6. SPENT NUCLEAR FUEL MANAGEMENT SPECIFIC

6.1 Vulnerabilities

06.01 (002) Vulnerabilities

COMMENT
Commentors express the opinion that spent nuclear fuel is currently stored in poor conditions and that
DOE will not take responsibility for the waste currently existing.  Commentors also state that they do not
trust DOE to manage additional spent nuclear fuel any better in the future, because DOE may not have
learned from the last 40 years of spent nuclear fuel management.
RESPONSE
DOE acknowledges its responsibility to safely manage spent nuclear fuel (SNF).  The Secretary of Energy
has publicly affirmed that current DOE policy and practice emphasize safety and environmental
considerations above other program goals.  DOE is formally committed to protecting the safety and health
of its workers, the public, and the environment.  Furthermore, DOE intends to design, construct, and
operate facilities in a safe manner, relying on lessons learned from the last 40 years of SNF management. 
DOE is working to rectify and eliminate any adverse environmental impacts from past programs.
Problems at existing storage facilities have been identified in the Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Materials and Their Environmental, Safety and Health Vulnerabilities.  This report, called the spent
nuclear fuel vulnerability assessment, and associated action plans to resolve identified vulnerabilities are
acknowledged in Volume 1, section 1.1.2 and Appendix J-2, and Volume 2, section 2.2.5.  Additional
site-specific information is in Volume 1, Appendices A through F.  Environmental consequences of SNF
management are presented for all alternatives in Volume 1, section 5.1, and mitigation measures are
discussed in section 5.7.  For all alternatives analyzed, the impacts of SNF management activities would be
small.

06.01 (005) Vulnerabilities

COMMENT
The commentor states that the EIS fails to acknowledge current problems with spent fuel handling and
storage, and that these problems will continue to be ignored if DOE begins its massive transportation and
concentration program. 
RESPONSE
Problems at existing storage facilities have been identified in the Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Materials and Their Environmental, Safety and Health Vulnerabilities.  This report, commonly referred
to as the spent nuclear fuel vulnerability assessment, and associated action plans to resolve identified
vulnerabilities are acknowledged in Volume 1, sections 1.1.2 and J-2, and Volume 2, section 2.2.5.  
Additional site-specific information is in Volume 1, Appendices A through F.  Environmental
consequences of SNF management are presented for all alternatives in Volume 1, section 5.1, and
mitigation measures are discussed in section 5.7.  For all alternatives analyzed, DOE is committed to
complying with applicable Federal, state, and local regulations and DOE Orders to ensure protection of the
environment and the health and safety of the public and site employees. See also the response to comment
03.05 (024).

06.01 (006) Vulnerabilities

COMMENT
The commentor raises two issues:  (1) the ability of the K-basins to withstand a credible earthquake and (2)
the chemical breakdown of the spent nuclear fuel in the basins.
RESPONSE
The continued management, storage, and chemistry of spent nuclear fuel currently stored at the Hanford
Site will be evaluated in the Hanford Spent Nuclear Fuel Management EIS (tiered from this EIS) and in
the EIS for the Management of Spent Nuclear Fuel from the K-Basins at the Hanford Site, Richland,
Washington.  The EISs will consider both the seismic conditions and the chemistry of the spent nuclear
fuel.

06.01 (008) Vulnerabilities

COMMENT
The commentor states that existing storage conditions for N-Reactor fuels in the Hanford Site K-basins
must be corrected immediately because of degradation from corrosion and hydriding.  
RESPONSE
Descriptions of SNF stored at the Hanford Site and technologies for managing SNF are presented in
Volume 1, section 1.1.  Hanford-specific information on N-Reactor fuel and conditions at the K-basins is
given in Volume 1, Appendix A, section 2.3.  More general information on management options for
degraded SNF and associated management technologies is in Volume 1, Appendix J, sections J-3 and J-4. 
DOE agrees that it is necessary to deal with spent N-Reactor fuel, especially in the 105-KE Basin.  This
situation was prominently identified in the Spent Fuel Working Group Report on Inventory and Storage
of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear Material and Their
Environmental, Safety and Health Vulnerabilities  (called the spent nuclear fuel vulnerability
assessment).  These concerns also are reflected in a June 1994 Tri-Party Agreement to initiate
encapsulation of uncontainerized fuel.  This agreement between the State of Washington, the
Environmental Protection Agency (EPA), and DOE has a target date of December 2002 for removal of
SNF and sludge from the 105-K basins.  See also the response to comment 06.01 (006).

06.01 (009) Vulnerabilities

COMMENT
The commentor requests that the EIS address cleanup of Idaho National Engineering Laboratory
contamination and the safety of existing spent nuclear fuel storage facilities, particularly ICPP-603. 
RESPONSE
The evaluation in Volume 2 of this EIS bounds environmental impacts from environmental restoration (or
cleanup) activities at the Idaho National Engineering Laboratory (INEL).  However, specific decisions
related to cleanup at INEL are generally addressed under an enforceable agreement executed by DOE, the
Environmental Protection Agency (EPA) Region X, and the State of Idaho on December 9, 1991, the
Federal Facility Agreement and Consent Order (FFA/CO).  The FAA/CO establishes a comprehensive
process that integrates the remediation requirements of Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), the corrective action requirements of the Resource
Conservation and Recovery Act (RCRA), and the State of Idaho's Hazardous Waste Management Act. 
Cleanup activities are conducted under the process and schedule established in the FFA/CO.  Records of
Decision (RODs) under the FFA/CO process are signed by all three entities and represent a joint
determination that environmental protection will be achieved through implementation of the selected
remedy.  The FFA/CO's role in INEL's environmental restoration program is discussed in detail in Volume
2, sections 2.2.6 and 7.2.5.
DOE has a program for safely managing and storing SNF and other radioactive materials at each of the sites
considered in the EIS.  It is DOE's policy to design, construct, and operate its facilities in a way that
provides a level of safety and safety assurance that is in accord with applicable Federal, state, and local
regulations and DOE Orders.  DOE will manage SNF in a manner that ensures protection of the
environment and the health and safety of the public and site employees. The potential impacts from storing
radioactive materials associated with SNF are discussed in Volume 1, Chapters 5.  Environmental
consequences of SNF management are presented for all alternatives in Volume 1, section 5.1, and
mitigation measures are discussed in section 5.7.
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be
small.  Problems at existing storage facilities have been identified in Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Material and Their Environmental, Safety and Health Vulnerabilities.  This report, commonly called the
SNF vulnerability assessment, and associated action plans to resolve identified vulnerabilities are
acknowledged in Volume 1, sections 1.1.2 and J-2 of the EIS.  Additional  information is included in
Volume 2, section 2.2.2.

06.01 (011) Vulnerabilities

COMMENT
The commentor asserts that DOE failed to acknowledge the urgency of the vulnerabilities associated with
existing storage facilities at the Hanford Site, as highlighted in the Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Material and Their Environmental, Safety and Health Vulnerabilities, and that the EIS needs to be
modified to include the three specific actions included in the Hanford Federal Facility Agreement and
Consent Order (Tri-Party Agreement) in January 1994. 
RESPONSE
DOE concurs that action is necessary to deal with spent N-Reactor fuel, especially in the 105-KE Basin. 
This situation was prominently identified in the spent nuclear fuel vulnerability assessment.  These
concerns also are reflected in a June 1994 Tri-Party Agreement to initiate encapsulation of uncontainerized
fuel.  This agreement between the State of Washington, EPA, and DOE has a target date of December 2002
for removal of SNF and sludge from the 105-K Basins.  A fourth amendment to the Tri-Party Agreement
(January 1994) contains specific milestones related to managing SNF at the Hanford Site.  Descriptions of
SNF stored at Hanford and technologies for managing SNF are in Volume 1, section 1.1. Hanford-specific
information on N-Reactor fuel and K-basin conditions is given in  Volume 1,  Appendix A, section 2.3. 
More general information on management options for degraded SNF and associated management
technologies is in Volume 1, Appendices J-3 and J-4, respectively. 

06.01 (013) Vulnerabilities

COMMENT
The commentor states that the EIS is based on an unjustified presumption that spent nuclear fuel must be
moved to be stored.
RESPONSE
Volume 1, section 1.1.2 discusses the corrective actions for the SNF vulnerability assessment conducted by
DOE.  Volume 1, section 1.1 of the EIS presents a comprehensive discussion on the options available for
managing SNF, including storing, stabilizing, transporting, and preparing it for final disposition.  Specific
technologies to accomplish these options are discussed in Volume 1, Appendix J.  These options are
incorporated to varying degrees in all of the alternatives, as described in Volume 1, Chapters 3 and 5. 
Volume 1, Figures 3-1 and 3-6 show the number of shipments expected for each alternative, and Figure 3-7
compares estimated shipments among all of the alternatives.  The wide range in shipment numbers reflects
DOE's desire to consider all realistic transportation possibilities and the related stakeholder concerns.  In
addition, the alternatives have definite purposes for relocating SNF, such as storing similar fuel types
within a single secure facility.  Thus, the alternatives attempt to balance transportation concerns with other
worthy considerations, including nonproliferation, worker safety, and cost effectiveness.

06.01 (014) Vulnerabilities

COMMENT
Commentors note that descriptions of alternatives in Volume 1, Tables 3-1 through 3-4 mention the fuel
storage problems at Test Area North but not at other storage facilities at the Idaho National Engineering
Laboratory that were identified as not meeting current standards, such as the fuel in pool storage at
ICPP-603.  The commentor adds that no matter what alternative is selected, fuel should be moved from all
facilities that do not meet current standards. 
RESPONSE
DOE is currently taking steps to correct outdated and potentially unsafe facilities.  Problems at existing
storage facilities have been identified in the Spent Fuel Working Group Report on Inventory and Storage
of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear Material and their
Environmental, Safety and Health Vulnerabilities.  This report, commonly called the SNF vulnerability
assessment, and associated action plans to resolve identified vulnerabilities are acknowledged in Volume 1,
sections 1.1.2 and Appendix J-2 of  the EIS.  Additional site-specific information is presented in Volume 1,
Appendices A through F.  INEL plans to move SNF from ICPP-603 by December 31, 2000, as an interim
action, and the impacts of the action are included in the No Action alternative.  Volume 1, Chapter 5 and
Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of all the alternatives
considered in this EIS.  The analyses show that the impacts of all alternatives would be small.  While there
are differences among the alternatives, these differences by themselves are not sufficient to distinguish
between alternatives.  For all alternatives analyzed, DOE is committed to 
complying with applicable Federal, state, and local regulations and DOE Orders to ensure protection of the
environment and the health and safety of the public and site employees.

06.01 (016) Vulnerabilities

COMMENT
The commentor states that the condition of the spent nuclear fuel and the spent nuclear fuel storage
facilities is not adequately covered in the EIS, and cites specific problems with the spent nuclear fuel and
the K-basins at the Hanford Site.  In addition, the commentor believes that, based on the Spent Fuel
Working Group Report on Inventory and Storage of the Department's Spent Nuclear Fuel and Other
Reactor Irradiated Nuclear Material and Their Environmental, Safety and Health Vulnerabilities, it is
apparent that none of the facilities in the DOE complex is acceptable for the continued storage of existing
inventories of spent nuclear fuel, much less additional fuel from another location.
RESPONSE
DOE believes that the condition of SNF and existing storage facilities, as well as the associated
vulnerabilities, are adequately represented in the EIS.  Problems with the K-basins and other storage
facilities identified in the Spent Fuel Working Group Report on Inventory and Storage of the
Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear Material and Their
Environmental, Safety and Health Vulnerabilities are being addressed by corrective action plans that are
proceeding independently of this EIS.

06.01 (017) Vulnerabilities

COMMENT
The commentor states that it is urgent to address the vulnerabilities at the Hanford Site identified in the
Spent Fuel Working Group Report.
RESPONSE
Descriptions of SNF stored at the Hanford Site and technologies for managing SNF are in Volume 1,
section 1.1.  Hanford-specific information on N-Reactor fuel and K-basin conditions is given in 
Volume 1, Appendix A, section 2.3.  More general information on management options for degraded SNF
and associated management technologies is discussed in Volume 1, Appendix J, sections J-3 and J-4.  DOE
agrees that it is necessary to deal with spent N-Reactor fuel, especially in the 105-KE basin.  This situation
was prominently identified in the spent nuclear fuel vulnerability assessment.  These concerns also are
reflected in a June 1994 Tri-Party Agreement to initiate encapsulation of uncontainerized fuel.  This
agreement between the State of Washington, EPA, and DOE has a target date of December 2002 for
removal of SNF and sludge from the 105-K basins.
Under all alternatives except No Action, production reactor SNF would be removed from its present
storage location.  Volume 1, Appendix A, section 2.3 has been revised to provide additional information
on the Hanford Site vulnerabilities described in the spent nuclear fuel vulnerability assessment of
December 1993.

6.1.1 Working Group Report and Action Plans

06.01.01 (001) Working Group Report and Action Plans

COMMENT
Some commentors state that the safety and health vulnerabilities, some of which have been identified in the
Spent Fuel Working Group Report  have been ignored or are not acknowledged in the EIS, and ask
whether the public had input to the report.  Others ask if the No Action alternative would be used by DOE
as an excuse to avoid its responsibilities for spent nuclear fuel vulnerabilities, and some commentors cited
this as a reason for supporting the No Action alternative.  
RESPONSE
The Spent Fuel Working Group Report on Inventory and Storage of the Department's Spent Nuclear
Fuel and Other Reactor Irradiated Nuclear Material and Their Environmental, Safety and Health
Vulnerabilities  (spent nuclear fuel vulnerability assessment) and associated action plans to resolve
identified vulnerabilities are acknowledged in Volume 1, section 1.1.2 and Appendix J-2, and Volume 2,
section 2.2.5 for INEL.  These sections note that Phase I, Phase II, and Phase III Action Plans have been
released for public comment.  
Additional site-specific information is presented in Volume 1, Appendices A through F.  The
environmental consequences of SNF management are presented for all alternatives in Volume 1, section
5.1, and mitigation measures are discussed in Volume 1, section 5.7.  For all alternatives analyzed, DOE is
committed to comply with applicable Federal, state, and local regulations and DOE Orders to ensure
protection of the environment and the health and safety of the public and site employees.  With the
exception of the No Action alternative, all alternatives fully address the identified vulnerabilities. 
Although the No Action alternative includes actions for safe and secure SNF management, as discussed in
Volume 1, section 5.1.2, the minimal actions allowed by the No Action alternative may not completely
resolve all the long-term vulnerabilities at all existing facilities identified in the SNF vulnerability
assessment, particularly for degraded SNF.  As a result of public comments, additional information on the
vulnerability assessment and corrective action plans and their relationship to this EIS has been added to
Volume 1, Appendices A, C, and F.
For additional discussion on the No Action alternative as it relates to SNF storage, see the response to
comment 06.05 (016).
       

6.2 Existing Facilities

06.02 (002) Existing Facilities

COMMENT
The commentor states that the use of a hypothetical spent nuclear fuel processing project in the EIS is
misleading because DOE started constructing the fuel processing facility at Idaho Chemical Processing
Plant in 1991.
RESPONSE
The hypothetical facility is described in Volume 2, Appendix C, SNF6.  This facility was used to provide a
basis for estimating the impacts of constructing the facility at other sites considered in the EIS.  The project
data sheet states that the existing Fluorinal Dissolution Process (Idaho Chemical Processing Plant Building
601) and Fuel Processing Restoration Project were considered as part of the structure of this hypothetical
project.

II COMMENT

Commentors question where spent nuclear fuel from foreign research reactors would be stored if brought
into the United States, and express concern about the ability of existing spent nuclear fuel storage areas at
Savannah River Site to safely store foreign research reactor spent nuclear fuel, given the current conditions
of spent nuclear fuel storage areas.
RESPONSE
Foreign research reactor (FRR) SNF is discussed in Volume 1, sections 1.1 and 1.2.  DOE has decided to
accept up to 409 SNF elements, which will be stored temporarily at the Savannah River Site.  DOE is
preparing a separate EIS entitled Proposed Nuclear Weapons Nonproliferation Policy Concerning
Foreign Research Reactor Spent Nuclear Fuel (Draft), which will determine whether to accept up to
25,000 additional elements and which port(s) of entry would be used.  Volume 1 of this EIS addresses the
cumulative environmental impacts of managing all DOE FRR SNF through 2035, including the additional
25,000 FRR elements.
Consequently, the impacts associated with FRR SNF are evaluated under the management alternatives
analyzed in Volume 1, along with the DOE SNF generated in the United States.  Problems at existing
storage facilities have been identified in the Spent Fuel Working Group Report on Inventory and Storage
of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear Material and Their
Environmental, Safety and Health Vulnerabilities  (spent nuclear fuel vulnerability assessment).  This
report and associated action plans to resolved identified vulnerabilities are acknowledged in Volume 1,
section 1.1.2 and Appendix J-2.  Additional site-specific information is presented in Volume 1, Appendices
A through F.  As noted in the summary section of Volume 1, on a nationwide or site-specific basis, the
implementation of any of the alternatives would not significantly contribute to cumulative impacts.  The
main storage location(s) Preferred Alternative language for all DOE SNF, including that from foreign
research reactors if the decision is to accept such fuel into this country, will be addressed in the ROD for
this EIS.  For  locations of  foreign research reactors SNF management under DOE's preferred alternative,
see the response to comment  04.04 (008).

