NEPA and Other Formal Comments

Atomic Histories & Nuclear Testing

LANL’s Central Mission: Los Alamos Lab officials have recently claimed that LANL has moved away from primarily nuclear weapons to “national security”, but what truly remains as the Labs central mission? Here’s the answer from one of its own documents:

LANL’s “Central Mission”- Presented at: RPI Nuclear Data 2011 Symposium for Criticality Safety and Reactor Applications (PDF) 4/27/11

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NukeWatch Compilation of the DOE/NNSA FY 2020 Budget Request – VIEW

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LANL FY 2020 Budget Request – VIEW

Sandia FY 2020 Budget Request – VIEW

Livermore Lab FY 2020 Budget Chart – Courtesy TriValley CAREs – VIEW

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Scoping Comments to the National Nuclear Security Administration On the Los Alamos National Laboratory Site-Wide Environmental Impact Statement

LANL SWEIS COMMENTS
NNSA Los Alamos Field Office
3747 W. Jemez Road
Los Alamos, NM 87544
Via [email protected]

Dear National Nuclear Security Administration:

Nuclear Watch New Mexico hereby submits these scoping comments on the new Los Alamos
National Laboratory (LANL) Site-Wide Environmental Impact Statement (SWEIS).

Executive Summary

First, NNSA should complete a new nation-wide programmatic environmental impact statement on expanded plutonium pit production. A new LANL Site-Wide Environmental Impact Statement should then be “tiered” off of that document and address all of these issues outlined in these scoping comments, and in particular the site-specific impacts of expanded plutonium pit production. In the event that NNSA continues its arguably illegal behavior in not completing a new PEIS, a new draft LANL SWEIS should nevertheless analyze the issues outlined in these scoping comments, particularly expanded plutonium pit production.

A Reduced Operations Alternative is not only a reasonable alternative but is in the actual best interests of the nation. Such an alternative would best preserve stockpile reliability by foregoing production of new pits that may deviate from tested designs; conservatively maintain the existing, extensively tested nuclear weapons stockpile; augment and accentuate nonproliferation programs, especially the development of monitoring and verification technologies that could help underpin a future world free of nuclear weapons; and augment and accentuate cleanup programs that are truly comprehensive, permanently eliminating the threat to groundwater.

Read/Download full comments HERE 


Nuclear Watch New Mexico Comments on U.S. Nuclear Regulatory Commission's Interim Storage Partners/Waste Control Specialists Consolidated Interim Storage Facility Draft Environmental Impact Statement

RE: Docket ID NRC-2016-0231/Report Number NUREG-2239, the U.S. Nuclear Regulatory Commission's Interim Storage Partners/Waste Control Specialists Consolidated Interim Storage Facility Draft Environmental Impact Statement

Dear U.S. Nuclear Regulatory Commission (NRC) Commissioners and Staff,

We respectfully submit these comments in response to the Draft Environmental Impact Statement (Docket ID NRC-2016-0231) regarding Interim Storage Partner's (ISP) application for a license to build and operate a “Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas” (NUREG-2239), which plans to bring at least 40,000 metric tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country to west Texas. Please know that we do not consent to our region becoming a national radioactive high-level waste dumping ground or to transporting up to thousands of canisters of radioactive waste through thousands of communities. We should not have to risk the contamination of our land, aquifers, air, plants, wildlife, and livestock. We do not consent to endangering present and future generations.
Read/Download full comments HERE 


Nuclear Watch New Mexico Scoping Comments on the LLNL SWEIS

Re: Scoping Comments on the LLNL SWEIS

Dear NEPA Document Manager:

I appreciate this opportunity to submit comments on the scope of the National Nuclear Security Administration’s (NNSA) Site-Wide Environmental Impact Statement (SWEIS) for the continued operation of the Lawrence Livermore National Laboratory (LLNL) Main Site in Livermore, CA and Site 300 high explosives testing range near Tracy, CA.

