On Feb. 22, the National Nuclear Security Administration released a draft environmental assessment for the Radiological Laboratory Utility and Office Building (a.k.a. “Rad Lab”) at the Los Alamos National Laboratory. This is pursuant to requirements under the National Environmental Policy Act to provide the public with an opportunity to review and comment on major federal proposals. The comment period closed on April 25.
NNSA’s proposal is to re-categorize the Rad Lab as a Hazard Category-3 nuclear facility so that it can raise ten-fold the amount of plutonium used there from 38.6 grams of plutonium-239 to 400 grams. NNSA claims that the proposal’s only purpose is to maintain materials characterization and analytical chemistry capabilities for plutonium at LANL.
This involves transferring those operations out of the old, deteriorating Chemistry and Metallurgy Research (CMR) Building to the Rad Lab and its neighboring plutonium pit production facility, PF-4.
Re-categorizing the Rad Lab as a Hazard Category-3 nuclear facility is just one of four construction subprojects at the Rad Lab and PF-4 that relocate analytical chemistry and materials characterization operations; together, they cost $2 billion.
Even though the draft Rad Lab environmental assessment lists various “reasonably foreseeable actions” that will affect LANL in the future, it completely fails to mention expanded production of plutonium pits, the cores of nuclear weapons.
That omission is absurd (intentional?), since expanded pit production is far more than just foreseeable – it is statutorily required by the FY 2015 Defense Authorization Act and is being actively planned for.
The independent, congressionally commissioned Defense Nuclear Facilities Safety Board recognizes this, and calls it for what it is. One of its weekly reports from 2015 refers to infrastructure projects connected to replacing the old CMR Building, including two that “primarily support the increased capacity required for larger pit manufacturing rates.”
To top it off, the draft Rad Lab environmental assessment is grossly premature.
It has been widely reported that NNSA will announce on May 11 where future plutonium pit production will take place, either at LANL or the Savannah River Site in South Carolina, or both.
It is absurd that NNSA started the environmental assessment process before that decision, which could render re-categorization of the Rad Lab to a Hazard Category-3 nuclear facility unnecessary to begin with.
More narrowly, some of the Rad Lab environmental assessment’s specific deficiencies are:
⋄ It lacks any consideration of toxic beryllium risks, when the FY 2019 NNSA budget says that beryllium analysis will be a new capability at the Rad Lab. Beryllium is a light metal used in materials research, defense systems and testing at LANL that in powdered form and airborne can be highly toxic.
⋄ Contrary to stated Department of Energy National Environmental Policy Act (NEPA) policy, there is no analysis of the possibility of “intentional destructive acts,” defined as sabotage or terrorism, including intentional airplane crashes, that could damage the facility.
• The draft Rad Lab environmental assessment explains away safety and seismic concerns based on “preliminary” analyses. That’s not good enough. Safety and seismic concerns should be resolved through completed, peer-reviewed analyses.
Finally, if NNSA decides on May 11 to conduct expanded plutonium pit production at the Savannah River Site, or perhaps LANL as well, then a nationwide programmatic environmental impact statement (PEIS) will be required.
In any event, NNSA is required to produce a new or supplemental PEIS to raise the current 20 pits per year cap on pit production that has been in place since 1996. Ironically, the plan to increase future pit production to 80 pits a year is not intended just to keep the existing nuclear weapons stockpile safe and reliable. Instead, it is for future speculative, new-design nuclear weapons called Interoperable Warheads that the Navy doesn’t even want.
Moreover, future pit production could undermine confidence in nuclear weapons reliability, since exact replicas of existing pits are NOT going to be produced.
NNSA needs to go back to the drawing board to get its plutonium ducks in a row under NEPA. Following its May 11 decision, NNSA should begin a nationwide review of plutonium pit production, why it’s needed and what it will cost the American taxpayer in financial, safety and environmental risks. These are all things that the public should know.
Coghlan is executive director of Nuclear Watch of New Mexico (www.nukewatch.org), a Santa Fe-based group that tracks Los Alamos National Laboratory and related issues in the Southwest.