 |
Categories |
|
 |
| | | |
| | |
|
|
|
| | | published Friday, February 29, 2008 | 954 Views | |  |
February 28, 2008
Pantex Hearing
Submitted by:
Susan Gordon
Director, Alliance for Nuclear Accountability
Draft Complex Transformation Supplemental Programmatic Environmental Impact Statement
The Draft Complex Transformation SPEIS released in December 2007 describes the history of the 1996 Stockpile Stewardship and Management Program, which evaluated alternatives for maintaining the safety and reliability of the U.S. nuclear weapons stockpile. The Record of Decision (61 FR 68014, December 26, 1996) documented the decisions related to fulfilling these requirements without underground testing. The ROD did not propose any new production facilities.
Therefore, no environmental impacts were envisioned for the huge ‘transformation” that is currently being proposed. I question the legality and appropriateness of offering “Complex Transformation” as a supplement to the original SSM PEIS and 1996 Record of Decision. I believe that the Complex Transformation plan should have been released as a stand alone Programmatic Environmental Impact Statement.
I also want to point out a glaring discrepancy in the 1996 ROD and the Draft SPEIS. The Kansas City Plant had a clear and important role in the ROD, but has been left out of the SPEIS. The Kansas City Plant has been proposed for a new half billion-dollar facility located several miles from the current site. Spending 500 million taxpayer dollars on a facility that will have environmental impacts in its community and plays such a central role in the weapons complex is a serious omission. This needs to be rectified before a new ROD is issued.
Public Participation
I want to thank Ted Wyka for ensuring all the documents for the Draft SPEIS were posted on the web site. That is of great benefit to those of us who spend hours actually reading them.
The Kansas City community has been cut out of the SPEIS process and was only given the opportunity to comment during an Environmental Assessment hearing last year. They had to hold their own hearing on the EA to educate themselves and gather additional comments. This is not an acceptable situation.
More than 33,000 comment documents were received during the scoping period and the majority of them stated that the U.S. is violating the Nuclear Non-proliferation Treaty (NPT). Most also stated that the National Nuclear Security Administration (NNSA) should assess an additional alternative – disarmament in compliance with the NPT – and not design new weapons. The Draft SPEIS does not present such an alternative. This deficiency must be rectified in the final SPEIS, which should include a fifth alternative: A No Production Alternative.
No Production Alternative
Under the No Production Alternative, the NNSA would continue to operate only those facilities required to achieve the safe, secure, efficient disassembly and dismant-lement of nuclear weapons and the disposition/disposal of their constituent parts.
Weapons Design and Certification
The need for weapons design activities will shift; some weapons design capacities will need to be maintained to address possible questions that arise during decommissioning, disassembly, dismantlement and disposition of the stockpile.
Maintaining three fully equipped national laboratories will not be necessary; consolidation of required laboratory-based activities will result in considerable savings—economic as well as environmental, savings that could be dedicated to addressing environmental concerns across the weapons complex.
Plutonium Operations and Pit Manufacture
Plutonium operations requirements will be reduced to questions of safe extraction, processing and disposal of plutonium currently in pits, in storage, or in other NNSA inventories. The location of such operations would be determined by an analysis of current technical and infrastructure capacities. Any facilities (new or upgraded) that conduct plutonium operations should incorporate transparency in their physical infrastructure as well as the processes in order to facilitate international verification of plutonium handling.
Activities required for plutonium currently in warheads would include: disassembly of warheads and pit removal; staging of pits awaiting further dismantlement; dismantlement of pits; safe and secure storage of pit materials until disposition activities are completed.
All plutonium should be placed under international monitoring and administrative control at the earliest possible moment.
The need for pit manufacture will be eliminated. Facilities currently available for pit production at Los Alamos would be given consideration for any role required in the disposition of plutonium from retired warheads or in other NNSA inventories. All other plutonium facilities would be decommissioned and scheduled for demolition.
Uranium Operations and Secondary and Case Fabrication
Uranium operations in support of disassembly, dismantlement and disposition regimes would be located at the Y12 Plant in Oak Ridge, Tennessee, where considerable infrastructure, including a Uranium Storage Facility under construction, currently exists.
