Commentors express concern that the perceived mitigative effects
of decontamination and decommissioning (D&D) jobs at ORR described
in Summary section S.4.1 and table 3.7.1-5 would not materialize
based on previous experience. The commentors are concerned about
when the D&D work would be budgeted and whether these jobs
would begin immediately or would be phased in. One commentor wants
to know specifically what jobs are going to be created and if
Washington agrees that these new jobs are going to be funded and
asks that a table be provided showing employment and socioeconomic
impacts through 2030. The commentors ask if Washington does intend
on funding the (proposed 1,318) D&D jobs, is this a steady
state requirement and how many years can the level of expenditure
continue once it starts. A commentor states as an example that
the D&D on Building 9201-4 has been scheduled for 15 years
and does not seem to be a priority. A commentor is also concerned
about who would do the D&D work (Lockheed-Martin people or
contract workers), and how soon it would have to be scheduled
in order for Lockheed-Martin workers to be kept on the payroll.
Another commentor is concerned that people from K-25 are included
in the D&D figures that are planned for Y-12. The commentor
is concerned that DOE is just shifting people and money for D&D.
- Response: For base case single-shift operations, the total
Y-12 workforce would fall to 3,916 from the No Action level of
4,721. The workforce would consist of 1,980 workers conducting
nonstockpile management activities, 784 core stockpile management
workers, and 1,152 workers performing landlord activities in preparation
for D&D of the facilities. The projected D&D employment
at Y-12 is shown in section 4.2.3.8. Workers performing landlord
activities are necessary for transition of the facility and would
be in place whether the funding comes from the Environmental Management
program or continues to come from DOE's Office of Defense Programs
(DP). Over the period 2005 to 2030, the number of these workers
would range from a high of 1,522 in 2016 to a low of 557 in 2030.
When D&D activities reach a peak in 2016, Y-12 would employ
435 fewer workers than under the No Action alternative.
The commentor wants to know where the impacts to the agricultural
economy were analyzed in the PEIS.
- Response: The Stockpile Stewardship and Management PEIS does
not analyze the economic impacts to particular sectors such as
the agriculture sector. Rather, the document evaluates impacts
to the regional economy as a whole, which includes the agricultural
sector. However, none of the proposed alternatives would make
use of prime farmland or involve activities affecting farm production.
Under normal operation, there would be no direct impacts to the
agricultural economy. Any potential impacts to agriculture resulting
from an accident are analyzed in appendix section F.4.
Commentors state that the socioeconomic impact to Oak Ridge and
the surrounding communities has not been appropriately analyzed.
One commentor expresses concern about the data used for the socioeconomic
study and the financial impact studies which show little impact
on the city of Oak Ridge and the ORR region. Another commentor
asks what the community will do with the unemployed workers that
have been at ORR for 20 to 25 years. The commentors also indicate
that the study's results must be questioned because personnel
from the city of Oak Ridge were not directly involved in the analysis.
- Response: The socioeconomic impacts associated
with the alternatives at ORR extend beyond the city of Oak Ridge
and include all the jurisdictions within the four-county region
of influence (ROI). The database used for the socioeconomic study
was developed using the most recent information available from
the Departments of Commerce and Labor, as well as financial reports
provided by cities, counties, and school districts. The impacts
were measured using the latest version of Regional Input-Output
Modeling System II (RIMS II), a model developed by the U.S. Bureau
of Economic Analysis. The model is used by Government agencies,
university researchers, and private economists to measure economic
impacts. The socioeconomic impacts for the alternatives considered
for ORR are discussed in section 4.2.3.8. DOE has created the
Office of Worker and Community Transition to help ease the unavoidable
impacts associated with the restructuring of the contractor workforce
at DOE sites. The office has issued its Interim Guidance for Contractor
Workforce Restructuring which includes options to encourage voluntary
separations and assist affected workers in transition to new careers.
The final guidance also includes measures such as transferring
employees to other missions or other sites, providing additional
training and educational assistance, or counseling for the employees.
In addition, DOE anticipates working closely with other businesses
in the communities surrounding the sites to keep them informed
of skilled personnel in the labor market.
In accordance with the NEPA process, the city of Oak Ridge has
been invited to provide comments on the proposed alternatives
from the time of initial scoping to the Final PEIS. Any comments
provided by the city or any other commentors are taken into account
and incorporated into the Final PEIS.
Commentors recognize that downsizing the nonnuclear fabrication
mission at KCP will result in a loss of possibly 300 to 900 jobs
over a period of time. The commentors want to know what can be
done, what resources can be utilized, and how the business community
can help lessen the number of jobs lost. The commentors point
out that even with the possibility of additional future work at
KCP, there is concern and they want to know if it is possible
to maintain a higher rate of employment in the Kansas City area.
