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Of concern: a) DNFSB finds Los Alamos plutonium facility does not adequately protect the public; b) NNSA seeks new campus in Santa Fe NM and/or Espanola NM December 5, 2019 Dear colleagues -- (Beating Dead Horses Department: we think both the House and Senate approaches to pit production are quite wrong-headed. But you knew that. I have no idea if greater restraint can prevail at this late stage.) First, you will have noticed that the DNFSB has published a staff report dated in August of this year that summarizes several longstanding concerns with the safety basis of Building PF-4, the main plutonium facility at LANL. The cover letter from Chairman Hamilton, dated Nov. 15, requests a response and a briefing within 60 days. Our simplified remarks on this report for our more active local members and the news media are here. There is no need to add very much here, except this: it might be easy to dismiss the dispute between NNSA and the Board as scholars arguing over how much risk can fit on the head of a big earthquake. That would not be quite right. On the one hand NNSA makes a number of quite remarkable assumptions that do not bear close examination, and on the other hand NNSA is backtracking from long-standing (since 2006) prior understandings and commitments regarding necessary safety-class systems. That backtracking follows and is accompanied by continual deprioritization and schedule slippage. The Documented Safety Analysis (DSA) of February 2019, which purports to provide a PF-4 safety envelope without any active safety-class systems whatsoever, has brought all this to a sharp focus. I don't know how it feels over at the DNFSB, but I for one feel like a fool for ever thinking PF-4 could be or would be brought to modern safety standards. Mitigation by lowering MAR just enough to just squeak beneath the 25 rem exposure guideline, whether it is actually just-barely-adequate mitigation or not, is asking for trouble. Our organization does not trust that LANL will abide by those MAR limitations and neither, we believe, should you. When has LANL ever kept such promises? Time passes, faces change, commitments are forgotten, downgraded, and papered over in the service of today's new and urgent priorities. Further, we believe the carefully-documented, objective concerns of the Board are only the tip of a larger iceberg that includes what we might call "inchoate" or "safety culture" concerns, which are difficult for DNFSB's supremely-professional safety engineers to write about. The very fact that NNSA and LANL would renege on these critical, long-standing safety promises is proof that safety is not the priority LANL claims it is. Second, you may have noticed that LANL and NNSA (the Los Alamos as well as Albuquerque offices) are involved in efforts to redevelop a 67-acre parcel of land near the commercial center of Santa Fe. Almost everything we know about these proposals so far comes from two newspaper articles, linked and quoted in this letter to our local members, as well as this Bulletin. From "Developer proposals hint at what’s in store for city-owned midtown campus," Santa Fe New Mexican, 11/25/19: The National Nuclear Security Administration, which administers the Los Alamos National Laboratory management and operating contract, submitted a master developer proposal to build an open-campus environment with administrative offices, sustainable green spaces, engineering space, light manufacturing, training facilities and research and development. There would be no radiological or hazardous activities performed at the midtown property, said Al Stotts, an NNSA spokesman in Albuquerque. Besides applying for "master developer" of the whole site, NNSA and LANL are also applying as partners in other expressions of interest. I am wondering -- where is the adult supervision? If NNSA tries to open a site in Santa Fe "there will be war," in the words of one well-connected Democratic Party activist with whom we met yesterday, meaning that this proposal will become an instant lightning-rod for protests of all kinds. Lawyers have already been called, not even by us (yet). Does Congress really want to open a new LANL site in the middle of Santa Fe? The potential Espanola gambit is mentioned here. First a "megabridge" and highway through a roadless area, and now this? Third, I have had two guest editorials published recently that might be of interest.
Thank you for your attention, Greg |
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