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Weapons of Mass Destruction (WMD)

08 Socioeconomics

08.01

Commentors express concern that the perceived mitigative effects of decontamination and decommissioning (D&D) jobs at ORR described in Summary section S.4.1 and table 3.7.1-5 would not materialize based on previous experience. The commentors are concerned about when the D&D work would be budgeted and whether these jobs would begin immediately or would be phased in. One commentor wants to know specifically what jobs are going to be created and if Washington agrees that these new jobs are going to be funded and asks that a table be provided showing employment and socioeconomic impacts through 2030. The commentors ask if Washington does intend on funding the (proposed 1,318) D&D jobs, is this a steady state requirement and how many years can the level of expenditure continue once it starts. A commentor states as an example that the D&D on Building 9201-4 has been scheduled for 15 years and does not seem to be a priority. A commentor is also concerned about who would do the D&D work (Lockheed-Martin people or contract workers), and how soon it would have to be scheduled in order for Lockheed-Martin workers to be kept on the payroll. Another commentor is concerned that people from K-25 are included in the D&D figures that are planned for Y-12. The commentor is concerned that DOE is just shifting people and money for D&D.

  • Response: For base case single-shift operations, the total Y-12 workforce would fall to 3,916 from the No Action level of 4,721. The workforce would consist of 1,980 workers conducting nonstockpile management activities, 784 core stockpile management workers, and 1,152 workers performing landlord activities in preparation for D&D of the facilities. The projected D&D employment at Y-12 is shown in section 4.2.3.8. Workers performing landlord activities are necessary for transition of the facility and would be in place whether the funding comes from the Environmental Management program or continues to come from DOE's Office of Defense Programs (DP). Over the period 2005 to 2030, the number of these workers would range from a high of 1,522 in 2016 to a low of 557 in 2030. When D&D activities reach a peak in 2016, Y-12 would employ 435 fewer workers than under the No Action alternative.

08.02

The commentor wants to know where the impacts to the agricultural economy were analyzed in the PEIS.

  • Response: The Stockpile Stewardship and Management PEIS does not analyze the economic impacts to particular sectors such as the agriculture sector. Rather, the document evaluates impacts to the regional economy as a whole, which includes the agricultural sector. However, none of the proposed alternatives would make use of prime farmland or involve activities affecting farm production. Under normal operation, there would be no direct impacts to the agricultural economy. Any potential impacts to agriculture resulting from an accident are analyzed in appendix section F.4.

08.03

Commentors state that the socioeconomic impact to Oak Ridge and the surrounding communities has not been appropriately analyzed. One commentor expresses concern about the data used for the socioeconomic study and the financial impact studies which show little impact on the city of Oak Ridge and the ORR region. Another commentor asks what the community will do with the unemployed workers that have been at ORR for 20 to 25 years. The commentors also indicate that the study's results must be questioned because personnel from the city of Oak Ridge were not directly involved in the analysis.

08.04

Commentors recognize that downsizing the nonnuclear fabrication mission at KCP will result in a loss of possibly 300 to 900 jobs over a period of time. The commentors want to know what can be done, what resources can be utilized, and how the business community can help lessen the number of jobs lost. The commentors point out that even with the possibility of additional future work at KCP, there is concern and they want to know if it is possible to maintain a higher rate of employment in the Kansas City area.

  • Response: In September 1994, DOE created the Office of Worker and Community Transition to help ease the unavoidable impacts associated with the restructuring of the contractor workforce at DOE sites. The office has issued its Interim Guidance for Contractor Workforce Restructuring which includes options to encourage voluntary separations and assist workers in transition to new careers. The final guidance also includes measures such as transferring employees to other missions or other sites, providing additional training and educational assistance, or counseling for the employees. In addition, DOE anticipates working closely with other businesses in the communities surrounding the sites to keep them informed of skilled personnel in the labor market. Because KCP is small relative to the large, diversified economy of the Kansas City region, the downsizing is expected to have little effect on the regional economy. Kansas City derives almost all of its employment growth from non-DOE activities.

08.05

The commentor believes that the socioeconomic analysis does not consider the social and economic impact of the people at LANL who were laid off at the plutonium facility. The commentor believes that DOE needs to look at the integrity of the people in the socioeconomic analysis. The commentor also believes that the 22 people laid off at the plutonium facility should be interviewed for the socioeconomic analysis.

