As you may know from Tri-Valley CAREs recent electronic newsletters, the National Nuclear Security Administration is undertaking a new Site-Wide Environmental Impact Statement (SWEIS) for Continued Operation of the Lawrence Livermore National Laboratory.
This is an extremely important process – it will determine the limits for the environmental impacts the Lab will be allowed to generate for the next 15-years.
All public comments, whether submitted in writing or offered orally at a public hearing, are equally important. This is YOUR opportunity to have your voice heard.
You may comment on things that are contained in the SWEIS. Equally, you may comment on things you believe should be analyzed the SWEIS. And, you may also comment on what you see as “reasonable alternatives” to the shocking expansion of nuclear weapons activities that the government proposes in the SWEIS. In other words, what would like to see take place at Livermore Lab instead?
The SWEIS is being done pursuant to the National Environmental Policy Act (NEPA), and, under the law, the agency must respond in the final document to all comments it receives.
This electronic news alert contains three parts
In part one: Tri-Valley CAREs’ Executive Director, Marylia Kelley, shares some excerpts from the SWEIS that she will be highlighting at the upcoming public hearings. You are invited to add your own perspective to the 12 talking points Marylia provides, and to use them in your own written or oral comments.
Note: Marylia and Tri-Valley CAREs’ Staff Attorney, Scott Yundt, will continue to offer additional points from the document as we make our way through the 3-volumes and more than 1,400 pages that comprise the entire SWEIS.
In part two: Tri-Valley CAREs’ Board President, Loulena Miles, shares some of her planned testimony on the SWEIS. Loulena is an attorney, and she focuses on the ways the nuclear weapons proposals in the SWEIS do not comply with international law, despite the bald assertion in the document that everything is “fully consistent with current treaty obligations.” Some of this material stems from various Tri-Valley CAREs forums, and Loulena invites you to use any of it you wish in your comments.
In part three: We summarize the SWEIS meeting notices.
Part One: “Shocking plans, talking points & page references”
The SWEIS proposes to raise the allowable limits on tritium (radioactive hydrogen) and weapons-grade plutonium at Livermore Lab. Members of the public should oppose these increases. Here are a few details on the SWEIS plans to increase radioactive dangers for workers, the public, and the environment in which we all live.
- The SWEIS proposes an increase in the emissions limit for radioactive tritium from two locations – the main tritium facility in the “Superblock” and the National Ignition Facility (NIF). The larger releases are slated to begin in 2023 (see page S-40).
In the context of these planned increases, the SWEIS describes loading tritium reservoirs with up to 1,500 curies of tritium at time. It then states that both the main tritium facility and the NIF could release the entire tritium load directly into the environment without having it go through any tritium “recovery system” (see section 3.3.3).
One curie is a large amount of radiation, equal to 37 billion radioactive disintegrations per second. If this plan is not stopped, it will put radioactive tritium directly into the air we breathe; it will travel with the wind and tumble into our neighborhoods as it goes, fall out over our homes in the rain, and become organically bound in our plants. Tritium exposure is related to numerous bad heath outcomes, including deadly cancers.
- The SWEIS proposes to increase the administrative limit for weapons-grade plutonium in building 235 from its current allowable limit of 8.4 grams or less to a new limit of 38.2 grams (see page S-41). The administrative limit refers to how much weapons-grade plutonium can be in the building at one time. This is an increase of nearly 5x. Plutonium can be deadly in microscopic amounts; it emits extremely high-energy rays (alpha particles) that tear through tissue as the plutonium radioactively disintegrates within the body.
- The SWEIS also proposes to revise the administrative limits for “radioactive materials” at the NIF. The radioactive materials used at the NIF include tritium; however, plutonium-242 is also used in NIF experiments. While the description on page S-41 is very sparse, this may be a big deal, and should be called out.
In sum, the public should demand that all three of these plans be canceled!
The SWEIS fails to provide any real alternatives, which is contrary to the intent of the National Environmental Policy Act that lays out the requirements for a SWEIS. Instead, the document only contains a broad brush “no action” alternative and a “proposed action” alternative.
Furthermore, the “no action” alternative should be limited to the programs and the current scope of activities that already exist at Livermore Lab. Yet, in this SWEIS, the NNSA has shoveled in 19 new projects (totaling 416,300 square feet) and called them part of the “no action” alternative.
