CMRR Nuclear Facility Sample Public Comment Letter
Deadline for Sumbmission by Email is Close of Business Tuesday July 5, 5 pm (MST)

July XX, 2011

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John Tegtmeier, CMRR&ndsash;NF
SEIS Document Manager
Department of Energy—Los Alamos Site Office
3747 West Jemez Road
Los Alamos, NM 87544

Re: Need for the Department of Energy (DOE) to Withdraw the draft Supplemental Environmental Impact Statement (draft SEIS) for the Proposed Nuclear Facility of the Chemistry and Metallurgy Research Replacement (CMRR) Project at the Los Alamos National Laboratory (LANL)

Dear Mr. Tegtmeier:

The draft SEIS is inadequate and technically indefensible for analysis of the risks of constructing and operating the proposed CMRR–Nuclear Facility with a capacity of quadrupling the current production of 20 plutonium triggers for nuclear weapons to up to 80 per year. I respectfully request that the DOE withdraw the draft CMRR–NF SEIS.

The National Environmental Policy Act (NEPA) requires a federal agency to provide a range of alternatives. DOE has not provided viable and workable alternatives. The “Modified CMRR–NF” alternative would allow construction with enhancements to address the growing number of seismic issues. There are two construction options: the “Deep Construction Option” and an inadequately analyzed “Shallow Construction Option,” which do not meet NEPA requirements. Assumptions were made for key parameters in the analyses of the Shallow Option. The draft SEIS fails to offer and analyze realistic alternatives and therefore must be withdrawn.

The draft SEIS misrepresents the seismic hazard at the location of the proposed CMRR–Nuclear Facility. Intensive research by Robert H. Gilkeson, Registered Geologist, discovered that the draft SEIS misrepresents the possible ground motions by a large amount, omits important seismic information about the potential of active faulting close to the proposed site, and makes assumptions because the necessary field investigations have not been done.

There are seven key parameters that must be investigated in order to characterize the seismic hazard. They are the fault locations; the fault geometry; the direction of the slip on the faults; the maximum magnitude of an earthquake; the rate at which earthquakes reoccur on the faults; kappa, which is a key parameter for ground motions at specific LANL sites; and the shear velocity of the reference rock, which is dacite. In order to obtain this information, field studies must be conducted.

LANL scientists recommended these studies in three key seismic reports written in 1995, 2007 and 2009. But the recommended studies were not done. As a result, assumed values for the seven key parameters were inserted into computer programs to estimate the seismic hazard for the design of the proposed Nuclear Facility.

Further, both surface–rupturing synchronous and simultaneous earthquakes have occurred along the Pajarito Fault System. For these types of earthquakes, multiple synchronous earthquakes produce a greater seismic hazard than the simultaneous earthquakes. But the draft SEIS states the contrary that simultaneous ground–rupturing earthquakes produce a greater seismic risk.

These errors will ultimately result in the underestimation of the seismic hazard risk and the impacts to public health and the environment from releases from the proposed Nuclear Facility. The LANL scientists recommended that comprehensive field studies must be done to gather the necessary information about the seismic hazard. The comprehensive field studies must be done before a new EIS is submitted for public review and comment.

The draft SEIS demonstrates that DOE will continue to waste water for manufacturing nuclear weapons; create more radioactive, hazardous and toxic waste; spew pollution into the air; and exceed its existing electric power needs.

Further, I am in solidarity with Santa Clara Pueblo Tribal Resolution No. 08–16 in which the Pueblo opposes the expansion of plutonium pit production at LANL and making that production capacity permanent.


[Note: This sample letter was prepared by Concerned Citizens for Nuclear Safety and is presented here by as a public service. For background on this issue please read Subhankar Banerjee’s July 1 article “Las Conchas Fire Woke Us Up—Let Us Now Stop The Plutonium Bomb Factory” here.]