We at Tri-Valley CAREs have composed a 7-point comment letter that we are asking you to send to the National Nuclear Security Administration during the public comment period on the Livermore Lab’s environmental review.
The comment period closes on Wednesday, January 18. While it is best to send your comments on or before January 18 to ensure your voice is counted, the NNSA stated at its public hearing that it will “monitor the email box for public comments until the end of the month.”
For your reading ease (and that of the NNSA, too) we have numbered each comment 1 through 7. As always, you should feel free to add your thoughts to the “sign and send” letter or to subtract something from it.
To send the comment letter to NNSA, copy the text and then click the email link at the top of the letter to send it to the NNSA Document Manager. Don’t forget to add your name and contact information at the bottom of the letter before you hit “send.”
MY COMMENT LETTER
On the Livermore Lab Draft Site-Wide Environmental Impact Statement
By email to: [email protected]
Postal mail: Ms. Fana Gebeyehu-Houston,
LLNL SWEIS Document Manager,
1000 Independence Ave., SW, Washington, DC 20585
Dear Ms. Fana Gebeyehu-Houston:
These are my comments on the National Nuclear Security Administration’s (NNSA) Draft Site-Wide Environmental Impact Statement (SWEIS) for the continued operation of the Lawrence Livermore National Laboratory (Livermore Lab) Main Site in Livermore, CA and Site 300 high explosives testing range near Tracy, CA.
- Plutonium Increase Opposed. According to the SWEIS, the NNSA is proposing to increase the administrative limits for plutonium mixtures at Livermore Lab’s Building 235 from 8.4 grams plutonium-239 under the No-Action Alternative to 38.2 grams under the Proposed Action. (SWEIS 3-54) 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. This is an unacceptably dangerous increase in plutonium and its associated risk at a site that has failed security drills and is located in close proximity to residential neighborhoods and within a 50-mile radius of nearly 8 million people. The SWEIS should analyze an alternative that removes plutonium from the Lab, rather than increasing it.
- Transparency Needed on Livermore Role in Plutonium Pit Plans. While the SWEIS discloses an increase in plutonium levels for Livermore Lab, as noted above, it inappropriately avoids analysis of the programmatic reason for the increase. Livermore has a “hands on” role in pit production that has environmental risks even though full-scale production of 80 or more pits/year will be done at two other locations. The Government Accountability Office (GAO) states that the NNSA pit production plans “rely” on Livermore Lab and other non-production sites. Here is how GAO describes a key aspect of Livermore’s role: “As the design agency for the W87-1 warhead—the first warhead designed for newly produced pits since the Cold War— Livermore is responsible for qualifying the pit production process and certifying that the pits produced meet the intent of its design. Qualification and certification requires a variety of tests, such as production evaluations, engineering certification testing, physics certification testing, and the replacement of some equipment (GAO-23-104661, January 2023). The SWEIS should make clear all of the ways in which plutonium operations proposed for Livermore Lab are related to NNSA’s expanded plutonium pit production plan. Further, these operations should be canceled.
- Tritium Emissions Increase Opposed. The site-wide air emission of tritium (radioactive hydrogen) will increase from 129.2 Curies of tritium in the 2019 baseline, to 300 Curies of tritium in the No Action Alternative, all the way to 3,610 Curies of tritium for the Proposed Alternative. This is almost a 28-fold increase in the amount of tritium emitted from the Lab. The SWEIS states this will result in a corresponding increase of 27 times the annual dose to the offsite population from the 2019 baseline to the Proposed Action Alternative. Additionally, this will result in an increase of 12 times the numbers of cancers from the 2019 baseline to the Proposed Action Alternative. This is an unacceptable increase in risk. 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 health outcomes, including deadly cancers. The SWEIS should analyze an alternative in which the experiments that require the tritium loading operations are not done at Livermore and tritium activities are reduced, not increased at the Lab.
- No Advanced Hydrotest Facility. The Proposed Action in the SWEIS includes building a 75,000 square foot “Advanced Hydrotest Facility” (AHF) at Site 300 (see page S-40). Livermore Lab pushed for a new AHF at Site 300 in the mid-1990s. 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, increasing the risk of operating the AHF. Further, it is notable that a weapons designer at the time referred to the proposed AHF as “a nuclear weapons designer’s dream,” referring to its capacity to help design new plutonium primaries. The SWEIS should specify the programmatic usages of the AHF and its potential proliferation impacts. The decision should be to cancel plans for an AHF.
