POOKSTACKS- DOCUM£NTS Hearing Record of the Public Hearing on the Draft Environmental Impact Statement Livermore Site Livermore, California DOE/EIS-0028-D Livermore, California April 12, 1979 c «*o. *ta ^ Held by U.S. Department of Energy The person charging this material is re- sponsible for its return to the library from which it was withdrawn on or before the Latest Date stamped below. Theft, mutilation, and underlining of book] are reasons for disciplinary action and may result in dismissal from the University. To renew call Telephone Center, 333-8400 UNIVERSITY OF ILLINOIS LIBRARY AT URBANA-CHAMPAIGN UNIVERSITY OF ILLINOIS LIBRARY URBANA-CHAMPAIGN STACKS ,■■< Hearing Record of the Public Hearing on the Draft Environmental Impact Statement Livermore Site Livermore , California DOE/EIS-0028-D Livermore, California April 12, 1979 Members of the Presiding Board John B. Farmakides, Chairman Dr. Trowbridge Grose Dr. G. Victor Beard Held by: U.S. Department of Energy :■.&- Doc. Index to the Hearing Record of the Public Hearing on the Draft Environmental Impact Statement Livermore Site DOE/EIS-0028-D Livermore, California -- April 12, 1979 TAB 1. Federal Register Notices 2. Presiding Board's Statement and Exhibits and Written Statements presented at the Hearing 3. Transcript of the Hearing 4. Staff Statement in Response to Comments Received on the DEIS — March 1979 ££# Tab 1 Federal Register Notices Public Hearing -- 44FR11821, March 2, 1979 Availability of DEIS — 43FR43379, September 25, 197! ■'•■-• 11821 NOTIOES 11822 [6450-01 -M] DEPARTMENT OF ENERGY UVERMORE SITE, LIVERMORE, CALIF. Public Hearing on Draft Environmental Impact Statement (DOE/EIS-0028-D) The Department of Energy issued the draft Environmental Impact State- ment, Livermore Site (DOE/EIS-0028- D) in September 1978, for public review and comment, with a three- month comment period. The draft En- vironmental Impact Statement ^DEIS) was prepared in compliance with the National Environmental Policy Act (NEPA) to assess the environmental impact of continued operation of the Lawrence Livermore and Sandia Labo- ratories located in Alameda County near Livermore, California. The E1S assesses the potential cumulative envi- ronmental impacts associated with the current site activities, including the operation of the laboratories, and with the alternatives to current operations at that site. Notice is hereby given that DOE will conduct a public hearing in connection with the draft statement commencing at 9:00 a.m. on April 12, 1979, at the Granada High School Auditorium, 400 Wall Street, Livermore, California. The purpose of the hearing is to afford further opportunity for public comment regarding the DEIS. In order to sharpen and focus the major issues for discussion and examination at the hearing. DOE will make available a staff statement summarizing and ad- dressing the substantive areas of con- cern raised in the written comments received on the DEIS. The areas of concern include: (1) Mission and location of the laborato- ries; (2) health effects and dose calcu- lations; (3) seismology and hydrology; (4) emergency plans; (5) environmen- tal monitoring analysis and standards; (6) accident analysis and central sys- tems; (7) transport of radioactive ma- terials in the environment; and (8) transportation of radioactive materi- als. The above Issues and other issues raised at the hearing will be addressed and appropriate revisions made in the EIS, which is expected to be issued later this year in final form. The hearing will be conducted by a three-person Presiding Board selected by DOE. The Chairman of the Board and one other member of the Board will consititute a quorum. The Chair- man of the Board will be Mr. John Farmakides, an administrative law judge who is Chairman of the Con- tract Appeals Board at DOE. The other two members of the Board are Dr. L. Trowbridge Grose, Professor of Geology at the Colorado School of Mines, and Dr. G. Victor Beard, Physi- cal Chemist and Professor of Nuclear Engineering, at the University of Utah. Persons, organizations, or govern- mental agencies wishing to appear and make a presentation are encouraged to become "full participants" in the pro- ceedings by filing with Mr. W. H. Pen- nington, Deputy Director, Office of Environmental Compliance and Over- view, UJS. Department of Energy, Mail Station E-201. Washington. D.C. 20545. (301) 353-3034. not later than 5 p.m., EST. on April 5, 1979, a notice of Intent to participate. The notice shall set forth: (1) The name and address of the participant and his representative, if any; (2) the nature of the partici- pant's interest in ihe proceeding; (3) the text of any statements to be pre- sented at the hearing, or a reasonably detailed, summary thereof; (4) the names and addresses of all witnesses to be produced at the hearing by the participant and a summary of the sub- stance of the proposed testimony; and (5) the amount of lime desired to com- plete the presentation. The Presiding Board will endeavor to schedule the full amount of time requested by full participants (those who file a notice of intent to participate) subject to the imposition of such reasonaDle time limits as are consistent with orderly procedures and as will assure other full participants a meaningful oppor- tunity to present their views. Persons, organizations, or govern- mental agencies wishing to participate, but who do not file a notice by 5 p.m.. EST. on April 5. 1979, may notify Mr. Pennington before the hearing or the Presiding Board during the hearing of their desire to make a presentation. Such parties shall be admitted as "lim- ited participants" and shall be heard at such times as the Presiding Board shall permit for a period of not more than 15 minute.; each, unless the Pre- siding Board, in its discretion, allows additional time. The public hearing will be legislative rather than adjudicatory in nature. Discovery, subpoena of witnesses, cross-examination of participants, tes- timony under oath and similar formal procedures appropriate to a trial-type hearing will not be provided. Partici- pants will reference and produce, on request of the Presiding Board, the documents on which they rely. DOE will make available appropriate witnesses to explain the background. purpose and environmental impacts of the laboratories at Livermore and to respond to appropriate questions. Questions may be posed to partici- pants (including DOE staff members) during the course of the hearing by other participants (including DOE staff members) and the Presiding Board, either orally or in writing, pro- vided that: (a) All questioning shall be subject to the control and discretion of the Presiding Board, (b) questions shall be permitted from limited par- ticipants only to the extent that they are relevant to the issues identified in the staff statement, unless the Presid- ing Board determines that additional questions are necessary to develop an adequate record, and (c) any partici- pant (including DOE staff members) may elect to answer any such ques- tions either orally at the hearing or in a written submittal to be filed with the Presiding Board before the close of the hearing record, which date shall be determined by the Board. A transcript of the hearing will be made. The Record of tlie hearing shall consist of the transcript, and all docu- ments received into the record by the Presiding Board. After the close of the hearing record, the Presiding Board shall render its Report. The Report shall be based upon the Presiding Board's review of the DEIS and the hearing record and shall: (a) Identify those un- resolved issues raised at the hearing which the Presiding Board deems to be critical to future decisions concern- ing the operations and reasonable al- ternatives, and (b) present the recom- mendations of the Presiding Board concerning the treatment of these issues in the final environmental impact statement in a manner which will assure informed decisionmaking. In discharging its responsibilities, the Presiding Board shall not undertake to resolve issues or render judgment concerning the operations. The Record and the Board Report will be fully considered and taken into account in the preparation of the final environmental impact statement and in making decisions. The Record and the Board Report will be made availa- ble for public inspection at the loca- tions noted below as soon as practical after the close of the hearing. Copies of the DEIS, the formal comments re- ceived, and the staff statement are available for public inspection at the DOE public document rooms located at: Public Reading Room. FOI. Room GA-152. Porrestal Building. 1000 Independence Ave.. SW., Washington. D.C. Albuquerque Operations Office. National Atomic Museum. Kirtland Air Force Base East, Albuquerque. New Mexico. Chicago Operations Office, 9800 South Cass Avenue, Argonne. Illinois. Chicago Operations Office. 175 West Jack- son Boulevard. Chicago. Illinois. Idaho Operations Office. 550 Second Street. Idaho Falls, Idaho. Nevada Operations Office. 2753 South High- land Drive. Las Vegas. Nevada. Oak Ridge Operations Office. Federal Building. Oak Ridge. Tennessee. Richland Operations Office. Federal Build- ing. Richland, Washington. Energy Information Center. 215 Fremont Street, San Francisco. California. Savannah River Operations Office, Savan- nah River Plant. Aiken. South Carolina. In addition, the above documenta- tion will also be available for public in- spection at the Visitor's Center at the Lawrence Livermore Laboratory. Copies of the staff statement can be obtained from Mr. Pennington, the Energy Information Center in San Francisco, or the Visitor's Center at the Lawrence Livermore Laboratory. Dated at Washington. DC this 27th day of February 1979. For the United States Department of Energy. Roth C. Clusen. Assistant Secretary for Environment. IFR Doc. 79-6238 Filed 3-1-79. 8.45 am] FEDERAL REGISTER. VOL. 44, NO. <*3— FRIDAY, MARCH 1, 1979 Tab 2 Letter from Presiding Board to Mrs. Ruth Clusen (May 17, 1979) transmitting the Statement by the Presiding Board and Appendices- Exhibits and written Statements Submitted at the Hearing *£%£ w». Specific Comments 1. p. 2-18, section 2.1.6.5, last sentence: Please identify the 'accepted standard." 2. p. 3-1 to 3-2: Will the run-off from the area drained by Arroyo Las Positas and the other areas feeding the man-made lake cause any significant accumulations of radionuclides in the lake? 3. p. 3-15: At what frequency are the pre-HEPA filters (glove box filters) changed in building 251? Are they disposed of as transuranic waste (i.e., above 10 nanocuries per gram)? 4. p. 3-17: There is a conspicuous absence of a building drain retention system for building 331. This building is the major source of gaseous tritium releases and it is understood that typical tritium liquid effluents originate from equipment contamination in building 419. The FEIS should clarify the relationship between decontamination of building 331 equipment and building M19. The liquid effluents from building 419 should also be addressed. In the future it is possible that a water fire-protection system would be installed in building 331. The FEIS should discuss briefly the mitigating measures that would accompany this decision. 5. p. 3-36 to 3-37: The radiological impact section on these pages is lacking much significant information. , EPA believes that the additional information requested in the following items is necessary for a proper and thorough evaluation of the facility's radiological impacts: a. With the exception of the few maximum individual dose results reported there is no mention of what radionuclides were considered in the assessment. It is necessary to know the significant impacts from the other radionuclides, along with the definition of what is considered significant, to provide a complete picture of the impact. b. It is necessary to assess population doses as well as the individual doses discussed in "a" above. From this should come health effects estimates in the form of morbidities, mortalities, and genetic effects. c. There needs to be a presentation of the assumptions and methods used in preparing the dose assessment. The methods, i.e., models, presentation could simply be a reference to the available literature, if appropriate. Enclosure 4 d. From this presentation it appears that only direct and airborne pathways were considered. Food and water pathways rust also be considered or adequate reasons given for not considering them. The data associated with then should also be presented to the extent that a reviewer could independently evaluate them. e. There is currently proposed Federal Radiation Guidance from EPA concerning levels of transuranles in the general environment (EPAA-77-018). While this Guidance has not yet been signed by the President, DOE should consider presenting a comparison of the expected doses to individuals from alpha radiation from transuranles released from LLL/SLL with the levels provided in the Guidance, viz. , one mlllirad per year to the pulmonary lung or three mlllirad per year to the bone. 6. Section 3.9: The analysis of both historical and postulated accidents and effects was generally well done. The following items would further strengthen this portion of the EIS: (a) Provide the X/Q values for specific locations such as the nearest residence, nearest cow and pasture, and nearest school; (b) Provide estimates of individual doses, population doses, and health effects received from historical accidents, if available; (c) Provide the age groups being assessed; and, (d) Provide health effects estimates for postulated accidents. 7. p. 3-^7, Section 3.9.1: Specify the "appropriate radiation or concentration guides. Comments not related to radiation !• P. 2-59: It is noted that DOE believes that Site 300 is the only known natural location for the wildflower known as Amsinckia grandiflora. The DEIS does not cite this flower as being endangered or threatened; however, EPA expects DOE to consult with the Department of the Interior to ascertain the flower's status and what measures need to be taken to protect its critical habitat. Enclosure 4 2. p. 3-71 to p. 3-73: EPA understands the sensitivity regarding the discussion of safeguards and security systems. However, heavy reliance upon electronic detection equipment may leave such systems vulnerable in case of a power failure. The assumption is that LLL has contingency plans for this circumstance but a confirmatory mention of this fact in the FEIS would assure that this possibility has not been overlooked. 3. p. 2A-11, Geologic History section, 23rd line: The term "clay" is incorrect, it should be "alluvium" or "siltstones and sandstones." Enclosure 4 y Congress of tf)e ®mteb States teniae of &epregentatibeg Ronald V. Dellums 8th district. California district of columbia committee chairman. subcommittee on fiscal and government affairs armed services committee April 11, 1979 ANY REPLY TO THIS LETTER SHOULD BE ADDRESSED TO OFFICE CHECKED. washington office: □ 2464 Rayburn Building Washington. DC. 20515 (202) 225-2661 district offices: □ 201 13th Street, Room 105 Oakland, California 94604 (415) 763-0370 D 3557 Mt. Diablo Boulevard Lafayette. California 94549 (415) 283-8125 □ 2490 Channing Way. Room 202 Berkeley. California 94704 (415) 548-7767 Donald R. Hopkins DISTRICT ADMINISTRATOR STATEMENT FOR DEPARTMENT OF ENERGY HEARINGS, APRIL 12, 1979 RE: THE U.C.