



The commentors suggest that underground
testing should be resumed and/or that the capability to resume
nuclear testing should be maintained. Commentors state that the
proposed stewardship facilities are new and unproven and are skeptical
about the future safety and reliability of the Nation's stockpile
without underground testing at NTS. Other commentors state that
the United States is required by the National Defense Authorization
Act to maintain a readiness posture, and that to be without testing
capability with the possibility of unanticipated international
developments would be unrealistic and perhaps foolhardy. Other
commentors feel that the capability and reliability of our nuclear
weapons will be greatly reduced without underground testing, and
that the effects of changes or modifications to weapons can only
be verified through testing.
- Response: As part of the August 1995
announcement to pursue a CTBT, the President stated that he had
been assured "that we can meet the challenge of maintaining
our nuclear deterrent under a Comprehensive Test Ban Treaty through
a science-based stockpile stewardship program without nuclear
testing." However, the President cautioned that, "while
I am optimistic that the stockpile stewardship program will be
successful, as President I cannot dismiss the possibility, however
unlikely, that the program will fall short of its objectives."
The President went on further to say that, "In the event
that I were informed by the Secretary of Defense and Secretary
of Energy... that a high level of confidence in the safety or
reliability of a nuclear weapons type which the two Secretaries
consider to be critical to our nuclear deterrent could no longer
be certified, I would be prepared, in consultation with Congress,
to exercise our `supreme national interests' rights under the
Comprehensive Test Ban Treaty in order to conduct whatever testing
might be required."
Thus, it is possible--although not probable--that under a CTBT,
the United States might one day exercise its "supreme national
interests" rights to conduct underground nuclear testing
to certify the safety and reliability of its nuclear weapons.
Consequently, section 4.12 of the PEIS includes a programmatic
evaluation of the environmental impacts of underground nuclear
testing at NTS.
The commentors question the rationale, timing,
purpose, and need for planned subcritical testing at NTS. One
commentor believes that the Draft PEIS fails to consider the programmatic
decision on whether to proceed with proposed subcritical hydronuclear
experiments as part of the Stockpile Stewardship and Management
Program and, if so, where to conduct such experiments. The commentor
also believes that the proposed subcritical tests are clearly
part of DOE's Stockpile Stewardship and Management Program and
that there is no justification for failing to analyze the proposed
subcritical tests in the Draft PEIS. Specifically, the commentors
are concerned about the need for these tests since the stockpile
has been certified to be safe and reliable as recently as November
1995. One commentor asks if subcritical tests are included in
the NTS Site-Wide EIS. Other commentors express concern that these
tests would be seen internationally as nuclear tests, and that
they may affect the Russian elections and the CTBT. One commentor
states that weapon configurations could result in fission yields
that, while small, would nevertheless contradict the express goal
of achieving a zero-yield CTBT. Another commentor states that
subcritical testing is a necessary component of the stockpile
mission and can only be performed at NTS. Other commentors state
that the PEIS does not adequately consider or analyze these tests,
that they should be included in the Final PEIS, and that the tests
should be postponed if necessary for inclusion. One commentor
states that these tests are necessary, but should be carried out
at LANL or LLNL, not NTS. Another commentor questions whether
the subcritical tests are a legitimate interim action.
- Response: DOE believes subcritical experiments
do not constitute a new activity at NTS. In addition, the Lyner
Complex is not a new facility. Subcritical experiments have been
conducted at
- NTS over many years. Historically, operations
at NTS have included tests or experiments that included both HE
and special nuclear materials that were intended to produce no
nuclear yield or negligible nuclear energy releases. These experiments
frequently remained subcritical (i.e., they did not achieve a
self-sustaining fission chain reaction). They were often performed
as dedicated, stand-alone experiments. Such experiments were described,
for example, as one point safety tests and equations of state
tests, and, in the prior terminology, were included under the
broad umbrella of nuclear testing since testing with nuclear explosive
yield was the predominant activity. Some of these earlier subcritical
experiments were conducted on the surface while others were conducted
underground in shafts, shallow boreholes, and tunnels. However,
environmental considerations resulted in a decision to conduct
these experiments only underground so that radioactive materials
would not be introduced into the surface environment. The environmental
impacts of the surface experiments were principally due to dispersal
of special nuclear materials, such as plutonium, and other materials,
by the detonation of HE. Subcritical experiments were mentioned
in environmental statements prepared by the predecessors of DOE
in the early 1970s, as well as in the 1977 NTS EIS under the names
mentioned above.
DOE is considering conducting the subcritical experiments referenced
by the commentor in the Lyner Complex. Initial work on what is
now known as the Lyner Complex began in the late 1960s, but it
was not used at that time. Further work took place in the 1980s
and early 1990s to develop a complex that could be used to perform
intentionally designed low-yield tests or experiments, which,
among others, would have included some experiments which would
be expected to remain subcritical or provide negligible energy
release. The Lyner Complex was completed under the 1977 NTS EIS
and was subsequently used for testing purposes. With the moratorium
on nuclear testing and the anticipated CTBT, Lyner will be dedicated
solely to the conduct of dynamic experiments (including subcritical
experiments) and hydrodynamic tests.
The term, "subcritical experiments," does not define
a new form of activity at NTS. The use of the term is intended
to clarify the fact that such experiments could not achieve the
condition of criticality and that they would meet current and
prospective U.S. commitments to the moratorium on nuclear testing
and the anticipated CTBT. Although the specific term "subcritical"
was not used in the previous EISs, some tests and experiments
conducted over the past four decades, as well as the impacts of
those tests and experiments, are substantially the same as those
contemplated by the new terminology.
The principal diagnostic tools that DOE currently uses to study
nuclear weapons primaries are hydrodynamic tests and dynamic experiments.
The PEIS identifies that DOE, under the No Action alternative,
would continue to use testing facilities currently available at
NTS and the national laboratories. Additionally, section 3.1.2
of the Final PEIS has been expanded to discuss the issue of subcritical
testing.
Note that nuclear detonation does not occur with subcritical testing.
The environmental impacts of these tests are well within the previous
operational impacts at NTS and are bounded by analyses performed
in the NTS Site-Wide EIS as well as this PEIS. The remoteness,
large size, and infrastructure at NTS make it a logical location
to conduct these experiments.
An analysis of subcritical tests is included in the NTS Site-Wide
EIS as part of the continue current operations (No Action) alternative.
The impacts which result from operation of the Lyner facility
are analyzed in chapter 5, and a description of the facility is
located in appendix A of the NTS Site-Wide EIS. Further Lyner
Complex details are addressed in a classified appendix to the
NTS Site-Wide EIS.
Subcritical experiments are a long standing part of NTS's mission
and DOE believes that the provisions of CEQ regulations regarding
interim actions are inapplicable to a decision by DOE whether
to continue conducting these experiments at NTS after completion
of the NTS Site-Wide EIS. In the Stockpile Stewardship and Management
PEIS, DOE is proposing ways to augment the existing nuclear weapons
stockpile stewardship program for the specific purpose of accommodating
the lack of underground nuclear testing, rather than reconsidering
the entire stewardship program. Ongoing activities, such as the
subcritical experiments at NTS, that are not affected by the decisions
to be made in the Stockpile Stewardship and Management PEIS process
are not interim actions under the regulations. Therefore, if DOE
decides to conduct subcritical tests at NTS in the future, that
decision will be made after considering the analysis contained
in the NTS Site-Wide EIS, and will be documented in an ROD for
that EIS.
Several commentors ask about the circumstances
and people responsible for making the recommendations to resume
underground nuclear testing under the "supreme national interest"
clause of the CTBT. Specifically, who could make the decision
to resume testing and how the decision would be implemented if
the stockpile were judged to be unreliable. Commentors are specifically
concerned about the pressures experienced by laboratory directors
while making the certification of reliability, and what other
options were available to them instead of resuming underground
nuclear testing. Another commentor is concerned that the responsibility
for certification of nuclear weapons rests solely in the hands
of the weapons laboratories, with no outside review by unbiased
parties.
Several commentors state that nuclear deterrence
is necessary and must be maintained and that having a nuclear
deterrent permitted the nonproliferation process to work and put
the United States in a position to promote peace. Commentors state
that our safety and national security has been based on our deterrence
policy and that our technological advances, particularly those
made by LANL and LLNL, led to the collapse of the Soviet Union.
Other commentors state that nuclear deterrence provides for common
worldwide security and that a deterrent remains necessary in light
of the threats from other nations and terrorist groups.
The commentors believe that DOE is assuming
a nuclear war-fighting posture instead of a deterrence posture,
that U.S. policy relies on violence and that this threatens the
rest of the world. Other commentors state that the Stockpile Stewardship
and Management Program is driven by the Nuclear Posture Review
(NPR), which is based on U.S. first-strike capability, and that
DOE has coupled the terms "deterrence" and "first-strike"
in order to diminish the difference between the two. Another commentor
states that the PEIS did not clearly state if the Stockpile Stewardship
and Management Program is only intended to maintain nuclear retaliation
capability, and how it would compare two strategies based on first-strike
capability or retaliation against a non-nuclear adversary. Other
commentors believe that the safety of the weapons is not in question
and that DOE is orienting the Program towards examining the explosive
yield of the weapons or towards designing new and/or improved
weapons. The commentor states that the deterrence would be just
as effective with a lower yield weapon. A commentor feels that
DOE should develop skills of mediation to be used nationally and
universally, instead of threats of weapons and military might,
where everyone loses and nobody wins. Other commentors express
opposition to the Program stating that we need to wage a war of
peace and have a Department of Peace in this country. Another
commentor wants to stop the connection between technical research
and development and war and killing, stating that if our scientists
would benefit from the development of a super computer then it
should be placed in one of our great universities, hospitals,
or at the Peace Institute and not used for new bomb making.
The commentors state that nuclear weapons
are not a deterrent; do not maintain peace; are unnecessary, immoral,
and unethical; and should be eliminated. Commentors also state
that the United States should pursue a policy of complete national
and worldwide disarmament and denuclearization, and these options
should be considered in the PEIS. The commentors state that these
policies would strengthen our national security and our international
relations, particularly with respect to our treaty obligations,
and that most people worldwide favor the elimination of nuclear
weapons. Commentors feel that the United States needs to lead
by example and to encourage the rest of the world to follow our
lead in disarmament, and that this is the only course of action
that will result in nonproliferation. Other commentors state that
it is this action that will result in nonproliferation. Other
commentors state that the creation and/or maintenance of jobs
is not an adequate excuse to continue to build nuclear weapons.
One commentor cites the successful disarmament of mustard gas,
nerve gas, and antipersonnel weapons as examples for the nuclear
weapons industry to follow.
The commentors state that the proposed Stockpile
Stewardship and Management Program, and specifically the proposed
stewardship facilities, violate existing and proposed treaties,
specifically the CTBT and NPT, and agreements on nonproliferation.
The commentors believe that these facilities will lead to new
and more powerful weapons designs, continued weapons testing,
increased competition among nuclear weapons states, advancement
of weapons technology, and provide the impetus and capability
to other countries and terrorists to develop nuclear weapons.
One commentor states that DOE has decoupled the terms "design"
and "development," and "nonproliferation"
and "disarmament" and that the United States says there
are no plans to produce new weapons but that design activities
continue. Commentors also state that the Program will give other
nations the impression that the United States is moving forward
in its nuclear weapons program (e.g., W-76 re-certification, W-88
pit rebuild, and B-61 Modification 11) and is therefore encouraging
others to continue with weapons development as well. Commentors
state that the long- and short-term nonproliferation impacts have
not been fully addressed and analyzed in the PEIS. Other commentors
point out that in their view, reestablishing pit fabrication at
LANL is against nonproliferation goals and the spirit of the treaties.
One commentor states that the nuclear weapons life-extension program
is contrary to the NPT. Another commentor feels that the United
States should lead the way internationally in START I and II,
CTBT, NPT, and all future "nuclear deterrence treaties."
International oversight of the stockpile stewardship program could
help solve nonproliferation concerns, according to one commentor.
In addition, commentors believe that the
PEIS fails to mention that the stewardship program will be used
to maintain the expertise of weapons development, research, design,
testing, prototyping, and certification. One commentor states
that the rationale for designing new weapons to keep the scientists
from getting rusty is not enough to warrant continued design of
weapons. Another commentor believes the PEIS should consider a
future treaty that may require DOE to disclose whether or not
the stewardship program does weapon designing. The commentor believes
that DOE should separate the advancement of the science of nuclear
weapons from the maintenance work. The commentor also states that
we do not need to alter the designs to meet new challenges from
other countries.
- Response: The issue of nonproliferation
is addressed in section 2.6. As stated in that section, on August
11, 1995, the President announced his commitment to seek a zero-yield
CTBT. He also established several safeguards that condition U.S.
entry into a CTBT. One of these safeguards is the conduct of science-based
stewardship, including the conduct of experimental programs. This
safeguard would enable the United States to enter into such a
treaty while maintaining a safe and reliable nuclear weapons stockpile
consistent with U.S. national security policies.
One benefit of science-based stockpile stewardship is to demonstrate
U.S. commitment to NPT goals; however, the U.S. nuclear posture
is not the only factor that might affect whether or not other
nations might develop nuclear weapons of their own. Some nations
that are not declared nuclear states have the ability to develop
nuclear weapons. Many of these nations rely on the U.S. nuclear
deterrent for security assurance. The loss of confidence in the
safety or reliability of the weapons in the U.S. stockpile could
result in a corresponding loss of credibility of the U.S. nuclear
deterrent and could provide an incentive to other nations to develop
their own nuclear weapons programs.
The experimental testing program would continue to be used to
assess the safety and reliability of the nuclear weapons in the
remaining stockpile. Much of this testing is classified and could
not lead to proliferation without a breach of security. Use of
classified data from past U.S. nuclear tests is also a vital part
of the overall process for validation of new experimental data.
Most of the component technology used for the proposed enhanced
experimental capability is unclassified and is available in open
literature, and many other nations have developed a considerable
capability.
Proliferation drivers for other states, such as international
competition or the desire to deter conventional armed forces,
would remain unchanged regardless of whether or not DOE implemented
the proposed action analyzed in the PEIS. In the NPT, the parties
agree not to transfer nuclear weapons or other devices, or control
over them, and not to assist, encourage, or induce nonnuclear
states to acquire nuclear weapons. However, the treaty does not
mandate stockpile reductions by nuclear states, and it does not
address actions of nuclear states in maintaining their stockpiles.
Section 3.1.2 of the Final PEIS has been expanded to address these
issues. As explained in that section, the national security policy
framework discussed in this PEIS seeks a new balance between U.S.
arms control and nonproliferation objectives and U.S. national
security requirements for nuclear deterrence while pursuing these
objectives (section 2.2). In addition, a discussion is provided
on some of the more difficult issues that must be considered in
determining the balance, including a discussion of experimental
capability (section 2.6). In particular, the issue of nonproliferation
and the proposed NIF was studied in detail. The NIF and the Issues
of Nonproliferation Draft Study, prepared by the DOE Office of
Arms Control and Nonproliferation, has been the subject of extensive
public involvement, interagency review, and review by outside
experts. The study concluded that the technical proliferation
concerns of NIF are manageable and can therefore be made acceptable
and that NIF can contribute positively to U.S. arms control and
nonproliferation policy goals (appendix section I.2.1 of Volume
III). NIF is a proliferation concern because of its broader scientific
applications and expected frequent use by researchers worldwide
and, like the other proposed enhanced experimental facilities,
because of its possible relevance to the development of new weapon
designs. However, the development of new weapon designs requires
integrated testing. None of the proposed facilities, either alone
or together, could perform such integrated testing of new concepts
and, therefore, cannot replace nuclear testing for the development
of new weapon designs. The national security policy framework
and the technical issues that drive the proposed action for enhanced
experimental capability remain the same.
DOE is directed to maintain nuclear weapon capability, including
the capability to design, develop, produce, and certify new warheads.
In addition, maintenance of the capability to certify weapon safety
and reliability provides a limited inherent capability to design
and develop new weapons. However, no new-design nuclear weapon
production has been directed. DOE has not advanced a rationale
of new weapon design "to keep scientists from getting rusty."
Instead, DOE has advanced a comprehensive program of stockpile
stewardship and management which maintains essential capabilities
for stockpile safety and reliability while meeting other legal
and policy directives.
Regarding the comment on the Life Extension Program, the Nation
is no longer developing new-design weapons to replace existing
weapons. Consequently, weapons' lifetimes are expected to extend
beyond their original design goal of about 20 years. In accordance
with our international treaty obligations, the Nation's nuclear
weapons stockpile is being significantly reduced, and the Nuclear
Weapons Stockpile Memorandum (NWSM) accounts for these reductions.