To offer one example, included in the 19 new projects is 25,000 square feet of new plutonium infrastructure in the main plutonium facility in the Livermore Lab’s “Superblock” (page S-26 plus the map that precedes it).
To offer some context, the term Superblock at the Livermore Lab Main Site designates a collection of core nuclear weapons facilities including the main plutonium facility (building 332) with plutonium globe box lines, furnaces and a huge plethora of experimental and fabrication areas, the main tritium facility (building 331) with tritium glove boxes, high pressure fill operations (and even actinide [plutonium] operations located in the tritium facility’s segment 2), and the hardened engineering test facility (building 334) where plutonium bomb cores or parts are shocked, shaken and heated to demonstrate how the radioactive metal will perform from launch to detonation (yes, this means nuclear war). The Livermore Lab contains many, many other nuclear weapons buildings, but those in the Superblock are considered the Lab’s nuclear weapons development centerpiece. Many hazardous activities, accidents, spills and releases have occurred here.
The public should demand that the “no action” alternative be truly “no action” and that the 19 new projects be removed. Furthermore, the public should comment on true alternatives (like conversion of the Lab to civilian science) and not limit themselves to the 2 generic ones in the SWEIS that both expand nuclear weapons activities.
Nuclear weapons activities already make up about 88% of the more than $2 billion dollars the Lab receives annually from the Dept. of Energy. It is just wrong for the SWEIS to present the public with one alternative that increases nuclear weapons activities under supposed “no action” and a second alternative that puts new weapons activities on steroids.
The “proposed action” alternative (meaning what the Lab wants) includes a shocking 75 new projects totaling 3.3 million square feet (see page S-42 and the table). In case you think square footage is boring, let me share a sampling of the projects that square footage will contain. (Note, I am continuing the numbering system I began with above for specifics items.)
- The proposed action in the SWEIS includes a new, 60,000 square foot, “Next Generation Life Extension Program Research & Development Fabrication Building.” This is for new warhead work, including the fabrication (production) of new-design weapons components in order to test them out (see page S-38 and surrounding pages). This is not only nuclear proliferation provocative and costly, it can also be quite hazardous to human health and the environment. It should not be built.
- The proposed action in the SWEIS includes building a 75,000 square foot “Advanced Hydrotest Facility” at Site 300 (see page S-40). This may alarm some Livermore Lab old-timers and Tri-Valley CAREs members alike. In the mid-1990s, Livermore Lab pushed for a new AHF at Site 300. However, Site 300 was determined to be an inappropriate location due in part to the AHF’s associated hazards and the proximity of the public. Over the last 25 years, the City of Tracy has expanded its boundary toward Site 300 and the population has skyrocketed. The public should oppose this project!
- Other new projects at the Lab’s Main Site include a new Engineering Shop support facility, a new Nuclear Science Center, a new High Bay, a new “Classified Lab” (why not disclose at least its name, which is done done with other classified facilities?), and more. These are all directly related to new weapons activities, assuming the “Classified Lab” is in that grouping (see Pages S-38 to S-40).
- Specific to NIF and related weapons research, the proposed action includes a new “High Energy Density” support facility and a “Future NIF Laser Expansion”.
- At Site 300, additional facilities in the proposed action alternative include a new “Weapons Test Facility,” and a new “Accelerator Bay and Support Bunker” expansion, among others.
In sum, the public should outright oppose this huge expansion of new nuclear weapons development activities at the Lab. If this goes forward the way it is outlined in the SWEIS, it will enable a whole generation of new warhead development.
- The SWEIS discloses that there will new plutonium activities at Livermore Lab, however the “mission” has been vague and opaque! Tri-Valley CAREs has documented through other sources that Livermore Lab will have a “hands on” role in NNSA’s plans for expanded plutonium pit production.
The production of the 80 or more new pits per year would take place at the Los Alamos Lab in New Mexico and the Savannah River Site in South Carolina. However the federal budget contains money for new plutonium glove boxes at Livermore Lab that are expressly to support “expanded plutonium pit production”. And, a Los Alamos National Lab NEPA document states that LANL will ship plutonium to Livermore for “materials testing” in support of “expanded plutonium pit production.”
