For immediate release February 3, 2021

New billboard raises awareness of multibillion-dollar plutonium bomb factory under construction near Santa Fe

Unprecedented, major change in LANL mission looms

-- meanwhile --

Santa Fe County Commission tacitly endorses expanded LANL plutonium bomb production, seeks payoff in nuclear weapons jobs, educational outreach and training, lucrative local contracts

Resolution also seeks fresh environmental analysis to "reassure" and "inform" citizens as plans proceed

From Part Two below: "In contrast with many prior Santa Fe City and County resolutions (see below), this resolution does not oppose pit production, nuclear weapons, or a new arms race, and it does not seek to halt construction of LANL pit production facilities prior to production of a SWEIS, as the National Environmental Policy Act (NEPA) requires. It does not seek to halt factory construction at all."

Contact: Greg Mello, 505-265-1200 office, 505-577-8563 cell
Permalink * Prior press releases

Albuquerque, NM -- This is a long press release and memorandum, written to serve multiple audiences. Read and use what you need.

• Part One: New billboard
• Part Two: Resolution endorses pit production; seeks payoff, environmental analysis
• Part Three: Selected background on plutonium pits

Part One: New billboard

Tomorrow or Friday (February 4th or 5th), the Los Alamos Study Group's new billboard on northbound I-25 near Bernalillo will be installed.

The billboard is part of the Study Group's growing campaign to educate lawmakers, visitors, and the New Mexico public about the proposed plutonium warhead core ("pit") factory at Los Alamos National Laboratory (LANL), a major change in LANL's mission and the largest construction project in the history of New Mexico in constant-dollar terms.

Some 212,500 views per week are expected. It will look like this:

(Billboard web page) (larger pdf of this billboard).

Further billboards are planned, among other campaign elements.

The campaign is being funded by hundreds of grassroots donors. (The Study Group greatly welcomes contributions to this campaign -- via a secure, no-fee Paypal portal, by check, or any other means.)

This is a new mission. LANL has not had an industrial pit mission since 1949, when the pit production mission was transferred to the Hanford site. Starting in 1952, portions of the mission gradually moved to the Rocky Flats Plant near Denver over a number of years. From 1965 to 1989 "Rocky" manufactured all the plutonium components for the U.S. nuclear stockpile. At Los Alamos, Hanford, and Rocky Flats, pit production has always left a legacy of worker illness and early deaths, as well as irremediable contamination.

In a pair of decisions posted to the Federal Register on September 2, 2020 (here and here), the National Nuclear Security Administration (NNSA) assigned an industrial pit mission to LANL, for the first time in 72 years.

Two months later on November 5, 2020, NNSA also formalized a decision (here and here) to remodel a large, modern, safer but unfinished plutonium facility at the Savannah River Site (SRS) to provide pits as well.

The two multibillion-dollar factories are expected to cost $12 billion (B) just over the FY19-FY25 period, with many more billions after that (slides 23-27). 

Of the two factories, only LANL might be able to provide pits in the 2020s. Thus only LANL might be able to provide new pits for the new silo-based warheads slated for production starting in 2030. 

The SRS facility, once built and operating, will have all the production capacity that is needed. Meanwhile, LANL production is supposed to take place in an older, small and admittedly unsafe facility that will require round-the-clock production to reach as much as 20 pits per year (ppy). The more-than-doubled staff necessary to operate 24/7 makes LANL operations very expensive, in addition to being risky.

At LANL, construction for pit production is expected to cost at least $3.4 B (slide 23) over the FY19-25 period, on top of the billions already spent in prior years (i.e. 1992-2018), with more billions in construction planned but not yet budgeted for the late 2020s. In addition to construction costs, NNSA estimates startup and operational costs at LANL at $4.2 B over the same FY19-FY25 period (slide 23).

Each LANL pit can be expected to cost somewhere between $40 and $60 million (M), many times more than the Congressional Budget Office expects pits from SRS to cost and roughly 100 times more than what NNSA has recently projected. Over the last quarter-century, LANL's pit production costs have increased roughly 50-fold, as plan after plan has failed.

These and other interesting background issues are summarized in Part Three below, with references.

The cost of preparing for pit production at LANL exceeds that of any prior construction project in New Mexico, with the exception of the combined interstate highway system (slide 21).

****

(Related, another billboard in the campaign)

We believe that today's press release from New Mexico Voices for Children should remind all of us that New Mexico's social development policies have not been successful overall.

The covid pandemic has dramatically worsened the situation for at-risk children in this state, despite many excellent initiatives by state and local governments, nonprofits, churches and businesses, and individuals.