II COMMENT

The commentor notes that the EIS emphasizes the use of new facilities and believes that DOE should make
more effective use of existing and currently uncompleted facilities.
RESPONSE
DOE did consider facility usage in its decision-making process for the identification of a preferred
alternative for SNF management.  The alternatives considered in this EIS include those based on using
existing facilities and those based on using new facilities.  To the extent practical, DOE favors using or
modifying existing facilities when safety and environmental considerations would not be compromised and
when such modifications and operations are relatively cost effective.  Although not part of the EIS, a
separate cost report on SNF management has been prepared and identifies the cost difference between
using existing facilities and building new facilities.

II COMMENT

The commentor asks when more effective storage facilities will be available. 
RESPONSE
Following the ROD for this EIS, if the alternative selected requires new storage facilities, DOE will begin
upgrading existing facilities or building new facilities as soon as possible after appropriate National
Environmental Policy Act (NEPA) reviews are performed and funding is available.  A typical construction
schedule for new nuclear facilities is 7 to 10 years.  In the meantime, DOE will continue its program of
safely managing and storing SNF and other radioactive materials at each of the sites 
considered in the EIS.  DOE manages SNF in accordance with applicable Federal, state, and local
regulations and DOE Orders in a manner that ensures protection of the environment and the health and
safety of the public and site employees.

II COMMENT

The commentor states that DOE failed to analyze what it will do when ICPP-666 is full, which could be
long before 2002. 
RESPONSE
DOE analyzed various methods of expanding the storage capacity at INEL to accommodate projected
receipts under each of the alternatives.  The capacity of Building 666 at the Idaho Chemical Processing
Plant (ICPP) can be increased by implementing the Increased Rack Capacity for ICPP-666 Project,
described in Volume 2, Appendix C, SNF2.  This project would extend the ability to receive fuel at
ICPP-666 by several years.  In addition, depending on the alternative selected, additional storage capacity
at INEL could be provided by additional reracking at ICPP-666 [see Volume 2, Appendix C, SNF3,
Additional Increased Rack Capacity (ICPP-666)] or by constructing Project SNF4,  Dry Fuel Storage
Facility: Fuel Receiving, Canning/Characterization, and Shipping (see Volume 2, Appendix C, SNF4).

II COMMENT

The commentor asks if there are sufficient glass containers available at the Savannah River Site to handle
all of the wastes that might be shipped to that site under some of the alternatives considered in the EIS. 
RESPONSE
DOE believes that the commentor is referring to the vitrified (glass) high-level waste logs being produced in
the Savannah River Site Defense Waste Processing Facility.  This facility does not require glass containers,
rather it adds inert materials to the waste materials and melts them into a vitrified form in preparation for
interim storage or disposition.  This technology is not directly applicable to SNF, but to the liquid
high-level waste produced from processing SNF.  Detailed information on this activity is available in the
Supplemental EIS - Defense Waste Processing Facility, Savannah River Site.

II COMMENT

The commentor notes that, while the EIS states that spent nuclear fuel is stored in water pools or
above-grade dry storage, there is some spent nuclear fuel in below-grade dry storage at the Idaho Chemical
Processing Plant at the Idaho National Engineering Laboratory.
RESPONSE
Some SNF is stored in below-grade dry storage at ICPP.  Volume 1, section 5.8.3 has been changed to
clearly include isolation from the environment in below-grade dry storage.

II COMMENT

The commentor identifies specific safety issues associated with the continued management, storage, and
chemistry of spent nuclear fuel, principally N-Reactor fuel, currently stored at the Hanford Site, or suggests
continued wet storage for N-Reactor fuel.
RESPONSE
DOE has fully evaluated the safety issues associated with SNF management at the Hanford Site and other
DOE sites and reported the results of this evaluation in the Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Materials and Their Environmental, Safety and Health Vulnerabilities.  This EIS evaluates the impacts
associated with SNF management at Hanford, including normal emissions and accidental releases and has
found that they would be small.  The continued management, storage, and chemistry of SNF currently
stored at Hanford will be evaluated in the Hanford-specific NEPA reviews.  One such NEPA review is
being prepared for the transfer of fuel from the K-basins.  
Appendix A has been revised to reflect the proposed path forward for the K-basins.

II COMMENT

The commentor expresses an opinion that DOE is currently storing "other spent fuel high-level nuclear
waste" at the Hanford Site in illegal "once-through" cooling pools that discharge water directly into already
contaminated soils and flush contaminants into the Columbia River.
RESPONSE
Storing SNF in basins is not illegal;  the SNF storage basins do not use "once-through" cooling.  The spent
nuclear fuel vulnerability assessment fully describes SNF at Hanford and identifies vulnerabilities
associated with this storage.  Eight of the Hanford production reactors, all of which have been retired, did
use "once-through" cooling systems.  Direct discharges to the Columbia River from the K-basins are in
accordance with an existing, legal National Pollutant Discharge Elimination System permit.  Appropriate
measures are being taken to isolate from the rest of the basin a known area in the K-East basin where leaks
to the ground have occurred.

II COMMENT

The commentor raises an issue about the numerical designation of a specific spent nuclear fuel storage
facility.
RESPONSE
The numerical designation of the facility in question is of no intended significance.  

II COMMENT

The commentor states that the spent fuel capacity, which could be provided by the reracking of the High
Flux Isotope Reactor at the Oak Ridge Reservation, is not addressed in the EIS.
RESPONSE
A discussion of the SNF management program at the Oak Ridge Reservation (ORR) is in Volume 1,
Appendix F, Part Three, section 2.3.

II COMMENT

Commentors suggest that the discussion of transuranic waste in Volume 1, Appendix F, Part Three does
not explain how or why the waste is generated.  Commentors also question whether the Oak Ridge
Reservation has facilities capable of handling more waste than is obligated by present programs.
RESPONSE
Small quantities of radioactive wastes, including transuranic wastes, would usually be generated during
some fuel stabilization activities.  The quantities identified in Volume 1, Appendix F, Part Three are
estimates of the maximum amount that could be generated from these activities.  Actual quantities
generated are likely to be smaller.  A discussion of transuranic wastes is presented in the EIS in 
Volume 1, section 3.3.4.  Additional information about waste generation can be found in the reference,
F-Team Final Report.  This report is available in reading rooms and information locations listed in the
EIS.
SNF management generates low-level waste.  For ORR, this is described in Volume 1, Appendix F, Part
Three, section 5.14.2, which states that low-level waste generated by SNF management activities under the
wet-storage option is estimated at 7,800 cubic meters, and the dry storage option would generate
significantly less.  This section shows that ORR has a capacity for storing low-level liquid waste of about
98,300 cubic meters.  The addition of 7,800 cubic meters would not significantly impact the capacity or
the decisions associated with low-level waste management at ORR.
SNF management  also generates small amounts of transuranic waste, although transuranic waste is not
shipped to ORR, as commentors' remarks imply.  This is discussed in Volume 1, Appendix F, Part Three,
section 5.14.2, which states that transuranic waste generated by SNF management activities would be
shipped directly to the Waste Isolation Pilot Plant, if it is available.  If the Waste Isolation Pilot Plant is not
available,  ORR transuranic management capacity would be evaluated, including options for additional
storage.

II COMMENT

Commentors state that reactor-irradiated nuclear materials are currently stored in poor conditions, cite
some examples of the vulnerabilities at Idaho National Engineering Laboratory from the Spent Fuel
Working Group Report  and express the opinion that DOE may not manage additional spent nuclear fuel
any better in the future.
RESPONSE
Problems at existing SNF storage facilities have been identified in the Spent Fuel Working Group Report
on Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Materials and their Environmental, Safety and Health Vulnerabilities.  This DOE report, also called the
vulnerability assessment, and associated action plans to resolve identified vulnerabilities are acknowledged
in Volume 1, sections 1.1.2 and Appendix J-2, and Volume 2, section 2.2.5.  Additional site-specific
information is in Volume 1, Appendices A through F.  Environmental consequences of SNF management
are presented for all alternatives in Volume 1, section 5.1, and mitigation measures are discussed in
Volume 1, section 5.7.  For all alternatives analyzed, DOE is committed to comply with applicable
Federal, state, and local regulations and DOE Orders to ensure protection of the environment and the
health and safety of the public and site employees.
The Secretary of Energy has publicly affirmed that current DOE policy and practice emphasize safety and
environmental considerations above other program goals.  DOE is committed to protecting the safety and
health of its workers, the public, and the environment.  Furthermore, DOE intends to design, construct, and
operate facilities in such a way as to provide a level of safety equal to or better than that associated with
the operation of commercial facilities.  DOE is working as quickly as possible to rectify and eliminate
adverse environmental impacts from past programs.
Immediate actions to correct any possible unsafe storage practices and to address SNF vulnerabilities
include transfer of SNF from the Underwater Fuel Storage Facility at ICPP-603 and other facilities to new,
more modern facilities at ICPP-666.  These actions also involve inspection and canning of corroded fuels. 
Volume 2, Table 2.2-1 lists specific corrective actions and schedules to address SNF vulnerabilities at
INEL.

II COMMENT

The commentor asserts that DOE has not demonstrated that safe storage methods are available; that DOE
kept secret the fact that spent nuclear fuel storage areas at ICPP-603 had been unsafely storing spent
nuclear fuel; that only after a whistleblower gave this information to the State was it admitted by DOE; and
that transfers of spent nuclear fuel from ICPP-603 at the Idaho National Engineering Laboratory may not
be as safe or as quick as projected.
RESPONSE
DOE is taking the actions necessary to ensure safe SNF storage, including the SNF currently being
transferred from ICPP-603.  In the absence of substantiation of the commentor's assertion, DOE has no
reason to question the safety or speed of the transfers from ICPP-603 or the requirements that ensure
safety.  DOE has aggressively identified and disseminated information about the vulnerabilities and
deficiencies of its SNF management facilities.
See the response to comment 06.02 (015) for more information on vulnerabilities associated with SNF
storage.

II COMMENT

Commentors state that DOE should reconstruct all existing facilities at the Idaho National Engineering
Laboratory that do not comply with the current design standards, such as those for seismic and
confinement requirements.
RESPONSE
DOE Order 5480.28, Natural Phenomena Hazards Mitigation, sets forth DOE policy for designing,
constructing, and operating DOE facilities so that workers, the general public, and the environment are
protected from the impacts of natural phenomena hazards on DOE facilities.  This Order specifically
requires facilities to be reevaluated when there is any change in design and construction standards. 
Additionally, in accordance with DOE Order 5480.23, Nuclear Safety Analysis Reports, existing facilities
at INEL are required to undergo periodic safety analyses, including seismic and confinement design
reviews.  When appropriate, design modifications are made.  Besides design modifications, DOE uses
emergency preparedness plans and administrative controls to minimize potential hazards.
INEL reactors and confinement structures meet requirements as outlined in their safety analysis reports,
safety evaluation reviews, and safety basis documents.  These reviews show that potential impacts at the
site boundary are within regulatory limits.  Engineered barriers are designed for operations that have a
potentially high impact or high probability of occurrence.
The seismic analyses, which have been completed for some facilities at INEL, show that most facilities are
adequate to meet current earthquake standards.  For facilities that do not meet current standards, corrective
actions have been identified and implemented.  As an example, DOE is taking action to transfer spent
nuclear fuels from potentially vulnerable facilities to modern facilities.  Further, several of the projects
described in Volume 2, Appendix C are proposed by DOE to replace or upgrade existing facilities at INEL. 

II COMMENT

The commentor states that long-term radiation exposure has compromised spent nuclear fuel confinement
barriers in Savannah River Site canyons by changing the concrete into a spongy substance.  Additionally,
the commentor requests that DOE identify the canyon confinement boundaries and those conditions that
will ensure their safe maintenance.
RESPONSE
Periodic inspections of Savannah River Site canyons reveal some erosion of interior surfaces due to
long-term exposure to acids and bases.  This erosion, or etching, has left the surface with a pitted or spongy
appearance.  Tests have shown this to be only a surface phenomenon that does not compromise the
structural integrity of the 4- to 5-foot-thick concrete confinement barriers.

II COMMENT

Commentors state that DOE has failed to recognize in the EIS the problems with existing storage facilities,
such as compliance with environmental laws and safety requirements, and question whether the
vulnerabilities identified in the Spent Fuel Working Group Report will be addressed adequately.  One
commentor notes that the U.S. District Court ordered immediate action to mitigate unsafe storage practices
at the Idaho National Engineering Laboratory.
RESPONSE
As noted by the commentors, DOE prepared a report on vulnerabilities of the current program and has
been directed by the Secretary of Energy to develop an integrated, long-term SNF program.  The SNF
vulnerability assessment and associated action plans to resolve identified vulnerabilities are 
acknowledged in Volume 1, section 1.1.2 and Appendix J, and Volume 2, section 2.2.5.   Additional
site-specific information is in Volume 1, Appendices A through F.  Environmental consequences of SNF
management for all alternatives are discussed in Volume 1, section 5.1, and mitigation measures are
discussed in Volume 1, section 5.7.  For all alternatives analyzed, DOE is committed to meeting applicable
Federal, state, and local requirements and DOE Orders to ensure protection of the environment and the
health and safety of the public and site employees.  However, under the No Action alternative, the
minimum actions deemed necessary for the continued safe management of SNF would be implemented.
Action has been taken at INEL to correct any possible unsafe storage practices, including transfer of SNF
from the Underwater Fuel Storage Facility and other facilities into more modern facilities, as well as
inspection and canning of corroded fuel.  However, the U.S. District Court did not order that immediate
action be taken to mitigate unsafe storage practices at INEL.

II COMMENT

The commentor asks why Volume 1, Table 1-2 lists only 45 non-DOE facilities, while the text talks about
55 such facilities.
RESPONSE
There are a total of 57 non-DOE facilities representing domestic, licensed, small generators of SNF.  The
45 facilities identified in Volume 1, Table 1-2, Appendix E, Table 2.1-1 are non-DOE facilities that may
contribute to projected SNF inventories during the next 40 years.  The EIS has been revised to make this
distinction.

II COMMENT

The commentor requests that the word "proposed" be deleted from Volume 1, Appendix E, section 3.3
with regard to the  Fort St. Vrain Independent Spent Fuel Storage Installation, because the facility is in
operation.
RESPONSE
The requested changes have been made.

II COMMENT

The commentor suggests that a reference to Las Vegas being 80 kilometers to the east of the Nevada Test
Site is incorrect and should be deleted.
RESPONSE
The sentence intended to infer that the Union Pacific railroad is near Las Vegas,  not the Nevada Test Site. 
The EIS has been clarified.

II COMMENT

The commentor identifies three issues related to the transfer of fuel between the K-basins at the Hanford
Site.
RESPONSE
Volume 1, Appendix A, section 3.1 and Attachment A discuss basin storage at the Hanford K-basins.  The
potential for an inadvertent criticality related to this transfer has been considered (Smith, G. L., 1991,
Westinghouse Hanford Company, Richland, Washington, internal memorandum to J. P. Schmidt,
Westinghouse Hanford Company,  Richland, Washington, Consequences Analyses of Hypothetical
K-Basin Accident Scenarios, 105 KE/KW Accident Liquid Discharge, August 14; and Monthey, M. J.,
1993, Engineering Study of the Transfer of Irradiated Fuels on the Hanford Site, WHC-SD-TP-ES-001,
Rev. 0, Westinghouse Hanford Company, Richland, Washington).  The details provided in Volume 1,
Appendix A, section 3.1 and Attachment A are adequate for the evaluation and comparison of alternatives
in this programmatic EIS.

II COMMENT

The commentor requests more information concerning near-term plans for the Hanford Site K-basin fuels.
RESPONSE
The EIS evaluates five alternatives for SNF interim management over a 40-year period.  Near-term actions
for any specific SNF management location will be the subject of site-specific NEPA evaluations.
Volume 1, Appendix A, section 2.3 has been revised to provide additional information on the current
status of K-basin fuel.  Additional information concerning foreign processing of N-Reactor fuel was added
to Volume 1, section 3.2.5 and Appendix A.

II COMMENT

The commentor suggests that removal of all fuel from pool storage at ICPP-603 by December 31, 2000, at
the Idaho National Engineering Laboratory be added as a project in Volume 1, Appendix B, Table 3-2
(potential spent nuclear fuel projects for each alternative).
RESPONSE
On-site SNF movement is under-way.  This activity is considered part of normal SNF management and is
not considered a potential activity.

II COMMENT

The commentor requests that the EIS provide information on the capacity of ICPP-666 following each of
the rerack projects and a comparison of the capacities to the amount of SNF expected at the Idaho National
Engineering Laboratory under the Ten-Year Plan alternative and the Maximum Treatment, Storage, and
Disposal alternative.
RESPONSE
The EIS has been modified to incorporate the requested information.  Specific changes are found in
Volume 2, Appendix C, Projects SNF2, Increased Rack Capacity for ICPP-666, and SNF3, Additional
Increased Rack Capacity (ICPP-666).  The comparison to the amount of SNF expected under the Ten-Year
Plan alternative and the Maximum Treatment, Storage, and  Disposal alternative is provided in Volume 2,
section 3.1.1.  The EIS has been changed to compare rack capacity and projected inventories under the
various alternatives.

II COMMENT

The commentor states  that the short-term impacts of the transfer of spent nuclear fuel from ICPP-603 to
other facilities are not addressed in the EIS.
RESPONSE
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be
small.

