BY GREG MELLO
Los Alamos Study Group

Today the National Nuclear Security Administration (NNSA) released a draft “Supplement Analysis” (SA) to the 2008 Site-wide Environmental Impact Statement (SWEIS), for operations at Los Alamos National Laboratory (LANL). NNSA has said it will accept comments for 45 days, until April 24. (If you wish to comment, email lanlsweissa@nnsa.doe.gov, with subject line “LANL SWEIS SA comment.”)

This SA – draft or final – is not an environmental impact statement (EIS) of any kind, or even an abridged or supplemented EIS. It is an analysis of whether to supplement LANL’s 2008 SWEIS.

NNSA is under no obligation to issue a draft SA, and NNSA is under no obligation to consider any comments received. An SA is basically an open “memo-to-file.” NNSA will consider the comments it receives to refine its SA only for the purpose of preventing (as best it can) any successful legal challenge. That is the bureaucratic purpose of the SA. It is an ass-covering document. The public comment NNSA offers is completely meaningless.

Plutonium warhead core (“pit”) production at the Savannah River Site (SRS) is by contrast receiving a detailed local EIS. Yet the environmental impacts in and near SRS will be smaller in absolute terms, affect fewer people and environmental resources, affect no tribes or tribal lands, will be less impactful than the previous mission in the former MOX facility, and will be a smaller part of the overall environmental footprint of the SRS site than the pit production mission at LANL.

According to NNSA, undertaking a 30 pit-per-year mission at LANL will require “24/7” operations at TA-55. LANL says it must hire a net 1,400 new people to staff such an effort, in a contemplated wider expansion of several thousand net new hires. LANL is being transformed into what NNSA now calls a “production agency.” Dozens of new buildings are planned. Given PF-4’s looming obsolescence, the pit mission will require new nuclear facilities, quite likely sooner rather than later. A new highway through the Caja del Rio roadless area, and high bridge over White Rock Canyon, have been proposed. Out of room on “The Hill,” NNSA is considering a new campus for LANL elsewhere. The roughly 20,000 drums of transuranic waste being stored at LANL now have no convincing pathway off the Hill, as pit production will take up most of the WIPP shipment space allocated to LANL, given legally-binding shipping agreements with other cleanup sites.

None of this merits examination in a comprehensive EIS? Please.

The 2008 SWEIS is obsolete in dozens of important ways. The “LANL” it envisioned is much different than the LANL of today – and more so, the LANL being planned. For one thing, LANL lacks the large new nuclear facility for storing, shipping, and handling plutonium that was then planned and nearing construction. That building didn’t happen. (Among the reasons for this was a thick unconsolidated stratum beneath TA-55, which cannot physically bear a large nuclear facility built to modern safety standards in the event of a large earthquake. The cure for this was to be a foundation reaching roughly 130 feet deep, the elevation of the bottom of the adjacent Twomile Canyon. Those adverse conditions obviously persist today.)

The reasonable alternatives available to NNSA today are very different than those contemplated in 2008 as well, both as to main alternative and as to options within them. Today, we have a profound climatological crisis, which affects decisions about commuting. We have massive congestion in the regional road network. Los Alamos has a housing shortage – is the County ready for the 5,000 new homes its consultants say are needed? Was that foreseen in 2008? (No.) Projected electricity demand in the County has doubled since 2008. All these questions and impacts need to be considered thoroughly and thoughtfully.

NNSA does not want to pin itself down in any formal process involving the public that would create a Record of Decision, or commit to any actions to mitigate the frankly huge impacts of building and operating a plutonium processing facility operating around the clock “24/7” in NNSA’s words, in Los Alamos.

Failure to formally reach out to the Los Alamos community, and the communities surrounding Los Alamos, is a brazen act of environmental defiance by the Trump Administration.

In this environmental crisis, where are our environmental champions, as they have tried to portray themselves — our senators, and Ben Ray Lujan?

They are nowhere to be seen. In fact, they are right there with Trump on this. Senator Udall claims to support the National Environmental Policy Act (NEPA) — just not at LANL apparently. Our delegation says it likes science, but apparently not environmental science, where LANL’s impacts are concerned. Apparently, they do not want environmental truths about LANL’s situation and proposed missions to be analyzed and published. Apparently, they do not want even the minimum quantum of democracy available under law to be used.

In their service to power, they have forgotten themselves. Their failure in this matter — their obsequiousness to LANL — is altogether outrageous.