Comment on the Proposed CMR Replacement Facility

Comment on the Draft Environmental Impact Statement for the Proposed Chemistry and Metallurgy Research Replacement Project at Los Alamos National Laboratory.

The National Nuclear Security Administration (NNSA), a semi-autonomous agency within the Department of Energy (DOE), recently issued a Draft Environmental Impact Statement for the proposed Chemistry and Metallurgy Research (CMR) Building Replacement Project at Los Alamos National Laboratory.

The CMR Building performs analytical chemistry and materials characterization that NNSA claims are critical to the nuclear weapons stockpile stewardship activities conducted at LANL. NNSA argues that a replacement CMR facility is necessary because the current CMR Building, which is more than 50-years old and heavily contaminated, cannot adequately accomodate the expanded operations that the CMR facility is expected fulfill according to the 1999 Sitewide Environmental Impact Statement for LANL.

In CCNS's review of the Draft Environmental Impact Statement, we found serious deficiencies in NNSA's analysis of the impacts of the CMR Building Replacement Project. We have prepared a short list of comments, to be submitted to Ms. Elizabeth Withers, Environmental Impact Statement Document Manager for NNSA, by June 30, 2003. Please take a moment to review the comments and fill in the required information fields. By clicking "Submit," you will be sending these comments in Ms. Withers. The final Environmental Impact Statement, which is expected to be released later this year.

It is vitally important that we communicate our concerns to DOE and NNSA about the inadequacies of the draft Environmental Impact Statement. The Draft Environmental Impact Statement overlooks three key issues:

waste generation and its subsequent storage or disposal;

the cost of constructing a new CMR facility and demolishing the existing CMR building; and

the broader implications of the facility as regards global nonproliferation.

For more information about the proposed CMR Building Replacement Project, please see the CMR fact sheet prepared by Nuclear Watch of New Mexico at www.nukewatch.org or the CCNS Weekly News Update for June 4, 2003. To request a copy of the Draft Environmental Impact Statement for the CMR Building Replacement Project, please contact Ms. Withers at ewithers@doeal.gov.

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Elizabeth Withers EIS Document Manager Los Alamos Site Office National Nuclear Security Administration U.S. Department of Energy 528 35th Street Los Alamos, NM 87544-2201 Dear Ms. Withers, I submit the following comments on the Draft Environmental Impact Statement (Draft EIS) for the Chemistry and Metallurgy Research Building Replacement (CMRR) Project at Los Alamos National Laboratory (LANL), released by your agency in May 2003. * NNSA claims that contaminated debris resulting from the disposition of the existing Chemistry and Metallurgy Research (CMR) Building will be stored or disposed of at either Technical Area-54 (Area G) or at an offsite commercial facility. However, the 1999 Site-wide EIS for LANL (LANL SWEIS) states that Area G likely will have reached capacity by 2009. Although NNSA does not intend to release a project-specific work plan for the disposition of the CMR for at least 15 years, a work plan should be drafted as soon as possible accounting for this discrepancy, specifying an offsite commercial waste facility, estimating the cost for disposition, estimating related air and water emissions, and occupational effects from disposition activities. This data should be included in the Final CMRR EIS. * Although NNSA claims that the design/build approach may save upwards of $450 million in construction costs, the Draft EIS includes neither a definition of the approach, nor provides actual cost estimates. This information should be included in the Final CMRR EIS. * According to the Draft EIS, waste generation doubles, triples or even quadruples for the four Action Alternatives that NNSA is considering. This increase violates the Department of Energyšs policy on pollution prevention, which requires facilities to reduce the volume of waste they create. * NNSA argues that the CMRR is necessary to accommodate expanded CMR operations, which were selected as the Preferred Alternative for CMR operations in the Record of Decision for the LANL SWEIS. However, the LANL SWEIS specifies that more training in support of nuclear nonproliferation be included in expanded operations at the CMR. Nevertheless, the Draft EIS indicates that training for nonproliferation will be eliminated from LANL operations altogether. Should the CMRR project continue, nonproliferation training must be reinstated as an operations priority. Thank you for your consideration of my comments.

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