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23 November 2007
Department of Energy's nuclear weapons stockpile stewardship and management
environmental impact statement:
http://www.eh.doe.gov/nepa/eis/eis0236/eis0236.htm
EIS 0236 provides detailed descriptions of US nuclear weapons
facilities
(with figures
1,
2 and
3)
and current
research.
This is an excerpt of public comments on the weapons stockpile program.
http://www.eh.doe.gov/nepa/eis/eis0236/vol4/v4c340.htm#40
[undated]
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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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.
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.
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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.
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).
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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
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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.
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.
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.
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.
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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.
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.
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.
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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.
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.
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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.
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.
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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.
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.
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.
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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.
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.
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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.
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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).
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
The commentors refer to the cover sheet of the Draft
PEIS which states that a classified appendix presents the "purpose of and
need for the plutonium-242 to be stabilized at SRS for use in future weapons
complex research and development activities." Some commentors question why
the classified appendix was referenced, while other commentors believe that
unclassified portions of the appendix should be provided as part of the Draft
PEIS. One commentor further states that the note on the appendix should have
been prominently presented in the body of the Draft PEIS, rather than at
the end of the cover sheet. In addition, commentors believe that the role
of plutonium-242 in the Program and the nonproliferation implications of
separating plutonium-242 and its environmental impacts should be explicitly
discussed in the context of this PEIS, even though these may be covered in
facility-specific statements. Commentors express concern since plutonium-242
has been linked to serious environmental problems at SRS. One commentor states
that the DARHT EIS should have addressed all plutonium isotopes, including
those outside of LANL.
-
Response: The need for plutonium-242 is not classified.
Certain information regarding shipping, storage, and the specific use of
plutonium-242 is classified. Section 4.19 discusses the use of plutonium-242
for R&D and the potential environmental impacts of transporting this
material to the alternative sites. In the Interim Management of Nuclear Materials
Environmental Impact Statement (DOE/EIS 0220) dated October 20, 1995, DOE
indicated that certain quantities of plutonium-242 existed at SRS and that
this material has properties which make it useful for future R&D activities.
In the PEIS, DOE has indicated two alternatives for this material: to stabilize
and continue to store the plutonium-242 at SRS, and to stabilize the
plutonium-242 at SRS and transport this material to either LANL or LLNL.
The preferred alternative is to transport the material from SRS to LANL for
storage. Further details concerning the desirable properties of this material,
the actual quantities, or the technical issues associated with its use are
classified and are contained in a classified appendix to the PEIS.
The commentor correctly notes that a classified supplement to the Stockpile
Stewardship and Management PEIS has been prepared to support DOE decisions
needed regarding future R&D use of plutonium-242 and that DOE has prepared
a NEPA review of the environmental impacts from stabilizing plutonium-242
now held in solution at the SRS. DOE has left decisions for storing the material
to the Stockpile Stewardship and Management Program ROD.
The actions at SRS to stabilize plutonium solutions, including solutions
containing plutonium-242, are directed at addressing vulnerabilities identified
in DOE's Plutonium Vulnerability Assessment (DOE/EH-0415, November 1994).
Correction of these vulnerabilities has been emphasized by the Defense Nuclear
Facilities Safety Board. DOE decided to convert the plutonium-242 currently
in solution at SRS to oxide which will be placed in storage containers. DOE
has determined that as a matter of policy it has programmatic need for this
material for DP R&D activities.
The commentor asks about plutonium infrastructure outside of LANL that would
be related to DOE's decision to construct and operate DARHT. As noted in
the DARHT EIS, LANL was determined to be the only reasonable location for
DARHT capability; in part this was due to the existing plutonium infrastructure
at LANL that could support dynamic experiments with plutonium (DARHT EIS,
Volume I, section 3.10.1, page 3-41). DOE did not determine that any other
plutonium facilities, besides the ones at LANL, would be needed to support
operation of DARHT. DOE's decision to operate DARHT is unrelated to its decisions
regarding stabilizing plutonium solutions at SRS. (See DARHT EIS, Volume
II, Comment Response 17-37, page RPC-52.)
A commentor asks what, if any, consideration has been
given to safeguards/inspection provisions in these studies.
The commentors believe DOE "arrogantly" decided which
alternatives are reasonable and do not agree with the justification for the
No Action alternative in the summary as an unreasonable alternative. One
commentor wants to know what are the reasonable alternatives to the items
on the list entitled "DOE stockpile stewardship costs" and for anything that
DOE does. Another commentor would like more discussion about why there is
a need for improvement in the current process for a Complex that is not going
to be building new weapons. One commentor further notes that DARHT is considered
a fait accompli and the No Action alternative actually contains significant
programmatic commitment to a next generation hydrodynamic testing facility
as well as many other alternatives mentioned and unmentioned and there have
been no programmatic analyses of alternatives for retaining knowledge of
secondary physics--DOE proposes to build NIF and the Atlas Facility, but
does not mention why this is necessary.
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Response: Reasonable alternatives are those that would
accomplish the purposes and needs described in the PEIS. These reasonable
alternatives are analyzed in detail in the PEIS. Other alternatives were
considered in the PEIS process, but eliminated from detailed study because
they were judged to be unreasonable, as described in section 3.1.2 of the
PEIS. Section 3.1.4 describes why No Action is not a reasonable alternative.
Chapters 2, 3 and appendixes I, J, and K explain the need for and describe
enhanced experimental capability.
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 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 the 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 to ensure a safe, secure, and reliable
stockpile.
