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Weapons of Mass Destruction (WMD)

40 Nuclear Weapons Policies

40.01

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.

40.02

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.

40.03

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.

40.04

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.

40.05

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.

40.06

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.

40.07

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.

40.08

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.

40.09

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.

40.10

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.

40.11

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.

40.12

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.

40.13

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.

40.14

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.

40.15

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.

40.16

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).

40.17

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.

40.18

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.

40.19

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.

40.20

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.

40.21

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.

40.22

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.

40.23

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.

40.24

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.

40.25

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.

40.26

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.

40.27

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.

40.28

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.

40.29

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.

40.30

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.

40.31

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.

40.32

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.

40.33

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.

40.34

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.

40.35

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.

40.36

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.

40.37

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.

40.38

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.

40.39

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.

40.40

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.

40.41

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.

40.42

A commentor asks what, if any, consideration has been given to safeguards/inspection provisions in these studies.

40.43

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.

40.44

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.

40.45

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.

40.46

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.

40.47

A commentor wants to know if the sites followed any standards when submitting numbers for the PEIS.

40.48

The commentor raises the concern that the Albuquerque Operations Office was censoring DOE contractor employees from participating in the public hearings.

40.49

The commentor thinks that Summary section S.3.6 should list NTS as an alternative site for all of the large experimental physics machines.

40.50

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.

40.51

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.

40.52

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.

40.53

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.

40.54

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.

40.55

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.

40.56

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.

40.57

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.

40.58

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.

40.59

The commentor asks if DOE has integrated the PEIS with the DOD mission.

40.60

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).

40.61

The commentor suggests that DOE provide a definition of hazardous chemicals in the glossary or possibly use the term "hazardous substances."

40.62

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.

40.63

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).

40.64

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.

40.65

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.

40.66

The commentor expresses the opinion that Pantex should be the preferred site for future Complex missions.

40.67

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.

40.68

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.

40.69

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.

40.70

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.

40.71

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.

40.72

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.

40.73

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.

40.74

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.

40.75

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.

40.76

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.

40.77

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.

40.78

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.

40.79

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.

40.80

The commentor asks where fabrication of enriched uranium primaries will be assigned.

40.81

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.

40.82

The commentor asks, relative to section 3.2.2, what ORR DP assignments are not performed by Y-12.

40.83

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.

40.84

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.

40.85

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."

40.86

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.

40.87

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.

40.88

Due to its focus away from consolidation, the commentor believes that the Stockpile Stewardship and Management Program is very different from Complex 21.

40.89

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.

40.90

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.

40.91

The commentor states that the Stone and Webster document referenced in the Stockpile Stewardship and Management PEIS was not made available to the public.

40.92

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.

40.93

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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