Tri-Valley CARES – 2007-04-20 22:03:25
Stop Dangerous Bio-Warfare Agent Research
At California’s Livermore Lab
• The Public Comment Period only runs until May 11, 2007
Email your comments to email@example.com
Important Points You Can Make in Your Comments:
I/We oppose the opening of a bio-warfare research facility (called a BSL-3) at the Livermore Lab main site.
• Advanced biodefense research (i.e., with bio-warfare agents) should not be collocated with nuclear weapons research
• 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 fault lines. The BSL-3 is a portable that was brought to Livermore Lab on a truck. This BSL-3 laboratory should not be operated in this seismically active area. The revised Environmental Assessment mentions that new research by the USGS determined there is a 62% chance that one or more magnitude 6.7 earthquake will occur in the area within the next 30 years.
Other studies predict a MM 10 shaking (very violent — on a scale of 1 to 10) to occur in the Livermore area. The revised EA mentions these facts, but does not fully account for them in conducting its hazards 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.
• The revised Environmental Assessment did not analyze the environmental and health impacts of a release of 100 liters of bio-warfare agents at one time. In fact, the revised EA failed to even disclose that other Livermore Lab and Department of Energy documents state the BSL-3 will house up 25, 000 different samples of pathogens adding up to a total of 100 liters of bio-agents at a time. Therefore, the hazard of the BSL-3 facility is far greater than the 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.
• A public hearing should be held by the Department of Energy so that the community can learn more about this plan and provide oral comments.
• The 30-day written comment period is too short. Most area residents 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 deadline should be extended for 45 additional days. And, a public hearing (see above) should occur within the extended public comment deadline.
Basic Facts About Livermore Lab’s
Bio-Warfare Agent Facility
The Department of Energy’s (DOE) Lawrence Livermore National Laboratory (LLNL) purchased a 1500 square foot prefabricated building that will house a high-level Bio-Warfare Agent Research Laboratory inside LLNL. Up to 100 Liters of bio-agents will be used there at any one time.
Researchers will aerosolize and genetically modify agents such as plague, anthrax, botulism and rabbit fever. This is a historic decision because these types of high-level agent experiments have never before been located inside a nuclear weapons research laboratory.
Where is it located?
It is located in the heart of Livermore Laboratory – a 1.3 square mile facility with nearly 10,000 on-site workers, and residential housing across the street. The DOE considers a 50 miles radius around the lab as the “affected environment” for impacts, an area stretching from San Jose to San Francisco (and including Stockton, Concord and many communities in between).
What Agents will the lab experiment on?
The lab is a Bio-safety Level 3 (BSL-3) lab, housing a level three select agents lab (level 4 is the highest and is reserved for Bio-Agents with no preventative treatment or known cure). Agents in a BSL-3 are known to cause serious or potentially lethal disease as a result of inhalation. This lab can use any “select agents” – organisms that “have historically been associated with weaponizing efforts”.
What Types of Experiments are planned?
Experiments will genetically modify these agents and aerosolize them (spray them) onto testing animals inside of special cabinets. The risks posed by genetically modified pathogens have never undergone a broad independent assessment. The lab will infect a maximum of 100 animals at a time, namely mice, rats and guinea pigs.
Scientists and policy makers are concerned that genetic modifications could accidentally or intentionally create super-strains that have no known treatment or cure ultimately resulting in bio-weapons of the future. The environmental study conducted by the lab did not study the hazards of genetic modification.
Hazards of Genetic Modification:
In Sept, 2003 UC Berkeley researchers admitted that they had accidentally created a super-strain of tuberculosis (TB) through genetic modification of ordinary TB that multiplied faster and was more lethal. US government studies have also led to the creation of extremely deadly forms of mousepox, rabbitpox and cowpox. The mousepox is impervious to anti-viral drugs and vaccines.
Hazards of Aerosolization:
Aerosolization of select agents is potentially a form of weaponizing them. A gaseous suspension of fine particles resulting from aerosolization makes these agents far more dangerous in the event of accidental occupational exposure and, in the case of failure of containment, public exposure.
Lack of Independent Oversight:
No independent regulatory agency is responsible for safety at LLNL on a continuing basis. Safety is a matter of self-regulation. This type of management hasn’t worked at other federal labs where the anthrax used in the letters to the media and government officials was most likely derived.
Dual-Use Nature of this Research:
The bio-warfare agent research at Livermore Lab is inherently dual-use. Although DOE states that this lab is purely defensive – there always remains a chance that they could be used for offensive weapons research. The “defensive research” at LLNL will be virtually indistinguishable from “offensive research”.
