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Previously: Bulletin 261: Public discussion, July 25: “The Steepest Time: Youth and Crisis at the End of an Age,” July 18, 2019

Bulletin 262: New Mexico Democrats push Trump nuclear weapons agenda regardless of environmental costs, suborn NM Environment Department to blackmail DOE into more LANL pit production and warheads

July 24, 2019

Dear friends and colleagues –

First, a reminder: if you are in or near Santa Fe, don’t forget the upcoming public discussion tomorrow. It will be an interesting and energizing discussion. My (Greg’s) part will be sharply strategic and direct, not technical.

At this point you may want to skip to the bottom of this Bulletin and read the last three paragraphs, then return to here and skim the text, looking first at the bolded text. You may want to prioritize looking at the short videos of our senators throwing the Governor’s weight around. Next, you might read some of the non-technical references that immediately follow. If you want to truly empower yourself, read them and this Bulletin thoroughly. If you want or need to be more deeply involved, check out the links and the end notes.

Here are some recent non-technical resources on pit production not previously shared, which can be useful as references for national security professionals and interested citizens alike.

• Plans for plutonium pit production at LANL as part of a more than a trillion dollar weapons program, Cultural Energy interview(KCEI, Taos and northern NM, host Robin Collier), Jul 16, 2019


• National Environmental Policy Act (NEPA) compliance for plutonium pit production, LASG letter to Senator Udall, Jul 8, 2019 (Especially important for New Mexicans; all necessary background is linked within.)


• Industrial pit production at LANL: mistaken mission, wrong place, Greg Mello, Los Alamos Monitor, Jun 30, 2019


• Plutonium won’t bring prosperity, just ruin, Greg Mello, Santa Fe New Mexican, Jun 29, 2019


• Nuke-Backing NDAA [National Defense Authorization Act] Passes Senate in Landslide, Dan Leone, Exchange Monitor, Jun 28, 2019. Includes a discussion of the bipartisan pit production amendment by Martin Heinrich and Lindsay Graham in its context. We cannot include a discussion of all the nuclear aspects of the NDAA, now awaiting House-Senate negotiations (in which the hawkish Senate holds the stronger hand) in this Bulletin, as interesting and useful as that would be.


• Guest Column: Los Alamos is unsuited for pit production, Greg Mello, Aiken Standard, Jun 26, 2019


• We don’t need more pits, LANL can’t make them, Greg Mello, Albuquerque Journal, Jun 17, 2019


• Administration announces plan to conduct environmental analysis of plutonium warhead core (“pit”) production in SC, No comparable commitment in NM, LASG press release, Jun 10, 2019

Pit production is repeatedly described by the Trump Administration’s nuclear warhead agency, the National Nuclear Security Administration (NNSA), as its highest priority (video). In Bulletin 258, we told you why.

Now to our main subject.

The New Mexico congressional delegation – and apparently also Governor Michelle Lujan Grisham, according to both senators – have variously been working against most House Democrats to make sure that –

• The Administration’s “requirement” to start producing “at least 80”[1] plutonium warhead cores (“pits”) per year (ppy) by 2030, the need for which is contested by the Democratic majority in the House, becomes statutory law; as far as we know this is Senator Heinrich’s particular contribution; and


• All these pits, however many there are, are produced at Los Alamos National Laboratory (LANL).

Make no mistake. Pit production, especially at 80 or 80+ ppy, would be a gigantic program with gigantic costs[2] (over time, tens of billions of dollars, the exact cost dependent on the scale, whether modern safety standards are ever finally met, and on the remaining service life of key buildings, which is still unknown). It would have great risks to workers, other programs, legacy waste removal, the public, and tribes, and would have heavy environmental impacts no matter where it takes place. Even a “modest” 30 or 30+ ppy program implies major environmental impacts, given the actual (not idealized) LANL situation.

At LANL the impacts would, in our estimation, be catastrophic to the town as well as the Lab.

The environmental impacts could easily include failure to ever move the huge backlog of transuranic waste off “The Hill.” This backlog stands at about 20,000 drums: those stored at Area G, plus the roughly 1,000 drums at PF-4, plus the drums stored outside at TA-55, plus those stored at the Transuranic Waste Facility. In other words, a big part of LANL “cleanup” could halt.

LANL’s director Thom Mason has just now started to lift the veil on the new offices and parking garages needed to house a growing production staff. Many of these would presumably be located in or near the crowded TA-55 plutonium complex and related TA-50 and TA-63 wasteplexes in the center of LANL.

