30.02

Several commentors request additional cost information or express dissatisfaction with the selection of Pantex as the preferred alternative over NTS. Information requested includes specific differences in security guard costs and estimated dollar savings for Pantex versus NTS. Another commentor requests that DOE use a "fair and open cost comparison" of all alternatives in analyzing sites and that this information be shared with the public.

• Response: The preferred alternative for the A/D mission is to downsize the current operations at Pantex. The final decision will be documented in the ROD. Cost effectiveness is only one of the many factors DOE used to arrive at the preferred alternative. The PEIS analysis shows that while there is some potential for adverse environmental impacts associated with continuing A/D operations at Pantex, the impacts would be less for the downsized facilities than for the No Action alternative. Additionally, there is less technical risk associated with the Pantex alternative because Pantex personnel are currently performing this mission, whereas similar operations for assembly of nuclear test devices at NTS have historically been performed by laboratory personnel. Specific program and alternative costs are not part of the PEIS analysis. Stockpile management alternative costs have been analyzed in two supplementary documents provided by the DOE Albuquerque Operations Office. These reports, the Analysis of Stockpile Management Alternatives report, and the Stockpile Management Preferred Alternatives Report, are available for public review at the DOE Public Reading Rooms near each site.

30.03

Several commentors express support for NTS and for moving the A/D mission to NTS. Commentors state that NTS has the established infrastructure, trained workforce, and ideal location to accept such a mission. Commentors also state that even with the past nuclear activities conducted at the site, tourism and area growth was not affected. Some commentors suggest that NTS has not been properly represented in the Draft PEIS.

• Response: For the weapons A/D mission, only Pantex and NTS were considered as reasonable alternatives because no other DOE sites possess the experience and infrastructure to perform this mission. The preferred alternative is to downsize at Pantex because analysis discussed in the Analysis of Stockpile Management Alternatives report and the Stockpile Management Preferred Alternatives Report shows that Pantex is a lower cost and lower technical and schedule risk alternative than NTS. The preferred alternatives were developed by DOE using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. Retaining the weapons A/D mission at Pantex presents less cost and technical risk than relocating to NTS because Pantex personnel are currently performing this mission, whereas similar operations for assembly of nuclear test devices at NTS have historically been performed by laboratory personnel. Hence, additional risk is added to the NTS alternative due to: the support that would be required from the laboratories to assist in the qualification of production operations, the uncertainty of laboratory personnel availability, the significant amount of construction required on a very aggressive schedule, and the 1-year gap in operations which would result from transition of the mission to NTS. The two stockpile management alternatives reports are available for public review at the DOE Public Reading Rooms near each site.

30.04

The commentor cites section 3.7.1, Stockpile Management, and thinks the last sentence of the last paragraph should read "in the unlikely event ... of an accident instead of "... in the event of an accident."

• Response: The sentence in question is correct as stated since it refers to the consequences of a postulated accident, not the probability that it would occur. The PEIS analysis, as detailed in appendix F and as discussed in section 4.1.9.2, Facility Accidents, includes both the probability and the consequences of selected representative accidents. These accidents include both beyond design basis (high-consequence, low-probability) and design basis (low-consequence, high-probability) accidents.

30.05

The commentor cites appendix table A.3.1.1-1, states that the table should include the Burning Ground, and inquires about the location of the sanitization and demilitarization facilities and the waste treatment facilities.

• Response: The Burning Ground is not considered part of the A/D operation, but is covered separately in the HE fabrication function (see appendix table A.3.5.1-2). There is some uncertainty associated with the time period for the elimination of projected inventories of HE from weapon dismantlement, and consequently there is currently no approved schedule for this activity. A completion date of fiscal year 2000 is assumed in the PEIS and is considered conservative, as it allows for 2 additional years to complete the disposition of HE that would be generated at Pantex through 1998. In other words, the HE waste produced during dismantlements should be disposed of prior to the implementation of the downsized facility at Pantex. Appendix table A.3.1.1-1 is not intended to include all of the facilities needed to support A/D operations, only "key" facilities. Although some sanitization and demilitarization actions are conducted at Pantex, there are no facilities dedicated solely to these activities. Parts resulting from the A/D operations may be recertified and staged for reassembly, shipped to the originating site for evaluation or disposition, or processed as residual material in the waste management process. Waste management affected environment and environmental consequences of proposed stockpile stewardship and management actions at Pantex are discussed in sections 4.5.2.10 and 4.5.3.10, respectively, and appendix section H.2.4.

30.06

The commentor wants to know what DOE means by stating they would like to keep the stockpile as young as possible and asks if A/D will continue in order to keep the stockpile fresh. In addition, the commentor asks what happens to pits that come out of the disassembled weapons.

• Response: Weapons would be refurbished, modified, and retrofitted as needed for components that have, or are expected to be, degraded due to age. In many cases, the A/D site would be involved in fixing those components. The pits from disassembled weapons are either used in rebuilt weapons or are surplused and disposed of by the DOE Office of Fissile Materials Disposition.

30.07

The commentor thinks that there is no recognition throughout the PEIS that the Device Assembly Facility is a backup to Pantex, which could be critical to the successful implementation of treaty requirements. The Device Assembly Facility could act as a backup facility should Pantex be shut down as a result of a natural disaster or a safety violation. The commentor states that the PEIS process has analyzed two options: (1) to keep A/D operations at Pantex and (2) to transfer those operations to NTS. The commentor believes that the option to combine operations in a way that more completely protects the national options of the President has been completely disregarded.

• Response: The design of the Device Assembly Facility is identical to the facilities at Pantex and was recently built to support the underground testing program at NTS. It does not, however, have the space and capacity to serve as a complete backup to Pantex without significant construction that would take many years to accomplish. In addition, many of the existing bays and cells at Pantex would not be utilized by A/D operations but could be rapidly put to that use if some of the other facilities become inoperable.
  
  At one time there was another site performing A/D work, but the need for a redundant operation was not considered necessary; therefore, that site was closed. Given that the need for a backup facility was considered unnecessary during the Cold War, it is not reasonable to plan to have this capability at NTS at this time.

30.08

Referencing page 7-17 of the Analysis of Stockpile Management Alternatives report, the commentor believes a stockpile of 1,000 weapons was analyzed in order to increase the chance that production work would be moved to the laboratories. The 1,000 level favors lower production capability at the laboratories and makes Pantex look extremely large in cost, according to the commentor.

• Response: DOE established the baseline workload based on the best estimate of the future size and composition of the stockpile. In addition to the base case, two other workload levels were established as a means of providing a sensitivity analysis among the various alternatives. As such, the 1,000 weapon stockpile was considered to be a reasonable lower stockpile level and was used by all sites for all missions. It was not devised as a means to make one site appear more favorable than another.

