Final Environmental Impact Statement for the Continued Operation of the Pantex Plant (2023)



Chapter 3 provides responses to all comments received during the publiccomment period.

Section 3.2 below explains how to find information in this chapter. However, the "green" pages at the very front of this volume alsoprovide another, easily located set of instructions for locating documents andcomments that are of particular interest.


The comments appearing in this chapter are categorized and organizedaccording to their topic, or resource category. The sequencing of resourcecategories is as follows:

  • Alternatives (01)
  • Relationship to other EISs (02)
  • Infrastructure (03)
  • Land use (04)
  • Geology and soils (05)
  • Water resources (06)
  • Air quality (07)
  • Acoustics (08)
  • Biotic resources (09)
  • Cultural resources (10)
  • Socioeconomic resources (11)
  • Intrasite transportation (12)
  • Waste management (13)
  • Human health (14)
  • Aircraft crash (15)
  • Intersite transportation (16)
  • Environmental justice (17)
  • Irreversible and irretrievable commitment of resources (18)
  • Unavoidable adverse environmental impacts (19)
  • Relationship between short and long term effects (20)
  • Cumulative impacts (21)
  • DOE policy (22)
  • NEPA process and procedures (23)
  • Miscellaneous (24)

The parenthetical code after each of the above categories comprises thefirst two characters of comment numbers for that topic category. For example,all comment numbers relating to water resources begin with "06".

It should be noted that during the public hearings, DOE pursued a policy ofsuggesting, but not requiring, people to identify themselves whenever they madea comment. Whenever a person identified himself or herself, that identificationwas made in the record of the hearing. When the person did not identify himselfor herself, an anonymous identification (such as unidentified speaker) wasentered into the transcript. This policy allowed a person to choose whether heor she wished the public record to identify himself or herself with theparticular comment. In addition, some of the postcards submitted had illegiblesignatures. Thus, for these two reasons, there are numerous comments attributedto unidentified commentors.


In the following subsections, the comments and their responses are placed inComment Number sequence as shown in the marginal code labeled "RC",for resource category. Thus all comments pertaining to alternatives (resourcecategory "01") are listed together. Following them are the commentspertaining to the relationship of this EIS to other EISs (resource category 02),etc.

3.1 Alternatives

RC: 01.001

Doc: HT11/16

[At]...Kirtland Air Force Base...they already have how many [plutonium pits] the Manzano Mountains?... Because Ive been told otherwise thatthere [are] a lot of pits stored in the Manzano Mountains.


In confirmation to the response given at the public hearing, there areno pits stored in the Manzano Mountains as identified in volume I, section 5.5. The Manzano Weapon Storage Area was deactivated by the Department of Defense inJune 1992, including deactivation of the Perimeter Intrusion Detection and AlarmSystem. Since 1990, intersite transportation of pits to Rocky Flats hasdiscontinued. Pantex Plant remains the primary location for interim pitstorage. The Manzano Weapon Storage Area is only being considered as analternate interim pit storage facility. Selection of this site as analternative is discussed in volume I, section 3.1.4.

RC: 01.002

Doc: HT11/17

So starting in the P-tunnel [NTS], would that mean that youd be opening itup where those tests happened and taking the pits into the assembly?

How far away from the actual tests are they stored from the sealed area?


Test areas at NTS would remain sealed and would not be disturbed. Theside tunnels used for previous nuclear tests are all permanently sealed off. These areas are not expected to affect pit storage activities. Further, theDefense Nuclear Agency (DNA) nuclear explosives program has been suspended. Should the tunnel be used for pit storage and the DNA nuclear explosives programresume, a new tunnel could be created for that program.

RC: 01.003

Doc: HT11/18

How about the device assembly facility, what kind of place is that where theother pits are [stored]?


The following detail is provided in addition to the response given atthe public hearing. The Device Assembly Facility (DAF) was constructed toperform assembly and disassembly of nuclear test devices and as a backup nuclearweapon assembly/disassembly facility to Pantex Plant. It is constructed withassembly cells and bays which could be used for pit storage. No pits arecurrently in storage at this facility.

RC: 01.004

Doc: HT11/28

Whats the difference between continuing the current mission and no action?


To reiterate the response given at the public hearing, there is nodifference. The current mission is the No Action in this EIS.

RC: 01.005

Doc: HT14/1

Any plutonium or special nuclear material storage disposal program must becompatible and integrated with the Tri-Party Agreement commitments andmilestones and should not affect the rate or funding of cleanup. The programwould have the safe disposition of plutonium as a priority.


The Hanford Site Tri-Party Agreement is an agreement among the U.S.Environmental Protection Agency, Washington State Department of Ecology, and DOEfor achieving the compliance with the remedial action provisions of theComprehensive Environmental Response, Compensation, and Liability Act (CERCLA)and with treatment, storage, and disposal unit regulation and corrective actionprovisions of the Resource Conservation and Recovery Act (RCRA). Pit storageoperations are regulated by the Atomic Energy Act.

RC: 01.006

Doc: HT05/8

From an environmental standpoint, what changes when you go from 12,000 pitsto 20,000 pits? You seem to have made a fairly substantial deal out of goingfrom 12,000 to 20,000 [pits]. And I wondered if there was anything more to itthan what youve just said. What should those of us concerned about theenvironment worry about going up to 20,000 pits?


To elaborate on the response given at the public hearing, no newconstruction of pit storage magazines would be required at Pantex as a result ofincreasing interim storage to 20,000 pits. Therefore, little to no changes inplant facilities and infrastructure, land resources, geology and soils, waterresources, air quality, acoustics, biotic resources, cultural resources,socioeconomics, waste management, and environmental justice are expected.

Pit storage itself has no impact on the environment other than a smallamount of radioactive exposure to workers, and should an accident occur, to thepublic. As Pantex Plant interim pit storage increases from 12,000 to 20,000, aperson in the vicinity of Pantex Plant has a slight increase in fatal cancerrisk (4.3 x 10-12) from potential aircraft crash plutonium dispersalaccidents compared with the baseline annual cancer risk of 1.7 x 10-3.

Clarifying language regarding pit storage activities has been added tointrasite transportation and human health sections as Pantex Plant increasesstorage from 12,000 to 20,000 pits.

The commentor is referred to volume I sections on Impacts of ProposedAction (4.3.2, 4.4.2, 4.5.2,... 4.16.2) for additional information.

RC: 01.007

Doc: HT13/1

The document talks about the 120-odd bunkers and then it talks about the 41[magazines] that are actually in the mountain, and on [page] 5-55, it says thatmore than 30 of these 41 magazines have a minimum overburden of 9 meters, andsix pages later, it says 35, so I just first want to get some clarificationabout the bunkers that we are talking about.

How many are there, and is the positionand Nan may be able to answer this aswell as the Major, is the position [such] that if storage happened at Manzano,only the bunkers with at least the minimum 9-meter overburden would be used?

So how many of the 41 [magazines] actually meet that standard?


Volume I, section 5.5, has been clarified to discuss only the 35magazines with a minimum overburden of 9 meters (30 feet).

For the 20,000-pit storage option, approximately 25 of the 35 Type Dmagazines would be utilized. For the 8,000-pit storage option, approximately 10of the 35 Type D magazines would be utilized.

The minimum 9-meter (30-foot) overburden was used to reasonably assessimpacts for comparison purposes with the other interim storage alternatives. Volume I, section 5.5.1, discusses and analyzes the impacts of storage atManzano.

RC: 01.008

Doc: HT13/6

I am interested in knowing, since there are 41 identified bunkers in themountain, and 20 or so, up to 25 could be used if all 20,000 pits would come,what is the present and continuing mission for the other nearby bunkers? Whatwould be in them? What would happen to them? What effect does storing pitshave on those bunkers that could affect the mountain and the pit storage?

Are they going to be answered in the context of between now and the time ofthe final EIS?


To elaborate on the response given in the public hearing, the storage ofpits in certain bunkers is not expected to impact the continuing mission of theother nearby bunkers. At Pantex Plant Zone 4, multi-purpose operations (i.e.,storage of weapons, pits, components, high explosives, wastes, environmentalmonitoring supplies, maintenance equipment) all occur within the same area aspit storage without any problems. The storage of other materials in theremaining 81 bunkers at Manzano would continue. The "Phase I EnvironmentalBaseline SurveyManzano Weapons Storage Area" contains brief descriptions ofthe storage activities at Manzano.

The environmental impacts of interim storage of pits at Kirtland AirForce Base are discussed and analyzed in volume I, section 5.5.

RC: 01.009

Doc: HT13/23

Does anybody else want to jump in before I go into some other things? Howdid the 20,000 number get established, 20,000 pits?

Why is that the bounding number since when we started dismantlement, we hadconsiderably more warheads than that?

It is a public number that the United States in the 80s had well over 25,000nuclear weapons. It is also a well-established number in the START II treaty,which has been ratified by the senate of the United States, that the goal wouldbe down to 3,500 warheads. So on the face of it, we would dismantle more --from dismantlement, we would have more than 20,000 pits.

Let me ask the question [a] little differently. Isnt it true that the20,000 number was first used by the Department of Energy in an EnvironmentalAssessment done three years ago, more or less, at Pantex, which was anenvironmental assessment that said, "Lets do this interim storage of 20,000pits at Pantex?" That is the first place that I am aware of that theDepartment used that number. Is that not true?

That number is a pre-START II ratification number, and it appears to me itis a pre-START II number in any case, and the real question is to put it in thecontext of the sitewide. The sitewide says there is the potential of handlingup to 2,000 weapons a year in terms of the analysis of the operation at Pantex,it talks about up to 2,000 a year, although it assumes that a more likely numberis 1,000 a year during this ten-year time frame.

Isnt it the case, terms of Pantex and the numbers of pits, that duringthe next ten years, there could be more than 20,000 pits?


Regardless of the number of operations per year, interim storage of upto 20,000 pits would be consistent with dismantlement to START II stockpilelevels. The EIS analysis assumes that combined activities of assembly,disassembly, and modification would not exceed operations on 2,000 weapons peryear. For assessment of environmental impacts, the EIS examines impacts acrossa reasonable range of activity levels by assessing impacts of activity levelsfor operations on 2,000, 1,000, and 500 weapons per year.

Operations on these numbers of weapons per year represent a reasonable,but conservative estimate of work that may be required at the plant, based oncurrent policy directives, and allow a set of defined tasks to be accuratelyanalyzed. The operations on each of the weapons in these defined sets areassumed to be extensive (representative of full assembly or disassembly). Actual workload and range of tasks are well understood, and impacts of actualoperations are expected to be encompassed by this conservative analysis. Accordingly, over 2,000 weapons per year may be worked on at Pantex Plantwithout exceeding the environmental impacts identified in this conservativebounding analysis. The 2,000, 1,000, and 500 weapons activity levels should notbe considered specific limits.

RC: 01.010

Doc: HT13/24

Is 20,000 pits for interim storage actually a bounding number or, within thenext ten years, could the number actually be higher than that? [This] is thespecific issue I would like to see addressed [in the final EIS].


See discussion in section 1.3.1 of this volume regarding the basis for20,000 pit storage limit. The number of pits stored at Pantex Plant would notexceed 20,000 without appropriate NEPA review.

RC: 01.011

Doc: HT13/25

Two questions in that regard: one is that if, in fact, the Department istaking the position that they would have to somehow supplement this or someother NEPA document before they completed 20,000, that should be expresslystated, and if that is not the Departments position, that specific statementneeds to be made in this document and in the ROD.

Related to that, I would also request that the document analyze where the20,000 number came from and how that would relate specifically to less thanSTART II levels of dismantlement.


DOE may supplement or revise the Pantex EIS as a result of changes otherthan interim storage issues. However, DOE expects to review the environmentalimpact analysis contained in the Pantex EIS before the year 2007 as part of theagencys ongoing compliance responsibilities under NEPA, regardless of the numberof pits placed into storage. In regard to the 20,000 storage level, seeresponse to comment 01.009.

RC: 01.012

Doc: HT13/26

I am going to throw out something, that you drop [Manzano] from this projectbecause it is not going to be a permanent storage [site]. You should get youract together and put [plutonium] where it is finally going to be. Put[plutonium] at one of the places that will be a permanent storage because of thefact that you, yourself, have said [Manzano] is only considered able to handlethe plutonium and not others, and this is only interim. Well, just wait and put[plutonium] where it is finally going. Get your other plan together, decide it,pick a site and hold onto it until then.


See discussion in section 1.3.1 regarding site selection process andsection 1.3.2 in this volume regarding site attributes.

RC: 01.013

Doc: HT13/31

How many bunkers are required for 20,000 pits?


Approximately 25 Type D magazines are required for interim storage ofpits at Kirtland Air Force Base. At Pantex, 18 Modified Richmond magazines and42 Steel Arch Construction magazines have been identified for storage of pits. Structures other than magazines would be used at other sites.

RC: 01.014

Doc: HT13/42

Is there a justification for continued exploration and alternative forms ofhigh explosives [HE] at this point in time that would justify the health andenvironmental risk?


To elaborate on the response given at the public hearing, highexplosives research and development, including testing, is an essential part ofstockpile maintenance. As long as there is a stockpile, this function must beperformed. The original Notice of Intent for the Pantex Site-Wide EIS (59 FR26635) included the possibility of relocating some or all of Pantex Plantoperations as part of the Relocation Alternative, including HE operations. Uponfurther review, it was determined that the relocation of operations, includinghigh explosive operations, from Pantex Plant within the time period of this EISdoes not meet the purpose and need for DOE to maintain minimum disruption ofweapon disassembly operations. The commentor is referred to volume I, chapter2, Purpose and Need for Action, for additional information. The Stockpile PEISassesses alternatives for the explosive operations at Pantex Plant.

RC: 01.015

Doc: HT13/79

As I imagine the process then, they go through a series of disassembly ofthe can subassembly to separate the different layers of metal, et cetera, so thefinal storage of the can subassemblies, is that considered anywhere?


The Disposition of Surplus Highly Enriched Uranium Final EnvironmentalImpact Statement discusses and analyzes the disposition of surplus cannedsubassemblies of highly enriched uranium (HEU) at Oak Ridge Reservation (ORR).

Only the transportation of HEU and depleted uranium components fromPantex Plant to ORR for storage, processing, and staging is addressed in thisEIS.

RC: 01.016

Doc: HT13/87

Pantex has a high degree of public support in the region. In repeatedpolling, it has registered over 80 percent for continued operation of the plant. The discussions here tonight about the deficiencies in the high explosivesprogram, I think, are misguided, and Pantex should be selected as a preferredalternative in the other PEIS, the SS&M PEIS, for continuation of highexplosives.

I make those comments on the record as Bob Juba with the Amarillo EconomicDevelopment Corporation speaking with the endorsement of the city government ofAmarillo.


The original Notice of Intent for the Pantex EIS (59 FR 26635) includedthe possibility of relocating some or all of Pantex Plant operations as part ofthe Relocation Alternative. Upon further review, it was determined that therelocation of operations, including high explosive operations, from Pantex Plantwithin the time period of this EIS does not meet the purpose and need for DOE tomaintain minimum disruption of weapon disassembly operations.

Programmatically, for the longer term, consideration of the attributesof Pantex Plants high explosive capabilities, as well as each of thealternatives considered for siting high explosive operations, would be part ofthe decision process in the SSM PEIS.

RC: 01.017

Doc: HT13/80

I wouldnt be incorrect in assuming that there is much more processing of acan subassembly that has to go on before it is ready for some sort of storageand the processing involved in the plutonium pit once it is removed? Is thatcorrect?


The Disposition of Surplus Highly Enriched Uranium Final EnvironmentalImpact Statement analyzes the disposition of canned subassemblies of HEU at OakRidge.

RC: 01.018

Doc: HT12/26

Im curious [about] whats being done to upgrade and correct that before youtalk about putting more there. Also, I have the general comment that storage atPantex is, like a lot of other DOE programs..., really...only interim action. It really doesnt lead to anything. These pits eventually are either going to bein the strategic reserves, stockpile management program or the dispositionprogram, and really youre a lot better off with bringing SavannahRiver where you get this energy of feeding into other programs because Pantex isnot an operating plutonium site. ...You just say, well, we dont really havenuclear facilities, we really dont have plutonium facilities. To do these othermissions you need those. So my general comment is that you ought to look atputting them [the pits] at a functional plutonium site, [of] which there reallyonly happens to be one.


The scope of the Pantex Plant EIS encompasses the ongoing operations,including interim pit storage, transporting pits to and storing on an interimbasis at an alternative site (e.g. Savannah River Site), and transportingclassified components between Pantex Plant and other sites. Pantex Plantalready has capabilities to perform all these missions.

In addition, see discussion in section 1.3.2 of this volume regardingsite attributes.

RC: 01.019

Doc: PC-006/1

Pits at Pantex are managed in facilities and operations [that] do not meetany of the DOEs standards for design and operation of nuclear facilities. Doubling the storage of pits under substandard conditions should not beconsidered a reasonable alternative.


Pit storage activities are not considered a high hazard operation asdefined by the term "nuclear facility" in appropriate DOE standards. Storage magazines are defined as category 2 "non reactor nuclear facility." After repackaging of pits into AT-400A containers, the moderate hazarddesignation is further reduced.

DOE disagrees with the commentor that current pit management operationsare substandard. The Pantex safety record is excellent. The environmentalimpacts of interim pit storage at Pantex have been discussed and analyzed,including potential Human Health impacts due to accident scenarios, in this EIS.

RC: 01.020

Doc: PC-024/3

P. S-7, left column, "No Action Alternative," 2nd paragraph, 5thline. The construction of the Hazardous Waste Treatment and Processing Facilityshould not be excluded under this alternative. Proposals, which make the NoAction Alternative unreasonable under NEPA, should not be included.


In the March 1996 Draft version of the Pantex Plant EIS, the proposedconstruction of the Hazardous Waste Treatment and Processing Facility (HWTPF)was considered necessary for enhancing waste operational efficiency and safetyand meeting regulatory requirements established in the Agreed Order. Withoffsite disposal shipments of mixed waste in 1994 and two shipments in 1996, asnoted in volume I, section, and changes contained in the August 1996FFCA Compliance Plan Annual Update document, construction of the HWTPF is nolonger considered a regulatory requirement. However, without the HWTPF, wastetreatment and processing capabilities remain greatly limited and do not meet theDepartments purpose and need. This information has been incorporated throughoutvolumes I and II, as appropriate.

RC: 01.021

Doc: HT16/40 specific question relates to appendix H-14, where on the pit reusefacility it talks about the glovebox type operations and the glovebox bays thatwill be included in this facility. I guess I have a couple of questions relatedto that. How many glovebox type enclosures are currently operating at Pantex?


There were 9 gloveboxes in use at Pantex Plant in August 1996.

RC: 01.022

Doc: HT17/21

The other comment has to do with the assumption that in the no actionalternative,...when you reach the 12,000 pits, disassembly would have to cease. Its really hard for me to believe that you [do] not have more creative minds inthe Department of Energy than this. If you can justify interim storage of12,000 pits at Pantex on the basis of an environmental assessment, I wouldsurely think that you could find ways to justify interim storage of pits atother locations until all of the issues that need to be resolved are resolved.


See discussion in section 1.3.1 of this volume regarding the basis for20,000 pit storage limit and section 1.3.2 of this volume regarding therelationship between the other EISs.

RC: 01.023

Doc: HT17/22

The unstated question, of course, is whether or not youre going to attemptto do processing of plutonium in the Panhandle. Thats the primary reason that Ibelieve most people here are opposed to the storage. Its not so much the riskof storage, which is, at least to my estimates, not very great. Its thepossibility that you will later use the Pantex facility as a staging ground forthe processing of plutonium, either taking the contents of the pits and makingthem into fuel rods or perhaps reprocessing spent fuel rods.


The Proposed Action and alternatives for the Pantex EIS do not involveprocessing of pits into any other form. Nor do the alternatives of this EISanalyze a proposal for Pantex to reprocess spent fuel rods. In addition, seediscussion in section 1.3.2 of this volume regarding the relationship of the S&DPEIS.

RC: 01.024

Doc: HT17/39

This document under review today does not meet the commitments made to thecitizens of this area in DOEs agreement two years ago. The examination ofalternative storage sites seems halfhearted at best. If the effort is broughtshort because of the threat to Albuquerque in using the existing ManzanoMountain facility, what are the citizens of Gray and Potter Counties to make ofthe governments regard for their safety.


In response to Item 1: As described in volume I, section 3.1.4, 60 DODinstallations were screened by the Nuclear Weapons Council staff. With theexceptions of the Manzano Weapon Storage Area, located on Kirtland Air ForceBase and Seneca Army Depot, the Council staff determined that none werefeasible. In addition, see discussion in section 1.3.1 of this volume regardingthe Site Selection Process.

In response to Item 2: DOE recognizes that all its facilities and allits hazardous materials, including plutonium, require varying levels ofoperational and environmental controls to protect the workers, the public, andthe environment. DOE continues to work with EPA, states, employees, unions,stakeholders, and the general public to develop programs and commitments tobetter manage its facilities and all hazardous materials.

RC: 01.025

Doc: HT17/41

...area residents are entitled to have a better idea of what the wastehandling facility and the pit reuse facility really do imply for our future.


The commentor is referred to volume II, appendix H. The proposed wastehandling facility would improve the Plants ability to handle its own wastes andenable fulfillment of the Agreed Order (Federal Facility Agreement) with theState of Texas. The pit reuse facility would not have the ability to processplutonium into any other form. It would merely support operations on thesurface of the pits.

RC: 01.026

Doc: HT17/53

It has been really difficult for me to read things like...we have 12,000pits at Pantex and no other [if] arrangements are made, then dismantlement willstop. It is a real frustration to read a line like that, and it feels verydisingenuous. One of the reasons that citizens groups such as mine press sohard for this document and work so hard for those issues, is that we could notbelieve that the Department of Energy was going to take the posture of we eitherstore them all in one place, we have no backup.


The No Action Alternative describes conditions that would result if theDepartment should not undertake to change the status quo. The No ActionAlternative does not have to be reasonable, and frequently is not. Rather, theNo Action Alternative is intended to provide a baseline for comparison. Frequently, as in this case, the consequences of continuing the status quo alsoserve to point out quite clearly that an action is needed. In the case of thisEIS, the Department has a Proposed Action to put up to 20, 000 pits in storageat Pantex Plant, and an alternative of relocating up to 20,000 pits to one offour other sites for interim storage. The Department will not store pits atPantex Plant beyond the current 12,000-pit level without examining theenvironmental impacts of storing an additional 8,000 pits. This EIS has beenprepared in accordance with requirements of NEPA and CEQ Regulationsspecifically to allow the Secretary of Energy to make decisions that will permitcontinued dismantlement of all weapons retired from the stockpile as well as tocontinue other operations of the plant.

RC: 01.027

Doc: HT17/63 terms of Nans characterization that the reason to do the no actionalternative is to provide a good baseline for what impacts of other alternativesand other actions would be, I think in numerous cases a [poor] job was done....


DOE believes the Pantex Plant EIS is an effective document. Seeresponse to comment 01.026.

RC: 01.028

Doc: HT17/67

...its inconceivable that you could be saying that continued storage atPantex of pits, if that were to happen for the next ten years, would be done forthat entire time in Zone 4. And so youre going to need to look explicitly inthis document at the alternative locations for that, the impacts and effects ofthat, et cetera.


At Pantex, 18 Modified Richmond magazines and 42 Steel Arch Constructionmagazines have been identified for storage of pits. No new facilities arerequired to store up to 20,000 pits. Environmental impacts at the alternativesites have been discussed and analyzed in volume I, chapter 5.

New pit storage facilities and upgrades to existing pit storagefacilities are within the scope of the S&D PEIS and SSM PEIS.

RC: 01.029

Doc: FG-003/1

The DEIS makes reference to "interim storage" of plutonium pits atthree DOE sites (Nevada; South Carolina; Washington State) and a Department ofDefense site at Kirtland Air Force Base, New Mexico. However, the DEIS did notdefine what constitutes "interim storage," either a fixed period ofyears or decades, or until a permanent storage facility is approved, upgraded orbuilt. If possible, the Pantex FEIS should define the minimum and maximum timelimits expected by DOE for "interim storage" (we recognize thedifficulty in this because nuclear storage projects often run into problems thatdelay their proposed timeliness).


Interim storage refers to the time period until the long-term storagedecisions are made and implemented.

RC: 01.030

Doc: FG-003/3

It would be helpful if the Final EIS could provide the tonnage of the 8,000to 20,000 pits that would be relocated under the interim pit storagealternative. If allowable under the national security considerations, it isrecommended that the FEIS quantify the weight in terms of plutonium [Pu], othernuclear material, and other constituents such as Resource Conservation andRecovery Act (RCRA) regulated hazardous waste.


The actual amount of plutonium contained in a pit is classified. Because of this, it is DOEs policy to present the amount of Pu at Pantex interms of the number of pits. The composition of other nuclear material, metals,and other constituents in a pit is classified. However, there are no RCRAregulated wastes in the pit form.

RC: 01.031

Doc: MG-002/3

There is information that leads Clark County to question the intent of DOEto actively pursue action alternative of storage of pits at the Pantex Plant. The DEIS makes reference to extensive restoration work that is being planned oris in progress at the Pantex and Hanford sites. We question whether it is soundpolicy to conduct such environmental restoration work at Pantex, a majority [of]which will be completed by 2000, and then store the plutonium pits on site, evenfor the short term. Given this, it would appear the pit storage relocationalternative may be more attractive than is presently represented in the DEIS. And, the NTS may emerge as the most feasible site for such relocation, since itis relatively close to the Pantex Plant, there are minimal environmentalrestoration plans for the NTS [as compared to other candidate sites] and thereare frequent mentions of the NTS as a disposal or storage site in other DOEEISs. For example, the Stockpile Stewardship and Management PEIS includes analternative which describes the complete closing of the Pantex Plant with itscapabilities relocated to NTS, Los Alamos and Lawrence Livermore facilities. The Pantex EIS does not address the implications of this alternative. Thisissue should be addressed in the final EIS and the Record of Decision.


Storage of pits does not generate environmental contamination. Environmental restoration activities are independent of the pit storagedecision. These activities will continue whether pits are stored at PantexPlant or not. DOE recognizes that all its facilities and all its hazardousmaterials, including plutonium, require varying levels of operational andenvironmental controls to protect the workers, the public, and the environment. DOE continues to work with EPA, states, employees, unions, stakeholders, and thegeneral public to develop programs and commitments to better manage itsfacilities and all hazardous materials. In addition, see discussion in section1.3.2 of this volume regarding Site Attributes.

Cumulative impacts related to changes in Pantex Plant operations fromdecisions resulting from the SSM PEIS, the S&D PEIS, and the WM PEIS arepresented in the Pantex Plant EIS.

RC: 01.032

Doc: PC-031/1

The promised analysis of alternative DOD storage sites looks only at theManzano Weapons Storage Facility at Kirtland Air Force Base and seems to rejectit since it is not included in the Storage & Disposition PEIS. As thefacility is deemed technologically adequate, we may only conclude by inferencefrom the very words of the document that the DOE takes a more cavalier attitudetoward the safety of Panhandle residents than people who live in Albuquerque. The fact that more people would be threatened in the Albuquerque area in no wayjustifies placing that liability just 17 miles east of the city of Amarillo inthe middle of such a highly productive agricultural area [that] is the beginningof a food chain reaching across the world. Those who assert otherwise are morepersuaded by convenience or dollars than reality. Is DOE so awash in funds thatit can afford building new facilities when Manzano Mountain is more thanadequate? Taxpayers as well as local residents deserve a better explanationthan exists in this document.


In response to Item 1: As described in volume I, section 3.1.4, 60 DODinstallations were screened by the Nuclear Weapons Council staff. With theexceptions of the Manzano Weapon Storage Area, located on Kirtland Air ForceBase and Seneca Army Depot, the Council staff determined that none werefeasible. In addition, see discussion in section 1.3.1 regarding the SiteSelection Process.

In response to Item 2: DOE recognizes that all its facilities and allits hazardous materials, including plutonium, require varying levels ofoperational and environmental controls to protect the workers, the public, andthe environment. DOE continues to work with EPA, states, employees, unions,stakeholders, and the general public to develop programs and commitments tobetter manage its facilities and all hazardous materials.

RC: 01.033

Doc: PC-025/7

The first two bullets in the second column on page 3-3 [volume I, section3.1.1]. Where are security and nonproliferation activities? They are routinecorrect?


Security and nonproliferation activities are part of the routineactivities performed by the plant along with waste management, infrastructureand building maintenance, etc., in the bullet addressing "continuingroutine Pantex Plant activities.

RC: 01.034

Doc: PC-025/8

On Page 3-7 in second column in the second paragraph. It appears a loop holeexists for DOE in dealing with the backlog of stored pits. If a containeravailability problem exists (like the FL container problem on F-2) DOE couldstore 20,000 pits without shipping one pit and not violate this EIS. What wouldbe the hard number before DOE would stop dismantlement to put pressure on thetransportation end? Lacking cans for shipment seems to make relocationalternatives unreasonable and thus not meeting the intent of NEPA, pleaseprovide technical justification. This EIS is flawed because the alternatives arenot "technically mature" to use a DOE phrase found in SSM and S&Dfor rejecting analyses of alternatives. Lack of cans appears to be a reasonablyforeseeable impact, please assess. The 12,000 alternative is not possible underthis EIS.


Under the Pit Storage Relocation Alternative, the number of pits ininterim storage at Pantex Plant could be greater than 12,000 pits for atemporary period until enough of the planned new transportation containers areavailable. This is not a loophole since the impact analysis considers thebounding effects of having up to 20,000 pits at the Pantex Plant. DOEs statedPreferred Alternative is the Proposed Action to retain the interim storage forup to 20,000 pits at Pantex Plant.

DOE would not stop weapons disassembly under the Relocation Alternativeeven in the case that there would not be enough transportation containersavailable at any particular point in time. The reason for this is that theexact timeframe within which any of the candidate sites could be made ready andthe 8,000 or 20,000 pits transferred can not be precisely determined. The needto continue the weapons operations at Pantex is independent of the interimstorage issue. Therefore, the disassembly of weapons has not been tied to thepit relocation schedule and under the Pit Storage Relocation Alternative allweapons operations (e.g., disassembly, assembly, etc.) would continue to beperformed at Pantex Plant.

The Pit Storage Relocation Alternative is reasonable under NEPA in thatthe technology for the storage containers is mature. DOE has the knowledge tobuild the containers and in fact has already built the test models. Furthermore, the Department already has a properly certified Type B container(the FL container), which could be produced if technical difficulties with theAT400A certification should arise. The impact of any delay in completing therequired testing of the container and beginning manufacture would only berelevant if Pantex Plant did not have the capacity for interim storage of thenumber of pits which could accumulate while the plant waited for the containersto be manufactured. Since Pantex Plant has the capacity to safely store all20,000 pits, there is no problem if there is a delay in receiving certifiedcontainers.

The only difference between the Pit Storage Relocation Alternative andthe Proposed Action is the potential interim storage of pits at a site otherthan Pantex Plant. The impacts of the Pit Storage Relocation Alternativeconsist of those described for the Proposed Action plus those associated withthe transfer operations. In other words, the impacts of the Pit RelocationAlternative include the impacts from the possible storage of up to 20,000 pits,and therefore, bound the impacts of the case where containers do not becomeavailable. The 12,000 pit limit only applies to, and is discussed under, the NoAction Alternative. Under the No Action Alternative DOE would ceasedismantlement once the interim storage level of 12,000 pits was reached.

RC: 01.035

Doc: PC-025/9

On Page 3-8 last bullet of page. If shipping cans are lacking, why is 8,000considered reasonable?


As stated in volume I, section 3.1.3, the availability of shippingcontainers affects only the schedule of shipments, not the feasibility of thealternative.

RC: 01.036

Doc: PC-025/11

Three bullets in second column of page 3-8. The rationale contains severalfatal flaws. The ability [that] includes past performance in securing pits,nonproliferation, and a safe and reliable stockpile should have been consideredin qualifying the sites. Please reassess sites based on these new criteria.Please remember when addressing this comment DOE stated to great length howvital DOEs missions regarding nonproliferation, security, and a safe andreliable stockpile were. What is the National Academy of Sciences position onplutonium storage?


The DOE disagrees with the commentor that the alternative storage siteselection process including Department of Defense facilities contains flaws orwas not reasonable. Current Pantex pit storage operations were used as abaseline for comparison purposes. Security and nonproliferation activities arepart of routine activities performed by Pantex Plant. Pit storage is arelatively simple function to performunlike manufacturing or chemical processingoperations involving nuclear materials. All sites evaluated in this documentcurrently perform, or have performed security functions for either similarmaterials or materials with similar security needs. All sites considered asalternatives would be capable of securely and safely storing pits and couldaccommodate nonproliferation objectives. The National Academy of Sciences hasnot addressed interim storage.

For an expanded discussion of the Pantex Plant Safeguards and SecurityProgram, the commentor is referred to the Pantex Programmatic InformationDocument (Pantex 1996b).

RC: 01.037

Doc: PC-029/2

Taking nuclear weapons apart at Pantex may make sense, but surely a bettersite for storage can be found. What do you think? I look forward to the seeingthe better alternatives in the final Environmental Impact Statement.


See discussion in section 1.3.1, regarding the site selection process.

RC: 01.038

Doc: PC-027/1

Your glossy presentation books dont actually offer much choice or manyalternatives. In fact, the choices and alternatives are very limited.


See discussion in section 1.3.1, regarding the site selection process.

RC: 01.039

Doc: PC-027/3

Regarding your proposal to use Kirtland Air Force Base/Albuquerque as a pitstorage site. Albuquerque is the largest city in our state. It is close toKirtland AFBthey are separated only by a gate guarda person can place one footin Albuquerque and the other on Kirtland Air Force Base. Its like storing nukesin the middle of a city. The highways are busy and prone to accidents. Theairport is busy too. One accident and youve lost a major population center. Your publication gives the impression that there is more separation than thereactually is between the base and the city. It takes only a few minutes to drivefrom the city to the Manzano site on the base. Many people work on the base, itis a large local employer. The city and the base actually touch and the citygrows every day. Albuquerque may have been a small town when the bomb wasdeveloped 50 years ago. It isnt small anymore.


In response to Item 1: The locations of Kirtland Air Force Base and theManzano Weapon Storage Area in relationship to the City of Albuquerque areproperly depicted in the Pantex Plant EIS.

In response to Item 2: The EIS, in volume I, section,discusses and analyzes an aircraft accident at Kirtland Air Force Base ManzanoWeapon Storage Area. With the minimum cover of 9 meters (30 feet) ofoverburden, the aircraft impact analysis shows potential accidents even withmilitary aircraft carrying conventional bomb loads, not a credible threat to pitstorage at the Manzano Weapon Storage Area.

In response to Item 3: DOE recognizes that all its facilities and allits hazardous materials, including plutonium, require varying levels ofoperational and environmental controls to protect the workers, the public, andthe environment. DOE continues to work with EPA, states, employees, unions,stakeholders, and the general public to develop programs and commitments tobetter manage its facilities and all hazardous materials.

RC: 01.040

Doc: SG-003/23

Page 3-2, Section 3.1.1 Proposed Action: Care should be taken to ensurethat the continued operation of Pantex Plant activities including "qualityassurance testing of weapon components and the research and production of weaponcomponents" is conducted in a fashion that will not increase DOE sliability for injury to natural resources.


DOE recognizes that all its facilities require varying levels ofoperational and environmental controls to protect the workers, the public, andnatural resources. DOE continues to work with EPA, states, employees, unions,stakeholders, and the general public to develop programs and commitments tobetter manage its facilities and natural resources. Nothing was found whichwould inhibit Pantex Plant from performing the missions stated in the ProposedAction.

RC: 01.041

Doc: PC-028/1

Page 5-7, 2nd column, 2nd para - It is not correct to state "and KAFB,near Albuquerque New Mexico-" Comment: KAFB is the southern boundary ofAlbuquerque, it is a joint use airport, (part of the city) - it is a part andadjacent to Albuquerque. Albuquerque is a major sized city, while the othercandidate sites are located away from major cities. You should give majorconsideration to either keeping Pantex as the only site, or consider the othertwo choices.


KAFB adjoins the city limits of Albuquerque, but is not part of thecity. A portion of the airport is under control of the city, but not all of theairport facilities are. See discussion in sections 1.3.1 and 1.3.2, of thisvolume.

RC: 01.042

Doc: CO-007/2

With all of the research, development, manufacturing and deployment pouredinto bomb-making, we are very short on environmentally sound methods for storageand disposition. Instead of the euphemistically named and costly program that isbefore us, we should be considering a "green" Manhattan II. Therequirements for dismantlement should be to: 1) dispose of the components insuch a way that they are not and could not be used in a bomb again, and 2)minimize, rather than contribute to, or perpetuate the waste stream ofradioactive materials.


In response to Item 1: The Atomic Energy Act requires DOE to sanitizeweapon components that are no longer needed through a process of destroying orremoving classified or other controlled matter and to demilitarize weaponcomponents through a process that results in an irreversible modification ordestruction of a weapons component or part of a component to the extent requiredto prevent use in its original weapon purpose.

In response to Item 2: The Pantex Plant Pollution Prevention/WasteMinimization Program originally implemented in 1991 has significantly reducedwaste volumes. The success of the program was instrumental in being awarded thePresidents Closing the Circle Award.

Final disposition of weapon-usable surplus plutonium is within the scopeof the S&D PEIS.

RC: 01.043

Doc: CO-005/10

The Agency should re-evaluate the risks to workers from low level radiationexposures using the risk factors reported in these studies. Such a reanalysiswould highlight the uncertainties associated with making predictions about thehealth effects of low level ionizing radiation. The issue of uncertainty inscientific theory is currently glossed by the misleading use of data from onlyone side of the debate.


See response to comment 14.129. The DOE understands that uncertaintiesexist in the methodology for evaluating human health risks. As discussed involume II, appendix D.6 a degree of conservatism has been introduced to thecalculations as a result of these uncertainties. However, DOE believes that theanalysis presented in this EIS is reasonable for evaluating environmentalimpacts of the alternatives.

RC: 01.044

Doc: PC-033/3

Page 5-55, Kirtland Air Force Base. Under the Pit Storage RelocationAlternative (section 3.13) the pit storage function currently carried out atPantex Plant would be transferred to another site. The Manzano Weapons StorageArea (WSA) is the candidate storage site at the Kirtland Air Force Base. Afterreviewing pages 5-55 through 5-75, I believe that the Manzano WSA would be theideal location for the storage of the plutonium pits. The Manzano Mountainfacility has the structure in place (storing office furniture at present);security is available; aircraft seem not to fly in a direct pathway to the WSA;water, air, and soil should not be adversely affected; and the local populationshould be better protected from accidental releases in this type of facilitywith the 30 foot coverage and better structure of the magazines. Some of themagazines at Pantex are 40 years old and have been proven to be unreliable forplutonium storage. I am referring to the heat build up in some of the magazinesthis past year and the installment of air conditioning units. Protection fromaircraft intrusion is not as great at Pantex, or terrorist missiles and/orbombs. Security has been proven to be very lax at times at Pantex and theproximity of the plant to the Amarillo International Airport (which is also usedfor military training flights), is also a concern. What are the reasons for notchoosing Manzano WSA over Pantex if that is a reality? If the DOD enters into aMemorandum of Understanding (MOU) with the DOE and Manzano is used for pitstorage, would the employees in charge of the Manzano WSA be employees of DOE orDOD?


See discussion in section 1.3.1, regarding site selection process.

DOE is currently studying the air conditioning option in four pitstorage magazines. By providing air conditioning, DOE seeks improved climatecontrol through reduction in the range of seasonal and daily temperaturefluctuation. DOE may choose to provide air conditioning to all pit storagemagazines based on these test results. DOE is fully committed to improve PantexPlants safe and reliable pit storage operations. Like the recent Stage Rightstorage configuration enhancement and the proposed AT-400A pit storage containerproject, the air conditioning option is expected to enhance storage operations. The fundamental safety design of the magazines is the physical structure of themagazines not air conditioning, Stage Right, or AT-400A containers. Theseenhancements are improvements to a sound pit storage management at Pantex Plant. Expect DOE to continue increasing the safety envelope.

The DOE and Pantex Plant take security issues very seriously. Pleasenote the numerous safeguard and security enhancement projects listed in appendixD of the Pantex Plant Programmatic Information Document (Pantex 1996b).

The risks associated with aircraft accidents have been discussed andanalyzed in volume I, section 4.15.

If Manzano is selected to conduct interim pit storage activities, thepits would remain under DOE control.

3.2 Relationship to Other Environmental Impact Statements

RC: 02.001

Doc: HT02-08/4

The agreement to evaluate alternative storage sites for pits, specificallyDepartment of Defense sites, seems to have been an insubstantial one since thatsite is not included in the actual storage EIS. If, as implied in the analysis,Manzano mountain becomes ineligible because of the threat such a facilityrepresents to Albuquerque, what are we to make of the governments concern forthe residents of the Panhandle?


As described in volume I, section 3.1.4, 60 DOD installations werescreened by the Nuclear Weapons Council staff. With the exceptions of theManzano Weapon Storage Area, located on Kirtland Air Force Base (at Albuquerque,New Mexico) and Seneca Army Depot (at Romulus, New York), the Council staffdetermined that none were feasible. Subsequently, it was determined that SenecaArmy Depot would not be available as a candidate site for pit storage. Inaddition, see discussion in section 1.3.1 in this volume, regarding the siteselection process.

For a discussion on the selection process for long-term storage ofplutonium the commentor is directed to chapter 2 of the S&D PEIS.

DOE recognizes that all its facilities and all its hazardous materials,including plutonium, require varying levels of operational and environmentalcontrols to protect the workers, the public, and the environment. DOE hasworked with EPA, states, employees, unions, stakeholders, and the general publicto develop programs and commitments to better manage its facilities and allhazardous materials. All of these plans and commitments have been reviewed todetermine if there are any conflicts or restrictions which would inhibit thePantex Plant from serving as a good location for the facilities proposed in theEIS. Nothing was found which would inhibit the Pantex Plant from performing themissions stated in the Proposed Action.

RC: 02.002

Doc: HT14/5

A systems analysis approach should be utilized to select the most effectivemethod for processing [of plutonium] and interim storage [of pits]. Thisanalysis should adequately address public and worker health and safety andenvironmental issues.


Processing of plutonium is not within the scope of the Pantex Plant EIS. The systems analysis approach is typically utilized in obtaining licenses,permits, and compliance assurance certification prior to operation offacilities. The systems analysis approach is not typically used in NEPAanalysis. The Pantex Plant EIS has addressed public and worker health andsafety and environmental issues. Moreover, the focus of the decision in thisEIS is the location of the interim storage not the method. A standardizedstorage method (Stage Right) is evaluated in this EIS in order to compare theimpacts at different candidate sites.

RC: 02.003

Doc: HT01-05/1

Based upon these reasons, I respectfully urge DOE to designate Pantex as thepreferred alternative site for all existing and new stockpile management andstewardship functions as well as consolidation of all plutonium storage anddisposition and any related functions.


See discussion in section 1.3.2 in this volume, regarding therelationship between the PEISs and the Pantex Plant EIS.

RC: 02.004

Doc: HT01-04/2

The EIS that deals with missile materials, storage, and disposition is onethat I have spent a good deal of time with. On the topic of storage, I feellike that were seeing that Pantex in its current role is ideally sited forstorage of plutonium pits. If it is anticipated that storage would...continueto be in that form, I dont think theres any question that Pantex, which isalready contemplated to have...or will have 21,000 pits in storage.... Butcertainly the vast majority of the pits in storage at Pantex, it makes sense tocontinue that function in that location.


See discussion in section 1.3.2 in this volume, regarding therelationship between the PEISs and the Pantex Plant EIS.

RC: 02.005

Doc: HT07/1

I just want to follow up and get the distinction, then, that the storage ofup to 20,000 pits, those pits are what Im going to call sealed, but youretalking about material that wont be sealed or will be packaged in some otherfashion?


To elaborate on the response given at the public hearing, each pit ishermetically sealed inside a protective cladding which is bonded to theplutonium. In the future, these pits will be stored in containers known asAT400A. AT400A storage configuration provides double shell container protection or, in the words of the commentor, a "sealed" package. Currently, pits are stored in ALR8 containers. Pits are encased by metal. Forweapons-usable fissile materials not in pit form, DOE would require similarmulti-layer "sealed" package containment. DOE recognizes that all itshazardous materials, including plutonium, require proper packaging to protectthe workers, the public, and the environment.

RC: 02.006

Doc: HT13/15

Is there a reason why it is only being looked at as interim and not longterm, or why is it suitable for one and not the other?


See discussion in section 1.3.2 in this volume, regarding therelationship of the S&D PEIS and Pantex Plant EIS.

RC: 02.007

Doc: HT13/22

You may not want to talk about this, but it seems like the Department istaking the position that these workers doses that we just talked about areinevitable, because even if the pits stay at Pantex, they will still have to beloaded out of Zone 4 and moved again, because the disposition PEIS says even ifthey all stay at Pantex, they would be loaded into Zone 12, is that correct?


To elaborate on the response given at the public hearing, the Departmentof Energy, through its contractor Mason & Hanger Corporation, is fullycommitted to the As Low As Reasonably Achievable (ALARA) program at Pantex Plantto help limit the number of personnel occupational exposures andpublic/environmental exposures to radioactive material. The majority of PantexPlant workers receive no radiation exposures (zero dose) during normaloperations. DOE Order 5480.11 and 10 CFR 835 specify a limit of 5 rem per yearfor occupational workers.

DOE recognizes to meet interim storage requirements, pits currently instorage at Pantex Plant would require workers to handle radioactive materialsincluding Zone 4 and Zone 12 pit transfers. This exposure has been discussedand analyzed in the EIS. DOEs commitment to reduced exposures, includes theimproved pit storage capabilities with the Stage Right automated pit storagesystem. When fully implemented this year, this system will significantly reduceZone 4 worker exposures. The Stage Right system uses a remote-controlledforklift to retrieve, place, and inspect Pantex Plant pit storage facilities,thus reducing hands-on radioactive material management.

RC: 02.008

Doc: HT13/27

I have a question or statement relating to how the sitewide and the twoPEISs, the [storage] and disposition and the stockpile stewardship PEIS, arerelating. We just spent a lot of time working on bringing people from all overthe state to the stockpile stewardship hearings, and the main topic ofdiscussion is plutonium pit fabrication at Los Alamos, and here we are talkingabout thousands and thousands of plutonium pits being dismantled.

It seems to me like the left hand doesnt know what the right hand is doing. One hand is trying to figure out what to do with pits, and the other hand iscreating more. Is that something that can in some way be tied in...if wehave...pits, it seems to me confusing that we would need to retool them todifferent specifications.


See discussion in section 1.3.2 in this volume, regarding therelationship of the PEISs and the Pantex Plant EIS. For the purpose ofclarification, weapons are dismantled, not pits. The intact, encased plutonium,or pit, from a dismantled weapon is placed in storage.

RC: 02.009

Doc: HT13/29

... Two points I want to make are, one, the fact that we have suchdifficulty in figuring out what to do with 20,000 pits, which I certainly do andwould hope that everybody here is, on the one hand, glad that we are getting20,000 pits out of bombs. That is a good thing, but the fact that what comesfrom the good thing of having fewer warheads armed and able to destroy the worldseveral times over is another problem, which is what to do with the 20,000 pits.

It is even more complicated because, as has already been stated, it would beone thing to say we know what to do with the 20,000 pits in the short termbecause we know what it do with the 20,000 pits in the long term. We know whatthe disposition is. In fact, we dont know what the disposition is.

I have talked about it in another context, so I will just summarize, I haveno confidence that the disposition PEIS in fact is adequately analyzing or isgoing to come up with a possible reasonable solution for longer term what to dowith those 20,000 pits. So I think it is something that some of us in thepublic and hopefully people in the federal government will pay a lot moreattention to in the future.


See discussion in section 1.3.2 in this volume, regarding therelationship of the PEISs and the Pantex Plant EIS.

RC: 02.010

Doc: HT13/81

Have they decided what they are going to be doing with the metal componentsfrom Oak Ridge once they have disassembled the secondaries to the point thatthey could go into storage that is equivalent to what the plutonium storagewould be, and would these sites possibly be considered in the future for storageof components of the secondaries the way we are currently looking at storage ofthe primaries?


The Disposition of Surplus Highly Enriched Uranium Final EnvironmentalImpact Statement discusses and analyzes the disposition of surplus HEU at OakRidge. In addition, see discussion in section 1.3.2 in this volume, regardingthe relationship of the PEISs and the Pantex Plant EIS.

RC: 02.011

Doc: HT13/82

They were not planning on shipping any of those components that aredisassembled from the secondaries back to Pantex or is allgoing to stay at Y-12 and Oak Ridge?


See response to comment 02.010.

RC: 02.012

Doc: HT13/83

You understand my general concern is, you develop a bunker that can store apit in a storage vessel, then you have got a bunch of spherical uranium orplutonium in the secondary components that need to go in at some point in astorage bunker inside a container format. Wouldnt we be looking at thepotential of once we put, for example, an Albuquerque bunker system intoprocess, wed be looking at potential in the future getting more than justprimary pits and looking at potentially getting a variety of others?

So the can subassemblies would be going into underground storage at OakRidge?...


See response to comment 02.010.

RC: 02.013

Doc: CO-010/1

... We do not believe that the community and stakeholders would supportsuch an action by the Department unless the site were also to be utilized forthe processing of the plutonium to a stable form for safe interim storage. Hanford would also be an ideal site for the processing of the excess plutoniumeither for vitrification of fabrication into reactor fuel for irradiation priorto disposal.

The site has the capability by operation of either or both the Fast Flux[Test] Facility (FFTF) and the WNP-2 Nuclear Power Plant on mixed oxide cores todispose of a substantial portion of the excess plutonium within the foreseeablefuture. This capability when coupled with the available mixed oxide fuelfabrication capabilities of the Fuel and Materials Examination Facility (FMEF)offers a single site processing and irradiation for disposal capability notfound at other potential storage sites. We believe that the Draft EIS should berevised to objectively evaluate this option in conjunction with the excessweapons disposal Draft EIS.

This area would be expected to be supportive of an excess plutonium storageand disposal mission provided that the related processing and fabrication taskswere also assigned here. Submitted herewith for the record is a positionstatement recently adopted by the Hanford Advisory Board [that] relates to thedisposal of excess weapons materials by irradiation in the FFTF. The HanfordAdvisory Board is a DOE sponsored stakeholder group representing variousinterests in the states of Oregon and Washington. This statement is consistentwith the position we have stated above on this subject.

Although the storage of excess weapons plutonium at Hanford in availablefacilities without further processing or utilization is probably significantlymore economical than the construction of new facilities at other sites, we donot feel that this is in the best interests of the community unless a concurrentprocessing mission was assigned to the site. A single purpose storage missionwould be opposed due to the potential conflict of other diversificationinitiatives.


DOE believes the interim storage alternatives covered under the PantexEIS are a reasonable management course for plutonium in pit form. In addition,see discussion in section 1.3.1 in this volume, regarding the site selectionprocess, and section 1.3.2 regarding the relationship between S&D PEIS andPantex Plant EIS.

RC: 02.014

Doc: PC-024/5

Page S-10, right column, "Related National Environmental Policy ActStudies" The Pantex FEIS should reflect delays in other EIS such as the SS&MPEIS and the NTS EIS.


The purpose of the summary is to inform the public that several NEPAdocuments, including SSM PEIS and NTS EIS, are ongoing and could have impacts atPantex Plant. The schedule of decisions in those documents does not impact theassessments contained in the Pantex Plant EIS. Cumulative impacts related tochanges in Pantex Plant operations from decisions resulting from the SSM PEIS,the S&D PEIS, and the WM PEIS are presented in the Pantex Plant EIS.

RC: 02.015

Doc: PC-024/6

Page S-13, left column, boldface. The title and the DOE control number forthe NTS EIS should be corrected to reflect changes that were made over sixmonths ago.


The section has been corrected.

RC: 02.016

Doc: PC-024/7

Page S-13, right column last three lines. This statement should indicatemore than the existing waste connection. It should mention the proposals tostore plutonium-239 pits there.


Consideration of interim storage and long-term storage of pits is notwithin the scope of the NTS Site-Wide EIS. See discussion in section 1.3.2, inthis volume.

RC: 02.017

Doc: PC-024/11

Page 5.6, left column, 3rd paragraph. It mentions that "[t]he P-Tunnelis also being proposed for the long-term storage and disposition ofweapons-usable fissile materials." The folks at the NTS are trying to sellthe use of limited tunnel space for two different purposes at the same time. Itis unlikely that it will be used for both purposes and therefore the competingEIS purposes need to be addressed.


One of the alternatives in the S&D PEIS is long-term storage anddisposition of weapons-usable fissile material in the P-Tunnel at NTS. The20,000 pits that are addressed for interim storage in the Pantex Plant EIS arepart of the inventory of weapons-usable fissile material in the S&D PEIS. Selection of P-Tunnel for interim storage of pits and long-term storage ofweapons-usable fissile material would not be using limited tunnel space for twodifferent purposes, but rather for the same purpose.

RC: 02.018

Doc: CO-006/2

In the Draft S&D PEIS, DOE characterizes Pantex as having the "greatestpotential" to experience adverse cumulative impacts from an increased rolein plutonium storage and disposition.... These conclusions also totallycontradict those contained in the SWEIS which characterize the impacts as "minimal"and "negligible." It is imperative that DOE correct the inaccuratemischaracterizations before making its final decisions for plutonium storage anddisposition missions.


Environmental impacts associated with interim storage of pits are withinthe scope of the Pantex Plant EIS. Environmental impacts associated with longterm storage and disposition are within the scope of the S&D PEIS. Theanalyses presented in the two EISs are both correct since disposition wouldintroduce plutonium processing not currently done at Pantex.

RC: 02.019

Doc: HT16/7

I really would like to understand why you [have] all...those cumulativeimpacts in here like you have, for instance, 4-239, where youretalking about the Storage and Disposition PEIS. And the last sentence in thereis: All doses would be within radiological limits and well below levels ofnatural background radiation, et cetera.... This document has consistentlyreferred back to the three PEISs and made...statements about impacts that itdoesnt seem to me [that] this document has the information to do. Can you...talkto me a little bit about that? It [the EIS] gives the impression youre makingsolid judgments that I dont think the information is sufficient to do.


The Pantex Plant EIS has detailed information on the impacts ofcontinued operations at Pantex Plant. Each PEIS has detailed information aboutthe impacts of its subject programs. The cumulative impact sections in thePantex EIS incorporates the information from the PEISs by reference and presentsthe total cumulative impact. Incorporating information by reference is part ofthe NEPA analysis process. The "Cumulative Impacts" sections of thisEIS address to the extent possible information relevant to Pantex Plant. Fordetailed discussions of environmental impacts evaluated in the other PEISs, thecommentor is referred to those documents.

RC: 02.020

Doc: HT16/9

The second issue I raise, though, is, for a number of the types ofoperations that are being talked about for the futureplutonium conversionfacilities, plutonium processing facilities, MOX fuel facilities, a newrevolutionary [evolutionary] light water reactorthere really [is] no history. There [is] no good history to go on in terms [of] what the actual releases are. So youre basing your analysis on what the current or assumed regulatory levelsare going to be, [not] on, in fact, historic performance. And so the point isthat you should be quite clear about that, which I think, in some cases, itsreally not. For example, on page 4-239 that Ms. Gattis just mentioned to you, Ithink it would be very helpful if you would just say, in terms of some of thesefacilities, there isnt historic data to base it on, so we are basing ouranalysis on these plants [that] are assumed to operate within the applicableregulatory limits.


See response to comment 02.019.

RC: 02.021

Doc: HT17/24

I would much prefer to see the Nevada Test Site deal with that particularmaterial [plutonium] as the last residue of a very difficult part of thiscountrys history and one [that] we are better off dispensing with, notcontinuing into the future.


See discussion in section 1.3.2 in this volume, regarding siteattributes.

RC: 02.022

Doc: HT17/27

Hearing tonight about transferring plutonium processing from Rocky Flats,which was judged by a DOE report the site most likely to constitute a threat tohuman life, a nine on a scale of ten, followed closely by Pantex, which was aneight on a scale of ten, gives me some pause for thought. Both of those siteswere rated ahead as threats to human life over the notoriously contaminatedHanford complex.


See response to comment 02.001, regarding hazardous materials.

RC: 02.023

Doc: HT17/46

...I appreciate the fact that some of the things that I mentioned may becovered in other documents, but I believe that this study itself has to dealwith those things. It will be making some of those decisions in the fact thatit does include those other documents, and I feel like it has inadvertently leftout some of those issues, and that needs to be more carefully addressed.


See response to comment 02.019.

RC: 02.024

Doc: HT17/72

...if the nuclear waste that is at such places such as Rocky Flats and thathas been refused by governors of other states is to be...brought down here, Iassume there will be the same problems as there are at other places, and itprobably just needs to be looked at a little bit more carefully.


The WM PEIS addresses DOE programmatic waste management issues andalternatives. In addition, see response to comment 02.001 regarding hazardousmaterials.

RC: 02.025

Doc: PC-017/12

Page 4-82 states that pit reuse is not a current activity at Pantex Plant. Can you assure us that the reuse will never become an activity at Pantex? Isreprocessing, MOX, or other potential pit activities ever to be an activity atPantex? If so, should not those issues be considered and studies on theireffects on health and safety for workers, neighbors, and agricultural workers,the potential contamination of our water, air, and agricultural activities andproducts be addressed before the future at Pantex is determined?


Noninvasive activities connected with pit reuse are part of the ProposedAction. See the discussion in section 1.3.2 in this volume, for furtherdiscussion of the plutonium activities addressed in the S&D PEIS.

RC: 02.026

Doc: SG-012/9

One alternative considered in the DEIS could have been placing plutonium ina permanent disposal, deleting interim storage (especially at Manzano WSA) as analternative.


See discussion in section 1.3.2 in this volume, regarding S&D PEIS. In addition, see response to comment 02.001 regarding site selection.

RC: 02.027

Doc: MG-002/4

For example, the Stockpile Stewardship and Management PEIS includes analternative which describes the complete closing of the Pantex Plant with itscapabilities relocated to NTS, Los Alamos and Lawrence Livermore facilities. ThePantex EIS does not address the implications of this alternative. This issueshould be addressed in the final EIS and the Record of Decision.


See discussion in section 1.3.2 in this volume, regarding SSM PEIS.

RC: 02.028

Doc: SG-003/11

In the Summary, page S-11, right column, the discussion on StockpileStewardship and Management Draft PEIS omits the "Downsize Pantex withtransfer of HE Operations" option briefed as a preferred alternative at theApril 22-23, 1996 meetings. The Stockpile Management Preferred AlternativesReport, pages l7 through 20 discusses fiscal impacts related to the transfer ofHE operations for fiscal years l996 through 2020. If this issue is anticipatedto impact the Texas Panhandle during the tenure of the Pantex SWEIS, the effectof transporting a large number of HE components over the roadways needs to beincluded.


See discussion in section 1.3.2 in this volume, regarding the SSM PEIS.

RC: 02.029

Doc: SG-003/12

In the Summary, page S-12, right column, the Light Water Reactor dispositionalternative from the Storage and Disposition of Weapons-Usable Fissile MaterialsPEIS has not been removed, although it was indicated in the April meetings thatthe [Light Water Reactor] (LWR) was no longer being considered for Pantex. Thisissue requires clarification.


Final disposition of plutonium alternatives are within the scope of theS&D PEIS. Since the Record of Decision on this PEIS has not yet beenannounced, LWR continues to be discussed in the cumulative impact section ofthis EIS.

RC: 02.030

Doc: SG-010/1

In reference to interim storage of plutonium pits at Pantex, Nevadasposition on this issue continues to be that DOE should adopt a proposed actionfor the permanent disposition of surplus plutonium pits before selecting newinterim or long-term storage sites for this long-lived material. In addition,to reduce duplication in storage, transportation, and security costs and toaddress risks associated with the proliferation of weapons-grade plutonium, DOEshould consider adopting a program that combines materials disposition (e.g.,plutonium vitrification) with long-term plutonium storage.

Implementing the Proposed Action as defined in the DEIS would enhance such aprogram; it would also help prevent redundant shipping campaigns of plutoniumbearing material on public roads and highways. This is important sinceexcessive transportation of plutonium on public roads remains controversial andis generally unacceptable to the public. For all of these reasons, officials inNevada have long stated that "DOE should link long-term materialsconsolidation and management with options for final materials disposition."


A description of the transportation of pits and the expected increase inrisk is presented in volume I, section 4.16.

RC: 02.031

Doc: SG-010/4

As previously suggested, State officials in Nevada believe that DOE shouldlink long-term fissile materials consolidation and storage with options forfinal materials disposition, and we believe the proposed action presented in theDraft EIS for Pantex supports this concept. As such, we continue to advocate astrategy that would bring together long-term pit storage with one or more of theplutonium disposition treatment options being considered in DOEs Storage andDisposition PEIS.


See discussion in section 1.3.2 in this volume, regarding S&D PEIS.

RC: 02.032

Doc: PC-030/1

While I am reasonably comfortable with interim storage of plutonium pits, Ibelieve that facilities for long-term storage should not be constructed atPantex or any other site when there is already an adequate facility at theManzano Weapons Storage Facility at Kirtland AFB in Albuquerque.


See discussion in section 1.3.2 in this volume, regarding S&D PEIS.

3.3 Facilities and Infrastructure

RC: 03.001

Doc: HT13/3

The document [page 5-55] also says that construction began June, 47, andbecame operational in April of 50, so that would essentially say that thebunkers we are talking about are more than 45 years old. My specific questionis, what is the design life of those bunkers?


Design life is a construction criteria specification rather than anoperational capability criteria. More appropriately, the remaining life cyclesof the bunkers, like those magazines currently at Pantex, are typically greaterthan 30 years. Design life of facilities can be extended with routinemaintenance. The Nuclear Weapons Council Staff, using DOE Site Screeningcriteria, determined the degree of construction required to adapt existingManzano facilities for the pit storage mission as feasible. Although Manzano isnot the preferred alternative, if selected and prior to the operation of pitstorage activities, DOE would complete a Safety Analysis Report and OperationReadiness Review to further document the safety of the facilities.

RC: 03.002

Doc: HT13/5

... The design question is an important one, I think, from a variety ofstandpoints. So my request would be that we get some more detailed design andengineering analysis of the bunkers in terms of design life, design capability. The major had said some of them [the bunkers] need to be upgraded. It seems tome we need to have more specific information on those things.

I didnt see any references in the document that give me that kind of detail,so if I have missed it, Id like somebody to tell me if there is a document thatdescribes it. Id like to know what it is. If there isnt a document thatdescribes it, Id like to know how that information is going to be presented.


See response to comment 03.001. During the selection process, asdiscussed in volume I, section 3.1.4, several of the magazines at Manzano werevisually inspected and found to require only very minor work, such asadjustments or replacement of doors. The great majority of any upgrades thatwould be needed to use the Manzano Weapons Storage Area is actually not to themagazines themselves, but to reactivate the security fence sensor system. Whilethe fence itself is intact, the computer and sensors used to detect intrusionwould need upgrades. The selection process documentation is available uponrequest.

RC: 03.003

Doc: HT12/20

Does Pantex conduct a plutonium storage operation in facilities that areconsidered to be nuclear facilities, rated nuclear facilities, and...thatconform to the DOE orders for nuclear facilities 6431A, for instance?


Yes, pit storage magazines are defined as Category 2 "non reactornuclear facility" in appropriate DOE standards. In addition, see responseto comment 01.019.

RC: 03.004

Doc: PC-024/9

P. 5-3, left column, last line. The Final Pantex EIS should clearly explainthe real reasons for the existence of the DAF and the P-Tunnel complex. The$100 million Device Assembly Facility was designed and constructed inanticipation of an expanded nuclear explosive testing program at the [NevadaTest Site (NTS)]. It was intended to be the assembly point for the nuclearexplosive devices. Since our nuclear test moratorium went into effect in 1992,its primary mission ended about 3.5 years before it was completed. It is nowbeing used to assemble nuclear and nonnuclear devices which involve largeamounts of high-explosives. The Pantex DEIS does not address any compatibilityproblems associated with pit storage and high-explosive assembly work at theDAF.


The selection of site alternatives for interim pit storage wasaccomplished by developing site suitability criteria, applying the criteria tocandidate sites, and determining the best sites to represent the range ofreasonable site alternatives. The selection of site alternatives is discussedin volume I, chapter 3. The Pantex Plant has been identified as the preferredalternative.

Volume I, section 5.2 discusses the DAFs original mission and notes thedesign of the DAF was based on the Pantex Plant designs for nuclear explosiveoperations. The original design of the DAF includes both nuclear explosiveoperation and a pit storage capability.

The current mission of the DAF is to maintain readiness to resumenuclear testing, if required, for national security. Only a portion of the DAFwill be dedicated to that mission. The remainder could be made available forstorage of up to 8,000 pits. Long term nuclear explosive contingency operationsand NTS alternatives are within the scope of the SSM PEIS.

Volume I, section 5.2 also discusses the P-Tunnels original mission anddesign.

RC: 03.005

Doc: PC-024/10

The P-Tunnel complex was constructed for the Defense Nuclear Agencys (DNA)nuclear explosive test program which also ended in 1992. The tunnel complex wasan alternate, and often much more expensive, way of performing undergroundnuclear explosion tests. Cost per test were often in the range of many tens ofmillions of dollars. Several DNA nuclear explosives test were conducted in thistunnel complex. Page 5-7, Figure 5.2.3.--Layout of P-Tunnel at the Nevada TestSite., contains a drawing of the existing complex. This map drawing shouldpoint out the locations and names of the nuclear test waste cavities. This, ora updated version of this map, should indicate where, in the vast tunnelcomplex, the proposed pit storage would take place. The Pantex DEIS makes nomention of where, in the many miles of tunnels, the pits might be stored, TheNEPA FEIS should provide such information.

The DNAs nuclear explosive program has been suspended.

The side tunnels used for previous nuclear tests are all permanentlysealed off. Disclosure of their location on the map is not necessary since theywould not have any effect upon pit storage (in the main tunnel) or on the StageRight equipment and operators. For pit storage, P-Tunnel would require minimalfacility upgrades (primarily the installation of guide rails for a Stage Rightforklift). The P-Tunnel alternative is well suited for the Stage Rightequipment and techniques successfully implemented at Pantex.

In addition, see response to comment 03.004.

RC: 03.006

Doc: PC-023/5

I hope that the Department of Energy has thoroughly inspected buildings onsite [that] have been subjected to such energy from explosive testing over manyyears of Pantex Plant operations. Structural integrity of Pantex Plantfacilities, especially storage locations for plutonium pits, is extremelyimportant to the safety of Pantex employees and area residents.


Volume I, section 4.3 discusses and analyzes environmental impactalternatives on plant facilities and infrastructure. Pantex Plant annuallypublishes a Capital Assets Management Process Report which includes rating eachfacilitys condition and remaining lifecycle. Pantex Plant facilities andinfrastructure are subject to numerous internal and external audits,inspections, reviews, and surveys on an annual basis. DOE understands and iscommitted to the safety of Pantex employees and area residents.

RC: 03.007

Doc: HT17/64

... In looking at what the range of activities would be to even continue onwith those current missions that are outlined for the next ten years, I reallydont think that in that period of time you would think that you wouldnt need todo a number of other upgrades and changes in your facilities besides the sixthat are specifically mentioned in this document. And I think you need to do amuch better job of analyzing...the age of buildings...[if] youre going to keepgoing with continuing operations over a ten-year period of time that you saythat this document covers.


DOE considers sitewide NEPA documentation to be living documentsrequiring periodic review and updates as appropriate. Tiered NEPA documents mayalso be needed. DOE has an established NEPA program to handle issues regardingroutine upgrades and maintenance of DOE facilities. Since 1990 Pantex Plant,has initiated 354 environmental checklists and NEPA related documents. 206 ofthe 354 were identified as upgrades, repairs, improvements, and maintenancerelated activities. Additional language has been added to volume I, section4.3.1.

Most projects for upgrades, repairs, improvements, and maintenance arerelatively small in size and scope and do not require performance of anEnvironmental Assessment or EIS. Larger projects, such as the six evaluated inthis EIS must proceed to the conceptual design phase before sufficientinformation is available for adequate analysis. The six facilities evaluated inthis EIS, represent the only foreseeable major projects that currently havesufficient maturity of conceptual design to allow assessment of environmentalimpacts.

RC: 03.008

Doc: PC-025/3

Why is infrastructure included in environmental impacts and as an additionalconsideration? Like my comments on SSM and S&D, if national security andnonproliferation [are] so important, why arent the environmental impactsdiscussed in the infrastructure section as a capability, assets, problem, this document?... Does Pantex out perform its alternative sites on theseissues? If so, the decision maker needs to know to make a reasonably informeddecision.... Why isnt security capabilities addressed in infrastructure impactanalysis so impacts can be reviewed and decide a true course of action? DOEshould consider redoing infrastructure analysis to include security relatedenvironmental impacts.


In determining reasonable relocation alternative sites, as discussed involume I, section 3.1.4, the DOE Site Screening Committee and the NuclearWeapons Council Staff screening methodology included assessment of the degree ofconstruction required and the degree of isolation. Thus, the securitycapabilities were assessed. Current Pantex pit storage operations were used asa baseline for comparison purposes. Security and nonproliferation activitiesare part of routine activities performed by Pantex Plant. All sites consideredas alternatives would be capable of securely and safely storing pits.

Volume I, sections 4.3.2, 5.2, 5.3, 5.4, and 5.5 discuss and analyzealternative site facilities and infrastructure including security assets (e.g.,material access control) in the EIS.

For clarification, the phrase "... national security, andinfrastructure." has been changed to "... national security, and sitespecific factors (e.g., local and political support, intellectual and technicalcompetencies).

An expanded discussion of the Pantex Plant Safeguards and SecurityProgram is available in the Pantex Plant Programmatic Information Document(Pantex 1996).

RC: 03.009

Doc: PC-025/12

On Page 4-11. What level of security is the burning ground, zone 10, andfiring sites under? The nonshaded area of DOE owned property is under what levelof security? The DOE leased property shading is not found in the legendwhatlevel of security is this?


DOE cannot disclose levels of security involving nuclear weapons sitesor facilities.

RC: 03.010

Doc: PC-025/13

Page 4-16. Should it be waste management activities utilities?


Yes, the word utility has been made plural.

RC: 03.011

Doc: PC-025/14

Page 4-18. Why Pit Storage Activity? Section 4.4, 4.5, etc. use Activities.In Waste Management Activities. Why no discussion about RCRA Closures?


The section title has been changed to "Pit Storage Activities."RCRA Closures are included in volume I, section, EnvironmentalRestoration.

RC: 03.012

Doc: PC-025/15

Page 4-18. Why Environmental Management? Section 4.4, 4.5, etc. call itEnvironmental Restoration?


The title and introductory sentence have been changed to read "EnvironmentalRestoration" to be parallel with sections 4.4 and 4.5 of volume I.

RC: 03.013

Doc: PC-025/16

Page 4-16 uses Environmental Restoration. Should page 4-18 include closures,page 4-16 does.


See response to comment 03.012. The text on page 4-18 of volume I ofthe Draft EIS states that the impacts are the same as those described on page4-16. No change was made to the EIS.

RC: 03.014

Doc: PC-025/17

General comment in section 4.3. ...Why isnt more presented aboutnonproliferation and sanitization and demilitarization in this section? Pleaseinclude environmental impact analysis of these issues in the infrastructuresection based on methodology definition on page 4-3 as a support requirement andSSM & S&D emphasis to the issues. How are nonproliferation andsanitization and demilitarization infrastructure effected by the varying levelsof activities as required by methodology on page A-l? Is there a backlog? Whatare the environmental impacts?


The environmental impacts from sanitization and demilitarizationoperations have been incorporated into impacts addressed in Air Quality andWaste management. Sanitization and demilitarization operations of highexplosives at the Burning Ground are included in the air quality modeling. Solid wastes generated in the sanitization and demilitarization of weaponcomponents are included in the waste volume projections for the three levels ofweapon activities. To account for fluctuations in waste generation rates a 10%margin was used in the analysis.

RC: 03.015

Doc: PC-028/10

Page 5-58, para. The recommendation to utilize the Manzano WSAfacilities ignores a very real condition. The Manzano WSA was built in the mid40s to 50s. Much of the facilities have not been improved over the years. Themajor plants have water leakage problems along with the storage magazines. Theelectrical system is outdated and has chronic problems, the fence securitysystem and fence are in need of major repair and upgrade. The facilitiesinfrastructure, except for the Phillips Lab R&D facility at Manzano, [has]been economically neglected and this is why Manzano WSA is not being utilized athistorical or design levels. There will be significant cost, overlooked in theDraft EIS, in putting a pit storage area on KAFB.


The conditions described apply to Plants 1 and 2 and their associatedtunnels which would not be used for pit storage. The magazines that would beused for pit storage are not connected to those problem facilities and are, infact, in excellent condition. See response to comment 03.002 regarding theupgrade to the fence.

3.4 Land Resources

RC: 04.001

Doc: HT02-08/3

There is again no consideration of the most basic industry of the Panhandle,agriculture.


The EIS has been revised to expand the discussion on agriculture insections 4.4, 4.5, 4.6, 4.9 and 4.11 in volume I of this EIS. Additionalinformation on these sections is provided in the Land Resources section of thePantex Plants Environmental Information Document (Pantex 1996). The proposedaction is not expected to adversely impact the agricultural industry of thePanhandle.

RC: 04.002

Doc: CO-008/36

Page 4-40, Paragraph 1, "By virtue of 30 TAC 335.557 (3), the futureland use designated at Pantex Plant is nonresidential." How are currentagricultural activities on DOE owned land classified?


DOE owns approximately 2,596 hectares (6,421 acres) of land currentlyused for agricultural purposes within the combined Main Plant and Pantex Lakeareas. These areas are managed by Texas Tech University (TTU) through a servicelease agreement with DOE. TTU in turn subleases to local farmers. These localfarmers can produce crops or raise cattle. Agricultural activities on DOEproperty can be limited to the extent necessary to meet Pantex Plant missionneeds.

The classification of future land use is a process related to theenvironmental restoration process as it relates to clean-up levels. Thiscomment specifically addresses the soil and sediment quality at solid wastemanagement units on Pantex Plant, as discussed in volume I, section ofthis EIS. Neither RCRA nor CERCLA govern agricultural activities at PantexPlant. However, both RCRA and CERCLA drive environmental restoration activitieson DOE property. Both have provisions to protect natural resources at PantexPlant.

RC: 04.003

Doc: HT12/3

Today at SRS we have a good future use plan. I am concerned that all of theother sites might not have a similar plan. Our SRS future use plan is an effortto ...maintain the largest national wildlife research area in America. I hopethe undeveloped areas at all of the sites have that same protection for theirwildlife. With SRSs future use plan, all future development is restricted toonly areas that have had prior development. No undisturbed areas are to bedeveloped.

I wish that DOE would make this a DOE-wide policy. I know how developersprefer to build on undeveloped land and are reluctant to take land previouslyused and reclaim it for new development. Future development on all DOE sitesstart the trend in America to build new on old abandoned sites.


The DOE Land and Facility Use Planning process (DOE P 430.1) outlinesfuture site development and reuse based on the shared long-term goals of theDepartment, the sites, and the stakeholders. Pantex Plant has a Multiple-UseLand Plan which addresses continued land-applied chemical use and grazing insensitive areas of the Plant as well as a Site Development Plan (DOE 1995j)which addresses the present and future framework for site operations. Four ofthe playa lakes at the Pantex Plant Site and Pantex Lake have been designated aswetlands. These areas are intended to protect and/or ensure surface waterquality and allow compliance with applicable air, water, and other naturalresources quality requirements, as well as protecting historical andarchaeological sites and ecological resources. The facility construction andmodifications presented in the Proposed Action alternative all occur onpreviously disturbed areas within Zones 11 and 12.

RC: 04.004

Doc: HT12/5

This has to do with the future use of SRS. the way, I just wrote abook on environmental uses of the Savannah River Site.... So Ive done a littleresearch, its just not off of the top of the head sort of thing. But what Iwant you all to keep in mind is that if we look at a primary use which isindustrial,...nuclear or non-nuclear, you can do a lot of things using the landuse concept and multiple use, okay? Youve got the primary use right here [that]would be the project that you all are talking about now. And as you go out fromthis primary area the protection increases.

Are you all aware of this Land-Use Baseline Report that was put out? Well,I want to submit that for you all to look at and read, okay. ...Its a synopsisof what the attributes of the Site are.


The potential interim storage of pits at Savannah River Site (SRS) is inaccordance with the Land Use plans at the site. DOE has reviewed and consideredthe Land Use Baseline Report in evaluating the impacts.

RC: 04.005

Doc: HT12/37

Savannah River can take these projects and it wont affect the environment. As a matter of fact, if you use a careful planning you can take these projects,put them in the core, weve got 310 square miles, put them in the core and evenincrease environmental activities in these four or five areas. Does that help?


The Pantex EIS concluded that use of this federal facility will notaffect current missions at SRS, nor will it affect the multiple environmentaluses of the site.

RC: 04.006

Doc: PC-024/8

Page 5-3, left column, "The Nevada Test Site," 3rd line. Changethe word "owns" to "operates". Change 350,000-hectare to322,195-hectare and change 864,000-acres to 796,160-acresthe later values arethe legal values.


Text and land area in section 5.2 have been changed in the final EISwith data from the Draft Environmental Impact Statement for the Nevada Test Siteand Off-site Locations in the State of Nevada (DOE 1996c). We now state thatNTS encompasses approximately 3,500 square kilometers (1,350 square miles) ofland area reserved to the jurisdiction of the DOE.

RC: 04.007

Doc: PC-024/16

And finally, I should mention that all the maps of the Nevada Test Site,that are presented in this document, need to be corrected before the FinalPantex EIS is issued. The maps should show the block of land that was withdrawnunder Public Land Order 1662, that was to be used in connection with the NTS(23FR 4700). A proper map of the test site can be found on page 4-10 of the "DraftEnvironmental Impact Statement for the Nevada Test Site and Off-site Locationsin the State of Nevada," January 1996 (DOE/EIS 0243).


The NTS maps have been corrected to include the block of land withdrawnunder Public Land Order 1662.

RC: 04.008

Doc: HT17/42

The tremendous growth of agribusiness, especially the fed beef industry andbeef processing industry in the Texas Panhandle, has occurred during the timespan that Pantex has been operating. I think thats pretty good evidence thatagribusiness and Pantex can coexist successfully on both counts. I think itsreally unfair to couch things as being either pro Pantex or pro agriculture,because they farm onsite at Pantex, they farm around Pantex, theres no problemwith the crops that are raised there, and people need to look at the bigpicture.


This EIS is being prepared in response to the National EnvironmentalPolicy Act, which requires a thorough assessment of any Federal undertaking thatmay significantly impact the environment, the populace and the local area. Serious consideration is given to existing and potential impacts to all areas,including agriculture, prior to making a decision on a proposed action. This isa method of looking at the "big picture" through documented, andcomparative, research and analysis.

RC: 04.009

Doc: HT17/45 was very distressful to [me] and other people that had noticed thatfarming and agriculture, as important as it is, was basically ignored in a lotof these documents or barely mentioned, possibly four paragraphs, a little over,in this document that I noticed.


Agriculture is discussed in volume I, sections 4.4, 4.5, 4.6, 4.9 and4.11 of this EIS. These sections have been updated with additional informationconcerning the regions agricultural base.

RC: 04.010

Doc: PC-025/18

... Is Pantex zoned for agriculture, ranching, water utility, irrigation,treatment, disposal, industrial, residential...? Please analyze the aboveoperations for zoning compatibility including this example: If the plant is notzoned for residential use, does the fire department qualify as residential?


Zoning is characteristically done in municipalities. Pantex is notinside the boundaries of a municipality. The Pantex Plant is not a residentialarea. The Plant has a fully staffed fire department located in Zone 12 North. See discussion in section 1.3.3 in this volume.

RC: 04.011

Doc: PC-025/19

On page 4-22. Recommend detailing the location of schools and elderlymeeting places including elderly care facilities. It seems to me children andelderly are sensitive areas.


Because the impacts to the baseline population as a whole are so minute,looking at individual populations is not warranted. However, the 134 primaryand secondary schools and the 6 institutions for higher education in the regionof influence together with the 27 nursing/convalescent homes in the 9 countyregion have been included in section in volume I.

RC: 04.012

Doc: PC-025/90

Land Resources assessment methodology is flawed because it does not assessdecontamination and decommissioning programs, as stated. There is a flaw sinceno zoning analysis exists in the analysis to prove or disprove incompatibility. [Where] is an analysis of the Deed?


At this time no plans have been finalized for the decommissioning of anyfacilities at Pantex Plant. The designation of facilities is pending decisionsregarding the future of Pantex Plant being made in the SSM PEIS. Legaldocuments concerning land rights were examined and are mentioned in volume I,the summary, chapter 1 and section 4.4.

RC: 04.013

Doc: CO-008/37

Agricultural activities are one aspect of the Pantex Plant. Theseagricultural operations impact Pantex Plants natural resources [considerably]and yet have received only cursory mention in various sections in the [EIS]. Because agricultural activities have not been detailed in the document as acontinuing operation of Pantex, are agricultural activities not to continue onthe publics Federal land, or has the public subtly been denied the opportunityto comment on this use?


DOE owns approximately 2,596 hectares (6,421 acres) of land currentlyused for agricultural purposes within the combined Main Plant and Pantex Lakeareas. These areas are managed by Texas Tech University (TTU) through a servicelease agreement with DOE. TTU in turn subleases to local farmers. These localfarmers can produce crops or raise cattle. Agricultural activities on DOEproperty can be limited to the extent necessary to meet Pantex Plant missionneeds. However, at this time there is no documentation that suggests thatagricultural activities on Pantex Plant will be discontinued. For the impact ofthis agriculture to soils at Pantex see volume II, appendix I. For impacts towater usage see the discussion in volume I, section

RC: 04.014

Doc: PC-027/5

Before planning to use the Manzano area as a "pit storage" site,coordinate with the base tenants to include Phillips Laboratory. The Manzanoarea is used for some research and development which may or may not becompatible with the your proposed nuclear pit storage.


The tenants that will be affected by the interim storage of pits at theManzano WSA have been considered throughout the EIS process (refer to volume I,section 5.5). Further coordination with these tenants will be initiated ifinterim storage at this facility is chosen in the Record of Decision. See alsoresponse to comment 04.015.

RC: 04.015

Doc: PC-028/3

Page 5-58, 2nd column, para The statement that Manzano WSA iscurrently being used, in part, [to store] furniture and documents is entirelymisleading. Phillips Lab has a major R&D operation in the WSA. Theaddition of a pit storage facility will have a major impact on access to R&Doperations and dramatically change the security posture within WSA.


The discussion cited focused only on the current uses of the magazinesthat would be potential locations for pit storage. There are other facilitiesin Manzano WSA, as the commentor states, but those facilities would not be usedfor or affected by pit storage.

RC: 04.016

Doc: SG-010/3

In an unrelated issue, we note that the Nevada Test Site is described in theDEIS as a "government owned, contractor-operated facility, currentlymanaged by Bechtel Nevada [and] DOE owns the 864,000 acre site in Nye County,Nevada." This statement is incorrect. DOE does not "own" theNevada Test Site. The Test Site occupies public lands that have been withdrawnfor nuclear testing purposes only. The Final EIS for Pantex must acknowledgethat the Public Land Orders for the Test Site do, in fact, limit the use of thesite to weapons testing and related research and development facilities only. Moreover, when the Nevada Legislature ceded its jurisdiction to the public landsthat now comprise the site, it did so on the basis of certain stipulated uses(i.e., nuclear testing) as defined in the Public Land Orders. Thus, while manybelieve the lands comprising the Nevada Test Site are federal lands, they are infact public lands that have been withdrawn for a specific national defensepurpose, and that purpose does not include long-term storage of fissilematerials, [nor] development of any major disposition technologies such asplutonium immobilization.


The suggested change was incorporated into volume I, section 5.2.

RC: 04.017

Doc: CO-005/2

In analyzing impacts in this document, the most important issue has to bethe region in which the Pantex Plant is located. With the mission of Pantex andrelated activities being conducted in the heart of production agriculture andthe beginning of the food chain, the presumption that these activities do notimpact agriculture must be fully assessed.


See response to comment 04.009.

RC: 04.018

Doc: PC-033/6

I would suggest that the DOE investigate this area further and include morein depth information in the final [EIS], (i.e., land devaluation in theimmediate vicinity of the Pantex Plant, comparing past land values to currentvalues and then future approximate values if various facilities/functions arelocated here; land use or crop restrictions; monitoring information of theoffsite vegetation and soils; and possible additional land userequirements/acquirements for various facilities if located here). I haveenclosed a DOE generated land use map of the Pantex Plant for your reference.


NEPA does not require, nor is it customary for NEPA documents to includemarket analyses. The land use associated with the new facilities proposed inthis EIS are discussed in volume I, section 4.4. Additional information aboutagriculture in the region has been added to this and other sections. Information from soil monitoring activities can be found in volume I, section4.5. Land use requirements/acquirements for future Pantex Plant facilities areperformed as-needed when projects or facilities are projected.

3.5 Geology and Soils

RC: 05.001

Doc: CO-008/32

Pages 4-38 and 4-39. These pages show that soil quality in many sites hasbeen affected. How much soil has been affected? For example, table,page 4-38, lists 37 sites that have been affected by "burning ground." What is the size of each of these sites?


Details about each site at Pantex Plant are not included in the EIS. Each grouping of sites is described in general. The decisions being evaluatedin this EIS neither affect nor are affected by the environmental restorationprogram that is addressing the contamination at these sites. The RCRA FacilityInvestigation (RFI) reports that are being drafted concerning these sites willinclude tremendous detail concerning these sites. These reports will beavailable to the public after approval by TNRCC. The amount of detail requestedby the commentor is inappropriate to include in the EIS for each group of sites. The information is provided below in response to the comment but will not beincluded in the main text.

The Burning Ground Assessment includes the Burn Pads (SWMUs 14-27), theBurn Trays (SWMUs 28-36), Landfills (SWMUs 37-44), the Burn Cages (SWMUs 45-46),the Solvent Pit (SWMU 47), the Solvent Pans (SWMUs 48-51), the Burn Rack, andFlashing Pits (SWMU 52). The individual Burn Pads were constructed of a 1-footthick clay layer over an approximate 15 by 15 feet area, and are approximately75 feet apart. The Burn Trays are approximately 75 feet long by 10 feet wide by1 foot deep, and are raised 2 feet above the ground. The landfills associatedwith the Burning Ground exist as cells, and are approximately 100 to 200 feetlong by 20 to 30 feet wide and range from 6 to 23 feet deep. Per the RFI,report the estimated volume of soils that have constituents above the decisioncriteria set forth for Risk Reduction Standard 2 is approximately 86,000 cubicyards. (Risk Reduction Standard 2 requires removal and/or decontamination ofall waste, waste residues, leachate, and contaminated media to standards andcriteria such that any substantial present or future threat to the human healthor environment is eliminated.) The area of soils around the Burn Pads, BurnCages, and Burn Racks with the constituents potentially above the decisioncriteria was defined by a 40 feet radius. The distribution of contaminantspresent at the Burning Ground vary to depths greater than 20 feet below groundsurface.

RC: 05.002

Doc: CO-008/33

Page 4-41, Paragraph 2. This paragraph states that the soil had beencontaminated to a depth of 20 feet. It would be very useful for the report toindicate, if the information is available, how the amounts of contamination arechanging with time. For example, the amount at 20 feet may be increasing ifdownward movement from the surface is occurring, or it may be decreasing ifdegradation is occurring. What are the trends?


Given the environmental conditions and chemical factors at the BurningGround, the amount of infiltration, and the sorption capabilities of thecontaminants of potential concern (COPCs) and their degradation products,vertical migration of the COPCs in soils and sediments identified at the BurningGround can be expected to be limited. It is unlikely that COPCs will migratelaterally or vertically much farther than the current extent. With recharge upto 3.24 in/yr possible below playas, from an annual precipitation of 19.1 inchesnear Amarillo, RDX would travel approximately 27 feet per 100 years. Consideringthe above playa infiltration rate exceeds the higher-ground recharge rate,migration could be expected to be even less in nonplaya areas. Biodegradationwill lessen transport of the organic COPCs as well. Present conditions affirmthe fact that contaminants have not typically traveled more than 10 or 20 feetfrom their source, and they have had up to 45 years to migrate.

RC: 05.003

Doc: CO-008/34

Page 4-41, Paragraph 2. There was no mention of soil remediation processes. Please describe the number of processes that have been undertaken, or planned,for soil remediation that could be used to enhance the natural degradationprocesses of the contaminants present in the soil. Although extensivemonitoring has occurred there seems to be a minimum number of restorationstudies.