  • Response: The Stockpile Stewardship and Management PEIS identifies and analyzes potential impacts of the proposed Stockpile Stewardship and Management Program alternatives, including the reestablishing of pit fabrication at LANL. The PEIS does include in the analysis the impacts of previous actions, such as layoffs at the LANL plutonium facility. The commentor's concerns about downsizing and the effects on site employees are being addressed by DOE's Office of Worker and Community Transition. This office oversees DOE policies to facilitate worker transition, including worker retraining, education, and relocation assistance. The socioeconomic impact analysis estimates direct and indirect economic impacts, including employment and income. The PEIS also estimates impacts to the regional population and the housing market, as well as impacts to public finance.

08.06

The commentor believes that any additional work that would come to Los Alamos from pit production should be contracted out to a private taxpaying company instead of going to the University of California, which does not pay taxes to the state or the community.

  • Response: The economic analysis does not take into account what type of contractor would be managing the implementation of the proposed alternatives. The purpose of the economic analysis is to evaluate the socioeconomic impacts of the proposed alternatives on employment and income in the regional economic area. The socioeconomic impact analysis also addresses impacts to population, housing, and public finances. Selection of the preferred alternative would not be affected if LANL's contractor were a private in-state company instead of the University of California. This is because the benefits to the local communities from a private contractor as opposed to a non-profit contractor are likely to be small. Any revenues generated by corporate taxes levied on a private company would be the result of a state corporate income tax. This revenue could then be dispersed throughout the state, rather than remain in the LANL region. It is unknown what portion of these funds would actually be allocated to the LANL region. Impacts to the local community public finance would more likely stem from local taxes paid by workers directly associated with the facility. Furthermore, the process of selecting a contractor for performing proposed alternatives would be accomplished separately from the NEPA process.

08.07

Several commentors believe that the laboratories do not understand the various processes at Y-12 to estimate accurate employment figures. The commentors state that a detailed breakdown of the job structure does not exist. The commentors wonder how the waste job structures at Y-12 will be moved to LANL and how many people for each function will be at all three of the sites. In addition, the commentors state that there is no description on a function-by-function basis of how the fabrication process can be implemented at another site, and this oversight allows for wildly unrealistic estimates at the other sites. Further, the commentors would like the PEIS to address the difference in worker experience between Y-12 and the laboratories and the cost of having to train a new workforce if the secondary and case fabrication mission were moved.

  • Response: In developing the data used in the PEIS and in the cost estimates, DOE formed a working group for each functional area that included all affected sites in order to share information and provide consistent data for all of the proposed alternatives. In the case of secondary and case manufacturing, this included knowledgable personnel from both Y-12 and the laboratories so that all three alternatives would be evaluating the same mission and requirements. Appendix A gives a breakdown of employment by labor category for each alternative at each site, and also includes details on how the process would be implemented at each site. This functional breakdown estimates the workers needed at Y-12, LANL, or LLNL.

08.08

Commentors ask about the difference between socioeconomics and environmental justice.

  • Response: Environmental justice analysis, as defined in Executive Order 12898, is performed to assess whether the proposed alternatives would have a disproportionately high and adverse effect on minority and low-income populations. The analysis is accomplished by examining the size and distribution of these populations and determining if adverse health and economic impacts would be borne by these groups to a greater degree than the population as a whole. Socioeconomics has a broader focus. Socioeconomics addresses the impacts of the alternatives on the economic and social characteristics of a region, such as population, employment, housing, and public finances. The socioeconomic impact sections analyze the effect the alternatives would have on the entire region, rather than on particular populations.

08.09

The commentor points out peculiarities, such as the concept that no indirect jobs would be generated for the 523 workers and 321 incremental workers associated with the secondary/case mission (table 3.4.4.3-2), that need to be resolved.

  • Response: The number of indirect jobs generated by each alternative depends on the mission performed and the types of existing industries within the region. In the region around LANL, there are few or no industries that would support the secondary and case fabrication mission. Therefore, the increase in site employment (direct jobs) would not result in a corresponding increase in supporting industry employment (indirect jobs).

08.10

The commentor states that the numbers included in the PEIS contain inconsistencies in logic and mathematics. For example, in section 3.4, the commentor notes surge operation is used for generating the operations analysis numbers, rather than the base case, which would presumably be the actual staffing levels and would be a more realistic identification of the manpower and socioeconomic impact. The commentor also wonders why the impact numbers calculated in the analysis in section 3.7.1.1 are based on the three-shift surge operation, when single-shift operation is the base case (table 3.1.1.1-1). The commentor feels this may have been done to reduce the socioeconomic impacts.

  • Response: The Final PEIS assesses socioeconomic impacts using both the base case single-shift and the base case surge (three-shift) production scenarios. However, DOE has analyzed the base case surge scenario (as well as a high case scenario where appropriate) to fully capture the bounding case. This is because a surge operation would require more workers than a one-shift operation and could potentially cause greater disruption of the local infrastructure (e.g., housing and public finances).

