40 Nuclear Weapons Policies

40.01

The commentors suggest that underground testing should be resumed and/or that the capability to resume nuclear testing should be maintained. Commentors state that the proposed stewardship facilities are new and unproven and are skeptical about the future safety and reliability of the Nation's stockpile without underground testing at NTS. Other commentors state that the United States is required by the National Defense Authorization Act to maintain a readiness posture, and that to be without testing capability with the possibility of unanticipated international developments would be unrealistic and perhaps foolhardy. Other commentors feel that the capability and reliability of our nuclear weapons will be greatly reduced without underground testing, and that the effects of changes or modifications to weapons can only be verified through testing.

• Response: As part of the August 1995 announcement to pursue a CTBT, the President stated that he had been assured "that we can meet the challenge of maintaining our nuclear deterrent under a Comprehensive Test Ban Treaty through a science-based stockpile stewardship program without nuclear testing." However, the President cautioned that, "while I am optimistic that the stockpile stewardship program will be successful, as President I cannot dismiss the possibility, however unlikely, that the program will fall short of its objectives." The President went on further to say that, "In the event that I were informed by the Secretary of Defense and Secretary of Energy... that a high level of confidence in the safety or reliability of a nuclear weapons type which the two Secretaries consider to be critical to our nuclear deterrent could no longer be certified, I would be prepared, in consultation with Congress, to exercise our `supreme national interests' rights under the Comprehensive Test Ban Treaty in order to conduct whatever testing might be required."
  
  Thus, it is possible--although not probable--that under a CTBT, the United States might one day exercise its "supreme national interests" rights to conduct underground nuclear testing to certify the safety and reliability of its nuclear weapons. Consequently, section 4.12 of the PEIS includes a programmatic evaluation of the environmental impacts of underground nuclear testing at NTS.

40.02

The commentors question the rationale, timing, purpose, and need for planned subcritical testing at NTS. One commentor believes that the Draft PEIS fails to consider the programmatic decision on whether to proceed with proposed subcritical hydronuclear experiments as part of the Stockpile Stewardship and Management Program and, if so, where to conduct such experiments. The commentor also believes that the proposed subcritical tests are clearly part of DOE's Stockpile Stewardship and Management Program and that there is no justification for failing to analyze the proposed subcritical tests in the Draft PEIS. Specifically, the commentors are concerned about the need for these tests since the stockpile has been certified to be safe and reliable as recently as November 1995. One commentor asks if subcritical tests are included in the NTS Site-Wide EIS. Other commentors express concern that these tests would be seen internationally as nuclear tests, and that they may affect the Russian elections and the CTBT. One commentor states that weapon configurations could result in fission yields that, while small, would nevertheless contradict the express goal of achieving a zero-yield CTBT. Another commentor states that subcritical testing is a necessary component of the stockpile mission and can only be performed at NTS. Other commentors state that the PEIS does not adequately consider or analyze these tests, that they should be included in the Final PEIS, and that the tests should be postponed if necessary for inclusion. One commentor states that these tests are necessary, but should be carried out at LANL or LLNL, not NTS. Another commentor questions whether the subcritical tests are a legitimate interim action.

• Response: DOE believes subcritical experiments do not constitute a new activity at NTS. In addition, the Lyner Complex is not a new facility. Subcritical experiments have been conducted at
• NTS over many years. Historically, operations at NTS have included tests or experiments that included both HE and special nuclear materials that were intended to produce no nuclear yield or negligible nuclear energy releases. These experiments frequently remained subcritical (i.e., they did not achieve a self-sustaining fission chain reaction). They were often performed as dedicated, stand-alone experiments. Such experiments were described, for example, as one point safety tests and equations of state tests, and, in the prior terminology, were included under the broad umbrella of nuclear testing since testing with nuclear explosive yield was the predominant activity. Some of these earlier subcritical experiments were conducted on the surface while others were conducted underground in shafts, shallow boreholes, and tunnels. However, environmental considerations resulted in a decision to conduct these experiments only underground so that radioactive materials would not be introduced into the surface environment. The environmental impacts of the surface experiments were principally due to dispersal of special nuclear materials, such as plutonium, and other materials, by the detonation of HE. Subcritical experiments were mentioned in environmental statements prepared by the predecessors of DOE in the early 1970s, as well as in the 1977 NTS EIS under the names mentioned above.
  
  DOE is considering conducting the subcritical experiments referenced by the commentor in the Lyner Complex. Initial work on what is now known as the Lyner Complex began in the late 1960s, but it was not used at that time. Further work took place in the 1980s and early 1990s to develop a complex that could be used to perform intentionally designed low-yield tests or experiments, which, among others, would have included some experiments which would be expected to remain subcritical or provide negligible energy release. The Lyner Complex was completed under the 1977 NTS EIS and was subsequently used for testing purposes. With the moratorium on nuclear testing and the anticipated CTBT, Lyner will be dedicated solely to the conduct of dynamic experiments (including subcritical experiments) and hydrodynamic tests.
  
  The term, "subcritical experiments," does not define a new form of activity at NTS. The use of the term is intended to clarify the fact that such experiments could not achieve the condition of criticality and that they would meet current and prospective U.S. commitments to the moratorium on nuclear testing and the anticipated CTBT. Although the specific term "subcritical" was not used in the previous EISs, some tests and experiments conducted over the past four decades, as well as the impacts of those tests and experiments, are substantially the same as those contemplated by the new terminology.
  
  The principal diagnostic tools that DOE currently uses to study nuclear weapons primaries are hydrodynamic tests and dynamic experiments. The PEIS identifies that DOE, under the No Action alternative, would continue to use testing facilities currently available at NTS and the national laboratories. Additionally, section 3.1.2 of the Final PEIS has been expanded to discuss the issue of subcritical testing.
  
  Note that nuclear detonation does not occur with subcritical testing. The environmental impacts of these tests are well within the previous operational impacts at NTS and are bounded by analyses performed in the NTS Site-Wide EIS as well as this PEIS. The remoteness, large size, and infrastructure at NTS make it a logical location to conduct these experiments.
  
  An analysis of subcritical tests is included in the NTS Site-Wide EIS as part of the continue current operations (No Action) alternative. The impacts which result from operation of the Lyner facility are analyzed in chapter 5, and a description of the facility is located in appendix A of the NTS Site-Wide EIS. Further Lyner Complex details are addressed in a classified appendix to the NTS Site-Wide EIS.
  
  Subcritical experiments are a long standing part of NTS's mission and DOE believes that the provisions of CEQ regulations regarding interim actions are inapplicable to a decision by DOE whether to continue conducting these experiments at NTS after completion of the NTS Site-Wide EIS. In the Stockpile Stewardship and Management PEIS, DOE is proposing ways to augment the existing nuclear weapons stockpile stewardship program for the specific purpose of accommodating the lack of underground nuclear testing, rather than reconsidering the entire stewardship program. Ongoing activities, such as the subcritical experiments at NTS, that are not affected by the decisions to be made in the Stockpile Stewardship and Management PEIS process are not interim actions under the regulations. Therefore, if DOE decides to conduct subcritical tests at NTS in the future, that decision will be made after considering the analysis contained in the NTS Site-Wide EIS, and will be documented in an ROD for that EIS.

40.03

Several commentors ask about the circumstances and people responsible for making the recommendations to resume underground nuclear testing under the "supreme national interest" clause of the CTBT. Specifically, who could make the decision to resume testing and how the decision would be implemented if the stockpile were judged to be unreliable. Commentors are specifically concerned about the pressures experienced by laboratory directors while making the certification of reliability, and what other options were available to them instead of resuming underground nuclear testing. Another commentor is concerned that the responsibility for certification of nuclear weapons rests solely in the hands of the weapons laboratories, with no outside review by unbiased parties.

• Response: Every decisionmaker has certain pressures placed upon him or her. The checks and balances designed into the national laboratory system as well as our Nation's system of government help ensure that decisions are made with the best available knowledge and that numerous viewpoints are taken into account. In announcing U.S. plans to pursue a CTBT, the President also announced a decision and coordination process which would require other military and civilian officials (including Congress), in addition to the laboratory directors, to join in any recommendation to resume underground nuclear testing.

40.04

Several commentors state that nuclear deterrence is necessary and must be maintained and that having a nuclear deterrent permitted the nonproliferation process to work and put the United States in a position to promote peace. Commentors state that our safety and national security has been based on our deterrence policy and that our technological advances, particularly those made by LANL and LLNL, led to the collapse of the Soviet Union. Other commentors state that nuclear deterrence provides for common worldwide security and that a deterrent remains necessary in light of the threats from other nations and terrorist groups.

• Response: The President has declared that the maintenance of a safe and reliable nuclear weapons stockpile will remain a cornerstone of national security policy for the foreseeable future. Changes to U.S. national security policies in the post-Cold War period have placed two significant constraints on the way DOE has traditionally accomplished its statutory nuclear mission: the United States has declared a moratorium on underground nuclear testing and is not producing new-design weapons. In August 1995, the President declared that the United States was seeking ratification of a zero-yield CTBT. Within these constraints, the proposed actions in this PEIS would enable DOE to maintain the core intellectual and technical competencies necessary to ensure the continued safety and reliability of the smaller and aging stockpile under a CTBT.

40.05

The commentors believe that DOE is assuming a nuclear war-fighting posture instead of a deterrence posture, that U.S. policy relies on violence and that this threatens the rest of the world. Other commentors state that the Stockpile Stewardship and Management Program is driven by the Nuclear Posture Review (NPR), which is based on U.S. first-strike capability, and that DOE has coupled the terms "deterrence" and "first-strike" in order to diminish the difference between the two. Another commentor states that the PEIS did not clearly state if the Stockpile Stewardship and Management Program is only intended to maintain nuclear retaliation capability, and how it would compare two strategies based on first-strike capability or retaliation against a non-nuclear adversary. Other commentors believe that the safety of the weapons is not in question and that DOE is orienting the Program towards examining the explosive yield of the weapons or towards designing new and/or improved weapons. The commentor states that the deterrence would be just as effective with a lower yield weapon. A commentor feels that DOE should develop skills of mediation to be used nationally and universally, instead of threats of weapons and military might, where everyone loses and nobody wins. Other commentors express opposition to the Program stating that we need to wage a war of peace and have a Department of Peace in this country. Another commentor wants to stop the connection between technical research and development and war and killing, stating that if our scientists would benefit from the development of a super computer then it should be placed in one of our great universities, hospitals, or at the Peace Institute and not used for new bomb making.

• Response: One benefit of science-based stockpile stewardship is to demonstrate the U.S. commitment to NPT goals; however, the U.S. nuclear posture is not the only factor that might affect whether or not other nations might develop nuclear weapons of their own. Some nations that are not declared nuclear states have the ability to develop nuclear weapons. Many of these nations rely on the U.S. nuclear deterrent for security assurance. The loss of confidence in the safety or reliability of the weapons in the U.S. stockpile could result in a corresponding loss of credibility of the U.S. nuclear deterrent and could provide an incentive to other nations to develop their own nuclear weapons programs. Also see the response to comment summary 40.60 for additional discussion of the stockpile stewardship and management alternatives and arms reduction goals.

