[NukeNet] URGENT: Sign & email this comment letter opposing a Bio-warfare Agent Research Facility at Livermore Lab's main site

[Marylia Kelley]

URGENT: Send a comment on the revised Environmental Assessment on or before
Friday, May 11, 2007.

You may use the text below as your comment. Or, you may edit it as you like
and then send it. The important thing is to SEND IT.

If you do use the letter provided below, be sure to include your name and
address at the end -- and do send it directly to DOE.

Comments can be submitted by by mail, email or fax to --
Samuel Brinker,
National Environmental Policy Act Document Manager
 U.S. Department of Energy,
 National Nuclear Security Administration,
 Livermore Site Office, M/S L-293,
 P.O. Box 808, Livermore, CA 94551-0808

 email: samuel.brinker at oak.doe.gov

 fax: 925/423-5650


I oppose a bio-warfare research facility (called a BSL-3) at the Livermore
Lab main site because:

   *      Advanced biodefense research (i.e., with bio-warfare agents like
live anthrax and plague) should not be collocated with nuclear weapons
research. If the U.S. mixes "bugs and bombs," it could complicate
enforcement of the Biological Weapons Convention, the international treaty
banning bio-weapons.

    *      Livermore Lab sits within a 50-mile radius of seven million
people. This highly populated area is not an appropriate place to conduct
experiments with some of the deadliest agents known.

    *      Livermore Lab is located near active earthquake fault lines. The
BSL-3 is a portable building that was brought to Livermore Lab on a truck.
This BSL-3 should not be operated in a seismically active area. The revised
Environmental Assessment states that new research by the USGS has
determined there is a 62% chance that one or more magnitude 6.7 earthquakes
will occur in the area within the next 30 years. Other studies predict a
quake with MM 10 shaking in the Livermore area (which is very violent  
the scale is 1 to 10). The revised EA briefly mentions these key facts, but
does not fully account for them in conducting its hazard analysis.

     *      The revised Environmental Assessment does not do an adequate
job of analyzing potential terrorist threats. For example, it too
optimistically assumes that most bio-agents would be destroyed in a
terrorist attack, and therefore not many would escape into the environment
and pose a hazard to workers and the community.

      *      The revised Environmental Assessment does not analyze the
environmental and health impacts of a release of the BSL-3's total
inventory of up to 100 liters of bio-warfare agents. In fact, the revised
EA fails to even disclose that other Livermore Lab and Department of Energy
documents state the BSL-3 facility will house up 25,000 different samples
of pathogens adding up to a total of 100 liters of bioagents at a time.
Therefore, the hazard level posed by the Livermore Lab BSL-3 is far, far
greater than the revised EA considers.

      *      The revised Environmental Assessment suggests that a potential
terrorist would rather try to find dangerous pathogens in nature than
attempt to steal them in larger, more concentrated quantities from the
Livermore Lab BSL-3. That assumption is absurd.

    *      The Department of Energy (DOE) should hold a public hearing so
that the public can learn more about this plan and provide oral comments.
So far, the number of public hearings that DOE has held on this important
issue is ZERO.

    *      The 30-day written comment period (which ends May 11, 2007) is
too short. Most area residents and other interested members of the public
don't know about the comment period. It has not been widely publicized by
the Department of Energy or Livermore Lab. Therefore, people are being
deprived of their right to comment.

    *      The written comment deadline should be extended for a minimum of
one additional month (to June 11). And, a public hearing (see above) should
occur within the extended public comment deadline.


* 	Please send me verification that you have received these comments
and that they will be included in the record.



My Additional Comments:






 Sincerely,
                   

Name:



Address:



City/State/Zip Code:



____ I DO want a copy of the final revised EA sent to me.

___ I DO NOT want a copy of the final revised EA sent to me. Send me only
the web url. Thank you.

Marylia Kelley,
Executive Director

Tri-Valley CAREs
2582 Old First Street
Livermore, CA  94551

Ph: (925) 443-7148
Fx: (925) 443-0177
Web: www.trivalleycares.org
Email: marylia at trivalleycares.org or marylia at earthlink.net