- Response: In September 1994, DOE created the Office of Worker
and Community Transition to help ease the unavoidable impacts
associated with the restructuring of the contractor workforce
at DOE sites. The office has issued its Interim Guidance for Contractor
Workforce Restructuring which includes options to encourage voluntary
separations and assist workers in transition to new careers. The
final guidance also includes measures such as transferring employees
to other missions or other sites, providing additional training
and educational assistance, or counseling for the employees. In
addition, DOE anticipates working closely with other businesses
in the communities surrounding the sites to keep them informed
of skilled personnel in the labor market. Because KCP is small
relative to the large, diversified economy of the Kansas City
region, the downsizing is expected to have little effect on the
regional economy. Kansas City derives almost all of its employment
growth from non-DOE activities.
The commentor believes that the socioeconomic analysis does not
consider the social and economic impact of the people at LANL
who were laid off at the plutonium facility. The commentor believes
that DOE needs to look at the integrity of the people in the socioeconomic
analysis. The commentor also believes that the 22 people laid
off at the plutonium facility should be interviewed for the socioeconomic
analysis.
- Response: The Stockpile Stewardship and Management PEIS identifies
and analyzes potential impacts of the proposed Stockpile Stewardship
and Management Program alternatives, including the reestablishing
of pit fabrication at LANL. The PEIS does include in the analysis
the impacts of previous actions, such as layoffs at the LANL plutonium
facility. The commentor's concerns about downsizing and the effects
on site employees are being addressed by DOE's Office of Worker
and Community Transition. This office oversees DOE policies to
facilitate worker transition, including worker retraining, education,
and relocation assistance. The socioeconomic impact analysis estimates
direct and indirect economic impacts, including employment and
income. The PEIS also estimates impacts to the regional population
and the housing market, as well as impacts to public finance.
The commentor believes that any additional work that would come
to Los Alamos from pit production should be contracted out to
a private taxpaying company instead of going to the University
of California, which does not pay taxes to the state or the community.
- Response: The economic analysis does not take into account
what type of contractor would be managing the implementation of
the proposed alternatives. The purpose of the economic analysis
is to evaluate the socioeconomic impacts of the proposed alternatives
on employment and income in the regional economic area. The socioeconomic
impact analysis also addresses impacts to population, housing,
and public finances. Selection of the preferred alternative would
not be affected if LANL's contractor were a private in-state company
instead of the University of California. This is because the benefits
to the local communities from a private contractor as opposed
to a non-profit contractor are likely to be small. Any revenues
generated by corporate taxes levied on a private company would
be the result of a state corporate income tax. This revenue could
then be dispersed throughout the state, rather than remain in
the LANL region. It is unknown what portion of these funds would
actually be allocated to the LANL region. Impacts to the local
community public finance would more likely stem from local taxes
paid by workers directly associated with the facility. Furthermore,
the process of selecting a contractor for performing proposed
alternatives would be accomplished separately from the NEPA process.
Several commentors believe that the laboratories do not understand
the various processes at Y-12 to estimate accurate employment
figures. The commentors state that a detailed breakdown of the
job structure does not exist. The commentors wonder how the waste
job structures at Y-12 will be moved to LANL and how many people
for each function will be at all three of the sites. In addition,
the commentors state that there is no description on a function-by-function
basis of how the fabrication process can be implemented at another
site, and this oversight allows for wildly unrealistic estimates
at the other sites. Further, the commentors would like the PEIS
to address the difference in worker experience between Y-12 and
the laboratories and the cost of having to train a new workforce
if the secondary and case fabrication mission were moved.
- Response: In developing the data used in the PEIS and in the
cost estimates, DOE formed a working group for each functional
area that included all affected sites in order to share information
and provide consistent data for all of the proposed alternatives.
In the case of secondary and case manufacturing, this included
knowledgable personnel from both Y-12 and the laboratories so
that all three alternatives would be evaluating the same mission
and requirements. Appendix A gives a breakdown of employment by
labor category for each alternative at each site, and also includes
details on how the process would be implemented at each site.
This functional breakdown estimates the workers needed at Y-12,
LANL, or LLNL.
Commentors ask about the difference between socioeconomics and
environmental justice.
- Response: Environmental justice analysis, as defined in Executive
Order 12898, is performed to assess whether the proposed alternatives
would have a disproportionately high and adverse effect on minority
and low-income populations. The analysis is accomplished by examining
the size and distribution of these populations and determining
if adverse health and economic impacts would be borne by these
groups to a greater degree than the population as a whole. Socioeconomics
has a broader focus. Socioeconomics addresses the impacts of the
alternatives on the economic and social characteristics of a region,
such as population, employment, housing, and public finances.
The socioeconomic impact sections analyze the effect the alternatives
would have on the entire region, rather than on particular populations.
The commentor points out peculiarities, such as the concept that
no indirect jobs would be generated for the 523 workers and 321
incremental workers associated with the secondary/case mission
(table 3.4.4.3-2), that need to be resolved.