The environmental restoration process at Pantex Plant is still mostly inthe investigation phase. Subsequent to this phase would be the remediationphase. Currently, potential remediation activities are being developed andrecommended to TNRCC, which has the approval authority.

RC: 05.004

Doc: CO-008/35

Page 4-29, Paragraph 1. Please provide a citation for "CaprockCaliche."


The citation to the reference (Pantex 1996) has been added to volume I,section 4.5.1.

RC: 05.005

Doc: CO-008/71

Page 4-37, Paragraph 2. The letters from EPA and TNRCC documenting theirapproval for the RCRA methodology undertaken by Pantex Plant should be cited.


The approval of the methodology is through the issuance of the hazardouswaste permit. This language has been incorporated into volume I, section 4.5.

RC: 05.006

Doc: CO-008/72

Page 4-41, Paragraph 2. Please correct typographical error, next to lastsentence: "Phase II characterization data is (are)..."


Correction has been made.

RC: 05.007

Doc: CO-008/73

Page 4-42, Paragraph 3. "The OSTP received waste water from AmarilloAir Force Base and Pantex Plant." Did it also receive waste water fromBell helicopter and the Amarillo Airport?


The Old Sewage Treatment Plant (OSTP) did receive wastewater from bothBell Helicopter and the Amarillo Airport. The sewer pipeline was then cut sothat effluent from the Amarillo Airbase complex flowed into Playa 5. A pump orlift station sent the wastewater on to the OSTP. This continued untilapproximately 1987 when the newer Wastewater Treatment Plant was brought on-lineand the previous agreement maintained by the DOE with the City of Amarillo wasdiscontinued. The EIS has been amended to include this information.

RC: 05.008

Doc: CO-008/74

Page 4-43, Paragraph 2. Potential sources of contamination to Zone 12groundwater includes the Burning Ground. It would seem that the Burning Groundis too distant to the Zone 12 groundwater location. Please clarify.


The Draft RCRA Facility Investigation Report for Groundwater in Zone 12at the DOE Pantex Plant identified the Burning Ground as a potential source ofcontamination to Zone 12 Groundwater. This is based on the presence ofcontaminants at depth in soil borings which potentially could leach into theperched aquifer with time. However, to date, groundwater investigations asdiscussed in volume I, section 4.6, Water Resources, indicate that there is noevidence of hydraulic connection between the perched aquifer in the vicinity ofthe Burning Ground and the perched aquifer under Zone 12.

RC: 05.009

Doc: CO-008/75

Page 4-43, Paragraph 3. Please provide a map of the landfills locations. Please correct typo in sentence "Characterization data indicates(indicate)..."


A map of landfill locations has been provided in volume I, section4.5.1. The typo has been corrected.

RC: 05.010

Doc: CO-008/76

Page 4-43, Paragraph 3. "However, maintenance caps will be placed asneeded over selected landfills as a voluntary measure to prevent potential waterinfiltration." If they are needed, would it be voluntary?


The term "voluntary" has been replaced by the term "proactive"to clarify that these actions are taken in advance of any possible directionfrom the regulator.

RC: 05.011

Doc: CO-008/77

Page 4-43, Paragraph 4. Inaccurate descriptions should be corrected: "Theditches also receive untreated industrial waste waters from Zones 11 and 12."


All available references state that only treated wastewaters for Zones11 and 12 are placed in the ditches.

RC: 05.012

Doc: CO-008/78

Page 4-43, Paragraph 4. Inaccurate descriptions should be corrected: Playa 4 also receives industrial and storm water effluent from Zones 11 and 12. Playa 2 receives industrial and storm water effluent from Zone 11. All of theplayas receive storm water from agricultural areas.


Pantex Lake and Playa 4 do not currently receive industrial wastewaterdischarges nor does Pantex Lake receive storm water runoff from Pantex Plant.

RC: 05.013

Doc: CO-008/79

Page 4-44, Table Inaccurate descriptions should be corrected:

Flow system 1 consists of Playa 1 and the unlined man-made ditches thatdirect runoff and waste water discharge away from Zones 4, 11, and 12 to thisplaya.

Flow system 4...away from Zone 11 and Zone 12 south (insert) to playa 4.

Flow system 5 also includes Pantex Lake (which received effluent from OSTPvia pipeline in prior years).


According to the September 1995 Ditches and Playas RFI (USCOE 1995f),Flow System 1 does not include direct runoff from Zone 4. The inconsistency ofnot stating that the ditches are man-made and that they direct runoff andwastewater discharge away from Zones 11 and 12 has been corrected. In regard toFlow System 5, page ES-3 of the September 1995 Ditches and Playas RFI indicatesthat Pantex Lake is a part of Flow System 5. This has been added to volume I,Table

RC: 05.014

Doc: CO-008/80

Page 4-45, Paragraph 3. Statements are not clear. "Characterizationdata indicated that contaminant levels were below remediation goals for all buttwo sites." Does this refer to 2 of the 12 sites in the AL-PX-11 group, or2 locations within the HE burn site discussed in greater detail? If the 2 sitesexcepted are indeed 2 of the 12 sites, then they should be described anddiscussed, at least in the same detail as was the HE burn site.


This reference is to 2 of the 12 sites in the AC-PX-11 grouping. Additional discussion of the status of these 2 sites has been added to volume I,section 4.5.1.

RC: 05.015

Doc: CO-008/81

Page 4-45, Paragraph 4. Please correct typo. "Characterization datais (are)..."


Correction has been made.

RC: 05.016

Doc: CO-008/82

Page 4-45, Paragraph 4. What location was selected for environmentalsampling for the DDT spill? At the building or at the playa?


According to Figure 25-1 of the August 1995 Miscellaneous ChemicalSpills and Release Sites RFI (USCOE 1995e), samples for the Building 12-35 DDTrelease were taken to the north and west of the building, and not at the playa.

RC: 05.017

Doc: CO-008/83

Page 4-46, Paragraph 1. Where is "the denuded [area] near Playa 1"located and what is the cause of its being denuded?


The denuded area is the former location of an electrical transmissionline pole, where annual hand-applied herbicides were reportedly applied for weedcontrol. The site is circular in shape and covers an area of approximately 0.90acres. The term "denuded" has been clarified by replacing it with "asomewhat barren area where herbicides were applied".

RC: 05.018

Doc: CO-008/84

Page 4-47, Table Under SWMU #143 Recommendations: "Thisarea has not been characterized to background for several analytical groups,including pesticides, PCBs, and metals." Please clarify. Does this meanthat sampling and analyses have not disclosed concentrations that are consistentwith background concentrations (i.e., have exceeded background values), or thatsampling and analyses have not been done for these groups of constituents?


According to page 6-18 of the August 1995 Miscellaneous Chemical Spillsand Release Sites RFI (USCOE 1995e), the nature of contamination has beenidentified on the basis of detected constituents and Risk Drivers. However, theextent of contamination has not been fully defined. Data collected during theRFI indicate that concentrations are now below their Practical QuantificationLimits (PQLs). This conflicts with the results of past investigations. It isfor this reason that further sampling is recommended to define the extent ofconstituents identified as contaminants of concern.

RC: 05.019

Doc: CO-008/85

Page 4-49, Table Under AOC #15, DDT release at Bldg. 12-35,exactly where did the sampling take place?


According to Figure 25-1 of the August 1995 Miscellaneous ChemicalSpills and Release Sites RFI (USCOE 1995e), samples for Building 12-35 DDTrelease were taken to the north and west of the building.

RC: 05.020

Doc: CO-008/86

Page 4-49, Table Please correct typo, Building 12-5 sumpRecommendations: "Additional data is (are)..."


Correction has been made.

RC: 05.021

Doc: HT13/4

In the EIS, it doesnt show that there are the three faults that go throughthis stupid mountain, and yet, it is well documented on many geologic reportsthat there are three major faults that go through the Manzano weapons storagefacility.

My if these facilities are 45 years old, they obviously werenot built with the current technological skills that go along withearthquake-type design. To me, that is a major concern.


According to our references, there is no evidence that indicates thatany of the three faults in the vicinity of the Manzano Storage Facility arecapable faults. A capable fault has one or more of the followingcharacteristics (c.f., 10 CFR 100 Part A): 1) Any movement in Holocene time inthe last 10,000 years, 2) more than one movement in the last 500,000 years, 3)demonstrably associated with seismic activity, and, 4) structural relation toanother structure shown to be capable.

RC: 05.022

Doc: HT17/25

There is no such thing as nonhazardous seismic hazards. My research intothe geological aspects of the Pantex Plant have uncovered some alarmingassumptions made by past experts under contract for the DOE. Because a list ofspecifics is rather long, I have prepared a separate report for your review thatwill be included in my written comments. The 1995 fault study submitted by theDOE basically suggests that local underground erosion is a primary feature atthe Pantex Plant and doesnt delve very deeply at all into the primary featurethat occasionally rocks with earthquakes three states at a time. That Pantex ismagically divorced from this phenomenon at its property lines and theWhittenburg trough is all but ignored.


See discussion in section 1.3.4 in this volume.

RC: 05.023

Doc: HT17/26

The secrets and lies concerning geology, hydrology, past contamination,current contamination, current pathways, future protections continue. I amwilling to go along with the Save the Ogallala Folks, for what good is it tohave an unsaved Ogallala, but Im not going to pretend we have anything evenremotely close to a pristine situation at the Pantex Superfund Site. We arealready in a situation where we just have to drink our poison in small amountsand learn to like it. The massive amount of data contained within the studiesdone by the Texas Bureau of Economic Geology, the Argonne National Lab, andothers prove this. The recent samples showing RDX hits in the Texas NaturalResource Conservation Commission lab test prove this. We would be ignorant tosight future emissions at Pantex without first reviewing the geological hazardstruthfully and openly.


See discussion in section 1.3.4 in this volume.

RC: 05.024

Doc: HT17/70

... I understand that we may comment a bit on the cumulative impact fromthe three PEIS documents, and the Pantex Plant and associated storage of nuclearweapon components PEIS is one that I havent taken as much note of as the othertwo PEIS documents, but I understand that in this document there...are someomissions [that] have been brought out. One of which, it has been noted thattheres nothing said about the Superfund Site projects in the study, and it wouldseem that might be something important to look at. All of us around here noticethe recognition of the Ogallala aquifer, as it is probably, in the UnitedStates, the largest fresh water aquifer.


See discussion in section 1.3.4 in this volume.

RC: 05.025

Doc: HT17/71

Its been said that Pantex is using some open and unlined ditches to disposeof waste water, and that should be addressed.


The use of unlined ditches and the impacts to the soils and groundwaterare discussed, respectively, in volume I, sections 4.5.1 and 4.6.1.

RC: 05.026

Doc: FG-003/10

A number of contaminants have been identified in the soil and groundwater(table at the existing site. The Final EIS should document whatmeasures have been taken to avoid potential contamination by the sourcesidentified.


The sources identified in the subject table are solid waste managementunits (SWMUs). Under RCRA most SWMUs are inactive sites and are not, therefore,active sources. However, contamination in the soil could act as a source forgroundwater contamination. Therefore, these sites are under the environmentalrestoration programs scrutiny. See discussion in section 1.3.4 in this volume.

Recommendations have been made to the regulator as to potential remedialactions. These recommendations have been summarized in volume I, section 4.5.1. These recommendations are still in draft stage and have not been approved bythe regulator. Active sources operate under permits and are monitored forcompliance.

RC: 05.027

Doc: FG-003/12

The DEIS (volume I, p.5-16) states that earthquakes pose the greatestnatural threat to storage of plutonium pits at NTS. The Cane Springs Fault wasidentified as the most significant seismic risk. However, the DEIS indicatesthat four faults in the NTS vicinity (Mine Mountain Fault) "are capable ofgenerating earthquakes of up to 0.85g," which is an 8.5 quake on theRichter scale. According to the Tritium FEIS (volume I, p. 4-117), the maximumcredible earthquake on the Cane Springs Fault is three to five miles from theDevice Assembly Facility.

The FEIS should recognize that the P-Tunnel at the NTS is due west of twoparallel faults, the Carpetbag Fault approximately five miles away and the YuccaFault approximately seven to ten miles away. The Tritium FEIS (volume I, p.4-117) describes both the Yucca and Carpetbag Faults as "capable faults,"as defined by the Nuclear Regulatory Commission regulations 10 CFR Part 100,Appendix A. However, the Tritium FEIS reported that the "possible magni-tude, intensity, and acceleration of earthquakes along the Yucca and Carpetbagfaults have not been estimated." The DEIS gives the impression that quakesalong any of the four faults in the NTS area could have an 8.5 magnitude on theRichter scale (volume I, p. 5-16).


When a facility specific study of all faults in the region has not beenmade, the DOE Standard for Natural Phenomena Hazards Design and EvaluationCriteria for DOE Facilities (DOE 1994u) dictates using the largest earthquakeexpected in the region and assume it can happen anywhere in the region.

RC: 05.028

Doc: PC-025/21

On page 4-39. Drop figure and place more detailed maps in appendix.Recommend using an example map in its place and refer to the appendix. Thefigure is silly. Otherwise include the location of the ditches and groundwaterfor completeness. Where is a comprehensive list of titled SWMUs in this EIS?


A figure detailing the ditches and playas flow system at Pantex Planthas been added to volume I, section 4.5.1, for completeness. A comprehensivelisting of titled SWMUs is located in the Pantex Plant Environmental InformationDocument (Pantex 1996).

RC: 05.029

Doc: PC-025/22

On Page 4-51, Environmental Restoration Activities. Question, "completedby 2000" is not consistent with other statements in the document.


The year 2000 is correct and has been made consistent throughout thedocument.

RC: 05.030

Doc: PC-025/23

On Page 4-51, Waste Management Activities. The burning ground is an openarea where fumed materials including metals, radioactive elements, etc. arereleased to the atmosphere and settle to the ground in the form of dust, watervapor, etc. and you state you do not expect impacts to the soil. How can thatbe...?

What is the representative contaminant deposition rate to the playas andburning ground?

Does HE explode while being burned and chunks of things get spread about?

Is it possible pieces sit around for years?

Further, you state on page 4-52 the material is typically nonhazardous, howdid the burning ground get contaminated? Please state you do not know or whatthe facts are.

Page 4-52, what is the source of the table?


Volume I, section 4.2, where the assessment methodologies for Geologyand Soils are discussed, has been clarified to better illustrate how impacts togeology and soils were assessed. Geological impacts consist of impacts togeological features from plant operations and impacts to the plant operationsfrom geological conditions or events. The search for geological features thatcould have been affected by plant operations identified only surface water andgroundwater. These are discussed in volume I, section 4.6, Water Resources. Seismic events and salt dissolution are the only identified geologic featuresthat could affect plant operations. These issues are discussed in volume I,section 4.5, Geology and Soils. Discussion of soils includes impacts to thesoil and impacts to humans from the soil. Potential impacts to the soilincluded any activities that would result in erosion or removal of valuablesoils from agricultural production. These issues are discussed in volume I,section 4.4, Land Use. Impacts from contaminated soil included potentialaffects on human health.

Contaminated soil within the Burning Ground is discussed in volume I,section There are three potential pathways for any contamination inthe soil to affect human health: getting into groundwater, blowing as dust, anduptake by crops. Volume I, section 4.6, Water Resources, describes contaminatedgroundwater, and volume I, section 4.7, Air Quality, describes the levels ofcontaminants detected. Crops outside the Burning Ground have shown nocontaminants at or above levels of concern. No crops are grown on the BurningGround.

Contaminant deposition rates were not modeled. The air quality modelingof Pantex Plant activities, including the Burning Ground, was performed toevaluate inhalation which is the overwhelmingly risk-significant pathway. Please refer to volume I, section 4.7, Air Quality, for further information.

When high explosives (HE) is burned it does not generally explode;however, it is known to happen. Safety procedures at the Burning Ground takethe risk of explosion into account. When the HE does explode some chunks canget dispersed within the Burning Ground.

The statement made on page 4-52 was incorrect. This section has beenmodified to read, "These wastes include treated wastewater from theWastewater Treatment Facility, and construction debris located onsite in a Class3 landfill. Residuals from the Burning Ground are disposed of in accordancewith the specifications of the hazardous waste permit."

The source for each facilities area (PC 1995g) is given in volume I,Table Additionally, this source has been added to the table.

RC: 05.031

Doc: PC-025/91

Geology and soils methodology is flawed since it does not describe what theassessment process is for the assessment. The section dictates what the impactsare. Thus DOE has prejudged the results. The assessment does not address thedecontamination and decommissioning program, as stated.


See response to comment 05.030. At this time no plans have been madefor the decommissioning of any facilities at the plant. Any future plans wouldhave to undergo cultural resource and NEPA review before implementation. Moredetail can be found in volume I, section

RC: 05.032

Doc: PC-016/1

In April of 1995, a study concerning fault identification at the PantexPlant was sponsored by Mason & Hanger-Silas Mason Co., Inc. (M & HSM), acontractor for the Department of Energy (DOE), in order to satisfy a Note ofDeficiency pertaining to a hazardous waste permit application for the PantexPlant located near Amarillo, Texas. Unfortunately, because this study was underan important deadline to satisfy a requirement of a vital permit for continuingoperations, it lacks the benefit of having undergone critical peer review. Thedata is interpreted and a conclusion is drawn using the opinion of only oneexpert: Daniel McGrath. The other experts mentioned in reference are not onrecord as sharing the conclusion he reaches. In fact, one of the geologistsmentioned in reference has gone on public record supporting a totally oppositeconclusion from the one reached in this study. The DOE fault study is also: incomplete, poorly argued, erroneously formatted, concluded in haste, and thus;invalid.

The Fault Study contains multiple references to an investigation carried outby a team from the Argonne National Lab. The use of references attempts tosupport the conclusion that Pantex does not sit on top of a fault. Yet, in anapparent contradiction, the Draft RCRA Zone 12 Groundwater Assessment, datedNovember 1995, and prepared by Argonne, clearly addresses the existence of amajor fault beneath the Pantex Plant. The Argonne report includes a powerful[visual] aide that depicts a deep, substantial fault they identify as theWhittenburg Trough. It would seem to be obvious even to the most uninformedperson that the experts from Argonne wished to draw attention to this feature. The expert for the DOE correctly states that hydrogeological characterizationstudies conducted by the Texas Bureau of Economic Geology (TBEG) have focused onmechanisms that would allow for rapid transport of contamination to the Ogallalaaquifer. He also includes the fact the faults would provide such a mechanismfor the rapid transport of water. But the TBEG reports are oddly silentconcerning the word faults, and do not directly address any argument for oragainst the existence of a fault at Pantex.

Do we have movement in the Holocene time in the last 10,000 years? Answer: Yes. "Holocene faulting has occurred on one portion of the AmarilloUplift-Wichita Uplift structure and may have occurred on another part of thesame structure in Potter County." And: "USR/Blume (1976) cite aHolocene (last 10,000 years) fault scarp 4 miles long, 20 miles northwest ofPantex Plant, on the Amarillo Uplift. Where the Amarillo Uplift extends intoOklahoma, about 150 miles from Pantex Plant, the Meers Fault also has a Holocenescarp. These two examples of Holocene faulting along the Amarillo Upliftstructure show the presence of some level, although clearly not intense, of thetectonism along this Paliozoic uplift."

Do we have more than one movement in the last 500,000 years? Answer: Yes. As stated above, "...a Holocene fault scarp 4 miles long, 20 milesnorthwest of the Pantex Plant, on the Amarillo Uplift...within the last 10,000years..."

Do we have demonstrated associated [seismicity]? Answer: Yes. "...recent11-year span, from January 1, 1977 to March 31, 1988, more than two dozen quakesmeasuring 2 or higher on the Richter scale were detected in the Texas Panhandleand South Plains, Oklahoma Panhandle and far Western Oklahoma, and thesouthernmost strip of Kansas...quakes estimated to be 4 to 4.5 on the Richterscale occurred on March 27, 1917; July 30, 1925; July 20, 1996; February 20,1974;...and others during 1934, 1948, and 1959..." And: "... Sincelocal records began in 1882, there have been four earthquakes in the Plant area. These occurred on March 27, 1917; July 30, 1925; June 19, 1931; and July 20,1966..."

Do we have a structural relationship to another structure that has beenshown to be capable? Answer: Yes. "... Holocene faulting has occurredon one portion of the Amarillo Uplift...and may have occurred on another part ofthe same structure in Potter County." And: "An assessment of naturalhazards at Pantex Plant (Jacobs 1993) lists "three major subsurface faultsand minor surficial fault" in the area of the Plant, as follows: (1) 155miles long, about 25 miles north of site, (2) 43 miles long, [about] 5 miles[south] of site, (3) 40 miles long, about 7 miles north of site, (4) 4 mileslong, about 20 miles northwest of site, surficial, USR/Blume (1976) havesuggested that faults (3) and (4) may connect."

If a capable fault must show one or more of the above [characteristics], andwe have just shown that all four characteristics are demonstrated, then itstands to reason that we have a capable fault. Fortunately for all of us,recent seismic activities at and near Pantex have been light to moderate. Pantex is currently classified as being in Earthquake Zone Number 1. Ponder thevery wise message contained within the following quote: "Seismic hazards,most notably active faults, are considered unacceptable for [nuclear] facilitiessuch as the Pantex Plant"- Daniel McGrath, Soil Scientist April 1995.


See discussion in section 1.3.4 in this volume.

RC: 05.033

Doc: PC-016/2

"Do we have earthquakes here?" Answer: Yes. (Page 3.)

"Do our core samples at the Pantex Plant show contrasting vertical andhorizontal layers?" Answer: Yes. (TBEG, Argonne, McGrath.)

"Do we have evidence that the Pantex Plant is near an epi-center forearthquakes?" Answer: Yes. The only local quake on record during thiscentury that successfully damaged a man-made structure occurred in Panhandle,Texas. Panhandle is the closest town to Pantex. The strongest local quakesoccurring during this century are said to have had epi-centers located about 10to 20 miles from the Pantex Plant. (Page 3.)


See discussion in section 1.3.4 in this volume.

RC: 05.034

Doc: PC-016/3

"Do we have groundwater samples showing differences that cansometimes indicate a fault?" Answer: Yes. According to the DOE expert,water in the [Dockum] group beneath the Pantex Plant is significantly betterthan the water found in other area [Dockum] wells. This fact indicates that theOgallala aquifer is not a confined aquifer. The Ogallala aquifer may becontributing to a more rapid recharge to the [Dockum] waters beneath the plantdue to a fracture or fault. The TBEG report of May 1995 describes a large "channel"that is allowing water to flow faster near the top of the "middle Ogallalaperching horizon." Further studies would tell us more about the lowerhorizons.


Though the water quality in the Dockum Group aquifer beneath the PantexPlant is relatively good, this does not necessarily indicate a fault, but itpoints to the intermixing of waters from the Ogallala aquifer and the DockumGroup aquifer. This intermixing could result from the movement of water as itis pumped from the Ogallala aquifer. For more detail about the faults seediscussion in section 1.3.4 in this volume.

RC: 05.035

Doc: PC-016/4

"Did the ground radar type of studies confirm that we havesharply tilted vertical soil layers beneath the Pantex Plant?" Answer: Yes. And further study would provide more description of these layers.


This does not necessarily mean that there is a fault or tectonicactivity. Subsidence can cause deformation below the surface of the stratalayers which can complicate reaching conclusions about tectonic deformation. The commentor suggests further study of the deformation to further define theseismic risk to Pantex Plant. DOEs current conservative assessment of seismicrisk does not require this specific information. The current risk assessment isdiscussed in volume I, section 4.14, Human Health.

RC: 05.036

Doc: PC-016/5

"Do we have sink spots (subsidence) at the Pantex Plant?" Answer: Yes. The playas at Pantex are "sinks". Subsidence hasinfluenced the development of many of the larger playa basins at the PantexPlant.


See discussion in section 1.3.4 in this volume.

RC: 05.037

Doc: PC-016/6

"Did the expert for the DOE overlook the fact that he provedthe case demonstrating the characteristics of a capable fault?" Answer: Yes. Unfortunately, when scientific papers are not shared with other experts,even a good scientist can make a big mistake. A process called "peerreview" involves many experts getting together to see if somebodys idea isright or wrong. "Peer review" is pretty important to scientists,because they can look [a little] silly if they go on record with bad informationor wrong ideas. Because we cannot control earthquakes, experts try to look veryhard to identify the safest places to build important buildings such as the onesat the Pantex Plant. Experts agree that geological faults are not the safestplaces to build important buildings on. Buildings that handle very dangerousnuclear materials and hazardous chemicals are not supposed to be built on acapable fault.


See discussion in section 1.3.4 in this volume.

RC: 05.038

Doc: PC-016/7

"Do we have experts who have indicated that the Pantex Plantwas built on a geological fault?" Answer: Yes. On January 8,1994, a[petroleum] geologist named Greg Wilson talked about his studies into the HighPlains area. He indicated that Pantex was on a fault, and thought more studiesshould be done to prove this. Other experts from the Argonne National Lab haveincluded maps in their studies that show a picture of a deep fault beneath thePantex Plant. An expert from TBEG has shown that subsidence has played a partin the formation of playas on the High Plains. Some experts use very clearlanguage to explain their positions, and some do not. Sometimes experts like touse very big, difficult words if they dont want to answer a question. We need tobe careful about becoming confused when experts talk, and learn to look morecarefully at the facts.


See discussion in section 1.3.4 in this volume.

RC: 05.039

Doc: PC-016/8

A hard look at the facts concerning the sub-surface surface conditions atthe Pantex Plant, in the present (here and now) time is in order. Nearly everybranch of specialized investigation is required to do this. Capable engineers,physicists, geologists, hydrologists, chemists, biologists seismologists, and[historians] all need to be consulted to clarify the current situation.

If academia chooses to mismanage the vast body of information that has beengenerated in recent investigations into the Pantex Plant, and deliberatelypresents a false model of the circumstances beneath the Pantex Plant, then theywill also predict a false outcome. Anticipating change and predicting outcomeswas once solely the responsibility of "seers" and prophets. Butscience, of its own [curiosity], evolution, and arrogance now shares aresponsibility for predicting accurate outcomes. The genie cannot be put backinto the bottle, but perhaps the genie can be better understood and better[disciplined]. If each branch of the sciences now met openly to discuss andreview the current information generated by the investigations conductedrecently at the Pantex Plant, a more useful "band-aid" might beapplied to the wound.

Neither the expert or the non-expert should become "lulled intocomplacency" just because the strength of local earthquakes during thiscentury have been light to moderate. Geological fault-science has proven thatthe ground shakes hardest along fault lines. Although new or unknown faults canalso surprise experts by suddenly becoming seismically active, known faultssimply should not be ignored. If the tectonic activity continues to increasesubstantially along the Pacific Rim, it could affect tectonic activity as faraway as places like the Panhandle of Texas. Assessing geological sensitivityfor the purpose of siting work with dangerous actinides is urgent and vital. Earthquake activity both at and around the Pantex Plant has been fairlyconsistent since records started a century ago. Not a single decade has passedin the Panhandle that some amount of seismic activity has not occurred. Aboveall, the contamination concerns may become secondary to criticality concerns, asa chain reaction in a geological setting would generate radiation and extremeheat in addition to releasing fission product contamination. As some expertsvery well know, it only takes small amounts of certain actinides suspended inwater to achieve criticality. Because of the instability of the AmarilloUplift/Whittenburg Trough/Potter County Fault connection to the Pantex Plant,and the threat the surface and groundwater may present to certain actinidesindicated to already be trapped in the soil, appropriate actions need to betaken promptly.


The EIS has examined the affected environment and the environmentalconsequences at Pantex Plant. This examination was completed by a broad rangeof professional disciplines (please see volume I, chapter 8, List of Preparers,for further information).

RC: 05.040

Doc: SG-003/25

Page 4-3, section 4.2, Impact Assessment Methodologies, geology and soils: Impacts should be assessed on the destruction of any geologic feature, not justthose specified unique.


The Impact Assessment Methodologies for Geology and Soils has beenclarified. The uniqueness of a feature is taken into account in assessing thesignificance of any potential impacts. See response to comment 05.030.

RC: 05.041

Doc: SG-003/65

Sections 4.5 and 4.6, which describe water resources and geology and soils,do not provide sufficient information for the reader to determine ifenvironmental impacts could result from continued operations and storage ofnuclear weapons at Pantex.


Sections 4.5 and 4.6 in volume I have been updated with additional data,new permit requirements, and descriptions of corrective action measures.

RC: 05.042

Doc: SG-003/67

Some of the maps in this document are used without referencing or obtainingpermission of the author. Figure was published by Gustavson (1981),but attributed to DOE (1981). Figure was prepared by Davis,Pennington and Carlson (Davis 1989), but attributed to DOE 1995.


The citations for both figures have been revised to give credit to theprimary authors.

RC: 05.043

Doc: SG-003/68

Page 4-27, Geomorphology, para. 1, ln 13. It is inaccurate to state thatplaya could play a role in the contamination of groundwater at Pantex Plant. Playa basins and ditches have been shown to be the sites where contaminatedsurface water is recharged to the subsurface (Gustavson and others, 1995).


The sentence in question has been revised in volume I, section Neither the original nor the current statement implied that contaminated surfacewater is recharged to the subsurface. However, noncontaminated water appliedover areas of contaminated soil have the potential to pick-up contamination fromthe soil and transport the contamination to groundwater.

RC: 05.044

Doc: SG-003/69

Page 4-27, Stratigraphy. para. 1, ln 4. The Blackwater Draw and OgallalaFormations beneath the Pantex Plant are not lithified and therefore are notrocks. The correct term is sediments. Rephrase sentence to "Thestratigraphy of the sediments and rocks..."


Sentence has been modified to read: "The stratigraphy of thesediments and rocks beneath Pantex Plant is discussed in descendingchronological order from more recent layers (surface deposits) to Permian -agelayers (salt deposits)."

RC: 05.045

Doc: SG-003/70

Page 4-27, Stratigraphy, para. 2, ln 6. The upper unit of the surface Soil(Pullman clay loam) of the Blackwater Draw Formation is the A horizon and itcontains no caliche. The first soil carbonate is found at a depth of about 24inches in the upper part of the B horizon (US Department of Agriculture, SoilConservation Service, 1972, Pullman Series: Established Series, 4 p).


The information has been incorporated into volume I, section 4.5.1, andthe sentences have been revised accordingly.

RC: 05.046

Doc: SG-003/71

Page 4-29, Stratigraphy, para. 1. The variable lithologies of the Ogallalaand Blackwater Draw Formations are not described. These descriptions shouldinclude a brief discussion of the complex heterogeneity of the Ogallala andBlackwater Draw because the variation in sediment types controls groundwaterflow in the formation.


A more detailed discussion of the variable lithologies of the Ogallalaand Blackwater Draw Formations has been incorporated into volume I, section4.5.1.

RC: 05.047

Doc: SG-003/72

Page 4-29. Sentence describing the lower part of the Ogallala implies thatthe fine-grained zone is the base of the lower Ogallala and generally confuseschannel deposits above the fine-grained zone (which actually falls within themiddle part of the Ogallala) with predominantly fluvial Ogallala sedimentswithin the lower part of the Ogallala [from] below the fine-grained zone.


See response to comment 05.046.

RC: 05.048

Doc: SG-003/73

Page 4-29, Stratigraphy, para. 1, ln 29. The fine-grained zone is not asandstone. Limited available core from the fine-grained zone shows interbeddedsands, silty sands, and muds. Because of the variability of sediments in thisunit, the vertical hydraulic conductivity varies by 3 orders of magnitude. Geophysical logs and core show that at least part of the fine-grained zoneconsists of fining upward sequences of fine sand, silty to clayey sand, and mud. Furthermore, these sediments are not lithified; thus, they are not sandstones.


See response to comment 05.046

RC: 05.049

Doc: SG-003/74

Page 4-30, Figure Well PXSB-03 is not just coarse sand. Thereare about 50 feet of sand and gravel near the bottom of the well.


This map has been deleted. A sentence has been added which refersreaders to Figure in volume I, section 4.6.1. This figure is ageologic cross-section of the lithology beneath Pantex Plant.

RC: 05.050

Doc: SG-003/75

Page 4-31, para. 3, ln 1. Salt dissolution and accompanying subsidence orcollapse are rapid processes on a human time scale. More than 2,000,000 tons ofsalt are dissolved each year along the eastern margin of the High Plains in theTexas Panhandle. Furthermore, about 2 years ago a very large sinkhole (250 ftwide and more than 60 ft deep) formed in northeastern Hall County, which likethe Pantex Plant lies in the salt dissolution zone shown in figure Development of this sinkhole was described in the Amarillo newspaper.


Estimates of salt dissolution rates along the eastern escarpment of theSouthern High Plains were tabulated in Regional Dissolution of Permian Salt inthe Anadarko, Delhart and Palo Duro Basins of the Texas Panhandle (Gustavson, etal, 1980). Although no estimates were provided for Carson County, mean saltdissolution rates ranged from 1.0312 x 10-5 feet per year for a site inPotter County to 5.6674 x 10-5 feet per year for a site in Armstrong County. Assuming that this range is applicable to salt dissolution rates at PantexPlant, then approximately 0.002 to 0.006 of one inch of salt dissolution wouldoccur during the entire 10-year time frame covered by this site-wide EIS. Foradditional discussion of salt dissolution, please refer to section 1.3.4 of thisvolume.

RC: 05.051

Doc: SG-003/76

Page 4-31, para. 3, ln 1. No attempt is made to describe the role of saltdissolution and subsidence in the formation of playa basins. High solute loadsin streams draining the region indicate that these processes are activeregionally. No mention is made of the potential effects, if any, ofdissolution-induced subsidence at the plant.


See discussion in section 1.3.4 in this volume.

RC: 05.052

Doc: SG-003/77

Page 4-31, para. 3, ln 11. While it is true that sinkholes or fracturesassociated with salt dissolution have not been described in Carson County,several playas on or near the Pantex Plant have been associated with dissolutioninduced subsidence. Furthermore, sinkholes or fractures have been identified inadjacent Armstrong and Donley Counties to the south, in Potter County to thewest, and in...


See discussion in section 1.3.4 in this volume.

RC: 05.053

Doc: SG-003/78

P. 4-32, Figure Gustavson (1981) who compiled the information onwhich this map is based, showed that sinkholes or fractures have been recognizedin Oldham, Potter, Donley, Briscoe, Motley, and Dickens Counties in addition tothe counties shown here.


The referenced figure, Figure (formerly Figure in theDraft EIS) "Zones of Active Salt Dissolution and Counties in whichSinkholes and Fractures Were Identified (DOE 1981)", was checked foraccuracy against the original figure contained in the reference document, "Impactof Evaporite Dissolution and Collapse on Highways and Other Cultural Features inthe Texas Panhandle and Eastern New Mexico (Gustavson 1981)." There wereno mistakes in the translation of this figure. Another figure in this referencecites that there are no sinkholes, collapse depressions, or fractures/faults inDonley, Motley, or Dickens counties. This document did not contain additionalinformation in the text to say that there were sinkholes or fractures in any ofthe counties mentioned in the comment (i.e., Oldham, Potter, Donley, Briscoe,Motley, and Dickens counties).

RC: 05.054

Doc: SG-003/79

Page 4-33, para. 2. Davis, Pennington, and Carlson (1989) reviewed inconsiderable detail the history of earthquakes in the Texas Panhandle. Eventsare shown using the Richter scale.


The commentor is correct when citing that Davis, Pennington, and Carlson(1989) reviewed the history of earthquakes in the Texas Panhandle in detail. These authors wrote a document, "A Compendium of Earthquake Activity inTexas," which was referenced in the Pantex Plant Environmental InformationDocument (Pantex 1996).

RC: 05.055

Doc: SG-003/80

Page 4-33, Soil Types, para. 2 or 3. No attempt is made to point out thatRandall clay soils are Vertisols and that deep desiccation cracks and roottubules, which are potential pathways for recharge, are characteristic of thesesoils. Furthermore, these soils have a udic moisture regime, which means thatwater moves down through the soil at some time in most years. That is, rechargeoccurs through even these clay soils.


Further detail on Randall and Pullman soils has been incorporated intovolume I, section 4.5.1. The following text has been added about Pullman soils,"This soil is classified as a Mollisol, which is noted by wide deep cracksthroughout the year. These cracks aid in groundwater recharge. The major usesfor these soils are grazing and dryland farming." The following text hasbeen added about Randall soils, "This soil is classified as a Vertisol,which contains a large amount of clay and has cracks at some time of the year."

RC: 05.056

Doc: SG-003/81

Page 4-33, Soil Types. In the discussion of soil sampling activities, thereis no mention of the preliminary soil sampling that took place as a result ofthe May 1989 tritium release. This is a significant problem resulting from thisomission for two reasons. First, there is no mention of this event or the knownareas of contamination within these report. Second, there have still not beenany characterization efforts completed beyond the initial preliminaryassessment, to determine the amount of contamination from this tritium release. This lack of characterization continues despite, at least using one data set,the apparent increasing tritium levels in perched groundwater in the area ofplaya 1.


Soil sampling took place as the result of the tritium release at cell12-44-1. This sampling was nonroutine and was reported in the Annual SiteEnvironmental Reports (ASERS).

This incident is not discussed in the Geology and Soils section, but itis discussed in the Human Health section.

There have been three types of prior evaluations of cell 12-44-1 and itsreleases. The first evaluation was to calculate offsite doses to a maximallyexposed individual, as required by both DOE 5400.1 and 40 CFR 61. The secondtype of evaluation was to characterize the contamination of the cell to plan forradiation protection measures during decontamination activities. The third typeof evaluation was to implement routine air monitoring and conduct specialpurpose soil and vegetation sampling in the vicinity of cell 12-44-1.

Volume II, appendixes C and I incorporate water and soil samplinginformation. For more information regarding radionuclide sampling, please seethese sections.

RC: 05.057

Doc: SG-003/82

Page 4-35, Figure Pantex is incorrectly located on the map. Thecorrect location is approximately 1/4-inch to the northeast of the center of theblack square or immediately adjacent to the system of faults and earthquakelocations that mark the buried Amarillo Uplift. The city of Amarillo is notlocated on the map.


Corrections have been made to volume I, Figure

RC: 05.058

Doc: SG-003/83

Page 4-50. The statement is made that there is no surface expression ofsinkholes or fractures associated with salt dissolution in Carson County. Weargue that, based on seismic data at the plant, the playas themselves are asinkhole-like expressions of salt dissolution.


See discussion in section 1.3.4 in this volume.

RC: 05.059

Doc: SG-003/84

Page 4-50, [Weapons] Related Activities, para. 2, ln 2. The statement ismade that the "potential impacts due to subsidence (resulting in sinkholesand/or surface rupture) are considered negligible because salt dissolution is aslow process relative to human activities." While the rate of saltdissolution may be slow relative to geologic time, the surface expression ofsalt dissolution can be catastrophic and result in the loss of life andproperty. Another inaccurate statement in this same paragraph refers to theabsence of sinkholes in Carson County. Paine (1994) demonstrated that manyplaya basins in the vicinity of the Pantex Plant formed as a result of surfacesubsidence over areas of salt dissolution. In this context playa basins aresimilar to sinkholes found elsewhere in the salt dissolution zone. Thus, it isinaccurate to imply that there are no subsidence features in Carson County bysimply stating that there are no sinkholes. A better approach would be toexplain that sinkholes are the product of catastrophic, rapid collapse into anunderground cavern. Playa basins on-the-other-hand formed in part as the resultof relatively slower surface subsidence over areas of salt dissolution.


See discussion in section 1.3.4 in this volume.

RC: 05.060

Doc: PC-030/4

The contaminated soil should be cleaned as soon as possible to mitigateflushing caused by storm run-off.


Investigations of the ditches and playas, related to the potential forcontamination, and the development of remediation plans are ongoing through thePantex Plant environmental restoration (ER) program (Pantex 1996: 5.2). VolumeI, section, has been revised to incorporate this information.

RC: 05.061

Doc: PC-033/4

In the Draft [EIS] I did not find the impact on area farmers when they areplowing, planting, or harvesting the crops in the possibly contaminated soils ofthe Pantex Plant property. If this information is available, I would like acopy please, and if it is not, I would like to have this included in the FinalEIS.


Volume I, section discusses the soil and sediment quality as aresult of the sampling at the Pantex Plant. The sampling that took placeoccurred on the property belonging to the Pantex Plant not Texas TechUniversity. Agriculture activities, as related to soil quality, would notimpact the health of the farmers who work the land.

3.6 Water Resources

RC: 06.001

Doc: HT11/26

Can you talk at all about water usage...for the dismantlement of the 20,000pits at Pantex?


To elaborate on the response given at the public hearing, thisinformation on weapons dismantlement is summarized in volume I, section Volume I, section, has been modified to include this detailedinformation for clarification purposes.

RC: 06.002

Doc: HT11/27

But the Pantex Plant feels that there is enough water to disassemble theentire 20,000?


Yes, groundwater resources are available for continued operations atPantex Plant. The plant uses only a small percentage of the groundwaterresources of Carson County. See discussion in section 1.3.5 of this volume fordetails.

RC: 06.003

Doc: HT05/1

On page 4-13 it's stated, and I quote, that the City of Amarillo has pledged5,526 million liters of water, or 1.6 million gallons per year as a potentialpart of the Pantex expansion.

a. All my questions are [on] the disposition issues considered expansionmissions and,

b. Where is the City of Amarillo planning to withdraw that amount of waterfrom?


To elaborate on the response given at the public hearing, the City ofAmarillo pledged 5,526 million liters of treated wastewater per year for thetritium supply mission, which required large quantities of water in excess ofthe plants production capacity. However, the decision has been made not tolocate the mission to Pantex Plant. The tritium supply mission has since beenassigned to the Savannah River Site.

a. Disposition missions were not part of the tritium supply mission forwhich the pledge was made. However, the City of Amarillo would likely extendthe same pledge for any new, large missions that might need such quantities ofwater. The continued operations discussed in the Pantex EIS would not requirethe quantities of water discussed for the tritium supply alternative and,therefore, would not require the use of the pledged water.

b. If there were a mission that required large quantities of treatedwastewater, the City would develop reclaimed wastewater from the City ofAmarillo Hollywood Road Wastewater Treatment Plant. The use of reclaimedwastewater could curtail the annual withdrawal rate from the Ogallala aquifer.

RC: 06.004

Doc: HT05/2

And, if...[pledged water] were to come from Carson County, where we alreadyexperience significant groundwater declines, it would mean that, if this totalamount was used,...a 23 percent increase in groundwater withdrawals from thatarea.


The pledged water would come from treated wastewater, not groundwater. See response to comment 06.003 for additional details.

RC: 06.005

Doc: HT05/3

I know the City has extensive groundwater rights. My main question iswhether and what criteria and how long is the pledge good for and those kind ofthings?


See response to comment 06.003.

RC: 06.006

Doc: HT05/4

So it's an ongoing offer? So there's no time frames?


See response to comment 06.003. We understand that the offer is onlycontingent upon new work (jobs) being brought to the plant.

RC: 06.007

Doc: HT05/5

... I think it's...a typographical error or something. But, in reading onPage 4-78, it was going into the agricultural uses in Carson County. And theyhad stated in that that there [were] 8,550 acres of irrigated agriculture inCarson County.

And a check with the Farm Service Agency, which is a Federal regulatoryagency, on the amount of acres in 1995 was 63,500 acres. Your withdrawal figureseems to be somewhat within range, but your acres are quite a bit off.

It's the Farm Service Agency [that] used to be ASCS. It's the government'sregulatory agency for the Federal Farm Program. And they keep it down to the10th of acres, so I know that they're correct.


On May 30, 1996, we received updated (1995) data from the PanhandleGround Water Conservation District (PGWCD) and the Farm Service Agency, which reported a total of 63,629 acres were irrigated in Carson County in 1995. PGWCDestimated a corresponding total irrigation pumpage of 81,702 acre-feet (26.6billion gallons) in Carson County in 1995. Volume I, section, has beenupdated with this information.

RC: 06.008

Doc: CO-008/62

Page 4-234, Paragraph 4. In light of the BEG study, please define thestatement, "hypothetical plutonium dispersal accident does not pose asignificant threat to the Ogallala aquifer."


Accident scenarios meet the risk limitation criteria discussed in volumeI, section 4.14. The source of the referenced Bureau of Economic Geology (BEG)study are stakeholder comments, submitted by BEG through the State of Texas(February 25, 1993), in an Environmental Assessment describing current weaponstaging and proposed component interim storage operations in Zone 4 of PantexPlant and a related supplemental report entitled "Potential OgallalaAquifer Impacts of a Hypothetical Plutonium Dispersal Accident in Zone 4 of thePantex Plant" (LANL 1992). The Los Alamos National Laboratories (LANL)report assumed an average recharge rate of 3 centimeters per year. In theirstakeholder comments on the LANL report, BEG commented that recharge ratesranging from 1.3 to 8 centimeters per year may be more applicable for the LANLstudy. BEG also raised additional questions regarding travel time estimatescalculated in the LANL study including, the effects of focused recharge,recharge rate estimates of 15.2 to 63.3 centimeters per year based on datingtritium concentrations in groundwater, and calculation of a "conservative"velocity for determining contaminant transport. DOEs responses to BEGs andother stakeholder comments are provided in the "Environmental Assessmentfor Interim Storage of Plutonium Components at Pantex and DOE Response toComments on the Pre-approval Environmental Assessment and the RevisedPre-approval Environmental Assessment and Public Meeting," volume I,section E, (DOE 1994w). This document is available for review in area publicreading rooms.

RC: 06.009

Doc: CO-008/87

Page 4-55, Paragraph 6 (last paragraph and continuation on page 4-57). Treated and untreated industrial discharges and stormwater, from bothagricultural and industrial areas, are directed to Playas 1, 2, and 4. [SeeTable page 4-59....]


According to the 1995 Environmental Report for Pantex Plant (DOE1996f:111), all effluents from plant operations are treated and, along with somenoncontact industrial discharges (e.g., steam condensate), are directed intoditches that drain to Playas 1, 2, and 4. Runoff from the southern portions ofZones 11 and 12 flow into Playa 4. Volume I, section, and volume I,Table, have been modified to reflect this updated information.

RC: 06.010

Doc: CO-008/88

Page 4-56, Figure Please check figure for Pantex Lake. Thefigure provided does not appear to be Pantex Lake. Please show full extent ofPantex Lake.


The referenced figure includes only the western portion of the PantexLake floodplain, set to scale. There are no current or proposed activities tobe conducted at Pantex Lake. Therefore, the full extent of Pantex Lake was notincluded in the figure in the Draft EIS. Figure, showing the fullextent of Pantex Lake, has been added to volume I, section

RC: 06.011

Doc: CO-008/89

Page 4-57, Paragraph 5 "Flow from the WWTF is small but continuous." What quantity is "small?" This term seems inappropriate andsubjective. Please quantify.


The National Pollutant Discharge Elimination System (NPDES) Permit (No.TX-0107107) specifies a 0.65 million gallons per day daily average dischargelimitation for Outfall 001. This permitted average daily discharge has beenincluded in volume I, section

RC: 06.012

Doc: CO-008/90

Page 4-60, Paragraph 2. At what cost is potable water provided to TTU?


The Pantex Plant provides Texas Tech University (TTU) with water forgrazing cattle under a service agreement with TTU. Water is sold to TTU at anegotiated price per the interagency agreement between DOE/AAO and TTU.

RC: 06.013

Doc: CO-008/91

Page 4-61, Paragraph 6. Requirements provided for the "TNRCC draftpermit" seem unusually similar to the current permit. Please provideupdated permit information.


A summary of requirements of the Final NPDES Permit (No. TX-0107107)have been discussed in volume I, section, and are provided in volume II,appendix C.

RC: 06.014

Doc: CO-008/92

"As discussed in section, surface water dischargepermits have been in effect since the late 1980's..." According toinformation you provided, a permit was first issued in 1980 (which is not "late").


The sentence has been modified to state, "surface water dischargepermits have been in effect since 1980...".

RC: 06.015

Doc: CO-008/93

Page 4-58, Table Why were Burning Ground structures notconsidered?


The Natural Phenomena Hazards Modeling Project: Preliminary FloodHazards Estimates for Screening Department of Energy Sites: AlbuquerqueOperations Office, (LLNL 1988), states that there are no structures located nearPlaya No. 3. Structure elevations are not referenced in the Pantex PlantFloodplain Delineation Report (DOE 1995c). Although the elevations of BurningGround structures were not included in these floodplain studies, they have beenadded to volume I, Table, as requested. The only structures thatcurrently exist above ground at the Burning Ground are the Explosive Burn Trays.These structures have a height of 2 feet above ground surface and an approximatesurface elevation of 3,572 feet above mean sea level. The Explosive Burn Traysare outside of the 100- and 500-year delineated floodplains for Playa 3, and aretherefore in compliance with 40 CFR 264.18, location standards for floodplains.

RC: 06.016

Doc: CO-008/94

Page 4-13, Paragraph 4, "The City of Amarillo has pledged 5,526million liters per year (1,460 million gallons per year) as a part of potentialplant expansion." Are disposition missions considered expansion?

Where is the City planning to withdraw this amount of water? If it were tocome from their Carson County Well Field, it would be a 23 percent increase incurrent pumping and would significantly add to the excessive drawdown problem inthat area.

What are the timeframe and conditions of the pledge?


See response to comment 06.003.

RC: 06.017

Doc: CO-008/95

Page 4-78, Paragraph 2. "In 1989, 760 irrigation wells in CarsonCounty pumped 115 billion liters (30.5 billion gallons) to irrigateapproximately 3,460 hectares (8,550 acres). This is incorrect. A check of FarmService Agency irrigated acres in Carson County revealed 63,500 acres in 1995.

PGWCD estimated irrigation pumping of 26.3 billion gallons of water pumpedin 1995.


See response to comment 06.007.

RC: 06.018

Doc: CO-008/96

Page 4-78, Paragraph 4. "Pantex Plant is located [in] PanhandleGroundwater Conservation District No. 3, which has the authority to requirepermits and limit the quantity of water pumped. Presently, the PanhandleGroundwater District does not limit the quantity of water pumped." Thatstatement is true for wells drilled and in use prior to July 19, 1995. For newwells, drilled after July 19, 1995, a landowner whose well produces annuallymore than 350,000 gallons of water per acre owned, on a section by sectionbasis, will be required to obtain a High Production Permit from the District.


The sentence, "Presently, the Panhandle Groundwater ConservationDistrict does not limit the quantity of water pumped" has been modified tostate, "Historically, the Panhandle Groundwater Conservation District...". Another sentence has been added that states, "However, for new wellsdrilled after July 19, 1995 that produce annually more than 1.3 million liters(350,000 gallons) of water per acre owned, on a section by section basis,landowners will be required to obtain a High Production Permit from thePanhandle Groundwater Conservation District."

RC: 06.019

Doc: CO-008/97

... Please define the extent and migration of the contamination. Moreinformation is needed to define the extent of the perched aquifer and whether itis in communication with the Ogallala aquifer.


Discussion of the extent and migration of contamination in the perchedaquifer has been updated to reflect the most recent data available at the timeof publication. Additional information, discussed in section 1.3.5 of thisvolume, has also been included in volume I, section

(Video) My Visit to Bomb City: An Interview with the Pantex Plant Historian in Amarillo, Texas

RC: 06.020

Doc: CO-008/98

... Are fissures present that would allow movement of the perched water toenter the Ogallala aquifer?


The term "fissure" refers to cracks, breaks, or fractures inrock. The Ogallala aquifer consists primarily of unconsolidated sand, silt,clay, and gravel. Unconsolidated materials are not prone to the development offissures. However, there is the potential for groundwater from the perchedaquifer to move downward toward the Ogallala aquifer through voids betweenunconsolidated sand, silt, clay, and gravel particles. Coarse-grained gravelsand sands transmit water faster than fine-grained silts and clays. Fine-grainedmaterial creates localized perching zones that limit the downward verticalmovement of infiltrating groundwater, as discussed in volume I, section

RC: 06.021

Doc: HT02-04/4

Records show that Pantex is monitored for some 160 different contaminants. And why is it being monitored for these contaminants? Because they didnt knowit, but they sent it into the groundwater. And I am addressing you as Pantex,but this forum also needs to address the fact that these discharges are onlymonitored, contaminant by contaminant.


Pantex Plant has several ongoing routine and non-routine monitoringprograms to identify the contaminants of air, soil, surface water, andgroundwater.

Volume I, section, and volume II, appendix I, discuss thesurveillance programs for soil and environmental restoration activities. VolumeI, Table, and Table I.1.2.13, volume II, Table I.1.2.13 characterizethe soil contaminations and quantify them.

Volume I, sections and, and volume II, appendix C,discuss and quantify the chemical constituents that exceed surface water andgroundwater quality decision criteria.

Ambient air quality is described in volume I, section and volumeII, appendix B. Volume I, Tables and, identify the airpollutants emitted from site-wide Pantex Plant operations and quantify them,contaminant by contaminant.

RC: 06.022

Doc: CO-008/99

Page S-15, Table S-1. The table on page S-15 should show percentages, togive the reader perspective on water use.


a. Plant used 230 million gallons in 1995.

  1. Texas Tech Farms used 66 million gallons (29%) of the total usage.
  2. Nuclear weapons operations used 163 million gallons (71%).

b. City of Amarillo consumed 16 billion gallons of water in fiscal year1995.

c. Pantex Plant including Texas Tech Farms used 1.4% as much as the City ofAmarillo and 1% of water use went for nuclear weapons.

d. Considering the water also used for irrigation, the plant withdrew 0.6%of the regional withdrawal from the Ogallala aquifer. Nuclear weaponsoperations consumed 0.43% of the regional withdrawal.

Pantex 1995 Water Usage, Reference: Draft EIS for the Continued Operationof the Pantex Plant and Associated Storage of Nuclear Weapon Components, March1996, page S-15.


Table S1 is intended to be a summary comparison of environmental impactsat Pantex Plant. It is not a summary of baseline conditions for the variousresource areas. As a result, the recommended change to Table S1 is notapplicable to the intended purpose of the table. However, this recommendationhas been applied to the information presented in volume I, Table Information in volume I, Table, has been updated with available dataand percentages for 1995.

RC: 06.023

Doc: CO-008/100

Page 4-63, Figure Why are drinking water sampling locations (atthe tap) provided on a figure titled to depict monitoring wells?


Drinking water locations have been omitted from the referenced figure(Figure in volume I. In addition, this figure has been retitled, "GroundwaterMonitoring Locations, Pantex Plant Site".

RC: 06.024

Doc: CO-008/101

Page 4-65, Paragraph 2. "The complete lateral and vertical extent ofperched aquifers are being defined." Please clarify.


The "lateral and vertical extent" refers to the aquiferslocation, shape or geometry, and depth. An expedited site characterization forthe Pantex Plant Zone 12 groundwater was conducted to develop a working model ofthe perched aquifer. Specific objectives included characterizing the extent ofthe perched aquifer, nature of groundwater recharge, direction of groundwaterflow, groundwater contamination, and identification of potential receptors. Thefindings of the expedited site characterization are presented in the Draft RCRAFacility Investigation Report for Groundwater in Zone 12 at the DOE Pantex Plant(Argonne 1995a). The word "complete" has been omitted from thereferenced sentence in volume I, section

RC: 06.025

Doc: CO-008/102

Page 4-69, Paragraph 2. Please correct typo, "the conclusion drawnfrom this (these) data..."


Correction has been included in volume I, section

RC: 06.026

Doc: CO-008/103

Page 4-69, Paragraph 6. Concerning the depth to groundwater calculations,were calculations made on the leased and owned land or just owned land?


Depth to groundwater calculations included the available data for ownedland (i.e., the main Pantex Plant).

RC: 06.027

Doc: CO-008/104

Page 4-69, Paragraph 4. "Although the effectiveness of thefine-grained zone to act as a barrier to vertical groundwater movement is notfully understood,..." The word "barrier" should be changed to "retardant,"to more correctly describe movement.


The text in volume I, section, has been revised.

RC: 06.028

Doc: CO-008/105

Page 4-71, Paragraph 1. What does the statement, "In 1990, therecoverable volume of water in storage and available for use in the Ogallalaaquifer was estimated at approximately..." refer to? Does it refer tothat volume beneath Pantex, contained in the High Plains Aquifer, or the entiremulti-state regional "Ogallala" aquifer? Please clarify.


The estimate refers to the recoverable volume of water in storage in theOgallala aquifer in the High Plains Aquifer System. The estimate was calculatedusing an aquifer simulation model of the High Plains Aquifer System, originallyconstructed in the early 1980s and updated and revised in 1990, to predictfuture aquifer conditions. Additional information is provided in Peckham andAshworth, 1993, "The High Plains Aquifer System of Texas, 1989 to 1990Overview and Projections." The phrase "in the High Plains aquifersystem (TWD, 1993)" has been added to the end of the last sentence in theabove-referenced paragraph in volume I, section

RC: 06.029

Doc: CO-008/106

Page 4-75, Paragraph 1. "It is highly likely that this and otherearlier releases contributed to the high concentrations of chromium..."(1976-1986). Are further investigations to be done to identify the source, oris it to be accepted as is? 1976-1986 seems rather recent to be the majorcontributor to the perched aquifer contamination problem. Verify dates and anyother sources of chromium.


Ongoing chromium investigations include determining whether elevatedchromium levels could have been caused by the amount of chemicals used forconditioning cooling water during the towers operational period (1950 to 1964),conducting chromium anion exchange and column studies to determine whether ionexchange resins would be an effective treatment technology, and geochemicalmodeling to predict the fate and transport of chromium species in groundwater. This information has been added to volume I, section

RC: 06.030

Doc: CO-008/107

Page 4-77, Paragraph 2. "Investigations to determine the potential forcontaminant migration to the Ogallala aquifer from Pantex Plant are ongoing." Please provide more specific information as to what investigations are ongoingor planned.


DOE has investigated the potential for contaminant migration to theOgallala aquifer from Pantex Plant in homestead wells that are located southeastof the plant boundary. Seven abandoned homestead wells have been sealed inorder to prevent potential pathways of contamination into the Ogallala aquiferunder the Groundwater Protection Project. A summary of the purpose and scope ofthe Groundwater Protection Project has been provided in volume I, section4.6.1.2.

RC: 06.031

Doc: CO-008/108

Page 4-77, Table

a. Under "Source," the Carson County Well Fields should be clearlyidentified as "City of Amarillo's Carson County Well Fields."

b. Does Carson County irrigation use (1989) include gallons used by TTU forirrigation at Pantex?


a. Correction has been included in volume I, section

b. Updated information has been provided in volume I, section The totals for water use in the county do not provide a list of individual usesso it is unknown whether TTU usage is included.

RC: 06.032

Doc: CO-008/109

Pages 4-78, 79, Paragraph 5. Because the TNRCC and EPA requirements in thenew permits will be quite different from the requirements of the permit compliedwith in 1994, it seems that the logic in this paragraph may be faulty. Astatement that all parameters in the proposed draft permit have been met forx-number of years would be more persuasive. Please update with current permitinformation.


Information from the Final NPDES (June 1996) has been summarized involume I, section, and is presented in volume II, appendix C. Surfacewater decision criteria have been revised in accordance with the required permitlimits for the Final NPDES and TNRCC Wastewater Discharge Permits. Thereferenced text in volume I, section, has been omitted from theparagraph.

RC: 06.033

Doc: CO-008/110

Page 4-79, Paragraph 4. The statement "Groundwater contamination hasoccurred in the perched aquifer as a result of past site-related activities,primarily through spills and unintentional releases," is not consistentwith information provided by Pantex Plant. Past practices were past practices. Rather than try to explain them as spills and accidents, a more positivestatement would be to provide some of the great strides that Pantex Plant hasmade in the past seven years to correct these practices and investigate andbegin to correct the extent of problems created by past practices.


The text has been modified to state, "Groundwater contamination hasoccurred in the perched aquifer as a result of past site-related activities. For the past seven years, the Pantex Plant Environmental Restoration Program hasassessed inactive sites, conducted investigations to determine the nature andextent of contamination, and implemented remediation strategies to eliminate anypresent or future threat to human health and the environment. These activitiesto investigate historical sources of contamination and correct the extent ofproblems created by past practices will continue in the future."

RC: 06.034

Doc: CO-008/111

Page 4-80, Paragraph 6. Please specify the "current activities"of UT Austin, TBEG, and TTU Water Resources Center.


The "current activities" of University of Texas at Austin,Bureau of Economic Geology, and Texas Tech University Water ResourcesInformation Center that are being referred to in the subject text include:

· Conducting a perched aquifer tracer test at the PantexPlant Zone 12 treatability site to evaluate the efficiency of groundwaterrecirculation for remediation, determine potential retardation effects on highexplosives from the injection of treated wastewater, and to predict long-termperformance of the remediation system.

· Soil vapor extraction modeling and conducting a tracertest in unsaturated sediments above the perched aquifer to predict theefficiency of soil vapor extraction.

· Investigating microorganisms for high explosivesdegradation.

· Bioremediation investigations and ecological riskassessments.

· Chromium investigations that include determining whetherelevated chromium levels could have been caused by the amount of chemicals usedfor conditioning cooling water during the towers operational period (1950 to1964), chromium anion exchange and column studies to determine whether ionexchange resins would be an effective treatment technology, and geochemicalmodeling to predict the fate and transport of chromium species in groundwater.

Volume I, section, has been updated accordingly.

RC: 06.035

Doc: CO-008/112

Page 4-82, Paragraph 7. Is the effluent volume a condition of the proposeddraft permits?


The NPDES permit has daily average and daily maximum effluent volumelimitations of 0.65 and 0.82 million gallons per day respectively for FinalOutfall 001. The permit also has reporting requirements for daily effluents atother outfalls. Specific Pantex Plant NPDES permit requirements are tabulatedin volume II, appendix C.

RC: 06.036

Doc: CO-008/113

Page 4-83, Paragraph 1. "Since about 82% of the groundwater withdrawalin Carson County is for irrigation, conversion to dryland farming could have amajor beneficial effect on the current rate of aquifer drawdown." UnderTexas Law, groundwater is private property. This statement refers to propertyowned by others and is inappropriate and irrelevant to the SWEIS. Pleasewithdraw this statement.


Statement has been omitted from volume I, section

RC: 06.037

Doc: HT02-04/2

We cannot fix a problem we are not permitted to face. I call on the DOE,Mason & Hanger, the unions, the DOD, the City of Amarillo, and the State ofTexas to correct, once and for all, this unethical situation that prohibitsdocuments such as the Zone 12 Groundwater Assessment proposed by ArgonneNational Lab from being easily available to the general public as well as to ourcivic leaders.


The Environmental Restoration program or cleanup process is governed byResource Conservation and Recovery Act (RCRA), Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA), or both, and theirassociated regulations. Both sets of regulations govern how environmentalcontamination is defined, characterized, and remediated. Following sampling,analysis, and characterization, a draft report that describes the data,analysis, and cleanup recommendations is sent to the regulator. After review bythe regulator, subsequent revision of the report, and final approval by theregulator, the final report is made available to the public. The approval ofthe report includes approval of the recommendations.

The RCRA Facility Investigation (RFI) for groundwater in Zone 12 atPantex Plant is not currently available to the public and there is no timeframefor providing this document to the public. The State of Texas is reviewing thisdocument and has yet to respond. DOE will not release the RFI until receivingState approval.

RC: 06.038

Doc: HT13/7

Another thing is the water and the springs in the mountain. Dry as it seemsall around here, particularly when we don't have any rain, there is actuallywater in the mountain. There is an intriguing sentence on page 5-59 in thedocument that says some magazines show evidence of water intrusion.

I am interested in knowing to what extent the water intrusion affects any ofthe 41 in the mountain and how many of the ones that potentially -- well, let'sstart with that. How many of the 41 are affected by water intrusion?


A survey of unlocked magazines was conducted at the Manzano WeaponsStorage Area at Kirtland Air Force Base in March 1993 to identify magazines thatexhibited evidence of water intrusion. The survey revealed that 41 magazineswere found to be dry, 21 showed at least some evidence of water intrusion fromleaks or seeps, 59 were locked, and 1 was sealed. It should be noted that thedegree of water intrusion is characterized more accurately as small, shallowpuddles rather than flooding.

RC: 06.039

Doc: HT13/8

Do you know what the causes of the water intrusion in the two were? Is it[a] water source? Is it flaws, engineering flaws, or cracks in the facility, orwhy is it and how is it that the water came in? The obvious follow-up is how doyou know that there won't be similar problems in any or all of the other 39?


The exact cause of a small amount of water in storage magazines at theManzano Weapons Storage Area at Kirtland Air Force Base was not determined. Thewater could have seeped in through small holes in the roof, walls, or floorjoints, or through the chimneys which vent the magazines to the atmosphere. Inany event, the obvious excellent condition of the visible interior of themagazines (walls, ceilings, floors) and the very small water puddles observed onthe otherwise dry floors suggest that very little work would likely be requiredto make the magazines suitable for pit storage. The magazine interiors actuallylook much younger than their actual age.

RC: 06.040

Doc: PC-011/1

To expand Pantex's role to accommodate any or all of the above is to megrossly irresponsible in view of the fact that the plant lies above the largestfresh water aquifer in the U.S., and that said aquifer is the lifeblood of thisarea's agriculture industry. Why the Ogallala aquifer has not been classifiedas a Class 1 water source is a puzzlement to me.


Texas enacted a groundwater law in 1949 that authorized the formation oflocal districts having the power to make and enforce regulations governinggroundwater withdrawal. By virtue of this law, Texas has given the power ofregulation to local groups, thus placing the responsibility for regulation atthe lowest possible governmental level capable of performing the desiredfunctions (USGS 1976). The Texas Water Code section 52.024 grants the TexasWater Commission (predecessor to the TNRCC) the authority to designateUnderground Water Management Areas in the State of Texas in the form of a ruleto protect groundwater resources. Groundwater resources in the area governed bythe Panhandle Groundwater Conservation District, including the Pantex Plantarea, have not been designated as Class I or a critical area. This text hasbeen added to clarify volume I, section

RC: 06.041

Doc: PC-011/3

It is a further contention by Pantex boosters that no substantial waterpollution has occurred except for the perched water above the Ogallala aquifer. On June 27, 1995, a water sample was taken from one of my windmill wells andsubmitted for analysis. The results yielded the following information:

For 16 high explosives tested for, results were below PQL [PracticalQuantification Limits]. For gross alpha, gross beta, Pu 239/240, Ra 226/228,Sr-90, tritium U 234/238 -- detected, but below Safe Drinking Water Actmaximums.

How much will these levels rise if Pantex's role is expanded? Is itsomething we are willing to risk? Is it truly necessary for the viability ofAmarillo's or the Panhandle's economy? Is short term economic prosperity wortheternal contamination?


The TNRCC detected low levels of high explosive contamination in adomestic Ogallala well located southeast of the Pantex Plant boundary; however,efforts to mitigate further contamination have been completed as discussed insection 1.3.5 of this volume. The well in question has been properly pluggedand abandoned under the supervision of the TNRCC and a replacement Ogallala wellhas been drilled and completed in order to prevent further potentialcross-contamination of the Ogallala aquifer. Pantex Plants GroundwaterProtection Project addresses these and future steps to assure the integrity ofoffsite groundwater quality. Volume I, section, has been updated andincludes additional information regarding the Groundwater Protection Project.The scope of this EIS does not include expansion of Pantex Plants role.

RC: 06.042

Doc: TG-001/1

There should be an addition to Table 6.5-4 in the Water Resource row. Thistable in the Draft EIS has only the New Mexico State environmental statutes. Ofthese 19 Pueblo Indian Tribes, six have received EPA approval for water qualitystandards under the treatment of State designation. These six are IsletaPueblo, Sandia Pueblo, San Juan Pueblo, Santa Clara Pueblo, Picuris Pueblo, andNambe Pueblo. And of the six, Isleta Pueblo is the closest in proximity anddownstream on the Rio Grande river from the Manzano Weapon Storage Area at theKirtland Air Force base, which is one of the alternative sites. Other Pueblotribes have draft water quality standards that they anticipate approval [for]soon.


Thank you for your observation. Table 6.54 in volume I, has beenmodified accordingly.

RC: 06.043

Doc: PC-034/12

... In volume I,...4.6, Water Resources (p.4-57) it is stated that "Playashave also been identified as possible sources of focused recharge to thegroundwater flow system at Pantex Plant. Unlined ditches have been used todispose of wastewater and stormwater in the past."

As written, the implication is that the Pantex playas recharge the totalgroundwater system, which includes the Ogallala aquifer. This is not true. AtPantex Plant the playas have been identified as...possible [sources] of focusedrecharge to the perched aquifer, and unlined ditches have been used to conveywastewater and stormwater.


Volume I, section, has been modified accordingly to state, "AtPantex Plant the playas have been identified as a possible source of focusedrecharge to the perched aquifer and unlined ditches have been used to conveywastewater and stormwater."

RC: 06.044

Doc: PC-034/13

... In August 1995, EPA issued a draft NPDES permit for the Pantex Plant,yet in volume I (pp. 4-61 and 4-62) very little information regarding thesubstance of this draft NPDES Permit is presented.

Question: Why? And why does this section on NPDES Permits containsuperfluous information about three-year old TNRCC draft permits on surfacewater discharges?


Volume I, section, and volume II, appendix C, have been updatedto present information from the Final NPDES and TNRCC Wastewater Dischargepermits.

RC: 06.045

Doc: PC-024/14

Page 5-12, left column, "Impacts of Facility Upgrades," last fivelines. No mention is made, in this report, concerning the radioactivetrititated water that drains out of some of the tunnels and collects in pondsoutside the tunnel entrances. Nor is there any mention of the possiblecollection of gaseous radionuclides in the tunnels that could originate from thewaste in the expended test cavities.


With respect to the tunnels at Nevada Test Site, the only tunnel that isbeing considered for storage of plutonium pits is P-Tunnel. There is nodrainage out of P-Tunnel. Upon completion of a weapons effects test, and therecovery of the data, the area is sealed to prevent radionuclide migration.

RC: 06.046

Doc: PC-023/2

With respect to water resources and water quality, I understand thatgroundwater and surface water contamination has been attributed to pastactivities at Pantex Plant. Heavy metals, solvents, etc. found in excessiveconcentrations in the perched groundwater can be linked to poor disposalpractices in the past, and improved waste handling should limit futurecontamination. However, since soils in recharge areas (including playas andditches) are contaminated, the contaminants can continue to move to the perchedaquifers. I am concerned about the quality of water in some relatively shallowdomestic wells in the vicinity. Your report states that at least two domesticwells draw water from perched groundwater.


Pantex Plant has worked very closely with EPA Region VI and the TNRCC toproduce wastewater discharge permits (EPA NPDES Permit No. TX-0107107 and TNRCCWastewater Discharge Permit No. 02296) that provide stringent wastewaterdischarge requirements that are protective of human health and the environment. An additional condition of the TNRCC requires Pantex Plant to conduct a study todetermine the feasibility of eliminating or minimizing discharges to playa lakesand open ditches or improving the quality of discharge. In addition, DOE isconducting a Groundwater Protection Project to alleviate the potential forgroundwater contamination.

RC: 06.047

Doc: PC-023/3

... It is possible that the water in the perched sources can move to theOgallala aquifer. The hydraulic gradient of the Ogallala in the vicinity ofPantex indicates well drawdown under Pantex Plant toward the City of Amarillowell fields in Carson County northeast of the plant. In other words,contaminants that leach to the Ogallala under Pantex will likely move toward thewells supplying water to the City of Amarillo. The City of Amarillo has pledgedup to 1,460 million gallons per year to Pantex Plant, up from the 221 milliongallons used in 1994. If pumping rates from these well fields increase, thewell drawdown will increase, thereby increasing the hydraulic gradient andincreasing the rate of movement of these contaminants toward the city's watersupply.


The 1,460 million gallons per year of water that was offered by the Cityof Amarillo refers to reclaimed wastewater from the Hollywood Road WastewaterTreatment Plant, not groundwater supplied from the Carson County wellfield, asdiscussed in the response to comment 06.003.

RC: 06.048

Doc: HT16/16

My main concerns about the discussions of the perched aquifer and theOgallala aquifer have to do with the limited amount of information that isavailable describing the limits of the perched aquifer to the south andsoutheast. And I'm also concerned about the lack of discussion of leakage ofperched aquifer waters through the perching horizon. In my reading of the DraftEIS, these two issues are not treated with any...kind of detail. And I wouldlike to know if there's any additional information available that may be addedinto the final statements. We don't know for sure, for example, what happens toperched...aquifer waters when they reach towards the limit of the perchinghorizon. Are they simply flowing off the edge of the perching horizon and theninto the Ogallala aquifer, or is it possible in some cases that the southernmargins of the perched horizon are more or less continuous or sort of flow intothe Ogallala aquifer.


An expedited site characterization was conducted in 1994 and 1995 tocharacterize the extent of the perched aquifer, nature of recharge, anddirection of groundwater flow. The results of the investigation are included inthe Draft RCRA Facility Investigation Report for Groundwater in Zone 12 at theDOE Pantex Plant (Argonne 1995a). Data collected during the expedited sitecharacterization were used to predict contaminant movement and to evaluatecleanup options for perched groundwater; the results of this study are reportedin Two-dimensional Groundwater Flow Model and Design Tool for Evaluation ofRemedial Options for Perched Groundwater at Pantex Plant (Battelle 1996a). Additional investigations are being conducted on private property south andsoutheast of Pantex Plant. The primary area of concern in this modeling effortis the perched aquifer underlying Zones 11 and 12 and the area east andsoutheast of the plant boundary.

The perched aquifer occurs as a result of localized groundwater moundsthat form beneath the playas from focused surface water recharge. The existenceof the perched aquifer is also dependent on the occurrence of a fine-grainedzone, reported to be approximately 30 to 110 feet thick. This fine grained zoneimpedes the downward movement of infiltrating groundwater. The fine-grainedzone has an irregular surface, and generally occurs 300 feet below land surface. Where the fine-grained zone is present, perched groundwater collects in sandand gravel deposits that form subsurface channel features. The perched aquiferis thickest beneath Playa 1, which is considered to be a source of focusedrecharge to the perched aquifer. Groundwater in the perched aquifer isconsidered to flow radially away from Playa 1. Recharge varies laterallybetween playa, interplaya, and drainage ditch environments.

It is important to note that the perched aquifer is stratigraphicallyhigher (closer to the surface) and not directly hydraulically connected with theunderlying Ogallala aquifer. The depth to groundwater ranges from 210 to 290feet below land surface in the perched aquifer and from 340 to 460 feet in theunderlying Ogallala aquifer.

The information provided in this response has been added to volume I,section, for clarification.

RC: 06.049

Doc: HT16/23

On Page 4-57, the first paragraph is somewhat confusing. We'd like to see astatement [that] clearly states that Pantex did at least historically discharge[to] Playa 5. It's implied in the statement they have in the first paragraph. We would like to see it just a little more clear cut. With regard to Ogallalacontamination, I understand the EIS had been written before we discovered someslight amount of contamination in the Ogallala proper. Since the EIS hasn'tcome out in its final version, I think it ought to be revised to go ahead andreflect the conditions we know about now.


According to the Pantex Plant Environmental Information Document (Pantex1996), no industrial discharges from Pantex Plant have ever entered Playa 5.

Discussion of contaminants of concern detected in the Ogallala aquiferhas been addressed in the Final EIS.

RC: 06.050

Doc: HT16/24

With regard to the Ogallala, the homestead wells, the EIS should note thatthe low vertical permeability of the fine-grained zone may be compromised bythese abandoned homestead wells that have been found on the Pantex site. Thesewells could provide contaminant pathways through the fine-grained zone to theOgallala.


See discussion in section 1.3.5 in this volume regarding the effortsconcerning the homestead wells in the Pantex Plant groundwater protectionprogram.

RC: 06.051

Doc: HT16/25

With regard to the facility boundary, the EIS should mention that DOE willtake whatever action is practicable to clean up the groundwater to residentialdrinking water standards beyond the facility boundary. ...On Page C-2 there'sa statement that...the Texas State Surface Water Quality Criteria do not applyto Pantex playas. But if you go through the Risk Reduction Rules, 30 TexasAdministrative Code, Subchapter S, Chapter 335, you'll note that Texas SurfaceWater Quality Criteria [do] apply to the Pantex playas surface water qualityvalues. The surface water quality determined in accordance with Risk ReductionRules [takes] precedence over the risk based concentration guidelines from EPARegion 3, which was cited on section C.1.2. The list of decision criteriadoesn't list the Texas Risk Reduction Rules, which also include Texas SurfaceWater Quality Criteria and drinking water standards and so forth. ...Since theEPA Region 3 guidelines don't apply to Pantex, which is in EPA... Region 6...andwe have the Texas Risk Reduction Rules and the Texas Surface Water QualityCriteria, all of which do apply, we'd just as soon you drop the EPA guidelinesand substitute the Risk Reduction Standards. This gets to be a problem lateron.

In Table C.1.2-1, some of the values cited apparently cite the EPA Region 3guidance. For instance, the standard for antimony should be 0.006 milligramsper liter, based on the Risk Reduction Rules, which refers it back to the SafeDrinking Water Act, rather than the 0.15 milligrams per liter cited by EPARegion 3 guidance. So, because we're using the wrong guidance, we're gettingthe wrong numbers cited in the EIS. Standards for gross alpha activity,according to the Risk Reduction Rules, should be 15 picocuries per liter ratherthan...N/Anot applicable. That was cited in the table. No water qualitystandard is provided by the Texas Surface Water Quality Criteria; therefore, theRisk Reduction Rules specify use of drinking water standards which are based onthe Federal Safe Drinking Water Act. Proposed drinking water standards shouldbe 50 picocuries per liter or 4 millirems per year for beta particleactivity....

And the TNRCC requests that DOE revise Table C.1.2-1 to cite the morestringent surface water quality standards for radionuclides that are developedin accordance with the Risk Reductions Rules. As such, the standard forplutonium-239/240 would be 2 x 10-8 microcuries per milliliter, based on theTRCR standards. ...they come out of the Bureau of Radiation Control, TexasDepartment of Health. Radium-226 and -228 should be 6 x 10-8 microcuries permilliliter, again, based on the drinking water standards, Federal drinking waterstandards. Tritium should be 1 x 10-3 microcuries per milliliter, based on theTRCR standards. Uranium-234 and -238 would be either 3 x 10-7 microcuries permilliliter, which is a TRCR standard, or 20 milligrams per liter, proposeddrinking water standard, whichever is more stringent.


DOE has completed a Groundwater Protection Project to cleanup thegroundwater to residential drinking water standards beyond the facilityboundary, as discussed in section 1.3.5 of this volume. The purpose andobjectives of the Groundwater Protection Project have been addressed in volumeI, section

Surface water quality decision criteria issues are summarized in section1.3.5 of this volume. In the Draft Pantex Plant EIS, EPA Region III Risk BasedConcentrations (RBC) Guidelines were used as a surface water quality decisioncriteria only for those constituents that did not have established surface waterquality standards, Pantex Plant wastewater discharge permit limits, or DOEDerived Concentration Guides (DOE Order 5400.5) for radionuclides. As a result,EPA Region III RBC Guidelines were used as decision criteria for the followingconstituents: antimony, beryllium, boron, cobalt, molybdenum, nitrite,strontium, tin, vanadium, 3,3-dichlorobenzadine, 4-methylphenol, acetone,benzoic acid, chloroform, ethylbenzene, methylene chloride, phenol, toluene,total xylenes, HMX, RDX, and ammonia. Of these constituents, the following arenow regulated in the NPDES and TNRCC Wastewater Discharge Permits: antimony,beryllium, cobalt, molybdenum, HMX, RDX, and ammonia. EPA and TNRCC determinedwhich constituents would have recording requirements and/or permit limitsspecified in the NPDES and Wastewater Discharge permits based on a review of themost recent surface water quality data available for the main outfalls andinternal outfalls. The most recent analytical data at the time of regulatoryreview were from 1993. The TNRCC calculated effluent limitations that werebased on the Texas State Water Quality Standards (30 TAC 307). The actualeffluent limitations, cited in the permits, are more stringent that thosecalculated by the TNRCC and reported in its Fact Sheet. As stated in the NPDESPermit, EPA has accepted the statistical calculations provided by Pantex Plantand has established metal limitations on case-by-case basis through bestprofessional judgment under 402(a) of the Clean Water Act for best availabletechnology economically available. In addition to the constituents that areregulated in the permits, the Pantex Plant Environmental Protection Departmentalso has conducted analyses for the following constituents that were notspecified in the permit: nitrite, strontium, vanadium, 4-methylphenol,3,3-dichlorobenzadine, chloroform, ethylbenzene, methylene chloride, phenol,toluene, acetone, benzoic acid, xylene, boron, and tin. By monitoring for theseadditional constituents, Pantex Plant is providing additional assurance that anychanges in chemical constituents and their relative concentrations areprotective of human health and the environment.

NPDES and Wastewater Discharge permit requirements have replaced RBCGuidelines from EPA Region III as decision criteria. Refer to volume I, section4.6.1.1, and volume II, appendix C.

The Atomic Energy Act authorizes DOE to protect public health and safetyand the environment in conducting programs, such as Pantex Plant operations. The purpose of DOE Order 5400.5 is "To establish standards and requirementsfor operations of the DOE and DOE contractors with respect to protection ofmembers of the public and the environment against undue risk for radiation...." It is DOEs objective to operate its facilities and conduct its activities sothat radiation exposures to members of the public are maintained within thelimits established in this Order and to control radioactive contaminationthrough the management of real and personal property. It is also a DOEobjective that potential exposures to members of the public are as far below thelimits as is reasonably achievable and that DOE facilities have thecapabilities, consistent with the types of operations conducted, to monitorroutine and non-routine releases and to assess doses to members of the public. In addition to providing protection to members of the public, it is DOEsobjective to protect the environment from radioactive contamination to theextent practical." As a result, the Risk Reduction Rule and drinking waterstandards are not applicable decision criteria for surface water quality atPantex Plant. The TNRCC Permit Fact Sheet (TNRCC, 1995a) states that the knownuses of the receiving waters are high quality aquatic life use and contactrecreation. The uses for the unclassified waters are intermittent playa lakeswith no significant aquatic life uses. Acute aquatic life criteria apply. There is no reference to drinking water standards or Risk Reduction Rules beingapplicable criteria for Pantex Plant surface water in either the TNRCC or EPApermits or their respective Fact Sheets.

RC: 06.052

Doc: HT16/26

My question refers to -- it's on Page 4-78. And you recognize, and I quote,groundwater management is a responsibility of local jurisdictions throughgroundwater management districts. The Pantex Plant is located in PanhandleGroundwater Conservation District Number 3, which has authority to requirepermits and limit the quantity of water pumped. And, in view of this statementin the document, why have you chosen not to register the perched waterproduction wells and the monitoring wells in compliance with Rule 4 of thePanhandle Groundwater Conservation District? It does not require permitting,but it does require registering and a semiannual report of any water qualityanalysis that were taken from the monitoring wells.


DOE is working with the Panhandle Groundwater Conservation DistrictNumber 3 to resolve this issue.

RC: 06.053

Doc: HT16/27

... I'd like for one of the DOE people to characterize to me how the systemfailed when, on a meeting on May 13th with Johnny Bolin [Guelker] and Danny[Dan] Ferguson of DOE, Boyd Deaver from the TNRCC here in Amarillo and myself,agreed that it was in everyone's best interest to not plug the Lee Cockrellwindmill located off site. And then, two days later on May 15th, it was relatedto me that that well was plugged. And I just wondered where the system failedand what has done to correct it.


The windmill well was plugged by mistake. It has been redrilled andsampled for chemical analysis.

RC: 06.054

Doc: HT16/28

When you were making the presentation on the water, you said thatradionuclides were significantly below DOE standards. Does that mean that theyare detectable?


Many radionuclides are naturally occurring in soils and groundwater. Activities of radionuclides detected in Pantex Plant groundwater samples werewithin the range of natural background water chemistry.

RC: 06.055

Doc: HT17/19

... I'm concerned, as Ms. Smith is, with the threat that I see to thefarmer in this community. When we see already that some of this stuff hasleached down into the Ogallala aquifer, and people...keep shooting off them testthings out there and all that, and they have all them cracks and stuff in theground.


Pantex Plant is currently conducting groundwater treatabilityinvestigations in conjunction with their ongoing environmental restorationprogram efforts. Contaminated groundwater is pumped out of the perched aquifer,treated in a carbon-filtration system to remove high explosive contamination,and then pumped back into the perched aquifer. When the treated groundwater isreintroduced into the perched aquifer it flushes and displaces the existingcontaminated groundwater, moving it toward the treatment system wells forcleanup. As stated in comment 06.020, the subsurface sediments in the OgallalaFormation consist of unconsolidated sand, silt, clay, and gravel; there are nocracks or fractures. Groundwater moves through void spaces betweenunconsolidated sand, silts, and gravels, and is being treated at an approximaterate of 42,000 gallons per day.

RC: 06.056

Doc: HT17/40

Pantex is a Superfund Site. We now have confirmed contamination in theOgallala Aquifer. It would seem that before we rush headlong into new missions,bringing new waves of radioactive pollution to this plant, that the documentshould at least address the effort to mitigate pollution already onsite. Itreally doesn't.


Additional information, including a description of the GroundwaterProtection Project and Corrective Action Plan for ditches and playas has beenadded to volume I, section For additional detail, see discussion insection 1.3.5 of this volume.

RC: 06.057

Doc: HT17/56

... There is no recognition that the Ogallala aquifer is the only source ofgroundwater for the entire Texas Panhandle, the South Plains, and parts of sevenother Midwestern states. The siting of hazardous and radioactive operationsover this finite water source is totally unacceptable. There is no substitutefor water.


See discussion in section 1.3.5 of this volume. The following sentencehas been added to the description of the Ogallala aquifer: "The Ogallalaaquifer underlies the whole of the Texas Panhandle, the South Plains as well asparts of New Mexico, Oklahoma, Colorado, Kansas, Nebraska, Wyoming, and SouthDakota."

RC: 06.058

Doc: PC-017/10

There are at least seven playa lakes just off the Pantex site on all sidesof the plant. Rainwater runs off the plant site into barrow ditches around theplant and drain into those offsite playas. This drainage is not addressed inthe PEIS. The Pantex lake receives none of the runoff. Why were the otherplayas excluded? The watershed on the south of Lake Meredith, a reservoir for13 cities, begins on the northwestern corner of Pantex. Water from that sectionof the plant (where the various EIS's show a nuclear reactor or two may beconstructed) runs into Lake Meredith.


EPA Region 6 NPDES Permit No. TX-0107107 authorizes Pantex Plant todischarge to the waters of the United States, under specified effluentlimitations and monitoring requirements. According to this permit, thedischarge from Pantex Plant is directed into four playa lakes, located adjacentto the waterbody of McClellan Creek, which flows into the North Fork of the RedRiver (Waterbody Segment Code No. 0224 of the Red River Basin). There are noknown surface water connections that could transport potential contaminants fromPantex Plant into the Canadian River. Due to the flat, level topography of thePantex Plant, streams are not well developed on the landscape and surface watersdrain to the playa basins, as discussed in volume I, section In theevent that contaminants were transported by surface runoff, the contaminantswould remain within the designated watershed (Pantex 1996).

RC: 06.059

Doc: PC-017/11

Page 4-79. Use of water from the perched aquifer and also the Ogallalaaquifer is just not true, as contamination is in the domestic wells of aneighbor to the east of the plant and a well to the south of the plant. Why arefalse statements being made? What measures are being taken to clean up thewater offsite? This contamination must be coming from the "Pantex AQUIFER." Pantex aquifer is a result of the waste being run into on site playas. Howwill the contamination of the Ogalala be cleaned? How do you determine "insignificant"amounts? Does DOE define "insignificant" as anything or amount theDOE does not want the public to believe may be harmful? Can "insignificant"amounts become "significant" if ingested or exposed over long terms? What is the long-term effect on health and safety?


Minute traces of high explosive contaminants were detected in theOgallala aquifer after publication of the Draft Pantex EIS. Volume I, section4.6.1.2, has been amended to provide the updated information. The relationbetween the past practices and contamination of the perched aquifer is discussedin detail in section 1.3.5 of this volume. The significance of the amounts ofany contaminants is considered by comparing the concentration to regulatorystandards which are based, in part, on health effects. Five years of surfacewater and groundwater quality data have been compared to site-specific permitlimits, DOE derived concentration guides for radionuclides and Federal and Statedecision criteria. Concentration limits have been based on State and Federaldrinking water regulations and health advisories.

