Documents: Full CCNS and EVEMG SWEIS Comments(pdf)September, 2006

Background InformationJune 25, 2005

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Links

NNSA Los Alamos Site Office NEPA Page

The Environmental Protection Agency's NEPA Information Page

The New Mexico Environment Department's Hazardous Waste Bureau's LANL Page

Citizens for Alternatives to Radioactive Dumping

Peace Action New Mexico

Nuclear Watch of New Mexico


Clean Up, Don't Build Up!
The Draft Site-Wide Environmental Impact Statement for
Los Alamos National Laboratory
The Department of Energy (DOE) released a draft Site-Wide Environmental Impact Statement (SWEIS) for Los Alamos National Laboratory (LANL). The SWEIS lays out the planned programs at LANL for the next five years and evaluates the environmental impacts of those programs.

The Department of Energy collected public comment regarding the draft LANL SWEIS and is now in the process of incorporating the public's comments and finalizing the document, as required under the National Environmental Policy Act. Below is a summery of the comments submitted by CCNS and the Embudo Valley Environmental Monitoring Group (EVEMG). The full comments and can be downloaded as a whole or in separate sections. Please click on the subject headings to down load a pdf of the full comments for that section.

CCNS and EVEMG submitted Exhibits to the text of our comments. The Exhibits included technical analysis of the water issues in the draft SWEIS as well as music and images which express our convictions and concerns about the LANL mission. The Exhibits can be downloaded as a whole, or click here to see the Exhibits. The images and music in Exhibit 6 can be found here.

General CCNS and EVEMG Comments

Throughout the draft LANL SWEIS, DOE/NNSA consistently uses misleading, incomplete and inaccurate information and technically indefensible data as a basis for analysis and relied on documents which have not been finalized to make conclusions in support of the Expanded Operations Alternative, the Preferred Alternative. For these reasons, we demand that the current draft LANL SWEIS be withdrawn. DOE/NNSA must finalize draft reports, provide accurate information/data collection and a conduct a subsequent reanalysis of data, which must all be released to the public for comment and review. NNSA/DOE must provide responses to comments to the public. Only then may a new draft LANL SWEIS be released for public review and comment under NEPA. Below is a summary of our justifications for our demand.

  • Click here for a pdf of the introduction to our comments

  • Click here for a pdf of the conclusion to our comments

    Air Emissions: pdf of our air comments

    • DOE/NNSA proposes to process 87,000 pounds of high explosives and up to 6,900 pounds of depleted uranium (DU) for dynamic experiments and studies annually in open air burning and explosions without proper, adequate and technically defensible monitoring.

    • Further, the 1979 LANL Final Environmental Impact Statement estimates that 220,000 pounds of depleted uranium were used in dynamic experiments during the history of LANL. From 1979 to present we do not know how much DU and high explosives have been used in experiments and remains in the environment.

    • DOE/NNSA is hiding under the “grandfather clause,” which allows for facilities existing before December 31, 1988 to emit toxic air pollutants without regulation. Many of these radioactive, toxic and hazardous air pollutants do not have any standards protective of human health and the environment.

    • DOE/NNSA continues to use evaporation as a waste disposal method for tritium. DOE/NNSA must develop alternative, energy efficient technologies to handle tritium wastes other than a method which involuntarily exposes living beings.

    • DOE/NNSA must evaluate increased air emissions due to increased power demand and car use by commuters.

    • DOE/NNSA is not providing the best care for Bandelier National Monument, a Class 1 area under the Clean Air Act.

    Waste: pdf of our waste comments

    • The draft LANL SWEIS does not make use of the transuranic waste numbers provided in the most recent regulatory document for the Waste Isolation Pilot Plant (WIPP). Therefore, DOE/NNSA overestimates the amount of transuranic waste that may be shipped to WIPP.

    • The draft LANL SWEIS omits that there is no disposal path for the majority of the transuranic waste which would be generated by the Expanded Operations Alternative.