-LAWRENCE LIVERMORE SITE DRAFT ENVIRONMENTAL IMPACT STATEMENT I am deeply concerned by the Draft Environmental Impact Statement for the Livermore site, and submit this statement to share with you some of these concerns. This DEIS is deficient in a number of areas, due primarily to the very narrow boundaries within which the Statement is framed. Because of this narrow focus, there is no serious consideration of a number of problems which could affect the health and safety of Bay Area and Northern California residents and have the potential to damage or destroy our local environment and perhaps more widespread areas. The Statement fails, for instance, to address the problems of radioactive waste disposal in a comprehensive manner, only suggesting that site containment is adequate. What, however, will ultimately become of this waste? When the bulk of radioactive waste will be with us for several hundreds of thousands of years, surely it can be considered to have an environmental impact, and certainly the Department of Energy should be concerned with the proper, permanent disposal of waste from the Livermore site—should such disposal even prove feasible. In this regard, we should note the many problems with disposal outlined by the Interagency Statement for DOE Hearings, 4/12/79 Page 2 Review Group on Nuclear Waste Management and the critique of their report by a number of state agencies. The statement is also deficient in dealing with the consequences of a major release of radioactive materials and an attendant civilian emergency. The definition of D.O.E. responsibility in such a situation is defined in the narrowest of terms, leaving other governmental agencies (whether local, state, or Federal) to cope with the monumental impact of a major accident. My office learned recently, for example, that in one of the cities in the 8th Congressional District, there has been but one meeting of the Disaster Council for the last two years and that no effective plans exist for dealing with this type of nuclear disaster, despite the real risk posed by the University of California Laboratories. While we can hold local officials responsible for such negligence, certainly D.O.E. bears a prime responsibility in this matter to make certain that the public clearly understands the devastation which could ensue in the event of a major release of radioactive materials. The DEIS seems the appropriate arena to explore these consequences. More immediately, however, I am particularly concerned by the recent discoveries of additional earthquake faulting in the Livermore Valley. As you may be aware, my office has been an intervenor in the N.R.C. hearings regarding the G.E. Test Reactor Vallecitos facility in the Livermore Valley, and we have seen that there are numerous earthquake faults which only recently have been mapped or properly identified for the potential intensity of a major seismic event. There is, in my estimation, an urgent need to undertake a thorough investigation of the faults on and near the Livermore Site. I understand that the Department of Energy agrees, and I want to take this opportunity to urge that this be a major independent study Statement for DOE Hearings, 4/12/79 Page 3 of the Tesla and other faults in the area to determine the full extent of the danger they pose. If the Tesla fault is longer than currently mapped and does run beneath the laboratory facilities at Livermore, the implications are manifold for possible danger to the health and safety of Bay Area residents. In the interim, there exists considerable danger in the form of large quantities of plutonium which are stored and used at the Livermore site. Were there to be a major earthquake that caused the release of this plutonium into the atmosphere, the consequences would, indeed, be catastrophic. In addition, other evidence presented here today indicates that there may already be a grave danger to the surrounding population from an increased risk of cancer. I request, therefore, that until such time as the potential danger of these newly discovered earthquake faults and other problems can be adequately assessed, all plutonium at the Livermore Site be removed to a storage facility or to another site removed from the threat of earthquake or other potential damage. Member of Congress RVD:ak Natural Resources Detense Council, Inc. Western Office 664 HAMILTON AVENUE PALO ALTO, CALIF. 943OI 415 327-1080 917 15TH STREET, N.W. WASHINGTON, D.C. 2OOO5 202 737-5000 December 21, 1977 A'erM York Office 15 V/EST 44TH STREET NSW YORK, N.Y. IOO36 212 869-0150 Natural Resources Defense Council COMMENTS ON ERDA-154 5-D Draft Environmental Impact Statement Rocky Flats Plant Site Golden, Colorado Arthur R. Tamp 1 i n Thomas B. Cochran Introductory Remarks The DOE proposes to modify the Rocky Flats facility and to continue its operation for the production of nuclear weapons. The draft EIS assumes that this proposed action is beneficial and asserts that an analysis of the alleged benefits of the proposal is beyond the scope of the environ- mental analysis. This position is clearly erroneous, con- flicts v;ith established legal precedents, and is indefen- sible as a matter of policy. The mandate of NEPA is clear — in evaluating any proposed major federal action, the agency must thoroughly ( explore the alleged benefits of the proposed action and alternatives which will equally or better achieve the legit: 'mate benefits sought. Absent preparation of a programmatic 100% Recycled Paper -2- impact statement on the United States nuclear weapons program, DOE is obligated to explore in this EIS the clearly relevant issues related to United States national defense and the role, if any, which Rocky Fiats can play in that defense, Kle pp e v. Sierra Club , 427 U.S. 390 (1976); Natural Resourc es Defense Council v. Nuclear Regulat o ry Commission , 54 7 F.2d 633 (D.C. Cir. 1976), cert granted 45 U.S.L.W. 3554 (Feb. 22, 1977). In addition, the existence of significant and author- itative criticism of the defense policy which is used as the unexplored premise of this draft EIS must be fully dis- closed and addressed in the EIS. Committee for Nuclear Responsibility, Inc. v. Seabor g, 463 F.2d 783 (D.C. Cir. 1971); Save Our Ten Acres v. K reger , 472 F.2d 463 (5th Cir. 1973); Enviror mental Defense Fund v. Corps of E ngineers, 325 F.Supp. 728 (E.D. Ark. 1971). Finally, despite the fact that major commitments have already been made based upon the assumed validity of our present national defense policy, the present proposed action cannot be authorized without analysis of the programmatic issues involved. Scient ists' Institute for Public Information v. A . E . C . , 481 F.2d 1079 (D.C. Cir. 1973). In the past the individuals preparing the various parts of an impact statement have done so in an atmosphere of anony- mity. This, we feel, has materially contributed to the poor quality of the statements. The U.S. Code at 18 U.S.C. § 1001 states : Whoever, in any matter wi chin the jurisdic- tion of any department or agency of the United States knowingly and willfully falsifies, con- ceals or covers up by any trick, scheme, or device -3- a material fact, or makes any false, fictitious or fraudulent statements or representations, or makes or uses any false writing or document knowing the same to contain any false, ficti- tious or fraudulent statement or entry, shall be fined not more than $10,000 or imprisoned not more than five years, or both. We therefore request that this state of anonymity be ended and that those who prepare the various parts of the FEIS be fully identified. General Comments We find this DEIS is seriously inadequate in a number of respects related to safeguards and health and safety. We shall comment on these subsequently. At this point, we shall comment on a major deficiency that makes the DEIS totally inadequate. It is. a deficiency that again demonstrates the crabbed interpretation of NEPA by ERDA and it must be corrected in the FEIS or in a separate Environmental Impact Statement. This deficiency relates to the benefits of the Rocky Flats Plant and hence to the cost/benefit or risk/benefit analysis. On page 1-4 of the DEIS it is stated, "The principal benefit from the Rocky Flats Plant is its contribution to national defense." On page 1-18, it is stated, "A complete benefit-risk analysis of the national defense program is beyond the scope of this Statement." The apparent basis for these statements appears on p. iv: The United States' current defense posture dictates the need for nuclear weapons. As a result, weapon production is a mandate of the Administration, Congress, and the Department of Defense. The production of nuclear weapons, in which the Rocky Flats Plant maintains a vital role, will- probably continue for as long as the world situation suggests that this -4- ccuntry must have a strong defense. The present and future operation of the Rocky Flats Plant there- fore cannot be divorced from America's defense needs. The approach taken and arguments presented in this DEIS are 'quite similar to those taken by the AEC in the case of the Clinch River Breeder Reactor and the LMFBR Program. The courts have asserted that this approach -was wrong ( Scientists' Insti- tute for Public Information v. A. E.G. , supra ) . By accepting the doctrine that the U.S. national security' dictates the need for any and all nuclear weapons and that the Rocky Flats Plant must maintain a vital role in their production, is simply an unacceptable crabbed interpretation of NEPA — an interpreta- tion that the courts have disallowed. This crabbed interpretation, among other things: o fails to consider the opinion of opposing competent authority; '" ~" & fails to consider whether continual production of nuclear weapons at Rocky Flats or elsewhere adv ersely affects our national security; o fails to consider the alternative of operating Rocky Flats or elsewhere at a reduced through- Put ' 9 fails to consider alternative -approaches to national security, such as nuclear disarmament; o fails to consider the impacts of the iise'of nuclear weapons; e fails to consider the impact of our nuclear weapons program on the development and expansion of similar programs world-wide; o fails to consider the impact of unilateral actions 'on our part with respect to reducing the nuclear 'weapons arsenal elsewhere; fails to consider the co mman d and control problems associated with nuclear weapons — problems that could result in unauthorized detonations and even -5- 'trigger a massive nuclear war; fails to consider the problems associated with the deployment and possible use of tactical nuclear weapons; fails to consider the sociological effects asso- ciated with the "balance of terror" philosophy? fails to consider the problems associated with •safeguards, including the invasion of privacy and the erosion of civil liberties. These represent some of the issues raised by competent authorities. As representative, we offer Dr. Herbert York who was chief scientist for the Department of Defense throughout the Eisenhower Administration and into the Kennedy Administration. In his book, Race to Oblivion (Simon and Schuster, New York, 1970), Dr. York states on page 21: In January, 1961, I had the opportunity to discuss these matters with John J. McCIoy, who was President-elect Ken- nedy's personal and principal adviser on matters of arms con- trol and disarmament. I communicated to Mr. McCIoy the substance of what I stated publicly before the Senate Foreign Relations Committee in 1963: Ever since shortly after World War II, the military power of the United States has been steadily increas- ing; over the same period the national security of the United States has been rapidly and inexorably di- minishing. ... It is my view that the problem posed to botli sides by this dilemma of steadily increasing military power and steadily decreasing national se- curity has no technical solution. If we continue to look for solutions in the area of military science and technology only, the result will be a steady and in- exorable worsening of this situation. I am optimistic that there is a solution to this dilemma; I am pes- simistic only insofar as I believe there is absolutely no solution to be found within the areas of science and technology. -6- On page 23 Dr. York indicates that other DOD officials share his views and notes comments made by the present-day Secretary of DOD: By no means am I the only Department of Defense official who has come to realize the dilemma of an cver-inercasina military power accompanied by an ever-decreasing national security. Nor am I the only defense official to realize that the dilemma cannot be resolved by the development and deploy- ment of ever more complex and more costly machines. Harold Brown said after serving more than four years as DDRE and nearly four years as Secretary of the Air Force: Those who have served as civilian officials in the De- partment of Defense at the level of Presidential ap- • pointment . . . have recognized the severely limited utility of military power, and the great risks in its use, as well as the sad necessity of its possession [The] higher their position and, hence, their respon- sibility, the more they have come to the conclusion that we must seek national security through other than strictly military means .T. and urgently. On page 91 Dr. York, drawing upon his long experience at DOD, states: Thus, the real reason that this year's defense budget is so and so many billion dollars is sim- ply that last year's defense budget was so and so many billion, give or take about five percent. The same thin?, of course,' applies to last year's budget and the budget of the year before that. Thus the defense budget is not what it is for any absolute reason or because in any absolute sense the total cost of every- thing that is supposedly truly needed comes out to be precisely that amount, but rather it is the sum total of all the political inlluenccs that have been applied to it over a history of many years, and that have caused it to grow' in the way that it has grown. On page 103 Dr. York points out a serious consequence of this budget process: -7- From tlic point of view of arms control and the arms race, these excesses in dollars and people also had serious conse- quences. The extra organizations and the extra people re- sulted in a larger constituency favoring weapons development. This larger constituency in turn strengthened those forces in the Congress "which hear the farthest drum before the cry of a hungry child," and consequently the whole arms race spiraled faster than before. ■" Concerning parity in the arms race, Dr. York states on page 169: Thus a balance of terror had been created such that neither side could conceivably survive a nuclear exchange no matter who struck first, and even fairly large deviations from strict . numerical parity could not seriously upset the balance. On page 228 Dr. York states the absurdity of our actions and processes The actions and processes described in this book have led to two absurd situations. The first of these absurdities has been with us for some time, and has come to be widely recognized for what it is. It lies in the fact that ever since World War II the military power of the United States has been steadily increasing, while at the same time our national security has been rapidly and inexor- ably decreasing. The same thing is happening to the Soviet Union. The second of these absurdities is still in an early stage and, for reasons of secrecy, is not yet so widely recognized as the first. It lies in the fact that in the United. States the power to decide whether or not doomsday has arrived is in the process , of passing from statesmen and politicians to lower-level offi- cers and technicians and, eventually, to machines. Presumably, the same thing is happening in the Soviet Union. On page 233 Dr. York discusses the problems of command and control and how our actions obtain reactions: -8- Can we rely on the Soviets to invent and institute the same kind of controls? What will happen as advances in our weap- ons technology require them to put more and more emphasis on the readiness and the quick responsiveness of their weap- ons? Do they have the necessary level of sophistication to solve the contradiction inherent in the need for a "hai,r_ trigger" (so that their systems will respond in time) and a "stiff trioo Cr " (so that they won't fire accidentally)? How good are Ikeir computers at recognizing false alarms? How good is the com- mand and control system for the Polaris-type^ submarine fleet now being rapidly, if belatedly, deployed by the Soviets'' Is it fail-safe? Finally, on page 239 Dr. York discusses unilateral actions by the United States: Just as our unilateral actions were in large part responsible for the current dangerous state of affairs, we must expect that unilateral moves on our part will be necessary if we are ever to get the whole process reversed. It may be beyond our power to control or eliminate the un- derlying causes of the arms race by unilateral actions on our part. Our unilateral actions certainly have determined its rate and