31 Management--Nonnuclear Components

31.01

Several commentors express support for KCP and the Secretary of Energy's decision to downsize the nonnuclear fabrication mission at KCP rather than transfer this mission to an alternative site; however, they are concerned about the loss of expertise and skill base. One commentor wants to know what level of flexibility is built into decisions should things change in the future, and one suggests an expansion of KCP's role in providing nonnuclear fabrication support.

• Response: As the commentors noted, the preferred alternative for the nonnuclear fabrication mission is to downsize KCP. The preferred alternatives were developed by DOE, using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. The PEIS does not analyze how well the preferred alternative meets operational needs. This analysis can be found in the Stockpile Management Preferred Alternatives Report and the Analysis of Stockpile Management Alternatives report, which show that the KCP alternative is lower in cost and has less technical risk than relocation to the laboratories. Technical risk is greater for the laboratory alternatives because KCP currently has an existing production infrastructure to support scheduled work, whereas the laboratories currently do not possess the required production capacity, and their production capability and infrastructure are less mature than that of KCP. The design of the downsized production alternative at KCP provides the technical capability, production capacity, and flexibility necessary to allow KCP to support scheduled nonnuclear production and a wide range of unanticipated production requirements. The two stockpile management alternatives reports are available for public review at the DOE Public Reading Rooms near each site.

32 Management--Pits

32.01

Several commentors are concerned that reestablishing pit production would lead to either increased weapons production, larger scale pit production capacity, or new designs of weapons. The commentors want clarification of proposed pit production capacities at LANL, historical pit production capacities at Rocky Flats, and the relationship between replacement pit production and the possibility of pit processing leading to new or improved weapons design. One commentor opposes continued production of plutonium pits and is of the opinion that the nuclear industry is the greatest threat to life on this planet.

• Response: The mission of the pit fabrication facility would be to reestablish the national security capability required to provide replacement pits for any stockpile weapon. Safety improvements to existing weapons pit designs could be incorporated if necessary and if directed by the President. Although there are presently no plans to develop any new weapons, the facility would be capable of fabricating new pit designs, should the President so direct in the national interest. DOE does not propose to establish higher manufacturing capacities than are inherent with the basic manufacturing capability. As discussed in section 3.1.1.1, stockpile management facilities analyzed in the PEIS are sized to support a base case stockpile size consistent with the Strategic Arms Reduction Treaty (START) II protocol and are therefore consistent with U.S. arms control policy. The capacity of the LANL pit fabrication facility is discussed in appendix section A.3.3.1, and is shown as a maximum of 80 pits per year, assuming surge (multiple-shift) operation, and use of equipment at full capacity. The capacity of Rocky Flats for pit production was about 2,000 per year. Actual production numbers are classified. With regards to larger-scale pit production, in sizing pit fabrication for the foreseeable future, consideration was given to establishing a larger fabrication capacity in line with the capacity planned for other portions of the Complex. However, after review of historical pit surveillance data, larger capacity was rejected because of the expected small demand for the fabrication of new replacement pits for the foreseeable future covered in this PEIS. Section 3.6 of this PEIS explains this in greater detail.

32.02

A few commentors question specific historical and proposed pit processing technologies. Specifically, commentors ask if the fissile materials will be melted and purified before being remanufactured and wonder if DOE would replace the pits with a different alloy or use the same alloy if a pit metal problem developed. If a different alloy is used, the commentors question whether DOE currently has the technology to change the plutonium alloy mix if a problem develops. One commentor states that the complex metallurgical structure of plutonium limits the processing possibilities and as an example gave the perceived failure of the near-net shape casting process employed at Rocky Flats. In the commentor's opinion, better computer modeling will not change the problem.

• Response: The mission of the pit fabrication facility would be to provide replacement pits for any stockpile weapon. Thus, the pit design and alloys would remain the same. New alloys or designs would relate to new weapon designs which are presently not planned, but may be implemented, should the President direct it in the interest of national security. The facility would have the capability to develop and fabricate new pit designs in that case. This capability would include testing and analysis to address the complexities inherent in plutonium processing.

32.03

The commentors oppose or express concern about reestablishing pit production at LANL and the oversight of ES&H issues by site management and personnel. Some commentors feel that a sound ES&H culture does not exist at LANL and that LANL has failed to implement "Conduct of Operations" successfully. These commentors also suggest that DOE institute a separate "chain of authority" for ES&H personnel to eliminate a conflict of interest that can currently occur when such personnel report to line management. Other commentors express concern about LANL's security and relationship with DOE, personnel management, plutonium handling, and waste management.

• Response: As stated in section 3.1.1, Planning Assumptions and Basis for Analysis, DOE will emphasize compliance with applicable laws and regulations and accepted practices regarding industrial and weapons safety, safeguarding the health of workers and the general public, and protecting the environment. Section 4.14 describes the regulations and requirements under which all DOE sites conduct their operations during the normal course of their work activities, including potential accidents and associated human health and environmental consequences of an accident. Although the commentor correctly points out that operations at LANL have occasionally been found to be out of compliance with various environmental laws, DOE and LANL management have made good faith efforts to bring laboratory facilities into compliance in a timely fashion. DOE expects its management and operating contractors operate its facilities in compliance with all Federal, state, and local laws. As explained in section 3.1.1.1, No Action Alternative Assumptions, conservative estimates were purposely used in the PEIS to provide a bounding analysis for the environmental impacts. New or better processes as described in section 3.5, Emerging Technologies, can reduce waste streams and lower the environmental impacts. Analyses discussed in the Analysis of Stockpile Management Alternatives report show that the LANL alternative is lower in cost and has less technical risk than the SRS alternative. Technical risk is lower for LANL because of recent experience in providing pits for nuclear explosive testing. The Analysis of Stockpile Management Alternatives report is available for public review at the DOE Public Reading Rooms near each site.

32.04

The commentor asks how often a flaw in a pit applies to an entire weapon type.

• Response: Whether or not a flaw in a pit applies to an entire weapon type depends on whether the flaw is a result of a design shortcoming or the manufacturing process. In the case of either a design or manufacturing shortcoming resulting in a flaw, the entire weapons type may well be affected, but these shortcomings could make only some units, subject to a particular history, susceptible. Similarly aging defects can affect a few weapons or many, depending on whether they uniformly affect the system or whether individual history of some of the units, is a factor in how the system ages or responds to an aging-related defect. A more detailed unclassified discussion of weapon defect history can be found in the tri-laboratory report Stockpile Surveillance: Past and Future (SAND95-2751, January 1996).

32.05

The commentor asks what the economic impacts associated with pit production would be at LANL. The commentor also inquires about the budget for the pit fabrication facility.

