8. NAVAL PROGRAM SPECIFIC

8.1 Preferences

08.01 (001) Preferences

COMMENT
Some persons expressed general opposition to one or more of the alternatives considered without
identifying technical reasons for the opposition.  Some of these expressions of opposition included the
following concerns:  Storage could last longer than planned.  The EIS and Record of Decision may not be
completed by June 1995.  Litigation over the sufficiency of this EIS could delay implementation.  An
alternative allowing removal from the shipyards might not be selected.  
RESPONSE
Some individuals oppose one or more of the alternatives identified by DOE and the Navy for the
transportation, receipt, processing, and storage of spent nuclear fuel.  Nevertheless, some alternative must
be selected since DOE has a considerable amount of spent nuclear fuel in existence.  To select an
alternative, the Navy is cooperating with DOE in this comprehensive EIS on spent nuclear fuel
management, including Naval spent nuclear fuel.  This EIS evaluates alternatives for spent nuclear fuel
management pending ultimate disposition.  Some of the alternatives which are being evaluated in the DOE
EIS will allow routine Naval spent nuclear fuel shipments to be resumed promptly.  Therefore, it is by no
means certain that storage at shipyards will be extended.

08.01 (002) Preferences

COMMENT
Some persons expressed support for one or more of the alternatives considered without identifying
technical reasons for their support.  Some of these expressions of support were based on such things as the
Navy's expertise, the amount of information and technology presented in the EIS, the safety or cost
effectiveness of the alternative supported, and the commentors' personal knowledge of the absence of
problems with Naval spent nuclear fuel and safety in the Naval Nuclear Propulsion Program in the past.
RESPONSE
DOE and the Navy must make a selection of an alternative for transportation, receipt, processing, and
storage of spent nuclear fuel and the support from the public is acknowledged.

08.01 (003) Preferences

COMMENT
Some persons expressed general satisfaction with the safety of the Naval Nuclear Propulsion Program.
Examples of these expressions of support include:
"I have a high confidence in the Navies (sic) ability to store the fuel at PSNS in a safe and environmentally
secure manner."
"My feeling is that I believe that the Navy has a good record of safety, I believe that they should get off the
back of the Navy and let them do their work."
"I just want everyone to understand that the Navy's nuclear program is safe and the workers that I represent
are very, very safe."
"As for transporting spent fuel the Navy has been transporting fuel safely across the country to INEL for
years."
"Proper examination of the fuel will help ensure the safety of the servicemen operating the ships and help
maintain a technical advantage by continually improving the reactor cores."
"The safety record for the navy nuclear program has been good."
"I've read the EIS and I'm in favor of the Navy being a good steward of the land, continuing its processing,
and I think it is within what we would call acceptable risk."
RESPONSE
Commentors provided statements of personal knowledge and conviction that the safety record of the Navy
in servicing nuclear-powered vessels and in handling and shipping Naval spent nuclear fuel which support
the Navy's statements in this EIS.  Some commentors affirmed the relationship between examining all Naval
spent nuclear fuel and ensuring the safety of nuclear-powered vessels and the sailors who serve aboard
them. 
These comments support the Naval Nuclear Propulsion Program and its continuing efforts to maintain
safety and minimize the risks associated with operation of the nuclear fleet.  Protecting the people who sail
and service nuclear-powered vessels, the public, and the environment has always been one of the highest
priorities of the Navy.

08.01 (004) Preferences

COMMENT
Some persons expressed opposition to one or more of the alternatives considered and provided reasons for
their opposition.  Some of these expressions of opposition were based on such things as the costs of
providing new facilities for Naval spent nuclear fuel management, the number of shipments involved,
existing pollution problems in the area, or the difficulty of evacuating an area.
RESPONSE
Some individuals oppose one or more of the alternatives identified by DOE and the Navy for the
transportation, receipt, processing, and storage of spent nuclear fuel.  Nevertheless, some alternative must
be selected since DOE has a considerable amount of spent nuclear fuel in existence.  To select an
alternative, the Navy is cooperating with DOE in this comprehensive EIS on spent nuclear fuel
management, including Naval  spent nuclear fuel.  This EIS evaluates alternatives for spent nuclear fuel
management pending ultimate disposition.   Analyses of the matters of concern and the reasons for
opposition identified have been considered in this EIS.
Analyses of the impacts associated with managing Naval spent nuclear fuel show that any effects on human
health or the environment would be small for all of the alternatives considered.  The potential impacts due
to normal operations or hypothetical accident conditions for management of Naval spent nuclear fuel
present little risk for all of the alternatives considered.

08.01 (005) Preferences

COMMENT
Some persons expressed support for one or more of the alternatives considered and provided technical
reasons for their support.  Some of these expressions of support were based on such things as the proven
nature of the existing Naval spent nuclear fuel management program, the lack of need to change existing
practices, or the unsuitable nature of some sites considered in comparison to others.
RESPONSE
DOE and the Navy must make a selection of an alternative for transportation, receipt, processing, and
storage of spent nuclear fuel and the support from the public is acknowledged.   Analyses of the matters of
concern and the reasons for opposition identified have been considered in this EIS.

II 08.01 (006) Preferences

COMMENT
Some persons expressed general opposition to one or more of the alternatives considered because they felt
that some of the alternatives to be evaluated in the Environmental Impact Statement would require further
site specific NEPA reviews, which would prevent prompt implementation.
RESPONSE
Appendix D to Volume 1 of this EIS includes in Chapters 3 and 5 and Attachments D and E detailed
evaluation of methods and facilities for storage of Naval spent nuclear fuel at Navy sites under the
alternatives considered.  Chapters 3 and 5 and Attachment F provide detailed information on the exposures
and potential health effects associated with each method of Naval spent nuclear fuel management at
shipyards and Navy prototype sites, as well the effects associated with examination of Naval spent nuclear
fuel at DOE sites.  In all of these cases, it is assumed that the facilities used for Naval spent nuclear fuel
management would be properly designed for the weather, seismic, and other conditions applicable to the
particular site evaluated.
This EIS provides the information necessary to show that all three methods of storage at shipyards and
Navy prototype considered (dry storage, storage in shipping containers, and storage in water pools) are
practical and could be accomplished safely and with very small risks.  This level of analysis is sufficient to
select a management alternative for Naval spent nuclear fuel.  Further NEPA review may be required for
construction of specific facilities, but this review could easily be conducted within the transition period
allotted for facility and equipment design and construction.

II 08.01 (007) Preferences

COMMENT
Some persons expressed general opposition to use of one or more of the Navy sites for storage of spent
nuclear fuel from other locations.
RESPONSE
Under the No Action and Decentralization alternatives, Navy sites would be used to store spent nuclear
fuel which was removed from reactors during servicing at the site performing the servicing, with the
exception of Norfolk Naval Shipyard, which would accept Naval spent nuclear fuel from Newport News
Shipbuilding and Drydock Company.  This transfer would be necessary because Newport News
Shipbuilding and Drydock is a private facility.  The EIS states that the Navy's preferred alternative is to
resume shipment of Naval spent nuclear fuel to INEL for examination and storage pending ultimate
disposition.

II 08.01 (008) Preferences

COMMENT
All U. S. citizens benefitted from the protection provided by nuclear-powered Naval vessels so the No-Action and Decentralization alternatives would not succeed in keeping Naval spent nuclear fuel in the
vicinity of those who derived the benefits of its use.
RESPONSE
As stated by the commentor, the argument that spent nuclear fuel should be stored at the location where it
is removed during reactor servicing in order to keep it in the locality of those who enjoyed the benefits
associated with its use does not apply to Naval spent nuclear fuel.  The commentor observes that all U. S.
citizens benefitted from the operation of the Navy's submarines and surface ships.
Section 3.9 of Appendix D to Volume 1 of this EIS discusses the fact that storing or examining Naval spent
nuclear fuel at Naval sites is not the Navy's preferred alternative.  The Navy has clearly stated its preferred
alternative for Naval  spent nuclear fuel: namely, transport to INEL for examination and storage pending
ultimate disposition.

II 08.01 (009) Preferences

COMMENT
Governor Andrus refused to allow spent nuclear fuel into Idaho.  DOE with the court's help has been able
to circumvent Governor Andrus for Naval spent nuclear fuel shipments to INEL.
RESPONSE
This statement is inaccurate.  In August 1993, the Secretary of the Navy, the Secretary of Energy, and
Governor Andrus signed an agreement allowing 19 specific shipments of Naval spent nuclear fuel to Idaho
while this EIS was being prepared and allowing for additional shipments if the Secretary of Defense
certified they were needed for National Defense.  In December 1993, the court accepted the agreement,
modifying its order to provide for the additional shipments while the EIS was prepared.  All shipments of
Naval spent nuclear fuel have been conducted in full compliance with this order.

II 8.2 NEPA-Related Comments

II COMMENT

Commentors stated that, a public hearing was poorly handled by the government representatives or the
public review process should be different.
RESPONSE
The public hearings on this EIS were designed to provide members of the public an opportunity to ask
questions and obtain information as well as provide comments.  To accomplish these goals, the hearings
consisted of a presentation summarizing the information contained in this EIS, a session in the main hearing
room during which questions from those in attendance were answered, and a period in which those in
attendance could state their comments on the content of the EIS.  In addition, a smaller room with a
recorder and a representative of DOE or the Navy was provided for those who did not wish to speak in
front of the audience or who did not want to wait to make their comments.  Informal question and answer
sessions were also conducted to provide an additional opportunity for members of the public to ask more
detailed questions.
The hearings began with brief summaries of the alternatives and the associated impacts by DOE and Navy
officials.  These summaries were intended to provide background on the nature of the decision to be made,
the alternatives considered, and the results of the evaluations of potential impacts on human health and the
environment.
The summary presentations were followed by a "question and answer" period to permit those in attendance
to obtain information they might desire concerning the alternatives, supporting analyses, or the results of
the evaluation of impacts.  These sessions were intended to allow those in attendance to bring out any
additional information on the EIS or the process that they might consider useful.  Each question and
answer during this session was recorded in its entirety as part of the permanent record of the hearings.
After the question and answer sessions, those in attendance were provided an opportunity to make a public
statement providing their comments on this EIS.  Each person's statement was recorded verbatim as part of
the permanent record of the hearings.  At the same time, a court recorder and an official of DOE were made
available in a small, separate room to allow those who did not wish to speak in front of the hearing
audience or who did not wish to wait for an opportunity to address the full hearing an opportunity to have
their statements recorded verbatim.  DOE and Navy officials were also made available in an informal
setting to answer additional questions from those in attendance.
Written statements were also accepted at each hearing location from those who wished to provide their
comments in that form.  In addition, a toll-free "800 number" telephone service was provided for those who
wished to submit comments orally or by facsimile.  Of course, written comments were accepted by mail. 
All written and oral comments, regardless of whether they were provided before the hearing audience, were
recorded and analyzed, with no greater weight given to the manner in which the comments were provided.
The goals and intentions of the Navy and DOE in designing and carrying out the public review process,
including the public hearings, was to make it as simple, easy, and convenient as possible for members of
the public to be fully informed and then provide their comments in the manner they preferred.

II COMMENT

Construction of the new dry cell at the Expended Core Facility was started without adequate NEPA
documentation.
RESPONSE
This comment is not accurate.  Adequate NEPA documentation existed at the time the Expended Core
Facility dry cell expansion construction was initiated.  Nonetheless, the dry cell construction was included
in Volume 2, Part B of the EIS to ensure that this EIS would be a comprehensive document presenting
information on all projects expected during the period which Volume 2 of the EIS covers.

II COMMENT

The discussion of the new Expended Core Facility dry cell in the EIS does not characterize emissions from
the facility.
RESPONSE
Annual releases of radioactivity from Expended Core Facility are identified in Table F.1.4.1.1-1 of
Appendix D to Volume 1 of the EIS.  Analysis of the environmental impacts of these emissions is included
in Appendix D.   Volume 2, Appendix C, of the EIS correctly states that emissions from the Expended
Core Facility would not be expected to change significantly due to the construction of the dry cell facility. 
Instead, operations now conducted in other parts of the Expended Core Facility would be replaced by
operations in the new dry cell if the new dry cell becomes operational.  Appendix C of Volume 2 has been
modified to clarify this point.

II 8.3 Policy

II II COMMENT

Operation of the Navy's nuclear-powered vessels should be stopped immediately or should be stopped until
a specified condition (such as a decision on ultimate disposition of spent nuclear fuel) is satisfied.
RESPONSE
Decisions on whether to operate nuclear-powered Naval vessels and the numbers of such vessels are made
by the Congress and the President of the United States.  Therefore, they are beyond the scope of this
Environmental Impact Statement.
Further, as discussed in the Environmental Impact Statement, spent nuclear fuel already exists and will
require safe management at some location.  The EIS considers management of spent nuclear fuel containing
2800 metric tons of heavy metal, 2700 metric tons of which is already in existence.  Approximately 65
metric tons of the total of 2800 metric tons of heavy metal is Naval spent nuclear fuel.  Thus, stopping the
use of nuclear power for Navy ships will not eliminate the need for safe management of spent nuclear fuel.

II COMMENT

A decision on the method for managing Naval spent nuclear fuel should be postponed until a plan for the
ultimate disposal of spent nuclear fuel is in place.
RESPONSE
As discussed in the Environmental Impact Statement, Naval spent nuclear fuel already exists and will
require safe management at some location.  There is no way to defer a decision on how to manage existing
Naval spent nuclear fuel until permanent storage is available.

II COMMENT

The Naval Nuclear Propulsion Program should be regulated by some other federal or independent agency.
RESPONSE
The Naval Nuclear Propulsion Program is subject to regulation by many other agencies, as specified in
applicable laws, executive orders, and regulations.  For example, the Naval Nuclear Propulsion Program is
subject to regulation under the Resource Conservation and Recovery Act (RCRA), the Toxic Substances
Control Act (TSCA), the Comprehensive Environmental Response Compensation and Liability Act
(CERCLA), the Superfund Amendments and Reauthorization Act (SARA), the Safe Drinking Water Act,
the Clean Water Act, the Clean Air Act, and many others.  All of these laws have either the U. S.
Environmental Protection Agency or appropriate departments in the host states as the regulator.  The Naval
Nuclear Propulsion Program's compliance with these laws is actively monitored by the EPA and the states
and since 1980 there have been more than 300 inspections, examinations, and audits by state and federal
agencies under these laws.  This monitoring has been facilitated by the efforts of the Naval Nuclear
Propulsion Program in the 1980's to ensure that the regulators received security clearances.
Decisions on the appropriate regulating agencies and the type, extent, and nature of regulation of the
operations of nuclear-powered Naval vessels and the Naval Nuclear Propulsion Program are made by the
Congress and the President of the United States.  Therefore, this issue is beyond the scope of this
Environmental Impact Statement.

II COMMENT

The Environmental Impact Statement should consider ways to reduce the amount of Naval spent nuclear
fuel produced, including reducing the number of nuclear powered warships in operation or to be built.
RESPONSE
The EIS explains the need for examination of spent Naval fuel to support achieving the goal of fuel lasting
the life of a ship, thus avoiding the need for refueling, and reducing the amount of spent nuclear fuel
created.  However, the draft EIS does not consider reducing the number of nuclear powered warships in
operation or to be built.  Such matters are directed by Congress and the President fulfilling their
fundamental Federal responsibilities under the Constitution in providing for the common defense.  It would
be inappropriate and unfeasible for this EIS to consider what the military force structure of the United
States should be.  Rather, the EIS analysis supports accomplishment of the Navy's fundamental mission as
established and funded by Congress.

II COMMENT

Some commentors indicated that DOE or the Navy is not providing complete, accurate, or truthful
information.
RESPONSE
The Navy has provided a large amount of information on the shipment of Naval spent nuclear fuel and the
types and amounts of radiation or radioactive material involved in releases from normal  operations and
postulated accidents in Appendix D.  Appendix D also includes descriptions of the Expended Core Facility
and Naval spent nuclear fuel operations.  The Navy has attempted to provide enough information on
radiation, radioactivity, and other aspects of operations or hypothetical accidents to allow independent
calculation of the environmental impacts.  This is intended to permit independent analysis and verification
of the estimated impacts calculated by the Navy.  Every effort has been made during the preparation of this
EIS to see that the best available information on impacts has been included, including public review in
accordance with the requirements of the Act.
In this EIS, the Navy has clearly stated its preferred alternative and discussed how this alternative would
support the Navy's mission, as established by Congress.  In Appendix D, the environmental impacts of the
Navy's proposed action and alternatives are evaluated in accordance with NEPA, the Council on
Environmental Quality regulations, and Navy regulations.

II COMMENT

Analyses of the alternatives should be performed by independent groups or individuals.
RESPONSE
The process specified under NEPA provides opportunities for independent evaluation of the environmental
impacts associated with alternatives for actions such as the subject of this EIS.  As a part of this process,
the draft EIS has been provided to a wide range of state, federal, and local agencies and officials and to
private groups and individuals.  This is intended to permit them to perform their own evaluation of the
analyses and the conclusions.  
Many of these independent reviewers submitted the results of their reviews as comments. These comments
were used to prepare the final EIS which is provided to the person deciding upon the alternative to be
selected.
The Navy has provided a large amount of information on the shipment of Naval spent nuclear fuel and the
types and amounts of radiation or radioactive material involved in releases from normal operations and
postulated accidents for all of the alternatives in Appendix D to Volume 1. The Navy has attempted to
provide enough information on the radiation, radioactivity, and other aspects of operations or reasonably
foreseeable accidents to allow independent calculation of the environmental impacts.  All of this
information is intended to permit independent analysis and verification of the estimated impacts calculated
by the Navy.

II COMMENT

The risks associated with the management of Naval spent nuclear fuel are unacceptable.
RESPONSE
The risks associated with all of the alternatives considered for management  of DOE's spent nuclear fuel,
including Naval spent nuclear fuel have been calculated and presented in this EIS.  All of these risks would
be small.  The risks associated with the normal operations involved in management of Naval spent nuclear
fuel and a broad range of hypothetical accidents are summarized in Chapter 3 of Appendix D to Volume 1.
For example, as summarized in Chapter 3 and described in more detail in Chapter 5 and Attachments A
and F to Appendix D, the risk resulting form normal operations or accidents associated with Naval spent
nuclear fuel management during the 40 years covered by this EIS would be far less than 1 additional
cancer fatality or radiation-related health effect over the entire time.  This risk is very small in comparison
to the other risks of daily life.

II COMMENT

The Navy and DOE have already made up their minds on the action they plan to choose and are not
seriously considering all of the alternatives presented or they plan to implement some action not revealed
in this EIS.
RESPONSE
In accordance with NEPA, no decision on the alternative to be implemented has been made or will be
made until the final EIS is issued and no actions are being taken in the meantime which would prejudice
that decision.  The final decision and the basis for it will be documented in the Record of Decision which
will be published in the Federal Register in June 1995.
In this EIS, the Navy has stated its preferred alternative and discussed how this alternative would support
the Navy's mission, as established by Congress.  In Volume 1, Appendix D, the environmental impacts of
the Navy's proposed action and all alternatives, including those which would not support the Navy's
mission, are evaluated in accordance with NEPA, the Council on Environmental Quality regulations, and
DOE and Navy regulations.

II COMMENT

The Navy or DOE will decide on the alternative to be implemented based on faulty or hasty research.
RESPONSE
NEPA requires the preparation of an EIS for major federal actions as a means to assure comprehensive
evaluation of the impacts associated with the alternatives.  It also provides for review of the EIS by the
public and other agencies in order to develop assurance that important aspects have not been overlooked or
that pertinent information has not been omitted.  Every effort has been made during the preparation of this
EIS to see that the best available information on impacts has been included, including public review in
accordance with the requirements of the Act.
The risks associated with all of the alternatives considered were found to be very small.  Even so, every
effort was made to use the best available information on the effects of the actions considered and the
methods for calculating effects which could not be measured.  A wide range of disciplines were examined
to assure that any important effects were not overlooked.  The results of independent reviews and public
comments have been carefully considered.  It would appear that the potential environmental impacts of the
alternatives considered have been evaluated thoroughly and the information is adequate to support the
required decision.
As a part of this effort, the Navy has provided a large amount of information on the shipment of Naval
spent nuclear fuel and the types and amounts of radiation or radioactive material involved in releases from
normal operations and postulated accidents for all of the alternatives in Appendix D to Volume 1. The
Navy has attempted to provide enough information on the radiation, radioactivity, and other aspects of
normal operations or hypothetical accidents to allow independent calculation of the environmental
impacts.  All of this information is intended to permit independent analysis and verification of the
estimated impacts calculated by the Navy.

II COMMENT

The Navy should analyze the effects of a reactor accident at the Kesselring Site.
RESPONSE
Such matters are outside the scope of this EIS.  The EIS deals with the alternatives for handling,
transporting, examining, and storing spent nuclear fuel, including Naval spent nuclear fuel, once it has
been removed from nuclear reactors.  It does not include any information to be used in conjunction with
decisions related to the start-up, shutdown, or continued operation of reactors.  Consequently, it is not
intended to include analyses of the effects of reactor accidents.

II COMMENT

The health, safety, and welfare of citizens should be considered in reaching any decision on the course of
action to be used for management of spent nuclear fuel.
RESPONSE
This EIS is devoted to analysis of all effects on human health and the environment which might result from
operations or reasonably foreseeable accidents associated with DOE and Navy management of spent
nuclear fuel.  The details of the analyses for Naval spent nuclear fuel management are described in
Attachments A and F of Appendix D to Volume 1.  Chapters 3 and 5 summarize the results of these
analyses and the detailed results are described in the Attachments to Appendix D.
Every effort has been made to include all possible affected areas, including any identified during the public
review of this EIS.  It is believed that no important area of potential human health effect or environmental
impact has been omitted from this EIS.
The health, safety, and welfare of citizens will be considered carefully in reaching any decision on the
course of action to be used for management of spent nuclear fuel.

II COMMENT

If the Navy and DOE decide to manage spent nuclear fuel at a location for the period covered by this EIS,
that location will become a permanent site for storage of spent nuclear fuel.
RESPONSE
It is not correct that a site selected for management of Naval spent nuclear fuel during the period of this
EIS will become a permanent site for storage of spent nuclear fuel.  Congress has determined under the
Nuclear Waste Policy Act, as amended, that spent nuclear fuel and high-level waste will be buried in a
geologic repository, independent of the location where DOE or commercial spent nuclear fuel is stored.
The Navy supports selecting and implementing an approach for final disposition of Naval spent nuclear
fuel as soon as possible.  There is no benefit to the Navy to store Naval spent nuclear fuel any longer than
is necessary to implement the method selected for ultimate disposition.  The Navy's commitment is
reinforced by the Navy's bearing the cost of storing Naval spent nuclear fuel pending ultimate disposition.
The 40-year period considered in this EIS is intended to provide enough time for selecting and
implementing a method for ultimate disposition.  In this EIS, the Navy has clearly stated its preferred
alternative for management of Naval spent nuclear fuel during the 40 year interim period and discussed
how this alternative would support the Navy's mission, as established by Congress.  In Volume 1,
Appendix D, the environmental impacts of the Navy's proposed action and all alternatives, including those
that would not support the Navy's mission, are evaluated in accordance with NEPA, the Council on
Environmental Quality regulations, and DOE and Navy regulations.
See also the response to comment 08.03.03 (001).

II COMMENT

The Navy should reconsider its policy of not notifying emergency response organizations of shipments of
Naval spent nuclear fuel passing through their areas of responsibility.
RESPONSE
The Naval Nuclear Propulsion Program does not announce the times or routes of shipments in order to
make it more difficult for terrorists, saboteurs, or hijackers to plan and execute an attack on these
shipments.  This is in accordance with federal government policy and regulations governing such
shipments.  The Navy's policy on notification is also in full compliance with the applicable state and
federal regulations for such shipments containing highly enriched weapons-grade uranium.  The extremely
rugged design of Naval spent nuclear fuel and the shipping containers, which comply fully with
Department of Transportation and Nuclear Regulatory Commission requirements, make it 
unnecessary for emergency response personnel to maintain any extraordinary level of alert during the
movement of shipments. 
As a practical matter, such notification would not improve emergency response or reduce the already small
risks for these shipments.  Every shipment is accompanied at all times by escorts who can immediately
contact the Naval Nuclear Propulsion Program emergency control center and federal or local emergency
response personnel in the event of a problem.  When notified, emergency response personnel would utilize
existing emergency response plans and capabilities, if needed.
The risks associated with the complete range of accidents which might occur during these shipments are
analyzed in detail in Attachment A of Appendix D to Volume 1 and were shown to be very small.

II COMMENT

The Naval Nuclear Propulsion Program refused to be included in the assessment of vulnerabilities for spent
nuclear fuel storage performed by DOE.
RESPONSE
This comment is incorrect.  The Naval Nuclear Propulsion Program participated in the referenced review of
potential vulnerabilities in DOE spent nuclear fuel facilities.  Facilities at the Idaho Chemical Processing
Plant and the Expended Core Facility at INEL used for the management of Naval spent nuclear fuel were
included in the study and are discussed in both the summary (Volume I) and the detailed information
sections (Volume II and III) of the final report.
DOE's Vulnerability Assessment states on pages 22 and 32 of Volume 1 that no vulnerabilities associated
with the storage of Naval spent nuclear fuel were identified.

II COMMENT

The risks and costs associated with the period of transition to a new alternative for the management of
Naval spent nuclear fuel are unacceptable.
RESPONSE
The risks associated with all of the alternatives considered for management of DOE's spent nuclear fuel,
including Naval spent nuclear fuel have been calculated and presented in this EIS.  All of these risks would
be small.  The risks associated with the normal operations involved in management of Naval spent nuclear
fuel and a broad range of hypothetical accidents are summarized in Volume 1, Appendix D, Chapter 3.
For example, as summarized in Chapter 3 and described in more detail in Chapter 5 and Appendix D,
Attachments A and F, the risk resulting from normal operations or accidents associated with Naval spent
nuclear fuel management during the 40 years covered by this EIS would be less than 1 additional cancer
fatality or radiation-related health effect over the entire time.  This risk is very small in comparison to the
other risks of daily life.
As discussed in the EIS, it is true that selection of an alternative which would involve a change from the
current practice of sending Naval spent nuclear fuel to the Expended Core Facility at INEL would involve
higher costs and could require a transition period during which Naval spent nuclear fuel would accumulate
at the sites where it is removed from reactors.  Even though the Navy does not prefer any of these
alternatives, the impacts on human health and the environment associated with such a transition period
have been considered in Volume 1, Appendix D and were found to be very small.

II COMMENT

The alternatives for management of DOE and Naval spent nuclear fuel should be reconsidered after ten
years or possibly even five years instead of forty years.
RESPONSE
The alternatives for management of spent nuclear fuel will be reconsidered in the future if new information
or circumstances show a need for changes in the strategy for management of spent nuclear fuel.

II COMMENT

The Navy has disregarded the requirements of NEPA by identifying a preferred alternative in the Draft EIS.
RESPONSE
The statement that the Navy has disregarded the requirements of NEPA by identifying a preferred
alternative in the Draft EIS is incorrect. To the contrary, the regulations issued by the Council on
Environmental Quality to implement NEPA require an agency to identify in the Draft EIS its preferred
alternative if one exists (40 CFR 1502.14(e)).  This preferred alternative may be altered in the Final EIS if
substantive issues are identified during public review of the Draft EIS.  Therefore, identifying a preferred
alternative in the Draft EIS does not imply that a decision has already been made or that the agency has
any lack of regard for the public process specified by NEPA or the value of the public review.
Identification of a preferred alternative in the Draft EIS is not a violation of the requirements of NEPA, nor
is it prejudicial to public or technical review.  It simply provides a clear indication of the agency's
preference based on the information available at the time the Draft EIS is issued and allows the public to
include this factor in their review of the Draft EIS.  Indeed, most draft environmental impact statements do
contain preferred alternatives to serve this purpose.

II COMMENT

The risks associated with defueling of nuclear-powered warships should be included in this EIS.
RESPONSE
Refueling and defueling of Naval nuclear reactors are considered to be part of the effort associated with
reactor operations.  The purpose of this EIS is to evaluate alternatives for and the possible impacts on the
environment and human health associated with the management of spent nuclear fuel, including Naval
spent nuclear fuel, after it has been removed from reactors.  Indeed, Nuclear Regulatory Commission
regulations and DOE Orders define spent nuclear fuel as "fuel which has been withdrawn from a nuclear
reactor following irradiation, the constituent elements of which have not been separated by reprocessing".
All of the alternatives considered would require removal of spent nuclear fuel from nuclear- powered
ships, so analyses of accidents associated with such work would not assist in the evaluation of the
alternatives for management of spent nuclear fuel.  This the case for other types of spent nuclear fuel as
well, and refueling of university or research reactors is similarly not within the scope of this EIS.

II COMMENT

The Navy should pay the costs for storage and disposal of Naval spent nuclear fuel.
RESPONSE
Under current federal policy, the Navy does pay the costs of storage for Naval spent nuclear fuel and will
pay the costs of disposal for Naval spent nuclear fuel once those costs are established.

II COMMENT

Disruption of the process of deactivations and refuelings of nuclear-powered Naval vessels will impair the
Navy's mission and affect the national security of this country.
RESPONSE
None of the alternatives considered in detail in this EIS would impact the Navy's ability to refuel and
defuel nuclear-powered warships because each alternative provides for a transition period while new
facilities would be procured or constructed.  The Navy's preferred alternative best supports the Navy's
broader mission by allowing examination of all Naval spent nuclear fuel.  The importance of examination
of Naval spent nuclear fuel to the Navy's mission is discussed in Section 3.7 of Appendix D to Volume 1 of
this EIS.

II COMMENT

Operation of reactors at the Kesselring Site should be stopped immediately or should be stopped until a
specified condition (such as a decision on ultimate disposition of spent nuclear fuel) is satisfied.
RESPONSE
Cessation or continuation of reactor operations at the Kesselring Site is not one of the alternatives being
evaluated in this EIS.  The continued operation of these reactors will not remove the need for a decision on
a method for safely managing spent nuclear fuel until a method for ultimate disposition is selected.
Therefore, the continued operation of the reactors at the Kesselring Site is beyond the scope of this
Environmental Impact Statement.
As discussed in this Environmental Impact Statement, spent nuclear fuel already exists and will require safe
management at some location.  This EIS considers management of spent nuclear fuel containing 2800
metric tons of heavy metal, 2700 metric tons of which is already in existence.  Approximately 65 metric
tons of the total of 2800 metric tons of heavy metal is Naval spent nuclear fuel and only a small portion of
this will be generated at the Kesselring Site in the coming years.  Thus, stopping the operation of the
reactors at the Kesselring Site will not eliminate the need for safe management of spent nuclear fuel.

II COMMENT

A commentor was skeptical that the transition to any new method for management of Naval spent nuclear
fuel could be implemented in time to prevent accumulation of spent nuclear fuel at Navy sites.
RESPONSE
Section 3.8 of Appendix D to Volume 1 of the EIS states that most of the alternatives would require a
period of implementation while facilities were constructed and equipment was procured.  Existing facilities
and equipment would be employed to the fullest extent to manage Naval spent nuclear fuel during the first
six years of the transition to ensure refueling and defueling of nuclear-powered warships could proceed as
necessary during this period.  Naval spent nuclear fuel would be transported to the Expended Core Facility
at INEL during the transition should an alternative be selected requiring construction of a new examination
facility or procurement of additional shipping containers for dry storage at Navy sites.  For the No Action
alternative, Naval spent nuclear fuel would be shipped to INEL for approximately three years.  For
alternatives requiring replacement of the Expended Core Facility, the transition would take approximately
six years.  After the transition period, the new facilities would be completed to the point that they could
begin to accept Naval spent nuclear fuel.
These transition periods represent the best estimate of the time needed to execute any of the alternatives,
given the need for federal budgeting, procurement, and construction.

