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Permalink for this bulletin. Please forward! Bulletin 266: US plutonium pit production plans advance, with new requirements (part I)
January 31, 2020 Dear friends and colleagues – Just before Christmas we wrote a detailed summary that would bring those most interested in warhead core ("pit") production more or less up to date on some of the key issues. Part II, covering more pit production and related issues, will come next week. Part III will come after the President's budget request to Congress (expected February 10). A somewhat less detailed article is also in the works. Meanwhile there's a lot of other news, which must wait. (Some has been sent to our "Friends" list, where our most frequent updates usually happen -- to subscribe send a blank email here!) Best wishes to all, Greg Mello, for the Study Group US plutonium pit production plans advance, with new requirements (part I) 12/23/19, with a minor update to 1/31/20 A portion of this December 2019 update was published at http://fissilematerials.org/blog/2019/12/us_plutonium_pit_producti_2.html. Additional content from us is now pending there, but space is limited. New requirements, funding There are new requirements for U.S. plutonium warhead core (“pit”) production in the recently-passed fiscal year (FY) 2020 National Defense Authorization Act (NDAA, S. 1790) and in the relevant FY2020 appropriations “minibus” for National Nuclear Security Administration (NNSA) programs (H.R. 1865, in Division C). Congress fully authorized and funded (e-p. 101) the Administration’s $712.44 million (M) request for pit production (“Plutonium Sustainment”) at two main sites: the Los Alamos National Laboratory (LANL) and the Savannah River Site (SRS). The new NDAA also gave statutory force to the Administration’s requirement to produce, “during 2030, not less than 80 war reserve plutonium pits” (§3116, pp. 754-5). In the process, an impossible requirement to demonstrate, for 90 days, an 80 pit per year (ppy) production rate by 2027 was stricken. At the same time Congress also required new pit production reports, adding to those it already requested but never received, to be listed shortly. Meanwhile Congress expressed again its abiding concerns about the sole proposed warhead which would use new pits, the W87-1. That warhead is scheduled to begin production and deployment in 2030 (e-pp. 79-81) on the proposed Ground-Based Strategic Deterrent (GBSD), which would replace the current Minuteman III land-based ballistic missiles. GBSD was almost fully funded in the FY2020 NDAA, at $552.4 M. An annual report on GBSD and W87-1 progress – including acquisition and operation of pit production capacity – is required (§31671, pp. 578-9), beginning in February 2020. The W87-1 would replace one of two Minuteman warheads, the W78. In the FY2020 NDAA (at §3135, pp. 762-3), defense committees require, in the late July 2020 timeframe, a “discussion of alternatives considered with respect to replacing the W78 warhead, including…technical risks, schedule, and costs.” The same section also requires the JASON defense consultants to analyze the W87-1 plan by May 2020, assessing certification risks as well as the threshold need for any upgrade to the existing W78 warhead. Both reports should come in time for next year’s authorization and funding decisions. Appropriators also require (e-p. 85) a detailed report from NNSA on W87-1 major design decisions, their costs, the major program risks with associated contingency plans – including the major risk that pit production will not meet the required schedule – as well as the status of technology and manufacturing readiness. The last 25% of the funds provided ($112.011 M for FY2020) are to be held back until the report is received. Appropriators unambiguously placed (e-p. 86) the acquisition of pit production capacity at both LANL and SRS under the Department of Energy’s (DOE’s) project management rules (DOE Order 413.3B) as a single project at each site with multiple sub-projects, to provide greater structure and accountability to both multibillion-dollar projects. Among other requirements, this Order requires formal clarity and commitments on a wide range of project parameters before construction can begin (e-pp. 30-34). Presumably this new “projectized” structure – long desired by appropriators, oversight agencies, and NNSA’s own acquisition and project management team – will appear in the Administration’s FY2021 budget request, traditionally expected on the first Monday in February. In addition, appropriation committees now require (e-p. 86) quarterly progress briefings on LANL’s progress in achieving an initial capacity of 10 ppy (required by 2024), on the two sites’ projects to acquire capacity beyond 10 ppy, and on how lessons learned from the Uranium Processing Facility (UPF) project, which (after being scaled down in 2014) now appears to be proceeding more or less on track, are being applied to plutonium