II COMMENT

The commentor notes that there has been nuclear waste stored at the Idaho National Engineering
Laboratory for the past 40 years, which was not intended to be long-term storage, but expresses the
opinion that this does not justify adding additional waste, and that possibly all of it should be moved.
RESPONSE
Volume 2, Chapter 5 and Volume 1, Appendix D discuss the impacts of waste management on INEL and
SNF management, respectively.  These impacts would be small under all the alternatives considered in the
EIS.

II COMMENT

The commentor states that the safety of existing technologies and facilities has been demonstrated for
decades.  
RESPONSE
This comment is consistent with the EIS, which shows environmental impacts from all the alternatives
considered would be small.

II COMMENT

The commentor states that the EIS does not adequately address spent nuclear fuel facilities and requests
that specific information such as layout plans, design standards, proposed safety measures, and
environmental monitoring plans be added.  Additionally, the commentor states that use of existing facilities
is unacceptable because the 40-year project lifetime exceeds the design lifetime of the facilities.
RESPONSE
This is a programmatic EIS to aid in making programmatic decisions for SNF management.  As such, it
evaluates the general technologies and types of facilities required under the different alternatives.  The
specific information requested by the commentor will be developed as part of the implementation of the
programmatic decisions.  The information would be available in later facility-specific NEPA reviews,
permit applications and design documents.
DOE recognizes the commentor's concern regarding facility design life.  DOE is taking steps to evaluate
facility design lives and taking appropriate action to upgrade facilities to safely extend their lives or to
replace facilities that cannot be upgraded.

II COMMENT

The commentor believes that releases due to degrading cladding have been calculated, and should be used.
RESPONSE
Volume 1, Appendix A of the EIS has been modified to include an evaluation of the risks identified by the
commentor.

II COMMENT

The commentor questions the capacity of K-basins to combine 105-KE and 105-KW volumes.
RESPONSE
The footnote for Volume 1, Appendix A, Table 3-2 has been changed to clarify the capacities of the
K-basins with reracking.
       

II 6.3 Inventories (amount and characteristics)

II 06.03 (001) Inventories (amount and characteristics)

COMMENT
The commentor notes an apparent discrepancy between Volume 1, Table 1-1, which states that there is no
existing foreign research reactor spent nuclear fuel in the United States, and the Foreign Research Reactor
EIS Implementation Plan, which addresses 15,000 elements of foreign research reactor spent nuclear fuel. 
RESPONSE
The Volume 1, Table 1-1 column headed "Existing" refers to SNF currently managed by DOE at DOE
facilities.  Until received in the United States,  FRR SNF is not managed by DOE and is not considered
part of the existing inventory.  Although the Implementation Plan for the EIS on the Proposed Nuclear
Weapons Nonproliferation Policy Concerning Foreign Research Reactor Spent Nuclear Fuel refers to
15,000 elements of  FRR SNF that would be eligible for return to the United States for management by
DOE in the event FRR SNF acceptance policy is renewed, the revised Implementation Plan refers to
25,000 elements of FRR SNF eligible for return to the United States.  These elements are not currently in
the United States or managed by DOE except for fuel shipments returned under the Environmental
Assessment of Urgent-Relief Acceptance of Foreign Research Reactor Spent Nuclear Fuel (Draft).

II 06.03 (002) Inventories (amount and characteristics)

COMMENT
The commentor states that DOE refers to approximately 290 metric tons of heavy metal instead of
approximately 1,200 metric tons of spent nuclear fuel at the Idaho National Engineering Laboratory. 
RESPONSE
The 290 metric tons of heavy metal (MTHM) and 1,200 metric tons (total assembly weight) of SNF that
DOE currently manages at INEL refer to the same amount of material and are consistent.  DOE uses the
heavy metal content of SNF as a common measure of the amount of fuel matrix in a fuel element.  This is
done to provide a standard of comparison among fuel types.  Fuel elements vary widely in the amount of
structural material in relation to the amount of fuel matrix associated with them.  The amount of structural
materials removed prior to storage may depend on fuel type.  MTHM provides a uniform basis for
measuring of quantity, irrespective of the structure of the fuel element.  DOE recognizes and manages the
structural material, either as an integral part of the fuel element, or as a separate material, as appropriate.

II 06.03 (003) Inventories (amount and characteristics)

COMMENT
The commentor states that the Kema Suspension Reactor Fuel is not addressed in the EIS.
RESPONSE
At the time the Draft EIS was prepared, the Kema Suspension Reactor Fuel was not on the SNF Inventory. 
Subsequently, the fuel was placed on the inventory.  The EIS has been modified to address this fuel.  A
discussion of the SNF management program at ORR, where the Kema Suspension Reactor SNF is stored,
can be found in Volume 1, Appendix F, Part Three, section 2.3. 

II 06.03 (004) Inventories (amount and characteristics)

COMMENT
The commentor points out that Volume 1, Appendix B states that there is no DOE production reactor fuel
stored in Idaho.  Volume 1, Appendix B, Table 2-2 indicates production fuel is stored at the Idaho
Chemical Processing Plant. The commentor suggests  resolving this apparent discrepancy.
RESPONSE
The ICPP does not store production reactor fuel, but only stores other aluminum-clad fuel from the
Savannah River Site, as referenced in Volume 1, Appendix B, Table 2-2.

II 06.03 (005) Inventories (amount and characteristics)

COMMENT
The commentor notes that in Volume 1, Table 1-8, the spent nuclear fuel inventory at the Oak Ridge
Reservation is 3.02 metric tons of heavy metal and in section 1.1 the inventory is stated to be 2 metric tons
of heavy metal and requests clarification.
RESPONSE
The correct SNF inventory at ORR is 3.02 MTHM.  The inventory number in Volume 1, section 1.1 has
been corrected to 3.02 MTHM.

II 06.03 (006) Inventories (amount and characteristics)

COMMENT
The commentor notes that Volume 1,  Appendix B, Table 2-2 indicates that graphite fuels are stored
underwater in ICPP-603 and believes that this is not correct.
RESPONSE
The commentor is correct.  Graphite fuels, such as Fort St. Vrain SNF, are not stored underwater in
ICPP-603; they are stored dry in the Irradiated Fuel Storage Facility, a separate portion of the ICPP-603
facility.  This error has been corrected in the EIS.

II 06.03 (008) Inventories (amount and characteristics)

COMMENT
The commentor requests spent nuclear fuel inventory information, including fuel type, for all Idaho
National Engineering Laboratory storage facilities.
RESPONSE
The primary INEL SNF storage facilities, the types of fuel stored, and the stored configurations are
presented in Volume 1, Appendix B, Table 2-2, and the relative properties of SNF at those facilities in
metric tons of heavy metal is presented in Volume 1, Appendix B, Figure 2-2.  Additional information is
available in Volume 1.  This document, T. Wichmann letter, Subject Spent Nuclear Fuel Inventory Data," 
is available at any of the reading rooms and information locations listed in the Volume 1 Summary.  See
also the response to comment 06.03 (013).

II 06.03 (009) Inventories (amount and characteristics)

COMMENT
The commentor identifies an apparent discrepancy between Idaho National Engineering Laboratory spent
nuclear fuel quantities in the EIS (288.68 metric tons of heavy metal) and those given in a presentation to
INEL Site-Specific Advisory Board (266.55 metric tons of heavy metal).  The commentor requests
clarification, particularly with respect to the fuel rods identified in the 1989 Radioactive Waste
Management Information System as having been shipped to the Radioactive Waste Management Complex
for disposal. 
RESPONSE
Both numbers are correct in the context in which they are given.  The presentation to the Site-Specific
Advisory Board reflects the inventory as of approximately January 1994, and excludes 17.81 MTHM that
were in the Experimental Breeder Reactor-II (EBR-II) at the time.  (Nuclear fuel is not considered to be
SNF until it has been discharged from a reactor after irradiation.)  The number given in the EIS is a June
1994 estimate that reflects the projected inventory as of July 1995.  This projected inventory includes the
EBR-II, fuel, as well as approximately 4 MTHM of other fuels.  These other fuels consist of  internal
receipts from other INEL reactors and the 19 Naval shipments allowed under the modified Court Order. 
The fuel rods identified in the 1989 Radioactive Waste Management Information System are not included
in this inventory because no positive determination has been made that they exist.  Regardless, disposition
of these materials will be resolved by the CERCLA action proposed for the Radioactive Waste
Management Complex.

II 06.03 (010) Inventories (amount and characteristics)

COMMENT
The commentor identifies specific inaccuracies in the EIS dealing with the number of Fort St. Vrain fuel
elements that are in storage and that would be transferred to DOE under the agreement, and recommends
that the inaccuracies be corrected.  
RESPONSE
DOE revised the EIS in response to this comment.

II 06.03 (011) Inventories (amount and characteristics)

COMMENT
The commentor notes that the EIS incorrectly states that facilities on the Oak Ridge Reservation do not
generate or manage spent nuclear fuel, high-level waste, or transuranic waste.
RESPONSE
ORR does generate and manage SNF and transuranic waste.  A discussion of SNF generation and storage at
ORR is presented in the EIS in Volume 1, Appendix F, Part Three, section 2.2.  Volume 1 of the EIS has
been modified to correct the statement about generation and storage of SNF and transuranic waste.  A
discussion of past generation activities at ORR is beyond the scope of this EIS.

II 06.03 (013) Inventories (amount and characteristics)

COMMENT
The commentor requests that considerably more detail be added to Volume 1, Table 1.1 to more fully
characterize the DOE spent nuclear fuel inventory.
RESPONSE
The level of detail requested for SNF characterization is not available in all instances; furthermore, such
detail is not essential for a programmatic NEPA document.  However, some additional characteristics of the
SNF are provided in each site appendix.  For example, see Volume 1, Appendix F, Part Three, section 2.3. 
Additional storage condition characterization can be found in the Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Materials and Their Environmental, Safety and Health Vulnerabilities, which is referenced in the EIS.

II 06.03 (014) Inventories (amount and characteristics)

COMMENT
The commentor raises questions about complete reliance on high-efficiency particulate air filters for
preventing emissions of radioactive particulates.
RESPONSE
To minimize airborne releases, projects at INEL involving radioactive particulates would take place within
a double-confinement structure.  Conservative assumptions normally are used to estimate releases to the
atmosphere, such as modeling only two filters in series when at least three are planned for actual
operations.  Also, although high-efficiency particulate air (HEPA) filters have established particulate
removal efficiencies of 99.97 percent (down to diameters of 0.3 micrometers), a conservative efficiency
factor of only 99 percent typically is used for operational safety and accident analyses.  These filters are
capable of removing particles as small as 0.001 micrometers from an airstream, but the manufacturer
performs the rating calibration at 0.3 micrometers using a standard aerosol-generating device.  The filters
are tested annually and inspected daily to ensure that their efficiency is maintained.  
Safety analyses for forthcoming INEL facility operations will not assume perfect HEPA filter operation.
Additional precautions will be taken to minimize airborne releases.  The pressure differential across each
filter is measured continuously to detect the formation of any holes or insecure filter installation.  Filter
temperature will be measured to promptly detect a filter fire.  
Finally, radiation sensors will be installed downstream of the filters to continuously monitor atmospheric
releases.  Detection of radioactive particulates above the natural background levels would result in a
prompt shutdown of facility operations. 

II II COMMENT

The commentor emphasizes that spent nuclear fuel should be classified as waste.
RESPONSE
The status of SNF is addressed in Volume 1, section 7.2.5.   Historically, SNF was reprocessed to recover
valuable products and fissionable materials.  As a recycled material, SNF is not considered a solid waste
under RCRA.  Since April 1992, however, DOE's focus on most of its SNF has changed to storage and
ultimate disposition.  This has created some uncertainty with regard to the regulatory status of some DOE
SNF.  DOE has initiated discussions with EPA, along with state regulators, about whether some SNF
should be designated as a waste, and about the potential applicability of RCRA to some of its SNF.  Until
decisions are made about which additional requirements might apply, SNF is still distinct from solid waste
materials.

II COMMENT

The commentor states that the EIS does not include substantial quantities of spent nuclear fuel that DOE
manages and references the National Academy of Sciences recommendation to manage materials that could
be generated from DOE's weapons-grade fissile materials program to an "SNF Standard."  The commentor
also states that the EIS does not include the recent purchase of 500 metric tons of highly enriched uranium
from dismantled nuclear weapons from the former USSR.  The commentor is of the 
opinion that a programmatic EIS not including these potential sources of spent nuclear fuel underestimates
the risks and other impacts and prevents meaningful evaluations of alternatives.
RESPONSE
The scope of the programmatic SNF portion of this EIS, described in Volume 1, section 1.3, is management
of DOE SNF in a safe and environmentally sound manner until decisions regarding its ultimate disposition
are made and implemented.  For the purpose of this EIS (as described in the 
Volume 1 Summary), SNF is essentially defined as fuel that has been withdrawn from a nuclear reactor
following irradiation, the constituent elements of which have not been separated.  SNF inventory also
includes uranium/neptunium target material, blanket subassemblies, pieces of fuel, and debris.  DOE's SNF
responsibilities, which are addressed in this EIS, include all current or reasonably foreseeable fuel
generated by DOE production, research, and development reactors; Naval reactors; university reactors
(both domestic and possibly foreign of U.S. origin); and some special-case commercial SNF, such as core
rubble from the Three Mile Island Unit 2 reactor.  
Materials that would be generated from the DOE weapons-usable fissile materials program, including
uranium from dismantled nuclear weapons, are outside the scope of this EIS.  These materials, otherwise
known as special nuclear materials, are being addressed in the Storage and Disposition of
Weapons-Usable Fissile Materials Programmatic Environmental Impact Statement, which is currently
being prepared.  Special nuclear material is defined as (a) plutonium or uranium enriched in the isotope
233 or 235, and any other material that the Nuclear Regulatory Commission, pursuant to the provisions of
the Atomic Energy Act of 1954, Section 51, determines to be special nuclear material; or (b) any material
artificially enriched by any of the foregoing, but which does not include source material.  
The above definitions are contained in Volume 1, Appendix H of the EIS.  There are distinct differences
between the management of SNF and special nuclear materials, such as the level of safeguards and security
required.  

II II COMMENT

The commentor expresses the belief that Navy spent nuclear fuel is probably more stable than other spent
nuclear fuel that DOE manages, such as graphite and aluminum spent nuclear fuel, and is thankful that
Naval fuel represents a substantial portion of DOE's spent nuclear fuel, because the radioactive materials
present in spent nuclear fuel will outlast the cladding and the temporary storage facility.  
RESPONSE
DOE agrees that because of the robust nature of Navy SNF, it is more stable and easier to store than the
graphite and aluminum fuels.  However, as described in Volume 1, section 1.1.3 and Appendix J, all types
of Navy and DOE fuels will be stored safely until ultimate disposition is decided.  For more information on
amounts and descriptions of SNF, refer to Volume 1, section 1.1.2 and site-specific Appendices A through
F.

II COMMENT

The commentor contends that the EIS is flawed because it does not indicate that transfer of partly corroded
spent fuel is a new venture by DOE, is untested, and may prove to be unsafe.
RESPONSE
DOE has substantial experience with handling and transferring SNF, including some corroded and
otherwise damaged fuel.  Transfers have been accomplished safely, and appropriate measures would be
taken to similarly ensure the safety of future transfers, such as placing the corroded fuel in suitable
containers.  DOE also has safety analysis systems in place to ensure that the risks of its activities are
understood and appropriately minimized.  All transfers are conducted in accordance with the safety
analysis requirements.

II COMMENT

The commentor identifies safety concerns related to handling metal fuels.
RESPONSE
The potential impacts from storage of radioactive materials associated with SNF are discussed in 
Volume 1, Chapter 5.  The impacts of transporting SNF are also discussed in Volume 1, Chapter 5.  The
environmental consequences of managing SNF, including metal fuels, are presented for all alternatives in
Volume 1, section 5.1, and mitigation measures are discussed in Volume 1, section 5.7.   Additional details
on the management of metallic SNF are provided in the site-specific appendices to Volume 1.  
DOE has a program to safely manage, transport, and store all types of SNF and other radioactive materials
at each of the sites considered in the EIS.
       

II 6.4 Technologies

II COMMENT

Commentors recommend several strategies for spent nuclear fuel management, as well as potential
technologies for the storing, stabilizing, and treating spent nuclear fuel.  
RESPONSE
Some of the management strategies and technologies recommended by commentors are already being
actively pursued by DOE, while others are currently speculative and require additional research to
determine their effectiveness for managing SNF.  Volume 1, section 1.1 presents a comprehensive
discussion of the options available for managing SNF, including storage, stabilization, transportation, and
preparation for final disposition.  Specific technologies to accomplish these options are discussed in
Volume 1, Appendix J.

II COMMENT

The commentor questions what techniques are being developed to ensure safe, long-term storage of nuclear
waste so it cannot be used again.
RESPONSE
Numerous technologies are already available for managing radioactive materials, and others are being
actively developed for this purpose.  Technological options for managing of SNF are described in Volume
1, section 1.1.3 and Appendix J of the EIS.  Current management practices for all types of radioactive
wastes are discussed in Volume 2, section 2.2.7, and technology development activities are described in
Volume 2, section 3.1.  Volume 2 is specific to INEL, but waste management technologies also generally
apply to other DOE sites.