- Response: The number of indirect jobs generated by each alternative
depends on the mission performed and the types of existing industries
within the region. In the region around LANL, there are few or
no industries that would support the secondary and case fabrication
mission. Therefore, the increase in site employment (direct jobs)
would not result in a corresponding increase in supporting industry
employment (indirect jobs).
The commentor states that the numbers included in the PEIS contain
inconsistencies in logic and mathematics. For example, in section
3.4, the commentor notes surge operation is used for generating
the operations analysis numbers, rather than the base case, which
would presumably be the actual staffing levels and would be a
more realistic identification of the manpower and socioeconomic
impact. The commentor also wonders why the impact numbers calculated
in the analysis in section 3.7.1.1 are based on the three-shift
surge operation, when single-shift operation is the base case
(table 3.1.1.1-1). The commentor feels this may have been done
to reduce the socioeconomic impacts.
- Response: The Final PEIS assesses socioeconomic impacts using
both the base case single-shift and the base case surge (three-shift)
production scenarios. However, DOE has analyzed the base case
surge scenario (as well as a high case scenario where appropriate)
to fully capture the bounding case. This is because a surge operation
would require more workers than a one-shift operation and could
potentially cause greater disruption of the local infrastructure
(e.g., housing and public finances).
The commentor expresses confusion about the difference between
direct and indirect jobs and requests that the glossary include
these terms. Another commentor refers to the discussion in the
Summary section S.4.1 and states that only direct employment impacts
are considered in socioeconomics. The commentor questions whether
negative factors (such as land use, waste management, hazardous
operations, and transportation problems) would have negative socioeconomic
impacts.
- Response: The socioeconomic analysis assesses both direct
and indirect economic employment impacts. Indirect employment
refers to jobs created or lost in industries that support activities
associated with the proposed alternatives while direct employment
refers to changes in site workforce. These definitions are included
in chapter 9, Glossary. Waste management, transportation, and
hazardous operations are assessed in terms of health risks to
workers and the public.
The commentor refers to figure 4.2.3.8-4 and states that the text
under public finance only discusses ROI impacts when the city
of Oak Ridge impacts are 5.5 and 7.5 percent. The commentor asks,
since these numbers are for 2005 and the staffing levels in 2030
are only half of the 2005 level, how this affects projected impacts
in 2030.
- Response: The text presents overall ROI impacts while the
figures show the effects to individual cities and counties. In
the Final PEIS, the range of the effects on cities and counties
is included in the text.
Commentors state there are inconsistencies between the Draft PEIS
(figure 4.2.3.8-1) and the Stockpile Management Preferred Alternatives
Report (page 39) regarding employment figures. The commentors
note that the Draft PEIS projects a continuously decreasing employment
level for the downsizing ORR alternative until the year 2030.
The commentors note that section 4.2.3.8 is the only section which
mentions Environmental Management support employment figures.
The commentors point out that the Stockpile Management Preferred
Alternatives Report contradicts the information in the Draft PEIS
by reporting employment levels that will not continue to decline
after the year 2008 and will in fact remain constant between the
years 2008 and 2030. The commentors state the public is unsure
which figures are accurate.
- Response: Figure 4.2.3.8-1 was incorrect and did not properly
reflect the employment numbers presented in the PEIS which represent
DOE's most recent estimates of the labor force required for the
mission. The ORR labor requirements have been revised since the
publication of the Draft PEIS. The base case single-shift core
stockpile management workforce will be 784 in 2005, while the
base case surge (three-shift) core stockpile management workforce
would be 1,376 in 2005. In addition, D&D employment would
begin in 2003, increase its employment requirements until 2016,
and gradually decrease until 2030. This is shown in section 4.2.3.8.
The preferred alternative number of workers expected at Y-12 is
1,080, which falls between the two bounding values analyzed in
the PEIS.
The commentor states that the 1,100 employees that have been added
to the Pantex workforce in the past few years are mostly ES&H
workers and not A/D workers.
- Response: Of the 1,100 worker increase at Pantex over the
past 5 years, approximately 25 percent are associated with ES&H
and waste management activities. About 75 percent of the additional
workforce is employed in production and dismantlement operations.
The commentor urges DOE to correct the socioeconomic impact portions
of the PEIS to accurately reflect the impact of Pantex on the
local economy, stating that employment related to Pantex represents
over 12 percent of all jobs in the Amarillo metropolitan area.
The commentor's assertion is based on the fact that the money
Pantex brings into the local economy supports many retail, medical,
educational, finance, insurance, and real estate jobs. Other commentors
state that the dramatic employment reduction of 3,549 jobs forecasted
in the Draft PEIS will severely impact the Panhandle economy and
that any reductions should come only after intensive cost and
technical analyses. The commentors feel the loss of 3,549 high
paying jobs would have greater than a 1-percent impact.
- Response: The socioeconomic impact sections look at the entire
regional economic area around the site, rather than the nearest
metropolitan area. The jobs considered are those jobs associated
with the mission at the site, and those jobs in other industries
in the area that are related to and support the mission activities.
