(The following is a letter that was sent to the Santa Fe County Commissioners Sat, Nov 27, 2010.)

Re: Proposed Joint Resolution from Santa Fe County (and City, passed) requesting an environmental impact statement (EIS) for the proposed Los Alamos plutonium complex

Dear Santa Fe County Commissioners --

I am writing in favor of the above Joint Resolution. 

The National Environmental Policy Act (NEPA) requires federal agencies to notify and invite comments from local jurisdictions regarding federal projects which could have significant impacts on the human environment.  Agencies must prepare an EIS examining all reasonable alternatives to a project prior to actions which would prejudice the agency toward the project, or actions which irreversibly commit resources.  The views of local jurisdictions (especially, their laws and regulations) must be taken into account. 

The National Nuclear Security Administration (NNSA) is poised to construct a large plutonium facility at Los Alamos National Laboratory (LANL), for the purpose of increasing the plutonium storage, manufacturing, and processing capabilities of LANL.  It is called the Chemistry and Metallurgy Research Replacement Nuclear Facility (CMRR-NF).

The full scope of the CMRR-NF project, in both its construction and operating phases, is not at all widely known.  Since the 2003 CMRR EIS it has doubled in gross area, increased its concrete requirements by a factor of more than 100, and introduced the so-called "hotel" design concept which makes future missions uncertain.  Even those planning its construction do not know all the missions proposed for this building, because they have no "need to know."  Its environmental, traffic, social, and economic impacts are even more mysterious, because they have never been studied in more than a cursory fashion.  Reasonable alternatives are not being analyzed. 

The proposed County resolution is not a referendum on the pros or cons of this facility.  It would merely ask for an EIS. 

If CMRR-NF is a basically good, solid idea, examination of alternatives and impacts via an EIS process can only improve it.  If it is a bad idea, NNSA, Congress, and the County need to know that sooner, rather than later. 

The last big plutonium facility built by the Department of Energy (DOE) was only operated for one month before design deficiencies crippled the building.  DOE called it a "fiasco."   

At present, NNSA is conducting a "supplemental" EIS (SEIS) process for this facility.  This process is meant to be a "quick-and-dirty" way to provide better NEPA "coverage" for the project, which continues.  The SEIS process has a number of defects.  For example, at present we know of no organization or agency which was properly notified of the SEIS process, including, we think, the County.  Second, the SEIS examines just two alternatives to building the proposed complex, one of which NNSA has already abandoned.  NEPA requires examination of all reasonable alternatives, not just one or two "straw men." 

Perhaps the greatest problem with the existing process is that the Administration, in its negotiations with the Senate, has already promised to build the facility.  The "alternatives" mentioned, supposedly the "heart" of the EIS process, are not being seriously considered. 

An EIS would help answer questions about this facility, including questions about its long-term economic impact.  What would be the cost to tourism, and to property values, of building and operating this facility, with the nuclear waste disposal and nuclear transportation that would go with it?  What would be the cost to the identity and attractiveness of Santa Fe County?  How well would the area's status as a major tourist destination hold up?  Tourism is certainly far more important than LANL in the region's economy, and far more important than the construction jobs temporarily associated with this building.   These are not trivial questions, potentially requiring considerable research.  NNSA, not the County, should pay for that research, and it should be done before CMRR-NF is a "done deal."  NNSA may be afraid of the answers, but we need to know.  NNSA is required to produce a mitigation plan for negative impacts, but if these impacts aren't known there will be no plan. 

NNSA has said that after construction there will be no new jobs as a result of this building.   So would the region be better off with a plutonium processing center, or not?  We don't even know how many construction workers are expected to come from out of state.  We know that many construction workers will need special nuclear certifications and must be recruited from afar; what we don't know is how many of these "guest workers" will be coming, where they will live, where their children will go to school, or how these and other impacts will be paid for.  An EIS would be the foundation for any such discussion.

The health consequences of a major accident could be very serious.  The economic consequences could also be very serious, and at lower contamination levels.  At Rocky Flats, a health advisory had to be, and may still be, attached to deeds of downwind properties. 

The incorporation of safety features into CMRR-NF design has only occurred because of independent oversight and years of political intervention, including by this organization.  A new EIS would greatly help with the process of internalizing responsibility.  No plutonium facility has ever operated without serious environmental problems.  To minimize these, or to avoid them, an EIS is needed. 

Further information is provided at http://www.lasg.org/CMRR/open_page.htm. 

I am available to answer any questions you may have.  My contact information is below. 

Thank you for your attention,

Greg Mello