• Response: The economic effects of pit production at LANL on regional economy and employment, population and housing, and public finance are discussed in section 4.6.3.8. The budget for the pit fabrication facility is not part of the PEIS. However, estimates of the operating costs for stockpile management alternatives at the various stockpile levels can be found in the Analysis of Stockpile Management Alternatives report, prepared by the DOE Albuquerque Operations Office. This report is available in the DOE Public Reading Rooms near each site.

32.06

Several commentors express support for SRS and its continued operation in support of existing and new DOE missions. One commentor asks if pit fabrication at SRS would be shut down. Another asks if Pantex or other sites would conduct pit fabrication. Several commentors express specific support for SRS to conduct pit fabrication activities.

• Response: SRS currently has no pit fabrication capability. SRS does maintain a major role in tritium recycling and is the preferred alternative site for tritium supply if accelerator production of tritium is ultimately chosen, as discussed in the Tritium Supply and Recycling ROD. As discussed in section 3.2.1, Site Selection, only those sites with existing infrastructure or facilities capable of supporting a given stockpile stewardship or stockpile management mission were considered reasonable site alternatives for detailed study in the PEIS. DOE analyzed only two sites as reasonable alternatives for pit fabrication and intrusive modification pit reuse: LANL and SRS. SRS was considered a reasonable alternative for only the pit fabrication mission because of its plutonium processing infrastructure. Although the final decision as to where this specific mission would be located will not occur until the ROD, the preferred alternative site for the mission is LANL.
  
  The analysis discussed in the Analysis of Stockpile Management Alternatives report shows that the LANL alternative is lower cost and has less technical risk than the SRS alternative. Technical risk is greater for the SRS alternative because LANL has recent experience in providing pits for nuclear explosive testing, whereas SRS has no experience with the kind of capabilities required for precision nuclear component manufacturing. Additionally, the LANL capability could be in place 2 years earlier than the SRS capability. The Analysis of Stockpile Management Alternatives report is available for public review at the DOE Public Reading Rooms near each site. As discussed in section 2.4.2, the Rocky Flats Plant formerly produced pits, and is no longer available for this mission. Therefore, DOE currently has no pit fabrication capability except for the limited R&D capabilities at LANL and LLNL.
  
  The weapons A/D mission, for which Pantex is the preferred alternative, includes provisions for nonintrusive modification pit reuse. This is not pit fabrication. As discussed in section 3.4.1 and appendix section A.3.4 of the PEIS, nonintrusive modification pit reuse does not involve plutonium processing or disassembly of the pit. The modifications would be to external features of the pit and would not result in handling exposed plutonium. After modification and inspection, the pit would be mated to main charge HE, which is a function of the A/D mission. Since the nonintrusive modification function is essentially a step between receipt of the pit and assembly with HE, DOE considers it reasonable and prudent to perform this function at the A/D facility.

32.07

The commentor notes that the stated objective in the PEIS is to preserve "core competency," but the Program fails to address this issue with regard to pit manufacturing. The commentor feels that a pseudo-manufacturing capability in an R&D laboratory is not the same. Another commentor believes that the No Action alternative description for pit fabrication was inadequate.

• Response: Currently, there is an R&D plutonium capability at LANL. The No Action alternative discussed in section 3.4.3.1 of the PEIS would maintain only a limited plutonium component fabrication capability at LANL and a less extensive capability at LLNL, and therefore would not provide sufficient pit fabrication capability to meet the requirements stated in section 3.1. Reestablishing pit fabrication at LANL would allow for the entire pit-related workload to be accomplished at the laboratory, which would preserve core competency better than having less work at each of two sites, the laboratory and the fabrication site. Analysis discussed in the Analysis of Stockpile Management Alternatives report shows that the LANL alternative is lower in cost and has less technical risk than the SRS alternative. Technical risk is lower for LANL because of recent experience in providing pits for nuclear explosive testing. The Analysis of Stockpile Management Alternatives report is available for public review at the DOE Public Reading Rooms near each site.

32.08

The commentor questions where pit components and beryllium components will be manufactured. The commentor believes that Y-12 has the experience and capability for recycling chips.

• Response: The manufacturing of pit components is an integral part of the pit fabrication mission and would be included with that mission which, in the preferred alternative, is LANL. The mission of fabrication of beryllium components that was formerly assigned to the Rocky Flats Plant was reassigned to LANL as a result of the Nonnuclear Consolidation Program in 1993. The Y-12 Plant would continue its historical role of manufacturing HEU parts for pits.

32.09

The commentor believes that SRS should close down and operations be transferred to another DOE site, preferably ORR or Pantex. Other commentors wonder what impact their comments on closing SRS have on the decisionmaking process, and what the best way is to do this.

• Response: Closing of SRS was not an alternative under consideration in the PEIS. The only alternative relating to SRS was for reestablishing pit fabrication and LANL was identified as the preferred alternative site for that mission. Over the past several years, some DP missions at SRS have been terminated and the majority of facilities turned over to Environmental Management. The remaining DP activities are associated with tritium, and are primarily located in H-Area, a small portion of the entire site.

32.10

The commentor notes that the environmental impacts per pit produced would be reduced by using advancements such as new welding techniques, dry machining, and the reduction of oils and organic solvent usage. The commentor also points out that the actual environmental impacts may be less than the impacts outlined in the document since conservative estimates were used in the analysis of the impacts.

• Response: New or better processes can reduce waste streams and lower the environmental impacts. Section 3.5 describes the emerging technologies for the stockpile management processes. The baseline flow sheet for plutonium fabrication did assume dry machining as suggested by the commentor, consequently a waste stream consisting of cutting oils is not analyzed in this PEIS. As explained in section 3.1.1.1, No Action Alternative Assumptions, conservative estimates were purposely used in the PEIS to provide a bounding analysis for the environmental impacts.

32.11

The commentor asks if the need for pit production outweighs the additional risks to the citizens of Los Alamos. The commentor asks what the citizens of Los Alamos will gain from bringing pit production to LANL.

• Response: Section 4.6.3.9, Radiation and Hazardous Chemical Environment, presents the incremental risk to members of the public in the LANL vicinity. Table 4.6.9.3-1 shows the annual exposure to the maximally exposed member of the public would be 8.7 mrem, which is 2.6 percent of the natural background radiation exposure of 340 mrem to the average individual. The total dose to the public within 80 km (50 mi) of LANL would be 1.4 person-rem, which is approximately 0.15 percent of the natural background total dose. Hazardous chemical exposures are also presented in section 4.6.3.9. For the pit fabrication alternative, the incremental hazard index (HI) for the maximally exposed member of the public would be 2.18x10 -4 which is approximately 0.16 percent of the No Action HI of 0.0135. This increase in HI corresponds to essentially a 0-percent increase in cancer risk. Benefits to the community are largely socioeconomic in nature. Section 4.6.3.8, Socioeconomics, provides information concerning jobs to be generated by the pit fabrication alternative. Facility modification activities would generate approximately 140 direct and 90 indirect jobs during the peak year of construction. Operation of the facility would generate about 260 direct jobs.

