For immediate release July 14, 2020

Permalink * Prior press releases

Protest at State Capitol on "Trinity" nuclear test anniversary asks Governor to request environmental analysis of proposed LANL plutonium industrialization, dramatic expansion of nuclear weapons work

Secret, ever-evolving plans for manufacturing warhead cores ("pits") have not been provided to Congress or to state and local governments, tribes, or citizens

Costs through 2025 have more than doubled over three years; total project costs "TBD"

Environment Department says pit production mission puts legacy waste removal, cleanup, at risk

Contact: Greg Mello, 505-265-1200 (office) 505-577-8563 (cell, use this on Thursday)

Albuquerque and Santa Fe, NM -- There will be a socially-distanced press conference and demonstration on the east side of the State Capitol on Thursday, July 16, at 10 am, organized by the Los Alamos Study Group.

We are respectfully asking Governor Lujan Grisham to request that the Department of Energy (DOE) begin the process of preparing a new Site-Wide Environmental Impact Statement (SWEIS) for the Los Alamos National Laboratory (LANL), with the attendant public, tribal, and government consultations that are required. We believe that the extraordinary expansion contemplated at LANL, which aims to change not just the size but the character of the laboratory dramatically, requires a new SWEIS.

LANL's expansion would be the largest capital project in the history of New Mexico in constant dollar terms (slide 23). It would admittedly change not only the laboratory but the town of Los Alamos as well as the surrounding region (see: LANL officials detail potential building boom, Albuquerque Journal, Aug 9, 2019 and related documents in the red box).

Significant impacts on surrounding roads, housing, water use, electricity supply, nuclear waste storage and transportation, and public risk from nuclear accidents have been scattered across many documents but never examined together or in the context of LANL expansion overall.

At this event we will emphasize the scale of LANL's expansion, its impacts, its secrecy and evolving nature, the lack of knowledge in state government about this expansion, the value of interdisciplinary environmental science, and the policy-neutral, "good-government" character of the National Environmental Policy Act (NEPA) process which requires EISs for federal decisions of this magnitude. It is DOE's agency-specific NEPA regulations which set up the requirement for a SWEIS in situations such as this. There will be multiple speakers.

We will also discuss the misguided national priorities which neglect citizens, the collapsing economy, and the environment in favor of defense and nuclear contractors, like LANL, which produce few jobs and what we believe to be little real value to society.

Also on Thursday Lisa Gordon-Hagerty, Administrator of the National Nuclear Security Administration (NNSA), will be visiting LANL's main plutonium facility and LANL's "V Site" ("V" for "victory") where the Trinity "Gadget," the first nuclear explosive, was mostly assembled.

Prior to Administrator Gordon-Hagerty, NNSA sought only one permanent pit production plant, with the Savannah River Site (SRS) the near-certain site for this mission. Gordon-Hagerty reversed course (see: 3. through 6.) after pushback from the New Mexico delegation, deciding that instead of one, NNSA should have two pit factories.

Priot to Gordon-Hagerty, the Trump NNSA assumed there would be an EIS for the pit mission wherever it was located (p. 57). Now NNSA's Draft Supplement Analysis (DSA) preliminarily concludes that no EIS analysis (let alone a SWEIS) is needed at LANL, although an EIS is being prepared at SRS. Our comments. No official final decision has been published.

The most recent LANL SWEIS was written in 2008 under very different planning assumptions and environmental realities than prevail today.

The purpose of any EIS is to compare the relative environmental, social, and economic impacts of alternatives to major federal choices. Today's alternatives bear little relationship to those examined in 2008.

As revealed two days ago by the House Appropriations Committee (p. 140), NNSA actually has no detailed plan of its own for pit production, despite statutory requirements to do so.

Triad, the LANL contractor, has apparently produced no site plan or strategic plans for LANL, despite DOE orders, contract requirements, and requests from the Los Alamos County Council and citizens.

NNSA also has no clear plan for other plutonium missions including oxidizing surplus plutonium, at LANL or anywhere else, despite claims otherwise ("GAO: Surplus Plutonium Disposition: Processing of surplus plutonium warhead cores ("pits") at Los Alamos is uncertain, may conflict with production of new pits, Oct 28, 2019). The Senate Armed Services Committee is concerned (see p. 416 in S. Rept. 116-236 to accompany S. 4049, the FY21 National Defense Authorization Act).