II COMMENT

The commentor proposes on-site disposition of spent nuclear fuel using technology involving Tela coils.
RESPONSE
DOE is unaware of any technology involving Tela coils that would be of practical benefit in managing
SNF.  Technologies currently available are summarized in Volume 1, Appendix J.  Development of future
technologies for managing SNF is beyond the scope of this EIS, and will be subjected to additional NEPA
review prior to implementation.

II COMMENT

The commentor supports technology development if it results in recycling fuel and ensuring safer long-term
storage.
RESPONSE
Numerous technologies are available for managing radioactive materials, and others are being actively
developed for this purpose.  Technological options for managing SNF are described in Volume 1, section
1.1.3 and Appendix J.  Current management practices for all types of radioactive wastes are discussed in
Volume 2, section 2.2.7, and technology development activities are described in Volume 2, section 3.1. 
Volume 2 is specific to INEL, but waste management technologies also generally apply to other DOE sites. 
DOE is committed to comply with all applicable Federal, state, and local regulations and DOE Orders.  All
radioactive materials will be managed to protect the environment and the health and safety of the public
and site employees.

II COMMENT

The commentor expresses the opinion that the "solution" to nuclear waste is the ceramic glass encasement
technology and that this technology should be at Hoquiam and Aberdeen, Washington.
RESPONSE
Technologies for the encapsulation of high-level waste in ceramic or glass logs are being considered for
immobilization of such wastes at a number of locations, including INEL's  proposed Waste Immobilization
Facility.  DOE does not currently consider it reasonable to locate such facilities at other DOE sites. 
Location of similar facilities at sites other than INEL is beyond the scope of this EIS.  In addition, Volume
1, Appendix J of the EIS describes technologies that are considered reasonable for SNF management at the
present time.

II COMMENT

The commentor states that the EIS merely describes potential technologies for processing spent nuclear
fuel and does not analyze their potential consequences.
RESPONSE
Volume 1, section 1.1 discusses DOE's plan to develop an integrated, long-term SNF program.  The
discussion also points out a number of actions that prevent DOE from making all decisions regarding SNF
management for the next 40 years at this time.  These actions include characterization of certain types of
SNF and lack of acceptance criteria for ultimate disposition.
There are more than 90 types of DOE SNF, and any spent fuel that is to be disposed of in a geologic
repository must first be characterized under an approved quality assurance program.  This characterization
database would be used to evaluate each fuel type to determine the extent of conditioning, if any,
necessary to meet repository waste acceptance criteria.
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be
small.

II COMMENT

Commentors recommend a particular technology that they believe would be beneficial for the management
or disposition of spent nuclear fuel, specifically alternative fuel processing methods, such as the work being
conducted at Argonne National Laboratories, and dry cask storage. 
RESPONSE
A summary of the technologies for SNF management, including some of the work being done by Argonne
National Laboratories, as well as dry cask storage options, are presented in Volume 1, Appendix J.  Some
of these technologies are already being actively pursued by DOE, while others are currently speculative
and would require additional research to determine their effectiveness for managing SNF.  To the extent
that the technologies recommended are viable, they were considered, with many other recommendations, in
the decision-making process for identification of the preferred alternative for SNF management.

II COMMENT

The commentor states that no interim decision concerning DOE's metal fuel at the Hanford Site should be
made without considering the ultimate treatment measures necessary to prepare this fuel for final
disposition, and that some of the treatment options mentioned in the EIS are as yet unproven technologies.
RESPONSE
General technologies and practices for managing SNF, including metal fuels, are discussed in Volume 1,
section 1.1.3 and Appendix J.  Therein, it is noted that technologies for final disposition of SNF cannot be
specified in advance of repository acceptance requirements.  These requirements are several years from
completion and approval, but a combination of the technologies described in Volume 1, Appendix J may
satisfy the eventual acceptance criteria, even though some of them are as yet unproven technologies. 
Furthermore, consideration is given by the alternatives analyzed in the EIS to providing or maintaining
processing flexibility that may prove necessary to meeting the acceptance requirements.  Consequently,
although the ultimate disposition of SNF is a high priority for DOE, the details of disposition activities have
not been finalized and are beyond the scope of this EIS.

II COMMENT

The commentor states that the Draft EIS does not adequately address the impacts of the proposals for
research and development of technologies to convert liquid high-level waste to a solid form for ultimate
disposal and proposals for any necessary interim storage.
RESPONSE
The impacts of proposals regarding converting liquid high-level waste to a solid form for ultimate disposal
and proposals for interim storage are discussed under the Project Summary entitled "Waste Immobilization
Facility (Technology Selection for Treatment of Sodium-Bearing and Calcined Wastes)."  See Volume 2,
Appendix C, HLW 2.  DOE believes the analysis performed for this project is adequate.

II COMMENT

The commentor recommends the quarter sections of land adjacent to the Zoo-East area be identified as an
"example site" the first time this site is mentioned in Volume 1, Appendix A, section 5.1, instead of 
waiting until section 5.1.2 to make this statement.
RESPONSE
The descriptions in Volume 1, Appendix A, sections 5.1 and 5.1.2 are very similar and in close proximity. 
Thus, there is little chance for confusion about the wording, and no change is required.

II COMMENT

The commentor wants Volume 1, Appendix A, Table 5.7-5 to indicate best available control technology
used in design.
RESPONSE
Volume 1, Appendix A, section 2.2.2 has been changed to make it clear that DOE standards are followed
for all design/construction activities.
       

II II COMMENT

One commentor states that the EIS alternatives specify either wet or dry storage without explaining either
the environmental consequences or reasons for not splitting the two storage types into separate alternatives. 
Commentors request information on the relative merits of wet storage versus dry storage of spent nuclear
fuel.  Commentors state that the EIS does not distinguish the consequences of reprocessing versus dry and
wet storage.  Information is also requested on spent nuclear fuel types, costs and benefits of processing,
short-term activities to fix storage problems, storage facility design, and work-force requirements.
RESPONSE
The EIS discusses wet and dry storage in Volume 1, section 1.1.3 and Appendix J.  Within alternatives,
estimated impacts of the particular storage type were included as input in modeling used to determine each
alternative's impact; therefore, the consequences related to a particular storage type are included in this EIS
(see Volume 1,  Appendix I, for example).  The analyses demonstrate that the impacts of all alternatives
considered would be small for both wet and dry storage.  Separation into additional alternatives based on
storage type is not likely to result in any significant difference in the consequences.
Volume 1, Chapters 1, 4, and 5 and Appendix J, and Volume 2, Chapters 2 and 4 and Appendix F provide
the requested information.  Volume 1, section 3.3 summarizes the SNF cost evaluation.  
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.

II COMMENT

The commentor advocates long-term storage or disposal of spent nuclear fuel in a manner that will allow
future generations to recover it and perhaps neutralize it, or otherwise treat it with technologies not
available today.  
RESPONSE
The ultimate disposition of SNF is outside the scope of this EIS.  This EIS addresses interim storage of
DOE SNF for a period of up to 40 years, until disposition decisions regarding DOE SNF are made.

II COMMENT

The commentor advocates considering monitored retrievable storage for spent nuclear fuel in lieu of
permanent disposal because of concern about criticality issues.
RESPONSE
Although the final disposition of fissile materials and SNF is outside the scope of this EIS, the Nuclear
Waste Policy Act (NWPA), as amended, determined that these materials will be disposed of in a geologic
repository.  DOE is aware of the criticality safety concerns and is considering several potential paths to
address these concerns, including processing of some SNF to separate the fissile materials.  To the extent
allowed by NWPA, DOE could use monitored retrievable storage for some SNF pending resolution of
long-term criticality safety issues.

II COMMENT

commentors suggest that highly enriched spent nuclear fuel and highly enriched spent nuclear materials be
stored in aboveground engineered storage facilities.
RESPONSE
As stated in Volume 1, Chapter 1: "In 1992, the Secretary of Energy directed the Department to develop an
integrated, long-term Spent Nuclear Fuel Management Program.  This program is assessing DOE's SNF and
fuel storage facilities, integrating DOE's many existing SNF activities into one program, identifying the most
appropriate and responsible means of facility operation, and ensuring that issues associated with SNF are
resolved safely and cost-effectively."  Solutions to the storage questions may require changes in
management strategies for these fuels, including such options as the construction of new facilities,
including those suggested by the commentor, and stabilization of certain fuels.  The program has also
established a programmatic objective to define a management path and proceed toward ultimate disposition
of DOE SNF.  Activities are currently in process to meet or address this objective.  Volume 1, Appendix J
provides an overview of technologies for SNF management.  Storage and disposition of special nuclear
materials is beyond the scope of this EIS, but is being analyzed in the Programmatic EIS for Storage and
Disposition of Weapons-Usable Fissile Materials  (see Volume 1, section 1.2.3).
       

II II COMMENT

The commentor states that the EIS should address the failure of science to turn nuclear waste into a  form
compatible with people and species on the planet.
RESPONSE
Technology development addressed within this EIS, such as the Waste Immobilization Facility (described
in Volume 2, Appendix C, section HLW2), is focused on meeting waste acceptance criteria for ultimate
disposition. These criteria will represent the best scientific consensus for a compatible form.

II 6.5 Ultimate Disposition

II COMMENT

Some commentors request information on DOE's long-range plans for reprocessing or processing.  Some
commentors oppose reprocessing of spent nuclear fuel for reasons such as poor past practices and
nonproliferation issues, while others support it because they want the fissile material or other valuable
resources to be recovered.  Other commentors support processing for the purpose of stabilizing the fuels for
long-term storage, but oppose reprocessing for purposes of separation and recovery of fissile materials.
RESPONSE
Processing and reprocessing are defined in Volume 1, Appendix H.  Processing means "applying a chemical
or physical process designed to alter the characteristics of the SNF matrix."  Reprocessing is defined as
"processing of reactor-irradiated nuclear material (primarily SNF) to recover fissile and fertile material, in
order to recycle such materials primarily for defense programs."  Thus, reprocessing is only one type of
processing.  As discussed in Volume 1, Chapter 1,  DOE made a policy decision in 1992 that reprocessing
of SNF for weapons production would be phased out.  This policy is still in effect. 
Volume 1, Chapter 1 also indicates that several forms of SNF processing may still be required to stabilize
certain types of SNF for safe storage.  In addition, there are many different types of fuel with widely
differing characteristics that may require treatment for safe storage and final disposition.  At this time,
repository acceptance criteria for SNF and high-level waste for final disposition have not been defined;
therefore, the types of fuels that may require some type of treatment or processing cannot be determined. 
Many of the treatments being studied do not separate fissile materials, although some do.  Because
repository acceptance criteria are not defined, it is not currently possible to determine whether fissile
material will have to be separated from some fuels (such as fuels containing highly enriched uranium) to
meet disposal criteria.  Processing and use of existing reprocessing facilities are evaluated in the EIS,
because these facilities could be utilized for short-term management of some fuels that were not designed
for extended underwater storage, but which are currently being stored underwater.  Specific technologies
for managing SNF are described in Volume 1,  Appendix J.

II COMMENT

Commentors express opinions that DOE is emphasizing transportation of spent nuclear fuel without
considering the goals and consequences of these actions, and that DOE advocates relocating spent nuclear
fuel instead of addressing current storage problems and long-term spent nuclear fuel management,
including ultimate disposition.  Commentors further note that there is no justification for transporting spent
nuclear fuel which is currently in storage before final disposition.
RESPONSE
Volume 1, section 1.1 of the EIS presents a comprehensive discussion of the options available for
managing SNF, including storage, stabilization, transportation, and preparation for final disposition. 
Specific technologies to accomplish these options are discussed in Volume 1, Appendix J.  These options
are incorporated to varying degrees in all of the alternatives, as described in Volume 1, Chapters 3 and 5. 
Volume 1, Figures 3-1 and 3-6  graphically indicate the number of shipments expected for each alternative,
and Figure 3-7 compares estimated shipments among all of the alternatives.  The wide range in shipment
numbers reflects DOE's desire to consider all realistic transportation possibilities and the related
stakeholder concerns.  In addition, the alternatives have definite purposes for relocating SNF, such as
storing similar fuel types at a single site.  In this way, the alternatives attempt to balance transportation
concerns with other important considerations, including nonproliferation, worker safety, and cost
effectiveness.
Problems at existing storage facilities have been identified in the Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Materials and Their Environmental, Safety and Health Vulnerabilities.  This report, commonly called
the SNF vulnerability assessment, and associated action plans to resolve identified vulnerabilities are
acknowledged in Volume 1, section 1.1.2 and Appendix J-2.  Additional site-specific information is
presented in Volume 1, Appendices A through F. 
Environmental consequences of SNF management are presented for all alternatives in Volume 1, section
5.1, and mitigation measures are discussed in section 5.7.  For all alternatives analyzed, DOE is committed
to meeting applicable Federal, state, and local regulations and DOE Orders to ensure 
protection of the environment and the health and safety of the public and site employees.  For all
alternatives, the environmental consequences would be small.
Volume 1, section 1.1.3 and Appendix J of the EIS notes that technologies for final disposition of SNF
cannot be specified in advance of repository waste acceptance criteria.  These requirements are several
years from completion and approval, but a combination of the technologies described in Volume 1,
Appendix J may satisfy the eventual acceptance criteria.  Furthermore, consideration is given by the
alternatives analyzed in the EIS to providing or maintaining processing flexibility that may prove necessary
to meeting the acceptance requirements. 
Ultimate disposition of  DOE SNF is a high priority.  For planning purposes, DOE had determined that the
SNF managed by DOE that is not otherwise dispositioned (e.g., chemically separated, with the high-level
waste being converted into a vitrified glass for repository disposal) is authorized for disposal in the first
repository.  This authorization is subject to the physical and statutory limits of the first repository, DOE
SNF meeting repository acceptance criteria, and payment of fees.  As part of its SNF management program,
DOE would (1) stabilize the SNF as needed to ensure safe interim storage, (2) characterize the existing
SNF inventory to assess compliance with the first repository's acceptance criteria, and (3) determine what
processing, if any, is required to meet the criteria.  Decisions regarding the actual disposition of DOE SNF
would follow appropriate review under NEPA and be subject to licensing by NRC.  This path forward
would be implemented so as to minimize impacts on the first repository schedule.

II COMMENT

Commentors express the opinion that disposal of spent nuclear fuel would result in the loss of valuable
resources, including some of the fission products, in addition to the uranium and plutonium, and urge that
DOE carefully guard and conserve these resources as well as pursue new and innovative ways of
neutralizing the dangers of spent nuclear fuel and making use of its constituents.  Additionally, some
commentors state that concentrating such resources in a particular location could cause future generations
to attempt to mine them.
RESPONSE
Under the Nuclear Waste Policy Act, as amended (Section 122), disposing of SNF in a geologic repository
requires that the material be retrievable for recovery of economically valuable contents for a relatively
short period of time.  This requirement will be met by appropriate siting and design criteria for the
repository.  In accordance with EPA's environmental standard (40 CFR 191), institutional controls and
provisions for safeguards and security will be implemented to address human intrusion considerations.

II COMMENT

The commentor states that DOE should stop trying to appease the public and create a repository in Nevada
or stop generating nuclear energy.
RESPONSE
Volume 1, Chapter 2 states the purpose and need for DOE action.  DOE must deal in an environmentally
sound manner with the SNF remaining in inventory, and with the small amounts to be produced from other
programs.  Neither disposal nor generation is within the scope of this EIS.

II COMMENT

The commentor states that the EIS does not adequately integrate important information related to ultimate
disposition (e.g. availability, cost, and acceptance criteria) with decisions on spent nuclear fuel treatment,
storage, and stabilization.
RESPONSE
General solutions for managing SNF are discussed in Volume 1, section 1.1.3 and Appendix J.  These
sections note that technologies for final SNF disposition cannot be specified in advance of repository waste
acceptance requirements.  These requirements are several years from completion and approval, but a
combination of the technologies described in Volume 1, Appendix J may satisfy the eventual acceptance
criteria.  Furthermore, consideration is given by the various alternatives in both Volumes 1 and 2 of the EIS
to providing or maintaining processing flexibility that may prove necessary to meet the acceptance
requirements.  As stated in Volume 1, Chapter 2, activities related to the final disposition of SNF are
beyond the scope of this EIS.

II COMMENT

The commentor states that, because there is obviously no risk associated with any alternatives, we should
abandon construction of the Yucca Mountain repository and retain the site for use as a storage facility
using existing technologies, because they have been demonstrated to be so safe.
RESPONSE
The EIS analyses indicate that the environmental impacts for all alternatives considered would be small. 
Nevertheless, Congress has mandated in the Nuclear Waste Policy Act, as amended, that DOE develop
geologic repository(s) for permanent disposal of SNF and high-level waste to ensure that this and future
generations are protected from the hazards of this material.  Accordingly, DOE is proceeding to
characterize the Yucca Mountain site to determine if it is a suitable site for a repository.  Until such a
repository is available, DOE will continue to store its SNF in accordance with the results of this EIS and
ROD.