Mason also stated that some of the new LANL facilities so urgently needed might be leased from private developers. Intriguingly, at about the same time Rep. Ben Ray Lujan recently introduced an amendment to facilitate movement of LANL activities into leased facilities, which was killed (for now) by the House Rules Committee because it could commit the federal government to large unfunded outlays for decades to come.[3]

The non-nuclear facilities mentioned by Mason would be just part of the first wave of supporting facilities in the larger industrial infrastructure required. Much of LANL – still mostly a research laboratory – would be transformed into a nuclear factory complex, with ramifying social, cultural, and political impacts, first and foremost in Los Alamos itself. It would have lab- and region-changing consequences. Pit production is not "just another lab program."

Hiring has already begun, at a rate of about 1,000 persons per year (about half are net new employees), joining local retirement as a cause of tightening local housing markets. Los Alamos County is responding with a residential building boom.

Where in all this, you might ask, is the plan for pit production at LANL? Is there a plan?

As far as the public, state, and tribes are concerned, there is no plan. There is supposed to be a plan – actually two of them, one for “30” (or is it 30+?) ppy and one for 80+ ppy – but neither have been released in any form.

It is likely NNSA and LANL are reluctant to release these plans because a) so far every plan for expanding pit production at LANL has collapsed under outside scrutiny (i.e. they have been more or less loony), and b) the 80 or 80+ ppy ambition for LANL is flat-out contradicted by NNSA’s own reports and testimony.

Our NM Democrats are helping the Trump Administration keep both these plans (or “plans”) under tight wraps, while also helping the Administration keep two very important recent unclassified studies of pit production by the Institute for Defense Analyses (IDA) away from public and journalist eyes – which in practical terms means, away from most members of Congress. (That’s four key documents being sequestered, if you are counting.)

We were able to obtain the executive summary of the larger of the two IDA studies, the one for DoD, which said (among other very interesting conclusions) that large-scale pit production might not be possible at all (p. v), a conclusion with which we agree (pp. 4-5). The other executive summary (largely a subset of the first) was subsequently posted by NNSA. Fortunately, we were able to brief the IDA team leaders as they began their studies.

Ironically, it was the NM delegation which successfully introduced the amendment requiring the IDA/DoD study (see §3120(b)). In more than one sense, they own it. Why can’t the public see it?

The NM Democrats are also utterly silent on the twin questions of whether a) any national environmental impact analysis of pit production – currently planned for two sites (LANL and the Savannah River Site, SRS, in South Carolina) – needs to be done, and b) on the question of whether a site-wide environmental impact statement (SWEIS) process at LANL needs to be done.

Don’t they care about the environment? Apparently not in this case (and many others we could name), not if there is a chance environmental considerations could derail support of the Trump nuclear weapons agenda.

NNSA has agreed to conduct an EIS at SRS but not at LANL (same-day analysis; formal notice; see also here), and thanks to previous litigation NNSA is under a court order to produce a national analysis. Four previous Department of Energy (DOE) decisions (Sept. 20, 1999, Sept. 26, 2008, Dec. 19, 2008, and July 10, 2009) limit pit production at LANL to at most 20 ppy, a fact which DOE concedes (p. 26851).

We believe the National Environmental Policy Act (NEPA) requires all three studies – fresh local studies at SRS and LANL as well as an updated national analysis. New NEPA analysis ought to be a "no-brainer" – even for senators and a congressman who love the pit mission and want it expanded as much as possible at LANL – indeed far beyond what is possible, apparently.

We have asked for help from our senators on these matters multiple occasions, most recently here. We believe that, because of their powerful positions in the Senate, they have the power to resolve both of these good-government, policy-neutral issues – transparency and environmental analysis. Martin Heinrich is the Ranking Member of the Strategic Forces Subcommittee of the Senate Armed Services Committee, with jurisdiction over the NNSA; Tom Udall is the #2 Democrat on the powerful Energy and Water Subcommittee of the Senate Appropriations Committee, again with jurisdiction over NNSA.

We hear only crickets from them, as the saying goes.

We’ve also asked congresspersons Ben Ray Lujan and Deb Haaland for help. Again we get only silence.  

We’ve asked the Governor, who is very aware of these issues and who has met with DOE officials to discuss some of them. Same non-response.