The Life Extension Program is a term used to describe the planning
activities which ensure that the nuclear weapons remaining in
the stockpile will continue to be safe and reliable. The Life
Extension Program is consistent with the NWSM and our international
treaty obligations.
Regarding comments that enhanced experimental capabilities are
directed more at the capability to design new weapons in the absence
of nuclear testing than at maintaining the safety and reliability
of the existing stockpile, this PEIS explains why these capabilities
are needed to maintain the safety and reliability of a smaller,
aging stockpile in the absence of nuclear testing (chapter 2).
The existing U.S. stockpile is highly engineered and technically
sophisticated in its design for safety, reliability, and performance.
The stewardship capabilities required to make technical judgments
about the existing stockpile are likewise technically sophisticated;
therefore, it would be unreasonable to say that these stewardship
capabilities could not be applied to the design of new weapons,
albeit with less confidence than if the weapons could be nuclear
tested. The development of new weapon designs requires integrated
nuclear testing such as occurs in nuclear explosive tests. Short
of nuclear testing, no single stockpile stewardship activity,
nor any combination of activities, could confirm that a new-design
weapon would work. In fact, a key effect of a zero-yield CTBT
would be to prevent the confident development of new-design weapons.
National security policy requires DOE to maintain the capability
to design and develop new weapons, and it will be a national security
policy decision to use or not use that capability. Choosing not
to use enhanced experimental capability for new weapon designs
would not change the technical issues for the existing stockpile
and, therefore, the stewardship alternatives would not change.
- The issue of new-design weapons is separate
from DOE's need to perform modifications to existing weapons that
require research, design, development, and testing. The phrase
used in this PEIS, "without the development and production
of new-design weapons," is meant to convey the fact that
the historical continuous cycle of large-scale development and
production of new weapons designs replacing older weapon designs
has been halted. For example, during the 1980s, about a dozen
new-design weapons were in full-scale development or production.
Over the decade, production of new-design weapons replaced dismantled
weapons nearly one for one. Today, only modifications to parts
of existing weapons are being performed or planned; dismantlement
has continued. This results in a smaller aging stockpile that
must be assessed and certified without nuclear testing. This is
now the primary focus of the stewardship program.
Some commentors believe that there was no
willful collusion among laboratories to further their weapons
complex activities; however, the commentors question the ability
of the proposed plan to get the job done. A number of commentors
believe that political and laboratory interests were influencing
the Stockpile Stewardship and Management Program plan and alternatives
and that the focus should be on national security and not politics.
Commentors state that the laboratory scientists and contractors
responsible for developing the program were using "inside"
and classified knowledge and influence to advise decisionmakers
on furthering their weapons program activities while reducing
the manufacturing mission at production plants, and that this
could have detrimental long-term effects. A commentor states that
the PEIS attempts to justify the stewardship facilities which
will primarily benefit the western laboratories, which already
provide redundant capabilities. Another commentor refers to the
statement made by Dr. Smith to the Armed Forces Subcommittee that,
"Today, we do not have the capability to manufacture replacements
for warheads that comprise our existing stockpile," and questions
why DOE was proposing to slash production capabilities while building
up basic programs at the weapon laboratories. Other commentors
believe that there were others, such as retired scientists and
experts, who should be involved in the study and that the focus
on the laboratories and their input was a mistake.
- Response: Production and laboratory
functions are different, but the difference is reduced as the
size of the production requirements becomes smaller. The first
atomic weapons were not only designed but also constructed at
the weapons laboratories. The laboratories have always had the
capability for small lot production principally in order to test
out designers' theories. In some respects, this could be considered
an advantage by increasing the synergism between the two activities.
Based on the environmental, cost, and technical analyses that
have been performed, the preferred alternative is to downsize
the stockpile management functions at ORR, KCP, and Pantex, and
not transfer them to the laboratories and NTS.
In the PEIS preferred alternative, the only "production capability"
which is being considered for one of the national weapons laboratories
is the reestablishment of pit fabrication. This function does
not presently exist within the Complex and has not existed for
some time due to the 1991 shutdown and subsequent closing of the
Rocky Flats Plant. Two sites were considered as alternatives for
the pit fabrication mission: LANL, which already has an active
program involving both fabrication and recovery of plutonium and
has fabricated pits for nuclear explosive testing, and SRS, which
has separated and produced plutonium metal from reactor targets
and has recovered plutonium from scrap materials. Analysis discussed
in the Analysis of Stockpile Management Alternatives report
shows that the LANL alternative is lower in cost and has less
technical risk than the SRS alternative. Technical risk is greater
for the SRS alternative because LANL has recent experience in
providing pits for nuclear explosive testing, whereas SRS has
no experience with the kind of capabilities required for precision
nuclear component manufacturing. Additionally, the LANL capability
could be in place two years earlier than the SRS capability. The
Analysis of Stockpile Management Alternatives report
is available for public review at the DOE Public Reading Rooms
near each site.
It is true that projected needs may actually turn out to be higher
or lower than the actual needs. This is one reason why the downsize-in-place
alternative is the preferred option for most stockpile management
missions. The proposed action for stockpile management would downsize
facilities over a number of years, but this action can be reversed
if necessary.
In the event science-based stewardship proposals could not assure
the continued safety and reliability of the nuclear weapons stockpile,
the resumption of underground testing at NTS would be considered.
On August 11, 1995, the President stated that if he was informed
by the Secretaries of Defense and Energy that a high level of
confidence in the safety or reliability of a nuclear weapons type
considered critical to the nuclear deterrent could no longer be
certified that he would be prepared, in consultation with Congress,
to exercise our "supreme national interests" rights
under the CTBT to conduct whatever testing might be required.
Chapter 2 of the PEIS discusses the national security policy considerations
and the role they play in defining the purpose of and need for
the Stockpile Stewardship and Management Program. DOE participates
regularly in Congressional hearings on defense issues in which
the stockpile stewardship and management issues are discussed.
Congress determines how funds are allocated, and DOE spends monies
consistent with Congressional direction. Therefore, Congress ultimately
determines whether the preferred alternatives of the program will
be implemented.
The majority of the U.S. core competencies and capabilities in
nuclear weapons reside at the weapons laboratories. Proposing
to locate new stewardship facilities at the weapons laboratories
and NTS would expand existing facilities at sites with an experienced
knowledge base and infrastructure and would help maintain the
core intellectual and technical competencies of the weapons laboratories.
Proposing to locate stewardship facilities at sites without the
knowledge base and infrastructure would be counterproductive to
the development of science-based stockpile stewardship.
One commentor refers to an article in the
New York Times in February that stated DOE was having trouble
verifying that sources of weapon grade materials in Russia were
actually coming from the dismantlement of weapons. The commentor
suggests that DOE not only look at downsizing, but look at what
they are going to do in terms of verifying sources of weapons
grade materials in Russia.
The commentor would like DOE to consider
site location (proximity to population centers) in the decisionmaking
process and urges DOE to perform their missions somewhere else.
Several commentors express concern about
the optimism of world peace in the future and that we are not
protecting the option that the world might revert to a more hostile
place. Commentors state that the laboratories need to maintain
a complete understanding of nuclear weapons, particularly in light
of the CTBT. Commentors would like the PEIS to consider the possibility
of nonratification of START II and noncompliance with the CTBT
and discuss the possibility that we may need stockpile levels
higher than START I. Other commentors note that even if the United
States and Russia honor nonproliferation agreements other nations
or groups may not and that the United States should prepare for
this eventuality. Another commentor states that the Stockpile
Stewardship and Management Program fails to meet its objective
of protecting the Nation's ability to respond to changing national
security needs.
Commentors state that the money spent on
nuclear weapons and the Stockpile Stewardship and Management Program
should be spent on other more needy social programs, and that
the jobs created are not worth the negative ramifications of the
Program. One commentor believes that enormous amounts of taxpayer
money are being wasted on militarily unusable weapons. Other commentors
believe that the money should be spent on more useful programs
such as medical care, day care, education, feeding the hungry,
housing, infrastructure, conservation, renewable energy, and environmental
cleanup. Another commentor feels the United States should invest
in peace, trust, and equality. Commentors also believe that the
Stockpile Stewardship and Management Program is a pork barrel
project for the nuclear military industrial complex and the corporations
that serve the complex. A commentor also states that national
security is really about having a well-educated, nonviolent, clean,
and safe community, and not nuclear weapons. Other commentors
ask why the public should feel comfortable with a plan that is
very costly and gives us less, not more, nuclear deterrent.
Many commentors question the Stockpile Stewardship
and Management Program costs and request clarification and more
discussion of the details and assumptions used in the cost analysis.
Several commentors want to see the cost analysis presented in
the PEIS. Specific issues expressed by the commentors include
the request for more information on D&D costs, life-cycle
costs, transportation costs of moving pits, site transition costs,
enhanced experimental program costs, training costs of new workers,
remediation and cleanup costs, and program cumulative and annual
costs.
Several commentors, concerned with the cost of the stockpile stewardship
facilities, ask if current facilities could be used since millions
of dollars have been spent on maintaining these capabilities at
the Complex sites. Other commentors state that there may be more
cost-efficient ways of achieving stockpile stewardship and management
goals, such as "piggybacking" onto the current sites
rather than transferring these activities elsewhere. One commentor
also asks what is the annual cost of the proposed Stockpile Stewardship
and Management Program for the next decade and how does this cost
compare to the cost of a conventional surveillance program, such
as the one that has been used successfully for the last 50 years.
Commentors also express concern that with the current cutbacks
in the Federal budget, spending money on new facilities is counterproductive.
One commentor asks how much money will be saved by rightsizing
the weapons complex as proposed. Another commentor states that
the cost analysis was faulty in showing the downsizing of Pantex
was more cost-effective than relocating the A/D and HE missions
to NTS.
- Response: The PEIS provides documentation
on the potential environmental impacts associated with the reasonable
alternatives. Cost is one of the factors considered in developing
the alternatives and identifying the preferred alternatives. Two
separate reports have been prepared, the Analysis of Stockpile
Management Alternatives report , and the Stockpile Management
Preferred Alternatives Report which outline the costs of the various
alternatives and the role costs play in the rationale for selecting
the preferred alternatives. These documents are available for
public review at the DOE Public Reading Rooms located near each
site.
The downsize-in-place alternatives were chosen for several reasons
including the availability of a trained workforce, existing mission
site infrastructures, the ability to expand capabilities in the
event of a change in world events, as well as other factors. Clearly
cost is an important factor, not only the cost of D&D of surplus
facilities but the costs of constructing new facilities and their
eventual D&D must also be considered as well.
The cost analysis that DOE has performed to address alternative
sites for accomplishment of the stockpile management missions
has been performed with participation from all weapons complex
sites. To assure peer review of cost estimates, each site was
given the opportunity to review and critique the cost estimates
provided by the competing sites. In addition, DOE commissioned
an independent validation of the cost estimates. Relocation of
the HE mission from Pantex to NTS was not considered a reasonable
alternative and was not addressed in the PEIS.
In the No Action alternative, the PEIS analyzes the alternative
of relying on existing facilities and capabilities to perform
the stockpile stewardship mission. However, as explained in section
3.1.4, relying on existing facilities would not ensure DOE's ability
to maintain core competencies in nuclear weapons in the long-term
while also maintaining a safe and reliable, smaller, aging, U.S.
stockpile. Thus, enhanced experimental facilities are proposed
and evaluated in the PEIS.
Commentors state that underground testing
should cease, the capability to resume testing should not be maintained,
and the NTS testing area should be closed. Commentors state that
there is no technological justification for testing, that closing
the test site would demonstrate U.S. resolve in ending its weapons
programs, and that it would be more fiscally responsible to stop
testing. Other commentors state that underground testing contaminates
the land and produces more nuclear waste. One commentor compares
the Stockpile Stewardship and Management Program to the Safeguard
C program, which maintained atmospheric testing readiness but
was discontinued when Congress learned of its costs. Another commentor
questions the need for funding NTS at such an enormous cost.
- Response: The United States has ceased
underground nuclear testing and is pursuing a CTBT. The President
also stated that he had been assured "that we can meet the
challenge of maintaining our nuclear deterrent under a Comprehensive
Test Ban Treaty through a science-based stockpile stewardship
program without nuclear testing." However, the President
cautioned that, "while I am optimistic that the stockpile
stewardship program will be successful, as President I cannot
dismiss the possibility, however unlikely, that the program will
fall short of its objectives." The President went on further
to say that, "In the event that I were informed by the Secretary
of Defense and Secretary of Energy... that a high level of confidence
in the safety or reliability of a nuclear weapons type which the
two Secretaries consider to be critical to our nuclear deterrent
could no longer be certified, I would be prepared, in consultation
with Congress, to exercise our `supreme national interests' rights
under the Comprehensive Test Ban Treaty in order to conduct whatever
testing might be required."
Thus, it is possible--although not probable--that under a CTBT,
the United States might one day exercise its "supreme national
interests" rights to conduct underground nuclear testing
to certify the safety and reliability of its nuclear weapons.
Consequently, section 4.12 of the PEIS includes a programmatic
evaluation of the environmental impacts of underground nuclear
testing at NTS.
Several commentors state that DOE should
not spend funds to continue the production and maintenance of
nuclear weapons, but instead should divert the funds and technical
expertise to developing methods of neutralizing radioactive waste
and to clean up from past activities. Commentors state that legacy
waste from past weapons complex activities should be cleaned up
first (e.g., the Chemistry and Metallurgy Research building at
LANL) before any new projects or programs are started and additional
wastes are created. One commentor believes that classification
issues are hindering cleanup efforts. Another commentor states
that contamination problems at NTS should have been addressed
earlier in the process before the Draft PEIS was prepared. Commentors
are concerned about the availability of funds for proposed cleanup
of excess facilities once turned over to Environmental Management
for disposition. One commentor states that the Nation could only
afford to maintain a minimal stockpile since we are faced with
the immense cost of cleaning up the environmental problems caused
by the nuclear weapons industry.
- Response: DOE has a program to decontaminate
and make available for other uses its excess facilities. The budget
for this activity has increased significantly since the end of
the Cold War. DOE has made every effort to prioritize the cleanup
of these excess facilities based on risk. Therefore, as the commentor
alludes, some low risk facilities may wait a significant time
period for decontamination because the higher risk facilities
are addressed first. However, DOE has demonstrated a commitment
to bring excess facilities to a safe shutdown condition awaiting
decontamination, and to maintain these excess facilities in a
safe condition until decontamination can proceed. DOE is committed
to both the cleanup of its excess facilities, but also to maintain
a nuclear weapons stockpile to meet national policy directives.
As stated in section 3.1.1, Planning Assumptions and Basis for
Analysis, DOE would emphasize compliance with applicable laws
and regulations and accepted practices regarding industrial and
weapons safety, safeguarding the health of workers and the general
public, protecting the environment, and ensuring the security
of nuclear materials, weapons, and weapons components. DOE would
also minimize the use of hazardous materials and the number and
volume of waste streams consistent with programmatic needs through
active pollution prevention programs and waste minimization. The
Chemistry and Metallurgy Research building at LANL is an analytical
chemistry laboratory that has been in continuous use since 1952.
See the response to comment summary 40.90 for further discussion
on the Chemistry and Metallurgy Research building.
The LLW disposal facility of NTS has been designed, constructed,
and managed in such a way so as to handle safely the materials
disposed of in this facility. This facility was sited due to the
remoteness of NTS, the depth of the groundwater, and other factors
which contribute to assuring the disposal of these materials can
be conducted in a safe manner.
The commentor recognizes the significance
of downsizing and wants to know if the PEIS discusses a transition
funding similar to that at the Mound Plant (e.g., reuse of plants,
refitting, and revised missions that could possibly give futures
to some displaced workers).
- Response: This is a programmatic document
and, as such, does not address detailed site-specific transition
planning. In the event that a decision is made to adopt the preferred
alternative, further site-specific review would take place. When
DOE closes a facility, a transition plan is developed, detailing
the cleanup plans, disposition of equipment, and ultimate disposition
of the land. There is an established process for including the
adjacent communities in this process and DOE's Office of Economic
Assistance has grants and other support services to assist in
the retraining and out-placement of all adversely affected employees.
It is DOE policy to reassign employees to new missions whenever
possible. As stated in sections 4.2.3.8, 4.4.3.8, and 4.5.3.8.,
the DOE Office of Worker and Community Transition would
- oversee the workforce restructuring
plans for ORR, KCP, and Pantex. This plan would be developed in
conjunction with the affected communities, local governments,
and elected officials. Factors considered in these plans would
include additional professional and vocational training at local
schools during the transition period; academic and vocational
counseling; help in preparing resumes and preparing for job interviews,
financial planning, and job searching techniques; coordination
with local businesses and economic development agencies to identify
available jobs; and means of informing the business community
of skilled personnel in the labor market.