scale to a very large degree. Very probably our unilateral actions can determine whether we move in the direction of further escalation or in the direction of arms control and, in the long run, nuclear disarmament. Conventional good sense urges us to keep quiet, to leave these matters to the experts and the technicians. My father, troubled by my repeated trips East to testify against the ABM, asked me, "Why are you fighting City Hall?" His metaphor is sound; the defense establishment is indeed our City Hall, and it can be depended upon to care for its own interests, whether or not these arc the interests of the entire nation. If we are to avoid oblivion, if we arc to reject the ultimate. absurdity," then all of us, not just the current "in" group of experts and technicians, must involve ourselves in creating the policies and making the decisions necessary to do so. The final paragraph of the above quotation corresponds to the mandate of NEPA. The preparation of impact statements only on selected parts of the nuclear weapons program is not adequate. requires an impact statement on the overall program. Unless this is done, the FEIS on the Rocky Flats Plant will totally inadequate and unacceptable. -9- ific Comments The headings in this section will refer to the chapter ings in the DEIS. Emergency Plans This chapter is quite misleading. It discusses plans, ^logical assistance groups, medical treatment and other s without in any way defining the value of these groups ;>lans in mitigating the consequences of a major release the RFP. It is essential that the statement discuss: The response time of such groups as IRAP; 3 3 The actual function of the groups in terms of preventing or reducing exposure or contamination and the time scale involved; j The nature of the possible medical treatment and its value in reducing effects; a The number of victims that could be given treat- ment; 3 In short, it is essential to justify the asser- tion that these plans have a significant value in reducing contamination, reducing exposure and mitigating effects. Safeguards This section is totally inadequate. It does not discuss J The threat size (internal and external) against which the system is designed; a The severe limitations of material accounting which makes this an almost useless safeguard tool; i The opinions of competent authorities who state that existing safeguards are inadequate; -10- o The social costs associated with the civil liber- ties implications of safeguards; k — o The GAO reports critical of ERDA safeguards. A detailed discussion of these factors is contained in the attached testimony of Thomas' B. Cochran, "Nuclear Weapons Proliferation and Safeguards." This is intended as an integral part of our comments. 3.1.2 Radiological Impacts This chapter seriously underestimates both the dose and effects from operational and accidental releases. 1. It presents only the annual dose when the important dose is the dose commitment over life time of the radionuclides in the biosphere. 2. The dose conversion factors used for Pu-2 3 9 in bone underestimate the bone dose by at least a factor of 10. 3. A non-conservative approach is used for determining the dose to man via the soil-plant route. 4. Recent evidence indicates that the BEIR Report esti- mate of the somatic and genetic effects of radiation were too low by at least a factor of 10. Hence the risk estimates used in the DEIS underestimate by a larger factor. These factors are discussed in detail in the attached "Testimony of Natural Resources Defense Council, Re: Chapter IV." This is intended to be an integral part of our comments. UNIVERSITY OF CALIFORNIA, BERKELEY BERKELEY • DAVIS • IRVTNE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO l| SANTA BARBARA • SANTA CRPZ DEPARTMENT OF PHYSICS BERKELEY, CALIFORNIA 94720 December 15, 1978 W.H. Pennington Mail Station E-201, GTN Department of Energy- Washington, D.C. 2054-5 Dear Mr. Pennington; I am writing in regard to the recently issued Draft Environmental Impact Statement for the Livermore Site (D0E/EIS-0028-D, Livernore Site, September 1978.) Having read this document I now wish to make some critical comments, raise some questions, and call for public hearings. In addition to roy work as a physics teacher and researcher on this campus I have, for a number of years, concerned myself with the activities of the Lawrence Livermore Laboratory: its connection with my university, its use of scientific people and knowledge and, most of all, its contributions to the nuclear arms race which threatens the very survival of humanity. I had not anticipated that the process of drafting and approving an EIS for this laboratory would involve issues as broad as these; but I was mistaken. The DEIS clearly and repeatedly asserts that the main benefit coning from the operation of this Laboratory is its contribution to the National Defense through its primary mission of nuclear weapons research and development. What is totally lacking, however, is any word about the costs or advers e i mpact s that are likely to follow from this activity. Thus, in a very central manner, the present DEIS is far out of balance and cannot be considered in compliance with the requirements of the law. There is a large body of opinion and published literature, encompassing both technical and lay people, which holds that the continued development of nuclear weapons is actually increasing the likelihood of nuclear war, thus decreasing the security of the nation and threatening enormous destruction to the human and natural environment. This risk side of the risk-benefit analysis has been totally ignored in the DEIS. Here are a few of the questions which the DOE should answer in order to provide a reasonable beginning for the necessary public review and evaluation of these hazards: 1) What Is the probability of nuclear wars, of various sizes, occurring ? 2) Wliat are the likely adverse consequences of such wars, to the population generally and to the ILL area in particular ? 3) How do the above mentioned risks compare with other types of nuclear accident risks that have been much debated - from nuclear power plant accidents, from earthquakes, from sabottage and terrorism, etc. ? I request tliat, in addition to providing authoritative government assessments of the questions I have raised, the Department of Energy hold adequate public hearings on this DEIS so that full public input to and scrutiny of such evaluations can be provided. Sincerely yours, Charles Schwartz, Professor of Physics l0tK?4y T UNIVERSITY OF CALIFORNIA, BERKELEY BERKFI.EY • IMV1S IRVINE • LOS ANGELES • niVF.KSlDK • SAN DIFCO • SAN FRANCISCO DEPARTMENT OK TIIYSICS SANTA BARK AHA • SANTA CHVZ (a5)6/^-U27 (415)642-7166 - messages BERKELEY, CALIFORNIA 94720 March 30, 1979 Vf. H. Pennincton, Deputy Director Office of Environmental Compliance and Overview U. S. Department of Energy Mail Station E-201 Washington, D.C. 20545 Dear Mr. Pennington; This is in confirmation of our telephone conversation this morning regarding the public hearing on DOS's Draft Environmental Impact Statement on the Livermore Site (D0E/EIS-002C-D) . I wish to be a "full participant" in these procedings, now scheduled for April 12, 1979, in Livermore. I shall participate as an individual concerned citizen and also as a professional research scientist and teacher: I have for many years concerned myself with the activities of the Lawrence Livermore Laboratory, its connection with my university, its use of scientific people and knowledge and, most of all, its contributions to the nuclear arms race which threatens the very survival of humanity. Following is an outline of the presentation which I wish to make at this hearing: A) Argument as to why assessment of the risks of nuclear war must be included in the LIS. This was the central point in my letter of December 15, 1978, criticizing the Draft EIS. The DOS" Staff Statement in Response to Comments Received" (dated March 1979) was totally inadequate in responding to this issue. B) Search for answers to the questions posed in my December 15 letter: 1) V/hat is the probability of nuclear wars, of various sizes, occurring ? 2) What are the likely adverse consequences of such wars, to the population generally and to the I .LI, area in particular ? 3) How do the abovementioned risks compare with other types of nuclear accident risks that have been much debated - from nuclear power plant accidents, from earthquakes, from sabotage and terrorism, etc. ? C) Follow-up inquiries from A) and B) and other related matters in the DEIS. As I told you, I shall attempt to bring in some expert witnesses to assist me in presentation of these matters; and I also requested that DOS provide appropriate experts from within the government and the Laboratory to provide authoritative responses to the questions indicated. I suggested specifically a) the Director of LLL, the Associate Director for Nuclear Weapons at LLL, or some designee of theirs who is expert in nuclear plans and strategy and consequences of nuclear warfare; b) from DOE, the Director of tho Division of Military Application, General Bratton, or his designee; and c) from DoD, an official of the Military Liaison Committee, which links the two agencies. I have a substantial amount of information and analysis to present and estimated that I would need about l£ hours to make ray own presentation with an equal amount of time needed in addition for the witnesses. Sincerely yours, Cf officials be- tween the laboratories and other parts of "t!i'- defen < community" is common Three of Livcrmore's ear- liest laboratory directors went on to be chief of the Pentagon's research and development work. 8 The follow- ing story of a fourth director shows how lab management and govern- ment policymaking are intertwined. Michael May was director of the Livermore lab from 1965 to 1971. In 1970 he published an article, also in Orbis, analyzing the deterrence the- ory of our strategic nuclear weapons force, and advocating a change to a counterforce strategy — one de- signed to fight and win a nuclear war. Many of the detailed arguments given by May in this early article turned up again in 1974, when Secre- tary of Defense James Schlesinger announced the shift in U.S. strategic policy toward a counterforce doc- trine. Within the past few years May has had the opportunity to carry his ideas into practice, serving as senior personal advisor to the Secretary of Defense for salt and then as a member of the U.S. delegation at salt. He is now once again at Liver- more as associate-director-at-large. May is not the only weaponeer involved in the salt talks; a number of people from the labs are involved as technical experts advising the ne- gotiators. But the problem is that people who have both political and bureaucratic interests in pushing weapons are not the ones who should be influential in negotiations that are intended to put them even- tually out of business. The former chairman of the General Advisory Committee to the U.S. Arms Control and Disarmament Agency — the group that helps to shape the Presi- dent's approach to salt — is none other than the director of the Los Alamos lab, Harold Agnew. Now we turn to the claim thatthc weapons programs of the laborato- * ries, regardless of how they may be initiated, must be approved by the Congress and the President. Of course there is a formal budget ap- proval process. The question is, how thorough is the review and evalua tion by people outside of the weap- ons complex? When the neutron bomb story hit the headlines, we were told that nei- ther the President and his staff nor most members of Congress were even aware of the existence of this item in the budget. But that is just one weapon. What about the many others? An article published in Science in June 1977 tells about a procedure established two years ago in which various parts of the Executive branch — dod, erda, acda and the National Security Council — were supposed to review every new weapons proposal and draw up a detailed "arms control impact state- ment" providing critical information about the impact the proposed weapon might have on the stability of the arms race. 9 The actual reports turned out to be so superficial that angry legislators called them "totally useless," a "farce," and a "mock- ery." The following remarks, made by Senator Stuart Symington at the opening of some subcommittee hearings in 1973, convincingly tear down the myth that the Congress has been abie to exercise effective re- view of nuclear weapons programs. Senator Symington was, by the way. not a softy on military matters; he served as Secretary of the Air Force under President Truman. This is the beginning of what we hope will be an informative and constructive series of hearings on the military applications of nuclear technology. Some have heard me state previously, not until I became a member of the Joint Committee and traveled to Europe with Sena- tor Pastore in the spring of 1971, did I realize the true military strength of the United States and became acquainted with the vast lethal power of our nuclear arsenal .... I actually learned more about the true strength of the U.S. forces in Europe in those six days than I had in some 18 years on the Armed Services Committee .... One cannot help ?? The university provides an aura of academic legitimacy to the business of weapons development. but consider the implications inci- dent to our defense and foreign policies if these facts were known by the appropriate committees of the Congress, as well as in more general fashion by the American people. 10 Another quotation deals specifi- cally with the role of the nuclear weapons laboratories. It was found in the 1974 report of the Scientific Advisory Committee set up by U& President Charles Hitch to review the work of the labs. In discussing the Primary Laboratory Mission, this report states: 'The established policy of the U.S. government is unequivocal concerning the necessi- ty for continued nuclear weapons research and development." And it cites, as an official statement of this government policy, the following sentence from a Congressional re- port: The committee fully recognizes and supports the invaluable role of AEC's weapons laboratories, test- ing installations and production fa- cilities in the development of a credible nuclear deterrent for the United States." I thought I should check into this reference and see what was the con- text from which this sentence of Congressional approval was gleaned. Was it indeed an "unequiv- ocal" policy statement based on a thorough evaluation of the weapons complex; or was it something else? What I found was this: a recommen- dation from the Appropriations Committee that the Weapons Test- ing Program budget be slightly re- duced and one project — for Artillery Fired Atomic Projectiles — be can- celled. The laudatory sentence cited above was tacked on as nothing more than a consolation prize, a pat on the head; indeed it seems almost like an apology from the Congress for not giving the weaponeers 100 peicent of what they wanted. Putting these several pieces to- gether, the overall picture of the U.C. nuclear weapons laboratories that emerges is as follows: • .Whatever outside control there is over the labs is by military, not civilian officials; • There is a substantial 'inter- change of upper level personnel be- tween the laboratories and the mili- tary establishment; • Laboratory managers take an aggressive political role in promoting not only particular weapons systems but also basic changes in military strategy and national policy con- nected thereto; they even play a direct and commanding role in inter- national negotiations on arms con- trol; • The degree of oversight exer- cised by our national leaders over the weapons program seems to be, at best, superficial; and • The amount of information pro- vided the general public is kept to an absolute minimum. It thus seems correct to conclude that our nation's nuclear policy has become the pri- vate property of the weapons tech- nocrats. We all know of President Eisenhower's warning, in his fare- well address, about the power of the military-industrial complex. Less well known is a second warning which Eisenhower made in that same speech: Yet in holding scientific