Tri-Valley CAREs

By Internet: https://tinyurl.com/LLNLSW9-2

By Telephone: +1-408-418-9388 Access code: 132 816 4460.

NNSA has also announced that its scoping meeting presentation will be posted on the agency’s NEPA Reading Room website (https://www.energy.gov/nnsa/nnsa-nepa-reading-room).

By Email to: [email protected]

By Postal Mail to: Ms. Fana Gebeyehu-Houston, NEPA Document Manager, National Nuclear Security Administration, Lawrence Livermore National Laboratory, P.O. Box 808, L-293, Livermore, CA 94551-0808

The Livermore Lab and its parent agency, the National Nuclear Security Administration, are undertaking a new Site-Wide Environmental Impact Statement (SWEIS) to analyze operations at the Lab’s Main Site in Livermore and its Site 300 near Tracy, CA over the next 15 years or more.

The first step in undertaking a new Site-Wide Environmental Impact Statement is called “scoping.” That’s the step happening right now.

The National Environmental Policy Act is the law that governs the process. The law requires that there be an early and open process for determining the scope of the issues to be addressed by the review. Remember, this SWEIS will authorize Lab activities for the next 15 years, i.e., from 2021 until 2036 at a minimum.

This is your opportunity to offer input on what the Site-Wide Environmental Impact Statement should include. What would you like to see the SWEIS consider for the Lab’s future? What should not be ignored? The law says scoping is for the “early identification of concerns, potential impacts, relevant effects of past actions and possible alternative actions.”

We at Tri-Valley CAREs have composed a 15-point comment letter that we are asking you to send to NNSA during the public comment period.

For your reading ease (and that of the NNSA, too) we have numbered each comment 1 through 15. As always, you should feel free to add your thoughts to the “sign and send” letter or to subtract something from it.

To send it to NNSA, just 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.”

By email to: [email protected]

Ms. Fana Gebeyehu-Houston, NEPA Document Manager
National Nuclear Security Administration (NNSA),
Lawrence Livermore National Laboratory (LLNL)
P.O. Box 808, L-293
Livermore, CA 94551-0808

Dear Ms. Fana Gebeyehu-Houston:

I appreciate this opportunity to submit comments on the scope of the National Nuclear Security Administration’s (NNSA) 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.

Pursuant to the National Environmental Policy Act the purpose of scoping is: “early identification of concerns, potential impacts, relevant effects of past actions and possible alternative actions.” Therefore, I ask that the analyses I am requesting be fully undertaken – and my questions fully answered – in the SWEIS.

1. The SWEIS should analyze an alternative future for Livermore Lab; one in which the Lab does more unclassified, civilian science work and less work on developing new and modified nuclear bomb designs. The Federal Register Notice, posted in the NNSA reading room, states that this SWEIS will guide activities at Livermore Lab for the next 15-years or more. It is therefore a responsibility of the agency to fully analyze an alternative path 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.

2. The NNSA “Scoping Meeting” slides on the SWEIS posted in the agency’s reading room state that the document will include “Approximately 55 new facility construction projects…” The SWEIS should be clear about which new facilities will used for nuclear weapons research and development and which ones will not.

3. The Livermore Lab Main Site was placed on the Environmental Protection Agency’s Superfund list of most contaminates sites in the nation in 1987. The Livermore Lab Site 300 high explosives testing range was placed on the EPA Superfund list in 1990. Both locations have multiple chemical and radioactive contaminants that have leaked into soils and groundwater aquifers, as well as some surface waters at Site 300. Both locations have on-site and off-site contamination that is being cleaned up under the Superfund law. Both locations have cleanup activities that will need to continue for the next 40 years or more. This past contamination must be fully considered in the SWEIS. Additionally, the SWEIS must state whether any program activities considered in the document will complicate or delay any of the Superfund monitoring or cleanup underway.

4. More than 2,000 current and former Livermore Lab employees have applied through the U.S. Department of Labor’s Energy Employee Occupational Illness Compensation Program for compensation due to serious illnesses, including cancer, believed to have been caused by on-the-job exposures to radioactive and toxic materials. The SWEIS must consider worker health and safety in all of its analyses. Further, the document must consider past worker exposures when contemplating further operations with these potentially deadly materials.

5. The NNSA “Scoping Meeting” slides on the SWEIS contain the following statement: “Operational changes – Changes to tritium emissions limits and Administrative Limit for plutonium and accident scenarios.” NNSA noted in particular that the SWEIS would seek to raise the emission limit for tritium, which is radioactive hydrogen. The SWEIS should not be used to justify increasing any radioactive emissions. Instead the SWEIS should analyze an alternative in which Livermore Lab’s operations with radioactive materials are reduced or curtailed. The emission (release) limits for all hazardous materials should be reduced, not increased.

6. The Federal Register Notice for preparation of the SWEIS states that expected operational changes at Livermore Lab include: “Changes to material at risk (MAR), administrative limits, and radiological bounding accident scenarios as a result of the de-inventory of Security Category I and II special nuclear materials from LLNL, which was completed in 2012.” Weapons-usable quantities of plutonium and highly enriched uranium were the specific materials removed in bulk quantities at that time. There must be an explicit analysis of the potential impacts of any changes to the limits instituted when these materials were removed.