08.11

The commentor expresses confusion about the difference between direct and indirect jobs and requests that the glossary include these terms. Another commentor refers to the discussion in the Summary section S.4.1 and states that only direct employment impacts are considered in socioeconomics. The commentor questions whether negative factors (such as land use, waste management, hazardous operations, and transportation problems) would have negative socioeconomic impacts.

  • Response: The socioeconomic analysis assesses both direct and indirect economic employment impacts. Indirect employment refers to jobs created or lost in industries that support activities associated with the proposed alternatives while direct employment refers to changes in site workforce. These definitions are included in chapter 9, Glossary. Waste management, transportation, and hazardous operations are assessed in terms of health risks to workers and the public.

08.12

The commentor refers to figure 4.2.3.8-4 and states that the text under public finance only discusses ROI impacts when the city of Oak Ridge impacts are 5.5 and 7.5 percent. The commentor asks, since these numbers are for 2005 and the staffing levels in 2030 are only half of the 2005 level, how this affects projected impacts in 2030.

  • Response: The text presents overall ROI impacts while the figures show the effects to individual cities and counties. In the Final PEIS, the range of the effects on cities and counties is included in the text.

08.13

Commentors state there are inconsistencies between the Draft PEIS (figure 4.2.3.8-1) and the Stockpile Management Preferred Alternatives Report (page 39) regarding employment figures. The commentors note that the Draft PEIS projects a continuously decreasing employment level for the downsizing ORR alternative until the year 2030. The commentors note that section 4.2.3.8 is the only section which mentions Environmental Management support employment figures. The commentors point out that the Stockpile Management Preferred Alternatives Report contradicts the information in the Draft PEIS by reporting employment levels that will not continue to decline after the year 2008 and will in fact remain constant between the years 2008 and 2030. The commentors state the public is unsure which figures are accurate.

  • Response: Figure 4.2.3.8-1 was incorrect and did not properly reflect the employment numbers presented in the PEIS which represent DOE's most recent estimates of the labor force required for the mission. The ORR labor requirements have been revised since the publication of the Draft PEIS. The base case single-shift core stockpile management workforce will be 784 in 2005, while the base case surge (three-shift) core stockpile management workforce would be 1,376 in 2005. In addition, D&D employment would begin in 2003, increase its employment requirements until 2016, and gradually decrease until 2030. This is shown in section 4.2.3.8. The preferred alternative number of workers expected at Y-12 is 1,080, which falls between the two bounding values analyzed in the PEIS.

08.14

The commentor states that the 1,100 employees that have been added to the Pantex workforce in the past few years are mostly ES&H workers and not A/D workers.

  • Response: Of the 1,100 worker increase at Pantex over the past 5 years, approximately 25 percent are associated with ES&H and waste management activities. About 75 percent of the additional workforce is employed in production and dismantlement operations.

08.15

The commentor urges DOE to correct the socioeconomic impact portions of the PEIS to accurately reflect the impact of Pantex on the local economy, stating that employment related to Pantex represents over 12 percent of all jobs in the Amarillo metropolitan area. The commentor's assertion is based on the fact that the money Pantex brings into the local economy supports many retail, medical, educational, finance, insurance, and real estate jobs. Other commentors state that the dramatic employment reduction of 3,549 jobs forecasted in the Draft PEIS will severely impact the Panhandle economy and that any reductions should come only after intensive cost and technical analyses. The commentors feel the loss of 3,549 high paying jobs would have greater than a 1-percent impact.

  • Response: The socioeconomic impact sections look at the entire regional economic area around the site, rather than the nearest metropolitan area. The jobs considered are those jobs associated with the mission at the site, and those jobs in other industries in the area that are related to and support the mission activities. Other changes to the local economy, such as changes in tax revenues and Government expenditures, are analyzed in the public finance portions of the socioeconomic sections. Total phaseout of Pantex would result in a loss of 3,549 jobs (1,644 direct and 1,905 indirect). This represents 1.4 percent of total employment in the Pantex regional economic area. The downsize A/D and HE fabrication alternative would result in a loss of 475 jobs (220 direct and 255 indirect), which is 0.2 percent of total regional economic area employment. While these job losses could negatively affect the Panhandle region, DOE's Office of Worker and Community Transition would work with the area to lessen any impacts.

08.16

The commentor states that the PEIS does not address the social impacts that go beyond the direct number of jobs, such as unnecessary infrastructure and empty schools. The commentor believes the main adverse impacts of a stockpile stewardship program would be associated with the construction of new facilities and in the societal effects of shifting responsibilities among installations.