    Ground and Surface Water: pdf of our water comments

    • Data is Not Representative: LANL's own Well Screen Analysis Report (WSAR) reports describe the samples as being not representative.
    • The Draft LANL SWEIS reveals the emerging presence of the radionuclide contaminants neptunium-237, plutonium-239, plutonium-240, and strontium-90 in the regional groundwater resource.

    • The data tables in the draft LANL SWEIS document the presence of neptunium-237 in the drinking water of Los Alamos County at levels above the Environmental Protection Agency (EPA) Drinking Water Standard (DWS).

    • The water quality data in the draft LANL SWEIS show that groundwater produced from "other springs" is contaminated with strontium-90 at a level more than 13 times greater than the EPA DWS.

    • Hexavalent chromium contamination is present in the regional aquifer at concentrations greater than four times than the EPA DWS.

    • The draft LANL SWEIS does not make use of the most recent regulatory surface water standards or list of impaired streams.

    Environmental Justice: pdf of our EJ comments

    • The incorrect definition of "low income" was used in the Environmental Justice analysis.

    • No scoping was done within the effected communities regarding the impacts to sacred sites or land use. Furthermore, the scoping done following the signing of the New Mexico Environmental Justice Executive Order 2005-56 was not used or referenced.

    • Environmental Justice was omitted from the cumulative impact analysis of Chapter 5, section 5.13.

    • The public comment hearings were scheduled during the Pueblo feast days.

    • Tribes who use the area for ritual practices were not included in the draft LANL SWEIS analysis.

    Cumulative Impacts: pdf of our cumulative impact comments

    • Not all communities within the limited 50-mile radius were contacted regarding the cumulative impact analysis. Furthermore, it appears that once contacted, no follow up was done.

    • DOE/NNSA provided no justification for the 50-mile radius analysis. Given that LANL and Sandia National Laboratories are located within 60 miles of each other, DOE/NNSA must provide a technically defensible analysis of what other nuclear sites are not included in the draft LANL SWEIS analysis.

    • Repeated references are made to a "modern pit facility" within the cumulative impacts analysis. DOE/NNSA must make no reference to this facility without proper analysis and upfront statement of intention as a primary discriminator on the Cover Sheet.

    LANL's Area of Influence: DOE/NNSA has limited the impacted area to a 50-mile radius around LANL in an arbitrary and capricious manner.

    • We know from the smoke plume resulting from the Cerro Grande Fire that the area of influence extends beyond a 50-mile radius. There is no technically defensible scientific explanation for this choice and it appears to be only a convenient round number.

    • If the impacted area were increased to a 60-mile radius around LANL, then Albuquerque, which has a population of nearly half a million, would be included in the area of influence.

    • Considering the close proximity of LANL and Sandia National Laboratories, the 50-mile radius does not account for the individual and cumulative impacts of these facilities. The designation must be increased in order to analyze the impacts of the programmatic effects of both national laboratories and other nuclear facilities, including uranium mines.

    • Technically defensible scientific analysis must be done to define the area of influence of the two national laboratories in New Mexico.

    Documents Still Not Available or Finalized:

    • Draft Agency for Toxic Substances and Disease Registry Public Health Assessment. The draft LANL SWEIS relies on conclusions made in the draft Agency for Toxic Substances and Disease Registry (ATSDR) Public Health Assessment which was released for public comment last summer. In comments about the draft assessment, the EPA stated, "ATSDR may have been overly conservative in their risk assessment approach and makes a blanket statement that there is no problem. ATSDR should redo their risk assessment to reduce conservatism and not assume that there is no risk."Exhibit 17.1.

    • Safety Analysis for Area G has not been completed. The last analysis was completed in 1997, almost a decade ago. Given that one of the greatest accident scenarios in the draft LANL SWEIS involves waste at Area G, the Safety Analysis must be released for public comment and review prior to DOE/NNSA releasing a new draft LANL SWEIS.