Pursuant to the National Environmental Policy Act the purpose of scoping is: “early identification of concerns, potential impacts, relevant effects of past actions and possible alternative actions.” Therefore, I ask that the analyses I am requesting be fully undertaken – and my questions fully answered – in the draft SWEIS.

Read/Download full comments HERE 


Nuclear Watch New Mexico Scoping Comments on the Holtec Draft Environmental Impact Statement (DEIS)

RE: Docket ID NRC-2018-0052, Draft Environmental Impact Statement, Public Comment

Dear NRC Commissioners and Staff,
We respectfully submit these scoping comments on the Holtec Draft Environmental Impact Statement (DEIS) to bring at least 173,600 metric tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country to southeast New Mexico. Please know that we do not consent to becoming a national radioactive waste dumping ground or to transporting up to 10,000 canisters of highly radioactive waste through thousands of communities. We should not have to risk the contamination of our land, aquifers, air, plants, wildlife, and livestock. We do not consent to endangering present and future generations.

Read/Download full comments HERE 


Comments on a proposed Class 3 modification to the Hazardous Waste Facility Permit for the Waste Isolation Pilot Plant - Excavation of a New Shaft and Associated Connecting Drifts, June 2020

Dear Mr. Maestas:
Nuclear Watch NM (NukeWatch) appreciates the opportunity to provide comments on the proposed WIPP Class 3 permit modification - Excavation of a New Shaft and Associated Connecting Drifts. Nuclear Watch New Mexico seeks to promote safety and environmental protection at nuclear facilities; mission diversification away from nuclear weapons programs; greater accountability and cleanup in the nation-wide nuclear weapons complex; and consistent U.S. leadership toward a world free of nuclear weapons.

General Comments

We strongly oppose the “WIPP Forever” plans that a new shaft would afford. Originally billed as a replacement exhaust shaft to help WIPP recover from the 2014 exploding drum event that shut down WIPP for three years, a proposed new shaft is now designed to increase WIPP’s capacity without full public disclosure. Federal laws, agreements with the State of New Mexico, and the WIPP Permit all provide that WIPP has a limited mission for up to 175,564 cubic meters of transuranic (TRU) waste and to operate for a limited lifetime. Other repositories and improved on-site storage must be developed for other wastes and newly generated TRU waste. These operations do not need a new shaft in order to be completed.

Read/Download full comments HERE 


Comments under the National Environmental Policy Act
on the Draft Environmental Impact Statement for Plutonium Pit Production at the Savannah River Site in South Carolina

Dear SRS EIS NEPA Document Manager,

We respectfully submit these comments1 for the National Nuclear Security Administration’s (NNSA’s) DOE/EIS-0541 Draft Environmental Impact Statement for Plutonium Pit Production at the Savannah River Site in South Carolina2 (hereinafter “DEIS”). Through comprehensive research, public education, and effective citizen action, Nuclear Watch New Mexico seeks to promote safety and environmental protection at defense nuclear facilities; mission diversification away from nuclear weapons programs; greater accountability and cleanup in the nation-wide nuclear weapons complex; and consistent U.S. leadership toward a world free of nuclear weapons.

These comments incorporate by reference the comments submitted by Nuclear Watch and others regarding NNSA’s Supplement Analysis of its 2008 Complex Transformation Programmatic Environmental Impact Statement.3 We believe they are relevant to connected issues which the agency seeks to segment contrary to statutory requirements under the National Environmental Policy Act.

Read/Download full comments HERE 


Comments from NRDC, OREPA, and NWNM On Draft 2020 SA

RE: Comments on the April 2020 Draft Supplement Analysis For the Final Site- Wide Environmental Impact Statement For the Y-12 National Security Complex, Earthquake Accident Analysis, DOE/EIS-0387-SA-04

On behalf of the Natural Resources Defense Council, Oak Ridge Environmental Peace Alliance (“OREPA”) and Nuclear Watch New Mexico, we are submitting these comments on the National Nuclear Security Administration’s (“NNSA”) April 2020 Supplement Analysis for the Site-Wide Environmental Impact Statement for the Y-12 National Security Complex (“2020 SA”).
Although we are taking this opportunity to comment on the 2020 SA, we must stress at the outset that the 2020 SA is not a lawful substitute for the new or supplemental Environmental Impact Statement (“EIS”) that is plainly required under these circumstances by the National Environmental Policy Act (“NEPA”). Our clients have called for a new or supplemental EIS for at least six years, but NNSA has done everything in its power to avoid preparing one. The 2020 SA—deficient as it is, as described below—again makes clear that a new or supplemental site-wide EIS is the only lawful and logical way for NNSA to proceed.

