ML20059L234
| ML20059L234 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 01/24/1994 |
| From: | Linda Williams AFFILIATION NOT ASSIGNED |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9402030318 | |
| Download: ML20059L234 (34) | |
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January 24, 1994 Chief, Enrichment Branch, Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety i
and Safeguards, Mail Stop 4-E-4, a
U.S.
Nuclear Regulatory Commissicn, Washington, DC 20555 Re: DE!S, Homer, LA.,
Docket No. 70-3070 Lear Commission:
- am writing this letter on behalf of my family who owns property directly adjacent to the proposed uranium enrichment plant to-be built in Homer LA.
I have several concerris that I will attempt to br:efly address-.
F;rst, I seriously question the findings of the Conrission l
in its DEIS study. I question whether the commission's staff can prepare a thorough unbiased report in an area that ' extends their regulatory gurisdiction.
Upon reviewing the report, : think it i
is flawed and not thoroughly prepared concerning-the dangers and i
impact on the community and the environment which !-will address in this document.
I would propcse that an unbiased, objective
'I third party prepare a study to ensure all relevant facts are being presented.
! would not want the preservation of-human life to depend on some egetistical sc;entist who disregards human 1;fe in the name of research (ie. the Department of Energy giving innorert o: mentally handicap individuals radiation), some bu-reaacrat trying to preserve his job, or some' politician and his 4
family financial'y prospering off the lives of innocent people.
Secondly, The DE!S report in the section " ABSTRACTS" page
- , concludes the "the facility can be operated with small 'and acceptable impacts on the public and the environment".
This statement is untrue!
As landowners directly adjacent to the pro-posed plant site, my family has not been notified or contacted for our input on how our property will be impacted by this plant.
Who has the commission's staff contacted to determine that the impact will be small and acceptable on the community?
Surely.not the people who own property and live in the community. As a matter of fact from the charts contained in the DEIS repor t:- it appears that some of this plant will actually be located'on our property.
If this plant is built, it will terminate'the access to our property, it will effect the water table on our' property and the community as a whole.
We, as well as others, will not be
.able to grow gardens, raise farm animals, go hunting and f ching and e v e n t u a '. l y retire op our property.
In other words, to simply enjoy the land that has been in my family for over 75 years.
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The DE!S. report is incomplete because' there Lis. a natural pond thati. joins ob: property with the LeSage-property, what.is-the status of this pond or is it listed as LAKE AVALYN? If-it is not Lake Avalyn then the drawings are omitting a large body of water.(Fig.
2.1.
and in the site development.2 2.1).
If-iti ls Lake Avalyn, then it is located on our property'and we have.not_
1 given anyone the right to use that pond'. 'If the_ body.of water on.
the LeSage. property is polluted with waste-from the plant,-won't
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it naturally contaminate our property?.The answer is1YES it.will because all of the bodies of water have streams that run.from them and connect all of the properties in the1 Forest Grove 3
Community.
The water tables are connected the.same' manner in which the oil and gas reserves are in the community. If'any.
A' contamination gets into the oil and gas l reserves or the water tables, all of the properties in the area between.the. Lisbon and.
1 Summerfield Highways will be polluted. What happens.if the l
streams and water tables find their way into Lake Claiborne, how far will the contamination reach?
Th'e DEIS report'does not mention or show all the streams that are feed-from this pond.in figures 4.1, 4.2 and 5.3.
As an example of.possible pollution from Uranian production and waste, I have attach excerpts' as y
Exhibit A.
from the Department of Energy Environment Waste' Man-agement clean-up projects.
The plants listed are uranium, inL nature and a!! have contamination problems the' likes of which the.
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DE S report neglects to mention and fully disclose and discuss.
t Eow will the people who live on parish Road 39'accessLtheir property?
! would'STRONGLY SUGGEST THAT ANY MAPS CR CHARTS ~THAT-ARE DRAWN include the names of the property owners which will l
give the people in the community a clearer' representation of how j
thei: property will actually be af f ected by this plant.
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parish Road 39 is moved, how will my family get to our property?~
=j These que.ttiens need to be address NOW rather than later!
t Thirdly, ! seriously question the commissions findings ch.
I the need for this plant.(Sect.
1.2.
DEIS report).
THE COLD WAR.
- S CVER AND THE WORLD IS AT PEACE!!
The U. S :. and Russia a r'e l
destroying their nuclear arsenals, wherenis the need1for another.
'l Uranian plant?
This proposed. plant is not listed as'partfof or i
in the DOE Nuclear Weapons Complex Reconfiguration program.
The' j
DOE admits that-a reduction of its nuclear' arsenal is warranted by the ending of the cold war.
It plans on using or reusing its nuclear stockpile to keep whatever nuclear warheads it'needs, to l
1 capacity. (Exhibit B,
- 6450-01p).
t Fourth,. What is going to happen to the people's property that is surrounding the plant, how are they going to be' compen-sated or are they going to he required to live under the~ smoke stacks, breathing the contaminated air like the1 people.in' Russia?
l If-they are going to~be compensated, what is the procedure. and.
i' hcw is fair market value going to be determined?
IfLthey are act' going to be. compensated'ior their land what happens when'there is.
an accident?
There will be some type of contaminationias a result of uranium production. (see Exhibit A).
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Fifth,'The hospitals in Homer, LA will not be able-to handle an; type of nuclear accident in the area.
f the DE S report says that the~ hospitals are sufficient, they are flat out l yi n g..
The hospitals in Ecmer had serious problems handling the last flu epidemic in early 1994., and ended.up having to turn people away Lastly, I have written president Clinton, Attorney Janet Reno and the Evironmental protection Agency asking them to look into the environmenta! impact that this plant would have on this small Black community.
I have attached a copy of the letter and a newspaper article about an area that the Clinton Administra-tion and Congress have expressed concern with environments!
justice. (Exhibit C)
I find it quite interesting that this_and other toxic waste type facilities, seem to always be proposed in
'Elack and poor neighborhoods.
Can you explain this?
- n conclusion, based-on the information presented in this letter,
- ask that you recensider placing this plant in our community and w e d g 'r the long term, negative and unnecessary effects on the env;ronnent and the people of this community.
Thank you for your
.sa.a.e...~.
Sincere:y yours, L
LAR '
A.
4: a L. A.. S, ESC.
32S' S.
.ULARE COURT DENVn CO 80231 (303) 866-5228 (WR)
(303) 752-2477 (HM)
- 02. ~ ; + 2. d e r. ' William Clinten Attc:ne; General Canet Reno C t h: W N.
E;ckey, Chief Enrichment Eranch Susan A. Malbrough
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DOE /S-0078P fpt United States Department of Energy "s,$/
Environmenta. Restoration anc Waste Management Five-Year Plan Fiscal Years 1992-1996 l
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ALBUQUERQUE OPERATIONS OFFICE INSTALIATION
SUMMARY
- URANIUM MILL TAILINGS REMEDIAL ACTION PROJECF In 1978, the Congress passed the Uranium Mill Tailings Radiation Control Act (Public Law 95-604), which directed DOE to provide for stabilization and control of the uranium mill tailings from inactive sites in a safe and environmentally sound manner. The sandlike tailings, located at 24 sites and associated vicinity properties, are the result of uranium production from the early 1950s until the early 1970s.
Compliance with proposed EPA UMTRA standards will require restoration of groundwater at some tailings sites. Activities described include only the UMTRA sites managed by AL Additional UMTRA activities are being conducted by other Operations Offices.
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EXTENT / TYPES OF CONTAMINATION STATUS Remediation was completed at 4 of 24 sites before Twenty.four sites in 10 States (4 of which are on Indian 4
reservations) consisting of one or more piles of tailmgs and FY 1990. "IW of these were completed in 1989. The abandoned mill buildings commitroent of three sites was missed by one site, which Appronmately 5000 vicimty properties, tailings used for was completed in IT 1990.
construction and landscaping before recognition of the "Dirough FY 1989, retsediation lias been coinpleted at potential hazards, and open lands contaminated by more than 3,500 of 5,000 vicinity properties, over 4,000 of windblomt taihngs imm sites which are the responsibihty of ID. Remediation was 30 million cubic yards of taihngs completed at 769 vicinity pmperties in 1989, which is Emanation of audon gas from decay of radium-226, (radon-greater than the commitment of 720 pmperties.
one additional site was completed during the first quarter 222, polonium-218, and 214)
Gamma radiation decay pmducts (lead 214, bamuth 214) of FY 1990, with two more projected to be completed by RCRA-lated huardous constituents in groundwater plus the end of the year. To daic (IT 1990),255 of the molybedum, radium, uranium, scienium, and nitrates scheduled 721 vicinity pmperties have been remediated.
Asbestos and other hazardous and mixed organic wastes at Engmeenng and NEPA documentation are under way on abandoned millsites all remaming sites.
HEALTH RISKS SPECIALCONSIDERATIONS Unstabihard piles will continue to emanate radon gas and Shared State / doe Funding allow dispenal of windblown contammation Site acquaition, engineenng, and remedial action costs are Unremediated vicinity pmp-rties will expose occurants of shared: doe 90 pertrnt and states 10 peteent. doe pays residential and commercial structures to unacceptable levels all crats for the four sites on Indian land. In addition, doe of radon gas.
pays all other project ccets such as project management and Unstabilized tailings piles will continue to contaminate control, NEPA documentation, conceptual design, and S&M.
gmundwater ihmugh inriltration of water.