  • Response: The socioeconomic impact analysis estimates direct and indirect economic impacts, including employment and income. The PEIS also estimates impacts to regional population and the housing market, as well as impacts to public finance for all sites and all alternatives. The analysis of population impacts indicates that any population change would be small relative to the resident population, and would not significantly impact school populations or existing infrastructure.

08.17

The commentor notes that in the Summary section entitled Secondary and Case Fabrication, the proposed plan is to cut Y-12's manufacturing capability from 2,350 current DP workers to 870, but that the data presented at the April 1 and 2, 1996 meetings in Oak Ridge were 3,126 current DP workers at Y-12 to be reduced to a downsized level of 1,080 in the year 2003. The commentor points out that the meeting data indicate a cut of 2,046 employees while the PEIS shows a reduction in DP supported workers of 1,480 for the same years. The commentor wants to know the impact of the new data which calls for a cut of 2,046 workers which is 38-percent higher than the data in the Summary section S.4.1 and in section 4.2.3.8.

  • Response: For base case single-shift production in 2005, the number of core stockpile management workers at Y-12 would fall from the No Action level of 2,741 to 784 while landlord responsibilities in preparation for D&D would require 1,152 workers. An additional 1,980 workers would be required for other program activities at the Y-12 facility under both the No Action or the downsize alternative. Total Y-12 workforce (core stockpile management and other programs) would be reduced from the No Action level of 4,721 to 3,916, a loss of 805 jobs. Employment in the ORR regional economic area would fall by less than 1 percent as a result of the change in site workforce.

08.18

The commentor refers to the Summary section S.4.1 and the proposed plan to cut Y-12's manufacturing capability from the current 2,350 workers to 870. The commentor wants to know the skill mix that will comprise the proposed 131 craftworkers and the 93 operatives identified in order to evaluate the feasibility of meeting the proposed production requirements. The commentor is interested in knowing how many workers will be involved in quality and certification and process development.

  • Response: The socioeconomic impact sections analyze changes to regional economics, employment, population, housing, and public finance resulting from changes in site employment. The detailed data requested by the commentor is not available because the types of craftworkers and operators were not needed for determining environmental impacts. The skill mix of the workers does not change the environmental impacts of the proposed alternatives. The Stockpile Management Preferred Alternatives Report presents an evaluation of the technical ability of the alternatives to meet the proposed production requirements. This report is available in the DOE Public Reading Rooms near each site.

08.19

The commentor contends that substantial local public and private money was put into building infrastructure to support DOE operations (i.e., roads, schools, and utilities). The commentor states that the PEIS does not consider the total national impact on local socioeconomics (i.e., cuts at ORR, expansion at another site). The commentor suggests that the PEIS needs to account for and address these "stranded costs."

  • Response: As seen in the socioeconomic analysis, the impacts to the regional economies from any of the proposed alternatives is small. In the case of the preferred alternative, the losses to the regional economy would be diminished by D&D activities associated with downsizing. Population decrease in any ROI jurisdiction would not exceed 4 percent as a result of downsizing to the preferred alternative. Therefore, there would be no large changes in the utilization of local services or utilities.

08.20

The commentor requests clarification on the level of importance placed on the impact of jobs lost or jobs gained in any particular area in making recommendations.

  • Response: The primary purpose of the Stockpile Stewardship and Management Program is to continue to support U.S. national security policies as directed by the President and Congress. The final decision to select a preferred alternative takes into account impacts to various environmental resources, including socioeconomics. The Record of Decision (ROD) will explain the rationale and the factors for DOE's decisions.

08.21

The commentor states that DOE should have analyzed in more detail the socioeconomic impacts associated with each of the proposed alternatives, including impacts associated with loss of employment population, unnecessary infrastructure, and empty schools, as well as other financial impacts on the region's economy. The commentor believes that local government representatives should be included in this more detailed analysis.

  • Response: The PEIS analyzes impacts to regional employment and income, as well as any changes to population or housing markets that could result from the proposed alternatives. In addition, impacts to local government and school district finances are assessed. Information on public finances were obtained from each city, county, and school district. Other data came from sources such as the U.S. Census Bureau and the U.S. Bureau of Economic Statistics. Input from local government officials and other stakeholders is obtained from public meetings, including scoping meetings.

08.22

The commentor states that DOE should explain the statement in the Stockpile Stewardship and Management Draft PEIS, "The downsizing A/D and HE fabrication alternative would result in the addition of 280 workers at Pantex."

  • Response: A majority of the worker reductions at Pantex would have already occurred under No Action. Under the base case single-shift scenario, downsizing Pantex (retaining A/D and HE missions) would result in the loss of 189 jobs from the No Action level of 1,644 jobs. A base case surge (three-shift) operation would require 1,927 workers. This represents an increase in employment requirements over No Action of 283 jobs. This number was rounded to 280 in the Draft PEIS.