The failure of our social development policies is the subject of a billboard on westbound I-40 at San Jon, NM. (For more on this billboard please see Billboard aimed at traffic entering NM raises question:is New Mexico a "failed state," and are nuclear weapons partly responsible?, Jan 30, 2020.)

(Billboard web page; larger pdf).

The data -- not just opinion -- reveals that New Mexico is experiencing social and environmental emergencies. With inadequate governmental response despite good intentions, New Mexico risks becoming a "failed state" -- essentially an internal colony with no real prospects for economic or social development. We believe our Governor and legislature do not grasp the gravity of the situation or the magnitude of democratic reforms needed.

We believe that among the principal factors corroding New Mexico's sovereignty, self-determination, and well-being is its status as the world's preeminent center for spending on weapons of mass destruction. This industry is poised to enter a new and more virulent phase in New Mexico if it is not effectively opposed. We do not believe this industry benefits our state in any way.

Part Two: Resolution endorses pit production; seeks payoffs, environmental analysis

On January 28 the Santa Fe Board of County Commissioners unanimously passed a resolution tacitly endorsing expanded LANL plutonium bomb production while promoting nuclear weapons jobs, educational outreach and training for nuclear weapons workers, and lucrative local nuclear contracts.

The resolution also requested a new Site Wide Environmental Impact Statement (SWEIS) for LANL.

This comes only after a September 2, 2020 Department of Energy (DOE) and NNSA decision to not produce a SWEIS at this time.

In contrast with several prior Santa Fe City and County resolutions (see below), this resolution does not oppose pit production, nuclear weapons, or a new arms race, and notably it does not seek to halt construction of LANL pit production facilities either prior to production of a SWEIS, as the National Environmental Policy Act (NEPA) requires -- or at all.

Unlike the language of this resolution, the NEPA statute, regulations, and case law do not condone environmental analysis after a federal decision is made and environmental impacts have begun.

The resolution does not mention the Treaty for the Prohibition of Nuclear Weapons (TPNW), which entered into force on January 22, 2021. For states parties, the TPNW stigmatizes LANL's main mission and charges signatory states to develop domestic laws, including criminal laws, that apply to anyone aiding LANL's main mission.

The resolution emphasizes the importance of keeping local governments "fully informed" about [projects] to facilitate large-scale production of additional plutonium warhead cores" at LANL so as to "make citizens aware" and to "reassure the citizens of Santa Fe County that the safety and environmental issues entailed in this growing project are being planned for in a careful and comprehensive way" (emphasis added).

The resolution states that "the citizens of Santa Fe County should benefit from the National Laboratory's presence through educational outreach, greater environmental remediation funding, workforce training and development and small business opportunities." (emphasis added).

The resolution requests that NNSA, as it conducts a new SWEIS, "take more concerted action to benefit the citizens of Santa Fe County," and "expand both their educational outreach opportunities and workforce training efforts to further benefit the citizens of Santa Fe County" and "further expand the procurement opportunities for our local small businesses vital to the generation of Gross Receipts Taxes needed for county operations." (emphasis added).

The resolution requests that NNSA suspend any planned expanded plutonium pit production [only] "until all outstanding nuclear safety issues are resolved" (emphasis added). To repeat, construction is not to be suspended.

Study Group director Greg Mello:

"We do not support this resolution. It is far too little, much too late, and much too supportive of nuclear weapons, pit production, and their purported "benefits" to New Mexico. These factual and moral distortions damage the public record and the moral temper of northern New Mexico. This resolution smacks of the Stockholm Syndrome, where captives come to love those who control and terrorize them.

"We want the County to rescind this resolution, which is one reason why we are going into this matter in detail.

"Some of the "whereas" sections contain what appear to be technical errors. Governing bodies are not in any position to opine on many of these issues anyway. They are in a position to make political judgments, and this is paradoxically what is missing. This resolution has no backbone.

"Commissioner Roybal works for LANL, and should have recused himself from considering this resolution. Commissioner Hamilton may have a conflict of interest also, if she works for a DOE environmental contractor.

"Leaving conflict of interest issues aside, the more important point is that Commissioner Roybal's "friendly" amendments could never have been considered if the resolution as originally offered had solid anti-nuclear-weapons features. It did not. So the wholesome debate that should have been triggered about the benefits of LANL, the merits of pit production, and the increasing role of nuclear weapons in Santa Fe County economics, society, and politics didn't happen.

"The real purpose of any resolution such as this would normally be to debate and establish a political and moral perspective in the community. What we got instead was unanimous cowardly consent.

