August 30, 2002

Ms. Elizabeth Withers
EIS Document Manager
Office of Los Alamos Site Operations
528 35th Street
Los Alamos, NM 87544

Re: Notice of Intent to Prepare an Environmental Impact Statement for the Proposed Chemistry and Metallurgy Research Building Replacement Project at Los Alamos National Laboratory

Dear Ms. Withers:

Concerned Citizens for Nuclear Safety (CCNS) makes the following comments about the scope of the draft environmental impact statement (EIS) for the proposed Chemistry and Metallurgy Research Building Replacement Project at Los Alamos National Laboratory (LANL), pursuant to the July 23, 2002 Federal Register notice:

1. CCNS requests to be place on the EIS mailing and document distribution list.

2. CCNS appreciates that the EIS contractor, SAIC, contacted the community about possible dates for the scoping meetings. Thus, we were able to avoid conflicts with other Department of Energy (DOE) hearings taking place in New Mexico.

3. The draft EIS should include a discussion of Article VI of the Non-Proliferation Treaty (NPT) in which the United States has agreed to "unequivocal commitment" move towards the total elimination of nuclear weapons. CCNS believes the replacement building is merely a "fig leaf" for nuclear weapons research and design.

4. The draft EIS should list all projects that may be under construction within the next ten years. The Comprehensive Site Plan lists a number of proposed projects, including the Advanced Hydrotest Facility.

The final Environmental Assessment for the Proposed Construction and Operation of a Biosafety Level 3 Facility at LANL," DOE/EA-1364, lists possible facility construction projects in the vicinity of TA-50 and TA-55 within the next ten years to include: a new building to house the TA-18 material storage and critical assembly operations, a new power line, "possible construction of a new building for pit manufacturing use," and a new waste management facility. p. 100. The draft EIS should include analyses the cumulative impacts of these proposed projects on the proposed replacement building and the affected environment.

These analyses should include an examination of TA-50's MDA C and any potential impacts to the affected environment.

5. The draft EIS should include an annual and lifetime inventory of actinide, other radioactive materials, and chemicals that will be used in the replacement building for processing, characterizing and storage of special nuclear materials and analytical chemistry that support the research and development capabilities. Dynamic experiments - need to handle large containment vessels.

6. CCNS objects to the placement of a hazard category 2 facility very close to a seismic fault trace. The Jemez Mountains are volcanic and the draft EIS should include a complete analysis of whether a $1 billion investment should be made at LANL. LANL sits on the Pajarito Plateau, a volcanic, earthquake, and major forest fire zone, above the largest fresh water artery in New Mexico, the Rio Grande. Downstream from LANL, over 10 million people use the Rio Grande for drinking, irrigation and industry. Those numbers are expected to increase.

7. The draft EIS should be specific about the use of the two or three buildings. What is the purpose of the third building? The draft EIS should discuss the impacts to the affected environment by the proposed tunnel and parking structure.

8. An ecological risk analysis should be included in the proposed action and the alternatives, including the no action alternative.

9. The draft EIS should include an analysis of impacts to the existing Radioactive Liquid Waste Treatment Facility (RLWTF) at TA-50 by the proposed replacement building. How will LANL reduce discharges from the proposed replacement building? The draft EIS should include the daily, monthly and annual proposed discharges from the proposed replacement building and resulting discharges from the RLWTF and their impacts to the affected environment.

10. The draft EIS should include an analysis of waste generation from the proposed replacement facility, including low-level, transuranic and high-level radioactive waste, and chemical and hazardous waste, on the affected environment.

11. How many people will be authorized to review the classified information associated with the draft EIS, besides DOE/NNSA and its contractors?

CCNS believes that before a replacement building(s) is built, that a Hazard Category 2 nuclear waste facility should be built above-ground for the transuranic waste stored in fabric tents at TA-54, Area G.

CCNS requests a response to our comments. CCNS also requests a copy of the determination and any final documents. 10 CFR § 1021.314(c)(3). Should you have any comments or questions, please contact me.

Joni Arends
Waste Programs Director