June 11, 2008

Re: http://www.dnfsb.gov/pub_docs/lanl/cor_20080516_la.pdf

Dear colleagues --

The National Nuclear Security Administration (NNSA) has not clarified the missions of the Chemistry and Metallurgy Research (CMR) at Los Alamos National Laboratory (LANL) to the satisfaction of the Defense Nuclear Facility Safety Board (DNFSB). 

In a May 16, 2008 letter to NNSA Administrator D'Agostino ("Operation and Safety of the Chemistry and Metallurgy Research Facility at LANL"), DNFSB Chairman Eggenberger expresses the Board's concern that a new Documented Safety Analysis (DSA) for continued operation of the CMR facility past 2010 is now expected to be delayed until February 2009. 

Such a delay would "leave little time [before planned CMR closure in 2010] for NNSA to complete any necessary upgrades to safety systems or identify alternative strategies for meeting national security priorities."  The DNFSB hopes NNSA will provide "an objective assessment of programmatic alternatives in lieu of rationalizing continued operations at CMR with minimal change."

The Board emphasizes "the need for a detailed definition of the scope of work proposed to continue in CMR," and repeats that "[i]t is essential that NNSA thoroughly understand the programmatic need for future activities in CMR."

"For example," Eggenberger continues, "NNSA has not identified a programmatic need to manufacture war reserve pits beyond the current campaign scheduled for completion in about 2010."  (Emphasis added.)

For the past two years if not longer this organization has repeatedly stressed that there appears to be no objective analysis of missions and associated nuclear facility requirements at LANL.  This lack of objective mission and facilities planning, in the specific case of the CMR facility and its related safety issues, is the main subject of Dr. Eggenberger's letter. 

We have also stressed that no convincing case -- apparently no case at all -- has been made for manufacturing more war reserve pits.  A Department of Defense (DoD) or Nuclear Weapons Council (NWC) order or memorandum requesting such manufacture would not in itself constitute a convincing case, but to our knowledge there is no such order.  Here the Safety Board states NNSA has not offered any pit production mission need past the current short W88 campaign.  While it is not the Board's role to analyze the validity of such a programmatic need, the total absence of one begs the question of whether NNSA is poised to assume unnecessary hazards at the CMR facility and other facilities associated with pit production. 

Going farther than the Safety Board, I believe NNSA is already incurring unnecessary, and very significant, hazards at LANL for the sake of pit production. 

I am concerned that the stated lack of objective analysis is a major factor allowing the $2.6 billion Chemistry and Metallurgy Research Replacement (CMRR) project to drift forward.  I believe it is necessary for Congress to request such a mission and facility analysis, preferably by an independent third party, and at a minimum to pause further CMRR project commitments, especially Final Design of the proposed Nuclear Facility (NF), until that analysis can be provided. 

I believe it likely that NNSA's internally-generated programmatic pit production aspirations are clouding its view of necessary CMR missions, their associated required scales, and how to maintain them.  If the entire suite of current and aspirational CMR missions were taken as an inviolable "package deal," it might appear that a large new nuclear facility were "necessary" to "replace" the CMR.  If, however, there is no need for war reserve pit production -- and there is no evidence of that -- would it be possible to meet the remaining mission needs in PF-4, LANL's several other nuclear facilities, the CMRR Radiological Laboratory, and possibly a portion of the CMR facility itself, for example a stabilized Wing 9?  No one seems to know yet. 

In the absence of a study of nuclear missions and facilities at LANL, and in particular in the absence of any stated programmatic need whatsoever for pit production, it is impossible to say if the CMRR and its related projects are justified.  Together, these projects will cost approximately $3 billion.  If continued they will absorb a disproportionate amount of management attention for another decade (or as is likely, longer).  It is truly shocking that Congress has so far funded this very large suite of projects without any analysis of alternatives, allowing the unchallenged pit production mission, which itself lacks any clear (let alone logical) statement, to obscure an underlying lack of clarity about the nature of the other CMR missions, and whether, and how, to support them past 2010. 

Sincerely,

Greg Mello
Executive Director