POGO makes comments on the final Supplemental Programmatic Environmental Impact Statement for the National Nuclear Security Administration’s (NNSA) Records of Decision on Complex Transformation

Mr. Thomas P. D'Agostino

Under Secretary for Nuclear Security & Administrator for NNSA

National Nuclear Security Administration

Department of Energy

Washington, DC 20585

Via Email

Dear Under Secretary D'Agostino:

We are writing to point out some serious deficiencies in the Final Complex Transformation Supplemental Programmatic Environmental Impact Statement (SPEIS).

1. 1. 1. The preferred alternative of up to 20 pits a year produced at LANL until the completion of the Nuclear Posture Review is not justified. Instead, NNSA should utilize the concept of "warm standby," which would address the stated need to retain the technical capacity to manufacture pits, while not creating more pits by giving scientists a finite amount of plutonium for perfecting a prototype. They would then destroy this model, and use the material to build another model, allowing them to advance their technical skills without adding pits to the stockpile, violating international agreements, or investing in additional storage.
      2. Without a pit production mandate, NNSA should not move forward with the construction of the Chemistry and Metallurgy Research Replacement Nuclear Facility (CMRR-NF) at LANL. There are significant Quality Assurance (QA) problems with NNSA construction projects, which is currently under review by the DOE Inspector General. Given this period of the federal government's limited economic resources, a $2.6 billion investment for CMRR-NF is unnecessary and wasteful—space already exists at LANL's Plutonium Facility-4 (PF-4) to complete any needed functions of CMRR-NF.
      3. Another expenditure that can be eliminated is the proposed construction of the Uranium Processing Facility (UPF) at Y–12. However, this option is not included in the SPEIS. The construction of a new building gives the Department of Energy (DOE) an out from actually downblending the hundreds of metric tons of excess highly enriched uranium (HEU) that DOE is storing at great cost and risk. Also, UPF will likely have soaring construction costs that should be avoided during this time of fiscal restraint.
      4. It is problematic that the SPEIS does not contain any goals for downblending of hundreds of metric tons of excess HEU. HEU needs not to be stored, but downblended, as it is highly desirable to nuclear terrorists who could use it to quickly and easily create a crude nuclear device.
      5. It is unsafe, and costly, that the Final SPEIS preferred alternative states that bomb-grade quantity and quality Special Nuclear Materials (SNM) will be removed from Lawrence Livermore National Laboratory (LLNL) "by the end of 2012." If NNSA considers this a priority and harnesses its resources, this task can be accomplished by 2009.

We hope that NNSA consider addressing these omissions in its Records of Decision.

Sincerely,

Danielle Brian

Executive Director

Project On Government Oversight