work. Lack of transparency, confusion over requirements continues Despite these new requirements, which may or may not be satisfied or lead to effective oversight, there is very little clarity as to what NNSA’s plans for pit production actually are, except in the most general terms. Congress nearly doubled Plutonium Sustainment spending this year ($361 M in FY2019 to $712 M in FY2020) without resolution of some contradictions and issues in the program, and without public transparency. Last year, Section 3120 of the FY2019 NDAA, introduced by the New Mexico congressional delegation, requires LANL to “implement surge efforts to exceed 30 pits per year.” It also requires a number of reports, none of which have seen the light of day. The valuable executive summary of the “independent assessment of plutonium strategy” required under subsection (b), written by the Institute for Defense Analyses (IDA), was at first leaked and later supplied under the Freedom of Information Act (FOIA). The full report, which unlike the executive summary is Unclassified Controlled Nuclear Information (UCNI), a relatively comprehensive treatment of pit production challenges and options, remains sequestered as of this writing, as does the corresponding report written for NNSA by IDA (Executive Summary). Detailed plans required under subsection (c) for producing 30 ppy and 80 ppy at LANL were not supplied to Congress until late this year, well after committee markups – if they were produced at all. And as of October, when the Government Accountability Office (GAO) published an important study concerning a key step in NNSA’s surplus plutonium disposition (SPD) program, NNSA apparently had not assessed the apparent contradictions between its SPD and pit production programs, also required by this subsection. Those contradictions remain unresolved, as discussed below. The required transparency, certification, and backup plans and schedules (subsections d, e, and f) were also partial, late, or possibly never submitted at all. Also last year, Senate appropriators required (p. 104) an unclassified assessment by the JASON group (with a classified annex as appropriate) of plutonium aging, the minimum and likely lifetimes of plutonium pits in nuclear weapons, and the feasibility of reusing pits in modified nuclear weapons. As of this writing that important study, which should be complete or nearly so, has not yet been given to Congress. In addition to the above requirements, last year appropriators required (pp. 165-166) a detailed report on the “scope, costs, and schedule required to meet [NNSA’s] pit production targets,” as well as “a project data sheet for the Plutonium Pit Production Project.” To the author’s knowledge, neither were ever created. Both of these requirements are now superseded by the new project structure and oversight plan in this year’s legislation and detailed above, which will hopefully be more lasting, meaningful and transparent. In addition to national-level plans, annual site plans are required by DOE Order 430.1C. At LANL, these are contract requirements (clause H-26). The most recent site plans for LANL and SRS were published in 2015 (Los Alamos Study Group files). Are production “modules” – a $4-6 billion, two-decade project – still required or planned at LANL? One of the largest ambiguities in the present plans concerns the underground plutonium manufacturing “modules” once proposed and still formally required for LANL. Are “not less than two” modules still required, per the FY2014 NDAA (e-p. 1058), by 2027, or are they planned for later years, or have they been realistically dropped from consideration altogether? Last year’s NDAA (Section 3120, subsection b) assumed the module plan was still viable, requiring study of an 80 ppy modular option. If feasible, module construction would be a $4-6 billion (B) project (p. 8). In 2015, NNSA estimated that such modules would require 12 years to begin hot operations, even with schedule “acceleration” (p. 4-11, Independent Cost Review of the [PF-4] Modular Approach Project, NNSA 2015, redacted, Study Group files). NNSA’s 2018 pit production Engineering Assessment (EA) estimated that underground modules (Option 2C) could be completed and commissioned only by 2034, and begin war reserve pit production only by 2038 (e-p. 238), a full 20 years after project initiation. The following year, GAO strongly criticized the module plan. NNSA’s 2017 pit production Analysis of Alternatives (AoA) had said an 80-ppy, modular strategy for LANL was impossible. And despite the Section 3120 requirements of the FY2019 NDAA, this past April NNSA Administrator Lisa-Gordon Hagerty reiterated that producing 80 ppy at LANL by 2030 would be impossible (pp. 14-16, 63-65). Even to reach 30 ppy at LANL would be “really stretching their capabilities” (p. 16). No modules have been shown in LANL’s long-range “draft” site plan presentations to contractors (pp. 36-37, p. 10) and local governments. Kelly Cummins, NNSA’s Program