Finally, in November of 1994, LANL began to screen its 1,482 permanent buildings for seismic vulnerability.  The preliminary "sidewalk screening" included some 479 buildings. Of these, a "Non-Exempt Priority List" was developed which included 169 of the "highest priority buildings" (e.g. those with potential nuclear hazards or large worker populations).  Of these 169 buildings, three, including PF-4, were subsequently given "detailed" seismic analysis. All three buildings "passed," although documents describing this analysis have not been released. ⁽¹⁸⁾

Although the PF-4 building apparently "passed" some sort of seismic evaluation, the critically-important fire suppression system that is meant to prevent a catastrophic fire involving pyrophoric plutonium metal would fail in the event of a major earthquake. ⁽¹⁹⁾   Such a fire would consume the High-Efficiency Particulate Arrestor (HEPA) filters at PF-4, probably resulting in a major release of airborne plutonium into the environment. ⁽²⁰⁾   For this reason, operational funds are now being used for design and reconstruction of the fire suppression system at PF-4. ⁽²¹⁾

The remaining 166 buildings were then assessed by a unique testing methodology developed for this occasion by LANL and its subcontractor Johnson World Controls Systems (JWCS).  Some of these buildings -- the total number is unknown to us--failed these screenings and evaluations.  Buildings which failed include the NMSF, the Tritium Processing Facility (TPF; an alias for the Weapons Engineering Tritium Facility, or WETF?) at TA-16, the Tritium Science and Technology Building at TA-21, the Sigma and other nuclear buildings at TA-3, TRU Waste Incinerator Building at TA-50, the CMR Building, and the Administration Building. ⁽²²⁾

After the bulk of these evaluations were completed, the LANL/JWCS evaluation method was peer reviewed by Degenkolb Engineers of San Francisco.  This review compared the LANL method with the well-established Federal Energy Management (FEMA) 178 method on six example buildings.  Though the two methods were described as having "reasonably good agreement" in these cases, the peer reviewers expressed a severe lack in confidence of both the LANL method and the process used to implement it:

Based on the potential for structural details to control the behavior of a building, and on the potential to over estimate the shear strength, it is our recommendation that the LANL/JCWS method be revised to somewhat reflect flexural and connection performance.  It can then possibly be used as a tool for prioritizing more detailed evaluations, but not as a means for determining the adequacy of a structure without further review.  The seismic performance of details as reflected in the FEMA 178 checklists is an important aspect of rapid screening which is so far overlooked by the LANL/JCWS method.

Due to obvious judgment required in such rapid evaluations, some form of peer review, possibly in-house, should be included in all future evaluation programs. ⁽²³⁾ (emphasis added)

According to Doug Volkman, LANL Seismic Coordinator, the suggested changes have been implemented.  Subsequent building evaluations have been done, including the NMSF, the CMR Building, and the TPF.  These buildings have "passed" these evaluations, although the nature of the evaluations have not been released and have not been submitted for peer review, contrary to the suggestions of the Degenkolb review. ⁽²⁴⁾   It should be noted that, despite "passing" this evaluation, seismic upgrades are now being done on these facilities. ⁽²⁵⁾

We do not know whether the LANL evaluations considered buildings to be constructed of ideal, or of real and as-built, materials.  For example, the concrete in the NMSF has reinforcing steel placed considerably out of specification, weakening the stiffness of the walls.  In one area, inspectors found "degraded" concrete with numerous hairline cracks, discoloration, and water seepage, all indicative of poor concrete quality.  ⁽²⁶⁾   Given that this facility is being upgraded to store up to 6,600 kg of plutonium -- this without any kind of environmental analysis -- these are non-trivial problems which warranted the cited letter from Defense Nuclear Facilities Safety Board Chairman John Conway to Assistant Secretary Vic Reis of DOE.

The most recent site plan for LANL was done in 1990.  The authors of that plan understood, in theory at least, the dangers posed by earthquakes.

Planning and development considerations with respect to the placement of facilities within fault zones focus primarily on the question of maintaining integrity of containment systems.  This question is of greatest importance regarding certain special nuclear materials and waste management facilities...

In the event of large earthquakes within the local fault systems, one must conservatively anticipate surface rupture along the fault traces.  Thus, any building built within a fault zone could be seriously damaged or destroyed by surface rupture, depending on the magnitude of the rupture.  This damage could result in destruction of containment structures...

Given these considerations, the siting of some kinds of facilities must be constrained by the location of major faults within the Laboratory.  ⁽²⁷⁾ (emphasis added)

This Plan maps the "concealed" Rendija and Guaje faults as extending completely across LANL from north to south, conservatively inferring their presence regardless of surface expression. 

Contrary to its practice at LANL, the DOE is required to conduct a "comprehensive land-use planning process with stakeholder involvement" prior to building new facilities.  This requirement is found in DOE Order 430.1, promulgated on August 24, 1995, which replaced thirteen previous orders with a single set of comprehensive "life-cycle asset management" requirements.  Although the University of California has formally accepted the requirements of this order in its contract, ⁽²⁸⁾   the local DOE office adamantly maintains that this Order is not "yet" applicable to LANL. ⁽²⁹⁾

DOE has recently chosen LANL as the site for plutonium processing and manufacturing for the nuclear weapons complex. This choice was in part based on risk analyses that assumed, for example, that the maximum release of plutonium from an earthquake at LANL would be less than 610 milligrams, and such an event was expected only about once every 100,000 years.  ⁽³⁰⁾

This choice was also based on the extensive use of old buildings, conspicuously the CMR building and the NMSF, that have failed seismic evaluations and require extensive and very expensive upgrades.

In the final analysis, even this investment will not assure that LANL facilities, and the surrounding community, are safe from earthquake hazard.  The history of the nuclear industry is replete with unexpected events thought impossible until they happened.

The seismic hazard in and around LANL is not fully understood.  Both what is known and what is not could have serious site planning and public health repercussions.  Critical information about the location and extent of a number of faults (especially the Rendija), their recurrence intervals, and their potential affect on the safety of high-risk buildings has either not been fully researched, developed, or published.  Should on-going seismic research be terminated, especially regarding the hazard at TA-55, the full extent of the hazard may not be known.  Conservative planning and design practices, as well as the requirements of specific DOE orders, are being abandoned in the rush to build nuclear facilities and produce plutonium components for nuclear weapons.

The seismic hazard in the Los Alamos area is serious enough to warrant sharp public and congressional concern over the proposed increase in storage, processing, and manufacturing of nuclear materials and the components made from them.  The safety measures in place could not confidently prevent large releases of nuclear materials in the event of earthquake and fire.  The risk analyses in the recent Stockpile Stewardship and Management Programmatic Environmental Impact Statement are inadequate.  The seismic hazards at Los Alamos should be more fully understood by geologists and engineers -- and even more so by policy-makers and the public -- prior to decisions that will increase risk to the public.