Commentors feel the Stockpile Stewardship and Management
Program is a responsible and necessary program for the U.S. stockpile of
nuclear weapons. One commentor states that the NPT and CTBT depend on the
Stockpile Stewardship and Management Program, especially NIF. In the absence
of underground nuclear testing, other commentors believe that the Stockpile
Stewardship and Management Program is absolutely vital for maintaining the
basics of nuclear weapons physics and keeping track on the condition of the
weapon stockpile. One commentor notes that it is important for the United
States to have the leading edge of nuclear weapons know-how, irrespective
of the winds of day-to-day politics. Another commentor states that given
the requirement for a safe and reliable stockpile, the ban on underground
testing, and the shrinking size of the stockpile, downsizing the overall
DOE Complex while building new facilities is reasonable. The commentor supports
the new facilities proposed because they are necessary to provide missing
data for computer modeling which cannot be supplied by underground nuclear
testing and can validate fixes for defects discovered during surveillance
and testing.
The commentor states that NTS has been part of any
number of programs that could possibly come to the site, yet those programs
end up going to LANL and LLNL and inquires about the possibility of NIF going
to NTS. Another commentor thinks that table 3.3-1, section 3.3, should
acknowledge the expertise at NTS in the experimental primaries and secondaries
and should also recognize NTS as a potential site for the siting of large
experimental facilities to do weapons simulation and effects tests.
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Response: DOE has looked at adding several missions
to NTS, given that maintenance of the test site for nuclear test readiness
remains a national policy requirement. To date, all proposed new missions
for stockpile stewardship and management have had compelling cost and technical
reasons for selecting other sites as the preferred alternative. DOE will
continue to look at NTS for potential future siting of new program
missions.
The preferred site alternative for NIF is LLNL. The preferred alternative
does not represent a decision, however. The ROD for NIF will be made no sooner
than 30 days after the filing of the Final PEIS with the EPA. NTS is a reasonable
site alternative for NIF, and could be selected in the ROD.
Table 3.3-1 is intended to show a broad view of current capabilities and
alternatives considered in the PEIS. As stated in section 3.2.9, Nevada Test
Site, DP activities, stockpile stewardship activities at NTS include conventional
HE tests, dynamic experiments, and hydrodynamic tests. These types of tests
can be used to study the physics of weapons primaries. NTS activities relating
to weapons effects and the physics of weapons secondaries have historically
been nuclear tests, which are considered as an future option only under the
"supreme national interests" provisions of any future CTBT. Additionally,
as stated in section 3.3.3, Weapons Effects, DOE is not proposing in this
PEIS any new facilities or alternatives solely for the study of weapons effects,
and would use existing facilities. A table has also been added to appendix
section A.1 further describing major existing DP facilities and activities
at these sites.
The commentor recommends a worldwide multi-national
testing program at NTS where all nuclear nations may test their own nuclear
devices under close supervision and control of the International Atomic Energy
Agency. In the commentor's opinion NTS features all required services, support,
maintenance, and insularity in place for such an international venture. Commentor
feels that a single world testing site would standardize international testing
while lowering the cost per user, would allow the definition of a legitimate
nuclear club, and the regime could corral mavericks engaged in unannounced
and covert buildup of unproved assets.
A commentor wants to know if the sites followed any
standards when submitting numbers for the PEIS.
The commentor raises the concern that the Albuquerque
Operations Office was censoring DOE contractor employees from participating
in the public hearings.
The commentor thinks that Summary section S.3.6 should
list NTS as an alternative site for all of the large experimental physics
machines.
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Response: NTS is listed as an alternative site for
NIF. For the remaining facilities, NTS was not considered a reasonable
alternative and is not listed. As discussed in section 3.3.1.2, Proposed
Contained Firing Facility, and in appendix J, CFF would augment and upgrade
the existing Flash X-Ray (FXR) Facility at LLNL, and therefore LLNL is the
only reasonable site. Similarly, section 3.3.2.3, Proposed Atlas Facility,
and appendix K state that Atlas would build on existing special equipment
at LANL such as the 1,430 megavolt-ampere (MA) generator in Building 301,
and therefore LANL is the only reasonable site.
The commentors express opposition to the Stockpile
Stewardship and Management Program, including NIF, stating that they are
dangerous and morally wrong. Some commentors remark that it is a waste to
use "human genius" in this manner since these talents may be used to solve
conflicts and the growing inequality of the world. One commentor believes
the United States is misinforming people by saying the United States will
not be producing and testing nuclear weapons. Another commentor believes
that the United States must revise its objectives and should be focusing
more on educating the youths of society and finding a cure for cancer. The
commentor does not believe the numbers associated with downsizing. The commentor
points out that the public knows the truth from a lie, and the lie is the
production and expansion of destructive weapons in the society.
The commentors express the opinion that stewardship
of the nuclear stockpile is a function that is best done at LANL. Stewardship
is a critical component of the Nation's security and LANL can guarantee the
integrity of the Nation's stockpile, according to the commentors. One commentor
indicates support for consolidating a portion of the weapons production
capability at LANL. Another commentor notes that LANL is developing technologies
for recycling, storage, and disposal of plutonium and enriched uranium;
technologies to reclaim contaminated sites and safely dispose of waste;
technologies to monitor and analyze the storage of nuclear components;
technologies to detect clandestine nuclear tests; and programs to transfer
technology to the Soviet Union. Given the state of affairs in the world today
with respect to nuclear weapons, the commentor believes that if LANL did
not exist, it would have to be invented because this Nation and the world
needs LANL and the technologies that it can provide.
The commentors state that DOE overlooked the potential
for Pantex, to perform new stewardship functions complementary to its current
management functions. Some commentors want DOE to designate Pantex as the
preferred alternative for all existing and new stockpile management and
stewardship functions as well as consolidation of all plutonium storage and
disposition and any related functions. According to the commentors, Pantex
has the resources, safeguards and security, existing facilities, and proximity
to LANL for technological information exchange (Atlas Facility and proposed
plutonium pit fabrication site) to downsize and/or consolidate while preserving
the integrity of the nuclear stockpile under increasing budgetary constraints.
