SPEAK OUT! Oppose Plutonium Utilization Proposed at Livermore Lab – Public Comment Period Extended to Monday, March 3rd
In early January, the National Nuclear Security Administration announced it is preparing a Supplemental Environmental Impact Statement (SEIS) to analyze its proposal for “Enhanced Plutonium Facility Utilization” at its Lawrence Livermore National Laboratory. The proposal would raise the security category from Category III to Category II, allowing for a significant increase in the “throughput” of nuclear weapons-grade plutonium at the Livermore Lab. Additionally the proposal will result in a corresponding increase in the amount of plutonium trucked in and radioactive waste trucked out of the Lab, using roads and freeways such as the nearby I-580.
Tri-Valley CAREs requested that the Lab extend the 30-day public comment period on the scope of the Supplemental Environmental Impact Statement to at least 60 days, but they refused. Consequently, we asked several local Members of Congress to write to the Lab requesting an extension of the public comment period. Representatives Josh Harder (CA-9) and Representative John Garamendi (CA-8) jointly contacted the Lab with the request, and the Lab announced at its public hearing on the SEIS on January 28th that it would extend the public comment period by 15 days to March 3rd! Huge thanks to Rep. Harder and Rep. Garamedi for their efforts to improve the public’s ability to participate in this process.
SEND WRITTEN COMMENTS BY MONDAY, MARCH 3rd TO:
Mr. Alan Chen, NEPA Document Manager
National Nuclear Security Administration, Livermore Field Office
7000 East Avenue, L-293
Livermore, CA 94550-9234
SUBMIT COMMENTS BY EMAIL: [email protected]
OR VIA PHONE: 833-778-0508 to leave a message
WHAT IS A SCOPING COMMENT:
The NNSA is currently receiving comments on the scope of the Draft Supplemental Environmental Impact Statement (SEIS) it will prepare pursuant to the National Environmental Policy Act. Therefore, comments at this stage are most effectively focused on what the public wants the NNSA to analyze in its Draft SEIS. In other words, what do you think should be included in the full draft SEIS.
For example, you can ask them to include potential alternatives to the proposed; ask them to include what kinds of experiments will be done with the plutonium; ask them to include the connections are to NNSA’s national plan to produce new plutonium pits (bomb cores) for new nuclear warheads; ask them to include potential accident scenarios; ask that they the potential impacts on workers, the public and the environment; ask them to include the transportation risks; ask them to include the security risks increasing the quantities of plutonium used in work stations all at once near a populated area; and, of course, do add any specific community conditions or concerns that you believe NNSA should consider, etc.
To expand on the above issues, Tri-Valley CAREs will put together some sample written comments in the coming days. Check our website at www.trivalleycares.org for them.
Here is a link to the Federal Register Notice of Intent for more background to comment on.
WHY A “SUPPLEMENTAL” EIS?
The announcement comes just 12 months after the Lab finalized a Record of Decision, concluding a lengthy public process on its Site-Wide Environmental Impact Statement (SWEIS) for “Continued Operations.” The SWEIS was intended to disclose and analyze the environmental impacts of the Lab’s ongoing activities over at least the next decade.
The SWEIS described some increase in plutonium related activities (mainly at the National Ignition Facility) and a small increase in plutonium limits in specific buildings, but kept the administrative limit for plutonium at the entire site at 300 pounds, and at any specific work station below “bomb-usable quantities.”
Tri- Valley CAREs and others repeatedly asked in public comment sessions during the year-long SWEIS process if it was contemplated that the Security Category limits at Livermore Lab would change over the next decade of plutonium and a return to the riskier kinds of nuclear weapons activities that used to occur there during the height of the Cold War. The answer given to Tri-Valley CAREs and the public was a flat ‘no’.
The SWEIS analysis and its public process should have included this plan, instead of it being relegated to a separate “Supplemental” EIS. This is exhausting for members of the public who are concerned about the Lab’s activities, forcing them to again engage and grapple with the cumulative environmental impacts of the Lab’s actions so soon.
WHAT IS THE LAB’S PURPOSE AND NEED FOR THIS PROPOSAL?
