For immediate release 4 June 2019

Initial press release; an update may follow after today’s House Armed Services Committee Strategic Forces Subcommittee (HASC/SF) markup, beginning 3:30 pm EDT (webcast)

Administration to conduct environmental analysis of plutonium warhead core (“pit”) production in SC; may analyze NM production; NNSA’s plan may violate 1998 court order and other applicable law

Contact: Greg Mello, Los Alamos Study Group, 505-265-1200 office, 505-577-8563 cell

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Albuquerque, NM – The National Nuclear Security Administration (NNSA), the nuclear production and nonproliferation arm of the Department of Energy (DOE), announced today its intent to prepare an environmental impact statement (EIS) under the National Environmental Policy Act (NEPA) for plutonium warhead core (“pit”) production at the Savannah River Site (SRS) in South Carolina.

Pit production at Los Alamos National Laboratory (LANL) – together with minor supporting activities and non-nuclear component production at other NNSA sites – will be the subject of a NEPA “Supplement Analysis” (SA), meaning that NNSA will analyze whether or not to conduct further environmental analysis of these activities.

The most recent analyses of pit production were the 2008 Complex Transformation Supplemental Programmatic Environmental Impact Statement (CTSPEIS) and 2008 Site-Wide Environmental Impact Statement (SWEIS) for LANL. Both concluded with records of decision (RODs) that limited pit production to a maximum of 20 ppy, at LANL alone.

The significant legal issues which underlie NNSA’s announcement were summarized in a February 2019 letter to NNSA and Pentagon officials from this organization, as well as previously. The issues which led to the 1998 stipulated order regarding pit production are summarized in this affidavit.

Study Group director Greg Mello: “NNSA’s decision to conduct an environmental impact statement process for its pit production plans for the Savannah River Site, while postponing a decision on whether or not to conduct a fresh nationwide analysis including LANL, appears deeply flawed. DOE settled a lawsuit brought by our organization and others with a stipulated order to produce a nationwide analysis if its pit production plans changed sufficiently. They have changed dramatically.

“In addition NNSA has for two decades, through four formal decisions, declared it would not exceed a production rate of 20 pits per year at LANL, in a sharply-bounded space – 11,400 square feet – within its aging and troubled main plutonium facility (Building PF-4). The impacts of higher production rates and more expansive plans have never been analyzed, except under unrealistic assumptions and conditions which NNSA acknowledges no longer apply or exist.

“DOE must do better. We urge DOE and NNSA to proceed directly, without delay, to the nationwide analysis DOE previously agreed to conduct should the day ever come when pit production would be pursued at more than one site, or at a larger scale, than was agreed in federal court in 1998.”

Today’s announcement came in a letter to New Mexico Senator Martin Heinrich, the text of which (as supplied to us this morning) is appended below. Formal publication in the Federal Register is expected on June 10.

NNSA and its consultants have long assumed, and NNSA Administrator Lisa Gordon-Hagerty has stated in congressional testimony, that at least some kind of NEPA analysis would be conducted, but the particular type and depth of NEPA analysis – at SRS, LANL, or nationwide – has not been specified until now.

If conducted properly and in a timely fashion, NEPA analyses have not been expected to be on the critical path for the SRS or LANL pit production projects. (See NNSA’s 2017 Pit Production Analysis of Alternatives [AoA], pp. 60-61, and 2018 Engineering Assessment [EA)] p. 4-6.)

If pursued, pit production at SRS would be centered in the proposed Savannah River Plutonium Processing Facility (SRPPF), which would be fashioned by repurposing the partially-constructed Mixed Oxide Fuel Fabrication Facility (MFFF). NNSA hopes to produce a minimum of 50 pits each year at this facility in single-shift operations, or 84 pits per year (ppy) on average (p. 13).

Pit production at LANL would be centered in the 41-year old PF-4, built in a different era, with a still-incomplete suite of safety features, for different purposes. NNSA proposes to build 30 ppy in PF-4.

NNSA has requested (p. 122) $410 million (M) for SRPPF for fiscal year (FY) 2020, to complete conceptual design. In April, NNSA said it believed SRPPF operations could begin in the FY2026-2028 timeframe. A 2017 NNSA study and a spring 2019 study by the Institute for Defense Analyses (IDA) for the Pentagon (reviewed here) both said, however, that such a deadline would be nearly impossible.

The text of NNSA’s announcement, as received:

The Administrator of the National Nuclear Security Administration (NNSA), Lisa Gordon-Hagerty, has signed a Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS) to evaluate plutonium pit production at the Savannah River Site (SRS) in South Carolina (the SRS EIS). The NOI will be posted in the Federal Register on Monday, June 10, 2019.

[P]lutonium pits are a key component for nuclear weapons, yet the United States’ current capability to produce them is limited.

Several factors drive the need to produce pits, including: the need to enhance safety features to support a modern deterrent, mitigate against the risk of pit aging, and provide the ability to respond to changes in deterrent requirements resulting from renewed peer competition. To address these needs the 2018 Nuclear Posture Review echoed previous administrations’ calls to revitalize this capability, stating the United States must “provide the enduring capability and capacity to produce plutonium pits at a rate of no fewer than 80 pits per year by 2030.”

Given this imperative, revitalizing plutonium pit production has become one of the most important missions in NNSA history. In May 2018, NNSA announced its proposed preferred alternative for pit production to begin conceptual design and outline the steps toward the next milestone in this long-term effort.

The preferred alternative, endorsed by the Nuclear Weapons Council, is to produce 30 war reserve pits per year at Los Alamos National Laboratory (LANL) beginning in 2026 and repurpose the former Mixed Oxide Fuel Fabrication Facility at the Savannah River Site (SRS) to produce 50 war reserve pits per year by 2030. This two-site approach would ensure resiliency, robustness, and flexibility for decades to come.

NNSA is committed to meeting its obligations under the National Environmental Policy Act (NEPA) as it carries out its obligation to establish this capability. Because pit production using the former MOX facility has not previously been analyzed, NNSA will prepare an Environmental Impact Statement for the proposal to produce a minimum of 50 war reserve pits per year at SRS. NNSA will also analyze the environmental implications of the 80 pits per year pit production mission complex-wide. Because extensive NEPA analysis of pit production on a complex-wide basis has previously been performed, NNSA will prepare a Supplement Analysis to determine whether that analysis remains adequate or not.

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