II II COMMENT

Some persons alleged that the storage of Naval spent nuclear fuel at Pearl Harbor Naval Shipyard would
violate a provision of the state constitution of Hawaii.
RESPONSE
The state constitution of Hawaii prohibits the disposal of radioactive waste within the state without the
approval of the state legislature.  Regardless of the applicability of that requirement to federal activities, no
disposal of spent nuclear fuel in Hawaii is considered in this EIS.  Under all of the alternatives considered,
Naval spent nuclear fuel would be monitored and maintained at the interim storage location while the
method for ultimate disposition is being identified and implemented, consistent with Congressional
direction, such as disposal in a geologic repository.  Currently, Congress has directed DOE to assess the
Yucca Mountain site in Nevada as a candidate geologic repository.

II COMMENT

The Office of State Planning for the state of Hawaii has requested submittal of a Coastal Zone Management
consistency plan if an alternative involving the storage of Naval spent nuclear fuel at Pearl Harbor is
selected.
RESPONSE
In accordance with the Coastal Zone Management Act (16 USC 1453), the Pearl Harbor Naval Shipyard,
as part of the Pearl Harbor Naval Base, is excluded from the coastal zone since it is on land controlled by
the Federal Government. Therefore, a Coastal Zone Management consistency determination is not required
for storage of Naval spent nuclear fuel at Pearl Harbor Naval Shipyard.
It should be noted that the impacts of the alternatives involving storage of spent Naval nuclear fuel at the
shipyard would be very small, so no impact on Hawaii's Coastal Zone would be expected if such an
alternative were selected.

II II COMMENT

The Environmental Impact Statement should provide a description of the impacts on the Navy's mission
resulting from not removing spent nuclear fuel from ships.
RESPONSE
Section 3.6.3 of Appendix D to Volume 1 provides a description of the impacts to the Navy mission (and
to the environment) that would arise from storing Naval spent nuclear fuel on inactive ships.  In summary,
storing Naval spent nuclear fuel aboard inactive ships would use up the limited space at shipyards, idle
skilled shipyard workers when the shipyards ran out of ship servicing work and room to do work, and tie
up highly trained Navy nuclear ship operators.  In return, this concept would not produce lower
environmental impacts than the alternatives considered in detail in this EIS and might actually increase the
environmental impacts.
It is physically possible to retain spent fuel in the reactors in nuclear-powered vessels and moor the ships at
shipyards until a decision on the ultimate disposition of spent nuclear fuel is reached.  Most inactive
Russian nuclear-powered submarines have been tied up at shipyards without removing their spent fuel. 
After a decision on ultimate disposition is made and implemented, the fuel could be removed from the
ships and transported to the permanent disposal facility.
Implementing this alternative would require extensive modifications to facilities at shipyards, including
increasing the number of piers and the availability of waterfront utilities to support the ships at their
moorings.  Other shipyard facilities also might have to be modified or replaced as a result of the use of
waterfront space to moor the numbers of ships involved during the 40-year period.  The construction of
piers and other needed facilities would cause impacts on the waterfronts and harbors and could affect the
local ecology.  The radiological effects on the environment or people in the vicinity would be negligible as
long as the nuclear-powered vessels and propulsion plants were maintained under the same procedures and
discipline used for operating ships, since the environmental effects of operating U.S. Navy nuclear-powered
vessels are well documented and known to be small.
This method for storing Naval spent nuclear fuel would cause some increase in construction activities, but
in the long run it would result in the idling of skilled workers as the shipyards ran out of room and work
schedules were disrupted by the loss of ship servicing work.  Mooring the ships without removing the
Naval spent nuclear fuel would also utilize highly trained Navy nuclear ship operators in the unproductive
task of watching over shut down ships.  The resources dedicated to providing the additional moorings
would produce no improvements in a shipyard's ability to perform its mission and would actually decrease
its capabilities.
In addition, the costs and impacts on national security resulting from such an approach would be large; it
would affect the ability of the U.S. Navy to carry out its mission.  Further, the costs of maintaining the
ships with spent nuclear fuel remaining installed under Navy operating procedures and providing the
additional piers and waterfront services and utilities would be large.  The costs of this approach would be
high both for ships which are to be decommissioned and for ships which would normally be refueled and
returned to duty.  In the case of ships which are being decommissioned at the end of their life, the primary
cost of this alternative would be to maintain qualified nuclear operators, shipboard equipment, and
associated shipyard support, including security, to ensure nuclear and radiological safety for the workers
and the public.  This would be more costly than removal of the spent fuel for storage because of the need
to maintain operating personnel aboard the ships until they are defueled.  Failure to remove the spent
nuclear fuel from Navy ships which are still needed for service would result in these ships being
unavailable once their currently installed reactor fuel reaches the end of useful life.  This is impractical and
even more expensive than leaving the spent fuel in decommissioned ships because the ships would have to
be replaced or the Navy would be forced to operate without the full complement of ships required to
execute national policies.
In summary, this alternative would be costly and would involve extensive actions which would have an
effect on the environment due to construction activities.  This alternative would also not permit continued
service of many Navy ships and only postpone decisions on a satisfactory storage location.  As a result of
these considerations, this alternative was eliminated from detailed analysis.
Storing Naval spent nuclear fuel on inactive ships would also prevent examination of the Naval spent
nuclear fuel.  The EIS explains that the inspections currently performed are important for three reasons:  to
provide data on current reactor performance, to validate models used to predict future performance, and to
support research to improve reactor design (See Sections 2.4.1, 3.1, 3.9 and B.2 of Appendix D to Volume
1).
Naval fuel examinations provide real data on reactor cores installed in ships currently operating in the
Fleet.  This information is essential to validate calculational models and analyses.  Through the years, the
Naval Nuclear Propulsion Program has built a substantial technical database from examinations of earlier
reactor core types.  The Program predicts the performance of current core types with calculational models
supported by this database.  Essentially no information exists yet on core types that will form the backbone
of the nuclear fleet for the foreseeable future (Trident-class submarines, LOS ANGELES-class submarines,
and NIMITZ-class aircraft carriers).  Data from these reactor core types are necessary to validate basic
assumptions of current models, provide a measure of variability which exists between individual cores and
within a single core, and identify any unanticipated effects of operation that have not been evaluated or
accounted for in current models.
Confidence in the validity of engineering models is essential for assurance that ship operations can
continue without restriction.  Since reactors operating in the Fleet are not taxed to the limits of their design
during peacetime operations, the Program requires a technically-sound basis for continuing to conclude we
have a robust design.  Prototype reactors can not by themselves provide this information as their operation
is not identical to that of a warship.  The fact that a core operated satisfactorily with no indication of a
problem during a normal shipboard lifetime does not guarantee that the core would have been acceptable
under the worst case conditions for which it was designed.  The examination of spent nuclear fuel from
each core provides the assurance needed that there are no unexpected technical issues not evaluated and
addressed in the models that would affect continued unrestricted operation.
Data from examinations also contributes significantly to improvements in reactor design.  Improvements in
calculational models and analyses have enabled the Program to increase both the lifetime and the
performance of reactor cores.  For example, the reactor cores installed in the USS NAUTILUS in the
1950's operated for two years.  Current reactor cores are designed to last over 20 years, a significant
technical accomplishment unique to Naval fuel.  The Navy is seeking to develop a life-of-the-ship (30 year)
core for the New Attack Submarine which is still in the design stages.  This core will further reduce the
amount of spent nuclear fuel generated in the long-term, as ships will not require refueling during their
lifetime.  Continuing data from current core types is essential if this effort is to succeed.
In the final analysis, examination of spent Naval fuel absorbs considerable resources.  In a time of
extremely tight budgets, the Navy would not be performing such examinations unless they were judged to
be necessary to support the conduct of technical work.  Examinations done over the last 37 years have
played a key role in achieving over 4400 reactor-years of safe nuclear reactor operations, having nuclear-powered warships steam over 100,000,000 miles, and increasing core lifetimes from 2 years to over 20
years.  The record shows there is no reason for reducing the technical basis upon which safe Naval reactor
design and operation are founded -- and that basis includes as a key cornerstone the examination of Naval
spent nuclear fuel.

II COMMENT

The EIS should explain further why examination of all Naval spent nuclear fuel is essential to the mission
of the Navy.
RESPONSE
The EIS explains that these inspections are important for three reasons:  to provide data on current reactor
performance, to validate models used to predict future performance, and to support research to improve
reactor design (See Volume 1, Appendix D, sections 2.4.1, 3.1, 3.9, and B.2).  The EIS evaluates five sites
for full examination of Naval spent nuclear fuel and one site for limited examination.  The Expended Core
Facility at INEL is the only existing facility with the capability for performing examinations of Naval spent
nuclear fuel.
Naval fuel examinations provide real data on reactor cores installed in ships currently operating in the
Fleet.  This information is essential to validate calculational models and analyses.  Through the years, the
Naval Nuclear Propulsion Program has built a substantial technical data base from examinations of earlier
reactor core types.  The Program predicts the performance of current core types with calculational models
supported by this data base.  Essentially no information exists yet on core types that will form the
backbone of the nuclear fleet for the foreseeable future (Trident-class submarines, LOS ANGELES-class
submarines, and NIMITZ-class aircraft carriers).  Data from these reactor core types are necessary to
validate basic assumptions of current models, provide a measure of variability that exists between
individual cores and within a single core, and identify any unanticipated effects of operation that have not
been evaluated or accounted for in current models.
Confidence in the validity of engineering models is essential for assurance that ship operations can
continue without restriction.  Because reactors operating in the Fleet are not taxed to the limits of their
design during peacetime operations, the program requires a technically sound basis for continuing to
conclude we have a robust design.  Prototype reactors can not by themselves provide this information as
their operation is not identical to that of a warship.  The fact that a core operated satisfactorily with no
indication of a problem during a normal shipboard lifetime does not guarantee that the core would have
been acceptable under the worst case conditions for which it was designed.  The examination of spent
nuclear fuel from each core provides the assurance needed that there are no unexpected technical issues
not evaluated and addressed in the models that would affect continued unrestricted operation.
Data from examinations also contribute significantly to improvements in reactor design.  Improvements in
calculational models and analyses have enabled the program to increase both the lifetime and the
performance of reactor cores.  For example, the reactor cores installed in the USS NAUTILUS in the 1950s
operated for 2 years.  Current reactor cores are designed to last more than 20 years, a significant technical
accomplishment unique to Naval fuel.  The Navy is seeking to develop a life-of-the-ship (30-year) core for
the New Attack Submarine which is still in the design stages.  This core will further reduce the amount of
spent fuel generated in the long-term, as ships will not require refueling during their lifetime.  Continuing
data from current core types is essential if this effort is to succeed.
In the final analysis, examination of spent Naval fuel absorbs considerable resources.  In a time of
extremely tight budgets, the Navy would not be performing such examinations unless they were judged to
be necessary to support the conduct of technical work.  Examinations done over the last 37 years have
played a key role in achieving more than 4,400 reactor-years of safe nuclear reactor operations, having
nuclear-powered warships steam more than 100 million miles, and increasing core lifetimes from 2 years to
more than 20 years.  The record shows there is no reason for reducing the technical basis upon which safe
Naval reactor design and operation are founded -- and that basis includes as a cornerstone the examination
of Naval spent nuclear fuel.
Language has been added to Volume 1 and Volume 1, Appendix D, Chapter 3 of the EIS explaining this
matter further.

II COMMENT

The EIS should explain how much Naval spent nuclear fuel receives more than just visual examination, and
why that is essential to meet the Navy's mission.
RESPONSE
The EIS explains that all Naval spent nuclear fuel is visually examined on exterior and interior surfaces
(See sections 2.4.1 and B.2 of Appendix D to Volume 1).  These examinations require that non-fuel
structural material first be removed from the fuel cells, an operation which is currently performed at only
one location, the Expended Core Facility at INEL.  About 10 to 20 percent of the spent nuclear fuel cores
receive additional examination in the form of detailed dimensional measurements to detect even minute
changes in fuel cell or fuel element dimensions, measurements to determine the amount of surface
corrosion on fuel elements which could impede heat transfer, and more intrusive sampling to discern
internal performance characteristics of the fuel.  The examinations are essential in supporting the Navy's
continued safe operation of Naval reactors and design of new, improved fuel having longer lifetime (see
sections 3.1 and 3.9 of Appendix D).
Naval fuel examinations provide real data on reactor cores installed in ships currently operating in the
Fleet.  This information is essential to validate calculational models and analyses.  Through the years, the
Naval Nuclear Propulsion Program has built a substantial technical database from examinations of earlier
reactor core types.  The program predicts the performance of current core types with calculational models
supported by this database.  Essentially no information exists yet on core types that will form the backbone
of the nuclear fleet for the foreseeable future (Trident-class submarines, LOS ANGELES-class submarines,
and NIMITZ-class aircraft carriers).  Data from these reactor core types are necessary to validate basic
assumptions of current models, provide a measure of variability which exists between individual cores and
within a single core, and identify any unanticipated effects of operation that have not been evaluated or
accounted for in current models.
Confidence in the validity of engineering models is essential for assurance that ship operations can
continue without restriction.  Since reactors operating in the Fleet are not taxed to the limits of their design
during peacetime operations, the program requires a technically-sound basis for continuing to conclude we
have a robust design.  Prototype reactors can not by themselves provide this information as their operation
is not identical to that of a warship.  The fact that a core operated satisfactorily with no indication of a
problem during a normal shipboard lifetime does not guarantee that the core would have been acceptable
under the worst case conditions for which it was designed.  The examination of spent fuel from each core
provides the assurance needed that there are no unexpected technical issues not evaluated and addressed in
the models that would affect continued unrestricted operation.
Data from examinations also contributes significantly to improvements in reactor design.  Improvements in
calculational models and analyses have enabled the program to increase both the lifetime and the
performance of reactor cores.  For example, the reactor cores installed in the USS NAUTILUS in the
1950's operated for two years.  Current reactor cores are designed to last over 20 years, a significant
technical accomplishment unique to Naval fuel.  The Navy is seeking to develop a life-of-the-ship (30 year)
core for the New Attack Submarine which is still in the design stages.  This core will further reduce the
amount of spent nuclear fuel generated in the long-term, as ships will not require refueling during their
lifetime.  Continuing data from current core types is essential if this effort is to succeed.
In the final analysis, examination of spent Naval fuel absorbs considerable re sources.  In a time of
extremely tight budgets, the Navy would not be performing such examinations unless they were judged to
be necessary to support the conduct of technical work.  Examinations done over the last 37 years have
played a key role in achieving over 4400 reactor-years of safe nuclear reactor operations, having 
nuclear-powered warships steam over 100,000,000 miles, and increasing core lifetimes from 2 years to over 20
years.  The record shows there is no reason for reducing the technical basis upon which safe Naval reactor
design and operation are founded -- and that basis includes as a key cornerstone the examination of Naval
spent nuclear fuel.
Section 2.4.1 of Appendix D to Volume 1 has been revised to include information on the amount of Naval
spent nuclear fuel which receives additional examination.

II COMMENT

Some Naval fuel inspection is performed in facilities other than ECF; this seems to be in conflict with the
navy's assertion that all its spent fuel is examined at ECF.  Complete information about the "test specimen
shipments to or from several laboratories and test facilities" mentioned at A.2.4 of Volume 1, Appendix D. 
A detailed description of all fuel examination and testing facilities available to the nuclear navy should be
provided.
RESPONSE
This EIS correctly states that all spent nuclear fuel removed from Naval nuclear-powered ships and
prototypes is transported to the Expended Core Facility at INEL.  This EIS in Volume 1, Appendix D,
Sections 2.4.1 and B.2, describes how all Naval fuel modules are visually examined in the ECF water
pools to verify that the spent fuel has performed as expected.  Some modules are selected for more detailed
examination or analysis.  These more extensive examinations, which include destructive as well as
nondestructive operations on the fuel and structural regions of the modules, are performed in the Expended
Core Facility water pools and shielded cells.
The Naval Nuclear Propulsion Program evaluates small specimens of both fuel and non-fuel materials for
possible use in Naval reactor systems.  As discussed in EIS Volume 1, Appendix D, Section B.3, such
specimens are irradiated at the INEL Test Reactor Area and then returned to the Expended Core Facility
for examination.  A typical specimen undergoes several cycles of irradiation and examination over a period
of months or years.  The examination includes nondestructive and destructive operations in the Expended
Core Facility water pools and shielded cells.  The destructive operations may include, for example,
sectioning of specimens for additional testing or analysis.
Certain specimens may require specialized testing or examination not available at the Expended Core
Facility.  After the initial inspections at ECF, these specimens are shipped off- site, typically to the Knolls
Atomic Power Laboratory or the Bettis Atomic Power Laboratory, for further inspection in their shielded
cells and glove boxes.
In summary, all Naval spent nuclear fuel and test specimens are examined at the Expended Core Facility at
INEL.  Nearly all of the individual tests and examinations are performed in the Expended Core Facility
water pools and shielded cells.  There are currently no other facilities available to the Navy which could
perform this work, but alternatives to the use of the Expended Core Facility at INEL are evaluated in this
EIS.  Specialized tests and examinations may be performed at off-site locations and environmental impacts
associated with the transportation of these specimens are included in this EIS (refer to Attachment A) to
provide a complete and comprehensive evaluation for all alternatives considered.

II COMMENT

There is a need to examine Naval spent nuclear fuel to maintain the safety of the nuclear- powered Naval
vessels and to promote improvements in that fuel, including longer-lived cores which produce less spent
nuclear fuel for a given amount of energy produced.
RESPONSE
The observation that examination of Naval spent nuclear fuel is important to maintaining the safety of the
Navy's nuclear power program and to improving the performance of future designs, along the way reducing
the amount of spent nuclear fuel which must be managed, supports the Navy's evaluation of the alternatives
in this EIS.  The ability to examine all Naval spent nuclear fuel is a factor in the selection of the Navy's
preferred alternative for the management of spent nuclear fuel.  The examination of spent Naval fuel
absorbs considerable resources.  In a time of extremely tight budgets, the Navy would not be performing
such examinations unless they were judged to be necessary to support the conduct of technical work. 
Examinations done over the last 37 years have played a key role in achieving over 4400 reactor-years of
safe nuclear reactor operations, having nuclear-powered warships steam over 100,000,000 miles, and
increasing core lifetimes from 2 years to over 20 years.  The record shows there is no reason for reducing
the technical basis upon which safe Naval reactor design and operation are founded -- and that basis
includes as a key cornerstone the examination of Naval spent nuclear fuel.

II II COMMENT

The possibility that Native American, Native Hawaiian, or other groups, including low income groups
might suffer disproportionately high human health effects or environmental impacts under any of the
alternatives considered for management of spent nuclear fuel should be evaluated.
RESPONSE
Analyses of the impacts associated with management of Naval spent nuclear fuel showed that any effects
on human health or the environment would be small for all of the alternatives considered.  The potential
impacts due to normal operations or hypothetical accident conditions associated with the management of
Naval spent nuclear fuel present little or no significant risk and do not constitute a credible adverse impact
to the surrounding population.  Therefore, the impacts of Naval spent nuclear fuel management also do not
constitute a disproportionately high and adverse impact to any particular segment of the population,
minorities and low-income groups included.
A description of the composition of the populations surrounding the sites considered for management of
Naval spent nuclear fuel and the results of evaluation of the potential for disproportionately high and
adverse impacts on subgroups of these populations has been added to Chapters 4 and 5 of Appendix D to
Volume 1. 

II II COMMENT

Some persons stated that they believed that past environmental practices of the Navy had resulted in
contamination of the water or soil in a location.  Most of these statements did not identify the specific
practices involved and in some cases did not identify a specific location, but one mentioned toxic waste in
Kitsap County, Washington, another mentioned pollution of Puget Sound, and some mentioned the
Kahoolawe and Waikane Valley areas of Hawaii.
RESPONSE
The Navy complies with all applicable federal, state, and local environmental laws and regulations for
protection of the environment.  Some of the federal laws and regulations which apply to Navy activities
include the Resource Conservation and Recovery Act (RCRA), the Toxic Substances Control Act (TSCA),
the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), the Superfund
Amendments and Reauthorization Act (SARA), the Safe Drinking Water Act, the Clean Water Act, and the
Clean Air Act, among many others.  All of these laws have either the U. S. Environmental Protection
Agency or appropriate departments in the host states as the regulator.  The Naval Nuclear Propulsion
Program's compliance with these laws is actively monitored by the EPA and the states and in recent years
there have been more than 300 inspections, examinations, and audits by state and federal agencies under
these laws with no significant findings.
Some concerns expressed about past environmental practices were not specific enough to permit
evaluation.  Others do not relate to the activities of the Naval Nuclear Propulsion Program, such as
Superfund sites in Kitsap County and the pollution of the Chesapeake Bay.
The Kahoolawe and Waikane Valley areas of Hawaii were target ranges.  These areas have not been
affected by the operation or servicing of nuclear-powered Naval vessels.  Similarly, the concerns about the
effects of past environmental practices at Pearl Harbor do not appear to be specifically related to the
activities of the Naval Nuclear Propulsion Program.  However, the Pearl Harbor Naval complex, the U.S.
Environmental Protection Agency, and the state of Hawaii recently entered into a Federal Facility
Agreement under Section 120 of the Comprehensive Environmental Response Compensation and Liability
Act (CERCLA).  This agreement has as its purpose the investigation and remediation of the environmental
impacts of past and present Navy activities at Pearl Harbor and assurance of the effectiveness of cleanup
actions by coordination with federal and state authorities.
Some of the issues identified in comments may appear to be related to the Naval Nuclear Propulsion
Program, but review of these cases has shown that they are not caused by the Program or the Navy.  The
following are examples of such matters:
1.  The report in the Seattle Post-Intelligencer of March 9, 1994, that low levels of Iodine-131 have been
detected in the water around Puget Sound Naval Shipyard apparently did not include the fact that the site
where Iodine-131 was identified is located near the outfall of the Bremerton sewage treatment plant. 
Iodine-131 is commonly used for therapeutic purposes in the treatment of medical patients who have
thyroid disorders and it is not unusual to detect Iodine-131 in sanitary sewer effluent resulting from
patients' excreta.  Consequently, the most likely source of the Iodine-131 found in Sinclair inlet is from
medical applications. 
Activities associated with Naval nuclear operations at the shipyard do not result in intentional discharge of
any radioactive liquid effluent. In addition, Iodine-131 is a product of fission in nuclear reactors, but all
Iodine-131 produced from Naval nuclear operations at the shipyard is totally contained within the nuclear
fuel and could not escape to the reactor coolant or the environment.  Frequent routine testing of the reactor
coolant confirms that Iodine-131 is not released from the fuel.  Consequently, the source of any radioactive
iodine in the waters of Puget Sound was not released from activities associated with nuclear-powered Naval
vessels.
2.  The reason Saratoga County was fined by the State of New York for problems in Kayderosseras Creek
during work on the Northline Bridge was not related to material released from the Kesselring Site.  In fact,
the fine had nothing to do with the sediment in the creek or material from the Kesselring Site or any other
site along the streams involved.  This has been confirmed by the Director of the Saratoga County
Environmental Management Services.
There is a memorandum of understanding between the New York State Department of Environmental
Conservation and Saratoga County covering work in watercourses and wetlands associated with bridge
maintenance or renovation.  The New York State Department of Transportation requested Saratoga County
to perform some work to prevent erosion or undercutting of the approaches to the Northline Bridge.  While
performing the requested modifications to the Northline Bridge approaches, Saratoga County exceeded the
scope of work allowed by the memorandum of understanding.  The New York State Department of
Environmental Conservation believed that the County should have obtained additional permission to
perform the work and consequently fined Saratoga County.
Annual sampling of Glowegee Creek upstream and downstream from the Kesselring Site confirms that
there is no significant difference between radioactivity upstream and downstream.  The results of sediment
sampling and other routine environmental sampling at and around the Kesselring Site are provided every
year to state, county, and local officials.
None of the issues raised in such comments are related to the management of Naval spent nuclear fuel or
the actions considered in this EIS.

II COMMENT

Some persons stated or implied that they believe that the Navy has not made reports of monitoring
available to the public, has incorrectly represented the conclusions of these reports, or has released
pollutants to the environment in violation of laws or regulations.
RESPONSE
This comment has no basis.  Navy Nuclear Propulsion Program work is subject to and complies with all
applicable Federal, state, and local regulations for protection of the environment, including the Resource
Conservation and Recovery Act (RCRA), the Toxic Substances Control Act (TSCA), the Comprehensive
Environmental Response Compensation and Liability Act (CERCLA), the Superfund Amendments and
Reauthorization Act (SARA), the Safe Drinking Water Act, the Clean Water Act, and the Clean Air Act,
and others.  The U. S. Environmental Protection Agency or state agencies regulate Naval Nuclear
Propulsion Program work in accordance with these statutes.
Compliance with these laws for Naval Nuclear Propulsion Program work is actively monitored by the EPA
and the states and over the last 14 years there have been more than 200 inspections, examinations, and
audits by state and Federal agencies under these laws with no significant problems identified and no fines
or penalties imposed.  The reports of the monitoring and inspections performed by these agencies can be
obtained from the agency involved, and the Navy has provided copies of many of these reports in response
to requests from the public.
The Navy has provided a large amount of information on the shipment of Naval spent nuclear fuel and the
types and amounts of radiation or radioactive material involved in releases from normal operations and
postulated accidents in Appendix D to Volume 1.  Appendix D also includes descriptions of the Expended
Core Facility and Naval spent nuclear fuel operations, including transportation (See, for example, Chapters
2 and 3 and Attachments A, B, and F).  The Navy has attempted to provide enough information on
radiation, radioactivity, and other aspects of operations or hypothetical accidents to allow independent
calculation of the environmental impacts.  This is intended to permit independent analysis and verification
of the estimated impacts calculated by the Navy.  Every effort has been made during the preparation of this
EIS to see that the best available information on impacts has been included.

II COMMENT

The commentor suggests that INEL's Radioactive Waste Management Information System Solid Waste
Master Database under-reports the curie content of Navy wastes sent to the Radioactive Waste
Management Complex, and that the wastes were buried in a manner that does not comply with applicable
regulations.  The commentor further states that items in the database in question were inappropriately
deleted during a database validation conducted in fiscal year 1992.
RESPONSE
This comment is inaccurate.  The Navy has complied and continues to comply with all applicable Federal,
state, and local regulations for protection of the environment and handling and disposing of radioactive
waste.  The commentor's reference to burial of 8 million curies at INEL appears to be based on erroneous
data in a 1989 unvalidated version of the database, later corrected by DOE personnel.
During the approximately 40 years of operation of the Navel Reactors Facility at INEL, the Naval Nuclear
Propulsion Program has shipped approximately 4 million curies of low-level radioactive waste to the INEL
Radioactive Waste Management Complex for disposal in accordance with all applicable regulations and
stringent controls.  Burial of low-level radioactive waste is the method for disposal prescribed by the
Nuclear Regulatory Commission for waste under its jurisdiction.  Sampling of the soil and groundwater in
the vicinity of  INEL has shown that the material buried at INEL for the Naval Nuclear Propulsion Program
has had no detectable effect on air or water quality and has had no effect on the environment beyond the
boundaries of the burial ground.
Examination of the database revealed that the entry proposed by the commentor as being deleted from the
database was, in fact, present in the database.

II COMMENT

The commentor stated concern that Pearl Harbor Naval Shipyard already holds some large containers of
radioactive waste and that the Navy claims such storage poses little threat to the surrounding community.
RESPONSE
This comment apparently refers to the use of shipping containers to store Naval spent nuclear fuel from
recently defueled ships at Pearl Harbor Naval Shipyard during the period required for preparation of this
EIS.  The storage of these containers is covered under the Environmental Assessment for Short Term
Storage of Naval Spent Fuel, dated December 1993, and issued by the U.S. Department of the Navy and
the associated finding of No Significant Impact.  Section 3.1 of the Environmental Assessment presents the
results of analyses of the environmental impacts associated with the  storage of a small number of
containers at Pearl Harbor until the Record of Decision supported by this EIS is issued on June 1, 1995. 
Volume 1, Appendix D, Section F.1.4.1.5 of the EIS presents the radiation exposure analysis results for the
storage of many more containers.  The results of both analyses show that risks to workers or the public
from the storage of Naval spent nuclear fuel in shipping containers at the Pearl Harbor Naval Shipyard are
very low.

II COMMENT

The Southeastern Public Service Authority power plant located on the Norfolk Naval Shipyard has emitted
dioxin.  The operation of the plant has not demonstrated a community good faith approach.
RESPONSE
Although this comment is not related to Naval spent nuclear fuel management, a response has been
provided.
The Southeastern Public Service Authority (SPSA) is a public agency created by the Virginia Water and
Sewer Authority Act.  In October 1992, SPSA assumed responsibility for operation and maintenance of the
refuse-derived fuel plant, operating the plant under contract to the Navy.  Solid wastes received from
communities including Norfolk, Portsmouth, Chesapeake, Suffolk, Isle of Wight, Virginia Beach, Franklin,
and Southhampton are shredded after sorting and removal of recyclable materials and burned in the plant
to produce steam for the Norfolk Naval Shipyard and electricity to supplement the service supplied by
Virginia Electric Power.  The SPSA plant at Norfolk Naval Shipyard does not violate the requirements of
the Clean Air Act since the U. S. Environmental Protection Agency (EPA) does not require compliance
with any standard for dioxin emissions until 1996.  In the absence of a federal standard for dioxin
emissions, in 1989 the state of Virginia, with Navy agreement, incorporated into the plant's air emissions
permit a dioxin standard consistent with the dioxin limit the EPA plans to implement in 1996.  The Navy
agreed to this standard at the time based on test data which was collected when the plant was relatively
new, but that data apparently was not representative of the long- term, steady-state operating conditions
because monitoring later showed dioxin levels exceeded these limits.  When the emissions were found to
exceed the permit levels, the Navy, SPSA, and the Virginia Department of Environmental Quality
established an agreement which resulted in a multimillion dollar contract, initiated in May 1993, to install
state of the art pollution control equipment which exceeds EPA criteria.  The plant will be in compliance
with the Clean Air Act requirements in September 1995, two months ahead of the EPA schedule.
In the meantime, a unique spray water system operating in the flues for all boilers at the plant has been
proven to reduce the dioxin and furan emissions by 95%.  Risk exposure studies by the Virginia
Department of Health have concluded that there is no unacceptable risk associated with the operation of
the SPSA plant and sampling in the vicinity of the plant has found no dioxin or furan levels above
background levels.
On a related point raised by the commentor, there is no record of a 1972 Supreme Court ruling involving
the SPSA and the subject of dioxins at the refuse-derived fuel plant.

II COMMENT

Commentors provided statements of personal knowledge and conviction that the safety record of the Navy
in servicing nuclear-powered vessels and in handling and shipping Naval spent nuclear fuel which support
the Navy's statements in this EIS.  Some commentors affirmed the relationship between examining all Naval
spent nuclear fuel and ensuring the safety of nuclear-powered vessels and the sailors who serve aboard
them. 
RESPONSE
These comments support the Naval Nuclear Propulsion Program and its continuing efforts to maintain
safety and minimize the risks associated with operation of the nuclear fleet.  Protecting the people who sail
and service nuclear-powered vessels, the public, and the environment has always been one of the highest
priorities of the Navy.

II 8.4 Proposed Action and Alternatives

II COMMENT

The Navy should consider some different alternatives than those in the Environmental Impact Statement.
RESPONSE
The Navy has considered in this Environmental Impact Statement all alternatives considered reasonable, as
required by NEPA (42 USC 4332) and Federal regulations (40 CFR 1502.14).