7. The NNSA has testified to Congress that its number one priority is to expand plutonium pit (bomb core) production. The rationale and timing for expanded pit production is driven by the “needs” of the W87-1 warhead under development at Livermore Lab. The production sites will be at the Savannah River Site in SC and the Los Alamos Lab in NM. That said, the environmental review document for pit production at Los Alamos contains a chart that shows that site shipping plutonium from New Mexico to Livermore Lab for “material testing.” How will the plan to use Livermore for “materials testing” of plutonium affect the changes being considered for MAR and administrative limits in the SWEIS? In the past, Livermore Lab officials have said they could declare “variances” to Livermore Lab’s plutonium limits to accomplish testing of bomb cores coming from Los Alamos. Will Livermore Lab use “variances” for “materials testing” of plutonium for pit production? The SWEIS needs to detail all potential impacts of Livermore undertaking “materials testing” of plutonium and explain in detail how this activity does or does not comply with the aforementioned MAR and administrative limits.

8. Livermore Lab has separately analyzed a plan to increase the size and weight of open-air bomb blasts at Site 300 by as much as ten-fold per each blast and more than 7-fold annually. These planned high explosives detonations involve more than 100 chemically hazardous contaminants. A future alternative that foregoes these outdoor detonations with hazardous materials at Site 300 must be analyzed in the SWEIS. Additionally, an analysis must be done of the utility, cost, and environmental impacts of maintaining Site 300 when other NNSA sites perform much of the same function farther away from population centers.

9. The SWEIS must fully consider the latest data from the United States Geological Survey (USGS) on earthquake scenarios in the Bay Area near the Main Site and the Central Valley near Site 300. Both the Main Site and Site 300 are on or very near earthquake faults. The USGS has recently published analyses that show greater quake intensity and other damaging impacts (e.g. possible liquefaction) for these specific areas of California.

10. The SWEIS must fully consider the impacts of climate change. On the one hand, it must analyze Livermore Lab operations’ potential contribution to global climate change due to emissions. The SWEIS must also analyze the impact of fires and other extreme weather events related to climate change on the Livermore Lab itself. In the current firestorms of summer/fall 2020, Site 300 had to be evacuated due to the proximity of the SCU Lightening Complex Fire. These types of events may increase in severity and frequency in the coming 15 years.

11. The Federal Register Notice states that “Over the 15-year LLNL SWEIS planning horizon, NNSA has identified more than 110 excess facilities, totaling more than 1.1 million square feet, to be decontaminated, decommissioned, and demolished.” It is assumed that this includes the “High-Risk Excess Facilities” previously identified by the Department of Energy Inspector General, but also many more facilities that pose a risk to workers and the public. Please include specific information in the SWEIS about plans to D&D each of these 110 facilities. Additionally, after $109 million that was supposed to be used for D&D work in fiscal 2021 was instead “reallocated” to nuclear weapons projects at the Lab, please specify in the SWEIS how the Lab will prioritize this D&D work, the expected time horizon for accomplishing the planned work, and how the buildings will be maintained in the meantime.

12. The scope for the SWEIS outlined in the Federal Register Notice includes a statement of “purpose and need” for the review. In that section the NNSA claims: “The U.S. nuclear weapons infrastructure is aging and historically underfunded.” Yet, there have been substantial budget increases for NNSA and its weapons labs during both the Obama and Trump administrations. In particular, during the current administration, the NNSA budget to “modernize” is 50% higher that when President Trump took office. In the context of these funding increases, the SWEIS should fully review assertions in the Federal Register Notice that the Lab “is in need of facilities and infrastructure investments. Half of the operating buildings at LLNL are assessed as being inadequate or in substandard condition.” Why haven’t the funds received by the Lab been used to adequately maintain existing infrastructure? Is this more a question of priorities than of available

13. The “purpose and need” statement outlined in the Federal Register Notice suggests that Livermore Lab is expecting ever-greater amounts of funding in future years. These expectations must be made explicit and analyzed in detail. Generally speaking, expenditures of funds should be a consideration in the infrastructure work the SWEIS proposes. Perhaps some new infrastructure projects should not be undertaken when their funding demand is considered. How will priorities be determined? These considerations must be fully explored in the SWEIS. Additionally, the SWEIS should take into account the “need” for capabilities at Livermore Lab that might be duplicative of other NNSA sites.

14. Further, the “purpose and need” statement for the SWEIS is heavily dependent on the Trump Administration’s controversial 2018 Nuclear Posture Review (NPR) and its call for a costly new generation of nuclear weapons. Over the 15-year time frame of the SWEIS, the 2018 NPR will be mooted by one or more new posture reviews, potentially very different than the one issued by the current President. A new NPR could be underway even before the SWEIS process is completed. Thus, the SWEIS “purpose and need” should not be driven by the Trump NPR, which in any event is a policy document and not a law.

15. Then the “purpose and need” statement briefly notes: “LLNL will complete Life Extension Programs [this is a catch-all phrase the agency uses to describe fully new warhead designs as well as refurbishments] by conducting testing and maintenance of weapons.” This statement is left to stand without further explanation of what “testing” and “maintenance” entail. Yet, it is precisely the weapons work covered by that sentence that will create “significant impacts to the environment.” The SWEIS needs to detail the scope and timeframes of the Life Extension Programs (LEPs) planned for Livermore Lab. It also needs to explain to what extent – and in what quantities – radioactive and toxic materials will be on site to accomplish the LEPs. And, as noted above, the SWEIS also needs to thoroughly analyze an alternative future for Livermore Lab.

The NNSA extended the public comment period for scoping the SWEIS by 30-days (from September 21, 2020 to October 21, 2020). The additional time is appreciated. However, the comment period should be extended for an additional 90-days during this historic period of a still-raging pandemic, statewide fires and other events and stressors that make commenting particularly difficult for members of the public during this time.

Please note that my preferred method for all notices involving the SWEIS is by email. I would like to receive links as they become available, including but not limited to the Draft SWEIS, which is anticipated to be completed in spring/summer 2021.

Sincerely,

Name:

Email (preferred for communications):

Postal Address (provided for completeness):