Groundwater Restorstion Comphance with UMTRA standards promulgated by EPA in 1983 did not require gmundwater restoration. Following a court remand in 1985, EPA proposed revised groundwater standards in 1987. Compliance with these revised standards, not yet finahzed, will require gmundwater characternation at all 24 UMTRA sites and groundwater restoration at some of those sites. Restoration will be performed under a new, separate doe project.
310
OAK RIDGE OPERATIONS OFFICE INSTALIATION
SUMMARY
- FEED MATERIALS PRODUCTION CENTER FMPC near Fernald, Ohio, is a large-scale, fully integrated facility with capabilities for processing uranium compounds into metals, melting and casting uranium metal, and machining uranium shapes to finished dimensions. Cleanup of the 1050-acre site and waste management now constitute the major site activities. Cleanup at the Reactive Metals, Inc., Extrusion Plant in Ashtabula, Ohio, is being performed in conjunction with these activities.
EXTENT / TYPES OF CONTAMINATION STATUS At FMPC, wastes include raffinate slurries containing De commitment to obtain a ROD on OU 6 in FY 1989 uranium and radium; wastewaters and various sohd wastes was rendered not applicable. h was decided that contaminated with uranium and thonum materials, armediation mill be covertd under a removal action. Final pyrophoric, and reactive chemicals; oils contaminated with remediation will be mnducted under OU 5 as negotiated in uranium; and organic solvents. More than 20 release the Consent Agreement.
A sitewide RLTS was initiated in 1986 to formulate, assess, sitcs and an estimated 900.000 cubic yants of waste have and recommend RA altemativa to mitigate identined been identified.
Onsite and offsite surface soil at RMI is contaminated, environmental concerns. His investigation has been and groundwater contains above background segmented into 5 (formerly 6) distince OUs.
concentratkins of uranium. Ficids Brook, which is
- Corrective measures due to inactive facilities involve adjacent to the site, mntains PCBs, chlorinated solvents, RCRA facilitics/ closures, RCRA waste bandling, and the toxic metals, and TCE.
UsT program.
Implementation of cleanup actions at the Fields Brook surerfund site and other RMI facilities has been inntrated.
Cleanup at RMI of offsite surface soil and groundwater is planned.
Cleanup of contamination in buildings and equipment at RMI is under way.
HEALTH RISKS SPECIAL CONSIDERATIONS There is uranium contamination in three offsite pnvate his Plan does not reDeet the Modernization study wells. DOE dug one well as an alternate water supply, propsats for FMPC and Reactive Metais, Inc., D&D.
Radon emissions from silos art a potential health nsk to workers.
he CDC is performing an independent trview of the FMPC histoncal emissions data to assess the accuracy of the reported emasions. It will then pe Torm independent modeling and a d<ne and risk assessment before deciding whether to do an epidemiological study. De CDC review, independent modelmg, and assessment are expected to take 18 months.
An IT Corporation repon on FMPC historical doses and potential health effects is crpected to be released in the near future.
(Contmued) 332
OAK RIDGE OPERATIONS OFFICE INSTALLATION
SUMMARY
- OAK RIDGE GASEOUS DIFFUSION PLANT ORGDP occupies a 1,500-acre site adjacent to the Clinch River approximately 10 miles west of downtown Oak Ridge, Tennessee. The original mission of ORGDP was the production of enriched uranium hexafluoride for defense purposes. Because of a declining demand for enriched uranium, the enrichment process at ORGDP was placed on standby in 1985 and was shut down in 1987. ORGDP now has a multipurpose mission that includes being the location of many contractor central staff functions, operating waste treatment facilities, serving as a center for applied technology, and supporting the development of the Advanced Vapor Laser Isotope Separation uranium enrichment technology, EXTENT / TYPES OF CONTAMINATION STATUS Operation of ORGDP for the past 44 years created he sWMUs at ORGDP have been identified, 23 RTI facilities and sites that contain haurdous materisis and plana have been submitted to EPA and TDHE.
wastes. He sites include burial grounds, pmcess facihties, Gmundwater monitoring is in progress.
storsge facilities, underground tanks, surface Closure of two surface impoundments by sludge removal ine,ui.di.whia, treata.uit fa611ince, pruens lines, and and cement finstion is in progress.
accurnulation areas that have the potential for releasing
- %c TSCA Incinerator is espected to be in full operation in contaminants to the environment. Uranium-contaminated FY 1990 after the State air test in June (the original 1989 liquid and aludge, solid PCBs, and RCRA hazardous commitment date was not met),
S&M activities for the inactive gaseous diNsion facilities wastes will be incinerated onsite.
One hundred ten sWMl's have been identified at and for the former centnfuge facilities are ongoing.
Centrifuge facilities cleanup is in progress.
ORGDP, Offsite surface waters have been contaminated sith radionuclides, metals, and organic compounds.
Planning for D&D of the diffusion facilities has been he gaseous diffusion facilities comprise approximately initiated, the execution of which is estimated to take 140 acres nese facilities contain extensive amounts of 30 years.
asbestos insulation, RCRA cils and chemicals, PCBs, special nuclear materials, and residual radmnuchdes. He gas centrifuge buildings, with 315,000 square feet of floor space, contain contaminated and classified centrifuge equipment and process materials.
HEALTH RISKS SPECIALCONSIDERATIONS Personnel exposure to friable asbestos-bearing materials, Delay or aferral of the TSCA Incinerstor would esuse PCBs, and RCRA-regulated oils and chemicals is a several doe facilities to continue to be in violation of concern in and smund the gaseous diffusion facilities.
Federal and State regulations relating to the disposal of Possible contamination of the Clinch River could affect haurdous materials, and no options for ahernative municipal dnnLing water supply, fishing, and recrestion.
disposinon exist.
He gaseous diffusion facilities are the largest in the Defense facilities D&D program, and they require mustained 5AM to ensure that health and safety requirements are met until decommissionirig con be completed.
336
5 OAK RIDGE OPERATIONS OFFICE INSTALLATION
SUMMARY
- PADUCAII GASEOUS DIFFUSION -
PLANT The principal onsite process at PGDP in Kentucky is the separation of uranium isotopes through gaseous diffusion. The process produces enriched uranium, which is used for nuclear fuel in commercial power plants and for military purposes. The site covers 750 acres (including 74 acres of process buildings). The site is included in a 3,422-acre tract of DOE-owned property.
EXTENT / TYPES OF CONTAMINATION STATUS Ninety-frve sWMUs have been identified as needmg site De Phase I investigation Site Wort Plan for characterization.
charactenzation of the rate and ettent of contaminant oroundwater contamination exists both onsite and offsite.
migration was submitted to EPA and Kentucky and was Sediment and soil contamination exists both onsite and approved by EPA. His met the crimmitment to cotoplete offsste.
this activity in FY 1989.
Characterization work began in May 3989 under the site Major known contaminants are technetium-99, TCE in the groundwater, and PCBs.
work plan required by the Consent order, meeting the commitment to begin field investigation in FY 1989.
TweNe utils and 50 borings are compiete.
l HEALTH RISKS SPECtALCONSIDERATIONS
- All residents whose wells were contaminated have been ER funding is included in the annual NE funding t
placed on public water supplies. Surrounding residential appropriation; however, revenue received for enrichment wells are being monitored.
services to commercial and government customers is used Potential health risks exist if the contaminant plume is not to offset appropriations.
characterized and remediated.
De HSWA Pertnit to be issued with the RCRA Postclosure Permit or the RCRA T/S/D Permit is expected in FY 1990. De HSWA Permit will drive the RFI process for all other SWMUs and spill sites not addressed under the Consent Order.
- Additional manpower requirements were identified during the 1990 baseline review. His manpower is necessary to comply with ACo and HsWA Permit schedules.
340
a OAK RIDGE OPERATIONS OFFICE INSTALIATION
SUMMARY
- PORTSMOUTII GASEOUS 5
DIFFUSION PIANT The principal onsite process at PORTS in Ohio is the separation of uranium isotopes through gaseous diffusion. This process produces enriched uranium, which is used for nuclear fuel in commercial power plants and for military purposes. The site covers -
3,700 acres (including 93 acres for the process buildings) approximately 20 miles north of Portsmouth, Ohio.
EXTENT / TYPES br CONTAMINATION STATUS seventy-three SWMUs have been identified as needing Closure plans for four RCRA units have been approved by site characterization.
regulators.
Known groundwater contamination exists at three units.
A groundwater assessment report for four RCRA units was Contaminanon plumes have been identified and are completed. meeting the W 1989 commitment date.
a presently contained within the site boundary, he commitment to complete closuit of X-616 in W 1989 As the 73 units are characterized, additional soil, surface has been delayed until W 1991 due to consent decree water, sir, and groundwater contammation as expected to considerations and has been combined with three other be confirmed.
units for completion in W 1991.
Major contaminants are technetium-99 TCE, and PCBs.
De commitment to submit the RF1 wort plan for Quadrant I in W 1989 was not snet due to delays in signing the Ohio Consent Decree and the EPA Administrative Consent Order.
A general RFI plan has been approved by Ohio EPA and
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is under review ty EPA Decontamination of abandoned GCEP facihties is planned for W 1991 HEALTH RISKS SPEClAL CONSIDERATIONS If DOE does not act wittun the next 5 years to remediate ER funding is included in the annual NE funding the groundwater contammation, offsite contamination will appropriation; however, revenues received for enrichment probably occur, this conclusion is based on the groundwater services to commercial and government customers are used to travel times at the site, offset appropnations, I
342
4 OAK RIDGE OPERATIONS OFFICE r
INSTALLATION
SUMMARY
- WELDON SPRING SITE REMEDIAL ACTION PROJECT This site, located about 30 miles west of St. Louis, Missouri,' was used by the Army as an ordnance works in the 1940s and 1950s; then, in the late 1950s and 1960s the AEC used Weldon Spring for the processing of uranium and thorium. The site is currently on the EPA NPL, and DOE is conducting a comprehesive RA, including long-term management of radiological waste.