Other changes to the local economy, such as changes in tax revenues
and Government expenditures, are analyzed in the public finance
portions of the socioeconomic sections. Total phaseout of Pantex
would result in a loss of 3,549 jobs (1,644 direct and 1,905 indirect).
This represents 1.4 percent of total employment in the Pantex
regional economic area. The downsize A/D and HE fabrication alternative
would result in a loss of 475 jobs (220 direct and 255 indirect),
which is 0.2 percent of total regional economic area employment.
While these job losses could negatively affect the Panhandle region,
DOE's Office of Worker and Community Transition would work with
the area to lessen any impacts.
The commentor states that the PEIS does not address the social
impacts that go beyond the direct number of jobs, such as unnecessary
infrastructure and empty schools. The commentor believes the main
adverse impacts of a stockpile stewardship program would be associated
with the construction of new facilities and in the societal effects
of shifting responsibilities among installations.
- Response: The socioeconomic impact analysis estimates direct
and indirect economic impacts, including employment and income.
The PEIS also estimates impacts to regional population and the
housing market, as well as impacts to public finance for all sites
and all alternatives. The analysis of population impacts indicates
that any population change would be small relative to the resident
population, and would not significantly impact school populations
or existing infrastructure.
The commentor notes that in the Summary section entitled Secondary
and Case Fabrication, the proposed plan is to cut Y-12's manufacturing
capability from 2,350 current DP workers to 870, but that the
data presented at the April 1 and 2, 1996 meetings in Oak Ridge
were 3,126 current DP workers at Y-12 to be reduced to a downsized
level of 1,080 in the year 2003. The commentor points out that
the meeting data indicate a cut of 2,046 employees while the PEIS
shows a reduction in DP supported workers of 1,480 for the same
years. The commentor wants to know the impact of the new data
which calls for a cut of 2,046 workers which is 38-percent higher
than the data in the Summary section S.4.1 and in section 4.2.3.8.
- Response: For base case single-shift production in 2005, the
number of core stockpile management workers at Y-12 would fall
from the No Action level of 2,741 to 784 while landlord responsibilities
in preparation for D&D would require 1,152 workers. An additional
1,980 workers would be required for other program activities at
the Y-12 facility under both the No Action or the downsize alternative.
Total Y-12 workforce (core stockpile management and other programs)
would be reduced from the No Action level of 4,721 to 3,916, a
loss of 805 jobs. Employment in the ORR regional economic area
would fall by less than 1 percent as a result of the change in
site workforce.
The commentor refers to the Summary section S.4.1 and the proposed
plan to cut Y-12's manufacturing capability from the current 2,350
workers to 870. The commentor wants to know the skill mix that
will comprise the proposed 131 craftworkers and the 93 operatives
identified in order to evaluate the feasibility of meeting the
proposed production requirements. The commentor is interested
in knowing how many workers will be involved in quality and certification
and process development.
- Response: The socioeconomic impact sections analyze changes
to regional economics, employment, population, housing, and public
finance resulting from changes in site employment. The detailed
data requested by the commentor is not available because the types
of craftworkers and operators were not needed for determining
environmental impacts. The skill mix of the workers does not change
the environmental impacts of the proposed alternatives. The Stockpile
Management Preferred Alternatives Report presents an evaluation
of the technical ability of the alternatives to meet the proposed
production requirements. This report is available in the DOE Public
Reading Rooms near each site.
The commentor contends that substantial local public and private
money was put into building infrastructure to support DOE operations
(i.e., roads, schools, and utilities). The commentor states that
the PEIS does not consider the total national impact on local
socioeconomics (i.e., cuts at ORR, expansion at another site).
The commentor suggests that the PEIS needs to account for and
address these "stranded costs."
- Response: As seen in the socioeconomic analysis, the impacts
to the regional economies from any of the proposed alternatives
is small. In the case of the preferred alternative, the losses
to the regional economy would be diminished by D&D activities
associated with downsizing. Population decrease in any ROI jurisdiction
would not exceed 4 percent as a result of downsizing to the preferred
alternative. Therefore, there would be no large changes in the
utilization of local services or utilities.
The commentor requests clarification on the level of importance
placed on the impact of jobs lost or jobs gained in any particular
area in making recommendations.
- Response: The primary purpose of the Stockpile Stewardship
and Management Program is to continue to support U.S. national
security policies as directed by the President and Congress. The
final decision to select a preferred alternative takes into account
impacts to various environmental resources, including socioeconomics.
The Record of Decision (ROD) will explain the rationale and the
factors for DOE's decisions.
The commentor states that DOE should have analyzed in more detail
the socioeconomic impacts associated with each of the proposed
alternatives, including impacts associated with loss of employment
population, unnecessary infrastructure, and empty schools, as
well as other financial impacts on the region's economy. The commentor
believes that local government representatives should be included
in this more detailed analysis.
