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October 10, 2012 Dear colleagues -- Furthermore, NNSA and Los Alamos officials told us that NNSA may also lose some pit testing capabilities that only take place in the Superblock at Livermore and are expected to be discontinued there in 2013. Pit testing includes thermal, vibration, and other environmental tests on pits that ensure that the weapon can successfully function from the time it is in the stockpile until it is deployed and reaches a target. Livermore officials told us that CMRR will not accommodate pit environmental testing because the systems used to conduct the environmental tests could cause vibrations through the rest of the facility. This could disrupt other work that requires precision instrumentation. Livermore officials also told us that these pit environmental testing capabilities are necessary to help meet nuclear weapons stockpile requirements. Because the CMRR was not intended to support all of these capabilities, NNSA will need to find another location if this plutonium-related work currently being conducted at Livermore is to be continued. NNSA has begun studying the extent to which the environmental pit testing capabilities will be needed, and if so, where they will be located. However, NNSA currently has no final plans for relocating them elsewhere. (Footnote 18: NNSA has initiated a study considering implications of potentially upgrading Livermore’s nuclear facility security and hazard categories for short periods to allow NNSA to continue and maintain needed plutonium-related capabilities. An NNSA official told us that NNSA is confident that the environmental pit testing capabilities will be maintained somewhere. ("New Plutonium Research Facility at Los Alamos May Not Meet All Mission Needs," GAO-12-337, Mar 26, 2012, pp. 18-19).This note focuses on the environmental testing of pits currently housed at LLNL and is silent regarding secondaries and regarding any other missions involving Security Category I and II quantities of plutonium that may be currently contemplated for LLNL. In passing, I do not understand the environmental testing mission -- it's nature, how much of it needs to be done, and when in the life-cycle of pits it needs to be done. I presume it is necessary to certify designs and possibly to certify production test units. What follows concerns facilities only, not the mission. B334 is a bigger building than might appear. At 6,300 sq. ft it is almost as big as the laboratory space in any one CMR wing (8,000 sq. ft.). A high bay with a 5-ton gantry is apparently required. Only half the space currently available at B334, or 3,000 sq. ft., is needed (Complex Transformation Supplemental Programmatic Environmental Impact Statement (CTSPEIS), p. 5-505), although both smaller and larger (than B334) square foot figures are mentioned in describing alternatives for this function at NNSS (CTSPEIS, pp. 5-496, 5-497). NNSA describes the existing building as follows. Building 334 (Hardened Engineering Test Building). Building 334 is a 6,300 square foot facility located on a 2.5-acre site in the Superblock section of the LLNL main site. This facility is often referred to as the Hardened Engineering Test Building (HETB). The building is primarily used for environmental testing of SNM. One half of the building is the Radiation Measurement Facility, including the Intrinsic Radiation (INRAD) Bay, and the other half is the ETF, consisting of the Engineering Test Bay (ETB). The two bays are separated from each other by a thick concrete wall. The HETB is a unique facility within the Nuclear Weapons Complex (NWC). With regard to INRAD measurement testing, it is currently the only building within the NWC that allows intrinsic radiation detection of SNM on configured assemblies (outside of drums or containers) and without significant background radiation present. The INRAD facility supports measurement operations for Nonproliferation, Homeland and International Security Division (NHI), the Accident Response Group (ARG), the Joint Technical Operations Team (JTOT), and radiation detector development work. With regard to environmental testing, Building 334 is currently the only building within the NWC that can facilitate environmental testing of SNM (i.e., pits and secondary assemblies containing SNM). Environmental testing includes vibration, shock, thermal conditioning, or combinations of these environments. Figure A.10-2 shows the location of Building 334 in Superblock, at LLNL. (CTSPEIS, p. A-90, emphasis added)We promised a colleague that we would look for a site at LANL that was suitable for this work. We looked for a Hazard Cat II or even Cat III nuclear facility with good security that could do this work at LANL. There isn't anything that looks remotely possible. The DNFSB site representative knows of no such structure. Some people far away might imagine that LANL is an easily-secured site. This is not the case, due to its topography, large distances between sites, and quasi-forested ground cover. Realistically, LANL could be described as having somewhat porous security except for key areas protected by PIDAS. Regarding