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STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AFFIDAVIT #2 OF GREGORY MELLO
IN SUPPORT OF PLAINTIFF'S MOTION
FOR PRELIMINARY INJUNCTION
I, Gregory Mello, declare as follows this 28th day of March, 1997:
1. I am the director of the Los Alamos Study Group ("LASG"), Santa Fe, New Mexico, which I founded and where I have worked since 1992. LASG's purpose is the study and dissemination of information related to the nuclear weapons activities of Los Alamos National Laboratory (LANL) and the other federal nuclear laboratories, and their environmental impacts. I received an undergraduate engineering degree from Harvey Mudd College in 1971. My master's degree in Regional Planning with emphasis on environmental sciences was awarded by Harvard University in 1975. At that University I worked as a teaching assistant in environmental geology. In addition to serving as an engineering consultant with a specialization in contaminant hydrology, I have worked as an supervising hydrogeologist for the Environment Department of the State of New Mexico. In 1984, I was assigned the leadership of hazardous waste enforcement activities at LANL, among other responsibilities. I conducted a number of site visits at LANL in 1984 and 1985, particularly of the waste treatment, storage, and disposal areas, and I initiated enforcement actions. In March of 1985 I completed a review of all literature concerning the geology and hydrology of LANL's radioactive waste disposal area at Technical Area (TA) 54, Area G.
2. In my capacity as Director and analyst for LASG, and as one aspect of an ongoing professional concern with the environmental risks engendered by LANL's activities, I have been attentive to the seismological safety implications of new LANL projects. Thus, I have reviewed the Final Programmatic Environmental Impact Statement for Stockpile Stewardship and Management ("PEIS") with reference to this particular concern. In order to assess the accuracy and external consistency of the data and assertions contained within the PEIS, I have gathered and reviewed the literature in this area, with particular regard to recent information published by geologists and engineers working for LANL as employees and contractors.
3. A significant portion of the new activities proposed for LANL in the PEIS and subsequent Record of Decision (ROD) will involve plutonium and will be conducted at the plutonium facilities at TA-55. Consequently, I have devoted substantial attention to seismic hazard at these facilities in particular.
4. My review of the documentary evidence was described in the attached study paper, "Seismic Hazards at Los Alamos National Laboratory with Emphasis on the Plutonium Facilities at TA-55" (Attachment 1). Most of the documents my colleague Todd Macon and I consulted for that paper (which are listed in its bibliography) were produced by LANL and its contractors; these are retained at LANL and I obtained them there. The remaining few documents in that bibliography are commonly available. The subsequent paragraphs of this affidavit summarize the findings of that paper.
5. Los Alamos National Laboratory (LANL) is located astride the Pajarito Fault System (PFS), an active and capable fault system containing 25 faults that have been identified as potential seismic sources capable of generating significant ground shaking. Ground shaking hazard at LANL is higher than might be indicated by the historical record and therefore higher than is commonly believed possible. Earthquakes could occur at LANL at Richter magnitudes up to an estimated 7.0. Overall, the seismic hazard at LANL is not fully investigated, and the surface investigations now being done have not, and indeed cannot, fully delineate this hazard. This is because not all capable faults have surface expressions.
6. The plutonium storage, fabrication and research facilities at Technical Area (TA) 55 are very near, if not directly over, an active fault (the Rendija Fault) which LANL geologists believe is capable of producing a 6.5 Richter magnitude earthquake. Such an event is capable of producing not just ground acceleration but also surface rupture, which can produce localized stresses on buried structures (e.g. fire suppression and electrical supplies) and building envelopes in excess of those generated by acceleration alone. The DOE believes that the probability of surface rupture at TA-55 is "sufficiently remote" (Attachment 2, p. 3). Ongoing studies are probing this risk further, and increased risk of rupture could invalidate current safety assumptions.
7. Despite the known hazard and uncertainties surrounding it, DOE maintains in the PEIS that its operations are essentially completely safe from significant seismic hazard (PEIS, p. F-25). Contradicting this claim, at least nine and possibly a great many more major LANL buildings, including its principal nuclear materials facilities, have failed seismic evaluations. For example, the Nuclear Materials Storage Facility (PF-41) has failed a detailed dynamic evaluation. While the Plutonium Facility (PF-4) structure has passed an evaluation, PF-4's current fire suppression system would definitely not withstand a quake. Building evaluations conducted by the Lab to determine earthquake vulnerability have been criticized by external reviewers.
8. The effects of seismic activity at LANL could include building collapse, fires, release of significant quantities of nuclear materials, blockage of emergency routes, temporary loss of function of the local hospital, loss of life, and environmental contamination.
9. DOE has recently tasked LANL to correct numerous deficiencies at PF-4 to bring that facility into a safe operating condition (Ibid, pp. 23-28). For instance, seismic upgrades to gloveboxes, hoods, and associated pass-throughs must be completed within 60 days of the latest Safety Evaluation Report approval date. LANL is also required to verify that gas pipe mountings, vault racks, and waste storage racks can sustain an Evaluation Based Earthquake (EBE). Prioritized upgrades to approximately 50 additional gloveboxes must be completed by March 31, 1997. Cracks of unknown origin and effect have been found in PF-4 walls which LANL is recommended to investigate. LANL is requested to replace its current Evaluation Based Earthquake safety report and analysis after the findings of requested new studies are available (Ibid, p. 7).
I declare under penalty of perjury that the foregoing is true and correct. Executed this 31st day of March, 1997 at Santa Fe, New Mexico.