The Department of Energy (DOE) and the National Nuclear Security Agency (NNSA) released a predecisional draft Environmental Assessment (EA) for its proposed Biosafety Level 3 (BSL-3) Facility on October 29, 2001. The EA outlines plans to build a new facility for manipulation and storage of infectious microorganisms at Los Alamos National Laboratory (LANL). A BSL-3 facility is a laboratory devoted to the study of live biological agents that may cause diseases with severe or lethal consequences, such as anthrax, tuberculosis, smallpox or plague. LANL is currently working on DNA of these agents under Level 2 approval from the Centers of Disease Control (CDC). In the EA, DOE/NNSA claim that expanded biological work at LANL would support DOE/NNSA missions for ýreducing counter threats from weapons of mass destruction including nuclear, chemical and biological.

Proposed Action and Alternatives. The Proposed Action and two alternatives differ in facility construction. The fourth alternative is a No Action Alternative. The Proposed Action is to construct a one-story, 3,000 square foot permanent facility. The first two alternatives involve using prefabricated buildings to house BSL-2 and BSL-3 facilities, either permanently or for a period of 12 to 18 months while a permanent facility is built. For the No Action alternative no BSL-3 facility would be built and DOE/NNSA would continue using off-site BSL-3 facilities.

DOE/NNSA is required by its own regulations to prepare an EA that will support a finding of no significant impact (FONSI). Concerned Citizens for Nuclear Safety (CCNS) and the New Mexico Toxics Coalition (NMTC) believe the predecisional draft EA does not support a FONSI. There are too many unknowns that are not addressed in the EA. The BSL-3 was not included in the Site-Wide Environmental Impact Statement for Continued Operation of the LANL; therefore DOE/NNSA is required to prepare a full Environmental Impact Statement with opportunity for public comment and public hearing.

Environmental and Health Impacts. The effects of the proposed BSL-3 facility would pose mainly human health risks. According to the EA, it is difficult to measure the risk to BSL workers and ýunfortunately, information on human health effects specifically related to BSL-3 laboratories located in the United States is not tracked in any formal manner. DOE/NNSA proposed to use LANL's past experiences with BSL-1 and BSL-2 laboratories as one way to assign risk. This is inadequate due to the increased number and hazardous levels of agents involved, and therefore do not provide any basis for the EA risk analysis.

DOE Inspector General's Report: In February 2001, the DOE Inspector General released a report that concluded that DOE's biological select agent activities suffered from "insufficient organization, coordination and direction." Also, DOE's activities "lacked sufficient Federal oversight, consistent policy, and standardized implementing procedures, resulting in the potential for a greater risk to workers and possibly others from exposure to biological agents maintained by the [DOE]."

Accident Scenarios. All of the three location options for the proposed BSL-3 facility are next to two well-traveled arteries between Los Alamos and White Rock. School buses travel this road every day. All three options are in or near LANLÝs administrative area (Technical Area 3) where one-half of LANL employees work. Option A is within one block of the Chemical and Metallurgical Research Building (CMR), one block of the beryllium facility and the thorium storage building. Option B is located just north of the Ion Beam facility and one block from the CMR building. Option C is located in Technical Area 58 (TA-58), southwest of the main TA-3.

Biowaste could end up in Santa Fe County. The proposed BSL-3 facility would create up to 50 pounds of potentially deadly waste every week, including contaminated clothing and petri dishes that might be contaminated with infectious agents. The EA indicates that the waste would be autoclaved (a process that kills microorganisms through a combination of heat and pressure) or be chemically treated, then disposed of as solid waste in the Los Alamos County landfill. Los Alamos County is proposing to ship waste to the Caja del Rio landfill in Santa Fe County, after the Los Alamos County landfill closes in 2004. The Solid Waste Management Agency, composed of Santa Fe city and county elected officials, voted recently in favor of granting "conceptual approval" to negotiate with Los Alamos County about bringing waste to the Santa Fe landfill. The vote was made before the EA was released revealing that waste from the proposed BSL-3 facility could be part of the waste stream. Miguel Chavez, Santa Fe City Council and member of the Solid Waste Management Committee, was quoted in the Albuquerque Journal North as saying, "Anthrax was not in the equation," and that he has second thoughts about going ahead with the Los Alamos County proposal.

Risk versus economic benefits. There would be no discernable economic benefit to the area, or the State, from the proposed BSL-3 facility (only five potential jobs will be created); however, the increased risk to public health and the environment could be substantial. Communities surrounding, downwind and downstream from LANL have been burdened with the risk from "special nuclear materials," hazardous materials and nuclear and chemical wastes stored on-site. This proposed facility poses an unacceptable additional burden.

Seismic activity. The proposed facility is located in an earthquake fault zone. According to the EA, the 1995 comprehensive seismic hazards study ýreports that faults in the TA-3 area show vertical displacements ranging from 1 to 10 feet (0.3 to 3 m). While surface ruptures indicated by near-surface vertical displacements can cause significant structural damage, surface rupturing earthquakes are low probability events. The 1998 study conclusions for the CMR building are that "the probability of damaging ground motion is at least 20 times greater than the probability of damage caused by surface rupture." Prefabricated buildings are not earthquake proof, therefore more in-depth analysis of the seismic activity is required.

Transportation. The existing BSL-2 facility receives approximately four shipments and ships out two per month. It is expected that the proposed BSL-3 facility would generate between 10 and 60 shipments per month. Diamond Drive and Pajarito Road access the proposed facility and are highly traveled roads. The proposed facility creates additional security and additional security and accidental release risks to public health and the environment.

Hazard Ranking. The Centers for Disease Control (CDC) in Atlanta, Georgia determines, and regulates, BSL Levels 1 through 4. Level 3 facilities may work with a wide variety of biological agents of human disease. The proposed facility is considered to be a ýmoderate hazardous facility with ýthe potential for considerable on-site but only minor off-site consequences to people or the environment.

Public Participation. There will be a public information meeting to discuss the BSL-3 facility on Wednesday, November 14, from 4 to 7 p.m. at the Los Alamos Inn, 2201 Trinity Drive, Los Alamos. Public comment on the EA is being accepted from now until November 19 at the office of Elizabeth Withers, NEPA Compliance Officer, Ms. Elizabeth Withers, NEPA Compliance Officer, Office of Environment, 528 35th Street, Los Alamos, NM 87544, or email at

Write to Ms. Elizabeth Withers and tell her that you are opposed to the proposed BSL-3 facility at LANL.

Read CCNS and the New Mexico Toxics Coalition's preliminary comments on the proposed BSL-3 facility

For more information, contact Concerned Citizens for Nuclear Safety at 986-1973 or the New Mexico Toxics Coalition at 982-2609.

November 10, 2001

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