Executive Officer for Strategic Materials, with other NNSA officials, recently said in a briefing that to reach 30 ppy, LANL will need to operate its PF-4 plutonium facility with multiple shifts, and that LANL will be hiring an additional 1,000 to 1,500 plutonium-related staff to do so. Her remarks echo those of LANL Chief Operating Officer Kelly Beierschmidt, who in New Mexico legislative testimony said LANL expects to hire 1,400 additional plutonium-related staff over the next five years. This is far more people than could be accommodated in PF-4 without multiple shifts, and far too soon to be accommodated in any new nuclear facilities, including modules. In part to handle shift work at PF-4 and ancillary facilities, LANL is planning new parking structures, a new entrance and change rooms for PF-4, a cafeteria/training facility, and offices (pp. 36-37, p. 10). At least for now, then, NNSA anticipates meeting its expanded pit production requirements at LANL through multiple shifts, rather than constructing additional nuclear facilities. Nevertheless, a requirement to build production modules, a massive undertaking, remains on the books. Preparations at the two production sites NNSA officials have said that roughly $500 M of FY2020’s $712 M for pit production preparations will be spent at LANL, with $205 M earmarked for spending at SRS. NNSA’s FY2020 budget request includes (p. 122) $410 M for pre- Critical Decision (CD)-1 (“approve alternative selection, cost range”) activities at the Savannah River Plutonium Processing Facility (SRPPF), as the repurposed Mixed Fuel Fabrication Facility (MFFF) is now known. No Project Data Sheet for the SRPPF was provided. At LANL, almost half of these FY2020 monies ($240 M) are to be spent on the four active subprojects in the protean Chemistry and Metallurgy Research Replacement (CMRR) project (pp. 385-415). In addition to these and the other pit-related LANL construction projects mentioned above, LANL is pursuing significant upgrades in its liquid and solid waste management capabilities, as well as several other pit-related general plant projects. A large project (“21-D-xxx,” more than $117 M) has now begun to greatly expand LANL’s electrical capacity to serve this and other expanding LANL missions. NNSA’s FY2020 budget request contains more than $4 billion in 40 separate construction projects over the coming 5 years at LANL, not counting maintenance and repairs. LANL itself estimates $5.5 B in building projects over the coming 5 years (p. 19), and $13 B over the coming decade. (This figure, confirmed to the Albuquerque Journal, is total project costs, including administrative costs). Much of this construction is directly or indirectly related to the expanding pit production mission. Geographic peculiarities of the LANL site and nearby residential areas include relative isolation from skilled labor pools and dissected, steep topography that limits construction. As a result of these two factors, plus LANL’s current and planned growth, plus the large number of LANL employees who are retiring in Los Alamos County, result in a local housing market and road network that are both overwhelmed. Severe traffic congestion is now a daily occurrence on LANL feeder roads, and almost no affordable housing is available in Los Alamos County for new staff and contractors. As a result, LANL has been pitching (see here and here) for a major new highway through a roadless National Forest area and a high bridge over an isolated reach of the Rio Grande. NNSA and LANL are also considering opening satellite campuses in Santa Fe (see here and here) and Espanola (p. 2), in another approach to handle the overcrowding on LANL’s mesas and in Los Alamos town areas. Safety is another issue dogging NNSA’s pit plans for LANL. Despite hundreds of millions of dollars in repairs and seismic and safety upgrades, LANL’s 41-year-old PF-4 facility lacks a completed dynamic seismic analysis and any active “safety-class” (i.e. survivable) systems to protect the public and co-located workers from exposures in the event of an earthquake and fire. Estimated maximum radiation doses to offsite individuals exceed DOE’s 25-rem standard, as explained here. NNSA has not prioritized or funded resolution of these issues and their disposition is at present unknown. At SRS, some 200 people are working on the “balance of plant” design (p.10) of the SRPPF in preparation for CD-1, expected in either FY2020 (Ibid) or FY2021 (p. 3). CD-2&3 (“approve performance baseline, start construction”) is expected in FY2023, barring setbacks, which if history is any guide, are more likely than not. Environmental analyses At SRS, a project-specific environmental impact statement (EIS) process for the SRPPF was announced on June 10, 2019. A scoping hearing was held; NNSA has not published the comments received (author’s comments). NNSA expects (p. 6) to conclude the EIS process in the fall of 2020 and to publish a Record of Decision (ROD) by the end of 2020. No