40.06

The commentors state that nuclear weapons are not a deterrent; do not maintain peace; are unnecessary, immoral, and unethical; and should be eliminated. Commentors also state that the United States should pursue a policy of complete national and worldwide disarmament and denuclearization, and these options should be considered in the PEIS. The commentors state that these policies would strengthen our national security and our international relations, particularly with respect to our treaty obligations, and that most people worldwide favor the elimination of nuclear weapons. Commentors feel that the United States needs to lead by example and to encourage the rest of the world to follow our lead in disarmament, and that this is the only course of action that will result in nonproliferation. Other commentors state that it is this action that will result in nonproliferation. Other commentors state that the creation and/or maintenance of jobs is not an adequate excuse to continue to build nuclear weapons. One commentor cites the successful disarmament of mustard gas, nerve gas, and antipersonnel weapons as examples for the nuclear weapons industry to follow.

• Response: As a result of the START I Treaty, START II protocol, and NPR, the Nation's nuclear weapons stockpile is being significantly reduced. However, even in the post-Cold War period, international dangers remain, and nuclear deterrence will continue to be a cornerstone of U.S. national security policy for the foreseeable future. Thus, DOE's responsibilities for ensuring the safety and reliability of the U.S. nuclear weapons stockpile will also continue. Stockpile stewardship contributes positively to U.S. arms control and nonproliferation policy goals by allowing the United States to pursue ratification of a zero-yield CTBT and by providing the United States with continued confidence in its weapons to allow for further reductions and to meet its NPT Article VI obligations.

40.07

The commentors state that the proposed Stockpile Stewardship and Management Program, and specifically the proposed stewardship facilities, violate existing and proposed treaties, specifically the CTBT and NPT, and agreements on nonproliferation. The commentors believe that these facilities will lead to new and more powerful weapons designs, continued weapons testing, increased competition among nuclear weapons states, advancement of weapons technology, and provide the impetus and capability to other countries and terrorists to develop nuclear weapons. One commentor states that DOE has decoupled the terms "design" and "development," and "nonproliferation" and "disarmament" and that the United States says there are no plans to produce new weapons but that design activities continue. Commentors also state that the Program will give other nations the impression that the United States is moving forward in its nuclear weapons program (e.g., W-76 re-certification, W-88 pit rebuild, and B-61 Modification 11) and is therefore encouraging others to continue with weapons development as well. Commentors state that the long- and short-term nonproliferation impacts have not been fully addressed and analyzed in the PEIS. Other commentors point out that in their view, reestablishing pit fabrication at LANL is against nonproliferation goals and the spirit of the treaties. One commentor states that the nuclear weapons life-extension program is contrary to the NPT. Another commentor feels that the United States should lead the way internationally in START I and II, CTBT, NPT, and all future "nuclear deterrence treaties." International oversight of the stockpile stewardship program could help solve nonproliferation concerns, according to one commentor.

In addition, commentors believe that the PEIS fails to mention that the stewardship program will be used to maintain the expertise of weapons development, research, design, testing, prototyping, and certification. One commentor states that the rationale for designing new weapons to keep the scientists from getting rusty is not enough to warrant continued design of weapons. Another commentor believes the PEIS should consider a future treaty that may require DOE to disclose whether or not the stewardship program does weapon designing. The commentor believes that DOE should separate the advancement of the science of nuclear weapons from the maintenance work. The commentor also states that we do not need to alter the designs to meet new challenges from other countries.

• Response: The issue of nonproliferation is addressed in section 2.6. As stated in that section, on August 11, 1995, the President announced his commitment to seek a zero-yield CTBT. He also established several safeguards that condition U.S. entry into a CTBT. One of these safeguards is the conduct of science-based stewardship, including the conduct of experimental programs. This safeguard would enable the United States to enter into such a treaty while maintaining a safe and reliable nuclear weapons stockpile consistent with U.S. national security policies.
  
  One benefit of science-based stockpile stewardship is to demonstrate U.S. commitment to NPT goals; however, the U.S. nuclear posture is not the only factor that might affect whether or not other nations might develop nuclear weapons of their own. Some nations that are not declared nuclear states have the ability to develop nuclear weapons. Many of these nations rely on the U.S. nuclear deterrent for security assurance. The loss of confidence in the safety or reliability of the weapons in the U.S. stockpile could result in a corresponding loss of credibility of the U.S. nuclear deterrent and could provide an incentive to other nations to develop their own nuclear weapons programs.
  
  The experimental testing program would continue to be used to assess the safety and reliability of the nuclear weapons in the remaining stockpile. Much of this testing is classified and could not lead to proliferation without a breach of security. Use of classified data from past U.S. nuclear tests is also a vital part of the overall process for validation of new experimental data. Most of the component technology used for the proposed enhanced experimental capability is unclassified and is available in open literature, and many other nations have developed a considerable capability.
  
  Proliferation drivers for other states, such as international competition or the desire to deter conventional armed forces, would remain unchanged regardless of whether or not DOE implemented the proposed action analyzed in the PEIS. In the NPT, the parties agree not to transfer nuclear weapons or other devices, or control over them, and not to assist, encourage, or induce nonnuclear states to acquire nuclear weapons. However, the treaty does not mandate stockpile reductions by nuclear states, and it does not address actions of nuclear states in maintaining their stockpiles. Section 3.1.2 of the Final PEIS has been expanded to address these issues. As explained in that section, the national security policy framework discussed in this PEIS seeks a new balance between U.S. arms control and nonproliferation objectives and U.S. national security requirements for nuclear deterrence while pursuing these objectives (section 2.2). In addition, a discussion is provided on some of the more difficult issues that must be considered in determining the balance, including a discussion of experimental capability (section 2.6). In particular, the issue of nonproliferation and the proposed NIF was studied in detail. The NIF and the Issues of Nonproliferation Draft Study, prepared by the DOE Office of Arms Control and Nonproliferation, has been the subject of extensive public involvement, interagency review, and review by outside experts. The study concluded that the technical proliferation concerns of NIF are manageable and can therefore be made acceptable and that NIF can contribute positively to U.S. arms control and nonproliferation policy goals (appendix section I.2.1 of Volume III). NIF is a proliferation concern because of its broader scientific applications and expected frequent use by researchers worldwide and, like the other proposed enhanced experimental facilities, because of its possible relevance to the development of new weapon designs. However, the development of new weapon designs requires integrated testing. None of the proposed facilities, either alone or together, could perform such integrated testing of new concepts and, therefore, cannot replace nuclear testing for the development of new weapon designs. The national security policy framework and the technical issues that drive the proposed action for enhanced experimental capability remain the same.
  
  DOE is directed to maintain nuclear weapon capability, including the capability to design, develop, produce, and certify new warheads. In addition, maintenance of the capability to certify weapon safety and reliability provides a limited inherent capability to design and develop new weapons. However, no new-design nuclear weapon production has been directed. DOE has not advanced a rationale of new weapon design "to keep scientists from getting rusty." Instead, DOE has advanced a comprehensive program of stockpile stewardship and management which maintains essential capabilities for stockpile safety and reliability while meeting other legal and policy directives.
  
  Regarding the comment on the Life Extension Program, the Nation is no longer developing new-design weapons to replace existing weapons. Consequently, weapons' lifetimes are expected to extend beyond their original design goal of about 20 years. In accordance with our international treaty obligations, the Nation's nuclear weapons stockpile is being significantly reduced, and the Nuclear Weapons Stockpile Memorandum (NWSM) accounts for these reductions. The Life Extension Program is a term used to describe the planning activities which ensure that the nuclear weapons remaining in the stockpile will continue to be safe and reliable. The Life Extension Program is consistent with the NWSM and our international treaty obligations.
  
  Regarding comments that enhanced experimental capabilities are directed more at the capability to design new weapons in the absence of nuclear testing than at maintaining the safety and reliability of the existing stockpile, this PEIS explains why these capabilities are needed to maintain the safety and reliability of a smaller, aging stockpile in the absence of nuclear testing (chapter 2). The existing U.S. stockpile is highly engineered and technically sophisticated in its design for safety, reliability, and performance. The stewardship capabilities required to make technical judgments about the existing stockpile are likewise technically sophisticated; therefore, it would be unreasonable to say that these stewardship capabilities could not be applied to the design of new weapons, albeit with less confidence than if the weapons could be nuclear tested. The development of new weapon designs requires integrated nuclear testing such as occurs in nuclear explosive tests. Short of nuclear testing, no single stockpile stewardship activity, nor any combination of activities, could confirm that a new-design weapon would work. In fact, a key effect of a zero-yield CTBT would be to prevent the confident development of new-design weapons. National security policy requires DOE to maintain the capability to design and develop new weapons, and it will be a national security policy decision to use or not use that capability. Choosing not to use enhanced experimental capability for new weapon designs would not change the technical issues for the existing stockpile and, therefore, the stewardship alternatives would not change.
• The issue of new-design weapons is separate from DOE's need to perform modifications to existing weapons that require research, design, development, and testing. The phrase used in this PEIS, "without the development and production of new-design weapons," is meant to convey the fact that the historical continuous cycle of large-scale development and production of new weapons designs replacing older weapon designs has been halted. For example, during the 1980s, about a dozen new-design weapons were in full-scale development or production. Over the decade, production of new-design weapons replaced dismantled weapons nearly one for one. Today, only modifications to parts of existing weapons are being performed or planned; dismantlement has continued. This results in a smaller aging stockpile that must be assessed and certified without nuclear testing. This is now the primary focus of the stewardship program.

40.08

Some commentors believe that there was no willful collusion among laboratories to further their weapons complex activities; however, the commentors question the ability of the proposed plan to get the job done. A number of commentors believe that political and laboratory interests were influencing the Stockpile Stewardship and Management Program plan and alternatives and that the focus should be on national security and not politics. Commentors state that the laboratory scientists and contractors responsible for developing the program were using "inside" and classified knowledge and influence to advise decisionmakers on furthering their weapons program activities while reducing the manufacturing mission at production plants, and that this could have detrimental long-term effects. A commentor states that the PEIS attempts to justify the stewardship facilities which will primarily benefit the western laboratories, which already provide redundant capabilities. Another commentor refers to the statement made by Dr. Smith to the Armed Forces Subcommittee that, "Today, we do not have the capability to manufacture replacements for warheads that comprise our existing stockpile," and questions why DOE was proposing to slash production capabilities while building up basic programs at the weapon laboratories. Other commentors believe that there were others, such as retired scientists and experts, who should be involved in the study and that the focus on the laboratories and their input was a mistake.

• Response: Production and laboratory functions are different, but the difference is reduced as the size of the production requirements becomes smaller. The first atomic weapons were not only designed but also constructed at the weapons laboratories. The laboratories have always had the capability for small lot production principally in order to test out designers' theories. In some respects, this could be considered an advantage by increasing the synergism between the two activities. Based on the environmental, cost, and technical analyses that have been performed, the preferred alternative is to downsize the stockpile management functions at ORR, KCP, and Pantex, and not transfer them to the laboratories and NTS.
  