- Response: The PEIS analyzes impacts to regional employment
and income, as well as any changes to population or housing markets
that could result from the proposed alternatives. In addition,
impacts to local government and school district finances are assessed.
Information on public finances were obtained from each city, county,
and school district. Other data came from sources such as the
U.S. Census Bureau and the U.S. Bureau of Economic Statistics.
Input from local government officials and other stakeholders is
obtained from public meetings, including scoping meetings.
The commentor states that DOE should explain the statement in
the Stockpile Stewardship and Management Draft PEIS, "The
downsizing A/D and HE fabrication alternative would result in
the addition of 280 workers at Pantex."
- Response: A majority of the worker reductions at Pantex would
have already occurred under No Action. Under the base case single-shift
scenario, downsizing Pantex (retaining A/D and HE missions) would
result in the loss of 189 jobs from the No Action level of 1,644
jobs. A base case surge (three-shift) operation would require
1,927 workers. This represents an increase in employment requirements
over No Action of 283 jobs. This number was rounded to 280 in
the Draft PEIS.
The commentor requests that the Comment Response Document contain
a description of the statistical rationale which supports the
PEIS statement that direct and indirect jobs lost (from transfer
of HE mission to laboratories) would not change the Pantex regional
economic area's unemployment rate, housing/rental vacancies, and
public finance expenditures/revenues. Another commentor feels
DOE should not consider 33 HE jobs as insignificant.
- Response: Under No Action, the HE mission at Pantex would
employ 105 workers and generate an additional 122 jobs in related
industries within the region. Phaseout of this mission would therefore
result in a total loss of 227 jobs in the Pantex regional economic
area. Total employment in the region is projected to be 248,442
in 2005. Therefore, the jobs lost as a result of the phaseout
of the HE mission would result in a loss of less than one tenth
of 1 percent of total regional employment and would not have a
measurable effect on the unemployment rate. Even if all of the
displaced workers were to leave the area, the impacts on population,
housing, and public finance would be negligible. As described
in section 3.8, the preferred alternative is to assign the HE
mission to Pantex.
The commentor requests an explanation be given in the Comment
Response Document regarding the apparent inconsistencies between
the Pantex Site-Wide Draft EIS, the Stockpile Stewardship and
Management Draft PEIS, and the Storage and Disposition Draft PEIS
regarding the numbers of indirect jobs created in the region for
each direct job at Pantex. The commentor notes that the Pantex
Site-Wide Draft EIS, page S-17; Stockpile Stewardship and Management
Draft PEIS, Summary section S.4.1; and Storage and Disposition
Draft PEIS, page 4-205 assume an economic multiplier of 1.65,
1.16, and 3.51 indirect jobs in the region for every direct job
created at Pantex, respectively.
- Response: Projections of the number of indirect jobs generated
depends on a number of factors, including the type of mission
activity performed, the type of data used, and the methodology
employed. This PEIS evaluates the socioeconomic impact of weapons
A/D at Pantex, while the Storage and Disposition Draft PEIS evaluates
the impacts from the storage and disposition of fissile material.
The activities involved in the two programs are quite different
and each requires vastly different inputs. The availability of
inputs within the region is what determines the multiplier. For
example, if the Pantex region contains industries that produce
the inputs required for storage and disposition activities, but
no industries that produce stockpile stewardship and management
required inputs, the storage and disposition mission would generate
a greater number of indirect jobs in the region. The Pantex Site-Wide
Draft EIS impact analysis was conducted at a different level of
detail, and the analysis employed a somewhat different methodology.
The commentor requests an explanation in the Comment Response
Document as to why DOE did not consult with the Amarillo Economic
Development Commission and/or the city of Amarillo regarding the
ratio of additional jobs in the region related to each job at
Pantex and use the information that taxpayers had already paid
for.
- Response: The number of indirect jobs generated by any of
the alternatives was determined using RIMS II from the U.S. Bureau
of Economic Analysis. This information is available for every
economic region in the Nation, and therefore lends consistency
to the analysis across sites.
The commentor states that the resulting benefits to the regional
economy, if the Stockpile Stewardship and Management PEIS alternatives
were located at LLNL, would be less than 1 percent. Given the
additional radioactive and hazardous materials and wastes to be
shipped to and from LLNL and handled at the facility, which projects
a certain radiological risk to the public (albeit small, as estimated
by DOE), the commentor states that the PEIS should contain an
explanation which details how regional/state costs resulting from
the proposed action will be offset by benefits to the regional
economy.
- Response: The benefits to the local economy in terms of increased
regional income and employment and public finance impacts are
discussed in the socioeconomic section 4.7.3.8. These benefits
can be compared to the costs of the alternatives.
The commentor feels the statement in the ORR section 4.2.2.8,
that all jurisdictions have positive fund balances, may be misleading,
since state law requires positive fund balances and jurisdictions
deal with this by generating capital obligations, which are not
included in fund balance calculations.
