More Time Needed to Comment about Proposed Expanded Plutonium Pit Production at LANL

What is the federal government thinking?  During the global pandemic caused by a highly infectious novel virus, the Department of Energy (DOE), National Nuclear Security Administration, and Los Alamos National Laboratory (LANL) are requesting public comments about their plans to expand the number of plutonium pits, or triggers, for nuclear weapons fabricated at LANL.  This week DOE agreed to a 15-day extension of time to provide public comments.  The new deadline is Saturday, May 9th.  https://www.energy.gov/nnsa/nnsa-nepa-reading-room

CCNS demands that DOE suspend the comment period until the COVID-19 pandemic is over.  The pandemic challenges the physical and mental health of the public, the social fabric of communities, the financial health of businesses, and the viability of government institutions, including DOE.  CCNS urges you to contact your elected officials to request suspension of the comment period until the pandemic is over.

Senator Tom Udall – https://www.tomudall.senate.gov/contact/email-tom

Senator Martin Heinrich – https://www.heinrich.senate.gov/contact/write-martin

Rep. Ben Ray Lujan (zipcodes in CD-3 only) – https://lujan.house.gov/contact/mail

Rep. Deb Haaland (zipcodes in CD-1 only) – https://haaland.house.gov/zip-code-lookup?form=/contact/email-me

Rep. Xochitl Torres-Small (zipcodes in CD-2 only) – https://torressmall.house.gov/contact/emailme

In a preliminary review of the Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory for Plutonium Operations, we found many references to documents going back 24 years, to 1996.  There are seven pages of references, comprising 77 individual technical documents and multi-volume documents, numbering thousands of pages, all supporting the draft.  https://www.energy.gov/nepa/downloads/doeeis-0380-sa-06-draft-supplement-analysis

Many of the documents were created by DOE as required by the National Environmental Policy Act.  These documents are “tiered” off of each other – demonstrating a confused maze of lengthy documents, all beginning with the 1996 Programmatic Environmental Impact Statement for Stockpile Stewardship and Management Environment Impact Statement.  https://www.govinfo.gov/app/details/FR-1996-12-26/96-32759  In previous comments about DOE’s expansion plans, CCNS requested DOE provide schematics to show how the documents are related to and tiered off of each other, but that was not done.

Some documents describe a proposal using two sites – LANL and the Savannah River Site in South Carolina – for fabrication of a range of pits from 20 to 450 per year.

The current document states there will be more transportation of materials and parts between LANL and the Savannah River Site, including plutonium and beryllium.  Page 18.  More radioactive, toxic and hazardous waste will be generated.  Pages 52-55.  New buildings and parking lots are needed for an estimated 400 new employees.  Page 17 and 15.

The seismic danger is underplayed.  Page 36-40.  Compare LANL’s 2014 approximate peak ground acceleration (PGA) of 0.31 g [“A gravitational force of 1 g is equal to the conventional value of gravitational acceleration on Earth’s surface (9.8 meters per second per second) footnote 14 on Page 37] with the Honor Our Pueblo Existence, CCNS and Robert H. Gilkeson, Independent Registered Geologist, August 20, 2013 comments to the Defense Nuclear Facilities Safety Board.

The recently completed and the planned future structural upgrades to the LANL PF-4 are deficient because they are based on the far too low ground motions of approximately 0.5g (1 g is the force of gravity at land surface). DOE Standard 1020-2012 requires the structural upgrades to the LANL PF-4 to survive the much larger ground motions of 1.68 g from a Seismic Design Category-5 (SDC-5) earthquake.  Page 2.

A huge amount of time will be needed to generate informed public comments.  Reviewing 24 years’ worth of dense documents in and of itself would take many weeks.  Further, the comment period overlaps with comment periods for the federal industrial waste water permit for the LANL outfalls, the federal individual stormwater permit for LANL, and the draft environmental impact statement for the proposed Holtec facility to hold spent plutonium fuel rods.

1. We hope everyone is safe and staying home. CCNS continues to work to expose and oppose the proposals of the nuclear industry during the pandemic.  Please support CCNS financially as we continue our oversight. Many thanks!  http://nuclearactive.org/    

2. Please contact the New Mexico congressional members and ask them to suspend the public comment period for the Draft Supplement Analysis at:

Senator Tom Udall – https://www.tomudall.senate.gov/contact/email-tom

Senator Martin Heinrich – https://www.heinrich.senate.gov/contact/write-martin

Rep. Ben Ray Lujan (zipcodes in CD-3 only) – https://lujan.house.gov/contact/mail

Rep. Deb Haaland (zipcodes in CD-1 only) – https://haaland.house.gov/zip-code-lookup?form=/contact/email-me

Rep. Xochitl Torres-Small (zipcodes in CD-2 only) – https://torressmall.house.gov/contact/emailme

3. The Stop the New Nuclear Arms Race, scheduled for May 22 -25 at Maryville College in Maryville, TN, has been canceled due to the closure of Maryville College due to the pandemic.

4. Saturday, April 25, 2020 ONLINE – WORLD CONFERENCE: ABOLISH NUCLEAR WEAPONS; RESIST & REVERSE CLIMATE CHANGE, FOR ECONOMIC & SOCIAL JUSTICE

April 25, 2020 9 a.m. New York/Boston/Washington, D.C.
9 a.m. EDT, 3 p.m. Central Europe, 10 p.m. April 26 Tokyo

Register at:  bit.ly/abolishnuclear

In the context of the suffering and changes being wrought by the pandemic, the two- hour world conference will focus on the continuing urgent need to abolish nuclear weapons and its relationship to stanching the climate emergency and challenging injustices which have left so many people marginalized and vulnerable. Additional sessions of the World Conference and four workshops will be for a healthier time in the future.

To accommodate people across the world the conference will be held at 9 a.m. New York/Boston time (3 p.m. in Europe, 10 p.m. in East Asia) with simultaneous interpretation. The conference will be held in concentric circles with up to 500 people in the conference itself with simultaneous live streaming so everyone can join by listening in. The conference will also be recorded and posted and made available on the worldconference2020.org and co-sponsors sites for continuing availability.

Speakers include:
• Sharon Burrows (ITUC, Australia)
• Reiner Braun (IPB, Germany)
• Joseph Gerson (AFSC/CPDCS/IPB, USA)
• Emad Kiyaei (IDG Group, Iran)
• Hiroshi Takakusaki (Gensuikyo, Japan)
• Rev. Liz Theoharis (Poor People’s Campaign, USA)
• Dr. Carlos Umana (IPPNW, Costa Rica)
• Wada Masako (Japan Confederation of A- & H- Bomb Sufferers Organizations, Japan)

Invitations pending to United Nations Office for Disarmament, the Sunrise Movement, and Marshall Islands

REGISTRATION: https://bit.ly/abolishnuclear

For more information: check out the Facebook site World Conference 2020 – Moving Online or write: JGerson80@gmail.com

Tags: CCNS, COVID-19, Department of Energy, DOE, Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory for Plutonium Operations, Holtec, Honor Our Pueblo Existence, LANL, LANL individual stormwater permit, LANL outfalls, Los Alamos National Laboratory, National Nuclear Security Administration, pandemic, Programmatic Environmental Impact Statement for Stockpile Stewardship and Management Environment Impact Statement, Robert H. Gilkeson