II COMMENT

The "no action" alternative should be revised to consider the cessation of nuclear powered warship
refueling and defueling to make it a true "no action" alternative.
RESPONSE
Spent nuclear fuel and nuclear-powered warships currently exist, so there can be no alternative which truly
involves no action.  The No Action alternative defined in the EIS represents the minimum practical amount
of action which can be taken with respect to spent nuclear fuel.
Ceasing the refueling and defueling of nuclear powered warships would entail substantially more action
than the description of the "no action" alternative currently in the EIS.  Specifically, the Navy would need
to: (a) provide additional pier space to tie up ships which would have otherwise been refueled or defueled;
(b) keep more Naval personnel on duty as crew members for ships which were scheduled to be
decommissioned; (c) rearrange operating schedules to reflect for the unavailability of nuclear-powered
warships planned for refueling; (d) substantially reduce the work at Naval shipyards resulting in the layoff
of thousands of workers with commensurate serious economic impacts to the communities involved; and
(e) remove some ships from operation thus reducing the fleet size below the level needed to support
national policies.  For these reasons, as discussed in Section 3.6.3 of Appendix D to Volume 1, an
alternative of leaving nuclear fuel aboard nuclear-powered warships was not examined in detail.

II COMMENT

Storage for periods of the length considered in the EIS is not seen by some as "temporary" or "interim".
RESPONSE
Volume 1 of this EIS considers alternative approaches to safely, efficiently, and responsibly manage
existing and projected quantities of spent nuclear fuel until the year 2035.  This amount of time may be
required to make and implement a decision on the ultimate disposition of spent nuclear fuel.  This EIS
provides the environmental information to support decisions that will facilitate a transition between DOE's
current practices and ultimate disposition of spent nuclear fuel.  The Navy and DOE intend to make the
transition from fuel management under the alternatives considered in this EIS to ultimate disposition as
quickly as practicable.

II COMMENT

Navy plans for dealing with the transition from current practices for management of Naval spent nuclear
fuel to one of the other alternatives should be  discussed.
RESPONSE
The transition period required if certain alternatives were selected is described in Section 3.8 of Appendix
D to Volume 1.  As described in Section 3.8, the transition would make use of existing facilities and
transportation methods described under the alternatives considered.  The risks associated with all of the
alternatives considered for management of Naval spent nuclear fuel, summarized in Chapter 3 of Appendix
D are small, so the risks associated with the transition period would be just as small.

II COMMENT

A commentor advocated storage of Naval spent nuclear fuel at the Expended Core Facility at INEL for a
number of reasons.
RESPONSE
Long-term storage of spent nuclear fuel at the Expended Core Facility is not among the alternatives
evaluated in the EIS because such storage would result in no reduction in environmental impacts from
those for the alternatives considered and it would have a severe impact on the Navy's ability to perform its
mission.  Storage in the water pools at the Expended Core Facility would effectively preclude examination
of Naval spent nuclear fuel at that facility because storage would use up the space in the water pool needed
for machinery and examination equipment.  This would require the construction of new facilities for the
examination of Naval spent nuclear fuel or the loss of the ability to perform examinations of Naval spent
nuclear fuel.  The impact on the Navy's mission that would result from the loss of the ability to examine
Naval spent nuclear fuel is described in Chapter 3 of this EIS.
Analyses of the impacts associated with storage of the Naval spent nuclear fuel at DOE sites are included in
the appendices to the EIS for each site.  For example, section 5 of Volume 1, Appendix B, includes the
impact of storing Naval spent nuclear fuel in water pools at INEL.
Attachment F to Appendix D, Section F.1.4.1.4, does present the impacts of performing spent fuel
examination at Expended Core Facility.  In addition, the impacts of spent nuclear fuel examination at all of
DOE sites and Puget Sound Naval Shipyard and the impacts of water pool storage at the Naval shipyard
sites are presented.  Results of analyses of the impacts for dry storage at all of the Navy sites considered in
this EIS are also provided.  These results are shown in Section F.1.4.1.5 of Attachment F.  For INEL
analysis, a site near the Expended Core Facility at the Naval Reactors Facility was selected.

II COMMENT

According to a commentor, one hundred Naval spent nuclear fuel shipments to INEL planned during a
transition from current practices for management of Naval spent nuclear fuel to one of the other
alternatives make the No Action alternative a misnomer.
RESPONSE
The scope of this EIS is somewhat unique in that it evaluates ongoing operations; it is solely an assessment
of an action not yet initiated.  Accordingly, each alternative evaluated in this EIS for all spent nuclear fuel
must involve some period of transition and implementation while new facilities are developed or procured. 
During the transition periods, which range from about three years for the No Action alternative up to about
20 years for Centralization of all DOE spent nuclear fuel, existing facilities would continue to be used for
managing spent nuclear fuel.  Under the No Action alternative, Naval spent nuclear fuel would be
transported to INEL while shipping containers are procured for storage at Navy sites.  This EIS evaluates a
40 year period, so a three year transition period is not excessive.  Alternatives which would not require
transportation for Naval spent nuclear fuel to INEL during a transition are untenable because the Navy
would be unable to refuel and defuel naval vessels, thereby greatly impacting national security as further
explained below and in Volume 1, Appendix D, Section 3.6.3.  Moreover, such an approach would
actually involve substantially more action and environmental impacts than shipment of the Naval fuel to
INEL because all of the containers available to store Naval spent nuclear fuel at shipyards and prototype
sites have been filled during the period while this EIS was being prepared.
Of particular importance in this regard is the refueling of the aircraft carrier USS NIMITZ.  Refueling of the
USS NIMITZ is scheduled to begin in 1998, but refueling preparations are already underway for this first-of-a-kind effort.  
These preparations entail emptying, by late 1995, spent nuclear fuel from the earlier
refueling of the USS ENTERPRISE and defueling of the USS LONG BEACH.  This spent nuclear fuel is at
Newport News Shipbuilding and Drydock Company in a special support facility which is required for the
NIMITZ Class refuelings.  Once the facility is emptied, it would then be reconfigured for use, including
refurbishment, maintenance, and extensive training of refueling personnel.
If the facility cannot be emptied, the USS NIMITZ cannot be refueled.  The result is that the Navy would
have fewer carriers than congressionally mandated to fulfill its national security requirements for regional
conflicts (such as Operation Desert Storm) and peacekeeping (such as Somalia and Haiti).  The national
security need to ensure that the USS NIMITZ is refueled on schedule was certified by the Secretary of
Defense in October 1994 and accepted by the Governor of Idaho in January 1995, when he allowed
shipment of naval spent nuclear fuel from the Newport News Shipbuilding and Drydock Company to
continue.  Additional shipments would be required after the Record of Decision is issued on this EIS in
June 1995 to complete unloading the facility by late 1995.
Volume 1, Appendix D, Section 3.6.3 provides a description of the impacts to the Navy mission (and to the
environment) that would arise from storing naval spent nuclear fuel on inactive ships.  In summary, storing
naval spent nuclear fuel aboard inactive ships would use up the limited space at shipyards, idle skilled
shipyard workers when the shipyards ran out of ship servicing work and room to do work, and tie up highly
trained Navy nuclear ship operators.  In return, this concept would not produce lower environmental
impacts than the alternatives considered in detail in this EIS and might actually increase the environmental
impacts.

II COMMENT

The selection of the preferred alternative for the Navy should be based on a combination of the lowest risk
and the lowest cost.
RESPONSE
Section 3.9 of Appendix D to Volume 1 of this EIS states that the selection of the navy's preferred
alternative was based on consideration of several important issues, including consideration of the very
small environmental impacts associated with all of the alternatives considered.  Two of the predominant
issues are cost and risk.  Section 3.7.4 provides a summary of how the cost and risk values vary among the
alternatives.
A comparison of the change in the number of potential cancer fatalities that might occur in the general
population for each year of operation for each Naval spent nuclear fuel alternative is provided in Section
3.7.1.1, Table 3-1, in Appendix D to Volume 1.  This comparison is broken down to show the risks
associated with normal operations, the highest risk facility accident, and transportation operations.  The
risks due to Naval Nuclear Propulsion Program activities for any of the alternatives considered is very
small.  In all cases, thousands of years of repetition would be required before a single additional cancer
fatality would occur.  These risks are all so small that there is no real difference among the alternatives
from the standpoint of risk.
The costs associated with each Naval spent nuclear fuel alternative are summarized in Table 3- 8 in Section
3.7.4 of Appendix D to Volume 1.  The costs to the Navy for the alternatives considered range between
$1.5 billion and $5.7 billion over 40 years.

II COMMENT

Naval spent nuclear fuel shipping containers are ill-suited for storage.
RESPONSE
Naval spent nuclear fuel shipping containers are designed to withstand the rigors of shipment and
hypothetical accidents which might occur during shipping.  As a result, the certified shipping containers for
Naval spent nuclear fuel are rugged enough to endure the far less demanding conditions associated with
storage at Navy sites.  This fact is borne out by the Navy's Environmental Assessment for storage of Naval
spent nuclear until this EIS is completed and by the analyses provided in Attachment F of Appendix D to
Volume 1 of this EIS.
As stated in Appendix D, a long-term seal would be needed to replace the rubber seal in the shipping
containers if an alternative utilizing the shipping containers for storage for 40 years were selected as a
result of this EIS.  However, the existing seal is designed to last many years and is adequate for the period
until that decision is made.  The current shipping container seals are designed to contain radioactive
material during frequent loading and unloading operations and during shipment, requiring it to be flexible
and reusable.  Design of a seal for long-term storage would be simpler because repeated opening and
closing of the container lid would not occur during storage, allowing use of such methods as welding the
container shut.

II COMMENT

Naval spent nuclear fuel is being left indefinitely in shipping containers at shipyards.
RESPONSE
Naval spent nuclear fuel is being stored in sealed shipping containers at Navy sites during the period
required for preparation of this EIS and selection of an alternative for management of DOE spent nuclear
fuel.  The environmental impacts associated with this storage were evaluated in an Environmental
Assessment and Finding of No significant Impact issued in early 1994.  An Environmental Assessment was
prepared and a Finding of No significant Impact was issued because the impacts of the of the preferred
alternative for this short period of storage were found to be small.  The alternative which used storage in
certified shipping containers at the sites which would continue to perform servicing of Naval reactors
through June 1995 was selected as the best means of safely managing Naval spent nuclear fuel during the
time needed for completion of this EIS.
The Record of Decision identifying the alternative selected for management of spent nuclear fuel selected
will be issued on June 1, 1995.  At that time, implementation of the alternative selected will begin.  Naval
spent nuclear fuel stored at Navy sites will be transferred to the locations associated with the alternative
selected unless an alternative making use of storage at the Navy sites is selected.

II COMMENT

Management of Naval spent nuclear fuel at a Navy site should not be considered because of proximity to
population centers.
RESPONSE
Under NEPA, the Navy is required to consider the full range of reasonable alternatives, including the
alternative of taking no action.  The analysis in the EIS demonstrated that the environmental impact of any
of the alternatives would be small.  This analysis took into consideration population data for each site. 
Therefore, the Navy did not eliminate any locations from consideration based on these characteristics.
Although Naval sites are included in the analysis, the Navy has identified a preferred alternative in Section
3.9, Appendix D, Part A which would not store Naval spent nuclear fuel at Naval sites.  The Navy's
preferred alternative would resume the historic, technically sound and safe practice of conducting refueling
and defueling of nuclear-powered warships and prototypes as planned, transporting the Naval 
spent nuclear fuel to the Expended Core Facility at INEL for full inspection and examination, and
transferring Naval spent nuclear fuel to DOE for storage at that site.

II COMMENT

Management of Naval spent nuclear fuel at a Navy site should not be considered because of an airport in
the vicinity.
RESPONSE
The analyses in Appendix D to Volume 1 of the EIS specifically considered the location and characteristics
of the airports in the vicinity of each site (See Attachment F of Appendix D to Volume 1).  Even taking this
into account, the risk from an airplane crashing into a shipping container was shown to be very low and the
resulting risk of injury to the public small.  For example, the most limiting accident involving Naval spent
nuclear fuel is described in Attachment F of Appendix D to be an airplane crash into a shipping container
at the Pearl Harbor Naval Shipyard.  This accident would lead to 26 latent fatal cancers over the next fifty
years in the population within 50 miles of the shipyard.  Since the probability of the event is one chance in
100,000 per year, the risk would be 0.00026 latent fatal cancer fatalities per year or, in other words, about
one chance in 4000 of single latent cancer fatality over a year.  This risk is shared among the approximately
820,000 people residing within 50 miles of the shipyard who would be expected to experience over 2000
cancer fatalities from all other causes every year.

II COMMENT

Management of Naval spent nuclear fuel at Pearl Harbor Naval Shipyard should not be considered because
the Honolulu airport is close enough that it might be damaged, making it more difficult for emergency
assistance to reach the island.
RESPONSE
The most limiting accident involving Naval spent nuclear fuel is described in Attachment F of Appendix D
to Volume 1 to be an airplane crash into a shipping container at the Pearl Harbor Naval Shipyard.  This
accident would lead to 26 latent fatal cancers over the next fifty years in the population within 50 miles of
the shipyard.  Since the probability of the event is one chance in 100,000 per year, the risk would be
0.00026 latent fatal cancer fatalities per year or, in other words, about one chance in 4000 of single latent
cancer fatality over a year.  This risk is shared among the approximately 820,000 people residing within 50
miles of the shipyard who would be expected to experience over 2000 cancer fatalities from all other
causes every year.  The analyses in Appendix D of the EIS specifically considered the location of the
Honolulu airport relative to Pearl Harbor Naval Shipyard.  It also estimated the extent of contamination
that might result from hypothetical accidents.  The analysis of the impact of hypothetical accidents in
Appendix D of the EIS did not rely on any off-shipyard response.
Taking into account the location of the airport and the effects of hypothetical accidents, the risk that the
Honolulu airport could not be used to provide emergency assistance from the mainland would be very low
and the resulting risk to the public small.  Further, the Navy has significant emergency response capability
on Oahu and does not rely on the mainland, State, or local resources for emergency response beyond
existing emergency plans and resources.

II COMMENT

Management of Naval spent nuclear fuel at a Navy site should be ruled out because of an aquifer, stream,
or other water in the vicinity.
RESPONSE
Although the Navy's preferred alternative is not to store Naval spent nuclear fuel at Naval sites, under
NEPA, the Navy is required to consider the full range of reasonable alternatives, including the alternative
of taking no action.  The analysis in the EIS demonstrated that the environmental impact of any of the
alternatives would be small.  This analysis took into consideration nearby bodies of water.  Therefore, the
Navy did not eliminate any locations from consideration based on these characteristics.  The Navy has
managed its spent nuclear fuel for nearly 40 years now without any significant environmental impact on
water.

II COMMENT

Management of Naval spent nuclear fuel at a Navy site should be ruled out because of the possibility of
seismic activity in the vicinity.
RESPONSE
Although the Navy's preferred alternative is not to store Naval spent nuclear fuel at Naval sites, under
NEPA, the Naval Nuclear Propulsion Program is required to consider the full range of reasonable
alternatives, including the alternative of taking no action.  The analyses in Appendix D (See Attachment F,
Sections F.1.2, F.1.3, and F.1.4) took into consideration accidents which might be caused by natural
phenomena, including earthquakes equaling or exceeding the design basis of the facilities, and
demonstrated that the impacts were found to be small.  Any facility constructed for Naval spent nuclear
fuel management would be designed with adequate strength based on the specific seismic characteristics of
the site.  Therefore, the Navy did not eliminate any locations from consideration based on these
characteristics.  See also response 08.04(015).

II COMMENT

Management of Naval spent nuclear fuel at a Navy site should be ruled out because of the possibility of
severe weather in the vicinity.
RESPONSE
Although the Navy's preferred alternative is not to store Naval spent nuclear fuel at Naval sites, under
NEPA, the Naval Nuclear Propulsion Program is required to consider the full range of reasonable
alternatives, including the alternative of taking no action.  The analyses in Appendix D the EIS (See
Chapter 5 and Attachment F, Section F.1) showed that the environmental impact of any of the alternatives
would be small, including accidents which might be caused by natural phenomena, such as hurricanes,
tsunamis, or tornados.  Any facility constructed for Naval spent nuclear fuel management would be
designed with adequate strength based on the specific weather characteristics of the site.  Therefore, the
Navy did not eliminate any locations from consideration based on these characteristics.

II COMMENT

Additional Department of Defense sites should be considered.
RESPONSE
A site selection process was followed which is described in depth in the EIS and in associated reference
documents.  In view of the range of types of sites analyzed in the EIS (from large populations in coastal
areas to remote, desert-like, sparsely populated areas) and the conclusion that environmental impacts
would be very small at all sites, extrapolation to other sites would be expected to yield similar results.
For management of Naval spent nuclear fuel, certain physical requirements, such as a rail siding or paved
roadway, and administrative and support functions needed to safely handle and monitor the operations and
spent fuel are needed.  These administrative and support functions include physical security (since the
spent fuel contains highly enriched uranium), radiological monitoring, and emergency response capability. 
In view of the very small impacts for the sites considered, providing these administrative and support
functions and the physical facilities at a site which does not have them would produce greater impacts on
the environment with no associated reductions in impact.

II COMMENT

The Navy should consider some other site, either specified or not specified in the comment.
RESPONSE
For management of Naval spent nuclear fuel, certain physical requirements, as a rail siding or paved
roadway, and administrative and support functions needed to safely handle and monitor the operations and
spent fuel are needed.  These administrative and support functions include physical security (since the
spent fuel contains highly enriched uranium), radiological monitoring, and emergency response capability. 
In view of the very small impacts for the sites considered, providing these administrative and support
functions and the physical facilities at a site which does not have them would produce greater impacts on
the environment with no associated reductions in impact.

II COMMENT

The Navy should consider some other site which is not specified.
RESPONSE
For management of Naval spent nuclear fuel, certain physical requirements, such as a rail siding or paved
roadway, and administrative and support functions needed to safely handle and monitor the operations and
spent fuel are needed.  These administrative and support functions include physical security (since the
spent fuel contains highly enriched uranium), radiological monitoring, and emergency response capability. 
In view of the small impacts for the sites considered, providing these administrative and support functions
and the physical facilities at a site which does not have them would produce greater impacts on the
environment with no associated reductions in impact.

II COMMENT

Management of Naval spent nuclear fuel at a Navy site should not be considered if it is judged to be a
scenic area.
RESPONSE
Under NEPA, the Navy is required to consider the full range of reasonable alternatives, including the
alternative of taking no action.  The analysis in the EIS demonstrated that the environmental impact of any
of the alternatives would be small.  This analysis took into consideration the aesthetic and scenic values for
each site and showed that any impacts in this category would be small.  Therefore, the Navy did not
eliminate any locations from consideration based on these characteristics.
Although Naval sites are included in the analysis, the Navy has identified a preferred alternative in Section
3.9, Appendix D, Part A which would not store Naval spent nuclear fuel at Naval sites.  The Navy's
preferred alternative would resume the historic, technically sound and safe practice of conducting refueling
and defueling of nuclear-powered warships and prototypes as planned, transporting the Naval spent
nuclear fuel to the Expended Core Facility at INEL for full inspection and examination, and transferring
Naval spent nuclear fuel to DOE for storage at that site.

II COMMENT

Management of Naval spent nuclear fuel at a Navy site should not be considered if it is judged to be an
environmentally sensitive area.
RESPONSE
Under NEPA, the Navy is required to consider the full range of reasonable alternatives, including the
alternative of taking no action.  The analysis in the EIS demonstrated that the environmental impact of any
of the alternatives would be small.  This analysis took into consideration possible effects on the ecology for
each site and showed that any impacts in this category would be small.  Therefore, the Navy did not
eliminate any locations from consideration based on these characteristics.
Although Naval sites are included in the analysis, the Navy has identified a preferred alternative in Section
3.9, Appendix D, Part A which would not store Naval spent nuclear fuel at Naval sites.  The Navy's
preferred alternative would resume the historic, technically sound and safe practice of conducting refueling
and defueling of nuclear-powered warships and prototypes as planned, transporting the Naval spent
nuclear fuel to the Expended Core Facility at INEL for full inspection and examination, and transferring
Naval spent nuclear fuel to DOE for storage at that site.

II COMMENT

Use of the Puget Sound Naval Shipyard Water Pit Facility will preclude the performance of aircraft carrier
refuelings at Puget Sound Naval Shipyard and consequently jobs would be lost at the shipyard.
RESPONSE
The Decentralization Alternative for Naval Spent Nuclear Fuel Management includes an option which
would utilize the Puget Sound Naval Shipyard Water Pit Facility for examination of high priority fuel.  As
stated in this Environmental Impact Statement, the use of this facility for spent nuclear fuel inspection
would preclude its use for support of aircraft carrier refuelings.  If the option of using the existing water
pool for fuel examination under the Decentralization Alternative were selected, it would be necessary to
find other ways to support aircraft carrier refuelings.  Due to the limited space available at Puget Sound
Naval Shipyard, it might prove difficult to find alternate means to provide the needed support for aircraft
carrier refueling at that shipyard.
Long range plans have included Puget Sound Naval Shipyard as the west coast location for conducting
aircraft carrier refuelings.  This was the basis for constructing the Water Pit Facility.  Including the ships
currently under construction, the Navy will have at least nine nuclear- powered aircraft carriers.  While no
near-term refuelings are scheduled for Puget Sound Naval Shipyard, it is expected that future plans and
overlapping of refuelings and defuelings will require simultaneous servicing of two aircraft carriers, which
might require two shipyards to perform the work.  The comment presupposes that these refueling jobs exist
at Puget Sound Naval Shipyard and therefore could be lost, but other variations in the shipyard staffing
make this uncertain.

II COMMENT

Facilities for management of Naval spent nuclear fuel should not be located at sites where weapons are
handled or stored.
RESPONSE
Weapons are not handled or stored at any of the Navy sites considered in this EIS.  In the case of some
locations, such as the Pearl Harbor or Norfolk Naval Shipyard, other Navy facilities which handle or store
weapons are in the same general vicinity, but they are separated from the sites considered by a great enough
distance that the weapons would not constitute a threat to Naval spent nuclear fuel management.
Even though accidents associated with weapons are not reasonably expected to affect Naval spent nuclear
fuel, the consequences of such accidents would be within the limits of other accidents not related to
weapons analyzed in this EIS.  Appendix D to Volume 1 of the EIS includes an evaluation of a broad range
of hypothetical accidents which might occur as a result of human error, equipment failure, or natural
phenomena, including fires involving the storage facilities and projectiles striking the storage facilities.  The
results of these analyses are summarized in Chapter 3, tabulated for each individual site in Chapter 5, and
described in detail in Attachment F.  The analyses show that the risks associated with all of the accidents
are very low.
Although the Navy's preferred alternative is not to store Naval spent nuclear fuel at Naval sites, under
NEPA, the Naval Nuclear Propulsion Program is required to consider the full range of reasonable
alternatives, including the alternative of taking no action.  The evaluation of potential impacts on human
health and the environment provided in this EIS shows that the risks associated with all of the alternatives
and sites considered is very small.

II COMMENT

Storage of Naval spent nuclear fuel at Puget Sound Naval Shipyard might result in the loss of the ability of
the shipyard to operate efficiently.
RESPONSE
It is true that space is at the Puget Sound Naval Shipyard must be managed carefully.  However, as shown
in Table D-1 in Appendix D to this EIS,  between 33,000 and 77,000 square feet would be required for
three of the four possible methods for storage of Naval spent nuclear fuel at Puget Sound Naval Shipyard,
with the fourth, storage in shipping containers on railcars, requiring 260,000 square feet.  Storing or
examining Naval spent nuclear fuel at Naval sites is not the Navy's preferred alternative.  Even so, if an
alternative which would use storage at Navy sites were selected, the needed area could be provided at the
shipyard without limiting its ability to carry out its mission effectively.
In Section 3.9 of Appendix D to this EIS, the Navy has clearly stated its preferred alternative for
management of Naval spent nuclear fuel during the 40 year interim period and discussed how this
alternative would support the Navy's mission, as established by Congress.  Appendix D to Volume 1
contains an evaluation of the environmental impacts of the Navy's proposed action and all alternatives,
including those which would not support the Navy's mission, in accordance with NEPA, the Council on
Environmental Quality regulations, and DOE and Navy regulations.

II COMMENT

Management of Naval spent nuclear fuel at a DOE site other than INEL should not be considered, because
it would be necessary to construct a new facility similar to the existing Expended Core Facility.
RESPONSE
Under NEPA, the Navy is required to consider the full range of reasonable alternatives, including
alternatives which would relocate the management of Naval spent nuclear fuel to other locations.  The
analysis in the EIS demonstrated that the environmental impact of any of the alternatives would be small. 
This analysis took into consideration the potential effects of normal operations and postulated accidents 
for each site and for transportation of Naval spent nuclear fuel.  Therefore, the Navy did not eliminate any
locations from consideration based on these characteristics.
Although sites which would require the construction of a replacement for the existing Expended Core
Facility at INEL are included in the analysis, the Navy has identified a preferred alternative in Section 3.9,
Appendix D, Part A which would not examine or store Naval spent nuclear fuel at those sites.  While this
EIS shows that environmental impacts of constructing and operating an examination facility would be very
small, the cost of constructing such a facility would exceed $800,000,000.  The Navy's preferred alternative
would resume the historic, technically sound and safe practice of conducting refueling and defueling of
nuclear-powered warships and prototypes as planned; transporting the Naval spent nuclear fuel to the
Expended Core Facility at INEL for full inspection and examination; and transferring Naval spent nuclear
fuel to DOE for storage at that site.

II COMMENT

The water table at Puget Sound Naval Shipyard is just below the ground surface.  Therefore, construction
of a water pit facility at this location might not be possible.
RESPONSE
Construction and operation of a water pool facility at Puget Sound Naval Shipyard is feasible as
demonstrated by the existing Water Pit Facility.  The groundwater table is relatively close to the surface of
the ground in this region and this makes building design and construction more complex, but it can be
accomplished in a safe manner.

II COMMENT

Management of spent fuel at Puget Sound Naval Shipyard should be ruled out because only rudimentary
inspection facilities are available at the shipyard.
RESPONSE
The Decentralization Alternative for Naval Spent Nuclear Fuel Management includes an option which
would utilize the Puget Sound Naval Shipyard Water Pit Facility for examination of high priority fuel.  As
stated by the commentor, this alternative would provide only a limited capability for examination and
analysis of Naval spent nuclear fuel and, as described in the EIS, the ability to sustain further development
of the advanced nuclear reactors needed to ensure the safety and performance superiority of U.S. Navy
ships would be jeopardized.  However, under NEPA, the Navy is required to consider the full range of
reasonable alternatives, so this alternative has been included.
Although an alternative involving inspection of a limited amount of Naval spent nuclear fuel at Puget
Sound Naval Shipyard is included in the analysis, the Navy identified a preferred alternative in section 3.9
of Appendix D to Volume 1 which would not involve inspection of Naval spent nuclear fuel at the
shipyard.  The Navy's preferred alternative would resume the historic, technically sound and safe practice
of conducting refueling and defueling of nuclear-powered warships and prototypes as planned, transporting
the Naval spent nuclear fuel to the Expended Core Facility at INEL for full inspection and examination,
and transferring Naval spent nuclear fuel to DOE for storage at that site.

II COMMENT

Any facility for management of spent nuclear fuel should be adequately designed for the purpose, but the
EIS should present conclusions about the storage options that would be employed at each site.
RESPONSE
Appendix D to Volume 1 of this EIS includes in Chapters 3 and 5 and Attachments D and E detailed
evaluation of methods and facilities for storage of Naval spent nuclear fuel at Navy sites under the
alternatives considered.  Chapters 3 and 5 and Attachment F provide detailed information on the exposures
and potential health effects associated with each method of Naval spent nuclear fuel management at
shipyards and Navy prototype sites, as well the effects associated with examination of Naval spent nuclear
fuel at DOE sites.  In all of these cases, it is assumed that the facilities used for Naval spent nuclear fuel
management would be properly designed for the weather, seismic, and other conditions applicable to the
particular site evaluated.
This EIS provides the information necessary to show that all three methods of storage at shipyards and
Navy prototype considered (dry storage, storage in shipping containers, and storage in water pools) are
practical and could be accomplished safely and with very small risks.

II COMMENT

Commentors express a preference for alternatives that do not result in additional nuclear waste or spent
nuclear fuel being managed in Hawaii.  In addition, commentors express one or more of the following
opinions:
          That such material be stored in areas of low population, as opposed to areas of high
          population
          That better sites are available that present less risk
          That there is a risk to water resources, fragile ecosystems, or the environment
RESPONSE
See responses to comments 08.01 (001) and 08.01 (004).

II 8.5 Technical Issues

II II COMMENT

The Navy will be contributing a large proportion of the future spent nuclear fuel that must be managed by
DOE.
RESPONSE
As stated in the Summary and other sections of Volume 1 of this EIS, spent nuclear fuel representing
approximately 100 metric tons of heavy metal (MTHM) will be added over the next 40 years to the amount
currently being managed by DOE.  Of this total, approximately 55 MTHM will be produced by the Naval
Nuclear Propulsion Program.  Since DOE currently manages approximately 2700 MTHM of spent nuclear
fuel, including about 10 MTHM of Naval spent nuclear fuel, the Naval spent nuclear fuel at the end of the
period evaluated in this EIS would be 65 MTHM, which is approximately 2% of the total of 2800 MTHM
considered.

II COMMENT

The unique nature of Navy fuel is secret and poses a greater threat than conventional fuel.
RESPONSE
The statement that Naval spent nuclear fuel presents a significantly greater environmental threat than other
conventional reactor fuel is incorrect and without technical basis.
Sections 2.2, 3.7, A.7, B.2, and F.1 of Appendix D to Volume 1 of this EIS present information on the
integrity of Navy fuel.  Further details on the nature of Naval spent nuclear fuel which can be used to
evaluate the environmental impact associated with its management are provided in Attachments A and F to
Appendix D.  Although the detailed design of Navy fuel is classified, this EIS contains significant
information concerning its performance characteristics.
These design requirements for Navy fuel include:
a.  Battle shock.  Navy fuel is designed to withstand the shock encountered in a wartime battle situation
without damage.  These shocks are well is excess of the seismic shocks for which other reactor fuels are
designed.  As an example, Navy fuel can withstand shocks much greater than 50g, or 50 times the
acceleration due to gravity.  Civilian reactors are designed only to withstand the shock of an earthquake
which is typically less than 1g.
b.  Long life.  Navy fuel is designed to operate in a high temperature and high pressure environment for
many years.  Current designs are capable of over 20 years of successful operation.  Typical civilian reactor
fuel is designed to operate for only a few years.
c.  Total containment of fission products.  Navy fuel is designed to operate throughout its lifetime without
any release of fission products.  This is essential to minimize radiation exposure to the crew who live inside
the confined space of a submarine for many months at a time.  Some civilian reactor fuels are designed to
operate with releases of fission products and Nuclear Regulatory Commission requirements for civilian fuel
allow for a primary coolant radioactivity level equivalent to about 0.1 percent fuel damage during normal
operations.  This results in detectable fission product activity in the reactor coolant produced from the fuel.
d.  Rapid power transients.  Navy fuel is designed to operate successfully during rapid power transients
(e.g., achieve full power in seconds) while typical civilian fuel takes many hours to achieve full power to
ensure it is not damaged.  The Navy requirement is based on the need to rapidly change speeds or direction
of a ship, for example, to outrun a torpedo.
All of these very stringent operational requirements for Naval nuclear fuel enable it to maintain its integrity
indefinitely under the far less demanding conditions encountered during transportation and storage.