- Response: Not all states require positive fund balances. The
statement that all jurisdictions have positive fund balances was
used in all sections where applicable. Otherwise, local governments
without positive fund balances were identified. The analysis of
public finances includes past capital bonding obligations and
the projected payout of these existing obligations. However, as
stated in the methodology, there was no attempt to project capital
bonding that may be made in the future. The purpose of analysis
was to compare effects of the proposed alternatives to No Action.
Both were projected using the same assumptions and methodology.
09 Intersite Transportation
One commentor asks DOE to comment on its methodology for choosing
transportation routes, parking areas, and the overall transportation
plan. Several commentors urge DOE to educate the public about
the risks associated with hazardous shipments and to consult and
coordinate with local communities and interested parties along
proposed transportation routes regarding each community's transportation
responsibilities and needs (such as additional roads); the routing
of hazardous shipments and notification of interested parties;
the effects of these additional shipments on traffic patterns;
and the effect on property values. One commentor asks that DOE
expand the ROI beyond 80 km (50 mi), as these people could be
affected by transportation issues as well. Another commentor urges
DOE to use every safeguard possible to ensure that the public
is not at risk from transportation of nuclear materials.
- Response: The intersite transportation of Stockpile Stewardship
and Management Program materials is discussed in section 4.10
of the PEIS. Hazardous materials transportation routes are predetermined
by the Department of Transportation (DOT) in conjunction with
the individual states. Parking areas are generally at DOE sites,
military bases, and other predetermined locations. The transportation
planning for plutonium and highly enriched uranium (HEU) shipments
is carefully prepared by the DOE Transportation Safeguards Division
to provide both safety and cargo security. The risk from normal
(accident-free) transportation of radioactive materials by DOE
is minimal. Even severe accidents are highly unlikely to cause
injury or death from a radiological release because of the stringent
Federal DOT/Nuclear Regulatory Commission (NRC) packaging design
and transport safety requirements. In over 40 years of shipment
activity, neither DOE nor its predecessor has ever experienced
an injury or death from a radiological release during transportation.
The volume of radioactive shipments associated with this PEIS
would be small and would have negligible effects on the number
of shipments in transportation corridors. The transportation risk
analysis for the alternatives presented in section 4.10 of the
PEIS included the entire route, which is beyond the 80-km (50-mi)
ROI.
Several commentors contend that DOE has not provided equal treatment
to local communities and Native Americans in regard to transportation
issues such as emergency response and preparedness, and urge DOE
to inform all local communities of important transportation issues.
Another commentor notes that there are no evacuation plans for
the people of Santa Fe and Albuquerque in case of a transportation
accident involving nuclear materials. The commentor feels that
the PEIS does not adequately analyze the impacts of accidents
at LANL on the Pueblo of San Ildefonso. One commentor states that
DOE needs to provide better oversight and notification regarding
shipments through the city of Pahrump and Nye County, specifically
emergency preparedness, as Pahrump does not have the population
to be trained. Another commentor states that the emergency response
personnel along the transportation routes are not properly trained
and equipped to handle an accident involving nuclear materials.
- Response: DOT is responsible for coordinating Federal training
programs and for providing technical assistance to states, tribes,
and local governments for emergency response training and planning.
Evacuation plans and emergency response are local jurisdictional
responsibilities. However, DOE voluntarily provides limited free
training and technical assistance to local jurisdictions when
there is a specific special interest (e.g., in areas most likely
to be traversed by safe secure trailer shipments). Training is
also provided separately to law enforcement and emergency services
personnel to familiarize them with DOE's system for the safe transport
of nuclear materials. Interested parties can request this free
training through the DOE Community Advisory Board for each site.
Regarding the impacts of accidents at LANL and their effects on
the Pueblo of San Ildefonso, the PEIS describes postulated transportation
accident impacts at LANL and their effects on surrounding communities
in section 4.10.
If NTS were selected as the weapons A/D site, it is unlikely that
radioactive shipments would pass through Pahrump because of its
out-of-the-way location. The Federal officers who escort plutonium
and HEU shipments are trained to actuate the National Emergency
Response System if they, themselves, cannot handle emergencies
that may occur en route. First responders, such as state police
or other emergency services personnel, also know how to actuate
this system.
Commentors state that there is local concern about the transportation
of nuclear weapons parts and materials on the highways of Nevada,
Clark County in particular. The commentors do not want these types
of materials to go through Clark County and urge implementation
of a rail system through low-population areas. The rail system
could serve a multitude of purposes (e.g., mining) in addition
to DOE transportation, and would eliminate the danger of highway
transportation. The commentors urge a study of this alternative
and state that the rail system would provide equity to the people
of Nevada.
- Response: The methodology for the safe secure transportation
of nuclear materials (plutonium and HEU) is well established.
