Update - Written comments on the scoping process for Livermore Lab's Site-Wide Environmental Impact Statement are being accepyted by DOE until September 16th. See our August newsletter for details and a sample letter.

Amid plans to develop new, earth-penetrating nuclear bombs, build a bloated mega-laser and start up a local anthrax lab, it so happens that the meter has run out on Livermore Lab's National Environmental Policy Act (NEPA) coverage. NEPA is the nation's most fundamental environmental law.

Livermore Lab's NEPA operating document is called a Site-Wide Environmental Impact Statement (SWEIS), and the last one, completed in 1992, is now a decade old. On June 17th, the Dept. of Energy (DOE) National Nuclear Security Administration announced its intent to prepare a new SWEIS to "evaluate the environmental effects of the operation of the Lawrence Livermore National Laboratory (LLNL)." The DOE's Federal Register notice goes on to "encourage public involvement on the scope [issues] and alternatives" that the new document should consider.

Where to Send Written Comments.

Public meetings were held on Wed., July 10, 2002 and Thurs., July 11, 2002. Written comments are due August 13, 2002. To ensure their inclusion in the official record, written comments should be postmarked on or before August 13. Mail them to:

Mr. Thomas Grim
Documents Manager
U.S. DOE, Oakland Operations Office
1301 Clay Street #700N
Oakland, CA 94612-5208

The DOE has a toll-free number at (877) 388-4930.

Talking Points

This is the beginning stage of the NEPA process, called "scoping." Simply put, scoping means that the public is being asked to comment on the issues it expects the document to cover. Moreover, NEPA requires that the document analyze alternatives to a facility's current plans.

The SWEIS being prepared on the operation of Livermore Lab is slated to analyze programs for 10 years into the future. Therefore, it is appropriate to insist that it cover more than "business as usual" at LLNL. In essence, the SWEIS gets to the question of Livermore Lab's mission and provides an opportunity to tell the government what the Lab should and should not be doing over the next decade. Further, it is our chance to demand a careful assessment of LLNL's past, current and potential future harm to our health and environment. Here are some issues to raise:

LLNL Plans for an Anthrax Lab. Livermore Lab proposes to obtain a "BSL III" permit, which would allow it to handle anthrax, botulism, bubonic plague, and other deadly bio-toxins on site. It is appropriate to demand a thorough evaluation of the hazards a BSL III lab could pose to workers and the community. Additionally, questions could be raised regarding the fine line between "defensive" and "offensive" or military applications of research on anthrax and other biologic agents. Should anthrax research take place at a classified nuclear weapons lab? Should it take place in a heavily populated area?

New, Classified "Nuclear Technology." According to the DOE notice, LLNL will build an entirely new "Nuclear Technology" facility. This new "project" will be described only in a classified appendix to the SWEIS. The 1992 SWEIS did not contain a classified appendix. None of LLNL's bomb design programs requires a classified appendix, not even the earth-penetrator. So, what could be so deeply classified it cannot even be named in the SWEIS? A recent article in the San Jose Mercury News discloses that the secret project is the "resurrection" of Plutonium-Atomic Vapor Laser Isotope Separation (AVLIS), a project that Tri-Valley CAREs and other groups stopped in the early 1990s. Plutonium AVLIS is a scheme to heat plutonium to create a vapor and then shoot specially-tuned, toxic-dyed laser beams through the mix to ionize and separate out specific plutonium isotopes. It is important to insist that the SWEIS contain a full, unclassified description of the proposed project and a complete accounting of its potential hazards.

National Ignition Facility. NIF will allow weaponeers to continue research on new and "modified" nuclear weapons. Additionally, NIF will be used to test the effects of a nuclear weapon explosion on hardware (like satellites and nearby weapons). Therefore, NIF will be part of the Lab's "Star Wars" research. Should the NIF be completed or abandoned? Livermore Lab is developing plans to use plutonium, highly-enriched uranium and large amounts of lithium hydride in NIF experiments. These radioactive and toxic materials would be in addition to the radioactive tritium that, along with deuterium, will be NIF's "fuel." Plutonium, uranium and tritium from past Lab operations have polluted our environment. What will the future hold with NIF?

Advanced Simulation and Computing Initiative. Livermore Lab operates ASCI "white," the world's second largest super computer and has plans for "purple"-- an even bigger machine. Livermore's Sandia Lab just broke ground for a third huge computer complex, the 70,000 square foot Distributed Information Systems Lab. These computers and other behemoth mega-machines are enormous drains on our water (for their cooling systems) and energy resources. In California these are particularly precious -- and the SWEIS should include a full accounting of LLNL and Sandia's projected water and power use.