II COMMENT

Commentors state that criteria necessary for safe temporary or permanent disposal of spent nuclear fuel
should be identified and the alternatives compared with them.  Commentors give a list of criteria that
should be addressed, including transportation risks and accidents, human health risks after disposal,
pollution prevention, and cost.
RESPONSE
The ultimate disposition of SNF, including risks after disposition is beyond the scope of this EIS.  Volume
1, section 3.3 compares the impacts of the alternatives considered for managing SNF, including most of the
topics identified by the commentor, including  public health effects and risks from operations,
transportation, and accidents.  Volume 1, Chapter 5 and supporting appendices and reference materials
discuss the potential environmental consequences and identify possible measures to mitigate impacts in the
interim until disposal in the repository.  Congress has mandated in the Nuclear Waste Policy Act, as
amended, that the need for a repository and all alternatives to geologic disposal for SNF and high- level
waste need not be considered by DOE.
In following the requirements of NEPA, this EIS includes a complete description of the impacts and risks
associated with all of the alternatives considered for SNF management.  This EIS compares the various 
alternatives and, as discussed in Volume 1, section 3.3.6, DOE evaluated the cost of the proposed
alternatives.  This evaluation is available to the public.
Refer to Volume 1, Chapter 1 for an overview of DOE Spent Nuclear Fuel Management activities.

II COMMENT

The commentor is of the opinion that spent nuclear fuel could be reprocessed at the Hanford Site;
therefore, all spent nuclear fuel should be sent there for reprocessing.
RESPONSE
DOE considered in this programmatic EIS the potential for processing SNF for stabilization purposes.  In
1992, DOE instituted a policy that phased out reprocessing for weapons production.  No SNF is being
reprocessed at the Hanford Site.  Because existing facilities at Hanford are not capable of reprocessing
many of the fuel types managed by DOE, and due to significant safety concerns of operating existing
reprocessing facilities there, DOE has no plan to reprocess material at the Hanford Site with existing
facilities.

II COMMENT

The commentor expresses an opinion that the EIS does not address the problems associated with the safe
long-term storage of spent nuclear fuel.
RESPONSE
The potential impacts from SNF storage over a 40-year period are fully discussed in Volume 1, Chapter 5
and the Volume 1 site-specific appendices.  Specific environmental consequences of SNF management are
presented for all alternatives analyzed in Volume 1, section 5.1, and mitigation measures are described in
section 5.7.  Further details are provided for each site in Volume 1, Appendices A 
through F.
DOE has a program to safely manage and store SNF at each of the sites considered in the EIS, and
technological options for dealing with current and future inventories are discussed in Volume 1, Appendix
J.  In general, DOE has established a policy of designing, constructing, and operating its facilities in ways
that meet applicable Federal, state, and local requirements and DOE Orders.  All radioactive materials are
managed in a manner that ensures protection of the environment, the health and safety of the public, and
site employees.
Ultimate disposition of  DOE SNF  is a high priority.  For planning purposes, DOE had determined that the
SNF managed by DOE that is not otherwise dispositioned (e.g., chemically separated, with the high-level
waste being converted into a vitrified glass for repository disposal) is authorized for disposal in the first
repository.  This authorization is subject to the physical and statutory limits of the first repository, DOE
SNF meeting repository acceptance criteria, and payment of fees.  As part of its SNF management program,
DOE would (1) stabilize the SNF as needed to ensure safe interim storage, (2) characterize the existing
SNF inventory to assess compliance with the first repository's acceptance criteria, and (3) determine what
processing, if any, is required to meet the criteria.  Decisions regarding the actual disposition of DOE SNF
would follow appropriate review under NEPA and be subject to licensing by NRC.  This path forward
would be implemented so as to minimize impacts on the first repository schedule.

II COMMENT

Commentors question the schedule for ultimate disposal of spent nuclear fuel with regard to perceived
delays in New Mexico and Nevada, and problems with the associated siting process.  Some commentors
state that the proposed repositories are not the answer to spent nuclear fuel  management. 
RESPONSE
The repositories to which the commentors apparently refer are the Waste Isolation Pilot Plant (WIPP) in
New Mexico, for disposal of defense transuranic (TRU) wastes, and the Yucca Mountain site in Nevada,
for disposal of commercial SNF and high-level wastes.  Although the ultimate disposition of DOE SNF and
TRU wastes, and the perceived delays in the availability of associated facilities are outside the scope of this
EIS, the assumptions used in evaluating alternatives for interim management of SNF and managing TRU
wastes at INEL are discussed in this EIS.
As described in Volume 2, section 2.2.7, DOE plans to transport all stored and newly generated TRU
waste that meets the waste acceptance criteria to WIPP.  DOE's current schedule is to demonstrate
compliance with the disposal requirements as mandated in the WIPP Land Withdrawal Act of 1992
(Publication 102-579) and begin waste disposal operations in 1998.  Alternatives for managing that waste
in the interim are described in Volume 2, section 3.1.3.
Ultimate disposition of  DOE SNF  is a high priority.  For planning purposes, DOE had determined that the
SNF managed by DOE that is not otherwise dispositioned (e.g., chemically separated, with the high-level
waste being converted into a vitrified glass for repository disposal) is authorized for disposal in the first
repository.  This authorization is subject to the physical and statutory limits of the first repository, DOE
SNF meeting repository acceptance criteria, and payment of fees.  As part of its SNF management program,
DOE would (1) stabilize the SNF as needed to ensure safe interim storage, (2) characterize the existing
SNF inventory to assess compliance with the first repository's acceptance criteria, and (3) determine what
processing, if any, is required to meet the criteria.  Decisions regarding the actual disposition of DOE SNF
would follow appropriate review under NEPA and be subject to licensing by NRC.  This path forward
would be implemented so as to minimize impacts on the first repository schedule.
See also the response to comment 04.01 (005).

II COMMENT

The commentor believes that long-term management of  spent nuclear fuel is extremely problematic and
probably beyond human capability.
RESPONSE
General technologies and practices for managing SNF are discussed in Volume 1, section 1.1.3 and
Appendix J.  The EIS evaluates impacts of SNF management alternatives during the next 40 years until the
SNF can be disposed of in a geologic repository.  For the long-term (beyond 40 years), repository siting
and design requirements contained in the Nuclear Regulatory Commission's regulations (10 CFR 60)
address issues that span geologic time to ensure safe isolation of this material.  Therein it is noted that
technologies for final disposition of SNF cannot be specified in advance of repository acceptance
requirements.  These requirements are several years from completion and approval.
See also the responses to comments 06.05 (007) and 06.05 (010) for additional information on final
disposition of SNF.

II COMMENT

The commentor states that based on the overall risks of the spent nuclear fuel management alternatives
evaluated in the EIS, DOE should adopt an alternative plan that facilitates acceptance of foreign research
reactor fuels because the risks of doing so would be small compared with the possible dangers to the
United States from the diversion of fuel abroad. 
RESPONSE
The policy on acceptance of foreign research reactor fuels is not within the scope of this EIS.  See the
response to comment 06.09 (013) for additional discussion.

II COMMENT

The commentor asks if there is any research going on to find a better plan for spent nuclear fuel disposal
than encapsulation or vitrification, which the commentor asserts have been shown in testing not to work. 
RESPONSE
DOE, and others, are researching techniques to process SNF for disposal.  Contrary to the commentor's
statement, encapsulation and vitrification are viable technologies for certain spent fuels, as discussed in
Volume 1, Appendix J.  In all Volume 1 alternatives except No Action, research would continue, to 
ensure that there will be a broad base of technologies available, including vitrification, encapsulation, and
multipurpose canisters, for treating SNF to meet the repository acceptance criteria.

II COMMENT

The commentor believes that solutions do not exist for the problems of spent nuclear fuel and other wastes,
including commercial sources and low-level waste.  The commentor also states that an integrated approach
for dealing with these wastes is needed.  
RESPONSE
General solutions for managing SNF are discussed in Volume 1, section 1.1, and technological options for
dealing with the current and future inventories are described in Volume 1, Appendix J.  DOE has a
program for safely managing and storing SNF at each of the sites considered in the EIS.  The DOE
Environmental Management Program prepared the DOE-Owned Spent Nuclear Fuel Strategic Plan  for
the safe, reliable, and efficient management of DOE SNF and its preparation for disposal.  This plan is
available to the public.  All SNF and other wastes will be managed to ensure protection of the environment
and the health and safety of the public and site employees.  While DOE complex-wide management of
wastes is outside the scope of this EIS, the Waste Management Programmatic EIS is currently being
prepared to address an integrated national approach for dealing with these wastes.  The Draft Waste
Management Programmatic EIS will be issued for public comment later this year. 

II COMMENT

Commentors express the opinion that DOE is avoiding making a clear choice of a path forward on overall
management of spent nuclear fuel, including a decision as to ultimate disposition, by alluding to the
preparation of future documents to clear up the missing pieces to the "ultimate solution."  It was suggested
that the experience exists to make a decision now.  Commentors express frustration that a national nuclear
policy has not been established, and long-range plans do not exist.  Such policy and the "ultimate solution"
should include the total energy picture and its associated environmental impacts, nonproliferation, ultimate
disposition of spent nuclear fuel and nuclear waste, and other "nuclear age" problems.  Permanent
solutions are favored over interim solutions.  Commentors prefer the No Action alternative for spent
nuclear fuel management.
RESPONSE
This EIS addresses the interim programmatic management of DOE SNF nationwide, in addition to site-wide
environmental restoration and waste management activities at INEL.  Yucca Mountain is being studied as
the potential site for the first geologic repository.  If the site is found suitable, acceptance of
commercial SNF is expected to begin in 2010.  Although acceptance of DOE high-level waste is planned
for 2015, the date for acceptance of DOE SNF at the repository has not been finalized.  The 40 years for
SNF management is based on the maximum amount of time considered necessary to implement decisions
on the ultimate disposition of DOE SNF.  DOE, through this EIS, solicited public comment regarding both
program needs.  Regarding INEL activities, this period is indexed to both strategic planning periods and
budget forecasts, as well as looking into the future as far as reasonably foreseeable regarding specific
site-wide programs.  The programmatic SNF 40-year period is based on the maximum amount of time
considered necessary to make and implement decisions on the ultimate disposition of SNF by fuel type, to
define the criteria necessary to implement such disposition, and to have the facilities (such as geologic
repositories) available to implement ultimate disposition.  The need for such interim management is
discussed in Volume 1, Chapter 2, and the EIS Summary in greater detail.  Accordingly, DOE is evaluating
a reasonable range of alternatives for the safe and environmentally sound management of its SNF, as well
as the No Action alternative required by law.  The programmatic SNF portion of the EIS will be reviewed
and updated as necessary. 
With respect to establishing an overall national nuclear or energy policy, this EIS is devoted to setting the
strategy for the period required to develop and implement decisions on ultimate disposition.  Ultimate
disposition of  DOE SNF is a high priority.  For planning purposes, DOE had determined that the SNF
managed by DOE that is not otherwise dispositioned (e.g., chemically separated, with the high-level waste
being converted into a vitrified glass for repository disposal) is authorized for disposal in the first
repository.  This authorization is subject to the physical and statutory limits of the first repository, DOE
SNF meeting repository acceptance criteria, and payment of fees.  As part of its SNF management program,
DOE would (1) stabilize the SNF as needed to ensure safe interim storage, (2) characterize the existing
SNF inventory to assess compliance with the first repository's acceptance criteria, and (3) determine what
processing, if any, is required to meet the criteria.  Decisions regarding the actual disposition of DOE SNF
would follow appropriate review under NEPA and be subject to licensing by NRC.  This path forward
would be implemented so as to minimize impacts on the first repository schedule.
National policy with regard to the overall management of DOE's waste is being established through the
preparation of the Waste Management Programmatic EIS, which is on a parallel course with this EIS. 
The site-wide management of INEL waste streams is being coordinated with the programmatic document,
which will set the overall strategic approach.  Commercial SNF and waste management 
activities are not within the scope of either this SNF or the Waste Management Programmatic EIS
currently being prepared.  National energy policy is not within the scope of any of these documents.  
See the response to comment 03.05 (007) regarding alternative sources of energy.  See the response to
comment 01.01.01.01 (008) regarding preference for the No Action alternative.

II COMMENT

A commentor states that the ultimate disposition of DOE spent nuclear fuel is generally similar to
situations facing nuclear power utilities in the United States and other nuclear reactors worldwide.  Thus,
the commentor suggests that all spent nuclear fuel be turned over to the International Atomic Energy
Agency for choice of one final repository.  Other commentors suggest that an international approach be
taken regarding spent nuclear fuel  disposition or storage issues. 
RESPONSE
The scope of the EIS for SNF is discussed in Volume 1, Chapters 1 and 2.  These chapters explain that this
EIS is restricted to considering temporary storage (through 2035) and related interim measures for
managing only DOE SNF.  Consequently, the location and nature of a geologic repository, especially for
commercial SNF and SNF of international origin, are not included in this EIS because they are separate,
independent actions and the subject of Presidential and Congressional policies.  SNF and high-level waste
disposition is subject to the Nuclear Waste Policy Act, as amended, which restricts current repository siting
evaluations to the Yucca Mountain site in Nevada.  No treaties or other arrangements are in place or
envisioned as being feasible to combine SNF disposition efforts with those occurring outside the United
States.  Nevertheless, among the technologies described in Volume 1, Appendix J are several options that
would prepare SNF for satisfying eventual repository acceptance requirements.  These options are
consistent with SNF disposition approaches being actively pursued or under consideration in other
countries.  Also, as outlined in Appendix J, DOE maintains an awareness of international SNF efforts to
take advantage of any technological advancements elsewhere that would be helpful in the United States.

II COMMENT

The commentor suggests that funds should not be expended on moving toxic waste until final disposition is
known.
RESPONSE
DOE is committed not only to developing a Federal geologic repository for permanent isolation of SNF
and high-level waste, but to providing safe interim storage pending availability of permanent disposal
facilities.  DOE has a program for safely managing and storing radioactive materials at each of the sites
considered in the EIS.  Analyzing transportation of SNF and waste materials is necessary to varying degrees
under the alternatives DOE is analyzing for providing safe interim storage and management of SNF and
waste materials.  The alternatives have definite purposes for relocating SNF and waste materials, such as
storing and/or treating similar fuel and waste types within a single secure facility. Thus, the alternatives
attempt to balance transportation concerns with other worthy considerations, including nonproliferation,
worker and public health and safety, and cost effectiveness. 

II COMMENT

The commentor suggests disposing of spent nuclear fuel at sea, enclosed in a submarine, in a geologic
repository, or in outer space.  Another commentor opposes disposing of spent nuclear fuel at sea.
RESPONSE
In the late 1970s the Federal Government evaluated a full range of reasonable alternatives for ultimate
disposition of SNF and high-level waste.  These alternatives included mixed geologic disposal, sub-seabed
disposal, island disposal, and space disposal.  As a result of this evaluation, documented in a generic EIS
issued in 1979 by DOE, Congress mandated in the Nuclear Waste Policy Act in 1983 and it's 1987
amendment that geologic repositories be developed for permanent disposal of SNF and high-level waste,
that research and development or alternative means and technologies for permanent disposal be 
continued and accelerated (section 222) and that, in particular, sub-seabed disposal be initiated and
progress reported periodically to Congress (section 224).  DOE is proceeding with these activities. 

II COMMENT

The commentor states that to resolve the overall problem of storage of all types of spent nuclear fuel, DOE
should press ahead to determine where the ultimate repository of spent nuclear fuel will be.  Additionally,
the commentor urges DOE to complete the EIS process, and adopt the Navy's preferred alternative for
Naval fuel.
RESPONSE
Volume 1, section 3.1 shows the actions that would be undertaken by DOE to the extent required by the
Navy's preferred alternative.  Activities related to the management of SNF, including research and 
development activities would be included.  DOE is continuing to aggressively pursue investigation of the
candidate repository site at Yucca Mountain in Nevada for disposal of high-level waste and SNF. 
Ultimate disposition of  DOE SNF  is a high priority.  For planning purposes, DOE had determined that the
SNF managed by DOE that is not otherwise dispositioned (e.g., chemically separated, with the high-level
waste being converted into a vitrified glass for repository disposal) is authorized for disposal in the first
repository.  This authorization is subject to the total quantity of DOE SNF and high-level waste not
exceeding 10 percent (by weight) of the  first repository capacity limit (70,000 metric tons of heavy metal),
DOE SNF meeting repository acceptance criteria, and payment of fees.  As part of its SNF management
program, DOE would (1) stabilize the SNF as needed to ensure safe interim storage, (2) characterize the
existing SNF inventory to assess compliance with the first repository's acceptance criteria, and (3)
determine what processing, if any, is required to meet the criteria.  Decisions regarding the actual
disposition of DOE SNF would follow appropriate review under NEPA and be subject to licensing by
NRC.  This path forward would be implemented so as to minimize impacts on the first repository schedule.

II COMMENT

The commentor suggests that highly enriched spent nuclear fuel may never meet repository waste
acceptance criteria due to criticality and safeguards concerns.
RESPONSE
DOE agrees that highly enriched SNF is an issue regarding repository disposal, in particular concerns about
criticality.  This issue is being addressed by DOE and the Nuclear Regulatory Commission.  If the fuel must
ultimately be processed to satisfy the repository acceptance criteria, Volume 1, section 1.1.3 and Appendix
J of the EIS discuss the available technologies that may be needed for final disposition of SNF. 