Acceptable risk is not dependent upon the transportation mode
(truck versus rail) but rather upon the rigorous packaging design
requiring Federal safety certification. The packaging must retain
its contents under the most severe accident conditions (i.e.,
fire, impact, puncture, or water immersion). Rail transportation
for plutonium and HEU was abandoned in favor of the safe secure
trailers several years ago and is not now considered a viable
transportation alternative for these materials related to the
Stockpile Stewardship and Management Program.
The commentor believes that the PEIS should consider the risks
of hijacking when looking at the intersite transport of nuclear
materials.
- Response: All potential threats (including hijacking) to the
safety and security of nuclear materials in transit are considered
by DOE's Transportation Safeguards Division.
The commentor questions the safety record of nuclear shipments
in the Los Alamos area. Another commentor cites a safe secure
trailer turnover in Colorado about 5 years ago as proof that there
have been accidents with nuclear cargo.
- Response: Although DOE's transportation safeguards system
has experienced traffic accidents involving vehicles carrying
interstate shipments of radioactive materials, none, including
the accident in Colorado referred to by the commentor, have resulted
in a release of radioactive material. The safety of the system
is attributable in part to the training and certification of vehicle
operators and the design of the vehicles themselves. However,
the safety of DOE shipments does not rely just on these measures.
Primary containment of radioactive materials is provided by the
containers within which the material is placed for shipment. These
containers are designed to conform to the requirements for Type
B packages as specified by the NRC in 10 CFR 71. The packages
are fabricated and tested to ensure compliance with the standard
under normal conditions of transport and hypothetical accident
conditions including fire, impact, puncture, and water immersion.
The commentor refers to the Summary section S.2.3, High Explosive
Components, and states that safety issues related to shipment
of shaped charges were not assessed in detail, either in terms
of increased volume of shipments of shaped components over raw
HE, or in terms of the technical vulnerabilities of the components.
Another commentor questions whether hearings have been held to
discuss main charge transportation through the appropriately affected
states. Other commentors ask if an analysis has been made of the
additional hazards of transportation of HE from either of the
national laboratories to where it would be used, and what are
the increased costs of intersite transportation of HE from either
of the national laboratories to where it will be used. One commentor
contends that the safety impact of transporting hundreds of HE
hemispheres from the laboratories to Pantex (should HE manufacturing
be moved) is not adequately evaluated. A commentor also asks if
scrap explosives will be returned to the laboratories for disposal
or if Pantex will be responsible for disposition. Another commentor
states that separation of the explosive fabrication and A/D missions
would require that explosives be transported over long distances
in order to be mated with the physics packages. Therefore, the
commentor believes that in the case of LLNL, the extensive fogs
that create near zero visibility should be considered in any safety
analysis.
- Response: Transferring the HE fabrication mission from Pantex
to LANL and/or LLNL would require an estimated 150 rebuilds to
be shipped per year from the HE fabrication site to the weapons
A/D site. The accident risk from transporting this material would
be no greater than the risk encountered by the public from industry's
transport of similar explosives. Hearings are not required for
shipments of HE made in compliance with Federal transportation
regulations.
Transferring all or part of the HE fabrication mission from Pantex
to LANL and/or LLNL would require an estimated 12 round trips
per year to transport HE materials including the return of scrap
HE to the laboratories. The transportation of HE is described
in section 4.10 and appendix G of the PEIS. There would be no
impact from normal (accident-free) transportation. HE accident
impacts from transportation are bounded by the risk analyzed and
presented in the Facility Accident sections. Weapon component
shapes are classified and are shipped using the appropriate safeguard
measures in accordance with approved Federal regulations. HE main
charges would not be shipped with detonators installed and would
meet all DOT safety requirements.
The commentor asks how reliable the PEIS transportation computer
modeling is.
- Response: The RADTRAN computer code has been used in risk
analysis for over 10 years and is being constantly improved and
updated. It is accepted by the International Atomic Energy Agency
and its worldwide member countries as a reliable risk assessment
tool. RADTRAN calculates the collective dose to the exposed population
(workers and the public) from a postulated accident as well as
the collective dose from accident-free transportation. It produces
conservative estimates (those that tend to overstate impacts)
of radiation dose rates in a way that can be supported by available
data.
The commentor recommends that DOE should (a) directly involve
corridor states and tribes in preparing for large quantity radioactive
material shipments associated with the Stockpile Stewardship and
Management Program and other DOE programs; this would include
developing rail and truck transport plans, preferred routes, and
procedures prior to shipment (similar to the plans developed by
DOE and the Western Governors' Association for transuranic [TRU]
waste shipments to the Waste Isolation Pilot Plant [WIPP]); (b)
use only shipping containers that can be manufactured to meet
current Federal transport safety requirements; and (c) provide
accurate projected shipment information (i.e., quantities, schedules),
as well as necessary assistance and lead time for state emergency
response preparation. The commentor feels the Draft PEIS should
quantify the number, volume, transport mode, and characteristics
of radioactive materials being transported under the proposed
alternatives relative to baseline shipments.