32.12

The commentor wants to know the pit production capacity at TA-55 in LANL. The commentor also wants to know how easily the pit production capacity at TA-55 could be expanded. Another commentor states that there should not be any further capital investment above maintenance or steady state costs.

• Response: The TA-55 facility currently has the ability to make a few pits per year as part of the stockpile surveillance and rebuild program, but it is not a production facility or program. The expansion of TA-55 is discussed in section 3.4.3.2. Stockpile management facilities analyzed in the PEIS are sized to support a base case stockpile size consistent with the START II protocol, and are therefore consistent with U.S. nonproliferation policy. The capacity of the proposed LANL pit fabrication facility is discussed in appendix section A.3.3.1, of the PEIS, and is shown as a maximum of 80 pits per year, assuming surge (multiple-shift) operation, and use of equipment at full capacity. For information on cost and schedule for modification of the TA-55 plutonium facility, the commentor is referred to the Analysis of Stockpile Management Alternatives report which is available at the DOE Public Reading Rooms near each site.

32.13

The commentor asks how long pits can remain in the stockpile before buildup of decay products become a design or handling concern.

• Response: Modern nuclear weapons were designed with a minimum design life of 20 to 25 years. Based on existing surveillance data, DOE expects the pits to last at least this long, and probably considerably longer. However, very little historical and applicable data exists beyond 30 years. With regard to the buildup of decay products alone, DOE does not currently believe this will become a problem in less than 50 years. Other combined effects (radioactive and chemical) are not as well understood. Science-based stockpile stewardship, and enhanced surveillance technology in particular, will focus on improved predictive capability in this area.

32.14

The commentor points out a disparity in the amount of chemicals being used for fabricating pits at LANL and SRS. According to the commentor, SRS proposes to use 3,420 kg (7,536 lb) and LANL 32,886 kg (72,461 lb) which is a difference of a factor of about 10.

• Response: The processes at both SRS and LANL are the same. These numbers show only annual make-up after recycling of nitric acid (annual usage after the first year of surge production). The LANL number shows the first year requirement for surge production (e.g., 32,886 kg [72,461 lb] the first year with 3,420 kg (7,536 lb) of make-up each following year). Usage in subsequent years would be comparable to the SRS figure. Appendix tables A.3.3.1-4 and A.3.3.2-4 have been changed to reflect this fact in the Final PEIS.

32.15

The commentor wants to know if there will be waste management associated with the pit fabrication mission at LANL.

• Response: Waste generated from the pit fabrication mission would be managed within the existing and planned waste management infrastructure at LANL. No new waste management facilities would be needed to support the pit fabrication mission.

32.16

The commentor asks, if laboratory facilities are so capable, why are we investing in new facilities at LANL and why postulate that it will be another 5 years before LANL can make a production pit.

• Response: The laboratories are indeed capable, but are presently established as R&D facilities, not as production facilities. The assumed 5-year timeframe includes necessary equipment and facility modifications and establishment of appropriate quality and process control measures to ensure quality requirements would be met. The TA-55 plutonium facility is approaching 20 years of service, and many components of the facility need replacement or upgrading in order to sustain the R&D mission of the laboratory. This refurbishment constitutes the major portion of the DOE investment at the TA-55 plutonium facility. Reconfiguration of the internal arrangements of one of the wings of the building to provide for pit fabrication is a relatively minor part of the total task.

32.17

The commentor wants to know, for the pit production mission at LANL, if DOE will focus its attention on the greater hazards of processing and handling of plutonium and the eventual disposal of the waste or on simply the shipment of the finished product.

• Response: As stated in section 3.1.1, Planning Assumptions and Basis for Analysis, DOE will emphasize compliance with applicable laws and regulations and accepted practices regarding industrial and weapons safety, safeguarding the health of workers and the general public, and protecting the environment. Section 4.14 describes the regulations and requirements under which all of the DOE sites conduct their operations during the normal course of their work activities. This also includes potential accidents and associated human health and environmental consequences of an accident.

32.18

One commentor questions whether waste volumes include nonintrusive pit reuse operations, and whether the pit fabrication and nonintrusive pit reuse can be carried out simultaneously.

• Response: Waste volumes are analyzed for three-shift pit fabrication operations. This analysis is designed to bound the environmental impacts for any reasonably foreseeable workload. As discussed in section 3.4.1 and appendix section A.3.4 of the PEIS, nonintrusive modification pit reuse does not involve plutonium processing or disassembly of the pit. The modifications would be to external features of the pit and would not result in handling exposed plutonium. Estimated waste volumes from nonintrusive modification pit reuse are included in the weapons A/D estimates.

33 Management--Secondaries and Cases

33.01

Several commentors express support for continued operation of Y-12 and for retaining the secondary and case fabrication mission there. Reasons cited include past frequent upgrades of the facilities and processes at Y-12, historical expertise, and the exceptional troubleshooting and problem-solving experience of Y-12 personnel. Commentors suggest laboratory personnel are not experienced in manufacturing processes and cannot replace the experience of Y-12 personnel, and were concerned that the PEIS implied the Y-12 processes were out-of-date.

• Response: As noted by the commentors, the preferred alternative for the secondary and case fabrication mission is to downsize at Y-12. In addition to the No Action alternative at Y-12, DOE considered three alternative sites for the future secondary and case fabrication mission: Y-12, LANL, and LLNL. DOE considered the weapons laboratories at LANL and LLNL for secondary and case manufacturing as reasonable alternative sites to be evaluated as part of the NEPA process because of their design and existing limited R&D manufacturing capabilities. In appendix section A.3.2.1, the PEIS does state that Y-12 has performed the secondary fabrication mission in the Complex for over 40 years. This was not intended to imply that the production facilities are old and use old processes. In this section, the PEIS recognizes that during the past 12 years major restoration projects have brought the infrastructure support of this facility (Y-12) up to current standards and should allow the use of these facilities for up to an additional 40 years.
  