"What this resolution says is, "Go ahead and build the factory, tell us it's safe, let us come to your dog and pony shows and meanwhile come right on in and build your pit factory in our community. And you can indoctrinate and then take all our children if you need them. Take the kids, but give us your money.

"A better version of this resolution should have been considered a year or two ago, when it was timely. Now the hour is very late -- real opposition is needed. The highly-conspicous absence of any opposition to pit production in this resolution is very telling. Far from opposing, this resolution is not even agnostic about building a Rocky Flats Plant in northern New Mexico. It very much supports such a plan.

"We wish Commissioner Hansen had withdrawn this resolution when Commissioner Roybal proposed his amendments. Failure to do so was bad judgment in an experienced public servant. We expected and deserved better.

"The Santa Fe County Commission doesn't know what LANL's plans even are. Have they ever truly demanded to know? Does the Commission know what LANL's plans in Santa Fe County are? We know NNSA and LANL seek to lease additional LANL facilities in Santa Fe County. We believe some of those plans are already in motion. It appears the Commission is asleep at the switch. LANL and NNSA's specific plans are much more important to know, and know right now, than impact analysis a year or two from now based on generalized scenarios, which is what would come from a SWEIS. The lack of openness by NNSA and LANL is very concerning, and affects the County directly, but this resolution does not touch upon that.

"Among the documents the Commission needs, right now, are the contractually-required LANL Site Plan and the congressionally-required NNSA plan for plutonium pit production at LANL. These should be available to the public, and the County should be focusing its efforts on getting them. Only then should the Commission act -- on the basis of real knowledge.

"The information the Commission wants and needs will not be provided in a SWEIS, which will also not be written overnight or in any kind of timely manner vis-a-vis ongoing investments, construction, hiring, resulting housing and transportation needs, and so on. Producing a SWEIS normally takes at least a year.

"If the Commission knew what NNSA's and LANL's actual plans were right now, the County and its citizens would be in a much better position to consider the impacts, which a SWEIS will obscure more than reveal, while also delaying what little transparency it might provide. With actual, real information in hand (as opposed to the hypothetical world of a SWEIS), the Commission would be able to -- by itself and through the ordinary planning processes underway -- evaluate impacts, choose alternatives, and determine where the most important unresolved questions lie. Citizens would be in a position to help a great deal, and democratic processes would be strengthened.

"Given NNSA's prior decision to NOT produce a SWEIS, and the complete lack of support for a SWEIS from the New Mexico delegation, Governor, and legislature -- which even if present might not now be enough to reverse the DOE/NNSA decision -- the workforce and contracting language stands out as much more important than the NEPA part. If there is a SWEIS, will NNSA stop doing what it has been funded at over $1 billion to do, just in this fiscal year alone? There is a legal mandate for NNSA and LANL to continue, to meet a 2026 production deadline. So the answer is: assuredly not, unless the County were to act in some far stronger way. Unless the County can bring itself to actually oppose this mission, which this resolution does not do and the five commissioners just voted unanimously not to do, why is this more than the feeblest of gestures?

"Please note again that, contrary to NEPA, this resolution does not ask LANL to halt construction of a pit factory prior to the conclusion of the SWEIS process and a formal Record of Decision. That alone speaks volumes about the intent and meaning of this resolution.

"We would support a resolution which included asking for a SWEIS, even at this late date, but only if the above problems and huge omissions were corrected. We urge any other local government body considering such a resolution to think long and hard before opening the door to pit production with a resolution like this one that does not fix these fundamental problems.

"The resolution process, which has little enough value to start with, needs to be contentious to be valuable at all. We need to talk about our region's commitment to nuclear weapons, which play far too great a role in our political economy.

"At the same time we need to build careers and a new identity and self-determination in our communities and cities, based on a new, green social contract -- not a government nuclear weapons contract. We've got to build our lives and careers around taking care of each other and our environment, not in building doomsday weapons. We should stop processing plutonium altogether. If we do not it will sicken some of us and invariably contaminate the land and waters we depend upon. The billions of the dollars going into this factory is the money we need and deserve for our families, schools, and businesses."

Here are all the nuclear weapons resolutions passed by local governments in northern New Mexico since 1994. Some of them are described and excerpted below. As you can see, many of these resolutions are a lot stronger than the one that just passed.

