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| | | published Friday, November 21, 2008 | 2598 Views :: 0 Comments | |  |
November 21, 2008
U.S. Dept. of Energy
Ted Wyka, NA-101
Complex Transformation Comment
1000 Independence Ave., SW
Washington D.C., 20585
Dear Mr. Wyka,
The Alliance for Nuclear Accountability, a network of 36 local, regional and national organizations representing the concerns of communities in the shadows of the U.S. nuclear weapons sites, finds that the National Nuclear Security Administration’s (NNSA) Final Complex Transformation Supplemental Programmatic Environmental Impact Statement (SPEIS) did not adequately address comments submitted during the NEPA process. During that time more than 120,000 comments were submitted, most requesting that the final records of decision be delayed until a new nuclear posture review was conducted; that the nuclear weapons complex not support the development of new or modified nuclear weapons; that the role of the Kansas City Plant be included in the SPEIS; and that the NNSA support “curatorship” of the stockpile as a reasonable programmatic alternative. All of these issues are left unresolved in the Final SPEIS.
U.S. Nuclear Weapons Policy
The justification for Complex Transformation in the Final SPEIS stems, primarily, from policies set forth in the 2001 Nuclear Posture Review (NPR). However, those policies are outdated, do not comply with U.S. international obligations, and do not reflect the best security interests of the United States. Recognizing this and responding to a need for new nuclear weapons policies, Congress passed the 2008 Defense Authorization Act requiring the new administration to conduct a new Nuclear Posture Review. This review will study “the role of nuclear forces in United States military strategy, planning, and programming.” In doing so it is also required to determine the “the nuclear weapons complex that will be required for implementing the United States national and military strategy, including any plans to modernize or modify the complex.” NNSA should not move forward with any Records of Decision affecting the nuclear weapons complex until President-elect Obama’s administration conducts a full Nuclear Posture Review.
Modified or New Nuclear Weapons
Throughout the NEPA process, NNSA received thousands of comments opposing increased capacity for nuclear weapons production. These comments cited nonproliferation concerns, recent plutonium pit lifetime studies, and recent Congressional action that eliminated funding for new nuclear warheads.
Article VI of the Nuclear Nonproliferation Treaty requires signatories to negotiate in good faith the elimination of nuclear arsenals. In contrast, Complex Transformation signals to the rest of the world that the United States is rebuilding its nuclear weapons production capability. The U.S. cannot expect to convince nations such as North Korea and Iran to give up their nuclear programs while it plans for the production of a new generation of weapons.
The claimed need for wholesale revitalization of the nuclear weapons complex is not justified. In November 2006 independent experts concluded that the crucial plutonium pit “triggers for the warheads” have lifetimes of at least 85 years. The average age of nuclear weapons in our planned stockpile is 21 years old. The oldest warheads are 30 years old.
In 2007 and again in 2008, Congress eliminated funding for new nuclear weapons designs, stating that it was “prohibiting” the development “of a Reliable Replacement Warhead until the President has a post Cold War strategic nuclear weapons plan necessary to guide transformation and downsizing of the stockpile and nuclear weapons complex.” Clearly, the intent of Congress was to prevent NNSA from moving forward with the production of new nuclear warheads. Despite this, Complex Transformation would optimize the nuclear weapons complex for the potential production of the Reliable Replacement Warhead.
In light of these comments, the Final SPEIS does not provide sufficient rationale for recommending under the preferred alternative the production of 20 plutonium pits per year until a new nuclear posture review is conducted. Although this level of production is diminished from the “up to 80 pits per year” recommended in the draft SPEIS, there is a recommendation for the construction of a “Nuclear Facility” for the Chemistry and Metallurgy Research Replacement Project at Los Alamos and a Uranium Processing Facility at Y-12. These facilities will enable increased nuclear weapons production at a future date.
The Kansas City Plant
The Final SPEIS still does not include an environmental analysis for the Kansas City Plant at the Bannister Federal Complex. NNSA’s plan to build an entirely new production plant in a new location in Kansas City must be included in the SPEIS because of its central importance in the nuclear weapons complex. The estimated cost of building a new Kansas City Plant (KCP) is upward of $500 million. The KCP is responsible for building and/or procuring 85% of all non-nuclear components that go into a nuclear warhead and is listed in the SPEIS as part of the Nuclear Weapons Complex. Moving the KCP was an integral part of new nuclear weapons production originally envisioned under the 1996 Stockpile Stewardship and Management PEIS. However, instead of including an environmental analysis of moving KCP in the SPEIS, a separate, less stringent, Environmental Assessment was conducted finding “no significant environmental impacts.” By leaving the KCP out of the PEIS, NNSA is not providing the public with full environmental and economic impacts of Complex Transformation and the nuclear weapons complex as a whole.
Curatorship
The Curatorship Alternative offered by ANA is based upon reliance on the surveillance and nonnuclear testing program to determine when repairs might be called for. Only if there is compelling evidence that components have degraded, or will soon degrade, and could cause a significant loss of safety or reliability, would DOE replace the affected parts with new ones that would be manufactured as closely to their original designs as possible.
According to NNSA, the Curatorship Alternative was eliminated from detailed study as a stand-alone alternative because it does not define a programmatic alternative distinctly different from the range of alternatives analyzed in this SPEIS. NNSA claims that the “No Net Production/Capability-Based Alternative” includes many facets of a Curatorship Alternative, namely: not adding new types or increased numbers of weapons to the total stockpile; state-of-the-art testing and engineering capabilities to examine components and detect and appraise problems; and the capability to replace components, as needed. However, contrary to Curatorship, the “No Net Production/Capability-Based Alternative” supports the construction of major new nuclear weapons production facilities that are not needed and calls for the production of ten new warheads per year.
Under Curatorship, the NNSA would continue to operate only those facilities required to achieve truly needed maintenance and the replacement of limited-life components, along with the safe, secure, efficient disassembly and dismantlement of nuclear weapons and the disposition/disposal of their constituent parts. Because of these distinct differences, the Final SPEIS should have included Curatorship as a programmatic alternative.
The member groups of the Alliance for Nuclear Accountability who live next door to the DOE weapons production and waste cleanup facilities are directly impacted by the Complex Transformation final Records of Decision. Considering the serious flaws in the analysis provided in the Final SPEIS and the imminent review of nuclear policy and posture to be conducted by the new administration, we ask that any Records of Decision be delayed until they are completed.
Should you have any questions, please contact:
Nickolas Roth
Program Director
Alliance for Nuclear Accountability
322 4th Street NE
Washington, DC 20002
(p)202-544-0217
email: nroth@ananuclear.org
Sincerely,
Susan Gordon
Director
Alliance for Nuclear Accountability
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