  Analyses discussed in the Analysis of Stockpile Management Alternatives report show that the Y-12 alternative is lower in cost and has less technical risk than either of the laboratory alternatives. DOE considers the existing infrastructure and personnel resources at Y-12 as important and valuable Complex assets in implementing Program requirements. The existing facilities and worker skills at Y-12 were taken into account in the ranking system used by DOE in the Analysis of Stockpile Management Alternatives report. In this analysis, Y-12 received a much higher score in "Basic Production Capability" and in "Capability of Production Infrastructure" than either LANL or LLNL. These scores were important in the selection of Y-12 as the preferred alternative site for performing future secondary and case component production. Technical risk is lower for the Y-12 alternative because it is the current secondary and case fabrication facility for DOE and has produced components for all weapons in the current stockpile. Although some process development would be required to fully satisfy this mission at Y-12, the risk is low. Both the LANL and LLNL alternatives would involve modifications to Y-12 processes or a new process, which would require additional process development, qualification, and prove-in, and thus the technical risks are higher. The Analysis of Stockpile Management Alternatives report is available for public review at the DOE Public Reading Rooms near each site.

33.02

The commentor would like the PEIS to provide specific examples of the HEU recycling purification or processing technology as well as lithium processing technology that exists to a comparable extent with either of the design agencies as well as Y-12.

• Response: As stated in the PEIS Summary, Y-12 produces the secondary and case components and uniquely possesses the complex technological capability for processing HEU and lithium materials. The design agencies, LANL and LLNL, do not have in place the HEU and lithium processing facilities or infrastructure to any extent comparable to Y-12. These design laboratories have a uranium technology base and facility infrastructure which are only capable of supporting a very limited R&D fabrication capability.

33.03

One commentor states that the A/D activities at ORR/Y-12 should be moved to SRS because there is more acreage to provide an environmental impact buffer zone.

• Response: In referring to "the A/D activities at ORR/Y-12," DOE assumes that the commentor means the secondary and case fabrication mission. SRS was not considered a reasonable alternative for this mission for several reasons. Although SRS has processed uranium fuel, it does not have the necessary equipment and facilities for large scale machining and processing of HEU and other special materials needed for secondaries and cases. Y-12 and both of the laboratories have existing facilities which could, with some modifications, fulfill the secondary and case fabrication mission. The Analysis of Stockpile Management Alternatives report discusses the secondary and case fabrication alternative in more detail and is available for public review at the DOE Public Reading Rooms near each site.

33.04

The commentor wonders what will happen to the buildings and infrastructure if downsizing of Y-12 occurs.

• Response: Downsizing of Y-12 would result in the plant being multi-program sponsored. Seventy-six percent of the building floor area and associated infrastructure would be transferred to Environmental Management; 14 percent would belong to DP departments engaged in conducting the stockpile management mission; and the remaining 10 percent would belong to other programs such as Materials Disposition, Nuclear Energy, and Work for Others. After transfer to Environmental Management, a transition plan is developed, detailing the cleanup plans, disposition of equipment, and ultimate disposition. There is an established process for including the adjacent communities in this process and DOE's Office of Economic Assistance has grants and other support services to assist in the retraining and out-placement of all adversely affected employees.

33.05

The commentor is of the opinion that the proposals of LANL and LLNL in the Summary suggest some lack of appreciation for what is involved. According to the commentor, LANL and LLNL claim to do the downsize secondary and cases fabrication mission with 321 and 290 workers, respectively. The commentor points out that Y-12 will require 1,080 workers for the mission which is 3 to 4 times, as many workers as the laboratories proposals. The commentor wants to know if DOE believes the laboratories proposals and is concerned that at some time in the future DOE or some oversight group may be misled (by the apparently large savings) into assuming the laboratories can do the job as well as Y-12, and subsequently transfer the mission. The commentor believes this would be a major loss to the Nation in abandoned stretch capacity, overall cost, safety, and quality.

• Response: For the secondary and case fabrication mission, the data supplied by Y-12, LANL, and LLNL differ in many factors such as surge capacity, facility designs, processes, work plans, floor plans, and the utilization of in-house production versus vendor supplied materials. These factors account for the large differences in the workers requirements at Y-12 versus those presented for the weapons laboratories. These considerations were reflected in the evaluation performed by DOE and documented in the Analysis of Stockpile Management Alternatives report. Data for the PEIS were developed by working groups for each stockpile management mission. These working groups consisted of experts from each of the potentially affected sites. A review of data for consistency and accuracy was performed at both the working team level and at a senior management level. To bound the potential environmental impacts at each site, the PEIS uses data reflecting "surge," or maximum production scenario. Because it is expected that this workload would be performed in existing facilities, not surprisingly the maximum potential environmental impacts varied somewhat between the sites for this bounding surge case. In addition, however, each alternative was assessed for the same single low and high single shift workloads.

33.06

The commentor refers to section 4.6.3 and questions whether anyone really believes that only minimal modification to existing facilities at LANL would be required for the secondary and case fabrication mission. The commentor states that no facilities exist for large lithium hydride fabrication and processing, that only minimal uranium and assembly facilities exist, and that facilities must be adequate to deal with potential surge requirements. In addition, the commentor states that this type of equipment costs tens of millions of dollars.

• Response: Section 4.6.3 addresses the environmental impacts by disciplines (land use, water resources, and site infrastructure) of proposed stockpile stewardship and management alternative actions. Section A.3.2.2 describes in some detail the modifications of existing facilities that would be required at LANL to support the relocation of secondary and case fabrication. The statement in section 4.6.3.1, "Only minimal modifications to existing facilities at LANL would be required," is made in the context of land-use impacts due to the relocation of the secondary and case fabrication mission. The minimal land-related modification is associated with providing a nominal area for equipment staging, material laydown, and parking during the modification of LANL facilities. As indicated in section 2.4.2, DOE recognizes that the cost of transferring production technologies to the weapons laboratories and the re-creation of capital facilities are major Program considerations. These were important factors in the selection of Y-12 as the preferred site for performing the future stockpile management secondary and case fabrication mission.

33.07

The commentor asks, who, by name, are the supposed experts at the laboratories in uranium and lithium hydride, and what are their qualifications.

• Response: There are numerous experts at the laboratories. However, their names have no bearing on the environmental impacts addressed in this PEIS.

33.08

The commentor states that the analysis with regard to this study discusses the preproduction of a supply of enriched uranium and lithium hydride sufficient to provide for needs for up to 100 years. The commentor questions if past experience does not indicate that this will guarantee the loss of the associated technology.

• Response: Not providing in-house production capability does not guarantee the loss of the needed supplies of these materials or the requisite technologies to support the weapons program needs. Sufficient supply of enriched uranium and lithium hydride would be removed from existing stocks, processed, and stored during the transition period (in fiscal year 1998) to supply DP needs for greater than 100 years at the current PEIS base case workload, therefore there is little justification for providing in-house production capability. Various contingencies are readily available to justify not providing the capability for lithium hydride/deuteride and enriched uranium purification. These contingencies include: feed material preproduction and storage, increased direct recycle of the materials, commercial procurement of service as a backup, disposition of material to other DOE programs, and placing processing equipment in cold standby for reactivation. If unforeseen stockpile problems or demands increase the secondary workload significantly, contingency plans to reactivate equipment in cold standby or to procure additional processing can be developed. The preferred alternative at Y-12 includes a small capability for lithium salt production.