Read/Download full comments HERE 


David Jackson — Discussion of Seismic Risks at the Y-12 National Security Complex and Formal Comments to NNSA Regarding April 2020 Draft Supplemental Analysis for the Site

Dear Mr. Hutchison
You have asked me to review the National Nuclear Security Administration’s (“NNSA”) discussion of seismic risks at the Y-12 National Security Complex, particularly in association with NNSA’s 2020 issuance of a Draft Supplement Analysis for the Site- Wide Environmental Impact Statement for the Y-12 National Security Complex (DOE/EIS- 0387-SA-02) (“2018 SA”). I have reviewed the 2018 SA, as well as related documents including NNSA’s prior Supplement Analysis from 2016, NNSA’s 2011 Site-Wide Environmental Impact Statement, the data and models represented in the 2008 and 2014 United States Geological Survey’s (“USGS”) seismic hazard maps, Judge Reeve’s Memorandum Opinion and Order, the NNSA 2020 Draft Supplement Analysis, as well as more recent seismic hazard maps and underlying data from the USGS. In my professional opinion, NNSA has conducted no rigorous seismic hazard evaluation associated with its activities at the Y-12 National Security Complex. A more thorough consideration of seismic risks is essential in light of the hazardous and nationally important work done at this Complex.
I am a geophysicist with extensive experience considering seismic issues, in particular with regard to probabilistic seismic hazard analysis, statistical data analysis, earthquake forecasting and prediction, and the consideration of likely damage from earthquakes.

Read/Download full comments HERE 


COLLECTIVE COMMENTS: on the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations

Dear LANL SWEIS SA Document Manager,

We respectfully submit these comments for the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations (DOE/EIS-0380-SA-06, March 2020). That draft Supplement Analysis has “preliminarily” concluded that NNSA will NOT prepare a new LANL site-wide environmental impact statement, which is the wrong decision.

However, even before a new site-wide environmental impact statement (EIS) for Los Alamos Lab, we believe that NNSA is legally required to first complete a new programmatic environmental impact statement (PEIS) on its nation-wide plans for expanded plutonium pit production. This is necessary to 1) raise the production cap of 20 pits per year explicitly set by the 1997 Stockpile Stewardship and Management PEIS; and 2) because NNSA now proposes a second site, the Savannah River Site (SRS) in South Carolina, for redundant pit production, which is inherently a “programmatic” decision. NNSA argues that it can rely upon an outdated 2008 Complex Transformation PEIS which considered various levels of expanded plutonium pit production at five specific NNSA candidate sites. However, that outdated document did not consider simultaneous production at two sites. This changed circumstance is justifiable cause alone for a new programmatic environmental impact statement.

Read/Download full collective comments HERE 


NukeWatch NM: comments for the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations

Dear LANL SWEIS SA Document Manager,

We respectfully submit these comments for the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations

Through comprehensive research, education, and effective citizen action, Nuclear Watch New Mexico seeks to promote safety and environmental protection at regional nuclear facilities; mission diversification away from nuclear weapons programs; greater accountability and cleanup in the nation-wide nuclear weapons complex; and consistent U.S. leadership toward a world free of nuclear weapons.

These comments also incorporate by reference the attached comments submitted by Nuclear Watch and others regarding both the Complex Transformation PEIS Supplement Analysis and the proposed environmental impact statement for the repurposing of the MOX Fuel Fabrication Facility at the Savannah River Site. We believe both are relevant and directly connected issues which NNSA seeks to segment contrary to statutory requirements under the National Environmental Policy Act.