City of Santa Fe Resolution 2017-80, Nov 8, 2017
-- Supporting restricting first use of nuclear weapons act of 2017 and in opposition to nuclear weapons agenda of current administration

Santa Fe County Commission Resolution 2010-221, passed unanimously Nov 30, 2010
-- In support of a new Environmental Impact Statement for Los Alamos National Laboratory's Chemistry and Metallurgy Research Replacement Nuclear Facility Project

Santa Fe City & County Joint Resolution 2010-91, passed unanimously Nov 10, 2010
-- In support of a new Environmental Impact Statement for LANL's Chemistry and Metallurgy Research Replacement Nuclear Facility

City of Santa Fe Resolution 2008-17, passed unanimously Feb 13, 2008
-- Objecting to proposed nuclear weapons complex "transformation" activities at Los Alamos National Laboratory, including expanded plutonium pit production

… BE IT FURTHER RESOLVED that the governing body hereby states its objection to the expansion of nuclear weapons activities at the Los Alamos National Laboratory, including further increased plutonium pit production….

City of Santa Fe Resolution 2006-104, passed unanimously Aug 28, 2006
-- Objecting to proposed expanded nuclear weapons activities, including plutonium pit production, at the Los Alamos National Laboratory

… NOW, THEREFORE, BE IT RESOLVED BY THE GOVERNING BODY OF THE CITY OF SANTA FE that the governing body hereby states its objection to the expansion of nuclear weapons activities at the Los Alamos National Laboratory, including increased plutonium pit production; and …

City of Santa Fe Resolution 2005-39, passed unanimously Apr 13, 2005
-- Supporting compliance by the United States with the Treaty on the Nonproliferation of Nuclear Weapons

NOW, THEREFORE, BE IT RESOLVED BY THE GOVERNING BODY OF THE CITY OF SANTA FE that

Section I. The governing body recognizes:

(a) The legal obligation to nuclear disarmament stated in Article VI of the NPT and authoritatively interpreted in the 1996 unanimous advisory opinion of the International Court of Justice;

(b) The importance of United States leadership in nuclear disarmament and nonproliferation;

(c) That a posture of nuclear threat or deterrence cannot remain the sole prerogative of the United States and a small group of countries friendly or not actively hostile to the United States;

(d) That the federal commitment to nuclear weapons expends enormous resources and talent, creates security and safety problems that can never be fully solved; undermines the ethical basis of our society by promoting massive and indiscriminate violence, and permanently contaminates portions of our environment;

(e) That proposals to upgrade nuclear weapons, design new varieties of such weapons, maintain thousands of nuclear weapons or build new or expanded factories for the manufacture of nuclear weapons and nuclear weapons components should be viewed with dismay; and

(f) As immoral the notion that human security can ever be built upon instruments of mass destruction and the will to use them.

Section 2. The governing body calls upon our elected representatives to Congress as well as upon our Governor to publicly:

(a) Reaffirm the complete commitment of the United States to an unequivocal undertaking to the total elimination of nuclear arsenals leading to nuclear disarmament to which all States parties are committed under Article VI;

(b) Call for progressively and systematically dismantling our nuclear arsenal in concert with other nuclear powers pursuant to Article VI of the NPT and any other treaties and agreements as may be prudent to negotiate;

(c) Call for negotiations on treaties involving universal norms against all weapons of mass destruction;

(d) Reject all proposals to build new or expanded factories for nuclear weapons and nuclear weapons components; and [emphasis added]

(e) Request that the federal government minimize and ultimately halt disposal of nuclear waste in northern New Mexico.

Section 3. The City Manager is directed to forward this resolution to the Monitoring, Data Base and Information Branch of the Department for Disarmament Affairs of the United Nations, all members of the United States Congress, the Governor of the State of New Mexico and all members of the New Mexico Legislature….

City of Santa Fe Resolution 2003-64, passed unanimously, Aug 13, 2003
-- Objecting to the location of a Modern Pit Facility in Northern New Mexico

NOW, THEREFORE, BE IT RESOLVED BY THE GOVERNING BODY OF THE CITY OF SANTA FE that the governing body hereby states its objection to the Department of Energy regarding the location of a new and or expanded modern pit facility in northern New Mexico; and…

City of Santa Fe Resolution 1994-49, Jul 13, 1994
-- Supporting an Environmental Impact Study and Analysis of Alternatives at Los Alamos National Laboratory

NOW, THEREFORE, BE IT RESOLVED BY THE GOVERNING BODY OF THE CITY OF SANTA FE that: …

2. The City of Santa Fe requests that all applicable environmental laws be obeyed by the DOE, and appropriate (and legally mandated) citizen participation be actively supported in the determination of the future mission and function of LANL.

3. The City of Santa Fe requests that a site-wide Environmental Impact Study and National Environmental Policy Act, (NEPA) analysis be completed of LANL's future, prior to any Congressional or DOE actions which could prejudice the outcome of public and local government participation, and prior to any new major construction activities, including waste disposal facilities at LANL as requested in the letter to the DOE Secretary Hazel O'Leary, dated April 28, 1994, signed by the Eight Northern Pueblos Council, community, labor, religious, and environmental organizations representing over 20,000 citizens of the State of New Mexico….