Site-Wide EIS (SWEIS), which would examine the cumulative impacts and connected actions involved at the site, has ever been published for SRS. No visible National Environmental Policy Act (NEPA) analysis of pit production or site expansion is being conducted at LANL despite the dramatic scale of the investment, large number of construction projects, and the evident impacts, only some of which are mentioned above. On June 28, 2019, NNSA made available a draft “Supplement Analysis” (SA) in which the agency stated (e-p. 57) that no further nationwide (“programmatic”) EIS (PEIS) need be prepared for expanded pit production, even “with additional surge capacity at each site, if needed“ beyond 80 ppy (author’s comments here and here). A Final SA was published was made available on Jan. 8, 2020, making a formal determination (p. 67) that no further programmatic analysis is required to build and operate pit production facilities producing up to 80 ppy at either or both LANL and SRS, i.e. up to 160 ppy in total (e-p. 3). Now that Congress has fully funded the two-site pit production strategy, and NNSA has further committed to a 30 ppy production capacity at LANL with expanded environmental impacts admittedly extending into nearby cities and possibly including new LANL sites, litigation over the lack of either an appropriate PEIS or LANL SWEIS may ensue, as previously discussed on this blog and again in February of this year. Conflicts with other plutonium programs GAO’s October report highlighting the uncertainties in NNSA’s plans for plutonium oxide production for its SPD program was summarized in a Los Alamos Study Group press backgrounder. In sum:
LANL’s PF-4 also produces general purpose heat source (GPHS) Pu-238 fuel clads (e-p. 15), which are then fabricated into radioisotope power systems (RPSs). Like the plutonium oxidation mission, heat source production at LANL is also slated to grow dramatically in the same timeframe as pit production. Heat source plutonium is about 260 times as radioactive as weapons-grade plutonium (e-p. 13), and as such is a large component of the allowable material-at-risk (MAR) at PF-4. At one time, LANL expected to solve this mission conflict by moving heat source production into an underground module, but LANL never actually consulted with the heat source program, which categorically rejected any such move (e-pp. 28-29). Transparency, Analysis, and Due Diligence: Look Well before You Leap The future of NNSA’s pit production program is far from settled. Without prejudice as to ultimate pit policy, the author believes all parties would be served by much greater transparency. For members of Congress, cleared staff, and oversight agencies, the reports required by Congress and other documents that constitute the normal basis of intelligent discussion and decision need to be provided in a timely fashion. For the interested public, which has important roles to play, unclassified reports, complete project data sheets and accurate budget requests, site plans, and redacted versions of UCNI and classified reports should be created as appropriate. Neither has been happening. The result is that the executive branch is far too isolated, a condition associated with folly, waste, and project failure. Likewise, programmatic and site-wide EISs should be prepared promptly, saving time and increasing value for NNSA. In 2017, NNSA’s AoA assumed EISs would be done at both pit production sites, observing that neither was on the critical path for project completion at the time. In 1999, John Immele, former head of LANL’s nuclear weapons program, wrote in the November/December issue of LANL's Weapons Insider, A ... lesson from the weapons program of the early and mid-1990s as well as the fissile materials disposition program is the necessity for and (surprising) success of publicly vetting our strategies through environmental impact statements. (Los Alamos Study Group files) It is a lesson NNSA management has forgotten. Congress should remind them. In March of this year, the IDA concluded that NNSA was unlikely to meet its 2030 pit production deadline, and the measures NNSA proposed to accelerate project completion would likely create setbacks instead. The 2030 pit production deadline is managerially problematic. It derives entirely from the proposed 2030 deadline for the First Production Unit (FPU) of the W87-1 warhead. Many parties are not convinced that this warhead concept has been well thought through, as evidenced by the nature of the reports Congress is requiring. There are many non-W87-1 options available, discussion of which is beyond the scope of this post. No doubt the reports required in this year’s legislation will shed further light on some of these options. In light of these basic considerations and others, Congress would be well-advised to reconsider its statutory pit deadlines in the year ahead, before NNSA’s haste makes vast waste – again. ***ENDS*** |
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