DOE/EA-0812 ENVIRONMENTAL ASSESSMENT FOR INTERIM STORAGE OF PLUTONIUM COMPONENTS AT PANTEX LETTERS RECEIVED ON THE PRE-APPROVAL ENVIRONMENTAL ASSESSMENT AND THE REVISED PRE-APPROVAL ENVIRONMENTAL ASSESSMENT AND PUBLIC MEETING VOLUME 11 JANUARY 1994 U.S. Department of Energy Albuquerque Operations Office Amarillo Area Office Pantex Plant P.O. Box 30030 TABLE OF CONTENTS VOLUME II, SECTION I LETTERS RECEIVED ON THE PRE-APPROVAL ENVIRONMENTAL ASSESSMENT VOLUME II, SECTION II LETTERS RECEIVED DURING THE 1WO-WEEK COMMENT PERIOD FOLLOWING THE DECEMBER 6, 1993 PUBLIC MEETING (DECEMBER 6 TO 20, 1993) Volume 11, Section 1 Letters Received on the Pre-Approval Environmental Assessment Document Author Affiliation 1001 Ann W. Richards, Governor State of Texas 1002 Alison A. Miller Texas Air Control Board 1003 Thomas A. Griffy University of Texas at Austin, Department of Physics 1004 C. Ross Schulke U.S. Department of Transportation Federal Aviation Administration 1005 Jeri Osborne & Family Crtizen Comments 1006 Auburn L. Kitchell University of Texas at Austin, Texas Bureau of Economic Geology 1007 Joseph A. Martillotti Texas Department of Health, Bureau of Radiation Control 1008 Boyd Deaver Texas Water Commission 1009 Tom Millwee, Chief Texas Department of Public Safety, Division of Emergency Management 1010 Wah Kelley City of Amarillo/Counties of Potter and Randall Emergency Management 1011 Dana O. Porler Citizen Comments 1012 Margie K. Hazlett (1) Citizen Comments 1013 Margie K. Hazlett (2) Citizen Comments 1014 Sam Day, Director N ukewatch 1015 Addis Charless, Jr. Panhandle Area Neighbors and Landowners (PANAL) 1016 Jeri Osborne Citizen Comments 1017 Jim Osborne Citizen Comments 1018 Bob Bullock, Lt. Governor State of Texas 1019 W.H. O'Brien Operation Commonsense 1020 Benito J. Garcia, Chief State of New Mexico, Environmental Department 1021 Lawrence D. Egbert, MD Physicians For Social Responsibility 1022 James Thomas Hanford Education Action League (HEAL) 1024 Jay R. Roselius, Courtly Judge Carson County 1025 William and Mary Klingensmith Citizen Comments 1026 Tamara Snodgrass Citizen Comments 1027 Portia Dees Citizen Comments 1030 Judy Osborne Citizen Comments 1031 Louise Daniel Citizen Comments 1032 Betty E. Barnard Citizen Comments 1033 Norbert Schlegal Citizen Comments 1034 48 signatures/form letter Citizen Comments 1035 Karen Son Citizen Comments 1036 Arjun Makhijani, Ph.D. lnstitute for Energy & Environmental Research 1037 Bishop Leroy T. Matthiesen Diocese of Amarillo 1038 Boyd M. Foster, President Arrowhead Mills 1039 Tonya Kleuskens, Chairman The Texas Nuclear Waste Task Force 1040 Carl L. King, President Texas Corn Growers Association 1041 Beverly Gattis Military Production Network 1042 Beverly Gattis Save Texas Agriculture and Resources (STAR) 1043 Mavis Belisle, Director The Peace Farm 1044 Margie K. Hazlett. (3) Citizen Comments 1045 Beverly Gattis Serious Texans Against Nuclear Dumping (STAND) of Amarillo, inc. 1046 Dan Morales, Attorney General State of Texas, Office of the Attorney General 1048 Doris & Phillip Smith Panhandle Area Neighbors and Landowners (PANAL) 1049 Jerome W. Johnson Panhandle 2000 1050 Senator Teel Bivins (Dist 31) The Senate of The State of Texas 46 letters forwarded from the State of Texas. Document numbers not necessarily sequential. STATE OF TEXAS OFFICE oF THE GOVERNOR AUSTIN, TEXAS 78 7 1 1 ANN RICHARDS Februaly 25, 1993 GOVERNOR The Honorable Hazel R. Olealy Secretaiy of Energy Washington, D.C. 20585 Dear Secretary Olealy: Enclosed are the comments rny office has received to date regarding the U.S. Department of Energy's Predecisional Environmental Assessrnent for Interim Storage of Plutonium Coniponents at the Pantex Nuclear Weapons facility. The Texas Attorney General's Office wiH forward their comments to you under separate cover. The state of Texas has made evety effort to comply with the March 2, 1993 extended deadline provided by the U.S. Department of Energy. However, I have been notified that a few individuals do need additional time to complete their reviews. Therefore, I respectfully request that DOE establish a finai deadline of March 16, 1993, to ensure that all interested parties are given eveiy opportunity to have their concerns addressed. There is no question tliat producing the environmental assessment was a long and painstaking effort requiring the dedication and skills of many talented individuals. Preparing an appropriate response to that document elicited the sarne level of effort. Rather than attempting to summarize the comments, and thereby run the risk of either misinterpreting or failing to give them the full weight and attention they deserve, I arn forwarding the comments to DOE exactly as they were received in this office. Thus, each submission stands alone and deserves a detailcd response to the various concerns expressed in that document. I direct your particular attention to the comments prepared by Texas state agencies and universities. Yua Ot iur RA 12428 AusitN, TI:Nm 78711 (512) 463-2000 (V,.1 ,0/(512) 475-3165(TDD) air ‘411 I. 1.1.1.114 The Honorable Hazel