The commentors raise concerns that the PEIS
ignores the significant body of Congressional hearings and testimony
that science-based stewardship is not guaranteed to work, or that
if it works it will not be ready for at least another 10 years.
The commentor states that DOE has focused
almost exclusively on preserving the capabilities and core competencies
of the national laboratories, while paying little attention to
the production plants. The commentor also states that the PEIS
does not deal adequately with the production capacity that will
be needed to maintain the stockpile over the next 10 or more years,
and states that the entire PEIS analysis is based on optimistic
assumptions about future arms control agreements.
Several commentors
question the need for new pit manufacturing citing concerns of
advancing new nuclear weapons design (e.g., mini nukes) and increasing
the pit stockpile when plenty of pits are already available for
reuse in weapons. Other commentors express their opposition to
pit manufacturing activities at LANL. Another commentor questions
the workload associated with the pit fabrication options.
- Response: Because of the small demand
for the fabrication of replacement plutonium pits over the next
10 or more years, DOE did not propose a new pit fabrication facility
with a capacity equivalent to the capacities required for other
portions of the nuclear weapons production complex. However, limited
fabrication of new replacement pits would be required to maintain
capability and to replace pits lost during weapon surveillance.
Section 3.6 discusses DOE's future plans should a life-limiting
phenomenon be found in stockpile pits and a larger pit fabrication
capacity be required.
The No Action alternative discussed in section 3.4.3.1 would maintain
only a limited plutonium R&D component fabrication capability
at LANL and a less extensive capability at LLNL, and it would
not provide DOE with sufficient pit fabrication capability to
meet the requirements stated in section 3.1. DOE does not consider
it prudent to pursue an alternative which would prevent it from
fulfilling its national security mission. Additionally, DOE is
under the direction of the President and Congress, through PDDs
and the National Defense Authorization Act of 1994, to support
the maintenance of a safe and reliable nuclear weapons stockpile,
and to maintain the core intellectual and technical competence
of the United States in nuclear weapons. This includes competencies
in research, design, development, testing, reliability assessment,
certification, manufacturing, and surveillance capabilities. The
preferred alternative for the pit fabrication mission is to reestablish
production capability with a limited capacity at LANL. The preferred
alternatives were developed by DOE using data and studies on such
factors as cost, technical feasibility, technical risk and schedule,
ES&H, and national security. The Analysis of Stockpile Management
Alternatives report which contains the analysis of these factors
is available for public review at the DOE Public Reading Rooms
near each site. To bound the potential environmental impacts at
each site, the PEIS estimates are based on "surge" or
maximum production scenario. Because it is expected that this
workload would be performed in existing facilities that would
be modified to perform pit fabrication, it is not surprising that
the maximum outputs and the maximum potential environmental impacts
varied somewhat between LANL and SRS for this bounding surge case.
In addition, however, each alternative was assessed for the same
low case and high case single-shift workloads.
The commentor expresses the view that Pantex
should continue to store plutonium, and should be the preferred
site for any disposition options and related functions.
The commentors express both praise and criticism
of DOE's safety and environmental monitoring programs and protection,
and insist that all future DOE missions must be conducted in a
safe and environmentally sound manner. Commentors believe that
moving missions would potentially lead to a decline in worker
health and safety protection and an increased threat to the environment
at the mission's new site. Other commentors state that classification
and the shift of safety responsibility from workers to management
has weakened the DOE safety program at some sites, and that worker
knowledge and training were necessary for safe operations. One
commentor states that he did not trust DOE when it came to ES&H
monitoring and felt that workers' fear of losing their jobs prevented
people from raising safety concerns. The commentor believes that
the current system within DOE to shelter whistleblowers is not
effective in protecting the whistleblowers. The commentor believes
that the people at LANL were not laid off because they were whistleblowers.
One commentor believes that if stockpile stewardship and management
work came to LANL, employees with jobs related to health and safety
would be hindered from truth-telling from fear of management pressure
or job loss, since current management implements a subjective
and undemocratic system of employee evaluation and control.
A commentor refers to the Tiger Team findings
and tracking program at LANL as an example of DOE's lack of commitment
to reducing environment, health and safety issues. Another commentor
questions DOE's stated priority on safety in light of their cancellation
of the NEWNET air monitoring system. Other commentors state that
DOE has not conducted or released enough studies on worker and
public health effects and on past accidents and their results.
A commentor states that the recent forklift accident, the fatality
due to an electrocution and the root causes need to be identified
in the Accident History section of the PEIS. The commentor also
wants an analysis of the effect of the recent reduction-in-force
on the occupational safety at LANL. Another commentor feels the
workers at LANL are eminently competent to monitor their own safety
and environmental concerns.
- Response: As stated in section 3.1.1,
Planning Assumptions and Basis for Analysis, DOE would emphasize
compliance with all applicable laws and regulations and accepted
practices regarding industrial and weapons safety, safeguarding
the health of workers and the general public, protecting the environment,
and ensuring the security of nuclear materials, weapons, and weapons
components. DOE would also minimize the use of hazardous materials
and the number and volume of waste streams consistent with programmatic
needs through active pollution prevention programs and waste minimization.
The specific stockpile management assumptions are described in
section 3.1.1.1, and the stockpile stewardship assumptions are
described in section 3.1.1.2. It is unlikely that a change in
environmental regulation would result in a modification to the
Stockpile Stewardship and Management Program itself; however,
changes to the environmental regulatory setting may necessitate
the implementation of additional engineering and administrative
controls to meet new standards.
The overall subject of "whistleblower protection" is
one which DOE has given extremely high priority. DOE is pursuing
an open environment at its facilities so that employees can raise
concerns without fear; improvement in this difficult area is always
possible. DOE believes it is essential that workers at its facilities
have the opportunity to raise safety and environmental concerns
without fear of retribution. DOE has programs at all of its sites
to provide anonymity to workers who wish to raise such concerns.
All concerns are investigated thoroughly and necessary corrective
actions are directed.
AIRNET and NEWNET are the two air quality monitoring systems employed
by LANL. AIRNET data are reported to the public annually in the
Environmental Surveillance Report, and NEWNET data are publicly
accessible over the Internet computer links as they are collected.
Neither AIRNET nor NEWNET stations went offline during the Dome
Fire. Over the past 8 months, LANL has eliminated several AIRNET
stations that are no longer needed or were redundant with other
sampling as part of an overall effort to streamline the sampling
networks to ensure their effectiveness. Just prior to the outbreak
of the Dome Fire, LANL reprogrammed four of five monitoring stations
in the southern part of laboratory to transmit data at longer
intervals in order to determine long-clock stability, but returned
to the original transmittal intervals during the Dome Fire to
provide better coverage.
There have been several serious accidents at LANL within the past
18 months. Both DOE and the University of California conducted
investigations and developed recommendations to improve safety
awareness at LANL (see Type A Accident Investigation Report, DOE,
March 1996, and Final Report of the University of California Fact
Finding Team Concerning Recent Accidents at the Los Alamos National
Laboratory, University of California, March 19, 1996). In March
1996, the senior vice president of the University of California
directed LANL to implement the University's recommendation, including
developing an integrated safety management program. There is no
indication that the recent downsizing of LANL staff has had any
detrimental effect on occupational safety.
The commentors ask why information from
the Sandia Stockpile Study was left out of the PEIS. In particular,
information stating that weapons defects decrease over time and
the statement that nuclear weapons do not age, do not wear out,
and are not allowed to degrade. Commentors are of the opinion
that historical defect rates exceed the expected future stockpile
defects and that the proposed Stockpile Stewardship and Management
Program is not required. One commentor asks about the age of the
weapons in the stockpile and how long they will be maintained.
Another commentor asks about the design life of the remaining
stockpile weapons and indicates that an enhanced surveillance
program above that currently proposed by DOE may be needed. Despite
requests in scoping comments, the commentor states that the Draft
PEIS does not analyze whether individual stockpile stewardship
facilities are needed to diagnose safety problems, on the one
hand, and reliability problems on the other.
- Response: Chapter 2 of the PEIS discusses
aging impacts. The information in section 2.3 is based on the
latest data published in the tri-laboratory study. Section 2.3.3
of the PEIS, Historical Stockpile Data, provides a summary of
stockpile defect and aging data that were used as an input for
sizing the Stockpile Stewardship and Management Program. This
information was extracted from an unclassified report, Stockpile
Surveillance: Past and Future, dated September 1995.
As explained in that section, continuous evaluation of the safety
and reliability of the stockpile has always been a major part
of the U.S. nuclear weapons program. Since the introduction of
sealed-pit weapons more than 35 years ago, a formal surveillance
program of nonnuclear laboratory and flight testing has been in
existence. More than 13,800 weapons have been evaluated in this
program. The Stockpile Evaluation Program, with its reliance on
functional testing, has provided information that can be used
in the statistical analysis of nonnuclear component and subsystem
reliability. This program has detected about 75 percent of all
problems ultimately detected, and it has been the principal mechanism
for discovering defects and initiating subsequent repairs and
replacements. However, not all aspects of a nuclear weapon can
be statistically assessed this way. Weapons R&D at the three
weapons laboratories and nuclear testing have played an important
part in assessing the stockpile and in making corrective changes
when needed.
Nuclear tests have been a critical part of the nuclear weapons
program. They have contributed to a broad range of activities
from development of new weapons to stockpile confidence tests
to tests that either identified a concern or showed that remedial
actions were not needed. However, the United States has not conducted
a sufficient number of nuclear tests for any one weapon type to
provide a statistical basis of reliability assessment for the
nuclear explosive package. This is why the word "performance"
instead of "reliability" is used when discussing a nuclear
explosive package.
Although nuclear tests were never a part of the formal Stockpile
Evaluation Program, they played an important role in maintaining
the safety and performance of the weapons in the stockpile. Every
advantage was taken of developmental nuclear tests to eliminate
potential nuclear explosive problems. In some cases, nuclear testing
during development of one weapon type uncovered a problem that
was pertinent to a previous design already in the stockpile, which
then had to be corrected. Nuclear tests identified certain classes
of stockpile problems not observable in the surveillance program.
Nuclear tests have been used to resolve issues raised by the Stockpile
Evaluation Program, such as whether a particular corrosion problem
affected the nuclear yield of a weapon. Nuclear tests have also
been used to verify the efficacy of design changes. For example,
the adequacy of certain mechanical safing techniques was determined
through nuclear testing. In the case of a catastrophic defect,
tests have been used to certify totally new designs to replace
an existing design. Finally, in some cases, nuclear testing proved
that a potential problem did not exist.
Beginning in the late 1970s, DOD and DOE agreed to a formal series
of underground nuclear tests of weapons withdrawn from the stockpile.
These tests were referred to as Stockpile Confidence Tests. They
differed from developmental nuclear tests because the weapons
were from actual production, had experienced stockpile conditions,
and had minimal changes made to either nuclear or nonnuclear components
prior to the test. There have been 17 such confidence tests since
1972, including 4 tests in the early 1970s that were not officially
designated as Stockpile Confidence Tests. Confidence tests have
been conducted for each of the weapon types expected to remain
in the stockpile well into the next century.
In addition to the 17 confidence tests, at least 51 additional
underground nuclear tests have been conducted since 1972 involving
nuclear components from the stockpile, components from the actual
weapon production line, or components built according to stockpile
design specifications and tested after system deployment. The
objectives of these tests included weapon effects, weapons R&D,
confirmation of a fix, or investigation of safety or performance
concerns. Three of these tests (in addition to one confidence
test) revealed or confirmed a problem that required corrective
action. Four tests (in addition to three confidence tests) confirmed
a fix to an identified problem. Additionally, five tests were
performed to investigate safety concerns affecting three different
weapon types. These five tests verified that a problem did not
exist.
The confidence in the performance of the nuclear explosive package
has been based on underground nuclear test data, aboveground experiments,
computer simulations, surveillance data, and technical judgment.
The directors of the three weapons laboratories must certify the
nuclear performance of the weapons designed by their laboratory.
In a future without additional nuclear testing, the core capabilities
of the weapons laboratories that were developed to eliminate potential
problems in new weapon designs must now be employed to assess
stockpile problems. However, in the absence of nuclear testing,
the ability to assess nuclear components is more difficult; new
methods of assessment, discussed later, will have to be developed
to help compensate for this loss.
The historical stockpile database includes more than 2,400 findings
from more than 45 weapon types. Findings are any abnormal conditions
pertaining to stockpile weapons, such as out-of-specification
data. Findings are then investigated and assessed as to whether
or not they are a problem. Actionable findings are those that
require some form of corrective action. All major components and
subsystems have had problems that required corrective actions.
The number of findings for nonnuclear components is much larger
than that for nuclear components largely because there are so
many more nonnuclear components in a nuclear weapon that require
testing more frequently. However, the ratio of actionable findings
to distinct findings is much greater for the nuclear components.
Thus, when a finding has occurred for a nuclear component, it
has generally been a serious one requiring corrective action.
Often these corrective actions to nuclear components have required
changes to all of the weapons comprising the weapon type affected.
For the nuclear explosive package, there were approximately 110
findings on 39 weapon types requiring some remediation either
to the entire build of that design or to all weapons produced
after the particular finding. In addition to rebuilds and changes
in production procedures, other actions included imposing restrictions
on the weapon, accepting a performance decrement, and in several
cases, conducting a nuclear test to determine that the finding
did not require any physical change. There have been other instances
not counted as actionable where a material was chemically changing
and the weapon was closely monitored to see if further action
was necessary or it was an isolated case that did not require
remediation.
The commentors, in referring to the Sandia Stockpile Study, are
referring to briefing materials which were made publicly available
earlier in 1995 which dealt with only a portion of the nuclear
weapons historical defect and aging information. As described
in chapter 2 of the PEIS, the Stockpile Stewardship and Management
Program has been constructed to support national security policy
directions as provided to DOE by the President and the Congress.
Though weapon safety and weapon reliability can be driven at times
by different phenomena, they are also related in that an essential
ingredient of weapon safety is predictable response in all weapon
environments, including potential accidents. Each of the proposed
stockpile stewardship facilities would enhance the ability to
make judgments about the safety and reliability of the nuclear
weapons stockpile in the absence of underground nuclear testing.
Section 3.1.2 has been expanded in the Final PEIS to provide a
more detailed description and justification of DOE plans relative
to national security policy and the issue of weapon safety and
reliability. As explained in that section, national security policy
from the President and Congress requires a safe and reliable stockpile.
In order for the nuclear deterrent to be credible within the current
national security policy framework, it must be reliable in a militarily
effective way. From a PEIS perspective, separating safety and
reliability is similar to the issue discussed under stockpile
size (section 3.1.2.4, Denuclearization). It would require DOE
to speculate on an alternate concept of nuclear deterrence and
a national security policy framework to support it.
Commentors have also suggested acceptance of lower standards of
reliability as an alternative to enhanced stewardship capabilities.
This PEIS explains how the assessment and certification of nuclear
performance is carried out and how this differs from the more
conventional statistical methods used for assessing reliability
of the nonnuclear portion of the weapon. Assessment and certification
of nuclear performance is a technical judgment by the weapons
laboratories based on scientific theory, experimental data, and
computational modeling (sections 2.3 and 2.4.1). The question
is not whether to accept a lower standard of nuclear performance
(less nuclear explosive yield), but whether or not there is a
technical basis to confidently know how well the weapon will perform
at all. Enhanced stewardship capability is focused on the technical
ability to confidently judge nuclear safety and performance in
the absence of nuclear testing.
Aside from being inconsistent with the national security policy,
attempting to separate weapon safety and reliability, is more
technically complex than it sounds. A modern nuclear weapon is
highly integrated in its design for safety, reliability, and performance.
It contains electrical energy sources and many explosive energy
sources in addition to the main charge HE. The principal safety
concern is accidental detonation of the HE causing dispersal of
radioactive materials (plutonium and uranium). Modern weapons
are designed and system-engineered to provide a predictable response
in accident environments (e.g., fire, crush, or drop). However,
because of the technical complexity of potential accident scenarios
(i.e., combined environments) and the fact that complete nuclear
weapons cannot be used for experimental data, assessment of the
design and the effect of changes that might be occurring due to
stockpile environments must rely on other sources of experimental
data and complex computer modeling. Enhanced experimental capability
specifically related to the weapon secondary is a nuclear performance
concern. Enhanced computational capability in general, and enhanced
experimental capability related to the weapon primary in particular,
are both nuclear safety and performance concerns.
The commentors express support for maintaining
production missions at the production sites, and for maintaining
the funding required to continue these activities. Commentors
urge DOE to keep production missions at production plants that
have the experience and proven safety record to complete assigned
tasks. Commentors state that the existing production infrastructure,
personnel, and experience at production sites made moving these
missions to a laboratory an unreasonable alternative. In the view
of many commentors, production and R&D cultures were not compatible
and merging them would jeopardize the defense of the Nation. One
commentor further states that the quality and integrity of today's
stockpile is the result of production people and not the laboratories.