    • The Report in Preparation by the LANL Seismic Hazards Geology Team. The draft LANL SWEIS states that the seismic hazard report will be released in the fall 2006. In the 1999 SWEIS, DOE predicted 45,000 years between seismic events. However, based on new fieldwork, the draft LANL SWEIS states that this number has been reduced to 2,000 years between events. The draft LANL SWEIS must be withdrawn until this report is released to the public for review and comment before a new draft LANL SWEIS is prepared and released to the public for review under NEPA.

    Legitimate "No Action Alternative":

    • CCNS and EVEMG request that a legitimate "No Action Alternative" be included in the reanalysis of the draft LANL SWEIS. Such an alternative would seriously consider ceasing active nuclear weapons operations at LANL and begin cleanup of the 63-year toxic legacy.

    • CCNS and EVEMG ask for the inclusion of a "Greener Alternative," which focuses on sustainable operations and environmentally just practices at LANL. We were among many groups who requested these alternatives during the scoping session.

    • CCNS and EVEMG object to the statement that the "NNSA is not evaluating a similar alternative in this [2006] SWEIS because, as stated in the 1999 SWEIS…a Greener Alternative would not support the nuclear weapons mission assigned to LANL." It is revealing that DOE/NNSA and LANL emphasize nuclear weapons manufacturing over protecting the environment. CCNS and EVEMG believe that DOE/NNSA must seriously consider a mission for LANL that focuses on life-affirming research and the development for renewable non-nuclear energy, such as solar, wind and biomass, and clean-up technologies that support environmental and public health. Please see Exhibit 12.

    • Global warming and climate change issues are of paramount importance and must be addressed with the same critical fervor as developing nuclear weapons from 1943 to 1945.

    Nuclear Non Proliferation Treaty (NPT):

    • Article 6(c) of the NPT states "[T]he determined pursuit by the nuclear-weapon States of systematic and progressive efforts to reduce nuclear weapons globally, with the ultimate goals of eliminating those weapons, and by all States of general and complete disarmament under strict and effective international control." The Expanded Operations Alternative, the Preferred Alternative, presented in the draft LANL SWEIS calling for increased plutonium pit production violates the spirit of the NPT. DOE/NNSA must outline in the new draft LANL SWEIS exactly how a proposal to increase plutonium pit production for refurbishment of our nuclear stockpile honors our commitment under the NPT and is in accord with international efforts for disarmament.

    Exhibits pdf of most exhibits

    Some Exhibits are not available online. Please contact CCNS if you would like a hard copy of these Exhibits.

    • Exhibit 1: Gilkeson, Bob. "The Complex Geologic Setting Beneath LANL Requires the Use of Drilling Methods that Mask Detection of Most Radionuclide and Chemical Contaminants in Groundwater."

    • Exhibit 2: Gilkeson, Bob. "Deficiencies in the Draft LANL SWEIS for the Water Quality Data Produced From the LANL Monitoring Wells."

    • Exhibit 3: Gilkeson, Bob. "Failure of Draft LANL SWEIS to Address the Environmental Impact From the Hexavalent Chromium Plume in the Regional Aquifer."

    • Exhibit 4: Gilkeson, Bob. Failure of the Draft LANL SWEIS to Address Environmental Impact Because of Groundwater Contamination From the RCRA Regulated Disposal Sites at Technical Area 54."

    • Exhibit 5: George Rice, Remediation of MDAs

    • Exhibit 6:Multi Media Compact Discs

    • Exhibit 7: Email, Elizabeth Withers to Joni Arends, September 19, 2006

    • Exhibit 8: Census Articles

      • 8.1 Cotreras, Russell. "N.M. 40th in Nation in High School Grads." Albuquerque Journal July 3, 2004.

      • 8.2 Garcia, Patricia. "State's Social Health Poor, Study Says." Albuquerque Journal November 19, 2003.

      • 8.3 Burford, Katie. "More Live in Poverty, Group Says." Albuquerque Journal July 9, 2003.

      • 8.4 Armas, Genaro. "Thousands of Minority Kids Missed in Census." Albuquerque Journal December 7, 2002.