research and discovery in respect, as we should, we must also be alert to the equal and opposite danger that public policy could itself become the captive of a scientific- technological elite. That prophetic vision of yesteryear has become the entrenched reality of today. The weapons labs roll on as quite autonomous institutions, free of the impediments of democratic government. We, the people, not only pay for this enterprise with our taxes but we also suffer the growing threats to our very survival posed by the uncontrolled momentum of the nuclear arms race. Under the patronage of the U.C. Board of Regents, with the coopera- tion of the U.C. president's office, and with the consent of the faculty, the University of California has been the nominal administrator of the two nuclear weapons labs under contract from aec/erda/doc. The major features of this relationship have been described by various peo- ple. Edward Hammel, an assistant director at Los Alamos, has made the following pointed remarks: 12 With respect to U&- "manage- ment" of lasl operations, U.C. plays the role of a "benevolent ab- sentee landlord." The "business" of lasl is for the most part with Washington. U.C. understands that and interferes in program not at all. The major benefits to the labs from the university connection are, according to Hammel, "prestige," in that the U.C. name helps "in the recruitment and retention of scien- tific personnel"; and "indepen- dence," in that the laboratory staff "enjoys a much greater degree of freedom in its interactions with gov- ernment officials than would be the case" were they under some govern- ment or industrial management. That this "freedom" which the University of California grants to the lab managers may not be such a good thing was one of the sharpest criticisms made in the faculty's Zin- ner Committee report: "We are par- ticularly disturbed by the nominal leadership which the University pro- vides. The laboratories enjoy a de- lightful autonomy within the protec- tive shelter of the University, so delightful as to border on the licen- tious." That committee recommend- ed, and the faculty approved by overwhelming vote, a continuation of the university's relationship with the labs only with modifications de- signed to have the University exer- cise some responsible guidance over the operation of the laboratories. That noble intention has been a total failure. In the opinion of some people, including a number of scien- tists working at Livermore, the last September 1978 The Bulletin 23 The laboratories are something like Frankenstein's monster; it is no good trying to wash our hands and walk away. five years has seen an increase in the isolation of the laboratories from meaningful contact with the univer- sity community, and an increase in the autocratic character and behav- ior of the labs' top management. For example, one of the major recom- mendations of the Zinner Committee was that the laboratories prepare annual plans for their unclassified activities and have these plans re- viewed by campus authorities. When asked by the LLC. president's office, in 1976, what steps he had taken to implement this recommendation, lasl director Harold Agnew replied: These plans are reviewed and ap- proved by the appropriate erda Headquarters Program Managers, and form the basis for funding of the Laboratory. While we will be happy to provide you with copies of these plans, it is not likely that it will be acceptable to erda to make any changes of substance. 13 Thus the university provides an aura of academic legitimacy to the busi- ness of weapons development and provides the laboratory management with a two-sided carte blanche: they are free of any supervision from within the university and yet the university name gives them indepen- dence from any other source of con- trol. What the university has given to the weaponeers is more than free- dom, it is license: license to promote their own bureaucratic and political interests with an absolute minimum of accountability to the democracy that they claim their work is intend- ed to protect. I conclude that the University of California has thus done a very grave disservice to the people of this nation, and of the world, by its involvement in the nu- clear weapons business. The greater sins are probably not what the university has done in this connection, but what it has no/ done. ft has not taken a responsible part in the management of the labs. It has not worked i(» decrease secrecy and disseminate know, ledge about the weapons program. It has not fos- tered research that might be critical of the military establishment nor has it encouraged education about the vital issues of the arms race. And when some concerned individ- uals — faculty, students, people from the community — take the initiative and try to generate public education and serious study and debate about these issues, the University of Cali- fornia goes to painful iengths trying to maintain the curtains of daikness. Last November U.C. President Saxon ordered the arrest of six per- sons who had been quietly sitting in his outer office for 30 hours asking him to provide some official who would meet with them in a public debate about the nuclear weapons labs. 14 With continued public attention being given to the weapons labs, it is likely that much of the university's hierarchy is finding the subject a bit too embarrassing and would like to pull out of the weapons business. But for the university to pack up and get out, in the name of academic purity, would indeed be irresponsi- ble at this point. A great deal of harm has already been done. The labora- tories are, in more than one sense, something like Frankenstein's mon- ster; it is no good trying to wash our hands and walk away. Of course the university cannot solve this problem by itself. The military interests are deeply en- trenched and a major political fight in Washington will be needed to bring about any substantial change. There is a significant role that the university could play in this struggle, using its educational resources and its prestige. But we know better than to rely on the university officials for leadership: they have disappointed us too many times before. We need to mount a political cam- paign on our own. We need to arouse our fellow citizens to the dangers of the arms race and its promoters. We need to build a constituency of peo- ple who under land that democracy dies when decisions are handed over to technical experts, or hidden be- hind a veil of secrecy, or sold upon hysterical exaggerations of some ex- ternal threat. We need to work to bring the weaponeers under strict democratic control here at home be- fore we can expect to make any serious progress in reducing the threat of nuclear arms by agree- ments between nations. Notes 1. This committee was chaired by Paul Zinner, a professor of political science at the university. Professor George Wetherill, a mi- nority of one, argued that the university should not be in the nuclear weapons busi- ness. In a subsequent ballot of the entire faculty, 43 percent voted to sever the U.C. -lab ties. 2. The U.C. Nuclear WeaponN Labs Con- version Project (ucnwlcp), 608 Eshleman Hall, V.C., Berkeley, Ca. 94720. The author has been an active member of this group since its inception. 3. See R. G. Hewlett and O. E. Anderson, A History of the usa EC, Vol. I. The New World. 1939/1946 (University Park. Pa.: The Pennsylvania State Universitv Piess, 1962), p. 515. 4. See Science, May 13, 1977, p. 743. 5. Livermoie Valley Times, Aug. 10. 1977; Livermore Independent, Dec. I, 1976. 6. Major General Edward B. Giller (Genera! Starbird's predecessor in erda), quoted in Science. April 4. 1975, p. 30. 7. "Military Applications of Nuclear Tech- nology," Hearings, Subcommittee on Military Applications of the Joint Committee on At- omic Energy, April 16, 1973, Pari I, p. 49. See also J. K. Miettinen, "Enhanced Radiation Warfare," Bulletin, Sept. 1977. 8. They arc Herbert F. York, Haioid Brown (now Secretary of Delense) and John S. Fos- ter, Jr. 9. Science, June 10, 1977, p. 1181. 10. See n. 7, p. 1. 11. "Appropriation Bill for Public Works, Water and Power and Atomic Energy for the Fiscal Year 1974," HR 93-327, House of Rep- resentatives Committee on Appropriations, June 25, 1973. p. 6. 12. I.ASL office memo, July 18. 1977, with attachments. 13. Attachment C, Items for Discussion, Regents Meeting. Feb. 17, 1977; attachment 3-2. 14. The author and five othei members of the UCNWLCP, charged with the misdemeanor of trespassing, were acquitted after an 8-day trial in the local court. One juror, quoted in the press after the verdict was announced, said, "They had flic v long people on trial." 24 1 kifcf- O^T 1 s£7 ■rscssi Helping the Pentagon Aim Right A report on the Scientific Target Planning Staff CHARLES SCHWARTZ While the overall questions about nuclear war — the size, capability, threat and doctrine of the U.S. and the USSR nuclear arsenals — have been sub- jects of continual public discussion, the details of military plans associated with the possible use of these weapons have been, understandably, closely guarded secrets. Within recent months, however, the U.S. Secretary of Defense, James Schlesinger, has broached a public discussion of significant shift? in Charles Schwartz is professor of physics at the University of California, Berkeley. policy: more U.S. naclear missiles would be targeted on Soviet military and industrial targets rather than on cities, and efforts would be made to increase the accuracy and explosive power of the warheads. Debaters aroused over this issue may, for conve- nience, be classified as doves or hawks, with the fol- lowing definitions: the primary objective of doves is to assure that war will not occur; the primary objective of hawks is to assure that if war should occur, the United States will win it. In discussions of nuclear warfare policy doves and hawks are associated with countervalue and coun- terforce strategies, respectively. Doves argue that countervalue strategy (targeting our missiles November 1974 Bulletin of the Atomic Scientists 9 against cities as a threat of retaliation) is that which deters the other side from starting a nuclear war. Hawks argue that counterforce strategy (targeting our missiles against military and industrial installa- tions) is needed to minimize our own losses in the event that nuclear war should hreak out. Doves op- pose a counterforce strategy on the grounds that aiming our missiles at military sites, particularly with increased accuracy and payload, makes it look like we are striving for a first-strike capability, and that this can seriously destabilize the present bal- ance of deterrence. Hawks oppose a countervalue strategy on the grounds that the doctrine of retalia- tion against civilian populations is immoral and may not be a convincing deterrent against small scale nu- clear attacks. These two points of view have been in contention for as long as there have been nuclear missiles. The hawks have been dominant inside the Pentagon and inside Ihe circles of private industry which are close- ly allied with weapons development and manufac- ture; the doves have been dominant in the academic community. The Anns Control and Disarmament Agency has been perhaps the most responsive arm of the federal executive as far as the doves are con- cerned, but aci>a's power is hardly a match for that of the Department of 13efen.se. Members of Con- gress may be found aplenty on both sides of this debaie. One might ask the question, Why has Defense Secretary Schlesinger now launched this campaign for a switch toward the more hawkish nuclear mis- sile policy? It seems, however, that part of the shift in policy — the targeting on military sites in the USSR — has already taken place; the other part — increased accuracy and payload — is still being de- bated in Congress. This article will attempt to pro- vide some answer to the tjucstion stated above, going beyond the theory of the bargaining chip approach to SALT. Target Planning A new slice of information relating to nuclear tar- get ing policy has recently come into the public do- main. At the end of 1972 Congress passed the Federal Advisory Committees Act (PL 92-463) which requires annual publication of information about all the many advisory committees that are ap- pended to the federal executive branch. The "First Annual Report of the President to the Congress" on "Federal Advisory Committees" — a four volume, 5,703 page compilation — was issued eaily in 1973 by the Committee on Government Operations of the U.S. S'-n.-ite. On pages 1,315 to 1,318 of this docu- ', we found the report of the Scientific Target Planning Staff (.jsti's sac) for calendar year 1972. We learned there that this advisory committee was originally established on May 1, 1968 by the Joint Chiefs of Staff (JCS), with the approval of the As- sistant Secretary of Defense for Administration, and has the following stated function: "To provide time- ly technical and scientific advice of qualified scien- tists to the Director of Strategic Target Planning during the development of the Single Integrated Operational Plan." The committee met twice during 1972 (for three days in March and three days in Sep- tember) and minutes of these meetings were sub- mitted to JCS as "Top Secret Restricted Data." The committee membership is also listed. That is not a great deal of information but it is certainly enough to arouse one's curiosity. The name "Single Integrated Operational Plan" (siop) was previously unknown to this author; but it ap- peared shortly in two other public reports. In an ar- ticle, "The President and the Plumbers: A Look at 2 Security Questions," in the New York Timer, on Dec. 9, 1973, Seymour M. Hersh wrote, . . . the White House feared that Dr. Ellsberg . . . was capable of turning over details of the most closely held nuclear targeting secrets of the Uniled States, which were contained in a highly classified document known as the Single Integrated Operations Plans, or SIOP. . . . The SIOP was a joint services nuclear targeting document that had been drafted — under the aegis of the Air Forces Strategic Air Command — in the late 1950s. The plan combined all the nuclear targeting options of the individual military services into a com puterized program with centralized control. In essence, qualified sources said, the SIOP project controls the timing and attack patterns of American nuclear bombs that would be released from Army, Navy and Air Force strategic aircraft, missiles and sub- marines. It also includes specific targeting informa- tion for every significant military objective inside the Soviet Union and China, including the number and power of nuclear warboads programmed for each ob- jective. In the early days of the Kennedy Administration, the SIOP was drastically revised and provided with a limited series of nuclear options, the sources recalled, giving the President at least the flexibility to attack eitber the Soviet Union or China, and not necessarily both, as an earlier SIOP called for. Dr. Ellsberg, the source said, was active in working , on the revised nuclear targeting plans under then Sec- retary of Defense Robert S. McNamara. Well-in- formed sources said that although the plan had been updated and altered. Dr. FUsberg's information could have been extieinely compromising to national Security. The other report mentioning SIOP is entitled "U.S. Security Issues in Europe: Burden Sharing and Offset, MBFB [mutual and balanced force reduc- tion] and Nuclear Weapons," a staff report pre- pared for the Subcommittee on U.S. Security A new slice of information relating to nuclear targeting policy has recently coma into the public domain as a result of the 197? Act which requires annual publication of information about all advisory committees. 