EXTENT / TYPES OF CONTAMINATION STATUS De Weldon Spnng Site includes the followmg:
Radiological and chemical characternation of the site was completed in 198&
- QuarTy - 9 acre site containing 95/00 cubic yards of De 1989 commitment to issue a draft Rl/PS EA for quarry radiologically contaminated sod and rubble and 3/K0JiOO bulk waste removal was rendered no longer applicable due to gal of radiologically or chemically contaminated water incorporation of the EA into the Rl/PS.
Rafnnate Pats 4 waste lagoons,250J00 cubic yards of Environmental Compliance (CERCLA and NEPA):
rafnnate sludges, and $7 milhon gal of radioactrve or (1) Rl/f1Els Work Plan was issued in 1988.
chemically contarninsted water (2) RIM for quarry bulk waste removal was reviewed by
- Plant - 41 buildmgs and other structures and 470/Ko EPA and the State and issued to the public in March 1990.
cubic yards of contaminated soil and buildmg material (3) RI and Baschne Risk Assessment for chemical plant Vicmaty Properties - Approximately 25,000 cubic yards of cleanup and waste disposal have been reviewed by EPA and contaminated soil the State and are nearing completion.
Groundwater - Nitroaromatic and radiological (4) EIUCA for site water treatment piar. was submitted to contaminated groundwater at the quarry and the plant EPA and state in I cbruary 1990.
Several intenm response actions have been completed, and sites others are under way, including asbestos abatement, PCB abatement, buildmgs demohtion, chemicals stabihzatior., and uncontrolled offsite uranium discharges reduction.
HEALTH RISKS SPECIALCONSIDERATIONS Acting on guidance from the oMB, doe and the Army have No immediate health ruks have been identified based on information available to date.
signed an MOU for joint funding of ras for the plant site.
Radiological and chemical contamination has migrated To ensure employee safety, os}{A regulations relating to beyond the quarry site boundary. A county well supply is snedeal surveillance and trainmg for field workers in I
within one-half infle of the quarry site.
hazardous waste operations have teen implemented.
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- Radiological and chemical contamination has migrated beyond the plant site boundary.
1 A large high school is located downwind of the site and I
within onequarter mile of the site boundary.
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AUG
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. Department of Energy e
Washington, DC 20585 July 23, 1993 To Interested Parties:
In February 1991, the Department originally announced its intent to prepare a Programmatic Environmental Impact Statement (PEIS) regarding the reconfiguration of the Nation's nuclear weapons complex.
Since that time, significant reductions in the nuclear weapons stockpile have been made possible by the events leading to the end of the cold war. As a result, the Nation is in the process of reducing the stockpile to just 25 percent of levels which had been planned as recently as five years ago.
The urgency for a replacement tritium supply was eliminated by the stockpile reductions announced in September 1991 and the environmental analysis for selecting a new tritium source was incorporated into the Reconfiguration Programmatic Environmental Impact Statement.
Further reductions in January 1992 and the START 11 Treaty have caused the Department to reevaluate its earlier alternatives for reconfiguration of the nuclear weapons complex, and to propose changes in these alternatives. These changes are described in the enclosed " Revised Notice of Intent to Prepare a Programmatic Environmental Impact Statement for Reconfiguration of the Nuclear Weapons Complex.'"
Significant changes include the addition of a consolidated long-term storage facility for plutonium and one for uranium, as well as consolidation at a single site of all weapons complex functions involving a given nuclear material, e.g., plutonium storage, processing, component fabrication, and possibly related research and development would all be located at the same site.
In addition, the Department is proposing to add the Nevada Test Site as a candidate site for any or all of the weapons complex nuclear functions, and to eliminate the Hanford Site as a candidate site for these functions. The Nevada Test Site has been proposed as a candidate site because of its large size, remoteness, and significant existing infrastructure. The proposed elimination of Hanford as a candidate site is based upon the fact that weapons complex production missions have been terminated and it is now dedicated to an environmental restoration and waste management mission.
Alternatives for consolidation of'nonnuclear manufacturing have been evaluated in a separate Nonnuclear Consolidation Environmental Assessment (June, 1993).
A proposed Finding of No Significant Impact, based upon this environmental assessment, was published in the Federal Reaister for public review and comment on July 8, 1993 (58 Fed. Rec.
36658).
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Comments on the proposed scope of the Programmatic Environmental Impact Statement are invited from the public.
The comment period will extend through October-29, 1993.
Public scoping meetings will'be held near each of the sites involved in the environmental analysis for the PEIS and in Washington, D.C., beginning the week of September 6, 1993.
The locations, dates, and times for these meetings.will be' announced in the Federal Reaister and local media as soon as possible, Sincerely,
_ -up h
Everet H. Beckner Acting Assistant Secretary for Defense Programs Enclosure i
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DEPARTMENT OF ENERGY REVISED NOTICE OF INTENT TO PREPARE A PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT FOR RECONFIGURATION OF TllE NUCLEAR WEAPONS COMPLEX Published in the Federal Reaister on July 23, 1993 AGENCY:
Department of Energy ACTION:
Revised Notice of Intent (NOI) to Prepare a
Programmatic Environmental Impact Statement for Reconfiguration of the Nuclear Weapons Complex
SUMMARY
Since February 1991, when the Department of Energy (DGE) originally announced its intent to prepare a Programmatic Environmental Impact Statement (PEIS) for reconfiguring the nuclear weapons complex (56 Fed. Rea. 5590), the nuclear weapons stockpile has been significantly reduced.
To illustrate the magnitude of the stockpile reductions, the nation is presently in the process of reducing its nuclear weapons stockpile to approximately 25 percent of levels planned as recently as five years ago. These reductions have prompted a fresh look at, and reevaluation by the Department of, its earlier Reconfiguration proposal, to ensure that the effects of the historic events which ended the Cold War are taken into account in determining the appropriate configuration of the nation's future nuclear weapons complex. As a result, and pursuant to section 102(2)(C) of the National Environmental Policy Act (NEPA) of 1969, as amended (42 U.S.C 4321 gi leg.) and the Council on Environmental Quality (CEQ) regulations (40 CFR Parts 1500-1508), the DOE is issuing this revised notice of intent (NOI) to prepare a PEIS for reconfiguring its weapons complex.
Based on the reevaluation, the Department is proposing changes in the scope of the Reconfiguration PEIS, most notably:
(1) Addition of consolidated long-term storage facilities for plutonium and highly enriched uranium which will or may be needed in the future to fulfill national security requirements; (2) Addition of consolidation of functions involving like materials, including the option of integrating certain research, development and testing (RD&T) functions with the storage and processing functions; (3) Addition of the Nevada Test Site (NTS) in Nevada and deletion of the Hanford Site in Washington as potential sites for future weapons complex facilities; and (4) Changes in the no-action alternative as a result of recently announced 3
mission changes at weapon complex sites, including transferring the Rocky.
Flats Plant to a cleanup mission and placing the K-Reactor at the Savannah River Site in cold standby.
These proposed changes in the PEIS scope reflect the fact that the future nuclear weapons complex can be even smaller and more integrated than previously envisioned in the original N01.
The changes also reflect the increased importance associated with stewardship of existing special nuclear materials that will or may be used in the future to meet national security requirements.
On a related matter, prior to the issuance of the original.NOI, the Department had announced the preparation of two programmatic environmental impact statements, one concerning the reconfiguration of the nuclear weapons complex, and the second dealing with alternative strategies and policies for conducting the Department's environmental restoration and waste management program.
The Department determined at that time that these two programs were not so connected as to require a single environmental impact statement. While the Department is proceeding with this revised Notice of Intent for the Reconfiguration Programmatic Environmental Impact Statement, it will also be reviewing this initial determination in light of the changed circumstances described in this Notice.
To ensure that the public's concerns and views are fully considered, DOE is affording the public an opportunity to comment on the proposed scope of the Reconfiguration PEIS, and on whether it should be combined with the-PEIS on the environmental restoration ant' waste management program.
DATES:
Written comments on the proposed scope of the nuclear weapons complex PEIS are invited from the public. To ensure consideration in preparation of the PEIS, comments must be postmarked by October 29, 1993.
Late comments will be considered to the extent practicable.
DOE will hold public scoping meetings beginning in September,1993 to receive oral comments near all sites proposed to be analyzed in the PEIS. These are: Hanford Site, Idaho Engineering Laboratory, Los Alamos National Laboratory, Lawrence Livermore National Laboratory, Nevada Test Site, Oak Ridge Reservation, Pantex Plant, Rocky Flats Plant, and the Savannah River Site.
A meeting will also be held in Washington, D.C.
00E will announce the location, date and time for these public meetings in a subsequent Federal Reaister Notice, and in appropriate local media. The announcement of the meetings will be at least 15 days prior to any meetings. The public meetings will provide the public with an 4
opportunity to present formal oral comments and/or written statements, as well as an opportunity to engage in more informal conversations regarding the t
reconfiguration program with DOE representatives. Additional details regarding-the public meetings will be provided in the announcements to be published prior to the meetings. Following this additional scoping period, the Department will issue a revised PEIS Implementation Plan.