Commentors believe that there was no adequate peer review of laboratory
recommendations or manufacturing capability claims. Commentors
also state that design experts were not production literate, and
the weapons design and manufacturing functions should remain separate.
Other commentors state that the laboratories will not be able
to maintain the required quantities and quality of weapons components
if they are given the production missions.
- Response: Production and laboratory
functions are different, but the difference is reduced as the
size of the production requirements becomes smaller. The first
atomic weapons were not only designed but also constructed at
the weapons laboratories. The laboratories have always had the
capability for small lot production principally in order to test
out designers' theories. In some respects, this could be considered
an advantage by increasing the synergism between the two activities.
Data for the PEIS were developed by working groups for each stockpile
management mission. These working groups consisted of experts
from each of the potentially affected sites. A review of data
for consistency and accuracy was performed at both the working
team level and at a senior management level. The alternative of
transferring the stockpile management functions that currently
exist at ORR, KCP, and Pantex to the laboratories and NTS are
evaluated in the PEIS because they are deemed to be reasonable
alternatives. Based on the environmental, cost, and technical
analyses that have been performed, the preferred alternative is
to downsize the stockpile management functions at ORR, KCP, and
Pantex, and not transfer them to the laboratories and NTS.
The commentors question DOE's commitment
to attracting and retaining staff at laboratories and production
sites. Some commentors believe that DOE was favoring the design
laboratories over the production plants, while others believe
that because of the reduced workloads, staff and capabilities
are being lost everywhere in the weapons complex. The commentors
are also concerned that funding for sites, particularly Y-12,
was not adequate in maintaining their mission capabilities let
alone sufficient to make necessary upgrades at the site. Other
commentors contend that the proposed program reduces the production
capabilities and personnel within the complex and shifts most
efforts to the R&D laboratories and therefore reduces the
long-term success and flexibility of the program to meet national
security needs. Commentors also note that all the budget increases
are slated for the laboratories, while budget cuts are slated
for the production complex.
The commentors state that the analysis and
support studies for the management part of the Stockpile Stewardship
and Management Program was much more complete and balanced than
that for the stewardship part and urged DOE to prepare the same
level of analysis for stewardship.
- Response: The PEIS analyzes the potential
consequences to the environment if certain programmatic changes
to the Complex are implemented. National security policies in
the post-Cold War era require that all the historical capabilities
of the weapons laboratories, industrial plants, and NTS be maintained.
Those processes and facilities, such as stewardship R&D work,
that have no potential for being changed or moved as part of this
proposal are not analyzed beyond the No Action alternative. DOE
is not proposing to make any changes to these existing weapons
R&D activities at the three laboratories or NTS. Rather, DOE
is proposing to provide enhanced experimental capabilities (NIF,
CFF, and Atlas in appendix I, J, and K, respectively) to augment
existing R&D activities and stockpile stewardship capabilities
so that the safety and reliability of the stockpile can be maintained
in the absence of underground testing. The purpose and need for
the full range of laboratory capabilities contained at LANL and
LLNL and for continued peer review for weapon assessment and certification
are explained in chapter 2 of the PEIS.
For stockpile management, commentors believe
that the approach reveals the extent to which the PEIS is narrowly
focused on a single, pre-chosen alternative. The commentors state
that there is no separate analysis of the high and low cases in
which the impacts of these alternatives can be compared to the
base case alternative. According to the commentors it is not clear
that the different stockpile cases really represent alternatives
in the traditional NEPA sense at all, since they apparently will
require construction of the same facilities and will have very
similar impacts. The commentors also state that the three cases
analyzed by DOE (post-START II, START I plus, 1,000 warheads)
have minimal effect on the facilities and configurations proposed
by DOE such that there is no true programmatic review.
- Response: Two of the stockpile sizes
analyzed in this PEIS, a START I Treaty- and START II protocol-sized
stockpile, are the only ones currently defined and directed by
national security policy. The PEIS also analyzes a hypothetical
1,000 weapon stockpile for the purpose of a sensitivity analysis
for manufacturing capacity decisions. The NWSM specifies the types
of weapons and quantities of each weapon type by year (section
1.1). The NWSM is developed based on DOD force structure requirements
necessary to maintain nuclear deterrence and comply with existing
arms control treaties while pursuing further arms control reductions.
The PEIS explains the complexity of this process and why DOE does
not believe it reasonable to speculate with a large number of
arbitrary assumptions (section 2.2). However, this does not mean
DOE has failed to consider that a future national security policy
framework could define a path to a smaller stockpile.
- Stockpile stewardship capabilities are
currently viewed by the United States as a means to further U.S.
nonproliferation objectives in seeking a zero-yield CTBT. Likewise,
it would be reasonable to assume that U.S. confidence in its stewardship
capabilities would remain as important, if not more important,
in future arms control negotiations to further reduce its stockpile.
The path to a very small (10s or 100s) or zero stockpile would
require the negotiation of complex international treaties that
are also likely to require intrusive verification inspections
of nuclear weapons related facilities. Therefore, DOE believes
it reasonable to assume that complex treaty negotiations, when
coupled with complex implementation provisions, would likely stretch
over several decades. On a gradual path to a very small or zero
stockpile, stockpile size alone would not change the purpose and
need, proposed actions, and alternatives in this PEIS as they
relate to stewardship capabilities. The issues of maintaining
the core competencies of the United States in nuclear weapons,
and the technical problems of a smaller, aging stockpile in the
absence of nuclear testing, remain the same.
This PEIS evaluates reasonable approaches to stockpile management
capability and capacity that are consistent with a gradual path
toward a very small or zero stockpile. At some point on this path
further downsizing of existing industrial plants or the alternative
of consolidating manufacturing functions at stewardship sites
would become more attractive as manufacturing capacity becomes
a less important consideration. However, in the near term, the
preferred alternative of downsizing the existing industrial plants
would still be a reasonable action because the projected downsizing
investment pays back within a few years through reduced operating
expense; in addition, the downsizing actions are consistent with
potential future decisions regarding plant closure. In regard
to the proposed action for reestablishing pit manufacturing capability,
DOE does not propose to establish higher manufacturing capacities
than are inherent in the reestablishment of the basic manufacturing
capability of LANL, which is the preferred alternative. In developing
the criteria for reasonable stockpile management alternatives,
DOE was careful not to propose the introduction of significant
new types of environmental hazards to any prospective site. Therefore,
on a gradual path to a very small or zero stockpile, stockpile
size alone would not change the purpose and need, proposed actions,
and alternatives in this PEIS with regard to stockpile management
capabilities and capacities.
The PEIS does not analyze stockpile size in the PEIS as traditional
alternatives in the NEPA sense. Rather, the PEIS analysis is based
on the national security policy considerations discussed in chapter
2 of the PEIS and is consistent with and supportive of those national
security policies. The PEIS addresses plant operations to support
a range of stockpile sizes consistent with recent DOD plans, as
reflected in the NPR. More specifically, the PEIS addresses a
base case stockpile consistent with the recently ratified START
II protocol with additional data for a larger (START I) or smaller
(about 1,000 weapons) stockpile. The DOE Stockpile Management
Preferred Alternatives Report, which was released to provide programmatic
support to the PEIS, describes the DOE manufacturing capacity
strategy in more detail. Given the uncertainties in the world,
this strategy retains sufficient manufacturing capacity to support
the larger START I, yet is also flexible if the stockpile is reduced
below START II levels.
It should be noted that regardless of stockpile size, a goal of
the Stockpile Stewardship and Management Program, as directed
by national policy, is to maintain the core competencies of the
United States in nuclear weapons. Industrial capacity is only
indirectly affected by projected variances in stockpile size and
composition. Stockpile size must be linked with historical stockpile
data to arrive at estimates of average industrial capacity needed
to produce components for repair or replacement. Because this
cannot be done with mathematical precision, reasonable technical
judgment must be applied. The resulting forecast is a smaller
industrial base (with capacities on a scale of hundreds of weapons
per year versus the scale of thousands of weapons per year that
was the capacity prior to the end of the Cold War).
Several commentors express opposition to
the continued operation of all the major DOE weapons laboratories
(LANL, LLNL, and SNL). One commentor states that it is not obvious
why we need three R&D laboratories when we are not building
any new weapons. Other commentors believe that LLNL is an unjustified
costly duplication of LANL. In fact, some commentors referring
to the Notice of Intent for the PEIS and the PEIS itself state
that descriptions of LANL and LLNL are identical. In light of
the duplication of effort and especially the Galvin Committee's
recommendation, commentors ask how DOE justifies the continued
operation of both LANL and LLNL. Another commentor states that
the two laboratory option merits consideration. Other commentors
are of the opinion that the national laboratories should cease
all related nuclear weapons work and instead the country should
divert those technical and monetary resources towards civilian
uses. According to the commentors, alternate uses for the laboratories
should include research into cleaner sources of energy (e.g.,
solar, wind, and geothermal), recycling and solving the nuclear
waste problem.
The commentor would like to know what plan
the PEIS is based on and whether it is still the Stockpile Stewardship
and Management Program plan, dated May 1995, and whether this
plan has undergone significant revisions.
The commentors state that they were in favor
of DOE's plan to downsize the Complex, but did not see these reductions
reflected in the PEIS. Nor did the commentors understand how DOE
could severely downsize the production plants but at the same
time increase the laboratories' capability, capacity, and staff.
The commentors express concerns about the
threat of layoffs. Commentors believe that employees at LANL were
under pressure to support laboratory activities or be threatened
with layoffs. The commentors state that employees at TA-55 were
laid off even though the future expansion of this area was known.
One commentor points out that TA-55 may be vulnerable to sabotage
if the constant threat of layoffs exists.
The commentors believe that information
available to the public is increasingly being taken out of the
public record. A commentor cites the Operating Experience Summary
Report which was recently taken offline, presumably to hide the
number of troublesome incidents at TA-55. Other commentors cite
the new bomb designs that were on the Internet as proof that DOE
is still working on new bomb designs. One commentor requests that
this Internet document be made available to the public.
- Response: DOE requires its sites to
furnish a daily report to notify it of reportable occurrences
in the safety and health arena. The daily report provides initial
notification for internal use by DOE and the site. After any necessary
investigation, DOE and the site prepare a final report which is
made available to the public. The daily reports concerning LANL
include incidents at TA-55, although that facility is not afforded
any special treatment. At LANL, both the final occurrence reports
and an online summary prepared by the laboratory are referred
to as the Operating Experience Summary Report. In the past, LANL
put preliminary daily occurrence notification reports on its computer
network. LANL discontinued this practice because the initial reports
contain preliminary information that in some cases is incomplete
or inaccurate, and which is superceded by the final reports. The
final occurrence reports are available to the public in many forms,
including online.
DOE withdrew its DP Home Page from the World Wide Web on March
20, 1996. This action was in response to the discovery that part
of the information from the Office of Research and Inertial Fusion
came from a number of sources, some of which were outdated. Much
of the material in question was drawn from the Report of the Defense
Programs Research and Technology Development Program for Fiscal
Year 1993, covering the period from October 1, 1992 to September
30, 1993. This report was issued by the Office of Research and
Advanced Technology, a precursor office to the Office of Research
and Inertial Fusion. The Office of Research and Inertial Fusion
constructed its Home Page in early 1995 from the above-mentioned
report with links to other activities and documents in the DP
Home Page. The links were regularly updated as the DP Home Page
evolved, but the text describing Office of Research and Inertial
Fusion activities was not. In particular, the specific information
related to the Gulf War was only current in late 1992.
DOE has halted production of new-design weapons and is, therefore,
not performing such activities. DOE is charged with maintaining
the safety and reliability of existing nuclear weapons in accordance
with National Security Policy. An updated DP Home Page has been
prepared. DOE apologizes for the confusion caused by the outdated
material.
The commentor questions if DOE considered,
under the nonproliferation mantle, which facilities or sites pose
the least security risk. The commentor states that security capabilities
should be addressed in the infrastructure impact analysis. In
fact, the commentor suggests that the number of security breaches
over the last 10 years should be used as the key method to evaluate
the sites' security capabilities. Commentor asks whether there
are not competitions and assessments of each site's security possibilities
and feels that sites that are lacking in security should not be
considered for more work. The commentor adds, if LANL has a bad
record like the apparent security breach that helped the Russians
develop their first [nuclear] weapon, why DOE does not consider
an alternative site where security is taken seriously. Another
commentor questions the selection of LANL as a site for additional
pit production and for DARHT's "non-destructive testing"
based on reports of security deficiencies at LANL indicating a
general laxness in readiness to accept a 5-fold increase in pit
production. Other commentors refer to Summary section S.2.4 and
the statement "much of the (experimental weapons) testing
is classified and could not lead to proliferation without a breach
of security," stating that this implies that adequate security
classification of this component of the nuclear weapons program
will somehow preclude proliferation. Commentors feel that the
postulated relation between adequate classification and weapons
proliferation is not so simple.
A number of commentors state that remanufacturing
was a reasonable alternative that should be analyzed in the PEIS.
In the view of the commentors, the justification stated in the
PEIS for eliminating remanufacturing as an alternative for detailed
analysis was inadequate and not supported by appropriate studies.
Commentors believe that remanufacturing would be cheaper and more
compatible with maintaining the capabilities of production and
R&D laboratories than would the proposed stewardship program.
Another commentor requests that DOE provide a cost comparison
of the remanufacturing alternative as opposed to the proposed
science-based approach. Remanufacturing should not be done by
design engineers, according to one commentor.
- Response: The remanufacturer's point
of view is reflected in this PEIS by the fact that remanufacturing
to specification will be attempted when possible and when appropriate
to the problem being solved. With more than a half dozen different
weapon types projected to remain in the stockpile, and with each
weapon type containing thousands of parts, remanufacturing will
undoubtedly occur for a significant number of repair and replacement
activities. However, remanufacturing is not reasonable as a distinct
exclusive alternative to the ongoing stockpile stewardship program
or the proposed action of enhanced experimental capability for
the technical reasons discussed below. In addition, it would not
be a reasonable alternative because it does not fully support
national security policies that require the conduct of a science-based
stockpile stewardship and maintenance of the capability to design
and produce new weapons.
Remanufacturing weapon components to their original specification,
or maintaining weapons to their original design specifications,
would superficially appear to be a reasonable approach to maintaining
the safety and reliability of the stockpile in the absence of
nuclear testing. Precise replication, however, is often not possible.
Subtle changes in materials, processing, and fabrication techniques
are an ever-present problem. In some cases, specialty materials
and components become unavailable for com-
- mercial or environmental reasons. Implicit
in the remanufacturing assumption is that the design blueprint,
manufacturing process, and the materials used are specified in
exact detail in every way. However, there is an unwritten element
of "know how" that knowledgeable and experienced personnel
contribute to any complicated manufacturing process (for this
reason, controlling the acquisition of "know how" is
a major nuclear weapons nonproliferation objective). Materials
and processes are not always specified in important ways because,
at the time, they were not known to be important. The problem
is illustrated by the following hypothetical example.
A material produced for a critical weld has a specification for
a trace impurity; the manufacturing process consistently produced
the material with a trace impurity less than the maximum allowed
and the welds were satisfactory; the manufacturing process is
changed for some reason, such as cost or environmental concerns;
the material is now being produced with less trace impurity than
before the process was changed; the material is still within specification;
however, the welds are no longer satisfactory; it was unknown
at the time that the higher level of the trace impurity was necessary
to produce a satisfactory weld.
While remanufacturing sounds simple in principle, it is likely
in fact to present complex issues of design, manufacturing process,
and material variables. A simplified view of remanufacturing cannot
serve as a "stand alone" manufacturing approach, let
alone an alternative approach to enhanced stewardship capability.
In the absence of underground nuclear testing, nuclear components
(pits and secondaries) cannot be functionally tested. Stewardship
capabilities provide the analytical tools (experimental and computational)
to assess the significance of a problem observed during surveillance
and to decide if the problem should be fixed; and if fixed, to
certify that the fix will work (section 2.4.1). In the past, the
decision to fix or not fix an observed problem could be made with
nuclear testing (section 2.3). Stockpile stewardship strategies
focus on the basic material science and the enhanced experimental
and computational tools necessary to better predict age-related
defects and to make sound technical judgments on nuclear safety
and performance in the absence of nuclear testing.
The DARHT EIS (DOE/EIS-0228, section 2.3.2) provides an additional
discussion of the limitations of a remanufacturing-to-specification
approach. It discusses, as an example, the actions taken to evaluate
and resolve unanticipated deterioration of HE in the now-retired
W68 warhead for a submarine-launched ballistic missile. In that
case it was necessary to replace the HE with a more chemically
stable formulation. In addition, some other materials were no
longer commercially available, requiring changes in the rebuilt
weapons. Nuclear testing was ultimately used to verify that the
necessary changes were acceptable. DOE does not consider it feasible
to maintain all potentially obsolescent commercial sources and
processes used for materials in existing weapons; aging would
still occur in stored reserves of such materials.