RC: 06.060

Doc: FG-003/4

Page 4-57, second paragraph: In this paragraph and at other places in thetext it is asserted that the discharge water from the plant meets the surfacewater quality permit requirements. Because it is acknowledged in the documentthat leakage from waterways and playas enters the ground, EPA guidelines forgroundwater quality are of concern here. Under EPA's "Strategy for the90's" report of the Ground Water Task Force, the Maximum Contaminant Levels(MCLs) established under the Safe Drinking Water Act (SDWA) are to beused as reference points in evaluating groundwater quality. This Draft EIS alsorecognizes the significance of these MCLs when it lists them as "decisioncriteria" for ground water analyses presented in volume II. Therequirements under the National Pollutant Discharge Elimination System (NPDES)do not include all of the contaminants for which MCLs have been set for publicwater supply systems under the Safe Drinking Water Act and in many casesthe limits set under NPDES are higher than those under the SDWA. Under thesecircumstances, we recommend that Pantex consider protecting the groundwater byeither lining the ditches and playas with the level required to maintain, orrestore to, SDWA MCLs in the groundwater. Discussion on this matter should beincluded in the Final Statement.


Detailed information regarding the status and conditions of wastewaterdischarge permit limits is provided in section 1.3.5 of this volume. TNRCCWastewater Discharge Permit No. 02296 (as amended) requires that within one yearof the effective date of the permit (June 14, 1996), Pantex Plant must conduct astudy that determines the feasibility of eliminating or minimizing discharges toplaya lakes and open ditches or improving the quality of discharge. The studyshould, at a minimum, include the following proposals:

(1) upgrading existing treatment facilities or constructing newtreatment facilities to ensure no groundwater quality effects from discharges toplaya lakes and ditches,

(2) construction of synthetically-lined impoundments to confine treatedeffluent and a closed collection system from all process areas to the treatmentfacilities,

(3) establishment of an irrigation disposal site and accompanyingdisposal practices plan to eliminate discharges to the playa lakes,

(4) establishment of a reuse and conservation program for all processwastewaters, thereby eliminating any industrial effluent discharge to the playalakes and ditches, and

(5) development of a schedule for completion of proposals or any otherproposals deemed feasible by the permittee.

A Groundwater Contamination Assessment Report is being developed as partof the RCRA Facilities Investigation Work Plan, in association with the DraftRCRA Permit. Discussion of the requirements of the applicable wastewaterdischarge permits has been updated in volume I, section, and volume II,appendix C.

RC: 06.061

Doc: FG-003/5

Page 4-62, last paragraph: The first bullet describes "unsaturatedsands of the Blackwater Draw Formation and upper Ogallala" at the surface,but the diagram on page 4-64 indicates that the Blackwater Draw Formationconsists of clay. This inconsistency should be clarified in the FinalStatement.


The referenced discrepancy has been clarified by referring to "Unsaturatedsands and clays..." in volume I, section

RC: 06.062

Doc: FG-003/6

Page 4-65, third paragraph: It is stated that the perched aquifer "exhibitsradial flow." By way of clarification, the Final EIS should note that theflow is radial from Playa #1, suggesting that the playa is a major source ofrecharge locally.


Comment noted. The phrase "from Playa 1" has been added tothe referenced text in volume I, section

RC: 06.063

Doc: FG-003/7

Page 4-67: The map illustration depicts a domestic water well to thesoutheast of the Pantex property, just outside the area of the perched aquifer. The well appears to be in the flow area of the perched aquifer. The wellappears to be in the flow direction of the groundwater in the perched aquiferand may be in danger of contamination from groundwater in the perched aquifer. The Final EIS should identify the boundaries of the contaminated perched aquiferand establish what risk may exist, if any, for the potential contamination ofthe Ogallala aquifer.

Volume I, section, has been updated with the most currentinformation available.

RC: 06.064

Doc: FG-003/8

Page 4-71, third paragraph: It is indicated here that the quality ofsurface water being discharged is described earlier at section However, there is no description of the discharge water quality at the pointcited. It would be helpful if the FEIS could provide a complete description ofthe discharged water chemistry within the text.


A comprehensive description of the discharged water chemistry isprovided in volume II, appendix C. The referenced text has been modified torefer the reader to volume I, section, and volume II, appendix C, wheredescriptions/tabulations of the discharge water chemistry are provided.

RC: 06.065

Doc: FG-003/9

Page 4-72, second paragraph: It is difficult to visualize all theinformation about water quality and contaminant locations described here. [It]would be helpful to have one map to display this information in the FinalStatement. It would also be helpful if the FEIS could have a section describingthe past and current chemical quality of discharges. Section 4.6.1 makes ageneral attempt at this goal but is too generalized. The Final Statement shouldlist specific contaminants and major components of water chemistry, and describeany changes through time. A table showing concentration ranges, averages, etc.,would be appropriate for this discussion.


This type of information (specific contaminants and major components ofwater chemistry, source areas, and changes in concentrations through time) iscompiled in the Draft RCRA Facility Investigation (RFI) and will be available tothe public upon final regulatory approval. Figure has been added tovolume I, section to show the distribution of RDX concentrations in theperched aquifer. Information regarding past chemical discharges are discussedin volume I, sections and 4.6.1. Table in volume I listssource areas of suspected contaminants of concern to groundwater resources. Water quality summary tables that show average and maximum concentrations for a5-year timeframe are provided in volume II, appendix C.

RC: 06.066

Doc: FG-003/11

Two sites at the Nevada Test Site (NTS) were assessed for the interimstorage of plutonium pits, the P-Tunnel area and the Device Assembly Facilityarea. The Pantex DEIS (volume I, p. 5-8) indicates that groundwater at the twoNTS sites is characterized by a "deep water table," although depth togroundwater is not specifically quantified in the DEIS. A prior Department ofEnergy EIS reviewed by EPA Region 9 (FEIS, Tritium Supply [and] Recycling,October 1995, volume I, p. 4-114) stated that the depth to groundwater at NTSranges from 500 to 2,400 feet. The tritium FEIS also indicated that "thereare...areas of perched water that lie at considerably shallower depths" atNTS.


The referenced sentence in volume I, section, has been modifiedto give the range of depths to groundwater. The Pantex EIS only deals with theinterim storage of pits at the Device Assembly Facility, located adjacent toYucca Lake, and P-Tunnel at Ranier Mesa. The plutonium pits would becontainerized and stored in these existing facilities. As a result, groundwaterresources would not be affected by these storage activities.

RC: 06.067

Doc: FG-003/14

The Pantex FEIS should discuss whether either of the areas is characterizedby "perched considerably shallower depths..." as describedin the Tritium FEIS. If so, the groundwater impacts that are reasonablyforeseeable should the plutonium pits be damaged in a quake.


Plutonium pits would be placed in sealed containers that are designed towithstand impact. Thus, the contents are not expected to come into contact withgroundwater.

RC: 06.068

Doc: HT17/69

... I understand this [the Pantex EIS] there...are some omissionswhich have been brought out. ...It has been noted that there's nothing saidabout the Superfund Site projects in the study, and it would seem that thatmight be something important to look at. All of us around here notice therecognition of the Ogallala aquifer, as it is probably, in the United States,the largest fresh water aquifer.


As stated in volume I, section 6.4, Pantex Plant is working with the EPAand TNRCC to develop a tri-party Federal Facility Agreement to outline reportingrequirements, schedules, and funding for the Environmental Restoration Program. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)efforts are being integrated into the existing Resource Conservation andRecovery Act (RCRA) Facility Investigations, corrective measures studies, andcorrective measures implementations that are described in volume I, sections4.5.1.3,, and Language describing the extent of the Ogallalaaquifer has been added to volume I, section

RC: 06.069

Doc: PC-025/24

On Page 4-56, buildings listed do not appear to match diagram on page 4-243.Figure appears to be crowded with information. Recommend simplification.


Figure in volume I has been revised and simplified.

RC: 06.070

Doc: PC-025/25

On Page 4-60. Please explain. If a playa is a wetland [and] a wetland isconsidered waters of the United States...why is a playa not [considered] watersof the State?


In 1990, Pantex playas 1 through 4 and Pantex Lake were determined to bejurisdictional wetlands by the U.S. Army Corps of Engineers, and are thereforeconsidered to be waters of the United States subject to protection by theNational Pollutant Discharge Elimination System (NPDES). TNRCC Permit No. 02296has been amended (effective June 14, 1996) in accordance with the EPA Region VINPDES Permit No. TX-0107107 that became effective on June 1, 1996. Volume I,section, has been updated to discuss the terms and conditions of thesenew permits.

RC: 06.071

Doc: PC-025/26

... Do the number of wells located on the Pantex site represent significantpathways to increased groundwater contamination? What measures are taken tocontrol this pathway? In the event of a plutonium accident what is thepossibility that the well is open and plutonium enters the groundwater throughthe monitoring system? Assuming the well was open during an accident, what isthe release to the groundwater? What is the impact if Pantex loses groundwaterusage? Adjacent land owners?


The low vertical permeability of the fine-grained zone could potentiallybe compromised by abandoned homestead wells that could provide contaminantpathways through the fine-grained zone to the Ogallala aquifer. As aprecautionary measure, DOE has identified and sealed abandoned homestead wellsin order to prevent potential pathways of contamination into the Ogallalaaquifer under the Groundwater Protection Project. These precautionary measuresand other key aspects of the Groundwater Protection Project are discussed involume I, section In the event of plutonium accident, the plume wouldhave to pass over the open well at the times it was open. This probability wouldbe an order of magnitude less than the probability of a plutonium accident (seevolume I, section 4.14). The amount of plutonium that could get into an openwell is difficult to predict. Based on the small cross-section of the well andthe large area over which plutonium would be spread in an accident, the amountwould be very small.

RC: 06.072

Doc: PC-025/27

On page 4-63, why was OW-WR-20 utilized in cross section when the crosssection should go from 6-1003 to 6-1004 to 6-1005? Why was 6-1015 left out? What are the impacts if these wells are utilized? What is the quality of thehydrostatic cross section input data (i.e. well logs)?


The referenced cross section was taken from DOE 1994nn. OW-WR-20 wasutilized because the water quality of this well is discussed in volume I,section Perched monitor well 6-1015 was not included in the crosssection on the original reference and was not available at the time ofpublication of the Draft Pantex EIS. The referenced cross section has beenreplaced with an updated north-south trending cross section (Figure shows the axis of the paleochannel.

RC: 06.073

Doc: PC-025/28

On Pages 4-66 and 4-67. Why did you change nomenclature on PM-21 (466) andOW-WR-21 (467)?


Figure in volume I has been revised to refer to OW-WR-21,rather than PM-21.

RC: 06.074

Doc: PC-025/29

On Pages 4-66 and 4-67, why arent wells PXSP-OIA, PXSP-03, PXSP-04, etc.listed in appendix C, table C.2.1-1? What level of QA has been completed onthis section? Please include QA/QC certification documentation in appendixincluding signatures of key QA/QC personnel. Please provide documentationassuring QA/QC measures were implemented, met established goals, and necessarycertification exists.


The Draft Pantex EIS was prepared with available information supplied byPantex Plant. The references for Figures and in volume I areprovided in the referenced text. Data from all referenced well logs that weremade available by the time of publication were utilized and included in volumeII, appendix C. The administrative record includes files that provide QA/QCcertification documentation. Volume II, appendix C has been updated withadditional information that has become available since the publication of theDraft Pantex EIS.

RC: 06.075

Doc: PC-025/30

On page 4-67, why are wells off the Pantex Plant lacking well numbers?


The locations of offsite wells are shown. These wells are on privateland and data from these specific wells are considered private. Data have beenprovided to the extent practicable. Well numbers are provided for all onsitewells that are monitored by the Environmental Protection Department or by theEnvironmental Restoration Program. Inclusion of well numbers would not serveany purpose for this document. Please note that a map showing all vicinitywells has been added to volume I, section (Figure

RC: 06.076

Doc: PC-025/31

... Table, page 46-8. What is the reason the realistic estimateis an order of magnitude larger than the most conservative?


Aquifer performance tests were used to estimate groundwater velocities. The results of these aquifer tests are highly variable and are dependent on thetesting location and relative heterogeneities in the subsurface sediments fromone location to another, the duration that the test is run, variations intesting procedures, and the method of analysis. These variations in aquiferperformance testing lead to differences in groundwater velocity estimates.

RC: 06.077

Doc: PC-025/32

... What is the source of the statement "These perched zones arebelieved to be hydraulically separate from the perched aquifer in Zone 12 atPantex Plant?"


The referenced statement was provided as a personal communication(February 1996) from the Pantex Environmental Restoration (ER) Department, basedon the best available information at the time of publication of the Draft PantexEIS. Volume I, section, has been updated with additional informationthat has been provided by the Pantex ER Department since February 1996.

RC: 06.078

Doc: PC-025/33

And Page 4-69 in Ogallala aquifer section. Vicinity of ROI, more accurate?


The referenced text has been modified to state, "The Ogallalaaquifer is the principle aquifer and major source of water in the vicinity ofPantex Plant and surrounding region of influence," and "The Ogallalaaquifer underlies the Texas Panhandle and the South Plains, as well as parts ofNew Mexico, Oklahoma, Colorado, Kansas, Nebraska, Wyoming, and South Dakota."

RC: 06.079

Doc: PC-025/34

... Why aren't wells OW-WR-23, and 28 listed in Table C.2.1-1? DoesOW-WR-40 leak water to the perched from the contaminated Playa l? Is OW-WR-40above or below the floodplain? Are any of the well heads located in the PantexPlant or vicinity below any floodplain? What are impacts if there are [any]?


OW-WR-23 and OW-WR-28 are not wells. They are drinking water samplinglocations at Buildings 12-2 and 12-6 Cafeteria respectively. The referencedfigure has been corrected. Monitoring well OW-WR-40 is screened (or open togroundwater flow) from 580 to 610 feet below ground surface, within the Ogallalaaquifer. The fine-grained zone occurs well above the screened interval at adepth of 252 to 356 feet below ground surface. Because the well is onlyscreened in the Ogallala aquifer, the thickness of the fine-grained zone, andthe vertical distance (over 200 feet) between the perched aquifer and theOgallala aquifer, OW-WR-40 does not leak water to the perched aquifer from Playa1. Based on our review of five years of data, Ogallala monitor well OW-WR-40only exceeded decision criteria for one constituent, iron, during 1990, 1991,and 1993. However, no contamination from high explosives, organic compounds, orradionulcide contaminants of concern have been detected in this well. Accordingto the 1995 Environmental Report for Pantex Plant (Pantex, 1996c:87), "Therewas no indication of contamination by radiological constituents, metals,explosives, or organic compounds in Ogallala monitoring wells, and there was noevidence of contaminated groundwater from the overlying perched zone reachingthe aquifer." Details regarding the protection of cross-contamination fromhomestead wells are addressed in section 1.3.5 of this volume.

RC: 06.080

Doc: PC-025/35

Page 4-76. I'm confused, how can a zone be a source but a landfill is alocation? What does 12-5W, etc. mean? What is OSTP?


The "source" refers to the particular area of the plant wherecontaminants of concern potentially originated. The "location" refersto the specific building, landfill, leach bed, etc. within that source area. Designations such as 12-5W refer to specific buildings within the respectivezone, (e.g., Building 5W in Zone 12). OSTP is the acronym for the Old SewageTreatment Plant. Acronyms are defined in the EIS with their first usage and inthe list of acronyms and abbreviations.

RC: 06.081

Doc: PC-025/36

Appendix C is difficult to review in support of section 4.6 because DOEflip-flops the nomenclature for well numbers. As an example, table C.2.1-1 [hasthe] well ID as 15-20, but C.2.2-3 [has] PR-16, please standardize. On page4-77 isn't it three wells for lead: PR-16, OM-39, and PR-41?


Primary well numbers have been standardized for clarification. Thereferenced text in volume I, section, has been modified to state "...andlead in three wells...".

RC: 06.082

Doc: PC-025/37

Page 4-78. What is the source of the 704 million liters? What is the sourceof the 760 irrigation wells? What is the source of the two private wells? Do yoususpect more? What would be the impact of more perched wells?


The referenced text has been updated and revised. The updated source ofdata for Pantex Plant wells is the 1995 Environmental Report for Pantex Plant(Pantex, 1996c). Updated irrigation well data was provided by PanhandleGroundwater Conservation District No. 3 and the Farm Service Agency. The impactof more perched wells would be dependent on the wells intended use. Perchedmonitoring wells provide additional sources of information about the waterquality, potential contaminants of concern, and changes in chemicalconcentrations with time. Recovery wells are being used to pump contaminatedgroundwater out of the perched aquifer for treatment. However, if contaminatedgroundwater within the region of influence were used for domestic oragricultural uses, several potential pathways of exposure (e.g., ingestion,bathing, other potable water or agricultural uses) could result. DOE hasconducted a Groundwater Protection Project as a mitigation measure. Foradditional information about private perched wells, see discussion in section1.3.5 of this volume.

RC: 06.083

Doc: PC-025/38

Page 4-79, "the quality of the wastewater discharge is such that itwill not degrade..." What is the source of the statement? Please explainposition in greater detail. Doesn't the playa carry contaminants to theOgallala? If (regionally) perched water is used to supply cattle with water,would WWTF water be used as cattle drinking water. If not, how can the abovestatement be true?


The quality of wastewater discharge will not degrade the perched andOgallala aquifers, because the wastewater discharge is regulated through the EPARegion VI NPDES Permit and TNRCC Wastewater Discharge Permit. For additionalinformation regarding these permits refer to section 1.3.5 of this volume andthe updated discussion in volume I, section Surface water outfalls aremonitored to assure that the discharge water quality is within the specifiedpermit limits. Similarly, perched and Ogallala groundwater is monitored inonsite and offsite locations to assure that human health and the environment arebeing protected. The hydrology and recharge of the perched aquifer is verycomplex and the effects upon the vadose zone from continual discharge of waterinto the existing lakes and drainage ditches does not necessarily result incontaminated groundwater being driven into the Ogallala. The trace levels ofhigh explosive constituents that were detected in an offsite private well werebelieved to be due to special circumstances; see discussion in section 1.3.5 ofthis volume. Environmental Restoration (ER) investigations, conducted at orbefore the time of publication, have indicated that the extent of offsitecontamination detected in the perched groundwater has been limited to withinone-half mile southeast of the main Pantex Plant Site boundary. The ER programis currently conducting corrective actions, such as interim measures to remove "hotspot" areas of contaminated soils, to protect human health and theenvironment as discussed in section 1.3.5 of this volume.

RC: 06.084

Doc: PC-025/39

In Table 4.6.2-1, are margins included? Why is the liter conversionincluded?


The annual rates referenced in volume I, Table 4.6.21, include a 10percent margin. Liter conversion is included to comply with DOE policy.

RC: 06.085

Doc: PC-025/40

Table and Table have different sources.


No, both tables have a common source: Banner, E., Data Needs for theNew Projects at Pantex Plant SWEIS request for information supplied by M.Lincoln, Battelle Pantex, Amarillo, TX, May 17, 1995 (PC 1995g).

RC: 06.086

Doc: PC-025/41

In section, starting on page 481: What are the sources of water usein each of the 6 projects?


The source of water for the new facility construction and upgrades,discussed in volume I, section, would be Pantex Plant wells. As stated in section 1.3.5 of this volume, the upper bounding conditions (i.e., 2,000weapons level) would result in a projected annual groundwater withdrawal of1,011 million liters (267 million gallons), or an increase of 64 percent over FY1995 water use. Furthermore, under the 2,000 weapons scenario, Pantex Plantgroundwater withdrawals would only account for 0.8 percent of the totalestimated annual groundwater withdrawals in Carson County.

RC: 06.087

Doc: PC-025/92

Water resources methodology is flawed since the analysis is based onexamining permitted discharges of the NPDES system for which Pantex does nothave a permit (the permit is pending). Groundwater analysis is flawed sincegroundwater quality within the [region of influence] ROI [is analyzed] but theanalysis does not include other industrial, commercial, petroleum exploration(especially saltwater intrusion, and secondary recovery impacts), CERCLA andRCRA sites contaminating the groundwater. The analysis does not analyze thecontamination of the groundwater by underground storage tanks or agriculturenitrates. This information is readily available through the State of Texas. Yourmethodology specifically calls for ROI analysis of readily availableinformation. The analysis is further flawed because of the lack of analysis ofplayas within the ROI. Finally the analysis ignores the number of wells locatedin the ROI as potential contamination pathways to the Ogallala or whether any ofthese wells [are] resident in a floodplain. The analysis does not include ROIdamage from farming and livestock (e.g., nitrogen, pesticides, herbicides,insecticides).


Impact Assessment Methodologies are provided in volume I, section 4.2. Cumulative impacts include impacts of continued operations at Pantex Plantcombined with other reasonably foreseeable projects that could impact theenvironment at the plant site or in its region of influence (ROI). Theseinclude programs examined in Programmatic EISs for waste management, stockpilestewardship and management, and the storage and disposition of weapons-usablefissile materials. Information about new Federal proposed projects was sought,however, no information was forthcoming. The ROI for water resources includesPantex Plant and the surrounding area that could potentially be impacted byplant operations. The ROI for surface water is the onsite playas and ditchsystem, and floodplains delineated by the Army Corps of Engineers, as discussedin volume I, section The ROI for the perched aquifer is based on theextent and migration of contaminants, and is discussed in detail in volume I,section Although the ROI for the Ogallala aquifer has not beenquantifiably defined, it is limited to the extent of drawdown in Pantex Plantwells. The quantity of groundwater pumped from Pantex Plant wells issignificantly less than for irrigation and for municipal water use, as discussedin section 1.3.5 of this volume. Volume I, section, has been updated toaddress sealing homestead wells located in the ROI that could provide potentialcontamination pathways to the Ogallala. Damage from other land and waterapplications outside of the ROI is beyond the scope of this document.

RC: 06.088

Doc: CO-008/114

C-6, Table C.1.2-3. Results from sampling and analyses from Bushland areprovided as "background". Because some concentrations of analytesfrom Bushland samples exceed those measured in Pantex samples, how do youjustify presenting these data as "background"?


The control well at Bushland is completed in the Ogallala aquiferupgradient from Pantex Plant and is, therefore, unaffected by plant operations(Pantex 1995c:82).

RC: 06.089

Doc: CO-008/115

C-11, Table C.1.2-3. Provide a table that cross-references locationdescriptions for surface water. This would allow readers to recognize thelocations at which samples reportedly exceeded or lacked water quality criteria(this table). (Table C.2.1-1 on page C-21 provides similar cross-referenceinformation for the water wells.) Some of these locations appear to be playas,waters of the U.S., but it is difficult to tell from the descriptions.


The requested information is provided in volume I, Table

RC: 06.090

Doc: CO-008/116

C-13, Table C.1.2-3. Hexavalent chromium is shown to exceed the "standard"for 12-17 N, OW-WR-34, and Z-12-S. What was the total chromium for these samesamples (i.e., did the concentrations of hexavalent chromium in these samplesexceed the measured concentrations of total chromium in the same samples? [inwhich case the reported concentrations of hexavalent chromium may beexaggerated].)


Average hexavalent chromium concentrations that exceeded the decisioncriteria (and year of exceedance) are listed below:

· 12-17-N - 0.12 mg/L (1990)

· OW-WR-34 - 0.20 mg/L (1994) Bushland control sample.

· Z-12-S - 0.2 mg/L (1990)

The following are corresponding average total chromium concentrations:

· 12-17-N - 0.12 mg/L (1990)

· OW-WR-34 - 0.009 (1994) Bushland control sample.

· Z-12-S - 3.5 mg/L (1990)

Note that the hexavalent chromium concentration appears to beexaggerated on the Bushland control sample.

RC: 06.091

Doc: CO-008/117

C-28, Table C.2.2-1,...third line up from the bottom. The line reads "ParameterUnits STD RRS." Is this an error?


Yes, this was an error and the referenced line has been deleted involume II, Table C.2.21.

RC: 06.092

Doc: PC-026/1

Evidently Pantex continues to use open, unlined ditches to dispose of wastewater and storm water [that] discharges into the playas onsite. ...Theyare contaminated, and the Ogallala aquifer can also become contaminated. Thisis very scary.


Wastewater discharge permit requirements, upcoming investigations, andinterim corrective action measures are summarized in section 1.3.5 of thisvolume. The EIS has been updated accordingly.

RC: 06.093

Doc: PC-029/1

It seems to me that storing radioactive substances over the Ogallala aquiferis not a good idea. Is it true that high explosives from Pantex have been foundin the Ogallala? Have wells in the area been contaminated with plutonium?


See discussion in section 1.3.5 of this volume.

RC: 06.094

Doc: SG-002/1

The TNRCC is concerned that contamination in the perched aquifers beneaththe site indicates that past and present industrial discharge practices at thePantex facility have not been fully protective of natural resources at the site.The DOE should [ensure] that the threat of increased contamination to theOgallala aquifer and contaminant exposure to ecological receptors is limited tothe maximum extent practical.


See discussion in section 1.3.5 of this volume and response to comment06.051.

RC: 06.095

Doc: SG-003/18

The TNRCC is concerned that contamination in the perched aquifers beneaththe site indicates that past and present industrial discharge practices at thePantex facility have not been fully protective of natural resources at the site. The DOE should insure that the threat of increased contamination to theOgallala aquifer and contaminant exposure to ecological receptors is limited tothe maximum extent practical.


See discussion in section 1.3.5 of this volume and response to comment06.051.

RC: 06.096

Doc: SG-003/21

The Trustees do not oppose the DOE plan to construct an expanded HazardousWaste Treatment and Processing Facility (HWTPF). However, contamination in theperched aquifers beneath the site [indicates] that past and present industrialdischarge practices at the Pantex facility have not been fully protective ofnatural resources at the site. A treatment facility that is constructed andmaintained properly will prevent further injury to natural resources. Inaddition, the increase of industrial discharge volume to 2.9 million liters mayexacerbate contamination problems if additional measures are not taken by DOE toprotect valuable groundwater resources. DOE should [ensure] that the threat ofincreased contamination to the Ogallala aquifer and contaminant exposure toecological receptors is limited to the maximum extent practical.


A treatment facility, such as the HWTPF, that is constructed andmaintained properly will prevent further injury to natural resources. Additional measures that are being taken to ensure that the threat of increasedcontamination to the Ogallala aquifer and contaminant exposure to ecologicalreceptors is limited to the maximum extent practical are discussed in section1.3.5 of this volume.

RC: 06.097

Doc: SG-003/24

Page 4-2, Affected Environment. The document states that an area of 50 milessurrounding the Pantex site will be considered the region of influence. TheTrustees are concerned that this area will not encompass the potential area ofnatural resources that could be impacted since: a) the lateral extent of theperched aquifer has not been determined, and b) documented contamination in theOgallala and its flow direction provide the potential for this contamination toimpact various environmental receptors outside this radius.


Environmental restoration investigations, conducted at or before thetime of publication, have indicated that the extent of offsite contaminationdetected in the perched groundwater has been limited to within one-half milesoutheast of the main Pantex Plant site boundary. The distance of 50 miles istraditionally used as the maximum extent of a region of influence for NEPAdocuments.

See response to comment 06.087.

RC: 06.098

Doc: SG-003/26

Page 4-3, Section 4.2 Impact Assessment Methodologies, water resources: Thequalitative assessment of water quality impacts from wastewater and stormwaterrunoff does not adequately address potential impacts to surface water andgroundwater resources at the Pantex Plant. Furthermore, it does not considerexisting contamination in the sediments, surface water, and groundwater andtheir cumulative impacts. The text should be corrected to reflect what actionswould be necessary to thoroughly address the potential impacts to these naturalresources.


Volume I, sections 4.5 and 4.6, have been updated with additional data,new permit requirements, and descriptions of corrective action measures.

RC: 06.099

Doc: SG-003/29

Page 4-55, Affected Environments. The text states that there is [no]evidence that contaminants found in the perched zone have migrated to theOgallala aquifer. This is inaccurate and should be corrected to reflect thatthere is documented contamination in the Ogallala aquifer.


Groundwater quality sampling that was conducted after the publication ofthe Draft Pantex EIS indicated that contaminants found in the perched zone hadbeen detected (in small amounts) in the Ogallala aquifer. Volume I, section4.6.1.2, has been updated to report potential contamination in the Ogallalaaquifer. For additional information, refer to the summary provided in section1.3.5 of this volume.

RC: 06.100

Doc: SG-003/30

Page 4-62, Section Groundwater. While the discharges that arepermitted by EPA and TNRCC have protective standards [that] presently do notallow excessive levels of contaminants, existing contamination is alreadypresent in the perched aquifer and the playas. Therefore, the continualdischarge of wastewater provides a hydraulic head potentially driving thosecontaminants into the Ogallala. Contamination in the Ogallala has beendocumented and more stringent actions are required in order to prevent furthermigration of contamination [that] could result in greater injury to an extremelyvaluable groundwater resource.


We disagree. The hydrology and recharge of the perched aquifer is verycomplex and the effects upon the vadose zone from continual discharge of waterinto existing playa lakes and drainage ditches do not necessarily result incontaminated groundwater being driven into the Ogallala. The Ogallalacontamination which is referenced is believed to be due to special circumstances(cross-contamination through an open bore homestead well). This well and sixother homestead wells have been sealed under the Groundwater Protection Project. See discussion in section 1.3.5 of this volume and section of volume Ifor additional information.

RC: 06.101

Doc: SG-003/31

Page 4-69, Section Groundwater, Perched Aquifer portion. Seecomment #9.


See response to comment 06.099.

RC: 06.102

Doc: SG-003/32

Page 4-72, Groundwater Quality. The absence of trinitrotoluene in theperched aquifer may not be due to a reduction in the discharge of thiscontaminant, but rather an indication of it breaking down to degradationcompounds in the environment. Also, the text states that levels oftrichloroethene occurring at the site barely exceed the Risk Reduction Standards(RRS) decision criteria of 5 micrograms per liter. Data used to make thisdetermination may not be representative of actual levels of contamination at thesite. To accurately determine what is occurring at this site, properly screenedintervals in groundwater monitoring wells to accurately measure "sinkingchemicals, metals, radionuclides and high explosives," as well as theproper suite of analyses, should be employed for all potential contaminants ofconcern.


Concur, evidence of natural attenuation and degradation of highexplosive compounds including trinitrotoluene has documented during thetreatability studies. The maximum concentration of trichloroethene (i.e.,trichloroethylene) has consistently occurred in the perched aquifer south ofZone 11 in monitoring well PTX08-1005 as discussed in the Draft RCRA FacilityInvestigation Report for Groundwater in Zone 12 at the DOE Pantex Plant (Argonne1995a). In order to define the stratification of contaminants within theperched aquifer, due to different densities of the contaminants, it is necessaryto sample at discrete intervals and depths. Volume I, section, has beenrevised accordingly.

RC: 06.103

Doc: SG-003/33

Page 4-78, Section Impacts of Continued Operations, Weapon-Relatedactivities, Surface water. A thorough evaluation and consideration of existingcontamination in surface water and sediments of receiving waters at the Pantexsite is needed to adequately assess the potential impacts of wastewaterdischarges. Cumulative impacts of preexisting contamination and projected wasteloads must be considered.


See discussion in section 1.3.5 of this volume.

RC: 06.104

Doc: SG-003/34

Page 4-80, Section, Groundwater. The TNRCC permit does not includeradionuclide parameters. In order to prevent further injury to naturalresources, DOE regulatory oversight should be shared with another appropriateagency....


See discussion in section 1.3.5 of this volume and response to comment06.051.

RC: 06.105

Doc: SG-003/35

Ogallala ContaminationThe EIS should be revised to reflect that the Ogallalahas been impacted by Pantex operations, as evidenced in recent contaminatedsamples obtained from Mr. Cockrell's private off-site wells.


Although low levels of high explosive contamination have been detectedin a domestic Ogallala well located on the Cockrell ranch, efforts to mitigatefurther contamination have been completed. The well in question has beenproperly plugged and abandoned under the supervision of the TNRCC and areplacement Ogallala well has been drilled and completed in order to preventfurther potential cross-contamination of the Ogallala aquifer. Additionalinformation regarding the Groundwater Protection Project has been included involume I, section

RC: 06.106

Doc: SG-003/36

Homestead WellsThe EIS should note that the low vertical permeability of thefine-grained zone may be compromised by abandoned homestead wells. These wellscould provide contaminant pathways through the fine grained zone to theOgallala. The potential for this to occur has been demonstrated at the Cockrellfarm east of the Pantex Plant.


Efforts to identify and evaluate abandoned homestead wells in order toprevent potential pathways of contamination into the Ogallala aquifer have beencompleted under the Groundwater Protection Project.

RC: 06.107

Doc: SG-003/37

Facility BoundaryThe EIS should mention that DOE will take whatever actionis practicable to clean contaminated groundwater to the residential drinkingwater standards beyond the facility boundary (page 4-69).


See discussion in section 1.3.5 of this volume and response to comment06.051.

RC: 06.108

Doc: SG-003/40

Pantex Plant PlayasThe Risk Reduction Rules (RRR) (30 Texas AdministrativeCode (TAC),...335, Subchapter S), which include references to the Texas StateWater Quality Criteria (30 TAC...307), do apply directly to the Pantex PlantPlayas, contrary to the statement on page C-2.


Refer to the discussion of surface water quality decision criteriapresented in section 1.3.5 of this volume.

RC: 06.109

Doc: SG-003/41

Surface Water Quality ValuesThe surface water quality values determined inaccordance with the RRR take precedence over the Risk Based ConcentrationGuidelines from EPA Region 3 (Section C.1.2). The EPA Region 3 Guidelines arenot appropriate standards to apply when values are available in the TexasSurface Water Quality Criteria, the Federal Safe Drinking Water Act, orthe Texas Regulations for Control of Radiation (TRCR) (30 TAC...336).


Refer to the discussion of surface water quality decision criteriapresented in section 1.3.5 of this volume.

RC: 06.110

Doc: SG-003/42

Tables C.1.2-1 through C.1.2-3the standards listed in Table C.1.2-1 shouldcite values based on the RRR, rather than EPA Region 3 Guidance. For instance,the standard for antimony should be 0.006 milligrams per liter (mg/L), based onthe RRR, rather than 0.015 mg/L cited for EPA Region 3 Guidance. The standardfor gross alpha activity, according to the RRR, should be 15 picocuries perliter (pCi/L), rather than N/A. No water quality standard is provided by theTexas Surface Water Quality Criteria; therefore, the RRR specify use of thedrinking water standard. The proposed drinking water standard of 50 pCi/L (4millirems per year) should also be cited for beta particle activity. The TNRCCrequests that DOE revise Table C.1.2-1 to cite the more stringent surface waterquality standards for radionuclides that are developed in accordance with theRRR. As such, the standard for plutonium-239/240 would be 2E-8 microcuries permilliliter (mCi/ml), based on the TRCR standards. Radium-226 and Radium-228would be 6E-8 mCi/ml, based on proposed federal Drinking Water Standards. Tritium would be 1E-3 mCi/ml, based on the TRCR standards. Uranium-234 andUranium-238 would be either 3E-7 mCi/ml, the TRCR standards, or 20 mg/L, theproposed Drinking Water Standard, which ever is more stringent.


Refer to the discussion of surface water quality decision criteriapresented in section 1.3.5 of this volume and the response to comment 06.051.

RC: 06.111

Doc: SG-003/43

Constituents of ConcernThe constituents of concern for groundwater shouldnot be limited to those constituents that exceed risk based concentrations(Section C.2.2, page C-4). In addition, the nature and extent of contaminationmust be based on background values or laboratory Practical Quantitation Limits(PQL), rather than risked based values. These issues were addressed in DOE'srevised Sampling and Analysis Plan and the TNRCC's subsequent approval withmodification.


Water quality data from an Ogallala water supply well at Bushland providesregional background groundwater quality data, as discussed in volume II,appendix C, section C.2.2. Volume II, Table C.2.23, presents a tabulation ofwater quality sampling data collected from Pantex Plant Ogallala aquifer wellsthat exceed decision criteria. TNRCC and EPA Drinking Water Standards and DOEDerived Concentration Guidelines were used as the decision criteria, rather thanbackground values or laboratory Practical Quantitative Limits because theDrinking Water Standards and DOE Derived Concentration Guidelines are regulatedto be protective of human health.

RC: 06.112

Doc: SG-003/62

The sections that deal with Geology and Soils and with Water Resources aregenerally well done. One issue that is still not adequately covered relates tothe perched aquifer. The extent of the fine-grained zone which forms theperching layer is not known. The question of what happens to the perchedaquifer is not discussed. Does the fine-grained zone pinch out with the perchedaquifer groundwater flowing off the side, down to the Ogallala? Alternatively,will [groundwater in] the perched aquifer eventually migrate through thefine-grained zone and down to the Ogallala? All that the Draft EIS acknowledgesis "Recharge to the area aquifers is not fully understood."


Additional updated information regarding the nature and extent ofgroundwater contamination in the perched and Ogallala aquifers is presented insection 1.3.5 of this volume. Discussion in volume I, section, has beenrevised for clarification.

RC: 06.113

Doc: SG-003/63

Groundwater was not considered as a pathway for exposures potentiallyimpacting human health. An obvious concern of some people in the area iscontamination of the Ogallala from plant activities. In what way weregroundwater scenarios considered, and what pathway assumptions were used?


Groundwater as a potential pathway for exposure was discussed in volumeI, section Potential consequences to the Ogallala aquifer from anaccidental plutonium release were investigated in conjunction with a SafetyAnalysis Report and an Environmental Assessment, which included a study by LosAlamos National Laboratory (LANL 1992). The hypothetical accident was assumedto be a high-temperature fire caused by a jet plane impact into a Zone 4 storagemagazine containing nuclear weapons components, and the subsequent release andignition of jet fuel, leading to dispersal of plutonium. Four potentialelements of concern were identified: plutonium, americium, neptunium, anduranium. Of these four, plutonium was determined to pose the greatest risk. Los Alamos National Laboratories used the conservative assumption that thehypothetical jet fuel fire could disperse fine particulate plutonium downwind ofPantex Plant for a maximum distance of 50 miles. Prompt decontamination effortscould reduce radiation levels to 0.2 microcuries per square meter. Plutoniumand decay products could infiltrate downward toward the Ogallala aquifer. Themodel assumed an average recharge rate of 1 inch per year (10 times the HighPlains average), and that infiltrating recharge water would reach the Ogallalaaquifer at depths ranging from 50 to 400 feet. These analyses were conservativebecause the "worse-case" scenarios were based on a depth to the watertable of 50 feet whereas, at Pantex Plant, the typical depth to the top ofperched groundwater is approximately 270 feet and the depth to the Ogallalaaquifer ranges from 340 to 460 feet. For water table depths of 200 and 400feet, LANL calculated plutonium travel times of 305,000 and 610,000 years,respectively. Interactions with both surficial materials and the unsaturatedportion of the Ogallala Formation would be expected to make plutonium move at arate slower than the infiltrating water. During the transport time, radioactivedecay would be expected to further reduce plutonium concentrations. Currentknowledge of the perched aquifer leads to the expectation that where the perchedaquifer is present, the downward movement of plutonium would be further reduced,because the low permeability fine-grained zone would impede downward flow andpotential contamination would be more likely to move horizontally in the perchedaquifer.

RC: 06.114

Doc: SG-003/64

Table C.2.2-2 in volume II provides data on chemical concentrations measuredin the perched aquifer. A great deal of data is here, but I do not believe thatit represents all available data. The Draft EIS should explain what data wasused and what data was not used, and why.


Evaluation of baseline surface water and groundwater quality is based ona review of all available data tabulated in the Pantex Plant annual siteenvironmental reports (ASER) for a five-year period, from 1990 through 1994. Surface water quality data were collected from 29 onsite sampling locations from1990 to 1993; surface water samples were collected from only 17 of thesesampling locations in 1994. The surface water data collected over the past fiveyears does not include every sampling location each year, because some locationsonly have sufficient water to sample during storm events. Groundwater qualitymonitoring data were collected from over 20 onsite sampling locations, includingwells completed in the perched and the Ogallala aquifers. It should also benoted that the groundwater data collected over the four years do not includeevery sampling location each year. In 1995, 78 groundwater monitoring wellswere sampled. In addition to the ASERs, available U.S. Corps of Engineers (COE)quarterly groundwater monitoring reports were reviewed. Quarterly groundwatermonitoring was conducted to characterize the groundwater quality and extent ofcontamination in the perched aquifer, in association with the Ditches and PlayasRCRA facility investigation for Flow System 6. It should be noted that thewater quality constituents that were analyzed for the COE investigation are notalways the same constituents that are analyzed for the ASERs. One offsitelocation, Bushland Playa at the USDA Agricultural Experimental Station west ofAmarillo, was used as a control sample to give some insight on backgroundsurface water and groundwater quality.

All available surface water and groundwater data from the ASERs werecompiled into two cumulative data tables, one for surface water quality data,and the other for groundwater quality data. The data were evaluated through aprocess of elimination whereby all parameters with values below the detectionlimits or those reported as not sampled, not presented, or holding time exceededwere omitted from the water quality data under consideration. For theradionuclides, levels of uncertainty (reported +/- the measured value) wereomitted so the data could be processed. The remaining data were then exportedinto a data management system to speed data manipulation and to reduce thechance of human error. The surface water and groundwater quality data were thensorted by location, parameter, and average value. Contaminants of concern (COC)were determined by comparing tabulated annual average values to the decisioncriteria presented in volume II, appendix C. Volume II, Tables C.1.23, C.1.24,C.2.22, and C.2.23, present values that are greater than or without definedwater quality criteria for the five years of water quality data.

RC: 06.115

Doc: SG-003/66

Sections 4.5 and 4.6, which describe water resources and geology and soils,do not provide sufficient information for the reader to determine ifenvironmental impacts could result from continued operations and storage ofnuclear weapons at Pantex.


Volume I, sections 4.5 and 4.6, have been updated with additional data,new permit requirements, and descriptions of corrective action measures.

RC: 06.116

Doc: SG-003/85

Page 4-55, Affected Environment, para. 2, ln 19. The statement is made thatthere is no evidence that the contaminants found in the perched aquifer havemigrated to the Ogallala aquifer. Only a few (2 or 3) Ogallala aquifer monitorwells are located in areas where there is perched groundwater present. Thereare no Ogallala monitor wells beneath badly contaminated areas such as Zone 12,so there are no data on which to base the conclusion that no contamination hasoccurred. Furthermore, the unsaturated zone between the Ogallala and perchedaquifers has not been sampled so it is not known if these waters and sedimentshave been contaminated.


Volume I, section, has been updated with additional informationregarding the perched and Ogallala aquifers. For additional information, seediscussion in section 1.3.5 of this volume.

RC: 06.117

Doc: SG-003/86

Page 4-62, Groundwater, para. 1: There is no discussion of sedimentheterogeneity, which strongly affects groundwater flow rates.


Discussion of the effects of heterogeneous sediments on groundwater flowrates has been added to volume I, section See response to comment06.076.

RC: 06.118

Doc: SG-003/87

Page 4-63, Figure Why are there no monitor wells in the area ofPlaya 4? Considering all of the discharge that has occurred from Zone 12 southto Playa 4, it would seem appropriate to determine the nature of thehydrogeology in this area.


Playa 4 and the majority of its watershed are located on property ownedand managed by Texas Tech University. DOE has no jurisdiction to placemonitoring wells near Playa 4. There are monitoring wells in place on the DOEowned property north of Playa 4. Additionally, the Ditches and Playas SolidWaste Management Unit process is currently collecting samples from the area ofconcern noted in this document. Soil and water characterization of the ditcheson DOE owned property that leads to Playa 4 are ongoing (PC 1996x).

RC: 06.119

Doc: SG-003/88

Page 4-65. Perched Aquifer, para. 2, ln 1: Contrary to this confusingstatement, there are areas at Pantex where perched groundwater is present, butwhere gravel channels are not present and vice versa. The presence of gravelchannels does not control the presence of perched aquifers; it is the presenceof a stratigraphic horizon (in this case the fine-grained zone) with a verticalhydraulic conductivity lower than the flux of recharge water moving through theunsaturated zone. It is quite obvious that if the gravel channel were underlainby a coarse sand then no perched aquifer would have formed.


A stratigraphic horizon with a low vertical hydraulic conductivity, suchas the fine-grained zone, is necessary for formation of a perched aquifer. Thisclarification has been made in volume I, section

RC: 06.120

Doc: SG-003/89

Page 4-69, para. 4, line 6. If the spread of contaminants in the perchedaquifer is limited to the confines of perched aquifer in buried channeldeposits, then why are there so many perched aquifer monitor wells in Zone 12with contaminants, but located outside the gravel channel as mapped on page4-66? It seems obvious that something other than gravel channels is, at leastin part, controlling flow in the perched aquifer and that contaminants arepresent in perched aquifer water outside the gravel-filled channel.


There are heterogeneities in the subsurface sediments that result inpreferencial subsurface flow. The horizontal flow of perched groundwater iscontrolled by the fine-grained zone that limits the downward movement ofgroundwater, as briefly discussed in section 1.3.5 of this volume and in theresponse to comment 06.119.

RC: 06.121

Doc: PC-028/2

Page 5-8, 2nd column, 3rd paragraph:...The water usage and wastewaterproduction are of a major concern in New Mexico and Albuquerque. The State isexperiencing a major drought along with Albuquerque. Any additional water usageby KAFB drains the already lowering aquifers in Albuquerque. Go elsewhere!


The Pantex EIS only deals with the interim storage of containerized pitsat the Manzano Weapons Storage Area at Kirtland Air Force Base. As a result,groundwater resources would not be affected by these interim storage activities. Only the guard force and operations personnel (about 150 people) would needwater.

RC: 06.122

Doc: PC-028/4

Page 5-58, para Any additional water usage, by any operation putsadditional demands on a drought ridden state. Additionally, Albuquerque isexperiencing dwindling water supplies in their aquifers to include KAFB. Anyadditional water usage, even for pit operations, is not necessary since DOE canselect on the other alternatives and should.


See response to comment 06.121.

RC: 06.123

Doc: HT17/73

It would be IGNORANT to site future missions at Pantex without firstreviewing the geological hazards truthfully and openly. It would be doublyignorant to continue trying to hide contamination facts as they relate to theOgallala today. The recharge rate is MUCH faster than folks believed it to be afew years ago, and MUCH faster than what is being publicly acknowledged today.


Numerous scientific investigations have been conducted to determine thegeologic and water resource characteristics at and in the vicinity of PantexPlant. Volume I, section 4.5, addresses the geologic conditions and potentialfor seismic activity. Volume I, section, discusses the hydrogeologicconditions, including ranges of groundwater velocity and recharge estimates,based upon the most up-to-date information available at the time of publication. The Environmental Restoration Protection Program will continue to monitorexisting conditions and perform corrective actions as needed.

RC: 06.124

Doc: CO-007/1

... Two very important negative impactsthe drawdown from the alreadydropping water reserves and the contamination into it. The proposal givesinadequate information and inadequate protection of the crop-feeding resource inthe agriculturally rich eight state region where the Ogallala is locatednot tomention the water supply for Amarillo.


The importance of the Ogallala aquifer as a valuable regionalgroundwater resource supply is discussed in section 1.3.5 of this volume.

RC: 06.125

Doc: PC-030/3

No additional water should be channeled to the open ditches and playas atPantex because it will accelerate the flushing of contaminants into the soil andeventually into the aquifer.


See discussion in section 1.3.5 of this volume and response to comment06.060.

RC: 06.126

Doc: CO-005/4

A second major flaw in the document is the omission of the importance of theOgallala aquifer to this area. As the single groundwater supply for 46 countiesin the Texas Panhandle and the source of water for parts of seven midwesternstates, it is paramount that nothing be done to damage this priceless resource.What could be more important in an environmental document than a detail analysisof the water source, the future supply and the impacts to this source frompresent activities at Pantex. To ignore the tremendous impact that Pantex hasalready induced on this finite water source is inadmissible. We ask that youprovide detailed analysis on the effects of Pantex activities on the Ogallala(which includes the perched layer), the complete scope of contaminants, thecombined effects of these contaminants and how different constituents react invarying soils and water.


See discussion in section 1.3.5 of this volume. Additional informationhas been included in volume I, section

RC: 06.127

Doc: CO-005/5

We ask that the studies from the Bureau of Economic Geology (BEG) beincluded as part of the Pantex EIS. Why were the results of the years of workdone by BEG not included in the draft document? These are valuable studies withextremely telling results. Provide the reports, analysis and statements producedby BEG in their study at Pantex in the final document.


Many of the Bureau of Economic Geology (BEG) reports have been cited inthe Pantex Plant EIS. BEG reports are included in the administrative record andare available to the public.

RC: 06.128

Doc: PC-008/3

Plant used 230 million gallons in 1995.

  • Texas Tech Farms used 66 million gallons (29%) of the total plant waterusage.
  • Nuclear weapons operations used 163 million gallons (71%).

Amarillo Water District consumed 16 billion gallons in FY 1995.

Pantex Plant including Texas Tech Farms used 1.4% as much water as AmarilloDistrict. Nuclear weapons operations used 1% of the water used by Amarillo. Considering the water also used for irrigation, the Plant withdrew 0.6% of theregional withdrawal from the Ogallala aquifer.* Nuclear weapons operationsconsumed 0.43% of the regional withdrawal.

*Draft Environmental Impact Statement for the Continued Operation of thePantex Plant and Associated Storage of Nuclear Weapon Components, March 1996,page S-15.


Comment noted.

3.7 Air Quality

RC: 07.001

Doc: HT02-05/1

[The Proposed Action] is inappropriate for the reasons that winds and stormshere are very strong and tend to have...more far-reaching effect[s] than they doin other parts of the country.


This EIS only assesses the impacts of relocating interim pit storage. The potential relocation of other Pantex Plant operations is assessed in the SSMPEIS. The meteorology and climate (regional and local) at Pantex Plant arediscussed in volume I, section 4.7.1 of this EIS. The climatic characteristicsof the Pantex Plant area were taken into account in assessing the impacts of airpollutants from normal operations (see volume I, section 4.7) and from accidents(see volume I, section 4.14). The climactic characteristics of each of theother sites being considered for interim storage of pits were also taken intoaccount in assessing impacts (see volume I, chapter 5).

RC: 07.002

Doc: HT02-04/5

The use of strontium-90 to test containment at the Firing Sites is anunacceptable, unpleasant fact to me. Please tell me more about this, as well asthe other open air experiments conducted at the site.


In 1977, one test at Firing Site-15 involved the use of high explosivescontaining strontium-90 as a tracer. It was later determined that the lagoonwas contaminated with strontium-90. During a 1987 study, grab samples werecollected in the potentially affected area around the site. Strontium-89/90averaged 0.398 pCi/g. Another investigation was conducted at the site in 1995(PC 1996w). All potential radioisotopes were analyzed for, including uranium(U), thorium (Th), beryllium (Be), cesium (Cs), and strontium (Sr). Theseconcentrations were found to be well below the Nuclear Regulatory Commission(NRC) and Texas Department of Health (TDH) soil contamination limits. Detectedactivities ranged from 0.43 to 1.8 pCi/g for Be-7; from 0.34 to 0.01 pCi/g forCs-137; and from 0.14 to 0.86 pCi/g for total Sr isotopes. The NRC criteria forno further action were used for thorium, uranium, cesium, and strontium.

RC: 07.003

Doc: HT02-04/6

[Depleted Uranium] DU particles from test explosions at the Firing Sitespread into the air, land, and water offsite. DU is toxic and radioactive. While I thank you for starting to clean it up, once again, I must say, tell usmore.


Up until the mid 1980s, test firings were performed in the open areas atthe firing ranges, resulting in the dispersion of DU in the immediate area ofthe firing sites.

Soil and Sediment Quality, volume I, section, discusses thegeneral environmental restoration process. Volume I, section 4.5.1, discussesthe DU contamination at Firing Sites 4, 5, and 10. A request has been submittedto TNRCC to remove the four currently active Firing Sites from the Pantex PlantEnvironmental Restoration program. Firing Sites 4, 5, and 10 have a lowuranium-234 to uranium-238 ratio. An interim corrective measure is beingconducted on Firing Site-5 to remove surface DU contamination. Subsequentconfirmation sampling and risk assessment will be conducted at Firing Site 5. Confirmation sampling will be conducted to confirm that protective levels havebeen attained and no further action will be required.

For further information see volume II, section I.1.2.4 and TableI.1.2.11.

RC: 07.004

Doc: HT16/17a

One of the items that [was] mentioned was that one of the pollutants that wemonitor for is [total] suspended particulates, which is no longer true becausethere is no standard for total suspended particulates, so we stopped monitoringfor [them]. Although we take samples, those filters are forwarded to the Bureauof Radiation Control for radionuclide analysis.


The language in volume I, section 4.7.1 has been revised to say thatTNRCC no longer monitors for total suspended particulates.

RC: 07.005

Doc: HT16/17b

And the other item that was mentioned was that we monitor for metals. Again, we don't on a regular basis analyze for metals. We did take a sample in1993 for about 30 days30 samples. And then we analyzed for about 20 differentmetals through kind of a screening method. There aren't any concerns there orwe haven't been able to identify any. So we have not done any additionalanalysis for metals.


Text in volume I, section 4.7.1 has been revised to reflect that metalsare not routinely monitored.

RC: 07.006

Doc: HT16/18

And with regard to air quality impacts, both for No Action Alternative orthe consolidation alternative, the non-radiological air quality impacts will beminimal. Only potential is for particulates if more construction activity takesplace due to consolidation alternative. And, as the EIS mentions, that if thathappens, that mitigation measures will be used to control the particulateemissions. And I think that is a TNRCC-accepted method of control forparticulate emissions.


Volume I, section discusses the emissions from constructionactivities and volume I, section 4.7.6 discusses the potential mitigationmeasures to reduce emissions. Regarding the variance between monitoring dataand modeling results, see discussion in section 1.3.6 of this volume.

RC: 07.007

Doc: HT16/19

I would like to bring up some inaccurate statements in the EIS that need tobe corrected. In Table there's a footnote discussing the NationalAmbient Air Quality Standards, and I think that statement is not accurate,because for ozone and PM10 the determined by statistical methods. And that is based on expected exceedances over a 3-year period. And a3-year period, the number of exceedances or expected exceedances, averaged overthe 3-year period has to be one or less, otherwise that area is considerednon-attainment for that pollutant. For sulfur dioxide and nitrogen oxide annualstandards and for lead, the quarterly standard, are not to be exceeded. Andcarbon monoxide, there are two standards, the 1-hour standard and the 8-hourstandard. And [for] sulfur dioxide, a 3-hour standard and a 24-hour standardcan be exceeded only once per calendar year. And the statement in the EIS doesnot make that clear. And on page 493, there is a statement that says that AirQuality Control Region 211 is designated by EPA as better than Nationalstandards for total suspended particulates. That statement is incorrect becausewhen EPA established new standards for PM10 for (inaudible) particulates, thestandards for PM10 were taken out. So there is no more National standard forTSP. On the same page, 493, there is a discussion about methylene chloridefound in our monitoring at 213 parts per billion by volume on July 6th, 1993. But there is no mention made that this concentration was seven times the effectsscreening level established by TNRCC. Although, further review and analysis byour staff, toxicology and risk assessment staff, concluded that this one-timehealth episode would not result in any long-term health effects. There isgreater discussion about the slightly above ESL concentration of dichloroethane,whereas the discussion on methylene chloride was left out. Another point I wantto make is that in our four years of monitoring at Pantex we have found a numberof exceedances of PM10 National Ambient Air Quality Standards. Although themodeling done by both TNRCC and the EIS staff did not predict any possible PM10violations, actual exceedances happened. They could be due to blowing dust orlocalized earth-moving activities. But that is precisely the kind of scenariosanticipated in the consolidation alternative if additional construction activitytakes place. The EIS addresses this issue in section 4.7.6.


This comment discusses four individual points. Each of the points isaddressed in turn.

1) The footnotes containing the discussions of the standards associatedwith each of the pollutants have been revised in accordance with the comment andthe TNRCC Monitoring Operations Division reference "Smarter Air Monitoringfor Texas" (TNRCC 1994b).

2) The text discussing the standard for TSP has been deleted.

3) The discussion of the methylene chloride exceedance in section 4.7.1in volume I has been amended. The following sentences have been added. "Theconcentration was approximately seven times the ESL (30 ppbv) established byTNRCC.... In the case of the 1993 methelyne chloride exceedance, the TNRCCToxicology and Risk Assessment Section stated that the one exceedance was notexpected to result in any long-term health effects."

4) See section 1.3.6 of this volume for a discussion of the variancebetween PM10 monitoring data and modeling results.

RC: 07.008

Doc: HT16/20

Our modeling staff reviewed the modeling results that [were] given in theEIS. The TNRCC did clean air modeling in 1995 under the agreement in principle. And our staff used a different methodology to do the modeling for [the] Pantexsite-wide modeling. And the EIS staff...use the same model, the IndustrialSource Complex model, but they used a different methodology to do the modeling. But the conclusions that were arrived at by both models were the same, that onlyalcohols exceeded the effects screening levels. And when it was modeled foroutside the Pantex boundary, there was no exceedance of the standard or theguideline ESL. So that sort of validates the model, that two different groupsof people modeled the same emissions using different approaches, but [came] upwith the same conclusion. However, by reviewing the input into the models ourstaff found that a number of emission points were left out in the modeling thatthe EIS staff conducted, like the carbon monoxide emissions from emission points54, 85, and 160. Some of them are very minimal emissions. But, for example,emission point 160 is a natural gas boiler. It has the emissions of 13,000pounds per year, which was not included in the EIS modeling. The same thing,from the same boiler, the NOx emissions, the nitrogen oxide emissions, 53,000pounds a year, that was not included in the EIS model.


Emission points 54, 85, and 160 were active at the time TNRCC performedtheir modeling, but had become inactive by the time the modeling was performedfor this EIS. For a general discussion of the differences between the twomodeling efforts, see section 1.3.6 in this volume.

RC: 07.009

Doc: HT16/21

... There were a number of hazardous air pollutants that were left out inthe EIS modeling, which the TNRCC staff used in their modeling.


The air quality modeling for this EIS included all current and futurehazardous air pollutants. However, some of the pollutants had such negligibleconcentrations that they were screened out of the tables placed in the DraftEIS. In the Final EIS the tables have been expanded to include all of thehazardous air pollutants. See also the discussion in section 1.3.6 of thisvolume.

RC: 07.010

Doc: HT16/22

... We have had some PM10 exceedances, although [they] happened at theproperty, they are not considered a violation of the National Ambient AirQuality Standards. But that is one thing that needs to be taken intoconsideration when this expansion or consolidation alternative is considered,that some mitigation measures will be employed to avoid exposure to the workersor even potentially to the neighboring residents.


See discussion in section 1.3.6 of this volume.

RC: 07.011

Doc: HT16/29

Are all the known emissions for Pantex included in a list in this document,regardless of whether or not there's a standard that it was tested for, or do weonly talk about things that there's a standard that applies that you pick up inmonitoring? Or are they only monitored for if there's a standard and if there'sno standard they're not tracked...? ...I would be interested, and would likeeven to request, it would be nice if this document gave us a good thoroughpicture of the plant, regardless of, perhaps, health effects or whatever, justwhat the emissions are. And, if there are no health effects attached to certainthings, that's nice if you can specify that or just that there's not a standard,or whatever. But it would be nice to have a better picture, a clearer picture,of this plant as it currently operates.


See response to comment 07.009, and section 1.3.6 of this volume.

RC: 07.012

Doc: HT16/30

... When we reviewed the emissions data that they have reported in AppendixB and the emissions inventory that was submitted to us for our AIP modeling,there were a number of hazardous air pollutants, about 50 of them, that wereleft out. And, as I said, they are not very high quantities, but they werementioned in the emissions inventory that was submitted to us, but it is notincluded in the EIS.


See response to comment 07.009 and discussion in section 1.3.6 of thisvolume.

RC: 07.013

Doc: PC-031/2

Some of the most glaring deficiencies and omissions include the continuinguse of the Burning Ground with no alternative examined. This facility is nottechnically acceptable and this document ignores the agreement with our citizengroups to analyze alternatives. The air modeling is inadequate, by the words ofthe document itself. How could DOE expect credible results with no modeling forresidences on the south side of the Plant? There are still no monitors eitherat the perimeter or outside the plant measuring emissions that are notradiological.


There are several misunderstandings revealed in this comment. The factsare that:

1) Pantex Plant did conduct a Best Available Control Technology (BACT)of several existing or developmental alternatives to open burning/opendetonation. The analysis concluded that controlled open thermal treatment withexisting administrative controls constituted BACT. Thus, the plant proposes tocontinue that activity in this EIS. Since that study was completed, furtherdevelopment of procedures for chemical treatment has warranted furtherinvestigation of a base hydrolysis treatability study. Volume I, section 1.2.2and volume II, section G.3.8 contain additional information on this subject.

2) As stated above, the Burning Ground is not only technicallyacceptable, but technically the best available method of sanitizing HEcomponents as well as for treating HE-contaminated waste material.

3) The air modeling is not "inadequate, by the words of thedocument itself." The air modeling for this EIS was performed using EPAapproved models, a TNRCC approved data set for meterology and mixing heights,and a comprehensive set of emissions sources and emissions rates. Theconclusions of the air modeling are consistent with those of other modelingefforts independently conducted by another contractor and by TNRCC.

4) The air quality modeling included analysis for receptor locationsspaced at 100 meter intervals along the north, west, and east boundaries ofPantex Plant. On the south side of the plant, the receptor line was positionedto include most of the property leased from TTU. See Figure in volumeI for a graphical depiction of the "fence line" receptors. Any airpollutant concentrations emitted by the plant would have to cross thesereceptors before reaching an off-site residence. In addition, the modeling didinclude several residences on the south side of the plant. Some "residences"shown in Figure of the Draft EIS were inadvertently depicted atincorrect locations. This has been corrected in the same figure of the FinalEIS. It should be noted, however, that the residence locations used in theactual computer modeling were correct and the analysis of concentrations atresidences is valid.

RC: 07.014

Doc: PC-025/42

On page 4-94, The Target Range is where you explode nuclear devices?


Nuclear devices are not exploded anywhere at Pantex Plant. The TargetRange indicated in volume I, Figure is used to conduct live firetraining for security personnel with duty sidearms, sub-machineguns, andshotguns.

RC: 07.015

Doc: PC-025/43

Pages 4-96 and 4-99. What are the sources of the information in the tables?


The sources of information for Table are the Pantex PlantEnvironmental Information Document, Pantex Plant Emissions Inventory, and TNRCCEffects Screening Levels and the Clean Air Act.

For Table, the sources are TNRCC Air Quality ModelingGuidelines and calculations performed with ISCST2 and ISCLT2 models.

In the Final EIS both tables have been annotated to list these sources.

RC: 07.016

Doc: PC-025/44

General comment on section 4.7: Poor QA/QC of data has occurred in appendixB supporting section 4.7. Examples included below of showing incorrect data areas follows: page B-44, chromium, 45.4 kg, 1000, l hour; page B-44, chromium,363 kg, 1 hour, page B-45, cresol, 1,000, annual, #11; page B-45, cresolic acid,annual, #11; page B-46, ethyl benzene; page B-48, HF, 363 kg, 24-hour, #3; pageB-49, ketone, 363 kg, annual, 8, 10; ketone 363 kg, 1 hour, #2; Page B-50,methylene chloride, annual, #2; page B-50, naphthalene, 45.4kg, 1 hour, #5; pageB-51, NO2, 45.4 annual, is totally incorrect; page B-51, NO2, 363 kg, #1, #2,#5, #9, #11; page B-5 1, NO2 BGU, is totally incorrect. Page B-52, toluene, 500,I hour, #10; page B-52, trichloroethylene, annual, #8, #9, #10, #11. These areonly examples determined by visual inspection of data presented in appendix Bnot actual calculations. What level of QA/QC was completed? What level isrequired? Please provide QA/QC documentation including signatures assuringcertification of data quality. What proof does DOE give that the analysis is ofgood quality? I believe DOE will blow off my comments in SSM, S&D, andPantex projects regarding QA/OC. I believe I am presenting evidence that theQA/QC is technically substandard. Prove I'm incorrect.

Virtually every page of the table is incorrect to some degree.

Table B.4.11 has numerous concentrations reported with identical roots butorders of magnitude difference. This is highly unlikely and points to poorQA/QC. Cresol residence #l is in error. HF exponents are in error. Ketoneexponents are in error. Lead is incorrect in the 3rd quarter.


The QA/QC process used for the preparation of this EIS was conducted inaccordance with a Quality Assurance Program Plan tailored for the preparation ofthis EIS and consistent with DOE Order 5700.6c. The process involved multiplelevels of review, both internal and external to the team preparing the document.

The specific section cited in your comment, appendix B, relates to airquality analysis. Preparation of that particular section entailed the analysisof 3.8 million data elements from which the tables you cited were prepared. During the preparation of those tables, there were typographical errorsintroduced due to misreading of the authors handwriting. The same misreadingsthat occurred during the word processing step occurred during the reviews, withthe effect that the typographical errors in data were not caught by reviewers. Following the discovery of this problem with the particular authors handwriting, the review process was modified to ensure that the entries in the tables of theFinal EIS were rechecked against the original data set.

It should be noted that while the Draft version of appendix B containedtypographical errors in tables containing thousands of data entries, the airquality modeling and the analysis of modeling results as reported in both theDraft EIS and this Final EIS is still valid. Separate, independent modelingefforts by a different DOE contractor and by the TNRCC, using compatible, butslightly different methodologies, produced results in close agreement with themodeling performed for this EIS. None of the three independent modeling effortsfound that any individual pollutant concentrations exceed air quality standardsor Effects Screening Levels at the Pantex Plant boundary. The Draft EIS andTNRCC modeling did show that alcohols as a group would exceed a conservativelyselected Effects Screening Level of 100 micrograms per cubic meter. Subsequentanalysis to prorate the total alcohol concentration according to the quantity onhand of individual alcohols showed that none of the individual alcohols exceedtheir respective ESLs at the Plant boundary.

RC: 07.017

Doc: PC-025/45

Request extra public review time due to poor quality. I am concerned theinput data to the modeling is questionable due to errors noted in tables above.What assurance does DOE provide to certify input data is accurate? What methodswere used to qualify input data? What QA/QC documentation exists for input data? Specifically, what level of quality exists for estimated emissions rates?


Under regulations established by the Council on Environmental Quality,at least 45 days must be provided for public review of a Draft EIS (40 CFR1506.10(c)). In response to stakeholder requests, DOE extended the publiccomment period for this EIS to 98 days.

The models used for air quality analysis are the Industrial Source CodeModels (ISC-ST and ISC-LT) developed and approved by the EnvironmentalProtection Agency. The input data for air quality modeling was obtained fromtwo sources. Input data for meteorology and mixing heights were standardizeddata sets approved by the TNRCC. The input data for emissions inventory wasdeveloped by Pantex Plant for use by TNRCC. These data were developed byPantex Plant under a DOE-approved, NQA-1 Quality Assurance Plan that meetsrequirements of DOE Order 5700.6c. The input data sets have been reviewed byTNRCC as well as by technical experts of Pantex Plant and DOE.

RC: 07.018

Doc: PC-025/46

General comment for section 4.7. Tables lack sources.


Sources have been added to tables in the Final EIS.

RC: 07.019

Doc: PC-025/47

Page 4-112. Please explain why the paper incinerator listed on page B-17,the wastewater treatment facility's SO2, and landfill activities PM10 are notincluded?


The paper incineration emissions (CO, NO2, and PM10) were includedwithin weapons related activities. Wastewater facility and landfill activitiesare not considered significant sources of pollutant emissions; hence, are notincluded.

RC: 07.020

Doc: PC-025/93

Air does not assess methane releases from activities (oil, gas, andlivestock industries) in the ROI. Air does not include SO2 releases in the ROI.


Only the criteria pollutants (SO2, CO, NO2, PM10, Ozone, and Lead)and some VOCs are regulated by EPA (Under the Clean Air Act) for Air QualityControl Region 211. Table presents the SO2 releases in the ROI. Methane is not listed under the Clean Air Act, but is listed under TNRCCs list. Modeling results for Methane have been added to the Final EIS.

RC: 07.021

Doc: CO-008/137

Include a list of all air emissions onsite.


Volume I, section 4.7.1 (Table has been expanded to includeall chemical air emissions which are of potential significance in air qualityanalysis. The table shown in the Draft EIS omitted some of these emissionsbased upon modeling results which showed negligible emissions impacts. However,as a result of this and similar other comments, those chemicals are now shown inthe tables.

RC: 07.022

Doc: CO-008/138

Have all available emissions been used in the model?


Yes, all emissions sources have been modeled.

RC: 07.023

Doc: PC-027/7

... Page 5-73, Air Quality. Albuquerque managed to get off the EPA airmonitoring programif we hadn't gotten off we would have been in trouble. Allwinter long, Albuquerque citizens are not free to build fires in theirfireplaces or woodstoves any time they want to, we get fined for burning on a "NoBurn" day. We have many "No Burn" days. Our houses are checkedto see if smoke is coming out of the chimney on No Burn" days. There is atelephone number to call to get a recorded message about whether we can burn afire or not. We have to buy special gasoline for our cars in the winter timeand we are nagged constantly about car pooling, etc., to cut air pollution,[encouraged] to have "no drive" times in order to improve air quality. The information you present about the air in this area is not complete becauseit doesn't reflect the constraints we have to work at in order to achieveacceptable air. The city, county, and citizens work hard to get to this point. You plan to drive 120 vehicles 365 days a year and 30 vehicles 255 days a yearmaking 30- and 50-mile trips and say that your contribution to bad air would benegligible. I don't know -- we're really borderline on meeting the clean airspecs and have to work hard to hold the line.


DOE acknowledges the efforts of Bernalillo County citizens andgovernment to control air pollution. The effectiveness of that effort hasresulted in a change in status from "nonattainment for CO" to "maintenancefor attainment."

Volume I, Table shows the comparison of the total pollutants(such as CO, NO2, VOC, SO2, and particulates) that will be emitted from thevehicles related to pit storage along with the respective total pollutantsemitted in the Bernalillo County. These data show that the pollutants emittedfrom these additional vehicles would be negligible.

RC: 07.024

Doc: SG-003/44

The footnote on National Ambient Air Quality Standards (NAAQS) in Table4.7.1.31 in Volume 1 is inaccurate. Both ozone and PM10 NAAQS are based onexpected exceedances, meaning that non-sampling days must be accounted for whencalculating attainment determination. The NAAQS is attained when the expectednumber of days per calendar year, averaged over a 3-year period, with maximumhourly average concentration for ozone and 24-hour average concentration forPM10 above the standard is equal to or less than one. SO2 annual, NO2 annual,and lead quarterly NAAQS are not to be exceeded. CO 1-hour and 8-hour and SO23-hour and 24-hour standards cannot be exceeded more than once per calendaryear.


See response to comment 07.007.

RC: 07.025

Doc: SG-003/45

In the discussion of air monitoring results on page 4-93 in volume 1, it isstated that methylene chloride was found at 213 ppbv on July 6, 1993. There isno mention that this concentration was 7 times the effects screening level(ESL). Further review and analysis of the methylene chloride data by Toxicologyand Risk Assessment staff concluded that this one-time episode would not resultin any long-term health effects. Although there is detailed discussion ofslightly above ESL concentration of 1,2-dibromoethane, this additionaldiscussion on methylene chloride is left out.


See response to comment 07.007.

RC: 07.026

Doc: SG-003/46

TNRCC air monitoring at Pantex has found a number of exceedances of the PM10NAAQS. Although modeling by TNRCC and the EIS staff did not predict possiblePM10 violations, actual exceedances happened mainly due to blowing dust andlocalized earth moving activities. Precisely these kind of scenarios areanticipated in the Consolidation Alternative if additional construction activitytakes place at Pantex. The EIS addresses this issue in section 4.7.6 on page4-118 by stating that mitigation measures will be undertaken to alleviatetemporary dust emissions from construction activities. These are standardTNRCC-approved mitigation measures for particulate emission control.

See discussion in section 1.3.6 of this volume for explanation ofvariance between PM10 monitoring data and modeling results.

RC: 07.027

Doc: SG-003/47

TNRCC Modeling staff reviewed Appendix B, Air Quality Analysis, of theSitewide EIS and their comments are submitted separately. Additionally, the EISused the same model, the Industrial Source Complex Model, that the TNRCC usedfor modeling Pantex emissions. EIS modeling was performed in accordance withthe EPA guidance document, "Guidelines for Air Quality Models"(revised) and TNRCC guidance document, "Air Quality Modeling Guidelines." The modeling approach used by the EIS is different from the one used by TNRCC. However, both models arrived at the same conclusion.


See section 1.3.6 of this volume for a general discussion of thedifferences between the EIS and TNRCC modeling efforts.

RC: 07.028

Doc: SG-003/48

TNRCC used a tiered modeling approach that included a blend of screen andrefined modeling techniques because of the large number of fugitive emissionlocations, buildings, and pollutants, whereas the EIS modeling used a refineddispersion model to accommodate the large number of emission sources andpollutants.


See section 1.3.6 of this volume for a general discussion of thedifferences between the EIS and TNRCC modeling efforts.

RC: 07.029

Doc: SG-003/49

In the TNRCC approach, the TNRCC modeling results were added to the resultsof the modeling conducted by Radian Corporation in support of a permitapplication. Radian modeling addressed predicted impacts of emissions from theburning ground and container storage area. Therefore, TNRCC used an additivemodeling approach to account for emissions from some of the buildings to assessplant wide emission impact. Using this approach, TNRCC modeling concluded thatno predicted exceedances of the criteria pollutant impact public health. Themaximum concentrations of alcohols predicted at the property line was slightlyabove the ESL, but concentrations of alcohols predicted at the nearest residencewas below the ESL.


See section 1.3.6 of this volume for a general discussion of thedifferences between the EIS and TNRCC modeling efforts.

RC: 07.030

Doc: SG-003/50

Using a different approach, EIS modeling also concluded that there would beno exceedance of the NAAQS for criteria pollutants and that the only hazardousair pollutant that exceeded its ESL was alcohols. Again, predicted maximumconcentrations of alcohols for 11 residences located near Pantex were below ESL.


See section 1.3.6 of this volume for a general discussion of thedifferences between the EIS and TNRCC modeling efforts.

RC: 07.031

Doc: SG-003/51

The nonradiological air quality impacts due to the No Action Alternative andthe Consolidation Alternative will be minimal, especially if mitigation measuresare taken to control particulate emissions due to increased vehicular trafficand construction activity.


Your observation is correct.

RC: 07.032

Doc: SG-003/52

Data reviewed were contained in Tables B.3.6-1 through B.3.6-9 and TablesB.4.1-1 through B.4.2-3 of the EIS. Please note that no modeling input andoutput files were available to assist in our review. Therefore, a comparisonwas made of the emission rates and results presented in the EIS to the emissionrates and results reported in the TNRCC's Modeling Analysis of the Pantex PlantAmarillo, Texas, dated June 1995.


While the complete modeling input and output files are too voluminous toinclude in the EIS, the emissions rates are the key ingredient since themodeling equations and the meterology and mixing height data are identical tothose used by TNRCC. As described in the response to comment 07.009, theemissions inventory displayed in the Final EIS has been expanded to include allpollutants emitted by Pantex Plant.

RC: 07.033

Doc: SG-003/53

Some of the sources modeled by the TNRCC were not listed in Table B.3.6-1 ofthe EIS, so we assumed they were not modeled. However, in the TNRCC analysisthe predicted concentrations for the pollutants emitted from the omittedsources, plus all other applicable sources, were less than the respectiveNational Ambient Air Quality Standard (NAAQS). Following is a list ofpollutants and omitted sources: CO emissions from EPNs 54, 85, and 160; NO2emissions from EPNs 85, 157 and 160; and PM10 emissions from EPNs 157 and 160.


The cited sources are no longer active at Pantex Plant and were notincluded in the modeling. See response to comment 07.008, and for a generaldiscussion of the differences between the two modeling efforts, see section1.3.6 of this volume.

RC: 07.034

Doc: SG-003/54

All predicted concentrations in the EIS were less than those reported by theTNRCC except for alcohols, hydrogen chloride, methylene chloride, and PM10. Except for alcohols, the concentrations for all pollutants were below therespective Effects Screening Level (ESL) or NAAQS. The predicted concentrationfor alcohols was only slightly higher than the TNRCC-predicted value and lessthan twice the ESL.


See section 1.3.6 of this volume for a discussion of differences in themodeling efforts.

RC: 07.035

Doc: SG-003/55

The EIS Tables B.4.2-l and B.4.2-2 do not include all the pollutantsreviewed by the TNRCC. Therefore, we assumed that the EIS did not include anevaluation for them. However, the TNRCC reported in its analysis that noconcentrations for these pollutants were predicted to exceed an ESL or statestandard. The omitted pollutants follow: 1,3,5-Trinitrobenzenel-Butanol,2,4,6-Trinitrotoluene, 2,4-Dinitrotoluene, 2,6-Dinitrotoluene,2-Nitronaphthalene, 2-Ethoxyethanol, Acetone, Acetylene, Aluminum, Ammonia,Barium, Benz(a), anthraceneBenz(a), pyrene, Bismuth, Butadiene, Butane,Butene, Calcium, Chlorinated Fluorocarbon, Copper, Cyanogen, Cyclohexane,Cyclohexanone, Dimethylformamide, Dioxane, Ethane, Ethyl Acetate, Ethyl Ether,Ethylene, Formic Acid, Iron, Isobutane, Isobutanol, Ketene, Lithium, Magnesium,Methane, Methane, dichloroN-Butyl, Alcohol, Non-F Solvents,Ortho-dichlorobenzene, Propane, Propene, Pyrene, Pyridine, Silicon,Tetrahydrofuran, Titanium, Total Suspended Particulate, Trichlorofluoromethane,Trichlorotrifluoroethane.


The maximum fenceline concentrations of the pollutants, both thoselisted in the Clean Air Act and those listed by TNRCC (as stated above in thecomment) were modeled and compared to appropriate TNRCC ESLs. However, only theresults for those chemicals that are listed under the Clean Air Act, as amended(Nov 1990), and alcohols, as a group, which exceeded its ESLs were reported inthe Draft EIS. All of the maximum fenceline concentrations for all of thechemicals emitted by Pantex Plant, including those listed by TNRCC and used inits modeling, have been included in volume I, section 4.7 and volume II,appendix B of the Final EIS.

RC: 07.036

Doc: SG-003/56

On Page 4-93, Paragraph 2, 2nd Sentence: "AQCR 211 is designated by EPAas "better than national standards" for total suspendedparticulates..." To our knowledge there is no national standard for totalsuspended particulates. EPA replaced the Total Suspended Particulate standardwith the particulate matter standard during the late 1980's.


Commentor is correct. The text in volume I, section 4.7.1 has beenrevised.

RC: 07.037

Doc: SG-003/57

On page 4-95, paragraph 5, 2nd sentence, there is a typographical error: "TRNCC" should be changed to "TNRCC".


Correction has been made.

RC: 07.038

Doc: SG-003/58

Page 4-95, Air Quality Modeling, corresponding tables. It is not clear inthe narrative whether the air dispersion modeling referenced was conducted aspart of the Agreement in Principle or as part of the permit applicationsubmitted by the DOE.


Modeling was performed to fulfill the NEPA requirement to presentimpacts for current operations as well as predict those associated with thefuture operations being evaluated in the EIS. The monitoring data were notcomprehensive enough to create a baseline or to estimate the potential impactsof future operations to the surrounding population.

RC: 07.039

Doc: SG-003/59

Page 4-97, Table The following ESLs need to be corrected: Ethene, Trichloro:135 ug/m3 for the annual ESL1350 ug/m3 for the 30-minute ESL.


Table in volume I of the Draft EIS has been expanded andappears as Table in the Final EIS. The chemical "Ethene,trichloro-" in the Draft EIS appears as "Trichloroethylene" inthe Final EIS. We have inserted the annual and 30-minute ESLs as requested.

RC: 07.040

Doc: SG-003/60

Page 4-98, Table The following ESLs need to be corrected:Methanol:262 ug/m3 for the annual ESL2620 ug/m3 for the 30-minute ESL.


Methanol is listed in the TNRCCs ESL list as Methyl Alcohol, which hasthe same ESLs as mentioned above. The ESL for Methonol has been added asmentioned in the comment.

RC: 07.041

Doc: SG-003/61

Page 4-99, Table The format of the ESL should be converted to beconsistent with the other ESLs represented in the table (e.g., 135 ug/m3 shouldbe 1.35 x 10E2).


Changes have been made as requested for consistency.

RC: 07.042

Doc: CO-008/136

Are TNRCC air monitoring results included [in] the air quality calculations? If so, please cite.


Air monitoring results of TNRCC are described in volume I, section4.7.1.

3.8 Acoustics (Noise)

RC: 08.001

DOC: PC-023/4

The EIS reported that risks to the public from acoustics and natural seismicactivity are low. However, the report does not address structural damage tohomes and buildings on and offsite of the plant that have occurred due toexplosions. One home offsite of the plant suffered significant damage to itsfoundation, walls, roof supports, and plumbing as a direct result of a plannedexplosion at Pantex Plant. The "shock" energy from the explosionwhich caused the damage is similar to energy associated with acoustics andseismic activity.


Volume I, section, describes the noise from high explosivesdetonation. During 1994, Pantex Plant detonated 60 charges of HE. The maximumcharge exploded was 55 pounds. Noises from HE detonations were modeled by usingthe model BLASTO. The results are summarized in volume I, section 4.8.1, Table4.8.1.31. Almost any wind speed from the south quadrants could be expected togive at least 140 dB overpressure from a 55-pound HE burst at Firing Site-4. The nearest residences, 1 and 2, which are both just north of the site boundary,can feel discomfort due to the noise created by this detonation. Window damagewould rarely occur, but there could be interior plaster cracking depending onits age. Objects might occasionally be rattled from shelves, but damage to thefoundation, roof supports, and plumbing will not occur due to this kind ofexplosion (55 pound HE detonation).

RC: 08.002

DOC: PC-017/6

Last October 4, 1995, a very large explosive charge was set off for anemergency management drill. Our home received major damages. We would havebeen better off to have torn our home down and rebuilt from the ground up. Wewere originally told that the charge was 110 pounds of explosive. Later, plantofficials have said only 80 pounds of explosive was used. This was set offabout one-half mile southwest of our home. We are now learning of otherneighbors who have damages that possibly resulted from that explosion. Throughout the many years of living next to Pantex, the testing of highexplosives probably caused damages to our homes resulting in cracking, breakage,etc. The regular shaking and jarring could not possibly do our homes andproperty any good.


In October 1995, a charge greater than 55 pounds of HE was detonated. Pantex Plant does not plan to explode charges larger than 55 pounds of HE in thefuture. Should a larger charge be exploded in the future, the plant wouldperform appropriate NEPA review for that charge.

RC: 08.003

DOC: PC-025/48

Page 4-125, what are the impacts to animals especially birds as a result ofthese detonations? [Aren't] detonations generally used by construction industryto chase off nesting birds?


Detonations have been shown to disperse animals from a given area. However, these dispersals and the impacts are usually considered temporary innature. Many devices (including detonation) have been used with various degreesof success for bird control by some firms and agencies. See section 4.9, BioticResources, for a discussion of animals at the Pantex Plant.

RC: 08.004

DOC: PC-033/2

... On page 4-122 the map shows a noise measurement location marked "B"that is fairly close to the target range. The table on page 4126...lists theselocations as having been tested on 9-9,15, and16, respectively. Could youplease tell me if these were the times when qualifying was taking place at thetarget range, or were these just normal practice days? If the qualifying wastaking place I would like to see earlier and later times of day for thereadings. It seems very loud at my house when they are qualifying and theygenerally start very early in the morning, approximately 5-6 a.m. and sometimesare firing late at night, approximately 10 p.m. Could you please let me knowalso where that measurement location "B" is for certain? If it isclose to my house, where it is located and what it looks like?


Volume I, section 4.8.1, Table and Figure 4.8.11, show thatnoise measurements were made at location "B" (close to the targetrange). These measurements included the peak sound level from the vicinity ofthe target range. These measurements were made at 1:07 p.m. (9/9/94) and 8:40a.m. (9/15/94). No noise measurements were performed on 9/16/94. The peakvalue of sound was 47 dB at 4,000 Hz. The locations A and E are also close tothe target range (volume I, section 4.8.1, Figure 4.8.11). Sound measurementswere made at location A, on 9/9/94, at 9:45 a.m., 10:05 a.m., and 1:40 p.m. TheLeq measurements were 42, 48, and 43 dB respectively. Sound measurementswere also made at location E, on 9/15/94, at 9:45 a.m. and 10:00 a.m. The Leqmeasurement at location E was 43 dB and the peak value of sound was 42 dB at4000 Hz. The measurements were made with portable instruments. Themeasurements were made close to residences L4 and L5.

3.9 Biotic Resources

RC: 09.001

Doc: CO-008/19

Page 4-135, Paragraph 3: "Radiological surveys of beef cattleraised..." Please clarify this statement and provide the citation. Whattype of studies were done, when were they conducted, and by whom?


Radiochemical studies were conducted comparing cattle grazed on PantexPlant Site with control cattle grazed at the Bushland Experiment Station west ofAmarillo. The beef cattle food chain pathway was investigated by analyzing soil,native vegetation, grain, and cattle tissue samples. The study determined thatmeat (from cattle) grown on or near Pantex Plant did not represent aradiological hazard to the public because levels of these radionuclides were farbelow accepted guidelines.

The study was conducted in 1981 at three locations: a pasture 1-milewest of the Burning Ground at Pantex, the Texas Tech feedlot in the southwesternpart of the Pantex Plant Site, and the Texas A&M Experiment Station atBushland (west of Amarillo).

The study involved 11 scientists including L.C. Hollis (a veterinarianfrom the Texas A&M Veterinary Diagnostic Lab in Amarillo), J. M. Horton(Director of the Killgore Beef Cattle Center in Panhandle, Texas), and ninestaff scientists from Los Alamos National Laboratory.

The statement in volume I, section, was based on a reportentitled Supplemental Documentation for an Environmental Impact StatementRegarding the Pantex Plant, Agricultural Food Chain Radiological Assessment(LLNL 1982). This report, published in December 1982, was prepared in support ofthe 1983 Pantex EIS. Section has been revised to reference this studyand the following text has been added to this section in this EIS, "Thestudy indicated that if beef consumption of 79 kg/yr is assumed then the 50-yrdose commitment to an adult from ingestion of ground beef at 1.6 x 10-4pCi/g weight would be 0.2 mrem to bone, 0.01 mrem to kidneys, and 0.01 mrem toliver. These values are 500 times below the radiation dose each year fromnatural background."

RC: 09.002

Doc: CO-008/20

Page 4-139, Paragraph 1: Please clarify whether the type of "stocktank" is an earthen structure on one of the drainage-ways to the playa oris a galvanized or metal structure.


This stock tank is an earthen pit, approximately 5 to 6 feet deep.

RC: 09.003

Doc: CO-008/21

Page 4-139, Paragraph 2: "There are five playa Wetlands in thevicinity of Pantex Plant Site..." Do you mean 5 playas designated aswetlands? There are many more than 5 playas in the vicinity of Pantex.


Your interpretation is correct. The text in volume I, section,has been modified to read "There are six playas on DOE owned or leased landin the vicinity of the Pantex Plant Site. Playas 1, 2, and 3 on the main plant;Playas 4 and 5 on land leased from Texas Tech University; and Pantex Lake". The statement in the Draft EIS was based on the Wetlands Delineation study byHerrera Environmental Consultants published in 1995 (MH 1995) which delineatedPlayas 1-4 and Pantex Lake in accordance with guidelines in the Army Corps ofEngineers Wetlands Delineation Handbook (USCOE 1987). Playa 5 has not beendelineated.

RC: 09.004

Doc: CO-008/22

Page 4-140, Paragraph 2: Please correct typo "P. amphibum."


P. amphibum now reads P. amphibium.

RC: 09.005

Doc: CO-008/23

Page 4-142, Paragraph 1: How do you explain the significant decline fromthe 1993 to the 1995 floristic survey in the Echniocereus viridifloruspopulation?


Dr. Marshall Johnson (who conducted these floristic surveys) noted adecline in all age classes of this cactus, from 200 in June 1993 to 50 in July1995 and then an increase to approximately 75 in September 1995. He stated thatthe cause of the decline was unknown but said one could speculate that "(1)a high mortality rate prevails among the seedlings; (2) the greater luxurianceof the growth of HPG grass and forbs obscured the presence of the smaller plantsas compared to their possibly higher level of visibility in June; or (3) acombination of (1) and (2) above."

RC: 09.006

Doc: CO-008/24

Page 4-142, Paragraph 2: In the statement, "wetland resources wouldbenefit from continued operations since officials are taking steps to...,"what specific steps have been agreed upon?


A 29 May 1996 response from the U.S. Fish and Wildlife Service (FWS)stated the FWS "fully support Pantexs proposed plans to manage portions ofplant property for the benefit of native resident and migratory wildlifespecies, including the proposed playa basin management plans. As described inthe biological assessment, the Pantex Plant and surrounding area currentlycontains and supports significant wildlife resources, but with proposedmanagement, the area has the potential to support an even higher diversity andnumber of native plant and animal species, to the mutual benefit of both humansand wildlife." Appendix E of the 1996 Biological Assessment for the PantexPlant (DOE 1996d) includes the following management plans alluded to in the 29May 1996 FWS letter that are being used to protect wetlands at Pantex Plant:

· Interim Guidance Document for Pantex Plant Playas.

