Supplement Analysis for the Site-Wide Environmental Impact Statement for Continued Operation of Los Alamos National Laboratory -- Recovery and Storage of Strontium-90 Fueled Radioisotope Thermal Electric Generators at Los Alamos National Laboratory

This Supplement Analysis (SA) has been prepared to determine if the Site-Wide Environmental Impact Statement for Continued Operations of Los Alamos National Laboratory (SWEIS) (DOE/EIS-0238) adequately addresses the environmental effects of recovery and storage for disposal of six strontium-90 (Sr-90) fueled radioisotope thermal electric generators (RTGs) at the Los Alamos National Laboratory (LANL) Technical Area (TA)-54, Area G, or if the SWEIS needs to be supplemented. DOE's National Nuclear Security Administration (NNSA) proposed to recover and store six Sr-90 RTGs from the commercial sector as part of its Offsite-Source Recovery Project (OSRP). The OSRP focuses on the proactive recovery and storage of unwanted radioactive sealed sources exceeding the US Nuclear Regulatory Commission (NRC) limits for Class C low-level waste (also known as Greater than Class C waste, or GTCC). In response to the events of September 11, 2001, NRC conducted a risk-based evaluation of potential vulnerabilities to terrorist threats involving NRC-licensed nuclear facilities and materials. NRC's evaluation concluded that possession of unwanted radioactive sealed sources with no disposal outlet presents a potential vulnerability (NRC 2002). In a November 25, 2003 letter to the manager of the NNSA's Los Alamos Site Office, the NRC Office of Nuclear Security and Incident Response identified recovery of several Sr-90 RTGs as the highest priority and requested that DOE take whatever actions necessary to recovery these sources as soon as possible. This SA specifically compares key impact assessment parameters of this proposal to the offsite source recovery program evaluated in the SWEIS and a subsequent SA that evaluated a change to the approach of a portion of the recovery program. It also provides an explanation of any differences between the Proposed Action and activities described in the previous SWEIS and SA analyses