Utilizing facilities already in place at Pantex could eliminate costs of
duplicating facilities, related transportation, environmental remediation,
and start-up and training, according to the commentors. Several commentors
also note that Pantex is perhaps the most cost effective alternative for
any of the new construction that is contemplated. While commentors state
that there is a strong history of community support, they caution that current
and future functions at Pantex must be conducted in a safe and environmentally
sound manner and that expansion must be implemented in a way that does not
impair the health or safety of area residents or adversely affect the
environment.
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Response: The rationale for the various site alternatives
are discussed in chapter 2, as well as in various portions of section 3.1
of the PEIS. Pantex is considered as a reasonable site alternative for the
A/D mission, strategic reserve storage, and HE fabrication. Pantex does not
have an existing infrastructure for plutonium fabrication, secondary fabrication,
and nonnuclear component fabrication. Consequently, Pantex was not considered
as a reasonable alternative for these missions. Pantex was not considered
as a reasonable site alternative for stockpile stewardship facilities as
explained in section 3.1.2.1.
Pantex has essential capabilities to support the future stockpile management
program. In selecting reasonable alternatives for future stockpile stewardship
and management missions, however, DOE found it to be unreasonable to address
alternatives for new missions where no core capability for that new mission
was present at the site. In addition, DOE sought alternatives that tended
to further consolidate and streamline the infrastructure for the Program
because of the overall general reductions in work to be performed. For these
reasons, it was determined to be unreasonable to consider stewardship
experimental capabilities and plutonium pit production at Pantex, just as
it was unreasonable to consider relocation of the weapon A/D mission to sites
which had no core capability or facility infrastructure to deal with nuclear
explosives.
The commentors ask how the current Stockpile Stewardship
and Management Program minimizes the impacts on weapons performance due to
inadvertent or unavoidable changes in production methods. One commentor believes
that the statement that surrogate testing will be used to keep the weapons
database current is misleading. The commentor suggests that one method is
to devote a new effort to document the details of the current production
methods and to establish procedures which will minimize the changes in weapons
performance resulting from inadvertent or unavoidable incremental changes
in the weapons stockpile. Some commentors express concern that surrogate
testing while useful does not ensure unpredicted changes in performance.
In addition, commentors do not believe that the PEIS adequately focuses on
resources devoted to surrogate testing, the stabilization and preservation
of manufacturing capabilities, and the need for weapons experts to participate
in the decisionmaking process.
The commentor feels that the overall policy direction
is fatally flawed and leading completely in the wrong direction. The commentor
states that the overall policy direction leads the environmental study to
worry about such minutiae as one fatal cancer every 5 million years when
they are concerned with the nuclear safety of the world involving real weapons
of mass destruction, literally tons of plutonium, and an environmental
mess.
The commentor states one of the fundamental flaws of
the Draft PEIS is the outdatedness of all LANL environmental data and feels
that referencing the 1992 LANL Environmental Surveillance Report as "LANL
1994b" is deceptive.
The commentor states that the Draft PEIS fails to describe
the only programmatic alternatives actually considered, namely Stockpile
Stewardship and Management and No Action alternatives, in a way that allows
useful comparison. For stewardship, the only alternative to building the
proposed facilities is a No Action alternative continuing operation of existing
facilities with the same function. The commentor states that the Draft PEIS
fails to describe the No Action alternative in a comprehensible manner. The
commentor contends that the No Action description is poorly written, confusing,
and does not provide information sufficient to inform the reader of the actual
activities it encompasses. The commentor states that the No Action alternative
does not describe currently existing operations and facilities at DOE
sites--rather, it is an arbitrarily chosen set of "not stockpile stewardship
and management" activities, some of them in fact part of the stockpile
stewardship and management programs, which are expected to be in operation
almost a decade from now. The commentor believes that the PEIS does not
adequately delineate what the No Action set of facilities are at any given
site. This renders it virtually useless for comparison with the already too
narrow range of alternatives, according to the commentor. The commentor further
argues that the deficiency of the No Action alternative alone is sufficient
reason to withdraw the PEIS and republish the draft. One commentor stated
that the use of a specific date for ground-breaking (i.e., September 1995)
was inappropriate to define the No Action alternative.
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Response: In accordance with NEPA, the PEIS assesses
the No Action alternative. The No Action alternative is described in broad
terms in section 3.1.4, and in more detail in chapter 4 and appendix A of
the PEIS. Under No Action, DOE would not take the actions proposed in the
PEIS, but would continue with existing operations. For stockpile stewardship,
this means continuing the existing activities at LANL, LLNL, SNL, and NTS
related to stockpile stewardship. In order to aid the reader's understanding
of the major facilities that make-up the No Action alternative for stockpile
stewardship, tables have been added to the site descriptions in appendix
section A.1 of the PEIS.
During preparation of the Draft PEIS, the September 1995 planning assumption
was used as one of the considerations in determining whether a new facility
or upgrade would be part of No Action. However, it was not the only
consideration. DOE also considered whether a particular facility was addressed
in prior NEPA documentation, whether a facility met the requirements of the
CEQ for an interim action, and whether a facility or a modification was the
continuation of an existing mission. The Final PEIS contains a more appropriate
description of the rationale for No Action. As stated in the Final PEIS,
the No Action alternative for this PEIS is defined in a way that takes into
account the fact that DOE for decades has had in place a program for the
stewardship and management of the nuclear weapon stockpile. Consistent with
CEQ guidance, the No Action alternative consists of those facilities necessary
to maintain the status quo in terms of DOE's current program direction. These
consist primarily of existing facilities where DOE conducts weapons activities,
including modifications to those facilities necessary to maintain their current
mission capabilities. However, the No Action alternative also includes a
small number of minor new facilities that will also be needed simply to maintain
current mission capabilities at individual sites. Finally, the No Action
alternative includes two major new facilities which are proceeding independent
of this PEIS, and for which DOE has prepared separate EISs under the interim
action provisions of the CEQ regulations. These EISs are the PEIS for Tritium
Supply and Recycling (DOE/EIS-0161) and the DARHT EIS (DOE/EIS-0228).