08.23

The commentor refers to the ORR section 4.2.3.8 on public finance and wonders who projected that total expenditures for the public area would increase an average of less than 1 percent per year from the year 2000 to 2030.

  • Response: Section 4.2.3.8 on public finance at ORR states that total expenditures are projected to increase at an annual average of less than 1 percent during the period 2000 to 2005, and that this rate of increase should continue until 2030. The increase for the ORR combined ROI cities and counties expenditures between 2000 and 2030 is 9 percent. These projections are developed from financial forecasting models described in the methodology section and are based upon financial statements and budgets from these cities and counties; the latest available projections for population, income, and employment from the U.S. Bureau of Economic Analysis; and other data.

08.24

The commentor requests that the Comment Response Document contain a description of the statistical rationale which supports the PEIS statement that direct and indirect jobs lost (from transfer of HE mission to laboratories) would not change the Pantex regional economic area's unemployment rate, housing/rental vacancies, and public finance expenditures/revenues. Another commentor feels DOE should not consider 33 HE jobs as insignificant.

  • Response: Under No Action, the HE mission at Pantex would employ 105 workers and generate an additional 122 jobs in related industries within the region. Phaseout of this mission would therefore result in a total loss of 227 jobs in the Pantex regional economic area. Total employment in the region is projected to be 248,442 in 2005. Therefore, the jobs lost as a result of the phaseout of the HE mission would result in a loss of less than one tenth of 1 percent of total regional employment and would not have a measurable effect on the unemployment rate. Even if all of the displaced workers were to leave the area, the impacts on population, housing, and public finance would be negligible. As described in section 3.8, the preferred alternative is to assign the HE mission to Pantex.

08.25

The commentor requests an explanation be given in the Comment Response Document regarding the apparent inconsistencies between the Pantex Site-Wide Draft EIS, the Stockpile Stewardship and Management Draft PEIS, and the Storage and Disposition Draft PEIS regarding the numbers of indirect jobs created in the region for each direct job at Pantex. The commentor notes that the Pantex Site-Wide Draft EIS, page S-17; Stockpile Stewardship and Management Draft PEIS, Summary section S.4.1; and Storage and Disposition Draft PEIS, page 4-205 assume an economic multiplier of 1.65, 1.16, and 3.51 indirect jobs in the region for every direct job created at Pantex, respectively.

  • Response: Projections of the number of indirect jobs generated depends on a number of factors, including the type of mission activity performed, the type of data used, and the methodology employed. This PEIS evaluates the socioeconomic impact of weapons A/D at Pantex, while the Storage and Disposition Draft PEIS evaluates the impacts from the storage and disposition of fissile material. The activities involved in the two programs are quite different and each requires vastly different inputs. The availability of inputs within the region is what determines the multiplier. For example, if the Pantex region contains industries that produce the inputs required for storage and disposition activities, but no industries that produce stockpile stewardship and management required inputs, the storage and disposition mission would generate a greater number of indirect jobs in the region. The Pantex Site-Wide Draft EIS impact analysis was conducted at a different level of detail, and the analysis employed a somewhat different methodology.

08.26

The commentor requests an explanation in the Comment Response Document as to why DOE did not consult with the Amarillo Economic Development Commission and/or the city of Amarillo regarding the ratio of additional jobs in the region related to each job at Pantex and use the information that taxpayers had already paid for.

  • Response: The number of indirect jobs generated by any of the alternatives was determined using RIMS II from the U.S. Bureau of Economic Analysis. This information is available for every economic region in the Nation, and therefore lends consistency to the analysis across sites.

08.27

The commentor states that the resulting benefits to the regional economy, if the Stockpile Stewardship and Management PEIS alternatives were located at LLNL, would be less than 1 percent. Given the additional radioactive and hazardous materials and wastes to be shipped to and from LLNL and handled at the facility, which projects a certain radiological risk to the public (albeit small, as estimated by DOE), the commentor states that the PEIS should contain an explanation which details how regional/state costs resulting from the proposed action will be offset by benefits to the regional economy.

  • Response: The benefits to the local economy in terms of increased regional income and employment and public finance impacts are discussed in the socioeconomic section 4.7.3.8. These benefits can be compared to the costs of the alternatives.

08.28

The commentor feels the statement in the ORR section 4.2.2.8, that all jurisdictions have positive fund balances, may be misleading, since state law requires positive fund balances and jurisdictions deal with this by generating capital obligations, which are not included in fund balance calculations.