  In the PEIS preferred alternative, the only "production capability" which is being considered for one of the national weapons laboratories is the reestablishment of pit fabrication. This function does not presently exist within the Complex and has not existed for some time due to the 1991 shutdown and subsequent closing of the Rocky Flats Plant. Two sites were considered as alternatives for the pit fabrication mission: LANL, which already has an active program involving both fabrication and recovery of plutonium and has fabricated pits for nuclear explosive testing, and SRS, which has separated and produced plutonium metal from reactor targets and has recovered plutonium from scrap materials. Analysis discussed in the Analysis of Stockpile Management Alternatives report shows that the LANL alternative is lower in cost and has less technical risk than the SRS alternative. Technical risk is greater for the SRS alternative because LANL has recent experience in providing pits for nuclear explosive testing, whereas SRS has no experience with the kind of capabilities required for precision nuclear component manufacturing. Additionally, the LANL capability could be in place two years earlier than the SRS capability. The Analysis of Stockpile Management Alternatives report is available for public review at the DOE Public Reading Rooms near each site.
  
  It is true that projected needs may actually turn out to be higher or lower than the actual needs. This is one reason why the downsize-in-place alternative is the preferred option for most stockpile management missions. The proposed action for stockpile management would downsize facilities over a number of years, but this action can be reversed if necessary.
  
  In the event science-based stewardship proposals could not assure the continued safety and reliability of the nuclear weapons stockpile, the resumption of underground testing at NTS would be considered. On August 11, 1995, the President stated that if he was informed by the Secretaries of Defense and Energy that a high level of confidence in the safety or reliability of a nuclear weapons type considered critical to the nuclear deterrent could no longer be certified that he would be prepared, in consultation with Congress, to exercise our "supreme national interests" rights under the CTBT to conduct whatever testing might be required.
  
  Chapter 2 of the PEIS discusses the national security policy considerations and the role they play in defining the purpose of and need for the Stockpile Stewardship and Management Program. DOE participates regularly in Congressional hearings on defense issues in which the stockpile stewardship and management issues are discussed. Congress determines how funds are allocated, and DOE spends monies consistent with Congressional direction. Therefore, Congress ultimately determines whether the preferred alternatives of the program will be implemented.
  
  The majority of the U.S. core competencies and capabilities in nuclear weapons reside at the weapons laboratories. Proposing to locate new stewardship facilities at the weapons laboratories and NTS would expand existing facilities at sites with an experienced knowledge base and infrastructure and would help maintain the core intellectual and technical competencies of the weapons laboratories. Proposing to locate stewardship facilities at sites without the knowledge base and infrastructure would be counterproductive to the development of science-based stockpile stewardship.

40.09

One commentor refers to an article in the New York Times in February that stated DOE was having trouble verifying that sources of weapon grade materials in Russia were actually coming from the dismantlement of weapons. The commentor suggests that DOE not only look at downsizing, but look at what they are going to do in terms of verifying sources of weapons grade materials in Russia.

• Response: The PEIS does not address actions to secure and dispose of excess fissile materials. A major objective of the programmatic alternatives addressed in the Storage and Disposition Draft PEIS, however, is to demonstrate and encourage bilateral actions on both U.S. and Russian weapons grade plutonium. The commentor is referred to the purpose and need in the Storage and Disposition Draft PEIS for a more complete discussion of this subject.

40.10

The commentor would like DOE to consider site location (proximity to population centers) in the decisionmaking process and urges DOE to perform their missions somewhere else.

• Response: An indepth analysis was conducted to identify the potential environmental impacts associated with the reasonable alternatives. This analysis included proximity to population centers, along with many other factors so that absolute and comparative impact analyses can be made. Specifically, chapter 4 utilizes proximity to population centers in calculating both normal operational exposures and exposures resulting from accident scenarios for each of the alternatives considered.

40.11

Several commentors express concern about the optimism of world peace in the future and that we are not protecting the option that the world might revert to a more hostile place. Commentors state that the laboratories need to maintain a complete understanding of nuclear weapons, particularly in light of the CTBT. Commentors would like the PEIS to consider the possibility of nonratification of START II and noncompliance with the CTBT and discuss the possibility that we may need stockpile levels higher than START I. Other commentors note that even if the United States and Russia honor nonproliferation agreements other nations or groups may not and that the United States should prepare for this eventuality. Another commentor states that the Stockpile Stewardship and Management Program fails to meet its objective of protecting the Nation's ability to respond to changing national security needs.

• Response: The base case analyzed in the PEIS assumes a START II-sized stockpile. The PEIS also analyzes a higher case, which represents a START I-sized stockpile. DOE cannot speculate about the pace of Russian nuclear weapon dismantlement. However, by structuring the Stockpile Stewardship and Management Program consistent with the DOD NPR and associated PDDs, DOE has built flexibility into the Program to respond by maintaining at START I stockpile levels (which Russia has ratified) or making faster and deeper stockpile reductions in response to further arms reduction agreements.
  
  DOE continues to carefully evaluate the size of the weapons complex necessary to support projected stockpile and national security needs. It is true that projected needs may actually turn out to be higher or lower than the assumed needs. This is one reason why the downsize-in-place alternative is the preferred option for most stockpile management missions. The preferred alternatives for stockpile management would downsize facilities over the coming years, but this action can be reversed if necessary. If DOE were to transfer stockpile management missions from a site, those facilities would be less amenable to rapid expansion. Therefore, the downsize-in-place option gives DOE the most flexibility in the next several years to react to changing world events should the need arise.

40.12

Commentors state that the money spent on nuclear weapons and the Stockpile Stewardship and Management Program should be spent on other more needy social programs, and that the jobs created are not worth the negative ramifications of the Program. One commentor believes that enormous amounts of taxpayer money are being wasted on militarily unusable weapons. Other commentors believe that the money should be spent on more useful programs such as medical care, day care, education, feeding the hungry, housing, infrastructure, conservation, renewable energy, and environmental cleanup. Another commentor feels the United States should invest in peace, trust, and equality. Commentors also believe that the Stockpile Stewardship and Management Program is a pork barrel project for the nuclear military industrial complex and the corporations that serve the complex. A commentor also states that national security is really about having a well-educated, nonviolent, clean, and safe community, and not nuclear weapons. Other commentors ask why the public should feel comfortable with a plan that is very costly and gives us less, not more, nuclear deterrent.

• Response: Since the end of the Cold War, the DOE nuclear weapons program budget has been reduced significantly from its Cold War level. The Stockpile Stewardship and Management Program proposes further facility downsizing to optimize U.S. capabilities to meet future reduced stockpile levels. DOE proposes to the Congress a level of funding each year which meets Administration and Congressional policy directions. DOE is not in a position to make the difficult tradeoffs that may be required between alternative Federal programs.

40.13

Many commentors question the Stockpile Stewardship and Management Program costs and request clarification and more discussion of the details and assumptions used in the cost analysis. Several commentors want to see the cost analysis presented in the PEIS. Specific issues expressed by the commentors include the request for more information on D&D costs, life-cycle costs, transportation costs of moving pits, site transition costs, enhanced experimental program costs, training costs of new workers, remediation and cleanup costs, and program cumulative and annual costs.

Several commentors, concerned with the cost of the stockpile stewardship facilities, ask if current facilities could be used since millions of dollars have been spent on maintaining these capabilities at the Complex sites. Other commentors state that there may be more cost-efficient ways of achieving stockpile stewardship and management goals, such as "piggybacking" onto the current sites rather than transferring these activities elsewhere. One commentor also asks what is the annual cost of the proposed Stockpile Stewardship and Management Program for the next decade and how does this cost compare to the cost of a conventional surveillance program, such as the one that has been used successfully for the last 50 years. Commentors also express concern that with the current cutbacks in the Federal budget, spending money on new facilities is counterproductive. One commentor asks how much money will be saved by rightsizing the weapons complex as proposed. Another commentor states that the cost analysis was faulty in showing the downsizing of Pantex was more cost-effective than relocating the A/D and HE missions to NTS.

• Response: The PEIS provides documentation on the potential environmental impacts associated with the reasonable alternatives. Cost is one of the factors considered in developing the alternatives and identifying the preferred alternatives. Two separate reports have been prepared, the Analysis of Stockpile Management Alternatives report , and the Stockpile Management Preferred Alternatives Report which outline the costs of the various alternatives and the role costs play in the rationale for selecting the preferred alternatives. These documents are available for public review at the DOE Public Reading Rooms located near each site.
  
  The downsize-in-place alternatives were chosen for several reasons including the availability of a trained workforce, existing mission site infrastructures, the ability to expand capabilities in the event of a change in world events, as well as other factors. Clearly cost is an important factor, not only the cost of D&D of surplus facilities but the costs of constructing new facilities and their eventual D&D must also be considered as well.
  
  The cost analysis that DOE has performed to address alternative sites for accomplishment of the stockpile management missions has been performed with participation from all weapons complex sites. To assure peer review of cost estimates, each site was given the opportunity to review and critique the cost estimates provided by the competing sites. In addition, DOE commissioned an independent validation of the cost estimates. Relocation of the HE mission from Pantex to NTS was not considered a reasonable alternative and was not addressed in the PEIS.
  
  In the No Action alternative, the PEIS analyzes the alternative of relying on existing facilities and capabilities to perform the stockpile stewardship mission. However, as explained in section 3.1.4, relying on existing facilities would not ensure DOE's ability to maintain core competencies in nuclear weapons in the long-term while also maintaining a safe and reliable, smaller, aging, U.S. stockpile. Thus, enhanced experimental facilities are proposed and evaluated in the PEIS.

40.14

Commentors state that underground testing should cease, the capability to resume testing should not be maintained, and the NTS testing area should be closed. Commentors state that there is no technological justification for testing, that closing the test site would demonstrate U.S. resolve in ending its weapons programs, and that it would be more fiscally responsible to stop testing. Other commentors state that underground testing contaminates the land and produces more nuclear waste. One commentor compares the Stockpile Stewardship and Management Program to the Safeguard C program, which maintained atmospheric testing readiness but was discontinued when Congress learned of its costs. Another commentor questions the need for funding NTS at such an enormous cost.

• Response: The United States has ceased underground nuclear testing and is pursuing a CTBT. The President also stated that he had been assured "that we can meet the challenge of maintaining our nuclear deterrent under a Comprehensive Test Ban Treaty through a science-based stockpile stewardship program without nuclear testing." However, the President cautioned that, "while I am optimistic that the stockpile stewardship program will be successful, as President I cannot dismiss the possibility, however unlikely, that the program will fall short of its objectives." The President went on further to say that, "In the event that I were informed by the Secretary of Defense and Secretary of Energy... that a high level of confidence in the safety or reliability of a nuclear weapons type which the two Secretaries consider to be critical to our nuclear deterrent could no longer be certified, I would be prepared, in consultation with Congress, to exercise our `supreme national interests' rights under the Comprehensive Test Ban Treaty in order to conduct whatever testing might be required."
  
  Thus, it is possible--although not probable--that under a CTBT, the United States might one day exercise its "supreme national interests" rights to conduct underground nuclear testing to certify the safety and reliability of its nuclear weapons. Consequently, section 4.12 of the PEIS includes a programmatic evaluation of the environmental impacts of underground nuclear testing at NTS.

