“Scoping” Process Is Designed to Legitimate Nuclear Weapons, Mislead, and Distract
Los Alamos Study Group, Bulletin 308
(September 11, 2022) — As previewed in January (“Is DOE going to conduct a new SWEIS for LANL and if so what would it mean?,” Jan 7, 2022) and in August (“NNSA to conduct fake ‘environmental impact statement process to justify decisions, big future expansion, at Los Alamos,” Aug 18, 2022), the National Nuclear Security Administration (NNSA) has opened a “scoping” process for a Site-Wide Environmental Impact Statement (SWEIS) for Los Alamos National Laboratory (LANL).
Unless this process is fixed (see below), don’t bother taking part. It is a complete red herring. Your comments will mean nothing and accomplish nothing. If you care about nuclear weapons policy, or nuclear disarmament, or stopping the US war against Russia and the looming US war with China, or climate collapse, or any other important political objective, your time is better spent working on that.
This “scoping” process is designed to seduce you into thinking it is a legitimate process that will result in a more environmentally-friendly nuclear weapons laboratory, or a better and more complete environmental cleanup, or that the federal government is behaving in a responsible, legal manner. Above all it aims to solidify those beliefs at a group-emotional level.
It’s designed to legitimate nuclear weapons. The concept of an “environmental impact statement” for a new nuclear weapons factory, especially at this point in world history, is absurd. And as Voltaire said, “Those who can make you believe absurdities can make you commit atrocities.”
Any use of nuclear weapons would be a war crime, so these devices aren’t really “weapons” at all, as even Harry Truman belatedly figured out. They put the “terror” in “deterrence.” The terror comes from “collateral damage” — i.e. mass civilian death, which is known, accepted, and planned.
It would be far more worthwhile to solidify, deepen, and make public your antiwar and anti-nuclear weapons activism in any of a thousand ways, building solidarity there rather than in a vacuous process designed by a rogue nuclear weapons agency for its own purposes.
Don’t imagine that participation in this process will help lead towards a better environmental cleanup at LANL. It won’t. “Cleanup” is for “antinuclear” groups what “nonproliferation” is for arms control and academics — something for them to do that helps, rather than threatens, the nuclear weapons establishment by providing legitimacy and a distracting sense of agency to non-governmental actors far greater than actually exists. In both fields, various exogenous factors dominate. The views of citizens, or the contributions of academics, matter little.
The NNSA has offered two rather pathetic scoping meetings this week, in its minimalist show of compliance with the National Environmental Policy Act (NEPA). You can find out about them here.
In the face of such congealed error — moral, political, legal, economic, environmental — it is difficult for all of us to know how best to proceed. For legal reasons, and despite this being a fake process, we have made some initial comments, posted here: LASG initial scoping comments on the Site-Wide Environmental Impact Statement (SWEIS) for the Continued Operation of LANL, Sep 11, 2022. We did it so you don’t have to.
In brief, we request that NNSA:
- Halt implementation of decisions taken without adequate NEPA analysis;
- Provide documents necessary for us and others to submit informed public comment on the scope of the proposed LANL SWEIS;
- Identify the proposal and proposed action in a way that allows informed comments on impacts, alternatives, and mitigation measures;
- Extend the scoping period until NNSA clears its FOIA backlog regarding this vaguely defined pit production proposal, with adequate time to review these documents;
- Provide in-person scoping hearings in Los Alamos, Santa Fe, and Espanola with adequate time for questions, answers, and testimony; and
- Provide interactive scoping hearings that include:
- Detailed exhibits encompassing the full range of possible NNSA actions at LANL;
- Direct interaction between the interested public and responsible NNSA officials capable of answering questions about the proposed action and alternatives;
- Protocols to ensure all public comments are on the record.
See recent bulletins for details. Ways to contribute. Thank you — everyone.
Greg Mello, for the Study Group
The LANL “Campus Master Plan“
(August 28, 2022) — As a result of Freedom of Information Act (FOIA) requests, the National Nuclear Security Administration (NNSA) has provided some highlights of its grand plan for rebuilding and expanding Los Alamos National Laboratory (LANL), the so-called “Campus Master Plan” (“Plan”). We described these highlights previously here and here.
Triad LLC, NNSA’s management and operating contractor at LANL, submitted the Plan on September 29, 2021 (p. 5) and was credited with completion of the plan in NNSA’s fiscal year (FY) 2021 contract evaluation (p. 2).
In other words, this Plan is not a “draft.” There will be subsequent plans of course, but this one was took at least four years to produce and was extensively vetted within NNSA and Triad.
The Plan would add the equivalent of a whole additional national laboratory to LANL, for the new mission of “reliably” producing plutonium warhead cores (“pits”).