The commentor wants to know what evacuations plans
have been developed in the event of a nuclear accident or catastrophic fire
at LANL. Because of the limited egress in and out of the Los Alamos region,
the lack of well thought out and publicized evacuation plans can have grave
consequences.
The commentor states that the Stockpile Stewardship
and Management Program is not described in a manner which would allow for
meaningful comparison with other true program alternatives. The commentor
states that major parts of the Program, including facilities and actions
which are incomplete or have not been started, have been eliminated from
consideration, including for example, DARHT and tritium production facility
options. DOE has initiated or completed hundreds of millions of dollars worth
of new facilities and facilities upgrades throughout the Complex, apparently
implementing portions of the Program which the reconfiguration PEIS was supposed
to review and the commentor contends that this refurbishment of the Complex
in the absence of programmatic review has substantially narrowed the range
of options which DOE conceives as feasible. The commentor believes that the
public would have been far better served by using this PEIS for a comprehensive
look at the environmental impacts of the full Stockpile Stewardship and
Management Program, the Complex of the future as envisioned by DOE, in comparison
with other programmatic options (denuclearization, remanufacture, and such)
for managing the nuclear arsenal (which citizen groups have been demanding
for 5 years). Instead, the commentor states that the end result of 5 years
of reconfiguration is the presentation to the public of a fait accompli,
with the fundamental policy decisions already made and major program components
(e.g., DARHT) already underway.
The commentor asks if DOE has integrated the PEIS with
the DOD mission.
The commentors believe that the Draft PEIS does not
analyze a range of reasonable programmatic alternatives to meet the goal
of maintaining the stockpile safely in accordance with treaty obligations.
The commentors contend that the analysis in the Draft PEIS suggests that
the debate over stockpile stewardship and management is over and that the
program alternative has already been determined. According to the commentors,
these are fundamental problems which prevent meaningful participation by
the public and obfuscate informed analysis by decisionmakers. The commentors
believe that DOE should withdraw the Draft PEIS and prepare a revised Draft
PEIS, while all programmatic decisions and activities are put on hold. The
revised Draft PEIS should analyze "maintenance," "remanufacturing," interim
stockpile sizes, and a "zero" stockpile case--both with and without the
capability to reconstitute the arsenal--which is based upon a scenario of
global reduction and elimination of nuclear weapons in compliance with Article
VI of the NPT over time periods ranging from 15 years to the projected lifetime
of the proposed facilities (on the order of 40 years).
The commentors believe that the PEIS should include alternatives examining
the impacts of a policy course of reduction of nuclear weapons, ultimately
resulting in their elimination pursuant to U.S. obligations under Article
VI of the NPT. The commentors state that the PEIS should analyze the
environmental impacts for a stockpile size of less than 1,000 weapons. Several
commentors, noting the NPT calls for a move toward disarmament, believe that
the 0 to 100 stockpile size is a reasonably foreseeable situation and should
be analyzed. Other commentors argue that a zero-level stockpile should be
considered because it would satisfy nonproliferation obligations and there
is overwhelming public support for such an idea. One commentor questions
the rationale for the stockpile sizes assessed in the PEIS. More specifically,
the commentor implies that the lower case 1,000 weapons stockpile is not
well supported. Another commentor disagrees with DOE's assertion that "stockpile
management capabilities are independent of stockpile size."
In one commentor's opinion, the combination of an extremely one-sided analysis
of potential effects on the weapons nonproliferation climate, the elimination
from detailed analysis of all substantive program alternatives to the proposed
action, and technical analysis which conclude that a large complex can be
rebuilt and operated with few impacts at facilities with still unsolved waste
and contamination problems, leaves little doubt that the purpose of this
Draft PEIS is "to justify decisions already made" (40 CFR 1502.5).
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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 while still fully complying
with the treaty and national security policy constraints established
independently from the Stockpile Stewardship and Management Program. DOE
also believes that the PEIS adequately assesses the cumulative impacts of
proposed 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 not producing new-design
nuclear weapons or conducting underground nuclear testing (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 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 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 and
reliability, and thus are not reasonable.
Since the end of the Cold War, the United States has significantly reduced
the size of its nuclear weapons stockpile and the DOE has dismantled more
than 8,000 nuclear weapons. At the present time, the United States is further
downsizing the nuclear weapons stockpile consistent with the terms of the
START I Treaty, and DOE is continuing dismantlement. The United States has
recently ratified the START II Treaty and is hopeful that Russia will likewise
ratify this treaty. DOE acknowledges that further multilateral negotiated
reductions in the United States nuclear weapons stockpile could occur. However,
as discussed below, the negotiations required for such reductions are likely
to stretch well into the next century. Therefore, DOE believes the three
stockpile sizes utilized for the analysis in the Stockpile Stewardship and
Management PEIS fully account for future requirements while still being
consistent with and fully supportive of the goals of Article VI of the NPT.
Two of the three 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 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 reduc-
-
tions. Chapter 2 of the PEIS explains the complexity
of this process. DOE does not believe it reasonable to speculate with a large
number of arbitrary assumptions (section 2.2), and has selected a range of
stockpile sizes appropriate for the analysis and consistent with relevant
policy documents. The "low case" 1,000 weapon stockpile represents a hypothetical
case used for the purpose of a sensitivity analysis on manufacturing capacity
decisions. No specific DOE force structure projection corresponds to the
low case assumed stockpile. However, stockpile sizes in this range have been
proposed by others (see for example Foreign Affairs, Spring 1993).