With regard to stockpile management, remanufacturing without enhanced
stewardship capability would also have notable drawbacks. DOE
plans to maintain the capability to produce secondaries, and proposes
to reestablish the capability to produce pits, by producing small
quantities (10s) of each annually to maintain capability. This
capacity should be sufficient to replace components attrited from
the stockpile by surveillance testing. Remanufacturing these components,
without the enhanced stewardship analytical capability to determine
if and when replacement is necessary, is likely to require higher
levels of production than DOE believes necessary to maintain production
capability. Also, remanufacturing a nuclear component to the original
specifications will not prevent age-related problems related to
those specifications from recurring. Since these components use
plutonium and uranium, radiation exposure to personnel and generation
of radioactive waste would also be higher than necessary. If repeated
remanufacturing were required, further unnecessary risks would
result from additional weapon A/D operations and additional transport
of nuclear components between sites.
From an environmental impact point of view, the remanufacturing
concept would have greater impacts for the proposed action of
reestablishing pit capability because DOE proposes to use a cleaner,
less waste-generating process than was used at the Rocky Flats
Plant. All other environmental impacts would not be distinguishable
from those described in this PEIS because existing manufacturing
processes form the Program baseline.
Several commentors feel that the document
presents several misused terms and euphemisms which are intended
to deceive the public. The commentor feels the following terms
should be changed or decoupled so that there would be less acceptance
of the proposed program:
(1) safety and reliability: the commentor
feels this phrase translates into the expected blast of a nuclear
weapon must be greater than 90-percent yield. The commentor feels
reliable weapons are not required and that the stockpile may be
maintained with existing technology. The commentor feels that
greater unreliability may in fact discourage proliferation.
(2) flexibility: the commentor feels this
term translates into continued development of new nuclear weapons.
(3) modification: the commentor feels this
term applies to the construction of new nuclear weapons.
(4) national security: the commentor believes
this euphemism destructs "true" national security which
is the environment. The commentor feels that the Nation is less
secure because the money proposed for stockpile stewardship and
management may be used for poverty, education, and waste management.
A number of commentors express concern that
the proposed Program would not succeed and jeopardizes the defense
posture of the country. Commentors state that without underground
testing, the proposed stockpile stewardship program is a gamble.
A commentor also wants to know what criteria was used by the President,
Congress, and DOE in determining the potential success of the
program.
The commentors express concern that DOE
did not adequately justify the need for new or upgraded facilities
to implement the science-based stockpile stewardship program.
Some commentors suggest that rather than constructing new facilities
at added expense, a passive stewardship and management plan (i.e.,
curatorship) should be considered. One commentor asks that DOE
look at more "small-scale" techniques and facilities
to determine the safety and reliability of the enduring stockpile.
Another commentor believes that a non-science-based approach should
be studied and analyzed in the PEIS.
- Response: DOE believes that the PEIS
discusses a full range of alternatives for implementing the Stockpile
Stewardship and Management Program, and that it analyzes in detail
those reasonable alternatives that are capable of achieving the
goals of the Program. DOE also believes that the PEIS adequately
assesses the cumulative impacts of proposed new activities and
existing activities at the sites where the Stockpile Stewardship
and Management Program would be implemented.
It is a well established principle under NEPA that the goals of
a proposed action delineate the limits of the reasonable alternatives
to that action. That is, an alternative which does not accomplish
the agency's goals is not a reasonable alternative. Since its
inception, one of the primary goals of the U.S. nuclear weapons
program has been to ensure the safety, security, and reliability
of the Nation's nuclear weapons stockpile. Numerous facilities
have been built over the years at the three weapons laboratories
(LANL, LLNL, and SNL) and at NTS to conduct various activities
necessary to meet this goal.
As described in chapter 2 of the PEIS, recent developments in
national security policy have placed new constraints on the types
of activities available to achieve this goal. Specifically, the
United States is committed to ceasing both the production of new-design
nuclear weapons, and the underground nuclear testing of weapons
(see section 2.4). DOE's challenge in developing the stewardship
portion of the Stockpile Stewardship and Management Program has
been to determine whether, and how, to replace, modify, or augment
the existing capabilities of the laboratories and NTS so that
the goal of maintaining a safe, secure, and reliable stockpile
can be met, even as the enduring stockpile ages and underground
testing is no longer available.
DOE has examined from a programmatic perspective various approaches
to achieving this goal, and has determined that only an aggressive
science-based program that relies on sophisticated simulation
and computational technology would allow DOE to continue to ensure
the safety, security, and reliability of the stockpile. Alternate
approaches which are based on principles other than an aggressive
pursuit of the knowledge necessary to predict, detect, and correct
problems with the stockpile cannot achieve DOE's goals. Section
3.1.2 has been expanded to examine various other alternatives
or approaches (such as maintenance, remanufacturing, and a zero-stockpile)
that have been suggested, and to explain why each of them are
incapable of ensuring the stockpile's safety, security, and reliability,
and thus are not reasonable.
Using simulation and computational technology to better understand
the characteristics of nuclear weapons has been an element of
DOE's weapons program for many years. It was historically part
of the Research, Development, and Testing Program, the predecessor
of the proposed stewardship portion of the Stockpile Stewardship
and Management Program. In determining, for the reasons noted
above, that stewardship must be based on similar principles, DOE
effectively eliminated the option of replacing the existing proven
capabilities at the laboratories and NTS with a different, untried
approach. Accordingly, the PEIS focuses on facilities that could
modify or augment the existing capabilities in ways that would
achieve DOE's goal. In summary, DOE and its predecessors have
been "stewarding" the stockpile, utilizing science-based
principles, since the dawn of the nuclear era. DOE believes that
recent policy developments require an even more aggressive application
of these principles to ensure the safety, security, and reliability
of the stockpile.
DOE believes that the PEIS appropriately addresses the role of
existing facilities in the stewardship program. They are described
as part of the No Action alternative, in broad terms in section
3.1.4 and in more detail in chapter 4 and appendix A. This approach
to the No Action alternative (i.e., maintaining the status quo)
is consistent with guidance issued by CEQ (46 FR 180426, March
23, 1981). The environmental impacts of continuing the existing
activities at each of the sites associated with the Complex are
described throughout chapter 4. The cumulative effects that could
result when the impacts of the proposed new facilities are added
to those of existing activities are described in section 4.13.
DOE believes that in this way, the PEIS adequately presents the
impacts of the entire stewardship program, while focusing specifically
on the proposed new facilities that require a DOE decision, and
describing them in context with the existing facilities upon which
DOE would continue to rely on to achieve the goal of a safe, secure,
and reliable stockpile.
Because DOE intends to use the PEIS as a component in decisionmaking
in 1996, only those alternatives that are ripe for decisionmaking
are assessed in detail in the PEIS. Alternatives not yet reasonably
foreseeable, and which have not matured so as to be ripe for decisionmaking,
such as next generation facilities (see section 3.3.4), are not
assessed in detail in the PEIS. Nonetheless, they are acknowledged
and included to the extent practicable.
DOE does not agree with the assertions that stockpile stewardship
could be achieved using passive curatorship. Based on the national
security policies discussed in chapter 2, the future nuclear deterrent
will be based on a smaller, steadily aging nuclear weapons stockpile.
As explained in section 2.3 of the PEIS, historical data would
project that there will be actionable findings that will require
certified repairs or replacements to be made to the nuclear weapons
stockpile. Without underground nuclear testing, which was the
proof-positive means of determining whether a potential problem
existed or whether a problem was corrected, confidence in the
safety and reliability of nuclear weapons must be based more on
judgment.
Judgment-based confidence demands more than passive curatorship.
For judgment-based confidence, DOE is proposing a robust, science-based
stewardship program to obtain accurate scientific and experimental
data which can be correlated with past nuclear test data and used
to validate computer modeling. The existing experimental tools
were used in conjunction with nuclear testing and are inadequate
if used alone. Passive curatorship, or other stewardship-based
approaches which do not include the enhanced experimental tools
that would provide the necessary data to assess and certify a
stockpile without underground nuclear testing, would be inadequate
and unreasonable.
The commentors state that DOE has been inconsistent
in discussing the timeframe analyzed in the PEIS for stockpile
stewardship and management. Related to this, a commentor states
that it is not clear whether the period analyzed is for 25 years
or an indefinite timeframe.
The commentors ask about the three-laboratory
stockpile evaluation program, which DOE office would be responsible
for running the Program, and how many scientists and other skilled
technical workers would be needed to maintain the stockpile and/or
reactivate the weapons program in the future. One commentor asks
if the laboratories will be downsized with the loss of the new
weapons design and testing mission.
One commentor requests that DOE release
the results of studies related to special nuclear materials that
had been set-aside for the express purpose of studying future
aging effects.
The commentors question the Stockpile Stewardship
and Management Program's flexibility to meet changes in stockpile
size. Specifically, commentors ask what analysis was done, if
any, to indicate the limiting factors for secondaries, pit production,
and HE and what is the true surge capabilities for these areas,
and DOE's confidence in meeting these capabilities. Regarding
the capacity/capability of the Complex to respond to unanticipated
needs, one commentor refers to page 8-2 of the Analysis of Stockpile
Management Alternatives report, which states that build rates
above 100 per year would adversely impact the ability of LANL
to perform their surveillance and R&D missions. The commentor
asks if this means that there is no way that DOE could truly support
a surge.
Other commentors ask how the current Stockpile
Stewardship and Management Program ensures the timely up-sizing
of the nuclear weapons system should it become necessary. One
commentor states that the proposed action of increasing production
from a one-shift to a full-time basis using the same production
equipment seems to ignore the fact that the additional training
needed by capable machinists to properly and safely engage in
the highly demanding efforts of weapons production is about five
years. The commentor states that this is an unreasonable delay
in response to an urgent threat. Another commentor suggests that
the best way to accomplish a rapid scale-up of nuclear weapons
production is to establish a sufficient level of comparable machine
work at the production site to employ a staff adequate to go to
a full scale production. The commentor states that the technical
staff including machinists could then be rotated between the weapons
work and the equivalent work to maintain their skills at the proper
level. The commentor believes that if machine shop capabilities
for prototype work were deliberately pursued it should be possible
to employ a staff adequate to ensure a rapid scale-up should it
become necessary.
The commentors refer to the cover sheet
of the Draft PEIS which states that a classified appendix presents
the "purpose of and need for the plutonium-242 to be stabilized
at SRS for use in future weapons complex research and development
activities." Some commentors question why the classified
appendix was referenced, while other commentors believe that unclassified
portions of the appendix should be provided as part of the Draft
PEIS. One commentor further states that the note on the appendix
should have been prominently presented in the body of the Draft
PEIS, rather than at the end of the cover sheet. In addition,
commentors believe that the role of plutonium-242 in the Program
and the nonproliferation implications of separating plutonium-242
and its environmental impacts should be explicitly discussed in
the context of this PEIS, even though these may be covered in
facility-specific statements. Commentors express concern since
plutonium-242 has been linked to serious environmental problems
at SRS. One commentor states that the DARHT EIS should have addressed
all plutonium isotopes, including those outside of LANL.
- Response: The need for plutonium-242
is not classified. Certain information regarding shipping, storage,
and the specific use of plutonium-242 is classified. Section 4.19
discusses the use of plutonium-242 for R&D and the potential
environmental impacts of transporting this material to the alternative
sites. In the Interim Management of Nuclear Materials Environmental
Impact Statement (DOE/EIS 0220) dated October 20, 1995, DOE indicated
that certain quantities of plutonium-242 existed at SRS and that
this material has properties which make it useful for future R&D
activities. In the PEIS, DOE has indicated two alternatives for
this material: to stabilize and continue to store the plutonium-242
at SRS, and to stabilize the plutonium-242 at SRS and transport
this material to either LANL or LLNL. The preferred alternative
is to transport the material from SRS to LANL for storage. Further
details concerning the desirable properties of this material,
the actual quantities, or the technical issues associated with
its use are classified and are contained in a classified appendix
to the PEIS.
The commentor correctly notes that a classified supplement to
the Stockpile Stewardship and Management PEIS has been prepared
to support DOE decisions needed regarding future R&D use of
plutonium-242 and that DOE has prepared a NEPA review of the environmental
impacts from stabilizing plutonium-242 now held in solution at
the SRS. DOE has left decisions for storing the material to the
Stockpile Stewardship and Management Program ROD.
The actions at SRS to stabilize plutonium solutions, including
solutions containing plutonium-242, are directed at addressing
vulnerabilities identified in DOE's Plutonium Vulnerability Assessment
(DOE/EH-0415, November 1994). Correction of these vulnerabilities
has been emphasized by the Defense Nuclear Facilities Safety Board.
DOE decided to convert the plutonium-242 currently in solution
at SRS to oxide which will be placed in storage containers. DOE
has determined that as a matter of policy it has programmatic
need for this material for DP R&D activities.
The commentor asks about plutonium infrastructure outside of LANL
that would be related to DOE's decision to construct and operate
DARHT. As noted in the DARHT EIS, LANL was determined to be the
only reasonable location for DARHT capability; in part this was
due to the existing plutonium infrastructure at LANL that could
support dynamic experiments with plutonium (DARHT EIS, Volume
I, section 3.10.1, page 3-41). DOE did not determine that any
other plutonium facilities, besides the ones at LANL, would be
needed to support operation of DARHT. DOE's decision to operate
DARHT is unrelated to its decisions regarding stabilizing plutonium
solutions at SRS. (See DARHT EIS, Volume II, Comment Response
17-37, page RPC-52.)
A commentor asks what, if any, consideration
has been given to safeguards/inspection provisions in these studies.
The commentors believe DOE "arrogantly"
decided which alternatives are reasonable and do not agree with
the justification for the No Action alternative in the summary
as an unreasonable alternative. One commentor wants to know what
are the reasonable alternatives to the items on the list entitled
"DOE stockpile stewardship costs" and for anything that
DOE does. Another commentor would like more discussion about why
there is a need for improvement in the current process for a Complex
that is not going to be building new weapons. One commentor further
notes that DARHT is considered a fait accompli and the No Action
alternative actually contains significant programmatic commitment
to a next generation hydrodynamic testing facility as well as
many other alternatives mentioned and unmentioned and there have
been no programmatic analyses of alternatives for retaining knowledge
of secondary physics--DOE proposes to build NIF and the Atlas
Facility, but does not mention why this is necessary.
- Response: Reasonable alternatives are
those that would accomplish the purposes and needs described in
the PEIS. These reasonable alternatives are analyzed in detail
in the PEIS. Other alternatives were considered in the PEIS process,
but eliminated from detailed study because they were judged to
be unreasonable, as described in section 3.1.2 of the PEIS. Section
3.1.4 describes why No Action is not a reasonable alternative.
Chapters 2, 3 and appendixes I, J, and K explain the need for
and describe enhanced experimental capability.
DOE believes that the PEIS discusses a full range of alternatives
for implementing the Stockpile Stewardship and Management Program,
and that it analyzes in detail those reasonable alternatives that
are capable of achieving the goals of the Program. DOE also believes
that the PEIS adequately assesses the cumulative impacts of proposed
new activities and existing activities at the sites where the
Stockpile Stewardship and Management Program would be implemented.
It is a well established principle under NEPA that the goals of
a proposed action delineate the limits of the reasonable alternatives
to that action. That is, an alternative which does not accomplish
the agency's goals is not a reasonable alternative. Since its
inception, one of the primary goals of the U.S. nuclear weapons
program has been to ensure the safety, security, and reliability
of the Nation's nuclear weapons stockpile. Numerous facilities
have been built over the years at the three weapons laboratories
(LANL, LLNL, and SNL) and at NTS to conduct various activities
necessary to meet this goal.
As described in chapter 2 of the PEIS, recent developments in
national security policy have placed new constraints on the types
of activities available to achieve this goal. Specifically, the
United States is committed to ceasing both the production of new-design
nuclear weapons, and the underground testing of weapons (see section
2.4). DOE's challenge in developing the stewardship portion of
the Stockpile Stewardship and Management Program has been to determine
whether, and how, to replace, modify, or augment the existing
capabilities of the laboratories and NTS so that the goal of maintaining
a safe, secure, and reliable stockpile can be met, even as the
enduring stockpile ages and underground testing is no longer available.
DOE has examined from a programmatic perspective various approaches
to achieving this goal, and has determined that only an aggressive
science-based program that relies on sophisticated simulation
and computational technology would allow DOE to continue to ensure
the safety, security, and reliability of the stockpile. Alternate
approaches which are based on principles other than an aggressive
pursuit of the knowledge necessary to predict, detect, and correct
problems with the stockpile cannot achieve DOE's goals. Section
3.1.2 has been expanded to examine various other alternatives
or approaches (such as maintenance, remanufacturing, and a zero
stockpile) that have been suggested, and to explain why each of
them are incapable of ensuring the stockpile's safety, security,
and reliability, and thus are not reasonable.
