a possible development of inertial fusion as a source of electrical power for use by the commercial sector. As the nature, scale, and timing of any future benefits of new technological and scientific developments associated with NIF are uncertain, these are not currently included in the assessment of economic impacts in the EIS.

As with any government research facility and program funded through the annual appropriation process, funding for NIF would be dependent on annual decisions by the President and Congress. The purpose and need for NIF are tied directly to U.S. decisions to maintain a safe and reliable weapons stockpile as a key element of the deterrence policy. In the appropriations process, all Government programs compete for funding based on their merits. There is no direct causal relationship between funding one program and an increase or decrease in funding for another program at the same site.

21.11

The commentor feels the construction of NIF will be delayed because the decision regarding NIF will drag on for the next few years.

Response: DOE has developed a timeline of numbered sequential Key Decisions, now known as critical decisions. This management system will be used to ensure the orderly progress of the proposed NIF project. The Secretary of Energy in Key Decision 0 (January 1993) affirmed the need for NIF. Key Decision 1 (October 1994) approved the preliminary engineering design and site evaluation. Critical decision 3, scheduled in 1997 after the PEIS ROD, would authorize construction and major procurements. Critical decision 4, scheduled in late 2002, would authorize operation and first experiments.

21.12

The commentors state that DOE cannot state that the radiological health threat of NIF is small with certainty from a threshold exposure basis. Commentors are concerned that the use of tritium and deuterium fuel at NIF will add to the amount of tritium and other toxic chemicals being released into the environment and create radioactive waste. Another commentor is concerned that plutonium-239 or tritium would be produced at NIF. Other commentors express confidence that NIF is a safe facility which is not hazardous to the environment and that they believe that LLNL will accept and diligently implement any mitigation measures contained in the NIF appendix.

Response: Appendix section I.3.6.7 summarizes and compares the radioactive and hazardous chemicals impacts from normal operations at NIF, a low hazard radiological facility, to the general public surrounding all candidate sites. Conservative assumptions were used to ensure estimated potential radiological doses were maximized in the PEIS analysis. The calculated doses were then multiplied by 0.0005 fatal cancers per rem to obtain radiological health effects, assuming no threshold exposure limits. Results indicated that no cancer deaths would occur among workers and in the general public due to construction and operation of NIF.

The maximum tritium effluent (atmospheric release) from normal operations would be 10 Ci/yr (0.001 g/yr) for conceptual design operations and 30 Ci/yr (0.003 g/yr) for enhanced operations (appendix sections I.3.2.2.1 and I.3.2.2.2). No latent cancers are projected from NIF's 30 years of operation at any of the candidate sites. The quantities of hazardous chemicals used are small and the only emissions would be from the small quantities of volatile materials used for optics cleaning.

Under the postulated accident conditions at any candidate site over the 30-year lifetime, the risk of radiation-caused cancer fatalities to the public would be essentially zero (less than 1 in 700,000) when the anticipated extremely low accident frequency during NIF operations is taken into account. Modeling of four release scenarios covering a wide range of nonradiological chemical releases for each candidate site for NIF revealed that offsite nonradiological impacts would be negligible and no fatalities would occur (appendix section I.3.6.7).

The fuel for NIF experiments would consist of a mixture of tritium and deuterium and the experiments would create small amounts of activation products. The ratio of the mixture of tritium to deuterium, however, has not been determined. The unignited fuel and any activation products would be removed from the target chamber as described in the NIF appendix (appendix section I.4.1.2.8.1) and disposed of according to established procedures. The amount of low level radioactive waste projected to be generated is small and it is analyzed in the PEIS (appendix section I.3.6.8) for all candidate sites. Although each alternative site would implement waste minimization practices, the generation of additional wastes would be unavoidable. All alternative sites have current or planned capacity to handle wastes associated with construction and operation of NIF; however, this would entail offsite shipment of some of the wastes for all sites, except at LANL.

Experiments that use fissile material, such as plutonium-239, have been postulated, but not defined. However, no experiments of this type are foreseen in planned NIF operations and thus are not considered in this document. Any future determination to conduct experiments that have implications beyond the currently defined operational envelope and safety analysis would require both additional safety analysis and NEPA action in addition to possible facility modifications. Additional information can be found in appendix section I.3.5 of the PEIS.