Part Three: Selected background on pits

(Please also see: NNSA pit production strategy: no clear goals, plans, or likelihood of success; Production at LANL has high risks and costs, few or no program benefits, Oct 1, 2020, updated Oct 3, 2020)

In 2018 the National Nuclear Security Administration (NNSA) proposed – and since then Congress has fully funded, at least so far – construction and operation of two factories for producing new plutonium warhead cores (“pits”), one at Los Alamos National Laboratory (LANL) in New Mexico and one at the Savannah River Site (SRS) in South Carolina. At LANL, production must begin with one stockpile-ready (“War Reserve,” WR) pit in 2023, ramping up to 10 WR pits in 2024, then 20 in 2025, and then at least 30 such pits (“≥30 ppy”) by 2026. Combined production at both sites is required to be ≥80 ppy by 2030 (50 U.S.C. §2538a). Under the current plan, production from the larger SRS facilities at ≥50 ppy would be added to LANL’s ≥30 ppy to meet the overall 2030 production deadline.

Operations at the two sites would differ markedly. For example at LANL, two production shifts and one maintenance shift would be needed on a 24/7 basis to reach production ≥20 ppy (p. 15). The larger SRS facility has enough usable space to accommodate single-shift operation for up to ≥80 ppy two times over (~103 ppy on average, p. 13), not just ≥50 ppy, even if analytical chemistry (AC) is also housed there (pp. 76-79).

Further statutory requirements affecting LANL especially were enacted in 2018, after NNSA’s 2017 Analysis of Alternatives (AoA) for the ≥80 ppy mission found that existing facilities at LANL, even if augmented by new multibillion-dollar production “modules,” would not be adequate for the whole mission. Building a new production facility at LANL – the only LANL option NNSA found feasible – would cost more and take longer to provide than remodeling the existing SRS facility.

The LANL production complex would be based in a suite of repurposed facilities in Technical Area (TA-) 55, centered in a 42-year-old facility (“PF-4”) originally built for R&D, not manufacturing (p. 2). The SRS complex would be housed in and around a remodeled, partially-built new facility five times larger than PF-4 (pp. 48, 79), re-christened the “Savannah River Plutonium Processing Facility” (SRPPF). 

NNSA itself (p. 2), as well as the Institute for Defense Analyses (IDA) (p. vii), have previously said the ≥80 ppy-by-2030 requirement is highly unlikely to be met, especially if NNSA attempts shortcuts. In 2020, GAO cited a classified LANL study saying LANL was only “marginally capable” of reaching 30 ppy by 2026“ and sustaining that rate thereafter” (p. 30), a result to which NNSA Administrator Lisa Gordon Hagerty has also testified. Key LANL projects needed for pit production will not be completed until FY26-29 (pp. 193, 433, 490).

The FY21 NDAA provides a potential “out” from impossible pit deadlines

Pit production requirements were modified by Section 3114 (pp. 992-993) in the fiscal year 2021 National Defense Authorization Act (FY21 NDAA; became law on 1/1/21). This new law creates conditions that could lead to a delay by up to 5 years in any or all of the 50 U.S.C. §2538a requirements, affecting LANL, SRS, or both.

If independent cost estimates (ICEs) find that either of the two main multibillion-dollar, never-before-attempted, decade-long plutonium infrastructure projects now underway at LANL and SRS could cost more than 115% of DOE's preliminary estimates (the "low confidence" case), the Commander in Chief of the U.S. Strategic Command (CINCSTRAT) may certify that pit production deadlines can be delayed by up to five years if the "deterrence missions" and "military effectiveness" of the U.S. nuclear weapons arsenal would not be degraded by such a delay. Alternatively, the CINCSTRAT may decide that current production deadlines must stand. The production deadlines are statutory, so it would be up to Congress to formally change them on the basis of this recommendation.

Regardless of what the CINCSTRAT decides, if either of the ICEs is more than 115% of DOE's estimate, DOE must either change the project in question or certify to Congress that its own cost estimate is accurate after all. It is remarkable that the law requires preliminary cost estimates (those available at "Critical Decision One" or “CD-1” in DOE parlance) to be as this accurate.

