Alert: Public comment needed on proposed beryllium lathes at LANL

Editor’s Note: La Jicarita is posting the Concerned Citizens for Nuclear Safety (CCNS) weekly update asking for public comment regarding Los Alamos National Laboratory’s proposal to the New Mexico Environment Department to expand its beryllium operations. Time is of the essence: comments are due by midnight on Saturday, February 26. A sample comment letter is included in this post.

CCNS NEWS UPDATE

Runs 2/25/22 through 3/4/22

This is the CCNS News Update, an overview of the latest nuclear safety issues, brought to you every week by Concerned Citizens for Nuclear Safety.  Here is this week’s top headline:

  • Immediate Public Comments Needed about Two Proposed Beryllium Lathes at LANL

If you are concerned about proposed expansion of beryllium machining operations at Los Alamos National Laboratory (LANL), now is the time to express your interest to the New Mexico Environment Department Air Quality Bureau.  Public comments and expression of interest in the proposal to add two lathes for machining beryllium and a new sputtering coating operation are due by Saturday, February 26, 2022 at midnight Mountain Time by email to James.Nellessen@state.nm.us

Expression of your interest will allow you to review the Bureau’s analysis of the permit modification request for 30 days following notification.  It will also allow you to submit written public comments and request a public hearing.  See Subsection B of 20.2.72.206 New Mexico Administrative Code – Public Notice and Participation.  

CCNS has prepared a sample comment letter that you can use to express your interest. It is posted at http://nuclearactive.org/ and printed below:

. . . . . . . . .

February ***, 2022 – comments due by midnight MT on Sat. Feb. 26, 2022

By email to: James.Nellessen@state.nm.us

Jim Nellessen
Air Quality Bureau Permit Section
New Mexico Environment Department
525 Camino de los Marquez, Suite 1
Santa Fe, NM 87505-1816

Re:   Public Comments about Air Quality Permit Application from Los Alamos National Laboratory for Proposed Installation and Use of Two More Beryllium Lathes and a Magnetron Sputtering Coating Process at TA-35

Dear Mr. Nellessen:

Please accept these comments as my expression of interest in the proposed permit modification request by Los Alamos National Laboratory (LANL) to expand beryllium operations at Technical Area 35 (TA-35). I would appreciate notification from you about when the Air Quality Bureau’s analysis of the permit modification request is available for a 30-day public comment period and the opportunity to request a public hearing.

I am concerned about the defective public process including:

  1. The regulations require the broadcast of public service announcements (PSAs) on a radio station or television station “which serves the municipality or county in which the source is … located.” In this matter, LANL made arrangements for PSAs to be broadcast on Albuquerque radio stations (KMGA and KOBQ). LANL did not make arrangements for the PSAs to be broadcast on local radio stations, such as KRSN (1490 AM) located in Los Alamos, or KDCE (950 AM) in the Española Valley. As a result, the local communities were not properly informed of this administrative process.
  2. The Public Involvement Plan (PIP), which addresses “community participation needs for this permitting action were assessed to ensure appropriate promotion of public outreach by identifying whether there is a combination of environmental and demographic factors (i.e., low income community, minority community, limited English proficiency individual, Linguistically Isolated Households, etc.) that may impact public participation.” p. 1.

It is curious / discriminatory that the Air Quality Bureau used a 10-mile radius around TA-35 to determine the community participation needs. It does not include Pueblo de San Ildefonso and Santa Clara Pueblo. If a 50-mile were used as LANL uses in its analyses for National Environmental Policy Act (NEPA) documents, it would include many additional Pueblos from Taos to Albuquerque. LANL did not describe why a 50-mile radius was not used See the two maps at end of the PIP.

It is also curious / discriminatory that the Bureau did not use the 10-mile radius to determine the community participation needs for land grants and colonias communities. p. 8. It used a four-mile radius.

The Bureau did not explain its reasoning for using a 10-mile radius for Los Alamos County residents and a four-mile radius for land grants and colonias.

As a result of the Bureau’s choice of a limited radius, it did not find that the Public Notice would need to be translated into Spanish.

  1. I am concerned that LANL’s application does not state the room number within TA-35 where the sputtering operations will take place. That room has its own emissions stack on the roof of TA-35.
  2. The draft permit must prohibit operations of the existing lathe and the proposed two lathes at the same time. LANL states in its application that it will operate only two lathes at the same time. The permit must state that commitment.
  3. While the LANL application states that the polluted air will be pre-filtered prior to entering the single-stage HEPA filtration system, the public notice documents omits that information. Corrections must be done to the public notice documents.

Thank you for your careful consideration of my comments.

. . . . . . . . .

These two Public Involvement Plan (PIP) maps show the limited outreach done for this permit application.

In late December, LANL submitted an application to the Bureau to modify its air quality permit to add two lathes for machining beryllium to the existing lathe at the Target Fabrication Facility at Technical Area 35, near the Plutonium Facility. Scroll down to Los Alamos County, then to U.S. DOE/NNSA – LANL to Public Notice for Air Construction Permit (632M1) (posted 1/25/22). 

LANL states that it will operate only two of the three lathes at a time.  Even so, LANL is proposing to double these beryllium operations.  See Id., Original Application, p. 29 – 30 of pdf.

The existing permit allows micro-scale precision machining to manufacture small laser targets for use at the Lawrence Livermore National Laboratory located in California, as part of the Department of Energy’s National Inertial Confinement Fusion program.  

LANL also proposes to add a new coating process, called magnetron sputtering, that would take place in an unnamed room near the lathes.  Each operation would result in beryllium air emissions through stacks on the roof of the building.  See Original Application, p. 29 – 30 of pdf.

At atomic number 4, beryllium is a lightweight metal used in the nuclear weapons industry in fabricating plutonium pits, or the weapon’s trigger. 

Exposure to beryllium-containing dust and vapors can cause acute and chronic lung disease, called berylliosis, for which there is no cure.  Reports in the medical literature demonstrate that one to six percent of exposed employees are genetically sensitive to beryllium and are more susceptible to a form of berylliosis called chronic beryllium disease.  In our review of the permit application, CCNS found that LANL asked for a waiver from monitoring beryllium emissions, which the Environment Department granted in late December 2021.  See Original Application, p. 60 – 68 of pdf.  This is surprising because there are extra requirements for protecting Class I areas, such as the ambient air quality at the nearby Bandelier Wilderness Area.  See Original Application, p. 6 of pdf. 

Please see:  In response to Question 8, “Will the property on which the facility is proposed to be constructed or operated be closer than 50 km (31 miles) to other states, Bernalillo County, or a Class I area?”  LANL answered “yes,” and provided the distance in kilometers:  “Bandelier Wilderness Area (the wilderness portion of Bandelier National Monument) 0.0 km from the LANL boundary, 5.7 km from Building TA35-213.”

 

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