The United States’ dangerous nuclear arms racing just took another step forward. The federal agency that owns Lawrence Livermore National Laboratory released a Record of Decision (ROD) in the Federal Register on February 20th that entrenches – and markedly expands – nuclear weapons research and development at Livermore Lab for the next 15 years!
The National Nuclear Security Administration’s (NNSA) newly-released ROD concludes the multi-year process of preparing a 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.
Tri-Valley CAREs, other nonprofits, other government entities (such as the EPA) and many members of the public submitted comments on the SWEIS at various stages, including during its scoping, draft, and final phases. The vast majority of the public comments requested that the agency examine a future for the Lab in which our nuclear weapons stockpiles are reduced, nuclear weapons are dismantled at greater rates, warhead designs are strictly limited to maintaining the existing systems until they can be dismantled, and the nuclear weapons complex shrinks, thus enabling Livermore Lab to focus on civilian science pursuits. The final document and ROD did not consider these potential futures, and instead, pushed Livermore Lab in quite the opposite direction.
The Proposed Alternative, which was the one chosen by the NNSA in the ROD, drastically increases the nuclear weapons activities at Livermore Lab. For example, it proposes 126 new facilities be built, the majority of which will service the development of new and modified nuclear weapons.
Here are some of the most dangerous plans that are now enabled to move forward based on today’s ROD.
- Plutonium Quantities to Increase.The agency is plans to increase the administrative limits for plutonium mixtures – to 5 times the quantity of what is currently allowed. 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. Many public commenters noted that this is an unacceptably dangerous increase in plutonium at a site that has failed security drills and is located in close proximity to residential neighborhoods and within a 50-mile radius of 7 million people. Additionally, commenters requested that the NNSA make it clear to what extent Livermore Lab’s increased plutonium operations are related to the agency’s program to expand plutonium pit production. Instead, NNSA responded that it did not need to “make the crosswalk” visible. The ROD moves Livermore’s plutonium work forward and transparency regarding its purpose backwards.
- Tritium Emissions to Increase. The agency plans to increase the site-wide air emission of tritium from 129.2 Ci tritium in the 2019 baseline, to 3,610 Ci tritium. This is almost a 28-fold increase in the amount of tritium emitted from the Lab. This will result in a corresponding increase of 27 times the annual dose to the offsite population from the 2019 baseline. Additionally, this will result in an increase of 12 times the numbers of cancers from the 2019 baseline; a risk that many commenters complained was unacceptable. Yet, the ROD moves forward with these planned releases.Notably, 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 Advanced Hydrotest Facility. The agency plans to build a 75,000 square foot “Advanced Hydrotest Facility” (AHF) at Site 300. Livermore Lab pushed for a new AHF at Site 300 in the mid-1990s. A weapons designer at the time referred to it as “a nuclear weapons designer’s dream machine” for its capacity to help design new plutonium primaries (aka pits).” 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 – and the AHF was never built. Commenters pointed out that 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, which today’s ROD enables.
- New Bio Safety Level 3 Lab. The NNSA plans to replace the existing Animal/Biosafety Level-3 Facility at the Livermore Lab Main Site with a facility nearly twice the size. This bio lab performs biological warfare/defense experiments with highly contagious bio-agents, (including anthrax and botulism) on animals inside of a DOE/NNSA Classified nuclear weapons laboratory. There is no mandate for DOE to do bio defense research. And, by doing so at a weapons lab, it creates the optics internationally that Livermore may be planning to create bio weapons. Commenters were concerned that the agency did not conduct a separate analysis of a potential biological hazard release from the facility, but instead “tiered” from previous analyses performed for the smaller BSL-3 facility. Reliance on analyses that are over a decade old and not specifically tailored to the proposed action for the new BSL-3 makes the NNSA conclusions of safety doubtful.
In addition to announcing the agency’s decision to move forward with the most ambitious “proposed alternative” for Livermore Lab, the ROD contains a short section responding to “Comments on the Final LLNL SWEIS.” There, the NNSA again declines to provide any new material asked for by commenters. For example, NNSA refuses to provide additional Air monitoring at Site 300 asked for by the US Environmental Protection Agency. Nor does it provide any clarity on the locations of the existing air monitors. Instead, the NNSA punted the disclosure of locations of air monitors to a future environmental document.
In sum, the public input provided during scoping, and on the draft and on the final versions of the SWEIS, was not considered by the agency. Commenters overwhelmingly suggesting that the agency proceed with the environmentally preferable “No-Action Alternative” or develop an even less impactful alternative, both of which would result in fewer adverse impacts that the Proposed Action Alternative given the green light by today’s ROD.
Further, NNSA is not implementing any mitigation measures; its nuclear weapons development full speed ahead – worker and public safety be damned. Moreover, NNSA decided that examining the proliferation risks of the aggressive nuclear activities to be undertaken at Livermore Lab was “beyond the scope of its review.”
Tri-Valley CAREs will continue monitoring, analyzing, and pushing back against the dangerous plans outlined in this Record of Decision. The ROD is the agency’s green light to proceed, but it does not make the plans a foregone conclusion.
We have prevented facilities before (including the first attempt by Livermore Lab to build an Advanced Hydrotest Facility) and we will continue our work to reduce nuclear risks at Livermore Lab and move it – and our world – toward civilian science missions and the abolition of nuclear weapons.
Click here for the Record of Decision on the SWEIS
Click here for the SWEIS documents
Click here to see Tri-Valley CAREs comments on the SWEIS