      • 8.5 Armas, Genaro. "N.M Tops U.S. For Poverty in 2001." Albuquerque Journal September 25, 2002.

      • 8.6 Dickinson, Joy. "N.M. Ranks 50th in Child Poverty Report." Albuquerque Journal May 24, 2002.

      • 8.7 Propp, Wren. "Los Alamos Leads State In Median Income Level." Albuquerque Journal January 15, 2002.

      • 8.8 Massey, Barry. "Report: N.M. Still Among Nation’s Worst for Poverty," Associated Press, “Poverty Rate up for 4th Strait Year,” The New Mexican August 8, 2005.

      • 8.9 Armas, Genaro. "White Counties Found Big Income Gains." The New Mexican June 28, 2002.

      • 8.10 Tollefson, Jeff. "Senator: Income Numbers Skew Aid Eligibility." The New Mexican March 15, 2002.

    • Exhibit 9: Environmental Justice

      • 9.1 Associated Press. "Lawsuit accused LANL of discrimination against women, Hispanics." The New Mexican August 8, 2006

      • 9.2 CCNS comments regarding the draft EIS for the National Enrichment Facility, January 7, 2005

      • 9.3 Smith, Brice. "Soil Cleanup at Los Alamos National Laboratory." Science For Democratic Action April 2006.

      • 9.4 State of New Mexico Environment Department Office of the Secretary. "Additional Fish Consumption Advisories Announced." January 2, 2006

      • 9.5 State of New Mexico Office of the Governor. "Executive Order 2005-056 Environmental Justice Executive Order." November 18, 2005.

    • Exhibit 10: Santa Fe City Council

      • 10.1 Journal Staff Reports. "SF Against LANL Plutonium Work." Albuquerque Journal August 29, 2006.

      • 10.2 City of Santa Fe, New Mexico. "A Resolution Objecting to Proposed Expanded Nuclear Weapons Activities, Including Plutonium Pit Production [sic], at The Los Alamos National Laboratory and Directing the City Clerk to Inform Federal Authorities of the Objections."

    • Exhibit 11: Receipts

      • 11.1 CCNS and EVEMG draft LANL SWEIS Comments, 2006

      • 11.2 Letters Regarding the Draft LANL SWEIS, 2006. Sample Letter

      • 11.3 Letters Opposing Construction and Operation of a Modern Pit Facility, 2003. Sample Letter

    • Exhibit 12: Mission

      • 12.1 NM SEES. "New Security, New Mission, New Mexico."

      • 12.2 Don’t Let New Mexico Go to the Pits Placard.

      • 12.3 Hill, Judyth. "Wage Peace."

      • 12.4 Political Cartoon, "One of the Lesser Known Elvis Movies."

      • 12.5 Glasgow. "Join the Fun?" Albuquerque Journal 1997.

    • Exhibit 13: Maps

      • 13.1 Map Showing Proximity of Los Alamos National Laboratory and Sandia National Laboratories.

      • 13.2 Areas of the Continental United States Crossed by More Than One Nuclear Cloud from Aboveground Detonations.

    • Exhibit 14: Burroughs, John and Makhijani, Arjun. "Undermining Nuclear Security Agreements."

    • Exhibit 15: Cerro Grande Fire

      • 15.1 Question Sheet: Cerro Grande Fire

      • 15.2 Russ, Abel. "Comments on the 2002 Risk Assessment Corporation analysis of risks from the 2000 Cerro Grande fire at Los Alamos National Laboratory."

    • Exhibit 16: Water

    • Exhibit 17: Health

      • 17. 1 Letter, EPA, Re: Public Comment Release- Public Health Assessment of LANL, July 27, 2005

      • 17.2 Bernd Franke, Catherine M. Richards, M.S., Steve Wing, Ph.D., David Richardson Ph.D., and Concerned Citizens for Nuclear Safety. "New Mexico's Right to Know: The Impacts of LANL Operations on Public Health and Environment."

    • Attachment 1: Figures for Exhibits 1-4

    September 23, 2006



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