· Management Plan for Playa 2 Management Unit: Phase One.

· Natural Resource Management Plan for Pantex Plant,Amarillo, Texas.

· Management Plan for Revegetation of Playa Buffer Areasand Formerly Cultivated Areas.

· Update for FY94, Groundwater Protection ManagementProgram Plan, Pantex Plant.

· Land-Applied Chemical Use Plan for the Pantex Plant.

RC: 09.007

Doc: CO-008/25

Page 4-142, Paragraph 5: Please correct typo, last sentence. "...butthese impacts would not (insert "be") considered significant."


Suggested change has been made in the FEIS.

RC: 09.008

Doc: CO-008/26

Page 4-143, Paragraph 4: In the statement, "Environmental protectionactivities currently ongoing at the plant meet all regulatory requirements ofFWS," please cite the letter from FWS.


Environmental protection measures currently ongoing at Pantex Plantsupport sections 2(b) and 7(a) of the Endangered Species Act (ESA) whichrequires protection of threatened and endangered species. A biologicalassessment submitted by Pantex Plant officials on 9 May 1996 fulfilled section 7ESA requirements for Federal agencies to consult with the U.S. Fish and WildlifeService (FWS). A 29 May 1996 response from the FWS commended "Pantex fordeveloping a comprehensive and complete BA (biological assessment), and concurwith your assessment that the proposed action is not likely to adversely affectany Federally listed threatened or endangered species." This letter isincluded in volume II, appendix J.

RC: 09.009

Doc: SG-009/1

While we recognize Pantex efforts to discover the amount and extent of thehistorical contamination and Pantex current contaminant reduction in progress,we are concerned about impacts to wildlife from historic contamination listed inthe report. Due to the unknown extent of the historical contamination, TPWDrequests Pantex continue to describe the extent of contamination and encouragesefforts to clean up or rectify the contaminant impacts. Consider incorporating atimeline showing past efforts and future efforts in contaminant identificationand cleanup. If available, please send Joan Glass of our staff copies ofcompleted reports describing potential wildlife impacts.


The status of the contamination clean up effort is discussed in volumeI, section (Soil and Sediment Quality), with additional informationprovided in chapter 15 (Environmental Restoration) of the EnvironmentalInformation Document (EID) (Pantex 1996). A number of wildlife studies havebeen conducted at the Pantex Plant to identify resident and migratory species,in particular reptiles, birds, and mammals. Faunal studies summarized in volumeI, section 4.9 (Biotic Resources), and chapter 7 (Ecology) and chapter 16(Radiation and Hazardous Chemical Environment) of the EID, do not indicatesignificant contamination impacts to wildlife from Pantex operations. A timeline has been added to volume I, section summarizing previous and futureclean-up activities. A copy of the Pantex Biological Assessment (DOE 1996d) isbeing sent to Ms. Joan Glass.

RC: 09.010

Doc: SG-009/2

TPWD is also concerned about the unidentified minnow species from PantexLake. Because there are 6 Federally listed Notropis with 2 additional Statelisted Notropis species, the minnow species should be identified by a competentscientist. You may request assistance in identification of the minnow bycontacting the TPWD Freshwater Studies Program aquatic biologist, Kevin Mayes at(512)7546844. Upon contacting Mr. Mayes for identification, a minimum of 5specimens can be send to him at 300 C.M. Allen Parkway, Bldg. B, San Marcos, TX78666.


Pantex Plant personnel re-sampled the stock tank near Pantex Lake. Nospecimens of Notropis were found, but a number of fathead minnows (Pimephalespromelus) and one black bullhead (Ictalurus melas) were collected. It isunknown whether the identification referenced on page 4139 of the Draft PantexEIS was a misidentification, but that possibility is being investigated.

RC: 09.011

Doc: PC-034/11

Comment (and background information):

In Volume I, 4.2 "Impact Assessment Methodologies" (p. 4-4), under"Biotic Resources," it is stated that "Impacts to wetlands aremostly related to the potential discharge of contaminants to the playas."


How can impacts to wetlands be related to potential discharges ofcontaminants? Only actual discharges can have impacts!


The sentence has been revised to read "Impacts resulting fromwastewater discharge into a wetland system are evaluated, recognizing theeffluents would be required to meet Federal and state standards."

RC: 09.012

Doc: PC-025/49

Table, what is the impact to a human without ear protection over a1/4 mile range? A lifetime for residents?


Airblast noise resulting from detonation of HE is impulsive in natureand generally less than a second in duration. Personal exposure to 140 dB (from55 lb of HE) would not be anticipated to cause hearing damage from singleimpulse events. OSHA provides guidelines to ensure worker protection inelevated noise environments. Workers are not anticipated to have hearingimpairment at a distance of 1/4 mile from Pantex activities. The modelingresults provided in volume I, section 4.8.1, Table, were derived fromdata collected by Pantex personnel.

The OSHA 8-hour time weighted threshold limit value for a 140 dBexposure is 28 seconds. In 1994, 60 detonations of high explosives occurredfrom charges weighing 5 to 47 pounds. Due to the limited number of highexplosive detonations done each year and the short duration of each (i.e., lessthan 1 second), lifetime residents are not anticipated to be adversely affectedby high explosive detonations as currently conducted. As noted in volume I,section, additional NEPA review would be conducted if charges in excessof 55 pounds are detonated.

RC: 09.013

Doc: PC-025/50

Section 4.9. Given the semi-arid climate, what impacts have occurred as aresult of fires in the recent past? If fires have occurred in the past why isn'tit included in the affected environment? Does Pantex use controlled burns tocontrol vegetation? What is the impact? Does the plant dredge the playasystems? What is the impact? Is there a need to dredge in the near future?


The commentor asked seven questions which are answered in order. Wildfires have occurred in the Pantex Plant vicinity in the past. Propertyowned or controlled by DOE has been burned by uncontrolled wildfires. There isno mechanism to assess the impacts of past burns. Controlled burning is notused for vegetation control on DOE-owned land. Playas on DOE-owned land are notroutinely dredged. Playa 1 was deepened to increase water storage capacitybefore it was designated or delineated as a jurisdictional water of the U.S.(wetland).

RC: 09.014

Doc: PC-025/51

Page 4139. There appear to be more than five playa lakes in the vicinity ofPantex Plant (see page 4-56 of this EIS). Pratt Lake, Pantex Lake, and severalto the north and south of the site, please comment. Page 4142. Pit StorageActivities. Please describe non-adverse impacts to biotic resources.


Only playas at the Pantex Plant Site and Pantex Lake were investigatedunder biotic resources. See response to comment 09.003. Pratt Lake isdiscussed in section 4.6 (Water Resources) and included in volume I, Figure4.6.1.11 (Primary Outfalls and Floodplains at Pantex Plant Site). Also seeresponse to comment 06.058.

RC: 09.015

Doc: PC-025/52

Page 4-142. ER activities. "...would not considered significant."?


The sentence has been revised to insert "be" between "not"and "considered."

RC: 09.016

Doc: PC-025/53

Page 4-142. Waste Management: "... will have a long-term beneficialimpact on plant and animal species?" Landfills and an open burning activitythat fumes metals and radioactivity are considered beneficial? Please providedocumentation supporting statement. Any direct impacts to non-threatened,non-endangered species or non-wetlands? Please provide documentation supportingposition.


Volume I, section 4.13 (Waste Management) summarizes waste managementactivities to collect and dispose of hazardous, nonhazardous, radioactive,low-level radioactive mixed hazardous wastes in accordance with the PantexPlants Resource Conservation and Recovery Act (RCRA) Part B Permit. Volume I(Air Resources), section 4.7, summarizes air emissions at the Burning Ground. Data on the onsite construction debris landfill and burning ground emissionsindicate that they are being conducted in accordance with RCRA and Clean Air Actguidance. One of the intents of RCRA waste management regulations is tominimize adverse impacts to plants and animals. Recognizing that waste cannotbe simply ignored, the implementation of regulated forms of treatment anddisposal is more advantageous than the practices prevalent throughout Americanindustry prior to the 1970s.

RC: 09.017

Doc: PC-025/94

Biotic Resources [section] does not analyze the number of playas within theROI.


See responses to comments 09.003 and 09.014. Volume I, section 4.2 hasbeen revised to indicate that the ROI for biotic resources was restricted toinvestigation of flora and fauna at the Pantex Plant Site and the nearby PantexLake, which is also owned by DOE. Also see response to comment 06.058.

RC: 09.018

Doc: SG-003/7

This comment is a duplicate of comment 09.011.

RC: 09.019

Doc: SG-003/27

Page 4-4, Biotic Resources: The text states that U.S. Fish and WildlifeService and appropriate State agencies have been used in the process ofdetermining whether Pantex Plant operations would impact any plant or animal.This is incorrectly stated. The Trustees understand that an ecological screenhas not yet been completed for this site and an ecological risk assessment hasnot been performed. The text should be corrected to reflect what has actuallybeen assessed at this site and which agencies were involved.


A Biological Assessment (BA) of the Pantex Plant was submitted to theU.S. Fish and Wildlife Service (FWS) by the Amarillo Area Office on May 9, 1996in accordance with section 7 interagency consultation requirements of theEndangered Species Act (ESA). See response to comment 09.006 regarding thefavorable FWS reply. The BA was prepared in accordance with ESA guidance andmay not meet the requirements for a Natural Resources Damage Assessment requiredunder Section 107 of the Comprehensive Environmental Response Compensation andLiability Act. However, Pantex officials have had meetings with attendance byEPA, TNRCC (representing the Texas Parks and Wildlife Office), and the TexasGeneral Land Office. This additional information has been incorporated intovolume I, section 4.2 (Biotic Resources subsection) and chapter 6 (EnvironmentalCompliance Requirements for Implementing the Proposed Action and theAlternatives).

RC: 09.020

Doc: PC-028/8

The Biotic Resources (para and cultural resources (para be in [a] higher risk category. The higher risk not only includes possiblecontamination, but even more probable, the damage caused by increase of relatedactivities like facility preparation, transportation to and from, and even fromthe additional 150+ humans to be placed on or about the Manzano WSA full time. Select another site, not KAFB.


The analysis of both biotic (volume I, section and culturalresources (volume I, section leads to the conclusion that no impacts tothese resources are to be expected by the relocation alternative. However, thedecision to relocate or not would be made after consideration of environmental,cost, and other technical factors.

3.10 Cultural Resources

RC: 10.001

Doc: CO-008/27

Why were the agricultural based lifestyle and the community of Panhandle, asa cultural impact, not evaluated? Most people in the region are only onegeneration removed from the farm or their grandparents were farmers. Also, thesupportive business and families are involved in this culture. The culture ingeneral, and the resources associated with it, were not mentioned.


Volume I, section 4.10 addresses the prehistoric and historic resourceswithin the boundaries of Pantex Plant. Twelve historic agricultural sites havebeen recorded within the plants boundaries.

The community of Panhandle is located approximately 16 kilometers (10miles) east of Pantex Plant, and is thus outside of the area addressed bysection 4.10. A discussion of impacts to the agriculturally based lifestyle ofthis community is out of scope for this section. An ethnographic discussion ofagricultural lifestyles and resources as a "culture" are likewiseconsidered to be out of scope in this section of the EIS. Agriculturalresources within the plant boundaries and the ROI are discussed in volume I,sections 4.4, Land Resources; 4.5, Geology and Soils; 4.6, Water Resources; and 4.11, Socioeconomic Resources.

RC: 10.002

Doc: HT13/37

... Is it your position that [this EIS] adequately analyzes archeologicalsites for historic preservation purposes [at the Manzano Weapons Storage Area]?


To elaborate on the response given at the public hearing, the comment isconcerned with cultural resources at the Manzano Weapons Storage Area (WSA) onKirtland Air Force Base (KAFB). The KAFB Environmental Management Division hascoordinated historic preservation efforts, including all cultural resourcesurveys and findings within the Manzano WSA as well as the base. Twenty-sevenarchaeological sites have been located within the WSA by a 100% ground surveyconducted by Argonne National Laboratories. As discussed in volume I, section5.5.1.8, 22 of these sites have been recommended for inclusion or eligibility tothe National Register of Historic Places.

RC: 10.003

Doc: PC-034/14

Comment (and background information):

In volume I, ¤ "Native American Groups" (p. 4-150),it is stated that "An inventory of traditional Native American sitesidentifying features such as petroglyphs, ceremonial areas, or sacred sites hasnot been conducted nor have any such sites been identified at Pantex Plant (DOE1995K:4-280)." This statement is incorrect! Numerous archaeologicalsurveys have been conducted on both DOE-owned and DOE-leased land for thepurpose of identifying and recording of all Native American sites including anypetroglyphs, ceremonial, or sacred sites. That part of the sentence that statesno such traditional sites have been identified is correct. It is worthy of notethat the stated reference is incorrect both qualitatively and quantitatively! Page 4-280 of the given reference discusses Oak Ridge National Laboratory;however, when one turns to page 4-300 of that reference one finds: "NativeAmerican resources associated with these groups have not yet been identified atPantex, but the remains of temporary campsites, hunting locations, ceremoniallocations, or isolated burials are possible."

Question: How can these words be used as a reference for the statement inthe Pantex SWEIS? And why doesn't DOE know that these surveys have beenconducted?


The discussion of Traditional Cultural Properties (TCPs) is misleadingas presented in the draft document and has been clarified. The identificationof TCPs, as differentiated from archaeological or historical features, has beenconducted through consultation with the 10 tribes with recognized potential tiesto the area. There have been numerous cultural resource (archaeological andhistorical) surveys conducted at Pantex Plant that are discussed in volume I,section 4.10, and these surveys have no doubt identified features that could beTCPs. TCPs are identified through specific studies conducted to addressproperties or areas that are important in a communitys historically rootedbeliefs, customs, and practices. Studies of this type would typically entail adetailed ethnographic study involving consultation with Native American Groupswith traditional or ancestral ties to the area which is now Pantex Plant, andpossibly field inspections with these individuals prior to, or associated with,any survey project. This consultation is important as many TCPs may not bediscernible as such to anyone but a knowledgeable member of the group thatascribes significance to them.

The reference to page 4-280 is a typographical error. Page 4-280 wasthe location of the referenced section in the draft document. The correct pagenumber is indeed 4-300 in the Final Programmatic Environmental Impact Statementfor Tritium Supply and Recycling (DOE 1995k). This has been corrected in thefinal version of the Pantex EIS.

The words used as a reference in the Pantex EIS are accurate, andrepresent the status of known resources belonging to historic Native Americangroups that occupied or utilized the Pantex region. There is a possibilitythat campsites, hunting areas, ceremonial sites and isolated burials may bediscovered within the land that comprises the Pantex Plant. It is also possiblethat native plants with traditional medicinal or spiritual uses, landmarksimportant in religion, myth or visions, or areas of supernatural connotationsthat are kept secret until they are threatened, could be located within thisarea of land on the Texas panhandle. Cultural resource management involves muchmore than the survey and excavation work that DOE has conducted at the plant. It is an on-going management tool that traces and protects history andprehistory, as well as protecting the concerns of current Native Americanpeoples.

RC: 10.004

Doc: HT17/33

I am a member of the Cheyenne-Arapaho Tribes of Oklahoma, which is aFederally recognized tribe. I did receive a letter dated September 15th, 1994in regard to a summary notification of Native Americans. They mentioned severaltribes on there, and in going through this letter I noticed that the NorthernCheyenne was not on here; neither was the Northern Arapaho Tribe. I would askthat they be included in this Environmental Impact Statement.


The Northern Cheyenne and the Northern Arapaho Tribes have been includedin chapter 9, the List of Agencies, Organizations, and Individuals to whomcopies of the EIS are sent.

RC: 10.005

Doc: HT17/34

There's a lot of concerns as far as being a member of the Plains IndiansTribes. ...We have a lot of historical and traditional cultural propertiesrelated to this area, all the way down from...the northern Dakotas down to thePalo Duro Canyon. So, we do have some sites that are significant to us,...and Iam concerned about this. ...I would ask that you continue to address this on agovernment-to-government type basis and consult with the Federally-recognizedtribes


Cultural resources addressed in the Pantex Plant EIS only address knownor suspected areas or features within the boundaries of the plant. These arediscussed in volume I, section 4.10 of the document. Areas of traditionalcultural properties (TCPs) have not been identified by past inventories orresearch within the plant boundaries; however, TCPs of importance to varyingNative American Groups are located throughout the plains. DOE respects andprotects the TCPs when they are identified, and will continue to consult onthese issues with Native American tribes, governments, and groups.

RC: 10.006

Doc: HT17/35

...there are other tribes out there that are not Federally recognized whoyou might consider consulting with as well.


Consultations are made between the DOE and Federally recognized NativeAmerican Tribes, governments and groups, as well as Pan-Tribal groups such asthe Owens Valley Board of Trustees.

RC: 10.007

Doc: HT17/36

There's a lot of other concerns that I have, especially with the vegetationwithin the area. I also have some concerns with the potential adverse [effectsfrom] inadvertent discoveries of artifacts or human remains that may be there.


As discussed in volume I, section 4.10.2, any discovery of subsurfacecultural features or artifacts identified during land disturbance activitieswill be appropriately mitigated after consultation with the State HistoricPreservation Office (SHPO). Typically, in discovery situations, grounddisturbing work is halted until a decision can be made between the consultingofficials as to avoidance, collection, testing, or excavation. If human remainsare located the requirements of the Native American Graves Protection andRepatriation Act (NAGPRA) are followed; work is halted and the Pantex CulturalResource Media Manager, the Texas SHPO, and concerned Native American Tribalgroups and governments are immediately notified. Construction activities arenot resumed until the remains are removed by a tribal member, archaeologist orcoroner. It may also be decided to leave the remains in place, reroute theconstruction, and avoid further disturbance to the site. These decisions aremade on a case-by-case basis.

There have been no vegetated areas or specific plants identified to-datewithin the boundaries of the Pantex Plant that have been identified astraditional cultural properties. Traditional use of specific plants forreligious or medicinal purposes as well as harvesting areas may be identified asareas of future concern, but these have not been identified.

RC: 10.008

Doc: HT17/37

I am the designated NAGPRA representative for the Cheyenne Tribe. I don'tknow if any of you are familiar with the Native American Graves Protection andRepatriation Act of 1990. And that was one of my other concerns, that I noticedthat it was cited inside this study, but it wasn't really in detail.


DOE is knowledgeable of the Native American Graves Protection andRepatriation Act (NAGPRA) and will abide by its direction if mortuary remainsor related cultural items are located within Pantex Plant. The rights of linealdescendants and members of Indian Tribes to Native American human remains andfunerary objects with which they are affiliated will be instituted when and ifthese remains are located. Consultation with the appropriate State, Federal andTribal representatives will be instituted and if requested, reburial or atransfer of ownership of the items will be instituted. NAGPRA is mentioned involume I, section 4.10, but is not discussed in detail as no human remains havebeen located on Pantex Plant Site.

RC: 10.009

Doc: HT17/38

And I did this letter that there [were] scheduled visits to thetribes, and I would just like to ask if those visits have occurred, and if theyhave occurred, I would like to request copies of the comments that were receivedfrom those tribes.


The Pantex Plant Cultural Resource Manager visited the 8 Native Americantribes listed in volume I, section on June 22, 23, and 24, 1994. Thetribes did not submit comments regarding these visits.

RC: 10.010

Doc: PC-027/6

Reference historic and prehistoric resources in the Summary (Page S-24) andin the volume I - Main Report page 5-59, item "Twenty-sevenhistoric and prehistoric archaeological sites have been found in the ManzanoWSA. Of these sites, 8 have been recommended for inclusion in the NationalRegister of Historic Places and 14 others are considered to be potentiallyeligible for inclusion." Noted that you said there would be no impact tocultural and paleontological resources, but they may be so locked up because ofsecurity requirements that nobody will be able to see them. I would think thatinclusion in the National Register of Historic Places might involve thepossibility of a visit or a look at the site. Will that be possible ifstrengent security requirements are in effect?


The Manzano WSA is a secured area. Sandia National Laboratoriesprovides security to the facility and it is not available for public accesswithout approval. This policy would continue whether Manzano WSA is chosen forinterim pit storage or not.

RC: 10.011

Doc: PC-028/5

Page 5-58, para By placing the Pit storage area withinManzano WSA, the increased security will certainly reduce, even prohibitscientific and public access to the 27 historic sites. Consider the otheralternative sites which do not present this type of problem.


At present, the Manzano WSA is a secured access area. Scientific andpublic access to the area must be obtained from the U.S. Air Force. If thisarea is chosen for pit storage, access to the 27 historic sites is not expectedto change. The Secretary of Energy will consider the environmental impacts ofeach alternative along with mission requirements, technical factors, and publicinterest before issuing the Record of Decision.

RC: 10.012

Doc: PC-028/9

The Biotic Resources ( and cultural resources ( will be inhigher risk category. The higher risk not only includes possible contamination,but even more probable, the damage caused by increase of related activities likefacility preparation, transportation to and from, and even from the additional150+ humans to be placed on or about the Manzano WSA full time.


The analysis of both biotic (volume I, section and culturalresources (volume I, section leads to the conclusion that no impacts tothese resources are to be expected by the relocation alternative. However, thedecision to relocate or not would be made after consideration of environmental,cost, and other technical factors.

RC: 10.013

Doc: PC-033/7

I request a copy of the transcripts or notes taken from meetings with any ofthe affected tribes mentioned in the Draft SWEIS. Gordon Yellowman commented atthe recent hearing on June 25, 1996 and asked for a copy of the meeting notes. Nan Founds replied stating that they did not visit the individual tribes, butsent them a letter. She will send him a copy of the letter and commentsreceived. I am requesting copies of this [letter] and the comments received.


Comment noted. Refer to response to 10.009.

3.11 Socioeconomic Resources

RC: 11.001

Doc: HT03/1

Yes, there is one confusion factor, looking at all three PEISs, and that isthey use different multiplications for the number of direct jobs versus theimpact in the community.


To elaborate on the response given at the public hearing, a number ofcomments relate to the economic multipliers used in the Pantex EIS, SSM PEIS,and S&D PEIS. (Refer to Comment 11.016 which has been repeated by variouscommentors.) A general explanation of the multipliers is provided below toavoid duplication of responses to all such comments. Further details areprovided in response to specific comments later in this section.

All three documents referenced by the commentor use the U.S. Bureau ofEconomic Analysis regional economic model known as Regional Input-OutputModeling System (RIMS II) as the basis for employment and income impactanalysis. This model is used by government agencies, university researchers, andprivate economists to measure regional economic impacts. It is designed to besensitive to differences in the economy from one region to another.

The differences in the employment multipliers presented in the threedocuments are not because of the models used but because of the differences inthe input provided to the models by the authors of those documents. Theseinputs relate to a number of factors including the size of the region ofinfluence, the type of activity involved in the projects being considered(assembly/disassembly versus construction of a light water reactor, forexample), the number of direct employees needed, the average income per employeeor total payroll, the money spent on local purchases of goods and services tosupport Pantex operations or construction and operation of new facilities, themoney spent by the Pantex Plant workers in the local economy, and the averagewage rate applied to indirect workers. Since all inputs to the model areconverted into dollars, different wage rates applied to direct and indirectworkers can alone generate different indirect employment multipliers. Theactivities involved in the three programs described in the three referenceddocuments are different and each requires significantly different inputs whichmay or may not be available within the region of influence (ROI). This alsocontributes significantly to different multiplier values in the three documents.

RC: 11.002

Doc: HT10/2

The question is, why is there no cumulative impact analysis in thesocioeconomic impact analysis of past actions, like the cancellation in 1988 ofthe DOE program of a mine geologic repository for spent nuclear fuel andhigh-level radioactive waste in Deaf Smith County? That particular action was anaction that [caused] a great economic disaster here in the [Texas] Panhandleregion. And right now we are just barely coming out of..., or just towards theend of coming out of, that particular recovery from that particular action.


Cumulative impacts include the incremental impacts of the actions whenadded to other past, present, and reasonably foreseeable future actions. Socioeconomic impacts of past actions, though not discussed individually byprojects, are reflected in the baseline employment and population estimateswhich form the basis for evaluation of impacts from the proposed action andalternatives. Thus, any impacts from the cancellation of the repository programin Deaf Smith County on the Pantex ROI would already have been included in thedescription of the affected environment and the projections under the No ActionAlternative. Cumulative economic impacts of concurrent DOE actions for whichsufficient information was available have been discussed in volume I, section4.11.5. As mentioned on page 4-7 of the Draft EIS, information on other Federal(non-DOE), state or local projects including private developments was soughtthrough contacts with federal and state regulatory agencies, Amarillo EconomicDevelopment Corporation, Panhandle Municipal Water Authority, and the City ofAmarillo. This effort yielded only one project (future closure of Helium Plant)that would contribute to the cumulative impacts in the Pantex Plant ROI. Cumulative impacts of this project have been included in volume I, section4.11.5.4.

RC: 11.003

Doc: HT10/3

And then the more recent announcement of closure of the U.S. Department ofInteriors Bureau of Mines Helium Operation. [This is] not addressed anywhereunder cumulative impacts.


Volume I, section has been expanded to note that the HeliumOperations Plant, a facility that employs approximately 175 people, will bedownsized (employing 30 to 40 workers). As a result of Congressionallegislation, on October 9, 1996, the President signed the Helium PrivatizationAct of 1996 directing helium operations to discontinue production and sale ofrefined helium by no later than 18 months from the date of enactment (i.e.,April 1998). The downsizing will occur over the next 18-months.

RC: 11.004

Doc: HT08/1

... It will hurt the economy of this city to have another payrolleliminated... Already gone are the Air Force base, the helicopter plant, thehelium plant, and Pantex. What next? Cutting the payroll of this city further,I am against wholeheartedly.


The decisions to close federal facilities or operations are made bydifferent federal agencies in the context of national policies. DOE hasconsidered the cumulative economic impacts of these past actions in the baselineevaluation of the existing environment. DOE will further consider economicimpacts in the decision-making process for projects for which it is responsible. See response to comment 11.002.

RC: 11.005

Doc: HT11/19

Well, one concern that Id like to state is in your risk assessment, [whichis based] on 1990 census figures.... Because Las Vegas itself has changed somuch in the past six years, I think that...the 1990 census figures probablyarent...the ones to use.


Las Vegas has grown substantially since the 1990 census was taken.However, risk analysis requires population data by the smallest geographicalunits of the city or the region of influence such as Census Tracts or CensusBlocks. In fact, it is further broken down by sectors within a 80 kilometers(50-mile) radius circle from the project site in order to identify the potentialnumber of people who may be at risk at different distances from the projectsite. Only the 1990 census information is available at that level of detail(census tract and block level) and is, therefore, utilized in risk assessment toprovide a consistent basis for comparison of sites in different states.

RC: 11.006

Doc: HT11/32

We also, depending upon the number of shipments and nature of theshipments,...are concerned here with perceptions of risk and possibleconsequences of that on the tourism industry. This is...the mainstay of Nevadaeconomy, and if there were to be an incident or accidents on the interstate,especially near The Strip, this could have various severe consequences, economicconsequences.


Nuclear materials have been shipped to the Nevada Test Site (NTS) sincethe early 1950s. Radioactive waste has been shipped to the site since 1961. There is no historical evidence that perceptions associated with nuclearmaterial or waste shipments to the NTS have affected the economy of Las Vegas orresulted in a deterioration of tourism in Las Vegas. In fact, the Las Vegasarea has experienced remarkable growth over the past three decades. Tourism insouthern Nevada has increased from 21 million visitors in 1990 to a forecast 31million in 1996. Therefore, there is no reason to conclude that futureshipments to NTS would adversely affect tourism industry or the States economy.

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Since its establishment in 1975, the DOE Transportation SafeguardDivision has accumulated more than 119 million kilometers (74 million miles)over the road experience in transporting DOE owned cargo without any accidentsthat resulted in release of radioactive material. Section 6.3 of the PantexPlant Safety Information Document provides a listing of accidents resulting indamage to safe secure tractor trailers (Pantex 1996a).

RC: 11.007

Doc: HT14/6

But Im wondering just in the general proximity how many jobs, if any, willthis create for the Tri-Cities.


To elaborate on the response given at the public hearing, as stated involume I, section, approximately 150 additional personnel would berequired for the interim storage of pits at the Hanford site. This numberrepresents less than 1.0% increase in the total Hanford Site workforce. Most ofthe workers can be hired locally.

RC: 11.008

Doc: HT02-02/1

I have come to speak on health and safety issues, as well as the feasibilityof having plutonium, other nuclear materials, and other types of hazardousmaterials and chemicals in our front yard,...over the areas major water supply,and in this very productive and vital agricultural area[a] major food sourceforthe nation as well as the world just for Amarillos "[powers] that be"to possibly create a few more jobs and wealth for themselves.


The Pantex EIS has been prepared to evaluate the environmental impacts(including health and safety) of continued operations of the Pantex Plantirrespective of whether they occur in the rural areas surrounding the plant siteor in Amarillo. DOEs goal is to meet its mission requirements in a manner thatprotects the public, workers, and the environment; job creation may be anadditional benefit but is not the primary objective of any of the proposedalternatives. See response to comment 14.018.

RC: 11.009

Doc: HT01-08/2

Likewise, we believe that Pantex can be a site where good, high-paying jobsare created in a work environment that includes potentially dangerous materials. When measured in terms of payroll, Pantex is by far the areas largest employer. With 3,500 employees at the plant, a job multiplier of 3.87 shows that Pantexis responsible for a total of over 13,500 jobs in this region. This multiplierwas established by Dr. Ray Perryman at Southern Methodist University. Themultiplier reflects the fact that the money that Pantex brings into the localeconomy supports many retail, medical, educational, finance, insurance, and realestate jobs. All told, employment related to Pantex represents over 12% of alljobs in the Amarillo metropolitan area. I urge the DOE to correct thesocio-economic impact portions of all three EIS documents to accurately reflectthe impact of Pantex on our local economy.


DOE chose to use the U.S. Bureau of Economic Analysiss RegionalInput-Output Modeling System (RIMS II) as the basis for employment and incomeimpact analysis. This nationally recognized model is used by governmentagencies, university researchers, and private economists throughout the UnitedStates.

Pantex is a major contributor to the employment in the region. However,as explained in response to comment 11.001, the employment multiplier is aderived value and would differ even when the same researcher is looking atdifferent industrial activities. We believe that a multiplier of 1.65 indirectjobs for each direct Pantex job which translates to a total job multiplier of2.65 is more realistic when considering the proposed and alternative actionsbeing analyzed in the Pantex EIS. Dr. Perrymans analysis (see Amarillo EconomicDevelopment Corporation Release dated August 3, 1993 [AEDC 1993] and PerrymanConsultants, "Analysis Shows Pantex Plant Adds a Billion in Revenues andThousands of Jobs to Amarillo Economy," Press Release [Perryman 1993]) doesnot identify any specific job multiplier. In one place, he mentions that PantexPlant employs 3,100 persons. Then he estimates that the total employmentresulting from Pantex Plant operations is 11,688. This gives us a job multiplierof 3.77. (The commentor, using the rounded figure of 12,000 instead of 11,688,arrives at a multiplier of 3.87.) In the same article, however, Dr. Perrymanstates that Pantex Plant expansion by 2,400 jobs would result in 5,312 totaladditional jobs. This would imply a job multiplier of only 2.21, not 3.87.Should it be assumed that he is using two job multipliers because in the PantexPlant expansion scenario, he is looking at different activities (industries) atthe plant, which include peaceful uses for plutonium, operation of a linearaccelerator, and long-term storage of plutonium and not the current operationsof assembly and disassembly of weapons. Your comments have been considered bythe SSM PEIS and S&D PEIS authors and are addressed in their respectivecomment response documents.

RC: 11.010

Doc: HT01-08/1

And theres not enough words to say how important Pantex is to our jobsituation in Amarillo. If you use a multiplier index in the total take on oureconomy, were talking about [13,500] jobs out of the 3,500 job base that is atPantex. Needless to say, from our standpoint, whats truly important to thisarea from an economic standpoint, we strongly urge the DOE to do everything theypossibly can at the Pantex site.


The Department will consider economic impacts along with otherenvironmental impacts, mission requirements, costs and technologicalconsiderations in the Record of Decision.

RC: 11.011

Doc: HT07/2

One of the reasons that employment increased at Pantex by about a thousandpeople was not so much for the increased work in dismantlement, but to invoke asafety culture at Pantex. A lot of these safety infrastructure programs areindependent of the number of units youre doing. Whether you have one weapon ora thousand, you still need your conduct of operations, you still need yoursafety analysis, you still need your safety question determination, et cetera. And none of the numbers Ive seen seem to take into account that you have a baseline infrastructure that you cant go below without losing the safety culture. Id like you to respond to that.


To elaborate on the response given at the public hearing with Pantex EISspecific information, the decrease in the number of jobs from 3,800 workers atthe 2,000 weapon activity level to 3,000 workers at the 1,000 weapon activitylevel and 2,400 workers at 500 weapon activity level is less than it would be ifreduction were in proportion to the reduction in dismantlement. This is mainlybecause the numbers reflect a baseline infrastructure and safety-relatedworkforce which would remain at Pantex regardless of the volume of weapondisassembly activities. Safety at Pantex Plant is given highest considerationand will continue to be given the same consideration in the future.

RC: 11.012

Doc: HT07/3

My response to that, is that it was looked at...without looking at the plantas a total. ...The way the questions were asked, for the specific operations,we gave the numbers, but no one asked the questions about what it would take tomaintain your overall safety infrastructure. I believe thats true.


See response to comment 11.011.

RC: 11.013

Doc: CO-008/65

Page 4-172. It is stated that the work force could reach 10,220. This isbased on all Weapons and Disposition activities being done at Pantex. Pleasediscuss in a manner that shows the time frame break down between construction,weapons and disposition work, and the possibility that everything will not bedone at Pantex.


A workforce of 10,220 represents the cumulative (maximum) workforceassuming that current operations and waste management activities at Pantex Plantwould continue when activities relating to the storage and disposition ofweapons-usable fissile materials reach their full operational level. Thereferenced paragraph on page 4172 of the Draft EIS also indicates thatdisposition activities cannot start earlier than 10 years from the date adecision is made selecting Pantex Plant as the site for disposition activities.Construction of a completely new reactor could take even longer. However, itshould be noted that this discussion is relevant only in the event that Pantexis chosen as the site for long term storage and disposition of weapons-usablefissile materials. That issue is the subject of the S&D PEIS, not thePantex EIS.

RC: 11.014

Doc: CO-008/66

Page 4-172. Provide a work force break down by year and activity. Ifdownsizing is required, and exceeds attrition, please provide a downsizing plan.


Although impacts of various levels of downsizing are evaluated in theDraft EIS, a realistic downsizing plan cannot be developed until a record ofdecision is issued by the Department identifying the level of activity andassociated choice regarding new or upgraded facilities at the Pantex Plant. Thisdecision will not be made before the Final EIS for the Pantex Plant ispublished. The Department will, however, keep the public informed of itsactions on a regular basis and soon after a decision is made. Any decision thatwould result in downsizing would require a formal Workforce Reduction Plan andadditional public participation opportunities in accordance with the NationalDefense Authorization Act of 1993 (Public Law 102-484).

RC: 11.015

Doc: CO-008/67

Page 4-172. Knowing that all of the above activities are likely to belimited to 10 to 30 years, if there is an adverse impact from Pantex downsizing,is there money available to the Pantex ROI for long-term community assessmentand planning?


The Record of Decision on the S&M PEIS will identify whether PantexPlant would be downsized or not. If downsizing does occur, the affectedcommunities can request the DOE to provide financial assistance for communityassistance and planning. The DOE Office of Community and Worker Transition canbe approached to obtain help for the facility and community transition in caseof downsizing.

RC: 11.016

Doc: CO-008/68

Page 4-172. The socioeconomic analysis of the three EISs [is] notconsistent. The SWEIS Summary (page S-17) assumes 1.65 indirect jobs in theregion for every [job] at Pantex. The SSM PEIS (page S-32) assumes 1.16 and S&DPEIS (page 4-205) assumes 3.51. Please explain these differences. Why didntthe DOE use the analysis of the Amarillo Economic Development Commission (AEDC),which is based on local knowledge of the area? Their analysis gives a ratio of2.87 to 1 (REF. Chamber Quarterly, 2nd Quarter, 1996, Amarillo Chamber ofCommerce.)


Refer to the responses to comments 11.001 and 11.009 for generalexplanation of multipliers. The referenced article in Chamber Quarterly (ACC1996) states that AEDC uses a multiplier of 3.9 for jobs at Pantex and goes onto state that the 1,600 jobs projected to be phased out at Pantex couldultimately result in a total loss of 4,600 jobs in all areas of Amarilloeconomy. If this statement is correct, the number of indirect jobs would be3,000 (4,600 total jobs minus 1,600 direct jobs = 3,000 indirect jobs), or 1.88times the direct jobs. The comparable number in the Pantex EIS is 1.65 indirectjobs for each direct job. Please refer to Final SSM PEIS and S&D PEIS fortheir responses to your comment.

RC: 11.017

Doc: CO-008/69

Page 4-172. In the draft SWEIS Summary (page S-17, Table S-1), it is statedthat at the 500 weapon activity level, Pantex "would support 2,400 directjobs and 3,949 secondary jobs" and that "personal income additions tothe economy would be reduced to $356 million annually." Please explain whythis degree of economic loss would not only be an adverse but a SignificantAdverse Impact to the community.


The statement in volume I, page S-17 is a summary of the descriptionprovided in volume I, section (p. 4-167 of the Draft EIS), whichindicates that a combined loss of 3,715 jobs (1400 direct+2,315 indirect jobs)would increase the unemployment rate in the region of influence from 4.1 percentto approximately 6.2 percent and could trigger out-migration. The reduction ofpersonal income from $564 million at 2,000 weapon activity level to $356 millionat 500 weapon activity level would mean a loss of $208 million or 37 percent ofthe personal income generated by the 2,000 weapon activity level. Compared tothe total employment of 107,000 in Amarillo (Ref. Chamber Quarterly, 2ndQuarter, 1996, Amarillo Chamber of Commerce [ACC 1996]), this reduction wouldrepresent approximately 3.5 percent of the Amarillo area employment and 3.7percent of its total personal income of $3.65 billion in 1994. These impactswould, no doubt, be adverse and may be considered significant by some members ofthe community. The text in the Final EIS has been revised to include thisstatement. The article in the Chamber Quarterly referenced above, suggests thatthe jobs added in the next 6 to 7 years would reduce the impact of this jobloss.

RC: 11.018

Doc: CO-008/70

Page 4-165. At the 500 weapon activity employment level, what would be theimpact to the revenues for the governing bodies within the Pantex ROI, comparedwith the current revenues presented in table (page 4-165)?


At the 500 weapons activity level, Pantex workforce would be reduced by1,400 workers. Additionally, 2,351 indirect workers may lose their jobs in thePantex region of influence. For analysis purposes, we have assumed that alldirect workers and 50 percent of the indirect workers leave the Pantex region ofinfluence as a result of this action. Further assuming, for simplicity incalculation, that all workers live in the City of Amarillo and based on thecurrent per capita revenue of $457, the revenue loss in the City of Amarillowould be approximately $2.8 million about 3.6 percent of the total revenues ofthe City in 1994. In reality, this number would be lower since some of theseworkers do not live in Amarillo and the per capita revenue generated in thecounties of the region of influence is generally lower than in the City ofAmarillo. Discussion in volume I, section has been expanded to includepotential impacts on population and tax revenues.

RC: 11.019

Doc: HT13/17

One of my biggest complaints about the document, which strangely enough someof us do actually read it, a lot of times, under the affected environment, youlist everybody all the way from Rio Rancho to Belen and everybody to the west. There are people who live east of Manzano Base. It is the fastest growing areaother than Rio Rancho, and this is something that needs to be brought up.


As shown in volume I, section 5.5, Figures and,population living within a 80 kilometers (50-mile) radius from the ManzanoWeapons Storage Area (WSA) has been considered in the analysis. People livingeast of Manzano WSA are, therefore, included in the analysis.

RC: 11.020

Doc: PC-013/1

It will hurt the economy of this city to have another "pay roll"eliminated. The main 4 plans under plans to dispose of, and those already goneare - the Air Base.


See responses to comments 11.002 and 11.004.

RC: 11.021

Doc: PC-012/1

Section 4.11.5 on page 4-170 in volume I, Main Report is titled "CumulativeImpacts" and is referring to Socioeconomic Resources. It states that "Thissection describes the cumulative impacts on Pantex Plant. Cumulative impactsinclude the impacts of continued operations at Pantex Plant combined withimpacts associated with the activities described in the Waste Management DraftPEIS, the Stockpile Stewardship and Management Draft PEIS, or the Storage andDisposition of Weapons-Usable Fissile Materials Draft PEIS."

The Council on Environmental Quality Guidelines published in 40 CFR ¤1500-1508define Cumulative impact in ¤1508.7 as follows:

"Cumulative impact is the impact on the environments (emphasis added)which results from the incremental impact of the action when added to otherpast, present, and reasonably foreseeable actions. Cumulative impacts canresult from individually minor but collectively significant actions taking placeover a period of time."

Question: Why is there no analysis of the incremental socioeconomicimpact of this action, on the Pantex socioeconomic region of influence, whenadded to other past and present actions such as the cancellation, in 1988, ofthe DOE program of a mined geologic repository for spent nuclear fuel andhigh-level radioactive waste in Deaf Smith County, and the more recentannouncement of closure of the U.S. Department of the Interiors Bureau of MinesHelium Operations?


See responses to comments 11.002 and 11.004.

RC: 11.022

Doc: CO-002/1

In the draft SWEIS (p. S-17) it is stated that at the 500 weapon activitylevel Pantex "would support 2,400 direct jobs and 3,949 secondary [jobs],"and that "personal income additions to the economy would be reduced to $365million annually."

Please explain why this degree of economic loss would have not only anadverse, but a significant adverse, impact on the community.

At the 500 weapon activity employment level, what would be the impact onrevenues for the governing bodies within the Pantex region of influence comparedto the current revenues present in table (p. 4-165)?


See responses to comments 11.017 and 11.018.

RC: 11.023

Doc: CO-002/2

In Section 4.11.5 "Cumulative Impacts," referring to socioeconomicresources (p. 4-170), it is stated, "This section describes the cumulativeimpacts on Pantex Plant. Cumulative impacts include the impacts of continuedoperations at Pantex Plant combined with impacts associated with the activitiesdescribed in the Waste Management Draft PEIS, the Stockpile Stewardship andManagement PEIS, or the Storage and Disposition of Weapons-Usable FissileMaterials Draft PEIS."

The Council on Environmental Quality Guidelines published in 40 CFR ¤1500-1508define cumulative impact as follows (¤1508.7). "Cumulative impact isthe impact on the environment which results from the incremental impact of theaction when added to other past, present, and reasonable foreseeable futureactions regardless of what agency (Federal or non-Federal) or person undertakessuch other actions. Cumulative impacts can result [from] individually minor[but] collectively significant actions taking place over a period of time." (Emphasis added)

Why is there no socioeconomic analysis of the incremental impact of thisaction on the Pantex socioeconomic region of influence (ROI) when added to otherpast and present actions, such as the cancellation and shutdown in 1988 of theDOEs high-level nuclear waste repository in Deaf Smith County, and the morerecent announcement of closure of the U.S. Department of the Interiors Bureau ofMines Helium Operations in Amarillo?


See responses to comments 11.002 and 11.004.

RC: 11.024

Doc: CO-002/3

The socioeconomic analyses of the three EISs are not consistent. The SWEIS(p. S-17) assumes 1.65 indirect [jobs] in the region for every job at Pantex. The SSM PEIS (p. S-32) assumes 1.16, and the S&D PEIS (p. 4-205) [assumes]3.51.


See response to comment 11.001.

RC: 11.025

Doc: CO-002/4

The Amarillo Economic Development Commission (AEDC) analysis, based on localknowledge of the area and a regional impact study performed by Dr. Ray Perrymanof Southern Methodist University, gives a [ratio] of 2.77 additional jobs in theregion to every 1 Pantex job (for a total job multiplier of 3.77).


See responses to comments 11.001 and 11.009.

RC: 11.026

Doc: CO-009/5

In fact, the impact of Pantex employment in the region of influence ishighly significant to the region. Measured in terms of total payroll, Pantex isby far the areas largest employer. The reasonable job multiplier developed byDr. Ray Perryman at Southern Methodist University, a multiplier of 3.87, appliedto the some 3,500 employees at Pantex, suggests the site is responsible for atotal of over 13,500 jobs. Employment related to Pantex represents over 12% ofthe jobs in the Amarillo metropolitan area.

Incidentally, the three subject EISs inconsistently analyze the indirectjobs created in the region by Pantex employment: The site EIS assumes 1.65indirect jobs for each job at Pantex; the stewardship and management EIS assumes1.16; the storage and disposition EIS, 3.51 (by far, the most consistent withDr. Perrymans, which is the same, regional-experience-based multiplier employedby the Amarillo Economic Development Commission).

Certainly, we consider a potential 10% to 12% reduction in metro-areaemployment a major loss, and by no means a "negligible" concern. Westrongly urge the Department to correct the socio-economic impact portions ofall three EIS documents to accurately reflect the impact of Pantex employment inits region of influence.


See responses to comments 11.001 and 11.009.

RC: 11.027

Doc: PC-034/8

Table presents revenues for the governing bodies within thePantex ROI (p. 4-165). If Pantex is reduced to the 500 weapons activity level,what would be the impact to these revenues?


See response to comment 11.018.

RC: 11.028

Doc: HT17/1

I think the DOE has done a pretty good job of describing our economy;however, I think on the impact section there are some weaknesses. Its more of adescriptive document about our economy than it is a projection of what theimpacts of Pantex might be on the economy. I know youve used a number offigures for your job multiplier, in terms of how many jobs in the economy existas a result of the operations at Pantex. Is that a regionally sensitivemultiplier that youve come up with, or is that something thats just standardacross the board for the nation?


The socioeconomic impacts associated with the alternatives at the PantexPlant extend beyond the city of Amarillo and include all the jurisdictionswithin the four-county region of influence. The database used for thesocioeconomic study was developed using information from the Department ofCommerce and Labor, as well as financial reports provided by cities andcounties. The impacts were measured using the latest version of RegionalInput-Output Modeling System II (RIMS II), a model developed by the U.S. Bureauof Economic Analysis. The model is used by Government agencies, universityresearchers, and private economists to measure economic impacts and is availablefor every economic region in the nation. It is designed to be sensitive todifferences in the economy from one region to another.

RC: 11.029

Doc: HT17/2

I think there is some weakness [in] looking at the effects on certainsectors of the economy. In particular, I would note it [the EIS] doesnt talk alot about [the effects on] retail sales and employment in the retail sector,which has been a tremendous growth portion of our economy over the last fiveyears.


The socioeconomic impacts associated with the alternatives at the PantexPlant are described in terms of total earnings (salaries and wages to employees)and total personal income. It is true that impacts on individual sectors of theeconomy are not analyzed. However, the text in volume I, section,states that most of the secondary jobs in the local economy are in the retailtrade and service sectors.

RC: 11.030

Doc: HT17/3

It [the EIS] doesnt look extensively at wholesalers and industrialsuppliers, many of whom supply [products] to Pantex, but also associated withindustry in general. We wouldnt...have the diversity of industrial supplycompanies in Amarillo without Pantex, and I think that should be taken intoaccount.


See response to comment 11.029.

RC: 11.031

Doc: HT17/4

...perhaps the most important [aspect] would be the impact, if there weresignificant job losses. And I know this EIS doesnt contemplate it, but if therewere significant job losses beyond whats mentioned, even in terms of looking atthe [1,000 weapons] per year, let alone the [500 weapons], the real estatesector would suffer considerably.


The job losses resulting from reduced weapon activity level arediscussed in volume I, section and the job losses resulting from theclosure of the plant are summarized in volume I, section The loss ofapproximately 3,700 direct and indirect jobs would certainly impact the realestate sector, but it should be noted that not all unemployed workers,particularly the indirect workers, are likely to leave the Pantex region ofinfluence immediately or even over a longer period. The text in volume I,section has been expanded to include these effects.

RC: 11.032

Doc: HT17/5

... I think we have some pretty good historical data in Amarillo on whathappens when theres large outmigrations in number of jobs and in population. You can look back to what happened when the air base left town or look back inthe late eighties, what happened to our economy.


Comment noted. The text in volume I, sections and hasbeen revised to incorporate population and economic changes occurring prior to1990.

RC: 11.033

Doc: HT17/6

Id also ask that maybe additional analysis could be done on the tax revenueportions.


See response to comment 11.018. The text in volume I, section been revised to add a discussion of tax revenues.

RC: 11.034

Doc: HT17/7

Again, going back to the problems that happen when you talk about severe joblosses in the manufacturing sector of the economy. In terms of real estate, itwould have a dramatic effect on all the cities in the region and their abilityto raise revenue through property tax. ...There is discussion of the citysrevenue capacity in the document, but I think it could be strengthened. Counties are also very dependent in Texas on property tax. In fact, Texascounties are nearly completely dependent on property tax revenues. So, theysuffer severely when there are declines in property tax values. Finally, schooldistricts, which arent mentioned at all in the document,...are also verysensitive to property tax issues. Changes in the property value can haveinteresting effects in Texas because of our school equity financing law. Illnote that the Canyon School District, which is in the Region of Influence, isalready looking at a million dollar deficit because of certain property taxissues.


See response to comment 11.018. The text in volume I, section been revised to add a discussion of tax revenues.

RC: 11.035

Doc: HT17/8

The City of 1989, passed a half cent sales tax to reduce theproperty tax. So, in essence, they shifted their taxation burden from propertytaxes, to some degree, to retail sales. If retail sales do not grow at least atthe inflation rate, that translates into an actual, in essence, reduction in thefunds available to operate the city.


Comment noted. Retail sales would be reduced if the weapon levels arereduced to 1,000 or 500 per year. The reduction in worker earnings and personalincome are discussed in volume I, section

RC: 11.036

Doc: HT17/9

In looking at the government debt section of the document, the majority ofthe debt was listed as the City of Amarillo. I think theres 55 million dollarsof debt. That is primarily revenue bond debt...that is financed through utilityfees. Its not dependent on general revenue taxation at all.


Comment noted. Socioeconomic analysis in volume I, section,has been revised to provide a better discussion of population change and taxrevenue.

RC: 11.037

Doc: HT17/10

...I think there needs to be some analysis on what effect this might have onwater consumption, on water revenues in the city, because thats what backs thoserevenue bonds the debt that youve mentioned in there.


Additional information on impacts to overall tax revenues has beenprovided in volume I, section Impacts on individual sources ofrevenues are not provided because they depend on annual budgetary processes andare too speculative to be included in this EIS.

RC: 11.038

Doc: HT17/11

Finally,...maybe most importantly is population outmigration. Cities tendto be in a growth mode, they tend to plan on future growth. As happened inAmarillo in the sixties and again in the late eighties, when you haveoutmigration, it dramatically affects all sectors of the economy, particularlyretail and otherwise.


Volume I, section, provides socioeconomic impacts which couldoccur as a result of population inmigration. It should, however, be noted thatreduced workforce at Pantex Plant or even the closure of the plant would notresult in instant outmigration of population. Even after the closure of theplant, workers would continue to be employed at the site for decontamination anddecommissioning of plant facilities over a number of years.

RC: 11.039

Doc: HT17/13

The population figures that you just showed on your slides, I found...inVolume I, on page 4-155. Theres some conflicting population estimate numbersfor the Region of Influence given in the section dealing with accident riskestimates and fatal cancer estimates. The numbers that are given there are267,107 [for] population in the Region of Influence. And Im wondering what thedifference is in those estimates.


In the NEPA process regions of influence (ROI) are defined in relationto the potential for an environmental aspect to be affected. For health riskanalysis, whereby contaminants can be dispersed over large geographical areas byweather phenomena or surface features such as rivers, streams, etc.,traditionally such potential impacts are assessed within an 80 kilometer (50mile) radius of the facility of interest. On the other hand, studies have shownthat people tend to spend money in the communities where they live. Thus thesocioeconomic ROI, for NEPA analysis is traditionally analyzed by defining thepolitical (and census) boundaries within which at least 90 percent of a sitesworkers live. For the Pantex Plant, 96 percent of workers live in Carson,Potter, Randall, and Armstrong counties. Thus these four counties comprise thesocioeconomic ROI for Pantex Plant.

Since the 80 kilometer circle for the human health (accident) analysisincludes 14 counties, it has a larger population than the 4-county socioeconomicROI.

RC: 11.040

Doc: HT17/14

I neglected to mention one aspect that I think should be taken into accounton all the EIS documents for all sites, and thats the effect on nonprofitagencies that rely on contributions of the employees at the plant. You wouldhave a decline in the revenue to those nonprofit agencies; at the same time,youd have economic hardships, creating a larger need for those services.


Discussion in volume I, section has been expanded to includethe potential effect on non-profit agencies due to downsizing.

RC: 11.041

Doc: HT17/16

I think that we felt,...especially looking at your view graph here, that youhave brought it down to within just a four-county area for the Region ofInfluence. And yet for all the other study that was done throughout thedocument, it is a much wider [area], as was noted by Joe Martillotti.


See response to comment 11.039.

RC: 11.042

Doc: HT17/17

...the magnitude of the impact of agriculture was really not addressed andthe importance that agriculture has played in this area and the stability of thearea. And when the air base was phased out, it was agriculture that brought thispart of the State of Texas, or that kept it alive and kept it going. ...One ofevery four dollars of cash receipts from the State of Texas in total revenuecomes from crops and livestock that are produced in this part of the State.Right here in...the High Plains Trade Area, if these counties were detached fromthe rest of the State of Texas, this [area] would rank number one [nationally]in the fed cattle...production. These are very important items for this area,because youre right in the middle of a prime agricultural area. The cereal cropsthat are grown here are shipped all over the world. For any product that weraise here, if there is the slightest hint of any contamination, that coulddevastate this total area. I dont know how many of the other facilities aresituated in an area that is a bread basket as much as this area is. I dontthink that that was brought out in this document. One of four people isemployed in [an] ag-related job in this area. And for anything to happen inagriculture would devastate the area.


The Department of Energy recognizes the importance of both agricultureand Pantex Plant jobs in the Panhandle economy. The Department has programs ofenvironmental stewardship to protect the environment in general and neighboringfarms, ranches, and communities in particular. The analyses in this EISdemonstrate that the Pantex Plant and agriculture can not only coexist, butmutually and beneficially contribute to the economic and social fabric of theregion.

The contribution of agriculture to the regional economy of the Panhandlehas been expanded in volume I, sections 4.4 and 4.11.

RC: 11.043

Doc: HT17/18

... I think that its extremely important to realize that even for the Stateof Texas, the importance agriculture plays has a tremendous effect upon therevenue that the State of Texas receives. So that even though in this document,which is a nuclear document, it may seem a little strange to addressagriculture, I think that a complete risk analysis needs to be done with regardto just exactly what could happen with regard to the future for this area. Iknow that in 1991, when we first began looking at this issue, that the totalimpact of agriculture in this area was about three billion dollars, and now thathas increased to between five and six billion dollars, and with an economicmultiplier its [in] excess of 12 billion dollars. So, youre looking at atremendous figure there that could stand a chance of being hurt in some way. So, wed like to see that addressed.


See response to comment 11.042.

RC: 11.044

Doc: HT17/55

In our study of this document, we find that it fails to address themagnitude of agriculture in the Pantex ROI. In this, the heart of productionagriculture, it is unthinkable for agriculture, the viable, stable, andessential industry of the Texas Panhandle, not to be appraised. Whenconsidering continued and new [missions] at Pantex, work with radioactive,toxic, and hazardous materials, omitting a detailed analysis of the agriculturaleconomy, the basis for economic stability in this area, is a significantimpropriety. The dollar value of the agricultural industry to the Panhandleeconomy is in excess of six billion dollars, creating a local economic activityin excess of 12 billion per year. The State of Texas cannot afford a loss inState revenues from High Plains agriculture.


See response to comment 11.042.

RC: 11.045

Doc: PC-017/1

What kinds of studies (if any) have been conducted to learn the effects ofthe proposed actions -- storage of large amounts of plutonium, chemicals,nuclear waste, uranium and other toxic substance and/or the[processing]/reprocessing of those substances on agriculture production, sales,uses, etc? What were the results of such studies if any have been made? Agriculture is mentioned very briefly in the EIS. Agriculture is the majorindustry in the Texas Panhandle and the only industry near the Pantex Plant.


Risk assessments conducted in the Pantex EIS as well as in the SSM PEISand S&D PEIS have shown that Pantex Plant activities do not adversely impactagricultural operations in the region. This is clearly indicated by the growthof the agricultural economy in the ROI over the past several decades sincePantex Plant has been in operation. Pantex Plant routinely conductsenvironmental monitoring and the results are summarized in its annual siteenvironmental reports (see references to these reports in the Pantex PlantEnvironmental Information Document, [Pantex 1996]). One special study dealingwith radiological effects on beef cattle was conducted in 1982. It waspublished as a Supplemental Documentation for an Environmental Impact StatementRegarding Pantex Plant, Agricultural Food Chain Radiological Assessment (LANL1982). Refer to volume I, section of the Pantex EIS and response tocomment 09.001 for additional details. Additional agricultural documentationhas been added to volume I, sections 4.4 Land Resources, 4.5 Geology and Soils,4.6 Water Resources, 4.9 Biotic Resources, and 4.11 Socioeconomic Resources.

RC: 11.046

Doc: PC-017/3

What studies have been made on the long-term effects of those activitiesbeing proposed or possibly being proposed on our agricultural products? Whenwere such studies made? How were they done? What results were found? Wherewere they done? Were neighboring farmers and ranchers consulted? Who? Majorplans for the future of Pantex cannot be made until such studies are made andfound to be positive.


See responses to comments 11.045 and 09.001.

RC: 11.047

Doc: PC-025/54

Page 4-155. Given the fact that this is 1996 and the section uses 1990 data,has a significant change occurred in population since 1990 and the socioeconomicparameters to warrant estimating the affected environment closer to 1996 timeframe? How many visitors to Amarillo are there each year? Is that important? IfI-40 closes due to [a] Pantex accident, what are the impacts to East/WestInterstates?


We agree with your comment that Amarillo has grown substantially sincethe 1990 census was taken. Population change from 1990 to 1995 and estimates ofpopulation for the year 2005 are presented in volume I, section of theEIS. Impacts of downsizing have been measured against the more recentpopulation estimates available for 1995 and have been included in the expandedtext of volume I, section We do not have data on number of visitorsper year, but the money they spend is in the economic statistics. Probabilityof accidents on interstates used for carrying nuclear materials and theirimpacts have been presented in volume I, section 4.16, Intersite Transportationof Nuclear and Hazardous Materials.

RC: 11.048

Doc: PC-008/1

The socioeconomic analyses of the three EISs are not consistent. The SWEIS(p. S-17) assumes 1.65 indirect jobs in the region for every job at Pantex. TheSSM PEIS (p. S-32) assumes 1.16 and the S&D PEIS (p. 4-205) assumes 3.51. Please explain these differences. Why didnt the DOE use the analysis of theAmarillo Economic Development Commission (AEDC), which is based on localknowledge of the area? Their analysis gives a ratio of 2.87 to 1 (REF. ChamberQuarterly, 2nd Quarter, 1996, Amarillo Chamber of Commerce).


See response to comment 11.016.

RC: 11.049

Doc: SG-010/6

Research has demonstrated that nuclear-related activities such asradioactive material transportation have the potential to result in significantsocioeconomic impacts. These impacts originate in intense negative perceptionsand avoidance behaviors by the public, and public and media interests in "thingsnuclear" makes it almost certain that these negative perceptions willadversely affect a communitys quality of life and subsequently its commercial,residential, and business investment opportunities. Thus, we contend that DOEshould do everything possible to limit the movement of these dangerousmaterials.


DOE is very sensitive to public perceptions of nuclear-relatedactivities such as radioactive material transportation and has establishedstrict guidelines for transportation of such materials.

See response to comment 16.045 for the safety record of nuclearmaterials shipments over the past 20 years.

RC: 11.050

Doc: CO-005/1

We are greatly troubled by the fact that agriculture was totally discountedas the major economic stability of the entire area and the second-largestindustry in the State. Providing a job for one in every five Texans andgenerating more than $40 billion annually for the State of Texas, agriculturecannot be slighted in this document. Beyond the economic consideration issomething we must never forgetAGRICULTURE PRODUCES THE ESSENTIALS OF LIFE. Aslong as people need food, housing and clothes, they will need and depend onagribusiness. This factor was ignored in this environmental document, thuscreating a document that is flawed in its most basic conjecture.

This High Plains Trade Area, which encompasses the northernmost 26 countiesin Texas produces close to $6 billion annually in cereal crops and livestock, ofwhich $3.25 billion annually is in value-added industry, and creates localeconomic activity in excess of $12.5 billion.

This region produces 96.8 percent of the States sugar beets, 85 percent ofits fed beef, 48.4 percent of its corn and 47.5 percent of its wheat. Over100,000 jobs are generated by High Plains agriculture.


See response to comment 11.042.

RC: 11.051

Doc: PC-033/5

The agricultural industry and adverse impacts on this industry, as far as Icould tell, have been included in only four paragraphs in the Draft SWEIS. Inthis High Plains Trade Area agriculture plays a major role in the economicstability and I feel should warrant more in depth study as to the adverseimpacts on such a valuable industry than are dedicated in this Draft SWEIS.


The contribution of agriculture to the regional economy of the Panhandlehas been expanded in volume I, sections 4.4 and 4.11.

3.12 Intrasite Transportation

RC: 12.001

Doc: HT13/19

In the document on [pages] 5-60 and 5-61, you talk about intrasitetransportation within the bounds of Kirtland Air Force Base. There is nodiscussion here, and again, no reference documents, that describe anytransportation-related accidents within the bounds of the base.

I am interested in information [on] varying kinds of accidents ranging fromfender-benders to other kinds of accidents that would have happened within thebounds of the base [and] over whatever period of time you have that information.


Accident statistics are maintained by the U.S. Air Force. For 1995,there were a total of 271 vehicle accidents within Kirtland Air Force Base(KAFB); 241 were minor and 30 were major. A major accident involves a loss oflife or damage in excess of $10,000. For 1994, there were a total of 283vehicle accidents within KAFB; 233 were minor and 50 were major.

The potential of vehicle accidents involving pit shipments wasconsidered in the EIS analysis. It was concluded that it is not reasonablyforeseeable that an accident on KAFB would occur with the severity necessary tolead to a release of plutonium from an AT400A container within a Safe SecureTractor Trailer (SST). As discussed in volume I, section 5.5.1, the controlledtransportation route on KAFB does not contain threats that may create the severeenvironment required to lead to a dispersal of plutonium. In addition, basepersonnel traffic would be controlled as SST convoys pass through the baseroads. Thus, other vehicles do not pose a threat to the SSTs while on KAFB.

RC: 12.002

Doc: HT13/20

That wasnt my question. My question was what documentation exists oftransportation accidents within the bounds of the base?

DOE has got documents. If the Air Force has documents, that is fine. Iwant to know what exists because there is nothing referenced in this document,in the sitewide.


See response to comment 12.001.

RC: 12.003

Doc: HT13/21

I will be glad to get to the accident scenario in a little bit, but myquestion hasnt been answered. Just to sort of add to it, there is someinteresting numerical information in chapter 4 about actual numbers of transfersinternally within Pantex. There is not that same kind of information in thisdocument about Manzano, and that is the kind of information I am looking for. specific as you were looking at intrasitetransportation issues, did you receive, did you have access to, did you look atactual transportation analysis of accidents, transportation accidents, notnecessarily dispersal accidents, just accidents within the bounds of KirtlandAir Force Base?


See response to comment 12.001.

RC: 12.004

Doc: HT13/77

Are you all, in this document, proposing that the pits currently [in] AL-R8containers, be transferred into AT-400 containers in this interim timeframe?

What is that timeframe? Over what period of time would that transfer bedone?


DOE is planning on repackaging pits into AT400A during the periodanalyzed by this EIS. Pit repackaging is currently scheduled to begin in late1996 or early 1997. Repackaging of the pit inventory at Pantex Plant isexpected to take longer than 5 years.

RC: 12.005

Doc: HT12/15

What is the intent of the hole, the square [in the Stage Right pallets]?


Discussion of the Stage Right pallets is included in volume II, appendixF.

RC: 12.006

Doc: HT12/17

[In] the newer method of staging, [is there a] forklift [driver] on theforklift?


To elaborate on the response given at the public hearing, DOE hasintroduced an automated guided vehicle to replace the stage right shieldedforklift that has been used for operations within pit storage magazines. Theuse of the automated guided vehicle eliminates the need for personnel inside thepit storage magazines for inventories and inspections.

RC: 12.007

Doc: HT12/18

You said when I load these things Im going to put them in a Type Acontainer. Type B container, okay, fine. Now, you never said Im going to takethem out of that Type B container. So Im assuming theyre stored in a Type Bcontainer which is suitable for drop [of] 30 feet or puncture and so forth. Howin the world is a forklift going to ram a hole through it?


To elaborate on the response given at the public hearing, certificationtesting requirements for Type B packages are described in volume II, appendix F,section F.2.3. After consideration of the range of operational accidents thatcould occur, a bounding forklift accident scenario was developed. This accidentcould occur when a 20,000-pound forklift traveling at 5 miles per hour strikes ahorizontally positioned container that is fixed. The impact would occur betweenthe boom of the forklift and the container.

RC: 12.008

Doc: HT12/19

Okay, how many forklift operations [have] occurred?


There is no record of the number of past forklift operations, but therehave probably been at least 10,000, none of which resulted in a puncture of apit container.

RC: 12.009

Doc: HT12/27

Public Speaker: Thats, you know, the structures are ventilated, theatmosphere --

Unidentified Speaker: And thats -- they are not in containment.

Public Speaker: And, in fact, theyre [unintelligible] out in here that thestorage container, you know, is not sealed so its not a containment barriereither.

Unidentified Speaker: Wait a minute. The storage container is not sealed?

Public Speaker: ALR8s being unsealed the ALR8 container does not --

Unidentified Speaker: Theyre sealed containers. And the other point isthat regardless of which option were going to the AT400-A, which have the pitwhich is clad, the inner vessel which is welded, and then you have the outercanister. So actually thats layers of containment there and thats what weregoing to in terms of the AT400-A.


To elaborate on the response given at the public hearing, all pits arehermetically sealed within a metal clad. The ALR8 container is sealed but doesnot have an inert atmosphere surrounding the pit. The AT400A will provide aninert atmosphere as a defense-in-depth measure in addition to the pit clad. Further information on pit container design is provided in volume II, appendix F.

RC: 12.010

Doc: PC-034/1/2

In the Summary, Table S-1, under intrasite transportation, presentsperson-rem information (page S-18). The table is supported by Section 4.12 inthe main text. An underlying baseline person-rem appears to be incorporatedinto the estimates for the Proposed Action alternative. Neither the main textnor the table clearly states the assumptions used. The person-rem shown for thePit Storage Relocation alternative adds the estimated person-rem for pit storagerelocation and the person-rem from the 2,000, 1,000, and 500 weapons levelsunder the Proposed Action alternative.

Thus, while implementing the Pit Storage Relocation alternative, Plantworkers are assumed to receive the person-rem associated with the ProposedAction alternative. The radiation exposures for individual workers for thealternatives are within regulatory guidelines and do not have any public healthsignificance.


The dose estimate presented includes not only the expected doses fromweapons operations but also the expected doses from the interzone transfers of20,000 pits as part of the pit repackaging project. The No Action Alternativedose numbers presented include not only the expected doses from weaponsoperations but also the expected doses from interzone transfers of 12,000 pitsas part of the pit repackaging project.

The environmental impacts of interim pit storage at Pantex have beendiscussed and analyzed in the Pantex EIS. The Department of Energy, through itscontractor Mason & Hanger, is fully committed to the As Low As ReasonablyAchievable (ALARA) program at Pantex Plant to help limit the number of personneloccupational exposures and public/environmental exposures to radioactivematerial. The majority of Pantex Plant workers receive no radiation exposures(zero dose) during normal operations.


The environmental impacts of intersite transportation of plutonium pitsincluding each of the four alternative sites have been discussed and analyzed inthe Pantex EIS. DOE considered the Relocation Alternative as reasonable. However, DOE has determined continuing interim plutonium pit storage at PantexPlant as the preferred alternative.

Costs are not analyzed as part of the environmental impacts.

RC: 12.011

Doc: PC-034/3

In Table S-1 for the Proposed Action alternative, 50 workers receive 61person-rem for 2,000 weapons. Next, 50 workers receive 48 person-rem for 1,000weapons. Finally, 50 workers receive 41 person-rem for 500 weapons. How doesone scale these numbers? The same type of calculations are made for the NoAction alternative. Again, the numbers for person-rem do not follow the amountof work. Why dont the workers receive only one half the amount of person remfor a one half decrease in the work? Is there a certain amount of radiationthat they receive no matter what?


See response to comment 12.010.

RC: 12.012

Doc: PC-034/4

In the Pit Storage Relocation Alternative, the amount of person-rem from theProposed Action alternative appears to be added to what happens for pit storagerelocation. How can one add the person-rem for these two alternatives? Is thesame person-rem used two different times?


The Proposed Action includes continued weapons operations and pittransfers for pit repackaging. For the Pit Storage Relocation Alternative, bothof these activities will be performed in addition to the activities associatedwith offsite pit shipments.

RC: 12.013

Doc: HT15/46

Its not clear to me that the document reflects worker exposures of workerswho have been dealing with pit storage in Zone 4 West. So Id like to have someclarification about what is and isnt included in terms of the numbers that youregiving in the documents.


The Transportation and Staging Department is responsible for pit storageactivities as well as interzone transfers of nuclear material. Historicaldosimetry data and a description of responsibilities for this department areprovided in volume I, section 4.12.1, of this document. This historicaldosimetry data were correlated with historical material transfers to estimateimpacts from future operations.

RC: 12.014

Doc: HT15/47

So whats included in as transportation staging includes the workers in Zone4 as well as the Zone 12 workers involved in those two sites? Im just trying toclarify.

Yes, both Zone 4 and Zone 12 workers are included. The commentor isasking for clarification of the responsibilities and impacts for the departmentresponsible for pit storage and handling activities. The Transportation andStaging Department is responsible for pit storage activities in both Zones 4 and12 as well as interzone transfers of nuclear material. Historical dosimetrydata and a description of responsibilities for this department are provided involume I, section 4.12.1, of this document.

RC: 12.015

Doc: HT15/48

[Are] the calculations...for those [Transportation and Staging Department]workers...the 1993 to 1994 similar reading? When [is] the 1995 similar readinginformation going to be available and...included?


The Transportation and Staging Department had a cumulative dose of 3.642person-rem for 1995. This information is provided in the Final EIS.

RC: 12.016

Doc: HT16/10

It just occurred to me just as I was listening to you talk about whether ornot there would be less exposure if the pits were left onsite rather thantransporting them and I wondered if the repackaging were not part of thelong-term storage...[would then] be left onsite. And...if repackaging is a partof the action,...would [that] be part of the analysis also? Because it wouldprovide the same worker exposure as taking it out of the bunkers and moving itto a new location.


Onsite movements of pits differ significantly from offsite pitshipments. Because of the limited speeds for onsite transfers, the restraintprocedure required for pit containers is less complex and less time consumingthan the restraint procedure for offsite shipments. Because of the additionalcomplexity of the restraint procedure, dose estimates for offsite transfers aregreater than the estimates for onsite transfers.

RC: 12.017

Doc: HT16/13

If Pantex is chosen for long-term storage, [would] workers...actually beexposed to the same activity bringing them out of the bunkers as they would ifthey were taken out and moved to another location?


It is a correct statement that there will be continued onsite movementof pits. A discussion of the pit transfers and the subsequent impacts occurringduring the period analyzed in this document is provided in volume I, section4.12. Onsite movements of pits differ significantly from offsite pit shipments. Because of the limited speeds for onsite transfers, the restraint procedurerequired for pit containers is less complex and less time consuming than therestraint procedure for offsite shipments. Because of the additional complexityof the restraint procedure, dose estimates for offsite transfers are greaterthan the estimates for onsite transfers.

RC: 12.018

Doc: HT16/14

My question has to do with Figure F-6.3.1 on Page F-19, appendix F. Thereis listed a variety of collisions that might occur during transportation whichform the basis for the risk and the consequence analyses in that [appendix] andI note that aircraft collisions with the transport train have not beenconsidered, or at least theyre not listed. The stage right trailer, thewhatever trailer you would like to consider. I guess theres something hauling atrailer, so I think of it as a train. If were really looking at 30,000movements a year, which was the number referred to earlier in the discussion,the total exposure of all of those targets averaged over a year may match thetotal exposure of a single storage facility, in terms of hours of vulnerability. So it relates to an observation that Ive had that, in analyzing the aircraftcrash probability, theres been no consideration of the fact that the aircraft isonly in a position to impact the target for a short duration, a very shortproportion of its entire flight. Here weve got a slowly moving target thatsonly vulnerable for a short period of time and weve not worried about it. Whenyoure moving the missile instead of moving the target, we worry about the sumtotal of all these passes. When were moving the target more slowly, we say,well, its in the open for such a short period of time that its negligible.


To elaborate on the response given at the public hearing, aircraftimpacts into a moving vehicle containing weapons or weapons components wereconsidered in the analysis. The potential for this accident is discussed involume I, section 4.12.2. Assuming a trailer were continually parked withinZone 4, an aircraft impact frequency of less than 1 x 10-7 per year wascalculated. The risk from this accident using a frequency of 1 x10-7 per yearis presented in volume I, section 4.12.2.

RC: 12.019

Doc: HT16/42

In the document, it commented that 18 magazines are currently being used forpit storage. And then there was a chart that indicated pit storage magazines,22 of them was all. And, of August 1995, [there were] 7,950 pits atthe plant. And it just doesnt add up. We need to know where else the pits areat the plant. Youve got too many pits for too few magazines.


As of July 1996 there were just over 9,000 pits stored at Pantex. Thereare 22 Zone 4 magazines in Stage Right configuration. That is, magazines inwhich pits are palletized horizontally, in groups of 4 or 6, ALR8 containers(one pit per container). The Stage Right configuration utilizes the automatedguided vehicle forklift. Of the 22 Stage Right magazines, 18 Modified Richmondmagazines and 4 Steel Arch Construction magazines currently contain pits. Eachof the 18 Modified Richmonds has 424 pits in it (212 per side), whereas, the 4Steel Arch Construction magazines contain 252 pits each. In Zone 12, building1244, Cell 8 can hold up to 288 pits, and the 1226 Pit Vault (PV) holdsapproximately 150 pits. The following table summarizes the these quantities:

FACILITY/STORED PIT QUANTITIES: 18 MR Magazines/18 x 424=7632; 4SAC Magazines/4 x 252=1008; 12-44 Cell 8/288; 12-26 Pit Vault/150; TOTAL/9078.

It should be noted that the two Zone 12 facilities, 1244 Cell 8 and12-26 PV, are not currently completely full. Thus, the total number of storedpits is something less than 9,078 (as of July 1996). Since the total changesday to day, exact figures were not available as this response was written, butthese numbers indicate approximately 9,000 total pits currently stored atPantex.

RC: 12.020

Doc: HT16/43

I also would like you all to clarifytheres a place where you say pitsaccumulated on site. I would like to know if theres a certain point at which apit is designated as being in storage and if there is kind of an interim stagingstep where you can have some X number of pits.... If you dont mind, I wouldlike to have clarity about how all pits are categorized, they fall into whatcategories, et cetera.


To elaborate on the response given at the public hearing, there is nospecific interim staging step for pits designated for storage. When pits areremoved from dismantled weapons they are placed in ALR8 containers (at thispoint they are counted as "stored" pits with respect to the 12,000 pitlimit) and either palletized into Stage Right pallets in the dismantlementfacility or temporarily staged in the 12-26 Pit Vault until a quantity exists tofill a pallet. Stage Right pallets hold 4 or 6 pit containers per pallet,depending on the pallet size. Full pallets are then transported from Zone 12 toZone 4 and placed in one of the storage magazines.

With respect to pit categorization, pits at Pantex can be divided intofour primary categories as follows:

· SurplusInterim storage pits, not intended for futuredefense programs use.

· Strategic Reserve Reserved for potential use in futuredefense programs.

· Enduring StockpileCurrent stockpile weapons spares ormaintenance units.

· EvaluationSmall quantities of pits designated for qualityassurance tests.

With the exception of enduring stockpile pits (limited classifiedquantities), all of the aforementioned pits are considered as "in storage"and counted with respect to the authorized limit of 12,000 pits currentlyallowed to be stored onsite at Pantex. See the response to comment 12.019 fordetails on current pit quantities stored at Pantex.

RC: 12.021

Doc: HT16/44

Something that also doesnt seem to be in the document is theair-conditioning thats being installed in some of the pit storage you use. Things like that, that have to do with current operation and status of theplant, wed like to understand better.


The comment is correct. Two Modified Richmond magazines in Zone 4 haveair conditioners. Some pits have a maximum storage temperature which has beenestablished by the design laboratory (Los Alamos or Lawrence Livermore NationalLaboratory). The air conditioning is provided to maintain appropriatetemperatures during the summer months for these pits. Additional Zone 4magazines may have air conditioning installed in the future. This informationhas been added to volume I, section 4.3.

RC: 12.022

Doc: PC-025/55

Page 4-174: According to Table, Pantex is stockpiling nuclearexplosives or pit components in Zone 12. Please comment since interzonetransfers dont balance.


The commentor is incorrect. DOE is not stockpiling nuclear explosivesor pit components in Zone 12. The data in the referenced table refer totransfers occurring during 1994. The data do not include components that werebrought to Zone 12 late in 1994 and returned to Zone 4 early in 1995.

RC: 12.023

Doc: PC-025/56

Page 4-174: In the magic numbers of 12,000 and 20,000, what is the maximumnumber of pit components that would not be included in the storage limits butwould be managed in Zone 12 but not considered in storage under the definitionof storage? Is this discrepancy accounted for in the analysis? Will these pitsbe in AT-400 containers? If a shortage of AT-400 containers exists would therebe greater risk in Zone 12 management?


See response to comments 12.019 and 12.020. This small discrepancy isaccounted for in the EIS risk analyses, since all calculations used the maximumfacility limit quantities for evaluation purposes. It is planned that all pitswill eventually be stored in AT400 containers. The order or priority of whichpits will be repackaged first is not yet established. However, the riskassessments presented in the EIS were for ALR8 containers and constitutes abounding analysis with respect to risk. Thus, any number of pits which getrepackaged into AT400 containers would reduce the overall risk from pit storageregardless of whether they are in Zone 4 or Zone 12.

RC: 12.024

Doc: PC-025/57

Page 4-174. Has the analysis accounted for the aging of pits and aging ofcontainers? If Pantex has pits from the fifties, forty years of material fatiguefrom the radiation, thermal, handling, and other adverse environmentalconditions must be enormous. Has DOE accounted for this?


Pits have been under careful scrutiny for many years through various DOEprograms, particularly the weapons Quality Assurance Testing Program, whichincludes the Pit Surveillance Program and an accelerated aging program to ensurethat aging-related defects do not develop in pits. The same pits have alreadyspent several decades under surveillance of DOE, the national laboratories, andthe military in the field. Routine stockpile surveillance has been performed onthe pits for 20 to 30 years in more hostile environments than Zone 4. All dataindicate that pits and containers will not degrade over the interim storageperiod. The AT400A container is designed for a 50-year life. A pit and pitcontainer surveillance program will continue for the AT400A container. Thissurveillance program will minimize the likelihood of undetected failures in thepits and/or containers.

RC: 12.025

Doc: PC-025/58

In the Zone 4 West Activities section, on page 4-181. DOE estimates 20-22containers would be removed for surveillance activities. Should a problem becomeevident, what is the maximum number of surveys possible? What are the impacts? Was this considered?


Pits have been under careful scrutiny for many years through various DOEprograms, particularly the weapons Quality Assurance Testing Program, thatincludes the Pit Surveillance Program and an accelerated aging program, toensure that aging-related defects do not develop in pits. The same pits havealready spent several decades under the surveillance of the DOE, the nationallaboratories, and the military in the field. A routine stockpile surveillancehas been performed on the pits for 20 to 30 years in more hostile environmentsthan Zone 4. All data indicates that pits and containers will not degrade overthe interim storage period. The AT400A container is designed for a 50-yearlife. A pit and pit container surveillance program will continue for the AT400Acontainer. This surveillance program will minimize the likelihood of undetectedfailures in the pits and/or containers. Should a problem be detected additionalsurveillance would possibly need to be conducted, but it is not possible todetermine the number that would need to be examined without knowing what typepit was affected and what the nature of the problem might be.

RC: 12.026

Doc: PC-025/59

Page 4-182. What is a small number? Several magazines?


In this case, a small number refers to one Zone 4 magazine. The impactsfrom this facility have been evaluated in the EIS.

RC: 12.027

Doc: PC-025/60

General comment in section 4.12: The tritium accident caused quantifiableradiological impacts to plant personnel, facilities, environment, and public. For comparison purposes, please compare tritium accident with intrasitetransportation impacts. What is the maximum impact to plant personnel,facilities, environment, and public from tritium storage at Pantex? Has theexplosive damage potential of stored tritium been evaluated?


Intrasite transportation impacts are described in volume I, section4.12. Impacts to the workers related to the past tritium accident are discussedin volume I, section 4.14. All potential accidents involving tritium wereexplored. Volume I, section 4.14, discusses the risk dominant accidentsinvolving tritium.

RC: 12.028

Doc: PC-025/61

... Section 4.12.2. Since Table does not balance, where are theimpacts to storage activities in Zone 12 from pits, CSAs, and tritium?


These components are located on an interim basis within Zone 12. Pitsand Canned Subassemblies are stored on an interim basis prior to transfer toZone 4. Canned Subassemblies are also stored prior to transfer to the Y-12Plant at Oak Ridge. Tritium reservoirs are stored in the Tritium Vault withinZone 12. Radiological impacts related to these activities are included both inthe worker dose estimates and the accident risk evaluation provided in volume I,section 4.14.2.

RC: 12.029

Doc: PC-025/62

General question. What are the continuing impacts to transportation workersresulting from past tritium accident?


Exposures to plant personnel from the small amounts of tritiumoffgassing from the past tritium accident in Cell 1 are discussed in volume I,section 4.14, of this document. The total amount of tritium emissions are atthe limit of detection. As a result, it is not possible to calculate doses andconsequences to the non-involved workers and the public with high confidencelevels. To the extent practicable, the dose to the public has been estimated tobe less than 1.33 x 10-4 person-rem per year, resulting in a risk of 6.65 x10-8 excess LCFs. Practically speaking, the maximum dose to an individualnon-involved worker or member of the public would be effectively zero.

RC: 12.030

Doc: SG-003/3

Table S-1 in the Summary, under intrasite transportation, presentsperson-rem information (Summary page-18). The table is supported by Section4.12 in the main text. An underlying baseline person-rem appears to beincorporated into the estimates for the Proposed Action alternative. Neitherthe main text nor the table clearly state the assumptions used. The person-remshown for the Pit Storage Relocation alternative adds the estimated person-remfor pit storage relocation and the person-rem from the 2,000, 1,000, and 500weapons levels under the Proposed Action alternative. Thus, while implementingthe Pit Storage Relocation alternative, plant workers are assumed to receive theperson-rem associated with the Proposed Action alternative. The radiationexposures for individual workers for the alternatives are within regulatoryguidelines and do not have any public health significance....


The exposures associated with intrasite transportation under theProposed Action are the results of weapons transfers, pit transfers after weapondisassembly, and pit transfers from the repackaging of 20,000 pits. Theexposures associated with the Relocation of Pits Alternative are the results ofthe same activities as the Proposed Action plus the loading of either 8,000 or20,000 pits for offsite shipment. The No Action Alternative dose numberspresented include not only the expected doses from weapons operations but alsothe expected doses from the interzone transfers of 12,000 pits as part of thepit repackaging project.

RC: 12.031

Doc: SG-003/4

In Table S-1 for the Proposed Action alternative, 50 workers receive 61person-rem for 2,000 weapons. Next, 50 workers receive 48 person-rem for 1,000weapons. Finally, 50 workers receive 41 person-rem for 500 weapons. How doesone scale these numbers? The same type of calculations are made for the NoAction alternative. Again, the numbers for person-rem do not follow the amountof work.

In the Pit Storage Relocation alternative, the amount of person-rem from theProposed Action alternative appears to be added to what happens for pit storagerelocation. How can one add the person-rem for these two alternatives? Is thesame person-rem used two different times?


The exposures to the workers associated with intrasite transportationare the result of several activities (see response to comment 12.030). Only acouple of those activities will vary with, and therefore scale to, the differentweapons levels. The transfer of weapons for disassembly and the transfer ofpits after disassembly will vary according to weapons levels. The transfer ofpits for repacking will not vary according to weapons level.

Since activities associated with pit relocation (e.g., intersitetransfers, SST loading) and the Proposed Action (e.g., continued weapon storageand transfer operations) will be performed, the doses associated with theseactivities are added.

3.13 Waste Management

RC: 13.001

Doc: HT11/22

... Are [there] currently any waste by-products involved that result fromthe disassembling process?


For an elaboration on the response given at the public hearing, see thediscussion in section 1.3.9 of this volume.

RC: 13.002

Doc: HT11/23

Any nuclear waste by-products or radioactive waste? And is that wastestudied in this EIS?


For an elaboration on the response given at the public hearing, see thediscussion in section 1.3.9 of this volume.

RC: 13.003

Doc: HT11/24

So are most of the by-products stored onsite at Pantex?


To elaborate on the response given at the public hearing, currently,low-level waste (LLW) is stored onsite prior to shipment and final disposal atthe Nevada Test Site. All low-level mixed waste (LLMW) is stored in accordancewith the Agreed Order & Site Treatment Plan-Compliance Plan, 30 TAC 335, theRCRA Part B Permit and 40 CFR 260-280. In 1994, Pantex Plant disposed of 32.6cubic meters (42.4 cubic yards) of LLMW through an offsite commercial landfilllocated in Utah. In 1996, a second shipment of LLMW was disposed at the samefacility totalling 70 cubic meters (91 cubic yards). In September 1996, a thirdshipment was disposed at the same facility. Volume I, section 4.13, WasteManagement, presents the above information, including the updated informationregarding the 1996 LLMW disposal shipment. Eventually all stored LLMW would bedisposed offsite. See the discussion in section 1.3.9 of this volume.

RC: 13.004

Doc: HT02-09/2

What will the DOE and "We" do with all the waste that will begenerated for at least the next 20 years? There are no licensed facilities toaccept the wastes that are piled up on facilities throughout the DOE Complex atthis timewhy generate more than needs to be generated.


DOE is considering programmatic waste management strategies for the next20 years under the WM PEIS. The WM PEIS considers economic and environmentalimpacts including local, regional, and decentralized management strategies.

Pantex Plant, through a combination of successful pollution preventionand waste avoidance techniques (see volume II, appendix G), and offsite disposalof approximately 103 cubic meters (133 cubic yards) of LLMW, has reduced the "piledup" inventory equivalent to the volumes generated during 19921995. Furtherreduction is expected in fiscal year 1997.

RC: 13.005

Doc: HT02-04/3

Pantex, the Superfund site, is currently operating under no [discharge]permit with the State of Texas.


See discussion in section 1.3.9 of this volume regarding past practices.

RC: 13.006

Doc: HT13/84

Reference page 6-4 in the draft where it talks about permitting,specifically permitting at Manzano if pit storage was done...I have severalquestions related to that. Has...the Department of Energy had discussions withthe New Mexico Environment Department about what kind, if any, of permitmodifications would be needed if the pit storage was done at the Manzano site?

... Does the Department have a position about whether pit storage would besubject to a RCRA permit at Manzano or any other site?

(Ms. Founds: Since this is not waste or surplus material, it would not bepart of a RCRA permit.)

Reference page 6-4, the discussion...about permit requirements and thefact that Kirtland has an existing permit. It says that new permits or permitmodifications could be required. Would you explain that statement in relationto the statement that you just made, Nan?

So will the final EIS have a clear statement about what RCRA permittingrequirements the Department feels will be necessary at Manzano or any other sitefrom a RCRA standpoint?

Just as a follow-up to complete the loop, and I have primarily been talkingabout the Manzano site, but the question really relates to that I was surprisedthat the draft singles out Kirtland for that on this page. The Pantex site, ofcourse, also has a permit, so the question is, is the similar waste streammodification, to use your term, or waste stream results, would that be includedat any site that had a RCRA permit?

To make sure I understand, you are saying that the existing Pantex Part Bpermit covers storage of 20,000 pits at Pantex?

RCRA waste might result from those kinds of operations, but that is notsaying those are RCRA-type waste.