33.09

The commentor points out the differences in the amounts of chemicals being used for the same mission at different sites. One commentor cites table 4.17-4 and asks how LANL is going to use only 1,568,333 kg/yr (3,455,665 lb/yr) of chemicals when Y-12 plans to use 6,488,333 kg/yr (14,296,393 lb/yr) of chemicals (a 76-percent reduction) or whether the LANL chemical use is only an estimated amount. Another commentor questions specified differences in nitric acid and sulfuric acid consumption at Y-12, LLNL, and LANL.

• Response: Table 4.17-4 provides estimates of the irreversible and irretrievable consumption of annual operating resources for the stockpile management alternatives. The differences in the secondary and case fabrication chemical usage between Y-12 and LANL is a direct result of differences in the proposed processing techniques utilized at Y-12 versus those proposed to be used at LANL. As given in appendix table A.3.2.1-6, the annual chemical requirement for Y-12 is a total of 19,088,334 kg/yr (42,059,235 lb/yr), of which 14,000,000 kg/yr (30,847,600 lb/yr) is argon and 5,000,000 kg/yr (11,017,000 lb/yr) is nitrogen. Of this total quantity, 6,488,333 kg/yr (14,296,393 lb/yr) are estimated to be irretrievably lost. LANL did not propose to duplicate the current processes or work plans in use at Y-12 for the secondary and case fabrication mission, consequently a direct comparison on gaseous chemical consumptive use cannot be made. For example, the Y-12 enriched and depleted uranium processes utilize vacuum induction casting furnaces with leakage rate of approximately 30 microns/minute whereas LANL proposes to utilize furnaces with lower leakage rate (5 microns/minute) eliminating the need to employ an argon purge (Argon Lance). LANL also proposes to utilize commercial and government furnished products to the maximum extent possible and may well incorporate an optimistic view of vendor availability and qualifications. Therefore LANL's quantities are considered estimates based on reasoned judgment. The nitric acid and sulfuric acid figures given in appendix table A.3.2.2-6 for LANL were in error and have been corrected. The values are now the same as for Y-12 (1,000 kg [2,203 lb] of nitric acid and no sulfuric acid). The LLNL values are less than either Y-12 or LANL due to the smaller capacity of the LLNL facility in the surge mode.

33.10

The commentor requests an explanation of the impacts on downsizing Y-12 should the secondary and case component fabrication/downsize at Y-12 alternative be chosen. Specifically, explanations are requested regarding the impacts on the D&D program at Y-12, the impact to future continued operation of the facilities, operating systems, and programs.

• Response: The environmental impacts resulting from downsizing Y-12 are discussed in detail in section 4.2.3 of this PEIS.

33.11

Commentor recommends that DOE have the funding mechanisms for proposed downsized Y-12 facilities in place prior to the ROD.

• Response: Funding for the downsizing of Y-12 would follow the normal Government budgetary process with a submission to Congress for this project after the ROD is issued.

34 Management--High Explosives Components

34.01

A large number of commentors believe that HE functions should remain at Pantex. The commentors note that the Draft PEIS states that Pantex must retain HE capabilities to process the inventories already onsite from dismantling. Therefore, the least expensive option is to maintain HE functions at Pantex, according to the commentors. Commentors also indicate their disagreement with the statement in the Draft PEIS that there are no advantages to siting HE at Pantex as opposed to the national laboratories. The commentors cite the capital outlay for such a transfer as being cost prohibitive and the fact that if the need arises in future for new weapons production, the commentors believe it will be critical to have the HE facilities at the weapons production/assembly site.

• Response: The HE production mission includes HE procurement, formulation, component fabrication, characterization, surveillance, disposal, and storage. As discussed in the Analysis of Stockpile Management Alternatives report, DOE's goal for the HE fabrication mission is to assure core competency maintenance while achieving cost efficiencies. At the time the Draft PEIS was issued, the HE production mission which best achieved the overall objectives was not clear, therefore DOE deferred identification of a preferred alternative for the HE production mission while further analysis was performed. Since that time, DOE has completed the analysis and the preferred alternative for the HE production mission is to downsize the production mission at Pantex. The preferred alternative for HE fabrication was developed by DOE using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. The analysis of these factors are presented in the Analysis of Stockpile Management Alternatives report, and the rationale for the preferred alternative is found in the Stockpile Management Preferred Alternatives Report. Both reports are available for public review at the DOE Public Reading Rooms near each site.

34.02

Some commentors state that the HE mission be moved from Pantex to another site. Specifically, one commentor believes that the HE mission should be brought to LANL because a synergism exists between the research and design mission and the production of HE. Another commentor believes that the A/D and HE operations currently at Pantex and HE operations at Site 300, LLNL, should be consolidated at NTS.

• Response: NTS was not considered a reasonable alternative for the HE fabrication mission for several reasons. First, unlike the A/D mission, NTS does not have existing facilities designed for HE fabrication. As a result, transfer of the HE fabrication mission to NTS would require construction of a completely new facility. Second, both LANL and LLNL have existing facilities capable of meeting the HE fabrication requirements analyzed in the PEIS. However, in determining reasonable alternatives for these missions, DOE considered that, should weapons A/D be relocated, that it would be reasonable and prudent to use existing HE fabrication facilities at LANL or LLNL, rather than constructing new facilities, which would be required at NTS. The analysis of these factors are presented in the Analysis of Stockpile Management Alternatives report, and the rationale for selecting Pantex as the preferred alternative for A/D and HE fabrication can be found in the Stockpile Management Preferred Alternatives Report. Both reports are available for public review at the DOE Public Reading Rooms near each site.

34.03

The commentor states that the HE mission is to be assigned only to facilities with existing infrastructure. The commentor notes that according to the Draft Analysis of Stockpile Management Alternatives report, LANL is currently establishing a production infrastructure for the manufacture of detonators. As late as December 1995, however, no detonators have been produced. Also, the commentor notes that according to the Activity Implementation Plan, LLNL will restructure Site 300 to meet manufacturing requirements.

• Response: Four alternatives for the HE production mission were evaluated according to three ranking criteria. One criteria is capability of production support infrastructure. The Analysis of Stockpile Management Alternatives report provides a summary of all ranking criteria scores and explains the basis for these scores. DOE sought future Complex configurations that simultaneously maintained technical competence, minimized technical risk, and minimized costs. All technologies required for the HE mission have been previously demonstrated at LANL and LLNL. Both have in the recent past produced HE components in numbers greater than and at specifications comparable to those required for future production. The LANL and LLNL formulation, synthesis, and fabrication processes would require production qualification. Establishing the production and control processes necessary for production qualification represents a risk at an R&D laboratory; however, DOE has successfully qualified laboratory processes for production applications in the past.

