For immediate release August 18, 2022

NNSA to conduct lab-wide "environmental impact statement process" to justify two year old decision to add huge new mission to Los Alamos National Laboratory (LANL)

Documents obtained under FOIA reveal that much greater expansion is needed for the new mission than was admitted two years ago -- including one or more new plutonium facilities and other high-hazard facilities

Study Group: nuclear agency seeks legitimacy for illegal actions with a new "public process" that is itself post-hoc and illegal

Contact: Greg Mello, 505-265-1200 office, 505-577-8563 cell

Permalink * Prior press releases

Albuquerque, NM -- Tomorrow the National Nuclear Security Administration (NNSA) will publish a Notice of Intent to prepare a new Site-Wide Environmental Impact Statement (SWEIS) for Los Alamos National Laboratory (LANL). (For comments, see below.)

DOE and NNSA officials had already informally announced this process in late 2021 and again in early 2022 (see "Is the Department of Energy (DOE) going to conduct a new Site Wide Environmental Impact Statement (SWEIS) for Los Alamos National Laboratory (LANL), and if so what would it mean?" and "Los Alamos Study Group Responds To DOE/NNSA Announcement Of Plans For LANL Site-Wide Environmental Impact Statement" Los Alamos Reporter, January 8, 2022)

Months later, Ted Wyka, Manager of NNSA's Los Alamos Field Office, announced on June 21 that a new SWEIS process would begin some time soon. Today's announcement by NNSA sets that process formally in motion.

NNSA's announcement notes:

Tomorrow’s publication of the NOI in the Federal Register will begin a 45-day scoping comment period.  NNSA will accept comments from all interested agencies (federal, state, and local), public interest groups, federally-recognized Tribes, businesses, and members of the public on the LANL SWEIS. Following completion of the SWEIS, NNSA will decide which reasonable alternatives to implement and will announce its decisions through a Record of Decision (ROD).  Absent any new decisions associated with this SWEIS process, NNSA would continue to implement decisions announced in previous RODs. The comment period ends 45 days after the posting in the Federal Register [i.e. on Monday, October 3, 2022].

Following its usual practice, NNSA will consider all "currently assigned missions" to be part of the "no-action alternative," i.e. as having no additional environmental impacts or requiring any agency decision. This would include construction of "minor replacement facilities," "upgrades to existing facilities and infrastructure," and "decontamination, decommissioning, and demolition projects."

"Minor," in current NNSA parlance, means new construction up to $50 million in cost.

This "no action" includes at least $19.4 billion in new construction and operational costs for LANL's new plutonium warhead core ("pit") production mission through fiscal year (FY) 2033, of which $5.2 billion has already been spent. (See "Warhead plutonium modernization spending, actual & proposed by site," May 6, 2022" and "NNSA budget request for Los Alamos warhead 'pit' project adds five proposed plutonium buildings, fresh rad waste cost overruns, adding $329 million to LANL pit costs," May 9, 2022).

The words "pit" and "plutonium" are nowhere mentioned in NNSA's announcement.

In addition to this, NNSA will examine an "Expanded Operations Alternative."

This alternative includes the scope of the No-Action Alternative, as described above, plus additional modernization activities. This alternative includes: (1)  construction of replacement facilities; (2) more significant upgrades to existing facilities and infrastructure; (3) more significant DD&D projects. Under this alternative, NNSA would replace facilities that are approaching their end of life, upgrade facilities to extend their lifetimes, and improve work environments to enable NNSA to meet operational requirements. The proposed DD&D of older facilities would eliminate excess facilities and reduce costs and risk. This alternative would not expand capabilities and operations at LANL beyond those that currently exist.

For the benefit of those seeking to comment, NNSA announces that it will not consider analyzing the (reduced) impacts that would result from any alternative involving "transfer of current missions/operations from the Laboratory to other sites, as those actions would be inconsistent with the LANL mission defined by NNSA."

NNSA says it is conducting this SWEIS process in part "[b]ecause of comprehensive site planning activities that are under consideration..." The Los Alamos Study Group requested LANL's recent comprehensive site plans on September 17, 2020 under the Freedom of Information Act (FOIA) and again on April 22, 2022. We are currently litigating in Washington DC District Court to uncover the plans NNSA is cryptically referencing as the main justification for today's announcement ("Lawsuit seeks agency plans to accelerate production of nuclear warhead cores; Largest program in agency history is effectively secret -- and in trouble," Apr 6, 2022).

On August 11, 2022 we received a so-called "Campus Master Plan" describing some of the conclusions of the planning process that, as the agency says, are driving NNSA to create a new SWEIS.