R. O'Leary February 25, 1993 Page Two Nevertheless, one inescapable fact is readily apparent: A number of the assumptions and conclusions stated in the docurnent simply cannot be verified without more inforrnation. report In addition, state officials believe that the methodologies used in the 1001/1 addressing the potential impact of a plutonium release to the Ogallala Aquifer, and the section addressing the Aircraft Hazard Analysis, are so 1001/2 fundamentally flawed that they must be revisited. hi their current form, it is impossible to determine whether the resulting conclusions are, in fact, valid. Once you have had an opportunity to evaluate the enclosed comments, I am confident you will agree that significant portions of the assessment require further study. Therefore, any attempt to endorse or reject the assessrnent at this time would be premature. I am most concerned about the 6-10 year inteiim storage period. Specifically, I 1001/3 want to know when this 10-year period officially begins and ends. I also need clear and definite information about what procedures will be followed if the plutonium is still sitting at Pantex at the end of the 10-year period. After my staff and other state officials have had an opportunity to review your answers to our questions, they would Iike the opportunity to rneet with the appropriate DOE officials. The meeting held in January with individuals from your headquarters in Washington, the area office in Albuquerque and from the Pantex plant was very productive and beneficial. If you have any questions or need additional information, please have your staff contact Roger Mulder in my office at 512/463-2198. Thank you for your cooperatiOn. There is no question that protecting the human health and safety and the -onment of the Pantex community is a challen oal, and a res.! sibility th t all of us share. Sincer y, N w. RICHA DS Governor TEXAS AIR CONTROL BOARD February 19, 1993 Mr. Roger Mulder. Director Special Projects Environmental Policy Division Office of the Governor P.O. Box 12428 Austin, Texas 787)1 RE: Methodology Used to Assess the Probability of Aircraft Impact with Zone 4 Pantex Nuclear Weapons Facility (Pantex) Structures Dear Mr. Mulder: Executive Summary The "Environmental Assessment(EA) for Interim Storage of Plutonium Components at Pantex," dated December 1992, finds an airplane crash to be an incredible event, that is the probability of the event is lcss than one-in-a-million. The EA employs a method of reducing the probability of a serious credible event into unlikely specialized events. This, it is claimed, eliminates the need to report the potential consequences of the specialized events in the safety analysis. I believe the probability calculations developed for the total aircraft population should not be assumed to have the same validity at the subpopulation level. 1 have reviewed the methodology used to assess the probability of aircraft irnpact with Zone 4 Pantex plant structures. This analysis is included as Appendix E in the EA. The modeling of an airplane crash into Zone 4 structures of the Pantex plant closely follows the methods developed in the 1976 Sandia report (reference 2 of Appendix E). However, the accident rates and effective areas used to calculate the probability of irnpact are greatly reduced from the values used in the 1976 Sandia National Laboratories (Sandia) report. Most importantly, the analysis performed in the Sandia report is used to assess the overall probability of aircraft impact with Zone 4 structures. The EA applies the same methodology and claims the estimates of probability are valid at the subpopulation level (specific types of aircraft). As the research and methodology were developed to estimate the probability for the general population of aircraft, the "stretching" of this analysis to estimate the probabilities for specific subclasses of aircraft substandally degrades the validity of the estimates generated. or...,:lan"-R, Texans working for clean air ,,„ Mr. Roger Mtdder, Director -2- February 19, 1993 Subdivision into Aircraft Subclasses is Used to Eliminate the Need to Consider the Impact 1002/1 of Certain Types of Aircraft vvitli Zone 4 Structures Initially, the EA finds the probability that an aircraft will impact a Zone 4 structure to be greater than one-in-a-rnillion. In other words, the chance of airplane impact with a structure scheduled for the interim storage of plutonium is calculated to be a credible event. However, the potential consequences of airplane impact with Zone 4 structures are not reported. The probability of impact is developed by dividing aircraft into four classes: air carriers, military aircraft, aerial application, and general aviation. The probability of impact for any specific class of aircraft, except general aviation, is calculated to be less than one-in-a-million. Thus the EA concludes, it is unnecessary to consider any class of aircraft except for general aviation. This is a clear deviation frorn the 1976 Sandia report, which concludes only that the probability of aircraft impact is 4.7 in 100,000 (4.7E-05).