So we know there is a connection between Livermore Lab’s ramp-up of its plutonium activities and infrastructure and expanded pit production. The public has a right to be able to do the see clearly which activities are related to the very controversial plan to expand plutonium pit production – and to comment specifically on Livermore Lab’s role.
In sum, the SWEIS should do a crosswalk that would enable those public comments. This SWEIS deficiency should be called out. The public should demand a dedicated section in the SWEIS that details Livermore Lab’s role!
- There is a startling admission in the SWEIS about the dangers of the release of toxic and radioactive materials in a “design basis” earthquake (see pages S-32 and S-33). First, we know that the next Bay Area earthquake may exceed “design basis.” The map lists a dozen building with “seismic deficiencies” including building 235, which is the building discussed above in which the SWEIS would increase the administrative limit for weapons-grade plutonium nearly 5x!
- The SWEIS describes a new Livermore Lab laser isotope pilot program to enrich uranium on site. Long time Lab workers and Tri-Valley CAREs members alike may recall the fiasco at Livermore Lab called Uranium Atomic Vapor Laser Isotope Separation. The facility cost billions of dollars and never worked. What it did do was release hazardous materials into the environment, some of which ended up in groundwater near the building. It was finally canceled. Son-of-Uranium-Atomic-Vapor-Laser-Isotope-Separation should not be built!
Please use these talking points and notes, taken from the 100-page SWEIS summary document, as you see fit in your comments.
- Extend the comment period. You may have seen Tri-Valley CAREs recent electronic “action alert” outlining Tri-Valley CAREs’ letter to the NNSA requesting a 30-day extension to the public comment period. In your oral or written comments, please remember to ask for the extension. See also part 3 below for ways to submit your request.
Part Two: “The SWEIS is out of compliance with International Law”
The SWEIS states that the proposed action is in compliance with international law. The SWEIS says, “NNSA missions are conducted fully consistent with current treaty obligations.”
We vociferously disagree. Livermore Lab has been working to modernize the arsenal and push the envelope on weapons capabilities, essentially turning them into new weapon designs. This not only promotes nuclear development worldwide (everyone wants to keep up with the Jones not just for their credibility but also for their survival.) Livermore Lab is playing a central role in driving a new and dangerous global arms race. With the war in Ukraine and Russian nuclear saber-rattling, the U.S. nuclear weapons budget throws fuel on the fire of potential nuclear war. This is fundamentally in contradiction with our obligations under the Non-Proliferation Treaty (NPT).
The SWEIS states “[t]he NPT does not provide any specific date for achieving the ultimate goal of nuclear disarmament, nor does it preclude the maintenance of nuclear weapons until their disposition. Continued operations at LLNL enable NNSA to maintain the safety, reliability, and performance of the U.S. nuclear weapons stockpile until the ultimate goals of the NPT are attained [disarmament] and are consistent with the NPT.”
This is manifestly incorrect. The Lab’s objectives to maintain the arsenal include Life Extension Programs that are unnecessary, expensive, environmentally polluting and promote the nuclear arms race worldwide.
The country’s current stockpile of more than 5,000 nuclear weapons has been extensively tested and certified reliable and will be for decades to come. The escalating cost of maintaining the stockpile is not due to the difficulty of the task or the effects of aging warheads. It is caused by increasingly elective changes introduced into the stockpile as part of the Life Extension Program (LEP). (Note: the U.S. has 5,428 nuclear weapons according to the Federation of American Scientists, 2022.)
The desire to modify warheads or develop new warheads is a primary factor in the push to upgrade other parts of the nuclear enterprise. The cost of modernizing the stockpile, including infrastructure and delivery systems, is estimated to be $1.7 trillion over 30 years with a modest rate of inflation.
Some of the programs that need to be analyzed in the SWEIS are:
- Whether the development of the W80-4 “Long-Range Stand Off” weapon is in compliance with our treaty obligations under the NPT. (This weapon is intended for pilots to be able to “stand off” a target by thousands of miles and launch a precisely guided, radar evading nuclear weapon.) By any measure Livermore’s new warhead for this LRSO (Long Range Stand Off capability) is an offensive first-use weapon that is completely out of compliance with our treaty obligations and with our commitment to stockpile stewardship. Livermore Lab is also planning to develop that new warhead (the W80-4) into a version that would be placed on small attack subs that do not now have any nuclear weapons on them. These new nuclear weapons would not be distinguishable from the conventional weapons currently on board these ships. That means that a country under attack might not be certain if the warhead heading toward it was conventional or nuclear – this is one scenario whereby a nuclear war could start by miscalculation.