ADDRESSES:
Written comments on the scope of the PEIS, requests for further information on the DOE nuclear weapons complex reconfiguration program, requests for copies of the revised Reconfiguration PEIS Implementation Plan (when available), and requests for copies of the PEIS or PEIS Executive Summary (when i
available) should be sent to:
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Howard Canter, Deputy Assistant Secretary Office of Weapons Complex Reconfiguration U.S. Department of Energy P.O. Box 3417 Alexandria, VA 22302 (202) 586-1300 FOR FURTHER INFORMATION CONTACT: For general information on the DOE NEPA review process, please contact:
Carol M. Borgstrom, Director Office of NEPA Oversight, EH-25 U.S. Department of Energy 1000 Independence Avenue, S.W.
Washington DC 20585 (202) 586-4600 or I-(800)-472-2756 SUPPLEMENTARY INFORMATION:
Backaround:
Although the national security picture for the United States has changed dramatically, a safe, secure, reliable, and effective nuclear deterrent is central to the security of the United States, and will remain so for the foreseeable future.
Therefore, as long as the nation relies on a nuclear deterrent, it is necessary to maintain a nuclear weapons complex that is fully capable of supporting the nuclear deterrent by performing surveillance, evaluation, and maintenance of both the current and future nuclear. weapons The complex must also be capable of resuming new warhead production stockpile.
if the President authorizes the Department to replace aging weapons, or in response to changes in the international security environment.
Nonetheless, the significant stockpile reductions-- coupled with budget reductions which will not support a large, inefficient nuclear weapons complex--
dictate that the future weapons complex will undoubtedly look different in form and scope from the existing nuclear weapons complex. Given these realities, the Department must achieve and maintain a fully capable complex that is even smaller, less diverse, and less expensive to operate than that which was contemplated at the time of the original Notice of Intent.
DOE Nuclear Weapons Complex. The DOE nuclear weapons complex is organized into three functional elements:
(1)_ Nuclear Materials Storage, Processing and Component Fabrication; (2)
Nonnuclear Manufacturing; and (3)
- Research, Development and Testing (RD&T). When the original NOI was announced, the complex consisted of 13 major facilities located in 12 states. Due to recently announced mission changes, some functions that were previously performed at particular sites will no longer be performed at those sites.
Therefore, the currently functioning nuclear weapons complex is different from that identified in the original NOI. A description of the nuclear weapons capabilities at the sites to be included in the PEIS analysis which support the nuclear and RD&T functional elements of the weapons complex is provided in Table 1.
The environmental analysis of the proposed action and alternatives for consolidation 'of the nonnuclear functional element of the complex is documented in the separate 3
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- Nonnuclear. Consolidation. Environmental Assessment (June, 1993).
A proposed Finding of No Significant Impact, based upon this environmental assessment,'was published in the Federal Reaister for public review and comment on July 8,1993, (58 [g6 E m 36658).
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Table 1 2
CURRENT NUCLEAR WEAPONS COMPLEX SITES functional Element:
Nuclear Materials Storace. Processir.a and Component Fabrication Sites Pantex Plant (Amarillo, Texas)- Provides support, including surveillance and maintenance, of the enduring nuclear weapons stockpile; dismantles nuclear 1
weapons returned from the stockpile; produces chemical high explosive components; assembles, if required, nuclear weapons; provides interim storage for plutonium pits; conducts research, development and testing (RD&T) of high explosives and high explosive components.
Savannah River Site (Aiken, South Carolina)- Provides support for the enduring nuclear weapons stockpile including tritium processing and recycling operations, and tritium reservoir loading; provides interim storage for plutonium.
Y-12 Plant (0ak Ridge, Tennessee)- Provides support for the enduring nuclear weapons stockpile including stockpile evaluation, and limited fabrication capability for uranium and lithium weapons components; recovers and processes uranium and lithium materials from retired weapons; provides interim storage for uranium and lithium.
Rocky Flats Plant (Golden, Colorado)-
Currently in transition from a predominantly nuclear weapons production mission to an environmental restoration, cleanup, and waste management mission; provides interim storage for plutonium.
Hanford Site (Richland, Washington)- Provides interim storage for plutonium.
Functional Element: Weapons Research. Development and Testina Sites Lawrence Livermore National Laboratory (Livermore, California) - Conducts research and development of nuclear warheads; designs and tests advanced technology concepts; maintains weapons design program.
Los Alamos National Laboratory (Los Alamos, New Mexico) - Provides research and i
development of nuclear warheads; designs and tests advanced technology concepts; maintains weapons design program; provides limited fabrication capability for plutonium components; and provides interim storage for plutonium.
Nevada Test Site (Las Vegas, Nevada) - Conducts underground nuclear testing.
Sites included in this table are only those that deal predominantly with 2
nuclear mater.ials or nuclear components.
Four of the sites listed in the original NOI, i.e. Mound, Pinellas, Kansas City and Sandia National Laboratory, are not included in the table because analyses of functions involving these' sites were included in the Nonnuclear Consolidation Environmental Assessment.
In addition, the Idaho National Engineering Laboratory is not included because, since the publication of the original NOI, it has ceased the chemical processing of naval reactor spent fuel to recover enriched uranium.
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2 Reconfiauration PEIS Histgn:
On February 11, 1991, the DOE published the original N01 to prepare a PEIS for the Reconfiguration of the Nuclear Weapons.
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Complex (56 Fed. h 5590). DOE proposed to develop a comprehensive strategy to accomplish the goal of creating a smaller, less diverse, less costly nuclear weapons complex. At that time, DOE announced that the Reconfiguration PEIS would analyze the environmental consequences of alternative long-term reconfiguration.
strategies for the DOE nuclear weapons complex, envisioned to be in place early in the 21st century ~(" Complex 21"), and weigh these against the consequences of maintaining the existing configuration.
In that NOI, two reconfiguration options were propused: (1) relocating the nuclear weapons functions then performed at the Rocky Flats Plant (RFP).(Golden, Colorado) to another site; and (2) co-locating nuclear materials production and manufacturing functions assigned to Y-12 (0ak Ridge, Tennessee) and/or Pantex (Amarillo, Texas) with the relocated RFP functions.
DOE envisioned that the reconfigured weapons complex would - consist of stand-alone facilities for processing and fabricating plutonium and uranium / lithium components, as well as a facility to conduct weapons assembly / disassembly /high explosives activities.
The candidate sites considered for the relocation of these functions under either option were the Hanford Site (Richland, Washington), Idaho National Engineering Laboratory (Idaho Falls, Idaho), Savannah River Site (Aiken, South Carolina), Oak Ridge Reservation (0ak Ridge, Tennessee), and Pantex Site (Amarillo, Texas).
Additionally, the PEIS was to include an analysis of alternatives for consolidating nonnuclear manufacturing activities, and consolidating some research, development, and testing (RD&T) functions currently performed at Los Alamos National Laboratory (LANL), Lawrence Livermore National Laboratory (LLNL).
and Sandia National Laboratory (SNL).
At the time of that NOI, developing a new source of. tritium was of such urgency that decisions concerning the new production reactor (NPR) were believed to be needed in advance of decisions regarding the remainder of the complex.
Therefore, the Reconfiguration PEIS was separate from the EIS then being prepared for the NPR program to supply tritium.
Through a public scoping process, which included 15 public scoping meetings from March to August 1991, DOE solicited comments on its reconfiguration proposal. The purpose of the scoping meetings was to receive public' comments to assist DOE in preparing an Implementation Plan (IP) describing the scope of the PEIS, including the alternatives to be analyzed, and a schedule for completion.
The public comment period ended on September 30, 1991.
On September 27, 1991, President Bush announced an initiative to reduce the Nation's nuclear weapons stockpile.
In response to this initiative, the Department announced on November 1,1991, that it would delay decisions on the new production reactor technology and site and include the environmental analysis for a new tritium production source in the Reconfiguration PEIS. In light of the significantly reduced stockpile, this addition to the Reconfiguration PEIS resulted in the need to evaluate the impacts of "down-sized" reactors, reevaluate-alternative technologies such as accelerators, and to reevaluate the original reactor siting alternatives.
On November 29, 1991, DOE published a notice of opportunity for public comment, incorporating the NPR environmental analysis into the Reconfiguration PEIS (56 Fed. Rea. 60985). This public comment period ended on January 6, 1992.
6
P The September 1991 arms reduction initiative also provided DOE with the opportunity to accelerate the nonnuclear consolidation effort in the ' weapons
-complex without impacting national defense or the remainder of the Reconfiguration program. Therefore, in December 1991, the Department announced a proposal to accelerate nonnuclear consolidation, and on January 27, 1992, DOE published a notice of its plans to prepare a separate environmental assessment (EA) for nonnuclear consolidation within the nuclear weapons complex- (57 Fed.
Rea. 3046). Further reductions in the stockpile and a cessation of production of new weapons for the immediate future were announced by President Bush in his January 28, 1992, State of the Union message.
On February 19, 1992, DOE issued an Implementation Plan (IP) for the Reconfiguration PEIS (D0E/EIS-01611P). In that IP, DOE proposed alternatives for the Reconfiguration PEIS which would have assessed stand-alone' production facilities for plutonium and uranium / lithium components, as well as weapons assembly / disassembly activities.
While smaller in capacity than originally envisioned when the Reconfiguration NOI was announced, these stand-alone facilities would still have supported a relatively large stockpile.