Earth-Penetrators and Other New Nukes. LLNL is "modifying" the B83 to give it the ability to burrow into the earth before detonating. LLNL is also modifying the W80 (a nuclear warhead that sits atop submarine-launched and air-launched cruise missiles) along with several other weapons designs. Should this work continue? What would a full accounting of the hazards of new bomb development include?

Accidents, Spills, Leaks and Fires. Since its last SWEIS in 1992, when it promised no future impacts, Livermore Lab has continued to put its workers, the public and the environment at risk. Examples include uranium fires, a filter-shredding accident that contaminated workers with curium, a chlorine gas leak that forced an evacuation, tritium accidents, an explosion that sent one employee to the hospital, plutonium that had to be cut out of a worker's hand-and more. The new SWEIS must include a rigorous analysis of the potential threats posed by Livermore Lab operations with hazardous and radioactive materials.

Plutonium & Uranium. Livermore Lab's current administrative limit for weapons-grade plutonium is 1,540 pounds, and the Lab's stock is reportedly at or near that maximum limit. In the 1992 SWEIS, LLNL announced a goal of substantially reducing its inventory of plutonium. That has not happened. Livermore Lab may have more plutonium today than in the average years of the 1990s. Moreover, in 1999, LLNL announced plans to raise its administrative limit for enriched uranium from 660 to 1,100 pounds. At the same time, the limit for non-enriched uranium rose to 6,600 pounds. The SWEIS should analyze the potential impacts of these increases. Moreover, it should include the LLNL programs that use these radioactive materials so the public can comment on whether some LLNL programs should be canceled.

Security Problems. Are the nuclear materials at LLNL secure from theft and/or attack? Numerous experts say they are not. Lab employees have told us that LLNL management mishandled a bomb threat in the Lab's plutonium facility. Furthermore, the former President and Vice-President of the LLNL Security Police Officers Assn. have brought "whistleblower" lawsuits against the Lab, charging that they were fired for bringing serious security deficiencies to the attention of LLNL and DOE management. The SWEIS should analyze a series of scenarios to determine the security (or lack thereof) of nuclear materials at LLNL.

Earthquakes. LLNL is situated within 200 feet of the Las Positas fault, very near the Greenville fault, and in close proximity to other faults capable of generating high magnitude earthquakes. After the 1980 quake on the Greenville fault, LLNL sustained more than $40 million dollars in damages and a tritium leak. The Greenville fault had, until then, been classified as an "inactive fault." At the Lab's site 300 in Tracy, the Elk Ravine fault cuts across Lab property amidst a heavily-contaminated groundwater plume. The earthquake analyses in prior LLNL environmental documents have been incomplete. Moreover, the populations of Livermore, Tracy and the Bay Area have swelled since 1992.

Alternatives Analysis. As mentioned above, by law the SWEIS must contain an analysis of alternatives. The Federal Register notice discloses that Livermore Lab plans to gloss over this key requirement. Only three generic alternatives are listed: One, the "no action alternative," will consider all current activities along with unnamed "interim actions" (read these as the BSL III lab plus the closure of East Avenue). In other words, DOE defines no action as "business as usual" and then throws in two new projects just for good measure. The second is called a "proposed action alternative." It incorporates the "business as usual" alternative and adds possible plutonium use in NIF and the new "defense technologies" Plutonium AVLIS project to the mix. The third is called a "reduced operation alternative," but DOE says this doesn't mean decommissioning LLNL. There is very little description of what DOE thinks it does mean.

So, it's up to us to outline our alternatives for analysis. How about LLNL as a "green lab" devoted to peaceful and environmentally friendly science? What about site 300? Should open air tests with high-explosives and radioactive materials at site 300 continue? Or, should activities there be limited to cleanup and civilian programs? These and other questions must be placed squarely on the table.

It's your future, your community and our one, fragile Earth. What do you want to see happen in the next ten years?

Tri-Valley CAREs * 2582 Old First Street * Livermore, CA 94551 * Phone (925) 443-7148 * Fax (925) 443-0177

Email: marylia@earthlink.net

Contribute! [Action Alerts] [Citizens Watch Newsletters] [Reports] [Technical Comments] [Factsheets] [Web Links] [Mission and Goals]