II COMMENT

The commentor states that until final repository siting and its requirements are assigned, it is unreasonable
to consider other elements of the spent nuclear fuel program.
RESPONSE
As the EIS discusses, interim management of SNF must be addressed for up to the next 40 years pending
ultimate disposition.  The alternatives identified and evaluated in the EIS represent a full range of
reasonable alternatives for managing SNF, including the No Action alternative.  The environmental
impacts of these alternatives, along with other decision factors such as cost, mission impacts, and public
comment, will be considered in the decision-making process leading to the ROD.

II COMMENT

The commentor states that DOE's Environmental Management and Office of Civilian Radioactive Waste
Management should have an integrated approach to discussion of spent nuclear fuel and a joint effort be
undertaken to define the ultimate disposal in a geologic repository.  The commentor also recommends that
the EIS be revised to include a road map that would demonstrate a joint approach.
RESPONSE
Ultimate disposition of  DOE SNF is a high priority.  For planning purposes, DOE had determined that the
SNF managed by DOE that is not otherwise dispositioned (e.g., chemically separated, with the high-level
waste being converted into a vitrified glass for repository disposal) is authorized for disposal in the first
repository.  This authorization is subject to the physical and statutory limits of the first repository, DOE
SNF meeting repository acceptance criteria, and payment of fees.  As part of its SNF management program,
DOE would (1) stabilize the SNF as needed to ensure safe interim storage, (2) characterize the existing
SNF inventory to assess compliance with the first repository's acceptance criteria, and (3) determine what
processing, if any, is required to meet the criteria.  Decisions regarding the actual disposition of DOE SNF
would follow appropriate review under NEPA and be subject to licensing by NRC.  This path forward
would be implemented so as to minimize impacts on the first repository schedule.
As part of this path forward strategy, the Office of Environmental Management and the Office of Civilian
Radioactive Waste Management have established a working group to provide an integrated approach to
identify and address technical, regulatory, and institutional issues regarding disposal of DOE SNF in the
geologic repository.  This working group has made significant progress in defining the issues and
establishing work plans to address them.

II COMMENT

The commentor asks about the potential long-term radiation of DOE's waste, and supports the Ten-Year
Plan alternative for disposal of spent nuclear fuel at the Idaho National Engineering Laboratory.
RESPONSE
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be
small.  While there are differences in the impacts among the alternatives, these differences by themselves
are not sufficient to distinguish between alternatives.
Volume 1, Chapter 5 summarizes the radiological impacts associated with all the alternatives considered in
this EIS, including using existing facilities and constructing new ones.  Volume 1, section 3.3 summarizes
the cost of alternatives.  The health and safety of workers and the public has been considered in the
evaluation of these alternatives and the identification of a preferred alternative.  The information provided
on radiological impacts and facility costs is considered adequate for evaluation and comparison of the
impacts of all the alternatives considered in this EIS.   
Volume 1, section 3.1 describes the preferred alternative for SNF management.  See the response to
comment 04.04 (008).  Volume 2, section 3.4 discusses DOE's preferred alternative for SNF management,
environmental restoration, and waste management activities at INEL.  See the response to comment 04.04
(011).

II COMMENT

The commentor states that the repository for spent nuclear fuel will not take DOE fuels and that decisions
on managing Hanford Site materials should not be based on a mythical repository, but it should be
assumed that it will remain at Hanford forever.  The commentor also states that the Monitored Retrievable
Storage negotiations with Indian Tribes have not been successful.
RESPONSE
Although activities associated with licensing and opening the repositories or Monitored Retrievable Storage
are outside the scope of this EIS, general solutions for managing SNF in the interim are within the scope of
this EIS and are discussed in Volume 1, section 1.1 and Appendix J of the EIS.   More detailed
descriptions are in the Volume 1 site-specific Appendices A through F.  Therein it is noted that
technologies for final SNF disposition and a geologic repository site cannot be selected in advance of
repository performance requirements and waste acceptance criteria.  These requirements and criteria are
several years from completion and approval.  The repository must then be constructed and certified, which
could require decades to properly accomplish.  Evaluating and opening disposal sites for radioactive
materials is time consuming.  Yucca Mountain is being studied as the potential site for the first geologic
repository.  If the site is found suitable, acceptance of commercial SNF is expected to begin in 2010. 
Although acceptance of DOE high-level waste is planned for 2015, the date for acceptance of DOE SNF at
the repository has not been finalized.  DOE acknowledges these challenges by allowing up to 40 years for a
suitable repository to become fully operational.

II COMMENT

The commentor has an opinion on the second geologic repository being used for disposition of higher
reactivity spent nuclear fuel.
RESPONSE
Under the Nuclear Waste Policy Act, as amended, DOE is not authorized to work on a second repository
and is required to report to the President and to Congress between January 2007 and January 2010 on the
need for a second repository.  Concerns regarding disposal of higher-reactivity (enriched) SNF is being
addressed for the first repository between DOE Office of Environmental Management and Office of Civilian
Radioactive Waste Management.
       

II 6.6 Interim Management

II COMMENT

The commentor states that the EIS does not evaluate reasonable, safe alternatives for spent nuclear fuel
storage.
RESPONSE
DOE believes that the alternatives analyzed in this EIS are reasonable and in accordance with NEPA and
Council on Environmental Quality (CEQ) requirements to consider a range of reasonable alternatives. 
Alternatives range from the No Action alternative, required by law, to an alternative that consolidates all
SNF at one of five sites.  Alternatives dismissed are discussed in Volumes 1 and 2, section 3.2.  DOE
believes the discussion of the basis for dismissing other possible alternatives is adequate.

II COMMENT

The commentor states that possible future contamination of the Idaho National Engineering Laboratory
(ICPP-666) storage pool from spent nuclear fuel transferred from ICPP-603 could produce an
environmental impact.
RESPONSE
Volume 2, Appendix C, SNF4-1 discusses the Canning Characterization Project that could be instituted
under various alternatives at ICPP to keep this situation from occurring.

II COMMENT

Commentors express opinions that the interim spent nuclear fuel management program sites will become
"de facto" permanent storage sites for the nation and perhaps the world, and that the decision on a
permanent storage site will be delayed.   In addition, several commentors express the view that these sites
may not be suitable for permanent disposal of spent nuclear fuel, but because they may be politically and
economically weak, the storage sites will be forced on them.
RESPONSE
It is not DOE's intent to allow interim SNF storage sites to become de facto permanent storage sites.  In
fact, Congress mandated that the Federal Government pursue the development of a geologic repository for
the permanent disposal of SNF and high-level waste and directed DOE to study the Yucca Mountain site in
Nevada to determine if it is suitable for this purpose.  DOE currently is pursuing those directions.  DOE is
committed to developing facilities for permanent isolation of SNF and high-level waste.  Pending
availability of such disposal sites, DOE must provide for safe and environmentally sound storage and
management of these materials.  The implementation of safe interim storage and transition to ultimate
disposition represents the solution that DOE seeks to define with this EIS.
This EIS objectively evaluates 10 sites as reasonable alternatives for some level of interim SNF
management activity, without regard to or consideration of political or economic factors.  The analyses in
the EIS include environmental considerations, socioeconomic impacts, potential risks to the public from
operations and reasonably foreseeable accident conditions, and other environmental factors for a number
of options for management of SNF.  The EIS concludes that the alternative sites are environmentally
suitable for management of SNF and that there would be no significant risk to the public or the
environment due to interim management of SNF at any of the 10 sites being considered.
DOE considered public comment while preparing the EIS, upon which decisions will be based. Although
the EIS provides DOE with an informed basis for decisionmaking from the perspective of environmental
impacts and public comment, decisions will also consider such factors as national needs, schedules, and
costs.  In addition, implementation of decisions is subject to independent processes, including
Congressional funding and environmental permitting.  DOE intends, however, to develop and implement a
national SNF management strategy that best serves the overall needs of the nation.

II COMMENT

The commentor asks DOE to quantify the relationship between the capacity of any new storage facilities
planned and DOE's total inventory of spent nuclear fuel.
RESPONSE
The storage capacity required to safely manage the existing and projected SNF inventories depends on the
programmatic approach selected by DOE.  However, SNF storage facilities, complex-wide, would be sized
to provide the storage capacity required under the programmatic approach selected, considering the
availability of qualified existing storage under the specific alternative, at the specific site.

II COMMENT

The commentor notes that the transfer of fuels from Idaho Chemical Processing Plant Building 603 (ICPP-
603) to the newer storage pool in ICPP-666 is not assessed in the EIS.
RESPONSE
As discussed in Volume 2, Chapter 3,  phasing out wet storage in ICPP-603 and moving fuel to ICPP-666
is part of the No Action,  Ten-Year Plan, and Maximum Treatment, Storage, and Disposal alternatives. 
The impacts of moving this fuel have been assessed as a part of the overall impacts of these alternatives, as
described in Volume 2, section 5.1.

II COMMENT

The commentor notes that the EIS does not discuss the Test Area North Dry Cask Storage Project in
Appendix B, section 3.1.1.3, where it would be expected.  The commentor states that rather than moving
the spent nuclear fuel to the Idaho Chemical Processing Plant, it could be stored on an expanded pad at
Test Area North with less transportation, less handling, and less attendant risk.  In addition, the commentor
states alternatives to moving spent nuclear fuel from Test Area North to Idaho Chemical Processing Plant
should be evaluated in the EIS.
RESPONSE
The Test Area North Dry Cask Storage Project is proceeding as an interim action.  Volume 2, Appendix F
discusses two projects related to the use of Test Area North:  (1) dry fuel storage facility and fuel receiving,
canning, characterization and shipping; and (2) Test Area North pool fuel transfer.
Volume 2, section 2.2 states that as part of the vulnerability corrective action plan, DOE plans to move
SNF management activity from Test Area North to a more central location.

II COMMENT

The commentor states that relocation of spent nuclear fuel will only enlarge the area of the environment
that will later have to be restored, because both the old storage area from which the spent nuclear fuel will
be moved and the a new area to which it will be moved will both have to be restored eventually.
RESPONSE
Volume 1, section 1.3 discusses safe and environmentally sound management of SNF until decisions
regarding its ultimate disposition are made and implemented.  Storage options at each generating site and
other storage options are analyzed.  The analysis of the storage options of each alternative includes the
estimated type and size of a representative storage facility potentially needed at each site.  
DOE believes that relocation of some SNF could be a beneficial management strategy.  New facilities
would be designed both for safe storage and for more effective restoration when they are decommissioned. 
Removing SNF from older facilities in the near term could serve to reduce future environmental and safety
problems and allow restoration activities to begin.

II COMMENT

The commentor notes that the EIS states:  "DOE has scheduled the installation and operation of new fuel
characterization and canning equipment in the Irradiated Fuel Storage Facility before the Record of
Decision (1995)."  According to Westinghouse Idaho Nuclear Company, the earliest such a facility will be
operating is early to mid-1996, and the location has not been determined.
RESPONSE
Installation of new fuel characterization and canning equipment in the Irradiated Fuel Storage Facility is
now tentatively scheduled for early 1996.  The text of the EIS has been revised to reflect this change in
schedule.

II COMMENT

The commentor notes that DOE sites predominantly use wet storage, and only limited dry storage
experience exits within DOE.  The commentor recommends that DOE consider commercial experience
wherever possible to increase regulator and public acceptance, and reduce schedule and cost.
RESPONSE
Current and projected DOE SNF inventories are considered in this EIS.  Existing storage facilities are
identified, and their status, capacities, and accident histories are described.  SNF container design,
integrity, corrosion and corrosion byproducts, storage technologies, and storage facility design life are
factored into the EIS analysis for each alternative.  Storage options at the site of generation and other
storage options are analyzed.  The analysis of the storage options for each alternative includes the
estimated type and size of representative storage facilities potentially needed at each site.  Commercial
experience is considered whenever possible to increase public acceptance and reduce costs and schedules.
       

II 6.7 Cost

II COMMENT

Commentors want cost evaluation to be part of this EIS.
RESPONSE
Volume 1, section 3.3.6 summarizes the costs for implementing actions under each alternative.  In addition,
a discussion of the cost evaluation has been prepared for use by decisionmakers   For each alternative, the
cost evaluation considers capital costs for upgrades, operations, maintenance, decontamination,
decommissioning, and transportation.  The evaluation also addresses additional systems costs, including
disposition.

II COMMENT

The commentor expresses the opinion that a spent nuclear fuel management facility (spent nuclear fuel
receipt, inspection, processing, and temporary storage) would be less costly if built near the spent nuclear
fuel final storage repository, and that the cost of such a facility would be lower if it were built now rather
than in the future.
RESPONSE
The commentor may be correct in asserting that economies of scale and transportation cost savings would
help lower the eventual cost of a centralized SNF management facility located near a permanent SNF waste
repository.  It is also true that inflation causes cost escalations for facilities built in the future rather than
now.  DOE considered these issues when it identified the preferred alternative.

II COMMENT

The commentor indicates that the costs of handling and storing DOE spent nuclear fuel are considerably
higher than equivalent costs for commercial fuel and asks whether characterization facilities are really
needed and whether overseas processing of spent nuclear fuel might be more cost effective.
RESPONSE
Volume 1, section 3.3.6 summarizes the cost for implementing actions under each alternative.  For each
alternative, the cost evaluation considers capital costs for upgrades, operation, maintenance,
decontamination, decommissioning, and transportation.  The evaluation also addresses additional system
costs, including disposition.  This is adequate for evaluating and comparing the alternatives considered in
this programmatic EIS.  Volume 1, section 3.1 discusses the requirements for characterization facilities
under all of the alternatives discussed in this EIS.  Volume 1, section 3.2 has been changed to further
evaluate overseas processing of SNF.

II COMMENT

The commentor states that the cost of removing and mitigating environmental hazards associated with spent
nuclear fuel will increase in the future, so decisions need to be made soon.
RESPONSE
The commentor may be correct in assuming that costs may increase over time.  Volume 1, section 3.3.6 of
the EIS summarizes the costs of managing SNF.  The ROD for this EIS will be issued by June 1, 1995.

II COMMENT

The commentor asks that cost considerations be weighed against radiological impact and suggests that
using existing facilities could lower costs.
RESPONSE
Volume 1, Chapter 5 summarizes the radiological impacts associated with all the alternatives considered in
this EIS, including using existing facilities and constructing new ones.  Volume 1, section 3.3.6 summarizes
the cost for implementing actions under each alternative.  The health and safety of workers and the public
has been considered in the evaluation of these alternatives and the identification of a preferred alternative. 
The information provided on radiological impacts and facility costs is considered adequate for evaluating
and comparing the impacts of all the alternatives considered in this EIS. 

II COMMENT

Commentors state that the cost of the corrective action plans for the problems identified in the Spent Fuel
Working Group Report are underestimated and should have been included in this EIS.
RESPONSE
A summary of specific corrective actions to address the SNF vulnerabilities at INEL identified in the Spent
Fuel Working Group Report on Inventory and Storage of the Department's Spent Nuclear Fuel and
Other Reactor Irradiated Nuclear Materials and Their Environmental, Safety and Health
Vulnerabilities  at INEL are listed in Volume 2, Table 2.2-1.  Many of the corrective actions are currently
under way or have been completed.  Those activities for which NEPA review was complete before the
ROD for this EIS was issued are analyzed under the No Action alternative.  Although NEPA does not
require an analysis of the costs of implementing alternatives in an EIS, DOE prepared a cost evaluation for
all alternatives that includes the SNF facilities; the results are summarized in Volume 1, section 3.3.6.

II COMMENT

The commentor states that "moving nuclear waste around from 'interim site' to 'interim site' is dangerous
and extremely expensive."  The commentor also states that funds would be put to better use "cleaning up
and organizing individual sites and developing a program to eliminate waste."
RESPONSE
DOE evaluated the transportation impacts of shipping SNF; the results are presented in Volume 1,
Appendix I, and Volume 2, section 5.11.  DOE's cost evaluation of the proposed alternatives, summarized
in Volume 1, section 3.3.6, shows that transportation costs do not differ among alternatives. 
Transportation of the entire DOE inventory between widely dispersed sites was analyzed to provide a
reasonable range of alternatives and associated impacts for decisionmakers to consider.  These evaluations
show that the impacts of all the alternatives considered in this programmatic EIS would be small.

II COMMENT

Commentors state that the cost information presented is not truthful and that the costs will be higher than
stated.
RESPONSE
Volume 1, section 3.3.6 summarizes the cost for implementing actions under each alternative.  In addition,
a reference to the cost evaluation has been added to the EIS.  DOE has provided a significant amount of
information in these documents to allow independent evaluation of the costs.

II COMMENT

The commentor believes that the Federal Government should have to pay a tariff to locations willing to
house spent fuel.
RESPONSE
The government provides support to communities that have Federal facilities and projects, through the
creation of jobs and other associated benefits.  Payments to areas willing to accept SNF would be
determined by Congress or the President and are outside of the scope of this EIS.

II COMMENT

The commentor raises issues regarding the costs and scheduling of alternatives being considered within this
EIS.
RESPONSE
While cost and schedule issues will be considered in the decisions facilitated by this EIS, these are
administrative issues that are beyond the scope of this EIS.  DOE prepared a cost report, which estimates
the cost of each of the alternatives under consideration in this EIS.  This report is summarized in Volume 1,
section 3.3.6 and is available to the  public.