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 is 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 plant 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 closures.
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.
In conclusion, as a result of the START I Treaty, START II protocol, and
the 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.
Regarding the comment that DOE should prepare a revised Draft PEIS, DOE believes
that the Draft PEIS was adequate. The Draft PEIS assessed the direct, indirect,
and cumulative environmental impacts of the reasonable alternatives for the
proposed action and the No Action alternative. In response to public comments
on the Draft PEIS, DOE has made changes to the Draft PEIS as described in
section 1.8 of the Final PEIS. Additionally, DOE has prepared this Comment
Response Document which describes the comments received on the Draft PEIS
and DOE's responses to those comments.
The commentor suggests that DOE provide a definition
of hazardous chemicals in the glossary or possibly use the term "hazardous
substances."
The commentor states that the most egregious deficiency
of the PEIS is the total failure to include current Congressional legislation
(National Defense Authorization Act for Fiscal Year 1996, Title XXXI,
particularly sections 3137 and 3153) and associated national security policy
guidance. The conclusions of the House and Senate markups for fiscal year
1997 must also be considered. The PEIS must be redone based on the full range
of national security policies both Congressional and Presidential, according
to the commentors.
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Response: Chapter 2 of the PEIS discusses the major
national security policy considerations that are most relevant to the PEIS
analysis. Included in that discussion are PDDs, Congressional legislation,
DOD NPR, the NWSM, and four related treaties. While that list of national
security policy considerations is not meant to be exhaustive, it does represent,
in DOE's view, the most significant national security policy overlays that
define the Stockpile Stewardship and Management Program conditions for the
reasonably foreseeable future. Based on our understanding, the Draft PEIS
analysis is consistent with the current Congressional legislation (National
Defense Authorization Act for Fiscal Year 1996, Title XXXI). The Final PEIS
analysis takes into account, as appropriate, any other relevant 1997 legislation.
The commentor refers to section 3.3.4.2 and asks what
are the "prohibitively expensive alternative approaches" to the High Explosives
Pulsed-Power Facility (HEPPF).
The commentor refers to section 3.5 and states, after
all the concern expressed about subtle changes in materials and processes,
emerging technologies propose continuing work in areas which represent
significant changes in processes and materials. The commentor asks if the
intent to protect technical capability is to have technologies available
in case of a resumption of testing or a breakthrough in experimental technology,
or whether there is an expectation that DOE can just go ahead and use them
regardless of our previous protestations.
The commentor refers to section 2.3.4, and the different
materials that are referred to in this section, whose aging characteristics
are not well understood. The commentors question whether these materials
could not be replaced without compromising the military objectives of the
stockpile.
The commentor expresses the opinion that Pantex should
be the preferred site for future Complex missions.
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Response: One important strategy of the Stockpile
Stewardship and Management Program is to maximize the use of existing
infrastructure and facilities as we transition to a smaller and more efficient
Complex in the 21st century. Consequently, only those sites with an existing
infrastructure or facilities capable of supporting a given stockpile stewardship
or stockpile management mission are considered reasonable site alternatives.
Sites without a technical infrastructure or facilities for a given mission
would require significant new construction that would be costly and would
create excessive technical risk compared to sites with existing missions.
Pantex is only being considered for weapons A/D, HE fabrication, and storage
of nuclear materials.
With regard to stockpile stewardship, the majority of the Nation's core
competencies in nuclear weapons, as well as the facilities used for stockpile
stewardship, reside at the weapons laboratories and NTS. The President has
determined that the continued vitality of all three DOE weapons laboratories
and NTS remains essential to meet the requirements of stockpile stewardship
as the United States enters into a CTBT regime. Accordingly, to locate
stewardship activities at sites without the knowledge base and infrastructure
would be counterproductive to the development of science-based stockpile
stewardship. Further, two of the proposed stockpile stewardship facilities,
the Atlas Facility and CFF utilize existing facility infrastructure at LANL
and LLNL, respectively.
Commentors would like DOE to reconcile a declining
budget at Pantex with an increasing workload. The commentors state that the
fiscal year 1997 budget as proposed will lead to a reduction in force at
Pantex. One commentor, noting that the Stockpile Management Preferred
Alternatives Report reveals that Pantex, but not Y-12 or KCP, will undergo
this decrease in budget, asks why Pantex is suffering budget cuts if the
workload is constant and the other production facilities are not suffering
budget cuts.
The commentor states that the enduring stockpile was
built from the late 1970s to the early 1990s, approximately a 12-year period.
Assuming the stockpile has 8,400 weapons in it and that the life of a weapon
is about 30 years, in 2008, we would have to replace the stockpile at a rate
of 700 units per year. DOE is sizing the Complex to handle about 300 units
per year. The commentor would like DOE to explain this disconnection and
what it proposes to do about it.
The commentors state that they have no confidence in
DOE due to a past history of lies and deceptions in the nuclear program.
One commentor states that DOE should address the deceptions in the nuclear
program. Another commentor believes that a war crime tribunal should be
established to review past mistakes of DOE in order to charge them with first
degree murder and hang them.