Using simulation and computational technology to better understand
the characteristics of nuclear weapons has been an element of
DOE's weapons program for many years. It was historically part
of the Research, Development, and Testing Program, the predecessor
of the proposed stewardship portion of the Stockpile Stewardship
and Management Program. In determining, for the reasons noted
above, that stewardship must be based on similar principles, DOE
effectively eliminated the option of replacing the existing proven
capabilities at the laboratories and NTS with a different, untried
approach. Accordingly, the PEIS focuses on facilities that could
modify or augment the existing capabilities in ways that would
achieve DOE's goal. In summary, DOE and its predecessors have
been "stewarding" the stockpile, utilizing science-based
principles, since the dawn of the nuclear era. DOE believes that
recent policy developments require an even more aggressive application
of these principles to ensure the safety, security, and reliability
of the stockpile.
DOE believes that the PEIS appropriately addresses the role of
existing facilities in the stewardship program. They are described
as part of the No Action alternative, in broad terms in section
3.1.4 and in more detail in chapter 4 and appendix A. This approach
to the No Action alternative (i.e., maintaining the status quo)
is consistent with guidance issued by the CEQ (46 FR 180426, March
23, 1981). The environmental impacts of continuing the existing
activities at each of the sites associated with the Complex are
described throughout chapter 4. The cumulative effects that could
result when the impacts of the proposed new facilities are added
to those of existing activities are described in section 4.13.
DOE believes that in this way, the PEIS adequately presents the
impacts of the entire stewardship program, while focusing specifically
on the proposed new facilities that require a DOE decision, and
describing them in context with the existing facilities upon which
DOE would continue to rely to ensure a safe, secure, and reliable
stockpile.
Commentors feel the Stockpile Stewardship
and Management Program is a responsible and necessary program
for the U.S. stockpile of nuclear weapons. One commentor states
that the NPT and CTBT depend on the Stockpile Stewardship and
Management Program, especially NIF. In the absence of underground
nuclear testing, other commentors believe that the Stockpile Stewardship
and Management Program is absolutely vital for maintaining the
basics of nuclear weapons physics and keeping track on the condition
of the weapon stockpile. One commentor notes that it is important
for the United States to have the leading edge of nuclear weapons
know-how, irrespective of the winds of day-to-day politics. Another
commentor states that given the requirement for a safe and reliable
stockpile, the ban on underground testing, and the shrinking size
of the stockpile, downsizing the overall DOE Complex while building
new facilities is reasonable. The commentor supports the new facilities
proposed because they are necessary to provide missing data for
computer modeling which cannot be supplied by underground nuclear
testing and can validate fixes for defects discovered during surveillance
and testing.
The commentor states that NTS has been part
of any number of programs that could possibly come to the site,
yet those programs end up going to LANL and LLNL and inquires
about the possibility of NIF going to NTS. Another commentor thinks
that table 3.3-1, section 3.3, should acknowledge the expertise
at NTS in the experimental primaries and secondaries and should
also recognize NTS as a potential site for the siting of large
experimental facilities to do weapons simulation and effects tests.
- Response: DOE has looked at adding several
missions to NTS, given that maintenance of the test site for nuclear
test readiness remains a national policy requirement. To date,
all proposed new missions for stockpile stewardship and management
have had compelling cost and technical reasons for selecting other
sites as the preferred alternative. DOE will continue to look
at NTS for potential future siting of new program missions.
The preferred site alternative for NIF is LLNL. The preferred
alternative does not represent a decision, however. The ROD for
NIF will be made no sooner than 30 days after the filing of the
Final PEIS with the EPA. NTS is a reasonable site alternative
for NIF, and could be selected in the ROD.
Table 3.3-1 is intended to show a broad view of current capabilities
and alternatives considered in the PEIS. As stated in section
3.2.9, Nevada Test Site, DP activities, stockpile stewardship
activities at NTS include conventional HE tests, dynamic experiments,
and hydrodynamic tests. These types of tests can be used to study
the physics of weapons primaries. NTS activities relating to weapons
effects and the physics of weapons secondaries have historically
been nuclear tests, which are considered as an future option only
under the "supreme national interests" provisions of
any future CTBT. Additionally, as stated in section 3.3.3, Weapons
Effects, DOE is not proposing in this PEIS any new facilities
or alternatives solely for the study of weapons effects, and would
use existing facilities. A table has also been added to appendix
section A.1 further describing major existing DP facilities and
activities at these sites.
The commentor recommends a worldwide multi-national
testing program at NTS where all nuclear nations may test their
own nuclear devices under close supervision and control of the
International Atomic Energy Agency. In the commentor's opinion
NTS features all required services, support, maintenance, and
insularity in place for such an international venture. Commentor
feels that a single world testing site would standardize international
testing while lowering the cost per user, would allow the definition
of a legitimate nuclear club, and the regime could corral mavericks
engaged in unannounced and covert buildup of unproved assets.
A commentor wants to know if the sites followed
any standards when submitting numbers for the PEIS.
The commentor raises the concern that the
Albuquerque Operations Office was censoring DOE contractor employees
from participating in the public hearings.
The commentor thinks that Summary section
S.3.6 should list NTS as an alternative site for all of the large
experimental physics machines.
- Response: NTS is listed as an alternative
site for NIF. For the remaining facilities, NTS was not considered
a reasonable alternative and is not listed. As discussed in section
3.3.1.2, Proposed Contained Firing Facility, and in appendix J,
CFF would augment and upgrade the existing Flash X-Ray (FXR) Facility
at LLNL, and therefore LLNL is the only reasonable site. Similarly,
section 3.3.2.3, Proposed Atlas Facility, and appendix K state
that Atlas would build on existing special equipment at LANL such
as the 1,430 megavolt-ampere (MA) generator in Building 301, and
therefore LANL is the only reasonable site.
The commentors express opposition to the
Stockpile Stewardship and Management Program, including NIF, stating
that they are dangerous and morally wrong. Some commentors remark
that it is a waste to use "human genius" in this manner
since these talents may be used to solve conflicts and the growing
inequality of the world. One commentor believes the United States
is misinforming people by saying the United States will not be
producing and testing nuclear weapons. Another commentor believes
that the United States must revise its objectives and should be
focusing more on educating the youths of society and finding a
cure for cancer. The commentor does not believe the numbers associated
with downsizing. The commentor points out that the public knows
the truth from a lie, and the lie is the production and expansion
of destructive weapons in the society.
The commentors express the opinion that
stewardship of the nuclear stockpile is a function that is best
done at LANL. Stewardship is a critical component of the Nation's
security and LANL can guarantee the integrity of the Nation's
stockpile, according to the commentors. One commentor indicates
support for consolidating a portion of the weapons production
capability at LANL. Another commentor notes that LANL is developing
technologies for recycling, storage, and disposal of plutonium
and enriched uranium; technologies to reclaim contaminated sites
and safely dispose of waste; technologies to monitor and analyze
the storage of nuclear components; technologies to detect clandestine
nuclear tests; and programs to transfer technology to the Soviet
Union. Given the state of affairs in the world today with respect
to nuclear weapons, the commentor believes that if LANL did not
exist, it would have to be invented because this Nation and the
world needs LANL and the technologies that it can provide.
The commentors state that DOE overlooked
the potential for Pantex, to perform new stewardship functions
complementary to its current management functions. Some commentors
want DOE to designate Pantex as the preferred alternative for
all existing and new stockpile management and stewardship functions
as well as consolidation of all plutonium storage and disposition
and any related functions. According to the commentors, Pantex
has the resources, safeguards and security, existing facilities,
and proximity to LANL for technological information exchange (Atlas
Facility and proposed plutonium pit fabrication site) to downsize
and/or consolidate while preserving the integrity of the nuclear
stockpile under increasing budgetary constraints. Utilizing facilities
already in place at Pantex could eliminate costs of duplicating
facilities, related transportation, environmental remediation,
and start-up and training, according to the commentors. Several
commentors also note that Pantex is perhaps the most cost effective
alternative for any of the new construction that is contemplated.
While commentors state that there is a strong history of community
support, they caution that current and future functions at Pantex
must be conducted in a safe and environmentally sound manner and
that expansion must be implemented in a way that does not impair
the health or safety of area residents or adversely affect the
environment.
- Response: The rationale for the various
site alternatives are discussed in chapter 2, as well as in various
portions of section 3.1 of the PEIS. Pantex is considered as a
reasonable site alternative for the A/D mission, strategic reserve
storage, and HE fabrication. Pantex does not have an existing
infrastructure for plutonium fabrication, secondary fabrication,
and nonnuclear component fabrication. Consequently, Pantex was
not considered as a reasonable alternative for these missions.
Pantex was not considered as a reasonable site alternative for
stockpile stewardship facilities as explained in section 3.1.2.1.
Pantex has essential capabilities to support the future stockpile
management program. In selecting reasonable alternatives for future
stockpile stewardship and management missions, however, DOE found
it to be unreasonable to address alternatives for new missions
where no core capability for that new mission was present at the
site. In addition, DOE sought alternatives that tended to further
consolidate and streamline the infrastructure for the Program
because of the overall general reductions in work to be performed.
For these reasons, it was determined to be unreasonable to consider
stewardship experimental capabilities and plutonium pit production
at Pantex, just as it was unreasonable to consider relocation
of the weapon A/D mission to sites which had no core capability
or facility infrastructure to deal with nuclear explosives.
The commentors ask how the current Stockpile
Stewardship and Management Program minimizes the impacts on weapons
performance due to inadvertent or unavoidable changes in production
methods. One commentor believes that the statement that surrogate
testing will be used to keep the weapons database current is misleading.
The commentor suggests that one method is to devote a new effort
to document the details of the current production methods and
to establish procedures which will minimize the changes in weapons
performance resulting from inadvertent or unavoidable incremental
changes in the weapons stockpile. Some commentors express concern
that surrogate testing while useful does not ensure unpredicted
changes in performance. In addition, commentors do not believe
that the PEIS adequately focuses on resources devoted to surrogate
testing, the stabilization and preservation of manufacturing capabilities,
and the need for weapons experts to participate in the decisionmaking
process.
The commentor feels that the overall policy
direction is fatally flawed and leading completely in the wrong
direction. The commentor states that the overall policy direction
leads the environmental study to worry about such minutiae as
one fatal cancer every 5 million years when they are concerned
with the nuclear safety of the world involving real weapons of
mass destruction, literally tons of plutonium, and an environmental
mess.
The commentor states one of the fundamental
flaws of the Draft PEIS is the outdatedness of all LANL environmental
data and feels that referencing the 1992 LANL Environmental Surveillance
Report as "LANL 1994b" is deceptive.
The commentor states that the Draft PEIS
fails to describe the only programmatic alternatives actually
considered, namely Stockpile Stewardship and Management and No
Action alternatives, in a way that allows useful comparison. For
stewardship, the only alternative to building the proposed facilities
is a No Action alternative continuing operation of existing facilities
with the same function. The commentor states that the Draft PEIS
fails to describe the No Action alternative in a comprehensible
manner. The commentor contends that the No Action description
is poorly written, confusing, and does not provide information
sufficient to inform the reader of the actual activities it encompasses.
The commentor states that the No Action alternative does not describe
currently existing operations and facilities at DOE sites--rather,
it is an arbitrarily chosen set of "not stockpile stewardship
and management" activities, some of them in fact part of
the stockpile stewardship and management programs, which are expected
to be in operation almost a decade from now. The commentor believes
that the PEIS does not adequately delineate what the No Action
set of facilities are at any given site. This renders it virtually
useless for comparison with the already too narrow range of alternatives,
according to the commentor. The commentor further argues that
the deficiency of the No Action alternative alone is sufficient
reason to withdraw the PEIS and republish the draft. One commentor
stated that the use of a specific date for ground-breaking (i.e.,
September 1995) was inappropriate to define the No Action alternative.
- Response: In accordance with NEPA, the
PEIS assesses the No Action alternative. The No Action alternative
is described in broad terms in section 3.1.4, and in more detail
in chapter 4 and appendix A of the PEIS. Under No Action, DOE
would not take the actions proposed in the PEIS, but would continue
with existing operations. For stockpile stewardship, this means
continuing the existing activities at LANL, LLNL, SNL, and NTS
related to stockpile stewardship. In order to aid the reader's
understanding of the major facilities that make-up the No Action
alternative for stockpile stewardship, tables have been added
to the site descriptions in appendix section A.1 of the PEIS.
During preparation of the Draft PEIS, the September 1995 planning
assumption was used as one of the considerations in determining
whether a new facility or upgrade would be part of No Action.
However, it was not the only consideration. DOE also considered
whether a particular facility was addressed in prior NEPA documentation,
whether a facility met the requirements of the CEQ for an interim
action, and whether a facility or a modification was the continuation
of an existing mission. The Final PEIS contains a more appropriate
description of the rationale for No Action. As stated in the Final
PEIS, the No Action alternative for this PEIS is defined in a
way that takes into account the fact that DOE for decades has
had in place a program for the stewardship and management of the
nuclear weapon stockpile. Consistent with CEQ guidance, the No
Action alternative consists of those facilities necessary to maintain
the status quo in terms of DOE's current program direction. These
consist primarily of existing facilities where DOE conducts weapons
activities, including modifications to those facilities necessary
to maintain their current mission capabilities. However, the No
Action alternative also includes a small number of minor new facilities
that will also be needed simply to maintain current mission capabilities
at individual sites. Finally, the No Action alternative includes
two major new facilities which are proceeding independent of this
PEIS, and for which DOE has prepared separate EISs under the interim
action provisions of the CEQ regulations. These EISs are the PEIS
for Tritium Supply and Recycling (DOE/EIS-0161) and the DARHT
EIS (DOE/EIS-0228).
The commentor wants to know what evacuations
plans have been developed in the event of a nuclear accident or
catastrophic fire at LANL. Because of the limited egress in and
out of the Los Alamos region, the lack of well thought out and
publicized evacuation plans can have grave consequences.
The commentor states that the Stockpile
Stewardship and Management Program is not described in a manner
which would allow for meaningful comparison with other true program
alternatives. The commentor states that major parts of the Program,
including facilities and actions which are incomplete or have
not been started, have been eliminated from consideration, including
for example, DARHT and tritium production facility options. DOE
has initiated or completed hundreds of millions of dollars worth
of new facilities and facilities upgrades throughout the Complex,
apparently implementing portions of the Program which the reconfiguration
PEIS was supposed to review and the commentor contends that this
refurbishment of the Complex in the absence of programmatic review
has substantially narrowed the range of options which DOE conceives
as feasible. The commentor believes that the public would have
been far better served by using this PEIS for a comprehensive
look at the environmental impacts of the full Stockpile Stewardship
and Management Program, the Complex of the future as envisioned
by DOE, in comparison with other programmatic options (denuclearization,
remanufacture, and such) for managing the nuclear arsenal (which
citizen groups have been demanding for 5 years). Instead, the
commentor states that the end result of 5 years of reconfiguration
is the presentation to the public of a fait accompli, with the
fundamental policy decisions already made and major program components
(e.g., DARHT) already underway.
The commentor asks if DOE has integrated
the PEIS with the DOD mission.
The commentors believe that the Draft PEIS
does not analyze a range of reasonable programmatic alternatives
to meet the goal of maintaining the stockpile safely in accordance
with treaty obligations. The commentors contend that the analysis
in the Draft PEIS suggests that the debate over stockpile stewardship
and management is over and that the program alternative has already
been determined. According to the commentors, these are fundamental
problems which prevent meaningful participation by the public
and obfuscate informed analysis by decisionmakers. The commentors
believe that DOE should withdraw the Draft PEIS and prepare a
revised Draft PEIS, while all programmatic decisions and activities
are put on hold. The revised Draft PEIS should analyze "maintenance,"
"remanufacturing," interim stockpile sizes, and a "zero"
stockpile case--both with and without the capability to reconstitute
the arsenal--which is based upon a scenario of global reduction
and elimination of nuclear weapons in compliance with Article
VI of the NPT over time periods ranging from 15 years to the projected
lifetime of the proposed facilities (on the order of 40 years).
The commentors believe that the PEIS should include alternatives
examining the impacts of a policy course of reduction of nuclear
weapons, ultimately resulting in their elimination pursuant to
U.S. obligations under Article VI of the NPT. The commentors state
that the PEIS should analyze the environmental impacts for a stockpile
size of less than 1,000 weapons. Several commentors, noting the
NPT calls for a move toward disarmament, believe that the 0 to
100 stockpile size is a reasonably foreseeable situation and should
be analyzed. Other commentors argue that a zero-level stockpile
should be considered because it would satisfy nonproliferation
obligations and there is overwhelming public support for such
an idea. One commentor questions the rationale for the stockpile
sizes assessed in the PEIS. More specifically, the commentor implies
that the lower case 1,000 weapons stockpile is not well supported.