II COMMENT

The commentor states that the "massive" cost estimates for ICPP-666 and dry spent nuclear fuel storage
"lead us to wonder whether the scale of these projects might be a Trojan horse" to allow shipments of
additional spent nuclear fuel and other nuclear materials.
RESPONSE
Decisions for storing other nuclear materials will be decided through other NEPA documents, including
those discussed in Volume 1, section 1.2.  Facility costs are based on compliance with nuclear facility
requirements, as identified in DOE Order 6430.1A, General Design Criteria.  The size and cost of these
facilities vary by alternative and the proposed amount of  SNF to be stored.

II COMMENT

The commentor states that the cost of each proposed alternative and assumptions should be available to the
public and included in the EIS.
RESPONSE
While cost and scheduling issues will be considered in the decisions facilitated by this EIS, these are
administrative issues that lie beyond the scope of the EIS itself.  DOE  prepared a cost report, which
estimates the cost of each of the alternatives under considerations in this EIS.  This report is summarized in
Volume 1, section 3.3.6 and is available to the public.

II 6.8 Commercial Spent Nuclear Fuel

II COMMENT

The commentor requests that DOE accept greater-than-Class-C sealed sources from commercial nuclear
power plants, and that the EIS be expanded to include acceptance of commercial power reactor fuel and
high-level waste.
RESPONSE
Volume 2, section 3.1 discusses acceptance of greater-than-Class C sealed sources for recycling or storage
for all of the alternatives analyzed except the Maximum Treatment, Storage, and Disposal alternative.  As
discussed in Volume 1, Chapter 1 and the Implementation Plan, this EIS does not address commercial
power plant SNF or high-level waste, which are the subjects of the Nuclear Waste Policy Act, as amended.

II COMMENT

The commentor raises issues regarding commercial spent nuclear fuel, particularly with respect to
compensating communities for storage as is being discussed with tribal governments for commercial spent
nuclear fuel monitored retrievable storage.
RESPONSE
This EIS pertains to the programmatic management of DOE SNF.  Issues regarding SNF under the
cognizance of commercial power utilities are beyond the scope of this EIS.  Compensation to tribes as part
of negotiations between the former Nuclear Waste Negotiator and various entities to establish a commercial
SNF monitored retrievable storage facility is likewise beyond the scope of this EIS. 

II COMMENT

The commentor states that the Project Summary for Fort St. Vrain spent fuel shipments needs some factual
corrections.
RESPONSE
The Fort St. Vrain Project Summary has been corrected.

II COMMENT

The commentor states that there may be a relationship between DOE spent nuclear fuel and commercial
spent nuclear fuel.
RESPONSE
Except for a very few special-case situations as described in Volume 1, section 1.1, this EIS does not
discuss SNF from commercial power nuclear reactors.  Volume 1, Chapter 2 states that the decisions that
must be made to establish an effective program for DOE SNF are a) where to conduct SNF management 
activities, b) the appropriate facilities, capabilities and technologies for SNF management, and c) the
research and development activities to support the SNF management program.
See also the response to comment 04.01 (001).

II COMMENT

The commentor notes that the EIS fails to fully consider that the remaining useful life of the facility where
the Fort Ft. Vrain fuel is to be stored will be exceeded by 2015, well before a repository is expected to be
ready for this fuel.
RESPONSE
In Volume 2, Chapter 3, DOE proposes a dry storage facility in each of the alternatives in which Fort  St.
Vrain SNF would be received.  Yucca Mountain is being studied as the potential site for the first geologic
repository.  If the site is found suitable, acceptance of commercial SNF is expected to begin in 2010. 
Although acceptance of DOE high-level waste is planned for 2015, the date for acceptance of DOE SNF at
the repository has not been finalized.  DOE considered that the design life of the facility may be exceeded
before a repository is ready.  In the event that engineering studies cannot justify extending the use of the
existing facility, Fort St. Vrain SNF would be moved to the new dry storage facility.

II COMMENT

The commentor urges DOE to consider all contractual obligations to accept spent nuclear fuel equally, and
refers specifically to Fort St. Vrain fuel. 
RESPONSE
DOE considered its contractual obligation to accept specific fuels in its identification of a preferred
alternative for programmatic SNF management.

II COMMENT

The commentor states that DOE is responsible for accepting spent nuclear fuel and high-level waste from
commercial power reactors, referring to commercial spent nuclear fuel that DOE is obligated to manage
after 1998.
RESPONSE
As described in Volume 1, Chapter 1, this EIS focuses on DOE SNF from production, research and
development reactors, Naval reactors, university and foreign research reactors, and miscellaneous
generators.  Management of commercial SNF is beyond the scope of this EIS.  DOE's responsibility with
respect to commercial SNF is within DOE's Office of Civilian Radioactive Waste Management.

II COMMENT

The commentor states that, with respect to the No Action alternative, Public Service Company of Colorado
would not be able to transport the remaining spent nuclear fuel from the Fort St. Vrain facility and release
the facility for unrestricted use.
RESPONSE
DOE recognizes that this would be a consequence of the No Action alternative.  This has been considered
in DOE's identification of a preferred alternative for SNF management.
       

II 6.9 Miscellaneous

II COMMENT

The commentor states that the EIS should also include plans for dealing with errors or misjudgments and
provide compensation for damages for those locations that accept spent nuclear fuel. 
RESPONSE
Potential accidents and the impacts associated with these accidents are generally discussed in Volume 1,
section 5.1, and treated in more detail in Volume 1, Appendices A through F.  DOE includes contingencies
for dealing with errors in its planning for new facilities and activities, as well as procedures for existing
facilities and activities.  An in-depth analysis of the impacts of operations and potential accidents is
provided for SNF management operations in  Volume 1, Appendices A though F, and for INEL restoration
and remediation activities in Volume 2.  The analyses include potential hazards and consequences and the
possible methods, measures, or controls to be employed to minimize them.  The analyses confirm that the
risk from SNF management operations is small.
DOE will use the statutory indemnity contemplated by the Price-Anderson Act (42 USC 2210) to ensure
ready and prompt availability of funds to compensate the public for injuries and damages resulting from a
nuclear incident arising from activities conducted by indemnified DOE contractors.  Compensation
provided under the Act would cover nuclear incidents at INEL as well as nuclear incidents during the
transport of material to and from the site.
Although the Price-Anderson Act is the primary means for compensating the public for damages from
nuclear incidents, other remedies exist for claims not falling within the purview of the Act.  For example,
claims against DOE or its employees may be cognizable under the Federal Tort Claims Act, and claims for
environmental damage may fall within CERCLA.  These and other laws afford an injured party
mechanisms for seeking recovery for damages related to operation of DOE facilities.

II COMMENT

The commentor states that spent nuclear fuel does not require treatment prior to disposal and that DOE is
proposing treatment facilities only so that it can remain in the weapons production business. 
RESPONSE
Volume 1, section 1.1.3 discusses technologies for managing SNF, and more details on fuel management
technologies are provided in Volume 1, Appendix J.  Therein it is acknowledged that some SNF may not
require treatment prior to disposal in a repository.  However, there are many different types of fuel with
widely differing characteristics, which may make treatment necessary.  At this time, repository waste
acceptance criteria have not been defined; therefore, the fuels that might require treatment cannot be
determined at present.  Processing is being considered to provide the chemical or mechanical stability
needed for ultimate disposition or to meet limits on size or amount of fissile material in individual
containers.   
Many of the SNF treatment technologies being studied do not require separation of uranium or plutonium,
and thus would not be related to the weapons production business.  As discussed in 
Volume 1, Chapter 1, DOE made a policy decision in 1992 that reprocessing of SNF for weapons
production would be phased out.  That policy is still in effect.

II COMMENT

The commentor expresses the opinion that if people are unhappy with the current situation with respect to
spent nuclear fuel, they should participate in solving the problem, rather than complaining.  
RESPONSE
Through the public scoping process and the public comment period on the Draft EIS, many people and
organizations have participated in developing solutions to the SNF problem.

II COMMENT

The commentor states that the inset entitled "What is Spent Nuclear Fuel?" in the Summary is "rather
inadequate and 'harmless' as far as the lay public is concerned."  
RESPONSE
This insert was provided to clarify the definition of SNF for the public.  It has been modified to better
accomplish that.

II COMMENT

Commentors request that DOE address spent nuclear fuel management program priorities in the EIS in light
of funding and other limitations.  commentors also request that the public be allowed to comment on the
priorities.
RESPONSE
The Spent Fuel Working Group Report on Inventory and Storage of the Department's Spent Nuclear
Fuel and Other Reactor Irradiated Nuclear Materials and Their Environmental, Safety and Health
Vulnerabilities and associated action plans address some of DOE's immediate SNF management priorities. 
The Phase I Action Plan was issued in February 1994, the Phase II Action Plan in April 1994, and the
Phase III Action Plan in October 1994.  These action plans currently are being implemented.
Additionally, DOE has issued the DOE-Owned Spent Nuclear Fuel Strategic Plan.  This plan addresses
the issues associated with the management of SNF and its preparation for disposal.  The plan is available in
the reading rooms and information locations listed in the EIS.

II COMMENT

The commentor expresses the opinion that disposal of spent nuclear fuel in a repository will result in the
concentration of valuable resources at a particular site and that it would attract generations in the future
who would want to mine the resources.
RESPONSE
The ultimate disposition of SNF is not within the scope of this EIS.  This EIS considers interim storage
until the decisions on ultimate disposition are made.  The process that will decide the manner of ultimate
disposition will consider the resource value of SNF and its constituents, along with long-term management
and security concerns, including human intrusion.

II COMMENT

The commentor, although supportive of options that would help solve the plutonium (and highly enriched
uranium) waste problem, feels the Isaiah Project is not an appropriate option.
RESPONSE
The Isaiah Project has been proposed to consume excess plutonium as a mixed-oxide fuel in commercial
power-production reactors (specifically within the Washington Public Power Supply System).  Such
projects concern the management of existing special nuclear material, not SNF (which is no longer being
reprocessed to yield recycled fissile material).  The Isaiah Project is not included in the alternatives
considered in this EIS and its adoption or rejection would not change the need to select a method for SNF
management.  Future management of the current inventory of special nuclear material will be addressed in
the forthcoming EIS for Storage and Disposition of Weapons-Usable Fissile Material.  Preparation of
that EIS was recently announced in Volume 59 of the Federal Register, pages 31985 through 31989.

II COMMENT

The commentor questions why the EIS frequently mentions reprocessing activities and that the Court noted
that none of the fuel brought to the Idaho National Engineering Laboratory has been reprocessed. 
RESPONSE
The commentor seems to be referring to Fort St. Vrain SNF.  While there has been substantial reprocessing
of some SNF at INEL over its 40-year history, no Fort St. Vrain SNF has been reprocessed.  The existing
processing facilities at INEL do not have the capability to reprocess graphite matrix fuels, such as the fuel
used at Fort St. Vrain.

II COMMENT

The commentor asserts that the illustration of a fuel rod and a fuel assembly in the fact sheet What is Spent
Nuclear Fuel  is not representative of the vast majority of spent nuclear fuel managed by DOE and the
Navy.  Additionally, the commentor states that the other illustrations and descriptions of spent nuclear fuel
in the EIS summaries do not include descriptions of many fuels, including Navy fuels, Shippingport, and
TRIGA fuels.
RESPONSE
The illustrations and descriptions in the fact sheet and the EIS summaries were chosen by DOE because
they help provide a basic understanding of the typical components of SNF.  DOE is not attempting to
provide detailed descriptions of the numerous SNF types in this EIS; rather, DOE is describing the basic
considerations, such as cladding type and condition, that are germane to a general understanding of SNF
management.

II COMMENT

The commentor asks DOE to responsibly manage the radioactive materials (including radioactive wastes
and spent nuclear fuel) that DOE helped to create and wants to give DOE 2 years to make significant
strides in decontamination, stabilizing, and managing radioactive wastes, or replace it.
RESPONSE
DOE acknowledges its responsibility for safe management of radioactive materials, including SNF and
radioactive wastes.  DOE is committed to comply with all applicable Federal and state laws and
regulations, DOE Orders, and interagency agreements governing SNF and radioactive and hazardous
wastes.  According to Volume 2, Chapter 2, two programmatic EISs are being prepared at the national
level regarding DOE's SNF Program (Volume 1) and DOE's Environmental Restoration and Waste
Management Program (a separate forthcoming document). Additionally, DOE prepared a DOE-Owned
Spent Nuclear Fuel Strategic Plan for the safe, reliable, and efficient management of DOE SNF and its
preparation for disposal.  This plan is available to the public.
For more discussion on DOE's legal authority and responsibility for managing radioactive materials, see the
response to comment 03.04 (010).

II COMMENT

The commentor states that receipt of spent nuclear fuel from foreign research reactors may overload
existing storage capacities at the Norfolk Naval Shipyard.
RESPONSE
Volume 1, section 4.6 of the EIS states that the Norfolk Naval Shipyard is being considered solely for
temporary storage of Naval SNF, not SNF from DOE facilities or international sources.  Hampton Roads,
Virginia, is a potential port of entry being analyzed in the forthcoming EIS on the Proposed Nuclear
Weapons Nonproliferation Policy Concerning Foreign Research Reactor Spent Nuclear Fuel (Draft).

II COMMENT

One commentor favors keeping foreign spent nuclear fuel out of the United States.  Others question the
need, cost, motive, legality, or reasons behind such returns, especially given the ability to manage FRR
SNF overseas.  Another commentor states that this EIS should address what happens before the fuel lands
on our shores.
RESPONSE
Alternatives related to the acceptance of FRR SNF of United States origin, including shipping, are being
analyzed in a separate EIS.  This EIS does analyze the impacts of domestic transportation and management
of FRR SNF, which represents less than 1 percent of all SNF addressed in this EIS, should a decision to
return such fuel be made.  The environmental impact analyses are designed to produce a reasonable
projection of the upper bound for potential environmental consequences.  This requires the use of
appropriately conservative assumptions and analytical approaches.  In this context, "conservative" means
that an assumption or analysis would tend to overpredict, rather than underpredict, any adverse impacts.  
However, overly conservative analyses do not provide a useful basis for comparing alternatives.  DOE will
not make a final decision on the acceptance of FRR SNF until the EIS on a Proposed Nuclear Weapons
Nonproliferation Policy Concerning Foreign Research Reactor Spent Nuclear Fuel and this EIS are
completed.  
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be
small.

II COMMENT

The commentor discusses the need for cleanup at other sites, including non-DOE sites, including
consideration of alternatives that gauge environmental and accidental risks.  It was noted that the EIS
should address these problems.  The commentor states that DOE has willfully and illegally failed to
request the funding necessary to cease discharges and implement best available treatment and closed fuel
cooling to meet the deadlines in the Hanford Cleanup Agreement.  The commentor states this leads to a
lack of confidence for the storage of any additional fuels at Hanford.
RESPONSE
Cleanup at sites other than INEL is not within the scope of this EIS, which addresses programmatic
management of SNF at all sites (Volume 1), and limited to cleanup and waste management activities at
INEL (Volume 2).  However, the Secretary of Energy has publicly affirmed that current DOE policy and
practice emphasizes safety and environmental considerations above other program goals.  DOE is working
closely with EPA to remediate and eliminate adverse environmental impacts from past programs.  No
significant potential environmental impacts have been identified for any of the alternatives identified in the
EIS for SNF management.

II COMMENT

The commentor states that at a public meeting unrelated to the EIS, the commentor's suggestion to reuse
nuclear waste was ignored.  The commentor also states that the current administration has an anti-nuclear
policy.
RESPONSE
This EIS pertains to the programmatic SNF management and SNF management, environmental restoration,
and waste management at INEL.  SNF reprocessing to recover uranium and plutonium for defense purposes
is being phased out as a matter of national policy.  As discussed in Volume 1, section 1.1.3, however, SNF
processing is being evaluated for certain types of SNF for the purpose of stabilizing, rather than the
recovering, fissile materials, which would not eliminate the need for storage and eventual disposal.  The
nuclear policy of this administration is outside the scope of this EIS.

II COMMENT

The commentor expresses opinions regarding storage or disposition of fissile material, including such
material if foreign research reactor and spent nuclear fuel are reprocessed in Europe.
RESPONSE
These concerns relate to the management of special nuclear material, not DOE SNF,  which is no longer
being reprocessed to recycle fissile material.  Future management of the current inventory of special
nuclear material will be addressed in the forthcoming EIS for the Storage and Disposition of
Weapons-Usable Fissile Material, as described in Volume 1, section 1.2.3.  See also the response to
comment 06.09 (013).

II COMMENT

The commentor expresses an opinion that areas of little or no population and/or areas not near sensitive
resources are best suited for the management of spent nuclear fuel.  The commentor also urges DOE to
select the safest site for the management of spent nuclear fuel.
RESPONSE
Although SNF management activities can safely coincide with high population or otherwise sensitive areas,
risks can be higher in such areas.  However, public perceptions of risk from DOE and/or Navy activities
tend to significantly exceed the risks as presented in this EIS.
The EIS evaluates 10 sites as reasonable alternative sites for some level of SNF management.  The analysis
in the EIS includes a number of factors, including the risk to the public from operations and reasonably
foreseeable accident conditions.  Discussions on public health and safety can be found in the Occupational
Public Health and Safety sections in Volume 1 (and its associated site-specific appendices A through F)
and in the Health and Safety section in Volume 2.  The EIS concludes that the consequences to the public
and the environment due to SNF management activities at any of the 10 sites under consideration would be
small.  DOE tries to avoid high-population areas to the extent practicable.