The commentor believes the stated rationale that the
proposed Stockpile Stewardship and Management Program is needed to maintain
stockpile safety and reliability does not square with available data. The
commentor states that without DOE's rationale for the Stockpile Stewardship
and Management Program, it would be difficult for DOE to justify operating
current facilities, much less build new ones, since official policy now proclaims
that no new weapons will be produced. The commentor references that Sandia
Stockpile Life Study which found that with surveillance and repair, U.S.
nuclear weapons retain high safety and reliability. Further, defects caused
by aging are rare and have not increased over time and the stockpile is not
now reaching an advanced age due to scheduled retirements under arms reduction
agreements. The commentor opines that weapons are becoming safer as older
weapons types are retired. According to the commentor, the study adds weight
to previous studies and expert opinion showing that the safety and reliability
of the U.S. nuclear weapons stockpile can be maintained under a comprehensive
nuclear testing ban. Once corrected for additional weapons systems, the
commentors believe that the 1995 Stockpile Surveillance: Past and
Future report essentially validates the 1993 Stockpile Life Study. The
commentor states that key implication of the stockpile study--the U.S. arsenal
is highly reliable, underground testing has rarely been used to confirm the
reliability of stockpiled weapons, and future defects can be fixed with existing
surveillance programs and facilities--are highly relevant to the proposed
Stockpile Stewardship and Management Program.
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Response: The underlying rationale for the Stockpile
Stewardship and Management Program is the need to ensure the continued viability
of this Nation's nuclear deterrence. The commentor references the Sandia
Stockpile Life Study, for which a set of viewgraphs for a status briefing
were prepared by SNL in 1993. However, the data used to develop the interim
study arose from a database which was recognized to be incomplete and inadequate
in that much data, particularly that relating to problems found through methods
outside the DOE's formal Stockpile Evaluation Program, were incompletely
or inconsistently documented. In particular, findings and "actionable" findings
associated with the nuclear package (including the weapons primary and secondary)
were not completely documented. DOE understands that Sandia never completed
a stand-alone stockpile life study. Instead, at the request of DOE, the three
weapons laboratories (LANL, LLNL, and SNL) subsequently conducted a joint
study, Stockpile Surveillance: Past and Future (Johnson et al., 1995), which
has updated Sandia's preliminary data to provide a more accurate look at
the condition of the stockpile. This study was made publicly available in
1995 and was discussed in the PEIS. Sandia's preliminary findings were
reassessed, corrected, and incorporated into the tri-laboratory study. DOE
does not agree that Sandia's preliminary study "undercuts" the Stockpile
Stewardship and Management Program, as suggested by commentor; rather, this
preliminary study examined some of the types of problems with the enduring
stockpile that led to the development of the Stockpile Stewardship and Management
Program.
The commentor asks what the environmental, social,
cultural, and spiritual impacts, of having stockpile stewardship including
DARHT, on all the communities near Los Alamos, the people, the air, the flora,
the fauna, aquifers, livestock, agriculture, rivers, streams, businesses,
and tourism of the states of Arizona, Colorado, New Mexico, Texas, and Utah
and on the Nation.
The commentors express opposition to all current and
future nuclear weapons work at LANL including work associated with the Stockpile
Stewardship and Management Program. Another commentor questions the selection
of LANL based on allegations of sexual harassment at Albuquerque and pornographic
Internet "play" at Sandia.
Commentors believe Pantex is the wrong place for plutonium
storage. Another commentor believes DOE has decided that long-term storage
in Zone 4 is unsafe. One commentor states that he does not want Pantex to
become the next Rocky Flats where the only jobs are for nuclear waste handlers
and regulators. Another commentor believes plutonium is too dangerous to
transport.
Some commentors believe the PEIS should include the
new mission of recertifying dispositioned HEU and plutonium in section 2.4,
Purpose and Need, and section 3.2, Stockpile Management. One commentor cites
section 3.5.4 and questions why explosive materials are disposed of, but
plutonium and HEU are dispositioned. The commentor asks if a pit and
plutonium/HEU residue are classified, and thus dispositioned, why would HE
that is classified be disposed of. Commentor also asks why is classified
HE potentially part of "alternative disposal technologies" and not "alternative
disposition technologies." Another commentor asks if section 2.4.2, Industrial
Base, should include a mission for recertifying non-fissile materials placed
into storage and disposition. Another commentor asks what is excess explosive
materials and what is the difference between that and surplused plutonium
and HEU.
The commentors refer to appendix section A.3.1, and
based on the estimate of 200 weapon parts per weapon, asks the following
questions: how many parts are backlogged waiting for sanitization and
demilitarization; if a backlog exists, what are the impacts of downsizing,
relocating, and no action, on this backlog; who is responsible for sanitization
and demilitarization; why isn't this discussed in infrastructure; why aren't
the impacts assessed; and what is the through-put capacity of sanitization
and demilitarization for each of the 200 estimated parts; are these processes
readily available at other sites; and has DOE considered the nonproliferation
capability in selecting alternatives.
The commentors believe SRS should receive a major role
in the programs as determined in the ROD because it has the people, facilities,
security, infrastructure, experience, and support from adjacent communities
that will assist DOE in accomplishing the desired missions without adversely
affecting the environment and saving taxpayers millions of dollars.
The commentor states that it is impossible to reduce
the risk from nuclear weapons accidents to zero; however, and in particular,
there will always remain some risk that plutonium will be dispersed by fire
or explosion. The commentor believes the simplest and best ways to further
minimize this possibility are operational and deployment changes that reduce
the chances of an accident and risk to the public and further retirements
which lead to a smaller arsenal.
The commentor states that the citizens of Los Alamos
are entitled to know the current environmental conditions of LANL before
deciding whether the University of California has been good steward of existing
hazardous materials. Another commentor believes there is serious mismanagement
of the laboratory by the current contractor resulting in continuing
non-compliance with environmental laws and NEPA violations.