Since issuing that IP, an arms reduction agre,ement between the United States and Russia was announced in June 1992, and was signed by Presidents Bush and Yeltsin in January 1993 as the START 11 Treaty. This agreement caused the most significant reductions to date in the planned future weapons stockpiles of both nations, and has provided DOE with a historic opportunity to consider a much smaller weapons complex than previously envisioned.
Therefore, in the latter part of 1992, the Department determined that it was necessary to reevaluate the
' Reconfiguration program to ensure that only alternatives which reflected requirements of a greatly downsized nuclear weapons stockpile would be assessed in the PEIS.
Specifically, the Department has been reevaluating: (1) the_ appropriate sizing for the future weapons complex facilities;- (2) the capabilities and functions required for the future complex; (3) the siting alternatives' for each weapons function to be analyzed in the PEIS; and'(4) the technology alternatives for new tritium supply capacity.
This examination of program direction has resulted in several important conclusions, and certain departures from the Department's original planning basis. The overall proposed changes in the PEIS scope are described below.
Major Reconfiguration PEIS Scope Chances:
1.
Lona-term Storace for Soecial Nuclear Materials:
Because a significant number of weapons have been, and will continue to be, retired from the nation's active nuclear weapons stockpile, the Department proposes to analyze in the PEIS a consolidated long-term storage facility for plutonium and a consolidated facility for highly enriched uranium, to provide safe, secure, and reliable storage for these national assets. A consolidated storage facility for each of these materials would avoid duplicative processing and analytical laboratory capabilities, prevent multiple infrastructure and overhead costs, and preserve the ability to consolidate all functions involving like materials at one site, as described below.
Previously, the stockpile reductions mandated that relatively few weapons would be retired without replacement. Therefore, when the original NOI and IP H
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were prepared, the long-term storage of these materials was not a contemplated mission requirement since disassembled components would be recycled into new weapons. Presently the DOE does not have a consolidated facility to store either plutonium, which is stored at several different sites, or highly enriched uranium, most of which is stored in facilities at Oak Ridge, with small quantities stored at several other sites in the complex. Consolidated storage of plutonium and highly enriched uranium assets would be expected to improve j
security and accountability associated with these materials, reduce life-cycle l
storage costs, and eliminate duplicative facilities.
There is no proposal to i
store radioactive wastes at either the plutonium storage facility or the uranium storage facility.
l It is the Department's intention that plutonium would be stored in the consolidated long-term storage facility until it is either used in the weapons program or another use or disposition option is proposed and approved in the future.
It is expected that the highly enriched uranium (HEU) being returned from retired weapons will eventually be used to provide fuel for reactors requiring HEU, such as those in the nation's nuclear navy.
2.
Consolidation of Functions Involvina like Materials: Taking full advantage of the opportunity to restructure and downsize the complex means that activities involving like materials must be consolidated to the maximum exte'.it possible.
The Department considers it unreasonable to have plutonium canconcnt fabrication at one site, and plutonium storage facilities at a second site, particularly at a time when the Department is trying to downsize the complex and operate more efficiently.
Similar to the rationale for consolidated storage - facilities described above, separating these functions would require duplicative processing and analytical laboratory capability at each
- site, involve needless transportation of nuclear material between sites, and result in duplicative infrastructures and overhead costs.
The same rationale applies to uranium storage, processing and component f abrication, and to tritium processing and production. Therefore, the Department proposes that common to all alternatives analyzed in the PEIS would be co-location of all storage, processing, analytical laboratory and fabrication facilities for either plutonium or uranium at the same site in the future weapons complex.
Similarly, the Department proposes that tritium processing and tritium production be co-located at a single site.
Lastly, the Department intends to analyze the option of integrating some research, development, and testing (RD&T) activities, which historically have been performed in separate facilities at the national laboratories, into proposed weapons complex storage and processing facilities. This is expected to result in maximum utilization of both personnel and the proposed facilities, while also providing significant long-term cost savings by consolidating facilities which utilize like materials.
3.
Sitina Alternatives for Weaoons Functions:
Together with the original Notice of Intent, an Invitation for Site Proposals (Invitation) was published (56 Fed. Rea. 5595) which invited parties outside the DOE weapons complex to suggest sites for location of future weapons complex activities. Having received no expressions of interest from outside the DOE weapons complex as a result of the Invitation, a Site Evaluation Panel evaluated five DOE nuclear manufacturing and production sites which met the minimum qualification criteria in the Invitation and recommended in "A Report by the NWCR Site Evaluation Panel,"
(October,1991) that all five be considered further as potential sites for future i
weapons complex functions.
The minimum qualification criteria in the Invitation 8
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- encompassed land, water, and electricity availability as well as the absence of known unacceptable environmental, safety and health impacts associated with-siting, constructing, operating and decommissioning the facilities, that could not be mitigated by reasonable measures. Therefore, in the original IP, Hanford, Oak Ridge, Savannah River, Pantex, and Idaho were identified as reasonable alternative sites for the proposed reconfigured Complex 21 facilities.
Based upon its reevaluation of the original proposal, DOE proposes to add the Nevada Test Site (NTS) as a potential site for the Complex 21 facilities.
NTS is a large, remote site that meets the minimum qualification criteria against which the other sites were evaluated, and it has a significant existing infrastructure that could accommodate one or more weapons complex functions.
Additionally, the Hanford site has been eliminated as a candidate site for the future ' complex because nuclear weapons production functions at that site have been terminated, and the site is dedicated to environmental restoration and waste management activities.
The Department considers it to be unreasonable to terminate all weapons production missions from the site, spend billions of dollars in order to restore it for other uses, and then reintroduce nuclear weapons program construction and operation activities which will prevent other uses of the site for the long term.
The continued commitment to focussing activities on environmental restoration / waste management at Hanford is also consistent with the Secretary's recent reaffirmation of the importance of meeting the Department's cleanup goals at the site.
Regarding new tritium production, the NPR EIS was intended to assess Hanford, Savannah River, and Idaho as reasonable sites. New tritium supply would no longer be considered at Hanford, but would be considered at NTS. In addition, given the much smaller capacity required for tritium production requirements than originally contemplated, the Department has concluded that Oak Ridge constitutes a reasonable alternative site for a new tritium production facility.
- Further, there appears to be no basis for exclusion of Pantex as a candidate site for a new tritium production facility when it is considered a reasonable site for all other Complex 21 nuclear functions. Therefore, the Department proposes to add Oak Ridge and Pantex to the list of candidate sites for such a facility.
4.
No Action Alternative: Since the publication of the original NOI, there have been changes in the current weapons complex status. quo that in turn affect the PEIS no-action alternative. Some functions that were previously performed at particular sites are not, or will shortly no longer be, performed in existing facilities at those sites, and some sites that were previously part of the nuclear weapons complex either have a new mission or a greatly reduced capability. Therefore, if reconfiguration or modification / upgrade of the nuclear weapons complex were not to occur, the complex would be limited in its ability to support the projected future stockpile through the first half of the 21st century, and DOE would not likely be able to meet its Atomic Energy Act responsibilities. More specifically:
(1) The Rocky flats Plant (RFP) will transition from a production dominated site to an environmental restoration, cleanup, and waste management-dominated site in the near future. The contingency status of the buildings which could be used to manufacture any required new plutonium components will be removed. Therefore, the Department will no' i
longer be capable of manuf acturing and fabricating plutonium components at RFP; 9
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(2)-The Y-12 plant at Oak Ridge, Tennessee will have reduced capacity and will only be able to provide support-for the' enduring weapons stockpile and limited component fabrication capability. Y-12 would not maintain the capability to support the projected stockpile requirements.
(3) The K-Reactor at the Savannah River Site will be placed in a cold This will standby position with no planned provision for restart.
effectively eliminate the DOE's ability to produce tritium to support the projected stockpile requirements.
Future tritium requirements would be supported as long as possible by recycling tritium from weapons returned from the active stockpile. At some point the. nuclear deterrent capability of the nation would either be lost or based on weapons which would be significantly different than those in the current stockpile, and which Should there be no tritium would not meet present mission requirements.
production capability in the United States, purchase of tritium from foreign sources could be explored, but such purchase possibilities would not constitute an assured supply of tritium for the long term and would thus not represent a reasonable'PEIS alternative..
PEIS Alternatives: The PEIS will assess the environmental impacts of alternative configurations for both the Nuclear Materials Storage, Processing and Component Fabrication element of the nuclear weapons complex and some Research, Development and Testing (RD&T) elements.
In order to accelerate the consolidation of nonnuclear facilities and thereby achieve significant cost savings-while preserving technical competence which is being lost within the weapons complex, the environmental impacts associated with consolidation of.the Nonnuclear Manufacturing. element of the weapons complex have been assessed in a separate Environmental Assessment.
On May 27, 1993, the Department announced that it intended to finalize the Environmental Assessment and publish a proposed Finding of No Significant Impact (F0NSI) for public review and comment. The Environmental Assessment and the proposed F0NSI have been approved by the Department and the proposed FONSI was published in the Federal Reaister for public review and comment on July 8,1993_(58 Fed Rea. 36658).
- a. Alternatives for the Nuclear Materials Storaae. Processina and Component Fabrication Element: The Nuclear Materials Storage, Processing and Component Fabrication element of the weapons complex encompasses the following functions:
(1)
Plutonium (Pu): Pu Storage, Processing and Component Fabrication; (2)
Uranium / Lithium (U/Li): Uranium / Lithium Storage, Processing, and Component Fabrication; (3)
Assembly / Disassembly /High Explosives (A/D/HE); and (4)
Tritium Production / Processing.