Read/Download full comments HERE 


NukeWatch NM: Comments on NNSA’s Draft Supplement Analysis of the 2008 Complex Transformation PEIS that seeks to raise plutonium pit production from 20 pits per year to more than 80.

Dear NEPA Document Manager:

Nuclear Watch New Mexico is pleased to submit our comments on NNSA’s Draft Supplement Analysis of the 2008 Complex Transformation PEIS. Due to the highly related nature of the proposed actions for expanded plutonium pit production at the Los Alamos National Laboratory and Savannah River Site, these comments also incorporate by reference the attached comments submitted by Nuclear Watch and others regarding both this draft Supplement Analysis and the proposed environmental impact statement for the repurposing of the MOX Fuel Fabrication Facility.

Read/Download the full document HERE 


NukeWatch NM: Scoping comments for the National Nuclear Security Administration’s (NNSA’s) draft environmental impact statement for plutonium pit production at the Savannah River Site

Dear SRS EIS NEPA Document Manager,
Nuclear Watch New Mexico is pleased to submit these scoping comments on the National
Nuclear Security Administration’s (NNSA’s) draft environmental impact statement for plutonium
pit production at the Savannah River Site.

The Need for a Programmatic Environmental Impact Statement

This is our first and primary concern, that NNSA must first complete a programmatic
environmental impact statement (PEIS) on its nation-wide plans for plutonium pit production, in
advance of the Savannah River Site-specific environmental impact statement. To get right to the
point, we argue that the SRS EIS process should go no further than this scoping period and
should resume only after a completed formal Record of Decision for a new or supplemental
PEIS

Read/Download the full document HERE 


New Mexico Environment Department Response to Public Comments on the February 22, 2018 WIPP Draft Permit

On November 10, 2016, the Department of Energy (“DOE”) and Nuclear Waste Partnership (“NWP”) (together referred to as the “Permittees”) submitted a revised Class 3 Permit Modification Request to the New Mexico Environment Department (“NMED”) requesting to modify the Resource Conservation and Recovery Act (“RCRA”) Hazardous Waste Facility Permit (“Permit”) for the Waste Isolation Pilot Plant (“WIPP” or “Facility”). Specifically, the revised Class 3 Permit Modification requested to make changes to the WIPP Panel Closure Plan. NMED published a public notice on February 22, 2018, starting a 60-day public comment period which ended on April 23, 2018. NMED took final agency action on September 7, 2018. This document is the NMED response to public comments received on this draft Permit, as required by 20.4.1.901.A(9) NMAC.

Read/Download the full document HERE 


4/25/2018

NukeWatch's Comments Filed on NNSA Proposal to Raise Plutonium Limit Ten-Fold in Los Alamos' Rad Lab

See NukeWatch's critique of these plans - our official 'public comments' as submitted
Addendum to NukeWatch comments

Read/Download the full document HERE 


Nuclear Watch Comments on the Consent Order to Ryan Flynn, New Mexico Environment Department


Nuclear Watch Comments on the Consent Order to Kathryn Roberts, New Mexico Environment Department


Nuclear Watch Comments for DOE's Long-Term Management and Storage of Elemental Mercury Draft Supplemental Environmental Impact Statement (SEIS)


Nuclear Watch Comments on Draft Surplus Plutonium Disposition Supplemental Environmental Impact Statement - October 14, 2012

LANL Chemistry and Metallurgy Research Replacement Supplemental Environmental Impact Statement  -April 22, 2011

Nuclear Watch Scoping Comments for CMRR Supplemental Environmental Impact Statement (SEIS) - November 16, 2010

Nuclear Watch Additional Comments on the LANL FSWEIS  - June 11, 2008

NukeWatch Comments to NNSA on the Complex Transformation SPEIS - April 30, 2008

Nuclear Watch comments on the draft LANL Hazardous Waste Permit - February 1, 2008 [submitted to state authorities]

Nuclear Watch New Mexico's additional comments on the Kansas City Plant EA - January 31, 2008