There are several reasons the New Mexico Environment Department mayrequire RCRA permit modifications for both DOE and the Air Force. Since theManzano Weapons Storage Area (WSA) has several Air Force Solid Waste ManagementUnits as defined under RCRA, the responsibility for investigation, cleanup, andclosure of the SWMUs would likely continue under Air Forces RCRA permit. However a language modification might be required that any new SWMU resultingfrom a DOE activity would be DOEs responsibility. The Manzano WSA is notcurrently DOE property (see 40 CFR 270 criteria), language addressing theManzano WSA would likely be added to the DOE RCRA Part B permit and the AirForce RCRA Part B permit. New Mexico Environment Department is likely toconsider these changes as Class 1 modifications covered under 40 CFR 270 toassure integration of the Kirtland Air Force Base and DOE permits. In addition,see discussion in section 1.3.9 of this volume regarding permit requirements.

Clarifying language has been added to volume I, section 6.5.

RC: 13.007

Doc: HT13/85

To follow up on that helpful comment, is there a document that exists thatdescribes that analysis that you just gave?

My comment would be that prior to the time of the final, I would hope therewould be some written-down analysis that would be either included in the EIS orreferenced in a supporting document reference that provides this explanationthat has just been made, because I dont see it in page 6-4 in the way I read it,and certainly, there is no document...or documents referenced on that page thatprovides that information.


See discussion in section 1.3.9 of this volume regarding permit issues. Clarifying language has been added to volume I, section 6.5, with a source.

RC: 13.008

Doc: HT12/36

Public Speaker: I have a comment. Its a crosscutting issue, it should bebrought up in each one. Im past chair of the CSRA Planners Group.... The Stateof South Carolina is concerned with any new project coming into the area ifYucca Mountain doesnt [come] about. And that really has to be addressedstrongly. And Ive heard it from folks in the governors office and folks in thearea around here that before we can have any of these, that issue should besolved at the policy level, like somebody [mentioned]...

Unidentified Speaker: Of States concern of moving additional operationshere with South Carolina?

Public Speaker: Without their feeling that they will be a dumping ground.

Unidentified Speaker: Okay.

Public Speaker: And that Yucca Mountain should be the dumping ground orwhatever, but...the issue is, lets not have it stop here. ...Each one of theseprojects should be looking at the waste issue and even DWPF is not supposed tohave its glass containers stay here. So thats something that has to be stressedsomewhere as a crosscutting issue. I know its not unfamiliar with [you].


See discussion in section 1.3.9 of this volume regarding hazardousmaterials.

RC: 13.009

Doc: CO-003/1

The acceptance of plutonium at Hanford should not delay, defer, ornegatively impact Hanford cleanup.


See discussion in section 1.3.9 of this volume regarding hazardousmaterials.

RC: 13.010

Doc: PC-019/1

Enclosed is another problem associated with the plant pointed out byAmarillo Globe News. (Globe News, Article, "City Wont Search ForContaminated Glove," May 24, 1996.)


The specific issue referred to in the article is considered an isolatedincident. Pantex Plant has resolved the issue with the City of Amarillo and theState of Texas.

RC: 13.011

Doc: HT16/32

...the hazardous waste permit 51289 [that] is issued by the TNRCC andmentioned on Page 4-189, the comment...should be amended because the brand newpermit became effective February 16th, 1996. ...Section on Page 4-79,some of the units identified in the third paragraph have now been closed andyoull probably want this reflected in the EIS. On Page 4-147 and 148, theseparagraphs should be reviewed by the low-level mixed waste team for updates onthe current waste inventories, waste plans, and waste activities. Also,discussion of MTUs may need to be revised on these pages. ...weve issued theagreed order, site conception. Its an agreed order issued October 2nd, 1995concerning mixed waste. Im not sure thats fully reflected in the EIS.


Clarifying language has been added throughout the EIS regarding approvalof the Class 3 modification dated 2/16/96 and the relationship with the AgreedOrder. The offsite disposal of low-level mixed waste has been updated. Anotherchange included deletion of volume I, table, with the salientinformation being incorporated in the text.

RC: 13.012

Doc: HT16/34

...on Page 4-197, first column, first full paragraph, when you describe: InZone 4, two magazines, eight permitted conex boxes and 25 conex boxes are usedfor storage of low-level waste. I think I understand that better now. It wasvery confusing to me when I read it. So eight of the conex boxes are permittedand the other 25 are just the surge capacity thats been added without anypermitting process?


As a result of the recent Class 3 modification dated 2/16/96, clarifyinglanguage has been added throughout the EIS, including section 1.3.9 of thisvolume.

RC: 13.013

Doc: HT16/35

Theres a sentence in the middle of that paragraph that says: Stormwaterdischarge associated with industrial activities is discharged to the playas onsite. I dont know what that means. Can you help me there? I didnt know thatstormwater discharge was used in industrial activities.


The phrase "Stormwater discharge associated with industrialactivities" is regulatory language contained in the National PollutantDischarge Elimination System (NPDES) permit. The sentence was simplified toread "Stormwater drains to the playas onsite."

RC: 13.014

Doc: HT16/36

...on Page 4-204 where you do your cumulative thing with the PEISs again forthe disposition alternative. You list the types of wastes that will be involvedin that alternative. And even though a reactor, a nuclear reactor, is kind ofthe bounding case there, theres no high-level waste mentioned in category ofwaste that will be generated under that option. I think maybe you may need toadd high-level waste or spent fuel storage or something thats going to beimpacted under that.


Commentor is correct. The clarification has been added to volume I,section 4.13.5.

RC: 13.015

Doc: HT16/37

...since the contested case hearing negotiations got mentioned, in thesettlement agreement there was a much appreciated and significant commitment onthe part of the DOE to at least examine one alternative to the burning grounds,an alternative method of incineration of those wastes. Its not mentioned inthis document. It should be.


Additional language examining the continued study of an alternativedisposal method has been added to volume I, sections 1.2.2 and 4.13.1, andvolume II, appendix G of the EIS.

RC: 13.016

Doc: HT16/38

It says new facility construction and upgrades are not expected to impactwaste operations. One of the things that I have a concern about in thisdocument is the pit conversion and reuse facility, one of the two new facilitiesthat are covered by this document, which we dont seem to learn a great deal ofdetail about, in terms of what it generates in waste streams, et cetera. And,when you went through this viewgraph, I seem to infer from what you said thatthis statement was based, in part, on new facilities, I assume waste handlingfacilities, that had been built on site. And so Im asking you, is my concern abasis of definition of what impact is or what? I mean, how [do] we bring thesekind of broad blanket assumptions back into a document where youre talking aboutdust particles when you do construction and then you assert that theres noimpact. ...I mean, how do we relate this broad assertion to the fact that wehave new plutonium handling functions that are going to come onto the plant inthis document in this new facility and we have new kinds of hazardous wasteoperations that are coming on the plant with the other new facility? How can wesay that that has no impact?...if youre talking about negative impact as opposedto impact, its not accurate to say that it has no impact. Maybe your assessmentis that none of it is a negative impact. Is that an accurate interpretation?


To elaborate on the response given at the public hearing, the impacts ofnew facility construction and upgrades on waste management are discussed andanalyzed in volume I, section 4.13.2, and volume II, appendix H, including thePit Reuse Facility. The six projects presented in the EIS are the HazardousWaste Treatment and Processing Facility, Pit Reuse Facility, Gas AnalysisLaboratory, Material Compatibility Assurance Facility, Nondestructive EvaluationFacility, and Metrology and Health Physics Calibration and Acceptance Facility.

As described in volume II, appendix H, the Pit Reuse Facility operationsare limited to casing enhancements, cleaning, weighing, radiographing, leakchecking, inspection, and backfilling. These activities are not consideredplutonium processing or reprocessing. Plutonium processing and reprocessing arenot within the scope of the Pantex Plant EIS (see the Stockpile StewardshipManagement PEIS).

RC: 13.017

Doc: HT16/41

On the Federal Facility Compliance Act, this was being drafted whenthis draft document was made. And the document says that the impact of thisis...unknown at this time. I want to know if theres been an update on this orwill...there be more information forthcoming?


As discussed in section 4.13, Waste Management, the Federal FacilityCompliance Act Final Site Treatment Plan was approved by TNRCC in September1995, and an Agreed Order was issued October 2, 1995. In addition, thetri-party Federal Facility Agreement (FFA) continues to be negotiated (as ofSeptember 1996) regarding restoration activities. As discussed, impacts of anFFA remain unknown. Updated information has been incorporated in volume I,section 4.13.

RC: 13.018

Doc: HT17/68

...its been pointed out several times that this document intentionally didnttry to deal with the permits that have been issued between the time that thedocument was being written. The concern that I have, however, is...that it beexplicitly stated, not just in a chart showing the duration of the permits, butexplicitly stated that the permits that were talking about here, the existingpermits that you will be talking about, will all...need to be renewed, revised[again] during the ten-year time frame of this document.


DOE understands that the permits routinely undergo revision or renewalduring the EIS timeframe. Volume I, section 4.13.1, presents the Pantex Plantpermits, including effective date and expiration dates. Should renewed ormodified permits result in NEPA related compliance issues, DOE will addressthose issues at that time. As indicated in volume I, section 4.13, Pantex Plantsuccessfully renews and modifies existing permits, as necessary.

In addition, see general discussion in section 1.3.9 of this volumeregarding permits.

RC: 13.019

Doc: SG-012/1

Some of the actions appear to (potentially) be in conflict with NMED lawsand regulations.Vol. I, page 6-4, 6.5 Pit Storage Sites, under the paragraphreferring to Kirtland Air Force Base. The U.S. Department of Energy (DOE) mustbe in compliance with the Federal Facility Compliance (FFC) Order issued by NewMexico under the provisions of the Federal Facility Compliance Act. TheFFC Order has jurisdiction over generation and storage of mixed waste and sitetreatment plans for its disposition (p. 5-60, 5.5.10 Waste Management, "Thepit storage operations would generate less than 1 cubic meter (1.3 cubic yards)of mixed, low-level, and hazardous wastes.")


Clarifying language has been added to volume I, section 5.5 and chapter6.

RC: 13.020

Doc: SG-012/2

Mention of the New Mexico unilateral FFC Order is not included in table6.5-4.


The New Mexico unilateral Federal Facility Compliance Order was added tothe table.

RC: 13.021

Doc: FG-003/2

EPA suggest that Appendix G should reference the requirements of ExecutiveOrder 12902, Energy Efficiency and Water Conservation at Federal Facilities(March 8, 1994), particularly for the six new construction projects at Pantexlisted in table (gas analysis laboratory, materials compatibilityassurance facility, etc.). Section 306 of Executive Order 12902 containsspecific requirements regarding the construction of new facilities owned by theUnited States. Additionally, the Final EIS would be strengthened if it coulddiscuss whether this Executive Order has any implication on the proposed interimstorage of plutonium pits in Nevada, South Carolina, New Mexico, and WashingtonState in terms of energy and water conservation.


Additional information has been added to volume II, appendixes G and Hregarding Executive Order 12902. For the purpose of bounding the NEPA analysis,current levels of energy and water consumption were used to compare alternativesite impacts. The actual design of the proposed facilities includes an energyconservation analysis with life cycle costing.

RC: 13.022

Doc: PC-025/4

On Page 1-16 in column two in the first paragraph. What is the definition ofabnormal? Is the chance of a similar accident greater than 1 in a million? Ifnot, I would argue with DOE risk numbers that the incident is not abnormal. Forconsistency use risk assessment language for "abnormal." "Abnormal"means nothing. Use unlikely, extremely unlikely, etc. If this incident occurred,what calculations prove the event is abnormal? What number of similar operationswere completed before the event occurred? How do you justify orders of magnitudedifference between theoretical and actual experience, if one exists? Why doesthe WM PEIS identify Pantex as a TRU waste generator (see appendix) if Pantex is"Abnormal?"


The statement "Pantex currently is custodian of significant volumesof LLMW, LLW, and TRUW," found on page 12-1 of volume II of the Draft WasteManagement PEIS is incorrect. Pantex Plant currently manages three drums of TRUwaste as discussed in volume I, section 4.13.1.

The phrase "generated from an abnormal weapons dismantlementincident" has been deleted.

RC: 13.023

Doc: PC-025/63

See section 4.13. Why only to 1994 for data? DOE reports annually, correct?Status of permit modification? What impacts are expected? What is status of EPACERCLA negotiations?


Updated information has been incorporated in volume I, section 4.13. This includes adding 1995 data to Table The 1996 shipment anddisposal of low-level mixed waste to Utah has been incorporated. Impacts werereevaluated based on the updated information and presented in volume I, section4.13.2. The permit modification was approved on February 16, 1996. The EPAComprehensive Environmental Response, Compensation, and Liability Actnegotiations are continuing.

RC: 13.024

Doc: PC-025/64

Table Why no margin for ER wastes? ER wastes are the mostunpredictable!


A 10 percent margin has been added to environmental restoration wastevolumes.

RC: 13.025

Doc: PC-025/65

Table In SSM and S&D, the number of burning groundfacilities is expected to be reduced to one. Are the 9 trays and 3 pansexpected to be closed in the near future like the cages and pits?


The Stockpile Stewardship Manangement PEIS and Storage andDisposition PEIS look at environmental impacts through 2055. On February 16,1996, TNRCC approved a Class 3 modification which identifies DOEs operationalneeds for 9 trays, 3 pans, and 3 flash pads. The permit also identifies theneed for these facilities through 2100, the expected year of final closure. Theformer flashing pits and cages are no longer operational and are undergoing RCRAclosure per the permit. The RCRA closures are expected to be completed byfiscal year 1997.

RC: 13.026

Doc: PC-025/68

In sections mixed waste and hazardous waste on page 4-193. Where is all theexplosive burning waste noted in section 4.7 and table


For the purpose of NEPA analysis, waste categories (e.g. LLMW, HW, etc.)were used to assess waste management impacts. The commentor is referred to thePantex Environmental Information Document for detailed waste stream information.

RC: 13.027

Doc: PC-025/69

Page 4-199. How accurate is the 1.45 factor? Why doesnt table a margin?


The 1.45 factor represents the best available information. Table4.13.2.21 of volume I has been deleted as noted in response to comment 13.011.

RC: 13.028

Doc: PC-025/70

Page 4-202. 14,000 LLW shipments over 20 years? Thats 700 a year, almost 3shipments a week not including weekends. Is DOE hiding waste at Pantex, thenumbers presented in tables through -3 dont show this to be true? DOEis considering a landfill for at most 2,500 cubic meters over 10 years. Thatsstupid! Why dont you landfill the NHW around 13,000 cubic meters over 10 years,18,000 shipments of HW over 20 years? Thats 900 a year, almost one shipmentevery day not including weekends. Is DOE hiding explosive wastes? DOE shouldthink about a hazardous waste landfill for the 2,000 cubic meters over 10 years.


Volume I, section has been completely rewritten. The WM PEISinformation has been updated to reflect reduced waste volume projections.

RC: 13.029

Doc: PC-027/4

Reference page 6-17, volume I Main Report, Column PotentialApplicability/Permits: The word "permit" was omitted from this pageon New Mexico while it appeared in the South Carolina page 6-14 and the Texaspage 6-12. I know that water permits are required for businesses andindividuals and would assume that a government entity should also comply withthe permit requirements, especially since this State has severe water problems. The word "permit" should be added for those New Mexico areas where apermit is required. I realize that laws differ from state to state, but thereare some areas where permits are required here.


The table has been corrected to include the word "permit".

RC: 13.030

Doc: SG-003/38

Regulatory Oversight - The TNRCC would be more willing to embrace Pantexsmission within the State of Texas if DOE would promote independent regulatoryoversight for radioactive source, special nuclear, or by-product material. Weapplaud DOEs willingness to share its information concerning radioactivecontaminants; however, it is our opinion the public would be better served andpotential waste management errors minimized if the oversight authority wasshared with the TNRCC.


For DOE to continue to fulfill its responsibilities as mandated bystatute, Presidential direction, and Congressional authorization andappropriation, the generation of solid waste including "nuclear waste"is an unavoidable result. Recently, in response to numerous public requests forindependent regulatory oversight of radioactive source, special material andby-product material, the Secretary has created a Working Group on ExternalRegulation. This Working Group is presently reviewing various alternatives forexternal oversight of activities at DOEs nuclear facilities and will submit areport sometime in 1996.

RC: 13.031

Doc: PC-030/2

DOE should move with all possible speed to cease using the Burning [Ground]for waste management at Pantex.


The Pantex Plant continues to implement a Pollution Prevention/WasteMinimization Program to reduce environmental impacts through waste avoidance andwaste minimization. Appendix G of volume II contains detailed information ofthe PP/WM Program. As discussed in volume II, section G.3.2, Pantex Plant, in1994, as a result of a new procedural control reduced HE-contaminated hazardouswaste by 99%. As discussed in volume II, section G.3.8, in March 1994, a formalliterature search was conducted to investigate treatment/processing methods forHE other than open burning-open detonation. The Best Available ControlTechnology (BACT) analysis concluded that controlled open thermal treatment withexisting administrative controls constituted BACT. The alternatives weredetermined to be either technically infeasible or economically infeasible.

However, as part of the Pantex Plant continuing effort to reducepollution and minimize waste, DOE continues to study potential alternatives toopen burning of energetic materials at the Pantex Burning Ground (e.g.,commercial resale, base hydrolysis treatability study). This additionalinformation has been incorporated in volume I, section 4.13, and volume II,appendix G.

RC: 13.032

Doc: PC-033/1

Page S-6, col. 1, par. 1: It states that "Pantex also generates andmanages recyclable materials." What are these [materials] and where arethey recycled to? Do these include the various barrels of miscellaneous boltsand nuts that are sold at auction or to salvage what the general public canpurchase? These barrels have been known to contain various parts that are farfrom nuts and bolts and are apparently parts of disassembled weapons and otherconfidential tags and various seals included in these barrels of supposedlyrecycled materials that I have been told by plant employees are confidentialmakeup and design. How did these materials make it into a barrel ofmiscellaneous bolts and nuts at a salvage yard and what are the procedures forrecycling these bolts and nuts? Can any individual purchase these, and if sowhat is to keep them from copying the design and makeup of these parts?


Volume II, appendix G, addresses the current status of Pantex PlantsPollution Prevention and Waste Minimization program. Scrap metal or "nutsand bolts" can be recycled and are recycled through various outletsdepending on the value of the metal. In some cases due to liability concernsscrap metal is only sold to operators of smelters to ensure the "nut andbolt" is melted down.

The materials contained in weapon components in whole or in part areroutinely recycled. In cases were the weapon components are classified (i.e.,contain information subject to Atomic Energy Act regulation) or have thepotential for military-proliferation value, Pantex Plant is required by law todemilitarize and sanitize (D&S) weapon components. Examples of D&Sprocesses are presented in volume I, section 1.2.2, Disassembly of NuclearWeapons. After the D&S process, the resulting materials can be recycled. The Pantex Plant uses written procedures for identifying weapon componentsrequiring D&S, D&S processes, and releasing of D&S materials. Volume II, table G.3.71, in appendix G of the EIS, shows that 41 metric tons of"weapons metals" have been recycled with a salvage value of 2.1million dollars.

3.14 Human Health

RC: 14.001

Doc: PC-018/1

There are over 1 million people living in this area. All of the above wouldbe in danger of contamination if an accident did occur at Pantex.


The Pantex region of influence (ROI) for potential accidents includes an80-kilometer (50-mile) radius surrounding the plant. An ROI with a diameter of80 kilometers is the usual ROI for accident analyses in NEPA documents andSafety Analysis Reports. The population in the Pantex ROI is estimated at267,107 persons. A representative range of accidents including accidents thatcould result in the release of nuclear materials to this population has beenevaluated in this EIS. The impacts from potential accidents at Pantex Plant topeople in the area including the risk from contamination are discussed in volumeI, section 4.14.

RC: 14.002

Doc: PC-009/1

My question relates to DOE/EIS-0225D, Page 5-12, second column, secondparagraph, line 6. The document states starting at line 5: "With anadditional 0.11 LCF from pit handling, the total risk of *latent cancers amongworkers at the P-Tunnel would increase by 1.8 percent."

All references to latent cancers in that section titled "Impacts ofStoring 20,000 Pits", refer to LCFs, latent cancer fatalities, except line6 as indicated above by a "*". Does the increase of 1.8 percent referto "latent cancers" as it states, or to "latent cancer fatalities"as the rest of the section would seem to imply.


The commentor is correct. The increase refers to latent cancerfatalities, not latent cancers. The text has been revised.

RC: 14.003

Doc: HT11/1

... How many years is this [plutonium] considered to be actually hazardouswaste?


To elaborate on the response given at the public hearing, plutonium inpit form is not considered a hazardous waste. Weapons-grade plutonium is madeup largely of plutonium-239, which has a half-life of approximately 24,000years. After 24,000 years, one half of the plutonium will still be present. The standard calculation is that 10 half-lives or 240,000 years are requiredbefore all of the plutonium is decayed. Whether the plutonium is hazardousdepends on its location relative to human receptors.

RC: 14.004

Doc: HT11/2

... If the half life is 24,000 years, wouldn't the actual hazard be muchlonger than that?


See response to comment 14.003.

RC: 14.005

Doc: HT11/3

What was the consideration of the maximally exposed individual?...[From] 6.6rem, which I assume is the forklift driver or whoever punctures this thing,...wego all the way the public exposure.... Public exposure would not besafe 100 milligrams per year, and I was wondering how we went from one number tothe other just like that?


To elaborate on the response given at the public hearing, the involvedworker (forklift driver) is estimated to receive 6.6 rem of dose commitment whena pit is punctured. This dose commitment is over a 50-year period due to theinhalation of plutonium oxide dust released during the forklift accident. Theamount of plutonium oxide released is about 0.6 milligrams. This release isthen transported and dispersed by the wind. An individual at the site boundarywould also inhale some of the plutonium dust if located directly downwind fromthe release. The dose commitment that the maximally exposed offsite individualreceives is much less due to dispersion and deposition of the plutonium dustduring its movement from the release point to the site boundary.

RC: 14.006

Doc: HT11/4

And that [maximally exposed individual] person is really the person hangingaround for 24 hours a day?


To elaborate on the response given at the public hearing, the maximallyexposed individual is a hypothetical person who is assumed to be at the siteboundary for 24 hours a day.

RC: 14.007

Doc: HT02-02/2

It may be safer than other sites, but we can prove that accidentsat least Ihope the incidents that have affected us personally were accidentshave happenedthat [have] endangered our property as well as our personal safety and others inthe neighborhood of Pantex Plant.

There have been numerous major fires on the site, three of four within thepast two years. We took cold drinks and ice to the firemen on various occasions.We have had cast steel shrapnel chunked at us. We have picked up some 300 to 400pounds of a naval breech block, one piece weighing 59 pounds. Some of thisshrapnel was found some one and one-half to two miles from where it wasexploded. We have had tractor tires ruined from it.

Through the years, we have had windows broken, pictures knocked off walls,et cetera. On October 4, 1995, a very large charge of explosive was set off tosignal the start of an emergency management drill. This drill "test"broke our house, cracked the slab, rafters, walls, brick, shower, plumbingcausing flooding of the basement, and other damages resulting in some $30,000 inrepairs and replacement of carpets and other floor coverings, rebuilding theshower, cracks, et cetera. We also must have the house leveled.

Too many questions are yet unanswered by the studies that have beenconducted. Granted, it would be impossible to anticipate all potential problemsthat may arise, but there does seem to be a lack of scientific research used forthe study. It would appear that a conclusion has been drawn and figures tosupport that conclusion were used without any real scientific information.


Incidents or accidents occur at all active industrial plants and PantexPlant is no exception. However, there have been no accidents at Pantex Plantwhich have endangered personal safety of the public in the plant vicinity. DOEis committed to the safe operation of Pantex Plant, as well as the protection ofthe public, the environment, and the facility employees.

Grass fires were considered as part of the EIS risk assessment. Thespecific examples mentioned in the comment were fires which were containedonsite and posed no threat to Pantex operations or offsite property.

With respect to the Naval breech block event, that was a one-timeexperiment (almost 30 years ago) which is now precluded from reoccurrence byadministrative limits and procedures.

The analysis conducted for the EIS was done according to CEQ and DOEguidance in using the best information available and nationally accepted methodsand models.

RC: 14.008

Doc: HT05/11

Could you speak more toward the latent cancer fatality issue... and discusswhat is the most likely outcome?

If that's the actual expected...outcome, why isn't that put into yourstatement as the most important?

In other parts of the document, you indicate that the most likely outcome iszero cancers.

Well, I'm saying is you explain this in two different ways in your document.In this shorter version that you've put here in the narrative summary, youappear to attach some greater certitude to potential cancer risks than you do inthe other sections, especially in the appendix, where you indicate that the mostlikely outcome is zero cancers.

And I'm saying, for purposes of explaining this to the community, the moreappropriate explanation would be to indicate that the most likely outcome iszero cancers.


This discussion regards the interpretation of calculated risks fromradiological exposures, for example, 0.13 cancer fatalities from an exposure of330 person-rem. Further clarification of the interpretation of the calculatedrisks has been provided in the form of a discussion in section 1.3.10 of thisvolume.

RC: 14.009

Doc: HT05/12

Under the statement he was referring to, it said shipment of pits to analternative site would increase radioactive exposure of the Pantex Plant by 113.Why would it increase if the pits are shipped to an alternative site?


The offsite shipment of pits from Pantex Plant would require the removalof the pits from the Zone 4 magazines and the loading and the restraining ofpits within a Safe Secure Tractor Trailer vehicle. The performance of theseactivities will increase the worker exposure total.

RC: 14.010

Doc: HT05/13

What is the underlying base assumption of man-rem or person-rem exposurethat you have ascribed to ongoing site work at the 500, 1,000, and 2,000 levelssuch that you would be able to extrapolate from these numbers exactly what isthe base amount that you say they're going to get, irrespective of the number ofweapons that they're working?

... I've tried to deconvolute your calculations and I can't do it.

As the person who supplied that data from the Pantex Plant, I'm not able tofollow your calculations, nor do I see them stated anywhere in the documents.

I cannot extrapolate where there's a base of what they used to build up onsome of these numbers when they compared from site to site. There are someassumptions that were made that are not stated when they made the calculation onwhat might happen, especially when you start looking at making movements toalternative sites.

... I want some additional information [in the EIS] on the assumptions thatwere made in reaching these calculations, such that someone reviewing it, nothaving the opportunity to speak to [authors of the document], could also see iftheir pencil-whipping of the data would be the same as his.


This discussion regards the dose estimates for the Transportation andStaging Department provided in volume I, section 4.12, Intrasite Transportation. The commentor requests clarification on why the estimates for worker exposuresdo not scale to zero for a weapons activity level of zero. The reason that thisis not the case is because the dose estimates also include impacts related tointerzone pit shipments required for the pit repackaging project. Thus, even ata hypothetical zero weapons activity level, there will still be worker exposuresfrom pit transfers. Further clarification of this issue is provided as adiscussion in section 1.3.8 as well as in volume I, section 4.12.

RC: 14.011

Doc: CO-008/38

Page 4-205, Paragraph 4 Exposure from inhalation is the only pathwayassessed in Pantex SWEIS. Please discuss exposure through other pathways such aswater, soil, and vegetation.


Additional alternative pathway discussions have been added to volume I,section 4.14.

RC: 14.012

Doc: CO-008/39

Page 4-208, Paragraph 2. Internal exposures, received when radioactivematerials are deposited through inhalation, ingestion, absorption, areconsidered minor contributors to worker doses, therefore are not considered inthis document. Please define "minor."


Historical evidence of external and internal exposures at Pantex ispresented in the Pantex Plant Safety Information Document (Pantex 1996a). Theseexposures show that the internal exposure received by workers is typically afactor of 100 to 1000 less than the external exposure received by workers. Thetwo to three orders of magnitude difference between these exposures is why it isconsidered to be a minor contributor to worker exposures.

RC: 14.013

Doc: CO-008/40

Page 4-207, Paragraph 2. Please list improvements/changes in work practicesand scope that have been implemented to significantly reduce worker externalexposure?


The As Low As Reasonably Achievable (ALARA) program implemented atPantex Plant minimizes radiation exposure during performance of all radiologicaloperations. Plant management and the Radiation Safety Department are constantlyseeking ways to reduce exposures. As recently as January 1, 1996, exposurelimits were reduced from 1 rem/yr to 900 mrem/yr for manufacturing personnel and500 mrem/yr for the general plant population.

RC: 14.014

Doc: CO-008/41

Page 4-207, Paragraph 2. Please discuss the cumulative effects fromradiological exposure, hazardous chemical, toxic releases and emissions onindividual workers and the public population.


There is insufficient scientific evidence to quantify synergisticeffects between radiation and chemical exposures, if any. Effects of theseexposures are modeled individually using accepted scientific standards andmodels. The calculated effects from these exposures are shown individually tobe extremely low.

Additionally, a useful measure of potential human health effectsresulting from exposure to a combination of non-carcinogenic chemicals is thehazard index. Volume I, section, describes the basis and theevaluation of the hazard index for Pantex Plant. The hazard index calculationindicates that no adverse health effects are expected.

RC: 14.015

Doc: CO-008/42

Page 4-208, Paragraph 6. "Effects Screening Levels (ESLs) may beunrealistic, to state that none of the chemical concentrations exceed ESLs,therefore they are not expected to have adverse health effects to members of thepublic." What is the basis for this statement, when synergistic effectshave not been evaluated?


See response to comment 14.014.

RC: 14.016

Doc: CO-008/43

Page 4-209, Table Why are there no standards for 5 pollutantsresulting from Plant sources in Table


At the time the Draft EIS was produced, TNRCC had not establishedstandards for the fixed pollutants. Since the publication of the Draft EIS, theTNRCC has published standards for Trichloroethylene and for Ketones. Volume I,Table has been updated to reflect the new standards.

RC: 14.017

Doc: CO-008/44

Page 4-210, Table The table lists significantly higher ESLs forseveral contaminants, i.e., MIK, and MEK. Please correct the inconsistenciesfrom the table on page 4-209.


Page 4-210 was a continuation of table in the Draft EIS,which began on page 4-209. The ESLs presented in volume I, section 4.14 arespecific to each pollutant and are consistent with those presented in Table4.7.1.3-4.

RC: 14.018

Doc: CO-008/45

Page 4-210, Table Please address latent cancer probabilityresulting from releases and/or daily operations emissions. Describe cancers notlinked to radiological exposures.


The radiological emissions from normal operations are described involume I, sections 4.14 and 4.7. Modeling has shown that the doses to thepublic from these releases is small (6 x 10-5 mrem/yr for a maximum offsiteindividual from Pantex Plant sources compared to 334 mrem/yr from naturalbackground radiation). This dose is considered a negligible individual dose bythe National Council on Radiation Protection and Measurements. The yearly cancerrisk from this exposure is estimated at 3 x 10-11. When compared with thebaseline cancer risk in the vicinity of the Pantex Plant (1.7 x 10-3 per year),an individual has a much greater likelihood of incurring a cancer from sourcesother than Pantex Plant related emissions (e.g., from genetic predisposition,chemical exposure, diet, stress, and other sources of pollution). Cancermortality statistics for the State of Texas are available in the Pantex EISpublic information center.

The risk of cancer from chemical exposures to a hypothetical offsiteindividual is discussed in volume I, section 4.14. A hypothetical individualliving at the plant boundary would have an increase in lifetime fatal cancerprobability of 1.2 x 10-5 from exposures to carcinogenic chemicals releasedfrom Pantex Plant.

RC: 14.019

Doc: CO-008/46

Page 4-215, Paragraph 2. The June 1994 study by the Texas Cancer Registry,TDH, focused only on cancers of the breast, prostate, brain, thyroid, andleukemia. Other radiation-associated cancers, such as bone and lung were notincluded. Why? What about other types of cancers? Please include or justifyother types not included.


The referenced health study was performed solely by the State of Texas.However, discussion with Mr. Barry Wilson of the Texas Department of Health,Cancer Registry Division indicated that the "Study of Cancer in SelectedCounties Near the Pantex Nuclear Weapons Plant" (TDH 1994) report wasperformed "because of a request from environmental groups and mediaattention." The cancers studied were specifically requested by thesegroups.

RC: 14.020

Doc: CO-008/47

Page 4-215, Paragraphs 3 and 5. The epidemiologic study (Acquavella 1985)and the follow-up study conducted by NIOSH only looks at mortality ratios. Isthere an on-going health surveillance, either mortality or incidence, forex-workers of Pantex?


See discussion in section 1.3.10 of this volume regarding a plannedfollow-up study.

RC: 14.021

Doc: CO-008/48

Page 4-215, Paragraphs 3 and 5. Cancer is the only health issue addressed.What about all other health problems associated with nuclear and HE materialsprocesses? Please explain.


The risk of latent cancers is consistently the major endpoint formortality associated with nuclear and high explosive (HE) materials processes.The reasons for this focus include:

· Chemical hazards and impacts are analyzed in volume I,section 4.14 and are found to be small.

· Mortality from diseases other than cancer has not beenconsistently or significantly increased by radiation in human populations (BEIRV) (NAP 1990).

· Occupational dose limits (both for chemicals andradionuclides) are set such that deterministic effects (effects other thancancers) will not occur among adults if the dose limits are not exceeded (ICRP1983).

· Genetic damage to worker progeny is not expected atexposure levels experienced at Pantex Plant (ICRP 1991).

· The maximum exposures to offsite individuals frompotential accidents are not severe enough to cause deterministic effects (ICRP1983).

RC: 14.022

Doc: CO-008/49

Page 4-216, Paragraph 2. The yearly incidence rates (refer to work placeinjuries) measuring Pantex safety programs compares Pantex to nationalindustries. Is this a likely scenario? Why?


The frequency of workplace injuries provides clear indication of theseverity of hazards encountered by the workforce at Pantex Plant as well as theviability of Pantex Plant workplace safety programs. The frequency of work placeinjuries at Pantex Plant compared to other industries provides a relativecomparison both between the severity of hazards encountered at these differentworkplaces and the viability of workplace safety programs.

RC: 14.023

Doc: CO-008/50

Page 4-217, Paragraph 2. This paragraph states that a fire limited to theinterior of a facility would only cause internal releases in the room of thefire. Where would those internal releases eventually go? Wouldn't they have togo external? Please explain.


As stated in volume I, section 4.14.1 high efficiency particulate airfilters installed on ventilation system exhaust ducts will limit the amount ofparticulate radionuclides released to the environment.

RC: 14.024

Doc: CO-008/51

Page 4-218, Paragraphs 1 and 3. When and how will OSHA regulation of workerhealth and safety be implemented? What will the reporting mechanisms be?


The DOE and Occupational Safety and Health Administration (OSHA) haveagreed to a temporary pilot project to facilitate the shift of worker protectionto OSHA. Under a temporary pilot project agreed to by the two agencies, OSHAwill regulate and oversee worker health and safety at the Argonne NationalLaboratory in DuPage, Illinois. During the pilot, OSHA will evaluate the currentsafety and health program at Argonne and respond to employee complaints.

Information obtained during the Argonne pilot project is expected tohelp the two agencies determine the resource needs of OSHA if it is toultimately assume responsibility for worker safety and health at DOE facilities.While OSHA regulates and enforces worker health and safety at industrial andsome government workplaces, current law exempts most DOE facilities fromexternal regulation and enforcement. DOE internal regulations do, however,require all facilities to meet current OSHA standards.

RC: 14.025

Doc: CO-008/52

Page 4-218, Paragraphs 1 and 3. "DOE contractor operations at Pantexexpose workers to hazardous constituents." Are workers fully aware of theseexposures and of the combined effects to human health? Discuss in detail howworkers are prepared for these exposures, consequences, and effects.


All hazardous materials at Pantex Plant are required to have a MaterialsSafety Data Sheet (MSDS) that describes the hazards of the material and theproper packaging, handling, and disposal of this material. All Pantex Plantemployees are required to attend a hazards communication training course whichtrains them to read and interpret hazardous material labels and how to use anMSDS. Workers involved with specific activities such as hazardous chemicals,high explosives, and radioactive materials receive additional job-specifictraining.

RC: 14.026

Doc: CO-008/53

Page 4-218, Paragraphs 1 and 3. Daily routine emissions are not reported tothe public. Shouldn't workers and the public be made aware of these routineemissions for human health reasons and environmental consequences?


Daily routine emissions are reported in volume I, section 4.14.2 forradiological emissions and volume I, section 4.7.1 for hazardous chemicalemissions. Responses to comments 14.025 and 14.027 describe hazardcommunication with workers. Documents such as this EIS and site environmentalreports provide hazard communication with the public.

RC: 14.027

Doc: CO-008/54

Page 4-219, "The continuation of weapons-related operationsat Pantex would result in the continuation of radiological exposure to plantworkers." Have these workers been made aware of these health hazards? Dotheir families know the consequences of these health effects to themselves,also?


Radiological workers are required by federal law (10 CFR 835) to receiveradiological worker training. Radiological workers are required under article835.902 to be trained to ensure familiarization with the hazards they willencounter in the workplace. Uninvolved family members will not be exposed toradiation as a result of another family members employment at Pantex Plant. DOEis required to provide periodic reports to personnel of their individualdosimetry readings. This keeps workers informed of the level of exposure theyhave received and allows plant management to move personnel (e.g., expectantmothers) away from any operations that could be potentially harmful.

RC: 14.028

Doc: CO-008/55

Page 4-220, Table The cumulative radiological doses andexpected latent cancers to the public from normal operations have not beenassessed. Why are these exposures not evaluated?


The radiological emissions from normal operations are described involume I, section 4.14 of this document. Modeling has shown that the doses tothe public from these releases is small (6 x 10-5 mrem/yr for a maximum offsiteindividual). This dose is considered a negligible individual dose by theNational Council on Radiation Protection and measurements. The yearly cancerrisk from this exposure is estimated at 3 x 10-11. When compared with thebaseline cancer risk in the vicinity of the Pantex Plant (1.7 x 10-3 per year),an individual has a much greater likelihood of incurring a cancer from sourcesother than Pantex Plant related emissions (e.g., from genetic predisposition,chemical exposure, diet, stress, and other sources of pollution).

RC: 14.029

Doc: CO-008/56

Page 4-220, Table The combined toxic chemical, radiologicalreleases and emissions are not evaluated for workers or off-site populations.Why? Give exposure rates for both groups.


See response to comment 14.026 and discussion in section 1.3.10regarding chemical and radiological synergism.

RC: 14.030

Doc: CO-008/57

Page 4-221, Paragraph 4. Not all accident scenarios are evaluated. Only asubset that contribute a large fraction of the total risk from Pantex operationsare analyzed. Please give reasons why all potential scenarios are not evaluated.


All potential accident scenarios were not analyzed in detail becausetheir contribution to risk was determined to be small. It is standard practicein risk assessment to identify and discuss those risks with the greatestpotential to effect human health.

RC: 14.031

Doc: CO-008/58

Page 4-222, Paragraph 3. "For the risk significant scenarios forPantex, the frequency and consequence assessments are performed on a site-widerather than a facility-specific basis." What would the outcome be ifassessment were facility-specific?


The risk for an individual facility would be lower because the site-widerisk is the summation of the risks of all facilities. It was the intent of therisk assessment to identify the total risk that the Pantex Plant poses to thesurrounding communities.

RC: 14.032

Doc: CO-008/59

Pages 4-223 and 4-224, Figure On the evaluation of risk, doesDOE look at all types of cancers or only those noted in the workers study of1985? If so, why?


This assessment looked at all cancers that cause fatalities. Nonfatalcancers were not assessed. See discussion in section 1.3.10 of this volume.

RC: 14.033

Doc: CO-008/60

Pages 4-223 and 4-224, Figure What chemical and radiologicexposures are "non-involved workers" subject to? What steps are beingtaken to prepare these workers for unexpected health effects?


Daily routine emissions are reported in volume I, section 4.14.2 forradiological emissions and volume I, section for hazardous chemicalemissions. Radiological exposures to "non-involved" workers arediscussed in volume I, section 4.14.2; chemical exposures to "non-involved"workers are discussed in volume I, section Radiological doses duringnormal operations associated with future Pantex Plant activities would be wellbelow regulatory standards established by the Nuclear Regulatory Commission andEPA and, as such, no non-stochastic health effects are expected. Hazardouschemical exposures during normal operations will be maintained below regulatorystandards developed to prevent non-stochastic health effects.

RC: 14.034

Doc: CO-008/61

Pages 4-223 and 4-224, Figure The document only analyzesaccidents. Please include routine emissions from normal operations.


See response to comment 14.026.

RC: 14.035

Doc: CO-008/63

Page 4-237 - 239. The combined cumulative impacts resulting from adding thebounding alternative in the other three documents to the Pantex EIS do not fullyaddress all health effects. Give the complete combined cumulative health impactsof all four documents. [This comment applies to all analyses.]


Combining the bounding alternatives would be useful only if the boundingalternative is chosen from all four documents. However, since it is likely thatone or more of these documents would choose alternatives other than the boundingalternative, this format allows the readers and decision-makers the opportunityto combine these impacts appropriately.

RC: 14.036

Doc: CO-008/64

Page 4-239, Paragraph 6. Please provide a schedule for additionalevaluations mentioned in this paragraph.


Pantex Plant operations are continually evaluated by numerous internaland external regulators both DOE and other federal agencies such as the DefenseNuclear Facilities Safety Board. Results from these evaluations are tracked inan issues management system which ensures the findings are incorporated in thework practices of Pantex Plant. Additionally safety analysis reports arereviewed on an annual basis.

RC: 14.037

Doc: HT13/39

Could you talk some about the scope of what the high explosive researchprogram is and what the fatality rate has been over the last decade for workerswho are messing around with high explosives?


Pantex Plant performs high explosive (HE) synthesis, formulation,machining, extrusion, testing, process development, and analytical operations inperforming its HE research and development and production missions. The PantexEIS Proposed Action includes the continued research and production of HE andweapons components.

On March 30, 1977, two high-order detonations of different types of HEoccurred at Pantex Plant. The explosions occurred in Zone 11, Building 11-14A,Bay 8. This resulted in two immediate fatalities and ultimate fatal injuries toa third employee. At the time of the accident, Zone 11 was the plants highexplosive development area. High explosives activities in this area includedremotely operated pressing, contact machining (meaning the operator was verynear the work being done and was not protected in the event of an explosion),and certain support functions for high explosive operations. Contact machiningwith personnel present is no longer permitted at Pantex Plant.

RC: 14.038

Doc: HT13/40

So is the Pantex Plant going to be planning to experiment with new types ofhigh explosives as we look ahead in the coming years that the site-wide issupposed to cover?


See response to comment 14.037.

RC: 14.039

Doc: HT13/43

Secondly, related to that, there's been some discussion about a fatalityrelated to the Lawrence Livermore incident. Nan, I [thought] you said thefatality occurred at Pantex. That is not necessarily what I thought I heard Davesay, so I wish that somebody would clarify that with as much information as youfully have so that it is clear to everybody.


See response to comment 14.037.

RC: 14.040

Doc: HT13/44

I would like to clarify for everyone there were three people killed atPantex in 1977. If I remember correctly, two of them inside the building andone of them outside the building [were] killed, so what I would like to ask ishow will a document like this handle a facility at Pantex that is known to bedeficient?

There is a high explosives machining facility at Pantex that has publicaccess and public parking too close to the building, and it does not meet theplant's current standards, so how is something like that addressed in a documentlike this?


The facility referenced does not have public access and does not havepublic parking. Recently plant personnel determined that a small portion of thenearest parking lot is slightly closer than current regulations allow. Thosesafety regulations establish "buffer zones" that are intended to keepnoninvolved workers and the public far enough away from a high explosivesfacility that they would be expected to survive an accident. In the case cited,the only vehicles that are allowed to park in that area are Government vehiclesdriven by personnel with official business in the facility. This did not causethe facility itself to be deficient. Rather, it meant that the plant needed totake corrective action to satisfy regulatory requirements. Following thediscovery, the plant personnel filed an "Occurrence Report". Inaccordance with the DOE policy on openness, this report was discussed at thenext meeting of the Pantex Plant Citizens Advisory Board. Subsequently, theplant resolved the issue by removing that portion of the parking lot that waswithin the buffer zone.

Scenario #2 analyzes accidents involving accidental HE detonation. Because of facility design and buffer zones associated with HE facilities,impacts to non-involved workers are not expected.

RC: 14.041

Doc: HT13/45

  • .. You have a facility at Pantex that is a high explosives facility thatthe public can get too close to the building, and this is something that wasbrought before the Pantex Citizen Advisory Board a couple of months ago.
  • .. There is a parking lot too close to the building so that people who areoutside the building could be injured by an accidental explosion; that is otherworkers at the plant that may not be working in the facility, but they can benear that facility because the buffer zone is not appropriate.

How does a document like this handle a deficient facility?...


See response to comments 14.040 and 14.043.

RC: 14.042

Doc: HT13/46

In theory, I want to understand how a site-wide EIS addresses a facilitythat is not [adequate]. Do you just do this generally? Also, when you findsomething specific, do you discuss it in this document in general, or do youturn it into a generalized accident scenario rather than addressing specifics?


See response to comments 14.040 and 14.043.

RC: 14.043

Doc: HT13/47

Let me express a concern that I think is related to this, and that is why --let's keep on this point, because I don't think Nan is quite understanding thepoint, which is on the high explosives facility and the parking and also relatedto the gaps in the doors of the Zone 12 assembly/disassembly bays, there wasanalysis done related to this document.

However, I believe, and I would be delighted if anybody here can point me toit, I believe that neither of those specifics, the lack of buffer zone aroundhigh explosives and the specifics of the gaps and the mitigation efforts thathave been taken, neither of those things, in fact, are included in thisdocument.

[Ms. Bergman: The doors are.]

The discussion of the doors and gaps that were found and what was done is inthis document? Where?


During preparation of the Draft EIS, Pantex Plant personnel discoveredthat particular assembly/disassembly cells had larger gaps between the edges ofpersonnel and/or equipment doors and their frames than had been analyzed inprior studies. The cumulative gaps around the personnel and equipment doors ofindividual cells varied, but the worst case resulted in a total gap area greaterthan the 42 square inches that had been analyzed in previous Safety AnalysisReports. Since the gap area affects the amount of radioactive material that canbe forced out of a cell by the air pressure of an explosive accident, plantpersonnel immediately reported the variance and initiated an Unreviewed SafetyQuestion. To resolve the issue, the plant immediately implemented measures toreduce the amount of high explosives and plutonium allowed in the cell and thenmodified the doors to close the total gap area of each cell to less than 42square inches. Additional modifications have been designed to further close thegap area of each cell to less than 5 square inches. These modifications havebeen approved and funded for implementation in Fiscal Year 1997. This Final EISincludes health risk analyses of cell accidents that portray the present designbasis gap area (42 square inches) and the future gap area (5 square inches). See response to comment 14.040 for discussion of the buffer zone around the highexplosives facility.

RC: 14.044

Doc: HT13/48

Where in this document does it specifically say that you have, in anexisting high explosive facility, a parking lot that is closer to the buildingthan what current DOE requirements are, and secondly, where in this documentdoes it say that there were gaps around doors in virtually all of the majorassembly/disassembly bays at Pantex that were there for up to 13 years? Whereare those two statements in this document?


The buffer zone is not discussed. The problem identified has beencorrected and does not change the impacts in the EIS. The door gaps arediscussed as part of volume I, section 4.14, Scenario 1. See responses tocomments 14.040 and 14.043.

RC: 14.045

Doc: HT13/49

What computer model did you use to assess the risk associated withtransporting the pits from Pantex to Manzano?...


The ADROIT code was used to assess the risk associated with transportingthe pits from Pantex Plant to Manzano; specifically, it is used to modeltransportation carried out in Safe Secure Tractor Trailers (SSTs).

RC: 14.046

Doc: HT13/53

Perhaps I have missed it in Volumes 1 or 2 for the discussion of the tritiumrisk [for] current and proposed activities in Pantex. I understand duringdisassembly, they have to take the tritium bottles off of the weapons, andsometimes there may be trouble with the valves being open that should be closed.

I didn't see any discussion in here of the number of times that a base hadto be shut down because of tritium release setting off the monitors, and Ididn't see any analysis of what the health risk was from the tritium exposuresthat happened during dismantlement in the current report.

I didn't see any more generalized analysis of an accident that [allows]tritium to go into a water form and escape from the building. Did I miss itsomewhere, or is it not in here?

I didn't say "go off consistently," but I have heard there's beena number of incidents [where] tritium has escaped from a weapon that was underdismantlement.

I didn't see any accounting of the numbers of tritium releases that havehappened inside.

How many times has there been tritium released during dismantlement to thispoint in time?

In your bounding scenario that you have got, you are ballparking how manytimes that will happen as we move ahead into the future?

Do you expect there to be a subsequent tritium accident where there istritium released?

Is it the usual 1 x 10-4 when you have already had an accident that was 1 x1?

What I am suggesting in my comment is really the failure to reportaccurately on the accidents that have already occurred at Pantex.

The failure to really have a full discussion of the accidents that havealready occurred makes the public reader of these documents be somewhatskeptical about the extremely low estimates about accidents happening andextremely low estimates of health effects from the accidents that come about.

A more full discussion of the accidents that have already occurred, I think,would have contributed to a much greater sense of public credibility and thatwhich I think you will be encountering through the rest of this process.


Tritium is a potential health hazard for personnel engaged in weaponassembly or disassembly procedures. During these procedures, the hazard ofbodily tritium uptake by plant workers potentially exists due to potentialcontamination of weapon components by trace leakage of tritium gas from storagereservoirs in certain weapons. Valves on tritium reservoirs are closed duringdismantlement. Workers involved in these operations are monitored for tritiumuptake. The tritium bioassay program is in place to track tritium uptake byweapons workers. The bioassay program is also used to track the extent of anytritium releases. In 1993, the total tritium population dose was 0.183person-rem with a maximum individual dose of 14 mrem. In 1994, the totaltritium population dose was 0.115 person-rem with a maximum individual dose of11 mrem.

Facilities where tritium operations are conducted are equipped withRadiation Alarm Monitoring Systems (RAMS) that provide prompt warning to plantpersonnel so that they can effect emergency procedures and minimize possibleradiation exposures from the release of radioactive material. At times, a RAMSalarms because of system equipment failures not related to tritium releases;nevertheless, plant procedures dictate a facility evacuation anytime a RAMS isactivated. Occurrence reports for inadvertent tritium alarm actuations areavailable in the public reading rooms in Amarillo and Panhandle. These alarmactuations do not involve tritium releases.

There is also a hazard from potential accidents involving tritium. Volume I, section 4.14, describes two risk significant accidents involvingtritium: Scenario 5, Tritium Reservoir Failure from Internal Event, and Scenario7, Multiple Tritium Reservoir Failure from External Event/Natural Phenomena.Scenario 5 involves the release of tritium as a gas and Scenario 7 involves therelease of tritium as water vapor. Scenario 5 has occurred once in the past(reservoir discharge within Cell 1 in 1989); this event, with other pastaccidents, are described in detail in section 6.4 of the Pantex Plant SafetyInformation Document (Pantex 1996a). The impacts of this accident are describedin section 4.7, Air Quality. The frequency of tritium releases at Pantex Plantis defined as "anticipated" and is estimated based on historicalexperience at approximately 2 x 10-2 releases per year at a 2,000 operationallevel. Mathematically, this frequency indicates a tritium release related toScenario 5 every 100,000 operations. Even though this event is defined asanticipated does not guarantee its occurrence in the future. With adherence toprocedures and proper training, Pantex Plant personnel work to minimize thelikelihood of the reoccurrence of the Cell 1 tritium accident.

RC: 14.047

Doc: HT13/55

In your accident analysis, you have a puncture, so that is a puncture of onepit container, right?

Did you ever consider the possibility that there could be more than one?


Volume I, section, Scenario 6 examines the risk from plutoniumrelease due to a forklift impact during pit handling. The physicalconfiguration of pit containers precludes the possibility of puncture of morethan one by a single forklift. The frequency of the event, however, accountsfor all operations and thus considers all forklift activities.

RC: 14.048

Doc: HT13/56

What is the fire tolerance?


See discussion on Intrasite Transportation in section 1.3.8 of thisvolume regarding pit pyrophoricity.

RC: 14.049

Doc: HT13/58

We don't have any records about how these pits are going to hold up in thecoming decade, so we need to invest multiple billions of dollars in doingresearch to see if problems could develop in these pits sometime in the next 10,20, 30, 50 years. There is a lot of discussion about multiple billions ofdollars going into trying to answer those questions.


See discussion on Intrasite Transportation in section 1.3.8 of thisvolume regarding the DOE pit surveillance program.

RC: 14.050

Doc: HT13/59

Currently, how many of those pits in storage are actually under surveillanceor actually looked at visually each year of the 12,000 whatever it is pits instorage in Pantex? How many of them are actually taken out and looked at eachyear? Could you give us a ballpark idea?


Historically, pits have had few problems. With 20,000 pits in storage,approximately 20 pits per year will be inspected. These pits will be fromdifferent weapons programs. Approximately 22 AT400A containers will be testedyearly. Based on historically low problems with pits, DOE believes thissurveillance program will minimize the likelihood of undetected failures.

RC: 14.051

Doc: HT13/60

What is the length of time that the current containers have been studied tosee how effective their seal has been?

So what is the track record?

The reason why I ask is the similarity between the stockpile stewardshipconcern about what is going to happen to plutonium in the aging pit inside avery carefully sealed weapon where there's been decades of study of humidity,moisture, air pressure, materials compatibility...

With all this study, they are still investing multiple billions of dollars,because if you get a leak inside your pit, inside your container, inside yourweapon, if there is even a pinprick air hole, you can get moisture introducedinside a weapon, and the moisture can cause all sorts of problems, and oxygen,as we know, with these materials can cause all sorts of problems, but somehow,those same sorts of problems could happen with the pit in storage, could it not,if the seal on the containers is broken?

I may be wrong about this, but apart from the risk of a criticalityaccident, a nuclear explosion, aren't there also risks from the plutonium meldgetting oxidized, and isn't the oxidized metal more mobile than the metal itselfin the shape and the form of the pit? Isn't there a flammability risk for theplutonium metal as well? I [thought] I understood there were those two potentialrisks.


See discussion on Intrasite Transportation in section 1.3.8 of thisvolume regarding pit pyrophoricity.

RC: 14.052

Doc: HT13/61

Are you saying there is no flammability risk for the pits that are instorage in the current containers?... So are you saying it is pyrophoric,meaning that it ignites on contact with air?


Plutonium in pit form is not pyrophoric. See discussion on IntrasiteTransportation in section 1.3.8 of this volume.

RC: 14.053

Doc: HT13/62

So if your container developed, for example, a pinprick. If the seal on thepit developed a pinprick hole or rusting crack, then the plutonium metal becameoxidized from the contact with the oxygen which it wasn't supposed to have, andyou had some plutonium in an oxide form inside the plutonium metal pit, and ifit was exposed to air, are you saying there is no flammability risk and nodispersal risk?


All pits are hermetically sealed within a metal clad. DOE hasconsidered the potential for pit leakage during storage and has designed both acontainer and a surveillance program to minimize the likelihood of oxygenintroduction into a pit. The AT400A will provide a container within acontainer, the inner container having an inert atmosphere as defense-in-depthmeasures in addition to the pit clad. Scenario 6 examines the risk fromplutonium release due to a forklift impact during pit handling. The amount ofmaterial released in this event bounds any material released from a pinprickhole. Because the plutonium pit is made of plutonium metal, most of theplutonium remains in the storage container during a forklift accident. Lessthan 0.6 milligrams of plutonium oxide dust would be released from the storagecontainer.

The possibility of intentional damage to pits within Zone 4 is minimizedby an active personnel assurance program and a high level of security. DOEbelieves the policy, procedures, and security in place at Pantex Plant precludethe occurrence of the scenarios described by the commentor.

RC: 14.054

Doc: HT13/63

If you drilled a hole, for example, through your container, then you drilleda hole through a pit, and you left it sitting out in the sun for a couple ofdecades, there wouldn't be any problems whatsoever with any health or safety orenvironmental problems with the these stored pits? Is this what you are saying?


DOE believes the policy, procedures, and security in place at PantexPlant preclude the occurrence of the scenario described by the commentor.

RC: 14.055

Doc: HT13/64

What is the difference between a drilled hole and a pinprick hole in termsof introduction of oxygen into a part of the nuclear weapon pit that wasn'tdesigned to have contact with oxygen?...


All pits are hermetically sealed within a metal clad. DOE hasconsidered this scenario and has designed both a container and a surveillanceprogram to minimize the likelihood of oxygen introduction into a pit. TheAT-400A will provide a container within a container, the inner container havingan inert atmosphere as defense-in-depth measures in addition to the pit clad.

RC: 14.056

Doc: HT13/65

Isn't it true that the container in which the pit is placed is multilayered,there is metal, [there] is styrofoam, and there is stainless steel? We are nottalking about going through the external wall of the pit container, and then youhave got the pit right there.


Design features of both ALR8 and AT400A are provided in volume II,appendix F.

RC: 14.057

Doc: HT13/66

What if you puncture a pit, what happens then? How much of the pit woulddisperse? How would it actually get dispersed from a puncture? Would these bemetal particles or oxidized?


Because the plutonium pit is made of plutonium metal, most of theplutonium remains in the storage container during a forklift accident. Lessthan 0.6 milligrams of plutonium oxide dust would be released from the storagecontainer. The only pathway for release of this plutonium dust is through theopening caused by the forklift.

RC: 14.058

Doc: HT13/67

Over what length of time would that oxidation process and dispersal processhappen if you have had a puncture through a pit?

... How would the dispersal occur? Would the process of oxidation actuallysuspend some of these particles into air spontaneously without it having toreceive further kinetic energy?


See discussion on Intrasite Transportation in section 1.3.8 of thisvolume regarding pit pyrophoricity.

RC: 14.059

Doc: HT13/68

So if you, somebody, opened up 100 pits and poked holes in all of them. This kind of scenario like an internal sabotage scenario, somebody was reallymad at the DOE for getting laid off from their job after serving their nationfor 25 years in a job where they get picked on by the public all the time, andthey went in and they opened 50 of these containers and poked holes in pits andwalked out, what would the general scope of plutonium dispersal impacts be? DidI miss it somehow?

[What if this happened when] wind is blowing 50 miles per an hour?

But you have all the security around Pantex and the Kirtland base, and youdon't consider that.


DOE believes that the high level of security and personnel assuranceprogram at Pantex Plant will preclude the occurrence of the internal sabotagescenario described by the commentor.

RC: 14.060

Doc: HT13/72

Page 5-61 of the draft statement says that each of the bunkers at Manzanohas the capacity to store up to 800 pit containers in a Stage Rightconfiguration in you slide show. Has there been a Safety Analysis Report done onstoring...up to 800 pits in those bunkers?


Safety analyses have been done for similar structures at Pantex Plant. These facilities have capacities of hundreds to thousands of pits. The Manzanobunkers being considered for use provide similar or better capabilities forstorage than those previously analyzed at Pantex Plant. In any case, before DOEelected to move pits to Manzano, a full site-specific safety analysis report(SAR) would be developed for the proposed Manzano facilities.

RC: 14.061

Doc: HT13/73

Has the safety analysis report for storing pits in zone 4 at Pantex beenupdated since...the 1993 safety analysis report that was done at the time of theEA for interim pit storage at Pantex?


The Zone 4 safety analysis is being updated but is not complete.

RC: 14.062

Doc: HT13/75

Back to the ALR8 which is currently being used at Pantex, that has an oxygenatmosphere, and it is not a neutral atmosphere, it is not a sealed container, amI right?

You haven't put a special neutral helium in there, and you are notpreventing oxygen from getting in there. It is just air, right?

... So what I would like to know is how this document accounts for not justas accident like if a forklift threw something, but a pit that has a minor flawthat you all had checked for but overlooked so that over time, years of storage,you once again have this, perhaps, pinprick sort of thing going on in acontainer where oxygen is present, so you have your plutonium to oxidize overtime and perhaps surprise some worker when they open that canister at some laterdate.

How does this document evaluate that kind of scenario?


The AL-R8 pit container does not have a sealed inner container with aninert atmosphere. Additional details for the ALR8 container can be found involume II, appendix F. The pit itself is hermetically sealed so oxygen does nothave a route to the plutonium. Pits have been monitored over time and from astorage perspective no problems have occurred. DOE has considered this scenarioand has designed both a container and a surveillance program to minimize thelikelihood of oxygen introduction into a pit.

RC: 14.063

Doc: HT13/76

Do you stand by your earlier comment that about ten pits per year are allthat are examined out of the almost 8,000?

That is the number that I think are destructively tested.


Historically, pits have had few problems. With 20,000 pits in storage,approximately 20 pits per year will be inspected. These pits will be fromdifferent weapons programs. Approximately 22 AT400A containers will be testedyearly. Based on historically low problems with pits, DOE believes thissurveillance program will minimize the likelihood of undetected failures.

RC: 14.064

Doc: HT13/78

Where are the impacts, including radiation exposures, from that transfer tobe discussed in the Pantex Draft EIS?

Just to clarify that you are getting information to use in the final, sothere will be this further information you are talking about will be availablebefore the final? I am trying to figure out essentially where it fits in.

Let me say what I understood you to say so you can correct me if I misheard.You are saying that any worker exposures, radiation exposures to workers, forthis transfer from the ALR[8] to the AT400 is covered in the overall workerexposure analysis of operations in this document?

Is the operation is that operation, in terms of where it happens at Pantex,in terms of what facilities, et cetera, is that discussed in the document, andif so, where?

Is there a safety analysis report or other document that describes thistransfer process?

I am asking you now to tell me which specific document that you are talkingabout.

Again, just so we are speaking the same language, those three documents thatI heard you talk about are what I call the three background documents.

I dont recall, and if there are people here that know these documents betterthan I, that is why I am asking, I dont recall in any of those three backgroundinformation documents that this transfer procedure is, in fact, described. Ifit is, I would like somebody who knows that to tell me, because I missed it, andId like to read it.


At the time the Draft EIS was written, doses from the pit repackagingoperations were estimated to be within the current cumulative doses forproduction workers. Since, the Draft EIS was published the design of the pitrepackaging facility has been changed and is under development. Because ofthese changes, there is likely to be additional cumulative exposure to workersat Pantex Plant. Additional exposures due to the pit repackaging operation aredescribed in volume I, section 4.14.

RC: 14.065

Doc: HT13/86

I want to go back to an issue that was brought up earlier about theaccidents at Pantex and about supposedly deficient facilities at Pantex. I thinkit should be noted that [the high explosives] accident occurred nearly 20 yearsago....

The practices have changed since that time. The facilities at Pantex forhigh explosives are extremely modern. They are the only facilities in the DOEcomplex that can perform this mission today without any modification. Theparking lot problem is being addressed by management at the plant. It wasbrought up to the P[P]CAB in order to let them know that they are addressingthat.

The door gap issue has been widely discussed in P[P]CAB meetings and in thecommunity in Amarillo. I think that's been mischaracterized in the meetingtonight. I think that is being addressed by management at the plant.

I guess my comment would be both those issues have been raised in recentmonths concurrently with the production of this EIS, but near the end of theprocess at the time the draft was issued, I think it is unrealistic to expectvery contemporary events that occurred near the end of the process to beaddressed in this when they are really day-to-day management things that arebeing handled by plant management, and they are being done in concert with theP[P]CAB.

I will further comment that Pantex has an outstanding safety program. Pantexis used as a resource by employers in the Amarillo region for traininginformation, for how to institute a safety program, and there is an extremeconfidence in the safety and reliability of not only the weapons but theemployers who handle those weapons at the plant.


See responses to comments 14.040 and 14.043. The two cases cited werethe parking lot of the high explosives facility and the gap areas around thedoors of assembly/disassembly cells. It is correctly noted that the problemswere discovered by plant personnel, immediately reported to plant management,and promptly solved by plant action without accident or injury. These aresuccess stories of how the safety program is designed to preclude accident andinjury. The discussion of the door gaps is located in volume I, section 4.14,Scenario 1.

The Pantex Plant Cells are currently being operated within the safetybasis defined in a Justification for Continued Operation (JCO). This JCOestablishes administrative controls to minimize the consequences of a potentialaccident until the end objective of reducing the door gap area to 5 squareinches is reached.

RC: 14.066

Doc: HT13/89

I have a request that is kind of similar to and follows along with actuallyboth of the last two comments which related to this document, and that is thatnot only the history of safety practices at Pantex, but the history of safetypractices at each of the alternative sites...included, because while it is notnecessarily always specifically factored into your risk analysis that you do inthese documents, from a public standpoint, the public is interested inevaluating the safety performance of facilities in terms of handling hazardousand radioactive materials.

There are lots of differing perceptions on the part of the public as towhich facilities are safe and which facilities are dirty. The most helpful andobjective way of having some analysis of that is actually having somecomparative analysis of the historic practices at those various facilities sothat it can be identified whether certain facilities may have a "better"or "worse" safety record.

It is not up to me or anybody else to say, "We suppose this," or, "Wesuppose that." There is some actual data that is released in unclassifiedform so that it could be available to the public, and so I would request thatkind of information be done on all of the sites and included either in thedocument or a reference document that cites that.


The type of historic comparisons suggested cannot be realistically andmeaningfully presented. The Department and its plant operators have extensiveprograms to identify and analyze potential accidents in order to developtechniques that both minimize the possibility of occurrence and mitigate theconsequences should an accident occur. In like manner, when an accident doesoccur, root cause analyses are performed and changes are made to preventrecurrence. Because of these ongoing programs of safety analyses, facilitiesand procedures are continually improved. This means that the set of proceduresand facility conditions present at any given time are likely very different fromother times in history. Thus, a historical review of past accidents as anestimate of current safety is inherently flawed. This can be illustrated by thecase of the explosive accident that occurred in 1977. This is the onlyexplosive accident in the history of the plant that resulted in fatalities. Theprocedure that resulted in the accident was an operation in which a worker useda lathe to shape an experimental high explosive. The operator was killed in theresultant explosion, as were two other nearby personnel. Following thataccident, the procedure and equipment were both redesigned to eliminate thecause of the accident. The procedure is now performed by a computer controlledrobot to regulate pressure and under water to control the temperature of theprocess. The operator is no longer in the room when the process occurs. Thus,one cannot evaluate the safety of the current facility and its operations by thecircumstances that were present in the past. Instead, safety analyses areperformed by detailed examination of each step of the processthe physical andchemical characteristics of the materials and equipment used and the actionsperformed by humans and machines during the process. For each step of theoperation, every event that could initiate an accident is systematicallyidentified and the results of that occurrence are characterized. Motion andtime studies, measurements, and historical data are used to assist in estimatinghow frequently an abnormal event (e.g., dropping a wrench) is likely to occurand what could occur as a result of that event. From this analysis, acalculation can be made to estimate the frequency of an accident. Thencalculations are made to quantify the results of such an accident. This processresults in the most scientifically defensible prediction of the risk of anaccident under the actual circumstances present at the time.

RC: 14.067

Doc: HT13/18

Also, I wish the documents in the future would at least admit that we exist.Kirtland, in 1989, when they started the fire by accident, which was anaccident, said that South 14 could be the fire break. ...At that time, therewere 500 homes. Now, there are probably 750 to 1,000 families who live directlyeast of this facility. We would like some recognition of our concerns as well asthe Four Hills residents.


Range fires do occur during dry seasons in New Mexico. However, thenature of the alternative to relocate interim storage of pits to the ManzanoWeapons Storage Area at Kirtland Air Force Base would result in no fire hazard. The relocated pits would be sealed in stainless steel, welded shut, Type Bcontainers (e.g., the AT-400A) and placed in a magazine tunneled into thegranite of Manzano Mountain. The entrance to the tunnel and the interiorstorage magazine would be protected by heavy steel doors. There would be nohigh explosives or any other combustible material present inside the storagefacility. Consequently, there is nothing in the storage facility which could bea fuel to either start or sustain a fire. Likewise, the pit would be shieldedfrom any externally initiated range fire by the steel doors, the granite of themountain, and its own protective stainless steel container. It would not bepossible to either expose or burn the pit in any credible fire scenario. Thus,while a range fire might occur in the Kirtland area, the pits in the storagefacility would not be affected or contribute in any way to the consequences ofsuch a fire.

RC: 14.068

Doc: HT13/30

We have created some problems, quote, inadvertent problems, that we dare notcreate. The dangers associated with these plutonium pits in or out of warheadsare going to last for a long time, and it is unfortunate that we didn't have abroader public discussion about all of these issues before a decision was madeto even create the 20,000 plus warheads and what these unintended consequenceswould be.

I certainly hope as we talk about interim storage of pits, which frankly,for better or worse, is going to be a lot longer than ten years, and thisdocument should more clearly state that kind of along the lines, Nan, that you,in fact, said in answer to Janna's question, but I don't really see that kind ofcomment reflected in here, so that is the kind of change that needs to be madein this document.


It is DOEs policy to evaluate site-wide NEPA documents at least every 5years to determine whether the existing EIS remains adequate and whether toprepare a new site-wide EIS or supplement the existing EIS (10 CFR 1021.330).

RC: 14.069

Doc: HT12/6

Yes. According to your summary report there was a calculation of potentialrisks of -- the citizens of Savannah are within the range of the site forgetting cancer over a estimated of 50 years. Was there -- did you-all calculatethe -- not only the potential release of radiation coming from the SavannahRiver Site, but did you-all calculate the other plants that's releasing othertypes of chemicals and other types of radiation or other forms of radiation incombined with that which is coming from the Savannah River Site?

Because if you haven't and you only estimated the potential risk of cancercoming from the Savannah River Site, then there may be a greater risk oflow-income people getting the repercussion [effects] of what we economically aretrying to benefit from the Savannah River Site.

(Video) Gen. Milley & Austin Reveal Their Plans for the US Defense Budget!


The scope of the Pantex EIS includes evaluating the impacts of storingeither 8,000 or 20,000 pits at the P-Reactor at the Savannah River Site (SRS). The EIS concluded that no adverse health effects would be expected among thegeneral public, including minority and low-income populations, as a result ofnormal storage operations. Evaluating the impacts from other operations in thevicinity of SRS is beyond the scope of this EIS.

RC: 14.070

Doc: HT12/7

... Well, in my opinion, that is not fair to the citizens of Savannahbecause now you're only projecting what Savannah River Site. This is supposedto be a total...assessment of what's going to -- a health assessment, what'sgoing to take place.

So not only should it be calculated, the radiation that's going to bereleased from the Savannah River Site,...the total impact because say, forinstance, we may have a better chance if the Savannah River Site was closeddown, you know, instead of adding what radiation or what contamination would bereleased from the Savannah River Site, we may have a better chance of having alonger life span if we would close the plant down. So if there was a totalcalculation along with all the other plants along with Savannah River Site, thenI think there would need to be more input in the study as far as health...isconcerned....


See response to comment 14.069.

RC: 14.071

Doc: HT12/8

My concern is birth defects toward our children.... I've read in the pasthow different radiations...affect births, pregnancies of mothers, and I wouldlike to know the same situation in this area.


Radiological impacts to the public (including children) from Pantexoperations are discussed in volume I, section 4.14. Modeling has shown thatpotential doses to adults and children alike will be extremely small and asdefined by the National Council on Radiation Protection and Measurements, theyare negligible.

RC: 14.072

Doc: HT12/16

I assume that's gamma. The worker at what distance for that 6 rem?


The 6-rem worker dose from a forklift puncture is primarily alpharadiation due to the inhalation of plutonium dust. This 6-rem exposure is a50-year dose.

RC: 14.073

Doc: HT12/21

You have done SARs on those facilities?


The Zone 4 magazines have an approved Safety Analysis Report. The SARis currently being updated to the latest DOE Standard.

RC: 14.074

Doc: HT12/22

[Are you] familiar with plutonium vulnerability assessment done in Novemberof 94? It says that operations of storage activities are continuing with a -- onthe basis of a BIO instead of approved safety analysis reports.


The DOE Plutonium ES&H Vulnerability Assessment (DOE 1994cc) wasperformed to characterize ES&H vulnerabilities. An ES&H vulnerability isdefined as a condition or weakness that may lead to unnecessary or increasedradiation exposure of the workers, release of radioactive materials to theenvironment, or radiation exposure to the public. The study of Pantex Plant,completed in July 1994, identified four potential vulnerabilities: (1)explosion in an assembly cell dispersing plutonium outside of the cell/facility;(2) operational accident, human error, or equipment failure causing failure ofthe pit cladding or pit tube; (3) lack of experience concerning design and lackof knowledge of interim storage and aging of pits and RTGs; and (4) collapse ofroof over Bay 27, Building 12-26 due to natural phenomena. The report statedthat all handling of disassembled nuclear explosive components and sourcescontaining plutonium at Pantex Plant are performed by trained and qualifiedindividuals in accordance with operating procedures. Likewise, the reportconcluded that facilities containing the disassembled nuclear explosivecomponents and sources are designed to withstand adverse conditions with minimaldamage or release of plutonium. While the responses to these vulnerabilitiesare being addressed in other documents, this EIS discusses the relevant issuesthrough accident scenarios. The risk from vulnerability 1 is addressed involume I, section 4.14, accident Scenario 1. The risk from vulnerabilities 2and 3 are addressed in volume I, section 4.14, accident Scenario 6. The finalvulnerability is included as part of volume I, section 4.14, Scenario 3. Itshould be noted that the particular facility cited as vulnerable to naturalphenomena (Bay 27, Building 12-26) is scheduled to be phased out this fiscalyear. The operations performed in that building will be relocated to Building12-104A after completion of an Operational Readiness Review. In view of thenature of the vulnerabilities identified, the actions taken by the plant, andthe risk analyses of those vulnerabilities in Pantex Plant Safety AnalysisReports and in this EIS, there is sufficient information on potentialenvironmental impacts (including human health impacts) for the Secretary toproceed with a Record of Decision on storage of 20,000 pits.

RC: 14.075

Doc: HT12/25

I think that also the other vulnerability noted for Pantex was that...Pantexis the only site, the only major plutonium site, that is identified as having asingle barrier for plutonium....


All pits are hermetically sealed within a metal clad. The AL-R8container is sealed but does not have an inert atmosphere surrounding the pit.The AT-400A will provide a container within a container, the inner containerhaving an inert atmosphere as defense-in-depth measures in addition to the pitclad. Further information on pit container design is provided in volume II,appendix F.

RC: 14.076

Doc: HT12/29

... On page 5-33, you're talking about the worker at Savannah River healthconsequence and what you show...[as 4 x 10-3 to] the maximum exposedindividuals. But you say the probability of a cancer from all causes to thegeneral public is estimated to be twenty percent which implies that six of thethirty workers are going to develop cancer. Now, that doesn't sound like aninsignificant consequence to me. That sounds like a significant consequence.

That's from natural causes. Let me comment that the paragraph is unclear.That's what I'm saying, okay. The paragraph is unclear. I know what it means-- what it should mean.


The text refers to the number of cancer deaths from all causes in theUnited States. Twenty percent of all deaths in the United States areattributable to cancer from all causes. The text has been changed to clarifythe statement.

RC: 14.077

Doc: HT12/33

Work chart is totally confusing to me. And how a dose rate of one rem peryear at one meter at the surface of the trailer, why does that affect the humandose based on geography?


The dose identified refers to the expected dose rate outside of a SafeSecure Tractor Trailer carrying pits. It is used to estimate population dosesalong pit shipment routes.

RC: 14.078

Doc: HT12/34

... What's the natural radiation dose?


Background radiation doses for the Savannah River Site are provided involume I, section 5.3.2.

RC: 14.079

Doc: HT12/35

Now, I submit Pantex has a much higher background radiation than SavannahRiver. Now, you do not say we ought to move it to Savannah River in orderto...decrease the number of people at Pantex, did you? Get the people out ofthat god-awful place.


The average dose from natural background radiation to an individual inthe vicinity of Pantex Plant is 334 mrem/yr. The average dose from naturalbackground radiation to an individual in the vicinity of the Savannah River Siteis 312 mrem/yr.

RC: 14.080

Doc: CO-003/3

Any permit or plan approval for new Hanford programs/activities must befully integrated and must comply with all State of Washington public health andsafety rules and regulations.


Transition planning is described in volume I, section 5.1. Existinglaws, regulations, formal agreements, and DOE orders will form the basis fortransition planning and execution.

RC: 14.081

Doc: PC-011/2

None of the draft PEIS's have adequately addressed what would happen to thisarea's farm and ranch economy if a significant accident releasing substantialquantities of radionuclides were to occur regardless of how well it were to becleaned up. I think the public's perception of the contamination would be suchthat it would make our products unmerchantable not just for the immediatelyaffected area, but for the entire Panhandle's products.


Perceived risks are not easily quantified. The socioeconomic impacts ofsuch perceived risks are even more difficult to evaluate. However, a statementcharacterizing this potential has been added to the appropriate sections of theFinal EIS.

RC: 14.082

Doc: PC-006/2

Storage of pits at Pantex should not be [increased] until the findings ofthe [Plutonium] Vulnerability Assessment are resolved.


See response to comment 14.074.

RC: 14.083

Doc: PC-034/5

In Section (page 4-219) and in Figure (page 2-224), aquite classic error is made in explaining potential latent cancer fatalities.The error is to use risk estimates for exposures to large populations and toassume that applying that risk estimate to a specific group of workers allowsfor definitive conclusions about that group. In this example, the figureprovides the correct explanation. The text is misleading and might causeconfusion in the community by indicating that the 330 plant workers would suffera certain number of cancers.


Further clarification of the interpretation of the calculated risks hasbeen provided in section 1.3.10 of this volume.

RC: 14.084

Doc: PC-034/6

Health effects are important to understand. The section on continuedoperations talks about health effects for workers. A statement is made thatworkers would experience additional cancers.

In the figure, a different explanation is used. The statement in the figureis that an average number of cancers could occur if many groups of workers wereexposed. The final statement was that the most likely outcome is zero cancers.

What is the average community member to think?

What is the correct explanation?


Further clarification of the interpretation of the calculated risks isprovided in section 1.3.10 of this volume.

RC: 14.085

Doc: PC-034/7

The Department of Energy's Office of Emergency Management (NN 60) and theOffice of Emergency Response (DP 23) fund the DOE's Atmospheric Release AdvisoryCapability (ARAC), which is housed at the Lawrence Livermore NationalLaboratory. ARAC's computer models, which have world-wide acceptance, have beencalled into service in many real-time responses to both real and potentialaccidental releases of radioactive material. The Three-Mile Island nuclearpower plant (NPP) accident in 1978, the 1986 Chernobyl NPP disaster in theformer Soviet Union, and the U.S. Air Force Titan II missile accident inDamascus, Arkansas are just a few examples. In addition, the ARAC models havebeen utilized in every nuclear weapons accident exercise (NUWAX), since NUWAX79. Pantex Plant is an "ARAC Site" and is linked to the ARAC centerin Livermore via a computer-to-computer connection. ARAC operators are familiarwith Pantex operations and can respond in a matter of a few minutes with acomputer model graphic output showing the trajectory of the plume ofcontamination in the event of an accident. When, an if, a real accident occurredat Pantex it would be the ARAC models and the ARAC capability that DOE wouldcall upon to respond in real time.

... Since ARAC is funded by NN 60 and DP 23 and ready to respond to aradiological accident at Pantex, why did DOE choose to use a model like ERAD toassess consequences for this EIS?


The Atmospheric Release Advisory Capability (ARAC) is a U.S. governmentemergency assessment program designed to provide timely and credible assessmentadvisories to emergency managers for nuclear, chemical and biological hazardousreleases to the atmosphere. ARAC uses a series of codes and models integratedinto a coherent software system for automated communications, processing andmanagement of both data and calculated assessment products. It uses real timemeteorological data to identify populations at risk and enable mobilization forquick response. ARAC is not currently used for risk assessment purposes in anon-emergency situation to predict dose consequences.

The ERAD code was also funded by DOE to specifically address theradiological impacts associated with an explosive dispersal. ARAC uses aportion of the ERAD code for buoyant heated explosion cloud rise formulation. The ERAD code does have the capability to use climatological data in iterativecomputations to predict dose consequences required in NEPA documents.

RC: 14.086

Doc: PC-034/9

  • .. In Table, safety statistics for Pantex are compared togeneral industry, manufacturing industry and chemical industry (page 4-217).
  • .. Since the largest industry in the Panhandle is agriculture, should notthe agricultural statistics be included here?


The purpose of Table, in volume I, section 4.14.4, is tocompare the safety statistics for Pantex Plant with industries that are similarto the operations performed at Pantex Plant. This is the reason the statisticsare compared to general industry, manufacturing industry, and chemical industryrather than agricultural industry.

RC: 14.087

Doc: PC-034/10

... Appendix D, Human Health, does very little to explain how the impact tohuman health are derived or calculated. This appendix is more of an explanationof the risk assessment methodology than human health.


Volume II, appendix D as well as volume I, section 4.14, Figure4.14.2.1-1 provide detailed descriptions of the methodology followed to estimatehuman health impacts. Appendix D and section 4.14 discuss the estimated humanhealth impacts associated with continued Pantex Plant operations. Bothradiological and chemical impacts are described as well as other worker safetyissues.

The risk assessment methodology presented in volume II, appendix D wasutilized to identify the risk dominant impacts in terms of excess cancerfatalities from continued Pantex Plant operations. The human health appendixprovides references to reports such as the BIER-V report which provides furtherdetails on the human health effects of ionizing radiation (NAP 1990).

RC: 14.088

Doc: PC-024/4

Page S-9, right column, top of third paragraph. I suggest that the releaseof chlorine gas, as the dominant accident scenario, may not be accurate. If thePantex plant was targeted in a terrorist attack, that could prove to be muchworse. Another point, is that the chlorine accident may have been considered fora 10-year period, but the plutonium-239 will remain a hazard for over a quartermillion years.


The paragraph addressed begins with the sentence, "The dominantaccident scenario in terms of release of hazardous chemicals to the publicinvolves a release of 408 kilograms (900 pounds) of chlorine gas from the watertreatment facility." The contention here is that for accidents involvinghazardous chemicals (as opposed to radionuclides or high explosives), chlorineis the risk dominant hazard. Acts of terrorism are outside of the scope of theEIS, and are considered very unlikely due to the high level of security evidentat Pantex Plant.

Other risk contributors are also assessed in the EIS, so the conclusionabout chlorine does not preclude risk contributions from radioactive materialsand high explosives. These risk contributors are summarized in volume I,Summary.

The concern that the chlorine accident may have been considered for a10-year period is unnecessary. The frequency calculations used in the riskassessment are independent of how long a substance remains a hazard, and it isDOEs policy to evaluate site-wide NEPA documents at least every five years todetermine whether the existing EIS remains adequate and whether to prepare a newsite-wide EIS or supplement the existing EIS (10 CFR 1021.330) cited in volumeI.

RC: 14.089

Doc: PC-024/13

Page 5-11, Table, Major Sources of Radiation Exposure in theVicinity of the Nevada Test Site. This table should be removed because itcontains unnecessary information and is highly misleading in other respects. Theterm "Vicinity" can, and is likely to, refer to areas [that] aredozens of miles from the test site, and upwind of the test areas that are at thefar side of the vast test site.

Under the heading "Other Sources," is "NTS - environmentalradioactivity," which is shown to be at least 1,000 times less than anyother source including global "weapons test fallout" [in] which NTSwas one of the primary sources.

This EIS was supposed to conform with all the requirements set forth in the "Agenciesshall insure the professional integrity, including scientific integrity of thediscussions and analysis in environmental impact statements" (40CFR1502.24).


Volume I, section 5.2, Table presents the radiation environmentthat individuals in the areas surrounding Nevada Test Site (NTS) receive onaverage. The term "Vicinity" refers to the areas surrounding NTS andthe members of the public within these areas. These areas include both upwindand downwind areas from the test site.

Nuclear tests in the atmosphere at NTS have been confined to weaponshaving yields below 100 kilotons. All other atmospheric nuclear testing by theU.S. were made at the Eniwetok Proving Grounds in the Pacific Ocean. Thepredominate source of global weapons test fallout is from atmospheric testing ofmegaton-range detonations by the U.S. and the U.S.S.R. during the early 60s. Arelative comparison between the NTS environmental radioactivity and the weaponstest fallout was not made since both are less than 1 mrem and do not contributesignificantly to the radiation environment in the vicinity of NTS.

RC: 14.090

Doc: PC-024/15

Page 5-17, left column, first line. Though such an incident may result "...inno significant short-term radionuclide releases to the exterior environment,"the next quarter million years might tell a different tale. The mitigationanalysis of such an event should not be left to whatever kind of society followsus.


Should P-Tunnel become the preferred alternative for interim pitstorage, DOE would consider performing mitigation analysis for a tunnelcollapse.

RC: 14.091

Doc: HT15/25

Under the description of the risk about plutonium on Page D-5, both[involved] workers...and the public are vulnerable to plutonium inhalation if anaccident occurs that disperses it as respirable particles; for example, a fireor explosion. ...On Page D-23, there in the first column, first paragraph, itsays the long-term exposure pathways and the liquid exposure pathways were notconsidered.

So we want to be sure, not only that you can take into accurate accounttypes of flight and that type of thing. We want to make sure also that theconsequences of [a plutonium] release on a population on-site or off-site areaccurately taken into account. ...Long-term exposure [to plutonium has] to be aconsideration with soil, farming, and water. ...I have certainly not done fulljustice to this document, but I raise these issues.


Details on alternative pathways have been provided in volume I, section4.14.

RC: 14.092

Doc: HT15/34

For transportation of material, the listing of the accident scenarioincluded environmental impacts for transportation [accidents]. In theevaluation of those accidents, it wasn't included in this event tree analysis.


The human health impacts from transportation accidents are described involume I, section 4.16.

RC: 14.093

Doc: HT15/36

... It's really talking about the risk for inhalation of hazardoussubstances, as I understand the document. The risks for ingestion haven't beenincluded in there.

The inhalation cancer risk is above the normal, except for 1.45 x 10-7.


The risks from ingestion of hazardous substances have not been includedbecause the human health risk is dominated from exposures through inhalation.

RC: 14.094

Doc: HT15/37

... What was the assigned risk bin for accidents involving Ogallalaaquifer?


No accidents were identified during the preparation of the Pantex PlantEIS as capable of contaminating the Ogallala aquifer. Risk bins were for humanexposures. The pathway for human exposure form the Ogallala aquifer is not asignificant contributor. Additionally, several studies indicate that plutoniumdisposed from accidents will not reach the aquifer.

RC: 14.095

Doc: HT15/38

... We had trouble, particularly when the Ogallala [aquifer] wasinvolved,...multiplying the risks times the frequency that would happen. ...Inother words, if you're considering 10 to the minus 7 or 8 or 9, that multipliedby the likelihood of the accident occurring...reduces the significance. Theproblem with reducing the Ogallala [aquifer] is [that] it would be such acatastrophic event, that we'd rather not allude to the risk by the possibilityof the accident occurring.


See response to comment 14.094.

RC: 14.096

Doc: HT15/39

... I understand this EIS really evaluates the future activities at Pantexand several standard alternatives. So I think that approach is valid. But itseems that if the hazardous instances were discounted...because...theconstituents' concern were limited, based on that, [were] not seeing above thisparticular level. Their evaluation was not carried forward.

My understanding is that the risk was posed only for inhalation pathways,[not] that that would be only added together.


The commentors understanding of the EIS appears to be correct. However,it is unclear as to whether or not the commentor has a concern with the EIS. Further detail on alternative pathways has been added to volume I, section 4.14.

RC: 14.097

Doc: HT15/40

Model for chlorine?


The chlorine release scenarios were modeled using the EmergencyPrediction Information (EPI) code.

RC: 14.098

Doc: HT15/41

Did you base the probability of the accidents occurring on the data ofaccidents that have occurred in the past?

Would your analysis predict that there has been as many as one fatality inthe plant due to a radiological release?

What would you say the probability is, based on the data that you have, thatthere would be a death from the radiological release at the plant by someoneworking in the plant?

Based on past experience with the plants, you do not project...anyfatalities from a radiological accident?

Did you estimate any probability of this occurrence base upon previousexperience?

But the radiological risks were regarded as negligible; is that correct?

  • .. if you calculated them, what was the probability that someone wouldincur a fatality on account of a radiologic incident, one in 10,000, one in amillion?
  • .. what did you calculate the probability to be that any worker at thefactory would die as a result of a radiological release?


The accident analysis evaluated historical data in addition to PantexSafety Analysis Reports and other published safety documents. This isrepresented by the fact that scenarios involving accidental high explosivesdetonation and tritium reserve failures caused by an internal event areevaluated as being "anticipated." This means that they are expectedto occur at least once within a human lifetime.

There have been no fatalities at Pantex Plant due to radiologicalreleases. Also, no radiation-caused fatalities are predicted. Volume I,section 4.14, Table lists the predicted number of excess latent cancerfatalities from Pantex Plant operations.