II COMMENT

The EIS should include more details on the design and other characteristics of Naval spent nuclear fuel.
RESPONSE
Volume 1, Appendix D, sections 2.2, 3.7, A.7, B.2, and F.1 of this EIS present information on the integrity
of Navy fuel.  Further details on the nature of Naval spent nuclear fuel which can be used to evaluate the
environmental impact associated with its management are provided in Appendix D, 
Attachments A and F.  Although the detailed design of Navy fuel is classified, this EIS contains significant
information concerning its performance characteristics.
These design requirements for Navy fuel include:
a.  Battle shock.  Navy fuel is designed to withstand the shock encountered in a wartime battle situation
without damage.  These shocks are well in excess of the seismic shocks for which other reactor fuels are
designed .  As an example, Navy fuel can withstand shocks much greater than 50g, or 50 times the
acceleration due to gravity.  Civilian reactors are designed only to withstand the shock of an earthquake
which is typically less than 1g.
b.  Long life.  Navy fuel is designed to operate in a high temperature and high pressure environment for
many years.  Current designs are capable of over 20 years of successful operation.  Typical civilian reactor
fuel is designed to operate for only a few years.
c.  Total containment of fission products.  Navy fuel is designed to operate throughout its lifetime without
any release of fission products.  This is essential to minimize radiation exposure to the crew who live inside
the confined space of a submarine for many months at a time.  Some civilian reactor fuels are designed to
operate with releases of fission products and Nuclear Regulatory Commission requirements for civilian fuel
allow for a primary coolant radioactivity level equivalent to about 0.1% fuel damage during normal
operations.  This results in detectable fission product activity in the reactor coolant produced from the fuel.
d.  Rapid power transients.  Navy fuel is designed to operate successfully during rapid power transients
(e.g. achieve full power in seconds) while typical civilian fuel takes many hours to achieve full power to
ensure it is not damaged.  The Navy requirement is based on the need to rapidly change speeds or direction
of a ship -- for example, to outrun a torpedo.
All of these very stringent operational requirements for Naval nuclear fuel enable it to maintain its integrity
indefinitely under the far less demanding conditions encountered during transportation and storage.

II COMMENT

Naval spent nuclear fuel may be unsuitable for a geologic repository and expensive processing facilities
may be needed to prepare it for ultimate disposal.
RESPONSE
Since Naval spent nuclear fuel is very stable and has high structural integrity, it well suited for disposal
into a geologic repository without processing or destructive disassembly.  Under the currently foreseeable
criteria for accepting spent nuclear fuel for disposal in a geologic repository, Naval spent nuclear fuel
modules could likely be placed intact into the containers to be used for disposal.  Once placed in a
geologic repository, the corrosion-resistant characteristics of the Naval spent nuclear fuel would keep it in
a stable form which would preclude achieving a critical configuration for a period well in excess of 10,000
years, the  period specified for analysis in the Nuclear Waste Policy Act, as amended.
A discussion of the integrity of Navy fuel is presented in Section 2.2 of Appendix D to Volume 1 of this
EIS.  Further details on the nature of Naval spent nuclear fuel which can be used to evaluate the
environmental impact associated with its management are provided in Attachment F to Appendix D.  The
very stringent requirements for Naval nuclear fuel to operate at high temperatures, high pressures, and resist
corrosion in very hot water cause it to be more than adequate to endure the conditions which might be
encountered after emplacement in a geologic repository.
Finally, it should be noted that this EIS evaluates safe management of spent nuclear fuel for 40 years,
including processing where required to stabilize the fuel for safe storage.  No processing of Naval spent
nuclear fuel is required for that purpose.  In the unlikely event that waste acceptance criteria to be
established in the future were to require processing of Naval spent nuclear fuel to enable it to be ultimately
disposed of, that would be evaluated in accordance with NEPA requirements at that time, but that matter is
beyond the scope of this EIS.

II COMMENT

The EIS should include information on the effective power-generating life of Naval nuclear reactor.
RESPONSE
As discussed in Section 3.7.4 of Appendix D to Volume 1 of this EIS, the life of the current reactor cores
used in Naval nuclear-powered vessels is greater than 20 years.  The lifetime of Naval nuclear reactor cores
has increased by a factor of more than ten from the 2 year lifetime of the first core installed in the first
nuclear-powered submarine in the 1950's.  This increase in lifetime is in large part the result of the
examinations of Naval spent nuclear fuel conducted at the Expended Core Facility over the past 37 years. 
This increase in core life has reduced the environmental impacts associated with operation of the nuclear
navy, as described in Section 3.7.4.
A discussion of the integrity of Navy fuel is presented in Section 2.2 of Appendix D to Volume 1 of this
EIS.  Further details on the nature of Naval spent nuclear fuel which can be used to evaluate the
environmental impact associated with its management are provided in Attachment F to Appendix D.

II COMMENT

The EIS should include the criteria for determining when defueling of a Naval reactor is needed.
RESPONSE
The most important factor determining the need for refueling or defueling of any nuclear- powered warship
is the mission of the Navy laid out by the Congress and President of the United States.  If the mission
requires a ship to continue operating beyond the end of the useful life of the core installed in the ship, the
core must be replaced when it no longer is capable of producing sufficient power for ship operation.  If a
ship is no longer needed, the nuclear reactor fuel will be removed from the ship, even if it has not reached
the end of its useful lifetime.
With the end of the Cold War and the recent changes in the mission of the armed forces, the Navy has been
reducing the number of warships it has in service, including the deactivation of some nuclear-powered
submarines and surface ships.  Information on the recent decreases in the number of nuclear-powered
Naval vessels and current plans for future reductions in the number of nuclear-powered vessels is reflected
in this EIS.  However, it should be emphasized that such numbers are subject to change at any time
pursuant to Congressional or Presidential direction.
A discussion of the integrity of Navy fuel is presented in Section 2.2 of Appendix D to Volume 1 of this
EIS.  Further details on the nature of Naval spent nuclear fuel which can be used to evaluate the
environmental impact associated with its management are provided in Attachment F to Appendix D. 
Information on the operating lifetime of current nuclear reactor cores is provided in Section 3.7.4.

II COMMENT

The EIS should include information on how long Naval spent nuclear fuel will remain radioactive and the
amount of radioactivity in each core or module.
RESPONSE
Section F.1.4 provides detailed information on the radionuclides present in Naval spent nuclear fuel, their
half-lives, and the amounts of each present.  This section provides all of the data needed for analysis of a
range of postulated accidents at facilities storing or examining Naval spent nuclear fuel.  Section A.7.1
provides similar information on the radionuclides and amounts of each for analyses of postulated
transportation accidents involving Naval spent nuclear fuel.  The half-lives of these radionuclides are
readily available from standard scientific publications, such as chemistry and physics textbooks.  Each
section includes data on the fractions of each type of radioactive material that might be released in an
accident.  These data provide a detailed characterization of the kinds and amounts of radioactivity
associated with Naval spent nuclear fuel which is adequate to understand the nature of Naval spent nuclear
fuel and to evaluate the potential environmental impacts associated with all of the alternatives considered
in this EIS.

II COMMENT

The life expectancy of shipping containers may not be long enough to store Naval spent nuclear fuel safely
for the period considered in this EIS or may be incompatible with the half-lives of the radionuclides
present.
RESPONSE
Naval spent nuclear fuel shipping containers are designed to withstand the rigors of shipment and
hypothetical accidents which might occur during shipping.  As a result, the certified shipping containers for
Naval spent nuclear fuel are rugged enough to endure the far less demanding conditions associated with
storage at Navy sites.  This fact is borne out by the analyses provided in Attachment F of Appendix D to
Volume 1 of this EIS.
As stated in Appendix D, the only change to shipping container design is that a long-term seal would be
used to replace the rubber seal in the shipping containers if an alternative utilizing the shipping containers
for storage for 40 years were selected as a result of this EIS.  However, the existing seal is designed to last
many years and is adequate for the period until that decision is made.  The current shipping container seals
are designed to contain radioactive material during frequent loading and unloading operations and during
shipment, requiring it to be flexible and reusable.  Design of a seal for long-term storage would be less
demanding because repeated opening and closing of the container lid would not occur during storage,
allowing use of such methods as welding the container shut, if necessary.
The level of detail desired by the commentor for the data analysis is not appropriate for the decision that
will be made out of this programmatic document, and would not provide any information that would assist
the decision-maker in making this decision.  This broad environmental review document has been prepared
in accordance with NEPA and implementing regulations, that allow for a broad focus on issues actually the
subject of the decision.  Additional, more specific data, such as the proposed by the commentor, would be
provided, if necessary, in further site-specific environmental documents.
Attachment F.1.4 provides detailed information on the radionuclides present in Naval spent nuclear fuel,
and the amounts of each present.  This section provides all of the data needed for analysis of a range of
postulated accidents at facilities storing or examining Naval spent nuclear fuel.  Information on the half
lines radionuclides can be obtained from standard publications such as physics or chemistry text books. 
Section A.7.1 provides similar information on the radionuclides and amounts of each for analyses of
postulated transportation accidents involving Naval spent nuclear fuel.  Each section includes data on the
fractions of each type of radioactive material that might be released in an accident.  These data provide a
detailed characterization of the kinds and amounts of radioactivity associated with Naval spent nuclear fuel
to allow understanding the nature of Naval spent nuclear fuel and to evaluate the potential environmental
impacts associated with all of the alternatives considered in this EIS.

II COMMENT

The use of beta-quenching in the production of Naval nuclear fuel may be a defective process which could
compromise the storage of Naval spent nuclear fuel.
RESPONSE
The comment is incorrect with respect to Naval nuclear fuel.  It apparently refers to an article in a
magazine (Mother Jones) which reported statements to the Nuclear Regulatory Commission concerning
possible causes of defects in commercial nuclear fuel elements and the claims in an unrelated lawsuit.  The
lawsuit involved a technician who was suing his former employer over the results of a developmental
process related to what metallurgists call "alpha treatment" of material containing zirconium.
The concern in the technician's lawsuit involved the results of a test related to one step of the process for
manufacturing the cladding of nuclear fuel used in electrical generating plants operated by some utilities. 
Navy nuclear fuel material is produced by an entirely different process from that used to produce the beta-
quenched zirconium fuel cladding used in commercial nuclear plants.  As a result, Naval fuel material has
different properties from commercial fuel.  The procedure at issue in the lawsuit and the subsequent
processing steps are not used in the fabrication of Naval nuclear fuel.
The Naval nuclear fuel manufacturing process is backed by extensive testing, years of operational
experience, and examinations after reactor shutdown.  Examinations of spent Naval nuclear fuel performed
at the Expended Core Facility at INEL on all Naval nuclear fuel after use, as well as monitoring of
operating Naval nuclear fuel, have shown that there is no reason to expect failures of Naval spent nuclear
fuel to occur during storage for more than 100,000 years.

II II COMMENT

The commentor states that Native Hawaiian fishing ponds within the boundaries of Pearl Harbor Naval
Shipyard might be contaminated in the event of an accident involving Naval spent nuclear fuel stored at the
shipyard. 
RESPONSE
Volume 1, Appendix D, section 5.1.4 of the EIS shows that there would be no impact on the Native
Hawaiian fishing ponds resulting from routine Naval spent nuclear fuel storage operations at Pearl Harbor
Naval Shipyard.  This conclusion is supported by the fact that the handling of Naval spent nuclear fuel
from Naval vessels, including refueling and defueling operations and operations very similar to those
considered in this EIS, have been conducted at Pearl Harbor Naval Shipyard for almost 30 years without
impact on the environment.  Report NT-94-1, Environmental Monitoring and Disposal of Radioactive
Wastes from U.S. Naval Nuclear Powered Ships and Their Support Facilities, Washington, DC, March
1994, provides additional information on the results of environmental monitoring for past operations.
With regard to hypothetical accidents, Volume 1, Appendix D, Chapter 5, section 5.1.4 and Volume 1,
Attachment F, section F.1.3.8 provide the results of calculations of radioactive material dispersion and
deposition calculations for a hypothetical airplane crash into Naval spent nuclear fuel storage containers at
Pearl Harbor Naval Shipyard, the worst-case potential accident for that site.  In even this most extreme
case, an area of only about 110 acres might be contaminated to the point where radiation doses exceeding
the Nuclear Regulatory Commission limit for exposure to the general public (100 millirem per year) might
result for a person living full time on that land.  This discussion does not mean that an area of such size
would be made permanently unusable or inaccessible because the calculation assumes that no action is
taken to clean up the radioactivity or to otherwise mitigate the effects of the accident.  Radioactive
contamination could and would be removed in order to minimize the affected area and impacts on access
or use.

II COMMENT

Historic sites could be damaged or made inaccessible by accidents associated with Naval spent nuclear
fuel.
RESPONSE
Appendix D of this EIS (See Chapter 5, Section 5.1.4.14.3, and Attachment F, Section F.1.3.8) discusses
in detail the potential environmental effects in the event of a number of extremely unlikely accidents
involving Naval spent nuclear fuel.  It should be noted that servicing of nuclear reactors aboard Naval
vessels, including refueling and defueling operations and operations very similar to those considered in this
EIS, have been conducted at Navy sites for almost 40 years without impact on the environment.  For
example, Report NT-94-1, Environmental Monitoring and Disposal of Radioactive Wastes from U.S. Naval
Nuclear Powered Ships and Their Support Facilities, Washington, D.C., March 1994, provides additional
information on the results of environmental monitoring of past operations.
For the most severe of the hypothetical accidents, Volume 1, Appendix D (Chapter 5, section 5.1.4, and
Attachment F, section F.1.3.8) shows that in even these extreme cases an area of only about 110 to 210
acres might be contaminated to the point where radiation doses exceeding the Nuclear Regulatory
Commission limit for exposure to the general public (100 millirem per year) might result for a person living
full time on that land.  Most of this area would be within the boundaries of the DOE or Navy site,
depending on the site being considered.
This discussion does not mean that an area of such size would be rendered permanently unavailable for
public use since the calculation described in the preceding paragraph assumes that no action is taken to
clean up the radioactivity.  In reality, radioactive contamination could and would be removed in order to
minimize the affected area and impacts on access.  Historic Structures would not be destroyed or physically
altered in the event of any of the hypothetical accidents.

II COMMENT

The commentor states that use of the land at Pearl Harbor Naval Shipyard is not compatible with the
culture of Native Hawaiians and their perception of the sacred nature of the land, or "aina."
RESPONSE
As described in Volume 1, Appendix D, section 5.1.4 of this EIS, any facilities required for management of
Naval spent nuclear fuel at Pearl Harbor Naval Shipyard would be constructed within the existing
industrial area, and no additional land outside the shipyard would be used.  Naval spent nuclear fuel
management activities would be consistent with the existing activities at the shipyard; and established
procedures to prevent interference with any cultural activities or artifacts of Native Hawaiians would be
followed.
With regard to hypothetical accidents, Volume 1,  Appendix D, Chapter 5, section 5.1.4, and Volume 1,
Attachment F, section F.1.3.8 provide the results of calculations of radioactive material dispersion and
deposition calculations for a hypothetical airplane crash into Naval spent nuclear fuel storage containers at
Pearl Harbor Naval Shipyard, the worst case potential accident for that site.  In even this most extreme
case, an area of only about 110 acres might be contaminated to the point where radiation doses exceeding
the Nuclear Regulatory Commission limit for exposure to the general public (100 millirem per year) might
result for a person living full time on that land.
This discussion does not mean that an area of such size would be made permanently unusable or
inaccessible since the calculation assumes that no action is taken to clean up the radioactivity or to
otherwise mitigate the effects of the accident.  Radioactive contamination could and would be removed in
order to minimize the affected area and impacts on access or use.

II COMMENT

Storage of Naval spent nuclear fuel at Pearl Harbor Naval Shipyard might conflict with the resolution of
land claims by Native Hawaiians.
RESPONSE
The actions considered in this EIS would not affect the land claims of Native Hawaiians.  Appendix D of
this EIS (See Chapter 5, Section 5.1.4, and Attachment F, Section F.1.3 and F.1.4) discusses in detail the
potential environmental effects associated with storage of Naval spent nuclear fuel at Pearl Harbor Naval
Shipyard.  It should be noted that servicing of nuclear reactors aboard Naval vessels, including refueling
and defueling operations and operations very similar to those considered in this EIS, have been conducted
at Navy sites for almost 30 years at Pearl Harbor and more than 30 years at other Navy shipyards without
impact on the environment.  For example, Report NT-94-1, Environmental Monitoring and Disposal of
Radioactive Wastes from U.S. Naval Nuclear Powered Ships and Their Support Facilities, Washington,
D.C., March 1994, provides additional information on the results of environmental monitoring covering
current and past operations.
For the most severe of the hypothetical accidents, Appendix D (See Chapter 5, Section 5.1.4.14.3, and
Attachment F, Section F.1.3.8) shows that, in even these extreme cases, at a Naval shipyard an area of only
about 110 acres might be contaminated to the point where radiation doses exceeding the Nuclear
Regulatory Commission limit for exposure to the general public (100 millirem per year) might result for a
person living full time on that land.
This discussion does not mean that an area of such size would be rendered inaccessible or unusable since
the calculation described in the preceding paragraph assumes that no action is taken to clean up the
radioactivity.  In reality, radioactive contamination could and would be removed in order to minimize the
affected area and impacts on access.  The net result of the analysis in this EIS is that the outcome of any
claims by Native Hawaiians would not be altered by the alternative selected for management of Naval spent
nuclear fuel.
Although the Navy's preferred alternative is not to store Naval spent nuclear fuel at Naval sites, under
NEPA, the Naval Nuclear Propulsion Program is required to consider the full range of reasonable
alternatives, including the alternative of taking no action.  Similarly, the regulations issued by the Council
on Environmental Quality (40 CFR 1502.14(c)) to implement NEPA require the consideration of
alternatives which may be beyond the jurisdiction of the agency.  The analyses in Appendix D the EIS (See
Chapter 5 and Attachment F, Section F.1) showed that the environmental impact of any of the alternatives
would be small.

II II COMMENT

The analyses in the Environmental Impact Statement should consider health effects other than cancer
fatalities.
RESPONSE
The analyses of the potential effects of radiation exposure in this EIS do consider health effects other than
cancer fatalities and are based on the standards of the International Commission on Radiological
Protection.  Section F.1.3.3 of Appendix D to Volume 1 discusses the terminology and risk factors used by
the International Commission on Radiological Protection and how these factors were applied in calculating
the effects on human health in this EIS. In order to describe the effects of radiation exposure, the
International Commission on Radio logical Protection defines the term "health detriments" to include the
total impact of all fatal cancers, non-fatal cancers, and genetic effects.  The health detriments caused by
any exposure to radiation are calculated by taking the sum of all of these effects after multiplying each
effect by a weighting factor intended to represent the severity the impact of each type of effect on human
health.
Cancer fatalities were used to summarize and compare the results in the EIS since this effect was viewed to
be of the greatest interest to most people.  The EIS states that the number of total health effects (deaths,
non-fatal cancers, genetic effects, and other impacts on human health) may be obtained by multiplying the
latent cancer fatalities by the factor of 1.46 developed by the International Commission on Radiological
Protection.
As a result of this comment, Chapters 3 and 5 of Appendix D to Volume 1 have been revised to more
clearly indicate how other health effects are to be calculated.

II COMMENT

The effects of radiation are not well understood.
RESPONSE
The effects of radiation have been studied extensively.  There are many publications on the subject and the
field of radiation health physics includes a great many professionals who have devoted their careers to this
topic.  As a result of the widespread efforts to understand the effects of radiation, many experts on public
health believe that the effects of radiation on human health and the mechanisms involved are better
understood than the effects of other chemicals present in modern daily life.
There are many variations in natural background radiation and modern lifestyles.  For this reason and
others, there are some differences of opinion concerning the effects of exposures to low levels of radiation
and the methods which should be used to extrapolate the results of measurements to the very low radiation
exposures which would be involved in the actions considered in this EIS.  However, the International
Commission on Radiological Protection, whose reports and methods were used to calculate the impacts
reported in this EIS, has adopted the "linear method" for producing such estimates since this is the most
conservative method accepted by the scientific community.  The standards used by the International
Commission on Radiological Protection are kept abreast of the most up-to-date research and are modified
as necessary to incorporate new results.  The methods and standards used in the EIS are also consistent
with the most recent studies and recommendations of the Committee on Biological Effects of Ionizing
Radiation (commonly called BEIR V) and the National Academy of Sciences.
The Occupational and Public Health and Safety sections for the Navy sites in Chapter 4 of Appendix D to
Volume 1 provide a description of a very comprehensive epidemiological study by researchers from Johns
Hopkins University of the health of workers at the six Naval ship yards and the two private shipyards which
serviced the Navy's nuclear-powered ships.  This independent study evaluated a population of more than
70,000 workers over a period of approximately 25 years to determine whether there was an excess of
leukemia or other cancers associated with exposure to low levels of gamma radiation.  This study found no
evidence to conclude that the health of the people involved in work on U. S. Naval nuclear-powered
vessels had been adversely affected by exposure to low levels of radiation incidental to this work.
Some persons have proposed performing epidemiological studies of the people living in communities in the
vicinity of installations performing work associated with atomic energy.  However, as demonstrated by the
studies which have been attempted, such as those in Great Britain, the level of radiation exposure in the
communities from man-made radionuclides is very low with respect to the variations in background
radiation and other factors introduced by individual lifestyles.  This fact, plus other variables introduced by
nature and other industries in the communities, has made it impossible to perform credible studies or
develop definitive conclusions.  Efforts in this area are expected to continue, but after 50 years of extensive
study, the standards of the International Commission on Radiological Protection represent the most reliable
data available.
Based on all of these considerations, the effects of radiation are understood well enough to provide a
reasonable evaluation of the alternatives in this EIS.  The standards of the International Commission on
Radiological Protection have been used with the exposures for all of the alternatives evaluated in order to
provide a consistent basis for comparison.  However, in order to allow independent evaluation of the
effects, Attachment F to Appendix D of Volume 1 provides the amounts of radioactive material which 
could be released and the radiation exposures calculated for routine operations and accident conditions for
each alternative.

II COMMENT

Human health effects should receive greater consideration than such matters as jobs or costs in reaching a
decision on the course of action for managing spent nuclear fuel.
RESPONSE
This EIS is devoted to analysis of all effects on human health and the environment which might result from
operations or reasonably foreseeable accidents associated with DOE and Navy management of spent
nuclear fuel.  The details of the analyses for Naval spent nuclear fuel management are described in
Attachments A and F of Appendix D to Volume 1.  Chapters 3 and 5 summarize the results of these
analyses and the detailed results are described in the Attachments to Appendix D.
Every effort has been made to include all possible affected areas, including any identified during the public
review of this EIS.  It is believed that no important area of potential human health effect or environmental
impact has been omitted from this EIS.
The health, safety, and welfare of citizens will be considered carefully in reaching any decision on the
course of action to be used for management of spent nuclear fuel.

II COMMENT

An independent study of the health effects on workers associated with reactor servicing at shipyards should
be performed.
RESPONSE
The Occupational and Public Health and Safety sections for the Navy sites in Chapter 4 of Appendix D to
Volume 1 provide a description of a very comprehensive epidemiological study by researchers from Johns
Hopkins University of the health of workers at the six Naval shipyards and the two private shipyards which
serviced the Navy's nuclear-powered ships.  This independent study, published in 1991, evaluated a
population of more than 70,000 workers over a period of approximately 25 years (1957 to 1981) to
determine whether there was an excess of leukemia or other cancers associated with exposure to low levels
of gamma radiation.  This study found no evidence to conclude that the health of the people 
involved in work on U. S. Naval nuclear-powered vessels had been adversely affected by exposure to low
levels of radiation incidental to this work.

II COMMENT

A comment identified that the EIS states that storage of spent nuclear fuel at Puget Sound Naval shipyard
would cause less than one cancer fatality in 100,000 years and questioned whether any other industry has
achieved such a safety record.
RESPONSE
The comment appears to refer to Section 5.1.1.12 of Appendix D to Volume 1 of the EIS.  The specific risk
values quoted in this EIS for normal operations and accidents conditions at Puget Sound Naval Shipyard
may be found in Section 3.7 of Appendix D.  Specifically, the EIS states that "it could be stated that one
member of the population might experience a fatal cancer due to incident-free storage of Naval spent
nuclear fuel at the Puget Sound Naval Shipyard if operations continued for 15,400 years."  More
specifically, Table 3-2 in Appendix D shows that the number of fatal cancers per year to the general
population that would result from water pool storage of spent fuel at Puget would be 6.5 x 10-5 (1 cancer 
divided by 6.5 x 10-5 fatal cancers per year = 15,400 years).
Regarding the assessment of risks, this EIS is not intended to serve as a comparison of risks between spent
nuclear fuel storage activities and other industrial activities.
The analyses presented in this EIS do show that the environmental impacts associated with any of the
alternatives would be very small for both normal operations and accident conditions.  All of the
alternatives considered would result in radiation exposures to the public which would be well below
Nuclear Regulatory Commission or Environmental Protection Agency standards and far below the normal
risks of daily life.

II COMMENT

Radiation can cause damage to materials such as concrete or metal and this should be analyzed in the EIS.
RESPONSE
The commentor is referring to the well-known phenomenon of radiation embrittlement.  Embrittlement is a
condition that can be caused only by intense radiation in an operating nuclear reactor.  Naval spent nuclear
fuel in examination or storage facilities is in a subcritical (shut down) condition.  Therefore, there is not
enough neutron radiation present in spent nuclear fuel examination or storage facilities to cause
embrittlement.  Since the water pool structures or storage containers would not be exposed to levels of
radiation comparable to operating reactors, material degradation due to radiation would not occur in the
examination or storage facilities.  This conclusion is borne out by almost 40 years of experience in shipping
and storing Naval spent nuclear fuel.
The shipping containers used for Naval spent nuclear fuel are inspected after every shipment to assure that
they are acceptable for continued use.  They also receive maintenance and more detailed inspections at
specified periods.

II II COMMENT

Some persons questioned the impact on Pearl Harbor Naval Shipyard if the ability to perform nuclear
reactor servicing work for warships were lost as a result of the alternatives considered in this EIS.
RESPONSE
None of the alternatives evaluated in detail in this EIS would result in Pearl Harbor Naval Shipyard losing
the ability to service the nuclear reactors aboard Navy vessels.  Information on the socioeconomic impacts
associated with the loss of reactor servicing work was not included in this EIS for this reason.

II COMMENT

The potential impact on tourism in the vicinity of a Naval spent nuclear fuel management facility should be
discussed in the EIS.
RESPONSE
Since the actual environmental impacts associated with management of Naval spent nuclear under all
alternatives considered in the Environmental Impact Statement would be small, there is no reason to
believe that storage or examination of Naval spent nuclear fuel at any of the locations evaluated would
have any significant effect on tourism.  Even the impacts of hypothetical accidents are limited in extent and
small enough that there should be no impact on tourism.
Naval spent nuclear fuel has been managed at Naval shipyards, Navy prototype reactor sites, and INEL for
almost 40 years, incidental to the refueling and defueling of nuclear-powered warships.  This has been
done with no discernible adverse effect on tourism in the vicinity of these facilities.

II COMMENT

The effects on the marketability of products produced in the vicinity of a Naval spent nuclear fuel
management facility should be evaluated.
RESPONSE
Since the environmental impacts associated with management of Naval spent nuclear fuel under all
alternatives considered in the EIS would be small, there is no reason to believe that the marketability of
products produced in the vicinity of a Naval spent nuclear fuel management site would be affected.  Even
the impacts of hypothetical accidents would be small enough that there would not be any effect on the
marketability of products other than temporarily.
Naval spent nuclear fuel has been managed at Naval shipyards, Navy prototype reactor sites, and INEL for
almost 40 years, incidental to the refueling and defueling of nuclear-powered warships.  This has been
done with no discernible adverse effect on the marketability of products from the vicinity of these facilities.

II COMMENT

The effects on property values in the vicinity of a Naval spent nuclear fuel management facility should be
evaluated.
RESPONSE
Since the actual environmental impacts associated with management of Naval spent nuclear under all
alternatives considered in the Environmental Impact Statement would be small, there is no reason to
believe that storage or examination of Naval spent nuclear fuel at any of the locations evaluated would
have any effect on property values in the locality.
Changes in employment under any of the alternatives considered would be very small and would not create
demand that would affect housing and property values.  The largest impact on property values associated
with the alternatives considered would result from the shutdown of the Expended Core Facility at INEL.
Naval spent nuclear fuel has been managed at Naval shipyards, Navy prototype reactor sites, and INEL for
almost 40 years, incidental to the refueling and defueling of nuclear-powered warships.  This has been
done with no discernible adverse effect on property values in the vicinity of these facilities.

II COMMENT

The effects on jobs and economic development in the vicinity of a Naval spent nuclear fuel management
facility should be evaluated.
RESPONSE
The EIS does evaluate in detail the socioeconomic effects of each alternative.  The results of the evaluation
for management of Naval spent nuclear fuel are provided in Chapters 3 and 5 of Appendix D to Volume 1. 
As summarized in Chapter 3 of Appendix D, changes in permanent employment range from an increase of
about 10 jobs at each Navy site under the No Action alternative to a loss of 500 jobs at INEL for the
alternatives which would terminate the use of the Expended Core Facility.
As shown in the Socioeconomics sections for each site in Chapter 5 of Appendix D, the magnitude of these
changes with respect to the populations, regional economies, and local job markets in the vicinity of the
Navy sites would be too small to impact local economic development.  The largest impact on employment
or the local economy associated with the alternatives considered would result from the shutdown of the
Expended Core Facility at INEL.

II COMMENT

The effects of shipments of Naval spent nuclear fuel on the local infrastructure (such as streets or sewers)
should be evaluated.
RESPONSE
Shipments of Naval spent nuclear fuel from the Kesselring Site use multi-wheel transporters to move the
shipping containers to the nearest railroad siding, where the containers are placed on railroad cars for the
rest of the trip.  The many wheels on this vehicle ensure the load on each wheel of the transporter is
maintained below the highway weight limits for the roads used in the movement.  As a result, the loading
of each wheel of the transporter is less than the wheel loading of a regular commercial truck.  This is done
to prevent damage to the roads or any structures beneath them.  Permits which require the shipment not to
exceed posted load limits are obtained from New York State, Saratoga County, and the Village of Ballston
Spa.
The company which moves the Naval spent nuclear fuel shipping containers must post a bond to repair any
damage created during the movement.  Repairs to the  infrastructure in the municipalities along the transfer
route have never been required as a result of Naval spent nuclear fuel shipments over the last 37 years.  If
any damage to the infrastructure in Ballston Spa (such as the sewers system) should be shown to be caused
by the transport of Naval spent nuclear fuel from the Kesselring Site in the future, appropriate means are
available to compensate the town for repairs.
An evaluation of alternate routes was completed by the Naval Nuclear Propulsion Program in 1992.  It
showed that the route currently used is safe and is the best alternative available.  Copies of this report were
provided to local officials and placed in the Schenectady County Library.

II COMMENT

The impacts and possible mitigative measures associated with Naval spent nuclear fuel resulting from
possible base closures should be evaluated in the Environmental Impact Statement.
RESPONSE
The EIS takes into account the impacts arising from base closures at Charleston Naval Shipyard and Mare
Island Naval Shipyard.  As of January 1995, Naval spent nuclear fuel has been removed from these
shipyards under an agreement between the Secretaries of Energy and Navy and the Governor of Idaho.  In
addition, the EIS takes into account the most recent plans for fleet size and the increased number of
defuelings and inactivations scheduled over the next decade as a result of those plans.
Since speculation on the Navy sites that might be closed would not be appropriate, a detailed discussion of
how Naval spent nuclear fuel might be handled in the event of closures of bases not currently slated for
closure is not included.  In any event, Naval spent nuclear fuel would continue to be managed by the
Federal government and all efforts would be taken to move this material to an operational site if a location
storing Naval spent nuclear fuel were to be closed.  Further NEPA documentation might be needed to
address the effects of such an event.