NIF would monitor the release of elemental tritium and tritiated water. In addition, the tritium air monitoring system would measure NIF tritium emissions as part of the total from all site operations. Since tritiated water is 25,000 times as toxic as tritium in the hydrogen gas form, the site monitoring system concentrates on measurement of tritiated water. These measurements would be peer reviewed and would be done in accordance with the procedures approved by the respective regulatory agencies.

NIF would be constructed and operated in compliance with all applicable statutes, regulations, and standards (see appendix section I.5). In addition, specific mitigation measures that the selected site would implement are addressed in appendix section I.4.7. If specific mitigation measures, monitoring, or other conditions are required, they will be adopted as part of the ROD.

21.13

The commentor states that a "total systems life-cycle-cost" study should be performed, and updated every few years, for NIF. This would be similar to what is required of the Yucca Mountain project under the Nuclear Waste Policy Act. Another commentor states that whatever the estimate of how much NIF is going to cost, the life-cycle cost will probably end up being greater than the estimate.

Response: The individual elements of the NIF life-cycle costs such as design, construction and equipment procurement, installation and inspection, start-up testing, environmental and safety reviews, operations, and D&D were estimated in the Conceptual Design Report, which is available in the DOE Public Reading Rooms near each site. These cost elements, except for D&D, were independently reviewed in 1994. The review of D&D costs was performed in 1996. DOE requires that all projects conduct a life-cycle cost study, though not in the depth and complexity of that performed for the Yucca Mountain project under the Nuclear Waste Policy Act. NIF would perform a life-cycle cost study as part of the design process. The life-cycle cost study would be updated if any significant assumptions change.

21.14

The commentor suggests that both the proposed areas considered for "laydown" or temporary staging of equipment, materials, and supplies at LLNL, in the construction of NIF, be designated in the project-specific assessment in appendix I. The commentor also suggests that the potential impacts of the staging of NIF construction equipment and supplies at LLNL, as well as the impacts of construction of the proposed NIF, also be addressed in appendix I, as well as in the PEIS text.

Response: The proposed areas considered for "laydown" or temporary staging of equipment, materials, and supplies at LLNL, in the construction of NIF, are designated in appendix section I.3.4.1.3 and shown in appendix figure I.3.4.1.1-2 of the project-specific assessment in appendix I. The potential impacts of the staging of NIF construction equipment and supplies at LLNL, as well as the impacts of construction of the proposed NIF are addressed in appendix section I.4.1.2, as well as in the main text of the PEIS. Discussions of this same topic are also included in the appropriate sections of appendix I for the other alternative sites for construction and operation of NIF.

21.15

Commentors believe that the purpose of NIF is to advance nuclear weapons research, science, design, development, and testing. Commentors believe new materials require new designs, as occurred from the 1960s through the 1980s, and the combination of new materials and NIF will help contribute to new designs today. One commentor states that it is already known and certified through nuclear tests that the secondaries will operate as designed, if driven by the test certified primary, and questions the need for NIF for stockpile stewardship. Another commentor thinks NIF will probably have a major role in weapons research and design, wants an analysis of the long- and short-term impacts. Another commentor states that because NIF will continue weapons development that the PEIS should evaluate the impacts of nuclear explosions. A commentor is concerned with NIF being like a "super-oven" and is opposed to it being sited at LLNL.

Response: The President has declared that the maintenance of a safe and reliable nuclear weapons stockpile will remain a cornerstone of national security policy for the foreseeable future. Changes to U.S. national security policies in the post-Cold War period have placed two significant constraints on the way DOE has traditionally accomplished its statutory nuclear mission: the United States has declared a moratorium on underground nuclear testing, and has stopped the development and production of new-design weapons. In August 1995, the President declared that the United States was seeking ratification of a zero-yield CTBT. Within these constraints, the proposed actions in the Stockpile Stewardship and Management PEIS will enable DOE to maintain the core intellectual and technical competencies necessary to ensure the continued safety and reliability of the stockpile under a CTBT. In this situation the United States needs a comprehensive calculational ability and a set of experimental facilities that can access the physical regimes that exist inside exploding weapons. NIF is one of those experimental facilities. The Stockpile Stewardship and Management Program was constructed with the national mission of maintaining U.S. security in response to requests from the President and Congress.