Nuclear Watch New Mexico's comprehensive comments on the Kansas City Plant EA - January 14, 2008

Read NukeWatch's Comments on Defense Nuclear Facilities Safety Board "Government in the Sunshine Act" - January 4, 2008

Nuclear Watch New Mexico's scoping comments on the GTCC EIS - September 21, 2007

Nuclear Watch Comments on the scope of the GNEP Programmatic EIS - June 4, 2007

Nuclear Watch Comments on the Kansas City Plant EA - May 30, 2007

Nuclear Watch Comments on Livermore Biolab Draft Revised EA - May 11, 2007

Nuclear Watch Comments on the Divine Strake EA - February 7, 2007

Nuclear Watch Scoping Comments for Complex 2030 SPEIS - January 17, 2007

Nuclear Watch Comments on LANL SWEIS - September 26, 2006

Nuclear Watch Scoping Comments for EIS for Operation of a BioSafety Level-3 Facility at Los Alamos National Laboratory - January 17, 2006

Comments on the Draft Environmental Impact Statement for the Proposed Consolidation of Nuclear Operations Related to the Production of Radioisotope Power Systems - August 29, 2004

Nuclear Watch Comments on Changes to the National Environmental Policy Act (NEPA) - August 1, 2005

Comments to the Defense Nuclear Facilities Safety Board on its Recommendation 2005-1, "Nuclear Material Packaging" - April 20, 2005

Scoping Comments on the Proposed Los Alamos National Laboratory Site-Wide Environmental Impact Statement - February 28, 2005

Scoping Comments on the Draft Environmental Impact Statement for Consolidation of Radioisotope Power Systems - January 31, 2005

Comments on the Los Alamos National Laboratory Management and Operations Contract draft Request For Proposal - January 21, 2005

Nuclear Watch of New Mexico comments on the draft Order on Consent between the New Mexico Environment Department (NMED), Department of Energy (DOE) and University of California (UC) - October 2004

Comments on the Draft Environmental Impact Statement for the Proposed Consolidation of Nuclear Operations Related to the Production of Radioisotope Power Systems [224k] -August 29, 2004

Comments on the Draft Environmental Assessment for the Proposed Consolidation of Certain Dynamic Experimentation Activities at the Two-Mile Complex [34k] September 18, 2003

Scoping Comments to the Defense Threat Reduction Agency on the Programmatic Environmental Impact Statement For DTRA Activities at the White Sands Missile Range [16k] September 15, 2003

Comments on the Environmental Impact Statement For the Proposed Chemical and Metallurgical Research Building Replacement Project [47k] July 1, 2003

Scoping Comments on the Modern Pit Facility Supplemental Programmatic Environmental Impact Statement. [41k] November 26, 2002

Comments on Lawrence Livermore National Laboratory's Draft Environmental Assessment for the proposed Biological Safety Level 3 Laboratory [46k] September 7, 2002

Scoping Comments on the Environmental Impact Statement For the Proposed Chemical and Metallurgical Research Building Replacement Project [33k] August 31, 2002

Comments on the Proposed Disposition of the Omega West Facility [27k] May 25, 2002

Comments on the proposed Biological Safety Level 3 Laboratory's Draft Environmental Assessment [60k] November 26, 2001

Comments on the Draft Environmental Impact Statement (DEIS) for the Proposed Relocation of Technical Area 18 [43k] October 18, 2001


Scoping Comments to the DOE for the Environmental Assessment on LANL's Proposed Biological Safety Level 3 Laboratory July 10, 2001

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Click the image to view and download this large printable map of DOE sites, commercial reactors, nuclear waste dumps, nuclear transportation routes, surface waters near sites and transport routes, and underlying aquifers. This map was prepared by Deborah Reade for the Alliance for Nuclear Accountability.

Nuclear Watch Interactive Map – U.S. Nuclear Weapons Complex

Waste Lands: America’s Forgotten Nuclear Legacy

The Wall St. Journal has compiled a searchable database of contaminated sites across the US. (view)
Related WSJ report: https://www.wsj.com