- Response: Large numbers of radioactive shipments are not expected
under the Stockpile Stewardship and Management Program. The actual
route and quantity of material transported would be classified
information for purposes of national security, including security
of the shipments against attempts of diversion. However, DOE has,
on occasion, been able to identify to specific concerned communities
that shipments are not planned through their location. The analysis
presented in section 4.10 of the PEIS shows the risk to the public
to be low. Plutonium and HEU will be transported exclusively in
a Government-owned and -operated transportation system that provides
maximum safety and security. All shipments are escorted by Federal
officers, and only packaging that meets stringent Federal standards
for the shipment of these materials is used. The packaging and
transportation vehicles have, for example, been extensively tested
and certified to assure their safety against material dispersal
to the environment in hypothetical accidents involving such events
as crashes, fires, and water immersion. Packaging and transportation
methods and impacts are discussed in section 4.10 of the PEIS
and appendix G of the PEIS. Projected estimates of plutonium and
HEU shipments for the proposed alternatives are considered in
the transportation risk analysis. Information is provided by DOE
to state law enforcement and emergency services personnel on a
regular basis.
The commentor asks if it would violate security to tell us how
many shipments of radioactive material are going through Santa
Fe at this time.
- Response: Appendix section G.3 summarizes the shipments of
these radioactive materials between the sites. For the PEIS, shipment
numbers, routing, and date and time of shipments of plutonium
and HEU would be classified. See also the response to comment
summary 09.08.
Commentors express opposition to the transport of nuclear waste
and other deadly toxins. One commentor states that the transportation
risk numbers are terrifying.
- Response: Transport of nuclear materials has been ongoing
safely for more than 40 years. The analysis in this PEIS for transporting
nuclear materials shows that risks to the public are low. The
plutonium and HEU would be transported exclusively in a Government-owned
and -operated transportation system that provides maximum safety
and security. These hazardous materials shipments would be escorted
by Federal officers who can handle transport emergencies or actuate
the National Emergency Response System for assistance.
Commentors feel that transporting nuclear waste through New Mexico's
cities and countryside is dangerous, irresponsible, and the chance
for accident is too big to be taken. One commentor states that
they do not want high-level waste (HLW) trucked to LANL or on
New Mexico's highways. The commentor states that Federal Emergency
Management Agency does not even have a protocol for dealing with
a collision spill.
- Response: The Stockpile Stewardship and Management Program
does not generate HLW; however, under the preferred alternative,
there would be TRU waste shipments from LANL as discussed in section
4.6.3.10. The transportation of hazardous materials, including
radioactive waste, is essential for national commerce. The methodology
for the safe transport of these materials is well established.
The packaging is federally certified for safety and must retain
its contents under the most severe accident conditions (e.g.,
fire, impact, puncture, or water immersion). The transport of
all hazardous materials is regulated by Federal hazardous materials
laws that are applicable to DOE and other hazardous material shippers,
and cannot be preempted by individual states.
One commentor wants to know the extent of transportation (number
of trucks, routes, safety precautions, accident mitigation, and
such) of all nuclear materials along New Mexico's roads and the
extent to which this will increase once the pit fabrication mission
is implemented at LANL. Another commentor is concerned about the
number of pits that would be transferred between Santa Fe and
Pantex, and asks if there would be trucks going through Santa
Fe with Hiroshima-size nuclear potentials on them. Finally, one
commentor asks if there are trucks right now on the highway that
are transporting waste between Pantex and LANL.
- Response: Pit fabrication is not a new function at LANL; they
already have a research and development (R&D) pit fabrication
mission. As discussed in section 4.10, pit transportation would
include about four round trips per year of safe secure trailer
shipments. For the transportation of pits under this PEIS, the
shipment numbers, routing, and date and time of shipments would
be classified. These materials, however, would be transported
exclusively by the Government-owned and -operated transportation
system that provides maximum safety and security. A pit would
be shipped as a separate weapon component (without HE) and, as
such, would be unable to explode as a nuclear weapon. The potential
risk from transporting pits would be radiation exposure as a result
of a traffic accident. Nuclear materials in shipment are contained
in packages that have been designed and certified to meet NRC
standards to prevent a radioactive release during an accident.
There are currently no trucks on the highway transporting waste
between Pantex and LANL.
The commentor expresses concern about the transportation and safety
of low-level radioactive waste on commercial carriers.
- Response: DOE low-level waste (LLW), which consists primarily
of materials such as radioactively contaminated paper, protective
clothing, or cleaning materials that result from industrial processes,
has been transported safely and securely by commercial carriers
for more than 40 years. DOT requires high-integrity packaging
for such materials to the extent that potential exposure of radiation
at the outside of the package is insignificant (typically less
than 1 millirem (mrem) per hour per package at 1 m from the package).
DOE selects its commercial motor freight carriers of radioactive
material very carefully and subjects each carrier to routine evaluation
of its operating practices to ensure that they meet DOE and DOT
standards.