In the science-based stockpile stewardship program, NIF nuclear weapons research experiments can be used to verify increasingly sophisticated and comprehensive computer models and codes of the performance (reliability) of nuclear weapons and to assess the impact of changes in that performance due to age- or remanufacture-related changes in the remaining weapons stockpile in the absence of nuclear testing. This type of evaluation can be done for a weapon that has been tested before. NIF experiments, in combination with the existing nuclear test database, would be used in the computer calculations to determine if changes detected have an adverse effect on weapon reliability.

A study of the technical vertical and horizontal proliferation concerns surrounding NIF occurred between September 1994 and December 1995, including external reviewers, interagency coordination (DOD, Department of State, the Central Intelligence Agency, and the National Security Council), and public meetings. The unclassified results were published in the DOE document, NIF and the Issues of Nonproliferation Draft Study . In that study, the weapons design capabilities of NIF were extensively examined. It concluded that the development of new weapons requires integrated testing, such as occurs in nuclear explosive tests, in order to determine if the thousands of individual events interact properly. NIF by itself cannot perform such integrated testing of new concepts and, therefore, cannot replace nuclear testing for development of new nuclear weapons designs.

21.16

The commentor wants DOE to take a leadership role in preventing NIF from polluting the San Francisco Bay area.

Response: The construction and operation of NIF would not pollute the San Francisco Bay area. The analysis has shown that NIF would have no significant impacts to workers, the environment, or the public. The public would be exposed to a very small dose of radiation over the 30-year operating lifetime of NIF. No cancer fatalities would be expected to occur from exposures associated with routine operations (appendix section I.3.6.7). The release of volatile organic materials used for optics cleaning is small. All candidate sites have current or planned waste management capability to handle the wastes generated by operation (appendix section I.3.6.8).

21.17

Commentors feel that NIF will contribute to proliferation and lead to a less secure nation. Several commentors request that the short- and long-term nonproliferation aspects of NIF be further analyzed and included in the EIS. One commentor states that the detailed analysis in the report, National Ignition Facility and the Issue of Nonproliferation, does not support its conclusions. A commentor states there is no substantial analysis of the ongoing controversy on potential proliferation impacts of NIF. Another commentor believes that the only way NIF contributes to U.S. nonproliferation goals is by making the test ban acceptable to the U.S. weapons establishment. One commentor feels that discussions to determine the impacts of NIF on proliferation had occurred. A commentor states that the Draft PEIS does not have substantive detailed discussions about specific experiments NIF will do, such as studies of mixing of fissionable material into fusion fuel, on which to base a conclusion about NIF's worth and effect on nonproliferation.

Response: The Secretary of Energy committed the DOE's Office of Arms Control and Nonproliferation, an independent branch of DOE, which has no programmatic responsibility for NIF, to examine whether the facility would aid or hinder U.S. nonproliferation efforts before proceeding with substantial budgetary commitments to construct NIF. A study of the technical vertical and horizontal proliferation concerns surrounding NIF occurred between September 1994 and December 1995, including external reviewers, interagency coordination (DOD, Department of State, the Central Intelligence Agency, and the National Security Council), and public meetings. The original draft was classified so that all aspects of NIF operations could be analyzed. An unclassified version was then prepared and both versions were reviewed by seven independent experts in the technical, policy, and arms control fields to ensure accuracy, comprehensiveness, and consistency. The unclassified results were published in the DOE document, NIF and the Issues of Nonproliferation Draft Study and submitted to the Secretary of Energy for her decision. It concluded that the technical vertical and horizontal proliferation issues of NIF are manageable and can be made acceptable, and that NIF can contribute positively to the U.S. nonproliferation policy and arms control goals. DOE believes that the conclusions of the report are supported by the body of the report and the process that was followed assured that all views were accounted for and dealt with.

Article VI of the NPT calls for all of the parties to the NPT to "undertake to pursue negotiations in good faith on effective measures relating to cessation of the nuclear arms race at an early date and to nuclear disarmament, and on a Treaty on general and complete disarmament under strict and effective international control." NIF and other stockpile stewardship programs are designed to provide the United States with the confidence that its arsenal is adequately maintained during size reduction without testing.