  • Response: Not all states require positive fund balances. The statement that all jurisdictions have positive fund balances was used in all sections where applicable. Otherwise, local governments without positive fund balances were identified. The analysis of public finances includes past capital bonding obligations and the projected payout of these existing obligations. However, as stated in the methodology, there was no attempt to project capital bonding that may be made in the future. The purpose of analysis was to compare effects of the proposed alternatives to No Action. Both were projected using the same assumptions and methodology.

09 Intersite Transportation

09.01

One commentor asks DOE to comment on its methodology for choosing transportation routes, parking areas, and the overall transportation plan. Several commentors urge DOE to educate the public about the risks associated with hazardous shipments and to consult and coordinate with local communities and interested parties along proposed transportation routes regarding each community's transportation responsibilities and needs (such as additional roads); the routing of hazardous shipments and notification of interested parties; the effects of these additional shipments on traffic patterns; and the effect on property values. One commentor asks that DOE expand the ROI beyond 80 km (50 mi), as these people could be affected by transportation issues as well. Another commentor urges DOE to use every safeguard possible to ensure that the public is not at risk from transportation of nuclear materials.

  • Response: The intersite transportation of Stockpile Stewardship and Management Program materials is discussed in section 4.10 of the PEIS. Hazardous materials transportation routes are predetermined by the Department of Transportation (DOT) in conjunction with the individual states. Parking areas are generally at DOE sites, military bases, and other predetermined locations. The transportation planning for plutonium and highly enriched uranium (HEU) shipments is carefully prepared by the DOE Transportation Safeguards Division to provide both safety and cargo security. The risk from normal (accident-free) transportation of radioactive materials by DOE is minimal. Even severe accidents are highly unlikely to cause injury or death from a radiological release because of the stringent Federal DOT/Nuclear Regulatory Commission (NRC) packaging design and transport safety requirements. In over 40 years of shipment activity, neither DOE nor its predecessor has ever experienced an injury or death from a radiological release during transportation. The volume of radioactive shipments associated with this PEIS would be small and would have negligible effects on the number of shipments in transportation corridors. The transportation risk analysis for the alternatives presented in section 4.10 of the PEIS included the entire route, which is beyond the 80-km (50-mi) ROI.

09.02

Several commentors contend that DOE has not provided equal treatment to local communities and Native Americans in regard to transportation issues such as emergency response and preparedness, and urge DOE to inform all local communities of important transportation issues. Another commentor notes that there are no evacuation plans for the people of Santa Fe and Albuquerque in case of a transportation accident involving nuclear materials. The commentor feels that the PEIS does not adequately analyze the impacts of accidents at LANL on the Pueblo of San Ildefonso. One commentor states that DOE needs to provide better oversight and notification regarding shipments through the city of Pahrump and Nye County, specifically emergency preparedness, as Pahrump does not have the population to be trained. Another commentor states that the emergency response personnel along the transportation routes are not properly trained and equipped to handle an accident involving nuclear materials.

  • Response: DOT is responsible for coordinating Federal training programs and for providing technical assistance to states, tribes, and local governments for emergency response training and planning. Evacuation plans and emergency response are local jurisdictional responsibilities. However, DOE voluntarily provides limited free training and technical assistance to local jurisdictions when there is a specific special interest (e.g., in areas most likely to be traversed by safe secure trailer shipments). Training is also provided separately to law enforcement and emergency services personnel to familiarize them with DOE's system for the safe transport of nuclear materials. Interested parties can request this free training through the DOE Community Advisory Board for each site. Regarding the impacts of accidents at LANL and their effects on the Pueblo of San Ildefonso, the PEIS describes postulated transportation accident impacts at LANL and their effects on surrounding communities in section 4.10.

    If NTS were selected as the weapons A/D site, it is unlikely that radioactive shipments would pass through Pahrump because of its out-of-the-way location. The Federal officers who escort plutonium and HEU shipments are trained to actuate the National Emergency Response System if they, themselves, cannot handle emergencies that may occur en route. First responders, such as state police or other emergency services personnel, also know how to actuate this system.

09.03

Commentors state that there is local concern about the transportation of nuclear weapons parts and materials on the highways of Nevada, Clark County in particular. The commentors do not want these types of materials to go through Clark County and urge implementation of a rail system through low-population areas. The rail system could serve a multitude of purposes (e.g., mining) in addition to DOE transportation, and would eliminate the danger of highway transportation. The commentors urge a study of this alternative and state that the rail system would provide equity to the people of Nevada.

  • Response: The methodology for the safe secure transportation of nuclear materials (plutonium and HEU) is well established. Acceptable risk is not dependent upon the transportation mode (truck versus rail) but rather upon the rigorous packaging design requiring Federal safety certification. The packaging must retain its contents under the most severe accident conditions (i.e., fire, impact, puncture, or water immersion). Rail transportation for plutonium and HEU was abandoned in favor of the safe secure trailers several years ago and is not now considered a viable transportation alternative for these materials related to the Stockpile Stewardship and Management Program.

