December 12, 2012

Dear congressional colleagues –

The absurdity of the proposed tunnel portion of NNSA's evolving new plutonium sustainment plan continues to trouble me. 

The tunnel is meant to be connecting two nearly-adjacent buildings at Los Alamos National Laboratory (LANL): PF-4 (the main plutonium facility), and the Radiological Laboratory, Utility, and Office Building (RLUOB).  The tunnel is currently rumored to have an estimated cost of $140 million (up from $120 million in June -- see p. 27 in this Ventura presentation, pdf).  The two buildings are roughly 500 ft. apart as the crow flies (satellite view).  No doubt the tunnel would be longer.  We do not know the proposed tunnel route, or much else about it.
 
As you can see it is a crowded site.  The shallow tunnel would take, according to the Ventura presentation, 5 years to build.  It would go beneath the perimeter security system at PF-4 -- the one LANS has failed to properly construct -- which would logically necessitate extending the PF-4 special nuclear materials protected area to RLUOB and the installation of a security portal within RLUOB.  RLUOB is a radiological facility that does not house or handle security category I or II nuclear materials, is not constructed to do so, and would not otherwise require such a portal.  The semi-completed Nuclear Materials Safety and Security Upgrades Project II (NMSSUP II, current estimated cost, one-quarter billion dollars or nearly $5,000 per inch of fence) just built new portals to the PF-4 complex.  The tunnel project would require a duplicate portal.  That portal, in fact the whole tunnel, would need to be guarded, maintained, and integrated into the overall security system.  It would have to have a ventilation system, possibly a complex or safety-significant one.  The ambient pressure in the tunnel might have to be adjusted relative to PF-4, which can be tricky.  Fire protection would have to be provided.  There would need to be cameras.  I believe there would have to be guard stations at corners to provide lines of fire in each direction, since this tunnel would be within the special nuclear materials protected area.

Were it not for providing for these complex features and for complex interactions with existing, planned, and possible future construction at the site, this short, shallow tunnel surely could be built in one-tenth the time and one-tenth the money (in, say, 6 months, for $14 million).  This is another way of saying that this complex site, laden with underground utilities and security risks and complications, does not exactly beckon bulldozers and backhoes.  The cost and complexity are warning signals. 

May I commend to you instead a typical garden cart (such as this one available at Lowe's hardware stores) which can be immediately deployed for one million times less money than the tunnel.  It would be better to get two carts, especially given the hourly rate of the people who will go to pick them up.  I see that Metzger's in Los Alamos has some at $130.

This homely example, were we to pick it apart for all the lessons it offers, would explain just about everything we need to know as to why NNSA is so broken.  And why do I even have to say this, instead of NNSA?

Skeptics may argue that the tunnel provides additional benefits.  What benefits, exactly? I don't know what those alleged benefits might be.  We can be sure they are classified (Secret Restricted Data, SRD), for official use only (OUO), or else unclassified controlled nuclear information (UCNI), if they are even committed to paper at all.  The usual way bad decisions are made at NNSA is through heavy reliance on tacit assumptions supported by no analysis at all.
 
Since no one has offered any alleged benefits, I can't respond.  But the alleged benefits can be relied upon to fall into two categories: alleged benefits under current laws and policies, and alleged benefits under policies and laws that might or might not occur in the future -- "aspirational benefits."  The latter can sound "reasonable" – if money and complexity are not considerations.  But money and complexity are very strong negative factors.  A $140 million tunnel that takes 5 years to design and build is a pretty complex capital project, with no guarantee of success (as we have seen).

Operating such a tunnel will also be complex.  It will also be LESS safe, and no more secure, than a short stroll in the open air.   Ask yourself: why would fully-sealed containers housing gram quantities of plutonium and other radiological-level materials be safer inside a closed tunnel than in the open air?
 
There are, rightly, no DOE safety or security requirements for a tunnel for the transportation of plutonium in any quantity or form within an NNSA site, whether it be grams, kilograms, or tons, let alone for transportation of the merely radiological quantities required for the missions at RLUOB which would be served by this tunnel.  Throughout the entire history of LANL and all its varied research and production missions, there has never been any requirement to transport plutonium underground.
 
I submit that there is no a) safety, b) security, or c) any efficiency justification for any such system today or in the foreseeable future.  Does all this complexity, cost, operational difficulty, and delay sound efficient to you?  It doesn't to me. 

It would be supremely ironic if the same parties who say that "onerous" safety and security requirements are hurting efficiency and damaging "science" are now suggesting that this tunnel be built for "safety" or "security" requirements that don't exist and wouldn't be justified if they did.
 
Have those who have proposed a tunnel actually done any sort of analysis as to why a tunnel would be cost-effective, as opposed to alternatives?  Where's the present value analysis, the life-cycle cost?  We never had that even for CMRR.  Has anybody seen such a thing for this tunnel?  Just how many sample shipments need travel between the two facilities each day?  One?  Two?
 
Has anyone examined the management risks associated with the project?
 
As for security, it is widely understood that one of the greatest enemies of an alert security force is boredom. Transportation of samples, whether by recycled shopping bag or by cart the few hundred feet from PF-4 to RLUOB, would give the guards already on site something to do, a reason to be aware.  There would be no marginal cost. 

The tunnel is no doubt part of some vague, open-ended infrastructure scheme, the exact requirements, scale, timing, cost, and environmental impacts of which are not really known to any party, let alone formalized in any specific plan.  If a "project" is something that has a beginning, a middle, and an end, this proposed tunnel won't qualify.  Isn't this just what the GAO and DOE IG have warned about for two decades -- poorly-defined projects that are like the New Mexico state motto crescit eundo -- "it grows as it goes."  Won't it always be a sort of "a work in progress" – like the evolving requirements of the plutonium program as a whole, waxing and waning with political expectations and needs?  Just where, so to speak, is this tunnel going?  Does anybody know?
 
As far as I can tell, no one does know.  Before bringing in the backhoes it would be good to know the scope of the project.  There is no indication LANS and NNSA do know that.
 
So there, in a nutshell or rather a tunnel, is the problem.  The M&O contractor proposes to rush into something that sounds "reasonable" (especially in comparison to what it replaces) but costs one million times more than a simpler, more flexible, immediate alternative.  NNSA says, "Great!"  And so far no one has yet effectively objected.  When you're in a hole, as NNSA has been at TA-55 with the CMRR fiasco, it's best to stop digging.  Literally.
 
But the problems with this project are typical.  Why?  Because it is one of the purposes of contractor-devised projects to be expensive.  NNSA's contractors want to maximize their income and they will tell you just how to do it.

Boondoggles cannot by definition be managed well.

Thanks for your attention,

Greg Mello