10 No member of the Scientific Advisory Group comes from a university or is someone who is identified with the arms control community. Every member is associated with in- stitutions known for their 'pro-armaments' views. Agreements and Commitments Abroad of the Com- mittee on Foreign Relations, U.S. Senate, dated De- cember 2, 1973. This study deals mainly with the role of tactical nuclear weapons which the U.S. has deployed in Europe; and it discusses how those local issues are tied to larger plans for strategic nuclear war between the United States and the Soviet Union. That part of the report relating to siop (p. 21) reads as follows: The second major category of nuclear warfare for which the GSP (General Strike Plan) provides is gen- eral nuclear response which contemplates massive nu- clear strikes against targets [deleted] in order to [de- leted]. The general nuclear response would not be undertaken by theatre nuclear strike forces alone but only in conjunction with the execution of the Single Integrated Operations Plan (SIOP), the US. Joint Chiefs of Staff plan for the widespread synchronized use of U.S. nuclear weapons in an all-out war. Ac- cordingly, responsibility for carrying out NATO's general nuclear response falls on U.S. strategic forces based outside Europe. Targets to be struck in the general nuclear response are part of what is known as the "Scheduled Program" and include the Priority Strike Program (PSP) and the Tactical Strike Program (TSP). The PSP is com- prised of those strikes of highest priority to SACEUR [Supreme Allied Command Europe]. They include [deleted]. Another group of targets covered by the PSP are those included in the Allied Commander Europe's Critical Installation List. There are approxi- mately [deleted] targets on the list of which theatre nuclear forc-es would strike about [deleted] under the PSP [deleted]. The TSP is a list of about [deleted] nuclear strikes against [deleted]. These are [deleted]. All PSP and TSP strikes have been coordinated, or "deconflictod," with the U.S. SIOP target list main- tained by the Joint Strategic Targeting Center at Omaha. We were told by Defense Department officials that a general nuclear response might be required under two contingencies. The first would be [deleted]. The second would be [deleted]. One can only imagine what the deleted portions tell about targeting plans. However, it is already ap- parent from the two descriptions given above that siop is considerably more than just the retaliatory plan for a purely countcrvalue deterrent strategy: the references to military objectives and priority lists of targets clearly relate to a counterforce strat- egy. Scientific Advisory Group The new information which we have to present concerns the Scientific Advisory Group which bas been working on siop. The report on jstps sac, which we cited earlier, gives the names and ad- dresses of the 13 members of this advisory commit- tee. We have gathered whatever information we could find from open sources in an attempt to form a picture of the political-philosophical complexion of this group. The results are presented below. In summary, committee membership divides into three nearly equal categories : members are from ( 1 ) inside the government, (2) private industry, or (3) defense-contracted think tanks and weapons labora- tories. The government people are all employed di- rectly by the Department of Defense; two are in the military and three in civilian positions. The four industry representatives are all from very large firms in aerospace and electronics that are doing major amounts of business with the Department of Defense; two of them have previously held adminis- trative posts in the government. The last four mem- bers are from organizations which, while they are not major partners in the military-industrial axis, have long been intimately tied to the Pentagon. No member of this committee comes from a uni- versity or is someone who is identified with the arms control community. Every member is associated with institutions known for their "pro-armaments" views. We conclude that this advisory committee working on siop is overwhelmingly, if not totally, populated by hawks and super-hawks. The purpose of advisory committees, according to the Federal Advisory Committees Act, is to furnish "expert advice, ideas, and diverse opinions" to gov- ernment agencies. The committees are to make use of advisors from outside the government and, ac- cording to the Act, membership should be "fairly balanced in terms of the points of view represented and the functions to be performed." The executive order written to implement this Act says, further, "the membership of a committee whose sole func- tion is to consider scientific questions may be limit- ed to scientists. However, an effort should be made to include scientists representing different points of view and different types of employment (university, industry, etc.)." Thus, one could claim that this particular committee was illegally constituted. The principal aim of tins paper is to try to under- stand the new shift toward the counterforce nuclear strategy. If our attempt to sort out the mechanisms and the motives for this important change in nuclear policy rests in part on speculation, that is because the government and, in particular, the Department of Defense so habitually conceals the truth from the citizenry.* It is clear that siop is the pivotal blueprint for total nuclear war, certainly the most awesome docu- *A request for information about the Scientific Advisory Group was sent to the agency representative in charge cf this committee, whoso name and address were given in the published report cited above. No response was received. November 1974 Bulletin of the Atomic Scientists 11 1972 Members of the Scientific Advisory Group to the Joint Strategic Target Planning Staff Lt. Gen. Glenn A. Kent, USAF. Director, Weapons Sys- tems Evaluation Group, Arlington, Va. (formerly Assistant Chief of Staff. Plans and Analysis, Air Staff). Vice Adm. Robert L. J. Long, USN. Commander, Subma- rine Forces, U.S. Atlantic Fleet, Norfolk, Va. (formerly ex- ecutive assistant to Under Secretary of the Navy; deputy commander, Naval Ship Systems Command). Peter H. Haas. Scientific Assistant to the Deputy Director (Science & Technology) of the Defense Nuclear Agency, Washington, D.C. (formerly with the Defense Atomic Sup- port Agency and with the Army's H. Diamond Labs). Charles M. Johnson. Deputy System Manager for Science & Technology, Safeguard System Office, Arlington, Va. (He has held this position in the Army's ABM project since 1967.) Nils F. Wikner. Special Assistant, Net Technical Assess- ment, Defense Research & Engineering, Washington, D.C. (formerly Deputy Director, Defense Atomic Support Agen- cy; Special Assistant, for Threat Assessment, under Director of Defense Research & Engineering). James R. Burnett. Vice Presisent, TRW Systems, Redondo Beach, Cal. (TRW sales in 1972 amounted to $1.68 billion, mostly in aerospace and electronics manufacturing; 22 per- cent from U.S. government.) Welko E. Gasich. Corporate Vice President and General Manager Aircraft Division, Northiop Corporation, Haw- thorne, Ca. (Northrop sales in 1972 amounted to $574 mil- lion, with the aircraft division accounting for 45 percent of this; 56 percent of the company's business is with the U.S. military.) Fred A. Payne, Jr. (SAG Chairman) Vice President, Tech- nical Operations, Martin Marietta Corporation, Orlando, Fla. (Martin Marietta sales in 1972 amounted to $1.04 bil- lion; 52 percent of this was in aerospace manufacturing, the bulk of which is under U.S. government contracts. For- This ;-, ?ics cen- merly, Payne served as Deputy Director, for Strategic & Defense Systems, under the Director of Defense Research & Engineering.) Joseph F. Shea. Senior Vice President and General Manag- er, Equipment Division, Raytheon Co, Whalen, Mass. (Raytheon sales in 1972 amounted to $1.46 billion, manu- facturing in electronics and communications; 48 percent of sales to U.S. government. Formerly, Shea worked for TRW and for NASA.) Arthur T. Biehl. Vice President, Research & Development Associates, Inc., Santa Monica, Ca. (Formerly an Associate Director at the Lawrence Liveimore Laboratory (" LL); Biehl left this major weapons laboratory to K-iu fo.md the private Defense think tank, R&D Assori.-.U**, new organization was formed chiefly by th" ! department of the Rand Corp.. a group with nections within Department of Defense.) Charles A. McDonald. Associate Director •- plications, Lawreiic: ! ivermorc I/ihoraSr , ! (LLL, along with Mn> ].,.:< A) vri ...••. Sci-.-a! , ; the chief U.S. center io\ rvockvc vvcj: ■ velopmenl. Although nomiraliy ■•<:.'- University of Califon-;:-; un«:€i fund' ; .. laboratories conduct ihcit ^vapons i.r ■ of university invo'v^jiu.ir.. McDonald ??;'l I i join R&D Assoc--: icn ( •-.- ahn% ).' ' Dominic A. Paoli":ii >'.'.i ! at, Luleii -u Arlington, Va. (L«3 j " r Asi-vi^.N ■ vate defense consul ■■:■;■ firm, ■ mi • ■:. . ,!• . ganization has been '•• uuJ fto.' i ou; }.'■•■. our mail inquiry to i : r > L'aoi ii« o is captain, retired }:•■■.. '.-ic-nt?nc Advisory Group would be expected to tjiU*r in an important way. Is this committee's work only uechnical, or might it be expected to have an in- 1 .'i.ee on policy? The advisory committee is not ex- pected to do the detailed work of writing the computer program for siop; its job is to oversee, to provide advice and guidance. While all the members of; this advisory committee have technical training in their backgrounds, it is clear that at present most of thfewi hold top level executive positions in their re- spective organizations and are accustomed to shap- ing policies as well as administering them. The history of nuclear weapons development — from its very beginning — has been full of occasions where scientific advisors have had a crucial influence on the formation of military policy. The evidence we have collected showing the very hawkish composure of this committee, together with the retargeting op- portunity posed by the mikv system, leads us to be- lieve that the work of the Scientific Advisory Group for the Joint Strategic Target Planning Staff was the nexus of the decision to embark on the new counterforce strategy. Earlier, we posed the question of why Schlesinger decided to push a public campaign to move U.S. nu- clear forces more toward the counterforce program. He is not reported to be a particularly hawkish per- son, nor is it convincing that he has taken up this campaign simply as a way to promote the bureau- cratic interests of his department: the budgetary ef- fects of this policy change do not appear to be very significant. On the basis of the analysis up to this point, we are now led to make a guess: that the change of siop toward a stronger counterforce strat- egy was carried out under the self-generated author- ity of the Joint Chiefs of Staff and then presented to Schlesinger as a fait accompli. Such an idea is probably unwelcome to the think- ing of most Americans, used to the principle that our military establishment is subject to civilian rule. However, one should not overlook the paralysis and instability that infected the Presidency during Watergate. There were three different Secretaries of Defense in the first half of 1973, and the opportunity for military leaders to act on their own was there. We will not suggest that the hawkish scientific ad- visory group on siop was the sole author of a secret shift in basic nuclear policy; surely a number of of- ficers within the Department of Defense had to par- ticipate. We will propose that this scientific advisory group constituted the outside collaborators in a subtle but significant military coup. Some readers may feel that this author is being unduly imaginative and alarmist in the conclusions of the last few paragraphs. It is legitimate to consid- er how different sets of readers, seeing the facts col- lected here and having their own inclinations, may be motivated to respond. In particular, consider a Soviet military analyst. Such a person would have every good reason to consider the most sinister suggestions seriously. The move of the United States toward more of a counterforce posture may signal the possibility of the United States achieving a first-strike capability, and the Soviets would be motivated to respond in kind. It is in such action- reaction cycles that we fear the greatest likelihood of upsetting the nuclear balance and precipitating a disastrous nuclear war. □ 7&**^rJ~?f November 1974 Bulletin of the Atomic Scientists 13 Department of Energy Washington, D.C. 20545 MAY 17 1979 Mrs. Ruth Clusen Assistant Secretary for Environment Department of Energy Washington, D.C. 20545 Dear Mrs. Clusen: Consistent with notice of hearing issued on Friday, March 2, 1979 (43 F.R. 11821) public hearings were held on the Draft Environmental Impact Statement, Livermore Site, DOE/EIS- 0028-D, on April 12, 1979. The hearings were conducted by the undersigned Presiding Board in conformance with the pro- cedures set forth in the notice. Following review of the Draft Environmental Impact Statement and of the record compiled, the Board has identified some issues which may be critical to future decision making. The attached report sets forth these issues as well as the Board's recommendation concerning their treatment in the final impact statement. In addition, the Board has compiled a record of the hearings, consisting of the transcripts, and the written statements, documents and exhibits submitted by private persons and organizations, including the written comments submitted after the close of the hearings in response to Board request. In accordance with the notice, this hearing record and the Board's report is being transmitted to the Department's public document rooms. Further, in accordance with the notice of hearing and the mandate to this Board, this report is limited to those un- resolved issues relating to DOE/EIS-002 8-D which the Board determined critical to future decision making regarding Mrs. Ruth Clusen Page 2 the Livermore Site. This Board has neither undertaken to resolve the issues raised nor to render judgements concern- ing such issues. We trust, however, that their identifica- tion and our recommendations on how that should be addressed will assist the decision making process. Respectfully, THE PRESIDING BOARD _ V _ _ . _ G. Victor Beard L. Trowbridge Grose J#hn B. Farmakides, Chairman Enclosure: As stated STATEMENT IDENTIFYING VIEWS AND ISSUES ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT LIVERMORE SITE, DOE/EIS-0028-D by the PRESIDING BOARD May 14, 1979 I. INTRODUCTION In accordance with the notice of hearing dated March 2, 1979, the public hearings on the Draft Environmental Impact State- ment, Livermore Site, (DOE/EIS-0028-D) were held on April 12, 1979 in Livermore, California. The hearings were conducted by the Presiding Board (Board) established for this proceeding under the rules of procedure set forth in the notice. Comments were received from private and public organizations and from individual citizens.— As stated in the notice of hearing, the Board has identified only those issues which it considers to be critical to future decisionmaking regarding the Livermore Site. In addition, and as noted by the Board during the course of the hearing, the Presiding Board has not undertaken to judge the merits of the issues or to render judgment concerning the course of the operations. This report, along with copies of the transcript, oral and written comments 1/ Many of the participants raised similar or identical issues. Where possible, those issues that would so permit have been consolidated. In addition, the Board has not attempted to reference in this report all the participants who addressed a specific issue. That information is available in the tran- script and in the exhibits made of record. - 2 - and questions submitted to the Board by members of the public, organizations and government agencies, as well as the list 2/ of exhibits- attached as Appendix A hereto, including the written responses by the staff to the questions raised in the hearing, constitute the record of this public hearing. Concurrent with the submission of this report to the Assistant Secretary for Environment, it is being sent to the Acting Deputy Director, Office of Environmental Compliance and Overview, for placement in the Department's public document rooms. II. UNRESOLVED ISSUES A. Geological-Seismological The key issue most frequently identified by participants, including both technical experts and laymen involves the earthquake (seismic) safety of continued operations of the Laboratories on the Livermore Site. The potential for earthquakes and the effects of earthquakes relative to the Livermore Site is obviously a complex subject. It continues to receive a great deal of attention (as many other areas do in California) by the LLL staff, by the USGS , by academia, and by industrial and utility companies. The numerous comments received range all the way from: 1) the site must be abandoned because there is no 2/ Three participants were afforded the opportunity to submit their comments and questions to the staff for further clarifi- cation provided the same was done by April 16, 1979. (Hearing Transcript (Tr.) pp. 46, 98, 103). Only one such letter was received: recorded as Exhibit #13. - 3 - protection possible from inevitable earthquakes to 2) the site is well suited to safely withstand the most damaging earthquake that may strike. The staff is fully aware of the importance of this issue and has described in some detail their plans for future investigations to resolve • 4T 4. 