09.04

The commentor believes that the PEIS should consider the risks of hijacking when looking at the intersite transport of nuclear materials.

  • Response: All potential threats (including hijacking) to the safety and security of nuclear materials in transit are considered by DOE's Transportation Safeguards Division.

09.05

The commentor questions the safety record of nuclear shipments in the Los Alamos area. Another commentor cites a safe secure trailer turnover in Colorado about 5 years ago as proof that there have been accidents with nuclear cargo.

  • Response: Although DOE's transportation safeguards system has experienced traffic accidents involving vehicles carrying interstate shipments of radioactive materials, none, including the accident in Colorado referred to by the commentor, have resulted in a release of radioactive material. The safety of the system is attributable in part to the training and certification of vehicle operators and the design of the vehicles themselves. However, the safety of DOE shipments does not rely just on these measures. Primary containment of radioactive materials is provided by the containers within which the material is placed for shipment. These containers are designed to conform to the requirements for Type B packages as specified by the NRC in 10 CFR 71. The packages are fabricated and tested to ensure compliance with the standard under normal conditions of transport and hypothetical accident conditions including fire, impact, puncture, and water immersion.

09.06

The commentor refers to the Summary section S.2.3, High Explosive Components, and states that safety issues related to shipment of shaped charges were not assessed in detail, either in terms of increased volume of shipments of shaped components over raw HE, or in terms of the technical vulnerabilities of the components. Another commentor questions whether hearings have been held to discuss main charge transportation through the appropriately affected states. Other commentors ask if an analysis has been made of the additional hazards of transportation of HE from either of the national laboratories to where it would be used, and what are the increased costs of intersite transportation of HE from either of the national laboratories to where it will be used. One commentor contends that the safety impact of transporting hundreds of HE hemispheres from the laboratories to Pantex (should HE manufacturing be moved) is not adequately evaluated. A commentor also asks if scrap explosives will be returned to the laboratories for disposal or if Pantex will be responsible for disposition. Another commentor states that separation of the explosive fabrication and A/D missions would require that explosives be transported over long distances in order to be mated with the physics packages. Therefore, the commentor believes that in the case of LLNL, the extensive fogs that create near zero visibility should be considered in any safety analysis.

  • Response: Transferring the HE fabrication mission from Pantex to LANL and/or LLNL would require an estimated 150 rebuilds to be shipped per year from the HE fabrication site to the weapons A/D site. The accident risk from transporting this material would be no greater than the risk encountered by the public from industry's transport of similar explosives. Hearings are not required for shipments of HE made in compliance with Federal transportation regulations.

    Transferring all or part of the HE fabrication mission from Pantex to LANL and/or LLNL would require an estimated 12 round trips per year to transport HE materials including the return of scrap HE to the laboratories. The transportation of HE is described in section 4.10 and appendix G of the PEIS. There would be no impact from normal (accident-free) transportation. HE accident impacts from transportation are bounded by the risk analyzed and presented in the Facility Accident sections. Weapon component shapes are classified and are shipped using the appropriate safeguard measures in accordance with approved Federal regulations. HE main charges would not be shipped with detonators installed and would meet all DOT safety requirements.

09.07

The commentor asks how reliable the PEIS transportation computer modeling is.

  • Response: The RADTRAN computer code has been used in risk analysis for over 10 years and is being constantly improved and updated. It is accepted by the International Atomic Energy Agency and its worldwide member countries as a reliable risk assessment tool. RADTRAN calculates the collective dose to the exposed population (workers and the public) from a postulated accident as well as the collective dose from accident-free transportation. It produces conservative estimates (those that tend to overstate impacts) of radiation dose rates in a way that can be supported by available data.

09.08

The commentor recommends that DOE should (a) directly involve corridor states and tribes in preparing for large quantity radioactive material shipments associated with the Stockpile Stewardship and Management Program and other DOE programs; this would include developing rail and truck transport plans, preferred routes, and procedures prior to shipment (similar to the plans developed by DOE and the Western Governors' Association for transuranic [TRU] waste shipments to the Waste Isolation Pilot Plant [WIPP]); (b) use only shipping containers that can be manufactured to meet current Federal transport safety requirements; and (c) provide accurate projected shipment information (i.e., quantities, schedules), as well as necessary assistance and lead time for state emergency response preparation. The commentor feels the Draft PEIS should quantify the number, volume, transport mode, and characteristics of radioactive materials being transported under the proposed alternatives relative to baseline shipments.