This, and the collision between pit production and legacy waste removal that has been highlighted by the New Mexico Environment Department (NMED, "Comments to [NNSA] on the March 2020 [DSA] of the 2008 SWEIS for expanded pit production at [LANL]") are examples of why a site-wide, rather than a narrow, project-specific EIS, is needed.

Yesterday the Los Alamos Reporter revealed that NNSA's (evolving) pit production plans at LANL are really more of a LANL "proposal," and will be kept sequestered from the public by their Unclassified Controlled Nuclear Information (UCNI) status.

Study Group director Greg Mello:

"We hope the Governor will choose environmental science, democratic transparency, and NEPA compliance over whatever NNSA and LANL may be telling her in secret.

"A public NEPA process, with analysis and peer review by disinterested parties, is how the governments and government agencies -- all of them, including DOE and its subset NNSA -- become more fully conscious. In a large agency knowledge and responsibility are fragmented. DOE needs NEPA analysis to be smart about what they are doing.

"To pick just one example, if pit production starts DOE's own documents express doubt about how, or whether, it will be possible to get about 20,000 drums of legacy TRU waste off the Hill.

Some of the reasons we believe a new SWEIS is required are these. We have given this list to Governor Lujan Grisham in our invitation to her to attend our press conference.

• NNSA seeks to hire thousands (net) of new staff at LANL over the coming five years. LANL is poised to dramatically change into something never seen before. Triad, NNSA's management and operating contractor, has publicly discussed the fact that impacts of these expansion decisions will be regional and significant -- in terms of traffic congestion, housing, possible new roads and bridges, and possible secondary LANL campuses.

• The road network and housing markets are already stressed. A powerful factor not present or foreseen in 2008 is the fact that many LANL retirees are staying in the Los Alamos community and so a much larger fraction of the LANL workforce now commutes. In other words, the retiring Cold War demographic bulge is consuming much of the available housing, with regional effects.

• A common phenomena across several kinds of environmental impacts is that the Pajarito Plateau is in many ways "full": increases in environmental pressures result in greater-than-linear impacts. Examples are traffic slow-downs stretching miles every day near White Rock; the relatively abrupt need for 5,000 additional housing units (according to Los Alamos County's latest housing report), greatly expanding the County's total housing stock and population; contemplated urban development in wildlife corridors and open space areas; planned construction almost adjacent to the Tsankawi portion of Bandelier National Monument, and much more). Qualitative changes in impact, and kinds of impacts, are reasonably expected to occur.

• LANL has described a $13 billion dollar construction program over the coming 10 years, which would nearly double the replacement value of LANL as a whole. This program is more than six times the size of the Manhattan Project in New Mexico, in constant dollars. Some $5.5 billion is already programmed over the coming five years. LANL's public presentations have shown dozens of new buildings. In constant dollars, planned LANL construction over the decade exceeds the original cost of the interstate highway system in New Mexico. Just one building now being outfitted as a nuclear facility -- formerly the Radiological Laboratory, Utility, and Office Building (RLUOB) -- will be more costly than any single construction project in the state. It is almost incomprehensible that a brand-new program on such a scale -- involving processing, transporting, storing, and disposing tons of some the most dangerous materials known to humanity -- could proceed without an full environmental impact statement.

• The plutonium warhead core ("pit") mission is particularly impactful. Yet as we heard again Thursday from a senior analyst for Congress, there has been no final (signed) agency decision as to what the plan for this mission actually is, in detail (despite a long-past statutory deadline requiring one). (This a theme of our comments on the DSA, as noted above.)

• In the 2008 SWEIS, NNSA assumed LANL's plutonium missions would have access to a large, brand-new, safer plutonium facility at Technical Area (TA-) 55. That building was never constructed. No firm plan for constructing any such building has been revealed since then.

• Despite this we believe, and sources in government also said to us this week, that there are plans for new nuclear facilities at TA-55, despite their conspicuous absence from the DSA. All options for pit production at LANL examined in NNSA's pit production Engineering Assessment involved new nuclear facilities at TA-55.