RC: 14.099

Doc: HT15/42

Have you ever heard of a case of Mr. Glen McGough? The data indicates thatthere actually has been a death due to a radiological accident at the plant. The exact cause of his leukemia was never exactly identified. And the courtcase was sealed in 1983 so that there never has been an attempt to find out ifhis particular death was due to a radiological release.

We've also got recent cases involving a man named John Bell who claims thathis illnesses are due to a radiological release. And he also anticipates hisdemise soon. There may be some other cases. I have heard of a few.

In other words, without taking the actual records on people who have workedat the plant and doing anything, the probability that their deaths were in someway related to accidents that occurred in the plant, we have no reliable way ofprojecting how many deaths may occur in the future.


DOE has an ongoing worker health surveillance program. To date, therehave been no verifiable indications of adverse health effects from employment atPantex Plant.

RC: 14.100

Doc: HT15/43

... Based upon the actual history of the plant, could you have calculatedfatalities in the future? And if the calculations that you make indicateextremely low probability of deaths in the future from radiological release, howreliable are your calculations since what we do have, what we actuallyknow,...indicates a vastly greater risk than [what] even you calculated.


See response to comment 14.098.

RC: 14.101

Doc: HT15/44

... It bears some examination as to whether or not these particular casesare attributable to the fact that some of them were working at Pantex.

However, the point is that you've made a risk calculation. And in order todetermine whether or not it's accurate, we need to identify cases which may becontributable. It's not so much that I fear what is current activity at Pantex.It's what I anticipate may be coming in the future if the plutonium processingoccurs. And, in that case, we need to be exceedingly careful about thepossibility of radiological production.

If we calculate now what may happen in the future and our calculations areinaccurate, we will probably be inclined to take a much greater risk in thefuture operations in the plant than we ought. I think you should give thatconsideration.


See discussion in section 1.3.10 of this volume regarding healtheffects.

RC: 14.102

Doc: HT15/45

I think it's worth noting that in one obvious example of an industrialaccident which occurred at Pantex in 1979 that resulted in fatalities, neitherthe plant operator nor the Federal government was willing to take financialresponsibility for the consequences of the accident.


DOE provides compensation and restitution where appropriate, inaccordance with the governing law and/or Presidential direction.

RC: 14.103

Doc: HT15/49

I just need some help understanding about the consequence categories. When Ilooked at that, it struck me that this was an acute exposure, a one-timeexposure type; is that correct, or am I misunderstanding?


Exposures from accidental releases of radioactive material aredetermined from the concentrations and types of material released. During theperiod following an accident, exposures are from direct radiation from thepassing plume and from radioactive material deposited on the ground, inhalationfrom the plume, deposition on skin, and inhalation of resuspended groundcontamination. The inhalation of resuspended contamination is calculated forthe lifetime of the exposed individual. Once radioactive material enters thebody, it remains there for various periods of time depending on decay andbiological elimination rates. Tritium emits a weak beta particle and isbiologically eliminated from the body over several weeks. Plutonium emitsrelatively high-energy alpha particles and is retained in the body for periodsof several months to many years. This was accounted for in the EIS bycalculating a committed effective dose equivalent, which is a 50-year committeddose, not an acute exposure. Obviously, when an explosion occurs, its impactapart from any associated radioactive release is limited to the timeframe of theexplosion.

RC: 14.104

Doc: HT15/50

... I just wanted to understand what we're talking about when we talk aboutconsequences. The consequences are greatly varied depending on the materialwe're talking about, just as you referred to. So sometimes you say the acuteexposure is probably from an explosion. But, just as we talked about previouslywith aircraft and the probability of a...plutonium release getting into thesoil, there are materials that are toxic. ...So I'm wondering, how do they takeall those factors into account?


See response to comment 14.103. Additional details on long-term pathwayissues has been added to volume I, section 4.14.1.

RC: 14.105

Doc: HT15/51

... The [exposures] through the operation of Pantex are in addition to, notother than, so as not to avoid one choice or the other. These are additions toexposure.


The exposures from Pantex Plant operations are in addition to thosereceived from background sources. These exposures are discussed in volume I,section 4.14.

RC: 14.106

Doc: HT15/52

... Latent cancer fatality [risk factors] are all Greek to me. Would youtalk to me about that?

I'm not sure that I know what CEDE is and what it means?


Based on recommended risk factors of 0.0005 deaths per rem in thegeneral public and 0.0004 deaths per rem for workers, a latent cancer fatalityrisk can be calculated based on the amount of radiological exposure. CommittedEffective Dose Equivalent (CEDE) refers to radiation doses received fromradionuclides deposited in organs and tissues. Once deposited in organs andtissues, radionuclides provide a continual source of irradiation. To takeaccount of this continuing irradiation of organs and tissues that occurs afterthe intake of radionuclides, the CEDE is defined. The CEDE is the time integralof the equivalent dose-rate in a specific tissue following intake of aradionuclide into the body. The CEDE is usually calculated for a 50-yearperiod.

RC: 14.107

Doc: HT16/1

Along with that inhalation and the statement that was made in the documentthat DOE only addressed inhalation exposure, inhalation is the only pathwayaccounted for in the assessment of chemical and radiological airborne hazardsfrom normal operations (page 4-205). Now, does this mean that there areexposure pathways of non-airborne hazards, for example, through groundwatercontamination? And are these included in the analysis and where do we findthem?


Detail on alternative pathways has been added to volume I, section4.14.1.

RC: 14.108

Doc: HT16/2

Are there other pathways and accidents that are non-normal operations? Arethese included in the accident analysis?


Detail on alternative pathways has been added to volume I, section4.14.1.

RC: 14.109

Doc: HT16/3

The Acqua[v]ella Study I believe was referred to, the study on the workersat Pantex. Am I correct that this study compares workers to the community atlarge?...


The Acquavella study (Acquavella 1985) compared total and cause-specificmortality for Pantex Plant workers employed between 1951 and 1978 with expectedmortalities based on U.S. death rates.

RC: 14.110

Doc: HT16/4

In the accident scenarios and analysis, it seems as though everything has towork 100 percent correctly all the time. ...Is there any built-in analysis forif something does not actually fall into place like it is supposed to?


Volume I, section describes the mitigation features in place atPantex Plant to prevent or minimize potential releases. These include multipleprotective barriers and systems, reinforced buildings, and redundant safetyfeatures. Accident analysis begins with the premise that there has been anevent in which some form of failure of the protective barriers or systems hastaken place. Consequences are then calculated based on the type and degree offailure.

RC: 14.111

Doc: HT16/5

... Do you consider that there are different initiating events at differenttimes that would cause a different sequence? And is there data that supportsthis claim?


For each facility and operation at Pantex Plant, DOE has developed or isin the process of developing a safety analysis report. In addition, otherfacility-specific safety analyses have been performed and documented. Thesedocuments were utilized to identify potential accidents at Pantex Plant. Thefrequency of internal (e.g., equipment failures or human errors), external(e.g., aircraft crashes), and natural phenomena (e.g., tornadoes andearthquakes) initiating events were evaluated for different facilities andoperations. To bound the possible consequences, the amount of hazardousmaterial available for release was taken to be the maximum allowed by facilitylimits, rather than what might be actually present.

RC: 14.112

Doc: HT16/6

... What is the Panhandle's background, as far as radiological exposure? What's the norm for the region?

From background sources 334 is the total natural [background radiationdose]?

So the 330 that you have here, is that in addition to the 334?


The natural background radiation in the vicinity of Pantex Plant resultsin an average dose to an individual of 334 mrem/yr. The 330 rem referred tohere is the dose for all workers for ten years. Each worker is getting about111 mrem/yr (0.111 rem/yr) in addition to the dose from background sources.

RC: 14.113

Doc: HT16/8

This document and, frankly, the other PEISs, don't have historic data onworker exposures at MOX fuel facilities that they're basing their projectedimpacts on. They don't use that kind of data. So when you come to the public andmake statements like we're going to be within regulatory limits,...that doesn'thave anything to do with you probabilities and your risks, because theprobabilities and risks are not necessarily always related to the regulatorylimits.

... I think one of the things that I would suggest is that you make clearerin the text of the document, particularly on the health issues, specifically howyou're basing your analysis on historic data and where you really don't havemuch historic data or very limited historic data that you are, therefore,extrapolating to a 50-year CEDE or to a 10-year operational lifetime.


DOE has made this revision in the final EIS to ensure that the basis forthe dose numbers is apparent.

RC: 14.114

Doc: HT17/28

My surveys of radiation and health around several different Texas nuclearfacilities have impressed me with the failure of government and industry tostudy the health effects of such facilities in any meaningful way.

I'm happy to hear that there is another investigation of the Pantex areaunderway this summer by the Texas Department of Health in conjunction withATSTR, but I believe that we need much more thorough going studies, includingdoor-to-door surveys and follow-ups for former Pantex workers and residents ofthese counties.


See discussion in section 1.3.10 of this volume regarding healtheffects, including the planned follow-up study by the National Institute forOccupational Safety and Health (NIOSH).

RC: 14.115

Doc: HT17/29

I found it very instructive to do a simple analysis looking at all cancermortality before the tritium accident in 1989, in which 40,000 curies werereleased, compared to the years after, for which I had data at the time [and] Idid the analysis.

And there was approximately a doubling of the cancer death rates in CarsonCounty after the accident compared to the four years before.


The estimated impacts of the past tritium accident are described involume I, section 4.14 in relation to Scenario 5. The public impact from thisaccident is estimated at 8.0 x 10-2 person-rem. The hypothetical maximallyexposed offsite individual exposure is estimated as 1.1 x 10-2 rem. Thisexposure would result in an increase in individual lifetime cancer probabilityof 5.5 x 10-6 compared with a lifetime fatal cancer probability from all othercauses of approximately 20 percent for an average individual.

RC: 14.116

Doc: HT17/30

A 1979 study by...a group of University of Heidelberg scientists re-examinedthe U.S. experiments on which allowable emissions for nuclear facilities werebased, and discovered, looking at the protocols of these experiments, thatthey were doctored from the beginning.

Soil was cooked so there were no microbes present, so the uptake of plants'radionuclides was minimized. And...the radiation was induced just before theplants were harvested, instead of into the soil from the time the plant was aseed, just as an example of the way in which science was acting to obscure thereality of radiation exposure to humans.

The German scientists concluded that the allowable emissions were too highby a factor of 100. So, I keep that in mind in thinking about the expansion ofoperations at Pantex.


Discussion of DOE Occupational Radiation Protection standard developmentcan be found in 10 CFR Part 835.

The goals of current DOE radiation protection standards are based on twobasic types of radiation induced health effects: stochastic and nonstochastic.Radiation-induced health effects that do not have threshold doses are referredto as "stochastic effects." Examples include cancer and hereditaryeffects. The objective of the radiation protection standards is to limit theprobability of stochastic effects to acceptable levels. Nonstochastic effectscan only be manifested if a threshold dose is exceeded; therefore, the objectiveof the radiation protection standards is to maintain personnel exposure belowthe threshold doses in order to prevent these effects.

DOE currently accepts the assumption that there is no threshold forstochastic effects. DOE also currently accepts the linear threshold model forstochastic effects. The linear threshold model assumes that any radiation doseincreases a persons risk of cancer.

RC: 14.117

Doc: HT17/31

... I noticed a study of the area around Rocky Flats by Dr. Carl Johnson ofthe Jefferson County Health Department, who correlated plutonium levels in thesoil with cancer increases around Rocky Flats. It was a very close correlation,which was corroborated later by the DOE's own studies.

The second article I found worrisome was the contention of the University ofColorado scientist who believes that there is no way you can completely capturefine plutonium particles and prevent them from escaping into the air aroundplutonium processing facilities.

Given that Panhandle agriculture, the Ogallala aquifer, and the health ofmany area residents who I'm coming to consider close friends [are] at risk inthe event of contamination by plutonium, among other radionuclides that arereleased in plutonium processing, I would stress that the excess cancers thatDr. Johnson found, which were leukemia, lymph, lung, thyroid, testes, and breastcancers, which paralleled the cancers found in the survivors of the Japaneseatom bombs, are of concern.

And would request that no expansion of Pantex operations be considered untilthorough health studies, including door-to-door surveys and follow-ups, beconducted to examine the damage that I believe may have already been done tothis area by previous emissions.


See discussion in section 1.3.10 of this volume regarding the plannedfollow-up study by NIOSH.

RC: 14.118

Doc: HT17/32

... The track record at Pantex does not give us great confidence that anexpansion of an extremely dangerous operation could be handled with any moresafety than we've experienced in the past.


DOE is committed to the safe operation of Pantex Plant, as well as theprotection of the public, the environment, and the facility employees. Thesafety and health environment and impacts at the Pantex Plant are discussed involume I, section 4.14. In addition, further information on Pantex Plant safetyand environmental programs can be found in the Pantex Plant Safety InformationDocument and Environmental Information Document (Pantex 1996a, Pantex 1996).

The As Low As Reasonably Achievable (ALARA) program implemented atPantex Plant minimizes radiation exposure during performance of all radiologicaloperations.

RC: 14.119

Doc: HT17/44

... We were discussing earlier the effect, possibly the health effects onfarmers that do farm on the plant site itself, [whether] that has been addressedin this document or not. We would like for it to be.

I know that my husband has done some farming on the plant site. Just theother day he was combining some wheat on the plant site. That stirs up thedust, it disturbs the soil.


Soil and vegetation sampling of these areas show no levels of pollutantsthat would be a hazard to farmers.

RC: 14.120

Doc: HT17/49

There has been considerable concern over the status of how the plantestablishes its safety envelope, certain things like safety analysis reportsthat are being redone at Pantex. What is the status of updating the safetyanalysis reports so that you establish the safety of work for this plant?


Safety analysis reports (SARs) for Pantex Plant are being rewritten toDOE Order 5480.23. In accordance with that order, Pantex Plant has submitted aBasis for Interim Operations (BIO). The BIO includes the status of all SARs, aschedule for completion of the remaining SARs, and a summary/status of allUnreviewed Safety Questions. This report also defines the safety envelope,including compliance status. The DOE-approved BIO establishes the authorizedsafety basis for Pantex Plant. The latest BIO for Pantex Plant is available inthe EIS reading rooms in Albuquerque and Amarillo.

RC: 14.121

Doc: HT17/50

... I think there needs to be a description of unreviewed safety questions,or unresolved.

I don't think it would hurt at all to have a chart listing what they've beenin the past year or two, what are [still] pending, where we are on that.


The Pantex Plant Programmatic Information Document (Pantex 1996b)presents a listing.

RC: 14.122

Doc: HT17/51

What facilities are in compliance, and which ones aren't, with...DOE orders? And if there's been great change in recent history,...describe that change,that the orders were changed,...that [that] caused problems. Give it thecontext you want, but please give us more of the story to work with.


The Pantex Plant Programmatic Information Document (Pantex 1996b)presents a listing.

RC: 14.123

Doc: HT17/57

The approach to human health in the draft EIS is flawed. It uses onlyoptimistic scenarios of exposure, statistical methods that obscure potentialrisks and problems. Evidence used is one-sided, a very theoretical presentationwhich suggests more exactness in scientific knowledge than is supportable andseems designed to lend credibility where it is not necessarily due. Moreover,the theoretical approach is difficult to [wade] through. It obscures and hidesassumptions and it is meaningless to public concerns, because it is removed fromeveryday life experience.


The risk assessment and scenario for the EIS examined a wide range ofscenarios which included failures in safety systems and emergency responses. For example, scenarios involving fires typically include failures in the fireprotection system and emergency fire response crews in their event sequences. Most of the scenarios that are not initiated by external events are initiated byhuman errors such as dropping, improper forklift handling, or failure to followa procedure.

Concepts of relative risk, frequency, and consequence may be bothdifficult to understand and removed from everyday life; however, such atheoretical approach to risk quantification is the only fair and equitableapproach available. Prior epidemiological studies of Pantex Plant workers alsodisclose no excessive incidence of cancer at Pantex Plant. The inference fromthese studies is that the incremental risk to workers and the public from PantexPlant operations are very small. Results from the more theoretical approachused in the EIS are consistent with these empirical conclusions.

RC: 14.124

Doc: HT17/59

The data are one-sided. The use of prior studies and data in the draft EISpresent only one side of the scientific debate about the effects of low-levelionizing radiation.

The presentation is very lopsided. Studies not cited suggest health effectsincluding leukemia, thyroid cancer, and multiple myeloma have been found innuclear workers whose cumulative dose for their total working years was between2.5 and 5 rem. On page 4-205, it is reported that the average annual dose ofworkers at Pantex is 111 millirem. If we take a worker who is at the plant for25 years, then 111 millirem times 25 years is a cumulative dose of approximately2.775 rem. This value is within the range for which health effects wereobserved in these studies. Moreover, if we take the Pantex control level of 500millirem per year for most workers, 900...weapons operation workers, we getcumulative doses over a 25-year working life of 12.5 rem and 22.5 rem,respectively. These values are all much higher than the levels at which healtheffects are observed in these studies.

The agency should reevaluate the risk to workers from low-level radiationexposures using the risk factors reported in these studies.


See discussion in section 1.3.10 of this volume regarding theradiological risk factors.

RC: 14.125

Doc: HT17/60

... As the scientific uncertainty highlights, the standards used by EPA,NRC, and DOE are not protective standards. They are politically negotiatedstandards that allow workers and communities in the vicinity of a nuclearfacility to bear a higher cancer risk for the social benefits that are believedto come from the facility.


See response to comment 14.116.

RC: 14.126

Doc: HT17/61

The Acquavella study referred to, of 1985, relies on a weak methodologicalapproach and data sources that compares workers to the community at large. Thecancer registry data are not a credible source of data for detecting radiationeffects in the community surrounding nuclear facilities.


See discussion in section 1.3.10 of this volume regarding theradiological risk factors.

RC: 14.127

Doc: HT17/62

The draft EIS relies on inappropriate data to make risk estimates andcomparisons in the communities surrounding the Pantex Plant. Again, the mostoptimistic picture is painted with selective use of evidence and methods. Morerigorous studies are needed to more effectively estimate these risks.


See discussion in section 1.3.10 of this volume regarding the plannedfollow-up study by NIOSH.

RC: 14.128

Doc: PC-017/4

What studies have been made on the short-term and the long term health andsafety of those of us living near the plant, agricultural workers on and aroundthe plant, and the workers [at] the plant? Have past Pantex workers' healthbeen studied? Have there been follow-up health studies been made on theworkers? How were the health and safety studies done? When? What are theresults? No decision of the future of Pantex can be made until answers to thesequestions are assessed. Answers can only be found after adequate studies havebeen made.


See discussion in section 1.3.10 of this volume regarding health effectsinclusive of past, present and future health studies.

RC: 14.129

Doc: PC-017/5

We are told the activities at the plant have no and will not have any effector at most limited effect on the Pantex workers and on the neighbors andagricultural workers, yet studies have not been made for those conclusions. Weare relatively certain that past activities have been a serious threat to bothworkers and neighbors. The DOE and the contractors seem very reluctant to admitto those health and safety concerns. They appear to get very upset when anyinstances of health and safety get out. Why? Should not the public be keptinformed of such matters? If not, why not?


Each year, the Pantex Plant publishes a Site Environmental Report. Itincludes a reporting of all impacts to the environment and the public. ThePantex Plant Safety Information Document (Pantex 1996a), contains a listing ofpast accidents and events and explanations of their consequences.

RC: 14.130

Doc: PC-017/8

Most of us cannot afford to spend anywhere near what the DOE can and does tokeep from paying claims. [For] example, the John Bell compensation case inwhich Mr. Bell was made very ill because of uranium toxic fumes while he wasdrilling a uranium plug from a warhead. The DOE spent hundreds of thousands ofdollars to keep from paying about a $85,000 claim.


See response to comment 14.102.

RC: 14.131

Doc: PC-017/9

In the event of a disaster that causes damages to our agricultural productsand/or land, and/or inability to market our products because of possiblecontamination, will the DOE pay for those damages at a fair market value in atimely manner? Will they pay willingly without our having to take them tocourt? Will the DOE pay us for the lose of our top soil and clean the damagedsoil?


See response to comment 14.102.

RC: 14.132

Doc: PC-017/14

Is there a greater risk to farmers who are plowing and working the soil andharvesting of crops near the site than to the general public? What studies havebeen done to determine the potential of greater exposure? Should not thesestudies be done? Is there a danger to our children playing in their [sandboxes]or their swimming pools?


See response to comment 14.119.

RC: 14.133

Doc: PC-017/15

Page 4-104 discusses collective dose to surrounding population in a 50-mileradius. Would not [people] living next to the plant, especially those downwindbe expected to receive a greater dose than someone who lives in Vega to thewest, up wind, and about 40 miles away? Would not people downwind receivehigher doses than those generally up wind? If not, we ask for your proof.


People downwind of a release would receive a greater dose than thoseupwind of a release. People closer to the site will receive a greater dose froma release than a person in Vega.

RC: 14.134

Doc: SG-012/4

Vol. 1, page 5-65, 5.5.2 Resources Discussed in Detail, HumanHealth, Impacts of Storing 20,000 pits, "The combined worker dose fromunloading storage of 20,000 pits at the Manzano WSA would be 283 person-remdistributed over the 30 people directly involved material movement." Ifthere is a collective effective dose of 283 person-rem, which is a sum of apopulation of 30 workers, then the average effective dose per worker is 9.43rem. The maximum yearly allowable dose for radiation workers is 5 rem, accordingto DOE order 5480.11 "Radiation Protection for Occupational Workers"(1992, DOE). The projected radiation dose for these workers is in excess of theyearly allowable dose. The DEIS statement should be clarified and thecalculation (inclusive of the population numbers) on person-rem provided.


The 283 person-rem projected exposure is for the transfer of 20,000 pitsover an approximately 10-year time period. It is not, as the commentorsuggests, a yearly exposure.

RC: 14.135

Doc: SG-012/5

The term "person-rem" should be defined in the glossary section.


This term has been added to Chapter 10.

RC: 14.136

Doc: SG-012/6

Vol. 1, page 5-65, 5.5.2 Resources Discussed in Detail, HumanHealth, Impacts of Storing 20,000 Pits, and Impacts of Storing 8,000 Pits.Population doses and risk estimates from accidental releases are based oncurrent populations. Pits are placed in interim storage for 20 years, forinstance, and projected population growth is not reflected in the estimateddoses (nor is risk) over this time period. Albuquerque has had a high increasein population in the last 20 years.


It is DOEs policy to evaluate site-wide NEPA documents at least everyfive years to determine whether the existing EIS remains adequate and whether toprepare a new site-wide EIS or supplement the existing EIS (10 CFR 1021.330).

RC: 14.137

Doc: SG-012/8

Does the close proximity of the pit storage to weapons presently stored inthe Manzano WSA pose an increase in potential nuclear accidents? Why would theynot pose a problem?


Weapons are not stored in the Manzano Weapons Storage Area.

RC: 14.138

Doc: FG-003/13

EPA believes that the FEIS should provide more documentation as to potentialgroundwater impacts should an earthquake harm the plutonium pit facility orrender it inaccessible. In particular, we are concerned that DOE may haveconcluded that leaving the plutonium pits inside the P-Tunnel (should itcollapse) may have less environmental impact than attempting to retrieve thepits from inside a collapsed P-Tunnel (due to wording in the Pantex DEIS thatimpacts to workers and the public from radionuclide releases would be "negligible"because the plutonium containers would be sealed inside the collapse tunnel). Additionally, potential NTS impacts to groundwater, such a scenario, were notdiscussed in the Pantex DEIS. We recommend that the FEIS provide moreinformation of the depth to groundwater in the Device Assembly Facility andP-Tunnel areas and whether keeping plutonium pits in a collapsed tunnel mayultimately cause a migration of radioactivity to groundwater.


The analyses of this EIS focuses on immediate or near term effects onthe environment and do not address potential impacts over hundreds or thousandsof years. In this specific example, DOE has not concluded that, in the event ofa tunnel collapse, pits should be left entombed rather than retrieved.

DOE would evaluate the circumstances of any accident after it occurredto formulate the appropriate response. Since the response to each accident ishighly dependent upon the actual accident that occurs and the associatedimmediate risks, it is not appropriate to develop detailed accident specificplans in advance. General responses to emergency conditions are contained inthe Nevada Test Site (NTS) emergency preparedness plans. Should the site beselected for interim storage, those plans would be updated to include thestorage activities. A search is ongoing for more data on depth to groundwaterat both sites.

RC: 14.139

Doc: FG-003/16

The Pantex Summary (Table S-2) identifies the environmental impactsassociated with the alternative pit storage relocation sites. For NTS, therange of potential accident scenarios are limited to two: puncture of a pit dueto a forklift accident and an aircraft crash. Potential seismic hazards at NTSare not recognized in Table S-2, as they were in Volume I. We, therefore,recommend that Table S-2 be modified to recognize NTS seismic hazards. TableS-2 should also reflect seismic conditions that may exist at the proposedinterim pit sites in South Carolina, New Mexico and Washington State. Modifications to Table S-2 should be incorporated into the FEIS.


As discussed in volume I, section, the human health risk fromaccidents at the NTS is dominated by handling accidents. The contribution torisk from seismic events is negligible. As described in volume I, section5.3.2.1, the relative risk from earthquakes at Savannah River Site is over twoorders of magnitude below the risk from a forklift accident. Volume I, section5.4.2.1 describes the relative risk from earthquakes at Hanford Site to benegligible. As described in volume I, section, radioactive release froma Manzano storage facility would not result from an earthquake as long as therock overburden remained intact and the doors leading to the storage facilityremained closed. As identified in volume I, Summary Table S-2, the risk at allfour alternative sites is dominated by a forklift accident.

RC: 14.140

Doc: HT16/11

It just occurred to me just as I was listening to you talk about whether ornot there would be less exposure if the pits were left on site rather thantransporting them, and I wondered if the repackaging were not part of thelong-term storage in that option if they were to be left on site. And,...if so,if repackaging is a part of the action, that would be part of the analysis also? Because it would provide the same worker exposure as taking it out of thebunkers and moving it to a new location.


Pits are planned to be repackaged into AT400A containers no matter whichalternative is chosen. The onsite transfers required for this activity arediscussed in volume I, section 4.12. Onsite movements of pits differsignificantly from offsite pit shipments. Because of the limited speeds foronsite transfers, the restraint procedure required for pit containers is lesscomplex and less time consuming than the restraint procedure for offsiteshipments. Because of the additional complexity of the restraint procedure,dose estimates for offsite transfers are greater than the estimates for onsitetransfers.

RC: 14.141

Doc: HT16/12

... If Pantex is chosen for long-term storage, then the workers wouldactually be exposed to the same activity, bringing them [the pits] out of thebunkers as they would if they were taken out and moved to another location.


Onsite movements of pits differ significantly from offsite pitshipments. Because of the limited speeds for onsite transfers, the restraintprocedure required for pit containers is less complex and less time consumingthan the restraint procedure for offsite shipments. Because of the additionalcomplexity of the restraint procedure, dose estimates for offsite transfers aregreater than the estimates for onsite transfers.

RC: 14.142

Doc: PC-031/3

There is certainly no community health study upon which DOE can even basethe assertions they make. The public, Pantex workers, and former workers deserveadequate health studies of the cumulative impact and adverse health affectsresulting from combined exposures to radiological substances, hazardouschemicals, toxic releases, and daily emissions. DOE can not expect to becredible and has no basis to assert "no significant impact" untilproper studies have been done.


Past, present, and future health studies involving Pantex Plant arediscussed in volume I, section 4.14.1 of this document. To date, these studiesindicate that there have been no significant excess cancer mortality incidencesin the Pantex Plant area related to Pantex Plant operations. There have been noverifiable indicators as to any short- or long-term health impacts at the PantexPlant Site. Public exposure to radiological effluents has conventionally beenof extremely small quantity due to DOE safeguards and the nature of the missionsconducted at the facility.

RC: 14.143

Doc: PC-025/71

Page 4-205. Isn't it more accurate that the majority of Pantex Plantworkers receive no detectable (or observed) radiation exposures?


The commentor is correct. There is a lower limit below which radiationexposures are nondetectable from background radiation.

RC: 14.144

Doc: PC-025/72

Section 4-14. What's the big deal with the analysis? The death rate for usall is 100 percent. In the event of a serious accident resulting in deaths,shortened life spans, loss of the Ogallala [aquifer], loss of agriculture, orother damages, what are DOE's commitments to citizens of Amarillo (and others)for the damages? Is the answer "Nothing, it was an act of god, war, thecontractor was at fault?" I am serious when I ask this questionWhat are DOEand its contractors committed to should something go wrong? The people inAmarillo should know as well as the rest of us. Please don't answer thequestion with safety policy BS.... I want the answer to make the lawyers hurta little bit from sticking their collective necks out. One hundred percentrestitution? What the country can [bear]? What the lawyers can squeeze out? What the politicians can get? We the People will do what is right, just, and inthe finest tradition of America? What is the insurance?


DOE would respond to immediate emergency conditions in accordance withthe Pantex Plant Site emergency preparedness plans. The Department wouldevaluate the circumstances of any accident after it occurred to formulate theappropriate response. Since the response to each accident is highly dependentupon the actual accident that occurs and the associated immediate risks, it isnot appropriate to develop detailed accident specific plans in advance. Long-term commitments in terms of clean-up levels or possible compensation wouldbe in accordance with applicable laws, regulations, and direction by thePresident and Congress.

RC: 14.145

Doc: PC-025/73

Table Frequency of Scenario uses carefully chosen words likeAnticipated, Unlikely, et cetera. Please include the mathematicalrepresentation in the table...for the purpose of improved clarity. Pleaseexplain where the risk of a tornado is in table Where is a[lightning] strike event? It is a well known fact that one is more likely to behit by [lightning] than winning the lottery. Isn't a release of mercury likely? What about an accidental shooting? What is the risk of an employee beingkilled by an automobile onsite? Where is electrocution of an employee or aconstruction worker? What about confined space entry problem?


Natural phenomena events include weather-related occurrences (e.g.,tornadoes and severe winds) and earthquakes. They are accounted for in theaccident analysis by being included as initiating events that results in afailure and release (e.g., tritium reservoir failure). In volume I, section4.14, Table, natural phenomena are identified as possible initiatorsin Scenarios 3, 4, 7, 8, and 10. The risk from tornadoes and lightening strikesis dominated by the risk from earthquakes for all sites. The other eventsmentioned in the comment (mercury release, accidental shooting, automobilecasualty, electrocution, and confined space entry) are not risk dominant.

RC: 14.146

Doc: PC-025/74

Page 4-223. Should consider the Annual Risk to be calculated for the TexasPanhandle, I believe that is more representative of the Pantex area. Alsoconsider showing the Annual Risks for Oklahoma, New Mexico, and Kansas.


The annual fatal cancer risk in Potter, Randall, and Carson Countiessurrounding Pantex Plant is 1.7 x 10-3 LCF/year. Nationwide, the cancer risk isslightly higher. It is more appropriate to compare the Pantex Plant humanhealth impacts with the annual fatal cancer risk in the vicinity of Pantex Plantsince that is the area assessed in the EIS.

RC: 14.147

Doc: PC-025/75

In Scenario 7 on Page 4-231, how many reservoirs (or what percentage) failduring the scenario? Does the hydrogen released explode (like the Valujet oxygenproblem) and propagate? What is the inventory of sympathetic explosive,flammable, and combustible material in the adjacent buildings to the vault. Anyweapons in the adjacent buildings that could result in a Scenario 9 event? Whatabout stored/moving to being stored pits that would be near the vault and resultin a Scenario 8 event? Would the damaged reservoirs react like missiles? Wouldthis result in further release from other reservoirs? If the vault is breached,are others killed due to the hydrogen gas fire and reservoir missiles? How manypeople would be killed by the concussion blast of the aircraft impact andflammable material explosions resulting after the crash? How many people arelikely to be in the area? What documentation is available to prove all thetritium is not released in a massive explosion? The estimated number of tritiumcontainer breaches is consistent with plutonium container breaches resultingfrom an aircraft crash? Are the reservoirs designed stronger than the[plutonium] cans? In the event of a total release of tritium in the vault, aScenario 8 event, and a Scenario 9 event, what is the probability and theconsequence (in curies and fatal cancer probability)?


In Scenario 7, all of the reservoirs in the building are assumed to faildue to overheating. The hydrogen (tritium) release is oxidized in the flamesbut does not explode. The adjacent building 12-42 contains flammable andcombustible materials which are ignited. These materials are the heat sourcethat cause the reservoirs to fail. Due to the small size of the reservoirs,they would not behave like missiles.

During any aircraft crash, the number of people killed in the impactarea would depend on the type of aircraft, time of impact, and typical occupancyof the structure being impacted. The assessment did not quantify the number ofpotential fatalities but only recognizes that fatalities would occur if such anevent were to happen.

The tritium reservoirs are robust but are not designed to the samestandards as the AT400A plutonium storage container. The risk associated withan aircraft impact into 12-42 South Vault is bounded by the risk of Scenario 7because the frequency of Scenario 7 is greater than the frequency of an aircraftimpact into 12-42 South Vault.

RC: 14.148

Doc: PC-025/76

What is the concussion blast resulting from impact? What is the kill zonefrom the impact and the resulting fire? What is the number of plantcausalities?


See response to comment 14.147.

RC: 14.149

Doc: PC-025/77

The eleven scenario analyses are flawed since [they do] not allow formultiple scenarios resulting from one initial event. As an example, manyaircraft accidents involve two planes; however, this analysis looks at only oneimpact location. Further, a plane could lose an engine, as it breaks apart,into a weapon magazine while the remainder slams into a pit storage facility. Aircraft impact into tritium vault resulting in damage to pit and or weaponbeing moved and in near vicinity of ground zero.


In the Draft DOE Standard for Aircraft Crash Analysis (DOE 1996g), theprobability density function, used for computing the probability that anaircraft will crash, is based on national averages of all types of aircraftcrashes including incidences where two aircraft were involved. Thus, thisaspect has been considered in the methodology. In terms of the debris from onecrashing aircraft striking multiple facilities, the analysis includes aircraftdimensions (wingspans), building dimensions (length, width, and height) andlocations, and geometric factors which allow an aircraft to impact multiplefacilities. The engines possess the density and structural integrity to causesignificant building damage and were modeled as the primary penetrators for thefacilities of interest. The rest of the aircraft is not as capable of causingbuilding damage to the majority of the Pantex Plant facilities included in theanalysis.

RC: 14.150

Doc: PC-025/95

Accident analysis is flawed because severe weather is not analyzed.


As discussed in volume I, section, severe weather is includedin the evaluation of natural phenomena event initiators.

RC: 14.151

Doc: SG-003/1

In Section (page 4-219...) and in Figure (page 2-224), aclassic error is made in explaining potential latent cancer fatalities. Theerror is to use risk estimates for exposures to large populations and to assumethat applying that risk estimate to a specific group of workers allows fordefinitive conclusions about that group. In this example, the figure providesthe correct explanation. The text is misleading and might cause confusion in thecommunity by indicating that the 330 plant workers would suffer a certain numberof cancers.


Further clarification of the interpretation of risks has been providedin section 1.3.10 of this volume.

RC: 14.152

Doc: SG-003/2

Health effects are important to understand. The section on continuedoperations talks about health effects for workers. A statement is made thatworkers would experience additional cancers. In the figure, a differentexplanation is used. The statement in the figure is that an average number ofcancers could occur if many groups of workers were exposed. The final statementwas that the most likely outcome is zero cancers. What is the correctexplanation?


Further clarification of the interpretation of risks has been providedin section 1.3.10 of this volume.

RC: 14.153

Doc: SG-003/5

Appendix D, Human Health, does very little to explain how the impact tohuman health is derived or calculated. This appendix is more of an explanationof the risk assessment methodology than human health.


Duplicate comment. See response to comment 14.087.

RC: 14.154

Doc: SG-003/6

The U.S. Department of Energy's Office of Emergency Management (NN 60) andthe Office of Emergency Response (DP 23) fund the DOEs Atmospheric ReleaseAdvisory Capability (ARAC) which is housed at the Lawrence Livermore NationalLaboratory. ARAC's computer models, which have world-wide acceptance, have beencalled into service in many real-time responses to both real and potentialaccidental releases of radioactive material. The Three-Mile Island nuclear powerplant accident in 1978, the 1986 Chernobyl disaster in the former Soviet Union,and the U.S. Air Force Titan II missile accident in Damascus, Arkansas are justa few examples. In addition, the ARAC models have been utilized in every nuclearweapons accident exercise since NUWAX 79. Pantex Plant is an "ARAC Site"and is linked to the ARAC center in Livermore via a computer-to-computerconnection. ARAC operators are familiar with Pantex operations and can respondin a matter of a few minutes with a computer model graphic output showing thetrajectory of the plume of contamination in the event of an accident. When, andif, a real accident occurred at Pantex it would be the ARAC models and the ARACcapability that DOE would call upon to response in real time. Since ARAC isfunded by DOE Headquarters and is ready to respond to a radiological accident atPantex, why did DOE choose to use a model like ERAD to assess consequences forthis EIS?


See response to comment 14.085.

RC: 14.155

Doc: SG-003/8

Enhancement of public safety, protection of public health and the preventionof environmental degradation are crucial factors for assessing Pantex Plantmission accomplishment. Texans must be assured that these issues will receivesufficient attention prior to any decisions regarding plant operations. Thoroughand complete assessment of consequence analyses to a satisfactory confidencelevel is required to support the decisions under consideration.


See response to comment 14.118.

RC: 14.156

Doc: SG-003/9

In the Summary, page S-9, right column, it is stated that 8.1 E-6 LatentCancer Fatalities (LCF) per year would result from and aircraft crash into afacility with a weapons high explosive detonation. Scenario 3, described inVolume I, page 4-229 conflicts with this statement, indicating that theincreased risk is 1.8 E-11 latent fatal cancers per year. Table 3.14.2.l-4 inVolume I page 4-228, Excess Cancer Fatality Risk for Scenario 3 lists 5.1 E-6.These figures need to be verified, reconciled, and, if necessary, corrected.


The accident figures have been revised and verified.

RC: 14.157

Doc: SG-003/10

In the Summary, page S-10, left column, it states that from an aircraftcrash into Zone 4 facilities, 1.5 E-6 LCF per/yr for 20,000 pits and 9.8 E-7 LCFper yr for 8,000 pits would result. Table, Volume 1, page 4.228,Scenario 9 lists 6.0 E-8 excess cancer fatality risk. For Zone 4 weaponsstorage, 6.8 E-7 LCF/yr is given on page S-10. Scenario 3 in Table 5.1 E-6 excess cancer fatality risk. Page 4-250 lists the increase infatal cancer risk as approximately 2.2 E-11 increase in fatal cancer risk(compared to a baseline risk of 1.5 E-3 per yr). These figures need to beverified, reconciled, and, if necessary, corrected.


These figures have been verified and have been corrected in the EIS. Scenario 9 risk estimates are dominated by a seismic event effecting Zone 12rather than by an aircraft crash into Zone 4. The risk estimates for Scenario 3include aircraft crashes into both Zone 4 and Zone 12 buildings. The fatalcancer risk referred to on page 4-250 of the Draft EIS is for an averageindividual which is obtained by dividing the risk to the entire populationwithin the region of influence (ROI) by the number of people within the ROI.

RC: 14.158

Doc: SG-003/13

In the Summary, Table S-1, page S-20, gives a 4 E-l2 increase in fatalcancer risk, whereas in the same table, on page S-26 a duplicate entry gives 3E-12. Volume I, page 4-229, Scenario 3 lists an increased risk of 1.8 E-l1 LCFper year. Table, Scenario 3 gives 5.1 Excess Cancer Fatality Risk.Volume II page 4-250, right column lists 2.2 E-11 increase in fatal cancer risk(per yr). These figures need to be verified, reconciled, and, if necessary,corrected.


The entry in volume I, Summary, Table S-2 on page S-26 of the Draft EISis not a duplicate of the entry in Table S-1 on page S-20. The entry in volumeI, Summary, Table S-2 of the final EIS addresses the impact from pit storageonly. The entry in Table S-1 was in error and has been corrected. The accidentexcess cancer fatality risks have been verified.

RC: 14.159

Doc: SG-003/14

In the Summary, Table S-2, page S-25 right column, sixth line, between "in"and "0.04", insert "0.11 LCF and".


Agreed. The summary has been amended.

RC: 14.160

Doc: SG-003/15

In Volume I, page 4-l55, right column, the projected population in the ROIin 2055 ranges between 214,353 and 246,464. Figure, page 4.223 givesthe ROI population of 267,107 for risk estimates. Volume II, page D-28, leftcolumn, gives the population in the ROI as 267,107 for fatal cancer estimates.An explanation of the different populations is necessary, or one of the ROIneeds to be re-named.


The region of influence (ROI) for the socioeconomic analysis is definedon page 4-155 as the four counties surrounding Pantex Plant. The ROI for thehuman health analysis is the offsite population within an 80-kilometer (50-mile)radius of Pantex Plant as depicted in volume I, section 4.14, Figure 4.14.11. The text calling out Figure 4.14.1-1 in volume I has been modified by adding thefollowing sentence so that the ROI for the human health analysis is more clearlydefined: "This circular area surrounding Pantex Plant is the Region ofInfluence (ROI) for the human health analysis."

RC: 14.161

Doc: SG-003/16

In Volume I, page 4-215, right column, the statement concerning the PantexEpidemiologic Surveillance 1994 Annual Report should be updated to indicate thatthe report has been released. (The l995 Annual Report may also be available bythe time the Final Report is issued.)


Agreed. The EIS reflects the release of the 1994 Annual Report.

RC: 14.162

Doc: SG-003/17

In Volume I, page 4-223, Figure, fifth line from bottom,incorrectly refers to Table The correct reference is Table4.2.l.1-4. A similar error was noted in Volume II, Appendix E, page E-23, leftcolumn at the end of paragraph E.3.1.6.


Agreed. These corrections have been made in the EIS.

RC: 14.163

Doc: SG-003/39

... The risk from ingestion of hazardous substances should also be includedwhen calculating risk to onsite workers. The EIS only accounts for risk frominhalation.


The risk from ingestion of hazardous substances was not included becausethe risk to onsite workers is dominated by the inhalation pathway.

RC: 14.164

Doc: HT17/74

Without better data from these types of analyses, large uncertainties remainembedded in the draft EISand these are not mentioned or addressed. These aredifferent kinds of uncertainties than what I mentioned in #2 above. Those werescientific uncertainties. Now I am talking about uncertainties in the data. Athird kind of [uncertainty occurs] in measurements (because of lack of precisionin instrumentation).


A discussion of uncertainties and the method of incorporatinguncertainties in the accident risk assessment is provided in volume II, sectionD.6.

RC: 14.165

Doc: HT17/75

There are also inter-individual sensitivity issues to the public. Forexample, studies (not reported in the draft EIS) have found that prenatalx-rays, averaging between 20 mr [and] 400 mr have been found to double the riskof childhood cancer (Stewart and McMahon). Other studies have found effects fromlow-level radiation exposure (e.g., Kerber 1993). By the way, on page D-4 theAgency states that "since nondestructive examination using x-rays and gammarays is a well established industrial practice, this contribution to worker riskis negligible." It may be a well established industrial practice, butthere are newer studies that suggest the risks of low-level exposure from x-raysmay not be so benignthey clearly are not safe because, again, there is no safelevel of radiation exposure.


The risk factors used in the EIS to estimate the health impacts ofradiation exposure are obtained from the 1990 report of the National Academy ofSciences Committee on the Biological Effects of Ionizing Radiation, usuallyreferred to as the BEIR V report (NAP 1990). The studies of Drs. Alice Stewart,Brian MacMahon, and Richard Kerber were included in their assessment of thehealth impacts. While the risks associated with nondestructive examination arenegligible, nevertheless the worker exposure from this source is accounted forin the overall worker radiation exposure.

RC: 14.166

Doc: HT17/76

The draft EIS uses BEIR III and BEIR V reports (pages D-1 and D-2). The riskfactors derived from these reports are based on the hypothetical man. Thus, theydo not adequately account for inter-individual sensitivity to exposures ofradiation. There is no analysis of inter-individual sensitivity in the draftEIS, except the insufficient claim that conservative numbers and scenarios areused. This is not an analysis of inter-individual sensitivity. It is a way ofobscuring uncertaintiesagain. The DOE should recalculate risk factors using amore sophisticated analysis of inter-individual sensitivity among workers andmen, women, childrenit is also an issue for environmental justice. For example,the composition of the workforce at Pantex is 20 percent minority (see below formore comments about environmental justice).


The risk factors presented in the BEIRV report have been endorsed byboth national and international radiation protection organizations as the bestdescription that can be provided at this time of the risk of cancer resultingfrom a specified dose of ionizing radiation. These organizations include theNational Committee on Radiation Protection and Measurements and theInternational Commission on Radiological Protection. The risk factors utilizedin the EIS have also been endorsed and adapted by other federal regulatoryagencies including the Environmental Protection Agency and the NuclearRegulatory Commission. Details of the uncertainties in these risk factors,including inter-individual sensitivity is available in the following report: BEIRV National Research Council, "Health Effects of Exposure to Low Levelsof Radiation," National Academy Press, Washington, DC, 1990 (NAP1990).

RC: 14.167

Doc: HT17/77

The accident scenarios analysis presents the most optimistic view possible.All administrative control and safety programs are assumed to function properlyat all times (e.g., air locks). Numerous examples of malfunctioning orimproperly used safety and emergency response equipment and procedures,malfunctioning emergency back-up systems, human errors, et cetera have led toaccidents in a variety of industriessome of them highly regulated, such as thenuclear power industry, aircraft carriers, offshore oil drilling facilities,airlines, space travel (space shuttle), et cetera. In many cases, the failureswere of the type that were anticipated but they occurred in sequences orcombinations that were not, or the failure rates turned out to be higher thananticipated. Many of the failures can be associated with "humanreliability" issues (Tuler et al 1988, Tuler et al 1991, Tuler et al 1992,Kasperson et al 1995), and many...more.


See response to comment 14.123.

RC: 14.168

Doc: HT17/78

In the draft EIS there is no way to know how much attention was given tohuman error/reliability analysis in the evaluation of accident rates orconsequences. As I noted above, the document assumes that all emergencyresponse and administrative safety programs/control function at 100 percent atall times. Can the Agency provide data to support this claim? Do they havedata about the rates of incidentshuman errors in different tasks that arerelevant to this study? What is their definition of "recordable"(i.e., reportable) incidents? What is included in Table What arethe data for events which did not result in a lost worker day?


Human error/reliability was evaluated and is often the initiator formany of the scenarios addressed in the EIS. The document does not assume thatall emergency response and safety systems function at 100 percent at all times. Pantex-specific data, nuclear industry data, and general industrial data wereused to obtain human error rates for various tasks. Pantex Plant reportsoccupational injuries and illnesses in accordance with Title 29 CFR, Part 1904. As indicated in volume I, section 4.14, Table, not all recordablecases resulted in lost workdays.

RC: 14.169

Doc: HT17/79

The Agency should describe in detail its safety and emergency response plansand training programs for onsite employees and for offsite personnel (includingthose in the transportation system). Have any analyses/evaluations beenconducted on the reliability and effectiveness of response? Can they supplydata about the failure rates associated with the safety and emergency responseelements (mechanical and human)?


The safety and emergency response plans and training programs for onsiteemployees and for offsite personnel (including those in the transportationsystem) are voluminous, and inappropriate for verbatim inclusion in the EIS. Moreover, the conservative accident consequence assessments in the EIS ignoreworker and public evacuation. Hence, details pertaining to safety and emergencyresponse plans and training programs are not germane to the EIS human healthevaluations. Failure rates associated with the safety and emergency responseelements (mechanical and human) are used as the basis for the accident riskassessment in the EIS.

RC: 14.170

Doc: HT17/80

Has the DOE completed task analyses of the high risk tasks; e.g., assemblyand disassembly of pits and explosive components?


Detailed task analyses are completed on the assembly and disassembly ofeach weapon system. Pantex-specific data, nuclear industry data, and generalindustrial data were used to obtain human error rates for various tasksperformed at Pantex Plant.

RC: 14.171

Doc: HT17/81

Generally, how has the DOE studied and evaluated human error in the tasksdone at Pantex?


See response to comment 14.170.

RC: 14.172

Doc: HT17/82

In addition, the agency uses a baseline "activity level" of 2,000assemblies, disassemblies, testings, et cetera per year. They say that the mixdoes not matter when calculating impactswhich I presume means risks fromexposure from either incident free exposure or accident related exposure (page3-2). There must be a failure rate in these tasks. It might be small but it isnot zero. They may be initiating events for accidental exposures, or higher thannormal "incident free" exposures. My question is whether there is anyreason to believe that failure rates (human errors) in these tasks may bedifferent? Is it "harder" to take a weapon apart than to put ittogether? I think of a bike or car, where bolts are stripped, pieces sticktogether, get old, et cetera. Can this happen? The mix of "activities"will probably change as dismantlement occurs. Does the Agency havedisaggregated failure rate data for the different "activities"included in the operations done at Pantex? Produce the analysis showing thatthere are no differences in the failure rates associated with the differentactivities?


The mix of weapons operations refers to the relative portions of weaponassemblies and disassemblies. The risk from exposure is different betweenincident-free exposure and accident-related exposure.

There are differences between assembly and disassembly. Failure ratesfor the specific activities involved in the assembly and disassembly ofparticular weapon systems are classified. Bounding failure rates for theassembly/disassembly process were obtained from Pantex Plant safety documents.

RC: 14.173

Doc: HT17/83

Finally, I began this part by saying that the accident scenarios are alloptimistic scenarios in the sense that no (or no significant) exposures result.The Agency should go through the exercise and show us what might be the effectsof accidents that are not controlled perfectlywhat might be exposure pathways,exposure levels, and health effects of such a scenario? Even if the possibilityis small, we would like to see what the consequences are.


See response to comment 14.123.

RC: 14.174

Doc: HT17/84

As you say, risk is the product of probability of occurrence and magnitudeof consequences. What if worker exposure occurred because contamination didescape from air locks?


Consequences to involved and uninvolved workers are provided in volumeI, section 4.14.

RC: 14.175

Doc: HT17/85

What accidents have occurred at the plant? As shown in Table,what were these accidents? Can the DOE provide us with descriptions and anyresults of post-accident evaluations (including the methods of evaluation)? Whatworked well in containing them, and what did not? In other words, what featuresof the accident were not anticipated to occur together or with high frequency?


The Pantex Plant Safety Information Document (Pantex 1996a) providesadditional information on the accidents, incidents and off-normal or unusualoccurrences at Pantex Plant. This information provides the basis forPantex-specific accident and failure rates.

RC: 14.176

Doc: HT17/86

There is no system of community monitoring for contamination offsite? Thereis an implicit assumption that releases will only occur in controlled areas [or]that detection devices will observe every possible release. This does not seemto be a valid assumption.


Onsite monitors are placed to detect contaminates before offsite impactsoccur. Soil sampling is ongoing to detect historical contamination.

RC: 14.177

Doc: HT17/87

There is no analysis (as far as I remember right now) of synergistic effectsamong radiation exposures and chemical exposures and among chemical exposureswith different types of contaminants. The DOE should deal with this issue inthe EIS, citing and evaluating studies that address synergistic effects ofchemical exposures of different types. What analysis have they done to justifya claim that this is not a significant issue?


See discussion in section 1.3.10 of this volume regarding chemical andradiological synergism.

RC: 14.178

Doc: HT17/88

The DOE only addresses inhalation exposure. But this is a bit confusing. "Inhalationis the only pathway accounted for in the assessment of chemical and radiologicalAIRBORNE hazards from normal operations" (pg. 4-205). Does this mean thatthere are exposure pathways of non-airborne hazards? For example, throughgroundwater contamination? Are these included in the analysis anywhere? Likewise, are there other pathways in accidents (non-normal operations)? Arethese included in the accident analyses? How? What data do you have to supportthe claim that airborne hazards and inhalation exposure is the only significantpathway?


Additional details on long-term pathway issues have been added to volumeI, section 4.14.1.

RC: 14.179

Doc: CO-005/6

The entire approach to human health in the draft EIS is flawed. We are beingasked to comment on a document which seems to be driven by the goal ofreassuring the public that there are no health risks associated with the PantexPlant. It uses only optimistic scenarios of exposure, statistical methods thatobscure potential risks and problems, evidence used is one-sided, a verytheoretical presentation which suggests more exactness in scientific knowledgethan is supportable, and seems designed to lend credibility where it is notnecessarily due.


See response to comment 14.123.

RC: 14.180

Doc: CO-005/7

Moreover, the theoretical approach is difficult to wade throughit obscuresand hides assumptions and it is meaningless to public concerns because it isremoved from everyday life experiences (e.g., pg. D-2, brief attempt to explainindividual risk in terms of latent cancer fatalities).


See discussion in section 1.3.10 of this volume regarding radiologicalrisk factors.

RC: 14.181

Doc: CO-005/8

The data are one-sided. The use of prior studies and data in the draft EISpresent only one side of a scientific debate about the effects of low-levelionizing radiation. The [presentation is] very lopsided. Studies not citedsuggest that health effects, including leukemia, thyroid cancer, and multiplemyeloma, have been found in nuclear workers whose cumulative dose for theirtotal working years was between 2.5 [and] 5 rem (Geiger et al 1992; Gilbert1994; Kendall 1992; Kneale 1993; Wing 1991).


See discussion in section 1.3.10 of this volume regarding radiologicalrisk factors.

RC: 14.182

Doc: CO-005/9

On page 4-205 it is reported that the average ANNUAL dose to workers atPantax is 111 mrem. If we take a worker who is at the plant for 25 years, then111 mrem x 25 years = a cumulative dose of approximately 2.8 (2.775) rem. Thisvalue is within the range for which health effects were observed in thesestudies. Moreover, if we take the Pantex control level of 500 mrem/year for mostworkers and 900 mrem/year of weapons operation workers we get cumulative dosesover a 25-year working life of 12.5 rem and 22.5 rem, respectively. These valuesare all much higher than the levels at which health effects were observed inthese studies.


See discussion in section 1.3.10 of this volume regarding radiologicalrisk factors.

RC: 14.183

Doc: CO-005/11

Moreover, as the scientific uncertainty highlights, the standards used byEPA, NRC, and DOE are not protective standards. They are politically negotiatedstandards that allow workers and communities in the vicinity of a nuclearfacility to bear a higher cancer risk for the social benefits that are believedto come from the facility. These standards should not be used to suggest thatthere are safe doses of radiationthere are NO safe doses of radiation. This is acommonly agreed point at this time in the scientific community.


See response to comment 14.116.

RC: 14.184

Doc: CO-005/12

The Aquavella 1985 Study relies on a weak methodological approach and datasources (e.g., it compares workers to community at large). The critiques ofthis study are discussed in more detail in Dead Reckoning by Geiger et al 1992.


See discussion in section 1.3.10 of this volume.

RC: 14.185

Doc: CO-005/13

More about one-sided data. Cancer registry data are not a credible source ofdata for detecting radiation effects in communities surrounding nuclearfacilities (Sage 1994). This is a study that was done by Michael Sage, Directorof CDC/ATSDR. Cancer registry data in Texas are discussed in the draft EIS onpage 4-215.


Cancer risk data for the communities surrounding Pantex Plant were usedto provide a relative risk comparison between the cancer risks posed byoperations at Pantex Plant and the cancer risks from other causes. The effectsof radiation exposure are modeled on national and international recommendations.

RC: 14.186

Doc: CO-005/14

The draft EIS relies on inappropriate data to make risk estimates andcomparisons in the communities surrounding the Pantex plant. Again, the mostoptimistic evidence and methods. More rigorous studies are needed to moreeffectively estimate risksbetter exposure assessments, assessment of historicalreleases, and exposure pathways.


See response to comment 14.185.

RC: 14.187

Doc: CO-005/15

The draft EIS uses BEIR III and BEIR V reports (page D-1 - D-2). The riskfactors derived from these reports are based on the hypothetical man. Thus,they do not adequately account for inter-individual sensitivity to exposures ofradiation. There is no analysis of inter-individual senstivity in the draftEIS, except the insufficient claim that conservative numbers and scenarios areused. This is not an analysis of inter-individual sensitivity. It is a way ofobscuring uncertainties--again. I would direct the Agency to a growing body ofresearch literature on ways to address inter-individual sensitivity. The agencyshould recalculate risk factors using a more sophisticated analysis ofinter-individual sensitivity. This is not just necessary for inter-individualsensitivity among workers and men, women, children--it is also an issue forenvironmental justice. For example, the composition of the workforce at Pantaxis 20% minority.


See response to comment 14.166.

RC: 14.188

Doc: CO-005/16

Describe in detail the safety and emergency response plans and trainingprograms for onsite employees and for offsite personnel (including those in thetransportation system). What analyses/evaluations [have] been conducted on thereliabilty and effectiveness of response? Can DOE supply data about the failurerates associated with the safety and emergency response elements (mechanical andhuman)?


See response to comment 14.169.

RC: 14.189

Doc: CO-005/17

Have you completed task analyses of the high risk tasks; e.g., assembly anddissasembly of pits and explosive components? Generally, how has DOE studied andevaluated human error in the tasks done at Pantex?


See response to comment 14.170.

RC: 14.190

Doc: CO-005/18

The accident scenarios are all optimistic scenarios in the sense that no (orno significant) exposures result. Go through the exercise and show us what mightbe the effects of accidents that are not controlled perfectlywhat might beexposure pathways, exposure levels, and health effects of such a scenario? Evenif the possibility is small, we would like to see what the consequences are. Inyour words risk is the product of probability of occurrence and magnitude ofconsequences. What if worker exposure occurred because contamination did escapefrom air locks? What accidents have occurred at the plant? What were theseaccidents as shown in Table Provide us with descriptions and anyresults of post-accident evaluations (including the methods of evaluation). Whatworked well in containing them, and what did not? In other words, what featuresof the accident were not anticipated to occur together or with high frequency?


Duplicate comment. See response to comment 14.167.

RC: 14.191

Doc: CO-005/19

There is no analysis of synergistic effects among radiation exposures andchemical exposures and among chemical exposures with different types ofcontaminants. We ask that this issue be included in the EIS, citing andevaluating studies that address synergistic effects of chemical exposures ofdifferent types. What analysis have been done to justify a claim that this isnot a significant issue?


See discussion in section 1.3.10 of this volume regarding chemical andradiological synergism.

RC: 14.192

Doc: CO-005/20

The agency only addresses inhalation exposure. But this is a bit confusing. "inhalationis the only pathway acounted for in the assessment of chemical and radiologicalAIRBORNE hazards from normal operations" (page 4-205). Does this mean thatthere are exposure pathways of non-airborne hazards? For example, throughgroundwater contamination? Are these included in the analysis anywhere?Likewise, are there other pathways in accidents (non-normal operations)? Arethese included in the accident analyses? How? Provide the data to support theclaim that airborne hazards and inhalation exposure is the only significantpathway.


Details on alternate pathways have been added to volume I, section4.14.1.

RC: 14.193

Doc: PC-025/20

Also wetlands should be identified for the same reason. Like children andthe elderly, arent wetlands sensitive areas requiring analysis? Since Pantexplayas are points of recharge to groundwater, under an accident scenario, wouldnot 1,000 playas in the ROI pose a significant pathway to the groundwater? Ifan accident occurred, what is the maximum amount of plutonium, risk to thepublic, and other impacts to the groundwater from the playa pathway? What isthe impact if all groundwater in the ROI becomes contaminated with trace amountsof plutonium? Where are the nearest dairy cows? Should that be discussed dueto high risk pathway to small children?


Additional detail on alternative pathways has been added to volume I,section 4.14 of this document.

3.15 Aircraft Accidents

RC: 15.001

Doc: HT05/6

... On the airplane accident scenario, was that scenario based on theflight paths now? Or did you take into effect that the flight paths could bechanging when they get a new radar system out there at the Amarillo airport?

Will that show up in the final analysis, the final draft?


See discussion in section 1.3.11 of this volume.

RC: 15.002

Doc: HT05/7

I've heard that Delta [Airlines] no longer flies into Amarillo and thatAmerican Airlines has down-sized the aircraft that they're using. Does thishave an impact on the numbers that you have provided? Is it being considered infuture iterations of the model or what?


To our knowledge, a Delta Airlines shuttle continues to fly intoAmarillo. Continental Airlines discontinued service into Amarillo. AmericanAirlines used to fly MD-80s into Amarillo, but discontinued these in favor ofFokker 100s. This information will be accounted for in the RAMS data, but notnecessarily in the FAA airport operations data because of the four categoriesthis data is broken into. That is, although American Airlines replaced theMD-80s with Fokker 100s, they still constitute Commercial Air Carriers. Theonly difference that will be seen in the FAA data is whether or not AmericanAirlines increases or decreases its flights per day into and out of Amarillo. Future iterations of the calculation will take this into account.

RC: 15.003

Doc: PC-021/1

It is implied that the probability of an aircraft hitting a facility wouldbe unacceptable if it exceeded 10-7. DOT (FAA) Aircraft Systems Safety Analysestend to place events with probabilities greater then 10-7 in the category of "improbable"and require that such an event not create any hazard. If the probability is therange, 10-9, it is considered "highly improbable" and the event mayresult in a hazard but no loss of life. An event of probability, 10-13, isconsidered "extremely improbable." No event that would be consideredas "catastrophic" or resulting in the loss of life may exceed thisorder of magnitude in probability of occurrence. Since the perforation of orthe scabbing of a structure containing nuclear weapons material is considered ashaving the potential for causing an explosion, this event must be considered as"catastrophic."


The value of 10-7 has been chosen by the DOE as a bounding value foraircraft accident analysis. The selected frequency categories used in thePantex EIS are as follows:

· Anticipated (x ³ 10-2 per year)

· Unlikely (10-2 per year > x ³ 10-4 per year)

· Extremely Unlikely (10-4 per year > x ³ 10-6 per year)

· Not reasonably foreseeable (10-6 per year > x)

It can be seen that the value of 10-7 is on the fringes of the "notreasonably foreseeable" range. However, for conservatism, this value wasused as a boundary. In the context of the Appendix E text, the value of ">10-7"implies falling into one of the above four ranges. Also see discussion insection 1.3.11 of this volume.

RC: 15.004

Doc: PC-021/2

The characterization of mode of operations is much improved over that in theoriginal analysis, though I do have some question regarding the relative valuesof g. I find it somewhat surprising that the value for military aircraft islower than that for commercial aircraft. This is particularly troubling sincefighter, attack, and training aircraft tend to have a somewhat higher overallaccident rate.


The analysis used for the Pantex Draft EIS aircraft accident analysiswas that contained in the Draft DOE Standard (DOE 1995z) for "AccidentAnalysis for Aircraft Crash into Hazardous Facilities." The values usedfor the analysis came directly from this document. The values of g arepart of the Solomon model which has been eliminated in its use in the Final EIS. In-flight aircraft were analyzed using the new non-airport model.

RC: 15.005

Doc: PC-021/3

The impact angle used in the analysis is 15 degrees. This approach ignoresthe possibility of higher angle impacts such as those demonstrated by the UnitedAirlines Boeing 737 in Colorado Springs, the US Air Boeing 737 in Pennsylvania,the American Eagle ATR72 in Indiana, and more recently, the Valujet DC-9 inFlorida. (Incidentally, at least three of these accidents occurred during the "in-flight"phase of flight.)


See discussion in section 1.3.11 of this volume. Additionally, theFinal EIS uses guidance provided by the Draft DOE Standard (DOE 1996g) onaircraft crashes. This Standard uses even more conservative impact angles offive to seven degrees dependent on the flight mode and aircraft category. Itshould also be noted that the structural penetration calculations includedaircraft striking the structures via skidding into the walls as well as directhits onto the roofs. Direct high impact angle hits represent a small fractionof the risk.

RC: 15.006

Doc: PC-021/4

General aviation turbojets have wingspans of up to 90 feet.


The range of values listed in Table E.2.21 of volume II of the Draft EIScame directly from the Draft DOE Standard (DOE 1995z) for "AccidentAnalysis for Aircraft Crash into Hazardous Facilities." This value does notsignificantly affect the analysis results since the average weightedrepresentative wingspan for aircraft near Pantex was used, and maximum wingspanswere used for the other candidate storage sites. The Draft DOE Standard (DOE1996g) wingspans are listed in Table E.2.21 of the Final EIS.

RC: 15.007

Doc: PC-021/5

I question the accuracy of the stated equation for the speed of sound insoil. This is stated as:

Cs = {(Es á g) Ö r}0.5 where

Cs = the speed of sound in soil (ft/sec)

Es = the modulus of elasticity of soil = 470,000 lb/ft2

r = the density of soil = 130 lbs/ft3

g = the acceleration due to gravity = 32 ft/sec2 (actually, g = 32.174ft/sec2)

Using these values, I calculate the speed of sound in soil to be 340 ft/sec. I find this to be quite low in light of the Sea Level, ISA value for the speedof sound in air (1,116 ft/sec). Unfortunately, I do not have ready access toreferences regarding the values of Es and r.


Using the values provided, the speed of sound in soil does result in avalue of 340 ft/sec. An independent source was reviewed for application of thespeed of sound in soil and it indicated that the speed of sound in soil wasapproximately 39 percent of that in air. This value is dependent on the type ofsoil but shows the above overburden equation referred to by the commentor isapplicable.

RC: 15.008

Doc: PC-021/6

It should be noted that the 4,800 feet Mean Sea Level (MSL) ceiling for theprohibited airspace over the Pantex Plant equates to approximately 1,200 feetAbove Ground Level (AGL).


This has been corrected in the Final EIS.

RC: 15.009

Doc: PC-021/7

It is stated that helicopters have been omitted as a hazard "becausethey are forbidden from flying in the airspace over Pantex Plant and have littlepotential to penetrate facilities of interest." This is an incorrectstatement. Helicopters are prohibited from operating over the Pantex Plant ataltitudes of less than 4,800 ft MSL. They are free to overfly the plant athigher altitudes. Further, some helicopters operate at extremely high weightsand flight speeds. For example, let me submit the Sikorsky MH-53.


According to information obtained from the Amarillo Tower, helicoptersare prohibited from flying over the Pantex Plant at altitudes less than 4,800MSL (1,200 AGL). The only exception to this rule is the Southwestern PublicService (SPS) helicopter which does powerline inspection and maintenance. However, they must call the Tower for permission to do so. Information obtainedfor the Draft EIS was incorrect, and as a result helicopters were not consideredin the Draft EIS. Helicopters have been included in the Final EIS aircraftanalysis.

RC: 15.010

Doc: PC-021/8

There is a typographical error in which the Saab SF340 is referred to as theSF34.


In reading aircraft data from the RAMS data, some aircraft designatorsare abbreviated. It is our understanding that the SF340 and the SF34 are thesame kind of aircraft. The text has been modified in the Final EIS to readSF340.

RC: 15.011

Doc: PC-021/9

What category of operation do test flights by aircraft from the modificationand maintenance facilities at Amarillo International Airport fall under?


See discussion in section 1.3.11 of this volume. These flights areincluded in the RAMS data and are included in the FAA data as part of thetakeoff and landing operations at the Amarillo International Airport.

RC: 15.012

Doc: PC-021/10

RAMS data from 25 days in May 1995 were used to determine the spectrum ofoverflights on each high-altitude jetway. Since this data is recorded bycomputer, why was the sample only 25 days? What was the reasoning behind thechoice of May 1995? Was this period truly representative, or was this selectionmade as a means of weighting a particular result? Seasonal changes in both airtraffic and preferred routings could result in different answers.


At the time the analysis was completed for the Draft EIS, high-altitudeRAMS data from 25 days in May 1995 was all that was available. The non-airportmodel in the Draft DOE Standard (DOE 1996g) does not require this data.

RC: 15.013

Doc: PC-021/11

Are stated distances to airways the distances to the airway centerline or tothe edge of the airway. In general, federal airways extend 4 nautical miles toeither side of the centerline. As they are defined by the VORTAC's, at somedistances they may be somewhat wider than this minimum value.


The distances given are from the centerline of the airways to each ofZones 4 and 12. Airways are not considered in the Final EIS analysis.

RC: 15.014

Doc: PC-021/12

All commercial operations from Runway 04 were assumed to be bound for Dallason the 105-degree airway. What about test flights from the maintenance andmodification facility located [at the] Amarillo International Airport?


This conservative assumption was based on information obtained from theAmarillo Tower concerning the trend of aircraft taking off on Runway 04 tofollow routes bordering the plant along Highways 60 and 683. With the issuanceof the new Draft DOE Standard (DOE 1996g), there is no consideration of airways,so this assumption is not needed. See discussion in section 1.3.11 in thisvolume. The test flights are included in the RAMS data and are included in theFAA data as part of the take-off and landing operations at the AmarilloInternational Airport.

RC: 15.015

Doc: PC-021/13

Again, I am surprised that the value of g for military aircraft,particularly the small sub-category, is lower than that for air carriers. Again, combat and training aircraft tend to have a higher accident rate thanairliners.


The analysis used for the Pantex Draft EIS aircraft accident analysis isthat contained in the Draft DOE Standard (DOE 1995z) for "Accident Analysisfor Aircraft Crash into Hazardous Facilities." The values of g arepart of the Solomon model which has been eliminated in its use in the Final EIS. In-flight aircraft were modeled using the new non-airport model contained inthe Draft DOE Standard (DOE 1996g).

RC: 15.016

Doc: PC-021/14

[The] general aviation turbojet wingspan is too small. Examples of up to 90feet are easily found, especially in the ranks of new products.


The values listed in Table E.3.1.42 of volume II of the Final EIS areboth Draft DOE Standard (DOE 1996g) and average weighted representativewingspans for aircraft flying around Pantex Plant.

RC: 15.017

Doc: PC-021/15

Airliner landing skid distance is given as 1,860 feet while general aviationturbojet landing skid distance is quoted as 37 feet. The landing speeds of bothclasses of aircraft are comparable so the skid distance must be treated ascomparable. In fact, any general aviation aircraft that only skids 37 feet musthave either been moving very slowly or impacted something very solid. With a15-degree impact angle, this is unrealistic and misleading.


The values listed in Table E.3.1.42 of volume II of the Draft EIS camedirectly from the Draft DOE Standard (DOE 1995z) for "Accident Analysisfor Aircraft Crash into Hazardous Facilities." They have been updated inthe Final EIS per the latest version of the Draft DOE Standard (DOE 1996g).

RC: 15.018

Doc: PC-021/16

Impact velocities stated in table are unrealistic. A general aviationturbojet moving as slowly as 152 ft/sec (90 knots) is indeed in serious trouble. These aircraft are fully as fast as airliners and many military aircraft. Ifan airliner can impact the facility at 422 ft/sec (250 knots), it must beassumed that general aviation turboprops and turbojets can as well. Theseaircraft are certified to the same regulations (FAR Part 25) as air transportsand tend to operate in a similar manner.


The values listed in Table E.3.1.47 of volume II of the Draft EIS camedirectly from support material for the Draft DOE Standard (DOE 1995z) for "AccidentAnalysis for Aircraft Crash into Hazardous Facilities." They have beenupdated per the latest version of the Draft DOE Standard (DOE 1996g). Thissupport material is listed in the references at the back of Appendix E.

RC: 15.019

Doc: PC-021/17

Stated probabilities for damage exceed guideline maximum by two orders ofmagnitude.


The probability of damage is thus in the "extremely unlikely"range. The guidelines quoted by the commentor are FAA guidelines. Thisanalysis used guidelines provided by the Draft DOE Standard (DOE 1996g).

RC: 15.020

Doc: PC-021/18

As you can see, there are still a rather large number of inaccuracies in theanalysis. I recognize that the Aircraft Accident Analysis has been performed inaccordance with the guidelines presented in the Draft DOE Standard, "AccidentAnalysis for Aircraft Crash into Hazardous Facilities." However, it is mycontention that this methodology itself is still lacking in a number of areas.


The Draft DOE Standard (DOE 1996g) is in the process of being finalized. Based on the concerns raised at several of the public meetings, it has beenrevised accordingly.

RC: 15.021

Doc: PC-021/19

I cannot dispute the contention that the likelihood of an aircraft crashinginto a facility containing nuclear material is remote. My question for you nowis, what if the unlikely happens? If a light aircraft impacts an earthberm-protected igloo after sliding off most of its speed, the answer is mostlikely "nothing." Alternatively, if the aircraft is large and/orimpacts the structure at a high velocity, the potential exists for a catastropheof tremendous proportions.


While it is true that a large aircraft has the potential to damage afacility, this does not necessarily result in a release of radioactive materialssince many of the critical Pantex structures have super stout construction andearth overburden. However, in the structural analysis methodology,consideration of super stout structures, using the given equations, results in aconservative structural assessment. See volume I, section 4.15.7, for adiscussion of additional levels of conservatism in the Final EIS.

RC: 15.022

Doc: PC-021/20

Moreover, the analysis only predicts the probability of and partial damagepotential of an accident. No attention is given to the scenario of anintentional crash into the facility by a suicidal pilot. Where once this wouldhave been unthinkable, the events of recent years have shown that theunthinkable can and does happen. After all, who would have anticipated thebombing of the World Trade Center, the bombing of a Federal office building orthe suicide of a distraught student pilot by crashing his airplane into theWhite House. As I pointed out in my comments on the Aircraft Accident Analysis,the prohibited airspace over Pantex extends only up to approximately 1200 ftabove ground level. Under these circumstances, even basic single-engine generalaviation aircraft beginning at a cruising speed of 90 knots (152 ft/sec) can gofrom legal flight to being imbedded in a hazardous facility in less than 8seconds. There is simply no way to stop such an attack without undue danger toall air traffic in the area.


The Draft DOE Standard (DOE 1996g) states that it "does not includeconsideration of malicious acts (e.g., sabotage, terrorism, and war). Theavailable data on aircraft crashes do not support statistical assessments ofsuch acts. Further, such acts are not unique to aircraft, nor are theyinitiated by failures and errors associated with aircraft."

RC: 15.023

Doc: PC-021/21

Further, the recent Valujet accident in Florida leads me to raise thequestion of emergency use of the runways at Amarillo International Airport. Theproximity of Amarillo to the major East-West routes and the availability of anextremely long runway makes for an attractive option in the event of anin-flight emergency. In such an event, an aircrew is permitted to waive allregulations in the attempt to perform a safe landing. With the prevailingsoutherly winds, and the location of the Pantex plant, the chances [of] anaircraft making an overflight of the hazardous facilities while already in adegraded state are extraordinarily high. Will the facilities at Pantex swallowand contain a crashing airliner as effectively as the Florida Everglades?


The Draft DOE Standard (DOE 1996g) is applied based on normaloperations, as well as emergency conditions that may occur to aircraft in thevicinity of a given facility. These emergency conditions are accounted forstatistically in the probability density function (pdf). The probability ofhitting a facility is calculated based on these operations. The scenariodescribed above would not be applicable to Pantex due to the difference intopography.

RC: 15.024

Doc: PC-021/22

The presentation of pages of probabilities does little to address the "Whatifs" of the hazard presented by normal aircraft operations in the vicinityof hazardous facilities. Perhaps of more importance, these probabilities donothing to address the possibility, though remote, of malicious intent. Further, normal aircraft safety analyses tend to address only the hazard to theaircraft and its occupants, with some consideration given to the event thatinjury might occur if the aircraft or its components strikes individuals on theground. It is important to note that only limited damage to other than theaircraft itself is addressed. In the event that an aircraft hits and perforatesa facility containing fissile material for nuclear weapons the potential fordamage is not limited to the immediate vicinity. In this case, we are dealingwith the potential for widespread impact, including regions far downwind of theaccident site.


The Draft DOE Standard (DOE 1996g) states "The focus is onanalyzing the risk posed to the health and safety of the public and onsiteworkers from a release of hazardous material following an aircraft crash. Thus,this is not a standard on aviation safety and does not consider the risk to theoccupants of the aircraft, the risk to individuals inside a building affected bythe crash into the building, or the risk to other individuals on the ground,either within or outside a facility boundary, who might be directly impacted bythe crash... This standard does not include consideration of malicious acts(e.g., sabotage, terrorism, and war). The available data on aircraft crashes donot support statistical assessments of such acts. Further, such acts are notunique to aircraft, nor are they initiated by failures and errors associatedwith aircraft." Consequence analysis was completed for fissile materialsrelease, regardless of the initiating event. This analysis can be found involume II, section D.4.2.

RC: 15.025

Doc: CO-008/1

Page E-3, E.2.1. What is the relationship between the "j" valueand the probability of the aircraft penetrating the magazine?


The only relationship between the "j" value and theprobability of the aircraft penetrating the facility is the fact that the "j"index divides the aircraft into categories for use in the four factor formulafor determination of hit probability. The category j = 1 "Commercial: AirCarrier" will have a larger engine weight and diameter than the category j= 6 "General: Fixed-wing, reciprocating, single engine" and thus mayhave the potential to penetrate a given facility.

RC: 15.026

Doc: CO-008/2

Page E-3, E.2.1. Why is the term "scabbing" used on page E-3,paragraph 1, when the term "spalling" is used on Page 4-249 todescribe the same phenomenon? Please explain the different terms.


Spalling is a local damage that signifies the ejection of targetmaterial from the front face of the target. Scabbing is a local damage thatsignifies the peeling off (or ejection) of material from the back face of thetarget. The terminology on page 4-249 of volume I of the Draft EIS wasincorrect and has been corrected in the Final EIS.

RC: 15.027

Doc: CO-008/3

Page 4-241, Paragraph 3. What is the monitoring procedure and the maximumtime frame the magazines remain open?


Once magazines have undergone their periodic inventory check, they arelocked up for 18 months. During this inventory, the doors to the facility areonly open for a few hours. During the lockup time, the doors are monitoredthrough alarms as to unauthorized entry. Limiting Condition of Operation (LCO)information in the Zone 4 SAR states that only three magazines are allowed openat one time.

RC: 15.028

Doc: CO-008/4

Page 4-241, Paragraph 3. Do pilots flying at night use the Pantex lights asa landmark, instead of using the [VORTAC]?


All pilot training programs must be approved by the FAA and flightinstruction must be performed by an FAA licensed instructor. These flighttraining programs teach, among other things, fundamental techniques of flyingand navigation as well as the rules of flight. All flights must be performed inaccordance with either Visual Flight Rules (VFR) or Instrument Flight Rules(IFR). Both sets of rules govern flight at night, since the distinction isheight of cloud ceiling and visibility (i.e., distance one can see) rather thanwhether it is day or night.

If a pilot were flying at night under VFR conditions, one would expectthe pilot to take advantage of the lights of the Pantex Plant in the same way heor she would take advantage of other landmarks such as the lights of theAmarillo International Airport, lights of the City of Amarillo and othercommunities, lights of the prison, etc. That would be to use the spatialpattern of lights (and any unique aspects of particular light sources) asnavigation reference points to determine ones position and enable the pilot toeither confirm progress along the desired course or to make corrections tointersect the desired flight path. It should not be inferred that because thelights of Pantex (or any other visible location) are used as reference points,that the aircraft then flies over them. Rather, the lights are used to help thepilot mentally envision where the aircraft is in relation to where the pilotwants to be. It should also be noted that lights can be seen from greatdistances at night with the exact distance dependent upon the atmosphericvisibility and aircraft altitude (above ground level at that point in time. Typically, under normal VFR conditions in the vicinity of Amarillo, the rotatingbeacon and the high intensity approach lights of the Amarillo InternationalAirport would be visible from much further than 10 miles. Thus, under theseconditions, there would be no need for a pilot to fly over the Pantex Plant orVORTAC as a means of finding his or her way to the airport for a landing.

If a pilot were flying at night under IFR conditions, one would notexpect a pilot to use Pantex Plant as a landmark. Instead, the pilot would relyupon instruments inside the cockpit to navigate from point to point. Since thelocations of cities and other ground installations such as the Pantex Plant donot appear on IFR navigation charts, trying to see and use the lights of Pantexas a navigation reference would be pointless. Instead, the pilot would seek tofly along the centerline of a particular directional signal from an FAA radionavigation facility, such as the Amarillo VORTAC.

RC: 15.029

Doc: CO-008/5

Page E-5, E-2.2. Why is the 15-degree impact angle used in the analysis andthe possibility of higher angle impacts ignored. The Value Jet DC9 in theEverglades had an impact angle of about 75 degrees.


See discussion in section 1.3.11 of this volume regarding angle ofimpact.

RC: 15.030

Doc: CO-008/6

Page E-8, E-3.1, Paragraph 1 and Page E-11, E-3.1.2. Please add thestatement, "The 4800 feet Mean Sea Level ceiling over the Pantex Plantequals to only 1200 feet above ground level."


Correction has been made in the Final EIS.

RC: 15.031

Doc: CO-008/7

Page E-11, E.3.1.2. Why state that helicopters are "omitted" as ahazard because they do not fly over the plant? Neighbors observe them flyingover the plant regularly. Helicopters often operate at high weights and highspeeds.


See response to comment 15.009.

RC: 15.032

Doc: CO-008/8

Page E-11, E.3.1.2. Are aircraft or post maintenance operational testflights from modification and maintenance facilities at the Amarillo Airportincluded in the report? These planes tend to circle over the plant repeatedly.


See discussion in section 1.3.11 of this volume regarding AmarilloInternational Airport operations.

RC: 15.033

Doc: CO-008/9

Page E-15, 3.1.3, Paragraph 1. Why were only 25 days in May, 1995, used? To give a more accurate picture of over-flights, why not use 30 days, 60 days, 6months?


See response to comment 15.012.

RC: 15.034

Doc: CO-008/10

Page E-15, 3.1.3, Paragraph 1. Do the distances of Federal airways vary?


The widths of the Federal airways do vary. The high altitude beaconbeam is projected upward from the ground, and it expands with altitude.

RC: 15.035

Doc: CO-008/11

Page E-15, 3.1.3, Paragraph 1. Are distances measured from the centerlineor from the edge of the [VORTAC]? How far from the centerline do they extend?


The distances given are from the centerline of the airways to each ofZones 4 and 12. An airway model is not used in the Final EIS.

RC: 15.036

Doc: CO-008/12

Page E-15, E.3.1.3. It is a false assumption that all commercial operationsfrom Runway 04 are always bound for Dallas on the 105-degree airway?


This conservative assumption was based on information obtained from theAmarillo Tower concerning the trend of aircraft taking off on Runway 04 tofollow routes bordering the plant along Highways 60 and 683. With the issuanceof the new Draft DOE Standard (DOE 1996g), there is no consideration of airways,so this assumption is not needed.

RC: 15.037

Doc: CO-008/13

Page E-15, E.3.1.3. How many test flights for the modification andmaintenance facilities at the airport use Runway 04?


See discussion in section 1.3.11 of this volume regarding AmarilloInternational Airport operations.

RC: 15.038

Doc: CO-008/14

Page E-30, figure E.2.2-1. General aviation turbojet wingspans of up to 90feet are common now, particularly among newer aircraft. Why are they notincluded?


See response to comment 15.006.

RC: 15.039

Doc: CO-008/15

Page E-33, Table E.3.1.4-2. The skid distance of airliners and turbojetsare comparable. Airliners use 1860 feet, but 37 feet is used for generalaviation turbojets. That being the case, a higher angle impact would beexpected. The 37 feet at a 15-degree angle is unrealistic and misleading. Please reevaluate and define the aircraft categories and the skid distances ofgeneral aviation turbojets. Also, be consistent within the correlating tables,i.e. E.2.2-1 and E.3.1.4-2.


The values listed in Table E.3.1.4-2 of volume II of the Draft EIS camedirectly from the Draft DOE Standard (DOE 1995z) for "Accident Analysis forAircraft Crash into Hazardous Facilities." Since turbojets are not thedominant risk, this value does not affect the analysis results. The Final EISuses the Draft DOE Standard (DOE 1996g) which has updated skid distances.

RC: 15.040

Doc: CO-008/16

Page E-22, E.3.1.6, Paragraph 2. Is the crash scenario in [the] EISdifferent from that in Storage and Disposition PEIS? If it is, please explainwhy.


Yes, the crash scenario is different from that in Storage andDisposition PEIS. It is explained in volume I, section, that if any ofthe storage alternatives associated with this PEIS were implemented, there wouldbe a change in the aircraft crash probability. Any of these alternatives wouldinvolve the removal of all pits from Zone 4, which would reduce the aircraftaccident probability. For impact analysis, see the Final PEIS.

RC: 15.041

Doc: HT13/54

When you did your aircraft crash analysis from Pantex, you assumed it wouldbe in what kind of container?


To elaborate on the response given at the public hearing, in the DraftEIS aircraft analysis, the ALR8 container was assumed. The AT400A would providemuch more protection than the ALR8, thus the analyses presented areconservative.

RC: 15.042

Doc: HT12/31

... a large fraction of the accident analysis is directed towards airplaneaccidents airplane crash dispersing material. And you go through that atSavannah River, which is very improbable and low consequence should it happen,and you consider that a bounding accident. I question whether it is in fact abounding accident for a Class I facility like the P-Area reactor. I don't knowthat you've analyzed the bounding accidents.


The aircraft crash scenario at the Savannah River Site is not a boundingaccident for the P-Reactor. As is stated in the Final EIS, the probability ofaircraft crash into the P-Reactor was calculated as 1.2 x 10-6 for all types ofaircraft using the methodology outlined in the Draft DOE Standard (DOE 1996g). The probability of releasing material from P-Reactor, given the hit, wascalculated as ² 9.2 x 10-9.

RC: 15.043

Doc: PC-024/12

Page 5-10, left column, Section, Aircraft Accidents, 1st paragraph. ...The airspace [over NTS] is now highly restricted due to the past nucleartesting program and the activities of the surrounding U.S. Air Force's NellisAir Force Range (NAFR). This may not remain so if there are major changes inthe operating status of these facilities [that] are now under review inrespective EISs.


The issue of restricted airspace over NTS was revisited in the FinalEIS.

RC: 15.044

Doc: CO-006/1

The 1994 "Finding of No Significant Impact" arising from theEnvironmental Assessment found an airplane crash/accident occurring at Pantex tobe an "incredible event" not justifying the preclusion of additionalstorage at Pantex. Even so, the plant subsequently worked with the Departmentof Defense and the FAA to reduce flights paths over Pantex, and took other stepsto ameliorate the situation. However, the Draft EIS does not account for thereduced flights thereby exaggerating the probability for airplane accidents atPantex and their resulting impacts, and, incredibly, increases the probabilityof a crash from the 1994 "FONSI." In the recent hearings, Nan Foundsresponded to this concern by saying that DOE is formulating its own analysis notdependent on FAA data, but also stated there were serious problems with DOE'sanalysis, which would be addressed. In its initial analysis, DOE is ignoringnot only credible work already completed, but also the obvious reduction inaccident potential for use in determining the ES&H of siting new functionsat Pantex. This undermines the perceptions for fair and equal criteria for usein accurately comparing the various sites under consideration. We urge DOE tocorrect the analysis and avoid the wrongful preclusion of Pantex forconsideration of additional functions.


See discussion on aircraft crash in section 1.3.11 of this volumecomparing results of the previous analysis.

RC: 15.045

Doc: HT15/1

... I pose a question for DOE. Why in the prepared draft environmentalimpact assessment did the analysis of aircraft accidents the fourfactor analysis? [I] request that, before the final EIS is published,...theprobability risk assessment be conducted.


The aircraft analysis did cease with the four factor formula per se. However, the structural analysis results in Appendix E of volume II were used todetermine the release probability. These release probabilities were then usedin the Human Health sections to determine risk.

RC: 15.046

Doc: HT15/2

The analyses that have been done have been done on the basis of historicaldata. And the purpose of that analysis is to predict the likely impact on thefuture operations at Pantex. We know the future of some of the risk factors inthe aircraft accident rating. We know, for example, that GPS approaches alreadyexist, so some aircraft are now flying different routes. We know that the T-37flights from Reese Air Force Base ceased this month. And we know that the T-37flights, T-38 flights, and the B-1 flights from Reese will cease in December. So we know a number of the aircraft, that in the four factor model have driventhis outcome of about 4 x 10-5 for probability of an aircraft accident in ayear, will not exist in the future. And I recommend that in the final impactanalyses, those things that we know be included in the analysis so that we canall together look at the most accurate possible aircraft accident prediction.


As it stands, the Draft DOE Standard (DOE 1996g) does not allow for theconsideration of Global Position System (GPS) approaches and aircraft flyingdifferent routes. Also, until the RAMS data can reflect the change in thesemilitary aircraft, and until the Federal Aviation Administration (FAA) airportoperations data reflect the change, there is no way to incorporate the changeinto the model and apply it to Pantex Plant. These changes would reduce therisk at Pantex Plant and therefore the EIS is conservative.

RC: 15.047

Doc: HT15/3

In the draft standard appendix, it [discusses] the generic crash rates foreach aircraft category and subcategory [according to] accident reports publishedby the FAA in the RSD and by the United States military craft. ...You don'treference that published data. Is that data available and can we get a copy ofthat data?


The information is included as references in the "Data DevelopmentTechnical Support Document for the Aircraft Crash Risk Analysis Methodology".