Another commentor disagrees with DOE's assertion that "stockpile
management capabilities are independent of stockpile size."
In one commentor's opinion, the combination of an extremely one-sided
analysis of potential effects on the weapons nonproliferation
climate, the elimination from detailed analysis of all substantive
program alternatives to the proposed action, and technical analysis
which conclude that a large complex can be rebuilt and operated
with few impacts at facilities with still unsolved waste and contamination
problems, leaves little doubt that the purpose of this Draft PEIS
is "to justify decisions already made" (40 CFR 1502.5).
- Response: DOE believes that the PEIS
discusses a full range of alternatives for implementing the Stockpile
Stewardship and Management Program, and that it analyzes in detail
those reasonable alternatives that are capable of achieving the
goals of the Program while still fully complying with the treaty
and national security policy constraints established independently
from the Stockpile Stewardship and Management Program. DOE also
believes that the PEIS adequately assesses the cumulative impacts
of proposed activities and existing activities at the sites where
the Stockpile Stewardship and Management Program would be implemented.
It is a well-established principle under NEPA that the goals of
a proposed action delineate the limits of the reasonable alternatives
to that action. That is, an alternative which does not accomplish
the agency's goals is not a reasonable alternative. Since its
inception, one of the primary goals of the U.S. nuclear weapons
program has been to ensure the safety, security, and reliability
of the Nation's nuclear weapons stockpile. Numerous facilities
have been built over the years at the three weapons laboratories
(LANL, LLNL, and SNL) and at NTS to conduct various activities
necessary to meet this goal.
As described in chapter 2 of the PEIS, recent developments in
national security policy have placed new constraints on the types
of activities available to achieve this goal. Specifically, the
United States is not producing new-design nuclear weapons or conducting
underground nuclear testing (see section 2.4). DOE's challenge
in developing the stewardship portion of the Stockpile Stewardship
and Management Program has been to determine whether, and how,
to replace, modify, or augment the existing capabilities of the
laboratories and NTS so that the goal of maintaining a safe and
reliable stockpile can be met, even as the enduring stockpile
ages and underground testing is no longer available.
DOE has examined from a programmatic perspective various approaches
to achieving this goal, and has determined that only an aggressive
science-based program that relies on sophisticated simulation
and computational technology would allow DOE to continue to ensure
the safety and reliability of the stockpile. Alternate approaches
which are based on principles other than an aggressive pursuit
of the knowledge necessary to predict, detect, and correct problems
with the stockpile cannot achieve DOE's goals. Section 3.1.2 has
been expanded to examine various other alternatives or approaches
(such as maintenance, remanufacturing, and a zero stockpile) that
have been suggested, and to explain why each of them are incapable
of ensuring the stockpile's safety and reliability, and thus are
not reasonable.
Since the end of the Cold War, the United States has significantly
reduced the size of its nuclear weapons stockpile and the DOE
has dismantled more than 8,000 nuclear weapons. At the present
time, the United States is further downsizing the nuclear weapons
stockpile consistent with the terms of the START I Treaty, and
DOE is continuing dismantlement. The United States has recently
ratified the START II Treaty and is hopeful that Russia will likewise
ratify this treaty. DOE acknowledges that further multilateral
negotiated reductions in the United States nuclear weapons stockpile
could occur. However, as discussed below, the negotiations required
for such reductions are likely to stretch well into the next century.
Therefore, DOE believes the three stockpile sizes utilized for
the analysis in the Stockpile Stewardship and Management PEIS
fully account for future requirements while still being consistent
with and fully supportive of the goals of Article VI of the NPT.
Two of the three stockpile sizes analyzed in this PEIS, a START
I Treaty- and START II protocol-sized stockpile, are the only
ones currently defined and directed by national security policy.
The NWSM specifies the types of weapons and quantities of each
weapon type by year (section 1.1). The NWSM is developed based
on DOD force structure requirements necessary to maintain nuclear
deterrence and comply with existing arms control treaties while
pursuing further arms control reduc-
- tions. Chapter 2 of the PEIS explains
the complexity of this process. DOE does not believe it reasonable
to speculate with a large number of arbitrary assumptions (section
2.2), and has selected a range of stockpile sizes appropriate
for the analysis and consistent with relevant policy documents.
The "low case" 1,000 weapon stockpile represents a hypothetical
case used for the purpose of a sensitivity analysis on manufacturing
capacity decisions. No specific DOE force structure projection
corresponds to the low case assumed stockpile. However, stockpile
sizes in this range have been proposed by others (see for example
Foreign Affairs, Spring 1993).
Stockpile stewardship capabilities are currently viewed by the
United States as a means to further U.S. nonproliferation objectives
in seeking a zero-yield CTBT. Likewise, it would be reasonable
to assume that U.S. confidence in its stewardship capabilities
would remain as important, if not more important, in future arms
control negotiations to further reduce its stockpile. The path
to a very small (10s or 100s) or zero stockpile would require
the negotiation of complex international treaties that are also
likely to require intrusive verification inspections of nuclear
weapons-related facilities. Therefore, DOE believes it reasonable
to assume that complex treaty negotiations, when coupled with
complex implementation provisions, would likely stretch over several
decades. On a gradual path to a very small or zero stockpile,
stockpile size alone would not change the purpose and need, proposed
actions, and alternatives in this PEIS as they relate to stewardship
capabilities. The issues of maintaining the core competencies
of the United States in nuclear weapons, and the technical problems
of a smaller aging stockpile in the absence of nuclear testing,
remain the same.
This PEIS evaluates reasonable approaches to stockpile management
capability and capacity that is consistent with a gradual path
toward a very small or zero stockpile. At some point on this path,
further downsizing of existing industrial plants or the alternative
of consolidating manufacturing functions at stewardship sites
would become more attractive as manufacturing capacity becomes
a less important consideration. However, in the near term, the
preferred alternative of downsizing the existing industrial plant
would still be a reasonable action because the projected downsizing
investment pays back within a few years through reduced operating
expense; in addition, the downsizing actions are consistent with
potential future decisions regarding plant closures. In regard
to the proposed action for reestablishing pit manufacturing capability,
DOE does not propose to establish higher manufacturing capacities
than are inherent in the reestablishment of the basic manufacturing
capability of LANL, which is the preferred alternative. In developing
the criteria for reasonable stockpile management alternatives,
DOE was careful not to propose the introduction of significant
new types of environmental hazards to any prospective site. Therefore,
on a gradual path to a very small or zero stockpile, stockpile
size alone would not change the purpose and need, proposed actions,
and alternatives in this PEIS with regard to stockpile management
capabilities and capacities.
In conclusion, as a result of the START I Treaty, START II protocol,
and the NPR, the Nation's nuclear weapons stockpile is being significantly
reduced. However, even in the post-Cold War period, international
dangers remain, and nuclear deterrence will continue to be a cornerstone
of U.S. national security policy for the foreseeable future. Thus,
DOE'S responsibilities for ensuring the safety and reliability
of the U.S. nuclear weapons stockpile will also continue.
Regarding the comment that DOE should prepare a revised Draft
PEIS, DOE believes that the Draft PEIS was adequate. The Draft
PEIS assessed the direct, indirect, and cumulative environmental
impacts of the reasonable alternatives for the proposed action
and the No Action alternative. In response to public comments
on the Draft PEIS, DOE has made changes to the Draft PEIS as described
in section 1.8 of the Final PEIS. Additionally, DOE has prepared
this Comment Response Document which describes the comments received
on the Draft PEIS and DOE's responses to those comments.
The commentor suggests that DOE provide
a definition of hazardous chemicals in the glossary or possibly
use the term "hazardous substances."
The commentor states that the most egregious
deficiency of the PEIS is the total failure to include current
Congressional legislation (National Defense Authorization Act
for Fiscal Year 1996, Title XXXI, particularly sections 3137 and
3153) and associated national security policy guidance. The conclusions
of the House and Senate markups for fiscal year 1997 must also
be considered. The PEIS must be redone based on the full range
of national security policies both Congressional and Presidential,
according to the commentors.
- Response: Chapter 2 of the PEIS discusses
the major national security policy considerations that are most
relevant to the PEIS analysis. Included in that discussion are
PDDs, Congressional legislation, DOD NPR, the NWSM, and four related
treaties. While that list of national security policy considerations
is not meant to be exhaustive, it does represent, in DOE's view,
the most significant national security policy overlays that define
the Stockpile Stewardship and Management Program conditions for
the reasonably foreseeable future. Based on our understanding,
the Draft PEIS analysis is consistent with the current Congressional
legislation (National Defense Authorization Act for Fiscal Year
1996, Title XXXI). The Final PEIS analysis takes into account,
as appropriate, any other relevant 1997 legislation.
The commentor refers to section 3.3.4.2
and asks what are the "prohibitively expensive alternative
approaches" to the High Explosives Pulsed-Power Facility
(HEPPF).
The commentor refers to section 3.5 and
states, after all the concern expressed about subtle changes in
materials and processes, emerging technologies propose continuing
work in areas which represent significant changes in processes
and materials. The commentor asks if the intent to protect technical
capability is to have technologies available in case of a resumption
of testing or a breakthrough in experimental technology, or whether
there is an expectation that DOE can just go ahead and use them
regardless of our previous protestations.
The commentor refers to section 2.3.4, and
the different materials that are referred to in this section,
whose aging characteristics are not well understood. The commentors
question whether these materials could not be replaced without
compromising the military objectives of the stockpile.
The commentor expresses the opinion that
Pantex should be the preferred site for future Complex missions.
- Response: One important strategy of
the Stockpile Stewardship and Management Program is to maximize
the use of existing infrastructure and facilities as we transition
to a smaller and more efficient Complex in the 21st century. Consequently,
only those sites with an existing infrastructure or facilities
capable of supporting a given stockpile stewardship or stockpile
management mission are considered reasonable site alternatives.
Sites without a technical infrastructure or facilities for a given
mission would require significant new construction that would
be costly and would create excessive technical risk compared to
sites with existing missions. Pantex is only being considered
for weapons A/D, HE fabrication, and storage of nuclear materials.
With regard to stockpile stewardship, the majority of the Nation's
core competencies in nuclear weapons, as well as the facilities
used for stockpile stewardship, reside at the weapons laboratories
and NTS. The President has determined that the continued vitality
of all three DOE weapons laboratories and NTS remains essential
to meet the requirements of stockpile stewardship as the United
States enters into a CTBT regime. Accordingly, to locate stewardship
activities at sites without the knowledge base and infrastructure
would be counterproductive to the development of science-based
stockpile stewardship. Further, two of the proposed stockpile
stewardship facilities, the Atlas Facility and CFF utilize existing
facility infrastructure at LANL and LLNL, respectively.
Commentors would like DOE to reconcile a
declining budget at Pantex with an increasing workload. The commentors
state that the fiscal year 1997 budget as proposed will lead to
a reduction in force at Pantex. One commentor, noting that the
Stockpile Management Preferred Alternatives Report reveals that
Pantex, but not Y-12 or KCP, will undergo this decrease in budget,
asks why Pantex is suffering budget cuts if the workload is constant
and the other production facilities are not suffering budget cuts.
The commentor states that the enduring stockpile
was built from the late 1970s to the early 1990s, approximately
a 12-year period. Assuming the stockpile has 8,400 weapons in
it and that the life of a weapon is about 30 years, in 2008, we
would have to replace the stockpile at a rate of 700 units per
year. DOE is sizing the Complex to handle about 300 units per
year. The commentor would like DOE to explain this disconnection
and what it proposes to do about it.
The commentors state that they have no confidence
in DOE due to a past history of lies and deceptions in the nuclear
program. One commentor states that DOE should address the deceptions
in the nuclear program. Another commentor believes that a war
crime tribunal should be established to review past mistakes of
DOE in order to charge them with first degree murder and hang
them.
The commentor believes the stated rationale
that the proposed Stockpile Stewardship and Management Program
is needed to maintain stockpile safety and reliability does not
square with available data. The commentor states that without
DOE's rationale for the Stockpile Stewardship and Management Program,
it would be difficult for DOE to justify operating current facilities,
much less build new ones, since official policy now proclaims
that no new weapons will be produced. The commentor references
that Sandia Stockpile Life Study which found that with surveillance
and repair, U.S. nuclear weapons retain high safety and reliability.
Further, defects caused by aging are rare and have not increased
over time and the stockpile is not now reaching an advanced age
due to scheduled retirements under arms reduction agreements.
The commentor opines that weapons are becoming safer as older
weapons types are retired. According to the commentor, the study
adds weight to previous studies and expert opinion showing that
the safety and reliability of the U.S. nuclear weapons stockpile
can be maintained under a comprehensive nuclear testing ban. Once
corrected for additional weapons systems, the commentors believe
that the 1995 Stockpile Surveillance: Past and Future
report essentially validates the 1993 Stockpile Life Study. The
commentor states that key implication of the stockpile study--the
U.S. arsenal is highly reliable, underground testing has rarely
been used to confirm the reliability of stockpiled weapons, and
future defects can be fixed with existing surveillance programs
and facilities--are highly relevant to the proposed Stockpile
Stewardship and Management Program.
- Response: The underlying rationale for
the Stockpile Stewardship and Management Program is the need to
ensure the continued viability of this Nation's nuclear deterrence.
The commentor references the Sandia Stockpile Life Study, for
which a set of viewgraphs for a status briefing were prepared
by SNL in 1993. However, the data used to develop the interim
study arose from a database which was recognized to be incomplete
and inadequate in that much data, particularly that relating to
problems found through methods outside the DOE's formal Stockpile
Evaluation Program, were incompletely or inconsistently documented.
In particular, findings and "actionable" findings associated
with the nuclear package (including the weapons primary and secondary)
were not completely documented. DOE understands that Sandia never
completed a stand-alone stockpile life study. Instead, at the
request of DOE, the three weapons laboratories (LANL, LLNL, and
SNL) subsequently conducted a joint study, Stockpile Surveillance:
Past and Future (Johnson et al., 1995), which has updated Sandia's
preliminary data to provide a more accurate look at the condition
of the stockpile. This study was made publicly available in 1995
and was discussed in the PEIS. Sandia's preliminary findings were
reassessed, corrected, and incorporated into the tri-laboratory
study. DOE does not agree that Sandia's preliminary study "undercuts"
the Stockpile Stewardship and Management Program, as suggested
by commentor; rather, this preliminary study examined some of
the types of problems with the enduring stockpile that led to
the development of the Stockpile Stewardship and Management Program.
The commentor asks what the environmental,
social, cultural, and spiritual impacts, of having stockpile stewardship
including DARHT, on all the communities near Los Alamos, the people,
the air, the flora, the fauna, aquifers, livestock, agriculture,
rivers, streams, businesses, and tourism of the states of Arizona,
Colorado, New Mexico, Texas, and Utah and on the Nation.
The commentors express opposition to all
current and future nuclear weapons work at LANL including work
associated with the Stockpile Stewardship and Management Program.
Another commentor questions the selection of LANL based on allegations
of sexual harassment at Albuquerque and pornographic Internet
"play" at Sandia.
Commentors believe Pantex is the wrong place
for plutonium storage. Another commentor believes DOE has decided
that long-term storage in Zone 4 is unsafe. One commentor states
that he does not want Pantex to become the next Rocky Flats where
the only jobs are for nuclear waste handlers and regulators. Another
commentor believes plutonium is too dangerous to transport.
Some commentors believe the PEIS should
include the new mission of recertifying dispositioned HEU and
plutonium in section 2.4, Purpose and Need, and section 3.2, Stockpile
Management. One commentor cites section 3.5.4 and questions why
explosive materials are disposed of, but plutonium and HEU are
dispositioned. The commentor asks if a pit and plutonium/HEU residue
are classified, and thus dispositioned, why would HE that is classified
be disposed of. Commentor also asks why is classified HE potentially
part of "alternative disposal technologies" and not
"alternative disposition technologies." Another commentor
asks if section 2.4.2, Industrial Base, should include a mission
for recertifying non-fissile materials placed into storage and
disposition. Another commentor asks what is excess explosive materials
and what is the difference between that and surplused plutonium
and HEU.
The commentors refer to appendix section
A.3.1, and based on the estimate of 200 weapon parts per weapon,
asks the following questions: how many parts are backlogged waiting
for sanitization and demilitarization; if a backlog exists, what
are the impacts of downsizing, relocating, and no action, on this
backlog; who is responsible for sanitization and demilitarization;
why isn't this discussed in infrastructure; why aren't the impacts
assessed; and what is the through-put capacity of sanitization
and demilitarization for each of the 200 estimated parts; are
these processes readily available at other sites; and has DOE
considered the nonproliferation capability in selecting alternatives.
