Brief Partial Update on the Chemistry and Metallurgy Research Replacement (CMRR) Project at Los Alamos National Laboratory (LANL)

January 28, 2009

Greg Mello, Los Alamos Study Group

Summary

1.      LANL has recently written an “exit strategy” from the existing Chemistry and Metallurgy Research (CMR) building that does not include the CMRR Nuclear Facility (CMRR NF).

2.      The Defense Facilities Safety Board (DNFSB), required by law to certify the safety of CMRR NF design prior to full release of FY09 funds, has for the time being refused to do.  NNSA has stated that it “may not be economically feasible to…qualify…the active confinement ventilation system” to seismic design requirements.

3.      NNSA’s plan to construct a total of 4 large new plutonium facilities (3 nuclear facilities and 1 radiological facility), plus 5 related projects at LANL alone, needs more careful vetting.
 

Conclusion: it is at best premature to fund the CMRR project at this time.   We believe the entire project is not needed, for reasons summarized in the publications cited above. 

1.      In its 1/2/09 Weekly Site Report [1] (pdf), DNFSB reported that LANL had “recently” submitted an “exit strategy” from the existing CMR building that did not include use of the CMRR NF, the second (and by far the more dollar- and schedule-intensive) of the two buildings in the CMRR project.

To our knowledge this is the first public reference in at least five years to a LANL strategy for its plutonium facilities that does not include the CMRR NF.

Detailed design of the CMRR NF has not begun and the project remains controversial.  The House of Representatives has voted to withhold some or all CMRR appropriations (for both CMRR buildings) since project inception in FY04.  The House has attempted to withhold these funds (and attach conditions; see below) for multiple reasons, including the absence of a new nuclear policy, an associated nuclear posture, and consequent infrastructure plan.

NNSA estimated in February 2008 that the CMRR NF would cost at least $2 billion (B).  A validated cost estimate for CMRR NF will not be available until at least February 2010.

DNFSB says LANL recommended additional evaluation of upgrading the CMRR Radiological Laboratory, Utility and Office Building (RLUOB) to the status of a Category II nuclear facility.  This would be a major unplanned design change; the RLUOB is now about 2/3 completed.  All necessary funds have been appropriated for this building as originally designed.  Specification of RLUOB special facility equipment (SFE) is not yet completed.

NNSA and LANL have stated repeatedly since the February 2003 Congressional Budget Request (i.e. the FY04 CBR) that the RLUOB would be a Category III radiological facility – an analytical facility limited to less than 9 grams of plutonium-239-equivalent, plus an office and utility building – and not a nuclear facility containing kilograms or even tons of plutonium, which the CMRR NF would be.  This strategy was codified in the CMRR Record of Decision (pdf) (ROD) of February 12, 2004. [2]

According to DNFSB, LANL’s non-CMRR-NF, “CMR exit strategy” includes other elements as well, including improvements related to the existing TA-55 Building PF-4 plutonium vault.

LANL asserts that delays in the CMRR NF would cause safety, security, and programmatic risks.  The assumptions that lead LANL to these conclusions are not available to us and we cannot independently evaluate them.  In general we believe LANL and NNSA are planning on maintaining more plutonium missions, at a larger scale and production rate, than can be justified by NNSA’s and the Department of Energy’s (DOE’s) national security and energy mandates, the requirements of worker and public safety, and prudent fiscal management.

2.      Seismic issues have long been of concern at LANL.  Extensive seismic assessment over the past 20 years has increased the known probability of large accelerations in both the vertical and horizontal directions across the LANL site.  As a result of this new knowledge LANL is now operating under a site-wide Justification for Continued Operations (JCO), as multiple LANL facilities do not meet nuclear safety requirements and are being reevaluated, with potential changes to operations, structures, and equipment.

Seismicity is a central reason an exit strategy from the CMR Building is needed.  It is also a major concern in the design and operation of nuclear facilities at TA-55, including the proposed CMRR NF.  To date NNSA and LANL have not succeeded providing a preliminary design for the CMRR NF capable of meeting seismic requirements, despite years of work. 

The FY09 Defense Authorization Act requires DNFSB to certify CMRR design prior to releasing any funds over $50.2 million in FY09. 

Section 3112. Limitation on funding for Project 04-D-125, Chemistry and Metallurgy Research Replacement facility project, Los Alamos National Laboratory, Los Alamos, New Mexico.

Of the amounts appropriated pursuant to an authorization of appropriations in this Act or otherwise made available for fiscal year 2009 for Project 04-D-125 Chemistry and Metallurgy Research Replacement (in this section referred to as ‘‘CMRR’’) facility project, Los Alamos National Laboratory, Los Alamos, New Mexico, not more than $50,200,000 may be made available until—(1) the Administrator for Nuclear Security and the Defense Nuclear Facilities Safety Board have each submitted a certification to the congressional defense committees stating that the concerns raised by the Defense Nuclear Facilities Safety Board regarding the design of CMRR safety class systems (including ventilation systems) and seismic issues have been resolved; and (2) a period of 15 days has elapsed after both certifications under paragraph (1) have been submitted.