For each of these functions, the Reconfiguration PEIS will assess three different types of alternatives: (1) constructing and operating new facilities at any of five alternative sites; (2) modifying / upgrading existing facilities at existing sites; and (3) the no-action. alternative of continuing to operate existing facilities. Each of these alternatives is discussed below:
Alternative #1-- Constructina and Operatina New Facilities: For each of the four Nuclear Materials Production and Storage functions (Pu, U/Li, A/0/HE, and Tritium), the PEIS will assess the environmental impacts of constructing and
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1 operating new facilitier (referred to. as " modules") at any of five alternative sites:
q (1) Idaho National Engineering Laboratory (INEL);
(2) Savannah River Site (SRS);
(3) Oak Ridge Reservation (0RR);
(4) Pantex Site; and (5) Nevada Test Site (NTS).
Each functional module would contain those facilities necessary to accomplish the particular function. For example, the Pu mo_dule would contain facilities capa_ble of storing Pu, processing Pu, and fabricating Pu components. Additionally, both the plutonium and uranium functional modules would be designed to accommodate the option of integrating RD&T activities within the module so that these RD&T facilities could be collocated with other facilities involving like materials at a single site if desired.
The PEIS will bracket the potential environmental impacts that could result from constructing and operating the proposed new modules by analyzing each module individually, and by analyzing the total consolidation of all modules, at each alternative site. Thus, for each site alternative, the PEIS will present both an individual analysis for each module and a bounding case analysis for total consolidation of all four modules. The impacts of combinations of two or three-functions could be determined by adding the impacts of the individual modules.
Such an approach may introduce a small degree of conservatism to the PEIS analysis, but'is not expected to result in any significant change in the results of the analysis.
In any case, following the PEIS, more detailed site-specific NEPA documentation would be prepared as required to analyze the synergism of any selected combinations at a site.
The PEIS will also assess the environmental impacts associated with removing a particular function from an existing site.
For the tritium production function, the PEIS analysis will contain
'ufficient information to support the selection of a production technology. Four separate alternative technologies will be assessed in the PEIS:
Heavy Water-Reactor, Light Water Reactor, Modular High Temperature Gas Reactor technologies, and a linear particle accelerator. The PEIS will also contain enough information _
to support a decision concerning the locatio of the tritium production function.
Alternative #2-- Modifyina/Unaradina Existina Facilities:
The PEIS will also evaluate a modification / upgrade-in-place alternative.
Under this approach, weapons complex functions would not be moved and DOE would make those modifications and upgrades necessary to ensure compliance with Federal, State, and local environmental, safety, and health (ES&H) laws cnd regulations and meet future nuclear weapon stockpile requirements. The PEIS will provide information on, and an assessment of, the potential environmental impacts associated with these modifications and upgrades. More specifically, the modification / upgrade-in-place alternative for each of the Nuclear Materials Storage, Processing and Component Fabrication functions encompasses the following elements:
Plutonium Processina and Component Fabrication: Because, as noted above, the Department will no longer be capable of fabricating plutonium components at the Rocky Flats Plant, present research and development hcilities at the los Alamos National' Laboratory (LANL) would be used to i
process and fabricate plutonium components for this alternative to support 11 I
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the projected stockpile requirements through the first half of the 21st j
century.
However,- in order to satisfy ES&H and projected stockpile
- l production requirements, existing facilities might require modifications.
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The potential environmental impacts associated with modifying facilities at LANL, and operating the LANL f acilities, would be assessed in the PEIS.
Plutonium Storace: Plutonium storage would not be consolidated into a single dedicated Pu storage facility; rather, plutonium storage facilities at RFP, SRS,- Pantex, Hanford, and LANL would continue to be utilized to store quantities of plutonium in various forms through the first half of the 21st century. Any upgrades or modifications of these existing facilities required to satisfy ES&H or future storage requirements would be assessed in the PEIS.
Uranium / lithium Storace. Processino, and Component Fabrication: The potential environmental impacts associated with modifying existing U/Li facilities (mainly at Y-12), and operating those facilities through the first half of the 21st century, would be assessed in the PEIS.
Assembly / Disassembly /Hiah Explosives: The potential environmental impacts associated with modifying facilities at Pantex, and operating the Pantex facilities through the first half of the 21st century, would be assessed in the PEIS. For high explosives work, the alternatives evaluated in the PEIS will include modification of the facilities at LLNL or LANL.
Tritium Supolv: There is no modification / upgrade-in-place alternative for tritium supply because it would not be reasonable (either' technically or economically) to modify / upgrade the K-Reactor at SRS. Therefore, whether or not reconfiguration occurs, a new tritium production source would be needed in order for the Department to meet future tritium requirements.
As noted previously, purchase of tritium from foreign ' sources does' not constitute a reasonable long-term alternative for tritium supply.
Tritium Processina: The Replacement Tritium Facility (RTF) and other-support facilities at SRS would perform tritium processing as required to support the future stockpile requirements.
It is not expected that any modifications of the RTF would be required in order to' satisfy ES&H and projected stockpile production requirements; however, other support facilities at SRS might require modifications / upgrades.
Therefore, the-potential environmental impacts. of those modifications, along with the operation of the RTF and those support facilities, would be assessed in the PEIS.
Alternative
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No-Action (Continued Operation):
Under the no-action alternative, reconfiguration of the nuclear weapons complex would not occur, there would be no upgrades / modifications of existing facilities, and - future support of the nuclear weapons stockpile would be provided within _the confines of the existing nuclear weapons complex capabilities. Some mission requirements for maintenance of the future weapons stockpile would not be met under the no-action alternative. Therefore, for those mission requirements, the no-action alternative could not be adopted and is not considered to be reasonable.
However, the no-action alternative for those mission requirements will be.
presented in the PEIS to represent a baseline condition against which alternatives that would meet the Department's Atomic Energy Act responsibilities 12
This baseline has been affected by the recent developments could be compared, regarding the Rocky Flats Plant, Y-12 and the K-Reactor which were discussed-More specifically, the environmental impacts of utilizing existing previously.
facilities will be assessed in the.PEIS for the following components of the no-action alternative:
(1) Plutonium Processino and Component Fabrication: RFP would no longer be Existing capable of processing and fabricating plutonium components'.
facilities at LANL and LLNL would provide a limited fabrication capability for future plutonium components. The existing capability at LANL and LLNL would be insufficient to support the projected stockpile requirements.
(2) Plutonium Storace: Existing plutonium storage facilities at RFP, SRS, Pantex, Hanford, and LANL would continue to be utilized to store quantities of plutonium in various forms.
(3) Uranium / Lithium Storaag.
Processino.
and Fabrication:
Existing facilities (mainly at Y-12) would provide uranium / lithium storage, and limited processing, and component fabricating capability. The existing capability would be insufficient to support the projec.ted stockpile requirements.
(4) Assembly / Disassembly /Hiah Explosives:
Existinq facilities at Pantex would develop and fabricate chemical high explosive components, and assemble and disassemble weapons as required to support the projected stockpile requirements.
(5) Tritium Production: DOE would have no capability to produce new tritium to support future stockpile requirements.
Future tritium requirements would be supported as long as possible by recycling tritium from weap'ons returned from the active stockpile. Purchase of tritium from foreign sources could also be explored, but'as noted previously would not constitute an assured source of tritium for the long-term and is therefore not a reasonable PEIS alternative. As noted previously,. in the absence of a reliable source of tritium, the nation's nuclear deterrent capability would eventually either be lost or would be based upon weapons i
significantly different from those in the current stockpile and which would not meet present mission requirements.
(6) Tritium Processina: The RTF and other support facilities at SRS would perform tritium processing operations as required to support the projected stockpile requirements, in summary, the PEIS will support a decision to build one or more new functional facilities (modules) at any of five alternative sites, modify / upgrade one or more existing facilities, and continue to operate any of the no-action alternative i
facilities that could comply with ES&H and mission requirements. The PEIS will assess a full range of alternatives: from no-action (continued operations with existing facilities), to complete consolidation of the entire weapons complex functions at any of the five alternative sites.
Additionally, a number of alternatives within this full range would be evaluated, thus affording DOE the opportunity to assess varying degrees of consolidation.
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- b. Alternatives for the Research. Develonment, and Testina Element: The weapons complex also performs research, development, and testing - (RD&T) related to -
nuclear weapons design, manufacture, and performance. Much of this RD&T takes place at the Los Alamos National Laboratory (LANL) and the Lawrence Livermore National Laboratory (LLNL).
As previously stated, the PEIS will-evaluate integrating certain of these RD&T activities, i.e., those dealing with the use of special nuclear materials and depleted uranium in weapons manufacture, into the proposed Complex 21 modules. Therefore, the specific alternatives that will be evaluated in the PEIS for RD&T functions are as follows:
Plutonium (Pul RD&T: Pu RD&T is presently performed at LANL and LLNL.
Future Pu RD&T would either be consolidated with tre Complex 21 Pu module, consolidated at LANL or remain at the two sites where it is now performed.
Uranium (Ul RD&T: U RD&T is presently performed at LANL, LLNL, and Y-12.
Future U RD&T would either be consolidated with the Complex 21 U/Li module, consolidated at either LLNL or LANL, or remain at the three sites where it is now performed.