This document indicates, among other things, that to continue LANL's existing assigned missions more than 4 million square feet of new construction is needed for the main LANL technical area (TA-03) and the western end of Pajarito Canyon, where LANL's plutonium operations are located. "Several thousand" additional new staff members will be needed in Pajarito Canyon. LANL's main plutonium facility ("PF-4") will need to be replaced or augmented with one or more additional plutonium facilities, and two other large high-hazard nuclear facilities will also need to be replaced. The cost of a new plutonium facility alone would lie in the $10 billion range, if it is feasible. The previous effort failed. (That and previous failures were described as "Sisyphean" by the Congressional Research Service; see also Bulletin 281: LANL pit production: fifth failure in progress, Jul 16, 2021).

Despite years of planning, LANL's secret master plan indicates LANL still has no firm idea of how all these workers will all be able to get to work from faraway residences or travel from site to site within the Laboratory. Walking is suggested: the 40-square-mile LANL site is presented as "a highly walkable, pedestrian-oriented place where workers will find routine walking for access, exercise, and refreshment to be safe, convenient, and appealing." (See Bulletin 296: The troubled logistics of LANL pit production: how will LANL staff and contractors get to work?, Mar 26, 2022)

Until September 2020, when NNSA announced its decision to drastically expand LANL to take over the mission of the former Rocky Flats Plant (here and here), this organization, supported in this matter by hundreds of individuals and dozens of organizations and businesses, assiduously sought a new SWEIS for LANL, as detailed in our January 7, 2022 press release.

After NNSA's intention to prepare a new SWEIS was announced to the Los Alamos Council Council two months ago, the Study Group added this comment to its popular "Call for Sanity, Not Nuclear Production:"

There is absolutely no indication that NNSA will pause any preparations for pit production at LANL, or pause anything else, for the sake of National Environmental Policy Act (NEPA) compliance. NEPA requires analysis before, not after, decisions to proceed with major federal projects. In this case NEPA is being used in bad faith by DOE and NNSA to obscure rather than to provide transparency, and as a tool to provide legal coverage for current and future expansions and environmental impacts.

Greg Mello, Los Alamos Study Group director:

"NNSA's announcement of a new SWEIS, which explicitly aims at sweeping $20 billion in new plutonium activities under the rug over the '15 year' analysis period, is yet another high-handed pronouncement from our would-be nuclear masters. By calling this unprecedented expansion "no action," and a priori eliminating any alternative to it, NNSA limits public discussion to what it has already illegally decided to do, and the proposed further expansions it will gradually reveal over time.

"NNSA need not reveal its plans in this SWEIS, if past practice is any guide. That usually happens down the road a few years. NNSA will not be more candid now than it has been in the past.

"NNSA has announced that there will be no environmental comparison between 'LANL with its new plutonium production missions' -- 'Rocky Flats South' or 'MegaLANL' and the LANL that has existed up to now, a research and development site. LANL has other expanding plutonium missions as well, in surplus plutonium processing and heat source manufacturing.

"A lot of people in New Mexico think of LANL in static terms. The LANL they know is gone. The new LANL is a key nuclear weapons production site, responsible for the dirtiest job in the nuclear warhead complex. Politically, it's taking over Santa Fe. 'Plutopia' here we come. St. Francis, move over -- Bombs R Us. Oppie is the new patron saint.

"Until 2018, NNSA said LANL was not the best place for the new pit manufacturing mission. Then in 2019, congressionally-mandated independent reviewers told NNSA it could be disastrous ("very high risk") to operate LANL's old, cramped facilities on a 24/7 basis. Yet that is precisely what NNSA chose to do -- and now NNSA says that any alternative is "unreasonable." NNSA is saying that the professional advice of the highly-regarded Institute for Defense Analyses is unreasonable. If NNSA won't listen to IDA, they won't listen to you.

"This is a completely bogus process, in which NNSA seeks to create a veneer of legitimacy and public acceptance for its reckless plans. It's pure manipulation and spectacle.

"LANL documents obtained under FOIA, NNSA's own congressional testimony, and other federal sources reveal that NNSA is unlikely to meet its statutory obligations at LANL. Don't be fooled by NNSA's aura of invincibility. They have failed at this mission at LANL four times already and beneath the shiny paint, the present effort is failing as well. Leaders in the region need to "get their minds out of the lab," which has failed to provide economic and social development in its hinterland, and focus on the people and the environment. Reject pit production and nuclear weapons as the new economic identity for northern New Mexico. It's a fool's errand."

***ENDS***