The NIF and the Issues of Nonproliferation Draft Study does discuss, to the extent allowed by classification, the areas of weapons physics that can be addressed by NIF and the types of transparency and access control measures that can be used to assure support of the U.S. goals for nonproliferation. Detailed discussions, such as the mixing of fissionable material into fusion fuel, and its specific relevance to weapons physics issues remains classified. Such specific issues were addressed in detail in the classified version of the study and in classified discussions with the independent expert reviewers. These reviewers determined the conclusions of the unclassified report were supported by the full content of the study.

21.18

The commentor believes that NIF may contribute to exceedances of state standards for PM10 and VOC emissions and that complying with air quality standards will help sustain economic growth and vitality in the San Francisco Bay area. Therefore, the commentor recommends that NIF obtain offsets to mitigate its emissions of PM10 and VOC from operation even if they are not legally mandated.

Response: NIF would have small PM10 emissions during construction and small VOC emissions from operation largely from optics cleaning. Emission offsets will be provided for this project as required by air district regulation. California law prohibits any air district from issuing a permit which represents a growth in emissions after January 1, 1988. The air districts comply with this requirement by offsetting emissions from other sources. Each permit application is evaluated and offsets are provided from the Small Facility Bank, which is operated by the district or by the facility making the application in the form of emission reductions or emission banking certificates. Sources such as LLNL, with very small total emissions, may use the Small Facility Bank until their growth reaches a trigger level where the facility is required to offset all they have borrowed from the Small Facility Bank plus the emissions for the permit tripping the requirement. This offsetting policy provides for economic growth while at the same time reducing emissions. Facilities must offset to "permitted" emission levels and operate at "actual" emissions levels. The difference between "permitted" and "actual" levels is a reduction in the district's total emissions as required by California law. Also facilities may only obtain banking certificates for "actual" emissions while offsetting to "permitted" levels for their next project. This also provides for a reduction in emissions and is often referred to as the "transaction cost."

21.19

The commentor feels LLNL is not accurately reporting tritium in the yearly annual environmental report and values presented are underestimated. The commentor feels the tritium released from NIF will probably not be reported accurately as well. The commentor points out that the problem exists because the values reported represent contaminated water only. The commentor notes that tritium organically bound in organic surroundings, such as grass and tritiated water, is not being measured and it represents a hazard which is approximately 25,000 to 2,500,000 times more toxic than tritium gas.

Response: As described in the 1994 LLNL Environmental Monitoring Report, LLNL collects vegetation samples (usually annual grasses) quarterly from about 15 different locations throughout the Livermore, San Joaquin, and San Ramon Valleys. Vegetation samples are analyzed using a freeze-drying method, which removes essentially all of the water (which would, of course, include any tritium) from the sample. It is possible that some small fraction of tritium in the vegetation may be "organically bound," and not recovered in the freeze-drying process. However, this small fraction of unrecovered tritium would not add significantly to the amount of tritium reported. These measurements have been peer reviewed and are completely accepted by state and Federal agencies.

NIF would emit less than 30 Ci/yr (0.003 g/yr) of tritium. The impact of this small release to the public or the environment would be negligible. NIF would continuously monitor the release of elemental tritium and tritiated water. The LLNL sitewide monitoring system will monitor tritium emissions as part of the total from laboratory operations.

21.20

Commentors ask how LLNL became the preferred site, several encourage a Federal decision to proceed with NIF at the LLNL site because of the site's advantages and the analyses of environmental impacts showing any adverse impacts are generally not significant. Commentors desire to know if there was any possibility that NIF may come to NTS or LANL. Commentors are troubled by political siting decisions, including that elected officials lobby for NIF at LLNL on the basis of jobs and economics.