Environmental Issues. The PEIS will identify and analyze direct, indirect, and cumulative impacts resulting from the reconfiguration alternatives, including potential effects from constructing and operating the proposed facilities (i.e.,
impacts to air quality, water resources, plants and animals, land use, historic resources, archaeological sites, socioeconomic impacts); impacts associated with generating wastes (including radioactive, hazardous and mixed),- transporting radioactive, hazardous or mixed materials; and the potential consequences of both normal and accidental radiological and nonradiological releases on public and worker health and safety. The PEIS will examine other relevant issues identified by DOE or the public through the past and current scoping process.
Reconfiauration PEIS Decisions.
Following preparation of the final PEIS, DOE will issue a Record of Decision (ROD) to document its decisions on the long-term configuration of the nuclear weapons complex. The R0D will explain how DOE has balanced environmental considerations against other relevant factors, such as economic and technical considerations, and agency statutory mission, in reaching its decision.
Reconfiauration Plam DOE will use the decisions arising from the PEIS to develop _ a comprehensive reconfiguration plan to guide DOE in implementing the decisions contained in the R00. The plan will cover such subjects as identifying schedules for transferring responsibilities from one location to another, upgrading facilities in place or bringing new facilities (if any) on-line.
If necessary, the PEIS and the reconfiguration plan may be supplemented later, if there is a need to change or augment the programmatic decisions.
Classified Materia DOE will review classified material.while preparing the PEIS. The amount of classified material contained in the PEIS will be minimized to the extent presible consistent with national security requirements. However, despite the efforts to minimize its use, DOE anticipates that the completed PEIS, and its associated ROD, may include classified material which will not be available for general public review. This material would, however, be considered -
by DOE in reaching a decision on configuration of the future complex.
The ensuing nuclear weapons complex reconfiguration plan would include an unclassified summary document which would be available for public distribution 14 4
and a classified report which would not be made available to the general public.
Invitation to Coment. DOE invites comments on the scope of this PEIS from all interested parties, including affected Federal, State and local agencies and Indian tribes. DOE solicits comments regarding the scope of the PEIS analysis, suggestions on significant environmental issues, alternatives to be included in the PEIS, and other content.
To ensure consideration in preparing the draft PEIS, written comments must be postmarked by October 29, 1993.
Late comments will be considered to the extent practicable. Agencies, organizations, and the general public are invited to present oral comments pertinent to preparation of the PEIS at public scoping meetings. DOE will also accept written material at the meetings.
In addition, as discussed previously, there will be opportunities for more informal discussions between members of the public and DOE representatives during the scoping process.
Written and oral comments will be given equal weight in the scoping process.
DOE will _ hold public scoping meetings beginning in September 1993 to receive oral comments near all sites proposed to be analyzed in the PEIS. These are: Hanford Site, Idaho Engineering Laboratory, Los Alamos National Laboratory, Lawrence Livermore National Laboratory, Nevada Test Site, Oak Ridge Reservation, Pantex Plant, Rocky Flats Plant, and the Savannah River Site.
A meeting will also be held in Washington, D.C.
The time, date and location for these meetings will be announced by DOE.n the Federal Reoister in the near future.
Notice of the public meetings will be published in the Federal Reoister at least 15 days prior to the holding of each meet'nt The meetings also will be-publicized in local media and other means as.pprcyriate. Advance registration to provide oral comments at these meetings Mll b: facilitated using an "800 number" that will be provided in the Fede M teoister notice.
On-site registration on the day of the meeting will be accommodated to the extent possible.
DOE will prepare transcripts of the scoping meetings and make these available for public review. Subsequent to the scoping meetings,_ DOE will issue a revised PEIS Implementation Plan to provide up-dated information on how the PElS will be prepared in light of the scope changes.
DOE will announce the availability of the draft PEIS, when completed, in the Federal Reoister, and will solicit public review and comment on the draft PEIS. Comments on the draft will be considered in preparing the final PEIS.
Supportino Documents. The unclassified January,1991 Reconfiguration Study, the Implementation Plan (February 1992) and Revision (when available), and other unclassified supporting information are available for public review at the DOE public reading' rooms listed below.
California U.S. Department of Energy San Francisco Operations Office Public Reading Room 1301 Clay Street, Room 700N Oakland, California 94612-5208 (510) 65/-1762 15
Colorado U.S. Department of Energy Rocky Flats Public' Reading Room Front Range Community College Library 3645 West.12th Avenue i
Westminster, Colorado 80030 Attention: Will-ann Lamsens (303) 469-4435 Florida U.S. Department of Energy Public Reading Room Largo Public Library 351 East Bay Drive i
Largo, Florida 34640 j
(813) 587-6715 Idaho U.S. Department of Energy Idaho Operations Office Public Reading Room 1776 Science Center Drive Idaho Falls, Idaho 83402 (208) 526-9162 Missouri U.S. Department of Energy Public Reading Room Red Bridge Branch, Mid-Continent Public Library 11140 Locust Street Kansas City, Missouri 64137 (816) 942-1780 New Mexico-Albuaueroue
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U.S. Department of Energy Public Reading Room National Atomic Museum j
20358 Wyoming SE Albuquerque, New Mexico 87185-5400 Attention:-Diana Zepeda (505) 845-6670/4378 i
New Mexico-Los Alamos U.S. Department of Energy Community Reading Room 1450 Central Avenue Suite 101 Los Alamos, New Mexico 87545 (505) 665-2127
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Nevada U.S. Department of Energy Nevada Operations Office 2753 South Highland Drive Las Vegas, Nevada 89193 (702) 295-1274 Ohio U.S. Department of Energy Miamisburg Library 1
DOE Public. Reading Room 35 South Fifth Street Miamisburg, Ohio 45342 (513) 866-1071 South Carolina U.S. Department of Energy Reading Room University of South Carolina, Aiken Campus 171 University Parkway Aiken, South Carolina 29801 (803) 641-3320 Tennessee U.S. Department of Energy Oak Ridge Operations Office Freedom of Information Officer 200 Administration Road, Room G-209 Oak Ridge, Tennessee 37831 (615) 576-5765 Texas U.S. Department of Energy Reading Room Lynn Library / Learning Center Amarillo College 2201 South Washington Street Amarillo, Texas 79109 (806) 371-5400 Washinaton U.S. Department of Energy Public Reading Room Washington State University 100 Sprout Road Richland,-Washington 99352 (509) 376-8583 District of Columbia U.S. Department of Energy Freedom of Information Reading Room, Room 1E-190 Forrestal Building 1000 Independence Avenue, SW Washington,'DC 20585 (202) 586-6020 17
, For information on the availability of specific documents and hours of operation, please contact the reading rooms at the telephone numbers'provided.
Issued in Washington, D.C. this d-day of July,1993.
7 ot eter N. Brush Acting Assistant Secretary Environment, Safety and Health
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1 December 27, 1993 President William Clinton 1600 Pennsylvania Avenue, N.W.,
Room 39 Washington, DC 20500 RE:
Proposed LES Uranium Environmental Plant, Claiborne Parish,
- Homer, Louisiana
Dear President Clinton:
I am writing this letter regarding the placement of the abova referenced plant in another minority community in Louisiana.- My family has owned land in this black community for over 75 years.
While thisfplant will be placed adjacent _to our property we.have not been informed or received official notice of its operation.
A lot of the community is made up of senior citizens who own their homes and will be displaced if this plant is put into oper-ation.
i The Office of Nuclear Material Safety and Safeguard has given citizens 45 days or to January 16, 1994 to review the report.
This is insufficient time to review this report.
I am'asking you, President Clinton, and Attorney General Janet Reno to inves-tigate this plant in light of your " Environmental. Justice Policy."
"See attached article."
Thank you for.your attention.
Sincerely yours, e k (l9 Axi -
LL-c LARRY a WILLIAMS, ESO. -
3295 S. Tulare Court.
Denver, CO 80231' (303) 866-5228 (W)
(303 752-2477 (H)
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EXHIBIT (1-.
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President William'Clinton Page 2 Enclosure-cc:
Attorney General Janet Reno U.S. Department of Justice Tenth Street and Constitution Avenue, N.W.
W39hingt65, DC 20530 i
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.On Friday to dW ' ~ Perry speaks - j;,.,,,, ( gg. gggp }. A.tsocutad' ras, " ' ' ' ' sions in the sider racialdisparity acd minor-tms was tol Toxic emis-tion Agency has plehd to con- . Alengthy: f.. D., E50 WASHINGTON-LeRoy Alfred E Pouution area where he ity community impact when ! was end-the Amm, smen an-bnked to ra-lives already making decisions on toxic zine of ger 1i si search remembers when Spanish moss are more than cleanups, health standards, pol-
- Var ended draped the oaks and farms conunentao.
flourished along the Mississippi ,three. times lution fines, hmrdous waste l n Jan. 6. River of his hoyhood. Now a the iiverage in Louisiana, permits and otherinvironmen- . reports that swill. be 1-: ..y sexual allee j 5 and four chemical stench hangs thick in according to government data. talissues. l take part, the night air and the trees and Throughout the country, And President Clinton will chose to rerrs ~ article also r-poor, minority communities sign an executive order early a trooper wa Alfred. 66, has trouble are speaking out, seeking relief
- next year directing other feder.
ta retum for l operation crops are gone. l Il resume breathing, his wife has sinus from what they say is a al agencies to give similar i l l aning Jan. problems and " environmental disproportionate share of the considerationin their decisions, publication o justice" is the t2!k of his rural nation's environmental haz-of6cials said. "Any sugt Congress also is increasing dent offered l l :tnam and hometown, Carville, La. ards.