Implementation of the Plan would have profound impacts locally, regionally, and nationally. It would facilitate evolution of the US nuclear stockpile, albeit at a cost of more than $50 million per pit, roughly tripling the cost of warheads using LANL pits.* (*See the discussion from 2020 at slide 30, which could be updated with more current but still too low cost figures for pits from here and updated warhead costs estimated by GAO here. Further cost information will be available this fall.)
NNSA’s pit production endeavor is by far the largest project in the agency’s history, with LANL expected to require the majority of funding. (See: “Warhead plutonium modernization spending, actual & proposed by site,” May 6, 2022). Given the revelations of this Plan and other documents we have obtained via FOIA, LANL costs have increased significantly beyond those shown so far in NNSA’s budget documents.
There will be efforts to make the entire cost of expanding and rebuilding LANL on a vast scale, while adding and executing a huge new production mission — $20 billion or more over the coming decade — DISAPPEAR FROM DISCUSSION, on grounds that “it has to be done, so the cost doesn’t matter.” In other word, these costs may disappear into NNSA’s ever-rising “baseline” spending “requirement.” Unless citizens mobilize, there may be no objection in Congress or elsewhere in government.
While do not yet have the Plan itself, the highlights indicate that much more than $10 billion in additional costs, beyond those currently budgeted, will be required to sustain pit production at LANL, assuming it can be safely started at all, a major assumption. Why?
More than 4 million square feet of new construction is needed in the main LANL technical area (TA-03) and the western end of Pajarito Canyon alone, the latter being where LANL’s plutonium operations are located.
“Several thousand” additional new staff members will be needed in Pajarito Canyon beyond those working there a year ago, raising operational costs by $10 billion or more over the following decade. LANL’s main plutonium facility (“PF-4”) will need to be replaced or augmented with one or more additional high-hazard plutonium facilities.
Assuming a place could be found to put it, PF-4 replacement would cost at least $10 billion; smaller plutonium production “modules,” which do not appear feasible and entail high risks (slide 8), would also cost billions. According to the Plan and other documents, the Sigma nuclear facility in TA-03 must also be replaced, another “billion-plus” project. Numerous smaller projects necessary for pit production (but funded outside the pit production budget) are required.
Since 2018, NNSA has never presented a total startup cost, let alone a life-cycle cost, for pit production at any site. In fact, despite congressional direction NNSA does not have a resourced plan and schedule for pit production past the very first pit to be produced, i.e. past FY2023, which ends in 13 months (House Report 117-394, p. 166).
NNSA and the Department of Defense (DoD) hope that LANL’s pit production will speed up production of new-pit MIRVable warheads (W87-1s), for the new “Sentinel” ICBM system (video overview) by about a decade.
We believe it is unwise to provide a multiple independent warhead (MIRV) option for the new ICBM, or to do so ASAP, or for that matter to provide new warheads for it at all (W87-0s being adequate in all respects, if you like ICBMs or nuclear weapons generally and do not require MIRVing), or for that matter to retain so many ICBMs, or for that matter to retain ICBMs at all. There are so many other options it begins to appear that spending $20 billion or so extra is considered a benefit, not a cost.
The costs implied by this Plan are not all shown in current NNSA budgeting. For example, if NNSA expects to have any new plutonium facility operating at LANL by the early 2040s, design for that facility or facilities should be in NNSA’s 5-year budget plan, since no NNSA project costing more than $700 million has taken less than 16 years to build, and ramping up to full usage may take another 5 years (slide 9).
This early production is not necessary. There is no “pit gap.” NNSA Administrator Jill Hruby:
Let me just say another word about this. We are establishing pit production as a hedge against plutonium aging and pit aging. Our pits are not today at any kind of an aging cliff. So we can reuse pits. We just don’t like that plan because we may have to take them out before the end of the life of the weapon system.
Right now we are not at the cliff of aging program. We just would like to put new pits in because we want the weapons to stay in the stockpile for 30 years and we don’t have the 30-year confidence we’d like to have. (Emphasis added. April 27, 2022 Senate Armed Services Strategic Forces (SASC/SF Subcommittee hearing excerpted and posted here).
It’s a longer discussion than we can afford here, but for the relatively young W87-0 pits, we believe the public record shows that NNSA does have that confidence.)
The jurisdiction most impacted by LANL’s plans is Los Alamos County. As of last week, Los Alamos County Council (LACC) had never received this plan, according to LACC Chairman Randy Ryti (email of 8/24/22).
As far as we can tell, no New Mexico government, state or local — and as is likely based on our inquiries thus far, no external federal agency or congressional committee, and no tribe — has seen this Plan, let alone been apprised of its cost and impacts.
The LACC has been asking to see LANL’s evolving site plans since late 2019, when an early version of LANL’s Plan was briefed to hundreds of construction contractors and shortly thereafter to the County Council (“LANL officials detail potential building boom, Albuquerque Journal, Aug 9, 2019; “LANL Deputy Director Of Operations Discusses Infrastructure Plans And Challenges At Council Work Session,” Los Alamos Reporter, Oct 18, 2019).