For NNSA, doing the required NEPA analysis sooner rather than later should be their game plan – unless they have things to hide. Their problem is that they have plenty to hide. Their requirements conflict with their own official reviews and with the realities of the LANL site. On April 9 of this year, NNSA said (three times) to the House Strategic Forces Subcommittee that the 80 ppy mission could not be accomplished at LANL.

Only at LANL are facilities planned – and promoted by our senators and representatives – that admittedly do not meet modern nuclear safety standards for workers (slide 29). Some safety features take up space. At TA-55, space is at a premium. LANL’s proposal for underground “modules” at TA-55 “solves” this problem by not even attempting to meet all nuclear safety standards, saving space and lowering costs. Since the “modules” would be underground, public exposures in a serious accident would be minimal, at least in theory. Only workers would be harmed. No statute protects them.

As many of you know, local governments have been outspoken on environmental impacts of LANL and of this mission in particular, which essentially all previous New Mexico political leaders and LANL itself opposed.

So what we have here in New Mexico is a potentially gigantic, unprecedented program being pursued with unprecedented opacity.

It gets worse.

New Mexico political leaders have threatened to shut down DOE's plutonium disposition program if the whole 80 (or 80+) pit production program is not given to New Mexico (see video excerpts of Senate hearings here, here, and here). Our senators express themselves in the language of gangsters, claiming they will suborn the New Mexico Environment Department to force DOE to give LANL the whole pit mission to LANL by denying extension of the Waste Isolation Pilot Plant (WIPP) operating permit in whole or in part, as if that was a normal and ethical thing to do. The senators say the Governor has already had conversations with DOE about her “concerns.”

Ironically, the program New Mexico Democrats are threatening to halt is the permanent disposal of diluted surplus plutonium, about half the total U.S. stockpile, enough to make roughly 15,000 warheads. The purpose of WIPP is the disposal of plutonium waste from the weapons program, which this is.

The New Mexico Democrats seem indifferent to the fact that the pit mission itself proceeds from a Pentagon which is, as it always has been, considering using nuclear weapons in war. Pits age, but there is no current “pit aging problem” in the stockpile. The “problem” stems from artificial stockpile requirements, the source of which lies in cult-like ideology and the material interests of warhead contractors, especially at LANL and Lawrence Livermore National Laboratory (LLNL), which is designing the only warhead that requires new pits, a much-desired funding stream for that lab.

In the late 19th century Archbishop Lamy built Santa Fe's cathedral. In the early 21st century our senators and Governor now want to build a nasty "Notre Doom" on The Hill.

All this is particularly disappointing and perverse in the case of Senator Udall, given his father's late-career crusade. What a sad legacy he is making for himself (and all of us) with this.

Speaking now especially to New Mexicans, we would like you to write to our senators, Governor, and congresspersons, in open letters to editors or in other open settings, asking for full transparency about pit production and for both national and a local environmental impact statements under NEPA. Especially in northern New Mexico, we’d like you to ask local government and tribal officials to contact these same senior elected people, with the same message. They don’t have to take a stand against pit production, although that would be nice – just the fascist way it is being shoved down New Mexico throats, with zero public and tribal input. We are not using that f-word word lightly.

There is much citizens in other states can do right now as well. In general terms, get your senators and representatives to support the House version of the NDAA, which cuts back the proposed dramatic increase in warhead spending overall and in particular programs like pit production. It’s late in the legislative year, of course.

We will film and post tomorrow’s talks, which will go into broader strategic issues, and send them out promptly with supporting materials. The challenge of nuclear weapons – and within them, pits – cannot be properly or effectively addressed without seeing and acting in the broader context of the existential emergency faced by humanity as a whole.

Sincerely,

Greg Mello and Trish Williams-Mello, for the Study Group

[1] NNSA estimates that the Nuclear Weapons Council’s (NWC’s) requirement of “at least 80 pits in 9 out of 10 production years” will result in an average production rate of 103 ppy, 29% more than a simple “80 ppy” would seem to imply. We abbreviate the current requirement as “80+” ppy to distinguish it from an average of 80 ppy. By the same token, if the “30” ppy at LANL – currently, a statutory requirement, to be achieved by 2026 – is required to contribute to the “at least 80” ppy overall by 2030, as proposed by the Administration last year and also presumably in this year’s Heinrich-Graham amendment, it must also be “at least 30” ppy, by which NNSA means an average of 41 ppy, 37% more than a plain-language “30” ppy. So which is it? We don’t know. See p. 13 in NNSA’s Pit Production Analysis of Alternatives for an unclassified explanation of the NWC’s current requirements and NNSA’s production estimates.

