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| | | published Friday, September 19, 2008 | 1678 Views :: 0 Comments | |  |
General Comments
Mavis Belisle
DOE/NNSA is basing its approvals for current and future operations at the Pantex Plant on a previous environmental impact study that is out of date [Document Citation: Continued Operation of the Pantex Plant and Associated Storage of Nuclear Weapons Components (ROD published in 62 FR 3880, January 27, 1997)]. It does not currently reflect
• the current footprint of the operational area of the Plant,
• accurate boundaries of the Plant, given current access and adjacent land purchase activities underway by Pantex,
• the existing facilities on-site, given that buildings have been decommissioned and demolished and others constructed,
• technologies that have come into existence in the past approximately 13-years, and
• the nature of security in a post-9/11 world.
DOE/NNSA has failed to justify the selection of the Pantex Plant for its Plutonium Consolidation proposal given the fact that groundwater is a finite regional resource that is currently being mined from the Ogallala Aquifer in the Texas Panhandle region. Thus, the water resources required for this project is unreliable in the long-term.
Open-air Burning and Open-air Detonation
Open-air burning and open-air detonation at Pantex and all other DOE/NNSA sites should not occur. The environmental impacts for open-air burning and open-air detonation have not been evaluated and reported (for example, plume and/or dispersal air modeling have not been conducted for these operations).
DOE/NNSA did not explore any alternative to either open-air burning or open-air detonation. If no technologies currently exist as an alternative, DOE/NNSA should so state.
Pit Storage Concerns
The goal of pit storage and disposition is to provide an environmentally safe and secure pathway, and facilitate minimal transportation needs and minimal worker exposures when pits must be moved for evaluation or other activities. In contrast, plutonium disposal through MOX would result in substantial risks during transportation to workers and the public. Workers would be exposed during loading, unloading, and during transportation. In addition, conversion of plutonium to MOX will create additional risks and exposures and environmental contamination. Thus, DOE/NNSA should revisit and reconsider plutonium immobilization and/or vitrification as part of the plutonium consolidation process.
Any use of plutonium for nuclear power by utility companies increases the accessibility of nuclear sources to terrorists.
Is the proposed pit storage facility to be constructed underground? Details seemed sketchy. If not, how will the new storage facility address safety and security issues? These concerns have not been addressed.
Pits remaining in storage at Pantex
Consolidation of pits in storage in a new facility in Zone 12 provides some safety and security benefits, but has the potential to increase other risks. The location would place additional mounds of plutonium in the proximity of operations to which it was more distant when stored in Zone 4.
If, on the other hand, new environmentally safe and secure facilities were built in Zone 4, there would be the opportunity to open Zone 4 to international inspections as current international treaties require, without exposing assembly/disassembly and other routine activities at the Plant to additional security risks.
Pits kept at the site should be made as difficult as possible for reuse, which would minimize efforts for terrorists to acquire these pits. Examples are ______. DOE/NNSA did not examine methods that would make the nuclear materials undesirable to terrorist threats.
DOE/NNSA did not consider any of these reasonable alternatives for storage and disposition, and should do so now.
Other Unanswered Questions
Is some or all of the proposed “environmental testing” for new sites potentially more damaging to the environment than the environmental testing that has been conducted previously at other sites?
Unfunded Environmental Liabilities
DOE/NNSA has deprived the public of the use of its natural resource due to contaminated groundwater that has resulted from past Pantex operations and waste management methods. The public loss of its groundwater carries with it a financial liability under CERCLA (Natural Resource Damage Assessment) and DOE/NNSA should disclose its estimates for this future liability at Pantex and other sites.
For example, Pantex acknowledges that its groundwater will be contaminated for more than 100 years. Also, a document titled Pantex Plant FY 2006-2015 Ten-Year Comprehensive Site Plan acquired under the Freedom of Information Act disclose DOE/NNSA estimates for Pantex future environmental liabilities. This information should be included in the PEIS.
Groundwater
Although DOE/NNSA states that its water needs from the region’s sole source aquifer is miniscule relative to that used by agriculture and the City of Amarillo, the Ogallala Aquifer is a finite resource and current use is not sustainable.
While agricultural uses could respond rapidly to groundwater declines and rising energy costs, the DOE/NNSA operations at Pantex Plant lacks that flexibility, especially given the enormous investment of public funds in the approved and formalized procedures of operations and in construction of the proposed facilities, not to mention the ones already in existence.
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