II II COMMENT

The effects of earthquakes or other seismic events on Naval spent nuclear fuel management facilities should
be evaluated.
RESPONSE
The effects of a severe seismic event on Naval spent nuclear fuel management facilities are evaluated in the
EIS.  Attachment F to Appendix D of Volume 1 provides a discussion of the analyses performed and the
public health risks which might result from a seismic event at each site where Naval spent nuclear fuel
could be stored. The seismic events considered in the analyses included both an earthquake of the
magnitude used as the basis for the design of the facility (design basis earthquake) and an earthquake of a
magnitude which is more severe than that for which the facility must be designed (beyond design basis
earthquake.) 
Appendix D identifies that Naval spent nuclear fuel will retain its integrity even if an earthquake causes
complete draining of a water pool that is being used for storage of Naval spent nuclear fuel.  Air circulation
through the fuel racks and fuel units was shown to be sufficient to prevent cladding failure and release of
any fission products from the fuel in the unlikely event of complete loss of pool water.  The primary
consequences of the loss of pool water would be the potential for increased direct radiation and some
release of corrosion products.  The risks and effects of this and seismic events involving other types of
Naval spent nuclear fuel storage are very small and are included in Appendix D to Volume 1.
With regard to new facilities, Volume 1, Appendix D, identifies that if the Record of Decision involves the
need for new facilities for the interim storage of Naval spent nuclear fuel, detailed site-specific seismic
evaluations would be conducted for those sites and the results would be incorporated into the design of
new facilities.  The construction of any new facilities for Naval spent nuclear fuel management would meet
strict seismic standards for the interim storage of Naval spent nuclear fuel.  The design and construction of
these facilities to seismic standards which take into consideration the seismic character of the area would
ensure that structures could withstand a major seismic event.  Additional information regarding the facility
design considerations for Naval spent nuclear fuel management activities is provided in Attachment D to
Appendix D of Volume 1.

II COMMENT

Discussion of a fault in the vicinity of Puget Sound Naval Shipyard (or some other site) should be added to
the Environmental Impact Statement.
RESPONSE
Section 4.1.1.6.3 of Appendix D to Volume 1 provides a summary of the seismic hazards in the Puget
Sound area and identifies that the Puget Sound area is prone to seismic activity. This section also identifies
that a detailed seismic evaluation would be conducted and that any facilities constructed to store Naval
spent nuclear fuel would be designed to seismic criteria for that area. Since the seismicity of the area is
factored into the seismic design criteria, any facility constructed to that criteria would be expected to
withstand a major seismic event in that area.
The existing Puget Sound Water Pit facility was designed to the seismic design criteria for the Puget Sound
area and is expected to withstand a major earthquake in this area.  More specific information describing the
construction of the Puget Sound Water Pit Facility is provided in Volume 1, Appendix D, Attachment D,
section D.2. 
Although failure of spent nuclear fuel management facilities is not anticipated, the effects of seismic failure
of Naval spent nuclear fuel management facilities has been evaluated in the EIS.  Volume 1, Appendix D,
Attachment F provides a discussion of the analyses that were performed and the public health risks that
might result from a seismic event at each site where Naval spent nuclear fuel would be stored. The seismic
events considered in the analyses included both an earthquake of the magnitude used as the basis for the
design of the facility (design basis earthquake) and an earthquake of a magnitude which is more severe than
that for which the facility must be designed (beyond design basis earthquake.)  
Appendix D identifies that Naval spent nuclear fuel will retain its integrity even if an earthquake causes
complete draining of a water pool that is being used for storage of Naval spent nuclear fuel.  Air circulation
through the fuel racks and fuel units was shown to be sufficient to prevent cladding failure and the release
of any fission products from the fuel in the unlikely event of complete loss of pool water.  The primary
consequences of the loss of pool water would be the potential for increased direct radiation and some
release of corrosion products.  The risks and effects of this and seismic events involving other types of
Naval spent nuclear fuel storage are very small and are included in Volume 1, Appendix D.

II COMMENT

An up-to-date seismic analysis should be performed for any site considered for Naval spent nuclear fuel
management.
RESPONSE
An up-to-date seismic evaluation was completed for the Expended Core Facility at INEL since it is an
existing facility.  The seismic events considered included both an earthquake magnitude which is required
as the basis for the design of the facility (design basis earthquake), and an earthquake magnitude which is
more severe than that for which the facility must be designed (beyond design basis earthquake.)
Any new facilities needed for management of Naval spent nuclear fuel would be evaluated for seismic
hazards.  Even though design of the facilities incorporating seismic evaluation would make it unlikely that
any catastrophic damage would occur as a result of the most severe earthquakes postulated, the EIS
includes analyses of the effects of loss of water from the pools at the sites considered.  The effects of a
complete loss of pool water are reported in Attachment F to Appendix D and identify that Naval spent
nuclear fuel will retain its integrity even if an earthquake causes complete draining of a water pool.  Air
circulation through the fuel racks and fuel units was shown to be sufficient to prevent cladding failure and
the release of any fission products from the fuel in the unlikely event of complete loss of pool water.  The
primary consequences of the loss of pool water would be the potential for increased direct radiation and
some release of corrosion products.
The risks and effects of this, and seismic events involving other types of Naval spent nuclear fuel storage at
the Expended Core Facility and at other sites, are very small and are included in Volume 1, Appendix D. 
The construction of any new facilities for Naval spent nuclear fuel management would meet seismic
standards at least as good as the current Expended Core Facility.
Volume 1, Appendix D identifies that if the Record of Decision involves the need for new facilities for the
interim storage of Naval spent nuclear fuel, detailed seismic evaluations would be conducted for those
sites.  The construction of any new facilities for Naval spent nuclear fuel management would meet strict
seismic standards for the interim storage of Naval spent nuclear fuel.  The design and construction of these
facilities to strict seismic standards (which take into consideration the seismic character of the area) will
ensure that structures will withstand a major seismic event.  Additional information regarding the facility
design considerations for Naval spent nuclear fuel management activities is provided in Volume 1,
Appendix D, Attachment D. 

II COMMENT

A commentor felt that the discussion of hazards associated with volcanoes at the Expended Core Facility
was misleading because volcanic flows have occurred in the INEL region within the past several thousand
years.
RESPONSE
Section 4.2.6 of Appendix D to Volume 1 states that there are no active volcanoes known to exist near the
Expended Core Facility at INEL.  The probability that a volcano might cause a hazard at the Expended
Core Facility site is very low, estimated to be less than one chance in 100,000 per year.
The discussion in Section 4.2.6 of Appendix D to Volume 1 to this EIS has been revised to clarify the low
probability of volcanic hazards affecting the Expended Core Facility at INEL.

II COMMENT

Some areas in the vicinity of Puget Sound may be susceptible to liquefaction in the event of an earthquake. 
If the location at Puget Sound Naval Shipyard where railcars containing spent nuclear fuel were located
should liquify, the railcars could sink.
RESPONSE
The Puget Sound area is prone to seismic activity and liquefaction is a possible result of earthquakes in this
area.  The Puget Sound Naval Shipyard performs geotechnical evaluations whenever new facilities are
constructed or as necessary to update information about the site.  These studies are used as a basis for the
design of facilities on the shipyard and the shipyard has taken steps in the design and operation of its
facilities that would prevent or minimize any impacts should an earthquake occur.
Even if such an event were to occur, the analyses in this EIS demonstrate that the effects would be
minimal.  The shipping containers are watertight and would maintain their integrity even after a severe
earthquake because they are designed to withstand transportation accidents which could be more severe
than a seismic event.  Attachments A and F of Appendix D to Volume 1 provide a discussion of the design
of the spent fuel shipping containers and the results of analyses of severe accidents which might occur
during the various modes of shipping container transportation and storage.
If a railcar containing a shipping container loaded with spent fuel were to tip over or settle in the ground
due to liquefaction, no release of radioactive material to the environment or increase in radiation exposure
to any worker or member of the public would occur since the containers are designed to withstand
transportation accidents far more severe without breaching.  The shipyard would initiate emergency
recovery actions using the equipment available within the shipyard or from sources outside the shipyard to
upright or stabilize the railcar and container as soon as practicable as part of the recovery from the event.

II COMMENT

According to a commentor, Appendix D to Volume 1 inaccurately describes the magnitude of the Borah
Peak earthquake as " 6.9 when it was actually 7.3 on the Richter Scale", and that this results in an
incorrect derivation of the design basis peak ground acceleration value for the Expended Core Facility.
RESPONSE
The comment is inaccurate.  Seismologists commonly use one of three scales to describe the magnitude of
an earthquake.  These scales are the Richter scale, the Moment Magnitude scale, and the Surface Wave
Magnitude scale.  Unfortunately, seismologists have not prescribed a universal scale for describing all
earthquakes and it is sometimes difficult to convert the units from one scale to another as one would
convert temperature units from Fahrenheit to Celsius.
It should be noted that the Moment Magnitude scale is more widely used by seismologists as compared to
the Richter scale when discussing earthquakes. The Moment Magnitude scale reflects the energy released
at the source.  The Richter scale is the measure of the local ground motion in the 1 to 5 Hz range and is
satisfactory up to a magnitude of 6.5.  Seismographs saturate at magnitudes exceeding 6.5 so the news
media typically quote the Surface Wave magnitude of the event and call it the Richter Scale.  The Surface
Wave magnitude is a measure of the ground motion in the 0.05 Hz range and is measured at large distances
from the epicenter.  The Surface Wave Magnitude scale is also commonly used by some seismologists to
describe earthquakes at INEL. 
Section B.5.2 of Appendix D to Volume 1 states that the 0.24g peak ground acceleration is "derived on the
basis that a moment magnitude 6.9 seismic event centered near Howe on the Lemhi Fault would cause a
rupture of approximately 34 kilometers along the Lemhi Fault.  The Howe epicenter is the epicenter
located closest to the Expended Core Facility, and 6.9 was the moment magnitude of the Borah Peak
earthquake in 1983".  The seismologist who evaluated the seismic hazard for the Expended Core Facility at
INEL used the Moment Magnitude scale, and not the Richter scale, to describe the magnitude of the Borah
Peak earthquake and to derive the peak ground acceleration for the Expended Core Facility.  The Borah
Peak earthquake was also measured at 7.3 on the Surface Wave Magnitude scale, as identified by the
seismologist who evaluated the Expended Core Facility.  Some other studies of the Borah Peak earthquake,
such as that described in the Special Isotope Separator EIS, have cited the magnitude of the Borah Peak
earthquake as 7.3 on the Richter scale (on page 3-15 and in Table 3-2 on page 3-17 of that EIS).   These
are all references to the same magnitude earthquake; they are merely reported on different scales.

II COMMENT

There may be greater than minimal likelihood of a tsunami in the vicinity of Puget Sound Naval Shipyard
due to the possibility of large earthquakes beneath Puget Sound.
RESPONSE
The containers which would be used for dry storage are designed to withstand water immersion under
severe accident conditions and no deleterious effects would be expected from submersion of a container by
a tsunami.
Storage of Naval spent nuclear fuel in water pools at Navy sites is also considered in this EIS.  The Naval
spent nuclear fuel in water pools would normally be under water and the effects on the environment due to
flooding by a tsunami would be primarily limited to exchanging some pool water bearing radioactive
corrosion products with the flood waters.  Such a release would not be expected to occur except for the
most severe tsunamis which raised the level of the waters of Puget Sound many feet.  If that did occur,
Attachment F to Appendix D of Volume 1 provides analyses of the effects of water pool water being
released under accident conditions.  The results of these analyses represent an upper limit on the effects of
releases possible during a tsunami sufficiently severe to flood a water pool containing Naval spent nuclear
fuel.
Chapter 4 of Appendix D to Volume 1 has been changed to clarify that a tsunami could be caused in the
manner described.

II COMMENT

Additional information pertaining to seismicity near some Navy sites should be added to the EIS or the
information in the EIS does not reflect the latest geotechnical studies.
RESPONSE
Chapter 4 of Appendix D to Volume 1 contains sections which describe possible seismic hazards at each
Navy site, provide general background information regarding the seismicity at these sites, and provide
references where more detailed information can be obtained. In addition, the current Uniform Building
Code (UBC) seismic classification for each site is provided as a means for comparing the potential for
seismic hazards among sites.
The effects of seismic failure of Naval spent nuclear fuel management facilities have been evaluated in this
EIS.  Chapter  5 and Attachment F of Appendix D to Volume 1 provide summary and detailed discussions
of the analyses that were performed and the public health risks that might result from a seismic event at
each site where Naval spent nuclear fuel would be stored. The seismic events considered in the analyses
included both an earthquake of the magnitude used as the basis for the design of the facility (design basis
earthquake) and an earthquake of a magnitude which is more severe than that for which the facility must be
designed (beyond design basis earthquake.)  These analyses show that the risks associated with seismic
events involving Naval spent nuclear fuel are very small for all of the alternatives and sites considered.
The EIS states that if the Record of Decision identifies a particular site for interim storage of Naval spent
nuclear fuel, a detailed seismic evaluation would be conducted.  This evaluation would consider the latest
geotechnical information available at the time.  The EIS has been revised to eliminate the reference to
seismic risk zoning promulgated by the U.S. Coast and Geodetic Survey at the Kesselring Site.

II COMMENT

According to a commentor, seismic events up to magnitude 9 might occur in the vicinity of Puget Sound
Naval Shipyard.
RESPONSE
There has recently been speculation by some that earthquakes in the Puget Sound area might produces
magnitudes as high as 8.2 to 8.8.  On the other hand, some seismologists believe that earthquakes with
magnitudes exceeding 7 are unlikely in this region.  There is also some disagreement on the nature of the
fault movements that might occur in this area.
Although failure of spent nuclear fuel management facilities during seismic events within the design criteria
is not anticipated, the effects of seismic failure of Naval spent nuclear fuel management facilities have been
evaluated in this EIS.  Chapter  5 and Attachment F of Appendix D to Volume 1 provide summary and
detailed discussions of the analyses that were performed and the public health risks that might result from a
seismic event at each site where Naval spent nuclear fuel would be stored. The seismic events considered in
the analyses included both an earthquake of the magnitude used as the basis for the design of the facility
(design basis earthquake) and an earthquake of a magnitude which is more severe than that for which the
facility must be designed (beyond design basis earthquake.)  These analyses show that the risks associated
with seismic events involving Naval spent nuclear fuel are very small for all of the alternatives and sites
considered.
This EIS states that if an alternative making use of Navy sites for storage of Naval spent nuclear fuel were
to be selected a detailed seismic evaluation would be conducted.  This evaluation would consider the latest
geotechnical information available at the time.  The EIS has been revised to clarify the range of earthquake
magnitudes identified for the Puget Sound area.

II COMMENT

There are significant differences in interpretations of ground motions at INEL and the design acceleration
level of the fuel racks is not identified.
RESPONSE
Section F.1.4.2.1.1.3 of Appendix D to Volume 1 of this EIS states that the ground acceleration used to
evaluate the stability of the Expended Core Facility water pool and fuel racks in a design basis seismic
event is 0.24g.
Section F.1.4.2.1.1.3 of Appendix D to Volume 1 summarizes the bases used by expert seismologists to
determine the 0.24g peak ground acceleration for the Expended Core Facility.  The considerations and
techniques involved are described in more detail in the reference provided in Section  F.1.4.2.1.1.3.  The
facilities on INEL are many miles apart.  As a result, the distance between a fault epicenter, such as the
Lemhi fault epicenter at Howe, and each facility at INEL differs by a number of miles.  Since the ground
motion produced by an earthquake decreases as the distance from the epicenter increases, the same
magnitude earthquake at the epicenter (for example,  a moment magnitude 6.9 quake) will produce
different peak ground accelerations at the different facilities.
The references to Appendices B and D to Volume 1 provide more detailed discussions of the geotechnical
conditions in the vicinity of INEL and the various facilities at this large site.

II COMMENT

The EIS should provide seismic analyses documenting that the superstructure of the Expended Core
Facility has the ability to sustain design basis earthquake and accident scenarios.
RESPONSE
An up-to-date seismic evaluation was completed for the Expended Core Facility at INEL based on the
1994 Natural Phenomena Hazard Report referenced in Section F.1.4.2.1.3 of Appendix D to Volume 1. 
The analysis concluded that neither the superstructure nor the cranes would collapse, even though some
members of the superstructure would experience some localized damage.
The seismic analyses included both an 0.24g magnitude earthquake and an 0.40g magnitude earthquake
which is more severe than that for which the facility has been designed (beyond design basis earthquake). 
The seismic evaluation is discussed in Section F.1.4.2.1.1 of Appendix D to Volume 1.
The seismic analysis also evaluated the water pools. Based on the evaluation of the Expended Core
Facility, damage to Naval spent nuclear fuel is not expected.  Section F.1.4.2.1.1 of Appendix D to
Volume 1 provides the results of analyses for loss of water from the water pools at the Expended Core
Facility, even though an earthquake is not expected to produce such an accident.  In addition, Section
F.1.4.2.1.3 of Appendix D to Volume 1 provides the results of analyses for a crane load failure.  These
analyses show that the risks associated with such postulated accidents would be small.

II II COMMENT

The number of fatal cancers to the general population per year shown in Table 3-2 of Appendix D to
Volume 1 should be multiplied by the number of people in the population to obtain the risks associated
with Naval spent nuclear fuel management.
RESPONSE
The comment is incorrect, apparently resulting from a misreading of the information provided in the EIS. 
Table 3-2 of Appendix D to Volume 1 provides the total risk to the entire population for each alternative
considered.  The values in Table 3-2 should not be multiplied by the number of people in the population
since the number of people affected has already been included in the calculation of the numbers shown in
the table.  An explanation of how risk is calculated is provided in Section F.1.3.10 of Appendix D to
Volume 1.
The estimates of risk to the entire population from normal operations in Table 3-2 were obtained from the
results of detailed analyses provided in Attachment F to Appendix D.  The analysis in Attachment F was
performed by calculating the total number of fatal cancers that might occur in the total population within a
50 mile radius of each site evaluated for management of Naval spent nuclear fuel.  The details of the
analyses for the Navy sites and for the Oak Ridge Reservation and the Nevada Test Site are provided in
Section F.1.4.1, including the amounts of radioactivity which might be released to the environment for
each alternative considered and the number of people within 50 miles of each site.

II COMMENT

Population data for a large area surrounding sites considered should be used in the analyses.
RESPONSE
The EIS used population data from the 1990 Census for an area within 50 miles of each site for evaluation
of the potential environmental impact to the general population.  (Distributions for Navy sites are shown in
Appendix D, Chapter 4, and those for DOE sites considered are in the Volume 1 Appendices for each site.) 
Combining this population data with radiological exposures in the 50 mile radius region yielded the
collective person-rem for all of the people in the region.  These results were then converted to latent cancer
fatalities using correlations developed by the International Commission on Radiological Protection These
correlations are consistent with the most recent studies and recommendations of the Committee on
Biological Effects of Ionizing Radiation (commonly called 
BEIR V).
The area within 50 miles of each site encompasses all of the people who might be affected by radiological
exposure associated with the alternatives for spent nuclear fuel management.  As an illustration of this, the
analytical results for the most severe hypothetical Naval spent nuclear fuel accidents under all alternatives,
provided in the Facility and Transportation Accidents sections of Chapter 5, show that the maximum area
which might be contaminated with radioactivity to a level which would cause a person living there for 24
hours a day to exceed the Nuclear Regulatory Commission's limit to the general public of 100 millirem per
year would be less than about 210 acres for all cases.

II COMMENT

Information on the radionuclides present in Naval spent nuclear fuel and the amounts of each should be
provided in the Environmental Impact Statement.
RESPONSE
Appendix D to Volume 1 provides, in Attachments A and F, a list of radionuclides in Naval spent nuclear
fuel and the exposure to human beings and lists the quantity of each nuclide involved.  This information is
provided for both normal operations and accidents.

II COMMENT

All pathways for exposure to human beings to radiation or radioactive material and all effects of such
exposure should be included in the analyses of the impacts of normal operations and postulated accidents.
RESPONSE
The EIS includes an evaluation of all significant pathways by which radiation or radioactive materials can
impact human health.  These pathways include direct radiation from the spent nuclear fuel facility, direct
exposure from immersion in airborne radioactive material, direct exposure from radioactive material
deposited on the ground, internal exposure from inhalation of radioactive materials, internal exposure from
ingestion of radioactive materials (both from food and drinking water), and direct exposure from the surface
of or immersion in contaminated water.  The pathways used in the analyses for 
Naval spent nuclear fuel are described in Attachments A and F of Appendix D to Volume 1 of the EIS. 
Both latent fatal cancers and other health effects are discussed.

II COMMENT

Some commentors were concerned that an accident involving Naval spent nuclear fuel at a Navy site would
have disastrous consequences for a region.
RESPONSE
Appendix D to Volume 1 of the EIS includes an evaluation of a broad range of hypothetical accidents
which might occur as a result of human error, equipment failure, or natural phenomena, such as
earthquakes or tornadoes.  The results of these analyses, which are summarized in Chapter 3, provided for
each site in Chapter 5, and described in detail in Attachments A and F, show that the risks associated with
all of the accidents are very low.
The risks are very low even though the analyses included many conservatisms.  For example, the analysis
of an airplane crash into a container used to store Naval spent nuclear fuel assumed that the crash would
cause the container to be breached even though evaluation had shown that no part of an airplane could
penetrate the container.  The analyses used meteorological conditions (such as wind dispersion and speed)
which have only one chance in twenty of actually occurring, but no credit was taken for the fact that they
are worse than the actual conditions 95 percent of the time.  Further, the analysis of the consequences also
assumed that no evacuation of people in nearby residential areas or other mitigative measures were used to
reduce the effects.  As a result of these conservatisms, it is expected that the actual impacts of these
accidents would be 10 to 100 times less than calculated.
Even when the low probability of these accidents is not considered, the consequences without mitigative
measures or planned emergency response would not be so extreme as feared by the commentors.  The
principal reason for this is that Naval nuclear fuel is designed to withstand the conditions encountered in
combat and therefore is rugged enough to resist or minimize damage in even the most severe accidents.  In
addition to the rugged nature of Naval spent nuclear fuel by itself, the containment provided by the
facilities and transport containers, the precautions and procedures applied to this work, and the existing
emergency response capabilities of the Navy sites and the surrounding regions make it highly likely that the
actual consequences would be much less than calculated.
As described in Attachments A and F of Appendix D to Volume 1 of the EIS, all significant pathways by
which radiation or radioactive materials released by these accidents could impact human health have been
included.  Attachments A and F of Appendix D to Volume 1 of the EIS provide all of the information used
to calculate the effects of accidents involving Naval spent nuclear fuel so that an independent analyst could
use these data to perform calculations to confirm the accuracy of the conclusion that such accidents would
not be as disastrous as some persons feared.

II COMMENT

The potential health effects of exposure to radiation or radioactive material as a result of normal operations
or postulated accidents involving Naval spent nuclear fuel and all effects of such exposure should be
included in the EIS.
RESPONSE
The EIS includes an evaluation of the exposure and potential health effects associated with Naval spent
nuclear fuel management at all of the sites considered.  These analyses include all possible pathways, such
as direct radiation from the spent nuclear fuel facility, direct exposure from immersion in airborne
radioactive material, direct exposure from radioactive material deposited on the ground, internal exposure
from inhalation of radioactive materials, internal exposure from ingestion of radioactive materials (both
from food and drinking water), and direct exposure from the surface of or immersion in contaminated
water.  The analyses performed for Naval spent nuclear fuel management alternatives and their results are
described in Attachments A and F of Appendix D to Volume 1 of the EIS.  Both latent fatal cancers and
other health effects are discussed.

II COMMENT

The accident analyses in the EIS for Naval spent nuclear fuel storage facilities should include fires or
explosions on Naval vessels at shipyards as initiating events.
RESPONSE
Appendix D to Volume 1 of the EIS includes an evaluation of a broad range of hypothetical accidents
which might occur as a result of human error, equipment failure, or natural phenomena, such as
earthquakes or tornadoes.  These analyses included fires involving the storage facilities and projectiles
striking the storage facilities.  The results of these analyses are summarized in Chapter 3, tabulated for each
individual site in Chapter 5, and described in detail in Attachment F.  The analyses show that the risks
associated with all of the accidents are very low.
Section F.1.2 describes the procedure used to select accidents for detailed analysis.  The evaluation of
possible accidents concluded that accidents initiated at nearby locations, such as those on Naval vessels at
shipyards, would not produce more severe effects than the accidents chosen for detailed analysis and are
therefore not specifically evaluated.  The accidents selected included a hypothetical crash of a large
passenger or cargo aircraft directly on to the fuel storage areas, crashes which would involve both fire and
high energy projectiles, so the effects of such an event would likely far outweigh the effects of an explosion
on a vessel.
The consequences of Naval spent nuclear fuel storage facilities being struck by projectiles from weapons
have been specifically considered.  This evaluation was performed as part of the analysis of possible
terrorist or military attack.  The effects of such an attack have been deter mined to be less than the limiting
accidents analyzed in the EIS, specifically the crash of a large jet or an earthquake (See Appendix D,
Attachment F, Section F.1.2).  Attacks using anti-tank weapons or other specialized weapons, as well as
conventional explosives, were evaluated.
The reasons that the effects of a projectile from an anti-tank weapon striking one of the storage containers
would be less severe than the accidents analyzed are: (a) anti-tank weapons would be likely to cause a self-
sealing penetration in the metal of a container, unlike that which is assumed from the airplane crash
(impact from a 50 inch diameter engine rotor); (b) there is no explosive material inside the container, so it
will not "blow up" as a tank would if hit by such a weapon (in an attack on a tank, the artillery shells
inside the turret detonate from the energy injected into the turret by the anti-tank shell); (c) there would be
no fire to disperse the radioactivity that is released when the container is breached, unlike an aircraft crash
where the jet fuel might pool, ignite, and create such a fire.  The rugged design of 
containers and the thick walls of water pools, combined with the shock-absorbing nature of water with a
free surface, reduce the effects of other types of explosive charges.
Attachment F of Appendix D of the EIS has been modified to better describe this analysis.

II COMMENT

The analyses of normal operations and hypothetical accidents should include calculation of the exposure
to the maximum exposed individual for transportation and for each site for each alternative.
RESPONSE
The EIS does provide an estimate of the exposure for a maximum exposed individual for normal operations
and postulated accidents for fixed sites and transportation under all alternatives.  Attachments A and F of
Appendix D to Volume 1 provide the results of calculations of the potential exposure to the maximum
exposed individual for shipments and facilities for all alternatives, as well as the potential exposure to
workers, to a person at the point of nearest public access, and to the population in the vicinity.  Sections
A.8.2, A.8.3, and A.8.4 in Attachment A provide the detailed results for routine operations and accidents
during transportation and Sections F.1.4.1 and F.1.4.2 in Attachment F provide detailed results for normal
operations and accidents for each site considered.  The results tabulated in these sections show that the
risks to the maximum exposed individuals would be very small under all of the alternatives considered.

II COMMENT

The risks and costs associated with the period of transition to a new alternative for the management of
Naval spent nuclear fuel should be analyzed.
RESPONSE
Section 3.8 of Appendix D to Volume 1 of this EIS states that most of the alternatives would require a
period of implementation while facilities were constructed and equipment was procured.  Existing facilities
and equipment would be employed to manage Naval spent nuclear fuel during the transition.  Naval spent
nuclear fuel would be transported to the Expended Core Facility at INEL during the transition should an
alternative be selected requiring construction of a new examination facility or procurement of additional
shipping containers for dry storage at Navy sites.  Given this use of facilities and transportation routes that
are included in alternatives such as the 1992/1993 Planning Basis, the impacts per year during the
transition would be the same as given for those alternatives.  The potential 
environmental impacts of actions that would be taken to manage Naval spent nuclear fuel during a
transition period are therefore included in the EIS and all extremely small.

II COMMENT

The airplane crash accident analyses in the EIS for Naval spent nuclear fuel storage at Pearl Harbor should
include accidents involving shipping containers stored on railcars.
RESPONSE
Analyses of an aircraft crash into shipping containers stored on railcars at Pearl Harbor Naval Shipyard
were not included in this EIS because shipping containers are not stored on railcars at Pearl Harbor, but on
concrete pads.  Ship rather than rail transport is used to move Naval spent nuclear fuel to Puget Sound
Naval Shipyard.  Attachment F (including Table F.3-6) to Appendix D of Volume 1 includes analyses of
the accidents which might occur for storage of Naval spent nuclear fuel on concrete pads at Pearl Harbor
Naval Shipyard.
If an analysis were included for containers stored on railcars, the only difference in the result would be due
to a slight increase in the probability an airplane might crash into a container.  This is because the target
area for an array of containers on railcars would be greater than the target area for an array of the same
number of containers on a concrete pad.  The dependence of crash probabilities  on target area is described
in Section F.3 of Appendix D to Volume 1.  The difference in target areas is listed in Table D-1 in
Appendix D.

II COMMENT

The risks associated with "dry storage" at shipyards and prototype locations should be analyzed in this EIS.
RESPONSE
Appendix D to Volume 1 of this EIS includes, in Chapters 3 and 5 and Attachments A and F, detailed
evaluation of the possible exposures and potential health effects associated with Naval spent nuclear fuel
management at shipyards and Navy prototype sites.  These analyses include risks for transportation and
facility accidents for these alternatives, as well as for all other alternatives considered, and showed that the
risks from any alternative would be very small.  Transportation of Naval spent nuclear fuel for the
alternative involving the largest number of shipments was shown to produce less than one additional
fatality for the entire 40 year period considered.  Under the Decentralization alternative, three methods of
storage at shipyards and Navy prototype reactor locations are considered:  dry storage, storage in shipping
containers, and storage in water pools.   The risks associated with dry storage are specifically discussed in
this EIS.
This EIS shows that the risk associated with the transportation of Naval spent nuclear fuel or the risks
associated with storage at any location would be so small for all the alternatives considered that they do
not provide a basis for choosing among the alternatives.

II COMMENT

The risks associated with ships carrying Naval spent nuclear fuel to the Mainland should be analyzed in
this EIS.
RESPONSE
Appendix D to Volume 1 of this EIS includes, in Chapters 3 and 5 and Attachments A and F, detailed
evaluation of the possible exposures and potential health effects associated with the shipment of Naval
spent nuclear fuel from the Pearl Harbor Naval Shipyard in Hawaii to Puget Sound Naval Shipyard.  This is
the only movement of Naval spent nuclear fuel by ship and the only shipping route which makes use of the
Strait of Juan de Fuca and the upper portions of Puget Sound to the Puget Sound Naval Shipyard in
Bremerton.  No Naval spent nuclear fuel is shipped to the ports of Seattle or Tacoma.
The analyses reported in Appendix D include risks for normal operations and postulated accidents for
these alternatives, as well as for all other alternatives considered, and showed that the risks from any
alternative would be very small.  All transportation of Naval spent nuclear fuel for the alternative involving
the largest number of shipments was shown to produce less than one additional fatality for the entire 40
year period considered.  Under all alternatives but those which do not allow Naval spent nuclear fuel to
leave Pearl Harbor, a few shipments (fewer than 25) from Pearl Harbor to Puget Sound Naval Shipyard
would be made.
This EIS shows that the risk associated with the transportation of Naval spent nuclear fuel or the risks
associated with storage at any location would be so small for all the alternatives considered that they do
not provide a basis for choosing among the alternatives.  An analysis for a postulated accident which would
result in a serious fire aboard the vessel carrying Naval spent nuclear fuel in certified shipping containers
has been added to this EIS.

II COMMENT

Evaluation of a criticality event could be hampered because no references for ruthenium and cesium release
fractions were found.
RESPONSE
The cesium release fraction used is taken from the Nuclear Regulatory Commission's Regulatory Guide
3.34, as stated in section F.1.4.2.1.2.1 of Appendix D to Volume 1.  
The Nuclear Regulatory Commission's Regulatory Guide 3.34 does not include a release fraction for
ruthenium.  However, ruthenium was added to the postulated releases in order to provide complete
analyses consistent with those reported for other facilities in this EIS.  The ruthenium release fraction used
was obtained from a technical report prepared by Los Alamos National Laboratory.  This document, A
Guide to Radiological Accident Considerations for Siting and Design of DOE Nonreactor Nuclear
Facilities, LA-10294-MS, issued January 1986, was inadvertently omitted from the list of references in the
Draft EIS and has been added to the list of references in Attachment F of Appendix D to Volume 1.

II COMMENT

The loss of jobs in Southeastern Idaho should be considered in selecting an alternative for management of
Naval spent nuclear fuel.
RESPONSE
Appendix D to Volume 1 includes information on the socioeconomic impacts, such as increases or
decreases in employment at Naval spent nuclear fuel  management facilities, for each alternative
considered.  The data on socioeconomic impacts are summarized in Table 3-7 and Section 3.7 of Appendix
D.  The analysis summarized in Table 3-7 shows that selection of an alternative which ended the current
practice of shipping Naval spent nuclear fuel to the Expended Core Facility at INEL would result in the
loss of approximately 500 jobs in Southeastern Idaho.