- New Bio-Agent & Animal Research Lab Opposed. The SWEIS proposes to replace the current Animal/Biosafety Level-3 Facility with a facility nearly twice the size of the existing facility. (SWEIS 3-38) This lab performs biological defense experiments with highly contagious bio-agents, (including anthrax and botulism) on animals inside of Livermore Lab, a classified nuclear weapons laboratory. There is no mandate for bio-defense research to be done at Livermore (or by this agency). Expanding operations at Livermore Lab creates the optics bio-weapons may be created. Further, this SWEIS did not conduct a separate analysis of a potential biological hazard release, but instead tiered from previous NEPA analyses performed for the BSL-3 facility, despite the proposal to build a larger new BSL-3. (Appendix C, C-48) Reliance on NEPA analyses that are over a decade old and not specifically tailored to the proposed action for the new BSL-3 makes the document’s conclusions of safety doubtful. The SWEIS should analyze both an accident scenario and an Intentional Destructive Act scenario that are specifically tailored to the new BSL-3 as outlined in the Proposed Action. The SWEIS should further analyze the “purpose and need” for this facility and look at whether its work is redundant and/or duplicative of other BSL-3 labs at other agencies. The SWEIS should further analyze the potential for this lab to stimulate the proliferation of biological weapons research in other countries. This expansion of bio-warfare agent research with experiments on animals should be canceled.
- Reduce or Cancel New Warhead Development Programs. Livermore Lab is one of two locations that develop every nuclear warhead and bomb in the U.S. stockpile. The SWEIS is intended to guide Livermore Lab activities for the next 15-years or more. Over that time frame, Livermore’s proliferation-provocative new warhead activities can and should be curtailed and new missions pursued. Instead, the SWEIS only contains programmatic activities that increase Livermore Lab’s new warhead design activities. Livermore Lab is developing several new warheads and variants. Reasonably, the designs could be down-scoped to eliminate novel features or canceled altogether. They include:
- The W87-1, a wholly new warhead currently being designed at Livermore Lab to sit atop a new ICBM that the Pentagon is developing, called the Sentinel missile. The W87-1 will require new plutonium bomb cores (pits) and is a major driver for NNSA’s plan to expand plutonium pit production.
- The W80-4, a new warhead being designed at Livermore Lab for the new Long Range Stand-Off Weapon. This warhead will sit atop a new air-launched cruise missile.
- The W80-4Modification, a special variant of the new W80-4, designed for a new Sea-Launched Cruise Missile to will be placed on ships that do not currently carry any nuclear weapons and are not certified for that mission.
- Analyze Genuine Alternatives. The Proposed Action drastically increases the nuclear weapons activities at Livermore Lab. For example, it proposes 126 new facilities be built related to new and modified nuclear weapons. The SWEIS should analyze an alternative future for Livermore Lab; one in which the Lab does more unclassified, civilian science work and less, or no, work on developing new and modified nuclear bomb designs. Under NEPA, is the responsibility of the agency to fully analyze reasonable alternatives, which the Draft SWEIS fails to do. A civilian science alternative must be developed in the SWEIS, in part so that the environmental impacts of civilian science research can be compared to the impacts of nuclear weapons activities – and decision makers and the public alike will have these facts in hand when making decisions.
This examination of civilian science based alternative missions for Livermore Lab should include but not be limited to: minimizing and preventing infections disease pandemics, researching climate change adaptation and amelioration, expanding nuclear nonproliferation programs, pursuing R&D of nuclear disarmament technologies that support verifiability, irreversibility, and, where appropriate, transparency, developing new environmental clean-up technologies, alternative fuels, clean energy, environmentally friendly battery development, energy-grid efficiency, green building technologies, and other science areas that deal with the many challenges facing the United States and the world in the 21st century. The NNSA could hold pubic meetings specifically to develop these ideas in partnership with the community and non-governmental organizations.
Sincerely,
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