Today the National Nuclear Security Administration released the Final Site-Wide Environmental Impact Statement for Continued Operations of Lawrence Livermore National Laboratory (SWEIS) that purports to analyze all of the potential impact to the environment of the Lab for the next 15 years. The document was “scoped” in 2020 and released in draft form in November of 2022.
Tri-Valley CAREs participated in the public process on both the scoping and the draft. This included successfully requesting extensions of both periods so that the public could take more time reviewing these complicated and lengthy documents. Tri-Valley CAREs also worked to engage members of the public to participate by providing our analysis of the document and encouraging members of the public to get informed and provide either oral comments at the public hearings or written comments directly to the Agency. And of course, Tri-Valley CAREs submitted its own technical comments on the Draft SWEIS.
The final document includes a Summary and then three longer volumes, the third of which is entirely made up of the public comments received on the draft and the Agency’s responses to those comments.
Tri-Valley CAREs staff will conduct a thorough review of the SWEIS, but on first glance, the document remains alarming in its cavalier presentation of a major, proliferation provocative expansion proposal of one our nation’s major nuclear weapons facilities, and is disappointing in its limited and cursory treatment of the associated environmental impacts.
In sum, the final plan includes completely new nuclear weapons facilities (75 new projects in total) at the LLNL Main Site in Livermore and its Site 300 high explosives testing range near Tracy. And, among other dangerous changes, it increases the amount of airborne radioactive tritium that will be emitted from two facilities and likewise increases the amount of weapons-grade plutonium allowed in a third facility.
Here are a few key observations:
- Many commenters asked the Agency to analyze more alternatives that would look at lowering, limiting or changing the work at the Lab. However, the Final SWEIS continues to only analyze a “No Action Alternative” and a “Proposed Action Alternative.” The “No Action Alternative” actually continues business as usual and in fact even adds, “ the construction of new facilities; modernization/upgrade/utility projects; and decontamination, decommissioning, and demolition (DD&D) of excess and aging facilities.” The “Proposed Action Alternative would include the “No Action Alternative” actions plus, “75 new projects, totaling approximately 3.3 million square feet… Of this, 61 projects, totaling approximately 2.9 million square feet, are proposed at the Livermore Site; 14 projects, totaling approximately 385,000 square feet, are proposed at Site 300. In addition… 20 types of modernization/upgrade/utility projects each involving several facilities… DD&D [of] about 150 facilities… operational changes that would increase the tritium emissions limits in the National Ignition Facility (Building 581) and the Tritium Facility (Building 331)… increase the administrative limits for plutonium-239 at Building 235, and revise the National Ignition Facility radioactive materials administrative limits.” The final draft did not alter the Alternative Analyses at all.
- The U.S. EPA asked in their comment for the Lab to add air monitors to the perimeter of Site 300, noting that one was not enough considering the encroaching of a large Tracy housing development called Tracy Hills. In response, the Agency flatly refuses.
- While the agency formally acknowledges in the Final SWEIS that it is currently not seeking to increase the limit to do larger high explosive blasting at Site 300, it gives the caveat that it is not seeking the increase “yet.”
- The Agency failed to elaborate on the details of the relationship to LLNL’s plutonium activities to the planned enhanced plutonium pit production at other sites in the nuclear weapons complex, stating, “NNSA agrees that LLNL conducts plutonium and pit-related R&D activities but does not think a “crosswalk” would be meaningful to “show the relationship of LLNL’s activities to expanded pit production.”
- The Agency failed to address the comment asking that it analyze the potential impact on international biological weapons proliferation that the proposed expansion of its defense related biological agent research with a newly built, double-the-size BioSafety Level -3 Laboratory might have. It responds, “While NNSA does not believe that defensive biological research work promotes biological weapons proliferation, actions of other countries are beyond the scope of this SWEIS.”
In addition to these initial impressions, Tri-Valley CAREs will release an in depth analysis of the documents in the coming weeks. Despite the lack of official opportunity to submit comments, we will prepare a long form technical comment that our members can review and a shorter sign-and –send comment that members can send in themselves. Keep your eyes out for more from us, but in the meantime, the link to relevant documents is below.