November 6, 2006

George Allen

Complex 2030 SEIS Project Lead

Office of Transformation, U.S. Department of Energy

NA-10.1

1000 Independence Ave. SW

Washington, D.C. 20585

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Theodore A. Wyka,

Complex 2030 SEIS Document Manager

Office of Transformation, U.S. Department of Energy

NA-10.1

1000 Independence Ave. SW

Washington, D.C. 20585

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Citizen Action New Mexico’s Preliminary Scoping Comments and Request for National Public Hearings on the Supplement to the Stockpile Stewardship and Management Programmatic Environmental Impact Statement - Complex 2030 (“SEIS”).

Dear Mr. Allen and Mr. Wyka:

Citizen Action New Mexico is located in Albuquerque, New Mexico. Citizen Action is a non-governmental, non-profit organization that monitors Sandia National Laboratories for radioactive and hazardous waste dumping and other nuclear weapons related issues. Our organization is affiliated with at least 16 additional New Mexico non-governmental organizations located in the greater Albuquerque area.

Citizen Action is requesting that the DOE/NNSA hold public hearings for the scoping and the Draft SEIS at major metropolitan locations throughout the United States. An earlier 1991 scoping plan for a PEIS for Reconfiguration of the Nuclear Weapons Complex (“Complex 2010”) included 15 locations in the United States which are existing DOE sites. Currently the DOE/NNSA plans to conduct scoping meetings for the SEIS at only 12 locations. 

Limiting scoping and public hearings to sparsely populated areas surrounding DOE facilities prevents major metropolitan populations from participating in the scoping and hearing processes. In many instances from full participation in environmental concerns that are both national (and international) in scope. These concerns involve: 

• Increased transportation of radioactive and hazardous wastes through urban communities;
• Radiation exposure whether caused by accidental releases or potential terrorist attacks during transport;
• Environmental justice issues;
• Thefts of radioactive materials and use in terrorist weapons;
• Proliferation of nuclear weapons; and
• Potential increase in pollution and contamination to the air, land and environment from releases of toxic substances.

Since the resumption of nuclear weapons manufacturing, disarmament and proliferation are issues of national and international importance, additional locations within the United States should include major cities with large populations such as Seattle, WA; Portland, Oregon; Los Angeles, CA; San Diego, CA; Phoenix, AZ; New York City, NY; Boise, ID; Las Vegas NV; Atlanta, GA; Minneapolis, MN; Philadelphia, PA; Chicago, IL.  

Cities along transportation corridors for nuclear materials and waste transport should also be included as well. DOE/NNSA must also include, during the scoping hearings and public hearings for the Draft PEIS, discussion about the transportation corridors which will be related to the possible choices for construction of the Pit Facility.

The DOE/NNSA has not provided adequate time for the review of information upon which the Supplement to the Stockpile and Stewardship and Management Programmatic Environmental Impact Statement – Complex 2030 will be based. For several days the DOE/NNSA website at www.complex2030peis.com (now defunct) merely stated that the Complex 2030 PEIS is “coming soon.” None of the substantive documents upon which DOE/NNSA plan to rely have been provided at the website. The scoping hearings are not providing “an early and open process for determining the scope of issues to be addressed…” where information from DOE/NNSA is delayed in its presentation. At a minimum the website should include the links to the Records of Decision cited in the Federal Register Notice. The number of documents to be reviewed by the public for the SEIS is extraordinarily numerous and the period for review of these documents is too limited for the proposed schedule of public scoping hearings and the comment period to follow.

The environmental implications for renewed nuclear weapons production are national in scope and not simply limited to the DOE/NNSA proposed local production sites. The Complex 2030 modernization will include manufacturing infrastructure changes between at least eight various weapons facilities to begin designing and production of the Reliable Replacement Warhead (RRW) program which will result in the production of a new generation of nuclear warheads. 

The RRW program both threatens and impacts nuclear non-proliferation goals by increasing the nuclear arsenal of the United States while the existing arsenal is kept as a hedge during the development of the RRW. There is also the possibility of renewed testing for an untested system.

DOE/NNSA should issue a Notice of Intent to prepare a new PEIS and not a Supplement to a PEIS that is 10 years out of date. The Notice of Intent to Prepare a Supplement to the Stockpile and Stewardship and Management Programmatic Environmental Impact Statement – Complex 2030 ((NOI) purports to be based on the Environmental Impact Statement (SSM PEIS of November 19, 1996 and Record of Decision issued December 26, 1996). The current proposed NOI Supplement to the 1996 SSM PEIS is based on a document that is ten years out of date.