40.15

Several commentors state that DOE should not spend funds to continue the production and maintenance of nuclear weapons, but instead should divert the funds and technical expertise to developing methods of neutralizing radioactive waste and to clean up from past activities. Commentors state that legacy waste from past weapons complex activities should be cleaned up first (e.g., the Chemistry and Metallurgy Research building at LANL) before any new projects or programs are started and additional wastes are created. One commentor believes that classification issues are hindering cleanup efforts. Another commentor states that contamination problems at NTS should have been addressed earlier in the process before the Draft PEIS was prepared. Commentors are concerned about the availability of funds for proposed cleanup of excess facilities once turned over to Environmental Management for disposition. One commentor states that the Nation could only afford to maintain a minimal stockpile since we are faced with the immense cost of cleaning up the environmental problems caused by the nuclear weapons industry.

• Response: DOE has a program to decontaminate and make available for other uses its excess facilities. The budget for this activity has increased significantly since the end of the Cold War. DOE has made every effort to prioritize the cleanup of these excess facilities based on risk. Therefore, as the commentor alludes, some low risk facilities may wait a significant time period for decontamination because the higher risk facilities are addressed first. However, DOE has demonstrated a commitment to bring excess facilities to a safe shutdown condition awaiting decontamination, and to maintain these excess facilities in a safe condition until decontamination can proceed. DOE is committed to both the cleanup of its excess facilities, but also to maintain a nuclear weapons stockpile to meet national policy directives.
  
  As stated in section 3.1.1, Planning Assumptions and Basis for Analysis, DOE would emphasize compliance with applicable laws and regulations and accepted practices regarding industrial and weapons safety, safeguarding the health of workers and the general public, protecting the environment, and ensuring the security of nuclear materials, weapons, and weapons components. DOE would also minimize the use of hazardous materials and the number and volume of waste streams consistent with programmatic needs through active pollution prevention programs and waste minimization. The Chemistry and Metallurgy Research building at LANL is an analytical chemistry laboratory that has been in continuous use since 1952. See the response to comment summary 40.90 for further discussion on the Chemistry and Metallurgy Research building.
  
  The LLW disposal facility of NTS has been designed, constructed, and managed in such a way so as to handle safely the materials disposed of in this facility. This facility was sited due to the remoteness of NTS, the depth of the groundwater, and other factors which contribute to assuring the disposal of these materials can be conducted in a safe manner.

40.16

The commentor recognizes the significance of downsizing and wants to know if the PEIS discusses a transition funding similar to that at the Mound Plant (e.g., reuse of plants, refitting, and revised missions that could possibly give futures to some displaced workers).

• Response: This is a programmatic document and, as such, does not address detailed site-specific transition planning. In the event that a decision is made to adopt the preferred alternative, further site-specific review would take place. When DOE closes a facility, a transition plan is developed, detailing the cleanup plans, disposition of equipment, and ultimate disposition of the land. There is an established process for including the adjacent communities in this process and DOE's Office of Economic Assistance has grants and other support services to assist in the retraining and out-placement of all adversely affected employees.
  
  It is DOE policy to reassign employees to new missions whenever possible. As stated in sections 4.2.3.8, 4.4.3.8, and 4.5.3.8., the DOE Office of Worker and Community Transition would
• oversee the workforce restructuring plans for ORR, KCP, and Pantex. This plan would be developed in conjunction with the affected communities, local governments, and elected officials. Factors considered in these plans would include additional professional and vocational training at local schools during the transition period; academic and vocational counseling; help in preparing resumes and preparing for job interviews, financial planning, and job searching techniques; coordination with local businesses and economic development agencies to identify available jobs; and means of informing the business community of skilled personnel in the labor market.

40.17

The commentors raise concerns that the PEIS ignores the significant body of Congressional hearings and testimony that science-based stewardship is not guaranteed to work, or that if it works it will not be ready for at least another 10 years.

• Response: The purpose of the PEIS is to evaluate reasonable alternatives for the future weapons complex in order that we may determine how best to assure the continued safety and reliability of the nuclear weapons stockpile in the absence of underground nuclear testing. Science-based stewardship is the alternative to underground nuclear testing. While DOE recognizes that there is an inherent risk in any surrogate for underground nuclear testing, we are confident that the science-based stewardship program can be successful. Nonetheless, because there can be no absolute guarantee of complete success in the development of enhanced experimental and computational capabilities, the United States will maintain the capability to conduct underground nuclear tests under a "supreme national interest" provision in the anticipated CTBT.

40.18

The commentor states that DOE has focused almost exclusively on preserving the capabilities and core competencies of the national laboratories, while paying little attention to the production plants. The commentor also states that the PEIS does not deal adequately with the production capacity that will be needed to maintain the stockpile over the next 10 or more years, and states that the entire PEIS analysis is based on optimistic assumptions about future arms control agreements.

• Response: The preferred alternatives described in the PEIS would preserve the critical capacity and unique assets that exist in DOE's production plants. Although there would be downsizing of the production plants commensurate with a downsized stockpile, none of the production plants would be closed. The PEIS addresses plant operations to support a range of stockpile sizes consistent with DOD plans, as reflected in the NPR and the NWSM. A "No Action" alternative is also addressed which essentially preserves the status quo (no downsizing of facility infrastructure).
  
  DOE does not believe that the preferred alternative of downsizing reflects undue optimism about future arms control agreements. The stockpile has already been significantly reduced through dismantlement. Post-Cold War dismantlement to the START I-sized stockpile is already more than 70 percent complete and the remainder is scheduled to be completed within a few years. Regarding the production capacity cases analyzed, they reflect our best estimates based on analysis of historical stockpile problems and the current status of the weapons expected to remain in the future stockpile. The technical and cost analyses for production capability and capacity alternatives were published in two draft reports released in support of the Draft PEIS: the Stockpile Management Preferred Alternatives Report; and the Analysis of Stockpile Management Alternatives report, both dated February 1996. These reports will be released in final form to support the Final PEIS. Our analysis indicates that downsizing, which would occur over a protracted period of time, is the most cost-effective solution, involves the least technical risk, and affords the Nation the most flexible strategy in the event that national security policies change or future stockpile problems are greater than we anticipate.

40.19

Several commentors question the need for new pit manufacturing citing concerns of advancing new nuclear weapons design (e.g., mini nukes) and increasing the pit stockpile when plenty of pits are already available for reuse in weapons. Other commentors express their opposition to pit manufacturing activities at LANL. Another commentor questions the workload associated with the pit fabrication options.

• Response: Because of the small demand for the fabrication of replacement plutonium pits over the next 10 or more years, DOE did not propose a new pit fabrication facility with a capacity equivalent to the capacities required for other portions of the nuclear weapons production complex. However, limited fabrication of new replacement pits would be required to maintain capability and to replace pits lost during weapon surveillance. Section 3.6 discusses DOE's future plans should a life-limiting phenomenon be found in stockpile pits and a larger pit fabrication capacity be required.
  
  The No Action alternative discussed in section 3.4.3.1 would maintain only a limited plutonium R&D component fabrication capability at LANL and a less extensive capability at LLNL, and it would not provide DOE with sufficient pit fabrication capability to meet the requirements stated in section 3.1. DOE does not consider it prudent to pursue an alternative which would prevent it from fulfilling its national security mission. Additionally, DOE is under the direction of the President and Congress, through PDDs and the National Defense Authorization Act of 1994, to support the maintenance of a safe and reliable nuclear weapons stockpile, and to maintain the core intellectual and technical competence of the United States in nuclear weapons. This includes competencies in research, design, development, testing, reliability assessment, certification, manufacturing, and surveillance capabilities. The preferred alternative for the pit fabrication mission is to reestablish production capability with a limited capacity at LANL. The preferred alternatives were developed by DOE using data and studies on such factors as cost, technical feasibility, technical risk and schedule, ES&H, and national security. The Analysis of Stockpile Management Alternatives report which contains the analysis of these factors is available for public review at the DOE Public Reading Rooms near each site. To bound the potential environmental impacts at each site, the PEIS estimates are based on "surge" or maximum production scenario. Because it is expected that this workload would be performed in existing facilities that would be modified to perform pit fabrication, it is not surprising that the maximum outputs and the maximum potential environmental impacts varied somewhat between LANL and SRS for this bounding surge case. In addition, however, each alternative was assessed for the same low case and high case single-shift workloads.

40.20

The commentor expresses the view that Pantex should continue to store plutonium, and should be the preferred site for any disposition options and related functions.

• Response: These decisions will not be made until the Storage and Disposition Final PEIS is completed. In that PEIS, Pantex is being considered for the long-term storage of strategic and surplus fissile materials, and as a disposition site for surplus fissile materials. Although no preferred alternatives have been identified for the Fissile Materials Disposition Program, preferred alternatives will be identified in the Final PEIS, expected before the end of 1996. Pantex has many valuable attributes which will be considered in that analysis.

40.21

The commentors express both praise and criticism of DOE's safety and environmental monitoring programs and protection, and insist that all future DOE missions must be conducted in a safe and environmentally sound manner. Commentors believe that moving missions would potentially lead to a decline in worker health and safety protection and an increased threat to the environment at the mission's new site. Other commentors state that classification and the shift of safety responsibility from workers to management has weakened the DOE safety program at some sites, and that worker knowledge and training were necessary for safe operations. One commentor states that he did not trust DOE when it came to ES&H monitoring and felt that workers' fear of losing their jobs prevented people from raising safety concerns. The commentor believes that the current system within DOE to shelter whistleblowers is not effective in protecting the whistleblowers. The commentor believes that the people at LANL were not laid off because they were whistleblowers. One commentor believes that if stockpile stewardship and management work came to LANL, employees with jobs related to health and safety would be hindered from truth-telling from fear of management pressure or job loss, since current management implements a subjective and undemocratic system of employee evaluation and control.

A commentor refers to the Tiger Team findings and tracking program at LANL as an example of DOE's lack of commitment to reducing environment, health and safety issues. Another commentor questions DOE's stated priority on safety in light of their cancellation of the NEWNET air monitoring system. Other commentors state that DOE has not conducted or released enough studies on worker and public health effects and on past accidents and their results. A commentor states that the recent forklift accident, the fatality due to an electrocution and the root causes need to be identified in the Accident History section of the PEIS. The commentor also wants an analysis of the effect of the recent reduction-in-force on the occupational safety at LANL. Another commentor feels the workers at LANL are eminently competent to monitor their own safety and environmental concerns.

• Response: As stated in section 3.1.1, Planning Assumptions and Basis for Analysis, DOE would emphasize compliance with all applicable laws and regulations and accepted practices regarding industrial and weapons safety, safeguarding the health of workers and the general public, protecting the environment, and ensuring the security of nuclear materials, weapons, and weapons components. DOE would also minimize the use of hazardous materials and the number and volume of waste streams consistent with programmatic needs through active pollution prevention programs and waste minimization. The specific stockpile management assumptions are described in section 3.1.1.1, and the stockpile stewardship assumptions are described in section 3.1.1.2. It is unlikely that a change in environmental regulation would result in a modification to the Stockpile Stewardship and Management Program itself; however, changes to the environmental regulatory setting may necessitate the implementation of additional engineering and administrative controls to meet new standards.
  