3/ remaining questions on seismic safety.—' Specific subtopics of this general seismic issue were repeatedly raised by many respondents in writing and at the public hearings. They are both interrelated and interdependent, The Board believes that some of them are of critical import- ance to future decisionmaking and require further attention. These subtopics are briefly discussed as follows: 1. Determination of the safe shutdown earthquake (SSE) or seismic hazard. Considerable concern was expressed about different stated values of acceleration, mainly 0.5g 4/ as compared to O.8.— ' Various investigations for LLL over the past several years have incorporated different criteria for determination of levels of conservatism used to arrive at "g" values. New data, (characterization of the Las Positas fault, renewed study of the Tesla faults and increasing deployment of seismicity monitoring networks, etc) should improve ability to arrive at a firm and convincing "g" value 3/ Staff Statement in response to comments received on the DEIS is dated March 1979 (Hereafter: Staff Stat.)., p 8-17; Tr. 192- 198, J. Scheimer. See also Summary Statement by J. La Grone, Tr. 12-15. 4/ DEIS pp. 2A-29-30; staff state, p. 14-16; Tr. 198-200, D. Bernreuter; Tr. 201-202, J. Scheimer; Tr. Supp. 8-10, G. Barlow; Tr. 152, H. Rothblatt; Tr. 162, A. Baldwin; Ltr. from J. N. Brune to J. Farmakides, April 6, 1979; Tr. 27, J. Olsen, Tr. p. 223-4, F. Tocars. - 4 - based on most up-to-date state-of-the-art methods applicable to the Livermore site. Accordingly, clarification of the methods used to determine the SSE and "g" value and why these values differ from those of the Vallecitos site is needed in the FEIS. 2. Relative damage effects of possible instantaneous very high peak accelerations compared against a longer duration of strong ground motion. With more instrumentation of earthquake activity from various areas in the world, it is becoming apparent that unexpectedly high acceleration can occur from moderate magnitude earthquakes in areas close to the causative fault. -' Also duration of ground shaking can vary through seconds to tens of seconds. -^ As a matter of earthquake engineering for safe seismic design criteria of critical facilities, some discussion is needed in the FEIS directed to the relative importance of damage potential from peak acceleration as well as from longer 7 / duration ground motion.- 7 Also needed is a discussion of the measures to be taken by the laboratories to minimize these seismic effects. 3. Re-evaluation of geology of Livermore Valley with emphasis on delineation of faults. Considerable concern was 5/ Ltr. from J. N. Brune; Tr. p. 213-215, G. Barlow. 6/ Tr. p. 217, G. Barlow; Ltr. from P.M. Griffin to J. Farmakides 7/ Tr. 206-211, R. Gray; Tr. 180-183, J. Caid; Tr. 183-187, J. Autherford. Consideration should be given to treating such complex technical issues as may require detailed explanations in appendices to the main text. This would maintain the desired brevity of the main text while providing detail for those having interest in the specific subject involved. - 5 - expressed by participants on the occurrence of faults bordering the Valley, within the Valley, and especially near and 8/ under the Livermore Site.— Various maps and cross sections 9/ ... in the DEIS,— ' while they necessarily differ in scale, date of preparation, data base available, purpose, and theme, collectively reveal a confusing, if not conflicting, array of faults. Up-to-date clear maps and cross sections are necessary to resolve questions of known and inferred faults, their extent, sense of displacement, geometry, possible interrelationships, potential for seismic activity, and very importantly, their ages. As an example of the confusion that exists, the recently postulated "Las Positas fault" should, if possible, be verified and characterized. And while the delineation of local faults may have no affect on the determination of the SSE from the Tesla fault, the potential for surface rupture and local seismicity generated on nearby faults should be considered. The Tesla fault no. 1 in particular is mapped 8/ DEIS p. 2A-6-2A-21, 2C-10-2C-19; Staff Stat. 8-14; Tr. p. 21, C. Bowen; Tr. Supp. 6-8, 11, G. Barlow; Tr. 104-105, W. Riggin; Tr. 162-163, A. Baldwin; Tr. 166-168, R. Stolzman; Tr. 219-220, G. Barlow; Tr. 232-235, R. Zatkin; P.M. Griffin ltr. ; Ltr. from Friends of the Earth to W. H. Pennington dated Dec. 18, 1978; Ltr. from W. H. Fraley to C. Jackson dated April 2, 197 9; Ltr. from W. Riggan and S. Ladd to W. H. Pennington dated Dec. 18, 197 8; Ltr. from L. A. Arnold to W. H. Pennington dated Dec. 17, 197 8; Ltr. from L. E. Meierotto to W. H. Pennington dated Dec. 8, 1978. 9/ DEIS p. 2A-16, 2A-17, 2A-18, 2C-2 , 2C-9 , 2C-11, 2C-15, 2C-16, 2C-17. - 6 - as inferred to end at a point about midvray along the southern boundary of the Livermore Site. The Tesla fault no. 2 is inferred to pass either just outside the southwest corner of the site—/ or inside the site.—/ Though the uncertainty of fault occurrence is probably real, it is compounded by conflicting map data. The staff noted its intention to obtain additional data and to undertake study of these and other nearby faults, their age(s), and their potential for surface rupture. Another aspect of the geology of the Livermore Site is the definition of bedrock, the definition of soil, and the thickness and structure of each beneath the Site and in Livermore Valley in general.—/ These concerns under the heading of subsurface geology, appear to need further amplification and reassessment. For example, depth to Bedrock was questioned as well as soil layers stated to be 1000 feet thick. An improved seismotectonic model of the Livermore Valley and a new understanding of the relationship of local faults to regional faults should contribute to an improved estimate of the maximum credible earthquake (SSE) and surface rupture potential. It was pointed out — ' that the Tesla fault and 10/ DEIS p. 2A-17. TT/ DEIS p. 2C-9. 12/ DEIS p. 2A-23-2A-26; Ltr. from P.M. Griffin; Ltr. from R. Zatkin; Tr. p. 216-218, G. Barlow; Tr. p. 180-181, J. Caid. 13/ Ltr. from Friends of the Earth; Ltr. from L. E. Meierotto, Ltr. from W. Riggan and S. Ladd ; Ltr. from R. Zatkin; Tr. 165- 172, R. Stolzman. - 7 - the Las Positas fault may be a significant strand of much longer and possibly active fault systems, hence influencing the determination of earthquake magnitude based on fault length and displacement relationships. The staff states that in light of new data generated from their studies of the Vallecitos site and as a result of the "discovery" of the Las Positas fault, they plan to update their seismotec- tonic model for the Livermore region. — ' 4. Surface rupture potential. Although the concern about actual surface rupture potential within the Livermore Site is discussed above, this issue is emphasized because it was raised repeatedly and in detail by both laymen and experts It would appear that evaluation of this issue requires a reasonable determination of the capability of faults running through the site. (Tesla fault nos. 1, 2 and 3; Ramp thrust; Corral Hollow; Doutherty; and Las Positas) 5. Integrity of existing facilities in face of possible seismic shaking and of surface rupture was a subject of con- siderable concern. — ' The subject of safe seismic design is extremely complex and is one in which relatively little experience and testing are available. A better understanding of the Site geology, and further evaluation of the SSE and the Operating Basis Earthquake (OBE) should contribute to 14/ Staff Stat. p. 9-12. 15/ Tr. 183-187, J. Rutherford; Tr. 180-183, J. Caid; Tr. 204- 211, R. Gray. - 8 - clarify some important concerns raised on this subject. The Board recommends that this subject be examined thoroughly in light of new information being generated in the field of earthquake engineering. 6. The subject of seismic and geologic sitting criteria applicable to the Livermore Site. In view of the questions raised on this issue and the response of the staff it appears that further discussion and clarification of seismic safety standards for the Livermore Site, or for its more critical facilities, is needed in the FEIS.— / 7. Several participants urged the need for an independ- ent review and critique of any forthcoming reports on seismic hazard assessments at the Livermore Site.— / They were of the opinion that independent review is necessary to provide impartial credibility to such reports. B. Health Effects 1. Radiological Standards. The use of the current standards established for DOE laboratories including those at Livermore was questioned by a number of participants.—^ These questions were centered around (a) low level-long time exposure and (b) plutonium-lung and bone-exposures. These participants proposed that epidemological methods used by "Mancuso", "Sternglass" , "Lyon", and others 16/ Staff Stat. p. 14-15; Tr . 198-99, D. Bernreuter, Tr. 182, J. Caid; Tr. Supp. p. 7-10, G. Barlow; Tr. p. 313, J. B. Dickenson. 17/ Tr. 106, W. Riggan; Tr. 278-279, G. Oilley; Tr. 303, J. D. Smith; Tr. 314, J. B. Dickenson. 18/ Tr. 22-29, C. Bowen; Tr . 79-99, C. Johnson; Tr. 34-55, S. Ladd; Tr. 106, W. Riggan; Tr. 118-119, C. Schwartz; Tr. 164, 225, A. Baldwin, etc. - 9 - be used for long time-low dose "exposures". It was also suggested that plutonium standards proposed by "Gofman" , "Burleigh" and some Russian studies be adopted for plutonium lung and bone exposures . The staff responded that while they were aware of the current literature concerning this question, they had adopted the standards set forth in Title 10 CFR, Part 20 and related pertinent portions. These standards are endorsed by the International Commission on Radiological Protection and the National Council on Radiation, Protection and 19/ Measurements. — / The staff also noted that there are uncertain- ties implicit in epidemiological methods, measurements and calculations at low dose and long term exposures. There are also uncertainties involved in straight line extrapola- tions of gross biological effects against dose at low doses. It would appear necessary, in view of the concerns voiced in this area that the FEIS address this subject in more detail to include a summary of the efforts currently in process towards the review and evaluation of such standards. 2. Compliance with Radiological Standards. There were several comments criticizing the laboratory and field methods used to determine compliance with the radiological 20 / standards.— 7 One participant, Dr. Carl Johnson, stressed his 19/ See DEIS, pp. 3-74, items 3-7, 3-8. 20/ Tr. 29, C. Bower; Tr. 81-90, 93-97, C. Johnson; Tr. 151- 152, H. Rothblatt. - 10 - concern with the methods for plutonium sampling in soil.—/ In its response, the staff noted that Dr. Johnson's methods were not universally recognized, and in fact, were in conflict with the standards of both the Environmental Protection Agency and the Nuclear Regulatory Commission.—/ However, it would appear from both written and oral comments and from the published literature available that soil sampling for respirable particles is in a state of flux and that this discipline should be constantly monitored for improved acceptable methods.—/ From the record available, it would seem that the Livermore laboratories are complying with the adopted stand- 24/ ards. — This subject should be further discussed in the FEIS. 3. Toxicological Standards. Concern was raised as to the amounts of toxicological material released to the environment, and methods used to ensure compliance with 25/ adopted standards. — ' The labs have agreed to enlarge some sections of the FEIS giving more information in certain critical areas. We believe this to be desirable; however, it should not be overdone. Much of the detailed information asked by 21/ Tr. 82-97, C. Johnson. 22/ Staff Stat. pp. 6, 7. 2_3/ See also DEIS pp. 3-74, references: 3-1, 3-2, 3-3, 3-4, 3-13, 3-14. 2_4/ DEIS pp. 2-28, 2-44, 2-45, 2-60, 2-63, 2-64, 2-67, 3-22, 3-16, 3-17. See particularly Staff Stat. pp. 30 which shows the whole body exposure of Livermore employees in 1978 to be extremely low. 25 / Ltr. W. Talley to H. Pennington dated Apr. 13, 1979; Tr. 80, C. Johnson. 229 - 11 - some individuals can best be furnished by the existing lab reports. To include this vast amount of material in the report would detract from its desirable compact size. C. Maximum Credible Accident (MCA) 26 / Concern was repeatedly expressed — ■ that the DEIS was inadequate in the definition and evaluation of the MCA. Since the MCA may be determined by the Safe Shutdown Earthquake (SSE) this subject should be discussed in sufficient detail to permit meaningful evaluation. The FEIS should be clarified as to this issue, including a discussion as to the plans developed for responding to an MCA. The major concern of many participants centered around possible earthquake rupture of the two buildings containing plutonium and the fate of the plutonium if it were to escape its containment environment. Apparently, the Livermore laboratory uses a multiple containment philosophy which depends in large part in maintaining negative air pressure between certain pieces of equipment (glove boxes) and the room in which they are contained, as well as maintaining negative pressures between this room and other parts of the building. Obviously this philosophy depends on maintaining the integrity of the ducting system, the pressure pumps, and the motors driving the pumps. Many of the participants opined that the DEIS was inadequate because of its failure to discuss this 26/ Tr. 205, R. Gray; Tr. 281, G. Dilley, Tr. 284, D. Page; Tr. 309, J. Smith; Tr. 313, J. Dickenson. - 12 - system in detail, especially as it may be affected by an earthquake. For example, in case the containment building housing plutonium was breached by such an earthquake, what would happen to the available plutonium if fire develops and it becomes airborne. It would appear that a short appendix containing surface-to-volume relations and how they affect burning rates, slagging, and particle size distribution of the metal oxide should be added to the FEIS; otherwise, an attempt should be made to relate the maximum credible accident concerning Plutonium to other actual experiences, assuming the contain- ment is breached. It should be noted also that LLL and SLL handle accidental releases of titium with substantially different systems. Unnecessary speculation is promoted because the DEIS is unclear as to the reasons for this difference. This question should be more fully discussed in the FEIS. D. Socio-Economic and Other Issues 1. One group of participants— ^state that the DEIS is defective because it does not adequately analyze and evaluate the "benefits" of the Livermore Site. The discus- sion in the DEIS on the benefits of the Livermore site is considered, in their opinion, to be a mere conclusion, i.e. that the nuclear weapons policy of the United States is necessarily beneficial. |V/ For example, see Tr . 