On January 16, 2009, DNFSB sent two letters to NNSA regarding seismic design deficiencies in the CMRR NF project.  One letter and attached findings [3] (pdf) concerned seismic design issues overall; the other and its attached findings [4] (pdf) concerned seismic design of the active confinement ventilation system and its support.

An excellent summary (behind paywall) of the situation was provided on January 26th by George Lobsenz at Energy Daily. [5]  It is attached below, with permission.

The main problem, at least in the case of the active ventilation system required, is the high vertical acceleration which has occurred and may occur again at the site.  NNSA has stated that it “may not be economically feasible to seismically design and qualify some components of the active confinement ventilation system or its support system to PC-3 seismic design requirements.”  DNFSB, for its part, states “it is not acceptable to downgrade PC-3 seismic design requirements.”

Does this temporary impasse mean CMRR project funds are now, or soon may be, “on hold?  Can these issues be easily, quickly, and cheaply resolved?  Apparently not, but we do not know.

3.      Overall, the above facts suggest the merit of a much more careful vetting of interrelated plutonium missions and facilities at LANL, Lawrence Livermore National Laboratories (LLNL), the Savannah River Site (SRS), Idaho National Laboratory (INL), and possibly other sites, than has occurred thus far.  For example:

·         Are all the planned plutonium missions necessary or desirable, and if so, at what scale and intensity? 

·         Must all these missions be continuous?  Are some just contingencies? 

·         Are some missions, for example missions associated with advanced fuel cycle technologies, and with design and production of a Reliable Replacement Warhead (RRW) or other new or modified warhead, merely aspirational?  Do some mission “requirements” imply policy decisions that have not been made, or embody open-ended “flexibility” at great cost and program risk?

·         Is it necessary or desirable to have an active pit production program, as opposed to placing pit production on warm standby, making a few test pits for evaluation purposes only? 

·         Is it necessary to have a separate, active pit production technology development program, or could this be pursued in floor space reserved for pit production, were the latter on warm standby? 

·         Is a program for confined subcritical tests with Pu-242 necessary? 

·         Is a pit development program necessary?

·         Is it necessary or desirable to make MOX fuel, actually?  If it is, is it necessary to supply MOX for 6 nuclear reactors?  What about 4 reactors?  Or 2, as a pilot program? 

·         What is the true value added by nuclear forensics and what dedicated Category I plutonium space is truly and continuously required for it? 

·         How would changes in stockpile numbers, the number of weapon types supported, and the pace, timing, and intrusiveness of life-extension programs affect plutonium infrastructure requirements? A wide consensus supports significant stockpile cuts of some nature.  In addition, the U.S. is legally and politically committed to nuclear disarmament and an increasing number of former senior officials believe U.S. interests are best served by pursuing it.  Deliberation on these matters is under way and the outcome could, or should, affect plutonium infrastructure plans.  

·         Must Pu-238 missions remain at LANL’s PF-4, or would it make more sense economically for them to be at INL, were DOE’s “stove piping” overcome? 

·         What are the proposed missions of the CMRR project exactly, for both the NF and the RLUOB?  These have never been made clear, and the willingness of LANL to discuss modification of the RLUOB into another kind of facility altogether, at this late stage of construction, is somewhat shocking – and revealing. 

·         Within LANL as a whole, the relationship of current and planned a) nuclear and b) radiological facilities, in relation to proposed missions, has never been independently elucidated.  If the total suite of missions were to decline, what facilities would truly be necessary to maintain?  How are these facilities utilized today, and how might they be utilized tomorrow – with and without the CMRR NF?  Could some radiological missions currently planned for the CMRR RLUOB be done nearly as well and for less money at other LANL locations (e.g. TA-48 or TA-46), supposing programs there wind down? 

·         In addition to the CMRR, at least five other plutonium-related construction projects are planned for LANL, with a total cost of at least $1 billion.  Are all these necessary as well? [6]

·         These same kinds of detailed questions should be asked for other sites, such as SRS.  If plutonium missions are appropriately downsized and focused at these sites as well, are there other, simpler ways to accomplish them?  Today’s complex transformation plans cannot be taken at face value without carefully examining the assumptions they embody. 

·         Overall, does it make sense at the present time to commit to building four large new plutonium facilities: the CMRR RLUOB, the CMRR NF, the Pit Disassembly and Conversion Facility (PDCF), and the Mixed-Oxide Fuel Fabrication Facility (MFFF), three of which are multi-billion dollar nuclear facilities, and at least two of which have experienced serious problems even prior to construction?  These are decade-or-more-long construction and management commitments.