II COMMENT

One commentor stated that the EIS should include uncertainties on the estimates of aircraft crash
probabilities and of the resulting number of latent cancer fatalities.
RESPONSE
The analyses performed for airplane crashes contain a large number of conservative assumptions which
result in a worst case or bounding analysis which is intended to produce results which would not be
exceeded even if all uncertainties were at the most unfavorable limit of their ranges.  Section F.1.4.2.2.2 of
Appendix D to Volume 1 provides a description of the analysis of an airplane crash.
The risks are very low even though the analyses included many conservatisms.  For example, the analysis
of an airplane crash into a container used to store Naval spent nuclear fuel assumed that the crash would
cause the container to be breached even though evaluation had shown that no part of an airplane could
penetrate the container.  The analyses used meteorological conditions (such as wind dispersion and speed)
which have only one chance in twenty of actually occurring, but no credit was taken for the fact that they
are worse than the actual conditions 95% of the time.  Further, the analysis of the consequences also
assumed that no evacuation of people in nearby residential areas or other mitigative measures were used to
reduce the effects.  As a result of these conservatisms, it is expected that the actual impacts of these
accidents would be 10 to 100 times less than calculated.
The conservative assumptions discussed above result in analysis results which are much greater than those
which would be expected should the accident actually occur.  The exposures and latent cancer fatalities
which have been calculated and reported in this EIS for a hypothetical airplane crash are ten to one
hundred times higher than those which would result from a more realistic, best-estimate analysis.  Put
another way, a more realistic analysis would calculate risks which are 10 to 100 times less than those
contained in the EIS.

II COMMENT

One commentor stated that the formula for the effective crash area on page F-228 appears to be
inconsistent with the description in the text and that the area calculated using this formula would be
infinite for a crash attitude angle of zero.
RESPONSE
The formula for the effective crash area given in section F.3.2 is valid only for crash angles of descent
greater than zero degrees.  This is not a problem with the use of the equation because an airplane would
have to be flying along parallel to the ground at an altitude equal to or greater than the height of the
"target" for the angle to be zero.  In such a case, the airplane would clear the object and  there would be no
crash.
The term in question which contains the cotangent of the angle of the aircraft's descent (cot ) represents
the effective shadow area.  The effective shadow area is the area of the projection of the target elevation on
the horizontal plane behind the target.  The formula for the effective shadow area is: 
                 Ashallow =  (L + Aw)   H   cot 
As can be seen, as the angle of descent () decreases, shadow area increases.  For the limiting case where
 goes to zero, the aircraft clears the top of the target; hence, the effective shallow area projection does not
apply.  For the EIS, a value of 15 degrees is used for , based on the recommended value in the Sandia
1983 reference.
Section F.3.2 will be revised to note that the angle of descent during a crash ( ) must be greater than zero
for the effective crash area formula to be valid.

II COMMENT

One commentor requested that details on perpendicular distances between runways and potential Naval
spent nuclear fuel storage sites be provided in the EIS to allow for calculation of the exponential factors in
the crash probability expressions in Section F.3.2.
RESPONSE
Perpendicular distances between runways and potential Naval spent nuclear fuel storage sites can be
determined by interested parties from the aeronautical and site maps obtained for each site from the
Federal Aviation Authority referenced in section F.3.3.  For Pearl Harbor, the following distances were
used in calculating the airport crash probabilities:  
_______________________________________________________________________________________
Airport             Runway Designation   Y-miles from end of     X-miles from center-
                                         runway to SNF           line of runway to SNF 
_______________________________________________________________________________________
Honolulu Interna-    8 left               0.99                    1.75
tional/              8 right              0.93                    2.97
Hickam AFB           4 right              0.17                    3.32
_______________________________________________________________________________________
Barbers Point NAS    29                   3.9                     6.1
                     11                   5.6                     6.1
                     22 left              6.6                     1.4
                     22 right             6.6                     1.5
                     4 left               8.4                     1.5
                     4 right              8.4                     1.4
_______________________________________________________________________________________

II COMMENT

One commentor presumed that the reason aircraft crash probabilities for potential Naval spent nuclear fuel
management sites are small is due to the exponential decrease in the probability of an airplane striking an
object on the ground as the distance from airports increases.
RESPONSE
The observation that the probability of an airplane crashing into an object on the ground decreases rapidly
as the distance between an airport or airway and the object increase is borne out by the data on aircraft
crashes.  Objects or buildings near airports or using main air routes are more likely to be involved in a crash
than those at greater distances because there are more aircraft in the vicinity of airports or heavily used
airways and because an aircraft is more likely to crash during takeoff and landing than during other flight
conditions.
The exponential factors which are included in the crash probability formula take into account the fact that
the probability of an aircraft crash striking a specific target decreases exponentially as the distance from the
target to the centerline of the runway or airway increases.  Further, the rate at which this exponential
decrease occurs is dependent upon other factors such as the type of aircraft which is involved, and the type
of flight operation in progress, such as takeoff, landing, or level flight.

II COMMENT

A commentor requested more detailed justification in the EIS for the use of a reduced aircraft skid distance
of 300 feet at shipyards.
RESPONSE
The 300 foot skid distance identified in section F.3.3 is based on a review of several shipyard and
prototype sites which might contain Naval spent nuclear fuel.  This review showed that from most
directions an aircraft could not skid more than a few hundred feet before it would hit a building, crane, or
drydock in the crowded confines of a Navy site.  Such an obstacle would quickly bring the airplane to rest
and would thus limit the skid distance.
In addition, a more detailed quantitative analysis was performed for two selected site locations to check the
validity of the use of a 300 foot skid distance.  Analysis of these latter site locations was performed using
maps of the specific sites, locating on these maps the potential site where Naval spent nuclear fuel could be
kept, and calculating the average of the maximum skid distances for every direction around the Naval spent
nuclear fuel.   In this calculation, it was assumed that an airplane would skid 1600 feet along the ground
unless the distance it could skid would be limited by an existing building, drydock, or other substantial
structure.  No credit was taken for reductions in skid distance caused by cranes, high buildings, or raised
earthen berms.  The  average skid distances for these two shipyards calculated in this manner were 199 feet
and 314 feet.  These results support the use of the 300 foot skid distance in this EIS.

II COMMENT

This EIS should present in detail the differences between the Nuclear Regulatory Commission and Sandia
methods for calculating aircraft crash probabilities.
RESPONSE
There are several key differences between the Nuclear Regulatory Commission and Sandia methodologies
which will produce differences in the calculated crash probabilities at spent nuclear fuel sites.  First, the
Nuclear Regulatory Commission method treats crashes during landing and takeoff operations at airports as
equally probable events.  In contrast, the Sandia method distinguishes between the two, and assigns a
higher probability of occurrence to a crash during landing, which is consistent with crash data for
commercial and military aircraft.
Second, the Nuclear Regulatory Commission method calculates the probabilities of crashes for concentric
rings around the airports, whereas the Sandia method employs an approach using two zones based on the
direction of travel and whether the aircraft is landing or taking off.  With the Nuclear Regulatory
Commission method, the probability of an aircraft crash during takeoff or landing is equally likely to occur
in all directions at a given radius from the airport.  Thus, during a takeoff operation, a target located behind
the aircraft or off to the side of the aircraft is just as likely to be involved in an aircraft crash as a target
located ahead of the aircraft.  This result is not realistic based on existing crash data which indicates that
targets behind the aircraft and off to the sides are seldom, if ever, involved in crashes during takeoffs.  In
contrast, the Sandia crash zone approach identifies two distinct crash zones:  one ahead of the runway, and
one off to the sides of the runway.  Different crash probability values are used for each zone to avoid
calculating probabilities for unrealistic situations such as the one just described.
Finally, the Sandia method includes terms, not found in the Nuclear Regulatory Commission method,
which adjust the aircraft crash probability based on the angle between the centerline of the runway and a
line which extends from the end of the runway to the target, and aircraft type.   Civilian aircraft typically
follow a straight approach or departure route so this feature increases the crash probability if the target is
located along the runway centerline or at small angles from the runway centerline.  For military high
performance aircraft, similar crash probability adjustments are made during landing operations, but are not
made during takeoff operations since military aircraft typically do not follow a straight departure route. 
These angular adjustments in crash probability are consistent with crash data for both commercial and
military aircraft.

II COMMENT

The effects on endangered or threatened species in the vicinity of a Navy site as a result of routine
operations or accidents associated with Naval spent nuclear fuel management operations should be
evaluated.
RESPONSE
The EIS considers in detail the potential environmental effects of each alternative under routine operations
and accident conditions.  The results of these analyses show, and past experience demonstrates, that Naval
spent nuclear fuel can be managed safely and without adverse environmental effects.  Chapter 5 of
Appendix D to Volume 1 includes a discussion of the effects of Naval spent nuclear fuel management on
the ecology in the vicinity of the sites considered.
To ensure appropriate protection for protected species, the location for any new Naval spent nuclear fuel
storage or examination facilities would be selected to avoid ecologically sensitive areas, such as those in
the vicinity of threatened or endangered species.  Construction activities would comply with all applicable
laws and regulations, using established procedures for preserving air and water quality and minimizing such
impacts as noise and disturbance or destruction of habitat.
No Naval spent nuclear fuel storage or examination facility would release water carrying radioactive or
hazardous material to the environment.  In almost 40 years of receipt, transportation, handling, and
examination of Naval spent nuclear fuel, the Naval Nuclear Propulsion Program has never had a release of
radioactivity that has had a significant effect on the environment.  Based on the operations that would be
performed and the controls that would be in place, the impacts on air, water, ecological, or geological
resources of any Naval facility considered would be small.  Furthermore, experience has shown that since
Naval spent nuclear fuel management is a low-intensity industrial activity, its contributions to noise and
traffic would be inconsequential.  Detailed calculations have shown that the cumulative radiation exposure,
and the health impacts of that exposure, on the human population in the vicinity of a Naval spent nuclear
fuel facility would be inconsequential; correspondingly, it is judged that the operation of such a facility
would not threaten the existence of any species.
In the unlikely event of a serious accident involving Naval spent nuclear fuel, it is estimated that for the
most severe case only about 210 acres of land would be affected to an extent that would exceed the
Nuclear Regulatory Commission public limit of 100 millirem per year.  Most of this area would be within
shipyard or DOE site boundaries.  The affected area would require decontamination, but this does not
mean that an area of such size would be rendered permanently unavailable for use or even evacuated for
long periods of time.  In reality, radioactive contamination could and would be removed in order to
minimize the affected area.  Since the radiological effects of accidents on the human population would be
small, the radiological effects on species other than humans would also likely be small.

II COMMENT

The effects on endangered or threatened species in the vicinity of a Navy site as a result of routine
operations or accidents associated with Naval spent nuclear fuel management operations should be
evaluated.
RESPONSE
The EIS considers in detail the potential environmental effects of each alternative under routine operations
and accident conditions.  The results of these analyses show, and past experience demonstrates, that Naval
spent nuclear fuel can be managed safely and without adverse environmental effects.  Chapter 5 of
Appendix D to Volume 1 includes a discussion of the effects of Naval spent nuclear fuel management on
the ecology in the vicinity of the sites considered.
To ensure appropriate protection for protected species, the location for any new Naval spent nuclear fuel
storage or examination facilities would be selected to avoid ecologically sensitive areas, such as those in
the vicinity of threatened or endangered species.  Construction activities would comply with all applicable
laws and regulations, using established procedures for preserving air and water quality and minimizing such
impacts as noise and disturbance or destruction of habitat.
No Naval spent nuclear fuel storage or examination facility would release water carrying radioactive or
hazardous material to the environment.  In almost 40 years of receipt,  transportation, handling, and
examination of Naval spent nuclear fuel, the Naval Nuclear Propulsion Program has never had a release of
radioactivity that has had a significant effect on the environment.  Based on the operations that would be
performed and the controls that would be in place, the impacts on air, water, ecological, or geological
resources of any Naval facility considered would be small.  Furthermore, experience has shown that since
Naval spent nuclear fuel management is a low-intensity industrial activity, its contributions to noise and
traffic would be inconsequential.  Detailed calculations have shown that the cumulative radiation exposure,
and the health impacts of that exposure, on the human population in the vicinity of a Naval spent nuclear
fuel facility would be inconsequential; correspondingly, it is judged that the operation of such a facility
would not threaten the existence of any species.
In the unlikely event of a serious accident involving Naval spent nuclear fuel, it is estimated that for the
most severe case only about 210 acres of land would be affected to an extent that would exceed the
Nuclear Regulatory Commission public limit of 100 millirem per year.  Most of this area would be within
shipyard or DOE site boundaries.  The affected area would require decontamination, but this does not
mean that an area of such size would be rendered permanently unavailable for use or even evacuated for
long periods of time.  In reality, radioactive contamination could and would be removed in order to
minimize the affected area.  Since the radiological effects of accidents on the human population would be
small, the radiological effects on species other than humans would also likely be small.

II COMMENT

The effects of hurricanes or tsunamis should be analyzed in this EIS and considered in the final decision.
RESPONSE
While hurricanes can have high winds, hurricane winds normally cannot generate the very large, very fast
missiles analyzed for tornadoes.  For example, tornado winds of 360 miles per hour were used to generate
the wind-driven missiles used in evaluating storage in shipping containers, as described in Section F.1.4 of
Appendix D to Volume 1.  These winds are the same as those specified for design of nuclear power plants. 
Hurricanes very infrequently produce winds that could generate such missiles, so the analyses provided for
tornadoes in Appendix D provide an upper limit for the effects of hurricanes.  Examination of damage
caused by recent severe hurricanes shows that robust structures can withstand hurricanes.  Based on these
considerations, the analysis of wind-driven missiles in the EIS is reasonable and adequate.
The containers used for storage are designed to withstand water immersion under severe accident
conditions and no deleterious effects would be expected from submersion of a container.  Thus, the rugged
containers used for storage would be highly unlikely to be penetrated during a hurricane or tsunami.
Storage of Naval spent nuclear fuel in water pools at Navy sites is also considered under the
Decentralization alternative.  The Naval spent nuclear fuel in water pools would normally be under water
and the effects on the environment due to flooding by a hurricane or tsunami would be primarily limited to
exchanging some pool water bearing radioactive corrosion products with the flood waters.  Such a release
would not be expected to occur except for the most severe hurricanes or tsunamis.  Attachment F to
Appendix D of Volume 1 provides analyses of the effects of releases of water containing radioactive
material.  The results of these analyses represent an upper limit on the effects of releases possible during a
hurricane or tsunami sufficiently severe to flood a water pool containing Naval spent nuclear fuel.  These
results show that the risks of such releases would be small under all of the alternatives considered.
Some commentors expressed concern about the depth of flooding of drydocks during such severe weather. 
However, this is not a concern because Naval spent nuclear fuel facilities would not be placed in drydocks
since they are needed for ship maintenance and repair.

II COMMENT

Hurricanes can have winds like the 212 miles per hour measured during Hurricane Iniki in 1992.  Since
hurricanes are more common than tornadoes, the probability for a wind-driven missile is higher than the
tornado probability given in the EIS.
RESPONSE
The analysis presented in section F.1.4.2.2. of Attachment F to Volume 1, Appendix D, Part B, assumed a
missile driven by the winds of a tornado impacted upon a dry storage container.  This assumption was made
because winds produced by tornados are higher than hurricane winds and thus the impacting missile would
be traveling with higher velocity and would have higher kinetic energy.  Even at this higher velocity,
analysis has shown that the missile would not penetrate the container.  The probability of penetration at
the lower velocity of a hurricane (212 miles per hour) would be even smaller than the probability of
penetration for a missile propelled by the winds of a tornado (traveling at 360 mph).  
While hurricanes can have high winds, hurricane winds normally cannot generate the very large, very fast
missiles analyzed for tornadoes.  While hurricanes may occur more frequently than tornadoes the overall
risk from a hurricane is lower because of the lack of penetration of the container. 
The analysis of wind damage using missiles propelled by the winds of tornados is the same as is done for
design of nuclear power plants.  Hurricanes very infrequently have winds that could generate such missiles,
so the analyses provided for tornados in Appendix D provide an upper limit for the effects of hurricanes. 
Examination of damage caused by recent severe hurricanes shows that robust structures can withstand
hurricanes.  Based on these considerations, the analysis of wind-driven missiles in the EIS is reasonable
and adequate.

II COMMENT

Accidents could be caused by human error during handling or storage of Naval spent nuclear fuel.
RESPONSE
The range of hypothetical accidents analyzed in Appendix D to Volume 1 (more than ten different
accidents) include those which might be caused by human error, failures of equipment, and natural
phenomena, such as earthquakes or tornados.  The analyses provide calculations of the most severe
consequences which might be caused by reasonably foreseeable accidents.
The accidents analyzed include those caused by persons working with Naval spent nuclear fuel, such as
improper crane operation, and by others, such as aircraft crashes, which could be caused by pilot error. 
The analyses and some of the possible initiating causes are described in detail in Attachment F to Appendix
D.

II COMMENT

The effects of routine Naval spent nuclear fuel management operations on water consumption or usage
should be evaluated.
RESPONSE
For each of the locations considered for management of Naval spent nuclear fuel, consumption of both
surface water and groundwater has been evaluated.  (See the Water Resources sections of Chapter 5 in
Appendix D to Volume 1)  As stated in the EIS, consumption or usage of water is expected to represent a
small change at all of the sites.  
For example, current freshwater usage at the Puget Sound Naval Shipyard is identified in Chapter 4 of
Appendix D to Volume 1 as 676 million gallons annually.  At Norfolk Naval Shipyard, current water
consumption is 823 million gallons yearly.  None of the alternatives for Naval spent nuclear fuel
management would involve an increase in current water usage at any location of more than 3 million
gallons yearly.

II COMMENT

The effects on groundwater resulting from routine operations or accidents associated with Naval spent
nuclear fuel management should be evaluated.
RESPONSE
The effects of Naval spent nuclear fuel management on groundwater are addressed in Volume 1, Appendix
D.  During routine operations associated with spent nuclear fuel there would be no discharge of radioactive
or hazardous liquid effluents under any of the alternatives at any of the sites.  This is consistent with
current Naval spent nuclear fuel management practices.
The effects of accidents on groundwater are also addressed in Appendix D, Attachment F.  These analyses
consider exposure and risk associated with direct release of radioactivity to surface water or 
ground water, as well as potential for air releases which affect ground or surface waters.  Details of the
analyses are summarized in Attachment F.

II COMMENT

The effects on the ocean of routine operations or accidents associated with Naval spent nuclear fuel
management should be evaluated.
RESPONSE
The effects on the ocean of routine operations and accidents associated with Naval spent nuclear fuel
management are addressed in Attachment F to Appendix D.  Table F.1.3.8-2 addresses impacts to water
resources in the vicinity of locations involved with spent nuclear fuel operations.  The possible exposures
to radioactive material documented in Attachment F and the impacts of various Naval spent nuclear fuel
management alternatives include those due to any radioactivity entering the ocean near the shipyards.  The
effects of both deposition of airborne radioactivity and liquid effluent releases were analyzed.  Impacts due
to activities on and in the ocean (boating and swimming) as well as ingestion of sea food were included in
the evaluations.
From the start of the Naval Nuclear Propulsion Program, the policy of the U.S. Navy has been to reduce to
the minimum practicable amount the amounts of radioactivity released into harbors.  Navy procedures to
accomplish this have been reviewed with  DOE, the U.S. Nuclear Regulatory Commission, and the U.S.
Environmental Protection Agency.
The total amount of long-lived gamma radioactivity released into harbors and seas within twelve miles of
shore has been less than 0.002 curie during each of the last twenty-three years.  This total is for releases
from U.S. Naval nuclear-powered ships and from the supporting shipyards, tenders, and submarine bases
and at operating bases and home ports in the U.S. and overseas, and all other U.S. and foreign ports which
were visited by Navy nuclear-powered ships. (Refer to Report NT-94-1, Environmental Monitoring and
Disposal of Radioactive Wastes from U.S. Naval Nuclear Powered Ships and Their Support Facilities,
Washington, D.C., March 1994).  To put this small quantity of radioactivity into perspective, it is less than
the quantity of naturally occurring radioactivity in the volume of ocean water occupied by a single nuclear-powered submarine.
There are no fission product releases to the ocean from nuclear fuel on board operating Naval vessels
because the fuel is designed to contain fully any fission products in order to protect the crew.

II COMMENT

The Draft EIS does not account for severe water leaks from the Expended Core Facility.
RESPONSE
There is no evidence that any leakage is occurring from the Expended Core Facility (ECF) water pool.  
Each time water is added to the pool at ECF the amount is measured and recorded.  Actual measured water
additions to the ECF pool can be correlated with expected evaporation from the surface of the water pool
rather than leakage.  Nevertheless, section F.1.4.2.1.6 of this EIS presents an accident analysis for minor
water leakage from the ECF water pool.  The analysis was based on the largest amount of water leakage
from the ECF pool that is reasonably foreseeable.  This analysis used the isotopes and their concentrations
shown by measurement to be present in the ECF pool water to represent the radioactivity which might be
released to the environment.  
In addition to the analysis of minor water leakage, section F.1.4.2.1.1 presented an analysis of an accident
where the entire contents of the Expended Core Facility water pool are assumed to leak rapidly due to a
seismic event.  This analysis assumed that the isotopes normally present and those which could escape due
to shock impact from the seismic event would be present in the water leaking to the environment.  
The results of both these analyses indicate that the impact on the environment would be very, very small.
There have been leaks from the Expended Core Facility on occasion in the past, but these leaks have been
located and corrected when they occurred.  Monitoring of the groundwater in the vicinity of the Expended
Core Facility has detected no radioactive material released from ECF.

II COMMENT

Storage or management of Naval spent nuclear fuel at a Navy site would make it a more attractive target for
attack in the event of war.
RESPONSE
Since Naval spent nuclear fuel is not a strategic asset, the presence or absence of Naval spent nuclear fuel
would not be expected to alter the strategy of an aggressor with respect to attacking a Naval shipyard.
Information has been added to Appendix D of Volume 1 of the EIS which provides further discussion of
the effects of an attack on Naval spent nuclear fuel management facilities or equipment in the event of war,
terrorism or sabotage.  The effect of such an attack is expected to be conservatively bounded by the limiting
accident discussed at each facility under each alternative. For example, the most limiting accident involving
Naval spent nuclear fuel is described in Attachment F of Appendix D to be an airplane crash into a
shipping container at the Pearl Harbor Naval Shipyard.  This accident would lead to 26 latent fatal cancers
over the next fifty years in the population within 50 miles of the shipyard.  Since the probability of the
event is one chance in 100,000 per year, the risk would be 0.00026 latent fatal cancer fatalities per year or,
in other words, about one chance in 4,000 of a single latent fatal cancer fatality over a year.  This risk is
shared among the approximately 820,000 people residing within 50 miles of the shipyard who would be
expected to have over 2,000 cancer fatalities from all causes every year.  For an act of war, sabotage or
terrorist attack, it is likely the risk would be lower than calculated because it should be less probable that a
force would exist to disperse radioactive products into the atmosphere from a weapon as compared to the
motive force of the fire assumed in the case of an airplane crash.

II COMMENT

Storage or management of spent nuclear fuel at a Navy site would make it a more attractive target for
terrorist attack or sabotage.
RESPONSE
Naval spent nuclear fuel would be stored or examined only within the secure areas of a DOE or Navy site. 
The security precautions in effect at these sites, in addition to the extremely rugged containers or thick
walls of water pools, would make the Naval spent nuclear fuel management facilities unattractive targets
for terrorists.
Information has been added to Appendix D of Volume 1 of the EIS which provides further discussion of
the effects of an attack on Naval spent nuclear fuel management facilities or equipment in the event of war,
terrorism or sabotage.  The effect of such an attack is expected to be conservatively bounded by the limiting
accident discussed at each facility under each alternative. For example, the most limiting accident involving
Naval spent nuclear fuel is described in Attachment F of Appendix D to be an airplane crash into a
shipping container at the Pearl Harbor Naval Shipyard.  This accident would lead to 26 latent fatal cancers
over the next fifty years in the population within 50 miles of the shipyard.  Since the probability of the
event is one chance in 100,000 per year, the risk would be 0.00026 latent fatal cancer fatalities per year or,
in other words, about one chance in 4,000 of a single latent fatal cancer fatality over a year.  This risk is
shared among the approximately 820,000 people residing within 50 miles of the shipyard who would be
expected to have over 2,000 cancer fatalities from all causes every year.
For an act of war, sabotage or terrorist attack, it is likely the risk would be lower than calculated for the
airplane crash because it should be less probable that a force would exist to disperse radioactive products
into the atmosphere from a weapon as compared to the motive force of the fire assumed in the case of an
airplane crash.  For example, anti-tank weapon attacks on containers would be less severe than the
accidents analyzed because: (a) anti-tank weapons would cause a self-sealing penetration in the metal of a
container, unlike that which is assumed from the airplane crash (impact from a 50 inch diameter engine
rotor); (b) there is no explosive material inside the container, so it will not "blow up" as a tank would if hit
by such a weapon (in a tank attack, the tank shells inside the turret detonate); (c) there would be no fire to
disperse the radioactivity that is released when the container is breached, unlike an aircraft crash where the
jet fuel will burn creating such a fire.  The rugged design of containers and the thick walls of water pools,
combined with the shock-absorbing nature of water with a free surface, reduce the effects of other types of
explosive charges.  Attachment F of Appendix D of the EIS has been modified to better describe this
analysis.

II COMMENT

The EIS should describe the consequences of a terrorist attack on Naval spent nuclear fuel management
facilities.
RESPONSE
The consequences of such an attack have been considered and determined to be less than the limiting
accidents analyzed in the EIS, specifically the crash of a large jet or an earthquake (See Appendix D,
Attachment F, Section F.1.2).  Attacks using anti-tank weapons or other specialized weapons, as well as
conventional explosives, were evaluated.
The reasons that anti-tank weapon attacks on containers would be less severe than the accidents analyzed
are: (a) anti-tank weapons would cause a self-sealing penetration in the metal of a container, unlike that
which is assumed from the airplane crash (impact from a 50 inch diameter engine rotor); (b) there is no
explosive material inside the container, so it will not "blow up" as a tank would if hit by such a weapon (in
a tank attack, the tank shells inside the turret detonate); (c) there would be no fire to disperse the
radioactivity that is released when the container is breached, unlike an aircraft crash where the jet fuel
might pool, ignite, and create a fire.  The rugged design of containers and the thick walls of water pools,
combined with the shock-absorbing nature of water with a free surface, reduce the effects of other types of
explosive charges.  It is not credible that a terrorist attack would result in a criticality or meltdown of spent
nuclear fuel; however, in Section F.1.4.2.1.2 the consequences of a hypothetical criticality accident are
presented.  The risks associated with an accidental criticality are less than those associated with a drained
water pool or an airplane crash into dry storage containers.  Attachment F of Appendix D of the EIS has
been modified to better describe this analysis.
Terrorist attacks on Naval spent nuclear fuel during shipment were also evaluated.  The massive structure
of the shipping containers used for Naval spent nuclear fuel makes them an unlikely target of a terrorist
attack.  No such attacks have occurred in the nearly 40 years of rail shipments, which have now traveled
about 2 million kilometers.  Thus, the probability of a terrorist attack on a shipment is judged to be no
more than the probability of a rail accident which is listed in section A.7.1.2.1 of Attachment A to
Appendix D of the EIS.  The consequences of a terrorist attack are also judged to be no more severe than
those listed for transportation accidents.  Therefore the same conclusions reached for transportation
accidents apply to the risk to the extremely rugged shipping containers from terrorist attack during a
shipment.  In addition, during shipment, all Naval spent nuclear fuel containers are accompanied by escorts
who remain in contact with headquarters.  In the event of an emergency, state and federal resources would
be quickly summoned to stabilize the situation.

II COMMENT

The effects of a terrorist attack using a nuclear weapon should be evaluated for Naval spent nuclear fuel
management facilities.
RESPONSE
Naval spent nuclear fuel would be stored or examined only within the secure areas of a DOE or Navy site. 
The security precautions in effect at these sites would make the Naval spent nuclear fuel management
facilities unattractive targets for terrorists.  Although a detailed analysis of the effect of a nuclear weapon
attack has not been included in the EIS, such a scenario would not cause an uncontrolled chain reaction or
explosion in Naval spent nuclear fuel.  The only effect that might occur from a nuclear weapon detonation
would be damage or dispersion of the spent nuclear fuel.  The immediate death and destruction resulting
from detonation of the nuclear weapon itself would be of much greater concern than the limited delayed
effects associated with Naval spent nuclear fuel.

II COMMENT

The weight of the Naval spent nuclear fuel shipping containers may be greater than can be supported by
existing buildings or structures.
RESPONSE
The weight of shipping containers can be readily accommodated on any well constructed pad on firm
ground.  This is illustrated by the fact that they are within the weight limits for the railroads and are
transported over the standard rail lines and handled at the Navy shipyards and INEL without special
arrangements or structures.  Containers used in transport of Naval spent nuclear fuel have been used to
approximately 40 years without causing damage to existing buildings or structures.

II II COMMENT

It would be impossible (or very difficult) to evacuate Oahu in the event of an accident at Pearl Harbor
Naval Shipyard involving Naval spent nuclear fuel stored there.
RESPONSE
Evaluation of the results in this EIS shows that evacuation of Oahu should not be required even if the most
severe accident postulated for Naval spent nuclear fuel were to occur.
In order to help understand why this is the case for even severe hypothetical accidents, Appendix D (See
Chapter 5, section 5.1.4.14.3, and Attachment F, section F.1.3.8) provides the results of calculations of
radioactive material dispersion and deposition calculations for a hypothetical airplane crash into Naval
spent nuclear fuel storage containers at Pearl Harbor Naval Shipyard.  (As one measure of the conservatism
of the analyses, such a crash is not expected to breach a container, but in the EIS it was assumed that such
an accident would occur nonetheless.)  This is the worst case potential accident for that site.  These results
show that even under this extremely severe case, an area of only about 110 acres could be contaminated to
the point where radiation doses exceeding the Nuclear Regulatory Commission public limit of 100 millirem
per year might result for a person living full-time on that land.  Most of this area would be within shipyard
boundaries.  The potentially contaminated area would be small owing to the relatively small amount of
spent nuclear fuel in a storage container and the robust nature of the container and the fuel.
These results mean that the maximum area which might be considered for possible evacuation in the most
severe case would be very small and localized.  It should be kept in mind that the calculation described in
the preceding paragraph assumes that no action is taken to clean up the radioactivity released and people
would occupy the land full time for at least a year without any action to mitigate the 
effects of exposure.  In reality, radioactive contamination could and would be removed in order to
minimize the affected area and reduce impacts on any people involved.

II COMMENT

It would be difficult to obtain emergency aid from the Mainland in the event of an accident at Pearl Harbor
Naval Shipyard involving Naval spent nuclear fuel stored there.
RESPONSE
As discussed in this EIS (See Appendix D, Section 5.8.4), the Navy has significant emergency response
capability on Oahu and does not rely on resources from the Mainland for emergency response. 
Furthermore, the analysis of the impact of hypothetical accidents in the EIS did not rely on any off-shipyard response.  The State of Hawaii does have radiological emergency response procedures.  In
addition, the State of Hawaii plans in place to deal with natural emergencies such as hurricanes and floods
are sufficient to deal with any public response necessary in the unlikely event of a problem involving Naval
spent nuclear fuel.  Thus, any off-shipyard emergency response would reduce the potential health impacts
below the levels calculated in the EIS.

