NNSA Los Alamos Field Office [date (deadline is April 26, 2018)]
ATTN: CMRR Project Management Office
3747 West Jemez Road
Los Alamos, NM 87544
Via email to
Re: Comments on the Draft Environmental Assessment of Proposed Changes for Analytical Chemistry and Materials Characterization at the Radiological Laboratory/Utility/Office Building, Los Alamos National Laboratory, Los Alamos, New Mexico[1]
Dear CMRR Project Management Office:
I am writing to express my concerns over the draft environmental assessment for the Radiological Laboratory Utility and Office Building (AKA “Rad Lab”) at the Los Alamos National Laboratory (LANL). The National Nuclear Security Administration (NNSA) states this environmental assessment “is intended to provide sufficient evidence and analysis to determine whether to prepare an environmental impact statement (EIS) or to issue a Finding of No Significant Impact (FONSI) for the Proposed Action.” NNSA’s proposed action is to raise the operational limit for plutonium-239 to 400 grams (or the equivalent in other isotopes) in the Rad Lab. This would cause the facility to be re-categorized from a “Radiological Facility” to a Hazard Category-3 nuclear facility.
I believe that after completing a final Rad Lab environmental assessment NNSA should proceed to a full environmental impact statement because:
•NNSA has previously declared that on May 11 it will announce a decision on where future expanded plutonium pit production will take place, either at LANLor the Savannah River Site in South Carolina, or both. It is silly that this draft environmental assessment is underway just before that crucial decision, without which it can’t really be determinedwhether or not the Rad Lab truly needs to be re-categorized as a Hazard Category-3 Nuclear Facility. This draft EA is clearly putting the cart before the horse. Therefore, NNSA should proceed to a fuller environmental impact statement after its May 11 decision.
•NNSA is conducting this Rad Lab environmental assessment pursuant to the National Environmental Policy Act (NEPA), which requires the opportunity for the public to comment on major federal proposals. NEPA also requires that interconnected actions be considered together, and forbids segmentation into different narrow projects.
In a clear sign of interconnectivity, the Rad Lab’s planned re-categorization into a Hazard Category-3 nuclear facility is one of four “subprojects” in the NNSA’s FY 2019 budget request under the “Chemistry and Metallurgy Research Replacement (CMRR) Project.”All four subprojectsinvolve relocating analytical chemistry and materials characterization capabilities involving plutonium and other special nuclear materials out of the old, deteriorating Chemistry and Metallurgy Research Building. All together these subprojects will cost 2 billion taxpayer dollars. NNSA should analyze all four subprojects in one unified environmental impact statement. Conversely, this environmental assessment that analyzes only the narrow question of raising the plutonium limit in the Rad Lab is the segmentation that NEPA forbids.
•NNSA argues that this Rad Lab EA is solely about relocating operations from the old deteriorating CMR Building so that LANL will have enduring analytical chemistry and materials characterization capabilities for its ongoing plutonium mission. However, NNSA has not justified how LANL’s present plutonium mission would not be adequately served by the already raised limit of 38.6 grams Pu-239 equivalent (up from the original 8.4 grams) for the Rad Lab. Instead, this proposal to now raise the Pu-239 equivalent to 400 grams is all about LANL’s future plutonium mission, over which there is no mystery. That future mission involves expanding production from the currently sanctioned level of 20 pits per year to 80 pits per year by 2027, statutorily required by the FY 2015 National Defense Authorization Act.
•This is further reinforced by the Chemistry and Metallurgy Research Replacement Project’s troubled history. Briefly, NNSA has repeatedly sought (but failed) through various NEPA processes to raise the limit on plutonium pit production from that originally set by the 1996 Stockpile Stewardship and Management Programmatic Environmental Impact Statement (PEIS). Its Record of Decision relocated the plutonium pit production mission to LANL after a 1989 FBI investigating environmental crimes at the Rocky Flats Plant abruptly stopped production. It specifically limited pit production to 20 pits per year because of the deteriorated conditions at the old CMR Building that constrained analytical chemistry and materials characterization operations in support of plutonium pit production.
In 2011 NNSA completed a Supplemental EIS for the CMRR-Nuclear Facility, only to cancel it after its estimated costs soared to $6.5 billion.However, an internal NNSA study had advocated for 22,500 square feet of plutonium lab space in the CMRR-Nuclear Facility, “resulting in a production capacity of 50-80 ppy” (pits per year). This draft Rad Lab EA now seeks to create that same square footage of plutonium lab space, not coincidentally the amount needed to support expanded plutonium pit production. Ironically, future production is not to maintain the safety and reliability of the existing nuclear weapons stockpile. It is instead for speculative future “Interoperable Warheads” for both land and submarine-launched missiles that the Navy doesn’t even want. The point is that the mission of future plutonium pit production needs critical examination because the re-categorization of the Rad Lab to a nuclear facility is arguably not even needed.
•Should NNSA decide on May 11 to conduct future plutonium pit production at the Savannah River Site, or perhaps also at LANL, then clearly a new or supplemental programmatic environmental impact statement (PEIS) is needed. Moreover, any decision to expand plutonium pit production above the current limit of 20 pits per year would require a new or supplemental PEIS, regardless of future location(s).
•The draft Rad lab EA lists four “reasonably foreseeable future actions” that could lead to cumulative impacts at LANL.It is striking that expanded plutonium pit production is omitted, since it is not only reasonably foreseeable, but is actually congressionally required and actively planned for. It’s difficult to believe this omission is just a simple oversight, when it is so glaringly obvious, perhaps indicative of an intent to avoid the subject of expanded plutonium pit production altogether. That should be corrected in a fuller environmental impact statement or programmatic EIS.
•The FY 2019 NNSA budget request states beryllium analysis will be a specific capability under the Proposed Action. Yet there are only two passing references to beryllium in the draft EA, when it is a widely known, potentially severe occupational hazard across the DOE’s nuclear weapons complex. Moreover, a February 2018 DOE Inspector General report found long-standing deficiencies in LANL’sberyllium disease prevention program. Therefore, it is particularly notable that this draft Rad Lab environmental assessment fails to analyze potential beryllium occupational exposures, which a full EIS should correct.
• In violation of declared DOE NEPA policy, this draft Rad LabEA fails to have any analysis of Intentional Destructive Acts (defined as acts of sabotage or terrorism, including deliberate airplane crashes). This glaring deficiency should be corrected in a full environmental impact statement.
• DOE and NNSA should always hyperlink all reference documents in all NEPA documents.
In sum, following its May 11 decision on plutonium pit production, NNSA should proceed to a fuller environmental impact statement that analyzes interconnected proposals for relocating analytical chemistry and materials characterization operations at LANL. Should NNSA decide to conduct production at the Savannah River Site, or also at LANL, it should then proceed to a programmatic environmental impact statement (EIS) that analyses all aspects of future plutonium pit production.
Sincerely,
[Name and general location (for example “Santa Fe, NM”]
[1]Available electronically at