RC: 15.048

Doc: HT15/4

You said the evaluation techniques used to estimate crash rates aredocumented in References 1 and 2. But those references are also in the draftand they're not available to us here.


This information is located in the Technical Support Document, which followed approximately two months after the release of the Draft DOE Standard(DOE 1996g).

RC: 15.049

Doc: HT15/5

The methodologies that you used to convert FAA or military accident datainto crash probability [estimates]. Is that methodology available for ourreview?


See response to comment 15.048.

RC: 15.050

Doc: HT15/6

... Until we've had a chance to look at your data and an opportunity to doanalysis, how do we know that the crash probability distribution or the crashrates per landing probabilities reflects military operations, other militarypeople, military pilots [in] this analysis?


See response to comment 15.048.

RC: 15.051

Doc: HT15/7

Were you able to determine the small military operations that are actuallyfrom Reese Air Force Base?


The number of small military operations from Reese Air Force Base couldnot be determined separately, but the total number of small military aircraftwas determined.

RC: 15.052

Doc: HT15/8

The initiative Tom Williams spoke about in the reduction initiative, is thattaken into account in your application to the standard in the EIS or will it?


See discussion in section 1.3.11 of this volume. Additionally, a briefstatement in volume I, section, discusses a previous analysis of therelative risk reduction associated with the overflight reduction measures.

RC: 15.053

Doc: HT15/9

... "Small military [aircraft] tends to be the controlling hitprobability in the environmental impact statement. [Since] there's such a widevariety of aircraft types, why can't we actually do the analysis subcategory. Why can't we actually identify individual aircraft types and use available crashrates?


This was done for large and small military crash rates in the Final EIS,and it did not change the results more than five percent.

RC: 15.054

Doc: HT15/11

... We've talked several times this morning about the safety factors. Thesafety factors are there and they're not quantified. Is it possible to producea document that says this is our best estimate and this is the uncertainty thatremains in the assessment?


The authors of the Draft DOE Standard (DOE 1996g) indicated that thiscould not be done.

RC: 15.055

Doc: HT15/12

Since these numbers as point estimates will be used to make your decision, Ithink it's important that we be able to tell the senior decision-makers when wehave a lot of confidence in a number and when it's sort of a fuzzy number. Whenyou stay conservative, you create another problem. If I focus exclusively onone risk in life to the exclusion of others, I can bring that risk to very nearzero, but my risks in other areas go up.


For the Final EIS an effort was made to characterize the level ofconservatism inherent in the aircraft crash analysis.

RC: 15.056

Doc: HT15/13

Given the limited availability of the final analysis numbers, I find it verydifficult to try to guess what the impact might be in the refinement of thestandard. And I haven't heard this morning any kind of estimates as to whetheror not the refinement of the standard and the supporting documents might providesome clarification on this fuzziness Dr. Rock talked about, this conservatism. Is it generally agreed upon that there will be some reduction in that numericalrisk probability or is there any kind of feeling that anyone has on this?


Due to the changes made in the Draft DOE Standard (DOE 1996g) and theadditional level of detailed analysis, the risk results were shown to decrease. For the Final EIS an effort has been made to characterize the level ofconservatism inherent in the aircraft crash analysis.

RC: 15.057

Doc: HT15/14

That does provide the decision-maker some measure of comfort, if you will,in the conservatism of the numbers, but it does the exact opposite to the localcitizens. It provides them [with] a sense that the plant may not have been assafe as indicated over all the years that it's been in existence, which I don'tbelieve is the case. I believe that there's a point somewhere in between thatis more like the real answer to this problem. And that needs to be stated.


See discussion in section 1.3.11 of this volume comparing the results ofthe previous analysis.

RC: 15.058

Doc: HT15/15

... We're looking at two and a half months...for the information to beavailable to do those calculations and present that data. There won't be enoughtime to look at that and to say we accept this or we agree with this. It reallyplaces the state reviewers in a difficult position at this point. I think it'simpossible, actually. And I'm wondering about the date that the EIS is driven[toward]...I think [there is] some question as to what dates they [EIS and othertwo PEISs] will be available.... Are they on track? Is this still concrete oris there a possibility that we might allow for more comprehensive review of theinformation to provide the level of certainty...


This comment was made prior to the availability of the Draft DOEStandard (DOE 1996g) for Aircraft Crash Analysis and its associated technicalsupport documentation. Subsequently, the State of Texas formally requested anextension of the review and comment period for the aircraft crash analysis. Atthe time of this response, the Department had not reached a decision regardingthe request for extension. As of July 22, the Draft Standard (DOE 1996g) wasmade available. To maintain the schedule for the Final EIS, the State of Texasreviewers were provided copies of the Draft Standard and invited to participatein the final analysis.

RC: 15.059

Doc: HT15/16

What we want is...accurate information in the EIS. And if that calls for adelay in order to get the right numbers in there, then we are going to formallyrequest that the site-wide EIS delay until those right numbers are clear.


See response to comment 15.058.

RC: 15.060

Doc: HT15/17

If I hear you correctly, you're saying that you are driven by a deadline. And if later information comes in after that deadline you'll make thoseadjustments. And what we're saying is we're not bound to that deadline. We'drather have the right information. And if that takes a couple of months, we'rewilling to move that deadline back.


See response to comment 15.058.

RC: 15.061

Doc: HT15/18

So it will give a range and best estimate and worst case estimate, and ifwe're really lucky, the lowest accident estimate? If you only put it in theintroduction and you don't put it with the numbers so that the numbers areself-evidentall of us have had enough experience with the mediaI understand theheadline will lead to an incorrect assumption.


This comment pertains to the Draft DOE Standard (DOE 1995z) and not tothe Draft EIS. Due to the changes made in the Standard and the additional levelof detailed analysis, the risk results were shown to decrease. For the Final EISan effort has been made to characterize the level of conservatism inherent inthe aircraft crash analysis.

RC: 15.062

Doc: HT15/19

... I want to thank the DOE for the hard work on reducing and minimizingthe risks, to the extent possible. The committee that Tom Williams has workedon changed the approaches to the airport. But to build on the last commentthere, I'm afraid that in a very important process like an EISprocess,...(inaudible) and should be. I'm reminded somewhat of the scientificinformation that was put out by groups that later proved incorrect, like a foodscare abut eggs are good for you or bad for you, whatever. We get these maybepresumptive announcements about the risk factor that don't concur necessarilywith previous ones and they've not undergone the type of scrutiny that goodscience work demands. And that is what the State of Texas is asking for today,is to try and do that kind of peer review based on documents that will be comingin in the future. Going back to meet the consistency, people need to understandwhat the risks are and grasp that, including the new level of conservatism.... The accumulative effect of that [conservatism] changes the number radically fromwhat was the risk published in previous studies. I think there needs to be, asDr. Rock mentioned,...annotation in the document itself if you're going toremain fixed on those numbers. And I think the public deserves a very goodexplanation of why this number may not square with previous numbers, because thenumber of planes flying over there and the types of planes hasn't changed.


See discussion in section 1.3.11 of this volume comparing the results ofthe previous analysis.

RC: 15.063

Doc: HT15/20

If you know that steps are being taken to minimize that risk or the numberof overflights over Zone 4 in the future, maybe there should be a number forwhat the risk will be in those outcomes if it is, indeed, reduced throughmitigation steps. And I think those are things that could serve the public welland will make them feel more comfortable.


See discussion in section 1.3.11 of this volume regarding the AmarilloInternational Airport operations.

RC: 15.064

Doc: HT15/21

... I guess the only comment I had is [that] the numbers look very muchdifferent than they did in past studies. And what I'm hearing from you is[that] really things are extraordinarily conservative and minimized, but that'snot what's conveyed in the text. ...Maybe there's some way to convey that moreclearly in the text.


See discussion in section 1.3.11 of this volume comparing the results ofthe previous analysis.

RC: 15.065

Doc: HT15/22

... where you referred to the Zone 4 overflight work initiativesquantifying the results, does that mean this would be Volume 1? The initiativesare described in section, but there's no numbers applied there. There's no reduction, I guess, in the estimates.


The 82 percent reduction from the Overflight Working Group initiativesis documented in volume I, section 4.15.6. It is estimated that implementationof the MOU, the offset localizer, relocation of the VORTAC and 65 percent use ofthe GPS will result in an 82 percent cumulative risk reduction. This 82 percentreduction was estimated using the Solomon Model.

RC: 15.066

Doc: HT15/23

... It looks like there was a whole year that you were able to drawinformation off of, April 95 to March 96. [Why did you use] 244 days instead of365?


The Draft EIS analysis used one year (1994) of FAA data to determine thenumber of airport operations and 76 days of RAMS data to determine therepresentative wingspans, engine weights, and diameters. For the Final EIS, sixand one half years (January 1990 through June 1996) of FAA data were reviewedand the maximum number of aircraft for the four categories collected (AirCarrier, Air Taxi, Military, and General Aviation) was used. To characterizethe representative wingspans, engine weights, and diameters, RAMS data fromJanuary 19, 1995 to January 18, 1996 was collected. For this time period 330 of365 days of data were collected. The remaining 35 days were not available dueto the equipment being moved or the RAMS system was not in operation. Themissing 35 days would not change the results of the analysis. If 1995 FAAoperations data are used instead of the maximum data, the probability of hittinga facility is reduced by 15 percent.

RC: 15.067

Doc: HT15/26

The other observation I'd like to make is that statistics are a fascinatingthing. They are not a solution. They are no guarantee. So the aircraft crashprobability to be quite low is one thing. But it is that such things don'thappen can happen.


The comment author is correct. The Final EIS uses the best availablemodel and data. The Department believes that the risks are quantified withsufficient accuracy to allow decision makers to make correct decisions.

RC: 15.068

Doc: HT15/27

I think the most impressive thing to me are the mitigation efforts that theDepartment is undertaking, as well as made. I want to know, is it possible thatthe Department of Energy will then stop those mitigation efforts and we will nottry to move aircraft from flying over the plant.


The DOE is committed to the aircraft risk reduction issue. Themitigation measures will proceed regardless of the values presented in the EIS.

RC: 15.069

Doc: HT15/28

One of the effort of Pantex in moving overflights further toward thenorthwest corner of the plant, I can't help but observe that's where thenuclear reactor might be and that there are other facilities that are going tohave to be taken into account so that we know this is considered under thisaircraft crash analysis versus the aircraft analysis that related to the currentEIS.


The risk of this potential facility to aircraft will be evaluated intier NEPA documents to the Storage and Disposition of Weapons-Usable FissileMaterials PEIS should it become necessary.

RC: 15.070

Doc: HT15/29

... There are those times when there are accidents that do happen and thatare beyond the control of any of the mechanical problems that possibly could gowrong with an aircraft. And this was just an issue that we were wondering if ithas been factored in and how it was going to be factored in.


In this analysis, mechanical failure is one of the initiators consideredin the aircraft accident analysis. Mechanical failure contributors arereflected in the crash rates presented in the Draft DOE Standard (DOE 1996g).

RC: 15.071

Doc: HT15/30

... Since there are maintenance and modification of facilities at theAmarillo Airport, there are planes that are out on test flights and they do alot of circling. And we wondered were there considerations that these are notaircraft that are in tip-top flying shape the document.


See discussion in section 1.3.11 of this volume regarding the AmarilloInternational Airport operations.

RC: 15.072

Doc: HT15/31

I think that where we really are having difficulty with this on test flightis, to our knowledge, they are not all the time actually perfect aircraft thatare taking off. And I do appreciate this thing that they have to be in acertain condition. But that does not mean they do not have a problem at thetime of test flight. And these considerations, we thought, needed to be broughtout in the document.


See discussion in section 1.3.11 of this volume regarding the AmarilloInternational Airport operations.

RC: 15.073

Doc: HT15/32

I'd like to commend DOE and the FAA in their attempts to alleviate some ofthe concerns of the citizens on the probability of airplane crash in Zone 4 andZone 12. I hate to show my ignorance in this, but could you, in plain English,tell us what the probabilities of a crash are? Is it one in a million? Inprevious studies that number was quoted around. Why has that increased? Doesthat take in those hit probability factors?


See discussion in section 1.3.11 of this volume. Additionally, theprobability of an aircraft crash into Zones 4 or 12, as calculated in the DraftEIS, is 4 x 10-5 which is 40 in a million. The probability of an aircraftcrash into Zones 4 or 12, as calculated in the Final EIS, is 3.1 x 10-5 which is31 chances in one million. The corrected analysis, as well as other historicanalyses, all agree that the aircraft crash hit probability for Pantex Plant isin the low to mid 10-5 range (approximately 10 to 40 chances in one million peryear that an aircraft will hit Zones 4 or 12). It should be noted that hitprobability is not an accurate representation of risk. Risk involves anaircraft crash which leads to a release of plutonium. Probabilities for anaircraft crash leading to a release are in the 10-6 range (approximately 1 to 9chances in one million) or lower.

RC: 15.074

Doc: HT15/33

In past studies, that skid area has been factored and reduced. ...Whichskid factors are you using to determine [skid distances]?


The recommended skid distances given in the Draft DOE Standard (DOE1995z) for each aircraft category were used in the Draft EIS. In some casesskid distances were subsequently reduced in the case where one building wasshielded by another. The Final EIS uses skid distances updated in the Draft DOEStandard (DOE 1996g), and considered one building shielding another.

RC: 15.075

Doc: HT15/10

We're told that the support documents, the driving coefficient that controlthe outcome of the four factor detailed analysis, will not be available for twomonths. And we're being asked to wait. It's an issue of we're being asked totrust the support documents are fine, but we're not in a position to see forexternal peer review. My question is, can they be made available in a fashionthat will keep this process in a time line and give us a reasonable opportunityto do a technical peer review?


See response to comment 15.058.

RC: 15.076

Doc: HT17/43

We're also very encouraged to see that the Department of Energy has takensteps, working with the local government of the City of Amarillo and the Stateof Texas, in reducing the number of aircraft overflights. I think that showtheir good-faith efforts to try to operate in as safe a manner as possible. Wealso appreciate the Department of Energy's openness policy.


The Department will continue its good-faith efforts and openness policyin an effort to operate in as safe a manner as possible.

RC: 15.077

Doc: SG-012/3

Vol. I, page 5-63, 5.5 Kirtland Air Force Base, Aircraft Accidents,"An analysis was performed to determine whether expected bomb loads (one tofour 909-kilogram [2000-pound] bombs) could damage the Manzano storage magazinesin the event of an airplane crash. With the minimum cover of 9 meters ofgranite and earth, the magazines cannot be damaged by any foreseeable aircraftevents." Vol. II, page E-26, Aircraft Accident Analysis, E.3.2.4 StructuralCalculation, "A survey of contour maps reveals that the approximateoverburden for the Manzano WSA is approximately 3.05 meters." Based on theaforementioned information, it is unclear which of the above statements iscorrect. If the second statement is correct, then the minimum overburden is 3meters, and the analysis of the bomb loads should be further considered as aplausible accident analysis. Although a bomb load may not have impacts below 9meters of granite, it may impact 3 meters.


Commentor is correct. The minimum overburden at Manzano WSA is 9 meters. This error has been corrected in the Final EIS.

RC: 15.078

Doc: HT16/15

My question has to do with Figure F-6.3.1 on Page F-19, Appendix F.... There is listed a variety of collisions that might occur during transportation[that] form the basis for the risk and the consequence analyses in that[appendix]. And I note that aircraft collisions with the transport train havenot been considered, or at least they're not listed. The stage right trailer,the whatever trailer you would like to consider. I guess there's somethinghauling a trailer, so I think of it as a train. If we're really looking at30,000 movements a year, which was the number referred to earlier in thediscussion, the total exposure of all of those targets averaged over a year maymatch the total exposure of a single storage facility, in terms of hours ofvulnerability. So it relates to an observation that I've had that, in analyzingthe aircraft crash probability, there's been no consideration of the fact thatthe aircraft is only in a position to impact the target for a short duration, avery short proportion of its entire flight. Here we've got a slowly movingtarget that's only vulnerable for a short period of time and we've not worriedabout it. When you're moving the missile instead of moving the target, we worryabout the sum total of all these passes. When we're moving the target moreslowly, we say, well, it's in the open for such a short period of time that it'snegligible.


To elaborate on the response given at the public hearing, aircraftimpacts into a moving vehicle containing weapons or weapon components wereconsidered in the analysis. The potential for this accident is discussed insection 4.12.2 of volume I. Assuming a trailer was continually parked withinZone 4, an aircraft impact frequency of less than 1 x 10-7 per year wascalculated. The risk from this accident using a frequency of 1 x 10-7 per yearis presented in section 4.12.2 of volume I.

RC: 15.079

Doc: PC-025/78

Doesn't Amarillo have an airshow with flyovers during high risk maneuvers?Was this accounted for? If the incident rate for an airshow is higher than thegeneral aviation conditions set forth in section 4.16, how does DOE justify[that] the current NEPA analysis meets the intent of NEPA. In the last ten yearshow many airshow (US and worldwide) accidents have occurred relative to section4.15 parameters in determining frequency of crashes? Assuming an airshow highvelocity impact with at least two impact scenarios per year over the period ofthis EIS, what are the impacts to the public from releases?


Amarillo International Airport does have airshows on occasion, withaircraft performing high risk maneuvers. However, the probability densityfunction contained in the Draft DOE Standard (DOE 1996g) includes crashfrequencies based on national averages, which include those as a result ofairshow crashes. As a result, this scenario has been considered in the currentanalysis.

RC: 15.080

Doc: PC-025/79

In Scenario 7 on Page 4-231. What is the maximum tritium release incuries? Why isn't a direct high velocity aircraft crash into the vaultconsidered?


Aircraft impacts into the tritium vault are considered in the analysis. However, aircraft impacts are not risk dominant compared with the seismic event. The typical source term for this event is 3.9 x 107 curies (Ci).

RC: 15.081

Doc: PC-025/80

General comment, section 4.15. The VORTAC serves no real purpose. Acrippled plane goes where it wants to. What is FAA and DOE going to do if theonly way to bring a crippled plane in is over the plant? Shoot the plane down?


The probability density function contained in the Draft DOE Standard(DOE 1996g) includes crash frequencies based on national averages. These crashfrequencies are based on national statistics which include "crippled"aircraft if they resulted in a crash. Thus this hypothetical scenario has beenaddressed in the analysis.

RC: 15.082

Doc: PC-025/81

I would argue the total number of yearly flight operations is incorrect.Because neither the number of satellites or the Space Shuttle operations areincluded. I believe satellites have a nearly 100 percent orbital failure rate.Thus, a high velocity satellite impact is reasonable.


The Near Airport analysis outlined in the Draft DOE Standard (DOE 1996g)includes consideration of normal airport operations. Whereas the non-airporthigh altitude overflight model in the Standard considers impacts from highaltitude aircraft. Spacecraft (the Shuttle, satellites, etc.) ground impactsare statistically insignificant compared to conventional aircraft flights. Itshould be noted that the majority of spacecraft burn up in reentry, prior toimpacting the ground.

RC: 15.083

Doc: PC-025/82

Table 4.15.2-2 information seems impossible given the recent Valujetaccident where the plane blasted through a limestone formation. If the impactforces of that plane were used in analyzing impacts at Pantex, what wouldchange? Was the maximum velocity used in determining damage? Velocity is squaredin the force equation correct? The calculations on page E-l9 are flawed by usingslow moving aircraft. The LLNL report seems contrived to show the damage wouldbe minimal by using the 70th percentile velocities turning takeoff or landing.NEPA requires you to assess reasonable situations. Since the probability of anaircraft crash is independent of the damage it causes. I would argue a highvelocity impact of a massive plane is just as likely as a small plane at lowspeed, thus NEPA requires you to analyze the impact of the most damagingscenario, please comment.


See discussion in section 1.3.11 of this volume regarding angle ofimpact and response to comment 15.005.

RC: 15.084

Doc: PC-025/83

General comment, sections 4.15 and 4.16. Please provide information on thelevel of QA/QC defending the analyses of these sections. I would like the sameinformation as requested on water and air quality sections of this EIS.


The QA/QC of the referenced sections of the Draft EIS, as well as theentire document was conducted in accordance with the Tetra Tech QualityAssurance Program Plan, document number CB-1000, May 22, 1995. The program istailored for preparation of the EIS and to meet DOE Order 5600.6C and NQA-1 asappropriate. For detailed information, refer to these documents.

The assessments (including methodologies, models, and results) ofaircraft accidents in section 4.15 of volume I were subject to a multiple levelof technical peer review to ensure technical validity. Included in this reviewprocess was: (1) the analysts immediate supervisor, (2) the functional areamanager, (3) technical experts from the Amarillo Area Office, and (4) technicalexperts from the Albuquerque Operations office.

Additionally, the assessments (including methodologies, models, andresults) of aircraft accidents in section 4.15 of volume I were exposed toextensive peer reviews. These reviews included two workshops occurring overseveral weeks along with independent supporting analysis by the workshopparticipants. The participants included representatives from DOE, SandiaNational Laboratories, Lawrence Livermore National Laboratory, Los AlamosNational Laboratory, the Defense Nuclear Facility Safety Board, as well asnuclear safety experts from private organizations.

Additionally, these assessments were peer reviewed by DOE HeadquartersTechnical Safety Review Panel. This group is made up of safety expertsthroughout the DOE complex whose main responsibility is providing safetyanalysis guidance to Pantex Plant.

During the public review process, the assessments (includingmethodologies, models, and results) of the aircraft accidents in section 4.15 ofvolume I were reviewed by a group of independent scientists from Texas A&MUniversity and the University of Texas.

RC: 15.085

Doc: CO-008/17

Pages E-5 and E-16, E.2.1 and E.3.1.4. Why is the value of "y"[g] for military aircraft lower than that for commercial aircraft?


See response to comment 15.015.

RC: 15.086

Doc: CO-008/18

Pages E-5 and E-16, E.2.1 and E.3.1.4. The proximity of Amarillo to themajor east-west routes, and the availability of an extremely long runway makesfor an attractive option in the event of an in-flight emergency for bothmilitary and commercial overflights. In such an [event], an aircraft ispermitted to waive all regulations in the attempt to perform a safe landing. With the prevailing southerly winds, and the location of the Pantex Plant, thechances of an aircraft making an overflight of the hazardous facilities, whilealready in a degraded state, are extremely high. Will the facilities at Pantexbe prepared for such an emergency?


The probability density function contained in the Draft DOE Standard(DOE 1996g) includes crash frequencies based on national averages. These crashfrequencies are based on national statistics, which include emergency landingsif they resulted in a crash. Thus this hypothetical scenario has been addressedin the analysis. Additionally, the FAA and DOE have established a "hotline"between the air traffic control tower and the Pantex Plant operations center toprovide for immediate emergency communication should the need arise.

RC: 15.087

Doc: MG-001/1

I am concerned about the "plane crash" analysis. As Mayor, I havebeen deeply involved in efforts to reduce overflights over the plant, and otherpreventative measures. How can it be that the probability of a crash causing arelease has increased since your 1994 Finding of No Significant Impact, afterPantex and the Amarillo Airport? Even the DOE officials at the hearingsconceded that their analysis had serious problems, and needed to be corrected. I urge your office to correct these errors, and act to avoid wrongfullydepriving Pantex of future functions for which it may be selected.


See discussion in section 1.3.11 of this volume regarding the results ofthe previous analysis.

RC: 15.088

Doc: SG-003/90

As of this date, July 11, 1996the eve of the closing of the comment periodfor the draft EISthose personnel from Tetra Tech responsible for preparing theFinal EIS have not (1) received the DOE standard, (2) have not received thefinal technical support documentation, and (3) have [no] idea if the probabilityof an aircraft crash into a Pantex plutonium storage facility is 1 or 100 in amillion. Therefore, at the close of this comment period, we can not verifytheir results because none is available. What is known is that everythingpublished in the draft EIS will be changed based upon the new DOE standard.


See discussion in section 1.3.11 of this volume. Additionally, concerns1 and 2 are correct. However, for the Draft EIS, Tetra Tech personnelcalculated the probability of a crash into either Zone 4 or 12 [as] 4 x 10-5 or40 in one million, which is similar in magnitude to what has been calculated inthe past in previous aircraft crash analyses done for the Pantex Plant. This isdocumented in the Final EIS.

RC: 15.089

Doc: SG-003/91

The aircraft crash rates are fixed in the DOE standard; however, [we] do nothave access to either the Technical Support Documentation nor the data fromwhich the accident crash rates (usually reported as accidents per hundredthousand flying hours) have be calculated into a crash probability for eachtakeoff, for each landing, or an in-flight rate per square mile. Thiscalculation requires many assumptions and several different steps. Frominterviews, we have determined that draft DOE standard does a credible job inestablishing these crash rates. However, since DOE contractors have deniedaccess to both the data and the technical support documentation, we request thatthat the following points of potential errors be addressed by the DOEcontractor, reviewed by a competent authority, and be included in the Final EIS.


Crash rates are given in the Technical Support Documentation for theDraft DOE Standard (DOE 1996g), which has been made available.

RC: 15.090

Doc: SG-003/92

Military aircraft perform touch and go landings for proficiency trainingonly with an instructor on board. Additional landing practice is accomplishedas a low approach with the wheels not touching the runway. The civilian towercounts this low approach as two operations (1 takeoff and 1 landing) but norecord of a landing is recorded in the military records. We request details ofhow this discontinuity in the raw data is accounted for in the DOE standard. Werequest that following data be published in the Final EIS for all militaryaircraft with significant impact at the Pantex facility: accident and crashrates per hundred thousand flying hours; average hours per sortie; averagelandings and low approaches per sortie; and number of crashes attributed tolanding, takeoff, and in-flight categories.


Military records are not accounted for in the Draft DOE Standard (DOE1996g). We do not plan to gather this information because the Draft DOEStandard does not use this information. The information contained within theDraft DOE Standard is based on FAA records. Crash rates for various aircraftcategories are given in the Technical Support Documentation for the Standard,which has been provided to the commentor.

RC: 15.091

Doc: SG-003/93

It was pointed out in interviews that there are 422 off-airport crashes peryear of general aviation aircraft in the United States [that] are considered inthe calculation of the probability in-flight crash rate. This data may be true,but it would be overly conservative to assume the probability of crash into avacant or farming square mile was equal to the probability of crash into abuilt-up [area] such as the Pantex compound. Many general aviation crashes arethe result of engine failure, nearly all general aviation aircraft have flightcontrols that function without power and pilots are trained to attempt forcedlandings in those emergencies. No pilot given a in-flight situation where someflight control remains, would aim at the Pantex compound rather than away fromthe reinforced structures at the compound. Given the good weather conditions atAmarillo and the relatively open spaces surrounding the Pantex compound, thecrash site cited in the DOE standard would be greatly reduced for the localapplication of in-flight general aviation aircraft.


The suggestion of reducing the crash rate cited in the Draft DOEStandard (DOE 1996g) for the local application of in-flight general aviationaircraft has been taken under consideration, but is conservative given the factthat this factor cannot be quantified.

RC: 15.092

Doc: SG-003/94

In general we feel the DOE standard is a tremendous improvement in accuracyover the previously used Solomon model for predicting the probability of anaircraft crash into a facility. The Solomon model was far too overlyconservative in the estimate of the contribution of high altitude overflightaircraft. Since this new DOE standard corrects the in-flight contribution ofthe Solomon model, we would logically expect that the probability of an aircraftcrash into the Pantex plutonium storage facilitates should decrease fromprevious studies that used the Solomon model. We request that the Final EISprovide some narrative description of the new calculation of hit probability incomparison to the previously conducted studies and a short justification for thedifferences in the findings.

(Video) Glen Milner - The Largest Concentration of Nuclear Weapons in the Western Hemisphere


Information on previous aircraft analyses is presented in section4.15.1.3 of volume I of the Final EIS. This information is presented in bothtabular and narrative form. See also discussion in section 1.3.11 of thisvolume.

RC: 15.093

Doc: SG-003/95

After reviewing the draft EIS and conducting interviews, we recommend thatthe DOE standard in its application to the Pantex facility be localized for theconditions and aircraft traffic in the following ways: A. The small militaryaircraft subcategory which makes up a large portion of the traffic at AmarilloAirport must be studied by specific aircraft types. The T-38 and T-1 aircraft,which are the dominate aircraft types in the traffic stream, must have separatehit probabilities as well as separate release probabilities.


The current analysis can treat all large and small military aircrafttypes on an individual basis for crash rates. There is a less than five percentdifference in the results.

RC: 15.094

Doc: SG-003/96

B. The closure of Reese AFB in Lubbock, Texas by December 1996 will have asignificant effect on the forecast T-1 and T-38 traffic at Amarillo Airport andtherefore attempts must be made to use the actual forecast numbers rather thatpast history for these aircraft.


It is difficult to forecast what the closure of Reese Air Force Basewill do to the numbers of T-1s and T-38s. These aircraft may relocate toanother facility and yet still fly into Amarillo. An accurate description ofthe numbers of these aircraft would show up in the RAMS and FAA data. Thecurrent analysis is conservative with respect to the closure of this Base.

RC: 15.095

Doc: SG-003/97

C. The collection of RAMS data at Amarillo Airport has provided theDepartment with a very good record of the number and types of aircraft and theirground track in comparison to the Pantex facility. This data should be usedwhen necessary to adjust DOE standard crash rates, which are based upon a totalaverage of all airports throughout the United States. The takeoff ground tracksfor Runway 04 do not follow the typical pattern assumed when the data wascollected for the DOE standard.


The RAMS data has been used for the Final EIS to determine dominantaircraft on an individual basis to adjust the crash rates to be morerepresentative. There is a less than five percent difference in the results.

RC: 15.096

Doc: SG-003/98

D. When Using the RAMS data, insure that military aircraft that are information be counted as multiple aircraft rather than as a single aircraft.


The RAMS data distinguish military aircraft flying in formation asindividual aircraft. Each aircraft has a unique identification beacon that theRAMS records.

RC: 15.097

Doc: SG-003/99

The Pantex facility has super stout structures and consideration of thestructural capacity and resistance to aircraft penetration should be accuratelymodeled.


Analysis of structures is done using the Chang equations provided in theDraft DOE Standard (DOE 1996g). Application of these equations to these superstout facilities gives a conservative result. Section 4.15.7, volume I of theFinal EIS discusses this conservatism.

RC: 15.098

Doc: SG-003/100

The effective aircraft crash skid length should be localized to consider thelocal conditions at the Pantex facility.


See response to comment 15.074.

RC: 15.099

Doc: SG-003/101

The FAA and DOE have agreed to several mitigation measures to reduce theprobability of aircraft impact into Pantex and we applaud those efforts. Thedraft EIS provided an estimate of the effectiveness of these measures using theSolomon model which were significant. Although the application of this newmodel in the DOE Standard will probably estimate the effectiveness of thesemeasures as insignificant, we believe they are significant and should beestimated separately.


See discussion in section 1.3.11 of this volume. Additionally, the DOEis committed to the aircraft risk reduction issue. The mitigation measures willproceed regardless of the values presented in the EIS.

RC: 15.100

Doc: SG-003/102

We recommend that DOE continue to collect radar data at the Amarillo airportas a mitigation item for the Site Wide EIS. We highly recommend that thecurrent method of tracking radar should be improved with DOE funding astate-of-the-art system that is equal to the noise monitoring systems installedat many major airports in the U.S. This system should be automated andintegrated with a geographical information system and turned over to the airportfor their use in airport planning.


It is anticipated that the RAMS project will continue, and therecommendation stated will be taken into consideration.

RC: 15.101

Doc: SG-003/103

First, let me start by observing that the Department of Energy (DOE) hascreated the best available models for assessing the probability of an aircraftaccident at any point in the country. Second, DOE is to be congratulated forusing their models in their Environmental Impact Assessments. Third, DOE iscontinuing to improve their aircraft accident models. Unfortunately, thiscontinuous improvement poses difficulty for those who try to comment on theDraft EIS for Pantex. A major shift in modeling assumptions occurred betweenJuly 1995 and July 1996. The predicted annual risk of an aircraft accident inany square mile has increased as a result of changes in the model, not as aresult of changes in the aeronautical environment in the vicinity of the PantexPlant. The aircraft accident risk depends as much on the aeronauticalenvironment as it does on the assumptions of the model used for predictivepurposes. The final EIS must clearly portray both effects. It is importantthat this issue be addressed in the Executive Summary as well as in the EISitself.


A major shift in the modeling between the July 1995 and July 1996versions of the DOE Standard involved the consideration of in-flight/highaltitude aircraft. The July 1995 Standard utilized a non-airway model, whereasthe July 1996 Standard utilizes a non-airport model. The major differencebetween the two involves the combination of three terms of the four-factorformula [NPf(x,y)] in the non-airport model to give a DOE site-specific value tobe used to calculate hit probability. Regarding the aeronautical environment,it is known that the number of T-38s flying into the Amarillo InternationalAirport from Reese Air Force Base will decline when this base closes. This willmost likely result in a change in the aeronautical environment indicated by thecommentor. However, it is unknown whether these T-38s from Reese will migrateto another Base and still continue to use Amarillo Airport for their training.Until the RAMS and FAA data reflect this change in numbers of T-38s, the changecannot be reflected in the analysis.

RC: 15.102

Doc: SG-003/104

The discussion in the EIS points out that an Aircraft Accident can be aninitiating event in a scenario that leads to public exposure to radioisotopes. Because this is a very unlikely event, the authors attempt to quantify theprobability of the event. The Draft EIS used the Draft DOE Guidelines forAircraft Accident Prediction (July 95, Revised). During the period of publiccomment, HQ DOE announced its intent to publish final guidelines, now promisedfor mid-July 1996. Further, DOE wants the Final EIS to be based on the finalguidelines. The new paradigm is that aircraft accident locations are bestpredicted on the basis of the locations of previous accidents. The locationprobability density function is a smoothed average over the whole nation for enroute accidents. For near airport accidents it is a smoothed function of allaccidents as a function of distance and direction from a composite runway. Thisis a major change from the draft guidelines and prior accident models. Theseassumed the impact location would be near the point along an established "flyway"where an aircraft encountered difficulty and used probability factors withdimensions of accident probability per mile of flight. Preliminary calculationsshow that the new model predicts accident rates 2 to 10 times higher than theolder models. Since the Pantex EIS will be the first to use the new DOEAircraft Accident Guidelines, and since it may be used to compare predictedaccident probabilities at Pantex to those at other DOE facilities, how does DOEintend to explain the changed paradigm to members of the public and to seniordecision makers?


Since the release of the latest version of the Draft DOE Standard (DOE1996g), it has been shown that the results for the aircraft crash analysis havedecreased from the Draft Standard (DOE 1995z) and Draft EIS. The Draft DOEStandard (DOE 1996g) was applied to the alternative storage sites considered inthe EIS. This was not done for the Draft EIS. Many of the previous analysesconducted for these sites were conducted with methodologies that have since beenproven inadequate for a proper characterization of the risk due to aircraftcrash.

RC: 15.103

Doc: SG-003/105

In cooperation with FAA, DOE has initiated several mitigation measures toreduce the probability of an aircraft accident involving Pantex facilities. These include moving the back course localizer 6 degrees west and creating GPSinstrument approaches that move takeoff and landing operations more than 2 milesaway from Pantex. Plans exist to move the VOR onto the airport from its presentlocation near the Pantex fence line. This will reroute high altitude trafficaway from Pantex facilities. Unfortunately, the new accident model, based onlyon the history of previous aircraft accidents, is unable to demonstrate reducedaccident probabilities from mitigation measures. From conversations with KamiarJamali, DOE did not intend this model to be used for mitigation design. It isdesigned to provide a common basis for comparing one DOE location to another. Nevertheless, as existence proof for the benefit of mitigation measures, notethat the White House is surrounded by a no-fly zone. Request that DOE insurethat the final EIS give appropriate credit for mitigation measures completed andcontemplated. See the next comment for a suggestion.


Please see response to comment 15.104.

RC: 15.104

Doc: SG-003/106

To better understand the true flight environment at Amarillo, DOE installedthe RAMS system to record the flight tracks of every aircraft operating near thePantex Plant. This data has been analyzed by Dr. Y.T. Lin of Sandia labs. Inhis paper, "Assessment of Aircraft Risk Reduction at Pantex Plant," heuses actual RAMS data to compute the probability density function for aircraftdistance from Zone 4 for all recorded aircraft, Dr. Lin uses his data to makethree relevant points: 1) It shows dramatic differences in overflight activityon days when the USAF is flying compared to days when there are no militaryflights. 2) Only a small fraction of all flights approach within 2 miles ofZone 4. 3) The daily total of high altitude and low altitude en routeflights provide no clue as to the location of the VOR or of the FAA routestructure. These flights are better modeled as uniformly distributed. Can Dr.Lin's approach to analyzing RAMS data be used to demonstrate efficacy ofmitigation measures?


Dr. Lins approach could be used to analyze the effect of the mitigationmeasures. However, this would be inconsistent with the Draft DOE Standard (DOE1996g), as written.

RC: 15.105

Doc: SG-003/107

The proposed DOE Standard 3014-96, uses a hierarchical accident analysisscheme starting with simple, conservative models and progressing towardscomplex, accurate models. A screening level of risk <1E-6/yr is recommended. If at any point in the progression, the aircraft crash probability falls belowthis level, no further analysis is required. It is presumed that otherinitiating events become more important than aircraft accidents at thisprobability level. There are two problems with this approach. First, it leadssome to believe that only when the aircraft accident probability is below1E-6/(sq mi/yr) has an adequate margin of safety been provided. Second, thebase accident rate for general aviation aircraft is on the order of 500/yr over4,000,000 sq mi, or about lE-4/(sq mi/yr). There are four othercategories of aircraft in the DOE guidelines, each with their own accident rate: large military, small military, commercial air carrier and commercial air taxi. Thus, the total aircraft accident probability in the continental United Statesis above the screening rate, and full analysis is mandated by the DOE standard. DOE should very clearly explain the meaning of their screening level and of anyaircraft accident probabilities computed for the Pantex EIS. The Pantex EISwill be the first to use the new geographic based guidelines. Other DOElaboratories and locations have analyzed their aircraft accident risk usingearlier draft guidelines. Since DOE claims the aircraft accident model isdesigned to compare relative risk among DOE facilities, the revised predictionsfor all DOE sites should be included in the Pantex EIS. This means that the newguidelines need to be applied to all DOE operating locations so that Pantex canbe viewed in proper relationship to the others.


The screening criteria has been more clearly defined in the Draft DOEStandard (DOE 1996g), and this Standard has been applied to all alternativesites in the Final EIS.

RC: 15.106

Doc: SG-003/108

Although the geographic modeling approach is an interesting exercise, theEIS should also contain complete Amarillo Aircraft accident data from 1970 to1996. This data should then be explained in the context of the aircraftaccident model. That is, based on the accident model, is the real experience anexpected outcome? Suggest using the binomial distribution to estimate theconfidence in the predicted accident rate. Use confidence interval principlesto determine if the location and frequency of observed accidents are inreasonable agreement with the model.


Your suggestion has been taken into consideration. Attempts have beenmade to quantify uncertainty and compare predicted results with historicaccident data in the Final EIS.

RC: 15.107

Doc: SG-003/109

Personnel at HQ DOE understand the difficulty of explaining the aircraftaccident probabilities to the public. In a lively discussion at SAIC on 9 Jul96, hosted by Tim Haley and chaired by Kamiar Jamali, the suggestion was madethat EIS analyses not report the aircraft accident probabilities. Theseprobabilities are intermediate results from the model and do not indicate publichealth risk. An accident is merely a potential initiating event. Thesuggestion was that the EIS should focus on the release probabilities, instead. This movement from "hit probability" to "release probability"involves many intermediate layers of modeling. First, one must assume the angleof impact for the aircraft. Second, assume an impact velocity and compute theskid distance during which the aircraft retains sufficient kinetic energy topenetrate a storage magazine or transport trailer and storage container. Third,compute the probability that an aircraft will impact within the dangerous skiddistance from the facility heading toward that facility. Fourth, compute theprobability that a fire or a dense part of the aircraft will penetrate ordestroy the facility. Clearly, the probability that all of the above eventsoccur together is many orders of magnitude smaller than the simple probabilitythat an aircraft hits near a critical facility or transporter. It is also clearthat values assigned to the coefficient for each step affect the confidenceinterval about the point estimate of the release probability. Theunderstandable tendency is to assign worst case values to all parameters tocreate an upper bound on the estimated release probability. For purposes ofcommunicating to the public, it is desired to have an estimate of the centraltendency, the median or the mean value of the release probability as well. Include both the worst case and the mean value of the release probability due toaircraft accidents. The difference between point estimates of the worst caseand of the typical case will give public officials an internally consistentestimate of the safety factors built into the prediction algorithm used.


An effort has been made in the Final EIS to provide the requestedadditional information. It is our belief that the aircraft crash scenario wasanalyzed to the point where it was demonstrated that aircraft crash risk is oneto two orders of magnitude less than other risks associated with Pantex Plantoperations.

RC: 15.108

Doc: SG-003/110

Not all structures proposed for storage and handling operations at Pantexare constructed in the manner and with the materials assumed in the DOEstructural vulnerability analysis. That analysis seems to assume standard rebarreinforced concrete construction techniques. At Pantex there are somefacilities that are more stout and some that are less stout than the analysis inthe draft EIS seems to assume. Bundling the stout structures into the analysisprobably creates a pessimistic estimate of the true risk of release. SuggestDOE obtain data from a test involving crashing an F-4 into a section of acommercial reactor containment vessel. Use that data as a basis for assessingthe likelihood that a small military aircraft crash could be an initiating eventfor a release incident in a stout structure. Then assess the effect on theoverall risk to Pantex operations.


See response to comment 15.097.

RC: 15.109

Doc: SG-003/111

The present model seems to assume that an accident that results in internalspalling of a structure will produce a release. This assumption seems overlyconservative for pits stored in approved storage or shipping containers. Again,the data from the F4 Crash Test may provide valuable clues to theappropriateness of the analytical assumptions in the release models. Clarify inthe EIS the release probability from spalling incidents. This may be one of thefactors leading to an overly pessimistic assessment of the consequences of anaircraft accident. Since pits will be stored without chemical explosives,spalling seems an unlikely source for damaging both the storage container andthe cladding on the pit.


This suggestion has been included in the Final EIS. Concrete scabbingleading to release is more fully characterized and more accurate results arepresented in the Final EIS.

RC: 15.110

Doc: SG-003/112

In the aircraft accident consequence analysis, the DOE model assumes thateither a direct impact or a skidding impact can lead to a release. The modelassumes that the aircraft (or its dense structures acting as kinetic missiles)retains dangerous velocities for the entire skid. In reality, the velocityslows continuously during the skid. The target area is computed from the actualfacility dimensions, the aircraft wingspan and the skid distance. The skiddistance is the dominant factor in target area. Why not use a linearlydecreasing velocity as a conservative means for estimating remaining kineticenergy during a skid? This would dramatically reduce the area involved intarget zones and would refine the point estimate of critical aircraft accidentprobability.


See response to comment 15.074.

RC: 15.111

Doc: SG-003/113

The structural damage modeling assumes all aircraft in a single FAA categorypose similar risk to structures. These categories are useful for licensing, airtraffic control and taxing purposes, but may not be ideal for accident analysis. For example, both a T-37 and an F-15 are included in the small militarycategory. The T-37 has much less kinetic energy than an F-15, and has muchsmaller components that could become missiles. The damage potential of a T-37matches that of many general aviation aircraft better than it does an F-15. Nevertheless, the default portions of the DOE guidelines treats themidentically. Why does DOE use FAA categories rather that a more technicalcriteria to group aircraft? Suggest a product of wing loading and gross weightas a better metric. Aircraft with high wing loading always approach faster thanthose with low wing loading. Aircraft with high gross weights always have morestout pieces in their structures and engines than aircraft with low grossweights.


The FAA categories have been used in the Final EIS, in accordance withthe Draft DOE Standard (DOE 1996g). However, use of parameters specific to acertain aircraft type have been utilized. For instance, the T-38 and otherdominant aircraft are addressed separately. There is less than a five percentdifference in the results.

RC: 15.112

Doc: SG-003/114

Dr. Lin's analysis of nearest point of approach for each flight trajectoryprovides an alternative for site-specific accident modeling. It is not likelythat his work can be extended to a full analysis of RAMS data within thepromised schedule for the final EIS. However, his work does suggest that acareful examination of consequence analysis assumptions may be in order. One istempted to believe that aircraft flying directly over a facility may pose thegreatest risk. However, any aircraft impacting a facility from within a coneabove that facility must impact at a very large glide slope angle. At anglesgreater than 30 degrees, there is virtually no skid distance. Thus the facilityfloor plan is the target area for impact from above. Because this area is muchsmaller than that assumed in the DOE guidelines, the probability of thisaccident is much smaller. Can the distribution of the points of closestapproach be used to determine both the slant range and the line of sight angleto critical facilities? The effective target area for each facility will dependstrongly on the impact angle. This effect is not included in the DOE guidelinesbecause they default to a specified point estimate of the impact angle. Thebasis for this assumption is apparently discussed in the technical supportdocuments for the DOE Standard, but that is not yet published, and may not bepublished for several more months. A Monte Carlo analysis is likely the rightmeans for accommodating this important effect.


A suggestion was made to the authors of the Draft DOE Standard to allowfor the use of RAMS distances to the facilities of concern. The suggestion of aMonte Carlo analysis was taken under consideration. However, as the commentorhas stated, these alternate methodologies are unlikely to be available withsufficient time to meet the schedule of the EIS.

RC: 15.113

Doc: SG-003/115

A full risk assessment of aircraft accident potential would include a termfor a collision between an aircraft and a transport trailer, either on siteduring transport between structures or off site during cross country transport. No such term is evident in the draft EIS. Suggest that the probability of anaircraft accident impacting a transporter be computed. Due to the shortduration of exposure while in transit, it is expected that this risk will beshown to be negligible compared with other risks associated with fixed storagefacilities.


See response to comment 15.078.

RC: 15.114

Doc: SG-003/116

The tiered approach to aircraft accident modeling encourages the analyst toperform increasingly complex computations if the screening level has beenexceeded in the prior step. The next step for the Pantex modeling effortinvolves using actual aircraft specific accident rates rather than using averageaccident rates for each of the identified five aircraft categories. It is alsopossible to use available accident rates for the most commonly observed aircraftin a category and to use the category specific rates for the remainder. Ifaccident rates are assigned to specific aircraft (such as the USAF T-1, T-37 andT-38 aircraft), then verify that the appropriate rates are used for theremaining aircraft in that category. These may be derived from aircraftspecific accident data or estimated by marginal analysis of the entire categoryto determine the portion of the accident rate appropriate to the remainingaircraft types.


Specific rates for large and small military aircraft have been used inthe Final EIS. Results show a less than five percent change with additionallevel of detail.

RC: 15.115

Doc: PC-028/11

Per Vol II, page E-23, para E.3.2. There is [no] automatic fire detectioncapability nor prompt response from local firefighters. This is a seriousproblem even if the rock overburden would shield the pit storage area fromaircraft crashes. There is still the ground attendant problems of [a] mix ofground vehicles and equipment and humans.


Any damage that could be inflicted on the Manzano WSA bunkers isdominated by the aircraft accident scenario. As is stated in section E.3.2.4 ofvolume II, the pit storage at Manzano will be done in certified Type Bcontainers. Minor damage to the facility due to aircraft crash is notanticipated to cause damage to the containers sufficient enough to cause aplutonium release. As a result, any damage that could be caused by groundpersonnel or vehicle accidents is not sufficient enough to cause a plutoniumrelease.

RC: 15.116

Doc: FG-002/1

Regarding the Pantex Site-Wide Draft Environmental Impact Statement, Ibelieve the analysis of the "airplane crash" scenario is deficient. How can it be that the probability of a crash causing a release has increasedsince your 1994 Finding of No Significant Impact, particularly after Pantex andthe Amarillo Airport have worked together to reduce overflights of the plant andtaken other preventative measures? I urge the DoE to correct the analyticalerrors and act to avoid wrongfully depriving Pantex of future functions forwhich it may be selected.


See discussion in section 1.3.11 in this volume regarding the results ofthe previous analysis.

3.16 Intersite Transportation of Nuclear and Hazardous Materials

RC: 16.001

Doc: HT11/5

What would be the route that you would transport this to the test site?


For an elaboration on the response given at the public hearing, seediscussion in section 1.3.12 of this volume.

RC: 16.002


What about...the freeway system?


For an elaboration on the response given at the public hearing, seediscussion in section 1.3.12 of this volume.

RC: 16.003


Are these the transport system...highway route control monitors. Would theybe managed so that they would fall into that category?... They can be managedsuch that they do not fall into the highway route control formula. If they fallinto that category, we have lots of notifications for things like that. Infact, you have truck drivers in that situation that would not be allowed toleave their vehicles.


For an elaboration on the response given at the public hearing, seediscussion in section 1.3.12 of this volume.

RC: 16.004

Doc: HT11/8

And then you briefed on this if they were expecting to be highwayroutes. So my assumption is that they are not at this point expecting to loadanything from highway routes in quantity. That doesn't have anything to do[with] Federal marshals; that has to do with notification of states....


For an elaboration on the response given at the public hearing, seediscussion in section 1.3.12 of this volume.

RC: 16.005

Doc: HT11/12

How many shipments would come to the test site for the 8,000 versus the20,000 container of pits?


To elaborate on the response given at the public hearing, the exactnumber of pit containers that would be transferred per Safe Secure TractorTrailer is classified information. However, it would be between 20 and 30. This translates into between 400 and 600 shipments to transfer 12,000 pits.

RC: 16.006

Doc: HT11/13

And that would be over how long, what time period is that?


To elaborate on the response given at the public hearing, at the rate ofapproximately 2,000 pits per year, it would take about 10 years to relocate20,000 pits and 4 years to relocate 8,000 pits.

RC: 16.007

Doc: HT11/14

And if there were an accident along the route, do you...have any emergencyresponse ideas?...


To elaborate on the response given at the public hearing, the emergencyresponse plans and programs for the Transportation Safeguards Division (TSD) arevoluminous and inappropriate for verbatim inclusion in the EIS. In general,TSDs emergency response plans involve a tiered organizational response toradiological incidents. In Tier 0, local law enforcement and TSD couriersassess the severity of the accident and determine the need for radiologicalassistance. Tier I involves the deployment of Radiological Assistance Teams(RATs), a Regional Response Coordinator (RRC), and Public Affairs Office (PAO)personnel. These personnel will have appropriate monitoring and communicationsequipment to assess the radiological status of the incident. At Tier II,additional technical expertise is provided to the response group. At Tier III,the accident response group will assist in recovery, repackaging, anddecontamination operations. These four tiers correspond, respectively, to thefollowing levels: (0) no structural damage and no potential for publiccontroversy, (I) status of unknown or limited damage, (II) excessive damage ofSafe Secure Tractor Trailers (SST) or shipment, and (III) radiological releasecleanup/repackaging required.

Additional national emergency response resources from around the Nationare available if the severity of an SST convoy incident warrants such a call.

RC: 16.008

Doc: HT11/15

And you'd be using common carriers or contract carriers?


To elaborate on the response given at the public hearing, commercialcarriers are used for radioactive waste shipments from Pantex Plant to NevadaTest Site. Pits would be transported in Safe Secure Tractor Trailers.

RC: 16.009

Doc: HT11/20

The other thing is, during the risk assessment for transportation, was thisthe 1000 shipments over a six-year period? Was there any cumulative studiesdone on how that might impact with other shipments of waste proposed andcurrently planned through Nevada in terms of a cumulative impact riskassessment?


Details on cumulative impacts have been added to volume I, section4.16.5.


Doc: HT11/21

What would you say [is] the amount of shipments at this time per week intothe Nevada Test Site?... Do you have an approximate [number]?


To elaborate on the response given at the public hearing, Pantex wasteshipments are minimal compared with other sites that ship to the Nevada TestSite (NTS). The maximum yearly shipment to NTS from Pantex was 28 shipments. The projected shipment rate from Pantex is less than the average occurring overthe past three years. More details of radioactive waste shipments to NTS can befound in the Waste Management PEIS or the NTS Sitewide EIS.

RC: 16.011

Doc: HT11/29

... Are they [of] legal weight?


To elaborate on the response given at the public hearing, Safe SecureTractor Trailers (SSTs) are legal weight trucks. The class of general commercevehicles that most closely matches the SST in physical characteristics andtravel distribution is the 5-axle, tractor-semitrailer with a van cargo body anda 6080,000 pound gross combination weight.

RC: 16.012

Doc: HT11/30

What routes would you use?


See discussion in section 1.3.12 of this volume.

RC: 16.013

Doc: HT11/31

... My name is Russell Dibartolo;...I'm with the Clark County, NevadaDepartment of Comprehensive Planning, Nuclear Waste Division. And my particulararea has to do with impact assessment and review of Department of Energy impactassessments or...environmental impact statement activities.

One of the major things that we have found with a number of Department ofEnergy EISs or environmental assessments is that we feel that theyunrealistically limit their regions of influence that are studied. If youstudied, for instance, the Nevada Test Site within a 50-mile radius, you areleaving out with regard to any potential impacts or risks, over a million peopleor two-thirds of the population of the State of Nevada when you're dealing withshipments to the Nevada Test Site.

So one of the major requests we would have of you, the individuals preparingthis particular EIS and others within the DOE complex, is that you take a verygood look at the space between the sites. The [area] between the sites, [which]in this case is the Clark County metropolitan area also known as the Las Vegasvalley metropolitan area.

We're primarily concerned with the routing of this material. There arecertain areas in Clark County that we know of that are very high in accidentrates. We know that there are a number of areas in Clark County where there'sconstruction anticipated on the interstate and U.S. highways. This constructionprogram [is] to last about 10 years. We know there's a high correlation betweenconstruction, congestion, and accidents, and we would like you to take that intoaccount.


The region of influence as defined for the Nevada Test Site is not thesame as the population distributions used in the transportation risk modeling.The transportation risk model uses 1990 census block data to determine thepopulation distributions along Transportation Safeguards Division routes.

See general discussion on intersite transportation in section 1.3.12 ofthis volume for routing information.

RC: 16.014

Doc: HT11/36

You should also know that the Nevada Test Site has established for their EISprocess a transportation advisory group, and within that group is a smallersubgroup or team that's called a protocol working group. This particular workinggroup has already provided recommendations and census recommendations among anumber of local governments and other interested individuals or groups that havealready been sent to the Department of Energy prior to the comment deadline.

They are already working and addressing this, and this particular protocolworking group or transportation advisory group has turned out to be a very goodvehicle for our interactions. ...It's Frank DiSanza who is head of thatprogram.... He works with DOE Nevada, and...they have...brought together thatgroup. That group meets on an as-needed basis, generally once every two months.The transportation advisory group meets usually about once every quarter, andthat's been going on for probably a little bit more than a year.

And it came up for shipments such as this. There were shipments that wereplanned to come in through North Las Vegas. North Las Vegas by accident heardabout them. Turns out that they were just a very few shipments going to the testsite cutting across Craig Road, which is a convenient way...if you're goingsouth on I-15 and you go north on U.S. 95, it's a very good cut-off.

North Las Vegas officials became very concerned about that, and I wasworking at the university then as a consultant and was brought in to helpfacilitate meetings. And...from the need that was seen for that, we developedthis transportation advisory group, and it has worked very well.


See discussion in section 1.3.12 of this volume.

RC: 16.015

Doc: HT14/4

... The transportation of plutonium and special nuclear materials toHanford storage will require careful planning of routes and consideration ofweather emergencies to minimize the likelihood of an accident. Emergencypreparedness for minimizing the impacts of an accident will require financialsupport from DOE for State, tribal and local involvement, including adequateequipment and training. When materials are shipped, timely notification shouldbe provided to the transportation agencies.


See discussion in section 1.3.12 of this volume.

RC: 16.016

Doc: HT02-16/1

It is too dangerous to transport as well.


The risks associated with proposed pit shipments are described in volumeI, section 4.16 of this volume.

RC: 16.017

Doc: HT13/16

... To clarify, who is doing the certification?


To elaborate on the response given at the public hearing, the AT400Acontainer is currently undergoing certification testing at Sandia NationalLaboratories (SNL). The performance criteria that the package designer must useto assess Type B packaging against these empirically established hypotheticalaccident test conditions of the transport are prescribed in the NuclearRegulatory Commission regulations (10 CFR 71.73) and are discussed in volume II,appendix F of this document.

Following certification testing by SNL, DOE will develop a SafetyAnalysis Report for Packaging (SARP) for the AT400A. SARP provides DOE with adetailed safety analysis and risk assessment of the containers performance forits intended mission and expected useful lifetime. Following acceptance of thefinal SARP, DOE will issue a certification for the AT400A. The schedule for SARP is not yet available.


Doc: HT13/41

Will Lawrence Livermore and Los Alamos be shipping different sorts ofcompositions to Pantex and expecting them to do the machining and tooling?

[Unidentified Speaker: I would presume whatever the role that is identifiedfor Livermore and Los Alamos in the stockpile stewardship and management that itwill be supported by Pantex in their mission.]


To elaborate on the response given at the public hearing, transferringthe HE fabrication mission from Pantex Plant to Los Alamos National Laboratory (LANL) and/or Lawrence Livermore National Laboratories (LLNL) would require anestimated 150 rebuilds to be shipped per year from the high explosive (HE)fabrication site to the weapons assembly/disassembly site. The accident riskfrom transporting this material would be no greater than the risk encountered bythe public from industrys transport of similar explosives. Transferring all orpart of the HE fabrication mission from Pantex to LANL and/or LLNL would requirean estimated 12 round trips per year to transport HE materials including thereturn of scrap HE to the laboratories.

RC: 16.019

Doc: HT13/50

In that model, there are several options for how you input the humanpopulation numbers along the transportation route. Can you tell me,...for theinput of population data into those model runs, which of those options wereused? Are there some default values, such as rural is one person per squaremile, urban is five persons per square [mile], suburban is 2.5, [or arethere]...more specific ways to enter population data into the model?


The ADROIT code uses population information from the 1990 census. Forincident free calculations, the uniform population density along transportroutes was obtained by determining the maximum population density in censusblocks perpendicular to each roadway segment extended out to 30 kilometers. This maximum population density was used as the uniform population density forthat road segment. For accident calculations, 1990 census block data were usedfor the affected populations from postulated dispersal accidents.

RC: 16.020

Doc: HT13/51

The default values are also calculated from the 1990 census. I think myquestion was more specific in that we have this route, I-40, between Amarilloand Manzano, and I am wondering whether actual population data for, let's say, aquarter mile, approximately, on either side of I-40 between Manzano and Pantex,is that the sort of information that was used, or was it just the default valueplugged in where the default value also comes with the [1990] census, but it islike a statewide average or a regional average for rural and suburban?


Please see response to comment 16.019.

RC: 16.021


Could you give me an answer in sufficient time so I could submit a writtencomment about the values before the deadline?


Please see response to comment 16.019.

RC: 16.022

Doc: HT13/57

I just want to make sure I understood. Would you repeat what you said aboutthe drop onto a spike in terms of transportation testing?

Would you then explain why on page 4-256 of the document it says thepuncture test is a free drop of 40 inches onto a 15-centimeter diameter steelpin?

Again, to clarify, because I am trying to understand what is the informationpeople should rely on, on page 4-256, the 30-foot drop test [that] you talkedabout, and this is a quote, "a 9-meter (30-foot) drop onto an unyieldingsurface." It is not onto a pin or a spike. It is onto a flat, unyieldingsurface. I just want to clarify what you are saying in relation to what is inthe document.

[Unidentified Speaker: In the document that was identified or accepted bythe Department of Energy for its container certification, and I assume you aretalking about the AT-400 certification, there are three tests that are done. One is a 9-meter or approximately 30-foot drop test. The other is a drop teston an unyielding object. The other test is a puncturing test where they drop itfrom a lesser distance, and I believe it is 40 or 50 centimeters, I am not sure,on the spike that they are talking about.]

These tests are done in sequence, and then there is also a temperature test. Those tests are done and required by the NRC for certification of over-the-roadtransport of special nuclear material.

[Unidentified Speaker: I do want to point out that in these documents,please go back for very specific measurements to the document.]


The testing requirements for certification of Type B packages isprovided in volume II, appendix F.

RC: 16.023

Doc: HT13/69

So if you are transporting 8,000 pits, and somebody gets a hold of ashipment I forget how may pits are on the typical shipment.

[Ms. Founds: About 20.]

So somebody got a hold of 20 pits and decided to poke holes in them.


The threat of hijacking is taken seriously by DOE. The securitypolicies, procedures, and resources in place minimize the threat to TSDshipments.

RC: 16.024

Doc: HT13/70

What is the material that is so powerful? How thick is this?


Design information for the AT400A container is provided in volume II,appendix F.

RC: 16.025

Doc: HT13/71

Somebody passed me this dice diagram, AL-R8, and this is what you weretelling me was the container that was so secure that nobody could ever get ahole through it? It is a quarter-inch stainless steel, this new one that isproposed that isn't yet being used.... So you are saying you don't think itwould be possible for anybody to get that container open following atransportation accident because of that quarter-inch of stainless steel? Well,again, the credibility of believing...that there would be no possibilitywhatsoever that that container could be breached under any sort of accidentscenario.


Potential offsite transportation accidents resulting in plutoniumdispersal from AT400A containers are described in volume I, section 4.16.4.

RC: 16.026

Doc: CO-003/5

The transportation of plutonium and special nuclear materials to Hanfordstorage will require careful planning of routes and consideration of weatheremergencies to minimize the likelihood of an accident. Emergency preparednessfor minimizing the impacts from an accident will require financial support fromDOE for State, tribal, and local involvement, including adequate equipment andtraining. When materials are shipped, timely notification should be provided totransportation agencies.


See discussion in section 1.3.12 of this volume.

RC: 16.027

Doc: CO-010/2

An additional area of concern would be the "major issue" oftransportation of the excess plutonium materials to the Hanford Site. Webelieve that the Draft EIS needs to more fully evaluate the hazards andmitigation measures [that] would need to be implemented in support of thetransportation of significant amounts of these materials to the Hanford Site.


The Pantex EIS analyzed the risks associated with the shipment of pitsto the Hanford Site. The EIS analysis considers all potential accidents thatcould lead to a release of hazardous material. The analysis considered allcombinations (and inter-dependence) of puncture, crush, impact, and fireenvironments.

RC: 16.028

Doc: CO-006/3

Accurate comparisons between all sites under consideration should once againmake Pantex the preferred site. Maintaining and expanding the interim storagefacilities at Pantex would all but eliminate the significant transport costs,and the attendant environmental and political risks involved with moving thesefunctions to [another] site. Eliminating the unnecessary transportation ofradioactive materials, will translate into less cost and greater public safetyand protection. Ignoring or miscalculating the risks and costs associated withweapons materials would be a serious omission.


A description of the transportation of plutonium pits and the expectedincrease in risk is presented in volume I, section 4.16. No attempt was madeto estimate the cost of transporting pits.

RC: 16.029

Doc: HT15/35

I don't believe that there was the same degree of detail according to thereview of hazardous material as there may have been to the radiological aspectsof transportation. ...Aspects of transportation [are discussed], but not in thepotential for explosion, potential for HAZMAT spill, those sort of things intransportation in the transportation section. And I didn't see those addressedas potential candidate scenarios.


All hazardous material shipments are transported via commercial carriersin full compliance with applicable DOT regulations. Pantex Plant typeoperations do not consume or produce large quantities of hazardous chemicals. Consequently, the risks associated with Pantex Plant hazardous chemicalshipments are no greater than those associated with other industrial facilities. Further information on the types and quantities of hazardous chemical shipmentsassociated with Pantex Plant operations is available in the Safety InformationDocument (Pantex 1996a).

RC: 16.030

Doc: PC-017/13

If transportation of toxic materials and/or radiation materials to othersites poses a threat to [people] along [the routes] of transportation and toother travelers along the roadways, why would the storage of those substancesnot pose a greater threat to the health and safety of residents and workers ator near Pantex? We will have long-term, 24 hours per day exposure, which will bemuch greater than the meeting of a fellow traveler along the interstate or theexposure of someone in a roadside park.


The storage of pits in Zone 4 magazines does not result in radiologicaldoses to the communities surrounding Pantex Plant.

RC: 16.031

Doc: SG-012/10

Transportation of the pits is a very serious task. What assurances existfor safe transportation? For example, are the transporters meeting speed limits,obeying other traffic rules and using defensive driving techniques to reducetransportation risks? If drivers are [not] complying with safe drivingtechniques, accident risks are increased. These concerns should be addressed inthe DEIS.


Armed Nuclear Materials Couriers accompany each shipment containingspecial nuclear material. They also drive the highway tractors and escortvehicles while operating the communications and other convoy equipment. Couriers are required to obey all traffic laws. Transportation SafeguardsDivision (TSD) makes every effort to ensure its convoys do not travel duringperiods of inclement weather. Should the convoys encounter adverse weather,provisions exist for the convoys to seek secure shelter at previously identifiedfacilities. The TSD has also imposed a maximum 55-mile per hour speed limit onits convoys, even if the posted speed limit is greater.

RC: 16.032

Doc: MG-002/5

The Region of Influence (ROI) for the NTS alternative must be expanded toinclude the Clark County Urban Area through which all shipments are planned. Aswith other DOE EISs, the defined region of influence for the assessment ofimpacts is 50 miles. From Clark County's standpoint, this is a major flaw inthe study since the bulk of the impacts would result from the transportation ofthe plutonium pits and not the storage itself. This is because the storagetechnology is relatively advanced and the possible NTS storage sites are [well]isolated and controlled. Use of the ROI practically guarantees findings of noimpact. However, all highway routes that are under consideration for shipmentof the plutonium pits pass through the most congested areas of the State ofNevada on roads that are undergoing major construction, and in areas where thenumber of accidents and accident rates are the highest in the State.


See response to comment 16.013.

RC: 16.033

Doc: MG-002/6

Perceptions of Risk. The interstate route [I-15] historically used for DOEshipments to the NTS and now being considered for the additional Pantexshipments is within one-half mile of the Las Vegas Strip and downtown area. This is among the most popular tourist destinations in the country. This meansthat over 3,000,000 tourists who visit this area annually would be exposed totransportation safety risks and may perceive the area as dangerous and/or one toavoid, even under incident-free operation. Should even a minor incident (e.g.,unanticipated stoppage) or accident occur in this area, perceptions of itsseriousness may be amplified to a point that fewer people may choose this areaas their pleasure or business destinations. Even a minor downturn in thetourist cycle could have a devastating effect on the southern Nevada economy. Although the effects of perceived risk are not easily quantifiable, thisvariable must be taken into account as routes are screened and evaluated.


We agree that perceived risks are not easily quantified. Thesocioeconomic impacts of such perceived risks are even more difficult toevaluate. However, a statement characterizing this potential has been added tothe appropriate sections of the EIS.


Doc: MG-002/8

Accident Analysis and Emergency Management Measures. Another example of theserious constriction placed on impact assessment by a 50-mile ROI has to do withthe analysis of accidents and need for emergency management measures. Becausethe ROI takes into account only on-site areas, the impacts are so small as to bejudged insignificant, and transportation and emergency and emergency safetyissues do not need to addressed. Further, the new storage/transportationcontainer, the AT-400A, now under development, has not had real world experienceand its operational characteristics and vulnerability to acts of terrorism areopen to question. Again, this becomes insignificant if impacts are not beingconsidered outside the narrowly-defined ROI. In summary, we feel that allimpacts that have been addressed in the DEIS must be reconsidered using at leasta 100-mile radius from the Mercury entrance to the NTS in order to arrive at arealistic appraisal of potential impacts of relocation of the pits to that site. This would lead to a realistic appraisal of potential impacts due totransportation, the most public aspect of siting a storage area for plutoniumpits (and other waste) at the NTS.


See response to comment 16.013.

RC: 16.035

Doc: MG-002/9

While we accept the findings of the transportation risk analysis that isbased on the probability of a occurrence times its consequences, we are notconvinced of the validity of this approach for shipments to the NTS. The ClarkCounty Urban Area, with Las Vegas as its hub, contains the major concentrationof traffic and congestion in this mainly rural county. When the population,traffic, impedance, distance and other variables for links in the urban area areaggregated with those of all other links on a potential route, inside andoutside Nevada, the relative weight and importance of the urban links isdiminished. This then leads to a smoothing of the data and the usual result ofinsignificant risk. We ask that the DOE take another tack in assessing risk andresultant impact of transportation of nuclear materials, that of comparativerisk assessment as endorsed by the U.S. Department of Transportation in itsGuidelines for Selecting Preferred Highway Routes for Highway Route ControlledQuantity Shipments of Radioactive Materials, August 1992. This approach placesemphasis on comparison of routes on variables that are important indecision-making processes, rather than on probability figures that are almostalways insignificant and not interpretable to government decision-makers. Forexample, comparison may be made on exposure of special populations, impact onenvironmentally sensitive areas and even relative risk of negative perceptions. This type of analysis on prospective routes selected for analysis in cooperationwith affected jurisdictions would provide understandable results and a higherlevel of confidence in DOE actions than is not the case. As you know, ClarkCounty is willing to provide up-to-date information for your use in such anapproach.


The transportation analysis used in the EIS evaluates accidentsoccurring in both rural and urban areas. The Pantex EIS evaluates impactsassociated with the defined alternative of relocating pit storage from thePantex Plant. Included in the analysis are impacts associated with transportingpits to alternative storage sites by DOEs Transportation Safeguards Division(TSD). DOE is not using the Pantex EIS to decide between routes that will beutilized by TSD and as such, comparative routing analysis is inappropriate forthe Pantex EIS. Routes utilized by TSD are classified, compartmentedinformation and may not be disseminated except to persons with appropriatesecurity clearance and a need to know.

TSD operations are in compliance with the requirements of 49 CFR 177 forselecting, notifying drivers of, and adhering to preferred routes. The majorityof TSD travel (90 percent) is over interstate highway; the remaining 10 percentis over routes that meet the conditions for deviating from the preferred routewhen safety or security dictate such deviation. Regulations permit TSDdeviation from the requirements regarding notification of the routes used.

TSD personnel are briefed on construction, congestion, and severeweather along the route prior to travel. TSD crews make every effort to alter aroute or change travel time to avoid potential traffic hazards.

There is no "smoothing" of the risk due to sparsely populatedrural areas. The probability of a potential accident and the consequences ofpotential accidents are dominated by the urban areas.

RC: 16.036

Doc: SG-011/1

Please provide information on the metric ton amount of depleted uraniumcurrently stored on the Oak Ridge Reservation (ORR) and the metric ton amountthat will be shipped from the Pantex facility. Please provide the historicalmetric ton amount of depleted uranium at the ORR. Also provide information onthe environmental impacts for the interim storage of depleted uranium at theORR. The Division contends that if the historical levels of depleted uraniumstored (interim) at the ORR are exceeded, additional NEPA documentation shouldbe prepared to adequately address the impacts to human health and theenvironment.


The Pantex Plant EIS considers the environmental impacts associated withshipments of weapons and weapons components (including highly enriched uraniumand depleted uranium) related to Pantex Plant operations. The record ofdecision for the Pantex EIS will detail DOEs plans for interim storage ofplutonium components (pits). Impacts related to interim storage of depleteduranium at Oak Ridge Reservation are not relevant to the decisions resultingfrom the Pantex Plant EIS.

RC: 16.037

Doc: PC-025/10

If weapons are shipped around the world without an AT-400A style container,why does the [plutonium] require a special container? Doesn't a weapon pose thegreater risk potential?


The risks associated with nuclear weapons shipments are discussed involume I, section 4.14. Department of Transportation regulations and DOE ordersrequire the use of a certified Type B package for plutonium pit shipments.

RC: 16.038

Doc: PC-025/84

General comment sections 4.15 and 4.16. Please provide information on thelevel of quality assurance/quality control (QA/QC) defending the analyses ofthese sections. I would like the same information as requested on water and airquality sections of this EIS.


The quality assurance/quality control (QA/QC) of the referencedsections of the Draft EIS, as well as the entire document, was conducted inaccordance with the Tetra Tech Quality Assurance Program Plan (TT 1995). Theprogram is tailored for preparation of the EIS and to meet DOE Order 5700.6C andNQA-1 (ASME 1994), as appropriate. For detailed information, refer to thesedocuments.

The assessments (including methodologies, models, and results) of humanhealth impacts for volume I, sections 4.14 and 4.16, as well as the aircraftaccident assessment in volume I, section 4.15, were subjected to a multiplelevel technical peer review process to ensure technical validity. Included inthis review process was: (1) the analysts immediate supervisor, (2) thefunctional area manager, (3) technical experts from the Amarillo Area Office,and (4) technical experts from the Albuquerque Operations office.

Additionally, the assessments (including methodologies, models, andresults) of human health impacts for volume I, sections 4.14 and 4.16 as well asthe aircraft accident assessment in volume I, section 4.15 were exposed toextensive peer reviews. These reviews included two workshops occurring overseveral weeks along with independent supporting analysis by the workshopparticipants. The participants included representatives from DOE, SandiaNational Laboratories, Lawrence Livermore National Laboratory, Los AlamosNational Laboratory, the Defense Nuclear Facility Safety Board as well asnuclear safety experts from private organizations.

Additionally, these assessments were peer reviewed by DOE HeadquartersTechnical Safety Review Panel. This group is made up of safety expertsthroughout the DOE complex whose main responsibility is providing safetyanalysis guidance to Pantex Plant.

During the public review process, the assessments (includingmethodologies, models, and results) of human health impacts for volume I,sections 4.14 and 4.16, as well as the aircraft accident assessment in volume I,section 4.15, were reviewed by a group of independent scientists from Texas A&Mand the University of Texas.


Doc: PC-025/85

If the FL container is the only certified container available for shipmentpurposes, would DOE use the FL container to ease the 12,000 limit on Pantex ifthe AT-400A is not available? Is this a reasonable alternative requiring DOE toanalyze the use of the FL containers to prevent a shutdown at Pantex?


The alternatives considered in this EIS are container independent. However, DOE considers the AT400A container as the most likely to be used if theSecretary decides to choose a pit relocation alternative. DOE currentlypossesses a limited number of FL-containers (approximately 300). A significantfraction of these containers are in use at other facilities. The purchase of alarge number of FL-containers is not practical from either a programmatic or asafety perspective. DOE has committed to the development of a container thatwill enable compliance with the latest Nuclear Regulatory Commission (NRC) TypeB package certification testing requirements. The NRC recently modified thecertification testing requirements for Type B packages. The AT400A is beingtested to meet these newer, more stringent requirements. However, no datacurrently exist to prove that the FL-container will meet the newer requirements. The FL-container will retain its Type B certification based on previouscertification testing. However, this certification will be valid only for thosecontainers currently owned by DOE. DOE is committed to the development of a pitcontainer that meets the latest regulatory requirements.


Doc: PC-025/86

If the FL container is certified, why doesn't DOE order more FLs for storagepurposes?


See response to comment 16.039.


Doc: PC-025/96

... How many AT400A containers are in existence? Does this pose a problem,please analyze?


The design of the AT400A container is currently being finalized. Thereare only a few prototype containers in existence. Full scale production isexpected to begin at Pantex Plant in late 1996 or in early 1997.

RC: 16.042

Doc: PC-025/97

... Is it not reasonable that the most harmful event is a collision [with]heavy truck resulting in a rollover and fire. It appears that the event tree islinear rather than dynamic. Thus the analysis overlooks the compounding effectsand thus the maximum impacts.


All potential accidents that could lead to a release of hazardousmaterial are included in the databases used in the analysis. The analysisconsidered all combinations (and interdependence) of puncture, crush, impact,and fire environments. Further detail on the methodology and supportingdocuments can be found in volume II, appendix F.

RC: 16.043

Doc: CO-008/118

... How will the Texas Department of Public Safety and local emergencymedical services be handled in the Intersite Transportation Impact Assessment?Will the safety analysis developed by DOE be acceptable to the Texas Departmentof Transportation?


See discussion in section 1.3.12 of this volume.

RC: 16.044

Doc: CO-008/119

Page 4-262, Paragraph 3. Paragraph states, "These shipments are madein full compliance with all applicable DOT regulations." This is stated forhazardous material shipments on page 4-264, Paragraph 2, as well. As a generalcomment, the draft EIS makes assumptions about the equivalence of designrequirements and operations. They assume that the design requirements forvehicles, packaging, etc. are met at all times. How do they know this? Numerousstudies on compliance with regulations in the transportation industry show thatthere can be a significant difference between what is supposed to be and whatactually is. Moreover, many of the databases that are used to assess the safetyof hazardous materials transportation do not contain reliable and adequate datato make this assumption.


This statement that the draft EIS makes assumptions about theequivalence of design requirements and operations is incorrect. The analysisconsiders accidents resulting from improperly maintained equipment, humanerrors, and other failures to maintain vehicles properly. It is assumed in theanalysis that DOE Transportation Safeguards Division (TSD) has accidents ofsimilar severity and root cause as commercial trucking firms, which is aconservative assumption since TSD has not experienced an accident resulting fromimproperly maintained equipment. Further information on accidents consideredand databases utilized can be found in the Sandia National Laboratories document"A Statistical Description of the Types and Severities of AccidentsInvolving Tractor Semi-Trailers," (SNL 1994b).


Doc: CO-008/120

Page 4-262, Paragraph 3. Provide data about the operational reliability ofthe equipment, tasks, etc. and about the reliability of the inspection andmonitoring systems upon which safety relies. Are there data about inspectionand monitoring reliability? Has DOE assessed the completeness and reliability ofthe databases upon which they base their claims? Show with data that there is nosignificant difference between design and operations in this system. What arethe data?


The clearest indication of the operational reliability of theTransportation Safeguards Division (TSD) transportation system is its historicalaccident rate. The TSD accident rate is significantly lower than those ofcommercial trucking firms. The operating history with Safe Secure TractorTrailers (SST) transport is sufficiently long to define an overall tow-awayaccident rate. The mean estimate for the rate of tow-away accidents involvingan SST is 6.6 x 10-8 per mile. The tow-away accident rate for generalcommerce vehicles that most closely matches the SST in physical characteristicsand travel distribution is approximately 2 x 10-6 per mile.

It is assumed in the analysis that DOE TSD has accidents of similarseverity and root cause as commercial trucking firms, which is a conservativeassumption. Further information on accidents considered and databases utilizedcan be found in the Sandia National Laboratories document "A StatisticalDescription of the Types and Severities of Accidents Involving TractorSemi-Trailers," (SNL 1994b).

RC: 16.046

Doc: CO-008/121

Page F-26, paragraph 2,...left [column].... It is fallacy to [say] that "Becauseof the stringent regulations...there has never been...." The stringentregulations contribute to the result of no documented deaths of significantinjuries, but they are not the only reason. Luck, the smart response ofpersonnel, and other intervening factors not related to the quality of trainingand inspection plays a role.


We agree with the comment as stated. Text has been changed for theFinal EIS.

RC: 16.047

Doc: CO-008/122

Page F-26, paragraph 2,...left [column].... Did DOE assess how differentcombinations of "initiating events" may lead to accidents that couldresult in release of hazardous/radioactive materials? What combinations offactors were used? Was there any attempt in the study to look at this issue?


See response to comment 16.042.

RC: 16.048

Doc: CO-008/123

Appendix F, Tables and Figures F.5.1F.5.3. In the event of a large increasein [activities], how will the current system of transportation (includinginspections, loading, packagingin short, all the activities associated withmoving an object from one site to another) react? Will more inspections occur?Will more people be hired? Will more equipment be used? Or will the samenumber of inspections, equipment, and people be used to do more? How will thisaffect reliability in the system? (The research on human workload shows thatincreases in workload can increase failure/errors and that this may not occur ina linear fashion. Appendix F (tables and figures in F.5.1F.5.3) [is] based on100 observations100 observations over how many years (i.e., what frequency ofshipments)? Generally, there is good reason to suspect that as frequency ofactivities increase, one might observe more errors or more frequent errors.)Please provide clarification for exposure; i.e. what activity provides the mostexposure. Clarify exposure incurred by the repackaging of pits.


The acceptance of a pit shipment campaign is not expected to increaseaccident occurrence in a non-linear fashion. The workload increase if pitshipments occur will not strain the resources of the Transportation SafeguardsDivision even at a maximum weapons activity level. The total workload willstill be below peak levels of the past. In addition, TSD will operate using thesame procedures, maintenance, and training as in the past. The 100 observationsdescribed in the document refers to a statistical sample not a number ofphysical inspections. The exposure incurred by the repackagement of pits willbe discussed in volume I, section 4.14, of the Final EIS.

RC: 16.049

Doc: CO-008/124

Page 4-262, Table Data from radioactive waste shipments arelimited for the years 199294 only. Thus, one might expect that the "Annualexceedence probability" (Figures in F5.1F.5.3) would increase in the eventthe rates of shipping increase. What data were used to make the assumption thatfailure rates would increase in a linear fashion? How would the probabilitiesof accidents and the risks change if a non-linear relationship were assumed(increasing failures with increasing workloads and shipments)? Can DOE do thisanalysis? Why were data presented based on only 100 observations? Are there moredata than these?


Figures F5.1F.5.3 refer to Transportation Safeguards Division (TSD)shipments, not radioactive shipments. The acceptance of a pit shipment campaignis not expected to increase accident occurrence in a non-linear fashion. Theworkload increase if pit shipments occur will not strain the resources of TSDeven at a maximum weapons activity level. The total workload will still bebelow peak levels of the past. In addition, TSD will operate using the sameprocedures, maintenance, and training as in the past. The 100 observationsdescribed in the document refers to a statistical sample not a number ofphysical inspections.

RC: 16.050

Doc: CO-008/125

Page 4-269, Table Do the +/- factors around the base rate coverthe extra shipments that would occur to send the materials to other sites? Thedescription of action plans state that 2,000 weapons assemblies/disassembliesper year is the current activity level. Is this the base shipment schedule?


The +/- factors around the base rate bound a workload of 2,000 weaponsoperations per year with the subsequent intersite transportation. The base raterefers to the currently planned activity level for weapons operations, which isless than 2,000 operations per year.

RC: 16.051

Doc: CO-008/126

Page 4-269, Table When assessing the risks in a transportationsystem, was the entire system, from design of components, regulatory context,inspections and monitoring, to preparing material for transportation, toloading, to shipping, etc., considered? [If] not, explain. The reason this isimportant has to do with how failures/errors at one time in the system operationcan affect subsequent events. For example, if someone drives off the road whentransporting one load, the consequences only affect that single load ofmaterial. However, if there is an incorrectly designed or tested package (e.g.shipping container), it would affect all shipments using that package. This hasoccurred in the high-level radioactive waste transportation system.


The analysis was performed with a system perspective and considered allaspects of highway shipments. No attempt was made to model unidentifiedsystematic problems. The DOE believes that the policies and procedures in placeare sufficient to minimize the introduction of systematic problems into the DOETransportation Safeguards Division system by correctly identifying andcorrecting any such problems that occur.

RC: 16.052

Doc: CO-008/127

Page 4-269, Table Was a risk assessment completed for the totaltransportation system for improperly maintained equipment? Provide the datasources and the methodology used in this assessment. (It is not reasonable toassume that there will never be inspection failures.) How would such scenariosaffect risk estimates?


Accidents with root causes of improperly maintained equipment wereconsidered in the analysis. Further information on accidents considered and thedatabases used can be found in the Sandia National Laboratories document "AStatistical Description of the Types and Severities of Accidents InvolvingTractor Semi-Trailers," (SNL 1994b).

RC: 16.053

Doc: CO-008/128

Page 4-256, Paragraph 1. There have been mistakes (errors) made in thedesign requirements and testing protocol of the DOT and NRC for packaging andtesting, and thus in reported results. There are errors and failures inmonitoring and inspections so that malfunctioning/corrupted packaging continueto be used although they do not satisfy the testing requirements. Has DOEaddressed such scenarios in their analyses? If not, explain.


No attempt was made to model unidentified systemic problems. DOEbelieves that the policies and procedures in place are sufficient to minimizethe introduction of systematic problems into the DOE TransportationSafeguards Division system by correctly identifying and correcting any suchproblems that occur.

RC: 16.054

Doc: CO-008/129

Page 4-256, Paragraph 1. Regarding the adequacy of databases on pages F-18and F-22, prior studies suggest that they may not contain complete or reliabledata in all cases. ...Does DOE account for such inadequacies in theirassessments? For example, what is the uncertainty of these databases? Makingassumptions that reflect the uncertainties, in the data resulting from theirincompleteness and lack of reliability. Please reassess the risk.


Uncertainties in data and the means of quantifying these uncertaintiesare described in the following documents:

"A Statistical Description of the Types and Severities of AccidentsInvolving Tractor Semi-Trailers," (SNL 1994b).

"Determination of Influence Factors and Accident Rates for theArmored Tractor/Safe Secure Trailer," (SNL 1994a).

RC: 16.055

Doc: CO-008/130

Page F-19, Figure F.6.3.1-1. Safety analyses that do not directly addressthe role of human error in contributing to risks are weak. Human error is oftenfound to be the single largest contributor to failure frequencies. This EISseems to focus on mechanical failures. Is human error included in the failurerates that are used in event trees. How are they incorporated? How areassumptions made about human error rates in a greatly expanded transportationsystem (under scenarios of shipping pits to other sites and increased rate ofdismantlement)?


Accidents resulting from human error are included both in the accidentrate determination and in the accident severity determination. Furtherinformation on accidents considered can be found in the Sandia NationalLaboratories document "A Statistical Description of the Types andSeverities of Accidents Involving Tractor Semi-Trailers," (SNL 1994b). Theacceptance of a pit shipment campaign is not expected to increase accidentoccurrence in a non-linear fashion. The workload increase if pit shipmentsoccur will not strain the resources of Transportation Safeguards Division (TSD)even at a maximum weapons activity level. The total workload will still bebelow peak levels of the past. In addition, TSD will operate using the sameprocedures, maintenance, and training as in the past.

RC: 16.056

Doc: CO-008/131

Page F-19, Figure F.6.3.1-1. How many more shipments would there be eachyear (approximately) if the pits are shipped to SRS, NTS, etc? How muchlarger/smaller are these rates than current rates? Are these different ratesused to estimate different failure rates in the assessment? Would risk estimateschange at all, if times of shipments were changed (e.g., night time vs. day timevs. afternoon only vs. weekends, etc)?


The exact number of shipments per year is classified information. However, the workload increase if pit shipments occur will not strain theresources of the Transportation Safeguards Division (TSD) even at a maximumweapons activity level. The total workload will still be below peak levels ofthe past. In addition, TSD will operate using the same procedures, maintenance,and training as in the past.

Operating environments, such as road type, road location, and time ofday, play an important role in the observed accident rates of heavy trucks usedin general commerce. These same factors influence the accident rate of the SafeSecure Tractor Trailers (SST) used by the Department of Energy to transporthazardous cargos within the continental United States. Because there is nolimitation on the times that SSTs can travel, an average accident rate wasdetermined appropriate for influence factors related to the time of day and daysof the week. Additional details and discussions on how these influence factorswere accounted for in the analysis is available in the Sandia NationalLaboratories report "Determination of Influence Factors and Accident Ratesfor the Armored Tractor/Safe Secure Trailer," (SNL 1994a).

RC: 16.057

Doc: CO-008/132

Page F-8. How many shipments are actually anticipated per year? If pits areshipped elsewhere, how would shipment rates differ from FY 1997?


The exact number of shipments per year by the Transportation SafeguardsDivision (TSD) is classified information. However, the workload increase if pitshipments occur will not strain the resources of TSD even at a maximum weaponsactivity level. The total workload will still be below peak levels of the past. In addition, TSD will operate using the same procedures, maintenance, andtraining as in the past.

See responses to comments 16.005 and 16.006.


Doc: CO-008/133

Page F-8. What are the estimates for subsequent years? How much change willthere be in the system rate of shipments over the assessed period of time? Ifthey are being shipped to another location for storage, this would increase thenumber of shipments per year.


See response to comment 16.057. Additionally, see responses to comments16.005 and 16.006.

RC: 16.059

Doc: SG-010/5

Embracing this strategy will reduce risks and risk perception issuesassociated with the unnecessary transportation of fissile materials on publicroads and highways throughout the country. Clearly, a prolonged shippingcampaign of plutonium pits along the Nation's highways, especially through largeurban areas like Las Vegas, will cause significant adverse socioeconomic andcultural impacts even if no accidents occur.


See discussion in section 1.3.12 of this volume.


Doc: PC-028/7

Kirtland Air Force Base also serves as an International Airport. Majorhighways almost borders KAFB to the west and north. This places the transportof nuclear pits on, about, and above KAFB/Albuquerque. The air traffic isextremely high and the highways are busy with Albuquerque, New Mexico, andIntra/Inter state traffic. The other alternative sites dont have thisproblem-select one of them.


All alternative sites involve shipment of pits over routes that passthrough one or more cities with an international airport and busy highways. This is not unique to Kirtland Air Force Base (KAFB) or Albuquerque. Adescription of risk due to the transportation of pits to KAFB is presented involume I, section 4.16.