Response: Five locations (LLNL, LANL, NTS, North Las Vegas Facility [NLVF], and SNL) are considered in the PEIS for the NIF based on a two-step process for selection (appendix section I.3.4) and DOE has assessed the impacts of constructing and operating NIF at all of the candidate locations at the candidate sites. The PEIS provides information to decisionmakers and the public to allow a comprehensive assessment of the purpose and need, and to compare potential environmental impacts of constructing and operating NIF at all of the candidate sites. In the ROD, the Secretary of Energy will make a final site selection taking into account the results of the PEIS and other considerations such as cost differences, availability of scientific and technical personnel, and capability of facility infrastructure to support NIF. In the ROD, to be published at least 30 days after the Final PEIS is completed, DOE will explain all the factors, including environmental impacts, that DOE considered in reaching its decision on siting NIF.

In her October 20, 1994 approval letter for Key Decision 1, Energy Secretary Hazel O'Leary announced LLNL as the preferred site (appendix section I-5.6) because of its prominence as a leading center for laser science, engineering, and technology. LLNL has the required combination of existing facilities, equipment, infrastructure, and technical and management personnel required. The other weapons laboratories, SNL and LANL, meet all of the criteria, but not to the extent of LLNL. NTS meets four of the five primary siting criteria, lacking only a significant inertial confinement fusion infrastructure.

The environmental analysis for the construction and operation of NIF at each of the alternative sites is described in appendix sections I.4.1.2, I.4.2.2, I.4.3.2, I.4.4.2, and I.4.5.2. Impacts to human health from NIF operations would be within regulatory limits. NIF would be operated in accordance with applicable statutes, regulations, and standards (appendix section I.5) and enacting appropriate mitigation measures, including the development of a monitoring and mitigation plan which accompanies the ROD.

22 Stewardship--Atlas Facility

22.01

The commentor asks why a new Atlas Facility is under construction in Los Alamos when DOE already has an Atlas Facility in North Las Vegas, NV. The commentor questions why both are needed if they are the same. If they are different, the commentor states, the name of the new one should be changed to avoid confusion.

Response: The two facilities are not the same and have different purposes. The Atlas Facility in North Las Vegas was developed by LLNL from a plan called the Augmented Test Logistics Assembly System (ATLAS). The purpose of the facility was to provide a location for canister fabrication, instrumentation preparation, and other prestaging operations prior to vertical emplacement for underground nuclear testing at NTS. These activities were related to mechanical operations of the past experimental program. As a potential future stockpile stewardship facility, the purpose of Atlas at LANL is to perform high-energy pulsed-power experiments to simulate certain hydrodynamic and radiation effects and to predict the effects of aging on the weapons in the existing stockpile.

22.02

The commentor states that the description of the Atlas Facility is limited in both the executive summary and in section 3.3.2.3 of Volume I. Commentor recommends that DOE expand the discussion of the uses of the facility since it is unclear and, therefore, difficult to review the potential environmental impacts.

Response: A detailed description of the Atlas Facility and its potential environmental impacts and accidents are included in appendix K, Volume III of the PEIS.

22.03

The commentor states that the Atlas Facility is not needed because defects in secondaries (the primary area of research for Atlas) are quite rare. The commentor, noting that the Pegasus II Facility is used for up to 24 experiments annually while Atlas is supposed to perform up to 100 experiments, asks what is the need for the dramatic rise in experiments.

Response: This stockpile stewardship facility would be used to gauge the safety and reliability of weapons in the enduring stockpile. As noted in section 2.3.3, of the approximately 400 defects which required some corrective action since 1958, 110 were in the nuclear package. Of these the majority (approximately 90) were indeed associated with the weapon primary. However, the remaining number were still associated with the weapon secondary. The lower frequency of these relative to the primary related defects does not imply that DOE need not develop capabilities to address such defects, which might otherwise compromise stockpile reliability, when they arise. The existing weapons will age beyond the point in which DOE has historical experience. Furthermore, even defects which are determined to not require corrective action would have to be evaluated by DOE through the stockpile stewardship program including relevant experiments such as those for which Atlas is proposed.

There is no correlation between the number of experiments conducted annually at the Pegasus II Facility and the design capacity for Atlas because Pegasus II currently supplies limited data regarding weapons physics and Pegasus II's power capacity is insufficient to reach the conditions necessary for experiments planned for Atlas. Pegasus II, which was developed before the cessation of nuclear testing, does not readily support larger numbers of experiments because of operational procedures related to the facility design. The capability of Atlas to support up to 100 experiments per year, to meet anticipated programmatic needs, would be enabled by the design of that new facility.

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