With the secrecy of the program, the US aversion to inspection or verification protocols at the Biological Weapons Convention, the opaque nature of the Institutional Biosafety Committee, and with the lack of independent transparent oversight, its difficult to tell what type of research will be conducted there.
Bad Public Process:
The Department of Energy is attempting to approve this new BSL-3 lab without any public hearings or a thorough environmental review. We believe that a full Environmental Impact Statement should be prepared. The Department of Energy is preparing a full EIS for a BSL-3 lab at Los Alamos. The same should be done in Livermore.
There are a number of pathways for release of these deadly agents.
HEPA air filters:
The Lab will rely upon HEPA filters to prevent environmental release of deadly bio-agents. LLNL retired physicist Marion Fulk argues that HEPA filters can be ineffective under many conditions.
The lab sits within one kilometer of the Las Positas and Greenville faults. An earthquake in 1980 injured 44 people and cost the lab many millions in structural damages. In 2004 a lab study found that 108 buildings have potential seismic problems. 22 have unacceptable risks and 41 need detailed evaluation.
History of Accidents / Spills:
Although LLNL boasts its perfect record of no recorded infections by lab workers, our investigations found that they had several mishaps in the past with their lower level, less-infectious agents where employees poked themselves with needles and possibly threw anthrax out with the general trash.
• The Centers for Disease Control and Prevention (CDC) does not formally track lab-acquired infections and all infections are voluntarily reported. As a result, we have no accurate information about infections, releases and accidents. Infections often go under-reported for fear of reprisal and because journals only publish new or unusual infections.
An estimated 60 shipments per month (in and out) will travel by commercial courier. Livermore Lab just had an incident in September, 2005, where it mislabeled and improperly packaged “select agents” (biological organisms that are historically associated with bio-warfare purposes) and shipped them to two offsite laboratories. The incident resulted in a suspension of transfers during a Centers for Disease Control and Prevention (CDC) investigation.
Over the last decade or more, the US has demonstrated that it values the secrecy of its commercial and military facilities more highly than the transparency that is needed for effective international monitoring of compliance with the requirements of the 1972 Biological Weapons Convention (BWC).
Collocation of nuclear and biological warfare agent research at Livermore Lab could lead other countries to follow-suit causing nearly insurmountable verification problems. Identifying whether a bio-lab is conducting offensive research is generally a matter of intent of the researcher since many of the experiments are the same whether they are for peaceful purposes or for developing a biological weapons program.
Tri-Valley CAREs believes that bio-warfare agent research should be conducted only as needed, and then ONLY under the auspices of civilian science centers and not inside classified nuclear weapons laboratories. Tri-Valley CAREs also calls for strengthened oversight and reporting requirements for the treaty. Tri-Valley CAREs attended the BWC meeting in December of 2004 and again in 2006.
Institutional Biosafety Committees:
Keepers of the BWC ? LLNL claims that an internal committee — the Institutional Biosafety Committee will review all projects involving high-level bio-agents to ensure that experiments comply with international prohibitions against development of bio-weapons and with all other health and safety laws.
• The National Institute of Health requires IBC’s to make minutes available to the public and recommends that they hold open meetings. LLNL’s IBC improperly withholds minutes and refuses to allow Tri-Valley CAREs to attend meetings or be alerted when they are held.
• Community Members: The lab claims to include “community members” on the IBC, however, such members are kept secret and are hand selected by the committee. According to a study of IBCs, Livermore Lab stands alone in redacting this info.
• Send money – we need to raise funds to support our efforts.
• Write letters to the editor in publications near you
• Email your comments on the revised Environmental Assessment before May 11, 2007 to firstname.lastname@example.org
• Speak out at City Council meetings – or local club meetings
• Contact Tri-Valley CAREs to get involved.
A 2nd BIO-WARFARE AGENT RESEARCH LAB HAS BEEN PROPOSED FOR SITE 300 — LIVERMORE LAB’S HIGH EXPLOSIVES TESTING RANGE NEAR TRACY.
THE SITE 300 BIO-LAB WOULD HAVE 520,000 SQ. FT. OF BSL-3 AND BSL-4 LAB SPACE ON 30–100 ACRES.
A DECISION ON WHETHER TO MOVE FORWARD WITH THE SITE 300 PROPOSAL WILL BE MADE IN JUNE 2007.
CHECK TRI-VALLEY CAREs’ WEB SITE AT www.trivalleycares.org FOR OUR PETITION OPPOSING THE BIO-LAB AND FOR REGULAR UPDATES.