- The SWEIS should also analyze whether the development of the W87-1 is in compliance with our treaty obligations under the NPT. The W87-1 is the first wholly new warhead design since the end of the cold war. The W87-1 is slated to sit atop a new intercontinental ballistic missile, called the Sentinel Missile. The Lab is looking into 126 new technologies for this warhead design. This includes a new-design plutonium bomb core, called a “pit,” significantly different from anything in the U.S. stockpile. Livermore’s W87-1 warhead is a central reason the U.S. is planning to expand plutonium pit production at 2 locations – the Los Alamos Lab in NM and the Savannah River Site in SC. In fact, every plutonium pit that will be produced for at least 12-years will go inside a W87-1 warhead.
These new warhead designs do not comply with our treaty obligations. The US has an obligation under Article VI of the Nuclear Nonproliferation Treaty ‘to pursue negotiations in good faith on effective measures relating to cessation of the nuclear arms race at an early date and to nuclear disarmament…’
The International Court of Justice further clarified “There exists an obligation to pursue in good faith and bring to a conclusion, negotiations leading to nuclear disarmament in all its aspects under strict and effective international control.” Advisory opinion on the Legality of the Threat or Use of Nuclear Weapons, July 8, 1996.
We are not working in good faith toward nuclear disarmament when we are creating new weapons designs.
Not only is the Lab’s work out of compliance with our treaty obligations under the NPT but the Lab’s work is making our world more dangerous. Because the US does not take a leadership role in stopping the nuclear arms race, we just fan the flames of nuclear proliferation everywhere. And it is a dangerous time to do so. Internationally the world is on the brink of the use of nuclear weapons. Russia is continually threatening their use. North Korea is parading their new missiles as a show of force. China is revamping their nuclear infrastructure. Through this SWEIS, Livermore Lab is committing to continue the nuclear arms race indefinitely. How long will the human race survive if we don’t take decisive action and play a leadership role in eliminating nuclear weapons collectively?
To frame this in terms of the Site Wide Environmental Impact Statement, the Lab, under the National Environmental Policy Act has an obligation to study the potentially significant environmental impacts of their actions. There may be no greater significant environmental impact than nuclear war. Just living under the threat of nuclear war affects the psychology of our nation and the world.
Loulena additionally notes: The timing of the public comment period is in Bad Faith.
It is sadly in the Department of Energy’s bad faith playbook to hold a comment period during the Christmas holiday break. People are traveling and visiting family and wrapping gifts during the entirety of the public comment period. We call upon the Department of Energy to act in good faith and change its pattern and practice of holding comment periods during the holiday breaks.
Part Three: Public Hearings & Written Comment Address
The Public Hearings:
1) Wednesday, December 7, 2022 from 6:00pm – 8:30pm
At Garre Vineyard Bella Rosa Room – 7986 Tesla Road, Livermore
(Note: formal public hearing begins at 6:30pm, following an informal session)
2) Thursday, December 8, 2022 from 6:00pm – 8:30pm
At Tracy City Council Chambers – 333 Civic Center Plaza, Tracy
(Note: formal public hearing begins at 6:30pm, following an informal session.)
3) Tuesday, December 13, 2022 from 6:00pm – 8:30pm
This is a virtual public hearing. Meeting Link: http://tinyurl.com/LLNLSWEIS
Join by phone: (669) 900 -9128. Zoom Meeting ID: 852 6045 5697. Zoom Meeting Passcode: 975388
Written Comments, including requests for a 30-day extension:
1) Public comment can be submitted by email to: [email protected]
2) Or comments can be submitted by writing before 1/3/23 (the current end of the comment period) to: Ms. Fana Gebeyehu- Houston, LLNL SWEIS Document Manager, 1000 Independence Ave., SW, Washington, DC 20585
Thank you for your participation in this important process to concretely stem the tide of new nuclear weapons development at Livermore Lab and contribute to a positive change in US nuclear weapons policy.
Stay tuned from more updates from Tri-Valley CAREs as they happen!
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