The law applies to two capital projects only: the "Los Alamos Plutonium Pit Production Project" (LAP4, DOE Project 21-D-512, pp. 193-198), which is to be completed in FY28; and the "Savannah River Plutonium Processing Facility Project" (SRPPF, DOE project 21-D-511, pp. 199-205), to be completed by FY31, followed by prove-in and production. The new law does not apply to supporting projects like waste management facilities, training centers, analytical laboratories, parking garages, office buildings, overall site improvements, etc. unless they are part of these two line items.

Most importantly, the law does not apply to operational ("program") spending. Thus the cost of preparing for pit production at both sites is much greater than the costs of just LAP4 and SRPPF. So far, these extra costs are far greater at LANL, where most pit production spending (this year, about three-fourths of it; see slides 23 & 26) is in relatively unaccountable “program” spending. The opposite is the case at SRS. Also, the scope of LAP4 does not include at least $200 M annually in supporting construction. SRPPF is a newer project; its comprehensiveness cannot yet be determined.

DOE has never completed any project of the scale and complexity of either LAP4 and SRPPF projects without large cost overruns and schedule slippage (pp. v-vi). This is the pattern for "megaprojects" worldwide; only roughly one in a thousand megaprojects delivers the estimated benefits on the estimated schedule, within the estimated budget. NNSA's management of large projects is particularly fraught: NNSA and its predecessor DOE Defense Programs have never left the Government Accountability Office's (GAO's) "high risk list" for waste, fraud, abuse, and mismanagement in four decades.

The previously-estimated “$3 B” cost for establishing a nominal 30 ppy production capability at LANL (slide 2) and now the narrow scope of LAP4 have given many parties the mistaken impression that pit production at LANL would be relatively cheap. The reality is otherwise. As will be discussed further below, each LANL pit would cost 6-10 times what a SRS pit would cost, and almost 100 times what NNSA has claimed, whether or not NNSA's pit production deadlines are relaxed by up to five years (slides 28-31).

Pit production capability is a part of a large, costly nuclear modernization plan

Pit production is a central component in a large, complex plan to modernize or replace every warhead, missile, submarine, airplane, laboratory and factory in the U.S. nuclear weapons universe (DoD and NNSA roadmaps; summary pp. 11-12; NNSA’s plans and budgets). Success is far from certain. To execute this plan NNSA must increase its total (trained) workforce by 20,000, an increase of 50% in just 5 years.

In 2017 the Congressional Budget Office (CBO) estimated that modernizing and deploying U.S. nuclear forces over 30 years would cost ~$1.2 trillion. Updating CBO’s estimate and inflating it to 2021 dollars gives an up-to-date 30-year estimate of ~$1.45 trillion, or $2.0 trillion if environmental liabilities are included (pp. 8-9).

NNSA’s actual inflation-corrected warhead costs have risen more than 12% annually since 2013, jumping 23% just this year. Despite this increase, NNSA, GAO (here and here), and the U.S. Strategic Command all say in various ways that NNSA’s ambitious, simultaneous warhead schedules and programs are outstripping available infrastructure and personnel. As the CINCSTRAT recently noted, the availability of new pits is far from the only risk to NNSA’s ambitious warhead schedules.

Two purposes, two factories

NNSA, DoD and Congress appear to have two distinct pit production goals: 1) a short-term goal of reaching ≥80 ppy by 2030 which might produce an estimated ~231 pits from 2023 through 2030 (p. 16); and 2) a goal of acquire an enduring single-shift pit production capacity at ≥80 ppy, i.e. ~103 ppy on average (p.13). These two distinct goals are the only defensible reason for two industrial pit factories, as the larger SRPPF, once operational, would easily and more cost-effectively handle all needed production.

SRPPF’s 400,000 sq. ft. of useable space (p. 79) is much greater than the 110,000 sq. ft. of useable space needed for the ≥80 ppy mission, or 130,000 sq. ft. including essential building services (p. 76), leaving plenty of space in SRPPF for analytical chemistry and other supporting functions. If SRPPF is completed there would be no need for quantity production at PF-4, releasing that facility for R&D missions, as NNSA proposed in 2017 (p.2).

Early (i.e. 2020s) production, which must be at LANL if it can be achieved at all, may not be able contribute to enduring pit production capability, even with PF-4 recapitalization.  In June 2017, NNSA, under the direction of Obama-appointed Frank Klotz, ruled that the aging, small, otherwise-tasked PF-4 could not play an enduring role in pit production (pp. 2, 47-48). [2039 EOL).

Yet early production at LANL is needed if production of the W87-1 warhead is to begin in 2030 with new pits. That production is now a ~$14 B megaproject (slides 28-31) with dubious claims to longevity and high risk of failure.