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Response: DOE is committed to fully complying with
all applicable environmental statues, regulatory requirements, and Executive
and internal orders. All DOE facilities comply with the Emergency Planning
and Community Right to Know Act (42 USC § 11001), which requires facilities
to report the release of extremely hazardous substances and other specified
chemicals; to provide material safety data sheets; and to provide estimates
of the amounts of hazardous chemicals onsite. The conditions at LANL are
described in section 4.6.2 of the PEIS.
In general, contracting is not subject to NEPA review (see 10 CFR 1021, subpart
D, appendix A, except regarding procurements for developing new or emerging
technology).
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Although the commentor correctly points out that operations
at LANL have occasionally been found to be out of compliance with various
environmental laws, DOE and LANL management have made good faith efforts
to bring laboratory facilities into compliance in a timely manner. DOE expects
its management and operating contractors to operate its facilities in compliance
with all Federal, state, and local laws, and the University of California,
as management and operating contractor for LANL, has pledged to do so. DOE's
confidence in the University of California is reflected in DOE's recent decision
to extend the University's management and operating contract for LANL, LLNL,
and Lawrence Berkeley Laboratory for another 5 years.
The commentor makes a number of allegations, most of which are unrelated
to the University's management of the laboratory. While the courts found
that an EIS should be prepared for the DARHT facility, DOE is unaware of
any other NEPA violations, although DOE's Tiger Team recommended in 1991
that a site-wide EIS be prepared for LANL; regardless, the NEPA process is
conducted by DOE, not the University of California. DOE is unaware of any
refusal on the part of the university regents to meet with the citizens or
legislators of New Mexico, subject to their schedule constraints, and the
regents have held several public meetings in New Mexico on the subject of
LANL operations. The laboratory conducted both a voluntary separation program
and a reduction in force in 1995 to streamline its operations; these were
conducted within the University of California personnel procedures as they
apply to LANL and with the support and approval of both the University of
California and DOE. Statistics compiled by LANL do not indicate that these
actions disproportionately affected minorities or ES&H Division personnel.
This matter is the subject of current litigation. DOE supports the LANL practice
of debating opposing scientific theories in an atmosphere of academic freedom,
and does not agree that the integrity of either the laboratory's environmental
or scientific programs are under question.
The commentor believes that the PEIS does not make
a realistic distinction between strategic and surplus plutonium. The commentor
believes that the effort to maintain two-thirds of the plutonium in the United
States is evidence that the country is not serious about disarmament and
also gives rise to the suspicion that some effort is being made towards using
plutonium for commerce.
The commentor asks where fabrication of enriched uranium
primaries will be assigned.
One commentor requests that economy and safety be the
first considerations in Stockpile Stewardship and Management Program. The
commentor also expresses concern about the cost of cleanup in the event of
a catastrophe. Another commentor does not want decisions concerning the location
of operations and activities to fall into the "not in my back yard" syndrome.
The commentor believes impacts should be minimized to all workers, families,
and communities; and to the environment.
The commentor asks, relative to section 3.2.2, what
ORR DP assignments are not performed by Y-12.
The commentors request an explanation from DOE on why
LANL and LLNL stockpile management budgets show projected increases from
1996 to 2004 since the United States has terminated the development of new
nuclear weapons. Commentors reference the Stockpile Management Preferred
Alternatives Repor t, pages 26 and 30. One commentor asks if these projected
increases are based on transferring of missions from the production plants.
A commentor found the Draft PEIS unclear with respect
to the intended aims and plans that are being proposed for the Panhandle
area. Other commentors reiterated the community's adamant position that all
work performed at Pantex continue to be done in a fashion that protects the
environment including national resources such as the Ogallala aquifer and
agricultural land.
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Response: Pantex was considered a reasonable alternative
site for the weapons A/D mission and the HE fabrication mission. The weapons
A/D mission is described in section 3.4.1, and includes provisions for
nonintrusive modification pit reuse and strategic storage of plutonium and
uranium in the form of pits and secondaries. Secondaries would not be stored
at Pantex if Y-12 retains the secondary and case fabrication mission.
Additionally, storage of all or a portion of the strategic reserve could
be at another site, depending on DOE decisions regarding the Storage and
Disposition PEIS. The HE fabrication mission is described in section 3.4.5,
and includes HE procurement, formulation, component fabrication,
characterization, surveillance, disposal, and storage. Analysis of the water
and land-use impacts associated with each Pantex alternative were included
in the Draft PEIS. Selection of the preferred alternatives was accomplished
with full weight given to the results of this analysis. The Analysis of Stockpile
Management Alternatives report and the Stockpile Management Preferred
Alternatives Report are available for public review at the DOE Public Reading
Rooms near each site.
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, and protecting the environment. Section
4.14 of the PEIS describes the regulations and requirements under which all
DOE sites conduct their operations during the normal course of their work
activities, including potential accidents and associated human health and
environmental consequences of an accident.
The commentor believes that the Draft PEIS fails to
consider adequately the entire range of current and proposed actions connected
with the Stockpile Stewardship and Management Program and reasonable alternatives
to such actions. The commentor states that because of substantial changes
in the nature and purpose of DOE's atomic energy defense activities, as reflected
in the design and implementation of a long-term Stockpile Stewardship and
Management Program, the PEIS must consider in a comprehensive manner all
related, connected, cumulative, and similar actions designed to achieve the
goals of stockpile stewardship and management, including activities asserted
to be ongoing, as well as those described as "next generation."
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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 not producing new-design
nuclear weapons or conducting underground nuclear testing (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 nuclear 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 the 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 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.
The commentor thinks that the NTS table 3.2.9-1, should
be modified to include subcritical tests, references to high explosive and
dynamic experiments, testing of nuclear weapons, and testing of weapon effects.
The commentor states that DOE should not proceed with
the stockpile stewardship program until it has prepared and circulated a
new Draft PEIS, considered and responded to all comments, and issued a Final
PEIS and ROD.