  The overall subject of "whistleblower protection" is one which DOE has given extremely high priority. DOE is pursuing an open environment at its facilities so that employees can raise concerns without fear; improvement in this difficult area is always possible. DOE believes it is essential that workers at its facilities have the opportunity to raise safety and environmental concerns without fear of retribution. DOE has programs at all of its sites to provide anonymity to workers who wish to raise such concerns. All concerns are investigated thoroughly and necessary corrective actions are directed.
  
  AIRNET and NEWNET are the two air quality monitoring systems employed by LANL. AIRNET data are reported to the public annually in the Environmental Surveillance Report, and NEWNET data are publicly accessible over the Internet computer links as they are collected. Neither AIRNET nor NEWNET stations went offline during the Dome Fire. Over the past 8 months, LANL has eliminated several AIRNET stations that are no longer needed or were redundant with other sampling as part of an overall effort to streamline the sampling networks to ensure their effectiveness. Just prior to the outbreak of the Dome Fire, LANL reprogrammed four of five monitoring stations in the southern part of laboratory to transmit data at longer intervals in order to determine long-clock stability, but returned to the original transmittal intervals during the Dome Fire to provide better coverage.
  
  There have been several serious accidents at LANL within the past 18 months. Both DOE and the University of California conducted investigations and developed recommendations to improve safety awareness at LANL (see Type A Accident Investigation Report, DOE, March 1996, and Final Report of the University of California Fact Finding Team Concerning Recent Accidents at the Los Alamos National Laboratory, University of California, March 19, 1996). In March 1996, the senior vice president of the University of California directed LANL to implement the University's recommendation, including developing an integrated safety management program. There is no indication that the recent downsizing of LANL staff has had any detrimental effect on occupational safety.

40.22

The commentors ask why information from the Sandia Stockpile Study was left out of the PEIS. In particular, information stating that weapons defects decrease over time and the statement that nuclear weapons do not age, do not wear out, and are not allowed to degrade. Commentors are of the opinion that historical defect rates exceed the expected future stockpile defects and that the proposed Stockpile Stewardship and Management Program is not required. One commentor asks about the age of the weapons in the stockpile and how long they will be maintained. Another commentor asks about the design life of the remaining stockpile weapons and indicates that an enhanced surveillance program above that currently proposed by DOE may be needed. Despite requests in scoping comments, the commentor states that the Draft PEIS does not analyze whether individual stockpile stewardship facilities are needed to diagnose safety problems, on the one hand, and reliability problems on the other.

• Response: Chapter 2 of the PEIS discusses aging impacts. The information in section 2.3 is based on the latest data published in the tri-laboratory study. Section 2.3.3 of the PEIS, Historical Stockpile Data, provides a summary of stockpile defect and aging data that were used as an input for sizing the Stockpile Stewardship and Management Program. This information was extracted from an unclassified report, Stockpile Surveillance: Past and Future, dated September 1995.
  
  As explained in that section, continuous evaluation of the safety and reliability of the stockpile has always been a major part of the U.S. nuclear weapons program. Since the introduction of sealed-pit weapons more than 35 years ago, a formal surveillance program of nonnuclear laboratory and flight testing has been in existence. More than 13,800 weapons have been evaluated in this program. The Stockpile Evaluation Program, with its reliance on functional testing, has provided information that can be used in the statistical analysis of nonnuclear component and subsystem reliability. This program has detected about 75 percent of all problems ultimately detected, and it has been the principal mechanism for discovering defects and initiating subsequent repairs and replacements. However, not all aspects of a nuclear weapon can be statistically assessed this way. Weapons R&D at the three weapons laboratories and nuclear testing have played an important part in assessing the stockpile and in making corrective changes when needed.
  
  Nuclear tests have been a critical part of the nuclear weapons program. They have contributed to a broad range of activities from development of new weapons to stockpile confidence tests to tests that either identified a concern or showed that remedial actions were not needed. However, the United States has not conducted a sufficient number of nuclear tests for any one weapon type to provide a statistical basis of reliability assessment for the nuclear explosive package. This is why the word "performance" instead of "reliability" is used when discussing a nuclear explosive package.
  
  Although nuclear tests were never a part of the formal Stockpile Evaluation Program, they played an important role in maintaining the safety and performance of the weapons in the stockpile. Every advantage was taken of developmental nuclear tests to eliminate potential nuclear explosive problems. In some cases, nuclear testing during development of one weapon type uncovered a problem that was pertinent to a previous design already in the stockpile, which then had to be corrected. Nuclear tests identified certain classes of stockpile problems not observable in the surveillance program. Nuclear tests have been used to resolve issues raised by the Stockpile Evaluation Program, such as whether a particular corrosion problem affected the nuclear yield of a weapon. Nuclear tests have also been used to verify the efficacy of design changes. For example, the adequacy of certain mechanical safing techniques was determined through nuclear testing. In the case of a catastrophic defect, tests have been used to certify totally new designs to replace an existing design. Finally, in some cases, nuclear testing proved that a potential problem did not exist.
  
  Beginning in the late 1970s, DOD and DOE agreed to a formal series of underground nuclear tests of weapons withdrawn from the stockpile. These tests were referred to as Stockpile Confidence Tests. They differed from developmental nuclear tests because the weapons were from actual production, had experienced stockpile conditions, and had minimal changes made to either nuclear or nonnuclear components prior to the test. There have been 17 such confidence tests since 1972, including 4 tests in the early 1970s that were not officially designated as Stockpile Confidence Tests. Confidence tests have been conducted for each of the weapon types expected to remain in the stockpile well into the next century.
  
  In addition to the 17 confidence tests, at least 51 additional underground nuclear tests have been conducted since 1972 involving nuclear components from the stockpile, components from the actual weapon production line, or components built according to stockpile design specifications and tested after system deployment. The objectives of these tests included weapon effects, weapons R&D, confirmation of a fix, or investigation of safety or performance concerns. Three of these tests (in addition to one confidence test) revealed or confirmed a problem that required corrective action. Four tests (in addition to three confidence tests) confirmed a fix to an identified problem. Additionally, five tests were performed to investigate safety concerns affecting three different weapon types. These five tests verified that a problem did not exist.
  
  The confidence in the performance of the nuclear explosive package has been based on underground nuclear test data, aboveground experiments, computer simulations, surveillance data, and technical judgment. The directors of the three weapons laboratories must certify the nuclear performance of the weapons designed by their laboratory. In a future without additional nuclear testing, the core capabilities of the weapons laboratories that were developed to eliminate potential problems in new weapon designs must now be employed to assess stockpile problems. However, in the absence of nuclear testing, the ability to assess nuclear components is more difficult; new methods of assessment, discussed later, will have to be developed to help compensate for this loss.
  
  The historical stockpile database includes more than 2,400 findings from more than 45 weapon types. Findings are any abnormal conditions pertaining to stockpile weapons, such as out-of-specification data. Findings are then investigated and assessed as to whether or not they are a problem. Actionable findings are those that require some form of corrective action. All major components and subsystems have had problems that required corrective actions. The number of findings for nonnuclear components is much larger than that for nuclear components largely because there are so many more nonnuclear components in a nuclear weapon that require testing more frequently. However, the ratio of actionable findings to distinct findings is much greater for the nuclear components. Thus, when a finding has occurred for a nuclear component, it has generally been a serious one requiring corrective action. Often these corrective actions to nuclear components have required changes to all of the weapons comprising the weapon type affected.
  
  For the nuclear explosive package, there were approximately 110 findings on 39 weapon types requiring some remediation either to the entire build of that design or to all weapons produced after the particular finding. In addition to rebuilds and changes in production procedures, other actions included imposing restrictions on the weapon, accepting a performance decrement, and in several cases, conducting a nuclear test to determine that the finding did not require any physical change. There have been other instances not counted as actionable where a material was chemically changing and the weapon was closely monitored to see if further action was necessary or it was an isolated case that did not require remediation.
  
  The commentors, in referring to the Sandia Stockpile Study, are referring to briefing materials which were made publicly available earlier in 1995 which dealt with only a portion of the nuclear weapons historical defect and aging information. As described in chapter 2 of the PEIS, the Stockpile Stewardship and Management Program has been constructed to support national security policy directions as provided to DOE by the President and the Congress. Though weapon safety and weapon reliability can be driven at times by different phenomena, they are also related in that an essential ingredient of weapon safety is predictable response in all weapon environments, including potential accidents. Each of the proposed stockpile stewardship facilities would enhance the ability to make judgments about the safety and reliability of the nuclear weapons stockpile in the absence of underground nuclear testing. Section 3.1.2 has been expanded in the Final PEIS to provide a more detailed description and justification of DOE plans relative to national security policy and the issue of weapon safety and reliability. As explained in that section, national security policy from the President and Congress requires a safe and reliable stockpile. In order for the nuclear deterrent to be credible within the current national security policy framework, it must be reliable in a militarily effective way. From a PEIS perspective, separating safety and reliability is similar to the issue discussed under stockpile size (section 3.1.2.4, Denuclearization). It would require DOE to speculate on an alternate concept of nuclear deterrence and a national security policy framework to support it.
  
  Commentors have also suggested acceptance of lower standards of reliability as an alternative to enhanced stewardship capabilities. This PEIS explains how the assessment and certification of nuclear performance is carried out and how this differs from the more conventional statistical methods used for assessing reliability of the nonnuclear portion of the weapon. Assessment and certification of nuclear performance is a technical judgment by the weapons laboratories based on scientific theory, experimental data, and computational modeling (sections 2.3 and 2.4.1). The question is not whether to accept a lower standard of nuclear performance (less nuclear explosive yield), but whether or not there is a technical basis to confidently know how well the weapon will perform at all. Enhanced stewardship capability is focused on the technical ability to confidently judge nuclear safety and performance in the absence of nuclear testing.
  
  Aside from being inconsistent with the national security policy, attempting to separate weapon safety and reliability, is more technically complex than it sounds. A modern nuclear weapon is highly integrated in its design for safety, reliability, and performance. It contains electrical energy sources and many explosive energy sources in addition to the main charge HE. The principal safety concern is accidental detonation of the HE causing dispersal of radioactive materials (plutonium and uranium). Modern weapons are designed and system-engineered to provide a predictable response in accident environments (e.g., fire, crush, or drop). However, because of the technical complexity of potential accident scenarios (i.e., combined environments) and the fact that complete nuclear weapons cannot be used for experimental data, assessment of the design and the effect of changes that might be occurring due to stockpile environments must rely on other sources of experimental data and complex computer modeling. Enhanced experimental capability specifically related to the weapon secondary is a nuclear performance concern. Enhanced computational capability in general, and enhanced experimental capability related to the weapon primary in particular, are both nuclear safety and performance concerns.