The 1996 SSM PEIS differed remarkably from what is envisioned by the current NOI. The NOI envisions changing the size, composition and character of the nuclear weapons stockpile through the design of a new generation of nuclear weapons by the RRW program.

The NOI of DOE/NNSA fails to set forth the relationship of this Supplement PEIS to other DOE/NNSA documents and programs. The NOI presents a confusing muddle of documents that were not included in the 1996 SSM PEIS because they occurred subsequent to the SSM PEIS of 1996. The SSM PEIS may not have relied upon the later dated documents. The NOI does not set forth the modifications to the SSM PEIS (1996) that were based on later documents. The NOI does not include citation to documents upon which the SSM PEIS may have been based, but upon which DOE/NNSA does not intend to use for the Supplement. DOE/NNSA should provide a complete listing and presentation of all documents upon which it intends to rely on for its Complex 2030 SEIS on its website. Also, all reference documents for the SEIS should be on that website.

Scoping alternatives must be expanded to include a true “No Production, Only Reduction” alternative. The NOI fails to provide a reasonable range of alternatives that DOE/NNSA will consider. The only alternative for consideration to the proposed action of the Supplement Complex 2030 as presented by the NOI would appear to be the “No Action Alternative.” This is because the so-called Reduced Operation Alternative is automatically rejected as not meeting production capacity for national security objectives. The No Action Alternative as stated is conflicting, vague and misleading. The Alternative represents the status quo “as it exists today and is presently planned” without setting forth the future plans for the Reliable Replacement Warhead program. DOE/NNSA is in reality planning a new generation of nuclear weapons.

The term “Reliable Replacement” suggests that the current inventory of nearly 10,000 nuclear weapons are unreliable or not secure. The current inventory of nuclear weapons has been certified as “safe, secure and reliable” annually for the last ten years by the DOE/NNSA. DOE/NNSA admits that age-induced impacts on pits have not been observed for pits up to 42 years old. The average age of pits in the current stockpile is 21 years old and lifetimes of pits can be 60-90 years old. 4,000 pits exist in “strategic reserve” in addition to a 12,000-plus “surplus” at Pantex. On the basis of the existing number of pits alone, no justification can be found for further production of pits within the weapons complex for the RRW program.

There are as yet no reliable cost estimates for the RRW program, but expectations are that it may run into the tens of billions of dollars and may take up to two decades to complete. The current NNSA outlay for nuclear related weapons spending in 2007 totals to $6,600,000,000. In addition to the future costs of maintaining the current arsenal of nuclear weapons as a “hedge,” these overall costs will grow as the RRW program develops. The RRW program will further rob US citizens of funds that could be used for education, health care and homelessness.

The Complex 2030 Transformation PEIS must include consideration of potential increases in hazardous and radioactive wastes cleanup and the need for additional national repositories beyond the Waste Isolation Pilot Plant (WIPP) located in New Mexico. The environmental considerations of the production, transport, processing, reprocessing and disposal of additional hazardous and radioactive wastes which will be generated as a result of both nuclear and non-nuclear functions in the renewed nuclear weapons production need to be considered within the PEIS. 

Neither the Department of Defense nor the Department of Energy has cleaned up the hazardous waste and radioactive contamination at many locations throughout the United States from the nuclear weapons production during the Cold War. A decision to resume nuclear warhead production would involve a huge commitment of human and environmental resources and increased contamination of the human environment. In New Mexico, for example:

Sandia National Laboratories’ (SNL) Mixed Waste Landfill (MWL) threatens the drinking water supplies for Albuquerque, New Mexico with hazardous and radioactive wastes. DOE/NNSA has failed to excavate the MWL for long-term protection of the aquifer at SNL.

An emerging environmental emergency is the recent reporting of the radionuclide contaminant Neptunium-237 (Np-237) in the drinking water wells for Los Alamos County and the City of Santa Fe at levels that are a public health concern. The contamination is in the data tables in Appendix F of the Draft LANL Site-Wide Environmental Impact Statement. According to Appendix F, additional radionuclides that were detected at lower levels in the water produced from the drinking water wells for Los Alamos County include Plutonium-239 and -240, Americium-241, and Cesium-137. All of the radionuclide contaminants are the result of nuclear weapons research at LANL.

Neither SNL nor LANL have well monitoring programs that are compliant with the Resource Conservation and Recovery Act (RCRA). The laboratories’ inability to monitor the groundwater for hazardous and radioactive waste which has been produced in the past argues strongly against the ability of the laboratories’ ability to monitor and protect from future additional contamination to groundwater.  

We look forward to your response to the above comments and requests.

 Sincerely yours,

David B. McCoy, Director

Citizen Action New Mexico

PO Box 4276

Albuquerque, NM 87196-4276

505 262-1862

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