3.17 Environmental Justice

RC: 17.001

Doc: HT08/2

Executive Order 12898, Federal Actions to Address Environmental Justice inMinority Populations and Low Income Populations, President Clinton's February11th, 1994 memorandum for the heads of all departments and agencies requires ananalysis of environmental effects on low income and minority populations toinclude human health, social, and economic effects. Why does the draft of allthree documents analyze only the human health effects of the Proposed Actionsand not the social and the economic effects as required by the Executive Order?


Social and economic (Socioeconomic) impacts of the continued operationsat Pantex Plant have been considered in volume I, section 4.11, SocioeconomicResources. In the Environmental Justice section, the location of minority orlow-income populations, identified in volume I, Figure 4.17.11, and Figure4.17.12, leads to the conclusion that no disproportionately social and economicimpacts occur on minority or low-income populations from Pantex Plantoperations. The text in the volume I has been revised to state this conclusion. Section 4.17.2 of the Draft EIS provides discussion of beneficial economicimpacts to both majority and minority populations. A good example of adversesocial and economic impacts on minority or low-income community would be fromthe construction of a freeway through such a community. In the past, manyfreeway projects have divided these communities into detached neighborhoods withloss of social interaction, economic loss from declining property values, anddisruption of social and economic life resulting from forced relocation ofresidents from the project area. No such adverse impacts are generated by thecontinued operations of the Pantex Plant.

Human health impacts from Pantex Plant operations are strongly tied tothe geographic location of minority and low-income populations. If minority orlow-income populations are concentrated in the immediate vicinity of the plant,there is a possibility that such a population could be disproportionatelyimpacted. The Pantex EIS has analyzed the potential for offsite release in bothroutine and offsite conditions and has not identified a release scenario thatwould cause a disproportionate effect on any one population, including minorityor low-income populations.

RC: 17.002

Doc: HT08/3

The socioeconomic [analysis] is a little bit different than the ExecutiveOrder covering what we just talked about, the environmental justice in minoritypopulations. ...An analysis of the social and the economic [factors] have to goalong with the health effects in the environmental justice analysis, not justthe health effects.


See response to comment 17.001.

RC: 17.003

Doc: HT11/33

With regard to environmental justice, if you're shipping by -- through theinterstate, or if you happen to use rail, both the interstate and the rail goalong about the same route, more than 38 percent of the minority population ofClark County lives within a half mile of either of those routes. And so theimpacts or risks might be a little bit higher.... Thirty-eight percent of thepopulation along the railroad and interstate is minority or low-income. InClark County the minority, low-income percentage is 11. So there's asubstantial difference between the minority, low-income population along theroutes and the general minority, low-income population of Clark County.


The environmental justice issue has been analyzed consistently within a 80-kilometer (50-mile) radius circle from the project location ateach site under study. The issue of transportation safety has, however, beendiscussed in volume I, section 4.16, Intersite Transportation of Nuclear andHazardous Materials. The routing of radioactive materials (including waste)being shipped on the nation's highways and roads is subject to regulations thatare administered and enforced by the U.S. Department of Transportation. Theprimary objective of these regulations is to ensure that the motor vehiclestransporting a regulated quantity of radioactive material are operated on routesthat minimize radiological risk (49 CFR 397.101[a][1]). DOE will continuetransporting radioactive materials in accordance with these regulations.

RC: 17.004

Doc: CO-008/28

The current definitions/criteria of environmental justice do not take intoaccount the people in rural areas who are politically handicapped in comparisonwith a large urban center. The weight of the population in the urban areaimpacts elected representation to such a degree that the minority rural voters,in effect, have little voice, even when they are most highly impacted bydecisions. Definitions that are based on race/ethnicity or income alone do notaddress this problem. This is the situation that exists around Pantex, whereneighbors, no matter how well organized, cannot "outweigh" the numbersand interests of urban Amarillo.


Comment is noted. Concerns of all individuals, whether belonging tomajority or a minority and whether living in urban or rural areas are taken intoconsideration within the overall context of the assessment of potential impactson the population within the project's Region of Influence. However, theanalysis in the Environmental Justice section is provided to meet therequirements of Executive Order 12898, Federal Action to Address EnvironmentalJustice in Minority Populations and Low-Income Populations. Although no finalguidance for implementing the Executive Order has been issued by EPA, guidanceissued by the Council on Environmental Quality and the Department of Energys owninternal guidance were used to focus consideration of environmental justice onlarge enough groups belonging to minority or low-income populations and not onsingle or few rural voters. Communities in the Pantex region of influence havebeen defined as Census Tracts in the Amarillo urbanized area and rural BlockNumbering Areas (BNAs) outside the urbanized area.

RC: 17.005

Doc: CO-008/29

This comment is a duplicate of comment 17.001.

RC: 17.006

Doc: HT13/32

... When you are considering environmental justice, do you also considerthe number of nuclear projects that are already within a state?...

I mean it is like I am up in Los Alamos, and they want to move Rocky Flatsoperations to Los Alamos. They want to shoot missiles. They want to dumpradioactive waste in the Rio Grande. They want to put midlevel waste at WIPP. They want to do morethey want to expand the Alamogordo testing range. Shouldn'tthat be part of environmental justice to look at how many nuclear projects thereare already in the state?


The analysis in the Environmental Justice section is provided to meetthe requirements of the Executive Order 12898, Federal Action to AddressEnvironmental Justice in Minority Populations and Low-Income Populations. DOEfollows site selection criteria for these types of projects. DOE looks at allprojects currently existing and future projects across the country, and analyzeshow they will affect a local area. Our analyses concluded that none of theproposed actions would result in either significant impacts to the entireaffected populations or disproportionate adverse impacts to low-income orminority populations.

RC: 17.007

Doc: HT13/33

Isn't there an impact section that addresses the fact that there is noevidence that cumulative impacts will lead to a significant consequence to thepeople? Is that a part of the environmental justice?


Cumulative impacts have been discussed for each of the 17 environmentalresources or issues in this EIS, including environmental justice.

RC: 17.008

Doc: HT12/4

And so, based on that, I have a comment that I am going to make later, but Ithink that it's really important particularly under the NEPA regulations and ineffort by the Department of Energy to really bring the public more into thisdiscussion that at some point we look at what is the weakness of our outreachstrategy that does not allow us to bring more -- a diverse group of people fromthis area to these kinds of meetings.

Because based on what the gentleman just said -- and I just saw that in thesummary that it does, in fact, state that a disproportionate burden would beborne by minorities as it's defined here and low-income people in this area,then they should be in greater numbers at this table to, one, learn what is atstake, what are the potential dangers, what are the benefits, et cetera, etcetera, but also to be here to raise their own questions and concerns and thenbe prepared to help make recommendations that will be factored into the finaldecision.

Because we can point to the successes of the plant, the positive role thatit has played in this community, the fact that it is one of the largestemployers, but there may be some other things that those regular citizens needto say that may in some way shape the final decision on these particular threeEISs that's needed.


Your comment is noted. DOE has made significant changes in itscommunity outreach programs and continues to improve upon its past practices inresponse to public input.

RC: 17.009

Doc: HT12/9

... I'm curious, are there additional government policies that certaindemographic groups as being less valuable, more expendable, whatever the termmay be in, humane terms, as opposed to other populaces with regard toinstitutions like SRS?


To elaborate on the response given at the public hearing, the Nation'snuclear program has evolved over the past five decades in the context ofNational security requirements. Locations of nuclear facilities were notdetermined by the racial or ethnic characteristics of the population in thecommunities where facilities were located. The Federal government has, however,become more aware of the fact that certain Federal programs in the past haveresulted in disproportionately high environmental impacts on minority andlow-income populations. The President, therefore, issued Executive Order, 2898,in February 1994, to give environmental justice special consideration inlocating Federal facilities in future.

RC: 17.010

Doc: HT12/24

Okay. And then I had another question about the list, how comeenvironmental justice is broken out and it's not included under culturalresources or socioeconomic resources? And having taught NEPA, we normally wouldput it under there and not have it by itself. And I noticed it was discussed indetail. There are only two things discussed in detail and the rest is [not]....


Your comment is noted. It is true that till recently, environmentaljustice was implicitly included in the socioeconomic resources, particularly inthe social impact sections, when social impacts were evaluated separately fromthe economic impacts. With the issuance of the Executive Order 12898 in 1994,which calls for a discussion of environmental justice issue in all EISs, it hasbeen given special attention and was, therefore, discussed in greater detailthan has been the case in earlier documents.

RC: 17.011

Doc: HT12/30

Another comment is you claim here and also in the document of the SavannahRiver section fully evaluated environmental justice. And I read the two orthree pages on environmental justice and there are a lot of facts, there are noconclusions. ...Your companion EIS [SSM PEIS] ...makes all kinds of erroneousconclusions on environmental justice.... But you don't make none. And let youclaim you --


In accordance with Executive Order 12898, we conducted an analysis todetermine whether the project (interim storage of plutonium pits) would havedisproportionately high and adverse human health or environmental effects on theminority and low-income populations and concluded that no such impacts wouldoccur. Please refer to the Stockpile Stewardship and Management PEIS for theirresponse to your comment.

RC: 17.012

Doc: CO-002/5

This comment is a duplicate of comment 17.001.

RC: 17.013

Doc: SG-012/7

Vol. 1, page 5-69, Environmental Justice. The entire section relieson 1990 census data. The "no impact" decision does not considerprojected population growth in this location over the period of time that thepits may be in storage. Albuquerque, for example, has had a substantialincrease in population during the last 20 years.


The Environmental Justice section requires breakdown of population byminority and low-income groups at the lowest possible geographical level, suchas Census Tract or Blocks. The 1990 census is the only source which providesdata consistently for Pantex and the other four sites (Nevada Test Site,Savannah River Site, Kirtland Air Force Base, and Hanford). It gave us a commonbasis for analysis throughout this EIS. Socioeconomic impacts for theAlbuquerque area, including population changes, are discussed in volume I,section

RC: 17.014

Doc: MG-002/7

... The population along the Interstate and nearby connectors includes adisproportionate number of minority and low-income individuals [38% minority andlow-income, as compared to Clark County's 24%]. In addition, U.S. 95, theconnector between the Las Vegas Urban Area and the NTS, serves thefastest-growing area of the country with regard to new residents andconstruction. Designation of a transport route for plutonium pits along thiscorridor may serve to slow down such growth or, possibly, result in a generallowering of property values. Use of a constricted ROI causes these importantissues to be ignored. This is another example where a procedural conventionvirtually guarantees that potential impacts may not be identified.


See response to comment 17.003.

RC: 17.015

Doc: PC-025/87

General comment for section 4.17: What are the Minority and Low-Income areasby US congressional districts in the ROI? Does this show greater impactpotential? What about by Texas legislature districts? Page 5-55 Materiel vs.Material?


Environmental Justice analysis for minority and low income areas lookswithin an 80-kilometer (50-mile) radius circle centered in the southwest cornerof Zone 4 of Pantex Plant. Minority and low-income population is presented atthe lowest possible geographical level, i.e., Census Tract and Block numberingareas in the rural areas to identify maximum impacts. Data by U.S.Congressional districts, which are generally larger then Census Tracts, wouldshow fewer areas with concentrations of minority or low-income populations. Moreover, minority and low-income data are not available in sufficient detail atthe Congressional district and legislature district level.

On page 5-55 the word material is spelled two different ways. The wordspelled "materiel" used in the sentence "KAFB is an Air ForceMateriel Command base..." means equipment, apparatus, and supplies, as gunsand ammunition, of a military force. The word spelled "material" asused "nuclear material..." means the substance or substances out ofwhich a thing is or can be constructed.

RC: 17.016

Doc: CO-008/30

How are individual minority sensitivities in the worker population assessedin the study? Do the training programs and safety information, materials toworkers, and the community account for different literacy rates and/or primarylanguages? Does DOE have any data about the extent to which information aboutthe Plant is known or understood, or the effects of radiation exposure areknown/understood in the minority community? If so, provide the data.


Occupational Safety and Health Administration and implementing DOEOrders address safety and health issues for all workers at Pantex regardless ofminority or income status, including radiation exposure. Volume I, section4.17, Environmental Justice, discusses the potential for radiation effects onminority and low-income populations.

RC: 17.017

Doc: CO-008/31

Was exposure to contaminated clothing, for example by minority laundryworkers, considered? If so, how?


Radiation and/or chemically contaminated clothing is not laundered butis disposed of in accordance with applicable regulations.

RC: 17.018

Doc: PC-008/2

This comment is a duplicate of comment 17.001.

RC: 17.019

Doc: PC-028/6

Page 5-69, para section is listed as Environmental Justice.Of all the sites KAFB/Albuquerque has the highest, most diverse population, andputting the pit storage activity in KAFB adds [un]necessary risk toKAFB/Albuquerque.


The Manzano Weapons Storage area at Kirtland Air Force Base is one ofthe five sites which have been analyzed in this EIS to identify environmentalimpacts of pit storage. One of these five sites will be identified as the pitstorage site by the DOE after taking into consideration environmental, cost,technical, and other relevant factors.

RC: 17.020

Doc: HT17/89

The document is designed, again, to reassure. 20% minorities in theworkforce is presented as a benefit of good hiring practices. Minoritypopulations are assumed to live too far away (17 miles) to have any riskassociated with them. How was inter-individual sensitivity to the workerpopulation assessed in the study? It does not look like it was.


Analysis in the Environmental Justice section is provided at the CensusTract and Block Numbering Area levels. These are the smallest geographicalunits for which minority and low-income data are available. Inter-individualsensitivity to the worker population is dealt with as an administrative concernby the Pantex Plant management and is out of scope of the EIS analysis.

RC: 17.021

Doc: HT17/90

Do the training programs and safety/information materials to workers and thecommunity account for different literacy rates [and] primary languages? Does theagency have any data about the extent to which information about the plant isknown or understood, or the effects of radiation exposure are understood in thecommunities, minority and not?


All maintenance and production technicians at the Pantex Plant must passthe Audit Basic Learning Examination (ABLE) which establishes, if passed, thatthey have the equivalent of an eighth grade English reading and mathcomprehensive level. U.S. citizenship is also required. All Pantex Plantemployees, subsequent to hire, receive general employee training, which is givenin English, covering general safety training at the plant to include basicunderstanding of radiation safety. DOE and Pantex Plant have initiated a broadprogram of improving communication with the public by providing fact sheets,speakers, exhibits, information fairs, open houses, and presentations withmaterial geared to elementary school students. Pantex Plant also invites thegeneral public to attend Pantex Plant Night each month to speak directly withplant personnel. The time and place is announced through the local media. Inaddition, specific inquires may be made to the Pantex Plant information officeto obtain further information on training programs and plant safety.

RC: 17.022

Doc: HT17/91

The agency did not address the issue of radiation exposure to laundryworkers, etc. offsite or onsite. Often these kinds of exposures arepredominately to minority populations.


See response to comment 17.017.

RC: 17.023

Doc: HT17/92

How are transportation routes related to minority communities?


Transportation routes are selected with highest consideration given topublic safety and security of the materials being shipped. Generally, these areinterstate highways. Where DOE facilities are located away from interstates andalternate routes through communities are available, routes are selected toprovide maximum safety and security and are not based on minority populationdistribution.

RC: 17.024

Doc: CO-005/21

This comment is a duplicate of comment 17.020.

RC: 17.025

Doc: CO-005/22

How was inter-individual sensitivity to the worker population assessed inthe study? It does not look like it was. Do the training programs andsafety/information materials to workers and the community account for differentliteracy rates, primary languages. In the communities, how and who provides theinformation? Provide any data about the extent to which information about theplant is known or understood, or the effects of radiation exposure areknown/understood in the communities (minority and not)?


See response to comment 17.021.

RC: 17.026

Doc: CO-005/23

The document did not address the issue of radiation exposure to laundryworkers, etc. offsite or onsite. Often these kinds of exposures arepredominantly to minority populations.


See response to comment 17.017.

RC: 17.027

Doc: PC-010/1

If pits in SSTs travel through Hispanic neighborhoods, residents couldperceive that a threat to their health and safety.


The specific routes used by Safe Secure Tractor Trailers are classifiedfor National Security. Safe Secure Tractor Trailers may, however, travel asmuch through neighborhoods belonging to majority population as through minoritypopulations, including Hispanic neighborhoods. Pantex-related intersitetransportation activities will result in a maximum annual collective generalpopulation dose of 0.40 person-rem per year (4.0 person-rem for ten years ofoperations). The health and safety risks are, therefore, considered minimal andwould not affect Hispanic neighborhoods disproportionately.

3.18 Irreversible and Irretrievable Commitments of Resources

RC: 18.001

Doc: HT12/2

I'm looking for a complete environmental assessment [that evaluates],...thetotal environmental picture including, as NEPA mentions repeatedly, impact onfuture generations and conservation of nonrenewable resources.


Volume I, section 4.18, discusses irreversible and irretrievablecommitments of resources. Volume I, section 4.19, discusses unavoidable adverseenvironmental impacts. Radiological impacts are discussed and analyzed involume I, sections 4.7, Air Quality and 4.14, Human Health.

3.19 Unavoidable Adverse Environmental Impacts

No comments received.

3.20 Relationship Between Local Short-Term Uses of the Environment and the Maintenance and Enhancement of Long-Term Productivity

No comments received.

3.21 Cumulative Impacts

RC: 21.001

Doc: HT10/1

My comment and question revolves around the term cumulative impact. Asdefined in the Council on Environmental Quality Guidelines, cumulative impact isthe impact on the environment [that] results from the incremental impact of theaction when added to other past, present and reasonably foreseeable futureactions, regardless of what agency, Federal or nonfederal, or person undertakessuch other action. Cumulative impacts can result from individually minor, butcollectively significant actions, taking place over a period of time. That'sthe comment.


As directed by the Council on Environmental Quality, a scoping processwas employed to identify the scope and "significant issues" thatneeded to be addressed. The "scope" is defined to include both "connected,""cumulative," and "similar actions." Cumulative impacts areaddressed and discussed in each resource area as well as with the alternatives.

RC: 21.002

Doc: HT14/3

... Equity impacts must be addressed in the assignment of new nuclearmaterials, including plutonium, to Hanford.


This comment on equity impacts is part of the series of pointsspecifically related to long-term plutonium storage and disposition. Theconcept of equity is very difficult to apply within the specific scope of thisEIS because: 1) transfer of pits to Hanford Site would be only an interimaction of no more than 10 years, 2) the Hanford alternative is limited to only8,000 pits and it is not progammatically feasible to consider smaller amountsat multiple sites, and 3) long-term storage and non pit form plutonium andplutonium pits are within the scope of the Storage and Disposition PEIS.

RC: 21.003

Doc: CO-010/3

We are pleased to note that the Draft EIS has not identified any significantenvironmental impacts from the use of existing Hanford facilities for thispotential mission.


Volume I, section 5.4.1, assesses the environmental resources at HanfordSite that have the possibility to be impacted. The analyses indicate that theimpacts to the resource areas would be minimal.

RC: 21.004

Doc: CO-009/2

Fundamental to DOE's further consideration of the roles Pantex should playrelative to the changing missions of the nuclear complex is the unequivocalrecognition that even accumulatively, there would be NO significant adverseenvironmental impacts from retention and potential expansion of the variety ofmissions possible for Pantex.

The summaries of the relevant draft EISs do not report this fundamentalconclusion explicitly; rather, in some instances, the summaries misrepresentthat conclusion, reporting, instead, effectively minuscule environmentalpotentialities that are characterized as "adverse" only because theydo not equate to measurable "benefits." We suggest the rote languageof EISs should be expanded to recognize effectively neutral outcomes (not merely"beneficial" or "adverse" consequences).


Though the environmental "potentialities" (i.e., impacts)might seem "minuscule," 40 CFR ¤1502.2 states to "devotesubstantial treatment to each alternative considered in detail, including theProposed Action so that reviewers may evaluate their comparative merits."

RC: 21.005

Doc: HT17/12

Finally, I think the overall weakness is probably in the cumulative impacts. You've broken down the process into bits and pieces, where you look at, if thishappens you lose this many jobs, and if this happens you lost this many jobs. There's a real lack of effort to try to tie those together and integrate thatand say worst-case, best-case. And I think that would be really helpful for thepublic at large to find out what the future of the plant is.


When the scoping period occurred for the Pantex EIS, there were numerouscomments pertaining to socioeconomics (refer to DOE/EIS-0225-IP pages A-5through A-9). These comments were then utilized to prepare the methodologies(see volume II, appendix A), which were then formulated into the body of theEIS. Many of the socioeconomic comments were related to the cumulative impactsof the Proposed Action and Alternatives. The Cumulative Impacts sectionsincluding volume I, sections 4.21, have been simplified for easierunderstanding.

RC: 21.006

Doc: HT17/47

...One sort of succinct thing to deal with is in your cumulative impactsections, where you try to encompass the PEIS's that are floating around outthere, when you deal with the Storage and Disposition PEIS, you describe storageand speak to that. And then you describe disposition and characterize it assort of your bounding case that includes a reactor, and when there's a reactor,there's a MOX fuel site, a processing site, et cetera, et cetera. I ask you allto rework your storage definition. Storage does not mean that we won't haveprocessing at Pantex. ...That, too, can be the scenario under storage. But tohave storage set all by itself is inaccurate and it just won't do.


The scope of this EIS includes interim storage of pits. The StockpileStewardship and Management and the Storage and Disposition PEISs evaluatelong-term stockpile management and long-term storage and the final dispositionof plutonium, respectively.

RC: 21.007

Doc: MG-002/2

The EIS must take into account cumulative impacts on Clark County that mayresult from the selection of the Nevada Test Site (NTS) as a storage or disposalsite for a number of DOE activities. Given the approach taken in the DEIS thatidentifies only impacts from this one activity, it is not possible to reliablyestimate the impacts to a geographic area of jurisdiction that may result from anumber of initiatives taken by DOE. That is, even though other related NEPAstudies for storage or disposal of nuclear materials. Based upon the fact thatthe NTS is mentioned prominently in a number of ongoing DOE EISs, this lattersituation is a distinct possibility.


DOE recognizes the concerns as related to geographic cumulative impactsat the Nevada Test Site (NTS). The NTS EIS covers more specific issuesconcerning the cumulative impacts at this site; cumulative impacts from relatedNEPA studies at NTS are within the scope of the NTS EIS. For the Pantex EISpurposes, NTS was looked at in the context of interim storage, which hadresulted in no significant impacts to the environment, in both its natural andphysical aspects.

RC: 21.008

Doc: CO-008/135

... Page 3-4. Would the six referenced upgrades require new, or additional,environmental documentation if the Proposed Action is implemented?


There would be no additional environmental documentation for those sixproposed projects. Page 3-3 of the EIS states, "Specifically, the ProposedAction includes...Performing all required facility upgrades, modifications, andreplacement of facilities, and new proposed projects that are foreseeable atPantex Plant, as described below." The section then goes on to discusseach of the six proposed projects.

RC: 21.009

Doc: SG-010/2

In reference to the detailed analysis of potential environmental effects atthe two sites under consideration for pit storage at the Nevada Test Site (theDevice Assembly Facility [DAF] and the P-Tunnel Complex), we concur that pitstorage at either of these sites would not have any direct "significant"environmental impacts on existing environmental resources. We note that newconstruction at the Test Site would occur within existing facilities [inside theDAF or P-Tunnel complex] and/or on adjacent lands that are already disturbed. Because of this, we have purposely forgone a detailed review of the "direct"environmental impacts presented in the DEIS. There are, however, certain "indirect"and largely cumulative impacts that could result from pit storage at the NevadaTest Site. For example, if plutonium pits were placed in the P-Tunnel complex,local and/or regional earthquakes could pose significant seismic risks thatmight lead to tunnel collapse. In this regard, we concur that, if Nevada isselected for pit storage, a separate assessment of the risks associated withseismic events would be required.


If the P-Tunnel complex were to become the preferred option under theRelocation for Pit Storage alternative, DOE would consider performing a riskassessment for the facility.

RC: 21.010

Doc: CO-008/134

The combined cumulative impacts resulting from adding the boundingalternatives in the other three PEIS documents to the Pantex EIS do not fullyaddress all the combined effects. Give the combined cumulative impacts of allfour documents in each individual category of the document.


Each alternative relating to the PEISs and the Pantex EIS has beenaddressed individually. Due to the fact that there will be four RODs, thereaders are given the opportunity to review the cumulative impacts at each siteand for the proposed/alternative activities. In volume I of this EIS, section4.21 and chapter 5 discuss both the environmental and cumulative impacts asrelated to each candidate site. For further information relating to other siteslisted as alternatives, please refer to the other PEISs.

3.22 Department of Energy Policy

RC: 22.001

Doc: HT11/25

How many pits are ready to be stored right now...that [need] to bedecommissioned so that they can be stored somewhere? How many weapons are readyto be dismantled?


The actual number of weapons ready to be dismantled is classifiedinformation. The Pantex EIS evaluates, as an upper bound, the impactsassociated with dismantlement of 2,000 weapons per year. There are no pitswaiting to be stored.

RC: 22.002

Doc: HT01-02/1

I'm also concerned that we're focusing just on dragging out the life of thecurrent weapons without taking positive steps toward replacing them. And itwill be all too soon before the end of their design life is upon us. I thinkwe've got a real question whether we are able to build nuclear weapons again andhow.


Development of replacement nuclear weapons is not part of the ProposedAction or alternatives discussed in the Pantex EIS.

RC: 22.003

Doc: HT13/9

... One of the issues that a lot of us are concerned about when it comes topits, wherever they are, is the availability of not only local and Stateinspection of these facilities but international inspection.

[There is] a lot of concern about pits both here and in Russia and in otherplaces.... Folks want to know how they are handled to make sure they are notbeing misused, reused, put back in because these are, after all, supposed to besurplus pits that are not supposed to be for weapons anymore.


No specific program for International Atomic Energy Agency or otherinternational surveillance and/or inspection has been established. DOE hasimplemented security measures to ensure pits would not be subject to misuseduring storage and still be available for inspection.

RC: 22.004

Doc: HT13/10

Surplus pits. Pantex is a CERCLA site, but Sandia isn't yet. The questionthough is, how would international inspection be accommodated at the Manzanosite, that is both at Presidential directive in terms of the nonproliferationpolicy, and it is also something the rest of us are interested in. ...I aminterested in knowing how the access and accessibility of the site would be forinternational inspection.


To elaborate on the response given at the public hearing, DOE has notyet established procedures for international inspection of pits. However, atthis time there is no reason to believe that any facilities would needmodification to accommodate inspection. Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA) designation does not affect thepotential for International Atomic Energy Agency inspection of pits.

RC: 22.005

Doc: HT13/11

So you don't know, among the five sites [that] you have shown, if there areadvantages or disadvantages from an international inspection standpoint?


To elaborate on the response given at the public hearing, that issue wasnot a significant factor in selecting Pantex Plant as the preferred alternativefor interim storage of plutonium pits. Neither would it have been a significantfactor if any of the five alternate sites had been selected. However, theDepartment considers international inspection to be equally facilitated by allsite alternatives. Technical and policy issues, such as those pertaining tononproliferation, are part of the decision making process, but are not requiredto be part of the NEPA document as noted in 40 CFR 1501.2(b), 1501(b), and1505.2. However, the environmental factors, together with the policy andtechnical factors will be available to the decision maker at the time of thedecision; not just the environmental factors.

RC: 22.006

Doc: HT13/12

Just to be clear, the pits, for whatever interim period of time they are atwhatever facility they are, need to be inspectable. That doesn't necessarilymean that somebody can come in and physically look at the pits. There are waysthat pits can be inspected without physically being able to require to divulgethe shapes and those kinds of things.

So as an affirmative statement, and one of the many flaws in this document,from my standpoint, is the fact that it doesn't evaluate that issue, does notset up at any and all for the possible sites inspection criteria as a seriousflaw....


See response to comment 22.003. Additionally, the Department considersinternational inspection to be equally facilitated by all site alternatives.Technical and policy issues, such as those pertaining to nonproliferation, arepart of the decision making process, but are not required to be part of the NEPAdocument as noted in 40 CFR 1501.2(b), 1501(b), and 1505.2. However, theenvironmental factors, together with the policy, technical, and cost factorswill be available to the decision maker at the time of the decision, not justthe environmental factors.

RC: 22.007

Doc: HT13/13

... I would also argue that the policy of the United States set by thePresident is that surplus materials...are supposed to be subject tointernational inspection.


Final determination has not been made on whether specific pits aresurplus or part of the strategic reserve. The Pantex EIS addresses interimstorage of pits without regard to their ultimate disposition. Further, theDepartment considers international inspection to be equally facilitated by allsite alternatives. Technical and policy issues, such as those pertaining tononproliferation, are part of the decision making process, but are not requiredto be part of the NEPA document as noted in 40 CFR 1501.2(b), 1501(b), and1505.2. However, the environmental factors, together with the policy,technical, and cost factors will be available to the decision maker at the timeof the decision; not just the environmental factors.

RC: 22.008

Doc: HT13/28

I have another question. Will there be any difference in the level oftransparency in the plutonium pit disposition process if the plutonium pits aresitting on a DOD or DOE site in terms of international surveillance or in termsof the public being aware of what is happening with pits? Is there anydifference in what the public will know?

The Department of Energy's secretary does have a policy of greater openness,which is not something I have heard from the Department of Defense and don'texpect to hear it from the Department of Defense. I am wondering where therewill be some difference should be pits be at Kirtland.


The Kirtland Air Force Bases Manzano Weapons Storage Area is underconsideration as an alternative storage site within the Pantex EIS. If thisalternative is selected it will become a DOE facility and will be operatedaccordingly; thus there would be no difference with respect to surveillance,openness, or public awareness.

RC: 22.009

Doc: HT13/35

I guess the problem with the Department manager doing the risk [analysis] isthat nobody trusts the Department of Energy. I think that if you had somebodyindependent doing the risk analysis, then it would be more palatable.


40 CFR 1502.24 requires agencies to ensure integrity of analysis in anEIS.

RC: 22.010

Doc: HT13/36

I appreciate all your efforts, but there is just such a long history ofdeception here that it is hard to overcome and believe and trust data that comesout of the Department, and I am sorry that is true.


The preparers of the Pantex EIS have devoted considerable effort toensure the accuracy of data used. These efforts are intended to result in acredible document that can withstand scientific and legal scrutiny. Seediscussion in section 1.3.14 of this volume for a summary of actions theDepartment has taken to improve public trust during the preparation of its EIS.

RC: 22.011

Doc: HT12/10

... Right,...but everything seems to deal with policy. I mean, if we hadsome type of impact on the policy making from the beginning [because] it seemsas if now [you] are backtracking and want some type of input from thecommunity.... [You make decisions] behind our backs all the time and now youexpect us to think [you are] not going to continue to do this behind ourbacks.... I'm sort of stuck on, why is it like that.


The Department is bound by the NEPA and the implementing Council ofEnvironmental Quality regulations to not only allow, but actively seek, commentsfrom Federal, State, and local agencies; Native Americans; citizens; andinterested organizations. These efforts may appear convoluted and frequentlyresult in many comments ranging from intense support for, to intense oppositionto, a proposed action. See response to comment 22.005 for a summary of theactions the Department has taken to comply with NEPA and Council onEnvironmental Quality requirements.

RC: 22.012

Doc: HT12/11

... That's my concern as well. ...What's our input, how do we know this isgoing to count. You already did what you wanted to do without asking forpermission, [and] you're going to continue doing that. ...This part is just[really] a bunch of bull crap, we're just here.

So how we know what's going to be the outcome and [what] is the trueoutcome. If we say right now we don't deal with this anymore, is itgoing to take place, are you going to ship it somewhere else, [is it] going tohappen where we don't want it to happen. Or it's already voted where it's goingto go.


DOE disagrees that it ignores input from agencies, other organizations,or individuals. Each comment on the Pantex EIS receives careful analysiswhether presented in person, in writing, or via another mechanism. Analysis ofcomments does not always warrant taking the action recommended in a particularcomment. The DOE decision maker does see and consider the comment along withother environmental, technical, policy, and national security issues and factorsas part of the decision making process.

RC: 22.013

Doc: CO-003/2

Appropriate local and regional public information and involvement programsmust be conducted by the agencies to ensure that the public is fully informed ofthe risks, hazards, and impacts of such a program. This would be part of thenational dialogue on all nuclear materials (noted above) prior to assignment ofnuclear materials to a specific site.


By establishing the Storage and Disposition PEIS, Stockpile Stewardshipand Management PEIS, and the Pantex EIS, consistent with Council onEnvironmental Quality regulations, developing reasonable alternatives subject topublic comment, DOE does have confidence that a "national dialogue"has been reasonably established. DOE, with direction of the Office of thePresident, has attempted to raise the level of public awareness. Included inthis national dialogue is an exchange of information as needed with Stategovernors. DOE is proud to recognize the vast network of concerned, interested,and committed stakeholders throughout this nation.

DOE recognizes that all its facilities and hazardous materials,including plutonium, require varying levels of operational and environmentalcontrols to protect workers, the general public, and the environment. DOE hasworked with EPA, States, employees, unions, stakeholders, and the general publicto develop programs and commitments to better manage its facilities andhazardous materials, including wastes. All of these plans and commitments(e.g., Tri-Party Agreement) have been reviewed for the proposed sites todetermine if there are any conflicts or restrictions that would inhibit thesesites from serving as good locations for the facilities proposed in the EIS forinterim pit storage. Nothing was found that would inhibit the alternative sitesfrom performing the required missions, to include site cleanup.

RC: 22.014

Doc: CO-009/1

At this juncture in the proposed and appropriate downsizing of the nuclearcomplex, we again strongly encourage the Department and Administration topredicate all actions related to the nuclear complex on the conservativeassumption that at least rogue-state or terroristic nuclear aggression againstthe United States is probable. U.S. vigilance and nuclear preparedness are keyto coexistence with mad nations and persons. In turn, the Pantex Plant is,uniquely, a key to economically efficient continuing nuclear preparedness.


The President has declared that the maintenance of a safe and reliablenuclear weapons stockpile will remain a cornerstone of national security policyfor the foreseeable future.

RC: 22.015

Doc: PC-024/1

Page S-4, right column, "Assembly of Nuclear Weapons," 11th line. Remove the word "classified" since virtually all the components in the"physics package" are classified. Check the DOE book "DrawingBack the Curtain of Secrecy" "Restricted Data DeclassificationDecisions 1946 to the Present (RDD-3), January 1, 1996. [Your] descriptionshould also mention the D-T Tube neutron generators.


The word "classified" has been removed. Adding the phrase "D-TTube neutron generators" is not necessary for the purpose of summarizingthe description of the "physics package." Volume I, section 1.2.2,contains an expanded description of the "physics package."

RC: 22.016

Doc: PC-024/2

Throughout the EIS replace the word "staged" with the word "stored."


DOE believes that the EIS reasonably differentiates "staging"and "storage" activities as presented in volume 1, section 3.1.1.

RC: 22.017

Doc: HT16/31

... It would probably be helpful to know where there are places where theplant is self-regulating, where there isn't an external regulator withregulatory authority, as opposed to oversight.


Per Council on Environmental Quality regulations, volume I, chapter 6,Environmental Compliance Requirements for Implementing the Proposed Action andAlternatives, presents Federal and State statues, regulations, and ordersapplicable to each site evaluated in the EIS. The chapter identifies theresponsible agencies. In addition, see response to comment 22.018.

RC: 22.018

Doc: HT16/33

TNRCC would be more willing to embrace the Pantex mission within the Stateof Texas if DOE would promote independent regulatory oversight of radioactivesource, special material and by-product material. We applaud DOE's willingnessto share its information concerning radioactive contaminants; however, it is ouropinion that the public would be better served and potential waste managementerrors minimized if the oversight authority was shared with the TNRCC. Now,we're well aware ofthis might be a little too brutalof DOE's legalobstructionist attitude for the State picking up regulatory authority overradionuclides. We understand we do not have the authority. We also understandthat EPA in their assertive program do have the authority. And we are workingnow with the EPA to pick up that authority, at least to piggyback on to it, notthat we can assume it or they can give it to us, but we can certainly holdhands, in a sense, partner with the EPA in their assertive program while thisNPL is decided, to get some oversight on radionuclides, not that we feel likeit's a great issue. The issue is not that we feel there's a bunch ofcontamination out there. The issue is solely that...we think that DOE would doa better job with oversight. It's not an issue for Pantex necessarily. We feelthat Pantex has done a pretty good job, far better than some of the other DOEsites. It's strictly our ability to do what we are asked to do by the citizensof Texas, which is to regulate and to watch and to concur or not to concur. Wedon't want to hurt DOE. We don't want to hurt Pantex. We just want to do ourjob. ...We're in the middle of an FFA negotiation right now. And this will bean issue that we're not going to drop.


The Secretary has created a Working Group on External Regulation. Thisgroup is presently reviewing various alternatives for external oversight ofactivities at DOEs nuclear facilities and will submit a report sometime in 1996.

RC: 22.019

Doc: HT17/23

The world at this point needs alternative forms of energy, especially solarequipment, and it needs it very badly. Eventually we're going to have to decidewhich direction to go, whether we are going to go with nuclear power, and thatwould eventually involve some considerable reprocessing of plutonium or whetherwe will go for other means of electrical generation. I would like to see thePantex Plant take the lead in producing alternative methods of generatingelectricity and not trying to deal with plutonium, which is essentially a wastematerial of the cold war and the nuclear arms race.


Final disposition of weapon-usable plutonium is within the scope of theStorage and Disposition PEIS. One alternative for disposition is using excessplutonium as fuel for nuclear reactors which would generate electricity. Although alternate energy sources are not included in the Proposed Action forthe Pantex EIS, research on alternate energy sources is performed at a number ofDOE facilities. A variety of information on the Departments alternate energyprograms may be obtained by accessing the Internet home pages for theAlternative Fuels Data Center, the Energy Efficiency and Renewable EnergyNetwork (EREN), and the Energy Information Administration. Alternative energyinitiatives are included in "Department of Energy 1977-1994: A SummaryHistory."

RC: 22.020

Doc: PC-017/7

Will the DOE repair and/or replace or pay damages for all these damages? Will the DOE pay for the months of inconvenience and nerve wrecking experienceswe have been through?


The Department has a procedure for consideration of damage claims.Please contact Mason & Hanger Corporation legal department to initiate aclaim. Resolution of the claim will be dependent upon a determination of thecause, extent of damage, and current law regarding liability. See response tocomment 8.002 which immediately preceded comment 22.020 in the commentors letterof June 25, 1996. Comment 8.002 expresses concerns about alleged damage from ahigh explosives detonation on October 4, 1995.

RC: 22.021

Doc: FG-003/15

The Pantex FEIS should also outline DOE's intentions regarding the retrievalof plutonium pits in such a situation, as well as the feasibility of monitoringthe pit storage facility. The DEIS (Volume I, p. 5-17) gives the impressionthat the plutonium pits would remain entombed.

We ask that the FEIS provide further discussion regarding the wording onpage 5-17 of volume I, that "Some mitigation of a tunnel collapse would beneeded after a major seismic event. A separate assessment of the riskassociated with the mitigation would be necessary..." The Pantex FEISshould better define what is meant by "some mitigation" and a "separateassessment" (would the separate assessment be a NEPA document?). The FEISshould discuss what risks would be analyzed in the separate assessment: radionuclide emissions, worker health and safety, ground water contamination,etc.


The Departments response would be determined after consideration of thecircumstances that exist after the collapse and evaluation of the risks to theenvironment, the public, and workers involved in any recovery action.

RC: 22.022

Doc: SG-002/2

We applaud DOE's willingness to share its information concerning radioactivecontaminants; however, the TNRCC permit does not include radionuclideparameters. And as we have stated before, the TNRCC recommends that the DOEshare regulatory oversight with another Federal or State agency to minimize thepotential for further injury to natural resources.


See response to comment 22.018.

RC: 22.023

Doc: PC-027/2

I don't understand the need to store 20,000 pits anywhere. If we aredismantling the nuclear weapons, then we should get rid of the pits, not storethem. People who know about nuclear [material] should have the knowledge andimagination to come up with some use for the pits. Perhaps some nuclearfunction could use that material for some purpose. I can't see why we shouldneed so many for "strategic reserve and surplus". What is the ideabehind this storage, to snap them back into nuclear weapons should we decide tochange the rules?


DOE agrees with the commentor that final disposition is preferred overlong-term storage as identified in the Purpose and Need discussion of theStorage and Disposition of Weapons-Usable Fissile Materials ProgrammaticEnvironmental Impact Statement (S&D PEIS). However, DOE is required to meetCEQ regulations prior to implementing the S&D PEIS programs including finaldisposition. The S&D PEIS discusses and analyzes the strategy andtechnologies for long-term storage and the final disposition of surplusweapons-usable plutonium.

RC: 22.024

Doc: SG-003/19

We applaud DOE's willingness to share its information concerning radioactivecontaminants; however, the TNRCC permit does not include radionuclideparameters. And as we have stated before, the TNRCC recommends that the DOEshare regulatory oversight with another federal or state agency to minimize thepotential for further injury to natural resources.


See response to comment 22.018.

RC: 22.025

Doc: SG-003/20

However, the DOE is one of the Federal Trustees for natural resources andhas the responsibility of protecting those natural resources from further injuryon behalf of the public. In order to protect those natural resources fromfurther injury, the Trustees recommend that the DOE incorporate more stringentenvironmentally protective practices at the Pantex Superfund site.


The Pantex Plant continues to implement a Pollution Prevention/WasteMinimization (PP/WM) program to reduce environmental impacts through wasteavoidance and waste minimization. Volume II, appendix G, contains detailedinformation of the PP/WM program. The program was recently awarded thePresidents Closing the Circle Award.

In addition to the plants continuing effort to reduce pollution andminimize waste, DOE has agreed to further study potential alternatives to openburning of energetic materials at the Pantex Plant Burning Ground. Pantex Plantmaintains a Resource Conservation and Recovery Act (RCRA) Contingency-RCRA SpillPrevention, Control, and Countermeasures (SPCC) Plan to responsibly protectPantex Plant employees, the public, and the environment. The SPCC Plan isincorporated into Pantex Plant RCRA Part B Hazardous Waste Permit (HW-50284),which is subject to EPA and TNRCC regulatory oversight.

As discussed in the EIS, EPA and TNRCC share the responsibility for RCRAand Comprehensive Environmental Response, Compensation, and Liability Actrequirements including the establishment of restoration levels. Volume I,chapter 6, has been expanded to address the issue of Natural Resource DamageAssessments.

In addition, see responses to comments 22.018 and 22.026.

RC: 22.026

Doc: SG-003/22

Page 1-12, volume 1, section Environmental Restoration. Theinformation communicated in this text does not necessarily constituterestoration of the natural resources that have been injured as a result of thereleases of hazardous substances at this site. In order to perform actualenvironmental restoration, the nature and extent of contamination must bedetermined to evaluate the potential injuries to natural resources. After sucha determination, and in cooperation with the other Federal and State Trustees,restoration projects should be designed that will appropriately compensate thepublic for injury to natural resources. Performing remediation as needed tocomply with all appropriate regulatory requirements does not necessarilyconstitute compensatory restoration for injury to natural resources. In orderto reduce DOE's residual liability for injury to natural resources, the Stateand Federal Trustees encourage DOE to continue to work with the Trustees duringthe remedial process so that appropriate restoration will be incorporated intoremedial activities. Page 3-3 Performing environmental protection andenvironmental restoration activities. Please see specific comment #1.


DOE continues to work with EPA, TNRCC, employees, unions, stakeholders,and the general public to develop the Pantex Plant Environmental RestorationProgram and its commitments to better manage its facilities and restorationactivities. DOE is continuing to work with the trustees. As we move toward aFederal Facility Agreement, consultation will increase. Volume I, chapter 6,has been expanded to address the issue of Natural Resource Damage Assessments.

RC: 22.027

Doc: SG-003/28

Page 4-37 Environmental Restoration Process at Pantex Plant. See comment#l.


See response to comment 22.026.

RC: 22.028

Doc: PC-025/5

Of interest [is] why stored plutonium at Pantex [is] not considered solidwaste as defined in 40 CFR 261.2 (a)(l), (a)(2), (a)(2)i, (a)(2)ii, (a)(2)iii,(2)(b), (2)(b)1, (2)(b)2, (2)(b)3, (2)(c), (2)(c)(1), (2)(c)(2), 2(d), or 2(e).Why open burning of HE is not RCRA treatment? When does stored plutonium meetthe definition of land disposed (stored) as a solid waste? Why not if "accumulatedspeculatively", "inherently waste-like", scrap, dispositioned,recycled, studied, or burned? What would be the environmental impacts if storedplutonium meets the definition of a solid waste? I consider this a reasonableimpact.


In response to Item 1: The Atomic Energy Act (AEA) of 1954, as amended,regulates plutonium storage. Furthermore, 40 CFR 261.4 (a)(4), the ResourceConservation and Recovery Act (RCRA) specifically excludes AEA source, specialnuclear, or by-product material from regulation as a "solid waste." Therefore, stored plutonium is not a "solid waste" as defined by RCRA.

In response to Item 2: See response to comment 22.029.

In response to Item 3: As identified in response to Item 1 above,plutonium does not meet the definition of a solid waste and, therefore, landdisposal restrictions in 40 CFR 268 do not apply.

In response to Item 4: The environmental impacts of stored plutoniumare analyzed and discussed in this EIS. The environmental impacts of storedplutonium are independent of statutory and regulatory framework.

RC: 22.029

Doc: PC-025/6

The sixth dash on Page 3-3. Why arent HE components regulated by RCRA beforeburning? If I burn an experimental battery that contains lead and explosives butis a proprietary secret of my company, is that RCRA treatment? Requestconsultation with EPA and the U.S. Justice Dept. on the response.


Weapon components, materials, or parts of a component that are not beingreused cannot be declared waste until they have been demilitarized and sanitized(D&S) in accordance with the Atomic Energy Act, as amended. Once materialsare declared waste, they are managed in accordance with applicable Federal andState regulations. The environmental impacts from D&S operations have beenspecifically incorporated into impacts addressed in volume I, section 4.7, AirQuality, and section 4.13, Waste Management. D&S operations at the BurningGround were included in the site-wide air modeling analysis. Solid wastegenerated as a result of D&S weapon components activities are included inthe waste volume projections for the three levels of weapon activities. Toaccount for fluctuations, waste projections include a 10 percent margin. D&Soperations are part of the proposed continued operation of Pantex Plant asidentified in volume I, section 3.1.1, and, therefore, D&S operations arebounded by environmental impacts presented in the Pantex Plant EIS.

RC: 22.030

Doc: PC-025/66

... Volume I, section 4.13. Are pits a solid waste?


No, see response to comment 22.028.

RC: 22.031

Doc: PC-025/67

... Page 4-193. Is demilitarization and sanitization of weapons componentsRCRA [treated]? Are classified weapon components that cannot be demilitarizedand sanitized [and] sent to NTS, a solid waste? What is meant by declassifiedversus demilitarized and sanitized?


In response to Item 1: See response to comment 22.029.

In response to Item 2: See response to comment 22.029.

In response to Item 3: For clarification purposes "declassified"has been changed to "demilitarized and sanitized."

3.23 National Environmental Policy Act Process/Procedures

RC: 23.001

Doc: HT02-08/1

Combining these three documents into a single opportunity for public input,together with the very short amount of time much of the material has beenavailable, does justice neither to the NEPA process itself nor to the people andagencies that wish to make reasoned responses to these documents. At least inthe case of the Stockpile Stewardship as well as the Storage and Disposition,the documents are substantive enough to require careful analysis. It is also anunavoidable conclusion that the hearing process envisioned by NEPA has beentransformed by DOE into a format they feel they can more effectively controlthatbeing the workshops. There is nothing wrong with workshops per se, but they donot meet the government's full responsibility to the public. That any of us atall are standing here to give testimony is only the result of citizen lobbyingand the willingness of individuals to face down any obstacles to get theirconcerns into the public record.


Each of the documents has a public comment period, inclusive of publichearings/meetings as required by NEPA. During this time the public isencouraged to comment verbally at the hearings, in writing, by telephone, or bye-mail. The comment periods for these documents overlapped. It was felt thatthe public would be better served to have one meeting whenever possible todiscuss as many of the documents as necessary, depending on the geographicallocation of the meeting. This format also addressed feedback to reduce thenumber of meetings the public had to attend. The effort was intended to providethe public with as much information as possible and to allow for as long acomment period as could be scheduled.

For the record, the workshop format used for the public hearing is, infact, a response to stakeholder requests for this type of format. The entirehearing structure, including the joint presentation of the three EISs, theworkshop format, the time periods for formal testimony, the provision of spacefor displays by citizen groups, and the two-day afternoon and evening sessionswere planned by the Pantex Plant Citizens Advisory Boardnot DOE.

RC: 23.002

Doc: HT02-08/2

The Site-Wide EIS, an effort brought about by citizen lobbying of theDepartment of Energy, has not really been in the public domain long enough for adetailed consideration. Unfortunately, the substance of the document itself mayrequire much less time than the gravity of the issues warrants.


Although the Notice of Availability for the Draft EIS was issued lessthan a month before the first public hearing was conducted, the comment periodwas extended to July 12, 1996, during which time the public could submitcomments in writing, by telephone, a technical exchange meeting, or viaelectronic mail. Council on Environmental Quality regulations require a minimumcomment period of 45 days. For this EIS, DOE extended the comment period to 98days. Comments were accepted as late as July 29, 1996.

RC: 23.003

Doc: HT02-07/1

I came over today trying to have an open mind, but I realize that afterlistening to the City, the State, Federal elected officials, this is a donedeal. The most we can hope for is a safe facility.


The NEPA process requires a thorough evaluation of the Proposed Action,including a variety of alternatives. The decision to accept an alternative isnot made by city, county, or Federal elected officials at public meetings suchas this. The EIS evaluates the environmental effects of Pantex Plant operationsas well as the effects associated with interim storage of pits at alternatelocations. The final decision will be made by the Secretary of Energy, based onthe findings in the document as well as public input from all areas (private,elected officials, organizations, etc.).

RC: 23.004

Doc: HT11/9

You don't happen to have a web site where we can access more information?...


We do not have a web site; however, the DOE Home Page can be accessedthrough the internet. The DOE Universal Resource Locator (URL) address on theinternet is A list that links to DOE program offices can befound at A map with DOE sitescan be found at, specific inquiries on this EIS can be accessed through theInternet via

RC: 23.005

Doc: HT11/10

You have an internet address? Is that classified?


See response to comment 23.004. It is not classified.

RC: 23.006

Doc: HT11/11

What I wonder is, if I have any other questions, is there an area I can tapin and find frequently asked questions?


This Comment Response Document is one source for answers to frequentlyasked questions, another is the internet ( and phone calls tothe DOE EIS office in charge of this document (505-845-4351) or the Office ofNEPA Policy and Assistance (1-800-472-2756). While we do not post a listing offrequently asked questions per se, DOE will respond to any questions that anymember of the public may have. See response to comment 23.004.

RC: 23.007

Doc: HT11/34

... We were surprised by this meeting...maybe there was public informationor scheduling announcement that we missed. matter whether it's Pantexor [it] has to do with the people that are doing NTS, EIS or any of the EISswhere Nevada Test Site is involved, we would like to have a mechanism set upwhereby Department of Energy representatives and representatives of localgovernments that may be affected like Clark County can meet so that we can havea briefing...[to] prepare ourselves for statements [that] in many cases might bestatements of support, given that certain mitigation measures are taken or atleast addressed.


On June 5, 1996 a video conference call was conducted between DOEofficials, NTS officials, representatives from the State of Nevada Department of Transportation, the States Advisory Board, and representatives from ClarkCounty, including the Nevada Department of Comprehensive Planning, Nuclear WasteDivision, to discuss the EIS and transportation issues. DOE plans to continueinteraction with the State and local agencies to solicit their views beforedecisions are made.

RC: 23.008

Doc: HT11/35

And at this point I'd like to request a meeting among the management ofClark County, probably the Director of Comprehensive Planning, County Manager,and so on and representatives of Pantex to give us more detailed information. And I would like to also to request in your institutional program that there beperiodic updates with identified state holders or units of local government thatare affected.


See response to comment 23.007.

RC: 23.009

Doc: HT11/37

... The other major concern is...the initial interaction and the ongoingmechanism for ongoing communication, that clear communication makes things a loteasier on both sides.

The person that you might address any correspondence to with regard toestablishing a meeting with Clark County is Richard Holmes, H-O-L-M-E-S. He'sthe director of the Department of Comprehensive Planning for Clark County. Histelephone number is area code 702, 455-5175.


We appreciate this point-of-contact for Clark County. See response tocomment 23.007.

RC: 23.010

Doc: HT14/2

... Appropriate local and regional public information and involvementprograms must be conducted by the agencies to ensure that the public is fullyinformed of the risks, hazards and impacts of such a program. This would bepart of the national dialogue on all nuclear materials prior to assignment ofany nuclear materials to a specific site.


This is an excerpt from Advice No. 46 of the Hanford Advisory Boardregarding the Storage and Disposition of Excess Weapons Usable Plutonium andSpecial Nuclear Materials. The NEPA process ensures that the public is involvedin all phases of this type of large scale proposed project. Public hearings andcomment periods allow an avenue for personal interaction with the individualsinvolved with these projects prior to a final decision concerning the assignmentof nuclear materials to a specific site.

RC: 23.011

Doc: HT02-01/2

Technical analyses will be available later. Cost analyses will be availablelater. We do not have access to the information necessary to render an informedopinion, and the Department tells us that is how it will be. For instance, DOEdefends the absence of cost information by stating that NEPA does not require aFederal agency to supply cost analyses in a draft document. To that, I say "Sowhat." Such information is necessary to the discussion and so must be madeavailable.

The same applies to technical information. It is not possible that theDepartment has so little information that it can not give a clearer descriptionof what the operations for dismantling pits and processing plutonium willinvolve. And no citizen should be satisfied with being put in the position ofguessing.


The NEPA process is not a cost-benefit analysis process. Rather, thelaw requires that a NEPA document be prepared to ensure that environmentalimpacts are documented on the record before any decision is made on a majorFederal action. Costs are not required in order to assess environmentalimpacts. Volume I, chapter 4, of the EIS describes the affected environment andthe potential environmental impacts expected from the continued operations of Pantex Plant, as well as the associated interim storage of nuclear weaponcomponents. Non-environmental issues such as a cost breakdown between thealternatives have not been developed for the Pantex EIS. It should beunderstood that Pantex Plant does not dismantle pits. Issues associated withdismantling pits and plutonium processing are not covered in this EIS. Long-term management of the nuclear stockpile is within the scope of theStockpile Stewardship and Management PEIS, while long-term storage and the finaldisposition of plutonium is addressed in the Storage and Disposition ofWeapons-Usable Fissile Materials PEIS.

RC: 23.012

Doc: HT02-01/3

The decisions which these documents address are too important for us toallow the Department to go forward in this manner. Whether it is the case thatthe Department has the missing information yet is not revealing it, or whetherthe information is not complete, in either instance these draft documents arefundamentally deficient. The public deserves better. The law expects better. And the future must be based on something better.


The law requires consideration of all available relevant information. The information examined in this EIS is available to the public in two technicallibraries established in Tetra Tech offices in Albuquerque, New Mexico, andAmarillo, Texas. These libraries contain more than 2,800 documents assembled inthe course of preparing this EIS. The Pantex EIS provides a full and fairevaluation of all reasonable alternatives. Comments concerning the PEISs(Storage and Disposition, Stockpile Stewardship and Management, and WasteManagement) are beyond the scope of this EIS; however, these concerns have beenconsidered by the PEIS program staff and will be addressed in the PEIS commentresponse documents.

RC: 23.013

Doc: HT02-01/1

It was never the intention of our particular citizens' groups that you...notbe able to respond. That's a misunderstanding that I hope we can clarify, andperhaps a rereading of the letters will serve to do that, letters that have beenexchanged between the Department and four of the local citizens' groups.


The commentor is referring to the three DOE officials that were seatedat the table with the meeting facilitator. These individuals participated ashearing officers, and as such, did not engage in dialogue or provide answers tothe formal comments delivered by the 23 people that presented formalpresentations. DOE officials did engage in dialogue during all the workshopsessions.

RC: 23.014

Doc: HT01-04/1

I have to admit that stacking EIS on EIS on EIS has gotten a little bitconfusing, at least for me and my staff.


The review periods for these documents were scheduled to overlap becauseof similarities and scheduling issues. The Department realizes the difficultyto the public to review these EISs at the same time and greatly appreciates theeffort. We will take this under advisement for future projects.

RC: 23.015

Doc: HT07/4

... I think that because the CEQ guidelines say that you are to identifywhat the significant impacts are, that if there are no significant impacts, youshould state that in the EIS.


See section 1.3.15 in this volume for a discussion of significantimpacts.

RC: 23.016

Doc: HT05/9

With the first reconfiguration EIS proposal six or seven years ago, therewas one EIS [that] covered the reconfiguration of the nuclear weapons complex. I'd like to know what the Department's rationale is for dividing among a numberof EISs what essentially is one overall decision, which is what to do with thenuclear weapons complex as a whole.

Obviously, your site-wide EIS is a part only of the decision about what todo with pits now and in the future. Why is it that the Department has electedto split up the EIS process and to do fragmented segments?


The Reconfiguration Study, published in January 1991, envisioned severalmajor initiatives, the principal ones being relocation of the plutoniummanufacturing operations at Rocky Flats Plant to a new facility at another site,consolidation of nonnuclear operations, and either downsizing and modernizingother nuclear and research and development facilities in place or pursuingmaximum feasible consolidation (DOE 1991a). However, the specific concepts thenenvisioned were rendered inappropriate by major changes in world events,particularly, the collapse of the Soviet Union. In Response, the Departmentrestructured the reconfiguration concept into several separate but relatedprogram decisions that could be clearly defined and examined in detail. TheDepartment also found that it was too difficult to examine all the programs inone PEIS. Thus, the Department restructured the reconfiguration concept intoprograms for nonnuclear consolidation, tritium supply and recycling, andstockpile stewardship and management. Decisions on the first two have been made(following NEPA analysis) and the third is scheduled to be made in the fall of1996. In addition, a PEIS was developed to address a new issuehow to providelong-term storage and disposition of surplus nuclear materials resulting fromweapons dismantlement. The decision on that program is also scheduled to bemade in the fall of 1996.

RC: 23.017

Doc: HT05/10

But I'd like my comment to go to the fact that what you have really done ismade it impossible for the public to comment upon the overall program. You haveno real programmatic environmental impact statement about which the public isinstructed, educated and about which they can comment. And I seriously questionwhether the law really has been complied with.


As stated in the response to comment 23.016, the Department found thatpreparing one PEIS on the entire nuclear weapons program would have been solarge and complicated that it would have been too difficult for anyone todigest.

RC: 23.018

Doc: HT02-15/1

I'll reiterate what some other people have already told you, that trying todeal with three documents, actually in less than 30 days that people have hadall three of them together to compare, is clearly not an adequate amount oftime. And one must conclude [that] either the Department of Energy is in a verybig hurry and therefore they won't give an adequate [amount of] time for publiccomment, or that they don't understand the difficulty of dealing with threedocuments like this.


See response to comment 23.001.

RC: 23.019

Doc: HT02-15/2

... A number of people had expected that this format would also includetime for DOE officials to respond on the record, and I continue to believe thatthat should be the case.


The "format" referred to is the presentation of formalcomments at the Pantex public hearings in Amarillo, Texas. Individuals weregiven a 5-minute window to present a formal comment for the record, in front ofDOE representatives. This was not meant to be a discussion session. The publicwas encouraged to discuss concerns with DOE representatives during the general(workshop) sessions as well as the individual EIS breakout sessions that werebeing conducted during the public hearings. We appreciate your input, and willconsider your suggestions for future sessions. See response to comment 23.013.

RC: 23.020

Doc: HT02-21/1

Everyone who works at Pantex is there by their own choice. Why, now, shouldthe opinions of such a small group receive so much focus?


DOE places equal importance on every individuals opinion, and upholdseach individuals, agencys, or organizations right to be heard. As outlined byNEPA, the public comment period and the public hearings are held to facilitatethis opportunity.

RC: 23.021

Doc: HT06/1

The first question is for all of the DOE and DOE contractor folks in theroom, how many of them have completely read all three of the EISs? I see three,four, five, six, seven, eight hands, I think.

The point I would make is these folks, out of all the DOE and contractorfolks in the room, these folks have had a lot longer to look at all three ofthese documents than the public [has had], and so you're putting the public in avery difficult position in terms of dealing with all these documents.


The draft EISs that are referred to in this comment were released forreview by DOE and the contractors at the same time that they were released tothe public. The review time for these documents is brief for the circumstances,but it is in accordance with that required by law.


Doc: HT02-09/1

Many issues come into play in this very over-arching discussion. Not theleast among them [is] the cost to us, the taxpayer, to produce these documentsand to find them flawed in many ways. These documents are lacking importantinformation in many areas that make it virtually impossible to even begin thediscussion.


The draft phase of an EIS is designed to be a period when perceivedshortcomings in the document are identified for resolution or further analysis. Public hearings and an accessible comment period provide an opportunity forindividuals, agencies, and organizations to point out items that are unclear orsituations and alternatives that may not have been addressed to the satisfactionof the commentor. A period of time exists between the draft and the finalproduction of the document to address, and/or correct, these perceivedshortcomings.

RC: 23.023

Doc: HT02-04/1

Are all of the important damage reports in the public domain, or are manyvital documents concerning soil, air and groundwater contamination still beingsuppressed?


The Department provides to the public, upon request, any informationthat may be released under law. The law does exclude certain informationrelative to weapons design characteristics, for example, or that is exempt fromdisclosure by the Freedom of Information Act. Vital documentation has not beensuppressed by the government; however, specific technical weapons information isnot available to the public for security reasons.

Technical reports are located in the public reading rooms in WashingtonDC, Las Vegas, NV, Albuquerque, NM, Los Alamos, NM, Aiken, SC, Oak Ridge, TN,Amarillo, TX, Panhandle, TX, and Richland, WA. Inquiries concerning additionalmaterial concerning Pantex Plant can be directed to the DOE Albuquerque orAmarillo Area offices. Some environmental information is of a sensitive naturebecause of its relationship with certain projects, facilities, or missions. These reports are being studied and the information contained within them willbe resolved after it is studied.

RC: 23.024

Doc: HT13/14

Just to clarify, I think it is legitimate to have varying selection criteriathat go into less detail, but part of what an Environmental Impact Statement isrequired to do by law is to also evaluate the environmental impacts. So youcould use potentially certain criteria to select the sites, but once you haveselected them, whether it is Manzano, Nevada, Pantex, et cetera, you need tolook at the environmental consequences.

Part of the consequences, both environmental because inspection is going tobe important from not only an international, but frankly from a nationalconfidential standpoint, is the availability and the accessibility and howinspection could work.

On the face of it, it seems to me, knowing something about all the fivesites [that] you are looking at, that there are differing ways, at some sites,it would be easier to have international inspection, and some would be moredifficult, and I think that should be analyzed.


The Department considers international inspection to be equallyfacilitated by all site alternatives.

RC: 23.025

Doc: HT13/34

I would suggest that [the] cumulative impact part of your EnvironmentalImpact Statement should also include a cumulative psychological impact of allthese projects on the people of New Mexico and how much people here are going totake before there is some kind of rebellion involved. We already know thatcancer rates at Los Alamos, breast cancer rates, are 20 to 50 percent higher. We know that the child death rate there is higher than anywhere else in thestate. We know a lot of bad things about Los Alamos.

We are looking at the rest of our state and wondering if the rest of ourstate is going to go that way, too, so I would suggest a psychological impactalso be part of the cumulative effect of projects in an area.


Court precedents state that psychological impacts are not required for avalid NEPA analysis. The U.S. Supreme Court, in Metropolitan Edison Co., v.People Against Nuclear Energy (460 US 766 {1983}), held that psychologicaleffects need not be considered in a NEPA evaluation. People Against NuclearEnergy, an organization of residents living in the area, claimed the commissionshould consider the severe psychological stress caused to its members by thenuclear reactor restart, especially in view of the failure of another reactor onthe same site. While the Court did recognize that "human health mayinclude psychological health," and conceded that risk to human health,including psychological health, came under NEPA, the Court believed that thepsychological effects claimed raised policy questions that fell outside NEPA andthat analysis of the psychological risks of the nuclear reactor restart were notrequired.

RC: 23.026

Doc: HT13/38

Well, I also feel that if Kirtland becomes your number one choice, that itis your obligation to hold a hearing here, not to just do this.


The hearing in Albuquerque fully complies with the letter and spirit ofNEPA. Repetitive hearings on this same issue are at this time, consideredneither necessary nor a prudent use of the publics time and taxpayers dollars. Should a new, and previously, unaddressed alternative or significantenvironmental impact be discovered, the Department would consider additionalpublic meetings.

RC: 23.027

Doc: HT13/88

I just wanted to clarify the high explosive building with insufficientbuffer. I used as an example what I would ask that this site-wide do, which isprovide to people [with] an accurate description of the state of the plant, aPantex Plant site-wide EIS.... I would like this document to contain anappendix or something that gives us an update on the status of the SARs at theplant, the facilities, and the status of whether or not they are in compliancewith whatever DOE orders or whatever applies that DOE establishes to make thesefacilities meet whatever standards they have decided upon.

That is what I would like the site-wide to do. It is not to criticize theplant because in 1977, three people were killed, but it is telling that in 1996,you have a building that still has a similar problem, that people can get tooclose to it, so I would just like for this document to be complete enough thatpeople can read the site-wide EIS and get an understanding of the plant andwhere it is going, mitigation, whatever is needed, and it goes forward fromthere. That is my question.


The Department has established policies to continually emphasize safetyand encourage prompt resolution of any problems discovered. The cited incidentis discussed in the response to comment 14.040.

RC: 23.028

Doc: HT12/1

First of all,...if I suggested it, I didn't mean to, that cost should drivethe decision, but I think NEPA itself mandates that they [costs] be considered. If you've got two that are close together in environmental protection, youbetter know what they cost and maybeyou mentioned proliferation, which is thereason for all of this exercise. Timing, timing is not mentioned here.... Itcould have an impact on the decision and the costs.


See response to comment 23.011.

RC: 23.029

Doc: HT12/12

May I ask a policy question? By what process do you waive [weigh] strategicconcerns against potential negative impact to local populations? I was justwondering [if there] was any particular formula, equation, process?


The Record of Decision represents a judgment weighing all relevantfactors in the decision. There is no mathematical formula.

RC: 23.030

Doc: HT12/13

But are you...working with any type of independent entity that's not intotal opposition to DOE but, just in case you did a case study, let's say forinstance, cancer. And...are you...bringing in outside resources to say well,this is not what...we're finding.

Well...that's where the problem may be at, because you...hired them.... We're raising some very serious questions then. [You] should be able to fund uswith money for us to be able to go out and find [our] own independent study, ownindependent researchers, the individual that will research our problem for us. And then [together] we could sit at a round table and...come up with ananswer....

But...for [you] to appoint us someone or say, well, I [have] this personhere [and] you can call him and he'll help you out. [But]...that's not going towork because that's no different than [you] sending out doing the independentresearch yourself.


The Department does fund outside research when deemed appropriate toinvestigate matters about which in-house information is insufficient fordecision-making. The commentor is referred to EPAs Office of EnvironmentalJustice. This office provides grants to organizations specifically to studyenvironmental justice issues. This EPA money would be completely independent ofDOE and would directly address the commentors issue. The last EPA notice ofavailability for funding was announced in the Federal Register on Thursday, June13, 1996 (61 FR 30063), "Notice of Availability of FY 1996 MultimediaEnvironmental Justice Through Pollution Prevention Grant Funds." Forfurther information, the commentor should contact EPA at (202) 260-4109.

RC: 23.031

Doc: HT12/14

... A more narrow question is, is there a way to challenge the ROD, not tonecessarily change it although it may get changed in your process, but hisspecific question is, what is the procedure to challenge a ROD if you feel thatthat decision is against your community.


Public comments, as outlined in 40 CFR 1503, are actively encouraged byDOE. All comments received during review of the draft document have beenpublished and responded to in this volume of the EIS. These comments must beaddressed in an EIS as outlined in 40 CFR 1503.4. The public may appeal adecision under 40 CFR 1506.10 and make their views known even after thepublication of the final EIS. If a substantial opportunity exists to alter thedecision, the decision can be made and recorded at the same time that the EIS ispublished. This gives a 30-day parallel period when the EIS is under bothappeal and review. "No action shall be taken until the decision has beenmade public" (10 CFR 1021.315) as required by the recently revised DOE NEPAImplementing Procedures, published in the Federal Register on Tuesday, July 9,1996 (61 FR 36222). The decision can be made public by means such as a pressrelease or announcement in the local media.

RC: 23.032

Doc: HT12/23

... On your evaluation list, I had a question about why you didn't discussthings in detail and why you did. For instance, the facilities ininfrastructure at SRS are excellent,...but it says it's not discussed in detail.


Council on Environmental Quality regulations proscribe that NEPAdocuments avoid unnecessary detail. In the instance cited, there was no needfor further detail.

RC: 23.033

Doc: HT12/28

What I'm hearing Rick say to you is that he's reading another DOE documentthat's not badly out of date and it's different than what [your] EIS is sayingand what you're telling us here. And in order to go forward from here you needto take that document and...make a review against your EIS, correct and modifyas necessary. Isn't that what you're saying, Rick?


This EIS contains the most current information available.

RC: 23.034

Doc: HT12/32

It is the conservatism that you put in the bounding accidents[they] are waytoo conservative. They need to have some credibility even though they arebounding accidents. You can't just assume, like the safety analysis does,everything is the worse, NEPA doesn't allow that. NEPA says that you willdevelop reasonable but bounding accidents and I concluded from reading it beforeBob raised the question here earlier in the day that the accidents were notreasonable. They were bounding, certainly. ...I could have said that the guysconsume...or inhale the pit and, therefore, that's bounding, but that'scertainly [not] the intent of a NEPA process.


The accidents analyzed are both bounding and the most credible ofaccidents that safety specialists can conceive for the circumstances that exist.

RC: 23.035

Doc: CO-003/4

Equity impacts must be addressed in the assignment of new nuclear materials(including plutonium) to Hanford.


Equity along with environmental impacts, mission requirements, costs,and technical factors will be considered in the Record of Decision.

RC: 23.036

Doc: CO-009/3

(However, we do request that the Department include in the record "dockets"for these EISs the comments by SPS relative to listed potential environmentalconcerns recited in the draft Tritium Production-related EIS of 1995. In thosecomments, SPS rebutted the overly sensitive, generally not really site-specificbut knee-jerk and ill-informed, and frequently inaccurate characterizations ofenvironmental "concerns" about expanded missions at Pantex. Clearly,those earlier characterizations of possibly "adverse" impacts,especially those related to uses of groundwater, now are rejected by DOE. Nonetheless, a replete record supportive of the Department's April 23, 1996,publicly articulated conclusion that NO significant adverse impacts wouldresult, is appropriate.)


Each NEPA document prepared by the Department contains the most accurateinformation available at the time the document is produced.

RC: 23.037

Doc: CO-009/4

We requestwe are tempted to demandthat fair and open cost comparisons amongthe alternative sites for each function be used in analyzing sites, and thatsuch accountings be shared with the public that [has] demonstrated interest inthe nuclear complex.


See response to comment 23.011.

RC: 23.038

Doc: PC-023/1

First of all, I appreciate that this report has addressed many concernsexpressed by citizens groups with regard to previous reports. The writers andcompilers of the report should be complimented on their efforts in this process.


Thank you for the compliment. The Department will pass it on to theresponsible preparers.

RC: 23.039

Doc: PC-022/1

I would like to request [that] you hold public hearings in Albuquerque onthe Pantex Storage of Nuclear Weapons Components, as our city is one of thepossible sites.


The public hearing in Albuquerque was held on May 7, 1996.

RC: 23.040

Doc: HT15/24

We really are interested, as the State is as well, in seeing that theevaluations are good science, good process and all those things, because I don'tthink any of us are interested in having the numbers be unreasonable for anyreason or uninformed for any reason. So that is a problem for us. We do likethe idea of being able to read the document and understand thoroughly from whatis in the document, that we do think it's clear; there are not terms that areused that are not explained.


Thank you for the comment. That is always our objective and intent.

RC: 23.041

Doc: HT16/39

... None of the documentation related to the pit reuse facility isavailable to the public in Albuquerque, which is where I live, because the DOEreading room has none of these documents available to the public.


The specific documentation requested contains data that cannot bereleased to the public.

RC: 23.042

Doc: HT17/15

... There is an environmental justice section;... there probably ought tobe an economic justice section, also, because I think those at risk populationswould feel the effect of an economic slow down, while at the same time thoseagencies that help them would really suffer in terms of available funds. Andthat's more of a blanket statement and I don't know if that really falls underwhat your tasked to do under NEPA, but I think it's a failing not only relatedto Amarillo, but to all the communities that [you] are looking at.


Economic impacts are addressed in volume I, sections 4.11,,,, and

RC: 23.043


I only want to make two comments. And one is I guess to express frustrationat being in the situation we're in so very often with Pantex and the Departmentof Energy in general of being asked to trust us; the documentation isn'tcomplete, trust us; it's not ready yet, but it will be, trust us; we don't havethe cost analysis yet, but it will come, trust us; it's classified, we can'ttell you, but we assure you it's okay. And we find ourselves in this positiontime and time and time again.


This EIS has been prepared with the most current information availableat the time of preparation. Many of the changes from the Draft EIS to theFinal involve updating information that has become available recently. Allreferences made in the EIS are available to the public, save those classified orotherwise restricted references. The use of restricted references has been keptto a minimum in this EIS.

RC: 23.044

Doc: HT17/52

I would like to know the legal connection, if any, of the informationdocuments that you all have composed that go along with this site-wide [EIS].There are three volumes that [you] have worked with, and I would like to know,when you sit down with a site-wide, do you really need to sit down with thosethree documents, too, to look at the whole thing? ...Legally, does this thing[EIS] have to stand by itself and are those merely reference documents and theyhaven't got the same stand-alone right?


The Final EIS is the only official NEPA document. The other documentsmentioned are references used in preparing the EIS.

RC: 23.045

Doc: HT17/54

In your list of comments, scoping issues that were brought up in thisdocument, [you] left off the nonproliferation concerns. And if you'll go backto your implementation, you will find out that in scoping, nonproliferationreceived more comments than human health, socioeconomics, transportation, airquality. It was very nearly at the top of the list.


Subsequent to scoping, the Department determined that there would be nochanges to facilities necessitated by non-proliferation procedures. Therefore,there are no impacts to analyze.

RC: 23.046

Doc: HT17/58

We're forced here to comment on a very narrowly conceived document. We'rein a [compromising] position, because we're forced to play on the Agency'sground, with no input into the design of a better draft EIS. Again, we'reforced to be reactive, rather than to confront these issues up front in acollaborative, proactive manner.


A public scoping period was conducted in May and June 1994 to obtainpublic input into the scope and design of the EIS.

RC: 23.047

Doc: HT17/65

I think the document provides virtually no, none of the analysis that isnecessary in terms of looking at the baseline operations of existing pit storageat Pantex. One of the things, one of the easy things that should be done...istaking your two and a half year old EA for pit storage of those pits and lookingat what it said the impacts would be, [if] anything, other than the aircraftanalysis, which seems to be the only thing you've even tried to look at, andsaying, okay, over the last two and a half years what does the real data show upin terms of what's actually happened. What [if] those analyses were right, what[if they] were wrong, what [if they] were overly conservative, et cetera.


The 1994 Environmental Assessment for Interim Storage of PlutoniumComponents at Pantex was considered and utilized in the production of the PantexEIS. Baseline operations were also considered by utilizing the informationprovided in the Pantex Plant Environmental Information Document (Pantex 1996),the Safety Information Document (Pantex 1996a), and the Programmatic InformationDocument (Pantex 1996b) that were created by the plant as resource material. See response to comments 23.012 and 23.053.

RC: 23.048

Doc: HT17/66

... I think it is both poor practice and, frankly,...hard to justify thatin terms of looking at the baseline of existing impacts, the document providesno assessment of what the impacts of the operation have been to those nearbysurrounding residents to the plant. There have been impacts, and they need to beanalyzed. It's frankly disgusting that your only charting document of wherethese surrounding residences even are in the document are wrong, but there'smuch more wrong with the lack of analysis than that.


The Department believes that impacts have been properly assessed. Themap in the Draft EIS did mislocate some residences. That has been corrected inthe Final EIS. However, a check of the database shows that the grid coordinatesof the residences in the air quality model are correct and that the effectsdescribed were correctly modeled and analyzed in the text.

RC: 23.049

Doc: PC-017/2

How can you determine the safety and purity of our agricultural activitiesand products if no thorough studies have been done?


The available information from past studies, along with the analysesperformed in this EIS provide adequate assessment of potential impacts toagriculture and human health risks.

RC: 23.050

Doc: MG-002/1

We recognize that the DEIS follows the standard NEPA-mandated DOE format ofidentifying alternatives and then comparing and contrasting these alternativesby describing potential impacts on a number of environments. This standardformat is well-recognized as a reliable and valid process to identifytraditional impacts that may result from a major Federal activity such as thatdescribed in the DEIS. However, we feel that the approach falls short ofaddressing the concerns of those persons and institutions most affected by theproposed project, namely those located in proximity to the site of the proposedactivity and those located along related transportation routes. Residents ofClark County and visitors to the area certainly fall within this definition andwe would expect that their perceptions and concerns would be taken into accountas the Pantex EIS is finalized and the record of decision is reached.


Volume I, chapter 4, addresses the affected environment and thepotential environmental impacts in an 80-kilometer (50-mile) radius around thePantex Plant. Section 4.11, Socioeconomic Resources, and section 4.16,Intersite Transportation, address the commentors specific concerns. Commentsreceived in these areas have been considered and the final document has beenupdated where appropriate. All comments were considered in preparation of theFinal EIS, which the Secretary considers in issuing the Record of Decision.

RC: 23.051

Doc: PC-025/1

In general, I do not understand how this EIS and its Proposed Action, NoAction, and alternatives meets the intent of NEPA. Please explain how this2,000, 1,000, and 500 level analysis meets the intent of NEPA. I believe thelevels are not different enough to analyze, please comment. Plus don't theimpacts at 2,000 cover 1,000 and 500 levels, please comment on this issue.Please explain why an EA or supplemental EIS aren't more appropriate. Pleaseprovide a technical response including regulatory citations detailing why thisEIS meets the purpose of NEPA when the alternatives are so similar. Should theanalysis look at one level of activity and then limit detailing the "whatifs" at higher and lower levels if necessary. This would possibly reducethe size of the document by 50 percent.


The Pantex EIS was prepared to support the Proposed Action of continuedoperations and interim storage of up to 20,000 plutonium pits at Pantex Plant inaccordance with the guidance provided in NEPA (42 U.S.C. Section 4321 et seq.)and the implementing Council of Environmental Quality Regulations (40 CFR1500-1508). An environmental assessment is not a viable option for the ProposedAction, since the Secretary of Energy made a commitment to the Governor of Texasat the completion of the Environmental Assessment of Interim Storage ofPlutonium Components at Pantex Plant that the storage of plutonium pits wouldnot exceed 12,000 pits prior to completion of additional analysis in anenvironmental impact statement (herein referred to as the Pantex EIS). Therationale for the 2,000, 1,000, 500 activity levels bounding the Proposed Actionand alternatives is provided in volume I, section 2.2 of this EIS.

RC: 23.052

Doc: PC-025/2

On Page 1-14 in the second column in the last paragraph. If the decisionwill be based on cost, technology, national security, and infrastructureconsiderations, which documents covering cost, technology, and national securitywill be used? This implies the decision maker will use the information to makethe decision without public comment. Does that meet the intent of NEPA? Willthey be available to the public? Do the documents exist? When will thesedocuments be completed?


The analysis for this EIS has been conducted in accordance with CEQregulations (40 CFR 1500-1508). NEPA ensures that environmental issuesassociated with a decision are adequately addressed. Cost, technology, nationalsecurity, and infrastructure considerations are other decision making factorsthat DOE anticipates relative to this Proposed Action. These documents areprepared as needed prior to the Record of Decision.

RC: 23.053

Doc: CO-005/3

Provide us [with] the data that proves DOE has not already contaminated oursoil, air and water. Show us the documents where you have fully assessed theimpact nuclear and high explosive activities have had and will have in thefuture on regional agriculture. Until agriculture is fully assessed, the impactsfrom the range of alternatives cannot be adequately scrutinized.


See response to comment 23.023. More than 1,000 documents on PantexPlant were considered in preparing the EIS. These documents are available uponrequest from the Department. The Department has already provided baselineinformation in the form of three documents made available to the public. Thesedocuments are: (1) Programmatic Information Document (Pantex 1996b); (2)Environmental Information Document (Pantex 1996); and (3) Safety InformationDocument (Pantex 1996a).

3.24 Miscellaneous

RC: 24.001

Doc: HT02-22/1

... When we think of Pantex as people, 3,500 people, most of whom are veryhighly qualified, having a real appreciation for the quality of life for theirfamilies, here in Amarillo, we have excellent educational facilities fromkindergarten all the way through to graduate level.

We have excellent cultural facilities, symphony, art, opera and so forth. We have excellent climate. We're just about the right size for people who wantto really become an integral part of a good community to raise their families.

And of several different sessions that I have heard over the last few years,I don't recall having anybody express any concern about the fact that those3,500 people who work at Pantex, whomever they may be, need to have a place tolive and work in a place where they have a high quality of life.

And I think that is something that DOE needs to remember after they'veconsidered all the technical aspects, all the hard, cold facts, that we've gotto recognize that those 3,500 people have an excellent place in which to liveand do their work and raise their families.


Thank you for your comment.


Doc: HT13/74

... My that [the] safety analysis report [should] be madeavailable as the previous safety analysis report for Zone 4 was made availableto the public, and I specifically, Don Hancock, Southwest Research andInformation Center here in Albuquerque, want to be [notified] when that safetyanalysis report is available.


The previous Zone 4 Safety Analysis Report (SAR) was released to thepublic in 1994 due to the fact that the Zone 4 Environmental Assessment citedthis document heavily (DOE 1992f). As for future SARs, including the Zone 4,these documents are generally not available to the public due to the added costin declassification. As for the EIS, this document relies heavily on theProgrammatic Information Document (Pantex 1996b), the Environmental InformationDocument (Pantex 1996), and the Safety Information Document (Pantex 1996a).

RC: 24.003

Doc: HT17/48

Another piece, though, that really does trouble me is the lack of contextthat this document builds. Jerry Johnson, in his introductory remarks, did moreto sort of put the context out when we first started this meeting this morning,when he talked about in 89 it was this, in 91 we were talking about expanding,and by the time we got to 93 we were doing thus and so. A few lines, and yet itput far more perspective about what the department had been through, the nuclearweapons program has been through, and what brought Pantex to where we are today. For instance, instead of saying Pantex used to do staging and now we dostorage, I think it would not take many more words to say that Pantex [staged]plutonium components until 1989, when the Rocky Flats plant closed, and at thattime it began to hold them, and then say when storage actually initially began.


The context is stated in the summary section of the Pantex EIS asrecommended by CEQ 1502.12.

RC: 24.004

Doc: PC-025/88

... How many Information Document versions are there (i.e. 1995a, d, andh)? Why so many PCs? What does PC stand for? What does nd stand for? IsN441.1 correct?


There were numerous versions of the Information Documents (IDs). As theEIS was being produced, the most current ID was used; thus, the EIS listsdifferent versions of the IDs. PC is an abbreviation for personal communicationwhich was used as a reference; the abbreviation nd denotes no date. N441.1stands for a DOE Order (N441.1) titled, "Radiological Protection for DOEActivities"; this Order is current as of March 1, 1996.


Doc: PC-025/89

... Why only CDRs as source? Nothing better?


DOE procedures have tied NEPA into the project review and approvalprocesses. As a result, money is generally not approved for detail design untilcertain stages are completed in the NEPA process.

How to Find a Comment Response in Chapter 3

The comment responses appearing in chapter 3 are categorized and organizedaccording to their topic, or resource category. The sequencing of resourcecategories is as follows:

  • Alternatives (01)
  • Relationship to Other EISs (02)
  • Infrastructure (03)
  • Land Use (04)
  • Geology and Soils (05)
  • Water Resources (06)
  • Air Quality (07)
  • Acoustics (08)
  • Biotic Resources (09)
  • Cultural Resources (10)
  • Socioeconomic Resources (11)
  • Intrasite Transportation (12)
  • Waste Management (13)
  • Human Health (14)
  • Aircraft Accident (15)
  • Intersite Transportation (16)
  • Environmental Justice (17)
  • Irreversible and Irretrievable Commitment of Resources (18)
  • Unavoidable Adverse Environmental Impacts (19)
  • Relationship Between Short and Long Term Effects (20)
  • Cumulative Impacts (21)
  • DOE Policy (22)
  • NEPA Process and Procedures (23)
  • Miscellaneous (24)

The parenthetical number next to each of the above categories is theresource category identifier for that topic. For example, the resource categoryidentifier for all comments in volume III relating to water resources is "06".

Table GP1 lists all of the resource code identifier numbers and all of thedocument numbers associated with each commentor. A commentor may go directlyfrom the list of comment numbers to the Departments response to any of thosecomments. Comments and responses in chapter 3 are grouped by resource categoryand then by sequential comment number within the category. The combination ofresource category and comment number is termed a "Resource Category"(RC) identifier. For example, the first comment in resource category "06"would be labeled "RC: 06.001". To facilitate ease of location, eachcomment (and its response) in chapter 3 is marked with its unique "RC"identifier in the left hand margin.

Table GP2 lists all comment numbers that appear in each comment document. Toillustrate the use of Table GP2, suppose one had used Table GP1 to locate theletter written by Dana Porter. The Document Number shown in Table GP1 for Danasletter is "PC-023". Turning to Table GP2, one would then look for theentry "PC-023" under the left-hand column labeled "DocumentNumber". That entry appears in the "Document Number" column onpage GP17. For illustration, that portion of Table GP2 is shown below:

To the right of the document number entry are three more columns. Thecolumn labeled "Sequence Number" shows that in Dana Porters letter(PC-023) there are five comments (sequentially numbered 1 through 5). Thecolumn headed "Resource Category" shows that the first comment of DanaPorters letter is about resource category 23 (NEPA process and procedures), thesecond and third comments in that letter are about resource category 06 (waterresources), the fourth comment is about resource category 08 (acoustics), andthe fifth is about resource category 03 (infrastructure). The final column,labeled "Comment Number" tells the reader that Danas five comments arethe 38th comment in resource category 23, the 46th and 47th comments in resourcecategory 06, the first comment in resource category 08, and the sixth comment inresource category 03.

Continuing the example, suppose one wanted to see the responses to Danas twocomments on water resources. One would note the resource category (06) and thecomment numbers (046 and 047). Danas two comments on water resources would thusbe marked as "RC: 06.046" and "RC: 06.047" in chapter 3.

To find these two comments and their responses, one would turn to the sixthsection of chapter 3 (i.e., section 3.6) and scan through the ResourceCategories in the left hand margin until finding "RC: 06.046", Danasfirst comment regarding water resources. At this point the reader will seeDanas verbatim comment, along with the response to that comment. Immediatelyfollowing that comment and its response is the entry for "RC: 06.047",which is Danas second comment about water resources.

Having found the entry "RC: 06.046", one will also findimmediately under it an accompanying cross reference to the document number inwhich the comment originated. The marginal notations look like this:

RC: 06.046 Doc: PC-023/2

The marginal code labeled "Doc:" shows the document number andsequence number of this particular comment among all other comments that appearin that same document. In this example, the code "Doc: PC-023/2" meansthat this particular comment ("RC: 06.046") was the second comment inDocument Number "PC-023". With this information, the reader may, ifdesiring to do so, go back to chapter 2 to view the source document and considerthe context within which the comment was made.

When a person did not identify himself or herself, during the publicmeetings, an anonymous identification (such as unidentified speaker) was enteredinto the transcript. In addition, some of the postcards submitted had illegiblesignatures. Thus, for these two reasons, there are numerous comments attributedto an unidentified commentor.

(Video) (Part 1) DOE Atomic Energy Defense Activities and DOD Nuclear Programs

In using this volume, note that resource category identifiers 03 through 21also correspond to the sequence that those resource categories are analyzedwithin the affected environment and impacts analyses for Pantex Plant (inchapter 4 of volume I). In other words, a reader could know that since waterresources has a resource category identifier of "06" and is located inthe sixth section of chapter 3 (i.e, section 3.6) of volume III, that the maindiscussion of the Pantex Plant affected environment and impacts related to waterresources can be found in the sixth section of chapter 4 in volume I (i.e,section 4.6). This correlation is intended to make it relatively easy forreaders to use volumes I and III together in reviewing both the Final EIS textand the comments related to that text.


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1. 02 - Kristen Iversen, PhD - " An Introduction to the History of Rocky Flats..."
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