Tri-Valley CAREs hosted a virtual Community Forum on September 29, 2022 to bring attention to and discuss how a new Site-Wide Environmental Impact Statement (SWEIS) for Livermore Lab can affect our health & environment. Participants from the Tri-Valley, greater Bay Area, and Central Valley communities joined to learn about and discuss these important issues.

Forum presenters from Tri-Valley CAREs included executive director Marylia Kelley, staff attorney Scott Yundt, and bilingual community organizer Raiza Marciscano-Bettis.

The forum began with a short history of the Livermore Lab and the National Environmental Policy Act (NEPA), including what a Site-Wide Environmental Statement process entails.

The panelists then addressed some of the key issues to look for when the Draft SWEIS is released (likely in October), including: Livermore Lab’s mission and alternatives to it, current and planned new nuclear weapons development, new facilities and old facilities, ongoing cleanup at the Main Site and Site 300, bigger bomb blasts at Site 300, the possibility that the SWEIS will be used to increase the use and/or releases of radioactive tritium, plutonium and other hazardous materials, and the potential environmental and health impacts of those and other proposed activities.

The panel highlighted as well the importance of public involvement to ensure all issues are aired – and then to make sure they are fully responded to by the government (in writing). Additionally, panelists discussed ways in which public comments during a SWEIS process can influence, and even change, some of the outcomes in the final document.

So, What is a Site-Wide Environmental Impact Statement?

The SWEIS is a document that must be prepared to comply with the agency’s guidance for implementing the requirements of the federal National Environmental Policy Act (NEPA) as well as the underlying federal law. NEPA requires all federal agencies, including the Department of Energy and its National Nuclear Security Administration (NNSA) to analyze the environmental impacts of its actions.  Livermore Lab is continuing activities – and embarking on new ones – that can affect the environment, and so it must undergo a periodic full site-wide environmental review.

The Draft SWEIS, due out in October 2022, follows the Livermore Lab SWEIS completed in 2005. Thus, the decisions made in this new SWEIS are likely to determine the allowable parameters for Livermore Lab’s activities over the next 15 years, or more.

As a Community, What do We Look for in the Draft SWEIS?

Tri-Valley CAREs has prepared a 16-page Community Guide full of photos and specific things to look for in the Draft SWEIS – and we encourage you to check it out. You can download the file here https://trivalleycares.org/wp-content/uploads/2022/09/SWEIS-Community-Guide-final-09-28-22.pdf

The forum introduced many of the topics you will find in the Community Guide. In sum, panelists discussed that the SWEIS will include 55 new facility construction projects that should be scrutinized by the public in the draft document. Further, the SWEIS will identify more than 110 contaminated facilities at Livermore Lab that will be slated for decontamination and demolition over the coming 15-years. The cost, schedule, and worker and public safety should be detailed in the Draft SWEIS.

Important too will be the manner in which the ongoing Superfund cleanup of toxic and radioactive materials in soils and groundwater is detailed and prioritized in the Draft SWEIS. Similarly, whether Livermore Lab will continue to seek a special permit to increase the size of its outdoor (open air) bomb blasts at Site 300 should be clearly stated in the draft.

The Draft SWEIS may be used to raise administrative and “material at risk” limits for tritium (radioactive hydrogen) and plutonium at Livermore Lab. The plutonium limits are relevant to Livermore Lab’s role in expanded plutonium pit (bomb core) production, which has been described in other government documents as involving shipments of plutonium from Los Alamos Lab in NM to Livermore for “materials testing” as well as the purchase by Livermore Lab of new plutonium glove boxes to support the NNSA’s goals for expanded pit production.

Panelists noted that more than 2,000 current and former Livermore Lab workers have applied for federal compensation for serious illnesses, including cancer, believed to have been caused by on-the-job exposures. Tri-Valley CAREs emphasized that both worker and community health and safety should be clearly prioritized in the Draft SWEIS.

The Draft SWEIS must also include climate change impacts and seismic impacts. Both these issues have become more pressing since the prior (2005) Lab SWEIS. Panelists noted that Site 300 had to be evacuated recently due to the major SCU fire – and that this is just one example of the interaction between climate change and Lab operations. Similarly, the USGS has raised its estimates of the severity of earthquakes that could affect both the Main Site and Site 300, and recent maps show that parts of Livermore Lab are in “liquefaction zones;” and liquefaction impacts on Livermore Lab were not analyzed in prior SWEIS (or other) documents.

Panelists also discussed how the public could scrutinize the National Environmental Policy Act’s requirement for a “purpose and need” statement in the SWEIS. In its “scoping process” the NNSA said that its purpose and need is highly dependent on the Trump 2018 Nuclear Posture Review, which is out of date and was never a law in any event. This is worthy of public comment.

Another overarching issue addressed by the panel is that NEPA requires a SWEIS to include an “alternatives analysis”. In past SWEIS documents, the Lab tried to downplay that aspect of the review. It is therefore incumbent on the public to bring up all reasonable alternatives for Livermore Lab operations, programs and mission going into the future.

The panelists also discussed the extreme importance of public participation and engagement during this process. Our aim is that the public’s participation will lead to more environmentally safe and just decisions. Beneficiaries include our air, our water, and our land, and out health. Further, a positive change in Livermore Lab’s programs and mission can benefit our nation and our planet  (currently 88% of the Lab’s budget from the Dept. of Energy goes for one budget line only, the one called “nuclear weapons activities”).

As a Community, What’s Next?

Panelists told the community participants that “YOUR VOICE MATTERS”. Your knowledge about environmental protection, your health, and life experiences matter and only you can speak your truth.

With that in mind, Tri-Valley CAREs closed out the event by asking people to let us know if they think the government’s public hearings and written comment period are enough or if people want more public comment time or more hearings (as of date of the forum and this writing, the NNSA had not yet stated its plans). We asked people to “stay tuned.”

And we invite you to do that as well!

Your Tri-Valley CAREs team will provide analysis and information as soon as the Draft SWEIS and its comment period are published. And, if anyone prefers to speak (or get info) in Spanish, our bilingual community organizer Raiza Marciscano-Bettis can be contacted at [email protected].

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