For immediate release February 22, 2018

NNSA Issues Draft Environmental Assessment for One Part of Its Proposed Plutonium Factory Complex at LANL

Assessment concerns further modification and use of what is becoming the most expensive building in New Mexico history, as well as a portion of ongoing modifications to LANL's main plutonium facility

Two alternatives are examined within what Study Group calls a clearly-rigged framework, "little or no impacts" predicted as usual; connected actions with far larger risks, wastes, and impacts ignored entirely

Environmental "assessment" no substitute for comprehensive analysis examining significantly different plutonium futures for LANL and the nation

Contact: Greg Mello, Los Alamos Study Group, 505-265-1200 (office) 505-577-8563 (cell)

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Albuquerque, NM – Today the National Nuclear Security Administration (NNSA) released a draft Environmental Assessment (EA) of the impacts of "administrative and physical changes necessary to convert the Radiological Laboratory/Utility/Office Building (RLUOB) located in Los Alamos National Laboratory's [LANL's] Technical Area 55 [TA-55] from a Radiological Facility to a material-at-risk- [MAR-] limited Hazard Category [HazCat] 3 Nuclear Facility."

The analysis is meant to comply with the National Environmental Policy Act (NEPA), which requires environmental analysis of alternatives to major federal actions having a significant effect on the environment.

The modifications to RLUOB and the main plutonium facility at LANL (Building PF-4) that are the subject of this EA are 2 out of 7 sub-parts in the sprawling, ever-changing Chemistry and Metallurgy Research Replacement (CMRR) project, which in turn is part of a larger suite of construction and operational changes aimed at upgrading LANL's plutonium processing, handling, and waste facilities to enable the production of plutonium warhead cores ("pits" -- up to 30 per year) and related activities.

RLUOB, at $1.4 billion (B), is becoming the most expensive building in New Mexico history. (See table on this page: scroll down to April 2010).

LANL also proposes underground factory "modules" to expand its production capacity, which it estimates to cost up to another $3 B. NNSA has not agreed to build these and may never do so, though the New Mexico senators and Congressman Ben Ray Lujan are strong advocates.

The CMRR project was strongly criticized by congressional auditors in 2016 ("NNSA Needs to Clarify Requirements for Its Plutonium Analysis Project at Los Alamos," Government Accountability Office, Aug 2016; "Congressional auditors flay Los Alamos plutonium plans," press release, Aug 10, 2016).

The combined estimated price tag for CMRR's interrelated suite of projects was $2.9 billion (B) a year ago (see p. 423 in this budget request; descriptions of the CMRR sub-projects as they stood last year can be found on pp. 392-425 in this document).

This does not count at least several hundred million dollars in the many supporting projects with distinct budget lines, or any operating funds at all.

NNSA recently said expanding pit production at LANL to 30 pits per year (ppy) would cost $3 B (slide 2) between now and 2026 -- $2 B on construction and $1 B in operations. NNSA may also decide to spend what it currently estimates as an additional $1.9 to $7.5 B to increase LANL's pit production capacity from the hoped-for 30 pits per year to 80 pits per year (slide 9).

This vast suite of multi-billion-dollar activities aims at nothing less than replacing the role of the Rocky Flats Plant near Denver, which was raided in June, 1989 by the FBI and EPA for its environmental crimes. Rocky Flats became an environmental remediation site in 1992.

There has never been an environmental impact statement (EIS) encompassing this huge suite of activities at LANL. The original 2003 CMRR EIS analyzed very different (and much smaller) choices, as did the 2011 Supplement to that EIS. (Gross inadequacies of the 2003 EIS and 2011 Supplemental EIS with respect to the largest portion of the CMRR -- the Nuclear Facility, CMRR-NF -- were the subject of three legal actions by this organization over the 2010-2014 period. CMRR-NF could not proceed during litigation and was eventually canceled.)

For a basic understanding of pit production issues, we have prepared a new general overview of pit production issues (article, background), published today, for the blog of the International Panel on Fissile Materials.

As we wrote in an October 2017 fact sheet (Expansion of Los Alamos Plutonium Warhead “Pit” Factory Eyed),

DOE claimed for a decade that RLUOB would never contain more than 8 grams of Pu-239 equivalent (Pu-239e) radionuclides, total. It now turns out that RLUOB at 8 g Pu-239e cannot be used for its stated analytical chemistry purpose. DOE now says RLUOB needs a 400 g Pu-239e capacity, even though RLUOB was not built to such a “nuclear facility” standard. One issue is seismicity. DOE and LANL were aware of the site’s true seismic risks during design but chose to build RLUOB to a lower and now plainly inadequate standard. Originally, RLUOB cost $167 million (M). Its equipment cost an additional $197 M. DOE estimates the RLUOB re-do will cost $35 M for the building, plus $633 M for more equipment, plus $339 M to re-categorize RLUOB as a 400 g Pu-239e nuclear facility (how?). Total cost: $1.371 B, far more than any other building in New Mexico, including runner-up PF-4. Meanwhile PF-4’s new equipment tab is estimated at a cool $1.069 B, plus $180 M for the latest building repairs, supposedly the last but still not including seismically-qualified ventilation or back-up power or adequate fire protection. Hundreds of millions have already been spent on upgrading pit production infrastructure in PF-4 and adjacent buildings. Additional hundreds of millions are being spent on related waste management infrastructure. None of this includes operating expenses (past and future), waste management, or environmental remediation.

Today's EA proposes to make RLUOB a "material-at-risk- [MAR-] limited Hazard Category [HazCat] 3 Nuclear Facility," with no more than 400 grams of Pu-239 equivalent at risk. What this means is that the facility can have more plutonium than this present -- up to 2,610 grams, certainly -- provided no more than 400 grams is deemed "at risk," because (for example) the balance is maintained within fire-rated containers. Whether RLUOB could handle even more plutonium -- say, in a "national emergency" requiring more pits -- is an open question.

One purpose of the proposed change is to make more room in PF-4 for pit production by moving some activities out of PF-4 and into RLUOB.

Study Group Director Greg Mello: "Not only does NNSA need to conduct a proper EIS for LANL plutonium activities, but there is now a need for a nationwide programmatic EIS for plutonium activities generally, because the momentous decisions NNSA will make about pit production also affect multi-billion-dollar surplus plutonium programs in South Carolina, which in turn spill over to affect the size and operation of the Waste Isolation Pilot Plant (WIPP), as well as the need for a proposed pit storage facility in Texas.

"NNSA is segmenting its analysis and rigging its comparisons to make its plans seem much smaller and more benign than they are. NNSA offers a "six of one, half a dozen of another -- which would you like?" style of analysis. Nowhere does NNSA offer none, or one, or two units of impact. Let's see the impacts of LANL plutonium plans without LANL becoming a pit factory, without business-as-usual. Let's see what environmental improvement might be possible with NPT-compliant disarmament for a change, not "assuring mutual destruction forever."

***ENDS***