II COMMENT

Emergency planning for accidents involving Naval spent nuclear fuel should be described in this
Environmental Impact Statement.
RESPONSE
As discussed in Appendix D (Section 5.8.4), the Navy has significant emergency response capability at all
of its sites and does not rely on the State or local resources for emergency response.  Furthermore, the
analysis of the impact of hypothetical accidents in the EIS did not rely on any off-shipyard response.  All
of the states hosting Navy sites have radiological emergency response procedures.  In addition, other civil
defense plans in place to deal with natural emergencies are sufficient to deal with any public response
necessary in the unlikely event of a problem involving Naval spent nuclear fuel.
As a further point, the analyses of hypothetical accidents in Appendix D are conservative because they
assume that no off-site emergency response actions are taken.  Thus, any off-site emergency response to
protect the public would reduce the potential health impacts below the levels calculated in the EIS.

II COMMENT

The State of Hawaii's Department of Health would not be capable of responding to a major release of
radioactive material at Pearl Harbor.
RESPONSE
The analyses of hypothetical accidents in Appendix D to Volume 1 assume that no off-site emergency
response actions are taken in the event of even the most severe accidents.  Thus, if an off-site emergency
response occurred, it would reduce the potential health impacts below the levels calculated in the EIS.
As discussed in Appendix D (Section 5.8.4), the Navy has significant emergency response capability at all
of its sites, including Pearl Harbor, and does not rely on the State of Hawaii or local resources for
emergency response beyond existing emergency plans and resources.  Nonetheless, the state of Hawaii, like
all of the states hosting Navy sites, has emergency response procedures already established.  In addition,
other civil defense plans in place to deal with natural emergencies are sufficient to deal with any public
response necessary in the unlikely event of a problem involving Naval spent nuclear fuel.  Coordination of
Navy and local emergency response capabilities is tested periodically in drills simulating radiological
accidents at the shipyard.

II COMMENT

The existence of emergency plans and the state of readiness maintained by emergency response teams is an
indication that an accident is likely.
RESPONSE
Maintaining preparedness for emergencies has been judged by most people in the United States to be a
prudent step.  This does not mean that all of the emergencies for which preparedness is maintained are
highly probable or even likely, but reflects the belief that it is more prudent to train personnel and provide
equipment that might be needed in emergencies if they occur.  Experience has also shown that such
preparedness can be of great value in less severe accidents or in natural disasters.
Preparedness for the most severe accidents has been a basic tenet of the Navy and the Naval Nuclear
Propulsion Program from the very beginning of the use of nuclear power in warships. Despite steaming
more than 100,000,000 miles and accumulating over 4400 reactor years of operation without a reactor
accident or any problem having a significant effect on the environment, the Navy has continued to train
personnel how to respond a full range of accidents and has tested the preparedness of their personnel 
with periodic exercises.  These exercises include interaction with appropriate state and local agencies and
continue to form a cornerstone of the safety philosophy of the Naval Nuclear Propulsion Program.
The Navy's efforts to maintain vigilance and preparedness do not in any way indicate that accidents are
expected or accepted.

II COMMENT

There is no warning system in place in the vicinity of Puget Sound Naval Shipyard to alert the citizens in
the event of a radiological accident at the shipyard (and no funding mechanism exists to support such a
system).
RESPONSE
The EIS shows that the maximum area in the vicinity of Puget Sound Naval Shipyard  which might be
considered for possible evacuation in the most severe radiological accident involving spent nuclear fuel
management would be very small and localized.  Consequently, the normal methods for notifying the
public, such as the Emergency Broadcast System, commercial radio and television and police car public
address systems, are adequate.  In addition, the Navy has significant emergency response capability at all of
its sites.  These resources also would be available to provide public assistance if needed.
In order to help understand why this is the case for even severe hypothetical accidents, Appendix D to
Volume 1 (See Chapter 5, Section 5.1.1.14.3, and Attachment F, Section F.1.3.8) provides the results of
calculations of radioactive material dispersion and deposition calculations for a hypothetical airplane crash
into Naval spent nuclear fuel storage containers at Puget Sound Naval Shipyard.  It is an indication of the
conservative nature of the analyses in the EIS that an accident assuming breach of the container was
included in the EIS even though such an airplane crash involving the largest aircraft in existence would not
be expected to penetrate the containers.  This is the worst case potential accident for that site.  These
results show that even under this extremely severe case an area of only about 110 acres could be
contaminated to the point where radiation doses exceeding the Nuclear Regulatory Commission public
limit of 100 millirem per year might result for a person living full time on that land for a year and most of
this area would be within shipyard boundaries.  The potentially contaminated area would be small owing
to the relatively small amount of spent nuclear fuel in a storage container and the robust nature of the
container and the fuel.

II COMMENT

The citizens in the vicinity of Puget Sound Naval Shipyard are not prepared to respond to a radiological
emergency.
RESPONSE
Representatives of the Puget Sound Naval Shipyard have met a number of times in the past with the Kitsap
County Emergency Management (KDEM) Agency to address emergency planning related matters,
including Shipyard assistance of response to off-site radiological accidents and emergencies.  In these
discussions, the representatives of the Kitsap County Emergency Management Agency have stated their
intention to familiarize citizens and businesses with emergency planning concepts such as sheltering.  Puget
Sound Naval Shipyard will continue to work with local emergency planning organizations to ensure that
adequate response capabilities exist in the remote event of a radiological accident.

II COMMENT

The  Puget Sound Naval Shipyard does not share emergency response plans or conduct joint planning with
local emergency management organizations.
RESPONSE
This statement is inaccurate.  Over the years, the Puget Sound Naval Shipyard has conducted or attended
many formal meetings with the representatives of local emergency preparedness organizations.  Some
examples of the information exchanged during these meetings include: notification procedures, shipyard
response and assistance for radiological accidents at locations other than the shipyard, Kitsap County
Emergency Plan revision, information for shipyard annexes to the Washington and Kitsap County
Emergency Management Plans, radiation monitoring instrumentation, public information releases,
communication equipment, monitoring beyond the boundaries of the shipyard, aerial monitoring, accident
scenarios, shipment of radioactive material, training for county firefighters and Emergency Medical
Technicians, Event Category and Protective Action Recommendations, and an overview of nuclear-powered 
Naval vessels, the reactors installed in them, and Naval nuclear fuel.  The shipyard has 
also presented overviews of the Navy Environmental Monitoring Program and the Navy Radioactive Waste
Disposal Program.
Over the past 18 years, the Shipyard has met with the Kitsap Department of Environmental Management
(KDEM) approximately 30 times and has provided information for potential inclusion in annexes to their
emergency plans.  In January, 1992, the Shipyard assisted the Kitsap Department of Environmental
Management in reviewing and revising parts of the draft revision to the 1973 County plan.  The current
County Plan reflects information provided by the shipyard.  The Shipyard will continue to provide
technical assistance to the County as applicable information from the County's operating procedures is
added to the County's plan.
Many tours of the Shipyard Emergency Control Center and the control center to be used at the scene of an
accident have been conducted for state and local officials.  The Kitsap county emergency management
agencies have been involved with planning and conducting joint exercises.

II COMMENT

It would be very difficult to evacuate the area in the vicinity of Norfolk Naval Shipyard in the event of an
accident due to the large population and the poor highway system.
RESPONSE
The results of the analyses of postulated accidents in this EIS show that no evacuation would likely be
required even if the most severe accident postulated for Naval spent nuclear fuel were to occur at any of
the sites considered.
In order to help understand why this is the case for even severe hypothetical accidents, Appendix D,
Attachment F, Section F.1.3.8 provides the results of calculations of radioactive material dispersion and
deposition calculations for all hypothetical accident scenarios analyzed.  For the worst case potential
accident at Navy sites, the results show that an area of less than about 110 acres could be contaminated to
the point where radiation doses exceeding the Nuclear Regulatory Commission public limit of 100 millirem
per year might result for a person living full time on that land for an entire year.  Most of this area would
be within shipyard boundaries.
These results mean that the maximum area which might be considered for possible evacuation in the most
severe case would be very small and localized.  It should be kept in mind that the calculation described in
the preceding paragraph assumes that no action is taken to clean up the radioactivity released and people
would occupy the land full time for at least a year without any action to mitigate the effects of exposure. 
In reality, radioactive contamination could and would be removed in order to minimize the affected area
and reduce impacts on any people involved.

II II COMMENT

The cumulative impacts of radiation and other carcinogens should be analyzed.
RESPONSE
The radiological and non-radiological cumulative health impacts associated with each alternative involving
Naval spent nuclear fuel are addressed in Volume 1, Section 5.3 and in more detail in the Cumulative
Impacts section for each site in Chapter 5 of Appendix D to Volume 1.  The results of the analyses
performed in support of the EIS demonstrate that implementing any of the alternative at any of the sites
would not produce significant cumulative impacts.  As discussed in Volume 1, Appendix D, this stems from
the fact that release of radioactive materials is strictly controlled at minute levels, levels which are very
small compared to the amounts of radioactivity present in the environment from natural sources, and that
the only chemical releases associated with routine Naval spent nuclear fuel operations would be the small
amounts of combustion products associated with heating boiler operations and occasional emergency diesel
operations.
Radiological and non-radiological cumulative health impacts associated with carcinogens are treated
separately in the EIS because, with few exceptions such as cigarette smoke, increases in the effects of
known carcinogens caused by combination with exposure to radioactive materials or radiation have not
been quantified or conclusively identified by the scientific community.  Further, as noted above, spent
nuclear fuel operations release only a small level of combustion exhaust in addition to the minute levels of
radioactive material releases.  In addition, considerably less is known about the health risks due to
chemical carcinogens so quantitative tools for assessing these risks are either not available or not widely
accepted.  Consequently, combining risks associated with radiological and non-radiological carcinogens
would introduce considerable unnecessary uncertainty into the calculations for risks associated with
radioactivity.

II II COMMENT

The Navy should identify how it expects to manage greater-than-class C low-level waste.
RESPONSE
U.S. Nuclear Regulatory Commission 10 CFR 61 identifies three classes of low-level wastes which are
generally suitable for near-surface disposal:  namely, Classes A, B and C.  Wastes with concentrations
greater than those specified for Class C for certain short and long-lived isotopes were found to be not
generally suitable for near surface disposal.  These wastes are classified as "greater than Class C" Low-Level radioactive waste (GTCC LLW).  
In May 1989, the Nuclear Regulatory Commission promulgated a rule that requires disposal of 
commercially generated Low-Level Waste with concentrations of radioactivity greater than Class C in a
deep geologic repository, unless disposal elsewhere is approved by the Nuclear Regulatory Commission.
Currently, a small amount (about 25 cubic meters) of greater than Class C Low-Level Waste in material
removed from the ends of Naval spent nuclear fuel modules over the years is being stored at the Naval
Reactors Facility pending availability of a disposal facility licensed by the Nuclear Regulatory Commission. 
This material has been collected and held at the Expended Core Facility for many years.  In addition, about
0.02 cubic meters of test specimens are being stored at the Expended Core Facility as greater than Class C
Low-Level Waste pending availability of a permanent disposal facility.  This practice is expected to
continue over the period of time covered by this EIS.
This description of how greater than Class C Low-Level Waste is stored at the Expended Core Facility has
been added to Volume 1, Appendix D of the EIS.

II COMMENT

The quantity and character of Naval Reactors Facility specimens irradiated at INEL and other test reactors
that ultimately are sent to the Radioactive Waste Management Complex for shallow land burial should be
provided in this EIS since the data in this EIS suggest Greater than Class C waste.
RESPONSE
This EIS provides in Section A.7.3 of Appendix D to Volume 1 enough information on the number of
shipments of specimens from Naval Reactors Facility and the amounts of radioactivity and other
information related to these shipments to allow an independent analyst to perform calculations of the
potential impacts of these shipments.  These specimen shipments have been included to support evaluation
of possible cumulative impacts even though they are not part of the action evaluated by this EIS.
The statement that Greater than Class C waste is sent to the Radioactive Waste Management Complex at
INEL for shallow land burial is inaccurate.  Specimens which contain nuclear fuel are not sent to the
Radioactive Waste Management Complex at INEL.  Only those specimens which meet the Radioactive
Waste Management Complex acceptance criteria are ultimately sent to that facility for disposal.  Greater
than Class C radioactive waste from Navy operations has been held at the Naval Reactors Facility and will
continue to be held there until a site for ultimate disposition is designated.

II COMMENT

The Navy should consider the material removed from the ends of fuel modules during examination at the
Expended Core Facility as spent nuclear fuel.
RESPONSE
This EIS relies on definitions and classifications of nuclear materials set forth in the Nuclear Waste Policy
Act, as amended, and regulations issued by the Environmental Protection Agency (40 CFR 261) and the
Nuclear Regulatory Commission (10 CFR 61).  The categories set forth in these regulations are "Spent
Nuclear Fuel", "High Level Waste", "Transuranic Waste", "Low-Level Waste", "Low-Level Mixed Waste",
"Greater than Class C Waste", and "Hazardous Waste".
Volume 1, Appendix H sets forth the definition of spent nuclear fuel used in this EIS as "fuel that has been
withdrawn from a nuclear reactor following irradiation, the constituent elements of which have not been
separated."  The definition of High-Level Waste in Appendix H to Volume 1 is "highly radioactive waste
material that results from the reprocessing of spent nuclear fuel, including liquid waste produced from
reprocessing and a solid waste derived from the liquid....".  Transuranic Waste is defined as "waste
containing more than 100 nanoCuries of alpha-emitting transuranic isotopes, with half-lives greater than 20
years, per gram of waste, ....".   Low-Level Waste is defined as "waste that contains radioactivity and is not
classified as high-level waste, transuranic waste, or spent nuclear fuel".
The ends of the fuel modules removed from Naval spent nuclear fuel modules at the Expended Core
Facility are structural material which provides support and directs the flow of cooling water during
operation.  This structural material is removed by cutting through portions of the fuel modules which
contain no fuel.  The material removed from the ends of the fuel modules does not contain any fuel or
fission products from fuel and therefore cannot be considered "spent nuclear fuel".  They do not contain
transuranic elements or fission products and thus cannot be considered High Level Waste or Transuranic
Waste.  The amounts of radioactivity in the end boxes cause them to be classified as Low-Level Waste. 
Consequently the material removed from the ends of the modules at the Expended Core Facility is catego-
rized as Low-Level Waste due to the amount of radioactivity present in it.   The disposal of this structural
material at the Radioactive Waste Management Complex at INEL is accomplished in accordance with all
applicable regulations.  As indicated in Section 5.2.15 of Appendix D, Part A of Vol. 1 of the EIS, the
amount of Low-Level Waste generated each year at the Expended Core Facility is 425 cubic meters.  The
radioactive isotopes which represent 99% of the activity in the material removed from the ends of fuel
modules are identified in the following table:
      ISOTOPE               HALF LIFE
      Fe55                  2.73 years
      Co60                  5.271 years
      Ni59                  76000 years
      Ni63                  100 years
A description of the composition of material removed from the ends of fuel modules during examination
has been added to Volume 1, Appendix D, Attachment B of the EIS.

II COMMENT

The impacts of the waste generated at ECF are understated and the facts, as presented, could be
misleading.
RESPONSE
Section 5.2.15 of Appendix D, Part A of Vol. 1 of the EIS states that the amount of Low-Level Waste
generated each year at ECF is approximately 425 cubic meters.  The primary constituent of this Low-Level
waste is the material removed from the ends of Naval spent nuclear fuel modules at ECF to permit access
for visual examination of the spent fuel internal surfaces.  These ends of the fuel modules are structural
material which provide support and direct the flow of cooling water during operation.  This structural
material is removed by cutting through portions of the fuel modules which contain no fuel and the cutting
process does not expose nuclear fuel, leaving it completely encased in zirconium.
The structural material removed from the modules does not contain any fuel or fission products from fuel
and therefore is not "spent nuclear fuel".  It does not contain transuranic elements or fission products and
thus is not High Level Waste or Transuranic Waste.  The amounts of radioactivity in the material removed
from the ends of the Naval spent nuclear fuel modules allow them to be classified as Low-Level Waste. 
Their disposal at the Radioactive Waste Management Complex at INEL is accomplished in accordance
with all applicable regulations.  The radioactive isotopes which represent 99% of the activity in the end
boxes removed from fuel modules are identified in the following table:
              ISOTOPES CONTAINED IN CORE STRUCTURALS
             ISOTOPE        HALF LIFE      PRIMARY MODE OF               DECAY
             Fe55           2.73 years     Electron Capture (x-ray)
             Co60           5.271 years    Beta & Gamma
             Ni59           76000 years    Electron Capture
             Ni63           100 years      Beta
A description of the composition of the material removed from the ends of Naval spent nuclear fuel
modules during examination has been added to Volume 1, Appendix D of the EIS.
The analyses performed in the EIS include all phases of spent nuclear fuel management at INEL, including
generation, handling , and disposal or storage of Low-Level Waste.  The conclusion from these analyses is
that the normal operations associated with the management of spent nuclear fuel at INEL result in only
very small exposures to humans and the environment.  Consequently, the radioactivity associated with
Low-Level Waste is managed and disposed of under stringent controls so that the environmental impacts
are very small.

II COMMENT

According to the commentor, this EIS fails to include information on all radioactive waste streams from the
Expended Core Facility at INEL using Nuclear Regulatory Commission classifications.
RESPONSE
This EIS does characterize all radioactive waste streams from Naval spent nuclear fuel management at the
Expended Core Facility.  Volume 1, Appendix D, section 5.2.15 of the EIS provides a description of all of
the waste streams from the Expended Core Facility at INEL.  Appendix D, section 5.2.15 includes the
volumes of low-level radioactive waste and transuranic wastes produced each year and a statement that
there is no high-level radioactive waste produced at the Expended Core Facility.  This covers the
applicable radioactive waste categories defined by the Nuclear Regulatory Commission.  Section 5.2.15
also describes how all of the waste streams from the Expended Core Facility would be affected by each of
the alternatives considered.
The analyses performed in the EIS include all phases of spent nuclear fuel management at INEL, including
generation, handling, and disposal or storage of low-level waste.  The conclusion from these analyses is
that the normal operations associated with the management of spent nuclear fuel at INEL result in only
very small exposures to humans and the environment.  Consequently, although the radioactivity associated
with low-level waste is managed and disposed of under all applicable regulations and stringent controls so
that the environmental impacts are very small.
A description of the composition of the material removed from the ends of Naval spent nuclear fuel
modules during examination has been added to Volume 1, Appendix D of the EIS in response to a number
of public comments.  This information may help to understand the nature of the low-level waste produced
at the Expended Core Facility and why it classified as low-level waste.

II II COMMENT

The range of dose rates at 1 meter from loaded Naval spent nuclear fuel shipping containers should be
provided in the EIS.
RESPONSE
This EIS states in Section I-4.1 of Appendix I to Volume 1 (page I-45 of the Draft EIS) that "a dose rate of
1 millirem per hour at one meter (3.28 feet) was used for Naval-type SNF shipments, based on measured
dose rate from previous Naval SNF shipments."  The value of 1 millirem per hour at one meter was
obtained from the values measured from navy shipments in the past.  As described in Section A.7.1.1.2 of
Appendix D to Volume 1, the dose rate values used in the calculations for Naval spent nuclear fuel
shipments ranged from 0.1 to 1.8 millirem per hour at one meter.
For fuel types which had been shipped in the past, the values used in the analyses were calculated by
averaging the measured values.  For the fuel types which had not been shipped in the past, the exposure
rates from the applicable Safety Analysis Reports for Packaging were used, with suitable adjustment to
reflect a lower level of uncertainty than is used in such documents.  This lower level of uncertainty is
justified by the extensive measurements of exposure levels from past shipments.  To verify that this
technique reliably produced values which would not be exceeded in practice, it was checked by adjusting
the values used in the Safety Analysis Reports for Packaging for spent fuel types already shipped in the
same manner and comparing them to measurements.  In all cases, the estimated values exceeded the
measured values so this method is conservative.
Department of Transportation regulation for shipment of spent nuclear fuel limit the exposure rate at one
meter from the surface of the shipping container to 10 millirem per hour for any shipment, but, as discussed
above, the exposure rates for Naval spent nuclear fuel shipments are well below this level.

II COMMENT

A commentor did not understand how the consequences of an accident involving shipment of low-level
radioactive waste could be considered to be insignificant.
RESPONSE
This EIS states in Section A.5 of Appendix D to Volume 1 that the consequences of an accident involving
shipment of low-level radioactive waste from shipyards would be insignificant compared to the accidents
analyzed for spent nuclear fuel.  The probability of an accident and the severity (impact velocity, damage,
etc.) of an accident involving radioactive waste would be similar to spent nuclear fuel, but the amount of
radioactive material which might be available for release would be many tens of times less than the already
small amount of fuel available for release from spent nuclear fuel.  Therefore, the consequences would be
insignificant compared to those of spent nuclear fuel.
Sections A.8.3 and A.8.4 of Appendix D provide the risk and maximum consequences of postulated
transportation accidents involving spent nuclear fuel and the risks for all of the alternatives considered are
very small.   The risks associated with a low-level radioactive waste shipment would be even smaller than
these very low risks.

II COMMENT

A commentor expressed concern about the nature of the radionuclides which might be released in an
accident involving Naval spent nuclear fuel.
RESPONSE
Table A-14 in Appendix D to Volume 1 of this EIS provides the list of isotopes and amount of activity for
each isotope which would be released in an accident from an average shipment of Naval spent nuclear fuel. 
The two columns on the left in Table A-14 list the radionuclides and amount of radioactivity which might
be released by the most severe accidents which might cause both radioactive nuclides produced directly
from fission of atoms and radionuclides in corrosion products to be released.  The two columns on the right
list the radionuclides and activities for the less severe accidents which could only cause radioactive
material present in the corrosion on the outside of the fuel elements to be released.
Radioactive material in the very thin film of corrosion formed on the exterior of fuel elements can be
released by the shock of an accident such as a collision.  The materials referred to as "corrosion products"
are not corrosive.  The radionuclides resulting directly from fission of atoms occur only inside the fuel
elements and are completely contained by the cladding of the fuel.  They could only be released if the
forces of the accident are severe enough to break the fuel elements open or to melt.
The radionuclides listed could only be released as a result of an accident during transportation and
therefore they would not increase exponentially with the storage of shipments.  The radionuclides which
might be released during a postulated accident while Naval spent nuclear fuel is in storage at a Navy site
are addressed in detail in Attachment F of Appendix D to Volume 1.

II COMMENT

The term "person-rem" would be more appropriate than "rem" in some locations in Attachment A to
Appendix D of Volume 1.
RESPONSE
The text in the locations identified has been changed to use "person-rem" in all locations referring to
estimated dose to the general population.  A check of the remainder of Attachment A to Appendix D of
Volume 1 has been conducted to assure that the use of this term is consistent throughout.

II COMMENT

More detail concerning the neutron reduction factor used in the Naval spent nuclear fuel shipment
calculations used for the analyses in this EIS should be provided.
RESPONSE
Section A.7.1.1.9 of Appendix D to Volume 1 of this EIS states that a more realistic neutron reduction
factor was used for Naval spent nuclear fuel instead of the factor supplied in the RADTRAN4 computer
program.  This more realistic factor used the same basic equation used in RADTRAN 4 (Section 4.2.2 of
the RADTRAN 4 Technical Manual, Volume II [Neuhauser and Kanipe 1993]).  The basic equation is:
        DRn(r) = K x e-ux x (1 + a1r + a2r2 + a3r3 + a4r4) / r2 
        where:      DRn(r)    = neutron dose rate at distance r
                    r         = distance from source (m)
                    K         = constant
                    u         = linear attenuation coefficient (m-1)
              a1,a2,a3,a4     = dimensionless coefficients
The difference is that a value of 2.0 x 10-10 was used for a4 in lieu of 0.  This was done because it
reproduced the results of measurements of the neutron exposure from Naval spent nuclear fuel shipments
and yielded a higher exposure from each shipment than the standard value.  Attachment A to Appendix D
of Volume 1 has been revised to provide this detail.

II COMMENT

The Navy plans to make a few more shipments of Naval spent nuclear fuel than stated in the Draft EIS.
RESPONSE
The number of planned shipments has not changed from those presented in the Draft EIS.  The number of
shipments of Naval spent nuclear fuel identified in this EIS represent the best available information based
on long-term military force estimates during the next 40 years.
The commentor referred to information provided to him separately by the Naval Nuclear Propulsion
Program that stated that the number of shipments of Naval spent nuclear fuel over the past forty years was
revised to 599 instead of the 584 identified in Appendix D to Volume 1.  This change occurred as a result
of reviews of records of historic shipments, where one shipment sometimes included more than one
container, and updates necessary to reflect all shipments expected to be completed by June 1995.  The EIS
has been revised to reflect 599 shipments of Naval spent nuclear fuel in the years prior to the action
considered in this EIS.  This change results in less than a 1 percent change in the total calculated exposure
to the public and the results in the EIS have been changed accordingly.  However, the change does not
affect any of the comparison or analyses of environmental impacts provided in the EIS.

II COMMENT

The text in Section A.7.1.2.4 and the entries in Table A-13 in Appendix D to Volume 1 may be
inconsistent.
RESPONSE
Section A.7.1.2.4 of Appendix D to Volume 1 provides release fractions to be used in the calculation of
the consequences and risks for postulated transportation accidents involving Naval spent nuclear fuel.  This
section states that "from the modal study, the release fraction in lower left region R(1,1) is zero for the risk
evaluation".  Later it states "For the maximum consequence evaluation, 1% of the corrosion products might
be released for the lower left region, R(1,1)".  Table A-13 provides a summary of the cask release fractions
to be used for risk analyses so the value of 0.0 as described in the text and above is correct.
The document which describes the methodology used in the analyses of postulated accidents for Naval
spent nuclear fuel shipments provides more details on the use of the risk matrix and other information on
the application of the analytical technique.  See U.S. Nuclear Regulatory Commission publication
NUREG/CR-4829, Shipping Container Response to Severe Highway and Railway Accident Conditions,
UCID-20733, prepared by Lawrence Livermore National Laboratory for the Division of Reactor System
Safety and issued by the Office of Nuclear Regulatory Research, Washington, D.C., in 1987 and referenced
in Attachment A to Appendix D.

II COMMENT

The Navy has stated that approximately 580 to 600 shipments of Naval spent nuclear fuel to INEL would
be required under the alternatives which would continue inspection of Naval spent nuclear fuel at the
existing Expended Core Facility, but section A.7.2 of Attachment A to Appendix D to Volume 1 (page A-57) 
appears to indicate that 728 shipments would be required.
RESPONSE
There is no contradiction between the number of shipments used by the Navy in the EIS or in public
meetings or reviews.
Under the alternatives which would continue inspection of Naval spent nuclear fuel at the existing
Expended Core Facility, approximately 600 container shipments would be needed over the forty year
period to move the Naval spent nuclear fuel from shipyards and Navy prototype reactors to the Expended
Core Facility at INEL.  These shipments would travel by the commercial rail system (with the exception of
a few ocean shipments from Pearl Harbor Naval Shipyard to Mainland, whereupon rail transport would be
used, and a few miles traveled overland by a limited number of shipments of prototype spent nuclear fuel
to reach a railhead).  Section A.7.1 provides a discussion of the detailed basis for this number of shipments.
Section A.7.2 provides information concerning the transfer, within the boundaries of the INEL site, of
Naval spent nuclear fuel from the Expended Core Facility to the DOE storage facility at INEL.  These short
transfers (less than 5 miles, one way) would use roads not accessible to the general public.  These
shipments were included in the EIS to provide a complete evaluation of the possible impacts from all
aspects of movement of Naval spent nuclear fuel.  It is planned that all alternatives which would relocate
the examination of Naval spent nuclear fuel to other DOE sites would also involve similar transfers
conducted entirely within the boundaries of the new site.

II COMMENT

The EIS states that Norfolk Naval Shipyard is about 10 miles from Newport News Shipbuilding, but the
rail distance between the two facilities is 250 miles. A commentor questioned whether this information is
correct.
RESPONSE
The information on the rail distance between Newport News and Norfolk is correct.  Norfolk Naval
Shipyard and Newport News Shipbuilding and Drydock Company are on opposite sides of the James River,
about ten miles apart, but the two locations have no direct rail connection. Rail traffic from Newport News
must be routed through Richmond, Virginia, Petersburg, Virginia, and a portion of North Carolina in order
to reach Norfolk. The total distance traveled by a Naval spent nuclear fuel shipment would be 251 miles
and this value was used in the analyses performed for this EIS.

II COMMENT

The railroad tracks may not be in good condition to carry spent nuclear fuel.
RESPONSE
The requirements for railroad track inspections and the standards for track condition and safety are
established by the Federal Railroad Administration, a part of the Department of Transportation, and are set
forth in federal regulations (49 CFR 213).  In advance of each shipment of Naval spent nuclear fuel, the
Navy provides railroad companies who will move the Naval spent nuclear fuel with the number of railcars
and the weight of each railcar.  The railroad companies ensure that locomotives, tracks, and bridges are
capable of accommodating the shipment and completing it safely.
Naval spent nuclear fuel has been shipped from the various Navy sites by rail for 38 years without any
release of radioactive material.  Nevertheless, as described in Section A.4.1.4 of Appendix D to Volume 1
of this EIS, each shipment of Naval spent nuclear fuel is accompanied by escorts who remain in contact
with headquarters.  In the event of an emergency, state and federal resources would be quickly summoned
to stabilize the situation.  Moreover, Naval spent nuclear fuel is shipped in large, rugged, certified shipping
containers which are designed to withstand accidents which might occur during shipment.  Section A.4.1 of
Appendix D provides descriptions and photographs of the shipping containers used for Naval spent nuclear
fuel.

II COMMENT

The commentor states that DOE presents no information on the characteristics of the SPAN4 computer
code or the value in selecting it.
RESPONSE
The SPAN4 computer code was developed as an analysis tool specifically suited to the unique
characteristics of Naval SNF, therefore providing conservative yet more realistic values of the transport
index to exposure rate conversion factors presented in Volume 1, Appendix D, Attachment A, Table A-16. 
Volume 1, Appendix D, Attachment F, section F.1.3.6 provides additional discussion on the SPAN 4
computer code.

II II COMMENT

The costs of Naval spent nuclear fuel management could be very high.
RESPONSE
The costs associated with each alternative for the management of Naval spent nuclear fuel are provided in
Appendix D of this EIS in Section 3.7.4 (See Table 3.8) and in Attachment D (See Section D.1.6).  The
costs to the Navy for the alternatives considered range between $1.5 Billion and about $6 Billion for 40
years.

II COMMENT

The costs of Naval spent nuclear fuel management at INEL should include the costs of replacing the
existing Expended Core Facility.
RESPONSE
The Expended Core Facility at INEL is a modern facility which has been continuously upgraded and
expanded during its lifetime.  It meets all the requirements for accomplishment of its mission and for
protection of human safety and the environment.  Engineering evaluation of the facility and its structures
has shown that  it possesses more than adequate strength for earthquakes which might be expected at its
location.  A full engineering evaluation completed in 1994 showed that, even though the initial portions of
the facility were constructed in the 1950's, the entire facility meets the current seismic requirements.  It has
been well-maintained, it is not deteriorating (please see the photographs in Appendix D, Attachment B),
and it has adequate capacity for the foreseeable workload throughout the period covered by this EIS.  No
need to replace the Expended Core Facility is foreseen for the period covered by this EIS, so the costs of
replacement have not been included.