·         Also, does it make sense to build billions of dollars worth of new plutonium nuclear facilities while proposing to shut down a fully-equipped, modern plutonium facility at LLNL?  

Attachment 

Safety Board Raises Seismic Issue on Los Alamos Project

George Lobsenz, Energy Daily, January 26, 2009.  (Reprinted with permission.)

In a potential problem for a key nuclear weapons project, staff at a federal safety oversight board have for­mally notified the National Nuclear Security Administration that they may not be able to certify the design for a new plutonium-handling facility at Los Alamos National Laboratory because the agency has said it may cost too much to ensure the facility’s emissions confinement system can withstand a strong earthquake.

In a January 16 letter to the NNSA, the semi-autonomous Energy Department agency that manages the department’s nuclear weapons complex, staff at the Defense Nuclear Facilities Safety Board (DNFSB) said the position taken by NNSA is “not acceptable” given the risks posed by the Chemistry and Metallurgy Research Replacement (CMRR) project at the seismically active Los Alamos site.

Staff at the DNFSB said they wanted NNSA to “reconfirm its commitment” to making the emissions confinement system capable of withstanding so-called performance category, or PC-3, earthquake events.

NNSA’s position is somewhat unusual because commercial nuclear power plants and other nuclear facilities are typically designed to earthquake safety standards that are substantially equivalent to the PC-3 standard used by DOE.

The DNFSB staff’s concerns are important because Congress in the defense authorization bill for fiscal year 2009 specifically gave the DNFSB certification authority for the design of the CMRR project, which NNSA says is vital to maintaining weapons design and production capabilities at Los Alamos.

Under the defense authorization bill, Congress withheld $50.2 million in fiscal 2009 funding for the CMRR project subject to the DNFSB and NNSA providing formal certification to the House and Senate armed services committees that design of the CMRR facility was adequately protective of public safety.

As part of the certification process, the DNFSB staff earlier this month began sending “findings” to NNSA laying out their initial concerns about aspects of the CMRR design.

The staff has sent two findings, one about overall seismic safety of the CMRR and the other focusing on the so-called confinement ventilation system, which is critical to capturing and preventing the release of any harmful emissions from the facility.

While seismic safety has long been a key DNFSB concern on the CMRR project, the January 16 finding on the confinement ventilation system contains stronger language from DNFSB staff about the need for NNSA to change its position.

“The [NNSA’s] CMRR Nuclear Safety Design Strategy…states that it may not be economically feasible to seismically design and qualify some components of the active confinement ventilation system or its support system to PC-3 seismic design requirements,” the staff said in the finding.

“It is not acceptable to downgrade PC-3 seismic design requirements for the active confinement ventilation system.”

As for a solution, the DNFSB staff said: “NNSA should reconfirm its commitment to seismically design the active confinement ventilation system to PC-3 seismic design requirements.”

And in an accompanying letter to Gerald Talbot, assistant deputy NNSA administrator for nuclear safety and operations, DNFSB staff said that by sending a finding to NNSA, the staff was highlighting a safety issue that “has not been adequately resolved and that could preclude board certification.”

NNSA officials said they expected to address the DNFSB concerns in an internal review of the CMRR project that was now under way.

“We are aware of their concerns,” NNSA said in a statement to The Energy Daily Friday. “We are in the midst of a major internal review of our design plan and feel confident that the board’s questions will be answered when they see the results of this review. We look forward to continuing to work constructively with them to ensure that the CMRR is safe.”

NNSA has said that moving forward with the CMRR project is vital because the existing Chemistry and Metallurgy Research (CMR) building at Los Alamos is more than 50 years old and does not meet modern earthquake, fire safety and other environmental and public health protection requirements.

NNSA has been attempting to respond to safety concerns in the interim by removing some plutonium and other hazardous materials from the CMR building. However, the agency says it cannot shut down the CMR building because it provides critical capabilities for handling plutonium and other nuclear materials used in nuclear weapons.

As a result, NNSA has been trying to expedite construction of the CMRR facility, but has run into difficult design and cost problems, with the project’s price tag roughly doubling to an estimated $2 billion.

The DNFSB has had longstanding concerns with the design of the CMRR, especially NNSA’s initial plan to use “pas­sive confinement” strategies to prevent radioactive releases in some accident scenarios; passive confinement means radioactive releases will be confined by the buildings walls and ceiling, as opposed to being sucked up by an “active” ventilation system and trapped in filters.

Earthquake issues are of particular concern for the CMRR facility because Los Alamos is located in a seismically active area of New Mexico, In addition, the lab recently completed a new seismic review that showed earthquake risks to lab facilities are roughly 50 percent higher than previously believed.