the building's safety and security requirements, NNSA says: The nature of the work presently being conducted in Building 334 and Building 834 Complex, at LLNL, is to test classified test objects made from SNM and to test actual weapons and weapons components, and as such needs to be located in a secure PIDAS (Perimeter Intrusion Detection and Assessment System) area similar to what is found at the LLNL Superblock, and at LLNL Site 300. Any other location for this work would need to be a Category II Nuclear Facility and have the facility infrastructure to support this hazard level of work. (CTSPEIS, p. 5-504)The PIDAS requirement is obviously hugely expensive. NNSA's default plan since 2008 has been to move the functions of B334 from LLNL to Pantex. This choice was analyzed under NEPA in the Complex Transformation Supplemental Programmatic Environmental Impact Statement (CTSPEIS). This discussed in the CTSPEIS at pp. 5-496 to 497, 5-503 to 506, 5-540, and A-90 to 92. A Record of Decision (ROD) was issued to implement this decision on December 19, 2008 (Fed. Reg. Vol. 73, No. 245, p. 77662). This function is to be housed either in an existing 3,000 sq. ft. Pantex facility which is now only used intermittently but for similar purposes, or in the proposed Weapons Surveillance Facility (WSF) that was (or is) to replace a number of existing Pantex facilities and capabilities. (As an aside, the WSF does not appear in the FY2013 NNSA budget request, but the "Limited" Pantex FY11 Ten-Year Site Plan of March 15, 2011, which carries both NNSA and B&W imprimaturs, at p. 17, looks forward to FY2014 for the first $50 M in PED appropriations for this proposed $544 M facility. I have not pursued the status of this facility further in this memo, as it is not germane to the conclusions.) The test equipment could be transferred from LLNL in just three standard containers. Just four construction workers working for four months (2600 worker-hours) would be needed to make the necessary building modifications (a concrete-lined pit in an existing building and a roof extension); two people would need to be hired at Pantex. LLNL would shrink to that extent. No additional security measures or other costs are involved at Pantex, and there are essentially no environmental impacts or additional risks. Other options closely examined by NNSA were: a) underground at U1a at NNSS; b) in DAF at NNSS; c) adjacent to DAF; and d) in a new facility at SNL/NM. Three of those options would have needed a new building (or equivalent underground space). All the preferred options in the CTSPEIS involve closure of some or all environmental test facilities at LANL and LLNL -- it is a theme in NNSA's proposed consolidations. There has been no NEPA analysis of moving this function to LANL in the CTSPEIS or in any other NEPA document. Keeping this mission at LLNL (in B334) was not preferred in the CTSPEIS, but was analyzed in the "No Action" Alternative and also in the "Downsize in Place" Alternative. If this mission were the only reason to have Category I/II nuclear material at LLNL, doing so does not appear at all justified from cost and other perspectives.Nonetheless, assuming for the moment that the CTSPEIS analysis is adequate, issuance of an Amended ROD (AROD) to keep this mission at LLNL would appear to be a legal option. Contrariwise, it would not be possible to issue such a NEPA-compliant AROD for moving this to LANL because this option was not analyzed in the CTSPEIS. Issuance of a new "Supplemental CTSPEIS" (nota bene: this would be a supplement to a supplemental EIS) to support a decision to move this function to LANL (among any other changes contemplated) would be problematic due to the cost, complexity, and duration of effort. If attempted, such an effort could well prove to be illegal if challenged due to the age of the underlying Stockpile Stewardship and Management PEIS. We know of no reason to be concerned about the transportation of limited numbers of pits from LANL to Pantex, especially given the background of existing and proposed traffic in plutonium to and from LANL that goes with the pit production, surveillance, heat source, and other missions, not to mention any pit disassembly mission that might be added. While we do not see any current or foreseeable reason for the production of any pits for the stockpile, or for any but a de minimus pit disassembly mission at LANL, LANL, as the center of NNSA weapons plutonium activities, will remain the origin and destination of plutonium shipments for the foreseeable future, including to and from Pantex. We know of no serious safety or security problems with these shipments. Commercial gasoline, LPG, and chemical shipments are more problematic from both perspectives, however routine they may be. All in all, we know of no reason of any kind why the transfer of the pit environmental testing function from LLNL to Pantex could not, and should not, proceed if it has not done so already. If there are any errors or notable omissions in the above, please let me know. Thank you for your attention and best wishes, Greg Mello |
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