Current facilities at Y12 would be analyzed for suitability for uranium processing; the question of upgrading aging facilities vs. construction of a new uranium processing facility will be made only after a thorough cost/benefit analysis. In either case, all facilities will have transparency “designed-in” in order to facilitate international inspection of all stages of the uranium operations and eventually, international possession of all HEU.
Given the nature of thermonuclear secondaries, it would be expected that similar operations with other constituents—lithium, beryllium, etc—would be co-located with uranium operations, though evaluation of other options which might provide efficiencies or improvements in safety or security could be considered.
Weapons Assembly/Disassembly and High Explosives Production
Weapons assembly operations would cease, and resources dedicated to assembly operations would transition to disassembly. Facilities for staging retired warheads awaiting disassembly, the actual physical disassembly, and staging constituent parts awaiting transportation or disposal would be co-located. While the Pantex facility seems an obvious choice to locate such facilities, consideration could be given to other sites, which present efficiencies in operations or significantly reduce safety risks due to transportation. It does not seem likely that more than one facility would be required.
The need for High Explosives Production for nuclear weapons would no longer exist. Bench-scale facilities might be maintained until all questions about stability of HEX during disassembly/dismantlement operations are resolved
Category I/II SNM Storage
Co-location of storage facilities for some or all Category I/II SNM materials under international administrative control should be analyzed. Issues of safety and security that accompany transportation of Category I/II SNM will be evaluated against gains in efficiencies, safety, and long-term security before decisions are made.
This evaluation should incorporate site-specific evaluations at facilities currently handling Category I/II SNM and then be made on a programmatic basis.
Tritium Production and R&D
Tritium production will no longer be necessary. Tritium production activities at the Watts Bar Nuclear Plant in Tennessee will cease and TPBars will be decontaminated, decommissioned, and destroyed. Tritium operations at Savannah River will be scaled back—tritium extraction will cease.
High Explosives R&D
High Explosives R&D will cease.
Flight Test Operations
Flight Test Operations for nuclear weapons delivery systems will cease. Decontamination, decommissioning and environmental restoration of all facilities will take place.
Hydrodynamic Test Facilities
High explosive experiments to study weapons physics and assess the performance of nuclear weapons will no longer be necessary.
Major Environmental Test Facilities
Environmental facilities used to test nuclear weapons will no longer be necessary and will transition to non-weapons work or will be decommissioned and demolished.
Non-nuclear production.
Under the No Production Alternative, the Kansas City Plant will be included in the SPEIS. Any facilities at the Kansas City Plant necessary to support safe and efficient disassembly, dismantlement and disposition of the stockpile will be maintained; the result will be a dramatically reduced footprint for the Kansas City operations. Funding currently allocated for relocation of the Kansas City Plant can be dedicated to addressing environmental concerns at the current operating facility.
Benefits of the No Production Alternative
- The No Production Alternative will lead the way to addressing the horrendous environmental legacy of nuclear weapons production. By closing the complex our tax dollars can be redirected to clean up and remediate the health and environmental impacts to communities down wind and downstream from the weapons complex sites.
- The No Production Alternative can enhance the economic status of the communities in which facilities are located. Directing the efforts of the workforce toward dismantlement of warheads and cleaning up the weapon production sites will create jobs and improve the environmental quality of the communities. When sites are cleaned they become available for other economic development opportunities.
- The No Production Alternative is the only alternative that fulfills the United States’ obligations for disarmament under Article 6 of the Nuclear Nonproliferation Treaty. Further, it is the only alternative in which the United States complies with the 1996 World Court opinion that the threat or use of nuclear weapons is contrary to the rules of international law.
- The No Production Alternative provides the United States leadership called for by arms control, diplomatic and military leaders.
- The No Production Alternative will enhance security for the United States by stopping the global momentum toward nuclear proliferation and increase security for every country.
Click here to download a pdf of these comments
|
|
|
|
|
|
Fact Sheets 2008 |
|
|
| | | |
|
Fact Sheets for 2007 |
|
|
| | | |
|