Lawsuit Affidavits

The following affidavits were written by the Los Alamos Study Group for a 1997 lawsuit pending against the Department of Energy (DOE). The lawsuit, filed by thirty-nine organizations, seeks among other goals to enjoin portions of the DOE's Stockpile Stewardship and Management (SS&M) program on the basis that its programmatic environmental impact statement (PEIS) is inadequate.

The SS&M program includes operations at many facilities throughout the nation's nuclear weapons complex, and many organizations have contributed to the lawsuit. The affidavits on this site, however, are limited to the work of the Los Alamos Study Group and the SS&M activities scheduled to take place at the Los Alamos National Laboratory. They cover such issues as national security, nuclear waste storage, plutonium pit production, and seismic concerns.

Although the plaintiffs' request for preliminary injunction was denied in August of 1997, federal Judge Stanley Sporkin ordered the DOE to disclose more information about the SS&M program.  As of December 1997, the case is proceeding towards a full airing of the issues on their merits.

As of January 1998 a motion of contempt was filed in this case against Secretary of Energy Federico Pena and other DOE officials -- Link Here for Details.

• Greg Mello "Pit Production" Affidavit April 6, 1998



• Greg Mello Affidavit #1 (Area G, CMR)



• Greg Mello Affidavit #2 (Seismic)



• Greg Mello Declaration #1 (National Security, JASON study)



• Greg Mello Declaration #2 (Area G)



• Carlson Affidavit (Pit Production)



• NRDC HomePage for this Litigation
  (includes the request for relief, additional
  affidavits, and a list of plaintiff organizations)