34.04

The commentor states that in the PEIS, four HE alternatives are proposed and discussed, but in the Draft Stockpile Management Preferred Alternatives Report, only two options are recognized--downsizing of Pantex and the two-laboratory concept.

• Response: As shown in the Stockpile Management Preferred Alternatives Report, four HE production alternatives have been analyzed and ranked: downsize at Pantex, relocate to LANL, relocate to LLNL, and the two-laboratory alternative. DOE is also required by NEPA and CEQ to describe and evaluate the environmental impacts of a No Action alternative. The PEIS does not attempt to quantify or analyze the impacts of the two-laboratory alternative because the environmental impacts at either LLNL or LANL from the two-laboratory HE production alternative would not be greater than the environmental impacts which are analyzed in the PEIS for the entire HE production mission at LANL or at LLNL singularly.

34.05

The commentor believes that the transfer of operations from Rocky Flats to the laboratories was unsuccessful and that the lessons learned from that transfer should carry weight in the decision to site HE operations.

• Response: DOE assigned several missions previously conducted at Rocky Flats to LANL--pit surveillance, pit support, beryllium technology, and joint test assembly support. The transfer of the pit surveillance mission from Rocky Flats has been successfully completed and is currently being conducted at LANL. Transfer of remaining processes are in progress. Lessons learned from the transfer of the processes from donor to the receiver sites in the Nonnuclear Consolidation Program, including those from Rocky Flats to LANL are being recorded. This information would be used to improve the future transfers of operations under the stockpile management program. The technical risk of transferring the HE mission to the laboratories was analyzed in the Analysis of Stockpile Management Alternatives report . This report determined the risk of transferring HE operations to be minimal.

34.06

The commentor questions what the operating cost for the HE fabrication mission is in the Laboratory Implementation Plan.

• Response: It is not a straightforward exercise to estimate the annual costs to operate the HE plant. DOE chose to assume that the costs of operating the HE plant at each site would be estimated as increments to the assumed site missions. Pantex was assumed to have the weapons A/D mission, and the HE costs were estimated as incremental to that mission. Likewise, LANL and LLNL were assumed to continue their R&D mission, and the HE costs were estimated as incremental to that mission. The LLNL projected incremental increase in cost for manufacturing HE components is $560,000 per year; LANL incremental cost increase was estimated at $2.3 million; and Pantex incremental cost increase was estimated at $2.25 million. Details for these cost estimates can be found in the Analysis of Stockpile Management Alternatives report which is available for public review at the DOE Public Reading Rooms near each site.

34.07

The commentor wants to know if the HE manufacturing facilities at the weapons laboratories are as new and technologically advanced as the facilities at Pantex.

• Response: The HE facilities at LANL were designed and built for production scale operations, and were in fact, operated as production facilities supplying nuclear weapons HE components for many years. LANL has continually upgraded and modernized processing equipment in these existing facilities to provide prototype HE components to meet hydrodynamic and NTS program requirements. The equipment and processes used at LANL are very similar and in some cases identical to those used at Pantex for production. The HE facilities at Pantex were built during the 1980s, and are newer than LANL or LLNL facilities. The equipment in all three facilities was procured at about the same time (sometimes on the same purchase order).
  
  Similarly, the production scenarios envisioned for LLNL are well within their current capabilities using equipment and processes that are similar if not identical to Pantex. The LLNL High Explosives Application Facility is DOE's most recently activated major HE facility and meets or exceeds all modern ES&H requirements for explosive research, development, and production support.

34.08

In regard to HE fabrication, the commentor asks if the primary work is in the development program as opposed to fabrication.

• Response: For HE fabrication there is a minimum level of effort in both the development program and in the production mission that must be achieved to maintain competence. DOE has sought to address the level of expected future production requirements, and whether this level of work is sufficient to maintain competence. There is also synergy between HE fabrication work required for the development program and for the production mission. The level of effort for either is not steady and can be cyclical. DOE has taken these factors into account in determining its preferred alternative for the HE production mission.

34.09

The commentor states that according to the ranking criteria process, the two-laboratory concept ranks significantly lower than Pantex, which itself received a rating of 100 in all categories. The commentor notes that as the Ranking Criteria Process was applied to each category throughout the Stockpile Stewardship and Management PEIS, the facility which ranked highest received the mission, but HE fabrication is the only category which seems to run contrary to that rule.

• Response: DOE sought future Complex configurations that simultaneously maintained technical competence, minimized technical risk, and minimized costs. In the case of HE fabrication, downsizing operations at Pantex or relocation to one of the weapon laboratories would be the low cost alternative. However, concerns about potential loss of competency in HE at one or both of the laboratories may make the low-cost alternative a higher technical risk alternative. While the ranking criteria process shows the two-laboratory concept lower than Pantex, the decision as to a preferred alternative is not automatic. At the time the Draft PEIS was issued, the HE production mission which best achieved the overall objectives was not clear, therefore DOE deferred identification of a preferred alternative for the HE production mission while further analysis was performed. Since that time, DOE has completed the analysis and the preferred alternative for the HE production mission is to downsize the production mission at Pantex. The preferred alternative for HE fabrication was developed by DOE using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. The analysis of these factors is presented in the Analysis of Stockpile Management Alternatives report, and the rationale for selecting the preferred alternative is found in the Stockpile Management Preferred Alternatives Report. Both reports are available for public review at the DOE Public Reading Rooms near each site.

34.10

The commentors question why 432 people are required at the weapons laboratories to manufacture explosive components when Pantex has identified about 50 people to perform the operation, and how DOE justifies this additional cost.

• Response: The numbers 432 and 50 cannot be compared. The employment at the laboratories, 200 at LANL (table 3.4.5.3-2) and 232 at LLNL (table 3.4.5.4-2) include both HE workers and various direct support workers, while the employment at Pantex, revised to 37 in the Final PEIS (table 3.4.5.2-2) includes only HE workers, since the A/D support workers would be sufficient to also cover HE fabrication. Each site's employment impacts assume that site takes on the entire HE production mission; therefore, these numbers should not be added. To bound the potential environmental impacts at each site, the PEIS estimates the number of workers that could be used in a "surge," or maximum production scenario. Because it is expected that this workload would be performed in existing facilities (in the case of Pantex they were downsized current facilities), not surprisingly the maximum potential environmental and employment impacts varied somewhat between the sites for this bounding surge case. In addition, however, each alternative was assessed for the same low and high single-shift workloads.