40.23

The commentors express support for maintaining production missions at the production sites, and for maintaining the funding required to continue these activities. Commentors urge DOE to keep production missions at production plants that have the experience and proven safety record to complete assigned tasks. Commentors state that the existing production infrastructure, personnel, and experience at production sites made moving these missions to a laboratory an unreasonable alternative. In the view of many commentors, production and R&D cultures were not compatible and merging them would jeopardize the defense of the Nation. One commentor further states that the quality and integrity of today's stockpile is the result of production people and not the laboratories. Commentors believe that there was no adequate peer review of laboratory recommendations or manufacturing capability claims. Commentors also state that design experts were not production literate, and the weapons design and manufacturing functions should remain separate. Other commentors state that the laboratories will not be able to maintain the required quantities and quality of weapons components if they are given the production missions.

• Response: Production and laboratory functions are different, but the difference is reduced as the size of the production requirements becomes smaller. The first atomic weapons were not only designed but also constructed at the weapons laboratories. The laboratories have always had the capability for small lot production principally in order to test out designers' theories. In some respects, this could be considered an advantage by increasing the synergism between the two activities.
  
  Data for the PEIS were developed by working groups for each stockpile management mission. These working groups consisted of experts from each of the potentially affected sites. A review of data for consistency and accuracy was performed at both the working team level and at a senior management level. The alternative of transferring the stockpile management functions that currently exist at ORR, KCP, and Pantex to the laboratories and NTS are evaluated in the PEIS because they are deemed to be reasonable alternatives. Based on the environmental, cost, and technical analyses that have been performed, the preferred alternative is to downsize the stockpile management functions at ORR, KCP, and Pantex, and not transfer them to the laboratories and NTS.

40.24

The commentors question DOE's commitment to attracting and retaining staff at laboratories and production sites. Some commentors believe that DOE was favoring the design laboratories over the production plants, while others believe that because of the reduced workloads, staff and capabilities are being lost everywhere in the weapons complex. The commentors are also concerned that funding for sites, particularly Y-12, was not adequate in maintaining their mission capabilities let alone sufficient to make necessary upgrades at the site. Other commentors contend that the proposed program reduces the production capabilities and personnel within the complex and shifts most efforts to the R&D laboratories and therefore reduces the long-term success and flexibility of the program to meet national security needs. Commentors also note that all the budget increases are slated for the laboratories, while budget cuts are slated for the production complex.

• Response: Maintenance of competency in critical nuclear weapons technologies is a significant management challenge for DOE at both the production plants and the weapon laboratories. It is for this reason that DOE has proposed actions to promote teamwork and integration of work at the plants and laboratories for unique process and material technologies. DOE plans in this regard are described in more detail in the Stockpile Management Preferred Alternatives Report. An important objective of this teamwork and integration program is to provide a technologically challenging program which would assist in the attraction and retention of technical personnel.

40.25

The commentors state that the analysis and support studies for the management part of the Stockpile Stewardship and Management Program was much more complete and balanced than that for the stewardship part and urged DOE to prepare the same level of analysis for stewardship.

• Response: The PEIS analyzes the potential consequences to the environment if certain programmatic changes to the Complex are implemented. National security policies in the post-Cold War era require that all the historical capabilities of the weapons laboratories, industrial plants, and NTS be maintained. Those processes and facilities, such as stewardship R&D work, that have no potential for being changed or moved as part of this proposal are not analyzed beyond the No Action alternative. DOE is not proposing to make any changes to these existing weapons R&D activities at the three laboratories or NTS. Rather, DOE is proposing to provide enhanced experimental capabilities (NIF, CFF, and Atlas in appendix I, J, and K, respectively) to augment existing R&D activities and stockpile stewardship capabilities so that the safety and reliability of the stockpile can be maintained in the absence of underground testing. The purpose and need for the full range of laboratory capabilities contained at LANL and LLNL and for continued peer review for weapon assessment and certification are explained in chapter 2 of the PEIS.

40.26

For stockpile management, commentors believe that the approach reveals the extent to which the PEIS is narrowly focused on a single, pre-chosen alternative. The commentors state that there is no separate analysis of the high and low cases in which the impacts of these alternatives can be compared to the base case alternative. According to the commentors it is not clear that the different stockpile cases really represent alternatives in the traditional NEPA sense at all, since they apparently will require construction of the same facilities and will have very similar impacts. The commentors also state that the three cases analyzed by DOE (post-START II, START I plus, 1,000 warheads) have minimal effect on the facilities and configurations proposed by DOE such that there is no true programmatic review.

• Response: Two of the stockpile sizes analyzed in this PEIS, a START I Treaty- and START II protocol-sized stockpile, are the only ones currently defined and directed by national security policy. The PEIS also analyzes a hypothetical 1,000 weapon stockpile for the purpose of a sensitivity analysis for manufacturing capacity decisions. The NWSM specifies the types of weapons and quantities of each weapon type by year (section 1.1). The NWSM is developed based on DOD force structure requirements necessary to maintain nuclear deterrence and comply with existing arms control treaties while pursuing further arms control reductions. The PEIS explains the complexity of this process and why DOE does not believe it reasonable to speculate with a large number of arbitrary assumptions (section 2.2). However, this does not mean DOE has failed to consider that a future national security policy framework could define a path to a smaller stockpile.
• Stockpile stewardship capabilities are currently viewed by the United States as a means to further U.S. nonproliferation objectives in seeking a zero-yield CTBT. Likewise, it would be reasonable to assume that U.S. confidence in its stewardship capabilities would remain as important, if not more important, in future arms control negotiations to further reduce its stockpile. The path to a very small (10s or 100s) or zero stockpile would require the negotiation of complex international treaties that are also likely to require intrusive verification inspections of nuclear weapons related facilities. Therefore, DOE believes it reasonable to assume that complex treaty negotiations, when coupled with complex implementation provisions, would likely stretch over several decades. On a gradual path to a very small or zero stockpile, stockpile size alone would not change the purpose and need, proposed actions, and alternatives in this PEIS as they relate to stewardship capabilities. The issues of maintaining the core competencies of the United States in nuclear weapons, and the technical problems of a smaller, aging stockpile in the absence of nuclear testing, remain the same.
  
  This PEIS evaluates reasonable approaches to stockpile management capability and capacity that are consistent with a gradual path toward a very small or zero stockpile. At some point on this path further downsizing of existing industrial plants or the alternative of consolidating manufacturing functions at stewardship sites would become more attractive as manufacturing capacity becomes a less important consideration. However, in the near term, the preferred alternative of downsizing the existing industrial plants would still be a reasonable action because the projected downsizing investment pays back within a few years through reduced operating expense; in addition, the downsizing actions are consistent with potential future decisions regarding plant closure. In regard to the proposed action for reestablishing pit manufacturing capability, DOE does not propose to establish higher manufacturing capacities than are inherent in the reestablishment of the basic manufacturing capability of LANL, which is the preferred alternative. In developing the criteria for reasonable stockpile management alternatives, DOE was careful not to propose the introduction of significant new types of environmental hazards to any prospective site. Therefore, on a gradual path to a very small or zero stockpile, stockpile size alone would not change the purpose and need, proposed actions, and alternatives in this PEIS with regard to stockpile management capabilities and capacities.
  
  The PEIS does not analyze stockpile size in the PEIS as traditional alternatives in the NEPA sense. Rather, the PEIS analysis is based on the national security policy considerations discussed in chapter 2 of the PEIS and is consistent with and supportive of those national security policies. The PEIS addresses plant operations to support a range of stockpile sizes consistent with recent DOD plans, as reflected in the NPR. More specifically, the PEIS addresses a base case stockpile consistent with the recently ratified START II protocol with additional data for a larger (START I) or smaller (about 1,000 weapons) stockpile. The DOE Stockpile Management Preferred Alternatives Report, which was released to provide programmatic support to the PEIS, describes the DOE manufacturing capacity strategy in more detail. Given the uncertainties in the world, this strategy retains sufficient manufacturing capacity to support the larger START I, yet is also flexible if the stockpile is reduced below START II levels.
  
  It should be noted that regardless of stockpile size, a goal of the Stockpile Stewardship and Management Program, as directed by national policy, is to maintain the core competencies of the United States in nuclear weapons. Industrial capacity is only indirectly affected by projected variances in stockpile size and composition. Stockpile size must be linked with historical stockpile data to arrive at estimates of average industrial capacity needed to produce components for repair or replacement. Because this cannot be done with mathematical precision, reasonable technical judgment must be applied. The resulting forecast is a smaller industrial base (with capacities on a scale of hundreds of weapons per year versus the scale of thousands of weapons per year that was the capacity prior to the end of the Cold War).

40.27

Several commentors express opposition to the continued operation of all the major DOE weapons laboratories (LANL, LLNL, and SNL). One commentor states that it is not obvious why we need three R&D laboratories when we are not building any new weapons. Other commentors believe that LLNL is an unjustified costly duplication of LANL. In fact, some commentors referring to the Notice of Intent for the PEIS and the PEIS itself state that descriptions of LANL and LLNL are identical. In light of the duplication of effort and especially the Galvin Committee's recommendation, commentors ask how DOE justifies the continued operation of both LANL and LLNL. Another commentor states that the two laboratory option merits consideration. Other commentors are of the opinion that the national laboratories should cease all related nuclear weapons work and instead the country should divert those technical and monetary resources towards civilian uses. According to the commentors, alternate uses for the laboratories should include research into cleaner sources of energy (e.g., solar, wind, and geothermal), recycling and solving the nuclear waste problem.

• Response: On September 25, 1995, DOE was directed by the President to maintain nuclear weapons responsibilities and capabilities at the three weapons laboratories sufficient to ensure continued confidence in the safety and reliability of the nuclear weapons stockpile in the absence of underground nuclear testing. Consequently, both LANL and LLNL, as well as SNL, are required for the foreseeable future.
  
  Although with the end of the Cold War and changes in the world's political regimes the emphasis of the U.S. nuclear weapons program has shifted dramatically, nuclear weapons continue to be a "cornerstone" of national security policy. As long as the President and Congress maintain a defense policy based on nuclear weapons, DOE will continue to have the responsibilities for ensuring the safety and reliability of the U.S. nuclear weapon stockpile. Congress determines how funds are allotted to ensure the continued maintenance of a safe and reliable nuclear deterrent. The purpose and need for the full range of laboratory capabilities contained at LANL and LLNL and for continued peer review for weapon assessment and certification are explained in chapter 2 of the PEIS.

40.28

The commentor would like to know what plan the PEIS is based on and whether it is still the Stockpile Stewardship and Management Program plan, dated May 1995, and whether this plan has undergone significant revisions.

• Response: The PEIS is still based on the Stockpile Stewardship and Management Program plan dated May 1995. While that plan has not undergone substantive revisions, detailed planning of ongoing and future R&D activities continues to evolve (as is expected of R&D) and to be reflected in, for example, the evolution of DOE budget requests to Congress. As discussed in sections 3.3.4 and 4.11 of this PEIS, some of the new facilities described in the May 1995 plan are not yet at a state of maturity appropriate for formal proposal or analysis in this PEIS, nor can all facilities needed to fully implement the Program over time be fully identified at present.

40.29

The commentors state that they were in favor of DOE's plan to downsize the Complex, but did not see these reductions reflected in the PEIS. Nor did the commentors understand how DOE could severely downsize the production plants but at the same time increase the laboratories' capability, capacity, and staff.

