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September 13, 2013 Key point: From where I sit, it looks as if the NNSA 9/13/12 reprogramming request assumes RLUOB can and will be eventually converted into a Nuclear Facility irregardless of current DOE regulations, the absence of an applicable EIS, any analysis of alternatives, and endorsement of a long-range plan by Congress.
To ensure that NNSA’s investments in plutonium research facilities and capabilities result in an operationally effective and affordable solution, we recommend that the Secretary of Energy continue efforts to assess how plutonium research and other capability needs and stockpile requirements have changed, if at all, since the needs were revalidated in 2008, and develop a plan to appropriately meet the nation’s near-term and longer-term plutonium needs.The National Nuclear Security Administration (NNSA) concurred with that recommendation. That is not exactly an endorsement of the current state of planning. What's noteworthy to me here is that GAO asks NNSA and DoD to figure out their requirements. Seismicity is not the problem that is mentioned, regulations are not foregrounded, lack of funding is not mentioned. Lack of internal clarity about what NNSA really needs, and the absence of a plan, are the only two problems mentioned. GAO goes on to say: A change in approach from constructing the CMRR nuclear facility, however, raises a number of questions. These include whether NNSA will make costly investments in short-term facilities that may ultimately not address its longer-term plutonium research needs. It is imperative that NNSA make prudent investments that right-size the solution with the actual and anticipated needs or it may continue to spend significant sums of money with little to show for it.No kidding. GAO also notes that: The April 2012 study [LA-CP-12-00470] stated that the required number of activities in PF-4 would likely be too great to be supported in the facility but noted further that it was a rough guess given that no formal PF-4 space analysis has been performed. Following the study, NNSA tasked the M&O contractor for LANL with assessing the space inside PF-4 to see if it could be repurposed to better support plutonium research for the nuclear weapons program and other mission areas. (emphasis added)The failure to carefully and formally analyze the space requirements for all plutonium programs under different policy scenarios and present these analyses to Congress in the form of alternatives stands out as a yawning chasm in planning and communications at this point. That should have preceded the reprogramming request. RLUOB never had an AC mission to support pit production, because such AC work would exceed the Material At Risk (MAR) limit of a radiological facility. RLUOB cannot support AC for pit production without becoming a Nuclear Facility. The question of whether RLUOB, which was not designed according to modern (i.e. 2007, updated in 2009) seismic standards, or nuclear facility standards generally, could become a Nuclear Facility is not simple. Yet the reprogramming request, if granted, would spend $40-55 million just from this source for vague activities and procurements to add AC to RLUOB, and another $15 to $25 million to design an expensive tunnel that is certainly not needed for radiological quantities of material. I have written to you before about the lack of an analysis of alternatives and the lack of an environmental impact statement (EIS), a lack of clarity about mission requirements and PF-4 space utilization, and other issues. Today I am writing to say that, from where I sit, it looks as if the reprogramming request assumes RLUOB can and will be eventually converted into a Nuclear Facility irregardless of current DOE regulations, the lack of an appropriate EIS, and any analysis of alternatives, and endorsement of a long-range plan by Congress. It is possible this conclusion is premature, but I doubt it. If I am incorrect, this conclusion only underscores the need for the thorough vetting of proposals in the EIS process that Defense Programs has found so helpful in the past. As John Immele, former head of the nuclear weapons program at LANL, put it in 1999 in LANL's Weapons Insider publication, 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.I will be in Washington next week and I hope it is possible for some of you to shed some light on this situation -- and sooner or later provide some written explanation of NNSA's plans, whatever they are, before committing to any course of action. Sincerely, Greg Mello |
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