  • Response: Large numbers of radioactive shipments are not expected under the Stockpile Stewardship and Management Program. The actual route and quantity of material transported would be classified information for purposes of national security, including security of the shipments against attempts of diversion. However, DOE has, on occasion, been able to identify to specific concerned communities that shipments are not planned through their location. The analysis presented in section 4.10 of the PEIS shows the risk to the public to be low. Plutonium and HEU will be transported exclusively in a Government-owned and -operated transportation system that provides maximum safety and security. All shipments are escorted by Federal officers, and only packaging that meets stringent Federal standards for the shipment of these materials is used. The packaging and transportation vehicles have, for example, been extensively tested and certified to assure their safety against material dispersal to the environment in hypothetical accidents involving such events as crashes, fires, and water immersion. Packaging and transportation methods and impacts are discussed in section 4.10 of the PEIS and appendix G of the PEIS. Projected estimates of plutonium and HEU shipments for the proposed alternatives are considered in the transportation risk analysis. Information is provided by DOE to state law enforcement and emergency services personnel on a regular basis.

09.09

The commentor asks if it would violate security to tell us how many shipments of radioactive material are going through Santa Fe at this time.

  • Response: Appendix section G.3 summarizes the shipments of these radioactive materials between the sites. For the PEIS, shipment numbers, routing, and date and time of shipments of plutonium and HEU would be classified. See also the response to comment summary 09.08.

09.10

Commentors express opposition to the transport of nuclear waste and other deadly toxins. One commentor states that the transportation risk numbers are terrifying.

  • Response: Transport of nuclear materials has been ongoing safely for more than 40 years. The analysis in this PEIS for transporting nuclear materials shows that risks to the public are low. The plutonium and HEU would be transported exclusively in a Government-owned and -operated transportation system that provides maximum safety and security. These hazardous materials shipments would be escorted by Federal officers who can handle transport emergencies or actuate the National Emergency Response System for assistance.

09.11

Commentors feel that transporting nuclear waste through New Mexico's cities and countryside is dangerous, irresponsible, and the chance for accident is too big to be taken. One commentor states that they do not want high-level waste (HLW) trucked to LANL or on New Mexico's highways. The commentor states that Federal Emergency Management Agency does not even have a protocol for dealing with a collision spill.

  • Response: The Stockpile Stewardship and Management Program does not generate HLW; however, under the preferred alternative, there would be TRU waste shipments from LANL as discussed in section 4.6.3.10. The transportation of hazardous materials, including radioactive waste, is essential for national commerce. The methodology for the safe transport of these materials is well established. The packaging is federally certified for safety and must retain its contents under the most severe accident conditions (e.g., fire, impact, puncture, or water immersion). The transport of all hazardous materials is regulated by Federal hazardous materials laws that are applicable to DOE and other hazardous material shippers, and cannot be preempted by individual states.

09.12

One commentor wants to know the extent of transportation (number of trucks, routes, safety precautions, accident mitigation, and such) of all nuclear materials along New Mexico's roads and the extent to which this will increase once the pit fabrication mission is implemented at LANL. Another commentor is concerned about the number of pits that would be transferred between Santa Fe and Pantex, and asks if there would be trucks going through Santa Fe with Hiroshima-size nuclear potentials on them. Finally, one commentor asks if there are trucks right now on the highway that are transporting waste between Pantex and LANL.

  • Response: Pit fabrication is not a new function at LANL; they already have a research and development (R&D) pit fabrication mission. As discussed in section 4.10, pit transportation would include about four round trips per year of safe secure trailer shipments. For the transportation of pits under this PEIS, the shipment numbers, routing, and date and time of shipments would be classified. These materials, however, would be transported exclusively by the Government-owned and -operated transportation system that provides maximum safety and security. A pit would be shipped as a separate weapon component (without HE) and, as such, would be unable to explode as a nuclear weapon. The potential risk from transporting pits would be radiation exposure as a result of a traffic accident. Nuclear materials in shipment are contained in packages that have been designed and certified to meet NRC standards to prevent a radioactive release during an accident. There are currently no trucks on the highway transporting waste between Pantex and LANL.

09.13

The commentor expresses concern about the transportation and safety of low-level radioactive waste on commercial carriers.

  • Response: DOE low-level waste (LLW), which consists primarily of materials such as radioactively contaminated paper, protective clothing, or cleaning materials that result from industrial processes, has been transported safely and securely by commercial carriers for more than 40 years. DOT requires high-integrity packaging for such materials to the extent that potential exposure of radiation at the outside of the package is insignificant (typically less than 1 millirem (mrem) per hour per package at 1 m from the package). DOE selects its commercial motor freight carriers of radioactive material very carefully and subjects each carrier to routine evaluation of its operating practices to ensure that they meet DOE and DOT standards.



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