• Response: The No Action alternative assumes staffing reductions at DOE facilities over the next several years as overall (primarily weapon dismantlement) workload decreases. Further reductions in facility size and staffing are anticipated under either the "downsize in place" or relocation alternatives for stockpile management functions. Staffing reductions in the core weapons program have occurred at the laboratories in recent years as overall workload and commensurate funding have decreased. Significant staffing increases at the weapons laboratories are not anticipated with the implementation of the stockpile stewardship program. Modest increases would be associated with the introduction of pit fabrication to LANL and the construction and operation of NIF at LLNL. Personnel for new initiatives are expected to come primarily from existing laboratory staff. Employment for other programs at the laboratories (about 50 percent of total employment) is dependent on priorities and decisions outside the scope of the Stockpile Stewardship and Management Program.

40.30

The commentors express concerns about the threat of layoffs. Commentors believe that employees at LANL were under pressure to support laboratory activities or be threatened with layoffs. The commentors state that employees at TA-55 were laid off even though the future expansion of this area was known. One commentor points out that TA-55 may be vulnerable to sabotage if the constant threat of layoffs exists.

• Response: DOE is aware of the concerns that have been raised by LANL employees whose employment was recently terminated due to overall laboratory downsizing. DOE is working with the University of California to assure fair and equitable treatment of all current and former LANL employees. Overall reductions to laboratory and plant employment, however, have been necessary as overall workload and commensurate budgets have been reduced. Significant staffing increases at the weapons laboratories are not anticipated in the future with the implementation of the stockpile stewardship program. Modest increases would be associated with the introduction of pit fabrication to LANL and the construction and operation of NIF at LLNL.

40.31

The commentors believe that information available to the public is increasingly being taken out of the public record. A commentor cites the Operating Experience Summary Report which was recently taken offline, presumably to hide the number of troublesome incidents at TA-55. Other commentors cite the new bomb designs that were on the Internet as proof that DOE is still working on new bomb designs. One commentor requests that this Internet document be made available to the public.

• Response: DOE requires its sites to furnish a daily report to notify it of reportable occurrences in the safety and health arena. The daily report provides initial notification for internal use by DOE and the site. After any necessary investigation, DOE and the site prepare a final report which is made available to the public. The daily reports concerning LANL include incidents at TA-55, although that facility is not afforded any special treatment. At LANL, both the final occurrence reports and an online summary prepared by the laboratory are referred to as the Operating Experience Summary Report. In the past, LANL put preliminary daily occurrence notification reports on its computer network. LANL discontinued this practice because the initial reports contain preliminary information that in some cases is incomplete or inaccurate, and which is superceded by the final reports. The final occurrence reports are available to the public in many forms, including online.
  
  DOE withdrew its DP Home Page from the World Wide Web on March 20, 1996. This action was in response to the discovery that part of the information from the Office of Research and Inertial Fusion came from a number of sources, some of which were outdated. Much of the material in question was drawn from the Report of the Defense Programs Research and Technology Development Program for Fiscal Year 1993, covering the period from October 1, 1992 to September 30, 1993. This report was issued by the Office of Research and Advanced Technology, a precursor office to the Office of Research and Inertial Fusion. The Office of Research and Inertial Fusion constructed its Home Page in early 1995 from the above-mentioned report with links to other activities and documents in the DP Home Page. The links were regularly updated as the DP Home Page evolved, but the text describing Office of Research and Inertial Fusion activities was not. In particular, the specific information related to the Gulf War was only current in late 1992.
  
  DOE has halted production of new-design weapons and is, therefore, not performing such activities. DOE is charged with maintaining the safety and reliability of existing nuclear weapons in accordance with National Security Policy. An updated DP Home Page has been prepared. DOE apologizes for the confusion caused by the outdated material.

40.32

The commentor questions if DOE considered, under the nonproliferation mantle, which facilities or sites pose the least security risk. The commentor states that security capabilities should be addressed in the infrastructure impact analysis. In fact, the commentor suggests that the number of security breaches over the last 10 years should be used as the key method to evaluate the sites' security capabilities. Commentor asks whether there are not competitions and assessments of each site's security possibilities and feels that sites that are lacking in security should not be considered for more work. The commentor adds, if LANL has a bad record like the apparent security breach that helped the Russians develop their first [nuclear] weapon, why DOE does not consider an alternative site where security is taken seriously. Another commentor questions the selection of LANL as a site for additional pit production and for DARHT's "non-destructive testing" based on reports of security deficiencies at LANL indicating a general laxness in readiness to accept a 5-fold increase in pit production. Other commentors refer to Summary section S.2.4 and the statement "much of the (experimental weapons) testing is classified and could not lead to proliferation without a breach of security," stating that this implies that adequate security classification of this component of the nuclear weapons program will somehow preclude proliferation. Commentors feel that the postulated relation between adequate classification and weapons proliferation is not so simple.

• Response: DOE maintains a rigorous safeguards and security program as appropriate at each of its installations and for each of its operations. Specific provisions for safeguards/inspections are addressed in site-specific studies. DOE expects compliance with its safeguards and security requirements at all of its sites.

40.33

A number of commentors state that remanufacturing was a reasonable alternative that should be analyzed in the PEIS. In the view of the commentors, the justification stated in the PEIS for eliminating remanufacturing as an alternative for detailed analysis was inadequate and not supported by appropriate studies. Commentors believe that remanufacturing would be cheaper and more compatible with maintaining the capabilities of production and R&D laboratories than would the proposed stewardship program. Another commentor requests that DOE provide a cost comparison of the remanufacturing alternative as opposed to the proposed science-based approach. Remanufacturing should not be done by design engineers, according to one commentor.

• Response: The remanufacturer's point of view is reflected in this PEIS by the fact that remanufacturing to specification will be attempted when possible and when appropriate to the problem being solved. With more than a half dozen different weapon types projected to remain in the stockpile, and with each weapon type containing thousands of parts, remanufacturing will undoubtedly occur for a significant number of repair and replacement activities. However, remanufacturing is not reasonable as a distinct exclusive alternative to the ongoing stockpile stewardship program or the proposed action of enhanced experimental capability for the technical reasons discussed below. In addition, it would not be a reasonable alternative because it does not fully support national security policies that require the conduct of a science-based stockpile stewardship and maintenance of the capability to design and produce new weapons.
  
  Remanufacturing weapon components to their original specification, or maintaining weapons to their original design specifications, would superficially appear to be a reasonable approach to maintaining the safety and reliability of the stockpile in the absence of nuclear testing. Precise replication, however, is often not possible. Subtle changes in materials, processing, and fabrication techniques are an ever-present problem. In some cases, specialty materials and components become unavailable for com-
• mercial or environmental reasons. Implicit in the remanufacturing assumption is that the design blueprint, manufacturing process, and the materials used are specified in exact detail in every way. However, there is an unwritten element of "know how" that knowledgeable and experienced personnel contribute to any complicated manufacturing process (for this reason, controlling the acquisition of "know how" is a major nuclear weapons nonproliferation objective). Materials and processes are not always specified in important ways because, at the time, they were not known to be important. The problem is illustrated by the following hypothetical example.
  
  A material produced for a critical weld has a specification for a trace impurity; the manufacturing process consistently produced the material with a trace impurity less than the maximum allowed and the welds were satisfactory; the manufacturing process is changed for some reason, such as cost or environmental concerns; the material is now being produced with less trace impurity than before the process was changed; the material is still within specification; however, the welds are no longer satisfactory; it was unknown at the time that the higher level of the trace impurity was necessary to produce a satisfactory weld.
  
  While remanufacturing sounds simple in principle, it is likely in fact to present complex issues of design, manufacturing process, and material variables. A simplified view of remanufacturing cannot serve as a "stand alone" manufacturing approach, let alone an alternative approach to enhanced stewardship capability. In the absence of underground nuclear testing, nuclear components (pits and secondaries) cannot be functionally tested. Stewardship capabilities provide the analytical tools (experimental and computational) to assess the significance of a problem observed during surveillance and to decide if the problem should be fixed; and if fixed, to certify that the fix will work (section 2.4.1). In the past, the decision to fix or not fix an observed problem could be made with nuclear testing (section 2.3). Stockpile stewardship strategies focus on the basic material science and the enhanced experimental and computational tools necessary to better predict age-related defects and to make sound technical judgments on nuclear safety and performance in the absence of nuclear testing.
  
  The DARHT EIS (DOE/EIS-0228, section 2.3.2) provides an additional discussion of the limitations of a remanufacturing-to-specification approach. It discusses, as an example, the actions taken to evaluate and resolve unanticipated deterioration of HE in the now-retired W68 warhead for a submarine-launched ballistic missile. In that case it was necessary to replace the HE with a more chemically stable formulation. In addition, some other materials were no longer commercially available, requiring changes in the rebuilt weapons. Nuclear testing was ultimately used to verify that the necessary changes were acceptable. DOE does not consider it feasible to maintain all potentially obsolescent commercial sources and processes used for materials in existing weapons; aging would still occur in stored reserves of such materials.
  
  With regard to stockpile management, remanufacturing without enhanced stewardship capability would also have notable drawbacks. DOE plans to maintain the capability to produce secondaries, and proposes to reestablish the capability to produce pits, by producing small quantities (10s) of each annually to maintain capability. This capacity should be sufficient to replace components attrited from the stockpile by surveillance testing. Remanufacturing these components, without the enhanced stewardship analytical capability to determine if and when replacement is necessary, is likely to require higher levels of production than DOE believes necessary to maintain production capability. Also, remanufacturing a nuclear component to the original specifications will not prevent age-related problems related to those specifications from recurring. Since these components use plutonium and uranium, radiation exposure to personnel and generation of radioactive waste would also be higher than necessary. If repeated remanufacturing were required, further unnecessary risks would result from additional weapon A/D operations and additional transport of nuclear components between sites.
  
  From an environmental impact point of view, the remanufacturing concept would have greater impacts for the proposed action of reestablishing pit capability because DOE proposes to use a cleaner, less waste-generating process than was used at the Rocky Flats Plant. All other environmental impacts would not be distinguishable from those described in this PEIS because existing manufacturing processes form the Program baseline.

40.34

Several commentors feel that the document presents several misused terms and euphemisms which are intended to deceive the public. The commentor feels the following terms should be changed or decoupled so that there would be less acceptance of the proposed program:

(1) safety and reliability: the commentor feels this phrase translates into the expected blast of a nuclear weapon must be greater than 90-percent yield. The commentor feels reliable weapons are not required and that the stockpile may be maintained with existing technology. The commentor feels that greater unreliability may in fact discourage proliferation.

(2) flexibility: the commentor feels this term translates into continued development of new nuclear weapons.

(3) modification: the commentor feels this term applies to the construction of new nuclear weapons.

(4) national security: the commentor believes this euphemism destructs "true" national security which is the environment. The commentor feels that the Nation is less secure because the money proposed for stockpile stewardship and management may be used for poverty, education, and waste management.

