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"Forget the Rest" blog


Volume 15 No. 18                                                                                                                             April 29, 2011


A long-awaited National Nuclear Security Administration draft environmental analysis calls for sticking with the agency’s proposal to build a new Chemistry and Metallurgy Research Replacement-Nuclear Facility at Los Alamos National Laboratory. The draft Supplemental Environmental Impact Statement (SEIS), released after close of business on Friday, April 22, calls as expected for continued work to build the multi-billion-dollar facility, arguing that other alternatives considered do not meet mission and nuclear safety needs. The 344,000-square foot concrete complex would be far more massive than a plan approved in the early 2000s, a nod to the increased seismic risks at Los Alamos that have been identified in the years since. “Enhanced safety requirements and updated seismic information have caused NNSA to re-evaluate the design concept of the … the CMRR-NF,” according to the study. “The proposed Modified CMRR-NF design concept would result in a more structurally sound building.”

The new SEIS was released a few days before the NNSA appeared in federal court in Albuquerque to defend itself against charges that its environmental analysis of the project is inadequate. The Los Alamos Study Group, a New Mexico-based activist group, sued last summer, arguing that vast changes in the project rendered a 2003 analysis under the National Environmental Policy Act inadequate. Attorney Tom Hnasko, representing the Study Group, argued in the April 27 hearing for a preliminary injunction that would halt work on CMRR-NF, including ongoing design activities and security upgrades related to the facility. Hnasko compared the NNSA NEPA compliance with a federal agency that performs an environmental impact statement to build a small regional water retention structure and then decides to use it to authorize building the Hoover Dam. “You cannot commit to a project while the NEPA analysis is incomplete,” Hnasko told the court.

Record of Decision to Precede Construction

In response, NNSA counsel Andrew Smith argued that the case did not even belong before the court because a new SEIS is in preparation and construction will not commence until that review process is completed and a new “Record of Decision” is issued on the project. Princeton arms control scholar Frank von Hippel, testifying on behalf of the Study Group, argued that the need for CMRR-NF has become less urgent in the years since the project was launched, citing a report by the JASON Defense Advisory Group, a panel of independent government experts, that plutonium pits in U.S. nuclear weapons could last 100 years of more. The court discussion was continued to May 2, when federal officials will be given a chance to offer their rebuttal to the Study Group’s case.

SEIS Details

The SEIS considered and discarded a number of alternatives to continuing with CMRR-NF:

— A “no action” alternative, which would have continued with the original early 2000s design. Such an approach would not meet seismic nuclear safety standards, according to the SEIS;
— Continued use of the 60-year-old CMR building, where plutonium analytical chemistry is done at Los Alamos today. Safety concerns in the aging facility rendered that option in adequate, according to the SEIS. Upgrading the old facility also was determined to be technically infeasible and not studied in detail,
the draft analysis said;

— The possibility of locating the operations at a site other than Los Alamos was ruled out, based on previous review under the Complex Transformation process; and
— Other sites at Los Alamos also were not analyzed in detail because they had been ruled out in the previous environmental analysis done for the project.

One of the biggest changes between the early 2000s-era CMRR-NF and the current design is the massive amount of concrete to be used to harden the structure against earthquake damage - 150,000 cubic yards compared to 3,194 cubic yards in the original design. The SEIS makes clear that NNSA is still wrestling with the best way to build the new structure, with “deep excavation” and “shallow excavation” options currently on the table to deal with seismic stresses.

— From staff reports (reprinted with permission)

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