34.11

The commentors request the locations of proposed HE fabrication and testing facilities at LANL. One commentor refers to Summary section 5.3.7, Relocate to Los Alamos, and states that the statements that LANL R&D facilities currently possess sufficient (operational) capacity with little or no building construction/modification was not based totally on fact, as evidenced by the failure to adequately address concerns expressed in the April 22 and 23, 1996, Amarillo public meeting. In addition, the commentor states that further review of the Stockpile Management Preferred Alternatives Report and the Analysis of Stockpile Management Alternatives report verified that the DOE requirements for certification of those buildings to current standards was apparently ignored.

• Response: LANL HE fabrication process capability is already established. HE fabrication and storage functions would be supported in existing facilities at LANL TAs -9, -16, and -37. Since LANL HE facilities already exist and have sufficient capacity for stockpile management requirements, no new building construction and no significant modifications would be required. DOE requirements for certification of these buildings to current standards is an ongoing process and would continue as required. To assure that the laboratories would successfully implement HE production on the magnitude necessary to meet national security needs, the LANL formulation, synthesis, and fabrication processes would require production qualification.

34.12

The commentor refers to the LANL table 3.4.5.3-1 and states that this table contains insufficient information for analysis. The commentor states that the baseline numerical information contained in table 3.4.5.2-1 cannot be compared reasonably with "minimal" resource requirements. The commentor states that based upon simple comparison between tables 3.4.5.2-2 and 3.4.5.3-2, the missing "baseline" data should have been readily available for insertion in the table.

• Response: The tables in question display consumption requirements for the construction period and for 1 year of operations. Because the LANL HE fabrication process capability is already established, quantifying the minimal consumption requirements for construction/modification at LANL would not be useful to DOE in decisionmaking. HE fabrication and storage functions would be supported in existing facilities at LANL TAs -9, -16, and -37. Since LANL HE facilities already exist and have sufficient capacity for stockpile management requirements, no new building construction and no significant modifications would be required.

34.13

Several commentors ask when the preferred alternative for HE fabrication will be identified. One commentor states that the Stockpile Management Preferred Alternatives Report gives the impression that the decision has been made to transfer HE work to the laboratories. The commentor asks if this is true. If not, the commentor would like to know on what basis the decision on the preferred alternative for HE fabrication will be made.

• Response: Pantex, LANL, and LLNL were candidate sites for the HE fabrication mission. As discussed in the Analysis of Stockpile Management Alternatives report, DOE's goal for the HE fabrication mission is to assure core competency maintenance while achieving cost efficiencies. At the time the Draft PEIS was issued, the HE production mission which best achieved the overall objectives was not clear, therefore DOE deferred selection of a preferred alternative for the HE production mission while further analysis was performed. Since that time, DOE has completed the analysis and has determined that the preferred alternative for the HE production mission is to downsize the production mission at Pantex. The preferred alternative for HE fabrication was developed by DOE using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. The analysis of these factors are presented in the Analysis of Stockpile Management Alternatives report, and the rationale for selecting the preferred alternative is found in the Stockpile Management Preferred Alternatives Report. Both reports are available for public review at the DOE Public Reading Rooms near each site.

34.14

The commentor expresses concern about HE fabrication continuing at Pantex because of existing contamination problems from HE work. The commentor states that the first priority at Pantex should be the protection of the environment and public safety.

• Response: Pantex will continue operations in compliance with all applicable Federal, state, and local ES&H requirements, as well as all DOE-mandated standards that insure the protection of the environment and public safety.

34.15

The commentor believes it is unfair to provide the laboratories the economic benefit of taking over the Pantex HE manufacturing mission while Pantex and the citizens of Amarillo will retain the environmentally problematic mission of disposing of the replaced HE components and suffering economically by losing the environmentally cleaner manufacturing mission.

• Response: DOE's preferred alternative for the HE production mission is to downsize the production mission at Pantex. The preferred alternative for HE fabrication was developed by DOE using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. The analysis of these factors are presented in the Analysis of Stockpile Management Alternatives report, and the rationale for selecting the preferred alternative is found in the Stockpile Management Preferred Alternatives Report. Both reports are available for public review at the DOE Public Reading Rooms near each site.

34.16

The commentor points out that there is a disparity in the air emissions data being presented for sites conducting the same missions. According to the commentor, for the HE fabrication mission, Pantex, LLNL, and LANL propose to emit 413, 1,315, and 4,530 kg/yr (910, 2,897, and 9,981 lb/yr) of carbon monoxide; 122, 45, and 4,540 kg/yr (269, 99, and 10,003 lb/yr) for organics; 1,560, 349, and 22,700 kg/yr (3,437, 769, and 50,017 lb/yr) of nitrous oxides; and 0.02, 4.5, and 454 kg/yr (0.044, 9.9, and 1,000 lb/yr) of ammonia, respectively. In addition, the amount of HE powder required is different at each site. The commentor does not understand the reason for the disparity in both inputs and emissions for the same mission at different sites and wants to know where the numbers are coming from.

• Response: To bound the potential environmental impacts at each site, the PEIS estimates the workload that could be performed in a "surge," or maximum production scenario. Because it is expected that this workload would be performed in existing facilities (in the case of Pantex they were downsized current facilities), not surprisingly the maximum potential environmental impacts varied somewhat between the sites for this bounding surge case. The differences in the amounts and types of explosives shown in appendix tables G.3-2 and G.3-3 are due to the overall differences in work done by the three sites. This work includes at the laboratories both stockpile stewardship and potentially stockpile management workload in addition to reimbursable work for other customers. For Pantex, it includes potential stockpile management work plus an estimate of work for other Federal agencies. In addition, however, each alternative was assessed for the same low and high single-shift workloads.
  
  The differences in air emission numbers relate to inherent differences in the existing facilities and air emission control equipment at the three sites. Each alternative would utilize essentially the same production processes, and few of the criteria pollutant air emissions stem directly from these production processes.
  
  DOE recognized the apparent differences in these numbers between the alternatives during the development of the PEIS source data. Reviews were conducted to assure consistency and comparability by a team of technical experts with representation from each site. The numbers reflected in the PEIS reflect the consensus opinion of this intersite team.

34.17

The commentor believes that the HE fabrication mission at Pantex is the root of the excellent safety record at Pantex, and that separating the two missions at Pantex would destroy the synergistic safety benefits. The commentor expresses concern about accidental explosions that might result from A/D activities at Pantex without benefits of the safety expertise generated by the HE fabrication mission.

• Response: DOE has established procedures to ensure the safety of its workers at all sites. The preferred alternative for HE fabrication was developed by DOE using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. The analysis of these factors is presented in the Analysis of Stockpile Management Alternatives report, and the rationale for selecting the preferred alternative is found in the Stockpile Management Preferred Alternatives Report. Both reports are available for public review at the DOE Public Reading Rooms near each site.