A PF-4 “surge” involving 24-hour operations (p. 15)” became part of the program of record in 2020, following a mandate in the FY19 NDAA (at §3120). Yet NNSA’s 2018 Engineering Analysis (EA), prepared by Parsons, rated the LANL alternative involving a surge as by far the highest risk (Alt. 2c, s. 8; risks listed, pp. 4-22, 4-23) and in 2019 the IDA found that any PF-4 surge would be “very high risk” (p. vii).

Pit production in a facility built to purpose has strong economies of scale. Increasing capacity at SRPPF post-2030 from ≥50 to ≥80 ppy would require only an additional 22 pieces of equipment, 20% more (AoA, p. 17) and an additional 6,350 sq. ft. of Hazard Category (HC) 2 space (AoA, p. 45), less than 2% of the SRPPF total (EA, p. 2-30). The capital cost of this additional equipment and space is very small – much smaller than the uncertainty in costs at either LANL or SRS.  Increasing capacity at SRPPF from ≥50 to ≥80 ppy, single shift, would require an additional 185 staff (i.e. 10% more) (p. S-27). Total SRS pit operational costs would increase modestly – again, well within present uncertainties. Similar economies of scale were found in a 1998 Defense Programs study. As the AoA put it, ”the difference between a 50 WR ppy equipment set and an 80 WR ppy equipment set is within the range of error” (p. 2).

PF-4 currently houses several other NNSA plutonium missions and is the only U.S. facility capable of doing so. What space remains in PF-4 is too small to produce even 20 ppy without resorting to “24/7” production, as noted (p. 15).

Three work shifts (two for production, one for maintenance) requires a much larger staff and more support facilities, and therefore has high operating costs. LANL plutonium workers (direct and support) would number ~4,000 in the LANL plan, ~2,000 more (pp. 12, 15) than the ~2,000 already on staff as of late 2019 (NNSA Jan. 2020 briefing, not published), more than worked at the former Rocky Flats pit plant for all but its last decade.

The present two-factory approach marks a dramatic shift from the “two-pronged approach” (p. 2) that prevailed from 1996-2018, in which R&D, pilot pit production, and pit surveillance were conducted at PF-4 and, when necessary, an industrial pit capability in an appropriate facility would be established.

LANL’s three-decade pit struggle

In late 1987, the FY88/89 NDAA required a comprehensive study of warhead complex modernization (§3132), subsequently leaked to the press in December 1988. The report called for relocating the functions of the Rocky Flats Plant (RFP) as soon as possible. That same year LANL, then directed by plutonium scientist Siegfried Hecker, began to plan for a large (193,000 sq. ft.) new plutonium facility, the Special Nuclear Materials Laboratory (SNML), which was to be the most expensive project in LANL’s history. LANL also began to acquire key manufacturing personnel and equipment from RFP. LANL was formally assigned “non-nuclear” portions of the pit production mission in 1993 (Fed. Reg. July 8, 1993, pp. 36658-36663) covering 22 out of the 25 parts in a typical pit (p. 1).

The grandiose SNML was canceled in 1990 in favor of recapitalizing an existing facility via the Chemistry and Metallurgy Research Upgrades (CMRU), itself the largest capital project in the warhead complex in the early 1990s. CMRU proceeded haltingly for a decade before being found infeasible and canceled in 2001. During the latter part of this decade many pit production capital expenses at PF-4 were carried in the “Capability Maintenance and Improvement Project” (CMIP).

In 1996, LANL was formally assigned the interim pit production mission on the basis of representations that LANL could begin production at 50 ppy (single-shift, 5 days/week) beginning in 2002 at an incremental operating cost of $30 million (M)/year and an additional capital investment of $110 M over what was required at TA-55 anyway. An additional $44 M would buy 100 ppy capacity, then considered LANL’s maximum. In the same December 1996 decision LANL’s actual production was legally limited to ≤20 ppy, which remained the legal limit until 9/2/20.

Three months earlier, the FY97 NDAA had become law, requiring (at §3151) a report on reconstituting a larger pit production capability, based on the understanding that the LANL capability would be inadequate for stockpile production when that was eventually required. LANL’s technology demonstration, pilot production role was explained in the first Stockpile Stewardship and Management Plan and related documents obtained in litigation (see section E, this affidavit).

The cancellation of CMRU led to the initiation of the Chemistry and Metallurgy Research Replacement (CMRR) Project, involving construction of what gradually became a large (406,000 sq. ft.), expensive ($5.9 B) HC2 plutonium facility at TA-55, the CMRR Nuclear Facility (CMRR-NF), and a related radiological laboratory, utility, and office building (RLUOB). CMRR-NF was eventually cancelled after litigation-related delays. A decade of design and more than $400 M had been spent on the project.