The commentors believe SRS should receive
a major role in the programs as determined in the ROD because
it has the people, facilities, security, infrastructure, experience,
and support from adjacent communities that will assist DOE in
accomplishing the desired missions without adversely affecting
the environment and saving taxpayers millions of dollars.
The commentor states that it is impossible
to reduce the risk from nuclear weapons accidents to zero; however,
and in particular, there will always remain some risk that plutonium
will be dispersed by fire or explosion. The commentor believes
the simplest and best ways to further minimize this possibility
are operational and deployment changes that reduce the chances
of an accident and risk to the public and further retirements
which lead to a smaller arsenal.
The commentor states that the citizens of
Los Alamos are entitled to know the current environmental conditions
of LANL before deciding whether the University of California has
been good steward of existing hazardous materials. Another commentor
believes there is serious mismanagement of the laboratory by the
current contractor resulting in continuing non-compliance with
environmental laws and NEPA violations.
- Response: DOE is committed to fully
complying with all applicable environmental statues, regulatory
requirements, and Executive and internal orders. All DOE facilities
comply with the Emergency Planning and Community Right to Know
Act (42 USC § 11001), which requires facilities to report
the release of extremely hazardous substances and other specified
chemicals; to provide material safety data sheets; and to provide
estimates of the amounts of hazardous chemicals onsite. The conditions
at LANL are described in section 4.6.2 of the PEIS.
In general, contracting is not subject to NEPA review (see 10
CFR 1021, subpart D, appendix A, except regarding procurements
for developing new or emerging technology).
- Although the commentor correctly points
out that operations at LANL have occasionally been found to be
out of compliance with various environmental laws, DOE and LANL
management have made good faith efforts to bring laboratory facilities
into compliance in a timely manner. DOE expects its management
and operating contractors to operate its facilities in compliance
with all Federal, state, and local laws, and the University of
California, as management and operating contractor for LANL, has
pledged to do so. DOE's confidence in the University of California
is reflected in DOE's recent decision to extend the University's
management and operating contract for LANL, LLNL, and Lawrence
Berkeley Laboratory for another 5 years.
The commentor makes a number of allegations, most of which are
unrelated to the University's management of the laboratory. While
the courts found that an EIS should be prepared for the DARHT
facility, DOE is unaware of any other NEPA violations, although
DOE's Tiger Team recommended in 1991 that a site-wide EIS be prepared
for LANL; regardless, the NEPA process is conducted by DOE, not
the University of California. DOE is unaware of any refusal on
the part of the university regents to meet with the citizens or
legislators of New Mexico, subject to their schedule constraints,
and the regents have held several public meetings in New Mexico
on the subject of LANL operations. The laboratory conducted both
a voluntary separation program and a reduction in force in 1995
to streamline its operations; these were conducted within the
University of California personnel procedures as they apply to
LANL and with the support and approval of both the University
of California and DOE. Statistics compiled by LANL do not indicate
that these actions disproportionately affected minorities or ES&H
Division personnel. This matter is the subject of current litigation.
DOE supports the LANL practice of debating opposing scientific
theories in an atmosphere of academic freedom, and does not agree
that the integrity of either the laboratory's environmental or
scientific programs are under question.
The commentor believes that the PEIS does
not make a realistic distinction between strategic and surplus
plutonium. The commentor believes that the effort to maintain
two-thirds of the plutonium in the United States is evidence that
the country is not serious about disarmament and also gives rise
to the suspicion that some effort is being made towards using
plutonium for commerce.
The commentor asks where fabrication of
enriched uranium primaries will be assigned.
One commentor requests that economy and
safety be the first considerations in Stockpile Stewardship and
Management Program. The commentor also expresses concern about
the cost of cleanup in the event of a catastrophe. Another commentor
does not want decisions concerning the location of operations
and activities to fall into the "not in my back yard"
syndrome. The commentor believes impacts should be minimized to
all workers, families, and communities; and to the environment.
The commentor asks, relative to section
3.2.2, what ORR DP assignments are not performed by Y-12.
The commentors request an explanation from
DOE on why LANL and LLNL stockpile management budgets show projected
increases from 1996 to 2004 since the United States has terminated
the development of new nuclear weapons. Commentors reference the
Stockpile Management Preferred Alternatives Repor t,
pages 26 and 30. One commentor asks if these projected increases
are based on transferring of missions from the production plants.
A commentor found the Draft PEIS unclear
with respect to the intended aims and plans that are being proposed
for the Panhandle area. Other commentors reiterated the community's
adamant position that all work performed at Pantex continue to
be done in a fashion that protects the environment including national
resources such as the Ogallala aquifer and agricultural land.
- Response: Pantex was considered a reasonable
alternative site for the weapons A/D mission and the HE fabrication
mission. The weapons A/D mission is described in section 3.4.1,
and includes provisions for nonintrusive modification pit reuse
and strategic storage of plutonium and uranium in the form of
pits and secondaries. Secondaries would not be stored at Pantex
if Y-12 retains the secondary and case fabrication mission. Additionally,
storage of all or a portion of the strategic reserve could be
at another site, depending on DOE decisions regarding the Storage
and Disposition PEIS. The HE fabrication mission is described
in section 3.4.5, and includes HE procurement, formulation, component
fabrication, characterization, surveillance, disposal, and storage.
Analysis of the water and land-use impacts associated with each
Pantex alternative were included in the Draft PEIS. Selection
of the preferred alternatives was accomplished with full weight
given to the results of this analysis. The Analysis of Stockpile
Management Alternatives report and the Stockpile Management
Preferred Alternatives Report are available for public review
at the DOE Public Reading Rooms near each site.
As stated in section 3.1.1, Planning Assumptions and Basis for
Analysis, DOE would emphasize compliance with applicable laws
and regulations and accepted practices regarding industrial and
weapons safety, safeguarding the health of workers and the general
public, and protecting the environment. Section 4.14 of the PEIS
describes the regulations and requirements under which all DOE
sites conduct their operations during the normal course of their
work activities, including potential accidents and associated
human health and environmental consequences of an accident.
The commentor believes that the Draft PEIS
fails to consider adequately the entire range of current and proposed
actions connected with the Stockpile Stewardship and Management
Program and reasonable alternatives to such actions. The commentor
states that because of substantial changes in the nature and purpose
of DOE's atomic energy defense activities, as reflected in the
design and implementation of a long-term Stockpile Stewardship
and Management Program, the PEIS must consider in a comprehensive
manner all related, connected, cumulative, and similar actions
designed to achieve the goals of stockpile stewardship and management,
including activities asserted to be ongoing, as well as those
described as "next generation."
- Response: DOE believes that the PEIS
discusses a full range of alternatives for implementing the Stockpile
Stewardship and Management Program, and that it analyzes in detail
those reasonable alternatives that are capable of achieving the
goals of the Program. DOE also believes that the PEIS adequately
assesses the cumulative impacts of proposed new activities and
existing activities at the sites where the Stockpile Stewardship
and Management Program would be implemented.
It is a well-established principle under NEPA that the goals of
a proposed action delineate the limits of the reasonable alternatives
to that action. That is, an alternative which does not accomplish
the agency's goals is not a reasonable alternative. Since its
inception, one of the primary goals of the U.S. nuclear weapons
program has been to ensure the safety, security, and reliability
of the Nation's nuclear weapons stockpile. Numerous facilities
have been built over the years at the three weapons laboratories
(LANL, LLNL, and SNL) and at NTS to conduct various activities
necessary to meet this goal.
As described in chapter 2 of the PEIS, recent developments in
national security policy have placed new constraints on the types
of activities available to achieve this goal. Specifically, the
United States is not producing new-design nuclear weapons or conducting
underground nuclear testing (see section 2.4). DOE's challenge
in developing the stewardship portion of the Stockpile Stewardship
and Management Program has been to determine whether, and how,
to replace, modify, or augment the existing capabilities of the
laboratories and NTS so that the goal of maintaining a safe, secure,
and reliable stockpile can be met, even as the enduring stockpile
ages and underground nuclear testing is no longer available.
DOE has examined from a programmatic perspective various approaches
to achieving this goal, and has determined that only an aggressive
science-based program that relies on sophisticated simulation
and computational technology would allow DOE to continue to ensure
the safety, security, and reliability of the stockpile. Alternate
approaches which are based on principles other than an aggressive
pursuit of the knowledge necessary to predict, detect, and correct
problems with the stockpile cannot achieve DOE's goals. Section
3.1.2 has been expanded to examine various other alternatives
or approaches (such as maintenance, remanufacturing, and a zero
stockpile) that have been suggested, and to explain why each of
them are incapable of ensuring the stockpile's safety, security,
and reliability, and thus are not reasonable.
Using simulation and computational technology to better understand
the characteristics of nuclear weapons has been an element of
DOE's weapons program for many years. It was historically part
of the Research, Development, and Testing Program, the predecessor
of the proposed stewardship portion of the Stockpile Stewardship
and Management Program. In determining, for the reasons noted
above, that stewardship must be based on similar principles, DOE
effectively eliminated the option of replacing the existing proven
capabilities at the laboratories and NTS with a different, untried
approach. Accordingly, the PEIS focuses on facilities that could
modify or augment the existing capabilities in ways that would
achieve DOE's goal. In summary, DOE and its predecessors have
been "stewarding" the stockpile, utilizing science-based
principles, since the dawn of the nuclear era. DOE believes that
recent policy developments require an even more aggressive application
of these principles to ensure the safety, security, and reliability
of the stockpile.
DOE believes that the PEIS appropriately addresses the role of
existing facilities in the stewardship program. They are described
as part of the No Action alternative, in broad terms in section
3.1.4 and in more detail in chapter 4 and appendix A. This approach
to the No Action alternative (i.e., maintaining the status quo)
is consistent with guidance issued by the CEQ (46 FR 180426, March
23, 1981). The environmental impacts of continuing the existing
activities at each of the sites associated with the Complex are
described throughout chapter 4. The cumulative effects that could
result when the impacts of the proposed new facilities are added
to those of existing activities are described in section 4.13.
DOE believes that in this way, the PEIS adequately presents the
impacts of the entire stewardship program, while focusing specifically
on the proposed new facilities that require a DOE decision, and
describing them in context with the existing facilities upon which
DOE would continue to rely to achieve the goal of a safe, secure,
and reliable stockpile.
Because DOE intends to use the PEIS as a component in decisionmaking
in 1996, only those alternatives that are ripe for decisionmaking
are assessed in detail in the PEIS. Alternatives not yet reasonably
foreseeable, and which have not matured so as to be ripe for decisionmaking,
such as next generation facilities (see section 3.3.4), are not
assessed in detail in the PEIS. Nonetheless, they are acknowledged
and included to the extent practicable.
The commentor thinks that the NTS table
3.2.9-1, should be modified to include subcritical tests, references
to high explosive and dynamic experiments, testing of nuclear
weapons, and testing of weapon effects.
The commentor states that DOE should not
proceed with the stockpile stewardship program until it has prepared
and circulated a new Draft PEIS, considered and responded to all
comments, and issued a Final PEIS and ROD.
Due to its focus away from consolidation,
the commentor believes that the Stockpile Stewardship and Management
Program is very different from Complex 21.
The commentor states that nuclear weapons
stockpile stewardship includes storage security, safety, inspection,
and maintenance so that the operability of any stored weapons
are known and satisfactory. The commentor further suggests that
those who devise plans for stockpile stewardship should remain
aware of the technological advances in remote drilling control
that might make previously secure storage locations less so.
The commentor states that the Special Nuclear
Materials Research and Development Laboratory proposal is still
alive in the form of various proposed upgrades to LANL's Chemistry
and Metallurgy Research building and that the relationship of
the plutonium processing facility at TA-55 (PF-4), and the Chemistry
and Metallurgy Research building is made clear in the quote in
the fiscal year 1997 LANL Capital Asset Management Plan, Chemistry
and Metallurgy Research Activity Data Sheet, page A-17. The commentor
asserts that the Stockpile Stewardship and Management PEIS, with
respect to future activities at LANL, is merely rubber stamping
what the laboratory has been pursuing for a number of years.
- Response: In the late 1980s, DOE initiated
a NEPA review for a proposed facility named the Special Nuclear
Materials Laboratory at LANL, and issued its Notice of Intent
(NOI) to prepare an EIS for the project (55 FR 1251, January 12,
1990). The new laboratory was proposed to replace the Chemistry
and Metallurgy Research building. (Reconfiguration PEIS NOI, 56
FR 5594, February 11, 1991). DOE has since dropped its proposal
to construct the Special Nuclear Materials Laboratory, since with
a smaller nuclear material requirement the capacity of the Chemistry
and Metallurgy Research building, if upgraded, remains adequate.
The Special Nuclear Materials Laboratory was proposed at a time
when there were several new weapons systems in various phases
of the development and production cycle and DOE was still operating
its Rocky Flats Plant. At that time, DOE and LANL believed that
a greater analytical chemistry capability was needed at LANL to
support those efforts. DOE notes that a great deal of the background
information raised by the commentor reflects the evolution that
has occurred over the past 7 years as the Nation has made significant
changes in its nuclear deterrence policy. At many times since
1990, the nuclear materials support work performed at LANL has
been redirected by DOE to reflect the changing national priorities.
The former special nuclear materials proposal is not embodied
in the current plans to upgrade the 44-year-old Chemistry and
Metallurgy Research building, as the commentor alleges. DOE has
prepared an EA for the Chemistry and Metallurgy Research upgrades
(DOE/EA-1101), and has issued that EA in draft for public review
and comment. The commentor reviewed the draft EA and extensively
commented on that document. At this time, DOE proposes to upgrade
space in the Chemistry and Metallurgy Research building only as
needed to support the existing set of LANL operations. Two complete
wings of the Chemistry and Metallurgy Research building are in
the process of being placed in a safe standdown mode, and another
wing has been converted to office space only. The analytical laboratory
space in the wings currently proposed to be upgraded are those
wings that support LANL's existing mission in the nuclear weapons
program, deep space probes, nuclear material stabilization programs
(including waste management) and environmental restoration.
As noted in this PEIS, in the event that DOE should choose to
implement an expanded Stockpile Stewardship and Management Program
at LANL, further renovations to the Chemistry and Metallurgy Research
building would be needed to support pit production or other missions
analyzed in this PEIS. If LANL is selected for an expanded production
role as a result of the Stockpile Stewardship and Management ROD,
then some activities could be moved into the Chemistry and Metallurgy
Research building from building PF-4 at TA-55 into currently unused
space that would then be renovated for this purpose. The current
proposal to upgrade the analytical chemistry space in the Chemistry
and Metal-
- lurgy Research building sufficient for
existing needs would also support these future needs with no additional
building renovation.
The commentor also references the LANL 1993 Strategic Plan. The
sketch of a fully renovated Chemistry and Metallurgy Research
building referenced in the 1993 plan included essentially all
of the building. However, in 1995 DOE and LANL agreed to pursue
only those upgrades needed to support the existing nuclear materials
mission assignments at LANL which have resulted in changes from
the 1993 plan. For example, since the 1993 plan, two complete
wings of the Chemistry and Metallurgy Research building are in
the process of being placed in a safe standdown mode, and another
wing has been converted to office space only.
The Capital Asset Management Plan is an annual listing, for planning
purposes, of potential projects that might be required to support
current and future missions. DOE requires an annual Capital Asset
Management Plan report from all its weapons complex sites. As
such, it is not inappropriate for LANL to use this vehicle to
alert DOE to facility improvements or new structures that might
be required in the event that an enhanced stockpile stewardship
and management mission is assigned to LANL.
It is true that DOE has determined that, under the existing stockpile
stewardship and management activities that have been ongoing for
many years, facilities at LANL will have to be maintained, and
in some cases, repaired or upgraded, to allow LANL to continue
to fulfill its existing mission. Far from being a "stunning
admission" that future assignments are already being implemented,
DOE believes that it is simply good management practice to keep
its considerable real property--its buildings and other infrastructure--in
safe, sound, and operating order.
The commentor states that the Stone and
Webster document referenced in the Stockpile Stewardship and Management
PEIS was not made available to the public.
The commentor refers to tables 3.7.1-1 through
3.7.1-5 and asks if anyone has placed these numbers into a common
reference frame. According to the commentor, the LANL direct employment
numbers, utility requirements, and some of the discharge numbers
do not make sense.
The commentor refers to Volume I, tables
3.4.4.2-2, 3.4.4.3-2, 3.4.4.4-1, 3.4.4.4-2, 3.4.5.2-2, 3.4.5.3-2,
and 3.4.5.4-2 and requests that the term "surge operations"
be defined in chapter 9, Glossary.



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