• As revealed in LANL's DSA, NNSA proposes to operate its plutonium facility on a 24/7 basis. This has important safety and indirect environmental implications, not discussed anywhere.

• The 2008 SWEIS failed to account for the incompetent lower horizon of Unit Three of the Tshirege Member of the Bandelier Tuff ("Qbt3L"), present across LANL and of signal importance in any plans to construct new or replacement nuclear facilities on the south portion of TA-55, the only portion available for construction. The geologic and seismic properties of this stratum necessitated a complete redesign of the then-proposed Chemistry and Metallurgy Research Replacement Nuclear Facility (CMRR-NF) to meet the nuclear safety requirements of 10 CFR 830. The proposed underground production modules (inexplicably absent in the DSA) would not meet those standards, according to NNSA's Engineering Assessment. That is why they would be underground. We believe NNSA has not taken the geologic situation at TA-55 or indeed at LANL as a whole on board.

• According to a December 2019 report of the Defense Nuclear Facilities Safety Board (DNFSB), Building PF-4 does not adequately protect the public. Existing environmental analyses (e.g. the 2008 SWEIS) assume it does. Is not adequately protecting the public an acceptable environmental standard?

• NNSA has formally applied to develop a 64-acre (or larger) parcel in central Santa Fe. While this proposal has seemingly been rejected, the City of Santa Fe says aspects of this proposal are still under active consideration (and hence cannot be revealed). It unclear whether parallel NNSA and LANL proposals for development off Hwy 599, or in Espanola, or elsewhere, are active. LANL and NNSA representatives are on record as considering them. If they are reasonable alternatives they need to be analyzed in a SWEIS.

• NNSA is formally considering giving approximately 3,500 acres of national park quality land in LANL, in a known wildlife migration corridor, for the purposes of mixed residential, commercial, and light industrial development. The purpose of this possible transfer and development is to facilitate LANL's overall expansion. As such, it needs to be examined in a SWEIS.

• It is not just pit production (the subject of the DSA) which is expanding at LANL; decisions to expand other programs are being made as well. It is impossible to judge the combined and cumulative impact of these decisions without a SWEIS.

• There are approximately 20,000 drums of transuranic (TRU) waste at LANL -- about 18,000 at Area G (buried and aboveground) and about 2,000 elsewhere. With the advent of pit production, there is no longer a clear disposal pathway for these drums. The indefinitely-continued presence of these drums adjacent to Indian sacred lands -- which drums are being managed with more than a 100-fold lower assumed accident release fraction than similar TRU drums elsewhere at LANL -- raises significant environmental justice concerns.

• The maximum electrical load at LANL has approximately doubled over that foreseen in the 2008 SWEIS, necessitating a planned $300 million capacity upgrade project, which began this year but is currently paused until the fall of 2023. The nature -- let alone impact -- of this project is nowhere publicly described. The relative environmental impacts of reasonable alternatives are nowhere discussed.

• LANL has pitched a new high bridge over White Rock Canyon, to be connected by roughly 25 miles of new highway, most of which would pass through the Caja del Rio lands of the Forest Service and Bureau of Land Management. At the moment, it appears that this project is on hold indefinitely, but the primary impetus for the project -- better tapping the Albuquerque-area labor market, especially for construction crafts, while also avoiding traffic congestion for Santa Fe area commuters -- is strong. At the moment, this audacious proposal stands as a reminder of the wide social and environmental impacts of LANL's proposed expansion. The proposed land transfer to Los Alamos County is part of an alternative solution to that same "mission need," in NEPA terms.

• The Senate Armed Services Committee and NNSA are now both contemplating a major change in plutonium missions housed in PF-4, namely to terminate surplus plutonium disposition activities there, in order to liberate the space those missions occupy to make room for additional pit production. (See: GAO: Surplus Plutonium Disposition: Processing of surplus plutonium warhead cores ("pits") at Los Alamos is uncertain, may conflict with production of new pits, Oct 28, 2019.) This and related transportation and storage of plutonium, and related TRU waste management, have significant environmental impacts. This set of decisions, involving multiple sites and states, merits examination under NEPA, including at LANL.

• In 2008, understanding of the climate crisis was far less mature than it is today. NNSA's plans -- far more extensive than considered in 2008 -- also have larger climate impacts than was known then.

***ENDS***