In the notice, the purpose and need of the proposal is described as “optimizing” the facility “in support of mission areas including designs of the nuclear explosives package for Life Extension Programs…” This is agency jargon that simply means that the Lab seeks to increase the amount of plutonium on hand to design new plutonium pits, which are the radioactive cores of nuclear weapons. The government elsewhere has proposed to produce 80 or more new plutonium pits annually. This sudden, new scheme at Livermore Lab is timed to support that mission.
SOME HISTORY OF SECURITY FAILURES AT THE PLUTONIUM FACILITY AT LIVERMORE LAB
In 2008, Livermore Lab underwent a scheduled force-on-force security drill to test the security of the nuclear weapons usable amounts of plutonium it had at the Plutonium Facility inside the
Lab’s “Superblock,” the most heavily-guarded quadrant on its 1-square-mile Livermore Site on East Avenue. The drill was conducted by the DOE Office of Health, Safety, and Security as part of a seven-week audit of the Lab. The mock attack was not a surprise to the Lab, although a real attack would not be scheduled. Still, the mock terrorists were able to gain entry into the Superblock, obtain the nuclear material they sought and hold their ground long enough to detonate a simulated nuclear ‘dirty bomb.’ Additionally, a DOE team removed some of the plutonium material, demonstrating that in a real terrorism event, it could have been transported and detonated elsewhere.
Following these failures, Livermore Lab lost its Category II security. It then had to remove its large stock of plutonium, which was completed in 2012. To this day, Livermore Lab holds only a lower Category III Security, which restricts the Lab to smaller quantities of nuclear material on site.
Events since 2012 have made weapons-usable quantities of plutonium even less safe here than when the Lab failed its security drill and lost its authorization. For example, the City of Livermore has a larger population, and has extended its boundaries so that the plutonium would now be within Livermore City limits. And, the Lab has recently increased its workforce. The bottom line is that more Lab employees and local residents could die due to a terror attack or serious accident.
HOW IS THIS CONNECTED TO PLUTONIUM PIT PRODUCTION
The United States has not built new plutonium pits on an industrial scale since the Rocky Flats Plant near Denver, Colorado was shut down in 1989 by the FBI for environmental crimes. However, with a mandate from Congress and recent administrations to “modernize” the US nuclear weapons stockpile, the DOE National Nuclear Security Administration has initiated plutonium pit production for newly designed nuclear weapons, such as the W87-1 warhead. Designed by Livermore Lab, the W87-1 will top the new Sentinel Intercontinental Ballistic Missile. New plutonium pit production has begun at Los Alamos National Laboratory in New Mexico. Further, a major retrofit of an existing facility at Savannah River Site in South Carolina is proposed as a second plutonium pit production site, with costs recently estimated at $25 billion.
In November, a South Carolina District Court ruled in favor of plaintiffs Tri-Valley CAREs, Savannah River Site Watch, and Nuclear Watch New Mexico in litigation brought against DOE and its NNSA. The court agreed with plaintiffs that the government failed to “programmatically” evaluate the environmental impacts of its proposed enhanced pit production development plans. The judge’s ruling requires the agency to issue a Programmatic Environmental Impact Statement (PEIS) analyzing the full impacts of its plutonium pit production plans across the nuclear weapons complex.
In theory, this should include the role of Livermore Lab, where activities in this year’s budget already reflect a 50% funding increase over the previous year for “Enterprise [Plutonium] Pit Production Support”, reaching $97.35m. The new plan’s costs will likely push this over the billion-dollar mark.
The enhanced plutonium activities suddenly being proposed at Livermore’s Plutonium Facility should be included as part of the nationwide PEIS on plutonium pit production because it is a ‘connected action’ to producing new cores for new nuclear weapons. That PEIS is the appropriate document for a thorough analysis of alternatives in conjunction with the pit production plans in order to evaluate if this Livermore proposal is truly necessary, rather than producing a stand-alone Supplemental EIS focused solely on the Livermore site that may not include any analysis of the pit production mission, even though that is a driver for the decision.
Click here for the Federal Register Notice >
Click here for Tri-Valley CAREs’ Press Release >
Para leer esta infomación en españól HAGA CLIC AQUÍ!