Now RLUOB (re-christened “PF-400”) is being administratively upgraded from a Radiological Facility with a material-at-risk (MAR) limit of 8.4 grams Pu-239 equivalent (Pu-239e) to a Hazard Category 3 (HC3) Nuclear Facility with an ultimate MAR limit of 2.61 kg Pu-239e. NNSA currently promises to operate PF-400 with a MAR limit of 400 g Pu-239e. The cost of this building and its equipment have increased by a factor of 4 or more to $1.4 B (historic comparisons, p. 3; PF-400 is composed of four RLUOB subprojects, pp. 494-495). PF-400 completion is not expected until 4QFY28 (p. 493).

Over these years LANL has struggled with several TA-55 and pit-supporting projects, including the Nuclear Materials Storage Facility (designed and built defectively, never used, quietly bulldozed) and an upgraded security perimeter for TA-55 (~$5,000/inch, p. A-7). Radioactive liquid waste facilities as well as radioactive solid waste facilities have had their own sagas, as yet unfinished.

Eventually LANL was able to make a total 30 stockpile-quality (“war-reserve,” WR) W88 pits over a six-year period (FY07-12), all that were required (slide 24) in what was fundamentally a technology demonstration. The following year, PF-4 operations were shut down for numerous safety violations and remained at least partially halted through mid-FY17.

After three decades and billions spent or wasted, LANL has no current capability to safely make pits and will require billions of dollars in further capital investments and the initiation of 24/7 operations to reach a capacity, expected in FY25, of 20 WR ppy.

Pits, especially from LANL, will be costly

NNSA estimates the cost of producing new pits for the complete W87-1 warhead build – the size of which is classified – at $300-$750 M, 2-8% of the total W87-1 program cost  (p. 22), not counting the cost of building and starting up two new pit factories. CBO disagrees, estimating the marginal cost of each SRPPF pit at $6 M (p. 14), about one-third the total cost of each warhead, again not counting the capital and start-up costs of the two factories.

LANL’s costs would be higher still. As previously noted, in 2017 the cost of establishing a 30 ppy capability (the average, not the minimum) at LANL was thought to be $3 B (slide 2). Now NNSA has requested $7.6 billion (B) for pit production construction, equipment, and startup at LANL through FY25 (slide 23). In the absence of any resourced master plan, schedule, or backup plan from NNSA for pit production (GAO, e-p. 2; pp. 29-38), let alone one that is publicly-available, we estimate that building and operating the LANL plant up to the first W87-1 production year (2030) will cost $14 B (slide 29). assuming the current safety deficiencies and other difficulties can be surmounted.

We estimate pit production at LANL will cost $38-60 M per pit under various scenarios (slides 29-31), almost an order of magnitude more than at SRS and roughly two orders of magnitude beyond NNSA’s inferred cost for W87-1 pits.

The enormous cost premium attaching to immediate production also indicates higher risk. It is not yet possible to credibly predict future pit production at LANL, given the unresolved safety problems flagged by the DNFSB (slides 6-15; for dates of possible resolution see s. 21).

These large cost and risk premiums are a result of re-missioning an older R&D facility (PF-4) for industrial production, in order to meet the 2030 pit production deadline, which is driven solely by the first production date for the W87-1 warhead.

Can PF-4 meet modern safety standards?

LANL’s PF-4 lacks modern safety features (pp. 7-10; also here) to protect workers and the public in the event of a severe (“design-basis”) accident. PF-4’s safety basis “does not adequately protect the public,” according to the Defense Nuclear Facilities Safety Board (DNFSB, p. 5; more here).

Remarkably, after more than two decades of study NNSA is still not even sure whether the PF-4 building itself, let alone its safety systems, could survive a severe earthquake (p. 8; also here). Billions have already been spent to upgrade TA-55 facilities, and billions more are slated to be spent in safety and capacity upgrades at PF-4 and connected facilities through the end of FY29 (pp. 153-154, 440, 490).

For these and other reasons NNSA found that if LANL is to produce stockpile pits for very long, new plutonium facilities would be necessary. Two very different NNSA studies, each with very different underlying assumptions and authors, either eliminated (AoA briefing, report), or circumscribed (EA briefing, report), possible future roles for PF-4 in pit production. Neither major report thought the LANL option in the present pit strategy worthy of analysis.

From this and the June 2017 Secretarial-level decision of (pp. 2, 47-48) we infer that any long-term pit production plan at LANL includes new Hazard Category II (HC2), Security Category I (SC1) production facilities, as yet not included in any publicly-visible documents.

***ENDS***