II COMMENT

The Barnwell Nuclear Fuel Plant adjacent to the Savannah River Site could be modified to manage Naval
spent nuclear fuel as an alternative to the Expended Core Facility at INEL.
RESPONSE
It is correct that management of Naval spent nuclear fuel at the Barnwell Nuclear Fuel Plant appears to be
possible without large impacts on the environment.  The use of the Barnwell Nuclear Fuel Plant to provide
capabilities for Naval spent nuclear fuel management similar to those at the Expended Core Facility at
INEL is discussed in Chapter 3 of Appendix D to Volume 1.  This discussion includes the impacts
associated with the use of this facility for management of Naval spent nuclear fuel (Section 3.7.4).  The
Barnwell Nuclear Fuel Plant is included in Chapter 4, Affected Environment (Section 4.3), Chapter 5,
Environmental Consequences (Section 5.3).  The results of analyses of normal operations and accidents
the at facility are included with the results for the Savannah River Site in Attachment F (Sections F.1.4.1
and F.1.4.2) and are presented explicitly where they differ appreciably from the results for a Naval spent
nuclear fuel examination facility located on the Savannah River Site proper.
A brief description of the modifications needed to duplicate capabilities provided by the Expended Core
Facility at INEL is presented in Section E.2 of Appendix D to Volume 1.  This description was intended to
be sufficient for the purposes of evaluating environmental impacts for this EIS, but additional detailed
engineering work would be needed to determine the proper course of action if an alternative involving
relocation of Naval spent nuclear fuel management to the Savannah River Site were to be selected.  The
costs associated with use of this facility for Naval spent nuclear fuel management are included in the
discussion in Section 3.7.4 of Appendix D, with the conclusion that, while close to $800 million would be
needed to modify the facility, additional funds would be needed to buy it from the current owners.

II COMMENT

The costs for the ultimate disposition of Naval spent nuclear fuel should be included in the federal budget.
RESPONSE
Since the final method for ultimate disposition of Naval spent nuclear fuel or any of the other nuclear fuel
under DOE cognizance has not been selected, the costs have not been included in the federal budget
process.  The costs associated with the method finally selected for the ultimate disposition of Naval spent
nuclear fuel will be incorporated into the federal budget at the appropriate time in accordance with
established federal budgeting procedures.

II COMMENT

It is doubtful that the Expended Core Facility can be operated economically until the end of the period
covered by this EIS, when it would be nearly 80 years old.
RESPONSE
The Expended Core Facility at INEL has been upgraded many times since its original construction, as
needed to provide the capabilities and capacity required by the Naval Nuclear Propulsion Program and to
ensure the safety of the people who work there, the people of Idaho, and the environment.  As a result, the
current facility is safe and capable of fulfilling the Navy's mission.  It meets or exceeds current standards for
seismic events and radiological protection, even for those portions built in the 1950's.
The costs of operating and maintaining the Expended Core facility throughout the period of this EIS are
provided in Section 3.7 of Appendix D to Volume 1.  These costs include future improvements to the
facility, based on the assumption that it would need maintenance and modifications on about the same
schedule as in the past.  There is no reason to arbitrarily retire the facility simply because some number of
years have elapsed since its construction.

II COMMENT

The costs for normal operations and cleanup after accidents at the Pearl Harbor Naval Shipyard would be
higher than on the Mainland.
RESPONSE
The costs of constructing and operating a Naval spent nuclear fuel storage area for three types of storage at
Navy sites are presented in detail in Attachment D to Appendix D of Volume 1 and summarized in Section
3.7 of Appendix D to Volume 1 and the details are provided in other parts of Appendix D.  These cost
estimates show that management of Naval spent nuclear fuel at Navy sites would be higher for some
operations and lower for others.  The important point is that it would not be possible to provide
examination of all Naval spent nuclear fuel using only Navy sites.  The  principal associated with
differences in costs is related to the differences between the Navy sites and DOE sites.
The analyses in Volume 1, Appendix D, Section F.1.3.8, for postulated accidents involving Naval spent
nuclear fuel storage at Navy sites show that for the worst case potential accident an area of only about 110
acres could be contaminated to the point where radiation doses exceeding the Nuclear Regulatory
Commission public limit of 100 millirem per year might result for a person living full time on that land for
an entire year.  Most of this area would be within shipyard boundaries.  Consequently, the area which
might be considered for possible cleanup in the most severe case would be very small and localized and,
therefore, the cost of cleanup would not be appreciably different at any of the Navy sites considered.  It 
should be noted that this is the most severe accident;  reasonably foreseeable accidents would involve far
less area.
Although Naval sites are included in the analysis, the Navy has identified a preferred alternative in Section
3.9 of Appendix D to Volume 1 which would not store Naval spent nuclear fuel at Naval sites.  The Navy's
preferred alternative would resume the historic, technically sound and safe practice of conducting refueling
and defueling of nuclear-powered warships and prototypes as planned, transporting the Naval spent
nuclear fuel to the Expended Core Facility at INEL for full inspection and examination, and transferring
Naval spent nuclear fuel to DOE for storage at that site.

II COMMENT

The costs for dry storage of Naval spent nuclear fuel in immobile casks at Navy sites would be cheaper than
storage at INEL if the Multi-Purpose Containers being developed by DOE were used.
RESPONSE
As acknowledged by the commentor, Naval spent nuclear fuel can be safely and securely managed at all of
the sites considered in this EIS.  The costs of constructing and operating a Naval spent nuclear fuel storage
area for three types of storage at Navy sites, as well as costs for other alternatives for management of Naval
spent nuclear fuel, are presented in detail in Attachment D to Appendix D of Volume 1 and summarized in
Section 3.7 of Appendix D.  The costs for dry storage in immobile casks were developed using information
from currently available dry storage casks licensed by the Nuclear Regulatory Commission for use with the
spent nuclear fuel from commercial reactors.  Allowances were included for some additional costs for
designing new inserts to hold and cool Naval spent nuclear fuel, which would differ from the inserts used
for commercial spent nuclear fuel, and for installation of additional radiation shielding required for storage
within the confines of a shipyard.  All other costs associated with such storage, such as operating costs,
phase-in and facility closure costs, construction of concrete pads, and procurement of equipment needed to
load and unload the containers were included.
DOE is currently developing Multi-Purpose Containers which could be used for storage, transportation,
and disposal.  DOE placed a contract for design of the first Multi-Purpose Containers in March of this year
and plans to place the contract for manufacture of the first ones in the middle of 1997.  This means that the
first Multi-Purpose Container would be available in early 1998 and, even then, the early containers would
not be destined for Naval spent nuclear fuel.  The licensing of these containers by the Nuclear Regulatory
Commission for use in storage of spent nuclear fuel and issue of the Certificate of Compliance for use in
shipping are planned to be completed in 1997.  The dry storage casks used to develop the costs reported in
Appendix D are currently licensed and in use, making their costs reasonably well-known.
It is possible that the Multi-Purpose Containers could be used for Naval spent nuclear fuel at some time in
the future, but they would not be available inn time to support a change in the method of managing Naval
spent nuclear fuel.  These containers are estimated at this early stage of development to cost about
$350,000 to $430,000 for the 125-ton containers which would be needed for Naval spent nuclear fuel, but
some uncertainty in this estimate exists since the containers have not yet been designed or built.  Section
D.1.3.1 of Appendix D to Volume 1 states that about 290 containers would be needed, depending on the
loading of the containers.  A special insert for Naval spent nuclear fuel would have to be designed for the
Multi-Purpose Containers.  Design and separate licensing for this insert would be required.  In the end, the
costs of using the Multi-Purpose Containers for storage of Naval spent nuclear fuel would be substantially
greater than stated in the comment.
When the costs of concrete overpacks required for the Multi-Purpose Containers, any buildings required
for this method of storage, and the equipment to load and unload them are included, it is possible, given
the uncertainties in costs at this point in their development, that the costs for Multi-Purpose Containers
might not be less than those for immobile dry storage provided in the EIS.  If in the future, the costs for
Multi-Purpose Containers for immobile dry storage were found to be less than those for other methods,
they might well be adopted, but the total costs associated with the Multi-Purpose Containers, including
design and licensing, and their availability would have to be considered.
It should be remembered that the primary reason the Navy prefers not to store Naval spent nuclear fuel at
Navy sites is that full examination of all Naval spent nuclear fuel would not be possible.  The principal
reason that the Navy prefers an alternative which would resume the historic, technically sound and safe
practice of transporting Naval spent nuclear fuel to the Expended Core Facility at INEL for full inspection
and examination and transferring Naval spent nuclear fuel to DOE for storage at that site is that this would
allow the continued examination of all Naval spent nuclear fuel at the lowest cost and smallest risk, as
stated in this EIS.  Examination of all Naval spent nuclear fuel is an important part of the safety program of
the Naval Nuclear Propulsion Program which has allowed the nuclear Navy to steam more than
100,000,000 miles and accumulate over 4400 reactor years of operation without a reactor accident or any
problem having a significant effect on the environment.  Examination of Naval spent nuclear fuel has also
provided an important contribution to increasing the lifetime of Navy reactor cores by a factor of more 
than 10, reducing the amount of Naval spent nuclear fuel which must be managed.

II COMMENT

The commentor indicates that the Navy downplays the benefits of reduced costs and radiological effects
from decreased transportation, and the costs of necessary facility enhancements at INEL by dismissing
storage of its spent nuclear fuel at the point of origin due to cost.  The Navy has also failed to substantiate
the need to examine all of its spent nuclear fuel.  It was stated that the Navy is required to provide any
cost-benefit analysis that they may have prepared to justify their preference for the cheaper alternative of
keeping activities at INEL.
RESPONSE
Appendix D to Volume 1 of the EIS evaluates the environmental impacts of a reasonable range of
alternatives for the management of Naval spent nuclear fuel, including the No-Action alternative.  As the
environmental impacts would be small, there are no clear environmental discriminators between
alternatives.  The Navy's preferred alternative is justified on the basis of Navy programmatic needs such as
full examination of spent nuclear fuel, as well as the relative costs between alternatives [see response to
comment 8.5.11.(1)].  The relative cost of transportation is low compared to the costs of on-site
management of spent nuclear fuel, as discussed in section 3.3 of Volume 1 (see response to comment
6.7.(1)).  The discussion of the Navy's preferred alternative does not dismiss any of the other alternatives
evaluated in the EIS.  
Section 2.4.1 of Appendix D to Volume 1 of the EIS has been expanded to more fully discuss the need for
full inspection of Naval spent nuclear fuel.  See also response to comment 8.3.3.(2) in regards to the need
for full examination of spent nuclear fuel. 
Regarding a cost-benefit analysis, the commentor has specifically cited to 40 CFR 81502.23 in suggesting
that a cost-benefit analysis be prepared.  A cost-benefit analysis is not generally required by Council on
Environmental Quality requirements, but may be used "as an aid in evaluating environmental
consequences".  Because all evaluated environmental consequences are small and because of the difficulty
of developing generally accepted equivalency factors between different types of impacts, e.g., what
monetary value should be place upon the loss of 35 acres of sagebrush habitat?  DOE and the Navy have
not developed a cost-benefit analysis.  The range of estimated costs for implementing various alternatives is
summarized in Volume 1, section 3.3.6.

II 8.6 Miscellaneous

II COMMENT

Some persons felt that the term "spent nuclear fuel" is misleading because they believe that it means fuel
which has no power to destroy or no power to do work.
RESPONSE
The term "spent nuclear fuel" is used in legislation, such as the Nuclear Waste Policy Act of 1982, as
amended (42 USC 10101), and in regulations governing nuclear material and work (for example, 40 CFR
191, "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel,
High-Level Waste, and Transuranic Waste", and 10 CFR 53, "Criteria and Procedures for Determining
Adequacy of Available Spent Nuclear Fuel Storage Capacity") to define a specific category of nuclear
material and specify the manner in which it must be controlled.  All three of these examples use the same
definition (for example, see 42 USC 10101 (23)) of spent nuclear fuel as "fuel that has been withdrawn
from a nuclear reactor following irradiation, the constituent elements of which have not been separated by
reprocessing".  This category is used to denote fuel which has been used in a reactor and is no longer
usable for its original purpose.
This terminology is not intended to convey the impression that such fuel is no longer radioactive or no
longer requires careful management.  Because of its use as fuel in a reactor, spent nuclear fuel remains
highly radioactive.  DOE, the Navy, the Nuclear Regulatory Commission, and other organizations have
devoted much effort to the proper handling of spent nuclear fuel and protecting human beings and the
environment from the effects by ensuring that it is properly managed.

II COMMENT

Some persons felt that the term "spent nuclear fuel" is misleading because they believe that spent nuclear
fuel should be classified as waste.
RESPONSE
The term "spent nuclear fuel" is used in legislation, such as the Nuclear Waste Policy Act of 1982, as
amended (42 USC 10101), and in regulations governing nuclear material and work (for example, 40 CFR
191, "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel,
High-Level Waste, and Transuranic Waste", and 10 CFR 53, "Criteria and Procedures for Determining
Adequacy of Available Spent Nuclear Fuel Storage Capacity") to define a specific category of nuclear
material and specify the manner in which it must be controlled.  All three of these examples use the same
definition (for example, see 42 USC 10101 (23)) of spent nuclear fuel as "fuel that has been withdrawn
from a nuclear reactor following irradiation, the constituent elements of which have not been separated by
reprocessing".  This category is used to denote material which must be handled in accordance with specific
procedures and requirements.
This terminology is not intended to mislead or confuse.  On the contrary, the category "spent nuclear fuel"
should help understanding since it conforms to the terminology commonly used in public forums and
technical and regulatory circles to clearly denote the special characteristics, controls, and handling
associated with this particular class of material and how spent nuclear fuel differs from other types of
radioactive material.

II COMMENT

It appears that there is a plan for the same site at Puget Sound Naval Shipyard to be used for a proposed
Naval spent nuclear fuel storage facility and for another proposed Navy facility.
RESPONSE
This comment is an erroneous conclusion drawn from a map in the EIS.  The map on page D-12 of Volume
1 Appendix D shows the conceptual location of the interim storage site at Puget Sound Naval shipyard. 
The designated area in this figure approximates the general location where the interim storage facility
would be located.  The other facility referred to by the commentor is Puget Sound Naval Shipyard's
proposed mixed waste storage building.  The spent nuclear fuel storage location would not be sited in the
exact same location.  However, it is possible that they would be located in close proximity to each other.

II COMMENT

Some persons have confused the Navy's Environmental Assessment on the Short-Term Storage of Naval
Spent Fuel with this Environmental Impact Statement, which deals with the management of Naval and
other DOE spent nuclear fuel until a method for ultimate disposition can be implemented.
RESPONSE
Two NEPA documents considering aspects of Naval spent nuclear fuel management exist: one is this EIS
and the other is the Navy's Environmental Assessment on the Short-Term Storage of Naval Spent Fuel.
A 1993 ruling by the Federal District Court for Idaho limited the number of shipments of Naval spent
nuclear fuel which could be sent to INEL for examination until this EIS is completed and a Record of
Decision on the storage of DOE spent nuclear fuel is issued in June 1995.  This meant that safe storage of
some Naval spent nuclear fuel had to be accomplished by means other than shipment to INEL during the
period from the time of the court's order until the Record of Decision is issued.  Therefore, in accordance
with the requirements of NEPA, and as ordered by the Idaho court, an Environmental Assessment was
prepared to evaluate the alternatives for accomplishing safe storage during the brief period and to identify
and assess the impacts associated with each alternative considered.  This document is the Navy's
Environmental Assessment on the Short- Term Storage of Naval Spent Fuel.
An Environmental Assessment was prepared because the impacts of the preferred alternative for this short
period of storage were found to be small, as documented in the Finding of No Significant Impact issued
early in 1994 after a period of public review.  The alternatives considered in the Environmental Assessment
were necessarily limited to those which could be implemented immediately and would be used only
through June 1995.  The Environmental Assessment chose a No Action alternative which used storage in
certified shipping containers at the sites which would continue to perform servicing of Naval reactors
through June 1995 as the best means of safely managing Naval spent nuclear fuel during the time needed
for completion of this EIS.  The evaluation included Newport News Shipbuilding and the facility used at
that location for servicing nuclear-powered aircraft carriers.
This Environmental Impact Statement considers alternatives for managing all DOE spent nuclear fuel,
including Naval spent nuclear fuel, until a method for ultimate disposition can be implemented.  It covers a
period which begins after its completion and the issue of the associated Record of Decision in June 1995. 
The period considered extends 40 years from June 1995 because of the time needed to select and
implement a method for final disposition of the spent nuclear fuel.  This EIS considers a wider range of
alternatives than the Navy's Environmental Assessment because more time would be available to construct
new facilities or implement other long-term actions and because more types of spent nuclear fuel needed to
be considered.
The conclusions concerning the preferred alternative in its Environmental Assessment and this EIS
naturally differ because of the different periods of time available for beginning to use the alternatives for
management of Naval spent nuclear fuel, the amounts of spent nuclear fuel, the long-term effect on the
Navy's mission, and the effects on the environment considered in the two documents.  In both cases, 
management of Naval spent nuclear fuel can be accomplished safely and with very small environmental
impacts.
Some of the differences which result from the different time periods considered in the two documents have
been noted by commentors.  For example, the longer period covered in this EIS required the Navy to rule
out storage at Newport News Shipbuilding and Drydock Company because it is a private facility might have
to be purchased by the Federal government and currently plays an important role in the Navy's
infrastructure.  For the same reason, management of Naval spent nuclear fuel in water pools at Navy sites is
evaluated in this EIS but was not in the Environmental Assessment because there was not enough time to
construct or modify (as in the case of the water pool at Puget Sound Naval Shipyard) the facilities.  
Similarly, no modifications to the certified shipping containers were needed for storage during the interim
period ending in June 1995, but if an alternative involving management of Naval spent nuclear fuel in
shipping containers were to be selected for the longer period covered by the EIS, construction or
modification of facilities at Navy sites would have to be completed.  Finally, examination of Naval spent
nuclear fuel can continue until June 1995 due to an existing backlog of fuel so the impact on the Navy's
mission was not a determining factor in the Environmental Assessment.

II COMMENT

Some persons identified differences between the results of analyses presented in the Navy's Environmental
Assessment on the Short-Term Storage of Naval Spent Fuel  and the results of the analyses reported in this
Environmental Impact Statement, which deals with the management of Naval and other DOE spent nuclear
fuel until a method for ultimate disposition can be implemented.
RESPONSE
Two NEPA documents evaluating the environmental impacts of alternatives for managing Naval spent
nuclear fuel exist: one is this EIS and the other is the Navy's Environmental Assessment on the Short-Term
Storage of Naval Spent Fuel.  As identified by the commentor, there are some differences in the results of
the analyses performed for these separate documents.  This occurs because the Environmental Assessment
covers the period from the end of 1993 to June 1, 1995 and this EIS covers the period beginning June 1,
1995 and extending up to 40 years into the future.  As a result, substantially less Naval spent nuclear fuel
is considered in the Environmental Assessment than in this EIS and the cores from newer, larger nuclear-powered warships are not included in the Environmental Assessment since they will not be removed from
ships until well after June 1, 1995.
For example, as cited by the commentor, the probability that an airplane might crash into a shipping
container stored at Pearl Harbor Naval Shipyard is smaller for the Environmental Assessment than for this
EIS because there are fewer containers (6 by June 1, 1995, versus 42 by the year 2035).  The smaller
number of containers and the smaller area covered by the containers would reduce the  chances that an
airplane could strike a container.  The dependence of the probability on the effective area of the target is
described in Section F.3.2 of Attachment F to Appendix D to Volume 1 of the EIS.
Similarly, as pointed out by the commentor, the calculations of fatalities if an airplane were to strike a
container produce fewer potential deaths in the Environmental Assessment than in this EIS.  This is
because the amounts of radioactivity involved in the hypothetical accidents in the Environmental
Assessment were based on storage of smaller cores from earlier generation submarines which would be
removed from ships prior to June 1, 1995.  The similar calculations in this EIS are based on the largest
cores which might be stored at each location during the next 40 years.

II COMMENT

Information on the quantities and types of Naval spent nuclear fuel stored at the Expended Core Facility
should be included in this EIS.
RESPONSE
Naval spent nuclear fuel is not stored at the Expended Core Facility.  As described in Section B.2.4, some
components from the first Naval spent nuclear fuel modules, or from modules which show the most
pronounced effects of use, for designs currently in the fleet are retained in the water pools at the Expended
Core Facility for assisting in diagnosis of any problem which may occur.  However, as the various fuel
design types are replaced in fleet service, the fuel components related to the fuel design being retired are
removed from the library and transferred to ICPP.  Although these components do not constitute a large
amount of spent nuclear fuel, they are included in the analyses in this EIS.

II COMMENT

A commentor concluded that data reported in the EIS as being used in analyses were the results of the
analyses.
RESPONSE
The commentor misinterpreted information provided in the EIS, concluding that data used in analyses were
results of the analyses.   The commentor apparently thought the number of residents per square mile in
rural, suburban, and urban localities was the number of potential fatalities which might result from an
accident involving shipment of Naval spent nuclear fuel.  The number of residents per square mile in rural,
suburban, and urban localities was used to calculate the number of people living along transportation
routes.  This misinterpretation caused the commentor to conclude that the risks associated with
transportation of Naval spent nuclear fuel would be much higher than they actually are.
Section A.7 provides detailed descriptions of the input values used in the analyses of the shipment of Naval
spent nuclear fuel in order to allow independent individuals or groups to evaluate or even perform their
own calculations.  Section A.7.1.2.9 shows the number of people per square mile for urban, suburban, and
rural areas along transportation routes.  These are the numbers cited by the commentor.
The results of the analyses of risks for Naval spent nuclear fuel shipments show that less than one fatality
would be caused by transportation accidents or routine operations under any of the alternatives considered
in this EIS.  These results are tabulated in Section A.8.

II COMMENT

The commentor thought that the Navy stated in Volume I, Appendix D, Section 4.1.1.7.3, page 4.1.1-12,
of the Draft EIS that there are no radioactive airborne emissions from operations at Puget Sound Naval
Shipyard and questioned the accuracy of such a statement.
RESPONSE
The commentor misinterpreted the information presented in Volume I, Appendix D, Section 4.1.1.7.3,
page 4.1.1-12 concerning radioactive airborne emissions at Puget Sound Naval Shipyard.  The commentor
missed a key word in the first sentence in Section 4.1.1.7.3 which states that "Radiological facilities at all
Naval shipyards are designed to ensure that there are no uncontrolled discharges of radioactivity in
airborne exhausts."  This section and Section F.1.4.1 in Attachment F present the results of analyses based
the radioactive releases published in Naval Nuclear Propulsion Program Report NT-93-1, which is
available to the public.  The specific airborne releases used in the analyses for Puget Sound Naval Shipyard
are listed in Tables F.1.4.1.1-1 and F.1.4.1.1-2 on pages F-50 and F-52 of Attachment F.
As stated in Section 4.1.1.7.3, the results of the analyses show that emissions of radionuclides from each
shipyard result in an effective dose equivalent of less than 0.1 millirem per year to any member of the
general public, which is 1% of the Clean Air Act standard promulgated by the Environmental Protection
Agency in 40 CFR 61, Subparts H and I.  The analyses demonstrate that the risks associated with any of
the alternatives for management of Naval spent nuclear fuel are very small.

II COMMENT

A commentor stated that impact analyses for long term storage of spent nuclear fuel at the Expended Core
Facility were not present in the EIS.
RESPONSE
Long-term storage of spent nuclear fuel at the Expended Core Facility is not an alternative considered in
this EIS.  Some alternatives result in the Expended Core Facility being shut down and others result in the
Expended Core Facility continuing spent nuclear fuel examinations.  There are no alternatives which use
the Expended Core Facility as a storage facility.  In all alternatives, Naval spent nuclear fuel would be
shipped to either the Idaho Chemical Processing Plant at INEL or some other site after examination is
completed.  The sole exception is the small amount of library storage of Naval reactor components, which
is covered under the impact analyses for fuel examination provided in this EIS.
Storage of spent nuclear fuel in water pools at the Expended Core Facility would effectively preclude
examination of Naval spent nuclear fuel at that facility because storage would use up the space in the water
pool needed for machinery and examination equipment.  This would require the construction of new
facilities for the examination of Naval spent nuclear fuel or the loss of the ability to perform examinations
of Naval spent nuclear fuel.  The impact on the Navy's mission that would result from the loss of the ability
to examine Naval spent nuclear fuel is described in Chapter 3 of this EIS.
Analyses of the impacts associated with storage of the Naval spent nuclear fuel at the DOE sites are
included in the appendices to the EIS for each site.  For example, Section 5 of Volume 1, Appendix B,
includes the impact of storing Naval spent nuclear fuel in water pools at INEL.
Attachment F to Appendix D, Section F.1.4.1.4, does present the results of analyses of the impacts of
performing spent nuclear fuel examination at the Expended Core Facility.  In addition, the impacts of spent
fuel examination at all of the DOE sites and Puget Sound Naval Shipyard and the impacts of water pool
storage at the Naval shipyard sites are presented.  Results of analyses of the impacts for dry storage at all of
the Navy sites considered in this EIS are also provided.  These results are shown in Section F.1.4.1.5 of
Attachment F.   For INEL analysis, a site near the Expended Core Facility at the Naval Reactors Facility
was selected.

II COMMENT

The commentor requested clarification of information in the EIS which presents the impact of facility
accidents on close-in workers.
RESPONSE
The results of an evaluation of the impact to close-in workers involved in Naval spent nuclear fuel
management that might occur due to the various radiological accidents postulated in spent nuclear fuel
handling and storage are presented in Section F.1.4.3 of Appendix D to Volume of this EIS.  Section
F.1.4.3.2.2 provides information on the effects of a hypothetical airplane crash into the dry storage area. 
The commentor asked whether the statements in this section are intended to apply to people involved in
extinguishing the fire associated with the postulated crash.
As stated in Section F.1.4.3, the evaluation in this section includes workers at the spent nuclear fuel
management site working with the fuel or working very close to the scene of postulated accidents.  This is
contrasted with the worker located 100 meters from the radioactive material release point, defined in
Section F.1.3.2, for which exposures have been calculated and presented throughout Appendix D for
normal operations and postulated facility accidents.  Discussions of emergency preparedness training and
exercises and the bases for calculating individual exposure times are presented in Section F.1.3.9.

II COMMENT

A commentor thought that the water pool at Puget Sound Naval Shipyard was identified in Volume 1 of
this EIS as not in use but the commentor had heard that it was in use.
RESPONSE
Section 1.1.2.4 of Volume 1 of this EIS (page 1-11 of the Draft EIS) states that an existing water pool
facility, constructed to support the refueling of nuclear-powered aircraft carriers, is located within the
industrial zone of the Puget Sound Naval Shipyard.  This section further states that, to date, the facility 
has been used for refueling equipment demonstrations and testing.  The facility has not been used for
aircraft carrier servicing work.

II COMMENT

A commentor identified what appeared to be an inconsistency in the peak ground acceleration value
reported for ECF.  A value of 0.35g is quoted on page D-32 of Volume 1, Appendix D, Part B for the
Water Pit Facility and a value of 0.24g is quoted on page F-73 of Appendix D.
RESPONSE
There is no inconsistency in the peak ground acceleration data provided in Appendix D to Volume 1.  The
0.35g peak ground acceleration value provided on page D-32 refers to the Puget Sound Water Pit Facility
at Puget Sound Naval Ship yard.  The 0.24g peak ground acceleration quoted on page F-73 refers to the
Expended Core Facility at INEL.

II COMMENT

A commentor requested that the EIS identify whether other modes of transportation besides rail have been
used to ship Naval spent nuclear fuel to INEL.
RESPONSE
The EIS presents detailed descriptions of past and future shipments of Naval spent nuclear fuel in
Attachment A to Appendix D of Volume 1.  Section A.2 of Appendix D provides the desired information
on shipment of Naval spent nuclear fuel.
The only method used to ship Naval spent nuclear fuel to INEL in the past and the only method proposed
for future shipments is by rail.  The only exceptions to this are that Naval spent nuclear fuel from Pearl
Harbor Naval Shipyard is transported by ship from Hawaii to Puget Sound Naval Shipyard where the
shipping containers are transferred to railcars for the journey to INEL and the use of heavy-lift transporters
to move Naval spent nuclear fuel in shipping containers a few miles to the nearest railhead at the
Kesselring and Windsor sites.

II COMMENT

One commentor stated the water pit facility at Puget Sound Naval Shipyard was to be doubled in size.  She
expressed this concern due to the proximity of the water pit facility to the city boundary.
RESPONSE
The statement that the water pit is to be doubled in size is incorrect.  In Volume 1, Appendix D, page D-29, 
the EIS states that "Expansion of the Water Pit Facility to accommodate simultaneous refueling and
examination operations is undesirable due to the proximity of other shipyard facilities."  This is the reason
why Puget Sound would no longer have the capability to refuel nuclear-powered aircraft carriers should
the Decentralization, Limited Examination alternate be chosen.

08.06 (016) Miscellaneous

COMMENT
One commentor stated that the shipment of radioactive waste from the shipyards had not been included in
the EIS.
RESPONSE
Current practices for the management of radioactive waste at each of the shipyards considered in this EIS
are described in Sections 4.1.1.14, 4.1.2.14, 4.1.3.14, and 4.1.4.14 of Appendix D to Volume 1.  The
environmental consequences of waste management associated with each alternative for management of
Naval spent nuclear fuel are described for each shipyard in Sections 5.1.1.15, 5.1.2.15, 5.1.3.15, and
5.1.4.15 of Appendix D to Volume 1.

08.06 (017) Miscellaneous

COMMENT
Environmental Monitoring information from the 1985 EPA survey of Pearl Harbor was misquoted. In
addition, there are limitations in the EPA analysis that should make one cautious about drawing strong
conclusions.
RESPONSE
The misquotation cited on page 4.1.4-14 of Appendix D to Volume 1 has been corrected.  During editing
of the Draft EIS, the word "greatly" was inadvertently substituted for "significantly". 
The conclusions in Section 4.1.4.8.3 of Volume 1, Appendix D pertaining to the EPA analyses are a direct
quotation from page 11 of the EPA report (with the exception of the inadvertent editing change stated
above) titled "Radiological Surveys of the Pearl Harbor Naval Shipyard and Environs" (Callis 1987).  The
only other discussion in the EIS related to this EPA report directly precedes the statement of the EPA
conclusions and states that the purpose of the monitoring performed in the vicinity of Pearl Harbor Naval
Shipyard is "to confirm that the general public is not affected by operations of Pearl Harbor Naval
Shipyard".  This statement of purpose has been revised to directly quote the EPA's purpose statement: "The
purpose of the survey was to determine if operations related to U.S. Navy nuclear warship activities
resulted in releases of radionuclides which could contribute to significant population exposure or
contamination of the environment".   Consequently, the discussion in the EIS is consistent with the EPA
report.

08.06 (018) Miscellaneous

COMMENT
The EIS incorrectly referred to the Environmental Protection Agency regulations in 40 CFR 61, titled
"National Emission Standards for Hazardous Air Pollutants", as Nuclear Regulatory Commission
regulations.
RESPONSE
Appendix D to Volume 1 of this EIS was revised to properly identify that 40 CFR 61 is an EPA regulation
and more specifically refer to Subpart H of the regulation.

08.06 (019) Miscellaneous

COMMENT
The description for the Kesselring Site in Section 4.1.5 of Appendix D to Volume 1 states that the land
surrounding the site is either wooded or is used for farming.  There are also residential areas surrounding
the site.
RESPONSE
Section 4.1.5.2 of Appendix D to Volume 1 states that "most of the land surrounding the Site is wooded or
used for farming" and this characterization is correct.  The site is not surrounded by residences, but there
are many residences in the area.  The characterization was not intended to imply that there were no
residences in the vicinity, so Section 4.1.5.2 of Appendix D to Volume 1 has been revised to add a
statement that some of the land is used for residential purposes. 

08.06 (020) Miscellaneous

COMMENT
A commentor stated that she thought that the disposal of reactor compartments removed from
decommissioned nuclear-powered Naval vessels at the Hanford Site violates some requirement and barge
shipments to Hanford might be hazardous.
RESPONSE
The Naval Nuclear Propulsion Program conducts the shipment and disposal of the reactor compartments
from decommissioned Naval nuclear-powered vessels at the Hanford Site in compliance with all applicable
safety and environmental regulations.  This procedure was evaluated a number of years ago in an earlier
Environmental Impact Statement prior to initiation of any shipments.  That Environmental Impact
Statement demonstrated that the risks and impacts to human health or the environment associated with the
shipment and disposal of these reactor compartments are very small.  
No Naval spent nuclear fuel is shipped by barge up the Columbia River to the Hanford Site.  This issue is
beyond the scope of this EIS.