57, D. Elsberg; Tr. 108, C. Schwartz; Tr. 147, W. Reynolds; Tr. 260, M. Olney; Tr. 33, S. Ladd, etc. m - 13 - They maintain that such a conclusion is insuffici- ent to properly evaluate, assess, and balance the environ- mental costs involved. For example, one witness contended that the assumptions for continued operation of the Livermore Labs based on the needs of the national nuclear weapons program are incorrect; that in view of the status of nuclear technology and the inventory of nuclear weapons , each of which far outweigh the need, the benefits of continued opera- 28 / tion of the Livermore site could not be shown. — • He was of the opinion that the Livermore DEIS, can be meaningful only within the context of an environmental impact analysis of the entire national nuclear weapons program; which analysis could conceivably result in a conclusion to stop further nuclear weapons design and testing and thus reduce or eliminate the need for the Lawrence Livermore Labs. One witness commented that nuclear weapons could "never be made ethically acceptable in terms of public health and genetic integrity", and, therefore should be abandoned. However, he favored continued existence of the research and development effort at DOE and the Livermore laboratories so long as there exists a need to "stay-even-with, or ahead 29/ of [a. potential/ enemy. — In its response the staff notes that the DEIS is a site specific encironmental impact statement and fully 28 / Tr. 74-77, D. Elsberg. 29/ "Comments on the Environmental Impact Statement for the Lawrence Livermore Laboratory", Dr. John Gof man , p. 2-3, Tr. 160 - 14 - meets the requirements of NEPA. They further note that the national policy with respect to nuclear weapons design and production is imposed by both the Congress and the President and that the Department has no role as to the deployment and use of such weapons systems.— / While the staff response to this issue may be technically correct, nevertheless, the Board believes that the issue should be brought to the attention of the appropriate decisionmakers . 2. Another issue relates to the analysis of the "economic" cost benefit of the continued operation of the Livermore laboratories. Several participants— / noted that the DEIS did not adequately address the various economic factors that are involved. For example, concern was— / expressed that the economic costs of alternatives were not adequately considered since the ripple effects of the appropriations spent at the Livermore Laboratories, considered to be synonomous to military spending, are purportedly not as advantageous economically as if spent for commercial or industrial products. The witness also testified that the high probability of test ban treaty and its impact on the Livermore Labs should also be discussed — including the 30/ Staff Stat. pp. 2-3. 31/ Ltr. F.O.E. to H. Pennington, p. 5; Tr. 245-250, D. Thomas- glass; Tr. 302-304, J. Smith. But see Tr. 176-177, D. Hughes ; Tr. 178-180, H. Hubbard. 32/ Tr. 248-252, D. Thomas-glass; Tr. 259, A. Barreiro. T- 15 - impact such a treaty may have in reducing substantially the number of employees at Livermore and thus directly affecting the cost-benefit balance. Several suggestions were made that in performing this type of analysis, the alternative of assessing the use of Livermore laboratories for study and research on all energy options and technologies should be more adequately considered. E. Emergency Response Plan. 33/ Concern was voiced — ' that the emergency response and evacuation systems in the Livermore area are inadequate and not properly evaluated in the DEIS as to any off-site evacuation that may be made necessary by reason of the continued operations of the Livermore site. For example, apparently there is no suitable human radiological decon- tamination facility available in the region and the relevance of this fact to the continued operations of the laboratories was not discussed in the DEIS. In response the staff noted that while the laboratories were ready to assist as much as possible, such emergency plans were the responsibility of the local governments. — ■ The extent of the responsibility of the laboratories and the resources available in the event of an MCE should be treated in the FEIS. In addition, in view of the expressed concerns, it would appear that the laboratories may need to become more active in their attempts 33/ Tr. 269-277, V. Miller; Tr. 283, 284, D. Page; Tr. 20, 21, C. Bauer; Tr. 315, J. Dickenson; Tr. 317, D. Ellis. 34/ See Staff Stat. Supplement, p. 28, DEIS Appendix 3. - 16 - to assist the local and state agencies in developing such plans. F. Miscellaneous 1. The transportation of radioactive materials into and out of the Livermore site was identified as a hazard that has not been adequately addressed in the DEIS.— ^ For example, one witness noted that the containers used for shipping radioactive materials were inadequate and should be more fully discussed in relation to the type, and level, of radioactive materials being transported.— / On the other hand, the staff points out that the containers used for the transport of radioactive materials (non-weapon related) are built to the specifications and standards of the U.S. Depart- ment of Transportation.— ' One available option is to obtain clarification .from the Department of Transportation on this question for later inclusion in the FEIS. 2. The DEIS was also criticized by some— ' because it did not discuss various alternative options for the use of the Livermore site to the extent they thought necessary. They were of the opinion that the alternative uses for the site for all energy research should be more fully evaluated to include conversion of the facilities to solar energy research, etc. This issue should be clarified in the FEIS. 35/ Tr. 139-147, W. Reynolds; Tr. 86, C. Johnson. 36/ Tr. 143-145, W. Reynolds. 37/ DEIS 3-9, 2, 7; see also Staff Statement dated March 1979, p. 32. 38/ Tr. 38, S. Ladd; Tr. 245, Thomas-glass; Tr. 278, D. Dilley, ■>.•- ^S§ - 17 - 3. One participant requested names of the authors to the various sections of the DEIS be identified so as to enhance the credibility of the DEIS and to complete the 39/ record of the proceeding. — ' The staff response was that it is difficult to pin point the author of a specific section in view of the many people involved, because of the redraft- ing which occurs, and because the report is a total team project. — One suggestion advanced is that detailed scientific and technical material could be presented in appendices, with authorship of those appendices available to the public on specific request provided that it does not impinge on the objectivity of the individual authors, or does not result in their harrassment. 4. In conjunction with the statement by the staff that the Livermore Labs have undertaken a detailed plan 41/ to investigate the seismic activity of the entire area — a request was made that a public hearing be convened at a later time after the seismological data is compiled. The Board noted that it has no authority to convene such a hearing, however, in view of the request as it related to the seismic issues it agreed to raise the question for resolution by the appropriate decisionmaker. 39/ Tr. 242, 243, R. Zatkin. 40 / Tr. 242, 243, R. Duval. It is appropriate that the Board note for the record the cooperation and responsibility displayed by the staff during the hearing in attempting to answer as many questions as possible, and to address the issues raised. 41/ Tr. 193-197, J. Scheimer. j jjflSaS APPENDIX A DOE/EIS-0028-D Public Hearings Livermore Site April 12, 1979 Exhibits and Written Statements Submitted at Hearings: Ex. #1 Ltr. fr. Valerie A. Raymond, Chm. Bd. of Spvs. , 1st Dist. Cty. of Alameda ,CA. , to C. Jackson, DOE. , requesting that several reports along w/ltr. be in record. Tr. 15 #2 Statement fr. Congr. R.V.Dellums, 8th Dist. , CA. , for DOE Hearing dated April 12, 1979 #3 Mr. D. Ellsberg adopted statement of Natural Resources Defense Council, Inc., 12/21/77 on Rocky Flats Plant Site, DEIS ERDA-1545-D, and submitted it as his exhibit. Tr. 19 Tr. 78 #4 Exhibit by Prof. C.Schwartz, Tr. 108 including series of letters and articles plus copies of 2 posters prepared by Prof. Schwartz. #5 Series of documents by Dr. J. W. Tr. 160 Gofman, M.D., Ph.D., addressing the cancer hazard from inhaled plutonium; Testimony for the GESMO Hearings #6 Exhibits submitted by Friends of The Earth: (a) Letter dated 4/10/79 to J. B. Farmakides (b) Ltr. J. N. Brune, Prof .Geophysics, Tr. 212 U.Cal. at San Diego, dated 4/6/79 to J. B. Farmakides, enclosing testimony on behalf of Inter- veners Regarding CONTENTION 3 - GROUND MOTION, DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 & 2 Docket No.s STN 50-275, 50-323 (c) Ltr. fr. P. M. Griffin dated Tr. 215 4/6/79 to J. Farmakides - 2 - APPENDIX A {cont'd) Ex. #6 (cont'd) (d) "Preliminary Analysis of the Tr. 220 Peakes of Strong Earthquake Ground Motion - Dependence of Peaks on Earthquake Magnitude, Epicentral Distance and Recording Site Conditions" by Dr. M. D. Trifunac #7 Criticism Pertinent to: Tr. 230 Appendix 2A Geological and Seismological Investigation of LLL Site by L. H. Wright of 6/3/74 submitted by Robert S. Zatkin #8 Exhibits submitted by Mr. J. Ventresca Tr. 266 #9 Ltr. to Board by Mr. A.L. Tr. 255 Barreiro, UC Santa Cruz, representing himself and others (1100 on campus) #10 Testimony presented by Tr. 278 Grace Dilley, Berkeley, Calif., dated 4/4/79 addressed to W. H. Pennington, DOE #11 Response to DOE Staff Statement on Comments Received on DEIS for Livermore Site, March 1979, submitted by W. A. Lochstet, Environmental Coalition on Nuclear Power, by ltr. 4/9/79 #12 Ltr. to J. Farmakides from Ms. D. Headley dated 4/14/79 #13 Ltr. to R.A.DuVall dated 4/16/79 Tr. 103 fr. W. Riggan,UC Nuclear Weapons Labs Conversion Project, submit- ting list of unanswered questions by staff - per his testimony at hearinc BOARD OF SUPERVISORS VALERIE A.RAYMOND SUPERVISOR.FIRST DISTRICT April 11, 1979 Mr. Calvin Jackson United States Department of Energy 1333 Broadway Oakland, CA 94612 Re: Draft Environmental Impact Statement (DEIS) Lawrence Livermore Laboratory Dear Mr. Jackson: The Alameda County Board of Supervisors wishes to comment on the Draft Environmental Impact Statement prepared by the Department of Energy for the Lawrence Livermore Laboratory and have these comments entered into the record of the April 12, 1979 public hearing on this matter. The Board believes that the present draft contains insufficient infor- mation, as outlined in the attached reports from the Alameda County Planning Commission, the Environmental Protection Agency, and County staff, and requests that these comments be considered and responded to in the Final Environmental Impact Statement . Thank you for your consideration. Sincerely, Valerie A. Raymond Chairman VAR:my Ends . 1221 OAK STREET ■ SUITE 536 • OAK LAN D, CALI FORN IA 94612 ■ (415) 874-7367 Z£2£ BOARD OF SUPERVISORS VALERIE A.RAYMOND SUPERVISOR, FIRST DISTRICT COMMENTS ON LAWRENCE LIVERMORE LABORATORY/ DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS) The following comments are submitted by the Alameda County Board of Supervisors on the Draft Environmental Impact Statement (DEIS), prepared by the Department of Energy on the Lawrence Livermore Laboratory: 1. Data presentation and coverage . There should be a far more complete presentation of data and the final impact statement should be modified to address the following concerns: a) Summary concludes project operations pose no impact on surface or groundwater. No facts in report to support this conclusion. b) The tone of the report is very one-sided in that it emphasizes project benefits and minimizes potential hazards. c) No indication of amount of radioactive material stored and used on site is provided. d) The assumption is made that if radioactive material releases are below DOE standards then there are no impacts. With the current controversy over long-term effects of low level radiation and the setting of standards this assumption is difficult to support. e) The disposition of high-level radioactive waste is dismissed by stating that it is disposed at a DOE approved off-site area? Where is it? What are the impacts on Alameda County and the Bay Area? f) Safety procedures for handling liquid waste are described in detail and the impression is given that an accident is not possible. Accidents are always possible and, therefore, potential impacts on surface water and groundwater resources from an accidental release of contaminated liquid waste should be assessed. g) Impacts of accidental release of radioactive materials into the municipal sewage treatment plant should be assessed. 1221 OAK STREET • SUITE 536 • OAKLAN D, CALI FORN IA 9-4612 • (415) 874-7367 'Comments on LLL/Draft Environmental Impact Statement (DEIS) Pcige 2 ' April 9, 1979 b) 2. Seismic Studies . Additional seismic studies to be conducted be undertaken by indeoendPnt seismic engineers or the U. S. Geological Survey to include: P a) nf r th! V f 1Ua D i0n .° f d n ta fr0m: Herd ' s < 1977 ) investigation of the Las Positas, Greenville, and Verona faults; J A Blume and Associates (1972, 1978) seismic and geologic ' investigations of the effects of the Tesla and Las Positas tault zones on the Lawrence Livermore and Sandia Livermore Laboratories; and the Vallecitos site studies. This will VallT t0 el ° P a new tectoni "c model for the Livermore w?th U no,?c f Jo 1S n6 V m ° del t0 establish a field investigation with goals to resolve questions regarding the potential for surface faulting at the LLL/SLL sites and to develop reoccurrence intervals for active faults in the vicinity of the LLL/SLL sites! To perform a probabilistic based seismic hazard analysis for the Livermore site using appropriate activity levels as deducted from the field investigations. that L H ! u°" B P / 0grm should . be designed to evaluate potentially active fault zones that may lie under or near critical facilities sites and to address in detail shaking hazard potentials that may have impact on the sites. 3. Emergency response plans . S«?M?^?2c 1 ^" ClUde / eqUl r e ? ents for evacuation plans based on several possibilities from worst possible case to most probable case. c) seismic HAF:EHM:mso Wl ALAMEDA COUNTY PLANNING DEPARTMENT 399 Elmhurst Street, Hayward, California 94544 (415) 881 -6401 April 2, 1979 Mr. Calvin Jackson United States Department of Energy 1 333 Broadway Oakland, CA 94612 Dear Mr. Jackson: The Alameda County Planning Commission has the responsibility of planning for lands in Alameda County which may be impacted by the operation of the Lawrence Livermore Laboratory. The Commission considered a staff report on the* Draft "Environmental Impact Statement Livermore Site, Livermore, California, September, 1978, prepared by the U.S. Department of Energy at their meeting of Monday, March 19, 1979 to become familiar with potential impacts. The comments which follow are submitted to you for review and response in the Final Environmental Impact Statement. 1. The distribution of the DEIS to this Commission did not occur with sufficient time available to respond under the original schedule. This did not permit the time necessary to review the total document fully. The Commission had only one copy of the DEIS for its use. 2. The summary contained in the DEIS is brief to the point of being inadequate, and seemed to treat the substance of the report rather superficially. 3. There appears to be minimal correlation of the County General Plan and its elements with the evaluation made in the DEIS. It is questionable whether the County planning elements were reviewed as part of the preparation of the base document. A. The DEIS appears deficient in Its consideration of the impacts on the water resources in the Valley to the extent that the DEIS is judged to be inadequate for use in assessing the impacts the Lab may have on the surrounding community. This is particularly evident in the apparent lack of attention given to the impacts of any accident on the surface and ground water resources. The volume of liquid containing radio nuclides located at the laboratories is not identified nor is the direction of accidential spill addressed. In addition, air borne contamination that may be deposited on the surrounding properties with subsequent surface water runoff directly affecting the health and safety of the public and ultimately carrying the material back into the surface and underground water system has not been addressed. 