[2] Capital costs for an 80+ pit production capability were estimated by NNSA as $1.4 - $7.5 billion (B) in 2018 dollars for a single production site. LANL was at the high end, not including the estimated $3 B needed upfront for LANL to achieve 30 pits per year (ppy) by 2026.

Just one small part of this, the Radiological Laboratory Utility and Office Building (RLUOB), is the most expensive construction project in New Mexico history, at $1.4 billion.

In 2018, fifty-year life cycle costs (LCCs) for pit production were estimated to lie in the $14-28 B range if not twice that much as the authors are careful to explain, with LANL at the low end but not including replacement or life extension of LANL's main plutonium building PF-4, a fact which the New Mexico delegation and House Democrats (video) love to omit. NNSA Administrator Lisa Gordon-Hagerty pointed out this omission in her testimony (video) before the Senate Armed Services Strategic Forces Subcommittee on May 8, 2019.

In light of the unreleased IDA/DoD report these estimates are apparently obsolete, as Senator Heinrich has stated (video).

Replacement of the 41-year-old PF-4, if possible at all, would be at least a $10 B undertaking ($152,000 per useful square foot in 2011 which must be inflated to today's costs, multiplied by 60,000 square feet (e-page 254) plus some part of the roughly 36,000 sq. ft. (p. 44) needed for an 80 ppy production mission if that is also required, plus roughly $1 billion for security (p. A-7), plus an unknown amount for support buildings, utilities, radioactive waste handling, offices, parking, and roads at any new site, plus some sort of demolition and disposal for the contaminated PF-4 building and its contents, plus transition costs for the programs involved.

On the other hand PF-4 life extension, i.e. continued operation, is also an unknown and fraught prospect. The House version of the fiscal year 2020 National Defense Authorization Act requires (p. 341) replacement and life extension, both, to be studied by the end of this calendar year.

In our view, PF-4 should be made as safe as possible for existing missions, not industrial pit production, and conserved, not driven to early failure as is quite possible if pit production is pursued.

[3] That, of course, was the whole idea. Leasing allows off-budget cost growth, allowing present-day program expansion beyond current funding levels. At the same time, private real estate interests are enriched and DOE project management rules avoided. In effect, the prerogatives of the absolute weapon are leveraged into risk-free, long-term private rents.

This is not a new idea. In the waning days of the G.W. Bush Administration, a proposed $250 -$400 million, three-building “Los Alamos Science Complex” (LASC) was planned for a 16-acre parcel within TA-62, north of West Jemez Road, to house some 1,500 LANL staff. A developer was chosen and the project came within months of being built, only to be killed at the last moment by alert Senate staff.

In general, we do not think leased buildings are appropriate for the nuclear weapons enterprise, especially if used as "warehouses, light laborator[ies], or "other similar use[s]" as in Lujan’s amendment, especially if these buildings do not already exist.

At the Kansas City National Security Campus (KCNSC), the serious space problems experienced are, in our view, the result of a) an inappropriate and unnecessary lease arrangement, which put KCNSC into a facility that was too small, tilting the scales toward leasing over a government-owned building (new or reconditioned), b) over-optimistic assumptions about outsourcing, necessary to the leasing business plan, and especially c) an inappropriate and unnecessary schedule for warhead Life Extension Programs (LEPs), which is also creating a boom-and-bust staffing problem as well as round-the-clock production in some product lines.

In the Kansas City case, the GAO found that leasing was only cost-effective compared to owning and building when compared over an unrealistically short period of 20 years. Short comparison periods will favor the cheapest, worst buildings, with higher operating costs. NNSA has been using 50-year life-cycle costs to compare pit production facilities.

There has long been talk – and a growing number of examples – of an even more privatized nuclear weapons complex, where private developers own more facilities and lease them to NNSA, with management by other private contractors as is now the case. NNSA would be in the middle, absorbing all the liabilities and risks, fronting for money in Congress, and owning the land. The plums in this model are non-nuclear facilities which will not become contaminated and hence pose no risk to lenders.

Low or near-zero interest rates, which make price discovery impossible, put a thumb on the scales in any analysis of lease vs. buy alternatives. At near-zero interest rates it may seem better for the government to lease and for developers to build, using Other Peoples’ Money. But whether financed by federal debt or private debt, the illusion of free money hides the true costs of expansion. All the more reason, then, to conduct a high-quality, fresh NEPA analyses, which at their best can illuminate some of the non-pecuniary costs of projects.