Due to its focus away from consolidation, the commentor
believes that the Stockpile Stewardship and Management Program is very different
from Complex 21.
The commentor states that nuclear weapons stockpile
stewardship includes storage security, safety, inspection, and maintenance
so that the operability of any stored weapons are known and satisfactory.
The commentor further suggests that those who devise plans for stockpile
stewardship should remain aware of the technological advances in remote drilling
control that might make previously secure storage locations less so.
The commentor states that the Special Nuclear Materials
Research and Development Laboratory proposal is still alive in the form of
various proposed upgrades to LANL's Chemistry and Metallurgy Research building
and that the relationship of the plutonium processing facility at TA-55 (PF-4),
and the Chemistry and Metallurgy Research building is made clear in the quote
in the fiscal year 1997 LANL Capital Asset Management Plan, Chemistry and
Metallurgy Research Activity Data Sheet, page A-17. The commentor asserts
that the Stockpile Stewardship and Management PEIS, with respect to future
activities at LANL, is merely rubber stamping what the laboratory has been
pursuing for a number of years.
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Response: In the late 1980s, DOE initiated a NEPA review
for a proposed facility named the Special Nuclear Materials Laboratory at
LANL, and issued its Notice of Intent (NOI) to prepare an EIS for the project
(55 FR 1251, January 12, 1990). The new laboratory was proposed to replace
the Chemistry and Metallurgy Research building. (Reconfiguration PEIS NOI,
56 FR 5594, February 11, 1991). DOE has since dropped its proposal to construct
the Special Nuclear Materials Laboratory, since with a smaller nuclear material
requirement the capacity of the Chemistry and Metallurgy Research building,
if upgraded, remains adequate.
The Special Nuclear Materials Laboratory was proposed at a time when there
were several new weapons systems in various phases of the development and
production cycle and DOE was still operating its Rocky Flats Plant. At that
time, DOE and LANL believed that a greater analytical chemistry capability
was needed at LANL to support those efforts. DOE notes that a great deal
of the background information raised by the commentor reflects the evolution
that has occurred over the past 7 years as the Nation has made significant
changes in its nuclear deterrence policy. At many times since 1990, the nuclear
materials support work performed at LANL has been redirected by DOE to reflect
the changing national priorities.
The former special nuclear materials proposal is not embodied in the current
plans to upgrade the 44-year-old Chemistry and Metallurgy Research building,
as the commentor alleges. DOE has prepared an EA for the Chemistry and Metallurgy
Research upgrades (DOE/EA-1101), and has issued that EA in draft for public
review and comment. The commentor reviewed the draft EA and extensively commented
on that document. At this time, DOE proposes to upgrade space in the Chemistry
and Metallurgy Research building only as needed to support the existing set
of LANL operations. Two complete wings of the Chemistry and Metallurgy Research
building are in the process of being placed in a safe standdown mode, and
another wing has been converted to office space only. The analytical laboratory
space in the wings currently proposed to be upgraded are those wings that
support LANL's existing mission in the nuclear weapons program, deep space
probes, nuclear material stabilization programs (including waste management)
and environmental restoration.
As noted in this PEIS, in the event that DOE should choose to implement an
expanded Stockpile Stewardship and Management Program at LANL, further
renovations to the Chemistry and Metallurgy Research building would be needed
to support pit production or other missions analyzed in this PEIS. If LANL
is selected for an expanded production role as a result of the Stockpile
Stewardship and Management ROD, then some activities could be moved into
the Chemistry and Metallurgy Research building from building PF-4 at TA-55
into currently unused space that would then be renovated for this purpose.
The current proposal to upgrade the analytical chemistry space in the Chemistry
and Metal-
-
lurgy Research building sufficient for existing needs
would also support these future needs with no additional building
renovation.
The commentor also references the LANL 1993 Strategic Plan. The sketch of
a fully renovated Chemistry and Metallurgy Research building referenced in
the 1993 plan included essentially all of the building. However, in 1995
DOE and LANL agreed to pursue only those upgrades needed to support the existing
nuclear materials mission assignments at LANL which have resulted in changes
from the 1993 plan. For example, since the 1993 plan, two complete wings
of the Chemistry and Metallurgy Research building are in the process of being
placed in a safe standdown mode, and another wing has been converted to office
space only.
The Capital Asset Management Plan is an annual listing, for planning purposes,
of potential projects that might be required to support current and future
missions. DOE requires an annual Capital Asset Management Plan report from
all its weapons complex sites. As such, it is not inappropriate for LANL
to use this vehicle to alert DOE to facility improvements or new structures
that might be required in the event that an enhanced stockpile stewardship
and management mission is assigned to LANL.
It is true that DOE has determined that, under the existing stockpile stewardship
and management activities that have been ongoing for many years, facilities
at LANL will have to be maintained, and in some cases, repaired or upgraded,
to allow LANL to continue to fulfill its existing mission. Far from being
a "stunning admission" that future assignments are already being implemented,
DOE believes that it is simply good management practice to keep its considerable
real property--its buildings and other infrastructure--in safe, sound, and
operating order.
The commentor states that the Stone and Webster document
referenced in the Stockpile Stewardship and Management PEIS was not made
available to the public.
The commentor refers to tables 3.7.1-1 through 3.7.1-5
and asks if anyone has placed these numbers into a common reference frame.
According to the commentor, the LANL direct employment numbers, utility
requirements, and some of the discharge numbers do not make sense.
The commentor refers to Volume I, tables 3.4.4.2-2,
3.4.4.3-2, 3.4.4.4-1, 3.4.4.4-2, 3.4.5.2-2, 3.4.5.3-2, and 3.4.5.4-2 and
requests that the term "surge operations" be defined in chapter 9,
Glossary.