5. The impacts of a potential nuclear contamination entering the municipal waste disposal system should be assessed. Enclosure 2 Mr. Calvin Jackson April 2, 1979 Poge2 6. There is lock of agreement by geological authorities regarding the location and potential effects of the Las Positas fault. Additional geologic studies should be mode and included in the final DEIS to resolve all questions on this matter. It is requested that the additional studies suggested above to bring the report into conformance with the Federal Guidelines for the preparation of a DEIS be completed and that the new information be distributed to those receiving this DEIS so that comments on the new information may be included in the final DEIS to be certified by the Department of Energy. Thank you for your assistance and attention. Very truly yours, William H. Fraley Secretary When- ce: Board of Supervisors Director of Public Works Enclosure 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 1 2 JAN 1979 Mr.' W. H. Pennington Mail Station E-201 GTS Department of Energy Washington, D.C. 20545 Dear Mr. Pennington: Enclosed are the EPA review comments on the Draft Environmental Impact Statement, DOE/EIS-0028-D, entitled, "Livermore Site, Liveraore, California". Our major concerns with this environmental impact statement (EIS) are the lack of environmental data, the question of whether certain effluents are as low as reasonally achieveable (ALARA) and the incomplete dose assessment presented. There are aeveral areas in the EIS where the data presented is not sufficient to allow independent analyses of the radiation impact of the facility. EPA believes that this data should be incorporated into the final statement. The question of achieving ALARA levels for effluents from several specific facilities are detailed in the enclosed comments. Finally, the failure to present population doses, health effects estimates, food and water pathways considerations, radionuclides considered, and the methods and assumptions employed result in an unacceptably incomplete picture of the laboratory's environmental impact. In light of our review and in accordance with EPA procedures ; we h3v- rated the proposed action L0 (Lack of Objectives) and classified the statement as Category 2 (Insufficient Information). If you or your staff have any questions concerning our rating or comments, please do not hesitate to call on us. Sincerely y "l** * Peter Cook Acting Director Office of Federal Activities (A-10H) Enclosure EPA COMMENTS ON DOE/EIS-0028-D THE DRAFT ENVIRONMENTAL IMPACT STATEMENT ON THE LAWRENCE LIVERMORE LABORATORY SITE AT LIVERMORE, CALIFORNIA General Comments 1. This draft environmental impact statement (DEIS) relies heavily on referencing other reports, probably in order to minimize the size of the document. However, in some cases there is not enough information to enable a reviewer who does not have access to the references to determine the effect of site operations on the environment. The most significant omissions are in describing the environmental monitoring program and in summarizing data collected over the years to show whether any trend is apparent, ""here is also a need for better maps of both the site and the surrounding area. More detail is included in specific comments below. The final EIS (FEIS) should address these items. 2. EPA understands that the description of current and proposed activities is not up to date and that current plans are different in some cases. The FEIS should be current in all significant ongoing and proposed activities. 3. More information and discussion are needed to assure that the radioactive effluents that may affect persons off -site are at a level considered to be as low as reasonably achieveable (ALARA). The most significant of these are: (a) The 14 Mev neutron generator which is projected to deliver a fence line dose of 900 mrem per year. This is a high level of radiation for an unrestricted area and there is a need to more explicitly discuss whether this level is ALARA. Also needing discussion are when (and if) the relocation to Building 292 will occur and what the expected fence-line doses from the new facility will be; (b) The procedure which is relied upon for the Livermore sewage treatment plant to divert contaminated effluent at the plant rather than providing hold-up capability at the site; (c) The reasons why tritium releases to air and water cannot be further reduced needs to be explained; and, (d) The expected radiation exposure to passenger traffic from the LINAC, reactor, and relocated neutron generator operations if the new northwest entrance is still planned. Enclosure 4' *. There ia a deficiency within the DEIS in the description of the data produced by the off -site environmental sampling program. Although detailed information on the sampling locations, the types of samples (i.e., sever sludge, water, air), and the radionuclide concentrations are provided in the annual reports, from all we believe the FEIS should include a summary of much of the information contained in these reports to allow a eomplete, independent assessment of the Lawrence Livermore Laboratory (LLL) impact on the local environment. It would be particularly helpful to have a summary of average annual radionuclide ooneentratons in effluents and in all media for the past five years to aid in relating the annual effluent releases to present radionuclide concentrations in the immediate environs. The use of several years' data would also reflect the apparent variability of aite operations over time and would better indicate the full range 'of possible environmental effects than could be obtained by ehoosing a single year. Further, all radionuclide releases from Sandia Laboratories - Livermore (SLL), including liquid tritum releases, should be included in the annual release data (Table 3-1). 5. More discussion is needed on the environmental effects of site operation as determined from summarized trend data. Two areas of special interest are groundwater contamination at both the Livermore aite and Site 300 and the effects of discharge from the Livermore Water Reclamation Plant (LWRP). The Livermore-Amador Valley Wastewater Management Authority Project (presently under construction) will result in LWRP effluent being transported out of the valley and discharged into San Francisco Bay. This will significantly change the fate of future LLL liquid discharges; it should be addressed in the FEIS. 6. EPA questions the procedure of comparing effects from accidents st LLL with the 10 CFR 100 regulatory limits for accidents, this was done in several places in the DEIS. 10 CFR 100 applies strictly to accidents at reactor sites. If the accident doses from various LLL sources are to be compared with it, there needs to be an explanation of how these regulations relate to the accidents being analyzed. On a related subject, it is stated that DOE guidance say be used to triple the levels provided in the EPA Protective Action Guides (PAGs) before evacuation needs to be considered. This is an inappropriate extrapolation of the PAGs. Currently the PAGs are only Agency guidance and provide action ranges for only the whole body (1-5 rem) and the thyroid (5-25 rem). There ia no provision made for further extending these ranges. Further, protective action does not necessarily mean an action as drastic as evacuation. Protective action can be action that will reduce exposure or the chance of exposure. Enclosure 4 Eisenhower's other warning In his farewell address, President Eisen- hower issued two warnings to the Ameri- can people. The first of these is very well known, it fits easily into a variety of ide- ological frameworks and it is often quoted or paraphrased. We must, he said, he wary of "the acquisition of unwarranted influence, whether sought or unsought, hy the military-industrial complex." Eisenhower's second warning is much less well known, it is not so easily under- stood and it is seldom quoted except by specialists studying the Eisenhower ad- ministration. After noting that research played an increasingly crucial role in our society and that the ways in which it was conducted had changed radically in recent 'years, Eisenhower said, "Yet in holding scientific research and discovery in re- spect, as we should, we must also he alert to the equal and opposite danger that public policy could itself become the captive of a scientific-technological _elite." To understand this second warning, it is necessary to recall its context. This context consisted of the events that took place during the forty months from the launching of Sputnik to the end of his administration. The particular segment of the "scientific and technological elite" that he had in mind consisted of the hard-sell technologists who tried to ex- ploit Sputnik and the missile gap psy- chosis it engendered. We should be wary, he said, of accepting their claims, believ- ing their analyses, and buying their wares. They and their sycophants invented the term "missile gap," they embellished that simple phrase with ornate horror stories about imminent threats to our very exis- tence as a nation, and they offered a thousand and one technical delights for remedying the situation. Most of their proposals were expensive, most were complicated and baroque, and most were loaded with more engineering virtuosity than good sense. Anyone who did not immediately agree with their assessments of the situation and who failed to recog- nize the necessity of proceeding forthwith on the development and production of their solutions was said to be out of touch with reality, technically backward, and trying to put the budget ahead of surviv- al. The claims of such people that they could solve the problem if only someone would unleash them carried a lot of weight with the public and with large segments of the Congress and the pres-;. Other ^0F ~- ^r^pwspic^ r"* 1 ^ 1 ! ~v -s****^ i o s - * ■ s o i • ■ I | \.AJ f : 5 1 • i »■ V * ( & > i\ \ V \ v 1 • S, \ : K *l •\ K '/ : ■4 : * '| •1 * h 4 s 4 1 . iJ- ilLn-.vA'^^.-j-^ 'z~J*. « 0*i_ V-&* - *3 DWIGHT D. EISENHOWER— 1956 scientists and technologists had per- formed seeming miracles in the recent past, and it was nol unnatural to suppose that they could do it again. It seemed that radar had saved Britain, that the A-bomb had ended (he war, and that the H-bomb had come along in the nick of time to save us from the Russian A-bomb. On the home front, the relatively recent introduction of antibiotics had saved our children from the scourges of earlier times, and airplanes and electronics had become capable of carrying us, our words and our images great distances in short times. Scientists and technologists had acquired the reputation of being magi- cians who had access to a special source of information and wisdom out of reach of the rest of mankind. A large part of the public was therefore more than ready to accept the hard-sell technologist's view of the world and to urge that the government support him in the manner to which he wanted to become accustomed. It seemed as if the pursuit of expensive and complicated technology as an end in itself might very well become an accepted part of America's way of life. Hut it was not only the general public that believed the technologists under stood something the rest of the world could not. Many of the scientists and technologists themselves believed that only they understood the problem. As a consequence, many of them believed it was their patriotic duty to save the rest of us whether we wanted them to or not. They made their own analyses of what the Soviets had done. They used their own narrow way of viewing things to figure out what the Russians ought to do next. They then argued that since the Russians were rational (about these things any- way), what they ought to do next is what they must in fact now be doing, and they then determined to save us from the consequences of this next real or imagi- nary Russian technological threat. The Eisenhower Administration was able to deal successfully and sensibly with most of the resulting rush of wild ideas, phony intelligence, and hard sell. But some of these ideas did get through, at least for a while. Beyond that, dealing with self- righteous extremists who have all the answers- and there were many among the scientists and technologists at the time — is always annoying and irritating. As we now know, the commonly haro- que and occasionally bizarre technological ideas urged on us in those years were in fact a portent of things to come. Weap- ons systems and other high technology devices have become still more complex in the years since Eisenhower's farewell address. And this complexity is creating serious social and political problems of the general kind that Eisenhower warned us about. Today, there are even more peo- ple who tell us that because major weap- ons systems are so complicated only weapons experts can decide if they are needed, only those in on all the secrets and up on the most arcane elements of operations analysis can tell us whether arms control and disarmament is good or bad, and only nuclear experts are fit to decide whether, when, and where nuclear power plants should be built. There are today many scientists and engineers, and many members of the general public as well, who believe that basic issues like these are simply beyond the ken of the people and their elected representatives, and that public policy concerning such matters should indeed be made by a sci- entific technological elite. Eisenhower's second warning is even more pertinent today than it was when he made it. As fate would have it I worked fairly closely with Eisenhower during the last three years of hi* presidency, first as a member of the Science Advisory Com- mittee he set up immediate'y after Sput PHVSICS TODAY / JANUARY 197/ letters iiik under the chairmanship of •lames R. Killian Jr, and second as the first Director of Defense Research and Engineering, a new position created in I958,as another part of the response to Sputnik, in these positions, I was directly concerned with precisely those scientific and technologi- cal programs in which the President himself was most involved and my own view of the world gradually changed as I came to see and understand the overall situation in which we found ourselves. I had gone to Washington a technological optimist, full of confidence in the tech- nological fix. I came away three and a half years later gravely concerned ahout the all too common practice of seeking and using technological palliatives to cover over serious persistent underlying political and social problems. In partic- ular, I became convinced of the futility of always devoting out main efforts to find- ing a technical solution to the problem posed by the steady decrease in our na- tional security that was being brought about by the spread of high technology weapons throughout the world. This, it seemed to me, was not only futile but ba- sically absurd, because nearly all of the weapons which in the hands of others were (and are) threatening our national security, and indeed our very existence, had been invented or perfected by us in the first place. In sum. my views on the relationship between technology and se- curity did not arise out of Eisenhower's warnings; rather his warnings and my views both arose out nf the some set of circumstances, but hi: formal warnings did very much help to crystallize my views on the subject. I found it very reassuring thr.t the Commander-in-Chief, a profes- sional military man himself, shared my own growing doubts about the value and efficacy of placing such a relatively high priority on finding technical solutions to what were really political problems. Eisenhower's warnings, which were based largely on his remarkable intuition, pointed up very real and extremely seri- ous problems. If we forget or downgrade his warnings, it will be to our peril. Herbert F. York University of California, San Diego La Jnlla. California Abridged vemion 'if the author's mporutt on n 1 1 if/l of the Forum on Phytic* and Society Au arc! on 27 A/jnl 1976 Further dincuntion ofth'u ibject may be found in York'*, recently published book "Race to Oblivion" reviewed III 1 1. ■ , r >,. r {[mp, 1'l) Ether drift tested 1 hi I<-ii