BY JAY COGHLAN
New Mexico Nuclear Surveillance
“Scoping” means determining the issues that should be included in the public analyzes required by the National Environmental Policy Act (NEPA) of major actions proposed by the federal government. Under the Department of Energy’s own NEPA Implementing Regulations, the DOE must prepare a new or supplemental Site-Wide Environmental Impact Statement (SWEIS) for its major sites where there are significant new circumstances or information regarding environmental concerns”. The last site-wide EIS for Los Alamos National Laboratory (LANL) was completed in 2008 and is very outdated. Additionally, since 2018, the National Nuclear Security Administration (NNSA), the DOE’s semi-autonomous nuclear weapons agency, has aggressively increased production of plutonium “pit” bomb cores for nuclear weapons at the laboratory. .
On August 19, 2022, the NNSA finally announced its intention to prepare a new LANL SWEIS, but apparently the agency will not deal with expanded plutonium well production. The NNSA’s dubious argument is that it performed the legally required NEPA analysis for the expansion of plutonium well production in a 2008 complex transformation programmatic environmental impact statement, the LANL SWEIS of 2008 and a woefully inadequate “complementary analysis” in 2020 which concluded that a new SWEIS was not needed.
Issues that need to be resolved in a new LANL SWEIS include:
• First and foremost, the new SWEIS must deal with the expansion of plutonium well production at the Laboratory, when there are strong indications that this will not be the case. Projected expenditures of some $8 billion for plutonium facility upgrades, the unprecedented amount of off-site rental for office space, and the socio-economic impacts of a greatly expanded workforce all need to be analyzed. in a new SWEIS.
• Even before that, the need for a new nationwide programmatic environmental impact statement on the expansion of plutonium well production should be explored. This includes the need to expand production from the pit to begin with, which is unclear. Independent experts have concluded that the pits have a useful life of at least 100 years (their average age is now around 40 years). The United States already has at least 15,000 existing pits. Basically, no future pit production must maintain the security and reliability of the existing stockpile of nuclear weapons. Instead, it’s all for speculative future designs that can’t be tested due to the existing global moratorium on testing, possibly degrading confidence in the stock. Or, perhaps even worse, it could prompt the United States to resume testing, which would have serious consequences for international proliferation.
• LANL’s chronic history of nuclear safety incidents must be analyzed and resolved before expanding plutonium well production. These concerns are serious enough that major operations at LANL’s main plutonium facility (“PF-4”) have been halted for more than three years, yet nuclear safety incidents still occur.
• It is also unclear how production from the expanded pit can safely operate concurrently with other major plutonium programs at the aging PF-4 facility, such as the emerging issue of preprocessing some 34 metric tons of excess plutonium for eventual disposal to waste isolation. Pilot Plant (WIPP).
• In addition, the new SWEIS is to analyze the ability of the PF-4 to maintain the so-called peak production of 80 pits per year in the event that the planned concurrent production of pits at the Savannah River site is further delayed or may – even be cancelled.
• Potential doses calculated by the DOE to workers and the public from continued operations at LANL are orders of magnitude lower than those calculated by the Independent Defense Nuclear Installations Safety Board (some of which are lethal doses) . It is generally recognized that risk analysis is at the heart of NEPA. This discrepancy between the potential dose calculations of the NNSA and the Safety Board needs to be reconciled in the new SWEIS.
• LANL plans to intentionally vent up to 100,000 curies of radioactive tritium gas and possibly more over time. This deserves to be disclosed and analyzed in a new SWEIS project.
• The risk of wildfires at the Laboratory is increasing due to climate change, occurring at rates that were not credited by the DOE in the 2008 SWEIS. The effects of this accelerated change on human health and the environment require analysis in a new or complementary SWEIS. The DOE must also analyze the health and environmental risks of its demonstrated and systematic failure to implement the wildfire mitigation and protection measures that the DOE had previously relied on to support its conclusion. in the 2008 SWEIS that it could adequately manage the risk of forest fires.
• The legal framework and timeline for cleaning up hazardous and mixed waste pollution “inherited” from LANL operations has changed dramatically, with cleanup timelines for most contaminated areas ranging from no later than 2016 to no mandatory timeline, and with DOE estimates for cleanups extending beyond 2036. Yet no analysis has been done on the additional health risks and environmental consequences of ignoring these contaminants for more than 20 years. .
• In addition, the 2008 LANL SWEIS relied heavily on the 2005 Consent Order negotiated with the New Mexico Department of Environment (NMED). However, NMED has since sued the DOE to terminate the 2016 Revised Consent Order, thereby seriously jeopardizing the DOE’s reliance. Furthermore, the 2008 SWEIS did not substantially address what has since been recognized as the most serious and immediate environmental threat, namely hexavalent chromium contamination of the regional aquifer. The new SWEIS must solve all these cleaning problems.
• “Cleaning” must be defined. LANL plans to “cap and cover” some 200,000 cubic meters of radioactive and toxic waste and call it clean. The permanent threat to groundwater must be analysed. A complete cleaning, including the exhumation of the waste and an appropriate treatment, must be analyzed as a more than reasonable alternative.
• The environmental and public health hazards of per- and polyfluoroalkyl substances, or PFAS, are increasingly recognized and may be subject to future regulation. The draft SWEIS should analyze and disclose what is likely significant PFAS contamination in the laboratory.
• In the 2008 SWEIS Analysis and 2020 Analysis Supplement, the DOE specifically relied on the assertion that the Waste Isolation Pilot Plant will be available as a disposal site for all the laboratory’s radioactive transuranic waste, including the vastly increased plutonium waste streams that expanding pit production will inevitably bring. produce. This assumption is inconsistent with existing facts (for example, as reported by the National Academy of Sciences), therefore, the DOE’s reliance on it lacks a legal basis. Additionally, LANL’s poor waste management practices led to a ruptured barrel that shut down WIPP for nearly three years, costing the US taxpayer some $2 billion to reopen in a still limited fashion. The new SWEIS must address these and other issues related to radioactive and hazardous waste.
• The environmental effects of contaminated runoff from the Laboratory properties into the Rio Grande and the increasing contamination of the regional aquifer, notably by hexavalent chromium, were either insufficiently considered or completely ignored in the 2008 SWEIS. on their own, would require a new or additional SWEIS, but the need is exacerbated by the fact that the Buckman Direct Diversion Project (BDD) now diverts water from the Rio Grande to supply the City of Santa Fe and Santa Fe County. The DOE simply did not consider the implications of expanding laboratory operations on this critical water supply and how LANL could minimize the input of contaminants from the laboratory to the BDD, especially during times of low flow. or alternatively during high flow events which may carry contaminants.
• A new SWEIS must analyze the decontamination, dismantling and demolition plans for the huge chemical and metallurgical research building. What is the timetable and where will the low-level radioactive waste go?
• The SWEIS project should include a preservation analysis of the Caja del Rio immediately east and south of the Lab. This includes all possible new electrical transmission lines and the idea of a massive new bridge spanning White Rock Canyon that has been thrown around a few times.
• Environmental justice issues arising from increased pit production have not been sufficiently addressed. As the NNSA’s 2020 LANL SWEIS Supplement analysis documents, the population within the lab’s “region of influence” within a 50-mile radius is a minority at 68%. The DOE and NNSA’s plan to increase production both in total plutonium wells and in increased radioactive and hazardous waste, along with significant safety and health concerns, will place already burdened communities at risk. increased, which is in total violation of the presidential decree on environmental justice. .