• Response: DOE has reviewed the commentors' statements and has determined that the terms used in the PEIS are appropriate. As described in chapter 2 of the PEIS, the Stockpile Stewardship and Management Program has been constructed to support national security policy directions as provided to DOE by the President and the Congress. Though weapon safety and weapon reliability can be driven at times by different phenomena, they are also related in that an essential ingredient of weapon safety is predictable response in all weapon environments, including potential accidents. Section 3.1.2 has been expanded in the Final PEIS to provide more detailed description and justification of DOE plans relative to national security policy and the issue of weapon safety and reliability.

40.35

A number of commentors express concern that the proposed Program would not succeed and jeopardizes the defense posture of the country. Commentors state that without underground testing, the proposed stockpile stewardship program is a gamble. A commentor also wants to know what criteria was used by the President, Congress, and DOE in determining the potential success of the program.

• Response: In the event science-based stewardship proposals could not ensure the continued safety and reliability of the nuclear weapons stockpile, the resumption of underground testing at NTS would be considered. On August 11, 1995, the President stated that if he was informed by the Secretaries of Defense and Energy that a high level of confidence in the safety or reliability of a nuclear weapons type considered critical to the nuclear deterrent could no longer be certified that he would be prepared, in consultation with Congress, to exercise our "supreme national interests" rights under the CTBT to conduct whatever testing might be required. The rationale for science based stockpile stewardship is explained in chapter 2 and supported by further discussion in chapter 3 and appendixes I, J, and K.

40.36

The commentors express concern that DOE did not adequately justify the need for new or upgraded facilities to implement the science-based stockpile stewardship program. Some commentors suggest that rather than constructing new facilities at added expense, a passive stewardship and management plan (i.e., curatorship) should be considered. One commentor asks that DOE look at more "small-scale" techniques and facilities to determine the safety and reliability of the enduring stockpile. Another commentor believes that a non-science-based approach should be studied and analyzed in the PEIS.

• Response: DOE believes that the PEIS discusses a full range of alternatives for implementing the Stockpile Stewardship and Management Program, and that it analyzes in detail those reasonable alternatives that are capable of achieving the goals of the Program. DOE also believes that the PEIS adequately assesses the cumulative impacts of proposed new activities and existing activities at the sites where the Stockpile Stewardship and Management Program would be implemented.
  
  It is a well established principle under NEPA that the goals of a proposed action delineate the limits of the reasonable alternatives to that action. That is, an alternative which does not accomplish the agency's goals is not a reasonable alternative. Since its inception, one of the primary goals of the U.S. nuclear weapons program has been to ensure the safety, security, and reliability of the Nation's nuclear weapons stockpile. Numerous facilities have been built over the years at the three weapons laboratories (LANL, LLNL, and SNL) and at NTS to conduct various activities necessary to meet this goal.
  
  As described in chapter 2 of the PEIS, recent developments in national security policy have placed new constraints on the types of activities available to achieve this goal. Specifically, the United States is committed to ceasing both the production of new-design nuclear weapons, and the underground nuclear testing of weapons (see section 2.4). DOE's challenge in developing the stewardship portion of the Stockpile Stewardship and Management Program has been to determine whether, and how, to replace, modify, or augment the existing capabilities of the laboratories and NTS so that the goal of maintaining a safe, secure, and reliable stockpile can be met, even as the enduring stockpile ages and underground testing is no longer available.
  
  DOE has examined from a programmatic perspective various approaches to achieving this goal, and has determined that only an aggressive science-based program that relies on sophisticated simulation and computational technology would allow DOE to continue to ensure the safety, security, and reliability of the stockpile. Alternate approaches which are based on principles other than an aggressive pursuit of the knowledge necessary to predict, detect, and correct problems with the stockpile cannot achieve DOE's goals. Section 3.1.2 has been expanded to examine various other alternatives or approaches (such as maintenance, remanufacturing, and a zero-stockpile) that have been suggested, and to explain why each of them are incapable of ensuring the stockpile's safety, security, and reliability, and thus are not reasonable.
  
  Using simulation and computational technology to better understand the characteristics of nuclear weapons has been an element of DOE's weapons program for many years. It was historically part of the Research, Development, and Testing Program, the predecessor of the proposed stewardship portion of the Stockpile Stewardship and Management Program. In determining, for the reasons noted above, that stewardship must be based on similar principles, DOE effectively eliminated the option of replacing the existing proven capabilities at the laboratories and NTS with a different, untried approach. Accordingly, the PEIS focuses on facilities that could modify or augment the existing capabilities in ways that would achieve DOE's goal. In summary, DOE and its predecessors have been "stewarding" the stockpile, utilizing science-based principles, since the dawn of the nuclear era. DOE believes that recent policy developments require an even more aggressive application of these principles to ensure the safety, security, and reliability of the stockpile.
  
  DOE believes that the PEIS appropriately addresses the role of existing facilities in the stewardship program. They are described as part of the No Action alternative, in broad terms in section 3.1.4 and in more detail in chapter 4 and appendix A. This approach to the No Action alternative (i.e., maintaining the status quo) is consistent with guidance issued by CEQ (46 FR 180426, March 23, 1981). The environmental impacts of continuing the existing activities at each of the sites associated with the Complex are described throughout chapter 4. The cumulative effects that could result when the impacts of the proposed new facilities are added to those of existing activities are described in section 4.13. DOE believes that in this way, the PEIS adequately presents the impacts of the entire stewardship program, while focusing specifically on the proposed new facilities that require a DOE decision, and describing them in context with the existing facilities upon which DOE would continue to rely on to achieve the goal of a safe, secure, and reliable stockpile.
  
  Because DOE intends to use the PEIS as a component in decisionmaking in 1996, only those alternatives that are ripe for decisionmaking are assessed in detail in the PEIS. Alternatives not yet reasonably foreseeable, and which have not matured so as to be ripe for decisionmaking, such as next generation facilities (see section 3.3.4), are not assessed in detail in the PEIS. Nonetheless, they are acknowledged and included to the extent practicable.
  
  DOE does not agree with the assertions that stockpile stewardship could be achieved using passive curatorship. Based on the national security policies discussed in chapter 2, the future nuclear deterrent will be based on a smaller, steadily aging nuclear weapons stockpile. As explained in section 2.3 of the PEIS, historical data would project that there will be actionable findings that will require certified repairs or replacements to be made to the nuclear weapons stockpile. Without underground nuclear testing, which was the proof-positive means of determining whether a potential problem existed or whether a problem was corrected, confidence in the safety and reliability of nuclear weapons must be based more on judgment.
  
  Judgment-based confidence demands more than passive curatorship. For judgment-based confidence, DOE is proposing a robust, science-based stewardship program to obtain accurate scientific and experimental data which can be correlated with past nuclear test data and used to validate computer modeling. The existing experimental tools were used in conjunction with nuclear testing and are inadequate if used alone. Passive curatorship, or other stewardship-based approaches which do not include the enhanced experimental tools that would provide the necessary data to assess and certify a stockpile without underground nuclear testing, would be inadequate and unreasonable.

40.37

The commentors state that DOE has been inconsistent in discussing the timeframe analyzed in the PEIS for stockpile stewardship and management. Related to this, a commentor states that it is not clear whether the period analyzed is for 25 years or an indefinite timeframe.

• Response: The Program purpose and need is defined in chapter 2 of the PEIS to be consistent with currently planned national security policy. That policy includes compliance with the START II protocol, whose effective date is 2003. However, further arms reduction treaties beyond START II are possible, and the PEIS discusses further stockpile reductions. However, it would be speculative to prescribe a timeframe for implementation of treaties whose negotiations have yet to begin. To bound the environmental impacts for actions proposed in the PEIS, facility design lifes were by necessity assumed. Generally those facility lifes were assumed to be 25 years.

40.38

The commentors ask about the three-laboratory stockpile evaluation program, which DOE office would be responsible for running the Program, and how many scientists and other skilled technical workers would be needed to maintain the stockpile and/or reactivate the weapons program in the future. One commentor asks if the laboratories will be downsized with the loss of the new weapons design and testing mission.

• Response: DOE has a stockpile evaluation program (sometimes referred to as stockpile surveillance) which includes component tests and evaluations at laboratory and production facilities. The Stockpile Stewardship and Management Program includes enhanced experimental capabilities to improve the laboratory assessment capability as well as enhanced surveillance testing at laboratory and production facilities. The costs for this evaluation program are a substantial portion of the budgets of each site. Day-to-day management of this program is performed by the DOE Albuquerque Operations Office. The stockpile stewardship and management proposal does not include any alternatives that would result in downsizing of the laboratories.

40.39

One commentor requests that DOE release the results of studies related to special nuclear materials that had been set-aside for the express purpose of studying future aging effects.

• Response: A limited number of "shelf life units," such as pit components, were typically produced to act as "control samples" for use in stockpile evaluation activities. The component actually evaluated is the one returned from the weapon that was randomly sampled from the stockpile and, therefore, experienced actual stockpile environments while deployed. The "shelf life units" have not experienced actual stockpile environments. They are sometimes useful for comparison purposes to help distinguish cause and effect for observed anomalies in stockpile units. What can be said unclassified about problems with the stockpile is summarized in chapter 2 and the referenced unclassified portion of the tri-laboratory report. To the extent possible, these results have been factored into future stockpile management plans for components containing special nuclear materials.

40.40

The commentors question the Stockpile Stewardship and Management Program's flexibility to meet changes in stockpile size. Specifically, commentors ask what analysis was done, if any, to indicate the limiting factors for secondaries, pit production, and HE and what is the true surge capabilities for these areas, and DOE's confidence in meeting these capabilities. Regarding the capacity/capability of the Complex to respond to unanticipated needs, one commentor refers to page 8-2 of the Analysis of Stockpile Management Alternatives report, which states that build rates above 100 per year would adversely impact the ability of LANL to perform their surveillance and R&D missions. The commentor asks if this means that there is no way that DOE could truly support a surge.

Other commentors ask how the current Stockpile Stewardship and Management Program ensures the timely up-sizing of the nuclear weapons system should it become necessary. One commentor states that the proposed action of increasing production from a one-shift to a full-time basis using the same production equipment seems to ignore the fact that the additional training needed by capable machinists to properly and safely engage in the highly demanding efforts of weapons production is about five years. The commentor states that this is an unreasonable delay in response to an urgent threat. Another commentor suggests that the best way to accomplish a rapid scale-up of nuclear weapons production is to establish a sufficient level of comparable machine work at the production site to employ a staff adequate to go to a full scale production. The commentor states that the technical staff including machinists could then be rotated between the weapons work and the equivalent work to maintain their skills at the proper level. The commentor believes that if machine shop capabilities for prototype work were deliberately pursued it should be possible to employ a staff adequate to ensure a rapid scale-up should it become necessary.

• Response: The PEIS addresses several production capacities, each based on a specific potential stockpile level. Each production capacity assumed single shift operations; therefore, a significant sprint capacity was built into the planning assumptions. Because of the small demand for the fabrication of replacement plutonium pits over the next 10 or more years, DOE did not propose a new pit fabrication facility with a capacity equivalent to the capacities required for other portions of the nuclear weapons production complex. However, limited fabrication of new replacement pits would be required due to ongoing pit surveillance activities and to replace pits lost during weapon refurbishment. Section 3.6 discusses DOE future plans should a l