Triad’s planners do understand the importance of communicating with outside parties:
Collaborative planning with external stakeholders adjacent to the LANL site is critical to ensuring regional context… Appropriate interface with external stakeholders is also important to maintaining a positive image for LANL as a transparent and proactive partner with surrounding communities…. Future outreach activities involving the general public and other external stakeholders will be coordinated through/with NNSA... (“Los Alamos National Laboratory Campus Master Plan Communication Strategy,” Nov. 2, 2020, pp. 5-6, 8).
The Plan also includes the “National Energetic and Engineering Weapons Campus” (NEEWC, pronounced “nuke”), a 17-square-mile campus for engineering and environmental testing site for nuclear weapons and high explosives (for location, see the map at slide 9).
As noted in NNSA’s announcement of its new Site-Wide Environmental Impact Statement (SWEIS) process, it is “[b]ecause of comprehensive site planning activities that are under consideration, as well as other reasons, NNSA determined that it was appropriate to revisit the 2008 SWEIS analysis.”
As of September 2, 2020 — by which date NNSA had already begun its pit production capital improvement process and knew it would need to increase its pit production workforce by up to 2,000 people and work 24/7 at PF-4, had determined just the opposite — that it was NOT necessary to revisit the 2008 SWEIS analysis.
In other words, as a result of “comprehensive site planning activities” undertaken since September 2020, i.e. this Plan, NNSA now knows its mission will outstrip previous plans. More facilities and activities, with more impacts, will be required.
It is impossible to knowledgeably comment on the proper scope of NNSA’s proposed SWEIS without knowing what NNSA’s plans are. We will seek an extension of NNSA’s deadline for scoping comments (currently October 3, 2022) until the public and affected parties have had a chance to receive and analyze these secret plans.
Further light is shed by other plutonium planning and management reports we have obtained in heavily redacted form, in partial response to our ongoing FOIA litigation. From these documents and other sources, discussion of which would make this Bulletin very long, we know that LANL has fallen behind in its pit mission and incurred large unbudgeted costs, in part due to the Covid pandemic.
The probability of meeting statutory deadlines has fallen and risks have risen. Pending that discussion and further litigation developments we will not post those other documents on-line.
By the way, NNSA’s two-site pit production plan, or any plan involving 24/7 operations at LANL, is not supported by any of its own studies, or those of its consultants. This is not an impregnable juggernaut. It will fail — that much is certain. The questions are when and how, and with what impacts and harms.
“We call for sanity, not nuclear production.” Many of you have endorsed this simple call against a nuclear arms race and in favor of new national priorities. Some you have reached out to others, in the past or recently. Thank you!
It is particularly important to stop pit production and a new arms race right now, in this crucial decade.
So far there are 80 organizations and businesses and 325 individuals signed on. Here are the supporting organizations thus far:
| Women’s International League for Peace & Freedom (WILPF) | Rivers Run Through Us |
| Nuclear Energy Information Service | Nuclear Information Resource Service |
| New Mexico Interfaith Power and Light | Western States Legal Foundation |
| Alliance for the Earth | The Nuclear Resister |
| Earth Walks | Jemez Action Group |
| Veterans for Peace, Chapter 55, Santa Fe | Unitarian Universalist Congregation of Santa Fe, Environmental Justice Team |
| Ground Zero Center for Nonviolent Action | Jemez Sustainable Solutions |
| Veterans for Peace, Chapter 178 | Veterans for Peace, Spokane Chapter 35 |
| Thubten Norbu Ling Buddhist Center | Sahaj Marg Spiritual Foundation |
| PEAC Institute | CODEPINK/Taos |
| Story Ranch | Los Alamos Study Group |
| Peaceful Skies Coalition | New Energy Economy |
| Tewa Women United | Youth United for Climate Crisis Action (YUCCA) |
| World Beyond War | Environmentalists Against War |
| El Pueblo de Abiquiu Library & Cultural Center | Veterans for Peace, Chapter 63, Albuquerque |
| Albuquerque Mennonite Church | MAS Comunidad / penasconm.org |
- Press conference Tuesday 8/30/22, New Mexico State Capitol Rotunda, Santa Fe, 10:30 am
We will be sending a press release out about this tomorrow.
Greg Mello, Los Alamos Study Group, 2901 Summit Place NE, Albuquerque, NM 87106. 505-265-1200 office; 505-577-8563 cell
Resources
- Bulletin 307: Secret master plan for nuclear weapons design, production complex entails massive investments, on top of those revealed to Congress; call for opposition; press conference Tuesday 8/30/22
- Permalinkfor this bulletin. Simple home page. Detailed home page.
* Press releases. Bulletins. Letters. Plutonium pit production. Contact us.
• Please endorse the “Call for Sanity, Not Nuclear Production.”
• Reach out to others!