II COMMENT

The commentor raises questions regarding management of special nuclear materials and secondary wastes
generated by spent nuclear fuel processing, specifically the Actinide Recycle Demonstration Project, and
questions details of the Actinide Recycle Demonstration Project.  The commentor requests 
that the EIS provide additional information on projects or facilities that are in preliminary planning stages.
RESPONSE
The Electrometallurgical Process Demonstration Project (formerly the Actinide Recycling Demonstration
Project) is discussed in Volume 2, section 3.1.1, where SNF activities under the various alternatives are
discussed.  More detailed information is in Volume 2, Appendix C, section SNF8.  The objectives of this
demonstration are to investigate electrochemical processing of SNF, to produce a waste form that is
potentially suitable for a geologic repository, and to quantify volumetric reduction factors.  This
demonstration would produce high-level radioactive waste containing fission products, because SNF would
be processed.  Mixed wastes also would emerge because of electrorefiner operation involving cadmium,
plus sodium contaminants in the SNF to be used for this demonstration. 
Management of special nuclear materials such as highly enriched uranium is being covered by a separate
EIS and is outside the scope of this EIS.  Specific information is not available for facilities that have not
been constructed or activities that have not been conducted to acquire a valid baseline.  Generic projects
have been included in the EIS as placeholders to present readers with as comprehensive a range of
forthcoming projects as is currently possible.   These projects or facilities may require additional NEPA
documentation.  At such time, accurate information on secondary waste generation will be provided for an
assessment of impacts on waste management.

II COMMENT

The commentor states that the period of interim storage addressed in this EIS should not fix the date of
repository availability, and that consideration should be given to recycling rather than disposal.
RESPONSE
Decisions as to the ultimate disposition of SNF have not been made, and are outside the scope of this EIS. 
Ultimate disposition of  DOE SNF is a high priority.  For planning purposes, DOE had determined that the
SNF managed by DOE that is not otherwise dispositioned (e.g., chemically separated, with the high-level
waste being converted into a vitrified glass for repository disposal) is authorized for disposal in the first
repository.  This authorization is subject to the physical and statutory limits of the first repository, DOE
SNF meeting repository acceptance criteria, and payment of fees.  As part of its SNF management program,
DOE would (1) stabilize the SNF as needed to ensure safe interim storage, (2) characterize the existing
SNF inventory to assess compliance with the first repository's acceptance criteria, and (3) determine what
processing, if any, is required to meet the criteria.  Decisions regarding the actual disposition of DOE SNF
would follow appropriate review under NEPA and be subject to 
licensing by NRC.  This path forward would be implemented so as to minimize impacts on the first
repository schedule.
The 40-year period of interim management proposed in this EIS is designed to bound the date for decisions
on ultimate disposition to be made and necessary facilities, such as a potential repository, available for
implementation.  Yucca Mountain is being studied as a suitable geologic repository.  If the site is found
suitable, acceptance of commercial SNF is expected to begin in 2010.  Although acceptance of DOE
high-level waste is planned for 2015, the date for acceptance of DOE SNF at the repository has not been
finalized.
The current policy of DOE precludes the reprocessing of SNF to recover fissile materials.  Although such
policies are subject to periodic review, a need for the recovery or recycling of such materials is not
currently foreseen.

II COMMENT

The commentor believes that nonfinancial costs of spent nuclear fuel management, to the environment,
resources, and people, should be included in DOE's decision.
RESPONSE
DOE interprets the nonfinancial costs identified by the commentor to mean impacts to the environment. 
Volumes 1 and 2, Chapter 5 summarize the environmental impacts for all of the alternatives considered in
this EIS.  The impacts for all of the alternatives would be small.

II COMMENT

Commentors express opinions about the history of spent nuclear fuel mismanagement.
RESPONSE
The condition of SNF management facilities is the result of a number of factors.  Regardless of those
factors, it was recognized that the condition of these facilities cast doubt on the ability to continue to safely
manage SNF.  Therefore, DOE prepared a report commissioned by the Secretary of Energy on
vulnerabilities of the current program and has been directed by the Secretary to develop an integrated,
long-term SNF program.  The  SNF vulnerability assessment and associated action plans to resolve
identified vulnerabilities are identified in the EIS in Volume 1, section 1.1.2 and Appendix J, and Volume
2, section 2.5.2.  Additional site-specific information is in Volume 1,  Appendices A through F. 
Environmental consequences of SNF management for all alternatives are discussed in Volume 1, section
5.1, and mitigation measures are discussed in section 5.7.  For all alternatives analyzed, the impacts would
be small.

II COMMENT

The commentor indicates that information on the Fort St. Vrain site was incorrect and provided appropriate
data.
RESPONSE
These data have been incorporated into Volume 1, section 4.7.3, and Volume 1, Appendix E, 
section 3.3.2.

II COMMENT

The commentor suggests minor text revisions to the Fort St. Vrain project summary in 
Volume 2.
RESPONSE
The EIS has been changed to reflect the commentor's recommendation for text changes to the Volume 2
summary.

II COMMENT

The commentor notes that Volume 1, Appendix A, section 2.1.4 fails to mention the Bechtel Hanford
Company and states the opinion that privatization of certain activities may bring additional contractors into
key roles.
RESPONSE
The following sentence was added to the end of Volume 1, Appendix A, section 2.1.4:  "In 1994, the
Bechtel Hanford Company and a team of subcontractors became DOE's environmental restoration
contractor at the Hanford Site."   Future contractor arrangements at the Hanford Site are outside the scope
of this EIS.

II COMMENT

The commentor states that the EIS does not solve the current Idaho National Engineering Laboratory spent
nuclear fuel problems, let alone the ones that will be there in 40 years.
RESPONSE
Volume 1, Chapter 1 discusses DOE's plan to develop an integrated, long-term SNF program.  The
discussion also points out a number of reasons why DOE cannot make all decisions regarding SNF
management for the next 40 years at this time.  These reasons include (a) lack of characterization data on
the interim storage behavior of certain types of SNF and (b) lack of acceptance criteria for ultimate
disposition.  Volume 1, Appendix J identifies a number of activities currently under way to define a
management path and proceed toward ultimate disposition.  This EIS is one step in the plan to address
ultimate disposition.
This EIS is not a decision-making document; rather, it is a tool designed to aid the decision-making process
by evaluating the environmental consequences of proposed actions and their alternatives.  This information
is used by decisionmakers in conjunction with other information, such as costs and budgets, to determine a
course of action.

II COMMENT

Commentors request information on the relative merits of wet storage versus dry storage of spent nuclear
fuel.  Commentors state that the EIS does not distinguish the consequences of reprocessing versus dry and
wet storage.  Information is also requested on spent nuclear fuel types, costs and benefits of processing,
short-term activities to fix storage problems, storage facility design, and work-force requirements.  Other
commentors question why the two storage types are not split into two alternatives.
RESPONSE
Volume 1, Chapters 1, 4, and 5 and Appendix J, and Volume 2, Chapters 2 and 4 and Appendix F provide
the requested information.  Volume 1, section 3.3 summarizes the Spent Fuel Management Cost 
Evaluation Plan.  Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the
environmental impacts of all the alternatives considered in this EIS.  The analyses show that the impacts of
all alternatives would be small.

II COMMENT

The commentor expresses a general opinion that engineering has its limitations and fails to take into
account consequences and that the consequences of that engineering bring about and put a tremendous
burden on the whole society to solve those problems.
RESPONSE
The commentor's opinion regarding engineering and its perceived limitations is noted.

II COMMENT

The commentor wants to keep spent nuclear fuel where it is until "we come up with something safe."
RESPONSE
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be
small.  While there are differences in the impacts among the alternatives, these differences by themselves
are not sufficient to distinguish between alternatives.  Volume 1, section 3.1 describes the preferred
alternative for programmatic SNF management.  
See also the response to comment 04.04 (008).

II COMMENT

The commentor objects to reactor irradiated nuclear material continuing to be generated and causing
serious health effects. 
RESPONSE
Eliminating all current and future generation of DOE SNF would not significantly diminish the handling,
storage, and final disposition challenges DOE faces.  Inventories of DOE SNF are addressed in Volume 1,
section 1.1.  Approximately 86 percent of the current inventory originated in DOE weapons-production
reactors that have ceased to operate.  Another 8 percent was generated in DOE experimental reactors, most
of which have been shut down.  According to Volume 1, Table 1-1, the additional SNF to be generated
over the next 40 years (until 2035) will amount to only a 3-percent increase in the current inventory. 
Eliminating sources of DOE SNF altogether would require halting nuclear Navy operations and nuclear
research at universities, which is not within the control of DOE and is outside the scope of this EIS.

II COMMENT

The commentor asks how DOE will correct storage problems and what new designs have been tested for
handling and storing spent nuclear fuel.  Furthermore, the commentor is of the opinion that the EIS does
not address the broad issues of permanent storage and availability of mature technology.
RESPONSE
The potential impacts of storing radioactive materials associated with SNF are discussed in Volume 1,
Chapter 5.  Environmental consequences of SNF management are presented for all alternatives in Volume
1, section 5.1, and mitigation measures are discussed in section 5.7.
Problems at existing storage facilities have been identified in Spent Fuel Working Group Report on
Inventory and Storage of the Department's Spent Nuclear Fuel and Other Reactor Irradiated Nuclear
Materials and Their Environmental, Safety and Health Vulnerabilities.  This report, commonly called
the SNF vulnerability assessment, and associated action plans to resolve identified vulnerabilities are
acknowledged in Volume 1, section 1.1.2 and Appendix J-2.  Additional site-specific information is
presented in Volume 1, Appendices A through F.
At INEL, there is an ongoing dry storage demonstration project to gain information and experience with
using commercial dry storage casks for DOE fuels.  Dry storage is addressed in Volume 1, section 1.1.3 and
Appendix J.  
Volumes 1 and 2, and Appendix D discuss the impacts of waste management on INEL and SNF
management.  These impacts would be small under all alternatives considered in the EIS.  DOE determined
that the transfer of SNF at INEL from potentially unsafe storage to a newer storage facility is an effective
interim action that can be conducted prior to completion of this EIS.  Depending on the alternative selected
in the ROD for this EIS, various projects are proposed for interim storage and treatment of SNF pending a
later decision on ultimate disposition.  DOE will implement the reflected projects, described in Volume 2,
Appendix C, to address the deficiencies with current storage.  The proposed projects include reracking of
existing underwater storage facilities to more effectively use their capacities, constructing modular dry
storage facilities for longer-term storage, and processing facilities to treat and stabilize some SNF for
interim storage.  Commercial experience is considered whenever possible to increase public acceptance and
reduce costs and schedules.  The alternatives analyzed attempt to balance considerations such as using
existing facilities, minimizing transportation, consolidating similar fuels, and others.

II COMMENT

The commentor states that DOE fails to explain how spent nuclear fuel should be properly managed and
disposed of.  
RESPONSE
Volume 1, section 3.1 describes the preferred alternative for programmatic SNF management.  Volume 1,
Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of all the
alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be small.  
Volume 1, Appendix B, Chapter 2, specifically discusses INEL's program objectives.   
See also the response to comment 04.04 (008).

II COMMENT

The commentor states that the EIS fails to take an integrated approach to addressing the multitude of issues
involved in handling and storing spent nuclear fuel.
RESPONSE
Volume 1, Chapter 1 discusses DOE's plan to develop an integrated, long-term SNF program.  Volume 1,
Appendix J identifies a number of activities currently under way to define a management path to proceed
toward ultimate disposition.  DOE's Plan of Action to Resolve Spent Nuclear Fuel Vulnerabilities 
identified in the Spent Fuel Working Group Report on Inventory and Storage of the Department's Spent
Nuclear Fuel and Other Reactor Irradiated Nuclear Materials and Their Environmental, Safety and
Health Vulnerabilities identified this EIS as a vehicle to address the lack of a path forward for the ultimate
disposition of SNF.  In addition, this EIS focuses on a programmatic approach to SNF management. 
Site-specific SNF management issues will be addressed by additional NEPA reviews tiered from this EIS.

II COMMENT

The commentor requests that more details and options be provided in the EIS concerning costs of
alternatives, storage facility design, types of processing, improved long-term storage safety, and final spent
nuclear fuel disposition.  The commentor states that many of these same concerns were raised during the
scoping meetings and have not been adequately addressed, including minimization of spent nuclear fuel
transportation.
RESPONSE
The EIS has been augmented to include the estimated range of costs for each of the SNF programmatic
alternatives.  The  technological options for interim storage, transportation,  stabilization, and processing
are discussed in Volume 1, Appendix J.  Evaluation of specific designs and technology options are not
required at the programmatic NEPA level and will be analyzed in follow-on site-specific NEPA
documents.  DOE received approximately 1,900 comments during on the EIS scoping process.  DOE
attempted to respond to all the public concerns; however, the ultimate disposition of DOE SNF cannot be
specifically addressed in this EIS due to unknown future requirements for geologic repository acceptance
criteria, which in turn affect stabilization and treatment strategies.  The range of technological options that
DOE believes may be required for stabilization, treatment, or preparation for ultimate disposal are
discussed in Volume 1, Appendix J.  Minimization of transportation is a DOE goal consistent with safe and
efficient operations.

II COMMENT

The commentor states that the EIS should evaluate the best storage form, processing requirements and
other technical considerations required for long-term management of spent nuclear fuel.
RESPONSE
Volume 1 of the EIS is programmatic in nature and addresses the major management decisions while laying
the groundwork for the more specific technical decisions that the commentor believes should be evaluated,
such as the best storage form and processing requirements for specific fuel types.  However, the EIS
discusses the current SNF management problem and the need for action in Volume 1, Chapter 1. 
Technical considerations and solutions to the management problems are addressed in Volume 1, Appendix
J, including storage options, containers, and processing options.

II COMMENT

The commentor states that storage is not the optimum strategy for spent nuclear fuel management. The
commentor also states that plutonium is too readily available for making weapons and that it must be
degraded as rapidly as possible while maintaining the safety of the environment and the ability to recover
other valuable constituents.
RESPONSE
This EIS does not consider ultimate disposition of SNF; rather it considers interim storage until the
decisions on ultimate disposition of special nuclear material are made.  The process that will decide the
manner of ultimate disposition, which is the subject of another EIS, will consider the resource value of
SNF and its constituents, as well as the necessary safeguards against diversion of materials for weapons
production.  DOE has a program for safely managing and storing SNF and other radioactive materials at
each of the sites considered in the EIS.  DOE will manage SNF in accordance with applicable Federal,
state, and local requirements and regulations and DOE Orders in a manner that protects the environment
and the health and safety of the public and site employees. 

II COMMENT

The commentor requests that specific corrections or specific additional information regarding the
management options for the fuel elements at the Veterans Administration Medical Center, Omaha,
Nebraska, be included in the EIS. 
RESPONSE
As described in footnotes to Volume 1, Appendix E, Table 2.1-3, the Veterans Administration Medical
Center in Omaha, Nebraska, is a Category 2 Facility that does not routinely generate SNF.  No SNF is
expected to be generated by this facility during the period covered by this EIS.  Volume 1, section 1.1.2,
Table 1-2 has been deleted from the EIS because it duplicated Volume 1, Appendix E, Table 2.1-3.

II COMMENT

The commentor states that Volume 1, Appendix J does not appear to recognize the complexities that occur
when spent nuclear fuel is damaged, and that oxidation products on the outside of fuel are a source of
facility contamination during canning.  The commentor states that the EIS should be modified to address
this omission.
RESPONSE
The section of Volume 1, Appendix J to which the commentor refers is intended to provide an overview for
the reader of the technology options that are available to DOE for use in preparing SNF for interim storage. 
Technologies would be evaluated for appropriateness for specific fuels prior to use.  This evaluation would
identify potential problems and appropriate mitigation measures.  The potential for damaged or externally
contaminated fuels is routinely considered in DOE's evaluations of technologies for treatment or
conditioning of SNF.

06.09 (050) Miscellaneous

COMMENT
The commentor states that the Project Summary on Fort St. Vrain spent fuel shipments references a
previously prepared environmental assessment that may not be relevant. 
RESPONSE
The EIS has been corrected in response to this comment.

06.09 (051) Miscellaneous

COMMENT
The commentor expresses the opinion that the storage of spent nuclear fuel has adversely impacted Native
Americans and will next destroy the institution of the American family farm.
RESPONSE
Volume 1, Chapter 5 and Appendix K, and Volume 2, Chapter 5 summarize the environmental impacts of
all the alternatives considered in this EIS.  The analyses show that the impacts of all alternatives would be
small.

06.09 (052) Miscellaneous

COMMENT
The commentor notes that in Volume 1, section 4.6.5 the effective dose equivalent is provided in rem per
year, but in Appendix D, effective dose equivalent values are provided in millirem per year.  The
commentor suggests that units be consistent throughout the document.
RESPONSE
The EIS has been revised to ensure uniformity in units throughout the document.

06.09 (053) Miscellaneous

COMMENT
The commentor wants to ensure that mitigation is an integral part of planning and suggests that mitigation
should consider avoidance, minimization, rectification, and compensation.
RESPONSE
If necessary, a mitigation action plan will be prepared for this EIS in accordance with the CEQ regulations
at 10 CFR 1021.  All necessary mitigation is generally noted in this EIS.  Volume 1, section 5.7 addresses
mitigation measures relative to environmental impacts.