[CPEO-MEF] Sign-On Comment on Livermore Lab Operations

[marylia@earthlink.net]

Dear colleagues: Note (1) that the public comment period has been extended
to Sept. 16, and (2) you may send this comment on to the DOE either by mail
or email (below). Please read it through and send it. Many thanks.
--Marylia

Environmental consequences of Livermore Lab: Add any comments you wish,
then sign and either email or snail mail to the appropriate address (listed
below) before September 16, 2002.


Mail to:
Mr. Thomas Grim
Document Manager
U.S. Dept. of Energy
1301 Clay St., 700 N
Oakland, CA 94612-5208

Email to:
tom.grim@oak.doe.gov

Dear Dept. of Energy:

I am submitting the following comments on the scope of issues that must be
considered when preparing the new Site-Wide Environmental Impact Statement
(SWEIS) on the operation of the Dept. of Energy's (DOE) Lawrence Livermore
National Laboratory.

General Comments

Livermore Lab has a shameful history of accidents, spills, fires,
explosions and leaks. Radioactive pollutants, such as plutonium and
tritium, have found their way from Livermore Lab into our air, soil and
groundwater. Likewise, chemical contaminants from the Lab's main site and
site 300 high-explosives testing range have entered our environment. Today,
Northern California communities continue to have their health and safety
jeopardized by nuclear weapons and related programs at Livermore Lab.

DOE prepared a SWEIS on Livermore Lab operations ten years ago, in 1992. It
essentially promised no future harmful impacts. Looking back, we see that
during the past ten years Livermore Lab has had uranium fires, a filter
shredding mishap that exposed workers to curium, various tritium accidents,
a hazardous waste explosion, a chlorine gas leak that forced an evacuation,
an incident where plutonium had to be cut out of a worker's hand -- and
more. The new SWEIS must include a more rigorous and honest analysis of
potential threats posed by Livermore Lab operations with hazardous and
radioactive materials.

Further, Livermore Lab's continuing mission as a nuclear weapons
development facility must be challenged. The SWEIS must consider
alternatives, including a "Green Lab" scenario in which Livermore's mission
would be devoted to pollution cleanup and civilian science initiatives.

Specific Comments

1) Do Not Build a BSL-3 Facility to Allow Anthrax and Other Bio-Hazards in
Livermore.

The DOE and Livermore Lab plan to build and operate a 1,500 square foot
Biosafety Level 3 (BSL-3) facility, which would permit anthrax, bubonic
plague, small pox, botulism and other deadly pathogens and bio-toxins on
site. Further, DOE and the Lab are "fast-tracking" this very dangerous
facility by preparing a less stringent and lower-level review, called an
"environmental assessment," for it. Instead, DOE and Livermore Lab must (a)
fully analyze all potential hazards to workers and the public from the new
facility in the SWEIS, and (b) prepare a programmatic environmental
analysis that considers the national implications of building a BSL-3
facility at Livermore as well as a proposed BSL-3 facility at Los Alamos,
New Mexico. It is a fine line that separates "defensive" and "offensive"
research with anthrax and other bio-weapon agents. How will DOE assure the
world that this research is purely "defensive" (e.g., anthrax detection) if
it will take place within the confines of a super-secret, classified
nuclear weapons lab?

2) Do Not Construct and Operate a New Plutonium Technology.

The Notice of Intent to prepare the SWEIS mentions a new "Defense Nuclear
Technology, Classified Project" to be constructed at Livermore Lab. After
prodding from the public and reporters, Livermore Lab told the San Jose
Mercury News that the project was a Plutonium-Atomic Vapor Laser Isotope
Separation (Pu-AVLIS) facility. The Pu-AVLIS process would heat plutonium
metal to a vapor form, then shoot toxic-dyed laser beams through it to
separate the various plutonium isotopes. Pu-AVLIS poses a nuclear
proliferation risk as well as a health and environmental hazard. All plans
to operate this facility should be halted.

3) Do Not Develop New and Modified Nuclear Weapons, Including So-Called
"Bunker Busters."

Livermore Lab is redesigning the B83 "lay down" bomb to give it
earth-penetrating capability. Further, the Lab is modifying the W80 nuclear
warhead that sits atop cruise missiles. At the same time, Livermore is
working to put new military capabilities into additional nuclear weapons --
and to create other, new nuclear and high-tech weapons concepts. The SWEIS
must fully analyze the consequences of nuclear bomb development activities
at Livermore Lab. These activities make the use of nuclear weapons in
combat more likely. All work aimed at perfecting these new, "modified" and
"more usable" nuclear weapons must stop.

4) Halt Construction of the National Ignition Facility.

The NIF mega-laser is billions over budget, years behind schedule and, if
built and operated, will allow weapons designers to continue their deadly
pursuits. It should be stopped. Instead, DOE and Livermore Lab are
proposing to conduct additional experiments in NIF that will increase its
harm to workers and the community. The Lab proposes to use plutonium,
highly-enriched uranium and lithium hydride in NIF. These radioactive and
toxic materials would be in addition to the radioactive tritium that, along
with deuterium, will be NIF's "fuel." The SWEIS must analyze the
environmental and nuclear proliferation risks of all proposed NIF
experiments. These must be compared to the alternative of stopping
construction and foregoing all NIF operations.

5) Address Security Issues Involving Nuclear Materials.

Many experts have told DOE, Livermore Lab and the U.S. Congress that the
nuclear materials stockpiled at Livermore are not secure from theft and/or
attack. The administrative limit for plutonium at Livermore Lab is 1,540
pounds, roughly enough for 150 bombs. Lab employees have said that
management mishandled a recent bomb threat in the plutonium facility. The
SWEIS must analyze a series of scenarios to determine the security (or lack
thereof) of nuclear materials at Livermore Lab.

Additional Comments

1.

2.

Thank you for the opportunity to comment on the SWEIS and the future
operation of Livermore Lab. Protecting public health and the environment --
and preventing the further development of nuclear weapons -- must be
paramount considerations when preparing the SWEIS.

Sincerely,

        Name:

        Address:

        City/Zip:

.----- I do want my name placed on the DOE SWEIS mailing list to receive a
notice when the draft SWEIS is completed and public hearings are held in
2003.

----- I do not want my name placed on the DOE SWEIS mailing list.

Circulated by Tri-Valley CAREs * www.trivalleycares.org

Marylia Kelley
Executive Director,
Tri-Valley CAREs
(Communities Against a Radioactive Environment)
2582 Old First Street
Livermore, CA 94551
Phone: 1-925-443-7148
Fax: 1-925-443-0177
Web site: http://www.trivalleycares.org is our new web site address. Please
visit us there.

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