- : indepen-Asked whether the Their arguments have caught its attention. It held a hearing for silence is i te the one community's racial makeup - the attention of the Clinton ad-last spring on environmental a statement 70% black - is the reason it ministration, which is develop-justice, and some House mem-said Clintor houses 10 chem:c21 phnts, with ing an "envi onmental justice" bets are working on provisions tions about '
I chich the in environmental legislation to ries were f ietnamese net at the prospects for an 11th, Alfred policy. l exchange said, "I may die believc.g C The Ennronmental Protec. address mirority concerns. him," and r were not im; permanent U.S. residency,the Calif., where 130 businesses par-wa:m," Friddell s ud Friday.The hospitalnormally hasIS to 20 >NAI' Hai'ians must prove they face ticipate. women on the maternity fknr but , pe:secuw a ! c. B.a the Cu-i'EST V RGUt is averaging more than 30 now. lg ee:ciN 9 i iV n LSy Memoria! Hospi a. i, m Blizzard spawns baby boom gant wn had 28 babies Friday, up j j - l pennanent ienh:cy a yc2: ma j day r!:c: they ani < g ty u d M %d u W m.g from the average of In j Dec. 2{. I for siv deaths in West Virdnia ery. f tein boat , A h. u n ' c" - .~% s
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!.c. p.4 waM "h . Toxicemis-tion Agencyhas' pledged tofoon. .. Perry speaks sider racialdisparityand minor- ~. Alengthyr ALSO sions in the was end. tions was to l sman an. WASHINGTON-LeRoy Alfred IE Po!!ution area where he ity community irnpact when !st search remembers when Spanish moss linked to ra-lives already making decisions on Wie the Ame Warended draped the oaks and farms are more than cleanups, health standards, r,g. zine of ger CW ! twill-bee flourished along the Mississippi Ahree. times hition fines, hazardous waste conunentary. La Jan. 6. River of hi.s boyhood. Now a the a'verage in Louisiana, permits and other'Environinen-treports that ,,. a.,. ls and four chemical stench hangs thick in according to govemmentdata. talissues, sexual alleg
- take part, the night air and the trees and Thrcughout the country, And President Clinton will chose to rem l operation-crops are gone.
poor, mmority communities sign an executive order early article also r-Alfred, 66, has trouble are speaking out, seeking relief next year dtrectmg other feder-a trooper wa 11 resume breathmg, his wife has sinus from what they say is a al agencies to give similar intetum for
- nning Jan.
problems and " environmental disproportionate share of the considerationin their decisions, publication o justice" is the talk of his rural nation's environmental haz-officials said. "Any sugt
- tnam and hometown,Carville, La.
ards. Congress also is increasing dent offered iindepen-Asked whether the ' Their arguments have caught its attention. It held a hearing forsilenceis le the one community's racial makeup - the attention of the Clinton ad-last spring on environmental a statement khich the 70% black - is the reason it ministration, which is develop-justice, and some House mem-said Clinton ! etnamese houses 10 chemical plants, with ing an " environmental justice" bers are working on provisions tions about - i net at the prospects for an lith, Alfred policy. in environmental legislation to ries were ' exchange said. "1 may die believing it." The Environmental Protec-address minority concerns. him," and were notim; i
- NAk, permanent U.S. residency, the Calit,where 130 businesses par-warm,"Friddell said Friday.The Haitians must prove they face
- ticipate, hospitalnormally has 18to20 '
persecution at home. But the Cu. women on the matemity floor, but fING bans are automnically eligible for WEST VIRGNA is averaging more than 30 now. permanent residency a year and a Blizzard spawns baby boom Ruby Memorial Hospitalin Mor-gantown had 28 babies Friday, up day after they arrive. A blizzard last March was blamed fmm the average of 10. On; 20 for six deaths in West Virginia. fe in boat MW YORK g, _,g g p. beine cred-c
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2. y.. ~ 4 number of th m=nainas still mileareaaroundmyhouse." ' "* violate the tivil' Rights +Act?%'{hliirstdie' we-%11 Guifilid drink La..- To,be,pmr 1s./, exist, draws,for.. tourists. But thebeauty:of the.oncolusl stretch (O tan lith plant,fina!!y.stirre, pla te'
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11ackpeople', - pa , orhik doing,the'MississippiRiverbetween Bs. "to ask the Environmental Protece black, withoutis ttodmuch. ina Rouge and. New Odeans is tion ency to investigate possi ' hazanlous waste landEll'and a ce. in this commuultg work.in those ,'% nc azie h % 17dels is tin in th
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&Mt e aions around.Carville are more state. permitting process-hoping. them m% poor,*.blackJs-muni. mittee'forthe U.Si'Co5 mission on etw N M @k M,:, M[ d. .. ';. that the thelower Mio. v@asR :+ $wDeisel Jrepleoblack:Their :than.three.timeedhe state sver-n.teroperate a' plant.in ne,arby St.. ties?'S AlfredSsk6d.M'If that'stbot>f Civildights tfavestigated tom. c Gabriel to indnerate hasardous racism whatis? We'vejusttraded 'pfs* ts and said it could find no m weg the alsves who age."Ihey call'.us,l'ancer. Alley. oneformofslaveiyforanother." sit %vidence that"p%ifir hafid!ing haz.
- now,". Alfred 'said.'.We-got '100,1*astein n'amentkiln..,%.
'f.' The Clinton aNninhtratioir has - c "At lessTwe'hadifoal, our own -.an1&is'matEriaWCire '*4builttheplanterg'banaalane Their ' e. s..dthese,empts hacama sharecrop *. .n.= [ W' 3 g % ***4.c gardens.(.grty years,,ago,lh % foro., plants be(wse;tt.QM.m 9 pubaggeedt@y,estiga}e,whethergph y.*j ? v ,npoo reasons.
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4L.wd & *Au ':'MfOne.n..tDinese cw11x'asa uscws f.,..Waoasneigow1r .w & ns
- .saks V asu* r*.-..**r.
a i l FOCUSfrom 4a4 thinkins misht be even more.dar.. since the cultural Revoiution. He . g ng.than't!ntlof.Deng.IlaopingswasnarWintely. rocked-by. a i .1 Wp*h(.,.,. .. *.AUang'f He was not a backwaAperson.. ythauecwhocharged him the rela. y Ar.W4;peserght.c}}})e,,' GI* T @4r hy.h r.,172? - '.(.%nmumet outh,I.eague Dang said. ' -' "" * ~ tinly' steep sum of 5 yuan'(90 Over100-E[. small, intimatai fuH of pa The restaurant owner, Tang cents) for what turned out to be a in. gag ..,:.hdartinees, laddlerent to?.their Ruiren..whc, reportedly.h.as be. three-rninute ride. p g 'osehleperture freenMao'sideals-tome a mitunaire frorn a restau- "Shaoshan people used to be a
- Chairman Macg like the sua, rant next door to Mao's birthplace bit naive," U said ruefully. "Now
'~ $#y4}/jI.*%d'i *P 'v 'p,sy -h h heee P ~* P ..(8]Ihd[aB (lUD H8&$(%f][dlf strang. , Eildedas'the i "" " sheM-Mirinr KUke many Chinese,J.i 'ex- -WWhiske'y rAll750 mis. oy W. 5.5 *-! # c.73,.timage. f.the fL"% met n. lismemorr.: m :.talist' My f mity. prosed amsiv*nce asout Mas RadtdIIrant, Just opened by a.
- Tro not a big capi era.
- C
.N gd0 Odard m d' - woman from Mao's hometown.. purpose is to!spreas Mao Tse. " People see it as an ideal time, ) '. A' disco ball Anahnwt orange and tung thought,"'said the 64-year. when people.were more equaland gg B0lla W.C5iswb. m.t 5' beame : ento his earnest
- ok! woman,-who likes to tellvisi
- therewasless crime,".he said.
tors about a bdef encounter with., But U also remembers how he - U n....' fog; mil CaDdib '~=44"
- N. Most el the two dosen young Mao in.1959.*Waalioukt dobusi. and other teen-agers felt used by 4-
+- men and women'at the meeting sess. When we have moecy. our Mao when, after attacidng the still wets their work clothes - willbe richandstrong." party estaldishmenton his orders, jacitets and ties and nice dresses.' U1 orice one of Mao's they were exiled to the country-WlHESPEClal5 WinterfE5! Beer .. that contreet with the plain youthful 6torm troopera, the Red side tolivelike peasanta. W.
- 4 W.clothies%fMaa sb. d 4:*
's.r.:Guardat sold he does?not regard " 'v"I don't love him. Hate'Is too Sahltsbtllyci@~"iw'n10" ~ff0m COOTS r Dang t==iana.e that Mao, who commercialisatios of Mao as strong. Iblame him," said U. "He
- W. NE preached tbe virtue cilifing the disrespectful."It's pragmatic," he is resWie for many of the 005 Dt!Bolsnai m
- 9, ca nt, QQ @W anseern life would said, backwardas ofthecoun KendaH Jackson""*"O-~*"8" met have '
to althv , now assistEnt edito'r la
- Itwould ye been better ~ he mace or theit gathering (a y of an oEicini sensaabe,Esf-had died earlier."
Olateat1Ste.MidneHen,ps.4P9 33 . hernoksbar. - JhwJtseism smnannywentback ta, He added, "Deng's, China is fttZtf5tindfalomuot swe5 ~ ' ' ett' Wee were. alive aos, his Mas'starthpinee forthsSrs(time better.* - _ _o w. -. [ E - %f Ts f.= % e. o
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